S I M O N C L E A R & A S S O C I A T E S

P L A N N I N G A N D D E V E L O P M E N T

C O N S U L T A N T S

Simon Clear B.A. Dip. T.P. MIPI

Darran Quaile B.A. MRUP MSc BLUP MIPI

Paula Shannon BA. MRUP MIPI

3 TERENURE ROAD WEST,

TERENURE,

DUBLIN 6W

D6W YY79,

IRELAND.

Phone: 00-353-1-492 5934

Fax: 00-353-1-492 7617

E-mail: admin@clearconsult.ie

Web: www.clearconsult.ie

Vat No. 9803199H

h

Report

To

An Bord Pleanala

Brief Description of Proposed Mixed-Use Student

Accommodation

SHD Development

at

29b, 30 & 31

Prussia Street,

Dublin 7

For

Prussia Properties Limited

May 2020

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Introduction

This planning report, which provides a description of the proposed Mixed-Use Student

Accommodation development, has been prepared to support a Strategic Housing

Development planning application to An Bord Pleanála.

In summary, the proposed development consists of the demolition of the existing

industrial sheds/workshops located on the site and the construction of a student

accommodation development providing 296 no. student bedspaces in 4 no. blocks ranging

in height from 5 to 8 storeys. The area of the site is 0.285ha.

Site Location and Context

The subject site is located between Prussia Street and the TU Dublin Grangegorman

Campus currently being developed under the provisions of the GDA SDZ scheme as

approved and modified by ABP (ZE0005). The site is bound to the north by a number of

small two-storey dwellings built up to the boundary of the subject site, located on a

narrow street known as St Joseph’s Place. The boundary of the TU Dublin Grangegorman

campus is located to the east with the site abutting the boundary wall (protected structure).

There are a number of sheds/warehouse structures located along the southern boundary.

Also to the immediate south of the site is a 3-storey Georgian-style dwelling fronting

Prussia Street. The dwelling, with an address of 29 Prussia Street, is a Protected Structure

(Ref.6873). The western boundary of the subject site has frontage to Prussia Street.

OSI Map with Site Outlined in Red

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Relevant Planning History

There is no planning history on the subject site.

Pre-Planning Consultations with Dublin City Council (DCC) and An Bord Pleanala

(ABP)

3 no. pre-planning meetings were held in the offices of DCC on the 13th

December 2018,

5th

March 2019 and 13th

June 2019.

A summary of the pre-planning meetings held with DCC is provided below.

13th

December 2018

Mary Conway requested a report be prepared justifying student as opposed to

other accommodation at this location and a management strategy.

Noted a report was in preparation for DCC by EY investigating release of

permanent housing stock into long term use associated with increased PBSA.

Design issues related to scale, massing, future proof for neighbour development on

Prussia Street, repairing/renewing Prussia Street streetscape, separation distances,

shadow /daylight analysis, proximity/cantilever, pedestrian experience of route

to/from GDA campus via undercroft.

5th

March 2019

Information was provided regarding student accommodation sequential test,

limited concentration in North West inner suburbs and outline management

strategy.

Detailed description of interesting route for pedestrians from Prussia Street to the

Grangegorman Campus.

Undercroft soffit level explained with chamfered street level entrance and sections

on through route.

Concern with soffit level reiterated and need for more vertical emphasis to provide

more street grain/rhythm – detailing materials in street elevations.

13th

June 2019

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Design adjusted to address Prussia Street. Setbacks to upper levels. Lower ground

floor glazed route provides internet and interaction, soffit adequate at 4.2m, rising

to 7.4m at Grangegorman Campus portal.

Concern with horizontal emphasis on Prussia Street and detail for intervention in

Grangegormn boundary wall – need for feedback from GDA.

Two pre-planning meetings were held with the Grangegorman Development Agency

(GDA). As a result of the first meeting, held on 16th

November 2018, GDA informed the

applicants of an approved modification to the GDA SDZ scheme, affecting lands within

the GDA campus immediately adjacent to the site and encourages a pedestrian/cyclist

route through the proposed accommodation scheme directly into the TU Dublin campus.

This was communicated to DCC at a pre-planning meeting.

A second meeting was held on the 27th

of June 2019 with the GDA to confirm that the

design approach at the interface and at the intervention in the perimeter wall was

acceptable to GDA. The scheme now proposed reflects the outcome of that meeting.

A Tripartite meeting was held with ABP and DCC on the 7th

November 2019. Please refer

to the enclosed Response to ABP Opinion document for details of the design teams

response to the items discussed at the Tripartite meeting and those contained within the

ABP opinion.

A response to the Opinion issued by DCC prior to the Tripartite meeting is provided

below.

DCC acknowledge that the subject site has good levels of connectivity to public transport

links to the Broadstone Bus and Luas stops as well as a number of bus stops along Prussia

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Street and is an underutilised site. DCC also acknowledge that student accommodation is

an appropriate use for the site and that the proposal will not result in an overconcentration

of student accommodation in the area. In relation to plot ratio, DCC deemed the proposal

to be acceptable due to its location and proximity to transport links.

DCC provide a full analysis of compliance with the Building Height Guidelines and the

criteria for increased building heights. While it is acknowledged that the height of the

proposed development is consistent with the DCDP, concern was raised over the design of

the development and particularly the location of the substation to the front of the retail

unit at ground floor level. Consequently, the substation has been relocated to along the

internal street and has allowed an increase in width of the retail unit.

DCC welcomes the increased connectivity provided by the internal street giving

pedestrian and cyclist access from Prussia Street through to the TU Dublin Grangegorman

Campus. Concern was raised by DCC in their opinion in relation to the design of the

internal street and its attractiveness. Please refer to the enclosed Architectural Design

Statement for details on the design of the internal street. Concern was also raised by DCC

in relation to the potential overhang of the building to the public footpath on Prussia

Street. It is submitted that the subject proposal does not overhang the public footpath.

Concern raised by DCC in relation to Daylight and Sunlight have been addressed within

the enclosed JV Tierney Daylight/Sunlight Analysis Report.

An Archaeological Impact Assessment and Architectural Impact Assessment have been

prepared by Archaeology Plan and are enclosed with the planning application documents.

Additional plans, elevations and sections have been prepared by Douglas Wallace

Architects and are enclosed with the planning application.

Description of Proposed Development

It is proposed to demolish the existing building on site, which consist of a number of

industrial sheds and construct a student accommodation development with a total of 296

no. bedspaces. The development will range in height from 5-storeys fronting Prussia

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Street and increase to 8-storeys to the rear towards the TU Dublin Grangegorman

Campus. The development will be accessed from Prussia Street and will provide an

internal street creating a linkage from Prussia Street to the TU Dublin Grangegorman

Campus.

Proposed Site Layout Plan

The internal street will run through the ground floor of Blocks B, C and D and an entrance

into the TU Dublin Campus will be created in the boundary wall between the two sites.

The wall is a protected structure and the intervention has been designed in accordance

with the guidance provided by GDA.

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The boundary wall is random stonework capped by vertical stones laid to top and the

walls of the sheds on the subject site can be seen built on top of the Protected Structure.

Please refer to the Architectural Drawing No. PA-700 for details of the boundary

treatment and the entrance into the TU Dublin Grangegorman Campus.

Communal amenities in the form of a canteen, laundry room, study rooms, gym and

general communal areas are to be located in the basement and at lower ground level. A

retail unit will be located at ground floor level fronting Prussia Street. The building

fronting Prussia Street will be set back from the street to provide a public plaza, which

will form part of the internal street linking Prussia Street and the TU Dublin

Grangegorman Campus. The setback matches the building line of the protected structure

to the south at street level, with a high soffit level.

Proposed Prussia Street Elevation

Development Standards

The provisions of the DCDP and relevant National Guidelines, such as the ‘National

Student Accommodation Strategy’ and ‘Guidelines for Planning Authorities on

Sustainable Residential Development in Urban Areas 2009’ have been considered in the

design of the proposed development. The enclosed Consistency Statements and Schedule

of Areas provide further details of compliance with standards and the individual

breakdown of each area.

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Section 16.10.7 of the DCDP sets out provisions for ‘Guidelines for Student

Accommodation’ and these have been adhered to in the preparation of the design of the

proposed student accommodation scheme.

It is acknowledged in the DCDP that the ‘City Council supports the provision of high-

quality, professionally managed, purpose-built third-level student accommodation, either

on campus or in accessible locations adjacent to quality public transport corridors and

cycle routes, in a manner which respects the residential amenities of the locality.’

The subject development is located adjacent to the TU Dublin Grangegorman Campus

and makes a positive contribution to the built environment as the site is currently

underutilised and in need of redevelopment. The enclosed Architectural Design Statement

prepared by Douglas Wallace Architects contains a more detailed description of the

design of the proposed development in terms of design quality, scale, height and the

relationship to adjacent buildings.

Proposed Student Accommodation Units

Unit Type Number of Units Number of Bedspaces Area of Each Unit (m2)

Studio 256 256 12-19

Twin 20 40 17-27

Total 276 296

The proposed student accommodation units exceed the minimum standards set out in the

DCDP.

Communal Amenity Space

The subject proposal, which consists primarily of studio units, provides a range of

communal amenity areas and rooms, primarily located at basement and lower ground

floor level as shown in the tables below.

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Basement Communal Amenity Areas

Communal Area Area (m2)

General Communal Area 354

Canteen 162

Lounge 448

Gym 92

Study Room 50

Lecture Theatre/Cinema 80

Study Room 44

Total 1230

Lower Ground Floor Amenity Areas

Communal Area Area (m2)

Lobby/Lounge 77

General Communal Area 50

Courtyard 39

Total 166

Communal Open Space

Outdoor communal amenity areas are provided at 1st floor level in the areas between the

blocks of student accommodation. The outdoor communal amenity areas are provided as

roof gardens. Please refer to the enclosed Roof Terrace Landscape Plan and

accompanying Design Statement prepared by Dermot Foley Landscape Architects for

details on landscaping proposed.

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The DCDP requires that indoor and outdoor communal and recreational facilities for

students at a combined level of 5-7m2 per bedspace be provided in student

accommodation schemes. The proposed development provides 7.4m2 of communal areas

per bedspace.

Concentration of Student Accommodation

It is noted in the DCDP that ‘the planning authority will have regard to the pattern and

distribution of student accommodation in the locality, and will resist the

overconcentration of such schemes in any one area.’ In this regard, ‘the applicant will be

requested to submit evidence to demonstrate that there is not an over-concentration of

student accommodation within an area, including a map showing all such facilities within

0.25 km of a proposal.’

Please refer to the enclosed Student Accommodation Concentration Report which

addresses a sequential approach to provision of student accommodation adjacent to the 3rd

level institution and any potential for overconcentration in the area. In accordance with

Variation 3 of the DCDP, the report includes a map illustrating student accommodation

facilities within 1km of the subject site.

Car Parking

As the site has direct connection to the TU Dublin Grangegorman campus, which is a

non-vehicle campus as a result of the recent scheme modification on the West side, no

encouragement for car usage is included in the subject scheme and no on-site car parking

is proposed.

An arrivals / departure regime is described in the Student Management Plan and servicing

arrangements are facilitated within the development site.

Please refer to the Traffic Management Report prepared by CS Consulting Group for

further details.

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Bicycle Parking

The cycle parking standard for student accommodation is 1 space per 2 bed-spaces. A

bike store is proposed along the western boundary of the proposal, a number of bicycle

racks are also located to the front of the development along Prussia Street and to the rear

of the development, adjoining the TU Dublin Grangegorman Campus. A total of 148 no.

bicycle parking spaces will be provided, which is in accordance with the DCDP standards.

Daylight and Sunlight Analysis

A Daylight and Sunlight Report carried out by JV Tierney Consulting Engineers in

accordance with Site Layout Planning for Daylight and Sunlight by “Paul Littlefair” is

enclosed with the application documents.

The Daylight and Sunlight Report identified 6 no. sites surrounding and including the

proposed development to be assessed for the following:-

(A) Light from the Sky

(B) Gardens and Open Spaces

(C) Loss of Sunlight and

(D) Average Daylight Factor (ADF)

The ADF is only assessed for the proposed development and not the existing

developments.

In summary:-

134 windows have been tested under the (A) Light from the Sky methodology; 97

windows meet the criteria. Therefore 72% of all assessed windows meet the

criteria;

Only 1 out of 5 assessed amenity areas within the proposed development falls

below the criteria for (B) Gardens and Open Spaces;

4 out of 6 assessed garden areas meet the criteria for (B) Gardens and Open

Spaces for the surrounding houses;

All 10 windows tested for (C) Loss of Sunlight meet the criteria;

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316 rooms have been tested under the (D) Average Daylight Factor methodology;

285 rooms meet the criteria. Therefore, 90.2% of all assessed rooms meet the

criteria.

The Daylight and Sunlight report concludes that the testing indicates that the proposed

development will not have a significant effect on the tested parameters taking into account

the inner city location and the pattern of adjacent development.

Scheme Management

It is a requirement of the DCDP that ‘all applications for student accommodation must be

accompanied by documentation outlining how the scheme will be professionally managed

including confirmation that all occupiers will be students registered with a third-level

institution’. A Student Accommodation Management Plan has been prepared and is

enclosed with the planning application documents.

Part V

The provisions of Part V (Social and Affordable Housing) of the Planning Acts do not

apply to student accommodation in the City Council area.

Engineering Services

The proposed development will be serviced by a new drainage system with separate

sewers for both foul and storm water within the sites boundary but with a combined

manhole for both foul and storm water at the sites boundary with the provision of a ‘dead-

leg’ spur for future separation of the public drainage system by the Local Authority.

The following SUDs proposals are incorporated into the proposed development:-

Green roof

Low water usage appliances, to restrict potable water demand

Attenuation tank with flow control device

In terms of water supply, it is proposed to make a new connection off the existing

watermain on Prussia Street to the development site and supply a 100mm internal

diameter watermain to the proposed development site.

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Please refer to the enclosed drawings and Engineering Services Report prepared by CS

Consulting for further details on the above.

Flood Risk Assessment

The enclosed Flood Risk Assessment prepared by CS Consulting concludes that:-

The site is located in Flood Zone C and historically has no recorded flood events;

Predicted flood mapping for pluvial / tidal & fluvial flood events will not affect

the subject site;

The likelihood of onsite flooding from the hydrogeological ground conditions are

deemed to be minor and within acceptable levels;

The proposed development will have a storm water attenuation system to address a

1 in 100 year extreme storm events increased by 20% for predicated climate

change values. This will significantly reduce the volume of storm water leaving

the site during extreme storms which in turn will have the effect of reducing the

pressure on the existing public drainage system.

Irish Water Feasibility

By letter dated 21st February 2020 Irish Water confirmed that the proposed connection to

the Irish Water Network can be facilitated, subject to agreement. Please see letter of

confirmation from Irish Water enclosed with the Engineering Services Report.

Landscaping

Please refer to the Landscape Design Statement and accompanying drawings prepared by

Dermot Foley Landscape Architect for specific detail on trees and planting to be provided.

Bat Survey

A winter inspection of the site was carried out by Bat Eco Services and concluded that no

bat evidence was recorded during the winter assessment. The Bat Report also noted that

there is little scope for roosting bats and less scope for foraging and commuting bats

within the survey area and therefore the proposed development is unlikely to have an

impact on local bat populations.

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The mitigation measures provided in the enclosed Bat Report have been incorporated into

the Lighting Plan prepared by Renaissance Engineering for the proposed development.

AA/EIA Screening

An Appropriate Assessment and an Environmental Impact Assessment Screening Report

are included with the documents. The AA Screening Report concludes that there is no

likelihood of any significant effects on Natura 2000 sites arising from the proposed

development, either alone or in combination with other plans or projects. It is considered

that Stage 2 Appropriate Assessment is not required.

The EIA Screening Report concludes that no significant negative effects on any of the

environmental factors to be considered under the EIA Directive are anticipated as a

result of the proposed development.

Conclusion

This Planning Report has been prepared to accompany a planning application to An Bord

Pleanála for a strategic housing development consisting of 296 no. student

accommodation bedspaces in 4 no. blocks ranging in height from 5 to 8 storeys.

A total of 2,184m2 communal space is provided for the residents of the scheme. It is

submitted that the proposed development will provide a high quality student

accommodation scheme in an ideal location adjacent to the TU Dublin Grangegorman

Campus and high quality public transport.

The enclosed Statements of Consistency accompanying this application demonstrate that

the proposed development complies with the relevant national, regional and local

planning guidelines and objectives and that the proposal will provide for a sustainable and

efficient use of this brownfield site.

In conclusion, it is submitted that the proposed development is consistent with the proper

planning and sustainable development for the area and complies with all relevant national,

regional and local planning policies and guidelines.

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Simon Clear