SHD Application for 698 Student Beds

An application has been made to An Bord Pleanála for a SHD (fast-tracked) development at OLG containing 698 student bed-spaces over 8x blocks up to 7-storeys high, with inadequate open space and levels of sunlight, and only 9 car parking spaces. It completely disingenuous to suggest that there is any benefit to the community or OLG Schools, in having this oversized development on only 2.12ha.

Submissions on this development must be made directly to An Bord Pleanála. They needn't be lengthy, just your point of view. All submissions made to ABP are forwarded to DLR for consideration at their next meeting (10th March), which is scheduled for before ABP’s final date for submissions (18th March) so make sure to include a copy of your submission in emails to your DLR Councillors (email list below) directly before the 10th March meeting. This report is crucial. The DLR CEO’s Report and recommendation for refusal was integral in the successful Judicial Review and previous planning permission being quashed by the High Court.

It’s worth reading DLRCC’s Opinon on the consultation phase and also the Material Contravention Statement and Response to ABP Opinion which can be found under Planning Documents on www.ourladysgrovestudentshd.ie.

Key points to include in your submission that we will address in more detail (see relevant FB posts) are the following:

This application ABP 309430 is a Material Contravention of the DLR County Development Plan (2016-2022) on the following counts relating to Institutional Lands:

• Open Space provision of 25% - 

The quantity and quality of Open Space in this plan is lacking. The plan includes the provision of 7,956sq m of public Open Space in the form of a linear “nature trail” and small “recreational area”. The “nature trail” is compressed into narrow tracts around the borders of the site, which receive inadequate levels of sunshine. This linear “nature trail” is very narrow, includes trees and lighting and also functions as the access road for Fire and Ambulance services.

The only functional area of Open Space is the small “recreational area” with ½ basketball court, table-tennis tables and seating, however, this is unsuitable for school children. The “recreational area” is also the location of the underground water storage attenuation tank. There has been a huge reduction in size to the “recreational area” compared to the previous Durkan scheme. There has been a massive reduction in the Open Space provision compared to the original Masterplan proposed by the Congregation of RJM in 2016 when they sold the land.

This plan’s Open Space calculation is completely flawed. It does not include for the 22x 4-bed family homes (The Grove) and 19x apartments (Grove House), built in Phase 1 of this development or the 9 apartments in Errew House, even though the green strip behind Errew House (543sq m) has been included in the applicant’s total Open Space. Included in this plan’s Open Space calculation are the 2 courtyards, which are restricted for use by student residents and are primarily for the circulation of students and staff servicing the student blocks as they contain the controlled bike access route and refuse room. Also included in this plan’s Open Space calculation, are the existing yards and recreational areas within OLG school grounds, which are restricted for use by school pupils.

 It’s completely disingenuous to suggest that there is any benefit to the community or OLG Schools in having this oversized development on only 2.12ha with so little Open Space. School children will not wander the “nature trail” and residents will also not use this space for running or walking when it is shared with 698 students.

• Maintaining the Open character of the Site - 

Almost all proposed Open Space is compressed into narrow tracts around borders and does not constitute the provision of high-quality Open Space that is deemed critical in the context of Institutional Lands. There is no kick-about area proposed for 698 students. The pupils of OLG Primary would love a grassed kick-about area like they used to have, where they can run and play games in these unprecedented times of inactivity and obesity in children. OLG Primary (439 pupils) share a tarred yard where no running is allowed at breaks.

The original Masterplan proposed by the Congregation of RJM (2016), included a large Play and Learning Space (accessible to schools and residents), a small Play Area (with focus on 0-6yo), a small Kick-about Area and a new Hockey Pitch to be used by adjacent schools.

• Provision for School Expansion / Facilities - 

The site area of OLG schools is already substandard and this plan will allow for no expansion area for OLG Primary and very little for OLG Secondary Schools. OLG Primary School (16 classrooms) site size of 0.75ha is currently 28% below DoES guidelines of 1.04ha. OLG Primary School (+ 3 additional classrooms approved in 2018 but not built yet) site size of 0.75ha will be 50% below DoES guidelines of 1.5ha. OLG Primary School (16 classrooms) external play area of 1,600sq m is currently 42% below DoES guidelines of 2,800sq m and will be 61% below DoES guidelines of 4,200sq m when 3 additional classrooms are added.

• Density exceeds 35-50 units p/ha - 

The density proposed in this plan is now 164 units p/ha (calculated as 2 bedspaces p/unit). In determining the capacities of the Engineering infrastructure (DBFL Infrastructure Report section 5.2), the density of 698 student bedspaces are calculated to be 262 residential units. When applying this metric to the density of the this development, it results in a density of 123.59 units p/ha. Whichever way you calculate density, it constitutes an under representation of the true density to be delivered. The original Masterplan proposed by the Congregation of RJM (2016) comprised a residential development of 72 units. 

• Height exceeds 3-4 storeys - 

The heights proposed are 6 to 7-storey buildings. This development does not respect local context or the scale and proportions of surrounding buildings, which compromise primarily low-rise housing, and would be entirely out of character for the area and to the detriment of the local environment.

• Tree Removal - 

The design of this scheme has made no effort to incorporate existing trees. The removal of all of the trees from the centre of this site and replacing them with 6/7-storey blocks, goes against objectives to protect and preserve trees and woodlands and is not justified. They should be retained and incorporated within the scheme.

Other points to include with your observation on how this application goes against guidelines and viewpoints of parents and local residents:

• Zoning - 

The Draft DLR Development Plan (2022-2028) proposes to amend the zoning to a new SNI Zone “to protect, improve and encourage the provision of sustainable neighbourhood infrastructure”, where housing is not a permitted use. This application has the entire North Block and 75% of the Middle Block in this area. The original Masterplan proposed by the Congregation of RJM in 2016 when they sold the land, had this area allocated to OLG Schools. It would be an injustice to allow development on this land!

• Communal Facilities and Amenities - 

The total floor area of the proposed internal communal facilities and amenities (1705 sq m) falls short of the student housing standard of 12% of the total gross floor area of the proposed development.

• Daylight Analysis - 

There is significant overshadowing and inadequate levels of sunlight on the newly completed hockey pitch at OLG Secondary, as well as homes on Friarsland Rd and Roebuck Downs. Sunlight in Proposed Outdoor Amenity Areas shows 2 communal open space areas fail to achieve BRE recommended level of 2 hours sunlight on March 21st - North (28.8%) and South (31.8%) Amenity Area.

Average Sunlight Hours in Proposed Amenity Areas 6.4.2 shows the following daylight on December 21st: North Amenity Area (15min), South Amenity Area (15min), Public Park and Woodland Trail (1h 15min), Public Recreational Area (1h 30min) and Afterschool External Amenity Area (1h 30 min). The level of daylight in the Preschool / Afterschool outdoor area is severely lacking, at only 1h 30min a day!

• Car Parking and Road Safety - 

9 car parking spaces is totally unrealistic as students will be from outside Dublin. There is already intense parking pressure outside OLG Schools with only 30 car parking spaces available to parents/carers of OLG Primary (enrolment 439) and OLG Secondary (enrolment 309) Schools and The Grove Preschool (c.45 children). Between 5-7 of these spaces are taken by staff of The Grove Preschool (as detailed in Applicant’s Response to Planning Application D20A/192). That leaves 25 car parking spaces for approximately 800 children. Many of these 25 car parking spaces were taken all day with tradesperson’s vehicles during the build of Phase 1 - The Grove.

This has potential to adversely impact on parking and safety around OLG Schools and adjoining residential areas with overspill parking. 860 bicycle spaces are provided but no cycle lane is proposed for the access road to this site between OLG Schools and residences at The Grove.

• Safety during Construction - 

During the build of Phase 1 of this site (22 units at The Grove and 19 unit 5-storey Grove House), construction vehicles toppled over, trucks reversed around roundabouts at pick up times and hoarding blew over, putting the safety of school children at risk. Despite site delivery access restricted to take place outside of crucial drop-off and pick-up times (8:30-9:15am & 1:20-3:00pm) during the build of Phase 1 of this site, many vans, tradesperson’s vehicles and larger deliveries failed to comply. These restrictions did not take into consideration our youngest children being collected from The Grove Preschool at 12pm.

• Loss of Valuable Open Space - 

The developer will have you believe that the lands around OLG Schools are “underutilised” for a number of years. This land was a vital part of our school’s infrastructure and should have been protected. There is no doubt that our school was stripped of a well-used amenity. There is a moral obligation on the Order but also on the Planning System to protect institutional lands for future use.

• Impacts on Visual Amenity - 

By virtue of its height, scale and volume, this development will have an overly dominant and overbearing appearance and a detrimental impact on the visual amenity of residents, in particular for properties in The Grove and those located to the west and north.

• Conflict of Use on OLG Campus - 

The placement of 698 students in accommodation on the same campus as a pre-school, primary school and secondary girls school, is unsuitable. We are concerned about the anti-social behaviour often associated with student accommodation and the conflict of use proposed on OLG campus where adult students would share the same campus as school children ranging in age from 3 to 17 years. There are to be 92x windows overlooking teenage girls playing sport in their gym gear and we feel that this mix of uses is completely inappropriate.

• Demand for Student Accommodation - 

In light of the Covid19 global pandemic, the demand for student accommodation forecasts used by the applicant (dated 2016) to justify this development, are no longer valid. A pandemic is an unprecedented situation, but concerns have persistently been raised about the long-term viability and sustainability of the over concentration of student accommodation in Dublin.

The Union of Students in Ireland agrees that there is an overconcentration of purpose-built student accommodation (PBSA) in some parts of Dublin “There should be tighter restrictions on how many student accommodation blocks can be built in one local area if off-campus,” says their position paper on student accommodation from 2019. “Over saturation drives up the prices of land in urban areas, which affects communities and their ability to pay rent.” 

PBSA’s are priced for the international students, who make up 79% of their student residents, and are unaffordable for many Irish students who still end up in cheaper digs sharing houses, thus not alleviating housing pressures.

Michelle Byrne, vice president for campaigns for the Union of Students in Ireland (USI), said that her union has always been against luxury student accommodation. “We don’t need luxury bits, when it comes to the cinemas, the gyms, and students don’t necessarily want that because they can’t afford the price tags,” Byrne said. They ideally want on-campus affordable student accommodation, she said The USI are going to start to lodge objections to planning applications for student accommodation on the basis that the projects aren’t suitable and cost too much”, Byrne said. 

ABP have a new online facility for observations on SHD applications and you can pay the €20 by card. In order to make a valid observation to An Bord Pleanála you must:

-- include your name and address

-- state the subject matter of your observation i.e. Strategic Housing Development Case Reference: PL06D.309430 at Our Ladys Grove, Goatstown Road, Goatstown, Dublin 14

-- state your planning grounds of observations (reasons and arguments), and any items you wish to support your grounds of observations i.e. photographs and maps

-- submit the observations within the 5-week period (from 12/02/2021)

-- you can either download an observation form (Word), complete, save and upload or prepare your own observation document (Word or PDF) to upload.

-- save your observation as a Word or PDF document with your name and details of the case i.e. 309430 Our Ladys Grove - John Doe.pdf

--pay the €20 fee online

More details on how to make an online submission can be found on the ABP website here.

As well as An Bord Pleanála, here is a list of DLR Councillors to send your submission to:

sbrennan@cllr.dlrcoco.ie, acolgan@cllr.dlrcoco.ie, ddunne@cllr.dlrcoco.ie, agrainger@cllr.dlrcoco.ie, smcloughlin@cllr.dlrcoco.ie, pobrien@cllr.dlrcoco.ie, joleary@cllr.dlrcoco.ie,

ddonnelly@cllr.dlrcoco.ie, edowling@cllr.dlrcoco.ie, jkennedy@cllr.dlrcoco.ie, moconnell@cllr.dlrcoco.ie, bsaul@cllr.dlrcoco.ie, dsmith@cllr.dlrcoco.ie

kahmed@cllr.dlrcoco.ie, eblain@cllr.dlrcoco.ie, mfleming@cllr.dlrcoco.ie, pkinsella.cllr@dlrcoco.ie, lmccarthy@cllr.dlrcoco.ie, tmurphy@cllr.dlrcoco.ie, ooconnor@cllr.dlrcoco.ie