Planning submission on the Park Shopping Centre SHD
12 April 2021
I today submitted a planning observation to An Bord Pleanála in relation to the Park Shopping Centre Strategic Housing Development on Prussia Street, Dublin 7.
While the development certainly represents an improvement on the use being made of the land so close to the new TUD campus, the thriving neighbourhoods of Phibsborough and Stoneybatter, and the city centre, in my view there are serious issues with the applications as it stands, and in my submission I have urged ABP to reject the application at this time.
Of particular concern:
The applicant proposes to breach the minimum floor area standards in a number of the units. Minimum standards are there for a reason, and this kind of breach should never be tolerated.
Breach of acceptable daylight standards on adjacent streets, in particular for the houses on St. Joseph's Place.
Breach of the City Development Plan's height standards, adding to the overbearing nature of the development to a number of adjacent streets. Furthermore, I question the justification given of the local area being a "transport hub" in which such heights are deemed acceptable.
Over-concentration of purpose-built student accommodation (PBSA) in the locality. This would be the 11th PBSA development within a kilometre radius. 9% of the Dublin 7 population is now accounted for by PBSA. The over-concentration of this kind of development is at odds with the housing needs of the local community.
See my full submission below!
Park Shopping Centre and 42-45, Prussia Street, Dublin 7
Demolition of existing buildings, construction of 584 no. bedspace student accommodation, 32 no. build to rent accommodation and associated site works.
To whom this may concern,
The proposed redevelopment of the shopping centre is to be welcomed. The shopping centre currently makes sub optimal use of the land available to it. Given the proximity of the site to the city centre, to the TUD campus and to the thriving Dublin 7 neighbourhoods of Stoneybatter, Phibsborough and Cabra, I believe there is great potential to develop the site, consistent with the needs of the local community and adjacent academic institution.
However, I believe there are two very significant concerns regarding the proposal;
(i) a series of breaches of minimum building standards and the DCC City Development Plan relating to floor area size for the residential apartments, building height and daylight availability for adjacent housing and
(ii) disproportionate number of student accommodation relative to demand for this type of accommodation in the area.
On the basis of these, I urge the Board not to grant permission for this development as it stands.
Breach of Minimum Floor area standards
No breach of minimum building and floor area standards should be tolerated by An Bord Pleanála. In the applicant’s own housing quality assessment report for the build to rent accommodation in the scheme, it is apparent that the applicant intends breaching minimum floor area standards for the living/kitchen/dining areas for 18 of the two bed units with the majority of the remainder of the units at or barely above the minimum standard.
Furthermore and notwithstanding the flexibilities permitted under SPPR 8 (ii), it is not acceptable that the proposed storage space for each of the 32 build to rent units would be half of the minimum floor area standard. A key facet of any sustainable and durable accommodation is that there is appropriate storage space in each apartment. This planning application fails in this regard.
Breach of Daylight access for adjoining houses
The applicant’s own Daylight and Sunlight assessment highlights the proposed development’s breach of BRE guidelines on daylight and sunlight access of housing adjacent to the proposed site. The overbearing nature of the proposed development and material impact of adjoining houses, particularly those on St Joseph’s place is not acceptable. In the overall planning context report, the applicant notes that daylight availability will be below standard but that this is considered “reasonable in the urban context.”
It is vital that any future development is compatible and consistent with the basic living standards of those already living in the locality. In that context, I ask that this portion of the development be either reoriented away from the existing housing, or reduced in height so as to minimise the visual and privacy impact.
Breach of Height Standards
The Park Shopping Centre SHD, if built as proposed, would constitute a material contravention of the Dublin City Development Plan 2016-2022 in terms of the maximum height of the tallest building. As outlined in the ‘Material Contravention Statement’, the potential contravention is of less than a metre. However, this should not distract from the fact that this constitutes an attempt to wring the greatest possible number of units, and the maximum potential profitability, from the site. While development of the site is to be welcomed, this kind of profit-hunting attitude does not reflect well on the overall sustainability of the site.
Not only does this kind of contravention disregard the wishes of the elected representatives of Dublin City Council and the communities they represent, but bespeaks a negative attitude towards the principles of sustainable, democratic planning themselves. I would ask the Board to consider reducing the permitted height of the development, to bring it back into line with these principles.
I further question the justification offered for the proposed maximum height as being in keeping with the area’s status as a transport hub. While I acknowledge the positive work being done to improve the situation and the potential for significant improvements to the area once BusConnects is rolled out fully, I believe the congestion experienced daily on the Old Cabra Road, Prussia Street and Blackhall Place undercuts this assessment. Indeed, I question whether due consideration has been given to the extent to which congestion is likely to worsen as a result of this development.
Overconcentration in the locality
The proximity of the site to the new TUD Grangegorman campus renders it a suitable location for student housing. However, proximity to a third level institution must not be the sole criteria for permitting the development of student accommodation.
The application notes that the SHD will be the 11th PBSA development constructed within a 1km radius and in this context, serious questions now need to be asked as to the level of student housing demand in the vicinity.
Local communities in Dublin 7 have for several years now noted with frustration the exponential levels of development in the area which does not serve the needs of existing communities and disadvantaged people, rather focusing on premium housing, and forms of housing designed to facilitate short-term or term-time stays. The proliferation of PBSA in the neighbourhood sits alongside a similar explosion of ‘co-living’, Build-to-Rent, aparthotel and other tourist accommodation – developments proposed at the expense of the affordable housing so desperately needed by the community.
A report before Dublin City Council last year indicated that over 9% of the Dublin 7 population is now accounted for by PBSA. As we have seen over the past year with the large volume of applications for permission to convert student accommodation to tourist use around the city, PBSA as a model of housing provision is built on shaky foundations, and further pursuing it in the intense way proposed here undermines the potential for a sustainable solution to the housing crisis.
I argue that the severe weighting of this development towards PBSA and away from apartments accessible by the wider community constitutes a planning failure and should be opposed.
Furthermore, the ratio of student accommodation to formal apartments is above 4:1, meaning that Dublin City Council will only gain 3 social housing units under Part V, at an eyewatering cost of over €1.6 million.
Ultimately, I believe there are very serious concerns, articulated above, that need to be considered by the Board. We wish to see the site developed but it must be done in a manner that is sustainable and consistent with the needs of the local community; residential and academic.
I exhort the Board to reject the application at this time.
Senator Marie Sherlock