Richmond Road planning application observation LRD6006/23-S3
Planning Department
Dublin City Council
Civic offices
Wood Quay
Dublin 8
4th April 2023
Re: LRD6006/23-S3
158A Former Leyden’s Wholesalers and Distributors, Richmond Road, Dublin 3
At a time of such enormous housing need in this city, I welcome the planning application for the site of the former Leyden’s Wholesalers and Distributors business.
Specifically, the provision of artist space is most welcome. The provision of artist space follows from the requirement of the Dublin City Development plan and it is very welcome that the developer has offered the spaces to the artists who previously operated out of the Richmond Road studios on a long term lease of up to 25 years. With an increasing shortage of artist and performance space across the city, the certainty provided by these studios is a welcome addition.
However, the proposed design also gives rise to a number of concerns which I believe need to be addressed by special conditions attached to the granting of planning permission for the site;
Childcare facilities
The calculations deployed to justify the provision of 156sq meters of childcare places are deeply flawed. Firstly, it is simply not credible to exclude 30% of the two bedroom apartments from the measure of childcare need on the basis of (a) demographics and (b) a perspective, without foundation, that the apartments will, in the main, be populated by adults without children. This is at odds with the reality of the take up of available housing supply in Dublin at present. Furthermore, the analysis relies on out of date local information as to the availability of childcare provision and early years education in the area as it cites the facility in Corpus Christi Parish Hall which has been closed since December 2021 and also mistakenly includes a childcare facility located across the Liffey.
Given the severe shortage of appropriate childcare infrastructure in this part of the city, it is vital that the floor area allocated to childcare facility is increased and a special provision inserted accordingly.
Traffic management:
The location for the new development fronts onto Richmond road which has been beset by series of chronic traffic management problems and policy response failures over many years.
Grant of planning permission by DCC must be contingent on the developer working with the council to ensure that that stretch of road is improve for pedestrian and cyclists safety. It is simply unacceptable that planning would be granted in isolation to the broader needs of the road.
The chronic traffic management problems relate to a number of road features; narrow width of the footpath, the lack of paid parking, a serious lack of traffic calming measures, high traffic volumes and aggressive driving patterns. A Richmond road action plan was agreed with the local council in 2007 and was never implemented and since then there have been a series of ideas and plans which were never implemented. The move to introduce paid parking to the road has already been delayed from the original commitment for March/ April this year.
Cycle Parking and Loading bays
It is not clear where precisely provision of loading bays or space for delivery drivers has been made in the plans and if these will be easily accessible making deliveries to residents in the development. Consistent with the need identified above with regard to a safer pedestrian and cyclists environment it is vital that delivery vans do not have to resort to illegal footpath pakring in order to discharge their duties and that ample and safe provision is made within the development.
Special conditions must be inserted to make adequate provision for delivery bays and cargo cycle parking spaces.
Construction traffic management
Given the existing difficulties associated with traffic management as highlighted above, it is vital that special conditions are attached to the grant of planning that set out the hours of construction, community liaison responsibilities on the part of the developer and a detailed traffic management plan for moving vehicles plus construction worker parking for the duration of the construction project.
Daylight assessment
The new development must get the right balance between the provision of new housing, while maintaining consistency with the existing local community. Where the impingement of daylight is estimated to have a “moderate”, this is of concern and all efforts must be made to amend the design and minimise such impacts to negligible.
Yours sincerely,
Senator Marie Sherlock