statement of consistency · the national student accommodation strategy sets target for the...

STATEMENT OF CONSISTENCY

FOR A

STUDENT HOUSING DEVELOPMENT AT COOLOUGH ROAD, TERRYLAND, GALWAY CITY

PREPARED BY

ON BEHALF OF

Montane Developments (Ireland) Ltd.

January 2020

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CONTENTS

1. INTRODUCTION ................................................................ 3

2. NATIONAL & REGIONAL PLANNING POLICY ....................... 4

3 LOCAL PLANNING POLICY ................................................ 15

4 CONCLUDING REMARKS .................................................. 20

1. INTRODUCTION On behalf of the applicant, Montane Developments (Ireland) Ltd., Unit F4, Maynooth Business Park, Maynooth, Co. Kildare, this Statement of Consistency with Planning Policy accompanies this SHD planning application to An Bord Pleanála in relation to a proposed Strategic Student Housing Development at a site at Coolough Road, Terryland, Galway in accordance with Section 4 of the Planning and Development (Housing) and Residential Tenancies Act 2016. The site is currently greenfield and vacant but is located in the well-established suburban area

of Terryland, north of Galway City Centre.

The proposed development on the subject lands will comprise the following:

• A Student Housing development comprising 2 no. blocks ranging in height from 1 to 4 storeys, providing a total of 255 no. single bedrooms (of which 5 will be accessible bedrooms) divided into 38 no. clusters.

• Ancillary student facilities to include student communal laundry (c.110.39 sq.m), student gym/fitness centre (c.133.98 sq.m), reception/security area (c.109.11 sq.m), student common/seminar area (c.183.73 sq.m).

• Provision of 8 no. car parking spaces, 280 no. bicycle parking spaces, 3 no. motorcycle parking spaces, and coach drop off (with bus shelter).

• Bin stores, plant areas, switch room, ESB sub-station, gas skid. Access to be provided from Coolough Road. Provision of pedestrian crossing infrastructure at Dyke Road and Coolough Road.

• All associated site development works, including landscaped areas, boundary treatments, drainage works, lighting; site services and infrastructure.

The proposed student housing development is consistent with the definition of ‘Student Accommodation’ as defined under section 13(d) Planning and Development (Housing) and Residential Tenancies Act, 2016 as follows:

‘(a) means a building or part thereof used or to be used to accommodate students whether or not provided by a relevant provider (within the meaning of Qualifications and Quality Assurance (Education and Training) Act 2012), and that is not for use— (i) as permanent residential accommodation, or (ii) subject to paragraph (b), as a hotel, hostel, apart-hotel or similar type accommodation, and (b) includes residential accommodation that is used as tourist or visitor accommodation but only if it is so used outside of academic term times;’

This Statement of Consistency demonstrates that the proposal is in accordance with the relevant national planning policy, guidelines issued under Section 28 of the Planning and Development Act 2000 (as amended), and with local planning policy. It should be read in conjunction with the accompanying detailed documentation prepared by McGill Planning, UrbaArq Architects, CSR Landscape Architects, Fallon Consulting Engineers, Whitehill Environmental, Future Analytics Consulting, James Horan Architectural Illustrator, Traynor Environmental, TPS Consulting Engineers, Rory Sherlock Archaeologist, IN2 Consulting Engineers, Ryan & Associates Fire Consultants, Dr. Robert Meehan Hydrogeologist, Winters Property, and Montane Developments .

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2. NATIONAL & REGIONAL PLANNING POLICY The key national and regional policies and guidelines (including Section 28 Guidelines) relevant to the proposed development are as follows:

• Ireland 2040 Our Plan - National Planning Framework (2018);

• Draft Regional Spatial and Economic Strategy 2019- 2031;

• Guidelines for Planning Authorities on Urban Development and Building Heights (2018);

• Guidelines for Planning Authorities on Sustainable Urban Housing: Design Standards for New Apartments (2018);

• Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009), and the accompanying Urban Design Manual;

• Design Manual for Urban Roads and Streets (2013);

• Smarter Travel – A New Transport Policy for Ireland (2009-2020);

• The Planning System and Flood Risk Management (2009).

IRELAND 2040 OUR PLAN - NATIONAL PLANNING FRAMEWORK (2018)

The National Planning Framework (NPF) is the Government’s plan to cater for the extra one million people that is anticipated to be living in Ireland. The NPF seeks more balanced and concentrated growth, particularly within the five major cities in Ireland. The following target is outlined in relation to national growth:

“We have five cities in Ireland today in terms of population size (>50,000 people): Dublin, Cork, Limerick, Galway and Waterford. In our plan we are targeting these five cities for 50% of overall national growth between them, with Ireland’s large and smaller towns, villages and rural areas accommodating the other 50% of growth.”

More specifically, the following guidance is provided in relation to Student Accommodation:

“Demand for student accommodation exacerbates the demand pressures on the available supply of rental accommodation in urban areas in particular. In the years ahead, student accommodation pressures are anticipated to increase. The location of purpose-built student accommodation needs to be as proximate as possible to the centre of education, as well as being connected to accessible infrastructure such as walking, cycling and public transport. The National Student Accommodation Strategy supports these objectives. “

Key National Policy Objectives which relate to this site are set out below:

National Policy Objective 4 Ensure the creation of attractive, liveable, well designed, high quality urban places that are home to diverse and integrated communities that enjoy a high quality of life and well-being. National Policy Objective 13 In urban areas, planning and related standards, including in particular building height and car parking will be based on performance criteria that seek to achieve well-designed high-quality outcomes in order to achieve targeted growth. These standards will be

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subject to a range of tolerance that enables alternative solutions to be proposed to achieve stated outcomes, provided public safety is not compromised and the environment is suitably protected. National Policy Objective 11National Policy Objective 11 In meeting urban development requirements, there will be a presumption in favour of development that can encourage more people and generate more jobs and activity within existing cities, towns and villages, subject to development meeting appropriate planning standards and achieving targeted growth. National Policy Objective 27 Ensure the integration of safe and convenient alternatives to the car into the design of our communities, by prioritising walking and cycling accessibility to both existing and proposed developments and integrating physical activity facilities for all ages. National Policy Objective 35 Increase residential density in settlements, through a range of measures including reductions in vacancy, reuse of existing buildings, infill development schemes, area or site-based regeneration and increased building heights.

EVALUATION OF CONSISTENCY The subject site is located within the established Galway city suburb of Terryland. The proposed development seeks to deliver an appropriate form and scale of student residential development at a site that is located within c.1km of the National University of Ireland Galway (NUIG) campus. It is also within 750m of Terryland Shopping Centre. The proposed development complies with the over-arching NPF principles of compact urban growth at accessible locations, high quality urban design and increased densification. The proposal also specifically addresses the identified need for additional student accommodation at accessible locations proximate to one of the main universities in the country. The National Student Accommodation Strategy sets target for the construction of 21,000 Purpose-Built Student Accommodation (PBSA) to be made available by 2024. A Student Concentration and Demand Report that justifies the proposed location of this PBSA has been prepared by Future Analytics Consulting and is submitted with this application. This report has identified that notwithstanding the PBSAs currently in the development pipeline for the area there will still be demand for additional in order to meet the 2024 target. The proposed development will also contribute to the vitality and local economy of the Terryland area through increased in use of public transport, and increased demand for local services. Development of these lands is considered to be fully in accordance with the recommendations of the NPF.

DRAFT REGIONAL SPATIAL AND ECONOMIC STRATEGY 2019- 2031 Under the Local Government Reform Act 2014 the Regional Planning Framework has been revised with the previous Regional Authorities/Assemblies (ten in total) now replaced with three Regional Assemblies. The Galway area is within the Northern & Western Regional Assembly. The current (second) draft Regional Spatial and Economic Strategy for this region provides regional level strategic

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planning and economic policy in support of the implementation of the National Planning Framework. This includes the ambitious NPF growth targets for Galway (+50% by 2040) and to need for it to become a city of scale. Accelerating compact growth within Galway is promoted and a metropolitan area strategic plan (MASP) outlined. The RSES notes that Galway needs to accommodate a greater proportion of the growth it generates within its metropolitan boundaries and to address ongoing challenges including housing choice and affordability, transport/ mobility and urban quality. The MASP vision sees Galway becoming a leading global city, renowned as a successful, sustainable, competitive, compact and accessible city of scale, and that offers sustainable choices in housing, work, transport and lifestyle opportunities for its communities. In relation to student accommodation the MASP states:

“It is important to specifically refer to the student population of the city as it comprises a significant quantum of the city population (in excess of 24,000 students attend third level colleges in the city) and there is a particular demand for student niche accommodation in the city to meet their needs. The objective of the MASP is to support the provision of purpose built student accommodation both on and off campus at appropriate locations. Delivery of this type of accommodation can be met on a variety of mixed zoned sites and is beneficial in freeing up existing private house stock within existing housing developments. This type of accommodation also has the potential to meet tourism accommodation demands outside of term time.”

EVALUATION OF CONSISTENCY The subject development seeks to provide for student housing development on a vacant residentially zoned site close to NUIG campus and existing local services. The delivery of student accommodation at this location can in turn free up existing private house stock in this part of the city. The RSES and MASP principles of compact urban growth, improved residential supply and choice, improved land-use/transportation integration and better urban design are also achieved.

URBAN DEVELOPMENT & BUILDING HEIGHTS: GUIDELINES FOR PLANNING AUTHORITIES, 2018 The Guidelines set out national planning policy guidelines on building heights in urban areas in response to specific policy objectives set out in the National Planning Framework and Project Ireland 2040.

Under Section 28 (1C) of the Planning and Development Act 2000 (as amended), Planning Authorities and An Bord Pleanála are required to have regard to the guidelines and apply any specific planning policy requirements (SPPR’s) of the guidelines in carrying out their function. SPPRs as stated in the Guidelines, take precedence over any conflicting, policies and objectives of development plans, local areas plans and strategic development zone planning schemes.

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The Guidelines emphasise the policies of the NPF to increase levels of residential development in urban centres and increase building heights and overall density by both facilitating and encouraging the development of increased heights and densities by Local Authorities and An Bord Pleanála. It identifies the need to focus planning policy on “building up urban infill sites”. The Guidelines recognise that apartment developments of 4 storeys or more are now part of the housing mix in suburban locations of cities and promote the need for more 1 and 2 bed units in such locations to reflect wider demographic trends.

Development should include an effective mix of 2, 3 and 4-storey development which integrates well into existing and historical neighbourhoods and 4 storeys or more can be accommodated alongside existing larger buildings, trees and parkland, river/sea frontage or along wider streets.

EVALUATION OF CONSISTENCY It is considered that the subject site is an appropriate site for a student accommodation building of 1-4 storeys as proposed within this application. The proposal responds to its overall natural and built environment and it makes a positive contribution to the suburban context, establishing a local landmark development at an appropriate location to the northern edge of Terryland at one of the northern entrances to the city. The design and layout proposed for the blocks ensures that the site will have a strong urban street frontage and better passive surveillance onto Coolough road. The materials and finishes of the proposed blocks will be designed to a high architectural standard. The materials and finishes have also been considered with regard to the surrounding existing pattern of development and material palette in the locality. It is respectfully submitted that the proposed development has had regard to the planning policy framework as set out in the Building Height Guidelines and National Planning Framework. The provision of student accommodation at this location is supported by the height guidelines which encourages increased density and building heights. The proposed development complies with such objectives therefore is considered to be in accordance with the provisions of national policy guidelines.

GUIDELINES FOR PLANNING AUTHORITIES ON SUSTAINABLE RESIDENTIAL DEVELOPMENT IN URBAN AREAS, 2009 URBAN DESIGN MANUAL – A BEST PRACTICE GUIDE, 2009 Whilst the proposed development is not a standard residential development there are a number of common design principles which apply equally to student accommodation particularly where they are located adjoining existing residential areas. The national Guidelines elaborate a range of high-level aims for successful and sustainable residential development in urban areas. Where applicable these are assessed against the proposed scheme as follows:

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GUIDANCE EVALUATION OF CONSISTENCY

Prioritise walking, cycling and public transport, and minimise the need to use cars;

The application site is served by walking and cycling links connecting the site to the surrounding environs, to NUIG campus, Terryland shopping centre and to the city centre. A number of local upgrades to improve the footpath network along Dyke Road is also proposed as part of this application. In order to prioritise sustainable transportation means for students the proposal has restricted the number of car parking spaces within the scheme to 8. These spaces are intended principally for the use of maintenance staff and servicing for the blocks.

Provide a good range of community and support facilities, where and when they are needed and that are easily accessible;

The student accommodation proposal provides a number of on-site facilities for future students. Facilities include common rooms, gym, communal laundry, and seminar rooms. The site is well located in relation to retail and other services.

Present an attractive, well-maintained appearance, with a distinct sense of place and a quality public realm that is easily maintained;

The layout and design of development will establish a striking new building form within the area and will represent a new local landmark building helping to form a new and distinct sense of place and improving urban legibility. The proposed development will provide strong urban street frontage and passive surveillance onto Coolough Road.

Are easy to access for all and to find one’s way around;

The scheme is laid out logically with a main centrally located access point and students will be able to navigate easily and quickly around the development.

Promote the efficient use of land and of energy, and minimise greenhouse gas emissions;

The proposal seeks to apply best practice construction/engineering techniques and use of energy efficient materials to maximise energy capacity and minimise impacts of climate change in accordance with current buildings regulations.

Provide a mix of land uses to minimise transport demand;

The site is predominantly zoned for residential development of which student accommodation is a form. Ancillary support services for the students are proposed as part of the development. Otherwise the scheme is within 5-10 minute walk of a range of services in the area.

Enhance and protect the green infrastructure and biodiversity; and

The existing greenfield site is not rated of significant ecological importance and development of it can be considered. The proposed landscape strategy will facilitate green infrastructure and biodiversity

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particularly in the southern half of the site which is zoned open space and will provide a link east-west between the Corrib and other local green infrastructure.

The Urban Design Manual is the accompanying document to the Sustainable Residential Development in Urban Areas document which provides policy guidance for the creation of successful neighbourhoods having regard to a range of criteria. The proposal complies with the following design criteria:

1. Context –How does the development respond to its surroundings?


Appropriate increases in density respect the form of buildings and landscape around the site’s edges and the amenity enjoyed by neighbouring users.

The proposed development will increase the overall density of the area which at present is predominantly low density estates of own door housing. This site provides an opportunity to deliver a new architecture and sense of place. Form, architecture and landscaping

have been informed by the development’s place and time.

The development positively contributes to the character and identity of the neighbourhood.

The proposal is a striking design which at the same time respects adjoining developments within the layout and range of heights proposed.

2. Connections – How well connected is the new development


There are attractive routes in and out for pedestrians and cyclists.

The site is accessed off Coolough Road which provides connection to local services, public transport and NUIG campus.

The development is located in or close to a mixed-use centre.

The scheme will be located within c. 750m of Terryland Shopping Centre.

The development’s layout makes it easy for a bus to serve the scheme.

The site has been specifically designed to be accessible by a bus service to and from NUIG campus.

The layout links to existing movement routes and the places people will want to get to.

The site is accessed off Coolough Road which provides connection to local services, public transport and NUIG campus.

Appropriate density, dependent on location, helps support efficient public transport.

The density accords with national guidelines which promote high density development close to high public transport and local services. The minimal approach to car parking also enables this development to support the efficient use and maximise the sustainable use of public transport.

3. Inclusivity – How easily can people use and access the development?


Design and layout enable easy access by all.

The proposal has been designed for ease of access throughout the site in accordance with Part M of the building regulations.

New buildings present a positive aspect to passers-by, avoiding unnecessary physical and visual barriers.

The layout is designed to maximise visual and physical fluidity throughout the scheme. From the CGI’s it can be seen that the scheme will enhance the streetscape.

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4. Variety – How does the development promote a good mix of activities?


Activities generated by the development contribute to the quality of life in its locality.

The proposal will contribute to the housing mix of the area and will increase population creating additional demand for local services. It will also help free up standard housing supply for residents.

Uses that attract the most people are in the most accessible places.

A number of open spaces are provided throughout the scheme and will be easily accessible to students.

Neighbouring uses and activities are compatible with each other.

The area is characterised by residential uses; as such the proposed use is compatible with the surrounding area whilst at the same time improve the residential mix and making the area more sustainable in that regard.

Opportunities have been taken to provide shops, facilities and services that complement those already available in the neighbourhood.

The scheme is within 750m of Terryland Shopping Centre, it is therefore unnecessary to provide additional shops and services on site.

5. Efficiency - How does the development make appropriate use of resources, including land?


The proposal looks at the potential of higher density, taking into account appropriate accessibility by public transport and the objectives of good design.

The development provides for increased density of development compared to existing estates in the area. The gross plot ratio is calculated at 0.66; however, when the open space zoned area and road works are excluded then the net plot ratio on the residential zoning is 1.07. This increase in density compared to existing residential areas is considered in accordance with national policy and is appropriate for this particular site and location.

Landscaped areas are designed to provide amenity and biodiversity, protect buildings and spaces from the elements and incorporate sustainable urban drainage systems.

The restricted parking enables more landscaping. As a result, there is ample open space provided within the scheme which will help in promoting biodiversity and amenity.

Buildings, gardens and public spaces are laid out to exploit the best solar orientation.

The student development and open spaces will enjoy sufficient sunlight and daylight provision.

The scheme brings a redundant building or derelict site back into productive use.

The existing site is vacant and redundant. The proposed development accords with the zoning objective and wider local and regional planning objectives for the city.

Appropriate recycling facilities are provided.

Communal recycling facilities are provided in the dedicated bin stores.

6. Distinctiveness - How do the proposals create a sense of place?


The place has recognisable features so that people can describe where they live and form an emotional attachment to the place.

The Coolough Road is within the landscape corridor of the River Corrib. However, the existing character along the road at present is indistinct and fractured. The proposed development will establish a striking

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new building at a key site and will transform the sense of place.

The scheme is a positive addition to the identity of the locality.

The site is currently vacant. The proposal will provide an appropriate scale and quantum of development on an attractive site helping create a local landmark.

The layout makes the most of the opportunities presented by existing buildings, landform and ecological features to create a memorable layout.

The proposed layout adapts to the site boundaries and its constraints and seeks to develop them as a feature within the new student scheme. It also takes advantage of the existing trees along the southern boundary.

The proposal successfully exploits views into and out of the site.

The views of the site are constrained from the south-east and north-east due to the location, existing vegetation that surrounds the subject site. The site is open to the west along the Coolough Road and the proposed development established an attractive new building form along the road transforming the character of the surrounding area, providing a new urban edge and passive surveillance onto Coolough Road.

There is a discernible focal point to the scheme, or the proposals reinforce the role of an existing centre.

The development comprises of two blocks ranging in height from 1-4 storeys. The design creates a strong urban edge along Coolough Road, utilising the gradient and views into the site. Currently the locality is dominated by suburban low-density housing estates that lacks focus or identity. The proposed scheme will create a new focal point and landmark building along the Road for the locality, that responds to and integrates with the immediate and surrounding context.

7. Layout - How does the proposal create people friendly streets and spaces?


Layout aligns routes with desire lines to create a permeable interconnected series of routes that are easy and logical to navigate around.

Pedestrian permeability across the scheme and to/from Coolough Road is a key design outcome.

Block layout places some public spaces in front of building lines as squares or greens, and some semi-private space to the back as communal court.

The open space strategy for the scheme creates a number of open space areas of varying uses and sizes. This can be seen in the Landscape Masterplan by the Cunnane Stratton Reynolds Landscape Architects.

8. Public Realm - How safe, secure and enjoyable are the public areas?


The public realm is considered as a usable integrated element in the design of the development.

Public realm along Coolough Road is integrated into the design of the development and an attractive new streetscape will be provided. Within the scheme the landscaped areas will form part of the communal open space available to the students.

Roads and parking areas are considered as an integral landscaped

The scheme, due to the nature of the development and its accessible location, has minimal carparking

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element in the design of the public realm.

and this is located to the centre of the site. This has enabled the provision of additional high-quality landscaping throughout the development making the apartments and their surroundings a pleasant, peaceful location to be in.

10. Privacy and Amenity - How does the scheme provide a decent standard of amenity?


Homes are designed to prevent sound transmission by appropriate acoustic insulation or layout.

All units will be designed to prevent sound transmission in accordance with building regulations.

Windows are sited to avoid views into the home from other houses or the street and adequate privacy is affordable to ground floor units.

Adequate separation distance between opposing windows is achieved and overlooking is not considered an issue of the development particularly in relation to adjoining development.

11. Parking – How will the parking be secure and attractive?


Parking is provided communally to maximise efficiency and accommodate visitors without the need to provide additional dedicated spaces.

Parking is provided in a communal location at surface level.

Materials used for parking areas are of similar quality to the rest of the development.

Yes, the highest quality materials will be used throughout the scheme.

Adequate secure facilities are provided for bicycle storage.

Dedicated bicycle parking is provided at surface level. There are 280 bicycle parking spaces proposed.

12. Detailed Design – How well thought through is the building and landscape design?


The materials and external design make a positive contribution to the locality.

The proposed development uses a controlled nut varied palette of materials as are outlined in detail in the Architect’s Design Statement by Urban Arq.

Design of the buildings and public space will facilitate easy and regular maintenance.

This can be achieved and will be provided by the estate management company.

Open car parking areas are considered as an integral element within the public realm design and are treated accordingly.

Parking is at surface level and is limited in favour of providing high quality landscaped open space.

Care has been taken over the siting of flues, vents and bin stores.

Bin stores are located discretely within the site. No other flues or vents are proposed.

SUSTAINABLE URBAN HOUSING: DESIGN STANDARDS FOR NEW APARTMENTS GUIDELINES FOR PLANNING AUTHORITIES 2018 The Apartment Guidelines 2018 promote sustainable housing, by ensuring that the design and layout of new apartments provide satisfactory accommodation for a variety of household types and sizes, including families with children over the medium to long term.

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The development standards for apartments outlined in Chapters 3, 4 and 5 of the Guidelines are not applicable to student housing design which are subject to different design standards (e.g. - Guidelines on Residential Development for Third Level Students (DES 1999), the subsequent supplementary document (2005) and the Student Accommodation Scheme, (ORC 2007)) However, it is important to point out that the proposed development accords with the locational policies for higher density residential development outlined in Chapter 2.

EVALUATION OF CONSISTENCY The Guidelines state that Intermediate Urban Locations can accommodate higher density development that may wholly comprise apartments and can provide for densities of >45 dwellings per hectare. Whilst the proposed development does not comprise standard residential units, if one calculates density based on number of student clusters (38) divided by net site area (0.679 (i.e. residential zoned area minus open space zoned area), then the density of the scheme is c.56 clusters per ha. It is considered that the subject site is located in an Intermediate Urban Location which is defined as being within reasonable walking distance of third level institutions and short walking distance of reasonably frequent urban bus services. In this regard we note that the site is c.1km from NUIG campus and is also less than 250m from the local 407 bus service that operates to Galway City Centre (and would allow students to reach NUIG within 20 minutes). The site is also only 5-10 mins cycle from NUIG.

DESIGN MANUAL FOR URBAN ROADS & STREETS (DMURS), 2013 The Design Manual for Urban Roads and Streets (DMURS), 2013, sets out design guidance and standards for constructing new and reconfiguring existing urban roads and streets in Ireland. It also outlines practical design measures to encourage more sustainable travel patterns in urban areas.

EVALUATION OF CONSISTENCY The proposed development shall be configured internally as a ‘homezone’ type environment, in accordance with the principles of the Design Manual for Urban Roads and Streets (DMURS). This internal road shall be configured as a shared surface; car parking within the development is very limited and vehicular traffic within the site shall be minimal.

SMARTER TRAVEL – A SUSTAINABLE TRANSPORT FUTURE: A NEW TRANSPORT POLICY FOR IRELAND 2009-2020 Key targets of this national sustainable transport policy include:

• To support sustainable travel, future population and employment growth will have to predominantly take place in sustainable compact urban areas or rural areas, which discourage dispersed development and long commuting

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• Work-related commuting by car will be reduced from a current modal share of 65% to 45%, which will mean that between 500,000 and 600,000 commuters will be encouraged to take means of transport other than car driver (of these 200,000 would be existing car drivers). Change in personal behaviour will also be necessary for other travel purposes as most travel relates to non-commuting.

• Car drivers will be accommodated on other modes such as walking, cycling, public transport and car sharing (to the extent that commuting by these modes will rise to 55% by 2020) or through other measures such as e-working.

• The total kilometres travelled by the car fleet in 2020 will not increase significantly from current total car kilometres.

EVALUATION OF CONSISTENCY The proposed development is in line with this overall vision for better integration between land-use and transport. The minimal car parking provision along with the site’s proximity to NUIG campus, public transport and local services ensures that students will not rely on the private car.

GUIDELINES FOR PLANNING AUTHORITIES ON THE PLANNING SYSTEM AND FLOOD RISK MANAGEMENT, 2009 These guidelines require the planning system to avoid development in areas at risk of flooding, particularly floodplains, unless there are proven wider sustainability grounds that justify appropriate development and where the flood risk can be reduced or managed to an acceptable level without increasing flood risk elsewhere. The Guidelines adopt a sequential approach to flood risk management when assessing the location for new development based on avoidance, reduction and mitigation of flood risk; and incorporate flood risk assessment into the process of making decisions on planning applications and planning appeals.

EVALUATION OF CONSISTENCY The site is situated outside the Flood Zones A and B and is not at floodrisk. It is a suitable form of development for Zone C as confirmed in the assessment submitted with this application.

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3 LOCAL PLANNING POLICY

GALWAY CITY DEVELOPMENT PLAN 2017-2023

Core Strategy The site is located within the administrative area of Galway City Council and is therefore subject to the land use policies and objectives of the Galway City Council Development Plan 2017-2023. The City Plan came in to effect on the 7th January 2017. It includes a Core Strategy and Settlement Strategy that notes the need to accommodate continued population growth, in line with the City’s designation as a ‘Gateway’, in a sustainable manner. As per national and regional policy the Settlement Strategy promotes consolidation of the urban form of the City. The following strategic goals are noted:

• Promote balanced and sustainable economic development that will enable Galway

City to fulfil its role as a National Gateway and a Regional Centre, providing sufficient

employment opportunities and appropriate services.

• Use the role of the Gateway to harness the strengths and maximise the economic

development of the region.

• Provide for a built and natural environment that is of high quality and that contributes

to providing a good quality of life for residents and visitors and affords sustainable

transportation opportunities.

The proposed development provides for the creation of a high quality, professionally managed student accommodation to serve the City’s third level education population. The proposed development is considered in accordance with the aims of the Core Strategy in this regard.

Zoning & Development Standards The subject site is predominantly zoned R (Residential): “To provide for residential development and for associated support development, which will ensure the protection of existing residential amenity and will contribute to sustainable residential neighbourhoods”. Residential, residential institution, outdoor recreational use, accommodation for travellers, local shops, local offices, licensed premises, banks and other local services, buildings for education, childcare facilities, buildings for the care of the health, safety or welfare of the public, buildings for community, cultural or recreational use are all permitted in principle under this zoning. Uses such as hotel, guesthouses, hostels and B&Bs, part conversion or extension of private residence to studio, office, childcare facility or small enterprises by the occupier of the dwelling, at a scale as would not unduly interfere with the primary use of the dwelling, places of worship, public utilities may be open to consideration under R zoning. As a form of residential development, the proposed student accommodation development is in accordance with the residential zoning.

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The south of the subject site is zoned RA (Recreational Amenity): “To provide for and protect recreational uses, open space, amenity uses and natural heritage”. Outdoor recreation is permitted in principle under this zoning. This portion of the site is proposed for ancillary communal open space associated with the student accommodation. None of the proposed student accommodation blocks are located in the RA zoning.

Design & Height Section 8.7 of the Development Plan outlines a range of Urban Design principles (Character; Legibility; Ease of Movement and Connectivity; Quality of the Public Realm; Continuity and Enclosure; Diversity and Adaptability; Environmental Responsibility) which new developments are expected to reflect. We refer to the Design Statement prepared by UrbanArq Architects in this respect which outlines the rationale for the specific design and layout employed, and how it results in a high quality scheme that respects, responds to and integrates with the immediate and surrounding context. In relation to Building Height, whilst the Development Plan notes that the city is predominantly low rise, particularly with regard to the sensitive historic core, it is also recognised that height increases at appropriate locations “can help use land efficiently and provide for sustainable high densities.” The proposed 1-4 storey scheme is considered against the following principles outlined for assessing proposals for additional height: Protection of existing built heritage and residential amenity There is no built heritage in terms of protected structures or ACAs in the vicinity of the site. The specific layout and range of heights proposed has been carefully considered by the architects with the taller element located towards to the south-west of the site furthest from the existing estates to the south-east and north east and facing the Coolough Road.

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Creation of landmarks that enhance the city's legibility without eroding its innate character. The proposed development and in particular the 4 storey element are a response to this principle and seeks to achieve a local landmark development at the northern end of Terryland one of the oldest inner suburbs of the city and only 1.5km from Eyre Square. The site is strategically located at the end of a long stretch of the Coolough Road that heads south towards the city centre from Menlo and Coolough Village. Development of the site as proposed provides a unique opportunity to create a new urban marker that denotes the entrance to Terryland and the city, and which can be achieved without negative impact to the built and natural heritage characteristics that define the city at other more sensitive locations. Retention of existing benchmark heights so as to retain strategic views and to protect and enhance the general character of sensitive locations. The proposed development is 1-4 storeys which is considered an acceptable height range for this unique suburban site. Promotion of higher density at centres/nodes of activity, on large scale infill sites and along public transport corridors. As noted above the existing 407 bus route operates past this infill site.

Residential Standards & Amenities Section 11.3.2 outlines a variety of standards for development within “established suburbs” including Terryland where the subject site is located. New residential development is normally to be developed at a plot ratio of 0.46 although higher densities may be appropriate. Policy 2.6 (Established Suburbs) also seeks to ensure a balance between the reasonable protection of the residential amenities and the character of the established suburbs and the need to provide for sustainable residential development. The gross plot ratio of the development in this instance is 0.66. The net plot ratio (applying just the residential zoned portion of the lands – 0.679 ha) gives a plot ratio of 1.07. Whilst the proposed development does not comprise standard residential units, if one calculates density based on the number of student clusters (38 no.) divided by net site area then the density of the scheme is c.56 clusters per ha. This is considered appropriate having regard to the Design Standards for New Apartment Guidelines (2018) which state that densities above 45 units per hectare should be promoted in “Intermediate Urban Locations” (sites within reasonable walking distance of third level institutions and easy walking distance of reasonably frequent urban bus services.) Having regard to the unique nature of the site, and proximity to the NUIG campus, public transport and local services at Terryland it is considered that the proposed quantum and density of development is appropriate in this case.

Student Accommodation Policies Section 11.29 of the Development Plan supports the provision of purpose built student accommodation off campus at appropriate locations in terms of access to sustainable and public transport modes and third level institutes.

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In accordance with Section 11.29 we note, with reference to the architect’s design statement that the student accommodation proposal has been designed in accordance with national design standards for same. Accordance with the following criteria is also noted:

The location and accessibility to educational facilities and the proximity to existing or planned public transport corridors and cycle routes;

The proposed development is just over 1 km distance from NUIG campus located immediately west of Quincentennial Bridge. The site is therefore only 12 mins walk / 5 minute cycle from NUIG. The site is also less than 250 metres from the Coolough Road to Galway City Centre Bus Route 407 which runs every 30 minute Monday to Saturday. Students availing of this bus service would travel less than 20 minutes to access the NUIG Campus. It is also proposed that a dedicated bus service will serve the development when fully operational, as detailed in the Student Accommodation Management Plan submitted with the application.

The potential impact on local residential amenities;

There will not be any significant impact to local residential amenities during the operational phase of the scheme. Measures to reduce any impact are detailed in the Student Accommodation Management Plan. Although there will be some impact on air and noise during the construction phase, these will be mitigated and agreed on as per the Construction Management Plan.

Adequate amenity areas and open space; Significant communal open space is provided as part of the development. A large open space with informal running track is proposed to the south-east of the site for the student’s use.

The level and quality of on-site facilities, including storage facilities, waste management, bicycle facilities, leisure facilities, car parking and amenity;

A full range of services are provided on site for student including gym, laundry, communal rooms, seminar rooms, secure bicycle parking. Only 8 car parking spaces are provided in order to discourage car use by students in favour of more sustainable modes.

The architectural quality of the design and also the external layout, with respect to materials, scale, height and relationship to adjacent structures. Internal layouts should take cognisance of the need for flexibility for future possible changes of uses;

An innovative and exciting architectural language has been employed within the 1-4 storey accommodation building. The variety of materials used, and the building form provides a visually interesting series of elevations that read like a cluster of individual terraced units rather than one

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single building in each case. This serves to break up the massing of the buildings.

The number of existing similar facilities in the area. In assessing a proposal for student accommodation, the Council will take cognisance of the amount of student accommodation which exists in the locality and will resist the over-concentration of such schemes in any one area, in the interests of sustainable development and residential amenity.

There is only one other student accommodation facility within ½ km of the site – Menlo Park apartment complex which provides thirty-five 2 and 3 Bedroom apartments totalling 140 bed spaces. This facility is the same distance from NUIG as the proposed development. Further south, within 1km of the subject site are two additional student apartment developments – the 4 storey Gort na Coiribe and Cuirt na Coiribe developments located across from Terryland Shopping Centre. Given the above it is not considered that there is an over concentration of student accommodation in this particular part of Terryland.

Details of the full nature and extent of use of the proposed use of the facilities outside of term time.

The student accommodation will be professionally managed as outlined in the Management Plan submitted. Based on current research it is understood that the majority of the units will remain in student use outside of term time due to a combination of post graduates continuing to attend NUIG during the summer and also undergraduates maintaining their accommodation into the next term and remaining to work in the city during the summer. A proportion of the units that do become available in the summer will also be used by international language students that come in summer. Some of the units will may also be made available for short-term stays for professionals, mature students or weekend visitors outside of term time although this will be strictly controlled as outlined in the Student Accommodation Management Plan submitted.

Consideration regarding compliance with Part V arrangements for social housing will not be required where the accommodation is for student accommodation of a recognised third level institution.

Noted. No Part V units are proposed.

Transportation Policy 3.2 of the Development Plan promotes sustainable residential densities particularly along and close to routes where the Galway Transportation Strategy has proposals for a high quality sustainable transport network service. In this regard we note that the existing 407 bus service operates past the subject site with existing stops within 250m. The site will also be adjacent the planned Blue Route, which

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incorporates the existing 407 service to the city centre but will extend to Castlegar in the west of the city with the route to operate past NUIG. Policy 3.2 also promotes sites that are permeability proofed for walking, cycling and for access to public transport routes and endeavour to maximise permeability in existing developments and retain existing local links. Section 3.6 promotes cycling and walking. As outlined in the submitted Mobility Management Plan there are pedestrian footpaths located along both sides of the Coolough Road past the site with street lighting located to the east of this carriageway. The application site is connected to NUIG, local services at Terryland and local bus stops via a good network of footpaths and cycle routes. A total of 280 bicycle parking spaces are proposed as part of the development. Additional policies in relation to Waste Management (Policy 9.12), Light Pollution (Policy 9.11), Air Quality and Noise Policy (Policy 9.10), SUDS (Policy 9.8), Sustainable Building Design and Construction (Policy 9.5) and European designated sites (Section 4.2.1) are noted and the proposed development has been carefully considered with respect to same.

4 CONCLUDING REMARKS It is respectfully submitted that the proposed development will provide an appropriate form of high-quality student residential development for this residential zoned site, that is consistent with planning policy for the area. It is respectfully submitted that the proposed development will provide an appropriate form of high-quality residential development for this substantial residential zoned site providing for an efficient use of lands which are accessible to public transport and existing/planned social infrastructure. This statement has demonstrated the compliance of the development with the following:

• Ireland 2040 Our Plan - National Planning Framework (2017)

• Draft RSES for the North West Regional Assembly (2019)

• Guidelines for Planning Authorities on Urban Development and Building Heights (2018)

• Guidelines for Planning Authorities on Sustainable Urban Housing: Design Standards for New Apartments (2018)

• Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009), and the accompanying Urban Design Manual

• Design Manual for Urban Roads and Streets (2013)

• Smarter Travel – A New Transport Policy for Ireland (2009-2020)

• The Planning System and Flood Risk Management (2009)

• Galway City Development Plan, 2017-2023.

In conclusion, it is respectfully submitted that the proposed development is consistent with the proper planning and sustainable development of the area, and with all relevant national, regional and local planning policies and guidelines.

statement of consistency · the national student accommodation strategy sets target for the...

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