I?itzwilliam Place John Spoin Associates DublinZ Planning Development Consultants Chartered Town Planners 8: Chartered Surveyors wwxwisaplanningic Tel (II 662 5803 Fax ?1 676 6374 aim a {as I - rm Myth? 1 111 0 N'i? v. 0 Dublin City Council, Planning Department, Civic Of?ces. Wood Quay. Dublin8 26?? February 2020 Dear Sir Madam, RE: FURTHER INFORMATION RESPONSE IN RESPECT TO THE PROPOSED 1.0 1.1 1.2 MIXED USE DEVELOPMENT COMPRISING HOTELJ TO SHARED LIVING ACCOMODATION (INCLUDING SHARED AMENITY CO-WORKING I ARTIST STUDIOS AND PUBLIC EVENT QES AT 27-29 NEW ROW SOUTH. DUBLIN 8 THE SITE CONTAINS A PROTECTED STRUCTURE (RPS REF.: 5821). QCC REG. REF.: 4423119 INTRODUCTION On behalf of the applicant, TC Fumbally Properties Ltd. we hereby submit a response to the Further Information Request, issued by Dublin City Council on the 10th January 2020 for the proposed mixed use development under Reg. Ref.: 4423/19 on a site at 27-29 New Row South, Dublin 8. which contains a protected structure (RPS Ref.: 5821). The following sections of this cover letter provide a response to the issued raised in the FI Request which should be read in association with the accompanying responses which include the follows: a Shared Accommodation Demand and Concept Report prepared by John Spain Associates; 0 Additional lnfonnation on Communal Shared Areas and Amenity/Recreational Space prepared by The Collective; - Architectural Further Information Response including revised ?oor plans. additional sections and elevations. schedule of drawings and schedule of areas prepared by Hawkins Brown Architects in response to the items raised in the FI request; Updated Operational Waste Management Plan prepared by AWN Consulting; Enlarged Shadow Analysis Images prepared by IES Consulting; Further Information Response letter and appendices prepared by Five-Seven Architects; and Managing l)Irt?t?lnr2 luhn Spain IH- \nu mm ~\tlitl'l l'ZXL't?ufth' Dirccri It?s: I4 I ?11? I mu rum. m..I .w If}; Kurt}. ll ll . I Stt?plu'tt ltlair IH l? Mar}: Mtll' \l .I 1' Inpi-m I I I .m I lipl l\ .x I II a. Senior Iliiu'tnrs: Stephanie ll\ Blaine CrL-gzin u. iv. Associntu lulu.- nynu?r I . i .m m1 Nolan Slum Slum I. Spurn S. Stunt. 1n ll?clmd l'nm'illmm l?lzlt'k'. 2. Nu It?izltc )I??ccs: "1th In Manchester I .u'tls 1.3 1.4 1.5 2.0 2.1 2.2 2.3 2.4 27-29 New Row South . Further Information Response letter and drawings prepared by NRB Consulting. We enclose 7 no. copies of the Further Information Response. The revisions to the proposed scheme directly respond to the I request and do not result in any additional impacts on neighbouring properties. We have noted the concernslissues raised in the third party submissions and issues raised in the Planner's Report. The amendments arising from the FI response are not considered to be significant and, in our Opinion, do not warrant advertisement in this instance. The Further Information Respong dimssat?detail with the Planning Authority at a meeting on Thursday 30"1 January 2020 ich was attended by Mary Conway, Deputy City Planner, Liam Currie, Executive Planner, of the DCC Planning Department and Heidi Thorsdalen of the DCC Roads Department. The content of the documentation submitted with this Further Information Response was agreed in principle at this meeting. RESPONSE TO FURTHER INFORMATION REQUEST The following lists each number item of the Further Information Request and provides a response, which should be read in conjunction with the attached drawings and supporting documentation: 1. The applicant has not submitted suf?cient information or provided a satisfactory evidential base to demonstrate to the planning authority that the preposed shared accommodation scheme is based on an identi?ed need. This information is explicitly required by Section 5.18 of the Sustainable Urban Housing: Design Standards for New Apartments Guidelines for Planning Authorities as updated March 2018. The applicant is therefore requested to submit information to demonstrate the identi?ed housing need for shared accommodation at this location. Response In response to Item No. 1 of the FI Request, we refer the Planning Authority to the Shared Accommodation Demand and Concept Report prepared by John Spain Associates, which accompanies this Fl Response. The report is based on a requirement under Section 5.18 of the Sustainable Urban Housing: Design Standards for New Apartments Guidelines for Planning Authorities (Apartment Guidelines 2018) which states that it is ?the obligation of the proposer of a shared accommodation scheme to demonstrate to the planning authority that their proposal is based on accommodation need and to provide a satisfactory evidential base accordingly. The report demonstrates that, having regard to the location of the proposed shared accommodation development within the City Centre and the current shortage of housing units. particularly in the rental market, it is considered that there is a signi?cant need for such type of development. The subject site is considered to be a very well suited location for Shared Accommodation, having regard to it?s central and accessible location within the city centre and in proximity to a number of highly concentrated employment centres. John Spain Associates Planning Development Consultants 27-29 New Row South 2.5 2.6 2.7 2.8 2.9 2.10 2.11 The report also demonstrates that due to the changing demographic trends in Dublin and the rising costs of traditional renting, there is a demand for this type of accommodation and accordingly, there is a requirement for the proposed development to contribute, albeit in a limited way given the moderate number of bedspaces proposed. to address the housing crisis. It is also noted that there is no other shared accommodation development within a 1km radius of the site. The nearest proposed shared accommodation schemes are located 1.9km from the site at Rathmines House. Dublin 6. and 2.2km from the site on Hill St, Dublin 1. It is respectfully submitted that the attached report demonstrates compliance with Section 5.18 of the Apartment Guidelines and adequately responds to the requirements in Item No.1 of the FI Request PL lullThe applicant should note that Table 5b of T*t?he sustainable Urban Housing: Design Standards for New Apartments Guidelines for Planning Authorities specifically refers to minimum common living and kitchen facilities ?oor area (our emphasis). It is noted that the amenity floor area calculated by the applicant includes both communal kitchen/living rooms and other communal facilities such as the screening room, laundry and facilities. Therefore the proposal would result in a notable shortfall in the quantitative provision of communal facilities. The applicant is requested to address the planning authority's concerns by submitting revised proposals which deliver the quantum of communal living and kitchen facilities required by Table 5b of the Sustainable Urban Housing: Design Standards for New Apartments Guidelines. In response to Item No. 2 of the FI Request, we refer the Planning Authority to the revised ?oorplans and schedule of areas prepared by Hawkins Brown Architects. which accompany this Fl Response. It should be noted that the proposed has never been included within the calculation for communal living and kitchen facilities and the proposed laundry has now been omitted from this calculation. The applicant has also provided minor internal recon?guration of the bedrooms to improve the size and layout of the communal living areas. The applicant met with the Planning Authority on the 30th January 2020 to discuss how the development complies with the requirements under the Apartment Guidelines 2018 for communal shared areas for kitchen/living/dining. Under Section 5.16 of the Guidelines, Table 5b states that the minimum floorspace requirement for a common shared area for "living and kitchen facilities? will be calculated on a per bedroom basis 8 sq.m per person for bedrooms 1-3 and an additional 4 sq.m per persons for bedrooms which equates to an average of 6 sq.m of communal ?living and kitchen facilities" per shared accommodation resident. As outlined in the attached ?oorplans and schedule of areas, the proposed development provides a total 426 sq.m of communal Iiving/kitchen/dining areas for the 69 no. shared accommodation residents, which equates to 6.2 sq.m per bedspace and therefore meets and exceeds the standards set out in Table 5b of the Guidelines. As illustrated in Table 1, these areas are equally distributed throughout the scheme and provide for a variety of uses. John Spain Associates Planning 8. Development Consultants 27-29 New Row South 2.12 2.13 2.14 In addition to the standards set out in Table 5b of the Guidelines, the development provides wider recreation and leisure amenities as part of the overall development, as required under 5.17 of the Guidelines, including a and wellness centre (shared with the hotel) and 805 sq.m of external open space within the ground floor courtyard, ?oor rook terrace and seventh ?oor roof terrace. and outlined in Table 2. Table 1: Communal KitchenILivinllDining Areas in the Proposed Development Basement - Communal Living (Screening Room) 39 sq.m Ground . Communal Living (Library/Workspace) 70 sq.m Floor . Communal Living (Informal breakout) 22 sq.m . Communal Kitchen/Dining 63 sq.m 5th Floor . Communal Living (Informal breakout) 15 sq.m - Communal Living (Informal breakout) 17 sq.m Floor - Communal Living (Informal breakout) 15 sq.m . Communal Living (Informal breakout) 24 sq.m 7th Floor . Communal Kitchen/Dining 113 sq.m - Communal Living (Event Space Communal 48 sq.m Lounge) Total 426 sq.m Table 2: Provision of Communal Areas and AmenityIRecreational Space Communal Additional Additional External LivinglKitchenl Residents Internal Open Space Dining Area Support Facilities Amenity and per per bedspace per bedspace Recreation bedspace Space per bedspace Min. requirements 8 sq.m Not Specified Not Specified Not Speci?ed under Apartment Guidelines 2018 Proposed Shared 5.3 sq.m (a total 2.78 sq.m (includes 1.1* (shared 11.7 Living at New Row of 433 sq.m) reception, lobby, with hotel and South, Dublin 8 laundry facilities) includes gym, studio, wellness area, treatment room, lounge) *Total of 228 sq.m shared with hotel guests. Shared Accommodation represents 32% of rooms 1.1 sq.m per bedspace The Planning Authority agreed in principle to the quantum of communal living/kitchen/dining areas, in accordance with the requirements of the Apartment Guidelines, but required further comfort on the extent, nature and usability of the spaces for residential amenity as required for shared accommodation schemes. We refer the Planning Authority to the attached brochure prepared by The Collective which provides additional information on the communal shared areas and amenity/recreational space within the proposed development. The brochure outlines that the communal living/kitchen/dining areas provide a range of spaces for residents to encourage communal living. The brochure demonstrates the extent, nature, usability and function of each proposed communal area and John Spain Associates Planning 8. Development Consultants 27-29 New Row South 2.15 2.15 2.16 2.17 2.18 2.19 2.20 amenity/recreational facility within the proposed development. The brochure also provides examples of how such spaces are used in shared accommodation schemes in the UK. it is respectfully submitted that the above demonstrates compliance with the requirements of the Apartment Guidelines and adequately responds to the requirements in Item No. 2 ofthe Request. 3. The Planning Authority considers that the 20 sq lounge area on the 6th ?oor is poorly configured and is insufficient in terms of ?oor area. The applicant is requested to address this issue, it is recommended that the adjoining room numbers 8611 and 8612 are removed to allow for the provision of larger and useful communal area on this ?oor. Response In response to Item No. 3 of the FI Request, we refer the Planning Authority to the revised ?oorplans and schedule of areas prepared by Hawkins Brown Architects. which accompany this Fl Response. The applicant has provided minor internal recon?guration of the bedrooms to improve the size and layout of the communal living areas from 20 sq.m to 24 sq.m. As per the response for Item No. 2. the proposed development meet the requirements for communal living/kitchenldining space and also provides internal and external amenitylrecreational space. It is respectfully submitted that the above demonstrates compliance with the requirements of the Apartment Guidelines and adequately responds to the requirements in Item No. 3 of the Fl Request. 4. The Operational Waste Management plan refers to the provision of Area Waste Stations on each floor, however, these areas have not been indicated on the proposed ?oor plans. The applicant should be requested to clarify their locations. ALD- Response 119' Mi. ?St - A In response to Item No. 4 of the FI Request, we refer the Planning Authority to the updated Operational Waste Management Plan prepared by AWN Consulting. which accompanies this Fl Response. The updated OWMP now refer to the Area Waste Stations provided at each level of the shared accommodation ?oors. Disposal of waste will be managed by the Management Company as referred to in the Operational Management Plan submitted with the application. It is respectfully submitted that the attached document adequately responds to the requirements in Item No. 4 of the FI Request. John Spain Associates Planning Development Consultants 27-29 New Row South 5. The shadow impact images contained within Section 5.1 of the Daylight, Sunlight and Overshadowing analysis report prepared by are insufficient in terms of scale in order to allow for a full assessment of the proposal. The applicant is requested to re-submit these images in A3 size. Response 2.21 In response to Item No. 5 of the FI Request. we refer the Planning Authority to the Enlarged Shadow Analysis Images prepared by IES Consulting, which accompany this Fl Response. 2.22 The shadow analysis is now enlarged at A3 scale is now sufficient in terms of scale to allow for a full assessment of the proposal in terms of overshadowing. 2.23 As outlined in the documentation submitted with the planning application, the Shadow analysis shows different shadows being cast at specific times of the year for the proposed scheme in comparison to the previously permitted design. The images show what potential shadows could be cast and this is quanti?ed in the further sections of the report. 2.24 When compared to the previously permitted scheme there is minor additional shading noted throughout the periods considered and as such the impact of the proposed development can be classified as a minor impact when considering the overshadowing. 2.25 it is respectfully submitted that the attached shadow images adequately respond to the requirements in Item No. 5 of the Fl Request. 6. The Conservation Section has requested the following Additional Information: a) Details and methodology of the demolition process, the support/stabilisation of walls to be retained within the new scheme, particularly where internal dividing walls and roof are removed. b) Details and methodology in respect of salvaging, particularly the cast iron columns and girders stone paving and any other discovered features of interest and their proposed reuse within the scheme. c) Details of how the boundary walls will be protected and repaired in accordance with best conservation practice= d) Details regarding the formation of all new enlarged openings and lowered window openings formed within the stone walls (lintels, linings etc). e) Underpinning details where required to the existing wall fabric to be retained. t) A detailed section through the external retained historic walls showing the interface between the historic walls and the new internal lining and floor structure. The capping detail and junction with the new roof areas and the proposed new extension. g) Details of the junction of the new building and the adjoining building within the Fumbally complex to the east. h) Details of the proposed glazed link between the Protected Structure and the new comer building. John Spain Associates Planning DeveIOpment Consultants 2.26 2.27 2.28 2.29 2.30 2.31 2.32 . 3.91;: 27-29 New Row South Response in response to Item No. 6 of the Fl Request. we refer the Planning Authority to the response prepared by Five Seven Architects and drawings prepared by Hawkins Brown Architects and JJ Campbell Consulting Engineers, which accompany this Fl Response. The response prepared by Five Seven addresses each section under Item No. 6 with reference to the relevant drawing for further details. The response prepared by Five Seven concludes by stating the following: ?The conservation principle of promoting honesty of repairs and alterations will be employed to ensure that. while it is intended that the alterations would be in keeping with the character of the building and would employ appropriate materials in keeping with the industn'al aesthetic, alterations will not confuse the historic record of the building and will be discernible from original details.? The response also notes that the contractor and all site operatives will be clearly advised of the importance of the historic structure and the works be carefully supervised and inspected in this respect both by the Conservation Architect and the Site Manager. The Contractor shall be responsible for the careful salvage and storage of any original elements and materials of the existing structure that are in good condition and are to be re-instated as part of the works. It is respectfully submitted that the attached documents adequately respond to the requirements in Item No. 6 of the FI Request. 7. The Transportation Planning Division requires the following further information a) The submission of revised plans which include the following amendments: The provision of a minimum two metre wide footpath around the site. The footpath should not be overhung by any building. (ii) All outward opening doors reversed in order to avoid con?ict with the public realm. In response to Item No. of the FI Request. we refer the Planning Authority to the attached response prepared by NRB Consulting Engineers. The applicant met with the DCC Roads Department on the 30th January 2020 to discuss a proposed response to the Further lnforrnation Request. Further consultations have also taken place via email correspondence with Heidi Thorsdalen of the DCC Roads Department to agree in principle the proposed road improvements. It is acknowledged that the proposed scheme layout does not reduce the existing footpath widths. The overall site layout is shown on drawing with existing footpath widths dimensioned. The footpath width past the site on New Row South is generally 2.0m. It is acknowledged that the exiting footpaths are less than 2.0m in places. however the scheme provides a colonnade area which proves extra width for pedestrian at corner of New Row South and Blackpitts where the existing footpath is at its narrowest, giving footpath users an alternative and an opportunity to pass. The corner of the building is now chamfered at ground ?oor to further improve pedestrian accessibility and passing opportunity. in order to address the Planning John Spain Associates Planning Development Consultants 2.33 2.34 2.35 2.36 2.37 2.38 2.39 2.40 27?29 New Row South Authority's concerns. This now result in 12.3m of footpath of widths varying between 1.2m and 1.8m and provides an improved area where pedestrians can use the wider space to pass. Subject to agreement with DCC Roads Department, the Applicant is willing to accept a condition to rebuild and widen the existing footpath on Blackpitts to 2.0m into the existing carriageway where the road is 6.0m wide or more. tapering to match the existing footpath width at the corner of New Row South and Blackpitts. We note Blackpitts Road varies in width past the site. This will improve the existing footpath provision while also reducing the carriageway width on Blackpitts past the site. This would also be an effective traf?c calming measure. These proposed footpath works are shown on drawing NRB-RFI-OO1 enclosed. In response to Item No. 7(a)(ii) of the FI Request. we refer the Planning Authority to which shows any previously outward opening doors now reversed in order to avoid con?ict with the public realm. It is reSpectfully submitted that the attached documents adequately respond to the requirements in Item No. 7(a) of the Fl Request. b) The applicant is requested to address conflict between the cycle storage and the ramp associated with the delivery route. The applicant is also requested to confirm the system of cycle parking proposed. In response to Item No. 7(b) of the Fl Request. we refer the Planning Authority to the attached response prepared by NRB Consulting Engineers which states that In order to address any con?ict between the cycle storage and the ramp associated with the delivery route. a cycle route is designated up the ramp along the route to the cycle storage, past the delivery areas. The delivery areas are also clearly defined by way of road markings. as per the updated Hawkins Brown ground floor plan, so delivery vehicles park in the correct location and do not block cyclist access. The response prepared by NRB Consulting Engineers also provides details of the proposed cycle parking system proposed for the development. It is respectfully submitted that the attached documents adequately respond to the requirements in Item No. 7(b) of the FI Request. c) The applicant is requested to clarify non provision of disabled parking and if there is a relationship with any local car park providers in terms of providing parking for the proposed hotel. In response to Item No. 7(c) of the FI Request, we refer the Planning Authority to the attached response prepared by NRB Consulting Engineers which states that there are many existing and permitted hotels in Dublin currently/will operate without dedicated car parking. The proposed development does not provide for car parking spaces for either hotel or shared accommodation schemes. In response to the Planning Authority?s concerns. the delivery area at the ramped access to the development from Blackpitts, where deliveries will be managed, will be available as a managed set down space for disabled car parking for the shared living element of the scheme. This will be communicated to relevant residents who rent accessible rooms in the shared living element of the scheme. John Spain Associates Planning Development Consultants 27-29 New Row South 2.41 2.also note that there is an existing on-street disabled parking space on Blackpitts adjacent the Site which can be used for disabled car parking spaces/set down area. It is respectfully submitted that the attached documents adequately respond to the requirements in Item No. 7(c) of the FI Request. OTHER RELEVANT MATTERS . . . $40 '1 10 Appropnate Assessment itnote under the Appropriate Assessment section of the Planner?s Report, the following wording is included: ?Under Article 6 of the EU Habitats Directive and Regulation 30 of 8! NO. 94/1997 ?European Communities (Natural Habitats) Regulations (1997) any plan or project which has the potential to significantly impact on the integrity of 3 Nature 2000 site must be subject to an Appropriate Assessment. This requirement is also detailed under Section 177 (U) of the Planning and Development Act 2000 (as amended). it is considered that there will be no significant negative effects on any Nature 2000 site as a result of the proposed development. As a result a Stage 2 Appropriate Assessment would therefore not be required?. In this regard we note that the European Communities (Natural Habitats) Regulations (1997) have been revoked and the relevant legislation pertaining to Appropriate Assessment is Section of the Planning and Development Act 2000, as amended, which provides that a screening for AA shall be carried out by the planning authority to assess, in view of best scientific knowledge. if the proposed development, individually or in combination with another plan or project is likely to have a significant effect on the site or sites concerned. The application is accompanied by an Appropriate Assessment Screening Report prepared by Open?eld Ecology. The Screening Report concludes that, in view of best scienti?c knowledge, the proposed development, individually and in combination with other plans and projects. is not likely to have any signi?cant effect on any Natura 2000 site and that a stage 2 Appropriate Assessment is not required. We would be grateful if the Planning Authority can update to reflect the relevant legislation pertaining to Appropriate Assessment, as outlined above. Third Party Concerns We note a number of concern/issues were raised by third parties during the 5 week public consultation period. it is respectfully submitted that this Fl response, Planning Report and all other supporting documentation submitted with the application seeks to provide a comprehensive justi?cation for the proposed development. in response to the issues raised in the third party observations. The proposal is considered to be a positive in?ll development within the Inner City area and fully supports the policies outlined for the Liberties Strategic Regeneration John Spain Associates Planning 8. Development Consultants 27-29 New Row South area under the City Development Plan 2016-2022. The proposed development has been prepared to accord with the relevant National Planning policies. the Dublin City Development Plan 2016-2022 and Apartment Guidelines 2018. The application has been the subject of 3 no. formal pre-application meeting with the Planning Authority and Conservation Of?cer prior to lodgement and 1 no. meeting to discuss the FI Response which has informed the overall layout and design of the proposal. 4.0 CONCLUSIONS 4.1 The text response above and accompanying material submitted with this Fl response clearly illustrates how each of the FI Items have been addressed. 4.2 It is respectfully submitted that the revised proposals for the pr0posed mixed use development at 27-29 New Row South. provide a suitable response to the concerns raised by the Planning Authority and result in a suitable form of development on the subject site which accords with the proper planning and sustainable development of the area. Having regard to the above, we respectfully request that a decision to grant permission be issued in respect to the proposed development. 4.3 Please do not hesitate to contact us should you have any queries in respect to the information submitted. Yours sincerely, Gwyn?bx. John Spain Associates John Spain Associates Planning Development Consultants 10