SIMON CLEAR & ASSOCIATES
PLANNING AND DEVELOPMENT
CONSULTANTS
h

Student Accommodation Concentration Report

Dublin City Development Plan Compliance Report

for
Mixed – Use Student Accommodation Scheme
Prussia Street
Dublin 7

Simon Clear Associates

May 2020

3 TERENURE ROAD WEST,
TERENURE,
DUBLIN 6W
D6W YY79,
IRELAND.
Simon Clear B.A. Dip. T.P. MIPI
Darran Quaile B.A. MRUP MSc BLUP MIPI
Paula Shannon B.A. MRUP MIPI

Phone:
00-353-1-492 5934
Fax:
00-353-1-492 7617
E-mail: admin@clearconsult.ie
Web: www.clearconsult.ie
Vat No. 9803199H

 Purpose of Report
The purpose of this report is to address the provision and requirements of the DCDP in
relation to the distribution of student accommodation. The DCDP notes that applicants for
student accommodation will be requested to submit evidence to demonstrate that there is
not an over-concentration of student accommodation within an area, including a map
showing all such facilities within 0.25 km of a proposal.
Variation 3 of the DCDP now indicates – ‘The applicant will be requested to submit
evidence to demonstrate that there is not an over-concentration of student
accommodation within an area, including a map showing all such facilities within 1km of
a proposal’.

This report has been prepared to: Provide a policy context and analyse the demand for student accommodation in
Dublin City;
 Address the future development of student accommodation, primarily to serve the
new university campus in Grangegorman;
 Provide a justification for the provision of student accommodation on the subject
site

Overall Context
Dublin City faces a shortage of supply on every accommodation front, including
houses/apartments, rental accommodation, student accommodation, business community
accommodation, hotel and guest accommodation, social housing accommodation. There is
a requirement for a range of accommodation. Standard accommodation is understood in
this context to refer to apartments for permanent occupation.

When dealing with this range of shortage, it is not a matter of standard versus student, or
any other form of accommodation for that matter. Student accommodation is part of the
solution to the general accommodation shortage. It eases pressure on the market
for/availability of houses, apartments, home ownership possibilities and availability in the

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 rental sectors. This was recognised in a repoprt prepared by John O’Hara1, City Planning
Officer including the following observations: Pros
 There are benefits to Purpose-Built Student Accommodation (PBSA) in the city as
underutilised sites are unlocked and developed to provide quality PBSA.
 PBSA can also release private rental units for non-student use.
‘Destudentification’ – the movement of students away from certain areas from the
private rented sector into purpose built accommodation.
 Desirable daytime activity/animation/ “liveliness” into areas and adding to the
vitality of urban areas
 Promote the economy of its surrounding community through impacts of both
direct and indirect spending and create new local businesses including retail
services.
 Reduced parking needs.
Cons
 Negative impacts often associated with student populations can be by way of noise
generation and late night activity.
 The impact of the transient nature of students and term time limits leading to less
sense of community and less activity.
 High cost of PBSA for students could discourage students from leaving Houses in
Multiple Occupancy (HMO).
 Concern about displacement of other housing typologies.
The report indicated a relative absence of approved PBSA on the north west side of the
city compared to other parts, as shown on the map extracted from the report below.

1

Purpose Built Student Accommodation in Dublin: Context, Patterns of Development and Emerging
Trends; December 2016, presentation.

3

 Site Marked with Red Circle

The report noted there was not an overconcentration of student accommodation in PBSA
in the north-western sector. Student accomodation in D7, represents less than 10% of the
total population of the area. The addition of approximately 300 bed spaces will represent
an addition of <0.01% of the district population, by reference to the table below.

4

 The Government has identified student accomodation as a discrete form of residential
accommodation and has made specific provision for it in the latest amendments to the
Planning Act.2

Rebuilding Ireland: Action Plan for Housing and Homelessness was published in July
2016 and laid out an action oriented approach to addressing the national accommodation
crisis. Pillar four of Rebuilding Ireland focussed on the supply of rented accommodation.
Actions included the implementation of affordable renting initiatives as well as
encouraging build-to-rent developments to enhance the supply of student accommodation
(among others). The inclusion of student accommodation was designed to both increase

2

For the purposes of the Planning and Development (Housing) and Residential Tenancies Bill 2016, an Act
to amend the Planning and Development Acts 2000 to 2015, the Residential Tenancies Acts 2004 to 2015,
the Local Government Act 1998 and the Housing Finance Agency Act 1981, “student accommodation”
means non-permanent residential accommodation for students or related to a Higher Education Institute
which shall not be used for the purposes of permanent residential accommodation, as a hotel, hostel, aparthotel or similar but which may be used as tourist/visitor accommodation only during academic holiday
periods.

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 the supply of housing to students and to reduce dependency on the traditional rental
sector.

The National Student Accommodation Strategy
The National Student Accommodation Strategy launched in July 2017. It was designed to
further support the development of purpose built student accommodation.
The National Student Accommodation Strategy3 is designed to ensure that there is an
increased level of supply of purpose built student accommodation (PBSA) to reduce the
demand for accommodation in the private rental sector by both domestic and international
students attending our Higher Education Institutions (HEIs).

Particular measures of success will include full delivery of a number of key targets,
including: 1. Construction of at least an additional 7,000 PBSA bed spaces by end 2019;
2. Construction of at least an additional 21,000 PBSA bed spaces places by 2024
over the baseline figure of 33,441 PBSA bed spaces which are currently available.
3. To increase the number of students taking up Digs accommodation to around
4,000 per year by 2019. This would be an increase of 1,500 per annum compared
to 2016.
4. Production of a Quarterly Reporting document which will track both public
(HEI) and private developments of PBSA in Ireland to monitor the progress made
in relation to the targets outlined in this Strategy.
5. A significant increase in the quantum of bed spaces available to HEIs via
nomination agreements. This will require the development of relationships and
nomination agreements between private providers of PBSA and HEIs to increase
the availability of good quality PBSA for students attending HEIs. This will be an
added attraction for marketing HEIs as a location of choice for students both
nationally and internationally.

Housing for students is a specific and important segment of the overall housing sector
with distinct characteristics and requirements. This has a significant related impact on the
3

National Student Accommodation Strategy; Department of Education and Skills, July 2017.

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 private rental sector and an increase in the provision of student accommodation is a key
priority in addressing the housing crisis. There are a significant number of students
renting from private landlords in Ireland.

Accommodating students housed in either PBSA or in Digs will free up an additional
housing unit in the private rented sector that would otherwise have been occupied by
students. The impact of an additional 21,000 student accommodation bed spaces, in
addition to an additional 1,500 Digs spaces, will free up at least an additional 5,000 rental
units for the wider residential rental sector.

Students generally would prefer to reside in on-campus accommodation and research
internationally has shown that students living in on-campus accommodation have higher
retention rates than commuter students, and also exhibit higher scores on developmental
scales.

Research on the transition from school to higher education, commissioned by the National
Forum for the Enhancement of Teaching and Learning, highlights the impact that long
commutes can have for students new to higher education - as commuting times increase,
so too does the transitional challenge.
Commuting times impact on a student’s ability to engage with College, in particular to
participate in extracurricular events and social activities in the evenings.

A longer commute is likely to be more tiring and may have a knock-on impact on
academic aspects also.

The increased supply of student accommodation has economic benefit both through the
creation of jobs during the construction phase and through expenditure by the students
and their families in the local economy.

Appropriately located high-quality, purpose-built and professionally managed student
accommodation, can make educational institutions more attractive to students from
Ireland and abroad, and can also become a revitalising force for regeneration areas.

7

 The Government strategy is designed to ensure that additional student accommodation is
delivered in the short, medium and long-term and that such developments are integrated
into the communities in which they are sited for the betterment of the whole community.

Overall Student Numbers
All indicators point to a significant increase in full-time students attending publicly
funded HEIs for the next decade, from 2017. The HEA Key Facts and Figures for
2015/2016, published in November 2016, highlighted that there were 179,35410 full-time
enrolments in Department of Education and Skills (DES) aided HEIs in the academic year
2015/2016 (169,363 of those students attend either a university or an institute of
technology), up from 173,649 in 2014/2015 and from 169,254 in 2013/2014.

International Students
The International Education Strategy for Ireland,4 2016-2020 (IES) shows that:  In 2010/2011, 20,995 international students attended publicly and privately-funded
Irish HEIs;
 This increased by 58% to 33,118 international students in 2014/2015;
 The increase was primarily driven by increases in the non-EU student cohort,
which increased by 85% from 11,604 to 21,440 (compared to a 25% increase in
the EU student cohort);
 Since 2010, the largest increase has been seen in the number of students at
undergraduate level, which increased by 68% from 15,821 in 2010/2011 to
26,549 in 2014/2015;
 The numbers of postgraduate students also increased by 32% from 4,758 to 6,283;
 IES has set a growth target of 33% for the higher education sector, which will
result in an increase in international students in both public and private HEIs from
33,118 in 2014/2015 to approximately 44,000 by the end of the 2019/2020
academic year.
The availability of on-campus PBSA is an essential element of a HEI’s
internationalisation strategy. HEIs have consistently reported that international students
4

Irish Educated, Globally Connected, October 2016

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 demand guaranteed accommodation for at least the first year at time of recruitment.
Continued increases in international student numbers, combined with the impact of
increased domestic student numbers, will put further pressure on the availability of PBSA.

Role of the Private Sector in PBSA
Generally, it is anticipated that student numbers will continue to increase in the coming
years and this will lead to an increase in demand for PBSA.
This demand has brought global student housing specialists to Dublin, with the world’s
leading global investors in PBSA investing heavily here. These providers also have
excellent expertise in management of PBSA facilities. A number of international players
with specialist experience have come to Ireland to build and operate sustainable student
housing accommodation.

Based on the data available in 2017, approximately 18% of full-time students in Ireland
are accommodated in PBSA. This figure was low by international comparisons with the
equivalent figure for the UK published by Higher Education Statistics Agency (HESA)
being c. 27%14.

There is a requirement for investment from both publicly funded HEIs and private
developers to seek to comprehensively address the identified shortfall in PBSA. The HEA
statistical publication for 2014/2015 demonstrated that there were 81,566 full-time
students enrolled in HEIs in the Greater Dublin area out of the total of 173,649 full-time
enrolments nationally. This equates to 47% of the total full-time enrolments and shows
why the main concentration of PBSA development is centred on the Greater Dublin area.
Progress on delivery of Purpose Built Student Accommodation (PBSA)5
The year-end 2017 figures showed a total of 15,902 bed spaces either completed or in the
planning and development process.
By the end of 2018 this figure had risen to 19,293.
By the end of Q3 2019 the total potential figure had risen to 23,649.

5

Quarter 3 2019 Progress Report on the National Student Accommodation Strategy, October 2019.

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 As of the end of Q3, 2019, a total of 8,229 bed spaces have been completed. There are
5,254 bed spaces on site. Plans are approved for an additional 7,771 bed spaces,
representing a total of 21,254 bed spaces either complete, under construction or with plans
granted at the end of Q3 2019, implying 2395 submitted for planning permission but not
determined (23,649 – 21,254). A substantial proportion of these bedspaces are located in
Dublin. Note that not all permitted developments reach the construction stage.

Dublin City Council Research
In 2019, Dublin City Council commissioned a report on the Social, Economic and Land
Use potential impacts of PBSA in the Dublin City centre administrative areas 6. Some of
the information and conclusions from this report are summarised below:  The Government’s Rebuilding Ireland Action Plan underlines the importance of
providing well designed and located student accommodation to meet growing
demand and avoid additional pressures in the private rental sector (PRS) (standard
housing);
 At present there are 76,381 full time students enrolled in HEA‐aided third level
institutions in the Dublin area, with >53,000 students enrolled in the ten third level
institutions (HEA‐aided and private) within the canals of Dublin City;
 The National Student Accommodation Strategy, published in May 2017, sought to
ensure that there is an increased level of supply of Purpose Built Student
Accommodation (PBSA) to reduce the demand for accommodation in the private
rental sector by both domestic and international students attending Higher
Education Institutions (HEIs). This identifies the key target of the construction of
at least an additional 16,374 PBSA bed spaces to provide an overall supply of
28,806 PBSA bed spaces in the Dublin area by 2024;
 It is a policy of the Dublin City Development Plan 2016‐2022 to support the

provision of high‐quality, professionally managed and purpose built third‐level
student accommodation on campuses or in appropriate locations close to the main
campus, in the inner city or adjacent to high‐quality public transport corridors and
cycle routes, in a manner which respects the residential amenity and character of
the surrounding area, and in order to support the knowledge economy;
6

Social, Economic and Land Use Study of the Impact of Purpose Built Student Accommodation in Dublin City; DCC;
EY; Coyne Research Feb 2019

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  There are approximately 6,364 PBSA bed spaces currently operational within the

canals of Dublin city centre, growing to over 9,000 operational by 2020, given the
number under construction at present;
 There is the potential for a total of approximately 14,000 PBSA bed spaces to be

available for students by 2024, given the number of PBSA bed spaces approved
and in the planning process at present;
 While PBSA bed space provision in the Dublin City Council area is on track to

meet the NSAS supply target, this would address only one third of the predicted
demand for PBSA bed spaces by 2025 in the Dublin area, estimated at over
50,000;
 Interviews with students residing in seven PBSA facilities across Dublin found

that 79% of those surveyed are international students;
 With regard to the impact of PBSA on the local community, the consensus

amongst stakeholders was clear ‐PBSA has a positive impact;
 In general it is considered that any negative impact associated with the rise in the

number of students in a particular area is outweighed by the positive impact
regarding expenditure, engagement and regeneration;
 A review of recent PBSA developments in Dublin City has found that these

developments have resulted in benefits to the local environment, including the
renewal of vacant and underutilised sites, the restoration and reuse of historic
buildings and increased pedestrian linkages;
 The research also found that the majority of students in PBSA use local services

and facilities regularly and 15% work or volunteer locally, which could be
increased as these new facilities become more established in their local area;
 International comparisons indicate that Dublin has a relatively low proportion of

students accommodated in PBSA, with approximately 16% of the student
population accommodated in PBSA in 2018 compared to approximately 38% in
Edinburgh;
 As recognised in the planning policies of other international cities, a major

advantage of purpose built student accommodation is that that purpose‐built and
well managed schemes reduce potential issues such as antisocial behaviour,
compared to the widespread conversion of family housing into shared student
properties which are more difficult to manage;

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  The use of a criteria policy for PBSA developments, including topics such as

amenity, character, appearance and management, allows for consideration of
impacts on a site-by-site basis. This allows each case to be considered on its own
merit;
 By developing and utilising an appropriate Management Plan for PBSA, the

managers of PBSA can minimise any potential negative impacts from the PBSA
developments and their occupants on surrounding properties and neighbourhoods.
It also means that a positive and safe living environment can be created for
students as well as acting to develop and enhance the neighbourhoods in which
they are situated for the betterment of the whole community;
 There is a significant contribution to the economy of the local shops and services increased footfall and expenditure have led to the opening of new businesses in the

locality of PBSA;
 In general it is considered that any negative impact associated with the rise of the
number of students to a particular area is outweighed by the positive impact
regarding expenditure, engagement and regeneration.
 65% of all residents walk to college/university therefore proximity is key from a
planning perspective;
 In terms of the market for language schools, student numbers in 2017 increased to

just under 130,000 form 120,000 in 2016;
 Current employment in the sector is estimated at 145 employees (1:44 direct jobs

ratio);
 The development of PBSA in Dublin City Centre has impacted positively in terms
of regeneration, many being built on underutilised sites in areas that would have
not been otherwise developed;
 The PBSA sector is a necessary component of the residential stock of the city and
it has not forced out private residential development in instances where the sites
were already vacant and underutilised for a considerable number of years.

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 Edinburgh
Edinburgh has been cited by DCC as a peer city for policy relating to PBSA. The history
of planning policy for PBSA in Edinburgh, which has a high ratio of PBSA, emphasises
the benefits of purpose-built and well managed student accommodation schemes as
follows:  Increases competition and eases pressure on the general housing stock;
 Reduces potential issues such as antisocial behaviour;
 Assists the growth of third level institutions and the attractiveness of the city as a
centre for Higher Education;
 Regeneration development can take place at relatively high densities, allowing for
the efficient use of urban land.
 Open space and car parking provision can be tailored to reflect the nature of the
proposed use;
 Locational and design guidance states that student housing will generally be
supported adjoining a main university campus;
 Threshold limits can have a contradictory and unsustainable effect on the
development of PBSA - the prime planning issue is the location of PBSA on sites
where there is accessibility to third level institutions by sustainable transport
means.

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 Residential Tenancies (Amendment) Act 2019
The affordability of accommodation is a vital element in ensuring access to third level
education for all of our students. The Residential Tenancies (Amendment) Act 2019
provides rent predictability for students living under licence in PBSA, and their parents,
by including registered students residing under licence arrangements in PBSA during
term-time, under existing Rent Pressure Zone provisions. The provisions will come into
effect for licenses commencing from the 15th August 2019.

Grangegorman Redevelopment Context
The Grangegorman Campus was declared to be an SDZ by Government. The
Grangegorman Development Agency (GDA) prepared a planning scheme which was
approved by An Bord Pleanala, as described below:  The Grangegorman development7 represents a significant urban regeneration
project of 29 ha (73 acre) of underutilised land in Dublin’s inner city.
 It will deliver important facilities that underpin national and European
infrastructural needs, addressing Education, Health, the Arts, Community
Facilities and Student Accommodation, in addition to Sports and Recreation.
 The Grangegorman development relocates, on a phased basis, the Technological
University Dublin (TUDublin) c.40 buildings on dispersed sites within Dublin
City to a single campus;
 It also provides health facilities for the Health Service Executive (HSE), in
addition to community and recreational uses and commercial development.
 Planning has played a critical role in the delivery of the campus and in securing
Government support for the project.
The applicant’s design team consulted with the GDA before and during preparation of the
final scheme. It emerged from initial consultation that the proposed site was an ideal fit
for the alteration to the original SDZ scheme, as approved by ABP (ref. ZE 0005) and
could facilitate direct access for pedestrians and cyclists from the West into a new plaza in
the Grangegorman campus.

7

Developing a New Urban Quarter at Grangegorman, Dublin: The Role of Planning in its Successful
Delivery; Terry Prendergast BSc, MPhil, MSc, MIPI. Principal Planner, Grangegorman Development
Agency. Pleanail Article Nov. 2016

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 The proposal is a significant project to deliver a well-designed new pedestrian/cyclist
street and western portal to the GDA SDZ campus, in a mixed-use scheme allied with
student accommodation to serve the TU Dublin centralised campus that will be located
there. It is considered that student accommodation is the most appropriate type of
residential accommodation for the mixed-use scheme.
The proposal has been designed to give generous pedestrian and cyclist access to the TU
Dublin 3rd Level campus. The students will have immediate access to the campus and all
of its community facilities, obviating a need for replication of park and sports facilities on
a site elsewhere.

Recent planning permissions for an interim boiler-house serving the campus and longer
term plans for a consolidated boiler-house will result in a wider open space/plaza
immediately adjacent to the boundary with the current site. The recent alteration to the
SDZ approved planning scheme (ABP Ref. ZE 0005) was specifically intended to
eliminate vehicular access on the western flank from Prussia Street.

The development of the subject site for student accommodation delivers another identified
access point on the western flank as shown in the figures from the amended GSDZ
Scheme exhibited below. The new pedestrian and cycle route facilitates access into the
campus from public transport, either from Bus Connects Blanchardstown – City Core
route, or the Blanchardstown – UCD BRT. Prussia Street is identified as a strategic access
route into the city for bus public transport.

The western access will facilitate non-vehicular access and modes (walking and cycling)
through a traffic-free campus, by eliminating vehicle suitable entrances and creating a
new plaza within the campus immediately east of the subject site, to which the site will
connect, with marker buildings identifying the connection.

The particular access connection is identified as Access 21 in Figure 2.2 below

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 The revised public realm immediately east of the site is shown in Figure 4.3 below, with
the subject site part outlined in Red.

The amendments to the GSDZ Scheme relating to removal of vehicular traffic are shown
below, with a main pedestrian and cycle access shown in Figure 5.17.

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 New Student Accommodation – West of Grangegorman
The current proposal is additional to two developments currently projected for the area
west/northwest of the GDA campus. The historic Grangegorman campus itself is a
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 significant land area in the North West city sector, which along with the Phoenix Park has
historically affected population density and distribution in the locality. It should be noted
that the proposed mixed-use redevelopment: Is immediately adjacent to the TU Dublin campus at Grangegorman;
 Affords a newly designed western campus entrance in accordance with the
amended GSDZ Scheme approved by An Bord Pleanala;
 Provides better connectivity for Grangegorman into the north western quarter of
the city and further out into the Phoenix Park;
 Is a regeneration project for underutilised city centre land.

Only Balark, Prussia Street (203) and the Park Shopping Centre site (485) are existing
permitted PBSA in the north western residential suburbs extending from Grangegorman
to Phoenix Park. The addition of approximately 300 student bed spaces will give a total of
c.1,000 bedspaces in PBSA in the northwestern suburban residential area. The most recent
permissions for student accommodation on North Circular Road and on Rathdown Road
are located north of the campus.

The immediate context for land use on the east side of Prussia Street is predominantly
commercial development extending west from the Grangegorman campus wall, with an
enclave of residential development located to the north of the subject site, St Joseph’s
Place and Close. The main neighbourhood extends from the west side of Prussia Street to
the Phoenix Park. PBSA located adjacent to the western perimeter wall of the campus will
not affect the neighbourhood balance in the northwest suburbs of Dublin City.

The location of the proposed development and the location of other permitted and
proposed student accommodation proposals within a kilometer radius have been mapped,
as shown below.

18

 Fig. 5 Student Accommodation Concentration Map

Relevant Planning Permissions
Ref. 2038/17 – Nearby
Planning permission granted for the demolition of Park Shopping Centre and nos. 42-45
Prussia Street, Dublin 7 and creation of portal openings in the former boundary wall
(Protected Structure).
In summary, the redevelopment of the site will consist of:

Construction of new District Shopping Centre with two vehicular entrances from
Prussia Street for deliveries and access to undercroft/surface car parking for 117
cars.



Construction of student residential accommodation overhead the district centre
buildings (494 bedspaces) in two buildings ranging from 2 to 5 storeys over
ground floor commercial north side and 4 to 6 storeys over ground floor
commercial south side of a new pedestrian and bicycle street connecting Prussia
Street to the Grangegorman SDZ. The buildings range in height from two-storey
over retail (3-storeys) near the existing northern, western and southern boundariesnearest to Prussia Street-to six-storey over retail (7-storeys) and four-storey over
retail (5-storeys) along the new street extending towards the Grangegorman SDZ
campus.

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 

A new urban plaza designed to provide an appropriate contemporary setting for
Jameson House (Protected Structure, located on the opposite side of Prussia
Street) and requires insertion of a portal connection though a former boundary
wall (Protected Structure) into the development permitted under the approved
Grangegorman SDZ Planning Scheme 2012, linking to the permitted Public Realm
and Site Infrastructure (DCC Ref. 3373/12), being developed under the auspices of
GDA as Development Agency.

Ref. 2683/19 – amendments to permitted student accommodation scheme
Planning permission granted for amendments to previously permitted development Reg.
Ref. 4035/16 on a site of c. 0.5 hectare site located at and to the rear of 84-87, Prussia
Street, Stoneybatter, Dublin 7.
The amendments comprise of alterations to the permitted development of 193 no. student
accommodation bed spaces to consist of revisions to the fenestration to all elevations of
permitted Blocks B, C, D, E, F, G.
The permitted window detail comprises a deep window reveal c.1m inset into the external
facade and this amendment will revise this occurrence in c. 150 student bed spaces
throughout the scheme to a typical window detail.
The reason for the amendment is for practical maintenance and to ensure residents safety
and results in an overall increase to the permitted development floor area of c.170m2.
Ref. 4035/16 – parent permission for student accommodation scheme above
Planning permission granted for rear of 84-87 Prussia Street for demolition of the existing
vacant single storey commercial building and the construction of a student
accommodation development with 203 no. bedspaces in 32 no. student accommodation
units.

The proposed development comprises of the construction of a series of 1, 2, 3 and 4 storey
buildings, including a 4-storey building (3 storey plus 4th storey set-back) fronting
Prussia Street. The proposed development also provides for ancillary services and 3 no.
set-down/ drop-off car parking spaces along with 120 no. sheltered bicycle spaces at
surface level. Access to the development is to be via controlled pedestrian access from
Prussia Street with access for service vehicles also provided from Prussia Street.

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 Site Specific Considerations
Guidance on locational provision of student accomodation indicates that, if not located on
campus the segmential preference is for PBSA to be located adjacent, at the campus
boundary.

The site is brownfield with low-level economic activity, suitable for high-density
regeneration. The context indicated above is that the site will facilitate significant access
on foot and by bicycle into the TU Dublin Grangegorman campus. This will be a vehicle
free corridor. The site will be unsuitable for permanent residential development of houses
or apartments, if it is to fulfil a role for enhanced access to the TU Dublin Grangegorman
campus.

The proposed redevelopment scheme, as developed in consultation with the appropriate
bodies including GDA and DCC, is the most appropriate redevelopment solution for the
particular site and it contains a very considerable amount of community and civic gain,
which should be taken into account.
When completed, the new campus will accommodate a major 3rd Level Institution, TU
Dublin, which will have a large student and staff cohort (approximately 25,000; with
future expansion in addition), requiring accommodation, good quality modern urban
services and a safe urban environment.

The campus will also accommodate a significant public health element in the existing
HSE facilities including a Primary Care Centre, Library, community and recreation
facilities available to the entire community in the north western suburbs. All of these will
be to the benefit of the welfare of the students resident at this location. The facilities in the
redeveloped Park SC development nearby will benefit the students and staff in the
campus.

GDA/TU Dublin Student Accommodation
Following extensive liaison with the GDA, the applicant is fully aware of the
requirements and proposals for student accommodation at Grangegorman. The
Government decided that the Grangegorman Campus should be the unified location for all

21

 of the dispersed colleges of the newly designated TU Dublin in the North West Dublin
city sector. Decisions made at high level strongly influence the location adopted by
students for accommodation in cities.

It is the intention of GDA to provide on-campus accommodation on a phased basis, via
the PPP procurement process. GDA has acknowledged:  The need for the proposed accommodation;
 That it will be a valuable addition to the current proposed development on the site
of the new 3rd Level University, facilitating improved access on the western flank;
 That it is at a preferred location compared to other proposals in the pipeline;
 The quantum of SDZ scheme bedspaces will not achieve the DIT requirement for
student accommodation when the campus is complete.

All of the high level decisions will have an inevitable influence on the choice of location
for accommodation by students in the future. It should be noted that the professional
student accommodation providers, who met as a group at the DCC Convention Centre on
6th April 20178, have noted that the 4,000 DIT students that were renting already occupy
rental properties throughout the city. The tendency, with a concentrated campus at
Grangegorman, is that these students will gravitate to the D1 and D7 Districts to be close
to their college.

Policy Response
These issues relating to student accommodation arise due to the Government’s ambitious
targets to get a greater percentage of the population through higher education and Dublin
City Council’s policies stated in the statutory Development Plan to grow the Dublin
Institutions and to welcome increasing members of overseas students. The increases
cannot be accommodated in existing housing stock, which is currently in short supply.
Policy in the UK has been to encourage Councils to get together with 3 rd Level
Institutions to plan and provide for more PBSA. The issue to be addressed is demand
management. Early supply of PBSA works as a demand management tool.
8

The Class of 2020 seminar held in Dublin Civic theatre on 6 th April 2017 brought together the key
stakeholders of the Irish student housing sector. Accommodation issues limiting Ireland’s international
student growth. Posted 19 04 2017.

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 It is expected that 20,000 students will be based in the Grangegorman campus by 2021
which will radically alter the demographics of the area. GDA acknowledge that demand
for local student accommodation will rise significantly ahead of the ability of TU Dublin
to provide phased PBSA within the campus. The allocated campus accommodation
provision is a quantum fixed by the approved GDA SDZ Scheme. There is no flexibility
there to respond to greater demand, or necessarily, within a timescale to meet current
demand.

Policy in the Dublin City Development Plan requires demonstrably good management of
PBSA. Therefore, early provision of PBSA close to the campus will serve a demand that
will inevitably arise in the area and will reduce pressure for competition from student
accommodation providers in the ‘standard’ residential accommodation market.
GDA commissioned RPS to carry out a study of the potential for ‘studentification’ of the
north west suburbs due to the ingress of students and to make recommendations to assist
with the integration of students into the Grangegorman Area9. Dublin is regarded as a
large city capable of absorbing students to a greater extent than some small university
cities in the UK where studentification has become an issue.

Overall Context
In summary, the proposed student accommodation is at the closest possible location to the
new TU Dublin campus. It is located on the boundary wall and the overall scheme is
acknowledged by GDA as providing a pivotal western sustainable entrance into the
campus, which is a multi-purpose medical, college, education campus with a public park
and extensive recreation facility that will serve the north-western suburbs.
The overall development is significantly complementary to the GDA campus – one will
benefit from the other, while at the same time adding significantly improved
infrastructure, services, accommodation and access for pedestrians, cyclists and public
transport users from the west and north-west suburbs into the campus.

9

Grangegorman Strategic Development Zone Report on Student Integration in the Grangegorman Area;
January 2016; RPS Planning and Environment

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 The addition of the significant number of student residents will animate the area, will
increase the use of the GDA campus recreational and parkland facilities at times when
non-resident students have left and will make the place safer by their presence and passive
surveillance.

It is submitted that a number of these criteria for positive assessment are even more
pertinent for the mixed-use scheme under consideration, that is located at the campus
boundary in an area very well served by existing and future proposed public transport
(BRT included), with a very considerable enhancement of the public realm and
permeability through the city northwestern sector.
PBSA contributes significantly to the local economy and service providers in the vicinity.
A high ratio of students can be accommodated in PBSA in a locality where there is a 3rd
Level Institution without negative social effects, where the PBSA accommodation is
located close to the Institution as it is in the current case.

Simon Clear

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