COMHAIRLE CONTAE ÁTHA CLIATH THEAS
SOUTH DUBLIN COUNTY COUNCIL

MEETING OF DEVELOPMENT PLAN MEETING

Tuesday, March 01, 2022

MOTION NO.47

MOTION: Councillor C. O'Connor

OPR Observation 8 Housing Objective H3+,

Chapter 2 Pages 49-50

That in the support of the Government's Housing for all policy, in particular Section 6.3.1 Housing for Older People and SDCC's objective H3+ (Copies enclosed) relating to OS Open Space the Council Agrees to include community led housing for older people, Council affordable housing and nursing homes/retirement villages in established areas in the 'Permitted in Principle' column of the land use zoing matrix to give better effect to this farseeing and timely policy.

REPORT:

The motion proposes the inclusion of community led housing for older people, council affordable housing and nursing homes/retirement villages in established areas in the ‘Permitted in Principle’ column of the land use zoning matrix for lands zoned ‘OS’ ‘To preserve and provide for open space and recreational amenities’.

As per Table 13.15 of the Draft Plan, the zoning objective for ‘OS’ zoned lands is to ‘To preserve and provide for open space and recreational amenities’. The following uses are ‘Permitted in Principle’ as per the ‘OS’ Land-Use Zoning Table (Matrix) – Allotments, Community Centre, Cultural Use, Open Space, Recreational Facility, Sports Club/Facility.

The Draft Plan states that land uses that are listed as ‘Permitted in Principle’ are considered to be generally acceptable, subject to further assessment against the relevant policies, objectives and standards set out under the Plan.

As per Table 13.15 ‘OS’ Land-Use Zoning Table, the following uses are ‘Open for Consideration’– Agriculture, Bed & Breakfast (In existing premises), Camp Site, Car Park (For small-scale amenity or recreational purposes only), Cemetery (If provided in the form of a lawn cemetery), Childcare Facilities, Crematorium, Education, Garden Centre, Guest House (In existing premises), Home Based Economic Activities (In existing premises), Hotel/Hostel, Housing for Older People, Outdoor Entertainment Park, Place of Worship (In existing premises), Public Services, Recycling Facility, Residential, Restaurant/Café, Shop- Local, Stadium, Traveller Accommodation.

In respect to land uses that are listed as ‘Open for Consideration’, the Draft Plan states the following: Land uses that are listed as ‘open for consideration’ in the land use zoning tables may be acceptable to the Planning Authority subject to detailed assessment against the principles of proper planning and sustainable development, and the relevant policies, objectives and standards set out in this Plan.

Proposed uses in this category will be subject to full assessment on their own merits and particularly in relation to their impact on the development of the County at a strategic and a local level. Such uses may only be permitted where they do not materially conflict with other aspects of the County Development Plan.

In addition and as set out in the CE Response to the OPR’s submission (SD-C195-227) which put forward an observation to omit housing for older people and residential from the ‘open for consideration’ category, it was recommended that the  ‘OS’ Land-Use Zoning Table be amended to include a footnote after ‘Housing for Older People’ and ‘Residential’ where these are open for consideration to state: ‘Only where this accords with H3 Objective 4’

H3 Objective 4 in the Draft Plan states:

To support community led housing developments for older people and social and Council affordable housing in established areas on lands designated with Zoning Objective “OS” (To preserve and provide for open space and recreational amenities), only where the quality and quantum of remaining public open spaces is deemed to be adequate and the amenities of the area are preserved.

It is noted that in South Dublin there has been a legacy of older Council estates in particular, where large areas of public open space were provided. However, in some instances these open spaces are not functioning as they should and would not meet standards of multi-functionality and security, including passive surveillance, that would be best practice today. In light of this, and in the interests of compact growth and better layout and design, there are times when open space is more efficiently used to meet the demand for housing developments for older people and social and Council affordable housing.

H3 Objective 4 stipulates that ‘only where the quality and quantum of remaining public open spaces is deemed to be adequate, and the amenities of the area are preserved’ will housing developments for older people and social and Council affordable housing in established areas on lands designated with Zoning Objective ‘OS’ be supported.

It is considered Table 13.15 and the proposed footnote after ‘Housing for Older People’ and ‘Residential’ stipulating that such development would be open for consideration ‘Only where this accords with H3 Objective 4’ as per the CE Response/Recommendation in relation to the OPR submission, satisfactorily supports and facilitates the implementation of H3 Objective 4 whilst still maintaining the overarching land use objective which is ‘To preserve and provide for open space and recreational amenities’.

The motion seeks the inclusion specifically of ‘community led housing for older people’, ‘Council affordable housing’ and ‘nursing home/retirement home’ in the ‘OS’ Land-Use Zoning Table under ‘Permitted in Principle’. The footnote linking ‘Housing for Older People’ and ‘Residential’ use classes with H3 Objective 4 addresses the issue raised in the motion in respect to providing for ‘community led housing for older people’ and ‘Council affordable housing’ whilst also providing for the required caveats relating to the quantum and quality of remaining open space.

It is noted that ‘Housing for Older People’ is an existing use class defined in Appendix 6 of the Draft Plan as ‘Housing schemes that are specifically designed to meet the needs of older people that comprise independent housing’. In addition ‘Residential’ is defined in Appendix 6 as ‘The use of a building or part thereof including houses, duplexes and apartments designed for year round human habitation’.

The motion also seeks the inclusion of ‘nursing home/retirement home’ in the ‘OS’ Land-Use Zoning Table under ‘Permitted in Principle’. 

It should be noted that ‘Nursing Home’ and ‘Retirement Home’ uses are ‘Not Permitted’ on lands zoned ‘OS’ as per Table 13.15 of the Draft Plan.

‘Nursing Home’ is defined in Appendix 6 as ‘A building or part thereof used for the care of older and/or convalescing people’.?‘Retirement Home/Assisted Living’ is defined separately in the Draft Plan as it is in the current County Development Plan as ‘Semi-independent housing accommodation specially designed for older people in which dining, recreation, hygiene and health care facilities are shared on a communal basis’.

The land area (site) size and configuration requirements for Residential and Housing for Older People schemes, particularly smaller, infill Part 8 developments supported by H3 Objective 4, are significantly less than the land area (site) size and configuration requirements for Nursing Home/Retirement Home?developments.  For example, infill Residential and Housing for Older People schemes are achievable on different size and shaped sites and can work well in smaller clusters in established communities, optimising the cost benefit of underutilised Council owned lands and providing passive surveillance and improved functionality to larger open spaces. However, Nursing Homes and Retirement Homes are subject to the National Standards for Residential Care Settings for Older People in Ireland (2016) and require a significantly greater land area (site) with a more regular shape to provide the accommodation, facilities and amenities required to meet these standards.  

An examination of Housing for Older People Schemes within the County shows that such schemes usually range in size from 4 units to 12 units and require site areas of between 0.1 (1000 sqm) and 0.3ha (3,820 sqm) approximately. These types of schemes work well on infill, corner and end-of row sites in existing residential areas where a good standard of passive surveillance onto existing streets and green spaces can be achieved as well as a good standard of site permeability with on-site pathways linking directly to public footpaths and loop walks in open spaces thus providing safe and direct linkages to local amenities and services. On-site parking and access roads in such schemes are generally limited reducing the space requirement in this regard. 

An examination of Nursing and Retirement Home sites within the County over the last ten years shows a requirement for site areas ranging in size from approximately 0.4ha (4,000 sqm) to 2.0 ha (20,000 sqm). All such sites were large enough to accommodate between 60 to 100 plus bedroom units on average as well as extensive ancillary accommodation and appropriate levels of outdoor amenity space and on-site parking.  This type of development is generally not suited to corner/end-of-row sites in existing residential areas due to their overall space requirement, the extent and massing of the buildings required, and the volume of traffic movement generated by staff and visitors to such a facility.  These types of facilities usually require a direct access arrangement from the main road network. In addition, these type of facilities are generally enclosed for health and safety reasons and would not be conducive to through access or integration with the existing layout in the way that small housing schemes can be.

It should be noted that from a broad based analysis in the wider Dublin Region new purpose-built Nursing Home/Retirement Homes generally appear to provide for c. 100 bedrooms or greater resulting in a significant land area requirement.  The number of residents also equates to a maximum level of parking.  The Draft Plan stipulates a maximum of 1 space per 4 residents in Zone 1 (general rate within the County) and 1 space per 8 residents in Zone 2 (within town and village centres, within 800 metres of a train or Luas station and within 400 metres of a high quality bus service).  

Therefore, having regard to the above, it is considered that ‘Nursing Home’ and ‘Retirement Home’ land uses, by reason of their space requirement for larger-sized sites, usually located directly off the main road network, that can accommodate the necessary level of bedroom and ancillary accommodation, on-site services, amenities and car parking required to meet the standards in place, would be contrary to the overarching objective on ‘OS’ zoned lands which is to  ‘To preserve and provide for open space and recreational amenities’ and the aim of H3 Objective 4. 

In conclusion, it is recommended that this motion is not adopted and that the ‘OS’ zoning matrix retains ‘Housing for Older People’ and ‘Residential’ as use classes within the Open for Consideration category with the associated footnote ‘Only where this accords with H3 Objective 4’.  Furthermore, it is recommended that ‘Nursing Home’ and ‘Retirement Home’ remain as ‘Not Permitted’ in the ‘OS’ zoning matrix. 

CE Recommendation: It is recommended that this motion is not adopted and that the ‘OS’ zoning matrix retains ‘Housing for Older People’ and ‘Residential’ as use classes within the Open for Consideration category with the associated footnote ‘Only where this accords with H3 Objective 4’.  Furthermore, it is recommended that ‘Nursing Home’ and ‘Retirement Home’ remain as ‘Not Permitted’ in the ‘OS’ zoning matrix.