MOTION: Councillor L. de Courcy
That this council agree the dph of the Ninth Lock, Mill Centre site be restricted to a maximum of 150, but ideally 40-80 dbh as per the government's guidelines: "'City - Suburban/Urban Extension Suburban areas are the lower density car-orientated residential suburbs constructed at the edge of cities in the latter half of the 20th and early 21st century, while urban extension refers to the greenfield lands at the edge of the existing built up footprint that are zoned for residential or mixed-use (including residential) development. It is a policy and objective of these Guidelines that residential densities in the range 40 dph to 80 dph (net) shall generally be applied at suburban and urban extension locations in Dublin and Cork, and that densities of up to 150 dph (net) shall be open for consideration at 'accessible' suburban / urban extension locations (as defined in Table 3.8).'" https://assets.gov.ie/static/documents/2cd4f729-sustainable-residential-development-and-compact-settlements-guidelines-for-pl.pdf The current proposed maximum limit of dph 250 is excessive and unsuitable for a heritage suburban village like Clondalkin.
CE Report:
The proposed motion requests that the council agree that the Ninth Lock site be restricted to a maximum of 150 dwellings per hectare (dph), but ideally 40-80 dph as per the government's guidelines: ‘City - Suburban/Urban Extension’. It is put forward that the current proposed maximum density for the Ninth Lock Site of 250 dwellings per hectare (dph) is excessive and unsuitable for a heritage suburban village.
The Sustainable Residential and Compact Settlement Guidelines (the Compact Guidelines) were issued by the Department of Housing, Local Government and Heritage in January 2024. They replaced the Residential Density Guidelines 1999 and the Sustainable Residential Development in Urban Areas Guidelines 2009. The Compact Guidelines set out settlements, area types and corresponding density ranges. Clondalkin is within the Dublin City Metropolitan Area, and within a settlement area defined as Dublin City and Suburbs.
The different categories for the purposes of density are set out in Table 3.1 of the guidelines. For Dublin (and Cork) City and Suburbs they are defined as:
City – Centre (a range of between 100-300 dwellings per hectare)
City – Urban Neighbourhoods (a range from 50-250 dwellings per hectare)
City – Suburban/Urban Extension (a range of 40-80 with up to 150 dwellings per hectare at ‘accessible’ locations).
The criteria set out in the guidelines for designation of lands as City – Urban Neighbourhoods is as follows; (i) the compact medium density residential neighbourhoods around the city centre that have evolved overtime to include a greater range of land uses, (ii) strategic and sustainable development locations, (iii) town centres designated in a statutory development plan, and (iv) lands around existing or planned high-capacity public transport nodes or interchanges (defined in Table 3.8) – all within the city and suburbs area.
On this basis the LPF correctly identifies that the Ninth Lock site falls into the City – Urban Neighbourhoods definition by virtue of it being a large brownfield site on Town Centre (TC) zoned lands within Dublin City and Suburbs settlement.
Policy and Objective 3.1 of the guidelines states as follows ‘It is a policy and objective of these Guidelines that the recommended residential density ranges set out in Section 3.3 are applied within statutory development plans and in the consideration of individual planning applications, and that these density ranges are refined further at a local level using the criteria set out in Section 3.4 where appropriate.’
The LPF refers to the Sustainable Residential and Compact Settlement Guidelines 2024 in Chapter 6 under the heading Density. Chapter 8 Urban Design Strategy indicates the density range applicable to the Ninth Lock Framework site. Critically, while the density range to be applied is 50-250 dwellings per hectare (net), this is to be subject to refinement as indicated above in the quoted Policy and Objective 3.1 of the guidelines.
It is acknowledged that the density range is wide between 50-250 units per hectare. It would not be appropriate to suggest that this automatically means the maximum end of the range will be applied for the site. In addition to the parameters for development in the LPF, the Compact Guidelines give clear guidance on the refining of the ranges.
The Guidelines provide for a refining of density within the density ranges based on consideration of centrality and accessibly to services and public transport; and considerations of character, amenity and the natural environment (local context). Accessibility is defined within the guidelines based on certain distances to high capacity / high frequency / reasonable frequency public transport services, planned or existing. Figure 6.9 of the LPF provides a map of the accessibility analysis based on current walking distance to public transport. Accessibility can improve as new routes and improved access is delivered or can be delivered within development sites or other areas. However, the degree of accessibility will play an important role in informing the refining of the appropriate density within the site.
The ability to refine at the local level has been provided through the inclusion in the LPF of the Framework for the Ninth Lock site. The Framework sets out clear parameters for development which, alongside the criteria for refining set out in the guidelines, will further inform the refining of the density range for the site. For example, within the many parameters for development under different themes set out in the LPF in Section 8.7 the following seeks to ensure an appropriate transition between the village centre and the framework site:
→ Demonstrate how development has had regard and responded to the design principles, including urban grain, set out in this section for the framework site.
→ Ensure that development along Ninth Lock Road is designed to provide for an attractive approach to the village centre at a scale which facilitates the integration of new development along this road frontage with the village centre.
→ Ensure the provision of appropriately sized and purpose-built community facilities as part of any future development of this site, locating it to facilitate good placemaking along the Ninth Lock Road and the integration of new and existing communities with the village centre. See Chapter 6, CHE9 Objective 1
By having the parameters for development clearly set out in the LPF, and the clear rationale for refining density in the guidelines, the detailed examination of any planning application will be able to apply the refining of the density appropriate to the site or to areas within the site.
However, to make clear that there are different density categories within the wider LPF, it is recommended that Chapter 6 under the heading ‘Density’ should be revised. This is to make clear that while the density applicable to the town centre area of the LPF - the Mill Shopping Centre, the Ninth Lock Framework site and the area to the east of the Ninth Lock Road around Oakfield industrial area - is correctly identified as City – Urban Neighbourhood with a density range of 50 – 250 dph, the other areas of the LPF including the village centre and the zoned residential areas are all within the category of 'City - Suburban/Urban Extension with a density range of 40-80 dwellings per hectare with potential to rise to 150 dwellings per hectare in accessible locations as defined within the guidelines.
It is considered that the LPF has correctly identified the density range for the Ninth Lock Framework site, noting that it is subject to being refined to meet the context of the site as outlined above. However, as indicated above, Chapter 6 under the heading ‘Density’ should be revised to reflect the different density categories within the wider LPF.
CE Recommendation:
To amend the text in Chapter 6, section 6.3 under the heading Density as follows and shown in bold:
From
The Sustainable Residential and Compact Settlement Guidelines 2024 set out different density ranges for defined areas. The range applicable to Clondalkin is described as ‘City – Urban Neighbourhood’ within which the density range to be generally applied is 50 to 250 dwellings per hectare (net), subject to context and to some exceptions as set out in criteria in the guidelines
To
The Sustainable Residential and Compact Settlement Guidelines 2024 set out different density ranges for defined areas. The range applicable to Clondalkin zoned town centre area is described as ‘City – Urban Neighbourhood’ within which the density range to be generally applied is 50 to 250 dwellings per hectare (net), subject to context and to some exceptions as set out in criteria in the guidelines. All of the remaining areas within the LPF fall within the guidelines 'City - Suburban/Urban Extension’ with a density range of 40-80 dwellings per hectare (net) with densities up to 150 dph open for consideration in accessible locations as defined within the guideline
Advisory Note: Initial Screening for SEA for the Motion
This proposal would not provide the most evidence-based framework for development and has the potential to undermine sustainable development and proper planning - with potential for associated unnecessary adverse environmental effects on various environmental components. Taking this into account, SEA would be likely to be advised as being required.
Initial Screening for AA for the Motion
No AA issues; Stage 2 AA not required.