status of local area plans v1-6, housing objective cpo 6.x, v1-17, transport v1-62, development management v3-126

Uimhir Thagarta Uathúil: 
WW-C3-74
Stádas: 
Submitted
Údar: 
Ballymore group
Comhairliúchán: 
Proposed Amendments to the Draft Wicklow County Development Plan 2022 - 2028
Líon na ndoiciméad faoi cheangal: 
1
Údar: 
Ballymore group

Litir Chumhdaigh

Ballymore Group, Developer of the former Bray Golf Course in Bray.

Tuairimí

Chapter 3: Core Strategy

Caibidil: 
Section 2: Volume 1 » Chapter 3: Core Strategy
Please select the amendment number on which you are commenting.: 
Amendment V1 – 6

This amendment will create huge uncertainly as to the zoning status of zoned land in every LAP area in the County, including Bray.   A large planning application generally takes at least a year to prepare and may take up to another year to work its way through the planning system.  Certainty of the planning policy environment is therefore of critical importance both for an applicant and for the general public. 

Land is only zoned in a Development Plan or Local Area Plan if it is serviced and capable of being developed and if its development is in accordance with the proper planning and sustainable development of the area.  Developers buy zoned land in the expectation that the land continues to be developable for the life of the plan.    

The effect of the proposed amendment will be to massively increase the uncertainly around the planning process.  An applicant (or third party) will have no way of knowing whether the housing target has been hit at the time the application is being assessed and therefore whether the permission will be granted or not. 

Furthermore, its widely understood that the grant of a planning permission does not guarantee that a scheme will be built.  Indeed, the perceived ‘hoarding’ of planning permissions in recent years has been widely criticised and is perceived to be contributing to the housing crisis.  The Croí Cónaithe scheme (cited below) has identified the fact that 70,000 ‘uncommenced planning permissions’ exist in the five cities.  The effect of this proposed amendment will be to exacerbate this problem.  It will increase the risk of planning applications being made simply to ‘bank’ a quota of the housing target for a particular town.

While Ballymore agrees with the concept of compact growth, the idea that a planning application that is otherwise entirely consistent with the proper planning and sustainable development of a town, and will go towards addressing the housing crisis, might be refused planning permission only because it might breach a notional ‘housing target’ is extraordinary and very hard to understand. 

If implemented, it would undermine confidence in the entire planning system.  If there is no intention of implementing it, it should not be included in the Plan.

Chapter 6: Housing

Caibidil: 
Section 2: Volume 1 » Chapter 6: Housing
Please select the amendment number on which you are commenting.: 
Amendment V1 – 16

We welcome proposed Amendment V1-16.  Restrictions on occupancy of a proportion of new homes to residents of Co. Wicklow, which we believe could have been interpreted as being discriminatory.  Its deletion is welcomed. 

Chapter 6: Housing

Caibidil: 
Section 2: Volume 1 » Chapter 6: Housing
Please select the amendment number on which you are commenting.: 
Amendment V1 – 17

Ballymore strongly objects to Proposed Amendment V1-17 Objective CPO 6.X and requests that it is not included in the Development Plan.  This proposed objective is clearly intended to ban all Build to Rent (BTR) developments in the County and thus contradicts Government Policy. 

Specifically, this proposed objective is contrary to the Sustainable Urban Housing; Design Standards for New Apartments (December 2020), ‘Section 28’ Guidelines published by the Minster as recently as December 2020, which strongly promote BTR developments. 

Government policy is to consolidate new residential development within the existing urban footprint and especially in close proximity to high-capacity public transport systems and encourage the development of high-density apartment developments on brownfield sites. 

However, as worded, the proposed objective CPO6.X goes further than prohibiting BTR as it proposes to prohibit the sale of all residential units, whether developed to BTR standards or not, to ‘commercial institutional investment bodies’. 

Ballymore recently acquired the former Bray Golf Club lands in Bray, within 200m of Bray Town Centre and 500m of Bray DART Station.  The site is bounded by the Dun Laoghaire Rathdown (DLR) boundary, with a portion of the site within the DLR administrative area. 

There is a specific local objective in the Bray Municipal District Local Area Plan 2018-2024 for these lands to deliver more than 1,000 dwellings, and Ballymore is fully committed to achieving this target. 

This can only be achieved by developing a significant proportion of these units as apartments.  The proposed objective will prohibit the sale of these apartments (or any other housing typology) to ‘commercial institutional investment bodies’.

However the attractiveness of apartments in Bray to ‘owner occupier’ will also be severely negatively impacted by the Croí Cónaithe scheme, recently announce by the Government, as Bray falls outside the qualifying areas.  Thus, any new apartment scheme on the Bray Golf Course site will be competing with rival schemes in the Dun Laoghaire Rathdown area, which will be eligible for very significant government subsidies.  

Par 1.2 and 1.3 of the Croí Cónaithe scheme clearly acknowledge the construction of apartments for sale to owner occupiers is not currently commercially viable without the scheme.  

One of the key advantages of the sale of an apartment scheme to an institutional investor is that the investor will forward fund the scheme.  This hugely de-risks the entire project for the developer.

If this option isn’t available to a development in Bray, and if Bray is also discriminated against by the Croí Cónaithe scheme, it is very hard to see how any residential development could compete against developments in neighbouring Dun Laoghaire Rathdown. 

 

Appendix 1 - Development and Design Standards

Caibidil: 
Section 2: Volume 3 - Appendices » Appendix 1 - Development and Design Standards
Please select the amendment number on which you are commenting.: 
Amendment V3 – 126

A requirement for own door duplexes to have private open space of 10 sq m per bedroom will effectively kill duplex type development as a typology. 

Typically, the duplex typology has evolved so that the larger own door duplex unit sits over a smaller ground floor own door apartment, with the private open space of the duplex unit being provided at 1st floor level in the form of a terrace.  If the ground floor unit is a 2 bedroom unit with a footprint of say 80 sq m and the duplex unit above is a three bedroom unit with a footprint of say 60 sq m per floor, this only allows 20 sq m as a terrace, restricting the upper unit to a two bedroom unit. 

The duplex typology is an attractive affordable alternative to traditional houses, which has been especially appealing to owner occupiers.  Construction costs are on a par with house construction costs and maintenance costs are minimal.  It’s a useful way of achieving the higher densities nowadays required in housing schemes without having to build apartments, and offers a broader range of options to the house buyer. 

While some homeowners want a garden and therefore continue to opt for houses, not everyone does.  For homeowners who want an ‘own door’ home, but have no interest in a garden, the own door apartment/duplex is an attractive offer.

Faisnéis

Uimhir Thagarta Uathúil: 
WW-C3-74
Stádas: 
Submitted
Dáta a cuireadh isteach: 
25.05.2022 - 16:44
Líon na ndoiciméad faoi cheangal: 
1
Comhairliúchán: 
Proposed Amendments to the Draft Wicklow County Development Plan 2022 - 2028