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.