Below is an observation I submitted on the proposals for the Player Wills site, a large site being developed by property developer Hines. As the plans are so large, it is going directly to An Bord Pleanála, bypassing the Council. You can see the full plans here.
This ties in with a similar submission I made on the adjacent Bailey Gibson site. Comments are welcome to firstname.lastname@example.org
I welcome development on this site. The site is well-connected, close to the inner city, and has been disused or underused for many years.
It features a notable flagship building which would work well for commercial and community use, beside a site with capacity for high-density housing.
Apartment development is appropriate for new sites like this which are close to the city. Particularly in a housing crisis, development on this site is to be welcomed.
I have nine key concerns with the proposal, which require a rethink of the overall plans. They include:
Towers of 19 and 16 storeys would be grossly out of place in the area and would represent an overdevelopment. The agreed Dublin City Council SDRA plan for the area envisaged buildings ranging from 3 – 8 storeys. This proposal sees buildings over twice that height. Given that the area is almost exclusively two-storey, the original SDRA’s plan seems a more appropriate height for the area.
Tower 2 would be over 63m. This would make it the fifth-largest building in Republic of Ireland and the third-largest in Dublin – in area with no precedent for substantial height of this scale.
This tower alone would be overbearing and out of place. The building should be high-density, but this is beyond excessive.
The applicants make much of tiering/staging the height from three storeys on the periphery of the site – however the jump in height is so extreme that it negates any tiering.
Side note, not included in formal observation: I am in favour of dense and high development. While not a great answer to affordability, they can increase supply and can have an aesthetic appeal for core city centres. In particular, I didn’t object to 29-storey plans at Heuston station, as I felt such height could work in that context. Not the case here.
2. Councillors’ agreement
Records of pre-planning meetings with An Bord Pleanála notes that “non-statutory masterplan for the area which has been presented to elected members who are satisfied with its content.”.
This is untrue. Local councillors were presented with the revised masterplan, but certainly did not agree to nor were they satisfied with its content.
As one of the elected councillors, I and others made this point during the SHD’s presentation to the local area committee on 20 January 2021. The board should not be misled on this point.
The development’s proposal of 240 co-living unit should be rejected. This model is incompatible with the city development plan standards and such accommodation has rightly been recently been advised against by government policy.
Co-living was conceived as a niche form of development, but as a model is being overdeveloped in the area. Other co-living developments seeking or with permission in the Dublin 8 area include:
- 113-115 Cork Street
- The Collective on Fumbally Lane
- John Street South
- 72-74, Old Kilmainhan
This, combined with the increase in purpose-built student accommodation, would represent and overconcentration of small-room, lower-standards developments in the area.
In particular, the board should take account of these development’s suitability during future pandemics, as the close quarters of living would make compliance with government public health policy impossible.
4. Social housing
The plans indicate that all social housing units will be located in one block of the development. This would be unhelpful in making an integrated community and would lead to the kind of social segregation which Part V was brought in to combat.
“Pepper potting” units throughout the development would be a more appropriate response. If management costs for the housing provider are too excessive, a compromise of grouping numbers of social units together could be used – but a single social housing block will not be helpful to the long-term social sustainability of the wider development.
5. Traffic impact
In practice, vehicular access to much of the site will enter via the other adjacent site (Bailey Gibson). This envisages car traffic entering via Rehoboth Place/Avenue. The board should consider the impact on that already-narrow residential road.
Put simply that small road will be one of the main entries to both sites – an overburdening of its capacity.
All roads within the development should have fully kerb-segregated cycle lanes and particular care should be given to cycle access at junctions in and out of the development.
6. Construction management plan
This will be a large site. The developer has pledged that car parking for builders will be provided on-site. This should (a) have some form of allocation to ensure there is no spillover into local streets and (b) there should be more clarity on when these parking spaces will be be introduced and when they will be removed – i.e. will there be a point near the end of construction when the spaces are removed but work is ongoing?
Nearby large sites have also seen problems with noise, dust, and out-of-hours work. Any derogations allowing such work should be minimised and notified to residents. Noise and air quality monitors should be logged and publicly available online for all to see.
7. Cycle parking provision
Clear recommendations for cycling provision are part of the 2018 Design Standards for New Apartments, section 4.15.
The section calls for a minimum of one bicycle space per bedroom in a development. This development has 887 beds across PW1 and PW2, with 903 residential bike spaces. However, 95% of these spaces are in the basement of PW2. Care should be given to ensure that quick and easy bike parking access is available, and the board should be satisfied that the applicant is not “dumping” bike spaces in one part of the development leaving the other without provision.
The 2018 design standards also say that short-stay/visitor bike parking should be provided at a ratio of 1 to every two units. There are 732 units (including 240 co-living), which would require 366 visitor bike spaces. The applicants provide for only 110.
8. Green space
The applicant highlights the new green spaces on the site. These are to be welcomed, but the board should take care to examine which green space is provided on DCC land and bear in mind that the adjacent site (Bailey Gibson) made no provision for green space, with over 400 units proposed.
9. Social infrastructure audit
The supporting social infrastructure documentation (p14) for the development claims:
“The proposed development includes a total of 732 no. units. Of these, 160 no. are suitable for families and could generate childcare need. A facility of 275 sq.m is proposed, providing for 49 no. children.”
This is a flawed basis for analysis. Families come in many shapes and sizes. While you may not expect families in the 240 co-living units, in practice they will live in studios, one beds, and all parts of the development.
It is inappropriate to model childcare/infrastructure need only on those units the developer says are suitable for families.