Bonnington

2019 Development proposal at Bonnington Hotel site on the Swords Road, Whitehall, Dublin 9.

Town Planning Report Planning Report to include a screening for Appropriate Assessment to accompany planning application lodged with Dublin City Council on behalf of Liffeyfield Limited for a room only hotel development.

Manahan Planners 38 Dawson Street, Dublin 2 10/10/2019

Introduction This Planning Report has been prepared in connection with a planning application by Liffeyfield Limited for the development of a new building for use as a room only hotel located to the front of the Bonnington (formerly Regency) Hotel on the Swords Road in Whitehall Dublin 9.

Figure 1: Site Location Map

In summary, the proposal consists of 234 bedrooms spread over 7-storeys over a double basement for car and bicycle parking with the top two floors set back, a cafe and business suite, an external courtyard, and separate waste management facilities.

This report seeks to explain the proposed development and then assess the proposal against the relevant planning criteria.

Site Context The subject site sits3.5km from O’Connell Street and less than 6.5km from Dublin Airport and has frontage onto the N1 Swords Road. Currently, the site consists of a rectangular shaped singlestorey structure in use as retail with tarmac surface car parking in front.

Figure 2: Existing structure and surface car park

The subject site has an area of approximately 13,703 sq.m.

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The site is bounded to the north by the Highfield Hospital. Seven Oaks housing estate bounds the site to the south and Griffith Downs housing estate bounds the south-eastern section of the site. Bonnington Hotel bounds the site to the east. Both Seven Oaks and Gracepark Manor share the same access route from the Swords Road as the subject site. Griffith Downs is accessed directly from the Swords Road at a separate location (to the south). The surrounding heights range from single-storey to 6-storeys.

Figure 3: Aerial view of site with right of way and boundary outlined

The surrounding area is largely characterised by a suburban mix form of development with principally residential and commercial uses. The predominant residential style is two-storey red brick houses with front and rear gardens and off-street parking.

Due to the site’s location beside a Quality Bus corridor, it is well served by public transport in the form of a bus service. The N1 serves as a principal arterial route into the city centre and Drumcondra train station especially from trip generators such as the airport and Swords.

The subject site is designated Objective Z1 in the Dublin City Council Development Plan 2016-2022 which seeks to "to protect, provide and improve residential amenities.�

Figure 4: Extract from Dublin City Development Plan 2010-2016 Zoning Map B with site marked with red star

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Hotel use is considered an Open for consideration Use under the Z1 zoning. The site has been used for a hotel with ancillary uses (health club, conferences, functions) for many decades.

One of the key objectives behind this zoning is to maintain Sustainable Residential Neighbourhoods in close proximity of other complementary uses in particular along public transport corridors.

Planning History A planning application was lodged in 1999 and approved by both Dublin City Council (Reg. Ref. 2328/99) and An Bord Pleanála in 2000. This application proposed to build a significant extension to the East of the existing hotel. The upper floors were for bedrooms and the ground floor level to provide conference rooms, meeting rooms and other facilities.

An application for a 4-8 storey apartment development, containing 69 apartments and 100 car parking spaces, was previously granted permission (Reg. Ref. 2009/08) in this front part of the site. The permission expired in 2013. The Permission was not extended as the height approved was greater than that permitted in the then current Development Plan.

Permission was granted by Dublin City Council (2719/11) for the change of use of conference rooms to venue where music and dancing is permitted in addition to use as conference rooms.

This amended Condition no.2 of previously granted permission (Reg. Ref 4083/06). This condition restricted the use of the conference rooms as a venue "where music is played or as dancehalls or discotheques, except with a prior grant of permission".

Permission was then sought to change the allowed use of the conference rooms to a venue where music and dancing is permitted in addition to their continued use as conference rooms.

Permission was sought (Reg. Ref. 3179/12) in 2012 to “square off” the conference/function room by building a single storey extension of 127 sq. m. The extension would be situated over the adjoining podium. The Planning Authority issued a Decision to grant Permission and this Decision was upheld on appeal to An Bord Pleanála.

Retention permission was sought (2037/18) in August 2018 involving the creation of a new entrance and its exterior treatment to a recently upgraded lounge bar area within part of the hotel. Dublin City Council granted Retention Permission on the 19th September 2018.

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Pre Planning Consultation A Pre Planning Consultation meeting was held with the Planning Authority in which the details of the proposal were set out. Initially, it was purposed to extend the new building further toward the existing hotel which would have involved the demolition of the later additions to the original building. The Planning Officer suggested that this aspect of the proposal should be looked at closely and following consultations within the design team, it was decided to not extend the new building into the curtilage of the existing hotel.

In relation to the other aspects of the proposal, the Planning Officers responded as follows:  A hotel was a use permitted under the current zoning and was the established use of this site.  Any new building should present an attractive elevation to the adjoining Swords road.  The ground floor adjoining the footpath should not contain bedrooms but rather present an active frontage to the street. Attention should be given as to how the new building relates to the public footpath.  In terms of height the building should “step up” into the interior of the site.  A visual impact report should be included which should assess the new building in its context.  The potential for overlooking of the houses to the south and lands to the north of the site was to be assessed.  Traffic flows, servicing, parking within the site and in the underground car park are to be examined.  It was requested that the circulation area to the front of the existing hotel be considered for improvements in the context of this development.

The Proposal The Statutory Notices lodged with the application states the proposal involves the following.

Dublin City Council - Planning permission is sought by Liffeyfield Limited to carry out a development involving the demolition of an existing single storey building, (565 sq.m) in use as a retail unit, to the front of the Bonnington (formerly Regency) Hotel and the construction of a 5, 6 and 7 storey building as a separate room only hotel at the Bonnington Hotel site on Swords Road, Whitehall, Dublin 9.

The new building (with a total floor area of 8,768sq.m) will be used as a room-only hotel containing a reception area, coffee shop (350sq.m) and work space (78sq.m.) for guests and an ESB substation at ground floor, a total of 234 guest bedrooms on the upper floors and a double basement with 142 car parking spaces and 76 bicycle spaces for use by the hotel.

The proposed development will also contain services and all other ancillary works to service the hotel and will involve the reconfiguration of the existing car parking and landscaping to the existing hotel.

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Figure 5: Image of ÂŁD model of proposed development

The development consists of the addition of a new 234 bedrooms supported by the provision of basement car parking containing 201 car parking spaces and 76 bicycle spaces. The proposal involves the demolition of the existing single storey retail buildings fronting the Swords Road, a part of the existing hotel, and the construction of the new hotel extension over the basement car park. A dedicated set down and turning area is provided to the front of the Hotel.

Figure 6: proposal steps up towards interior of the site

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Planning Considerations Development Plan Policy As outlined above, the proposed development is located within an area with a zoning designation where Hotel use is Open for Consideration land use as per the current Development Plan.

The Council recognises the importance (CEE12) (i) to promote and facilitate tourism as one of the key economic pillars of the city’s economy and a major generator of employment and to support the provision of necessary significant increase in facilities such as hotels, aparthotels, tourist hostels, cafes, and restaurants, visitor attractions, including those for children. (ii) To promote and enhance Dublin as a world class tourist destination for leisure, culture, business and student visitors (CEE12). (iii)To promote and facilitate the optimum benefits (including the international marketing benefits) to the city of the Convention Centre Dublin, as well as all other major existing and future visitor attractions (CEE12).

In addition to supporting this economic pillar, it is the policy of the Council (iii) to promote and support the development of additional tourism accommodation at appropriate locations throughout the city (CEE13).

Likewise, it is the Policy of Dublin City Council: CEE1: (i) To promote and enhance the role of Dublin as the national economic engine and driver of economic recovery and growth, with the city centre as its core economic generator. (ii) To promote and enhance the city’s competitiveness and to address deficits, to improve the business environment so that existing jobs are supported and employment generated, and to be creative and practical in its responses to current economic challenges and opportunities.

The Impact on Tourism The tourism industry is one of Ireland’s most important sectors for a myriad of reasons. It is Ireland’s largest indigenous industry and is vital for its contribution to the local and national economy and generation of employment while supporting social inclusion and access to the labour market. There are ambitious targets for Dublin to double the number of visitors by 2020 as set out in the report: ‘Destination Dublin – A Collective Strategy for Growth to 2020’, Grow Dublin Taskforce.

However, the lack of hotel rooms in Dublin City Centre has been well documented. Therefore, there is a growing requirement for further investment in the hotel sector within the city to address this deficiency and assist in realising the ambitious targets especially a site within easy access of Dublin airport (6.4km).

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According to Aebhric McGibney, Dublin Chamber’s director of public and international affairs, ‘increasing the supply of hotels should prove helpful in terms of prices. It’s important that there is value in the market to ensure that the city is able to attract a varied mix of visitors’.

Eoghan O’Mara Walsh, CEO of the Irish Tourism Industry Confederation (ITIC) shares the same acumen and asserts that ‘additional hotels will add competition and make prices more attractive for tourists, especially in the wake of Brexit.

Similarly, Michael Lennon, President of the Irish Hotels Federation affirms that ‘tourism is an exceptionally competitive activity. We compete daily for business at both a domestic and international level and maintaining our competitiveness is absolutely vital to sustaining the growth of the industry, which supports jobs in the country’.

Based on the above, the provision of a 234 bed-only hotel and its ancillary uses would be a welcome addition to addressing some of the shortfall while enhancing the standard of accommodation within the city. The hotel will cater for the tourism market and capitalise on the subject site being in close proximity to the Airport and the City’s prime tourist and retail attractions such as Croke Park, Temple Bar and O’Connell Street and Grafton Street.

Further, the hotel proposal will operate both day and night to a variety of customers and is seen as a valuable contribution to harmonise with the surrounding existing uses. The existing Bonnington Hotel provides amenities such as a spa, swimming pool and gym along with a restaurant.

It is submitted that the re-development of this under-utlised land within the city with a view to consolidating and adding vitality to existing area, and ensuring the efficient use of urban lands and should be welcomed by the Planning Authority.

Built Form The existing building on this part of the site is orientated away from the Sword's Road. The main existing hotel building is set-back by more than 60m from the street. The development to the south and north of the site are contained behind high walls. See below.

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The image above shows the existing weak frontage onto Swords Road. All of these factors contribute towards a reduced amenity for pedestrians walking by.

The proposed development provides a building that addresses the street and also serves to provide a sense of enclosure that the surface level car park currently does not provide. This treatment of the western elevation will provide a greater sense of visual interest for pedestrians passing by.

Figure 8: Proposed treatment of road frontage

Building Height The now adopted new height guidelines, The Urban Development and Building Height Guidelines 2018, set a clear direction for developing our cities and towns upwards, rather than ever outwards.

The proposed building is five storeys facing the Swords road with a setback sixth floor and seventh floor. The proposed height is 25.6m with plant level. The sixth storey is set back from the front of the building (by approximately 12.5 m). The height of the sixth storey reaches 24.2 m approximately. This is consistent with the remainder of the hotel buildings on the site.

It is submitted that the height of proposal accords with the current Development Plan and recent policy on building height, in particular Section 3.2 of The Urban Development and Building Height Guidelines 2018.

Figure 9: Existing height topography

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Figure 10: Proposed contiguous elevations illustrating the set back top two floors in line with height of Bonnington Hotel

Parking According to Dublin City Council Parking Map Zones, the site is located within zone 3. Under this designation, hotels are required to provide 1 car parking space per 12 bedrooms or 15 bedrooms.

The site adjoins a Quality Bus Corridor and is on a radial route from the city centre to the airport.

Visual Impact The proposed building presents as a four with a setback fifth storey building to the Swords road, with the top floor set back again from the fifth floor.

By setting the sixth storey back, the uppermost level is visually recessed and subservient to the main body of the building below.

Figure 11: Montage of the proposed development highlight the visually recessed nature of the 6th floor

It is submitted that the architectural design this scheme is proposing is an appropriate response to the subject site.

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Consultant Reports On review of the proposal, the Planners advised to examine particular aspects of the proposal and their impacts on the surrounding environment. It was recommended that a Traffic and Transportation assessment, Construction/Traffic Management Plan, Mobility Management Plan and Overshadowing/ Daylight/Sunlight Analysis be carried out and submitted with the planning application. The following are summaries of these reports. The full list of accompanying reports is set out in the Cover Letter with this application.

Traffic and Transport Assessment NRB Consulting Engineers have carried out a Traffic and Transport Assessment of the proposed impact from the new development. This Transportation Assessment addresses the Traffic & Transportation issues associated with the operation of the hotel, and in particular the impact upon the operation of the Swords Road traffic signal controlled junction. Their report also includes a Construction/Traffic Management Plan and Mobility Management Plan. The report has been prepared in accordance with the TII’s Traffic & Transportation Assessment Guidelines. ‘The existing long established hotel includes a leisure centre to the rear of the site, supported by 286 managed (charged) car parking spaces and 8 coach parking spaces. The site is accessed internally via a simple priority junction, leading to a traffic signal controlled junction with the Swords Road. This Report has considered the combined impact of the subject development and a current proposal to construct and occupy a total of 125 'Build to Rent' Apartments and supporting facilities to the rear of the existing site (an application which is separate from the current application).

A Preliminary Mobility Management Plan is included as Appendix F which addresses the multi modal accessibility of the location and committed future improvements to public transport that will further enhance accessibility. A Preliminary Construction/Traffic Management Plan has also been prepared and is included as Appendix G. The report addresses servicing arrangements, taxi provision and set-down and pick-up, and demonstrates that these operational issues are facilitated within the plans.

The Assessment demonstrates that the combined effect of the of the proposed hotel extension and the proposed apartments to the rear combined has a negligible and unnoticeable impact upon traffic conditions - in fact it is expected the combined developments will result in an improvement in traffic conditions particularly with the removal of the large at grade car park.

The Report confirms that the road network and the current and future alternative transport modes are more than adequate to accommodate the transportation characteristics of the entirety of the proposed development, and that the hotel will operate in a safe and appropriate manner.

Based on our study, we conclude that there are no adverse traffic/transportation capacity, parking or operational issues associated with the opening of the proposed extension to the long established Hotel.’

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Overshadowing/ Daylight/Sunlight Analysis IES were appointed to undertake an Overshadowing/Daylight/Sunlight Analysis of the proposed development on the existing buildings. The following can be concluded based on the preliminary studies undertaken.

‘Shadow Analysis The Shadow analysis shows different shadows being cast from the proposed scheme. The Seven Oaks Residences, located south of the proposed development, experience no overshadowing. As Highfield Private Hospital is located a sufficient distance from the proposed development, there is minimal additional shadowing. The potential impact is quantified via the Daylight Analysis of existing buildings.

Daylight Analysis of Existing Buildings For the Seven Oaks Residential buildings and Highfield Private Hospital, all of the tested points have a VSC of no less than 80% of their original value. Therefore the proposed development exceeds the BRE recommendations.

Sunlight to Existing and Proposed Amenity Spaces As mentioned above under Section 3.3.17 of BRE’s Site Layout Planning for Daylight and Sunlight states that for a space to appear adequately sunlit throughout the year, at least half of the garden or amenity area should receive at least 2 hours of sunlight on the 21st of March.

As they currently exist, the amenity garden spaces of the Seven Oaks Residences do not meet the BRE guidelines. However, the symmetry between the existing and proposed sunlight analysis shows that the proposed building does not reduce the amenity area receiving at least 2 hours of sunlight by more than 20%. Therefore, the proposed development exceeds the BRE recommendations.

On the 21st of March, all of the existing amenity garden spaces at the Highfield Private Hospital would continue to receive at least 2 hours of sunlight on over 50% of their amenity areas, exceeding BRE recommendations’.

Flood Risk Assessment JBA Consulting was engaged to carry out a Flood Risk Assessment for a proposed residential development. The assessment concluded that: ‘From reviewing the available sources of flooding history and the site visit, the site has been shown to be in Flood Zone C with a low risk of flooding. There are no surface water bodies located adjacent to the site that poses a flood risk to the development; therefore the proposed commercial development is a suitable development type for this location.

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No history of flooding was identified at the site or surrounding areas based on review of floodmaps.ie. However, based on FloodResilienCity areas within the site boundary and along the Ballymun Road are at risk of pluvial flooding.

As part of proposed stormwater management measures, a stormwater attenuation tank has been designed for the development. The design is in compliance with the GDSDS standards as required by DCC. Stormwater discharge from the site will be limited to 2.8 l/s/h with the stormwater attenuation system designed to contain a 1 in 100 year rainfall event. The proposed measures are sufficient to manage stormwater onsite and the measures do not increase the risk of flooding to neighbouring properties, the measures will capture runoff and discharge at a Greenfield rate to a public sewer rather than contributing to surface ponding. The proposed FFL will provide a freeboard of c.150mm over the surrounding hardstanding level also provides additional mitigation from pluvial flooding.

Access to the site is located in Flood Zone C, and therefore access/egress can be maintained during a 1% AEP flood event.

The Flood Risk Assessment was undertaken in accordance with 'The Planning System and Flood Risk Management' guidelines and confirm that the development resides in Flood Zone C and is in agreement with the core principles contained within’.

Landscape and Visual Impact Assessment Ă it Urbanism & Landscape architects were appointed to undertake a landscape and visual impact assessment. The following is their conclusion.

The existing site at the Bonnington Hotel is currently consists of the Bonnington Hotel, Mc Gettigans Bar and Lounge. To the rear and east of the hotel development is the Bonnington Hotel Leisure Centre and Spa. A number of extensions were added to the hotel in the mid 20th Century and are visually poor with a dated appearance. To the west, fronting the Swords Road is a complex of buildings consisting primarily of a Centra shop, a car park and some green space. The back of house is accessed via a hard surfaced area to the north�west of the site.

The overall visual quality of the area to the west is visually degraded with poor quality architecture and a low quality landscape which is visually and physically degraded. The access road to the south of the site is visually poor in terms of landscape quality with an ad hoc arrangement of on road parking and poorly laid out pedestrian access.

Some medium to high quality elements are present in the older architectural facades of the original house that is now the main access to the hotel and Mc Gettigans Bar from the south of the site. High visual and landscape quality is present in the mature tree plantings surrounding the site on its boundaries, much of which is on lands adjacent to the site but offer a quality landscape setting and visual enclosure to the site as a whole. As such, the existing hotel which is substantially set back from the Swords Road is not visible as one travels north and south; views to the hotel become apparent when one approaches the immediate access road to the hotel. The Centra complex and car park are visually dominant on approach to the site.

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The proposed development, as discussed in this report, consist of the development of a 5, 6 and 7 storey 234 bedroom hotel development with business suite, reception area, hotel set down and double basement car parking. A suite of hard and soft landscape interventions offer a high quality landscape setting; the creation of a central courtyard space and cafĂŠ terrace to the Swords Road with public realm streetscape improvements.

In assessment the overall landscape and visual impact of the proposed development a number of verified views were assessed from points within the local area as representative views where there is a potential for impact on local key receptors. Views no.1 and no.2 depict the locals where the proposed development will be most visible given the open views into views into the site from the area immediately adjacent to the west of the hotel. Is has been assessed that the combination of the high quality architectural built form in conjunction with a high quality public realm strategy to not only address the changes in level but also to address the quality of the streetscape will have a moderate and positive impact on the visual and landscape quality of the site. The views from locations adjacent to the site from within local residential areas (views no. 3�6) will be slight to imperceptible and neutral, due to distance, the intervening built environment and existing tree planting screening the proposals from view.

View no 7 shows the upper floors of the proposed development over the canopy of the street trees on the Swords Road. This may be considered a moderate negative visual impact in that the existing view of the skyline is broken from this viewpoint. However, the presence of the hotel will over time be accepted as part of the view from this location. The future growth of the street trees will also further mitigate the potential visual impact of views to the upper levels of the proposed hotel as they grow. The final view 8 is depicted as a red line in the background of view. The proposed development will not be visible from this viewpoint.

Architects Design Rationale MOLA Architects conclude that: This proposal will enhance and enrich the local community and streetscape. By developing this under-utilised site and replacing the out-dated single storey Centra supermarket and car park with a high quality design, a new significant landmark is created on this primary route into the city.

The proposed hotel with a new cafĂŠ and landscaping on the ground level addresses and activates the Swords Road frontage and generates a positive impression with an appropriate public face to the hotel. The introduction of a double basement carpark and hotel drop off point also provides a clear traffic management solution for the area.

The palette of materials is to be of a high visual quality with attractive and durable materials.

The design for the site was amended and changed in response to the issues raised at our Preplanning Meeting with Dublin City Council. The issues were addressed and the studies requested, such as a Daylight, Sunlight and Overshadowing Study, were commissioned. These studies demonstrate that there should be no adverse impact on the surrounding area.

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Screening for Appropriate Assessment Planning applications are now required to undertake a “screening” as to whether the project proposed could have significant effects on a Natura site, such that a Natura Impact Study (NIS) is required to be lodged with the application. This section addresses this issue.

The Appropriate Assessment screening was undertaken in accordance with the European Commission Methodological Guidance on the provision of Article 6 (3) and 6(4) of the Habitats Directive 92/43/EEC (EC, 2001), Article 42 of the 2011 Habitats Regulations and the European Commission Guidance ‘ Managing NATURA 2000 Sites’, in relation to the 2009 publication from the Department of Environment, Heritage and Local Government; Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities’ and the European Communities (Birds and Natural Habitat) Regulations 2011.

Having regard to nature of the proposed development, the location of the application site in an established mixed-use urban area, the normal measures to be taken during construction to ensure proper management of waste on site, and the location relative to the nearest European site, it is submitted that no Appropriate Assessment issues arise. It is our opinion that the proposed development would likely not have a significant effect individually or in combination with other plans and projects, on a European site. Previous developments on this site were screened for potential impacts and it was considered that no adverse impacts might occur. In view of this there is no need therefore to proceed to carry out a Natura Impact Assessment.

Conclusion In conclusion, it is submitted that the proposal is an appropriate development response to this established hotel site. The application has addressed all of the issues which the Planning Authority requested be addressed. These studies did not identify any adverse impacts. The proposal will ensure sustainable development occurs adjacent and close to public transport corridors in order to maximise the use of public transport, to minimise trip generation and distribution and to promote sustainable development.

It is submitted the proposal is consistent with the proper planning and sustainable development of the area, and is consistent with the provisions of the city development plan. Accordingly we request that the planning authority grant permission for the development as proposed.

Manahan Planners 14th October 2019

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