Bonnington Hotel

2020 Planning Appeal re bed only hotel at Bonnington Hotel site on the Swords Road, Whitehall, Dublin 9.

Planning Appeal Statement Written grounds of appeal submitted to An Bord Pleanala to accompany planning appeal on behalf of Liffeyfield Limited for a room only hotel development at Swords Road, Whitehall, Dublin 9.

Manahan Planners 38 Dawson Street, Dublin 2 6/6/2020

Introduction This Planning Statement has been prepared in connection with a planning appeal by Liffeyfield Limited for the development of a new building for use as a room only hotel located to the front of the Bonnington 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.

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.

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 Manahan Planners

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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

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.

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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.

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.

Figure 5: Image of 3D 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.

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Figure 6: proposal steps up towards interior of the site.

Planning Authority Assessment The Planning Officers report assessed the proposal and extracts from the report are shown below in italics.

The report firstly addresses the Pre -Planning Consultation.

“PAC0332/19, meeting held 11 June 2019. The proposal presented differed from the submitted application. That proposal was for the partial demolition of the existing hotel (including the existing original much over-built house) and construction of a hotel extension internally connected to the existing hotel, which it was proposed to refurbish and reclad.”

The tone and content here and elsewhere is that it is considered a negative factor that the lodged proposal differed from that presented in the Pre Planning submission. In reality, the submission proposed demolishing the period house on the site so as to create a larger bed only hotel. The pre planning response to that demolition was that demolition may cause difficulties and so it was omitted from the proposal. We consider this change to be a positive one.

The planning report notes the following on the issue of “Pre-existing height in low-rise areas”.

‘Where a site has a pre-existing height over that stipulated above, a building of the same number of storeys may be permitted, subject to assessment against the standards set out elsewhere in the development plan and the submission of an urban design statement outlining: • •

•

The context with a site and area analysis which includes an appraisal of the character of the area adjoining the site The design principles which have been applied and how these will be translated to the development in terms of response to local character, layout, density, scale, landscape, visual appearance and impact on amenities, including sunlight Drawings, perspectives and photomontages to demonstrate how the approach has

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been applied.’

This application met those criteria. In relation to policy on tourism promotion, the planning report noted the following provisions.

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, apart hotels, tourist hostels, cafes, and restaurants, visitor attractions, including those for children.

Policy CEE13: (iii) To promote and support the development of additional tourism accommodation at appropriate locations throughout the city.

In assessing the proposal the planning Officer stated in respect of Zoning.

“While hotel use is open for consideration in the Z1 zoning, the proposed use must be considered in light of the overall zoning objective, (which is the protection of residential amenity). The hotel use is long-established on the site, pre-dating the surrounding residential developments, and indeed the 1963 Planning Act. Nonetheless, the use has intensified significantly over the decades, and the subject proposal is for an 80% increase in bedrooms”.

While there may be an increase in bedrooms, they are as explained elsewhere of a completely different nature to the existing ones on site. It is not therefore a straight projection increase in numbers when considering impacts.

In relation to the operation and management of the new hotel, the planner said, “There is minimal information given on the future management of the hotel. It is noted that the proposal presented at pre-planning stage was an extension to the existing hotel, with a new single shared reception area accessible directly from the shared basement car parking, and direct connections between the existing and proposed building on all floors. This appears to be a colocated hotel, rather than an extension of the existing. Guests staying in the new hotel would presumably have access to the conference, entertainment, and dining facilities in the existing hotel.

There are concerns about the impacts of late night noise and disturbance, as a result of the intensification of use on the site. Similarly, it would appear that guests of the existing hotel would have no direct access from the basement parking to their hotel, with resulting potential for flyparking and set-down conflicts. There are concerns, particularly given the location and zoning, that noise and disturbance has not been designed out. The applicant should be given the opportunity to address these issues.”

This assessment led to a Request for Further Information (RFI) and we address that below.

In relation to the internal quality of the proposal the planner stated, “An examination of the plans indicates that the bedrooms appear to comply with the relevant size standards”.

In relation to height, the planner stated, “The height limit set in the Development Plan for this area is 16 metres. Regarding the height of the proposed building, its maximum height (24.4 metres) is considerably taller than this 16 metre limit.

However, it is in keeping with the height of the existing long established hotel block. The applicant has submitted appropriate materials to aid the assessment, and as such it complies with the overall Development Plan policy on height.”

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In relation to visual amenity the planner stated, “Having regard to visual amenity, the proposal would present a more urban appearance to the main road from the airport than the current low rise building and surface car park. The design and materials proposed are acceptable. A Landscape and Visual Impact Assessment Report has been submitted. The proposal would not be visually overbearing on any of the nearby residential properties or public roads”.

The planner added the further assessment, Regarding impacts on daylight and sunlight, the applicant has submitted a Daylight, Sunlight, and Overshadowing study. There would be some impacts on Highfield Hospital – both to the daylight and sunlight received by the south wing, and to the sunlight received by the outdoor amenity space. However, these impacts would be within the acceptable limits as set out in the BRE recommendations. Similarly, there would be some impacts on neighbouring residential buildings (both daylight and sunlight) but again, these would be to a small extent, and are acceptable in a suburban built environment.

Regarding overlooking and impacts on privacy, there would be some concern regarding overlooking of the rear garden of 50 Sevenoaks, which depends heavily on screening from tree foliage to shield it from direct overlooking at a distance of approximately 20 metres. This could potentially be addressed by condition in the event of a grant.”

In relation to reports from other Departments the planner noted, “The file was circulated to the Transportation Planning Division, who had significant concerns regarding a number of issues, including the lack of clarity and certainty regarding the future use and management of the underground car park, the low ratio of parking spaces to hotel rooms and the resultant potential for overspill parking, the loss of coach parking, conflicts regarding set-down areas, and cumulative impacts with other developments and land uses. That Division has requested further information.

The file was circulated to the drainage division of the Engineering Department, who had no objections subject to a number of conditions.”

The planner then concluded, “It would be appropriate to allow the applicant an opportunity to address this by further information.”

Further information was then requested on 6 December 2019.

In reporting on the Information submitted, the planner stated, “The applicant has confirmed that the proposed and existing hotel will be under the one management and ownership, but will be distinctly different hotels.

A revised ground floor plan has been submitted, showing a set of double doors of c. 2.1 metres width providing a link between the two hotels, from the lobby area of the proposed hotel connecting to McGettigan’s Bar in the existing hotel. This doorway is not prominently located, but Manahan Planners

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accessed via a short corridor beside the toilets.

This door was added to the proposal in the RFI in case guests wish to move from one hotel to the other under cover. It is not expected that many will wish to avail of this option as it is contrary to the expected behaviour of guests in the bed only hotel.

“No reference has been made in the response to the potential for late night noise, nuisance, and disturbance, or any mitigation or management measures proposed. Given the layout proposed, the minimal internal integration between the two buildings, and the requirement to go through a bar to go from one building to the other, there is considerable potential for significant additional pedestrian activity on the site, including late night activity, as guests of one hotel access services in the other and return to their rooms.”

This paragraph reveals the thinking of the planning officer which led to the first reason for refusal. It is our submission that this is based on a flawed analysis and insufficient appreciation of the proposed product and how it will operate in this location. We address this more fully below.

The second reason for refusal derives from the following paragraph.

“The further information submitted was circulated to the transport planning division, and their report notes that while the submission clarifies the majority of issues raised, it does not adequately address their concerns. They note that while the site is suitable for a reduced quantum of parking, the limited provision proposed for the increased intensification of development would result in unacceptable overspill parking. They further note that there is unacceptable risk to pedestrians due to the conflict with vehicles, and that a redesign of the entrances and pedestrian routes is required. That division is recommending a refusal.”

In relation to Drainage, the planner stated, “No formal report was received from the Drainage Division. An email dated 03/04/2020 from the Division was received stating that no comments will be made on the basement impact assessment (received by way of further information) and stating satisfaction with conditions as they stand. The conditions recommended in the Drainage Report dated 27/11/2019 should, therefore, be attached in the event of a grant of permission.”

In the light of this analysis, the planner concluded, “While hotel use is open for consideration in the Z1 zoning, this is subject to overall compliance with the zoning objective, which is to protect, provide, and improve residential amenities. The development as proposed would not be well-integrated into the existing hotel use on the site, would create a significant intensification of hotel use, and as a result would be likely to lead to detrimental impacts on neighbouring residential amenity by reason of late night noise and disturbance. Additionally, there are concerns regarding pedestrian safety and overspill car parking, and the transport planning division is recommending a refusal.”

The Planning Authority then proceeded to refuse permission for the following reasons. The essence of each reason is highlighted in bold.

1. The subject site is located in an area with the zoning objective Z1 'Sustainable Residential

Neighbourhoods' with the landuse objective 'to protect, provide and improve residential Manahan Planners

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amenities' under the Dublin City Development Plan 2016 - 2022. Hotel use is open for consideration under the Z1 zoning objective, subject to compliance with the overall zoning objective. The development as proposed, in conjunction with the existing hotel use on site, would result in significant intensification of activity on the site, including late night activity, and by reason of noise and general disturbance would seriously injure neighbouring residential amenity and contravene materially a development objective indicated in the development plan for the zoning of land and would, therefore, be contrary to the proper planning and sustainable development of the area.

2. The subject site is located in an area with the zoning objective Z1 ‘Sustainable Residential

Neighbourhoods’ with the landuse objective 'to protect, provide and improve residential amenities' under the Dublin City Development Plan 2016 – 2022. Hotel use is open for consideration under the Z1 zoning objective, subject to compliance with the overall zoning objective. Having regard to the design and layout of the proposed access arrangements for the site and basement car park, the proposed development would result in potential vehicular and pedestrian conflict at the entrance of the site and the level of intensification of activity proposed would give rise to unacceptable levels of overspill parking on the adjoining access road and surrounding roads in the vicinity. The proposed development would, therefore, seriously injure the amenities of the area and would endanger public safety by reason of traffic hazard and obstruction of road users. The proposed development would, therefore, be contrary to the proper planning and sustainable development of the area.

We shall address those points in turn. The objections of the Planning Authority may be summed up as follows.

1.

The development will create a significant intensification of activity on the site, including late night activity, which would seriously injure neighbouring residential amenity by way of noise and general disturbance.

2. The proposed development would result in a) potential vehicular and pedestrian conflict at the entrance of the site and b) the level of intensification of activity proposed would give rise to unacceptable levels of overspill parking on the adjoining access road and surrounding roads in the vicinity.

Response to First Reason for Refusal As was stated in the documentation submitted with the application, this application is in respect of a bed only hotel which is a different product from the hotel in the center of the site. The potential for noise disturbance is thereby completely different to that of a regular hotel. The point was made by the planning officer in commenting on the further information lodged that the issue in regard to potential noise nuisance was not satisfactorily addressed in the response.

This was because to it was obvious to us and we thought abundantly clear that the potential for noise nuisance as a consequence of this product was virtually zero.

In the first instance the characteristics of this type of hotel are as follows.

• • •

This brand is focused on the transient traveller, it is a limited service brand focusing on quality room accommodation, There is no bar or restaurant, As the location is in close proximity to the airport and City Centre, the vast majority of guests will use taxis or public transport to access the hotel,

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• • • • •

•

The lobby will contain a reception with shared space with a bar and a grab-and-go food stand, The lobby is a compact functional space, There is no restaurant or room service as part of this brand, There are no convention and meeting facilities as part of this brand, only one small board room, thus there will be no meeting delegates at the hotel, As a legacy of the Covid 19 situation, this type of hotel has adapted its check in procedure so guests can check in to the room online without interaction with Hotel employees if necessary.

This hotel will be attractive for a particular type of guest. It is not aimed at a guest which is looking to stay for extended periods on property with multiple functions on offer.

When this application was first lodged there was no physical connection between the two hotels. This was because the two were completely separate entities. There were comments made as to how the odd guest staying in the bed only hotel might wish to go across to the main hotel to available of a particular amenity (e.g. gym facility) and the only way of doing so was through the open air car park which at times would mean braving the rain. In the light of that it was decided to open a door from the reception area of the new hotel into the bar in the existing hotel so that a guest could transfer from the bed only hotel into the main hotel undercover if they wished. We note that some of the objectors have mentioned that there may be noise from guests in the bed only hotel returning through the car park from activity in the hotel and that this might generate noise in the area, particularly late at night. This door obviates the need for that. The door is not very large or very obvious as it is not expected that it would be used very much and there is no intention to advertise its existence.

In relation to noise generally the Planning Authority will be aware of a serious of applications in relation to the use of the conference centre in the hotel for music and dancing and how this is renewed every two years, conditional on acceptable Acoustic Reports being submitted for the approval of the Planning Authority . The last grant of permission (Reg. Ref. 3353/18; ABP-30250718) required Acoustic tests to be carried out regularly over the recent two year period of the permission.

We enclose with this appeal the last four tests carried out which were in October, (two tests) and November 2019 and March 2020. These tests measured the sound at night at the boundaries of the hotel while music and functions were being held in the hotel. The tests showed no adverse results at the boundary of the site with residential dwellings. These tests were submitted to the Acoustic Division in Dublin City Council who accepted the results as complying with the condition. Due to the Covid-19, there have been no functions in the hotel since March 2020 and so no opportunity to produce additional tests subsequently.

The tests do show, however, that the existing full facility hotel, with its bars, restaurants and function room, do not produce a level of noise that will injure neighbouring residential properties. It is submitted that it would be unreasonable to conclude that the addition of a bed only hotel to this site, because of its more subdued nature, could general a level of activity that could seriously injure residential amenity in the area by way of “noise and general disturbance”.

We are also submitting with this appeal, Acoustic tests, for the past 5 years, all of which indicate no excessive noise at night at the boundaries of the hotel with the adjoining residential development.

The dates of these survey/reports, carried out by Decibel Noise Control, are set out below. All Manahan Planners

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show noise at the boundaries during functions at acceptable levels.

18/19 December 2015 from 21.30 to 00.30, 16/17 July 2016 from 20.00 to 01.00, 8/9 October 2016 from 21.00 to 01.30, 7/8 October 2017 from 21.45 to 01.30, 16/17 December 2017 from 21.00 to 01.00, 10/11 March 2018 from 22.00 to 02.00, 31 Aug/1 Sept 2018 from 22.00 to 00.55, A revised methodology was agreed with DCC on 8th July 2019, 5/6 October 2019 from 21.00 to 00.00, 19/20 October 2019 from 21.55 to 02.00, 16/17 November 2019 from 21.00 to 00.15, 10/11 March 2020 from 22.00 to 02.00.

All of these reports are enclosed with this appeal. In addition, we enclose a copy of letters from Dublin City Council attesting that the 4 most recent tests are acceptable and comply with the terms of the permission.

In the light of this factual information, in contrast to unsubstantiated opinion as to future impacts from a less intense use, it is submitted that this first reason for refusal does not stand up to scrutiny.

Response to Second Reason for Refusal In relation to the first half of the 2nd reason for refusal , namely the potential for vehicular and pedestrian conflict at the entrance of the site, we have engaged the services of an independent outside consultant (Bruton Consulting Engineers to do a Road Safety Audit (RSA) on the proposed development. This survey showed that there are no difficulties with or potential for conflict between vehicle and pedestrian movements in the design of this proposal. This report is included with the appeal. NRB Traffic Engineers provide the following commentary on this, noting, “The completed Independent Stage 1/2 Road Safety Audit for the development including Designer's Feedback Form taking account of the items raised in the Audit is enclosed. No significant road safety problems were identified as part of the independent Road Safety Audit.

It is important to note that all responses to address the issues raised in the Audit have been accepted and signed off by the independent Road Safety Audit team and the recommendations have been incorporated into the scheme drawing NRB-ABP-001 enclosed. Additional traffic calming in the form of a raised table is included on the hotels access road as recommended by the Road Safety Audit. Gullies will be provided upstream of the table to prevent ponding. This will also double up as another possible uncontrolled raised pedestrian crossing location.

The updated layout on drawing NRB-ABP-001 shows revised road markings to clarify the priorities and to address any conflicts for vehicles entering/exiting the underground car park and vehicles located in the set down area. This is a low-speed environment and will be reinforced by 20 kph signage. Dropped kerbs and tactile paving will be provided at the disabled access parking spaces

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The site access layout includes a raised table and uncontrolled pedestrian crossing facilities across the mouth of the ramp to allow pedestrians cross to the reception area. This is also a low-speed environment, and there is good inter-visibilty between vehicles and pedestrians, and the access is consistent with any-such junction into an underground or off-street car park.

There is also another pedestrian route to the reception area which avoids the underground car park access, as annotated on drawing NRB-ABP-001, which will be sign-posted to direct pedestrians towards the new Hotel reception allowing pedestrians to avoid the vehicular access if they wish to do so.”

In relation to the RSA, they conclude, “We would highlight that responsible roads design by qualified Engineers is achieved through the application of modern design guidance principles and through the commissioning of follow-on independent Road Safety Audits of said-design.”

In response to the second half of the second reason for refusal namely, the intensification of activity proposed would give rise to unacceptable levels of overspill parking on the adjoining access road this appeal is accompanied by a report from NRB traffic consultants which addresses this issue. They note as follows, “Given the nature and location of the hotel, it is anticipated that many guests will be arriving from, and departing to, the airport. With the location being on a main arterial route, and on a Quality Bus Route into the centre of the city, the majority of guests will arrive via public transport, taxi and Aircoach and will therefore not require any dedicated parking.

Limited on-site car parking is being provided, and we believe that this represents a sustainable and appropriate approach given the availability of alternative modes of travel.

The proposed hotel, which is a 'room-only' hotel, is a different type of offering than the existing Hotel and is expected to generate lower parking demand given its different customer profile and service offering. Many similar hotels in Dublin City operate very successfully and have no on site car parking whatsoever.

The proposed level of car parking is considered consistent with Demand Management and sustainability principles/measures, which are used to control parking & to reduce the attractiveness of the car as a means of travel. In our experience, Hotels of this nature are 'up-front' in clarifying that they do not have any or limited dedicated parking available on site. In these terms, the vast majority, if not all, customers will arrive fully aware of that fact.”

The NRB report concluded, “Given the provision of car parking numbers which are above the surveyed peak demand ratio, the room-only type new hotel proposed, the managed and paid car parking proposed on site and the Mobility Measures included with the application (for both the new and existing hotels and associated uses), the location relative to the Airport and City Centre and the customer profile, we believe that the level of car parking proposed is appropriate and the level of intensification of activity proposed will not give rise to unacceptable levels of overspill parking on the adjoining access road and surrounding roads in the vicinity.”

Again, a close examination of this reason shows that it also does not stand up to scrutiny. It is submitted that the two reasons given are insufficient to validly ground a cogent refusal. In contrast the reasons for granting permission are substantial. They are set out as follows in the pages below.

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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 and this proposal will cater to a different market. It is a market that will increase in need in a post Covid-19 world.

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.

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.

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Figure 9: 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 10: 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 carried out a Traffic and Transport Assessment of the proposed impact from the new development. This Transportation Assessment addressed 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 included a Construction/Traffic Management Plan and Mobility Management Plan. The report was prepared in accordance with the TII’s Traffic & Transportation Assessment Guidelines.

In response to the Decision of the Planning Authority, NRB have prepared a follow up report which addresses the issues raised in the Decision. It is attached to this appeal, as is a Road safety Audit, carried out by a separate practice.

Overshadowing/ Daylight/Sunlight Analysis IES were appointed to undertake an Overshadowing/Daylight/Sunlight Analysis of the proposed development on the existing buildings and its conclusions were accepted by the Planning Authority Flood Risk Assessment JBA Consulting was engaged to carry out a Flood Risk Assessment for a proposed residential development. The assessment was accepted by the Planning Authority.

Basement Impact Assessment (BIA) Report Following the request for Further information, a Basement Impact Assessment (BIA) report was prepared and submitted . The relevant division did not assess its contents. It did not identify any adverse outcomes from the basement proposal within the scheme.

Landscape and Visual Impact Assessment Ă it Urbanism & Landscape architects were appointed to undertake a landscape and visual impact assessment. Their conclusions were accepted by the Planning Authority.

Architects Design Rationale The application was prepared to a design by MOLA Architects. Their design rationale concluded that: Manahan Planners

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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.

The Planning Authority had no objections to the design of the proposed development.

Screening for Appropriate Assessment The proposal was screened for Appropriate Assessment. It concluded, 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.

The two reasons for refusal have been addressed and , in our opinion, have been fully responded to, and overcome, in this statement of appeal 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 An Bord Pleanala grant permission for the development as proposed.

Manahan Planners

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Manahan Planners 17th June 2020

Manahan Planners

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