Permission granted for change of use from retail to coffee shop in Rathmines for Butlers Chocolates

2019

Development proposed for Nos. 13-15 Earl Place and Nos.94 & 95 Marlborough St., Dublin 1.

Town Planning Report Planning Report to accompany planning application lodged with Dublin City Council for a proposed hotel development at 13-15 Earl Place and Nos.94 & 95 Marlborough St. to vary the proposal previously approved under Reg. Ref. 3442/16 by providing two additional set back storeys to the approved development.

Manahan Planners 38 Dawson Street, Dublin 2 4/09/2019

Introduction This planning report has been prepared in connection with a planning application by OCES Property Holdings Ltd for a development at Nos.13-15 Earl Place and Nos.94 & 95 Marlborough Street, Dublin 1.

Figure 1: Site location map

The site has an extant planning approval (Reg. Ref. 3442/16) for the redevelopment of a circa 0.64 hectare site centered on the Clerys buildings, 18-27 O’Connell Street Lower, Sackville Place, Earl Place and Earl Street North, Dublin 1. The proposal was for a mixed-use development which included retail, office, restaurants, bars, hotel, refurbishments and public realm upgrades to Earl Place. The planning application, to which this report relates, seeks to vary that approval by adding two set back floors to the approved hotel and to change the elevations to reflect the changes proposed. The two additional floors will add 37 bedrooms to the new hotel to bring the total number of bedrooms to 213.

It is submitted that this alternative development proposal is consistent with planning policy and the land-use zoning in the Development Plan and does not have any negative impacts.

Site Context The subject site of circa 1693 sq.m contained Clerys warehouse building at Nos 13, 14 and 15 Earl Place and extends to Nos. 94 and 95 Marlborough Street which forms part of a larger project known as ‘Project D1’ . Project D1 involves 18-27 O'Connell Street Lower, Sackville Place, Earl Place and Earl Street North (known as the Clerys Building,), Nos 13,14 and 15 Earl Place (Clerys warehouse), Nos 94 and 95 Marlborough Street including Earl Place, from Sackville Place to Earl Street North.

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The Clerys warehouse building is located to the east side of Earl Place and comprises of a part three, part four storey hipped roof brick building. The building historically acted as a warehouse for the Clerys store and is linked to same by a two storey rendered link bridge across Earl Place, which connects to the Clerys Building at first and second floor levels.

Nos 94 and 95 Marlborough Street are four storey buildings which form part of a terrace of similar buildings on the west side of Marlborough Street. They have a rendered finish and are in a poor state of repair and appearance.

Figure 2: Aerial photo of the area with the subject buildings outlined in red

The site is strategically located in Dublin’s City centre and lies c.1km west of the IFSC and Custom House. It is approximately 10km from Dublin Airport. The 3 Arena and prominent tourist attractions are easily reached by the Red and Green Line Luas which has stops located on adjacent to the site on the east of Marlborough Street and Abbey Street.

There are a mix of uses in the surrounding area, including a wide variety of retail and service uses on North Earl Street, O’ Connell Street and Marlborough Street. The planning application site area within the red lines below represents a significantly under-utilised site located in a central inner city location.

It is noted there are protected structures next to Nos 94 and 95 Marlborough Street. The buildings within the site are however not Protected. The site lies within a Conservation Area designation and is zoned Z5 with an objection ‘to consolidate and facilitate the development of the central area, and to identify, reinforce, strengthen and protect its civic design character and dignity’.

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Planning History A planning history search of the subject site was carried out using the Dublin City Council online planning search facility. The search included Nos 13-15 Earl Place and 94-95 Marlborough Street.

Reg. Ref. 3442/16 The site was part of a larger landholding that was the subject of a planning approval (Ref. Ref. 3442/16) in July 2006 ( the parent permission) for the redevelopment at a circa 0.64 hectare site located at 18-27 O'Connell Street Lower, Sackville Place, Earl Place and Earl Street North (known as the Clerys Building, a protected structure), Nos 13,14 and 15 Earl Place (Clerys warehouse), The application site included Earl place, from Sackville Place to Earl Street North, and the existing link bridge between the building at Nos 18-27 O'Connell Street Lower and the building at Nos 13,14 and 15 Earl Place.

The Statutory Notices for the proposed development comprised of the following: Part (i) : the removal, refurbishment, extension and partial change of use of the Clerys Building at 18-27 O'Connell Street Lower, Sackville place, Earl Place (not including the northern element to Earl Street North and Earl Place) to provide a mixed use retail, office, café, restaurant and bar development.

This included the alteration and removal of fabric, the upgrading and renewal of the second and third floor to accommodate a new structure and extension of 2 no. new floors resulting in the overall building having 6- storeys over 2- basement levels with a gross floor space of circa 18,079sq.m comprising of c. 2,000 sq.m retail/café/restaurant at basement (-1), c. 3,478 sq.m retail floor space in 2 no. units both over ground and first floor level, 2 no. café/restaurant/bar units at ground floor and basement (-1) of c. 416 sq.m and 1 no. café/restaurant/bar unit at first floor of c. 317 sq.m, c. 94 sq.m café/restaurant/retail/retail services (Class 2)/ bar use in 2 no. units at ground floor level, a unit of c.

210 sq.m comprising an entrance lobby/foyer area with ancillary bar/café use with access from Earl Place to serve the top floor destination at fifth floor level, c. 5,647 sq.m office floor space, c. 1,733 sq.m top floor destination floor space, plus ancillary basement and back house areas. The proposed development to include a central glazed atrium from ground to fifth floor (sixth storey) level.

The proposed development is to include the restoration and cleaning of retained facades, and the refurbishment and replacement of windows.

The new -2 basement level provides plant and storage areas staff facilities with 160 no. bicycle parking spaces, and other ancillary areas The existing basement -1 level is retail/café/restaurant use (c. 2,00 sq.m gross) with the ground floor level subdivided to create 2 no. retail units of c. 770 and c.

772 sq.m gross.(connected with basement -1 retail/café/restaurant area and first floor retail area) Each level has direct access from O'Connell Street at either side of a central entrance/lobby area, provision of a 2 no. café/restaurant/bar units (total gross floor space of c.416 sq.m) over ground and basement (-1) with access from Earl Place, 2 no. retail/café/restaurant/retail services (Class2)/bar units of c. 94 sq.m with access from Earl Place, access/lobby area for a top floor destination area to include ancillary bar/café use of c. 210 sq.m and office use to be provided on upper floors:(g) at first floor level, subdivision to create 2 no. retail units (of c. 967 sq.m and c. 969 sq.m gross) connected with the retail space at ground level and the retail/café/restaurant use at basement level -1, a

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café/restaurant/bar unit of c. 317 sq.m gross in the retained former Clerys Tearooms to the rear (east) with access from the retained and restored main staircase from ground floor level; (h) change of use of existing second floor from retail to provide c. 2,055 sq.m office floor space; (i) demolition of existing part third floor office level and plant rooms and the creation of new third, fourth and fifth floor levels to comprise c. 3,592 sq.m office floor space at third and fourth levels and a top floor destination area of c. 1,733 sq.m gross at fifth floor level under lightweight ribbed roof structure forming a contemporary glazed roof, to provide café/restaurant/lounge & bar uses, events and conference, performance and display areas, and an accessible external viewing/dining terrace to the west and a terrace to the east. The proposal will include setbacks at fourth floor level (fifth storey) and fifth floor level (sixth storey) to the north, south, east and west elevations, including provision of a terrace to the western, eastern, and parts of the northern and southern elevations at fifth storey (fourth floor); (j) amendments to ground floor elevation to O'Connell Street and Sackville Place including, at O'Connell Street, provision of replacement central entrance doors, creation of 2 no. new doors either side of the main central entrance area, replacement entrance doors to the southern end, and relocated entrance location and new entrance doors to the northern end and at Sackville Place, replacement entrance doors.

Part (ii): The Notice referring to Nos 13, 14 and 15 Earl Place stated, The demolition of the existing Clerys warehouse building at Nos 13,14 and 15 Earl Place and the construction of a 7- storey building of c. 8,337 sq. m gross floor space, including a 176 no. bedroom hotel of c. 7,800 sq.m (including ancillary and back of house areas), a c. 426 sq.m gross café/restaurant/bar unit at ground floor level with access from Earl Place.

It included the restoration, internal and external refurbishment and change of use of Nos 94 and 95 Marlborough Street (both currently vacant) to link to the proposed hotel, to provide 2 no. retail/restaurant/café/ retail service (Class 2) bar units (total gross floor space of c. 111 sq.m).

There are 10 no. bedrooms at first, second and third floors levels that are included in the overall 176 no. bedrooms.

The hotel will include setbacks on the east elevation at second floor level, north elevation at fifth storey level and on the east and west elevations at seventh storey level.

A proposed basement will accommodate 20 no. car parking spaces (for use by the proposed office use), 45 no. bicycle parking spaces, staff facilities, plant and storage areas.

Vehicular access will be via a car lift from Earl Place.

The development includes part demolition and internal and external refurbishment of the existing link bridge between the building at Nos 18-27 O'Connell Street Lower and the building at Nos 13,14 and 15 Earl Place and its incorporation into the hotel use (linked to the first floor of the hotel and first floor of the Clery Building), for use as a double height hotel reception/lobby area to include a terraced seating area on the roof of the link bridge.

Part (iii): The demolition of the northern element (with frontage to Earl Street North and Earl Place) of the Clerys Building and construction of a c. 5,539 sq.m six storey office building, comprising c. 3,327 sq.m gross office floor space and 2 no. café/restaurant uses at basement and ground floor level (total gross floor space of c. 412 sq.m), and 1 no. retail/restaurant use (103 sq.m

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gross), plus ancillary basement areas. The development includes a setback to the north elevation at fifth and sixth storey, including a terrace at fifth storey (fourth floor). The development includes a basement level to provide 60no. bicycle parking spaces, plant areas, storage area, staff changing and locker facilities and a café/restaurant area linked with a ground floor restaurant. At ground floor it is proposed to provide 2 no. café/restaurant units, 1 no. retail/restaurant/café use, an office entrance area from Earl Place, an ESB substation, a service/delivery area ( to also serve the refurbishment and extended Clerys Building), and other ancillary areas.

Part (iv): The proposed development includes public realm upgrades to Earl Place, all associated and ancillary works, including site infrastructure works, the provision of roof plant on the proposed hotel and office buildings and on a sunken level on the new glazed roof to the Clerys Building, hard and soft landscaping.

The overall proposed development provided a c. 7,800 sq.m gross 176 no. bedroom hotel (excluding ground floor café/restaurant uses and retail/café/restaurant uses), c. 8,974 sq.m office floor space, c.

3,478 sq.m retail floor space in 2 no. units, c. 412 sq.m café/restaurant floor space in 2 no. units, a c.

210 sq.m entrance lobby/foyer for access to the top floor destination area, with ancillary bar/café use, c. 2,103 sq.m retail/restaurant café use in 1 no. unit at basement -1 of the Clerys Building and in 1 no. unit in the northern extension, 1,159 sq.m café/restaurant/bar floor space in 4 no. units, including the unit associated with the hotel, c. 205 sq.m café/restaurant/retail/retail services (Class2)/bar in 4 no. units and c. 1,733 sq.m gross floor space at the top floor destination area fifth floor level of the Clerys Building.

The total gross floorspace of the overall development, including existing and proposed floor space, is c. 31,955 sq.m GFA including the basement areas. The area west of Earl Place was referred to as Blocks A and B while the Clerys warehouse is Block C and Marlborough Street is Block D. See key diagram below.

Figure 3: Previous permitted scheme outlined in blue with new proposal in red

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Proposed Hotel Development The approved development includes therefore the construction of a 7- storey 176 no. bedroom hotel of 8,337 sq.m gross floorspace, including a 426 sq.m gross café/restaurant/bar unit at ground floor level with access from Earl Place.

The approved development includes the restoration, internal and external refurbishment and change of use of Nos 94 and 95 Marlborough Street to link to the proposed hotel, to provide 2 no. retail/restaurant/café/retail service (Class 2)/bar units (total gross floorspace of 111 sq.m) and a reception area at ground floor level, and 10 no. bedrooms at first, second and third floor levels (included in the overall 176 no. bedrooms).

The permitted scheme will remove previous unsympathetic work to open up the ground floor level of Nos 94 and 95 to the hotel building behind and to restore the upper floors to active use as bedroom accommodation associated with the proposed hotel. The rear return currently has a haphazard expression and is in a state of disrepair. These works are deliberately contemporary and legible and do not affect original fabric. These works are intended to provide an increase in natural light levels, to give a better connection to the hotel, and to give a more ordered and coherent expression to the rear facade. We see these works as having a positive impact on the character of the protected structure.

The proposed hotel will provide greater passive surveillance on Earl Place where the foyer within the bridge link provides a vista up and down the street. A restaurant/café/bar at street level animates and activates Earl Place. The double height reception space and glazed link above break the massing into two elements in order to enhance the scale and grain of the reactivated street. An external terrace celebrates the views from the set-back top floor.

Internally the building is designed around the idea of “community”. The ground floor is given over to social and communal facilities and all bedrooms on the upper floors overlook one of two internal courtyards. Internal finishes adopt a palette of robust materials including concrete, terrazzo and timber, selected for the atmosphere they will lend to the interior. The plan organisation and atmosphere of the building provides a quiet backdrop to the daily lives of the guests using it.

The rear courtyard links the new hotel to Nos 94 and 95 where additional bedrooms are located on the upper floors above 2no. Retail/ café/restaurant/retail services (Class 2)/bar units providing access to Marlborough Street.

The new building successfully negotiates the relationship between new and old, referencing the historic and the contemporary. This is evident in the brick façade which is sensitive to its context and visually striking. The Roman format bricks create a horizontal emphasis across the façade and reflect the sturdy masonry characteristic of the area, whilst the handmade nature of the surface is expressed with sills and soffits and hand setting all the brickwork with the exception of the pre-cats soffits.

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Application Background The Applicant has gone on site on foot of Planning Permission Reg. Ref. 3442/16 and has begun works. Significant effort and expense is being expended to ensure the refurbishment of the Protected Structure and the delivery of the scheme. In addition, No.94 & 95 are being restored back to their original condition. Clearly, the costs associated with the refurbishment of derelict heritage buildings can be considerable.

The Design Team have identified that it would be possible to put an additional two floors on the new build area to bring the proposal to 9 floors, and do so in a manner that would ensure there would be no significant alteration in the external appearance of the proposal over and above that which has been approved. This has been achieved following a design study and massing assessment which informed the new design. The two extra floors change the bedroom number from 176 bedrooms to 213 bedrooms. This will improve the ratio of bedrooms to ancillary support areas, thereby making the hotel more viable and sustainable. Moreover a Visual Impact assessment and overshadowing study confirms there will be no adverse impacts as a consequence of this change.

In view of this we are now lodging a new application to add two additional set back floors containing 37 additional bedrooms on this site. There will be no change to proposed upgrade of 94 and 95 shown below.

Figure 4: Aerial Image of Nos.94 & 95 Marlborough Street currently in poor condition.

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The Proposal The proposal is set out in the accompanying drawings and documents and supporting reports. The Statutory Notice states the following: Dublin City Council – Planning permission is sought by OCES Property Holdings Ltd for development at 13-15 Earl Place and 94 & 95 Marlborough Street, Dublin 1. A proposal was previously approved (Reg.Ref. 3442/16) for the redevelopment of a circa 0.64 hectare site centered on the Clerys buildings, 18-27 O’Connell Street Lower, Sackville Place, Earl Place and Earl Street North, Dublin 1. This proposal was for a mixed-use development including retail, office, restaurants, bars, hotel, refurbishments and public realm upgrades to Earl Place.

Within that application, a hotel was approved which involved a) the demolition of 13-15 Earl Place (the former Clerys warehouse building) and the construction of a setback 7-storey building (23.21m in height), 176 bedroom hotel with a Gross Floor Area of 8337m2 to include ancillary café/restaurant/bar uses and ancillary facilities and b) the retention and refurbishment of 94 and 95 Marlborough Street for use as part of the hotel.

Permission is now sought to make changes to the approved hotel building at Earl Place. The changes are a) change the ground and first floor facade articulation; b) Remove 4 bedrooms from the ground floor and increase the restaurant size; c) eliminate the pedestrian connection from hotel to main development at 1st floor level; d) provide an additional bay to levels 5 and 6 and add two additional set back floors at levels 7 and 8 so as to provide a 9 storey building with 37 additional bedrooms; e) Alterations to all facades including change of brick colour, adding brick expression on the gable ends, and change in articulation of the façade.

The revised hotel building (30.995 m in height) will have 203 bedrooms with a Gross Floor Area of 9350m2 and will be built within the same footprint of the area permitted to be demolished at 13-15 Earl Place and approved previously for hotel. The total floor area has increased by 1664m 2 from the original planning area. There are no changes proposed to 94 and 95 Marlborough Street, which will operate as part of the competed hotel containing 10 bedrooms as previously approved

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Architects Design Rationale A design statement outlining the rationale behind the architectural design, prepared by HJL Architects, is enclosed as a separate document. That statement concludes as follows: This application endeavours to adhere to the revised document for Urban Development and Building Height guidelines 2019 taking into account all Specific Planning Policy Requirements necessary to the proposal, by adding two bedroom floors. Increasing the height of the proposed hotel allows the bedrooms to be removed from the ground floor and expands the F&B offering further activation to Earl Place. The current proposal adds a total of 27 bedrooms to approved scheme increasing the bedroom count to 203, a much more economically viable hotel size.

At the ground floor a 2 storey bronze architrave has been introduced to elevate the presence on Earl Place. The ground floor glazing has been recessed to widen the footpath and to allow the restaurant to spill on Earl Place. The massing of the bedrooms on levels 1-7 has been simplified with a regular bronze anodised punched window rhythm with a brick facade. At levels 8 and 9, the facade is set back in bronze anodised panels to lighten the mass in the skyline. The gable ends of been expressed with two-storey brick recesses to minimise the impact of blank party walls at the CIE and Guiney’s party walls.

Figure 5: CGI of proposed building as viewed from North Earl Street

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Figure 6: CGI showing access to hotel from Earl Place at night.

The architects have taken advantage of the opportunity of applying for two extra floors to alter the architectural treatment somewhat from that originally proposed and approved. It is submitted that the design of the proposed vertical extension, with its glass facade and bronze anodised punched window rhythm will bring an innovative and exciting feature to this area of the city centre. Images of the new building design are shown in the accompanying GGI images included in the application. The new building will be located within an area of the city with narrow streets and a tight urban grain and it is difficult therefore to obtain wide angle views of the proposed building in that context. Equally this context makes it difficult to view the impact of two additional set back floors on the completed building.

It is submitted however that the architectural treatment now proposed for the new building will complement and enhance the public realm upgrades along Earl Place. It should be welcomed on that account.

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Planning Assessment Policy Context The subject site is zoned Z5 with an objective that seeks “To consolidate and facilitate the development of the central area, and to identify, reinforce, strengthen and protect its civic design character and dignity.”

Figure 7: Zoning Map of the area surrounding the subject site

Section 14.8.5 of the plan states that the primary purpose of the Z5 zoning is ‘to sustain life within the centre of the city through intensive mixed use development’ and ‘to provide a dynamic mix of uses, which interact with each other, help create a sense of community and which sustain the vitality of the inner city both by day and night’.

Section 15.10.5 of the City Development Plan includes further guidance on Z5 zoned lands. The following points are of note: 

The primary purpose of this use zone is to sustain life within the centre of the city through intensive mixed-use development.



The strategy is to provide a dynamic mix of uses, which interact with each other, creates a sense of community and which sustains the vitality of the inner city both by day and night.



As a balance and in recognition of the growing residential communities in the city centre, adequate noise reduction measures must be incorporated into development, especially mixeduse development, and regard should be given to the hours of operation.

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

Ideally, this mix of uses should occur both vertically through the floors of the building as well as horizontally along the street frontage. While a general mix of uses e.g. retail, commercial, residential etc. will be desirable throughout the area on the principal shopping streets, retail will be the predominant use at ground floor level.

It is submitted that the proposal is consistent with the Z5 zoning objective in the Dublin City Development Plan 2016-2022.

Section 6.5.3 of the current City Development Plan highlights tourism as one of the key economic pillars for the city. In support of this policy CEE 12 (i) states: ‘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’.

It is submitted that the impact of the additional 213 hotel rooms would be positive. Obviously, it will contribute to reducing the very well publicised hotel room shortage in the city, which is widely reported to be putting a constraint on the tourism industry in Dublin. Further, the additional guests and facilities at ground level will contribute positively to the activation and success of this "new" public street on Earl Street.

It is not proposed to provide parking on site to cater for the expected increase in hotel guests. It is submitted that this is acceptable having regard to the accessibility and location of the proposal in such close proximity to the city centre, and LUAS line into the city centre. Moreover in the case of a hotel, most if not all tourists do not have cars and therefore most guests will arrive by taxi or public transport. Car hire for tourists generally occurs for tourists seeking to travel outside the Dublin area.

Arrangements are in place, however, to provide parking on a contract basis on neighbouring sites for those few guests who arrive by car.

Figure 8: Possible courtyard treatment

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Visual Impact Assessment Kennett Consulting Limited were appointed to conduct a Visual Impact Assessment and report whereby the assessment identifies the visual impact the proposal will have on the immediate vicinity and surrounding landscape. For more detailed information and images, see the report enclosed.

The report states that ‘it is therefore considered that the proposed development will have no greater impact than the consented Clery’s scheme and accords with the landscape objectives of national and local planning policy’.

Figure 9: View from junction at George’s Quay and Tara Street

The report contains a series of images from the wider perspective of adjoining streets which show the proposal development will be screened by intervening buildings. There will therefore be no significant or adverse impact upon the landscape character or visual amenity of these streets as a consequence of the two extra floors proposed.

The report concludes that their appraisal of the site’s context and the anticipated effects of the proposed development demonstrates that the landscape and the visual impacts arising will not be visible in most instances and will have a neutral impact in all instance where views of it occur.

Overshadowing Analysis EIS Consultants were appointed to carry out an Overshadowing Study to quantify the Sunlight / Shadow performance of the revised two extra storey on the Block C development located in off Earl Place. Their report concluded:

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“The results within this report demonstrate that the proposed development performance is almost identical to the performance of the currently permitted scheme”.

Figure 10: computer generated images of permitted and proposed scheme

This report shows that the proposed intensification of the use generated by the addition of two extra storeys at Earl Place will not result in any unreasonable negative impacts and will be positive for the area. See full report included in the application.

The Issue of Additional Height New height Guidelines issued in August 2018 provide guidance on allowable heights at the scale of the relevant town/city. The criteria states that: Proposed developments should make a positive contribution to place-making, incorporating new streets and public spaces, using massing and height to achieve the required densities but with sufficient variety in scale and form to respond to the scale of adjoining developments and create visual interest in the streetscape.

Section 2.3 recognises that ‘while achieving higher density does not automatically and constantly imply taller buildings alone, increased building height is a significant component in making optimal use of the capacity of sites in urban locations where transport, employment, services or retail development can achieve a requisite level of intensity for sustainability.

Furthermore Section 2.5 states ‘while taller buildings will bring much needed additional housing and economic development to well-located urban areas, they can also assist in reinforcing and contributing to a sense of place within a city or town centre, such as indicating the main centres of activity, important street junctions, public spaces and transport interchanges. In this manner,

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increased building height is a key factor in assisting modern place making and improving the overall quality of our urban environments.’

In this case, the permitted hotel under planning application Reg. Ref. 3442/16 has a floor area of 8337 sq.m in total. This proposal will have a building of 9350 sq. m, an increase of approximately 1664 sq. m from that previously approved. In order to achieve this, the height will increase from 23.2 m to 30.995m.

It is submitted that this increase in floor area and height on this site is a reasonable response to such a strategically located site, the emerging development in the area, and the expectation to densify and to make more sustainable use of valuable inner city land. Moreover, it complies with the criteria set out in Section 3.0 of the Urban Development of Building Heights Guidelines, 2018.

Furthermore, it is submitted that the proposed additional two storeys will improve the buildings' contribution to the vitality and vibrancy of the public realm through generating increased footfall in the area. It is further submitted that the proposal will make a more meaningful contribution to the emerging built form character within the area.

Screening for Appropriate Assessment In assessing the zone of influence of this project upon Natura 2000 sites the following factors must be considered:  Potential impacts arising from the project  The location and nature of Natura 2000 sites  Pathways between the development and the Natura 2000 network It has already been determined (and accepted) in the parent permission for this site that the site is not located within or directly adjacent to any Natura 2000 area. The addition of two further set back upper floors will not alter this assessment.

For projects of this nature an initial 2km radius is normally examined (IEA, 1995). This is an arbitrary distance however and impacts can occur at distances greater than this. There are no Natura areas within this radius. The South Dublin Bay and River Tolka Estuary SPA (site code: 4024); the South Dublin Bay SAC (0210) and the Poulaphouca Reservoir SPA (site code: 4063), from which drinking water supply for this development will originate, are all considered to fall within the zone of influence of this project. These are considered to be the only Natura 2000 areas within the zone of influence of the development as pathways do not exist to other areas. The North Dublin Bay SAC and North Bull Island SPA are also in this region although there is no pathway to these areas from the project.

In conclusion, this project has been screened for AA under the appropriate methodology. It has found that significant effects are not likely to arise, either alone or in combination with other plans or projects that will result in significant effects to the integrity of the Natura 2000 network. A full Appropriate Assessment of this project is therefore not required.

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Summary and Conclusion In summary, it is submitted that the proposed addition of two extra storeys will contribute positively to the on-going development of the area and should be welcomed on that account.

The additional bedrooms will make the hotel more viable and sustainable in line the Development Plan policy to support the tourist industry. It will increase the number of bedrooms available to support the communal facilities at ground floor level which in turn will provide the footfall to support the welcome upgrading and improvement of the public realm at Earl Place.

The proposed two extra floors will not have any adverse visual impact on the area. The building is located within an area of narrow streets and therefore the upper set back floors will not be visible to people on the adjoining footpaths.

The reports accompanying this application show that the two extra floors will not be seen from the surrounding streets as the views are blocked by existing buildings. Moreover the increased set back floors will not provide any increase in overshadowing of the adjoining buildings over and above that already approved.

A hotel as proposed will provide a contrasting and welcome amenity which will service the new developments in the vicinity. It is submitted that the architectural design and treatment of the proposal is of high quality by an award winning architectural practice and will add to the stock of high quality architectural buildings in Dublin.

It is submitted that the use and development proposed is consistent with the provisions of the Dublin City Development Plan, and is consistent with the proper planning and sustainable development of the area. The proposal provides positive benefits for the area and has been tested for any negative consequences. None emerged from the analysis undertaken.

Accordingly we request that the Planning Authority grant permission for this welcome and appropriate development.

Manahan Planners 4th September 2019

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