Submission to An Bord Pleanála on Hendron's Co-Living Proposal
Below is the text of my letter to An Bord Pleanála setting out my reasons for opposing a proposed co-living development on 36-40 Dominick Street Upper (the "Hendron's Site", SHD0027-20)
To whom this may concern,
The site in question is badly in need of development, and as such I welcome that a proposal has been put forward for the site. In determining the appropriate future use for the site it is critically important to understand the unique positioning of the building, its previous use, its protected structure status and its location in the wider community.
I have considered, in detail, the planning application and the shared accommodation demand report and based on that consideration, I urge An Bord Pleanála to reject this application.
The reason is fourfold.
1) The shared accommodation proposal does not meet the (few) standards set out for shared accommodation under the State’s Housing Design Standards.
Sustainable Urban Housing Design Standards for New Apartments (March 2018) set out that shared accommodation is appropriate where responding to an identified housing need. The guidelines further specify that need is for “new employees arriving in urban areas and seeking short term accommodation.”
Instead, justification for this planning application is predicated on a shortage of affordable housing supply in the area in question where workers are “struggling with the conventional rental market” (shared accommodation demand report). In the main, this “struggle” is described as one relating to price as opposed to duration of tenancy. This directly conflicts with Section 5.18 of the Sustainable Urban Housing Design Standards for New Apartments (March 2018) which sets out that shared accommodation is “...only appropriate where responding to an identified urban housing need at particular locations.” The guidelines are “not envisaged as an alternative or replacement to the more conventional apartment.”
As currently set out, this planning application envisages the Hendron’s site as an alternative to conventional apartment housing. Furthermore, it will not meet the identified housing need of the area for long term secure and affordable tenancies. As of the start of 2020, some 3,000 persons were on the Dublin City Council waiting lists in the north inner city, the majority of whom are single adults seeking one bed accommodation. In addition, the average rental price of a one-bedroom apartment in Dublin 7, as of Q3 2020, of €1634, was 60% of post-tax income of a worker on average earnings in this country. There is a serious housing affordability problem in the area, but one which shared accommodation as a temporary type of accommodation will not resolve.
2) There is no convincing evidence to suggest the building and adjacent new buildings should be for “shared living” accommodation.
I believe many in the community wish to see the Hendron’s site developed for housing and other uses but there is little evidence to warrant its use as shared accommodation other than the higher return per square meter for the developer. It is vital that An Bord Pleanála interrogate the evidence presented because in many instances, it appears manufactured to suit the argument, it conforms to no acceptable standard of referencing or sourcing and it is flimsy in linking trend to demand.
A lack of choice is frequently confused for taste and the authors do not appear to have any understanding of cause and effect. The applicant’s claim that an increase in rental demand “is driven by changing consumer preferences and a movement away from a traditional desire to own property” is a disingenuous interpretation of the affordability issues that currently surround home ownership (Shared accommodation demand report).
Furthermore, no attempt is made to consider the impact of a changing world of work in a post-pandemic world on future housing demand and work patterns and locations. The only reference to Covid-19 is in the reference to the proposed operator’s management plan. It beggars belief to imagine that the world will go back to “normal” once the pandemic is over and that there will no be structural changes to the world of work and the size of the international workforce in Dublin, with all the implications that go with that relating to housing demand.
3) The profile of residential accommodation proposed is at odds with what is needed in the community.
Unfortunately, the application undertakes no consideration of the needs of the local community. The shared accommodation demand report claims that co-living can meet the increase in “demand for active communities and neighbourly interaction.” Any serious analysis of strong and vibrant communities suggests many households anchored in their community either as long-term renters or owner occupiers. The co-living model is the very antithesis of sustainable communities and poses a threat to what are already fragile communities in the north west inner city.
Worse from the perspective of the residents, co-living developments are not covered under existing standard tenancy protections and thus stand to undermine tenants’ rights and set a worrying precedent for future trends in the area.
The site occupies a unique and important location opposite a site of much activity in recent years with the development of the Luas stop and the opening of the new plaza which will open up
Grangegorman to Constitution Hill and its environs. In that context, decisions taken about the future of the Hendron’s site must contain a vision for this unique triangle of activity; Hendron’s, the plaza, and the transport linkage.
Until recently, the Hendron’s site was home to local artistic and community activity and it is located in the middle of a tight knit and vibrant community encompassing the communities of Broadstone, Palmerston Place and the wider Phibsborough, Mountjoy Street and Dominick Street communities. It is in this context that An Bord Pleanála must consider the appropriate future use for the site.
4) The application should be rejected because of the over-concentration of transient planning proposals currently going through the planning system.
This planning application must be assessed alongside existing temporary accommodation provision in the area and planned temporary accommodation planned in the area.
The amount of purpose-built student accommodation both constructed in and planned for the local area, when placed alongside the proposed development, constitutes an over-concentration of housing of a similar kind, which is inimical to the push to create sustainable communities.
Unlike for PBSA applications, no report indicating the number of similar extant or proposed developments within a 1km radius is required for co-living developments. In the case of this planning proposal, it is vital that the proximity of PBSA developments must be looked at.
At present, some 1491 co-living units are currently going through the planning system within 1.6km of the Hendron’s site.
In Winter 2020, Dublin City Council granted permission for the temporary use of up to 1325 student accommodation units as tourist and short term accommodation until May 2021 in the north inner city. These four units are located within just 1.1km of the Hendron’s site.
Given the high level of uncertainty that surrounds the future delivery of higher education and the flow of international students to Dublin, there is strong reason to believe these student accommodation units may have to consider their future product offering.
In conclusion, I have consulted widely with residents’ associations and concerned local parties and I cannot support the proposed development as it stands. The proposed development would contribute to an already highly transient local population. There is also a high level of short-term lettings and accommodation for vulnerable groups situated nearby, and it should be clear that the addition of a stock of co-living units to the area will only intensify this trend. There is a very real concern locally that this development is seen as a severe over-concentration of housing that would alter the social fabric of the local area.
For the reasons laid out above, I exhort the Bord to reject the proposal.
Yours Sincerely,
Senator Marie Sherlock