Fingal Cycling Campaign has made a submission to An Bord Pleanála on the planned development at the Old School house in Clonsilla beside the Royal canal.

INTRODUCTION We are writing to you on behalf of the Fingal Cycling Campaign a subgroup of the Dublin Cycling Campaign which has been advocating for improved cycling infrastructure for Dublin for 28 years and a registered charity #20102029. Dublin Cycling Campaign is a member of Cyclist.ie (www.cyclist.ie), the Irish Cycling Advocacy Network, is the network in Ireland of Cycle Campaign, Bike Festival, and Greenway Groups, and is the Irish member of the European Cyclists’ Federation (www.ecf.com). Our aim is to make Fingal a safe and friendly place for everyone, of all ages, to cycle and walk. Dublin and Fingal Cycling Campaign welcomes the opportunity to comment on Osh Ventures Limited Designs for the Old Schoolhouse development in Clonsilla.

GENERAL COMMENTS Fingal Cycling Campaign welcomes the opportunity to comment on these designs. There are some nice cycling and walking features within the development but are undermined by the proposed road layout and barriers on the cycle paths at either end of the proposed shared cycling and walking facilities along the northern edge of the development. The overall design plan does not meet the objectives of the Kellystown area plan and the proposed Royal Canal Greenway route. The entrance to the development along the Porterstown road is a hazard for the large volume of primary and post-primary school children walking to Scoil Choilm. There are particular concerns relating to the planned road junction designs.

**SPECIFIC COMMENTS **

BICYCLE PARKING We recognise the Osh Ventures Limited have provided the number of bike parking spaces as specified in the Fingal County Development plan cycling parking recommendations and the Sustainable Urban Housing: Design Standards for New Apartments 2018. The bike storage facilities shown in Image 1,taken from document PE18105-CWO-01-ZZ-DR-A-006002- Bicycle Storage Compound, states all 80 bike parking spaces are located beside block A. It is unclear if these are visitor bike parking facilities or residential. If it is visitor parking in one location for a site that spans over approx 2 km long development would not be considered to be efficient or a network of parking facilities, direct or convenient as stated in Fingal development plan, See APPENDIX I. It’s not clear from the site parking plans referenced in the following document PE18105-CWO-ZZ-ZZ-DR-A-002008 Site Plan parking of what type of bicycle stands are being designed for the spaces within the undercroft part of the development that would be used by residents. Bike parking here without proper security -like cages- makes locking bicycles very difficult and prone to theft which is a serious problem in Dublin. These plans contradict the National Cycle manual, Fingal development plan and Sustainable Urban Housing: Design Standards for New Apartments 2018 recommendations for safe and secure bicycle parking within developments.It very difficult to comment on plans when they are not provided in detail or to see if they match the required specifications.
It’s not clear from designs if the two tiered bike racks are gas assisted? This makes these bike racks only suitable for certain types of bicycle. They won’t be compatible for larger heavier Dutch style bicycles, kids bikes or non standard bicycles such as Cargo bikes. Fingal CoCo recently put in place plans for Cargo bike parking in the Kellystown development directly across the canal from this development. Kellystown is planned to be a cycling and walking friendly development. https://www.dublincycling.com/cycling/cargo-bike-facilities-designed-new… Osh Ventures Limited are not in compliance with the Sustainable Urban Housing: Design Standards for New Apartments 2018. On page 25 of the Sustainable Urban Housing: Design Standards for New Apartments 2018 shown below in italics, it refers to planning authorities to ensure that the details of and access to cycle storage facilities at planning application stage. It’s unclear from the design standards in the application what the specific details are throughout the whole development. It also references Dublin Cycling Campaigns bicycle parking guidance document which recommends Sheffield stands. . Planning authorities should ensure that development proposals incorporate details on the provision of and access to cycle storage facilities at the planning application stage by the development proposer. Appropriate conditions in relation to the operation and maintenance of the cycle storage facilities should be attached to any grant of permission for apartment developments. Further information in relation to the design and provision of cycle storage for apartment developments can be found in the National Cycle Manual (National Transport Authority, 2011) and Bike Parking Infrastructure Guidance (Dublin Cycling Campaign, 2017).

Fingal County Council recommended bicycle parking stands as per their development plan called a “Sheffield stand”. Fingal Cycling Campaign recognises the space efficiency of the tiered parking facilities provided by Osh Ventures Limited. Although we also would recommend the use of Sheffield stands. Sheffield stands should be used or at least a mix of these types of stands be provided for both visitors and residents. Sheffield stands are a tried and tested bicycle parking and would be considered to be Gold standard across many cycling countries.
The bicycle parking plans in the development do not meet Fingal County Council’s own development plan 2017-2023 in Chapter 7 movement and Infrastructure “Objective MT13: Promote walking and cycling as efficient, health, and environmentally-friendly modes of transport by securing the development of a network of direct, comfortable, convenient and safe cycle routes and footpaths, particularly in urban areas.” Please see APPENDIX I In image 2 below it states that item number 16 in the index for Block A in document PE18105-CWO-01-ZZ-DR-A-002111- Block A - GA Elevations, Sections. Unfortunately there is no item labelled as 16 in the diagram within this document so we cannot comment on the design of bicycle parking if the image is not provided. This is an omission from Osh Ventures limited.

Please see attached submission for more details

http://www.clonsillashd.ie/

Clonsilla SHD We, Osh Ventures Ltd., intend to apply to An Bord Pleanála for permission for a strategic housing development at Old Schoolhouse Site (former Clonsilla School, Protected Structure RPS No. 700), Porterstown Road, Kellystown, Clonsilla, Dublin 15.

The Strategic Housing Development, which will be accessed from Porterstown Road, will consist of the following:

(i) The construction of a residential development of 198 no. Build to Rent apartment units (120 no. one beds, 59 no. two beds and 19 no. three beds) in 8 no. blocks (ranging in height from four/five to seven storeys in height) as follows:

Block A containing a total of 22 no. apartments (16 no. 1 bed units, 5 no. 2 bed units and 1 no. three bed units) measuring 4 to 5 storeys in height with all apartments provided with private balconies/terraces. Block B containing a total of 21 no. apartments (11 no. 1 bed units, 6 no. 2 bed units and 4 no. three bed units) measuring 5 storeys in height with all apartments provided with private balconies/terraces. Block C containing a total of 27 no. apartments (15 no. 1 bed units, 8 no. 2 bed units and 4 no. three bed units) measuring 6 storeys in height with all apartments provided with private balconies/terraces. Block D containing a total of 31 no. apartments (15 no. 1 bed units, 10 no. 2 bed units and 6 no. three bed units) measuring 7 storeys in height with all apartments provided with private balconies/terraces. Block E containing a total of 37 no. apartments comprising (27 no. 1 bed units and 10 no. 2 bed units) measuring 7 storeys in height with all apartments provided with private balconies/terraces. Block F containing a total of 31 no. apartments comprising (23 no. 1 bed units and 8 no. 2 bed units) being 6 storeys in height with all apartments provided with private balconies/terraces. Block G containing a total of 11 no. apartments comprising (3 no. 1 bed units and 8 no. 2 bed units) measuring 5 to 6 storeys in height with all apartments provided with private balconies/terraces. Block H containing a total of 18 no. apartments comprising (10 no. 1 bed units, 4 no. 2 bed units and 4 no. three bed units) measuring 4 to 5 storeys in height with all apartments provided with private balconies/terraces and (ii) internal/external refurbishment and alterations to the existing 3 storey Protected Structure (Former Clonsilla School - RPS No. 700) to allow for its change of use and conversion to provide a management office with ancillary community use for residents and

(iii) the construction of 1 no. childcare facility located within the ground and first floor levels of Block G.

A total of 100 no. car parking spaces are proposed including 96 no. spaces serving the proposed apartments, (32 no. standard spaces at undercroft level at Blocks B to H, 58 no. standard spaces at surface level at Blocks A, C, D, E, F and G and 6 no. disabled spaces at undercroft level at Blocks B, D and F), 3 no. spaces for the staff of the proposed childcare facility at undercroft level at Block G and 1 car-share space at surface level at the Old Schoolhouse.

A total of 392 no. bicycle parking spaces are proposed, including 312 no. spaces at undercroft levels and 80 no. spaces at surface level.

Planning permission is also sought for landscaping and infrastructural works, foul and surface water drainage, bin storage, ESB substation, open space areas including playground, boundary treatments, internal roads and footpaths (including a Greenway Cycle Path), upgrade to existing access from Porterstown Road and all associated site works to facilitate the development.