I very much support the amendments detailed as follows, particularly the reference to the use of evidence based data in the Dublin City Council Housing Need and Demand Assessment, to ensure a sustainable housing tenure mix that meet the housing needs of the city.
It is recognised that Build to Rent (BTR) serves an important role in meeting housing demand and can fill a gap in tenure mix in established areas of owner-occupier housing. Recent emerging trends however, would indicate that the dominance of BTR in large schemes can be to the detriment of {standard designed apartment} (build to sell) units. Whilst such development has its place in the hierarchy of provision of homes across the city, the Planning Authority will seek to avoid over proliferation of such use in certain areas and encourage such development as part of a healthy mix of tenure in order to create sustainable communities and neighbourhoods.
BTR should be concentrated (in prime inner-city areas and also) in areas of high intensity employment use, (such as within 500 metres walking distance of a high employment area i.e. more than 500 employees per hectare,) within 500m of major public transport interchanges ((e.g. Connolly Station, Tara Street Station and Heuston Station)) and within identified Strategic Development Regeneration(s Zones) {Areas}. Furthermore, applications for BTR schemes should be required to demonstrate {how the development supports housing need, particularly with regard to tenure, unit size and accessibility with particular reference to the Dublin City Council Housing Need and Demand Assessment and} that there is not an over-concentration of Build to Rent Accommodation within an area, including a map showing all such facilities within {a 1km radius}((3km)) of a proposal. Such housing will be controlled in the interest of providing a mix of tenure and unit types. In assessing the matter of overconcentration, the Planning Authority will have regard to factors such as:
• the number and scale of other permitted BTR development in the vicinity {(within a 1km radius)}((3km)) of the site,
• the household tenure and housing type of existing housing stock in the approximate vicinity {(within a 1km radius)}((3km)) of the site,
• and the proximity of the proposal to high capacity urban public transport stops and interchange (such as DART, Luas and BusConnects).
I also support the stated general presumption against large scale residential developments (in excess of 100 units) which comprise of 100% BTR typology. However, I do not think that the requirement for a minimum of (40%) {60%} of standard build to sell apartments within BTR developments will ensure a sustainable mix of tenure and long term sustainable communities as, aside from the size differential allowed relating to BTR, the aim of the BTR is to provide rental opportunities for the first 15 years and therefore I would consider that this laudable size requirement would not necessarily equate with the units built to the standard build being sold to individuals/families but rather they would be rented and probably at a higher rent given their larger size.
Perhaps it would be more beneficial to require all large scale residential developments to explicitly indicate the tenure mix and that this tenure mix should reference the local housing tenure and typology needs and the Dublin City Council Housing Need and Demand Assessment.
I would also include a reference in this section indicating that the gap in rental supply detailed in the DHPLG circular issued in 2016 (https://www.opr.ie/wp-content/uploads/2019/08/2016-Build-To-Rent-Housing-Projects-1.pdf) has now been bridged and more balanced development that ensures standard build units for sale and social housing/affordable cost rental now need to be prioritised.