Ministerial guidelines
Urban Development and Building Heights: Guidelines for Planning Authorities
Building height in towns and cities, and the criteria for taller buildings; plans may not set blanket height limits.
Department of Housing, Planning and Local Government · December 2018 · 26 pages
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- 5 ‘In urban areas, planning and related standards, including in particular building height and car parking will be based on performance criteria that seek to achieve well designed high quality outcomes in order to achieve targeted growth. These standards will be subject to a range of tolerance that enables alternative solutions to be proposed to achieve stated outcomes, provided public safety is not compromised and the environment is suitably protected.’ 1.19 Meeting the scale of the challenge set out in NPO 13 above requires new approaches to urban planning and development and securing an effective mix of uses. In particular, there is a need to support the development of a balance of uses within our urban centres (e.g. living, working, leisure), rather than focusing on just one or two uses that we are seeing in the development of some parts of our city centres, where offices are more frequently constructed than the homes that communities and economies also need, or in our suburbs that are predominantly residential and whose development in ever-extending outward arcs will necessitate more and longer travel to work, car-based mobility and a loss of quality of life as a result. 1.20 A key objective of the NPF is therefore to see that greatly increased levels of residential development in our urban centres and significant increases in the building heights and overall density of development is not only facilitated but actively sought out and brought forward by our planning processes and particularly so at local authority and An Bord Pleanála levels. 1.21 Increasing prevailing building heights therefore has a critical role to play in addressing the delivery of more compact growth in our urban areas, particularly our cities and large towns through enhancing both the scale and density of development and our planning process must actively address how this objective will be secured.
- Building Height and the Development Plan
- 72.0 Building Height and the Development Plan 2.1 Implementation of the National Planning Framework requires increased density, scale and height of development in our town and city cores, including an appropriate mix of both the living, working, social and recreational space we need in our urban areas. 2.2 At the same time, to meet the needs of a growing population without growing our urban areas outwards requires more focus in planning policy and implementation terms on reusing previously developed ‘brownfield’ land, building up urban infill sites (which may not have been built on before) and either reusing or redeveloping existing sites and buildings that may not be in the optimal usage or format taking into account contemporary and future requirements1. 2.3 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. Accordingly, the development plan must include the positive disposition towards appropriate assessment criteria that will enable proper consideration of development proposals for increased building height linked to the achievement of a greater density of development. 2.4 The Government has also committed to substantial investment in public transport infrastructure as a key tenet of Project Ireland 2040, particularly in our cities and towns through investment in a range of modal solutions, including rail, Metrolink, LUAS, Bus Connects and walking and cycling networks. In order to optimise the effectiveness of this investment in terms of improved and more sustainable mobility choices and enhanced opportunities and choices in access to housing, jobs, community and social infrastructure, development plans must actively plan for and bring about increased density and height of development within the footprint of our developing sustainable mobility corridors and networks. 1 A useful guide to assisting in this process is ‘Shaping the Future- case studies in adaptation and reuse in historic urban environments’ published by the (then) Dept. of Arts, Heritage and the Gaeltacht (2012)
- 8 2.5 Furthermore, 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, increased building height is a key factor in assisting modern placemaking and improving the overall quality of our urban environments. 2.6 In some cases, statutory development plans have tended to set out overly restrictive maximum height limits in certain locations and crucially without the proper consideration of the wider planning potential of development sites and wider implications of not maximising those opportunities by displacing development that our wider society and economy needs to other locations that may not be best placed to accommodate it. Such a displacement effect presents a lost opportunity in key urban areas of high demand for new accommodation, whether that is for living, working, leisure or other requirements in the built environment. 2.7 To give effect to these broad policy directions and a more active land management-centred approach as set out in the NPF, the preparation of development plans, local area plans and Strategic Development Zone (SDZ) Planning Schemes and their implementation in city, metropolitan and wider urban areas must therefore become more proactive and more flexible in securing compact urban growth through a combination of both facilitating increased densities and building heights, while also being mindful of the quality of development and balancing amenity and environmental considerations. Appropriate identification and siting of areas suitable for increased densities and height will need to consider the environmental sensitivities of the receiving environment as appropriate, throughout the planning hierarchy. The Environmental Sensitivity Mapping online tool, developed by the EPA, can be a useful guide in this regard. 2.8 Historic environments can be sensitive to large scale and tall buildings. In that context, Planning Authorities must determine if increased height buildings are an appropriate typology or not in particular settings. An Initial assessment of the existing character and setting of a place will assist in a robust framework for decision-making that will facilitate increases in building height and involve an integrated understanding of place. With regards to large-scale and tall buildings in historic urban areas, an examination of the existing character of a place can assist planning authorities, and others to: • establish the sensitivities of a place and its capacity for development or change and; • define opportunities for new development and inform its design. 2.9 In order to consider proposals in an integrated and informed way, an urban design statement addressing aspects of impact on the historic built environment should be submitted along with a specific design statement on the individual insertion or proposal from an architectural perspective addressing those items outlined above.
- 9 2.10 Notwithstanding the above, the provisions contained within Part (IV) Planning and Development Acts 2000, as amended, regarding architectural heritage and associated character/setting remain in place. Planning Authorities are the primary consent authority in establishing if proposals align with best practice in this area and which design standards are to be used in certain circumstances. Planning Authorities can reference Architectural Heritage Protection – Guidelines for Planning Authorities (DEHLG) and Shaping the Future – Case Studies in Adaptation and Reuse in Historic Urban Environments (DAHG) 2012. 2.11 Taking the matters outlined above and the broad policy directions into account, it is therefore critically important that development plans identify and provide policy support for specific geographic locations or precincts where increased building height is not only desirable but a fundamental policy requirement. Locations with the potential for comprehensive urban development or redevelopment (e.g. brownfield former industrial districts, dockland locations, low density urban shopping centres etc) should be identified where, for example, a cluster of higher buildings can be accommodated as a new neighbourhood or urban district or precinct. Such areas, particularly those in excess of 2 ha (approx. 5 acres) in area, should be accompanied by appropriate master-planning exercises and local planning frameworks to deal with movement, public realm, design and other issues that are best addressed at a neighbourhood level rather than at an individual site scale. 2.12 In this regard, areas to be included in this assessment are central and/or accessible locations and also intermediate urban locations where medium density residential development in excess of 45 residential units per hectare would be appropriate. Additional matters to be considered in such an assessment include: • Proximity to high quality public transport connectivity, particularly key public transport interchanges or nodes; • The potential contribution of locations to the development of new homes, economic growth and regeneration in line with the compact urban growth principles as set out in the National Planning Framework and Project Ireland- 2040; • The resilience of locations from a public access and egress perspective in the event of major weather or emergency or other incidents; • The ecological and environmental sensitivities of the receiving environment; and • The visual, functional, environmental and cumulative impacts of increased building height.
- 10 2.13 Taking account of the foregoing, a Specific Planning Policy Requirement of these guidelines is that; SPPR 1 In accordance with Government policy to support increased building height and density in locations with good public transport accessibility, particularly town/ city cores, planning authorities shall explicitly identify, through their statutory plans, areas where increased building height will be actively pursued for both redevelopment, regeneration and infill development to secure the objectives of the National Planning Framework and Regional Spatial and Economic Strategies and shall not provide for blanket numerical limitations on building height. 2.14 Certain urban locations often attract strong demand from other land uses, particularly of a commercial (non- residential) nature, which can result in a relative deficit in the supply of new residential development as part of appropriate mixed use neighbourhoods. This can militate against achieving the objective of increased proximity of new homes and employment which is a central theme of the National Planning Framework. Accordingly, in the interests of achieving national policy objectives for significantly increased urban housing delivery, there is a need for planning policy to ensure that an appropriate quantum of residential developments is included as part of significant development proposals for individual sites and urban neighbourhoods. In recognition of this need the following SPPR shall apply:
- 11SPPR 2 In driving general increases in building heights, planning authorities shall also ensure appropriate mixtures of uses, such as housing and commercial or employment development, are provided for in statutory plan policy. Mechanisms such as block delivery sequencing in statutory plans² could be utilised to link the provision of new office, commercial, appropriate retail provision and residential accommodation, thereby enabling urban redevelopment to proceed in a way that comprehensively meets contemporary economic and social needs, such as for housing, offices, social and community infrastructure, including leisure facilities. 2 2.15 In light of the above, planning authorities should critically evaluate the existing written statements and development objectives of their statutory development plans, local area plans and planning schemes for consistency of approach and where any policy departures arise, to undertake the necessary reviews, variations or amendments to ensure proper alignment of national and local planning policies. 2 A good example of such an initiative is the Block Delivery Objectives of the North Lotts and Docklands Planning Schemes of Dublin City Council.
- Building Height and the Development Management process
- 13 3.0 Building Height and the Development Management process Development Management Principles 3.1 In relation to the assessment of individual planning applications and appeals, it is Government policy that building heights must be generally increased in appropriate urban locations. There is therefore a presumption in favour of buildings of increased height in our town/city cores and in other urban locations with good public transport accessibility. Planning authorities must apply the following broad principles in considering development proposals for buildings taller than prevailing building heights in urban areas in pursuit of these guidelines: • Does the proposal positively assist in securing National Planning Framework objectives of focusing development in key urban centres and in particular, fulfilling targets related to brownfield, infill development and in particular, effectively supporting the National Strategic Objective to deliver compact growth in our urban centres? • Is the proposal in line with the requirements of the development plan in force and which plan has taken clear account of the requirements set out in Chapter 2 of these guidelines? • Where the relevant development plan or local area plan pre-dates these guidelines, can it be demonstrated that implementation of the pre-existing policies and objectives of the relevant plan or planning scheme does not align with and support the objectives and policies of the National Planning Framework? Development Management Criteria 3.2 In the event of making a planning application, the applicant shall demonstrate to the satisfaction of the Planning Authority/ An Bord Pleanála, that the proposed development satisfies the following criteria: At the scale of the relevant city/town • The site is well served by public transport with high capacity, frequent service and good links to other modes of public transport. • Development proposals incorporating increased building height, including proposals within architecturally sensitive areas, should successfully integrate into/ enhance the character and public realm of the area, having regard to topography, its cultural context, setting of key landmarks, protection of key views.3 Such development proposals shall undertake a landscape and visual assessment, by a suitably qualified practitioner such as a chartered landscape architect. • On larger urban redevelopment sites, 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. 3 City centre development in several UK and EU cities have successfully managed to both consolidate development through increased building heights, working sensitively and imaginatively with existing sensitive architectural building contexts – e.g. central London through the London Plan.
- 14 At the scale of district/ neighbourhood/ street • The proposal responds to its overall natural and built environment and makes a positive contribution to the urban neighbourhood and streetscape • The proposal is not monolithic and avoids long, uninterrupted walls of building in the form of slab blocks with materials / building fabric well considered. • The proposal enhances the urban design context for public spaces and key thoroughfares and inland waterway/ marine frontage, thereby enabling additional height in development form to be favourably considered in terms of enhancing a sense of scale and enclosure while being in line with the requirements of “The Planning System and Flood Risk Management – Guidelines for Planning Authorities” (2009). • The proposal makes a positive contribution to the improvement of legibility through the site or wider urban area within which the development is situated and integrates in a cohesive manner. • The proposal positively contributes to the mix of uses and/ or building/ dwelling typologies available in the neighbourhood. At the scale of the site/building • The form, massing and height of proposed developments should be carefully modulated so as to maximise access to natural daylight, ventilation and views and minimise overshadowing and loss of light. • Appropriate and reasonable regard should be taken of quantitative performance approaches to daylight provision outlined in guides like the Building Research Establishment’s ‘Site Layout Planning for Daylight and Sunlight’ (2nd edition) or BS 8206-2: 2008 – ‘Lighting for Buildings – Part 2: Code of Practice for Daylighting’. • Where a proposal may not be able to fully meet all the requirements of the daylight provisions above, this must be clearly identified and a rationale for any alternative, compensatory design solutions must be set out, in respect of which the planning authority or An Bord Pleanála should apply their discretion, having regard to local factors including specific site constraints and the balancing of that assessment against the desirability of achieving wider planning objectives. Such objectives might include securing comprehensive urban regeneration and or an effective urban design and streetscape solution. Specific Assesments To support proposals at some or all of these scales, specific assessments may be required and these may include: • Specific impact assessment of the micro-climatic effects such as downdraft. Such assessments shall include measures to avoid/ mitigate such micro-climatic effects and, where appropriate, shall include an assessment of the cumulative micro-climatic effects where taller buildings are clustered. • In development locations in proximity to sensitive bird and / or bat areas, proposed developments need to consider the potential interaction of the building location, building materials and artificial lighting to impact flight lines and / or collision. • An assessment that the proposal allows for the retention of important telecommunication channels, such as microwave links.
Source Department of Housing, Planning and Local Government: Urban Development and Building Heights: Guidelines for Planning Authorities (December 2018) · Licence the publisher's termsText read from the publisher’s PDF; tables, maps and drawings do not survive as text, and page numbers are the PDF’s (its first page is 1). Check the original before relying on a passage.