The Senior Planner Planning Policy Unit Floor 13 Cork County Council County Hall Cork 16 th January, 2017 RE: CORK CHAMBER SUBMISSION IN RESPECT OF: - DRAFT BALLINCOLLIG CARRIGALINE MUNICIPAL DISTRICT LOCAL AREA PLAN - DRAFT EAST CORK MUNICIPAL DISTRICT LOCAL AREA PLAN Cork Chamber welcomes the opportunity to comment on the draft Municipal District Local Area Plans. It is acknowledged that significant effort on the part of the Planning Authority has been put into the preparation of these detailed Plans. We have comments on a number of general and specific matters arising from the proposals for the Metropolitan Cork area, which we would ask the Planning Authority to take on board in the preparation of the final documents. This submission is made in respect of the Ballincollig Carrigaline Municipal District draft Local Area Plan (LAP) 2016 and East Cork Municipal District draft Local Area Plan (LAP) 2016. Cork Chamber is the leading business organisation for the promotion and development of economic and commercial activity in the region. The Chamber represents over 1,100 companies employing over 100,000 people across Cork, and as such, occupies a vital role in leading and developing business activity. 1. Context The Ballincollig Carrigaline Municipal District draft Local Area Plan (LAP) 2016 covers the largest of the Municipal Districts in the jurisdiction of Cork County Council. The 2011 population of this Municipal District is 71946 people (2011), or almost a fifth (c. 18%) of the total population of Cork County (399,802, 2011), and includes the Main Towns of Ballincollig Carrigaline Passage West/Monkstown/Glenbrook Cork City South Environs and Ringaskiddy in the Cork Gateway. The East Cork Municipal District draft Local Area Plan (LAP) 2016 is the 2 nd smallest Municipal District in Cork with 42,399 people (2011) and includes the towns of Midleton and Youghal. It includes the Urban Expansion Area of Water-Rock, Midleton. This has the capacity to deliver 2,500 dwellings. Midleton is expected to grow to 21,576 people.
The draft LAPs have been prepared for the horizon year 2022, however it is intended that, once adopted, they will remain in place for 10 years. In reviewing the Draft Local Area Plans, Cork Chamber note the new legislative obligations on planning authorities introduced via The Planning and Development (Amendment) Act 2010 which focus on ensuring that LAPs comply with devised Core Strategies contained within the relevant county/city development plan. These obligations extend to the provision of employment and jobs as highlighted in the national guidelines on the preparation of LAPS - Local Area Plans Guidelines for Planning Authorities 2013, Department of Environment, Community and Local Government, and specifically in relation to Section 5 of the guidelines which identifies the need to promote local economic development and employment growth by focusing on the predominant issues in an area. Cork Chamber highlight that neither the CDP or the emerging LAPs are supported by a considered economic development strategy and this represents a fundamental weakness in approach to providing for future employment needs. The draft LAPs are overtly focused on population and housing growth only to the disadvantage of other key strategic planning areas. These plans do not establish general employment targets or seek to identify existing or future sectoral growth needs locally which Cork Chamber considers to be an opportunity missed. The Government prepared Action Plan For Jobs 2015-2017 South West Region establishes the need to have a further 10-15% at work in counties Cork and Kerry by 2018 and to ensure the unemployment rate is within 1% of the State average. The plan establishes tangible targets such as 20% increase in export-led jobs by 2020, 40-50% start-ups, scaling and survival, and a quantified increase of 30-40% (additional 139) FDI investment projects. It recognises that this can only be achieved by collaboration among key stakeholders in the region working to achieve common goals. The Action Plan was developed under the auspices of a project delivery group comprising public bodies in the south west region, which included Cork County Council, and a failure to align the LAP production process with this wider network constitutes a missed opportunity. We also note the established practice of other local authorities such as Meath County Council who have prepared an economic strategy to identify key strategic employment requirements and marry these needs with traditional land use planning practices. A similar approach should be advanced here. 2. Key principles of the draft LAPs 2.1 Urban Expansion Areas The draft LAPs identify a series of Urban Expansion Areas such as Waterrock (Midleton), Carrigtwohill North, Ballynoe (Cobh), Ballyvolane, Ballinglanna/Dunkettle, Monard, Stoneview (Blarney), Ballincollig South, and Shannonpark (Carrigaline). These were the previously identified Special Policy Masterplan areas, the key difference being that the masterplans have now been prepared primarily by the Council. These areas have not been progressed for development despite being strategically important for some fifteen years.
However, we would suggest that the delivery of some of the lands included in the Urban Expansion Areas could proceed in the short term if there is sufficient capacity in water, waste water, road infrastructure and surface water provision. In this regard, the Draft LAP should set out a detailed phasing framework which will include parcels of land that are suitable for development in short term without a significant upgrade of infrastructure in order to achieve early wins in the Urban Expansion Areas. It is intended that the County Council will take a lead role in the delivery of core transport and water infrastructure, and is at an advanced state in discussions with funding agencies that will facilitate the design and construction of the new road water services and storm water infrastructure required. Where infrastructure is to be provided by the County Council, developers/landowners benefitting from that infrastructure will be invited to enter an agreement with the County Council and other relevant infrastructure agencies prior to the submission of planning applications to co-ordinate the delivery of the infrastructure with the commencement and delivery of new housing development. This procedure will also facilitate agreement between parties in relation to the payment of charges of contributions towards the cost of delivering the relevant infrastructure. We welcome the Council s decision to establish a specialist housing and infrastructure delivery team. At present, we understand that this is an internal working group. Cork Chamber highlights the importance of extending this group to be developed into a wider task force to include relevant representation from external agencies and the private sector, with the outputs of this representative task force being fed into the formal infrastructure delivery plan as part of targeted measures to achieve growth projections. This should be kept under review with regular reporting as part of a formal plan-monitor-manage approach to LAP delivery. In relation to water services, Irish Water has undertaken a strategic review of all settlements in the Metropolitan Area and is developing an investment programme for the implementation of the water services in line with the priorities identified by Cork County Council s urban expansion areas. The general approach is where Irish Water already have water infrastructure in a town or village then Irish Water will need to upgrade that infrastructure as necessary to meet the demands of current and future customers in the settlement. It is clear that Irish Water will have a major role to play in the delivery of infrastructure required to facilitate development in the County. The early publication of the Irish Water investment programme, as well as those of other related agencies such as Transport Infrastructure Ireland and the National Transport Authority, will be required. A draft Development Contribution Scheme is being prepared to reflect the infrastructure required to support the delivery of the residential and commercial development highlighted in the draft LAPs. It is intended to reduce the extent to which Special Contributions are necessary to facilitate development. The draft Development Contribution Scheme will not include the internal infrastructure required for the Urban Expansion Areas, nor limited external works specific to these sites, with these costs to be recouped on commencement/completion of development via section 47 agreements or special development contributions.
The scale of infrastructure investment is understood but the Development Contribution Scheme must not place an onerous burden across the County so as to stymie development occurring. Contributions related to infrastructure investment in Urban Expansion Areas must be specific to those areas only. Cork Chamber also highlights the need to ensure that both existing and future housing growth areas are supported by an appropriate range of social infrastructure including schools, health, sports and recreation, community and other facilities which contribute to long-term quality of life for residents. Such infrastructure provision is key to developing attractive locations which in turn attract investment and growth into the future and sustainable and vibrant communities. 2.2 Regeneration Areas/Town Centres/City Gateway s Initiative Regeneration Areas have been identified in all towns, in accordance with the Urban Regeneration and Housing Act, 2015. Such sites have the potential to contribute to the rejuvenation of the towns deliver housing, and perhaps act as a catalyst for other developments. These site may be subject to a vacant site levy in time. It would need to be clarified if Regeneration Areas identified in town centre zoned lands are, in sequential terms, the preferred location for development, and is it a requirement that their development has to be for mixed-use as opposed to a singular use such as retail? A mixed use approach should be more sustainable in the long-term. In relation to town centres, the draft LAPs references a proposed Town Centre Improvement Scheme, initially focused on towns such as Ballincollig and Carrigaline, and to include guidance on future land use and public realm improvements, urban design guidance, as well as opportunity sites and key buildings to be protected. More details will be required in relation to this potentially critical element of town centre regeneration. In retailing terms, retail cores have now been identified for each of the Main Towns. These mainly relate to the primary shopping area. It is possible that retail development outside these cores will be subject to the sequential test, even if they are located in the town centre. This will need to be clarified. Interestingly, the draft LAP also references the potential for a large scale retail warehouse (over 6000m 2 ) in Metropolitan Cork, which provides a strong policy context for future investment. This is a welcome policy initiative. The City Gateway s Initiative which proposes to reinvigorate entrance points to the City and provide a sense of arrival is to be welcomed.
2.3 Strategic Land Reserve By far the most significant element of policy intervention is in relation to the Strategic Land Reserve for the Metropolitan Cork area, the purpose of which is to provide a supply of land that can offset the risk of a major parcel of zoned land failing to commence development or to accommodate additional development pressures if low levels of development activity is experienced in the City Docklands or elsewhere. This is in the context of a planned house building rate of around 3500 units per annum. A Strategic Land Reserve capable of delivering c.9,019 units needs to be identified. The Council has identified c. 1489.2 ha of zoned lands across 12 sites, with the potential to deliver up to 37,225 units (assuming an average density of 25 units/ha). These sites include the Cork North and South Environs, a westwards expansion of the City to Ballincollig an amalgamation of Carrigaline and Ringaskiddy, a westwards extension of Carrigtwohill, as well as an westwards extension of Midleton (Midleton West, SRL11). Interestingly the total existing zoned land supply in the Metropolitan Cork area, to include the Urban Expansion Areas (up to 11000 units), is capable of delivering 32,059 units. However, Cork County Council has noted that there is only 1.5 years supply of existing zoned and serviced land. In this context, and given the significant investment required to unlock the development potential of existing zoned lands, together with the 1.5 years of existing supply, it is apparent that the Strategic Land Reserve with less fragmented ownership issues and potential services provision could play a vital role in the delivery of the projected 36000 housing units over the next 12 years in Metropolitan Cork. What is not clear is the trigger point for bringing forward these Strategic Land Reserves for development and in what priority. It is clear that these sites must be capable of being brought forward for development in the short-term. Furthermore, the draft LAP sets out a number of main criteria against which each of the identified Reserves will be assessed, however, each of the Reserve lands can or has the potential to satisfy, them. It is assumed that these identified Strategic Land Reserves have already been subject to an initial assessment that warranted their inclusion in the draft LAP. The key point is that potentially all the Strategic Reserve Lands may be suitable and it would be our submission that all such lands should be carried forward into the final LAPs. Furthermore, some of these lands by reason of their location relative to sustainable transportation modes, the character of their ownership, the availability of existing Irish Water services and schools, as well as their scale, could be zoned residential to be capable of being brought forward for development in the short-term to meet current supply constraints. Such sites could include Ardrostig, Frankfield/Grange, Ballincollig East-Carrigrohane, and Oldcourt. We would be concerned that the sustainable transportation objectives of the Cork County Development Plan 2014 should be reinforced in the advancement of any of the Strategic Land Reserves, and that any locations that are to be carried through to the final LAPs should clearly demonstrate how it is proposed to manage overall transport demand that does not contribute to increased congestion and to provide better pedestrian, cycle and public transport connectivity between existing and proposed land uses. This is particularly so for the non-rail based locations such as Ballincollig and Carrigaline. We note that the opportunity of the Old Passage Railway Line Greenway should be a relevant consideration in examining proposed residential locations in the City South Environs.
2.4 Flooding The draft LAPs include updated indicative flood zone mapping. The Council s approach to flooding is to avoid development in areas at risk of flooding; and where development cannot be avoided to take a sequential approach to flood risk management based on avoidance, reduction and mitigation of risk. Flood zones are based on an undefended scenario and do not take account of the presence of flood protection structures. It is our submission that the flood protection structures should be taken into account in the determination of flood zones, or at least a recognition that certain areas that are prone to flooding have the benefit of such defences. This is particularly important in our town centres across the County which by and large are located in flood zones. The national regional and local planning policy guiding the development of town centres should prevail, with the onus on the developer to satisfy the requirements of the Planning and Flood Risk Management Guidelines 2009 and the relevant objectives of the Cork County Development Plan 2014 including through the use of S47 agreements/special Development Contributions as appropriate, to ensure the ongoing maintenance of such flood defence infrastructure. 3. Draft Ballincollig Carrigaline Municipal District LAP 3.1 Population Growth In relation to specific elements of the Ballincollig Carrigaline Municipal District draft Local Area Plan, it is noted that it includes the Urban Expansion Areas of Shannonpark in Carrigaline, and Ballincollig South (Maglin) in Ballincollig. Shannonpark is included in the first tranche of the Urban Expansion Areas to be implemented. The Urban Expansion Areas have the capacity to deliver an additional population of c. 7,668 (4,000 units, 6,437 people Ballincollig; 1,587 new dwellings and 1,231 people in Shannonpark, Carrigaline). The draft Plan now incorporates the Shannonpark Urban Expansion Area masterplan as adopted, and proposed masterplans for Ballincollig (Maglin) are now identified. This latter masterplan makes provision for up to 3,570 residential units as well as open space, provision for schools, an office park and additional road and pedestrian/cycleway infrastructure, including reservation for the proposed Northern Ring Road. The preparation of the masterplans for the Urban Expansion Areas is welcomed, but our comments in section 2.1 above should be noted. More detail is required on the programme for funding and implementing these ambitious and important development areas. 3.2 Employment From an employment perspective, the draft LAP states that there is a strong supply of existing employment land within the Municipal District of some 505.78ha primarily for industrial use. The draft LAP proposes to ensure that such lands can be readily developed for such uses and any barriers to their development should be addressed. Specific comments are as follows:
It is noted that a new area for enterprise development has been identified in Ballincollig south of the town centre. It is indicated that this will be suitable for high quality office based employment. We welcome this proposal. This is in addition to an office park at Maglin Urban Expansion Area. In relation to the Cork Science and Innovation Park, it is stated in the draft LAP that, in light of new opportunities and initiatives being developed in the current Economic Recovery climate, that the overall model/approach be reviewed with a view to the option of putting forward revised updated proposals at the Amendment stage of the LAP, including the potential for a major medical campus. We welcome this proposal In relation to Ringaskiddy, it is noted that 344ha of land has been zoned for industrial use of which 236ha remains undeveloped. Consideration will be given to a bus service between Ringaskiddy and Carrigaline as well as old N28 walkway/cycleway route and a public ferry route between Cobh and Ringaskiddy. No additional industrial lands have been identified for Ringaskiddy. However it is noted that the route of the M28 will sever some of these zoned lands. It is stated that Cork County Council will engage with all relevant parties to future optimise and maximise the large amount of land zoned for industry at this location. It would be our recommendation that additional lands should be zoned for industrial development in Ringaskiddy in view of its status as the principal strategic employment location for the County. Further locations to the south of the existing development boundary, flanked by the proposed M28, should be considered in the finalisation of the LAP. In relation to Carrigaline Town Centre, a single T-01 town centre zoning objective is proposed, which is to be supported. The T-01 objective no longer includes reference to the preparation of an action plan/development brief, however, the text of the draft LAP references that the LAP will include an urban design framework to guide the desired urban structure. It will be important that the urban design framework is progressed in the short-term, with the input of all relevant parties, in order to realise the sustainable development of Carrigaline Town Centre. In relation to Cork Airport, and in line with the Airport s own masterplan, the draft LAP identifies an expanded area for office-based industry complementary to those in the existing Cork Airport Business Park, but within the Airport landholding. We note that there is an additional industrial site identified to the south-east of the airport for future airport use. Obstacle Limitation Surfaces (OLS) have been defined in accordance with the International Civil Aviation Organisation (ICAO) which define the maximum allowable height. We welcome the additional industrial site identified at Cork Airport, subject to an assessment of sustainable management of overall traffic demand. The material in the draft LAP is not sufficiently clear to establish what the implications might be. This needs to be clarified.
4. East Cork 4.1 Population Growth In relation to specific elements of the East Cork Municipal District draft Local Area Plan, it is noted that it includes the Urban Expansion Area of Water-rock, which is included in the first tranche of the Urban Expansion Areas to be implemented. It is however noted that there are constraints in Irish Water services in Midleton, with limited spare capacity. That said, it is stated that it is the intention of Irish Water to include funding of these projects as part of their next investment cycle. The preparation of the masterplans for the Urban Expansion Areas is welcomed, but our comments in section 2.1 above should be noted. More detail is required on the programme for funding and implementing these ambitious and important development areas. 4.1 Employment From an employment perspective, the draft LAP states that there is a strong supply of existing employment land within the Municipal District of some 194.9ha primarily for industrial use (principally at Aghada and Whitegate). The draft LAP proposes to ensure that such lands can be readily developed for such uses and any barriers to their development should be addressed. In relation to Midleton, the following is of note: It is noted that a former Mill complex on Dwyer s Road (to the south of the Midleton Park Hotel), which now trades as Midleton Business & Enterprise Centre, is identified as being suitable for redevelopment as a location for modern office space. We would support this proposal. An additional 15.5ha of industrial lands has been identified to the south-east of the town, fronting the N25. We would consider this to be sufficient for Midleton. From a retailing perspective, the draft LAP indicates that there is scope for additional retail development in Market Green to the west of the core town centre and Cuddigan s Yard/Broderick Street to the south. We would support this proposal. In relation to Youghal, the most significant change is that the extent of the town centre has been substantially reduced to focus on the existing linear town centre and adjacent sites only. In addition, the neighbourhood zoning objective that previously pertained to the former Seafield factory on the Cork Road has been removed. We would consider that this reflects the existing scale of retail use in the town, the existing level of vacancy, and the limited capacity for further retail development. In relation to Whitegate and Aghada, there are no changes proposed in the draft LAP. We would encourage the Planning Authority, in conjunction with the TII and the NTA, to consider the upgrading of the R630 Regional Road to national road status in view of the policies of the draft
LAP with respect to this area s status as Ireland s Energy Park. Ease of access to this significant opportunity site must be a priority. 5. Conclusion In conclusion, Cork Chamber welcomes the initiative of Cork County Council in identifying the preferred locations to support an additional uplift in population and employment over the lifetime of the LAPs. We welcome the implementation strategy put forward, but, in view of the current housing supply issues, would urge the Council to be as proactive as possible in identifying opportunities for the shortterm delivery of housing. We would also encourage the Council to consider increasing the quantum of zoned and serviced employment lands particularly in Ringaskiddy. Finally, we would urge the Council to ensure that sustainable transportation measures and access to Irish Water services underpin all preferred locations for the benefit of the region as a whole.