Submission regarding Kilkenny County Council draft Development Plan
The development plan describes the council’s policy regarding one-off housing in areas under urban influence as to facilitate the housing requirements of the local rural community. The definition of intrinsic members of the rural community is taken directly from the Rural Planning Guidelines document. The definition of the local area on the other hand is not provided for explicitly in the Rural Planning Guidelines document, rather Councils are encouraged to develop an objective policy that provides for the housing needs of the rural community and takes into account the individual character of the area. The drafted Plan has chosen to do this by insisting that successful applicants for housing in rural areas under urban influence must either work or have lived for a significant period of time in the local rural area (or their close family members must have) i.e. within 8km of the site (excluding, of course, urban areas as they would represent urban generated housing need). This has the effect of preventing urban sprawl and depopulation of more remote rural areas. This policy appears to be appropriate. However, apart from reducing the local area from 10km to 8km the wording is effectively identical to the previous plan and the interpretation of the wording of the definition by the Council has been quite restrictive. In effect, although the local area is defined as a ‘10km radius from the site excluding urban areas’, this has been interpreted as a 10km radius from the site excluding urban areas unless there are intervening urban areas. This interpretation has been made for example in my own planning application in 2011. This definition of local is extremely important as a very large proportion of the county is considered to be under urban influence. The logic for in effect defining rural areas as a 10, or now 8, km radius of the site unless there is an intervening urban area must be either (a) the urban area is a more appropriate location for housing the rural person or (b) the intervening urban area fragments rural population such that members of the rural community are not intrinsically linked if urban areas occur between them. I do not find either argument convincing. I will discuss each in turn: (a) A large proportion of the county’s population dwells in the rural area. It is not considered appropriate in the plan or in the Rural Planning Guidelines to direct rural dwellers to urban areas for housing. Indeed the plan commits to providing for the one off housing needs of rural dwellers. It is right that rural people should be facilitated in their desire to raise children as they have been raised. It can be difficult for members of the community to purchase or obtain appropriate sites within areas under urban influence owing for example to their expense. A rural dweller might then find him or her-self looking for planning on a compromise site on the far side of a town or village. I have found myself in exactly this position. Why should this in effect make them (or me) urban generated housing to be directed to urban areas? (b) There is some intuitive logic to the contention that intervening urban areas fragment rural populations. However, in practice I do not believe this really occurs. The particular rural areas affected are inevitably near urban areas and this affects their character. Members of this community of course frequently use the nearby town’s facilities and do not see it as any kind of a barrier to other nearby rural locations. In my own case, my homestead lies 3 km south of Kilkenny town and I have overwhelmingly clear empirical evidence that my social community is predominantly rural and extends throughout the rural areas surrounding the city. If you look at where my wedding guests came from you get a very clear idea of what my community is (my wedding guests are green while my wife’s guests whose homestead is on the edge of town are in yellow). I had 31 guests from rural areas near kilkenny town and only 6 from town (5 from more remote rural areas). What is most important to note is how the distribution of my own rural community is not fragmented by the town. I am sure this would be the case for most inhabitants of this type of rural area.
Another problem with excluding intervening urban areas is that there is no logical difference between two nearby locations being geographically on opposite sides of the town and two locations being linked via a route that goes through the urban area. If having to enter Kilkenny environs while travelling from one site to another makes them non-local, then from figure below, none of A, B, C or D could be considered local to each other. This does not seem reasonable to me.
I think it is a mistake to regard urban areas as a barrier to rural people’s communities. Perhaps if you were talking about large cities it would be so but certainly not in the case of a relatively small urban area like Kilkenny and even less so in other smaller urban areas. The current wording of the plan has apparently acted to prevent the County planners from accommodating people like myself who grew up in the rural area within the radial distance designated by the plan and whose social community is spread throughout the area surrounding both the site and my homestead. I would like to see the local area definition extended to include a statement such as ‘without regard for intervening urban areas’ i.e. The local area will be defined as an 8km radius from the site excluding urban areas but without regard for intervening urban areas’. Such a definition of ‘local’ could not induce urban sprawl, depopulate more remote rural areas or alter the fabric of the rural community. It would however, make a massive difference to making it easier for rural dwellers like myself to live within our own community.
