Re: Section 27 (b) Observations on the Kilkenny City & Environs Draft Development Plan 2014 - 2020
A Chara,
I refer to your notice received on the 19th June 2013 regarding the preparation of the Kilkenny City & Environs Draft Development Plan 2014 - 2020. The following are the observations of the South-East Regional Authority in this regard.
Introduction
Under Section 27(b) of the Planning & Development Act, 2000 (as inserted by Section 18 of the 2010 Act) the Regional Authority are obliged to prepare submissions / observations to be submitted to the relevant planning authority and copied to the Minister for the Environment, Community and Local Government. A submission shall contain a report which shall state whether, in the opinion of the Regional Authority, the Draft Development Plan is consistent with the Regional Planning Guidelines in force for the area of the development plan. If, in the opinion of the Regional Authority, the Draft Development Plan is not consistent with the RPG, the submission / observations and report shall include recommendations as to what amendments, in the opinion of the Regional Authority, are required to ensure that they are consistent.
This report contains the opinion of the South-East Regional Authority in relation to the above matters along with recommendations as required under Section 18 inserting new Section 27b of the Planning and Development (Amendment) Act, 2010.
Assessment
The South-East Regional Authority welcome the Kilkenny City & Environs Draft Development Plan 2014 – 2020 and acknowledge the efforts made to coordinate the objectives and policies of the development plan so that they are consistent as far as practicable with the South-East Regional Planning Guidelines 2010 – 2022. The Regional Authority consider that the overall population targets proposed in the Core Strategy and the policies and objectives contained within the Kilkenny City & Environs Draft Development Plan 2014 - 2020 are consistent as far as is practicable with the South-East Regional Planning Guidelines.
Comment of the South-East Regional Authority
Whilst the Regional Authority consider that the Kilkenny City & Environs Draft Development Plan 2014 – 2020 is consistent as far as practicable with the aims and objectives of the Regional Planning Guidelines for the South-East Region 2010 - 2022, the Regional Authority would like to make the following comments for the consideration of the Planning Authorities:
Chapter 1 Introduction
Sets out in a detailed manner the legal framework and the framing documents which inform the Kilkenny City & Environs Draft Development Plan 2014 – 2020. The draft plan is commended on acknowledging the importance of developing a public consultation process for plans and projects proposed by the local authority.
No alterations are considered necessary.
Chapter 2 Demographic & Socio Economic Trends
- This chapter gives a very clear and concise overview of the current socio-economic profile of Kilkenny city.
- The Regional Authority note that the populations figures used in Table 2.2 do not correlate with the Regional Authority’s own population figures. Although relatively minor in nature, the Regional Authority consider that the population figures in Table 2.2 should be revised so that they are consistent with population figures published by the Regional Authority.
Table 2.2 Recorded Population in South-East Region
|
|
2006 |
2011 |
% Change |
|
Clonmel |
15,482 |
17,793 |
2 |
|
Kilkenny |
22,179 |
24,423 |
10.1 |
|
Waterford |
45,748 |
46,732 |
2.2 |
|
Wexford |
18,163 |
19,645 |
8.1 |
SERA: Recorded Population Change in South-East Region
|
|
2006 |
2011 |
% Change |
|
Clonmel |
17,008 |
17,908 |
5.3 |
|
Kilkenny |
22,179 |
24,423 |
10.1 |
|
Waterford City* |
49,213 |
51,519 |
4.7 |
|
Carlow |
20,724 |
23,030 |
11.1 |
|
Wexford |
18,163 |
20,072 |
10.5 |
|
Dungarvan |
8,362 |
9,427 |
12.7 |
* includes environs of city in Co. Kilkenny
- The Regional Authority consider that the larger urbans, including county towns such as Carlow and Dungarvan, should be included in any comparative analysis of population change in the South-East Region.
- The population targets contained in Table 2.5 have been disaggregated so that the population targets are compatible with the timeline of the Kilkenny Draft Plan; this is logical and acceptable.
Recommendation:
Minor alteration to Table 2.2 recommended.
Chapter 3
- The Regional Authority are satisfied that the population figures used in the Core Strategy are aligned with the framework of principles outlined in Section 3 of the Regional Planning Guidelines 2010 – 2022 and that the policies and objectives contained within the core strategy are consistent as far as practicable with the South-East Regional Planning Guidelines.
- The Core Strategy provides a summary of the main objectives and policies of the draft plan and explains the logical process and reasoning for the adoption of policies.
- The strategic vision for the future of Kilkenny is clearly outlined. The implementation of this vision is expressed through a number of ‘actions’ which are further expanded upon in the main body of the draft plan.
- The Regional Authority agree that there is a need for low density housing in order to provide a choice in the housing market and as an alternative to one-off housing in the surrounding countryside.
- On the probability that the ‘Diageo Site’ will have a mixed-use zoning or a residential component when it becomes vacant, the Planning Authority should consider the potential housing yield on the ‘Diageo Site’ to see if these additional lands have the potential to influence the total housing land requirement.
No alterations are considered necessary. However, the planning authority should consider the potential housing yield of the Diageo site and assess the possible impact on the housing land requirement for Kilkenny city.
Chapter 4 Economy Development
The Regional Authority commend the draft plan on its pro-development policies and innovative vision aimed at stimulating and facilitating economic growth and acknowledge that the proposed Economic Strategy and its specific ‘actions’ will help position Kilkenny City to take advantage of any economic upturn.
This economic strategy sets out a vision in a series of innovative actions that will facilitate the delivery of a more attractive urban environment and contains a clear vision for the future development of the city through the development of the city’s heritage potential.
The Regional Authority welcome the strong retail policies aimed at supporting the primacy of Kilkenny City centre as the core retail area and supports the policies that identify the ‘Diageo’ site and the ‘Bareman Quay’ as the focus for retail expansion in the city and environs over the plan period. The Regional Authority agree that the development of these sites will ensure both consolidation and expansion of Kilkenny city centre.
No alterations are considered necessary.
Chapter 5 Housing & Community
- A detailed and concise section which covers all aspects of the predicted housing requirements of both the existing and projected population of Kilkenny over the lifetime of the plan.
- The Regional Authority recognise the importance attached to the proper provision of childcare facilities and early learning facilities.
- Kilkenny Borough Council is commended on its active social inclusion and positive ageing strategies.
- The Regional Authority consider that the draft plan may benefit from the identification of those elements of social infrastructure that are in deficit within Kilkenny City and propose appropriate policies / action that attempt to overcome this deficiency.
Recommendation:
Consideration be given to the identification of the elements of social infrastructure that are in deficit and pro-active polices to overcome this deficiency.
Chapter 6 Recreation
- The importance of green infrastructure and the expansion of the tourism industry are acknowledged with a series of positive actions and strategies.
- The draft plan recognises opens spaces, sporting facilities and recreation as an integral component of a good quality of life in an urban area.
No alterations are considered necessary.
Chapter 7 Heritage
- The draft plan recognises the importance of both the man-made and the natural environment as an integral component of a good quality of life.
- The draft plan is commended on recognising the rich and varied built, natural and cultural heritage resource of Kilkenny City and that heritage transcends the physical environment and includes traditions, practices, knowledge and skills which are an expression of our culture and that this heritage is a valuable economic resource that brings significant economic benefits to the city.
- The Regional Authority welcome the inclusion of ‘Green Infrastructure’ into the planning process.
- The draft plan contains strong development control standards/policies that aim to protect the historical and natural heritage of the city.
· Good detailed section on Architectural Conservation Areas.
No alterations are considered necessary.
Chapter 8 Infrastructure & Environment
The infrastructure section provides a detailed and clear approach which illustrates a strong vision for the future sustainable requirements of Kilkenny.
Good section on water quality, conservation and flood risk policies. Forward looking policies on the provision, expansion and upgrading of infrastructural services.
No alterations are considered necessary.
Chapter 9 Renewable Energy Strategy
This section provides a good overview of the various renewable energy options available to both private and commercial developments. The Regional Authority can confirm that the revised South-East Region Bioenergy Implementation Plan 2013 -2020 has now been published and contains detailed analysis of the potential bioenergy resources available in County Kilkenny, including forestry, municipal waste, agricultural by-products and biomass.
The renewable energy standards provide a strong platform for the expansion of renewable energy policy beyond the minimum standards contained in Technical Guidance Document L of the Building Regulations 2011.
Recommendation:
Update Section 9.4.1 and Section 9.6 to include bioenergy targets and data from the South-East Region Bioenergy Implementation Plan 2013 -2020.
Chapter 10 Transport
Very comprehensive, detailed and clear section which illustrates a strong vision for the future sustainable travel requirements of Kilkenny city coupled with strong policy initiatives to help facilitate the ‘smarter travel’ concept through the promotion of pedestrian /cycle infrastructures and a clear commitment to integrated public transport.
No alterations are considered necessary.
Chapter 11 Requirements for Development
A comprehensive and detailed section that sets out in a clear and concise manner the design standards required to deliver a high quality built environment that is attractive and that places quality urban design as a key element in achieving sustainable development.
No alterations are considered necessary.
Other Comments
- The Planning Authority should satisfy themselves that the Kilkenny City & Environs Draft Development Plan 2014 – 2020 is fully compliant with the requirements of the Regional Planning Guidelines in relation to Appropriate Assessment and Strategic Environmental Assessment, all relevant EU Directives and the Water Framework Directive and associated documents.
Conclusion
The draft plan sets out a clear vision for the future development of Kilkenny City in a series of actions that will deliver a more sustainable pattern of development and which promotes sustainable transport choices. The draft plan is commended on its aims, clearly expressed in spatial terms, that identify important opportune sites for regeneration, advocate improvement to the urban fabric of the city which will complement the heritage, cultural and historic character of the city as well as promote tourism.
Having reviewed the Kilkenny City & Environs Draft Development Plan 2014 - 2020, the Regional Authority are satisfied that the population figures used in the Core Strategy are aligned with the framework of principles outlined in Section 3 of the Regional Planning Guidelines 2010 – 2022 and that the policies and objectives contained within the plan are considered to be consistent as far as is practicable with the South-East Regional Planning Guidelines 2010 – 2022.
The observations contained within this submission are aimed at assisting Kilkenny Borough Council and Kilkenny County Council in ensuring that the final document is consistent with the Regional Planning Guidelines in accordance with Section 10 of the Act and complies with all other relevant statutory and policy requirements.
Should you wish to discuss any of the above issues please contact James Lavin, RPG Implementation Officer, on 052 6134352 or email: james.lavin@southtippcoco.ie
Is mise, le meas,
Stiúrthóir
