A Chara,
I refer to your notice received on the 19th June 2013 regarding the preparation of the Kilkenny Draft County 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 is 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 Draft Kilkenny County 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 Draft Kilkenny County Development Plan 2014 - 2020 are consistent with the South-East Regional Planning Guidelines.
Comment of the South-East Regional Authority
Whilst the Regional Authority consider that the Draft Kilkenny County 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 Authority:
Chapter 1 Introduction
Sets out in a detailed manner the legal framework and the framing documents which inform the Draft Kilkenny County 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 County Kilkenny.
No alterations are considered necessary.
Chapter 3 Core strategy
- 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.
- Strong commitment to the implementation of the National Spatial Strategy and the South-East Regional Planning Guidelines.
- The Council is commended on the use of expired LAPs as supplementary guidance documents particularly in relation to the natural and built environment.
- Section 3.5 sets out in a clear and logical manner the policies and objectives which inform the Rural Housing Strategy.
- The Regional Authority recommend the inclusion of a revised schematic map to illustrate the strategic vision in a spatial format and the relationship with adjacent local authorities and within the South-East Region.
Recommendation:
The inclusion of a schematic map illustrating the development plan policies and objectives for County Kilkenny in a spatial format should be considered.
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 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 environment and it contains a clear vision for the future development of the county.
The Regional Authority welcome the strong retail policies aimed at supporting the primacy of Kilkenny City Centre as the core retail area.
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 County 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 County Council is commended on its active social inclusion and positive ageing strategies.
- The plan recognises that the way to the successful integration of new housing is through appropriate layout, design, housing type and density.
No alterations are considered necessary.
Chapter 6 Rural Development
A comprehensive section that provides clear guidance on a wide range of development potential opportunities in rural areas, whilst placing the protection and enhancement of the environment at the centre of development policies.
No alterations are considered necessary.
Chapter 7 Recreation, Tourism & Arts
The importance of green infrastructure and the expansion of the tourist industry are acknowledged with a series of positive actions and strategies. The Council is commended on recognising and promoting the development potential of the Three Sisters rivers complex and its proactive policies in regard to the provision of playgrounds.
No alterations are considered necessary.
Chapter 8 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 County Kilkenny and that heritage transcends the physical environment and includes traditions, practices, knowledge and skills which are an expression of our culture.
- 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.
· Good detailed section on Architectural Conservation Areas.
No alterations are considered necessary.
Chapter 9 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 priority, provision, expansion and upgrading of water infrastructural services.
No alterations are considered necessary.
Chapter 10 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 section provides a strong platform for the expansion of renewable energy.
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 11 Transport
- Very comprehensive, detailed and clear section which illustrates a strong vision for the future sustainable travel requirements for County Kilkenny 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.
- Good section setting out the road works priority scheme over the lifetime of the plan.
No alterations are considered necessary.
Chapter 12 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 Draft Kilkenny County 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 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 county which will complement its heritage, cultural and historic character as well as promote tourism. The draft plan is also commended on its excellent referencing of source material.
Having reviewed the Draft Kilkenny County 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 practical with the South-East Regional Planning Guidelines 2010 – 2022.
The observations contained within this submission are aimed at assisting the 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
