24 July, 2013                                          NRA13-88257

 

Dear Sir/Madam,

The Authority welcomes referral of the Kilkenny City & Environs Development Plan, 2014 - 2020, and the opportunity to comment on emerging policies and the programme for development scheduled in the Draft Plan. The Authority provides the following comments for the Council’s consideration;

 

Strategic National Road Network

The Authority acknowledges the requirement for growth in Kilkenny and the identification of Kilkenny City as a Hub in the NSS.

The Authority attaches particular importance to the network of national roads continuing to play the intended strategic role in catering for inter-urban and inter-regional transport requirements that will serve Ireland’s return to economic competitiveness by providing faster, more efficient and safer access to and from our major ports, airports, cities and large towns.

The Council will also be aware of the priority to ensure adequate maintenance of the national road network in order to protect the value of previous investment outlined by Government in the ‘Infrastructure and Capital Investment 2012 – 2016: Medium Term Exchequer Framework’ (November, 2011).

The Council will note that the N77, national secondary route, although not referenced in Table 10.4 also serves the Draft Plan area.

The Authority welcomes the acknowledgement of the necessity to restrict access and junctions to the network to protect the investment made in the road network and to maintain it’s primary function, Section 10.4.3 refers.

 

Spatial Planning and National Roads Guidelines for Planning Authorities (DoECLG, 2012)

The Authority welcomes reference to the DoECLG Spatial Planning and National Roads Guidelines in Section 10.4.3 of the Draft Plan and the Councils commitment to follow the provisions of the Guidelines.

The Council will be aware that Government policy not only seeks to avoid access to national roads outside areas which are subject to reduced urban speed limits but also seeks to avoid the intensification of any existing access in such circumstances.

It is noted that lands adjoining the N10 on the Waterford Road are the only lands identified in the City & Environs Draft Plan that adjoin the national road network outside a location to which speed limits of 60kph or lower apply. The Authority welcomes the requirement that access to the lands will be dependent on an access alternative to the national road and the associated text outlined in Objective 10.4.6.

The DoECLG Spatial Planning and National Roads Guidelines do provide for circumstances where a less restrictive approach to the control of development accessing national roads may be applied in exceptions. It is noted that the Draft County Development Plan, 2014 – 2020, has identified three locations where such exceptions might apply; namely, Glanbia at Ballyragget (N77), Leggathsrath Roundabout on the M9 Link Road and the Belview Port Access Road (N29).

The County Council has identified in the Draft County Development Plan the intention to develop and agree a policy response to access at these locations with the NRA. As zoning designations at the Leggathsrath area are included in the City & Environs Draft Development Plan, the Council may consider it appropriate to align the provisions of the Draft City & Environs Plan with the Draft County Development Plan to ensure a consistent policy approach to development at this identified strategic location.

The Authority is available to liaise with the Executive of the Council to progress ‘exceptional circumstances’ in accordance with the provisions of Section 2.6 of the DoECLG Spatial Planning & National Roads Guidelines.

 

Strategic National Road Schemes

The Authority notes that there are a number of national road improvement proposals scheduled in the Draft Plan and while it is acknowledged that it is beneficial for the Council to schedule work programmes that it is proposed to deliver at a local level, the Authority advises that any improvements relating to national roads identified at a local level should be done so in consultation with and subject to the agreement of the NRA. The Council will be aware that the NRA may not be responsible for the funding of any such schemes or improvements.

The Council will be aware that the implementation of all national road schemes is subject to budgetary constraints and is subject to prioritisation and adequacy of the funding resource available to the Authority. In these circumstances and taking account of the difficult Exchequer financial position which we are currently experiencing, the relative priority or timeframe for national road schemes may be subject to alteration.

Other Transportation Measures

In relation to Cycling, Sections 6.4.2 and 10.1.2 refer, the Council will be aware of the National Cycle Network Scoping Study (2010) which has identified national cycling routes, some of which pass through Kilkenny. The Council may consider it relevant to address the Study in the Development Plan and/or provide for any potential future links that might arise from the study as Objectives of the adopted City & Environs Development Plan.

 

SPECIFIC POLICIES AND OBJECTIVES

Signage

While the Authority notes that Section 11.13 of the Draft Plan includes reference to the NRA Policy on the Provision of Tourist & Leisure Signage on National Roads (March 2011) no reference is made to the DoECLG Spatial Planning and National Roads Guidelines provisions relating to signage affecting national roads. 

 

With respect to the Draft Plan, the Planning Authority is referred to Section 3.8 of the DoECLG Spatial Planning and National Roads Guidelines which indicates a requirement to control the proliferation of non-road traffic signage on and adjacent to national roads. The Authority would welcome reference to Section 3.8 of the DoECLG Guidelines within the relevant sections of the Draft Plan in the interests of clarity.

 

Conclusion

The Authority acknowledges the significant undertaking for the Council in drafting a development plan and the requirement to consider and address a multiplicity of factors in developing a sustainable spatial planning framework not just issues relating to national roads. Notwithstanding this, the Authority acknowledges and welcomes the strong alignment in the Draft Plan with official policy concerning development planning and development management and national roads and compliments the Council in this regard.

It is requested that the foregoing comments and observations are taken into consideration in the adoption of the Kilkenny City & Environs Development Plan, 2014 – 2020.

As outlined above, the Authority is available to meet the Executive of the Council to discuss any issues arising in the foregoing or other matters related to the Development Plan and national roads.

 

Yours sincerely,

 

_____________________

Michael McCormack

Policy Adviser (Planning)