25 July, 2013 NRA13-88258
Dear Sir/Madam,
The Authority welcomes referral of the Kilkenny Draft County 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 and the identification of other key towns and settlements in the County in the Regional Planning Guidelines for the South East Region, 2010 – 2022.
The Council will also be aware that the National Spatial Strategy identifies the M9 (and M8), national primary roads, as strategic radial corridors and the N24 as a strategic linking corridor. In addition, the Regional Planning Guidelines identify the N10, N25, N29, N76, N77 and N78, national roads, as main access routes in the region.
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. National roads also have an important function in particular areas by providing access to more remote communities that may be served by a limited local or regional road network.
Given the level of reliance of Ireland on international trade and export markets, the Authority supports the development of policies and objectives that promote the objective of maintaining and protecting the safety and efficiency of national roads given their central role in catering for business travel and movement of goods to key markets, ports and airports.
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).
Having regard to the foregoing, 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 11.7.2 refers. Given the importance of the national road network and it’s required identification on Core Strategy mapping, the Council may consider it appropriate to also outline the important strategic role of the national road network for Kilkenny in the text of the Core Strategy.
Spatial Planning and National Roads Guidelines for Planning Authorities (DoECLG, 2012)
With reference to the foregoing, the Authority welcomes reference to the DoECLG Spatial Planning and National Roads Guidelines in Section 11.7.3 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.
In the interests of clarity, the Authority would welcome a cross reference of the policy position outlined in Section 11.7.3 to avoid the creation of any additional access point from new development, or the intensification of existing access, to national roads to which speed limits greater than 60kph applies with the Sections of the Draft Plan that address development types that may have the potential to generate a demand for frontage development on national roads, for example, Section 3.5.2 Rural Housing Policy (and Section 12.10), Section 4.6.4 Enterprise and Employment in Rural Areas, Sections 6.2, 6.4 and 6.5, Agriculture, Extractive Industries and Forestry, Section 7.9.3 Integrated Rural Tourism and Sections 10.5 and 10.6, Wind Energy and Bio-Energy.
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.
The Authority notes that specific locations have been identified in the Draft Plan; namely, Glanbia at Ballyragget (N77), Leggathsrath Roundabout on the M9 Link Road and the Belview Port Access Road (N29). The Authority acknowledges that the Council has identified in the Draft Plan the intention to develop and agree a policy response to access at these locations with the NRA. Further to previous discussions concerning these sites with the Council, the Authority confirms its commitment and availability to continue to work 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.
The Authority recommends alignment between the Draft County Development Plan, 2014 – 2020, and the Draft City & Environs Development Plan, 2014 – 2020, concerning the potential for developing ‘exceptional circumstances’ for lands at Leggatsrath as the Draft City & Environs Development Plan does not appear to address this matter.
The Authority notes the commitment outlined in the Draft Plan to review the Ferrybank/Belview Local Area Plan in 2015 and looks forward to consultation on the review of the Local Area Plan having regard to the strategic nature of the national road network in this area.
Strategic National Road Schemes
The Authority welcomes the inclusion of NRA national road schemes in Section 11.7.6 and the associated objectives to support the implementation of relevant schemes and to reserve alignments/improvement lines and corridors free from development that would prejudice the road proposals outlined in Section 11.7.8.1.
The Authority notes that there are a number of other road improvement proposals scheduled in 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.
Services Areas
The Authority notes the proposed objective, Section 11.7.8.2, to co-operate with the NRA to identify the need for service areas and/or rest areas for motorists along the M8 and M9 and to assist in the implementation of suitable proposals. The Council will be aware that Section 2.8 of the DoECLG Spatial Planning and National Roads Guidelines indicate the requirement for a forward planning approach to the provision of off-line motorway service areas at national road junctions and also addresses road side service facilities on non-motorway national roads and their junctions. It is recommended that proposals for off-line services and service stations are considered in the context of the DoECLG Guidelines and that this would be reflected in any amendments to the Draft Plan. Section 12.10.13 of the Draft Plan also refers.
Other Transportation Measures
In relation to other planned transport measures, the Authority notes proposals concerning the provision of Park & Ride facilities (Section 11.3.2) and requests consultation on proposals in this regard where there may be implications for the strategic national road network.
In relation to Cycling, Sections 7.3.2 and 11.1.1 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 County Development Plan.
SPECIFIC POLICIES AND OBJECTIVES
Signage
While the Authority notes that Section 12.10.11 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 County 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,
_____________________
Tara Spain
Senior Policy Adviser (Planning)
