Re: SUBMISSION ON THE DRAFT KILKENNY CITY AND ENVIRONS DEVELOPMENT PLAN 2014 - 2020
1.0 INTRODUCTION
1.1 On behalf of our client, Aldi Stores (Ireland) Ltd, Newbridge Road, Naas, Co. Kildare, we hereby make a submission Draft Kilkenny City and Environs Development Plan 2014 – 2020 as it relates to lands in the ownership of our client at Waterford Road, Kilkenny.
1.2 The site is currently zoned for residential purposes within the existing 2008-2014 Kilkenny City and Environs Development Plan with an objective to “protect, provide and improve residential amenities”. Given the current lack of demand for residential development, it is considered that a ‘General Business’ zoning on the site would be more appropriate. This submission requests that a ‘General Business’ zoning should be considered for this site and the specific objective Z7 be removed in the forthcoming City and Environs Development Plan
1.3 The subject site is located at the junction of the Waterford Road and the Bohernatounish Roads approximately 1 km to the southeast of the City Centre core retail area. Part of the site is currently occupied by an Aldi discount foodstore, the remainder of the site remains undeveloped. The area in the vicinity of the site is primarily urban with the predominant land uses being residential and commercial.
1.4 The site is currently zoned for residential purposes within the existing 2008-2014 Kilkenny City and Environs Development Plan with an objective to “protect, provide and improve residential amenities”. The lands are also subject to specific objective Z7 of the Plan which outlines that:
“Having regard to the location of the land at the junction of Waterford Road (Regional Road), Bohernatounish Road and Nuncio Road and notwithstanding the residential zoning on the site, development at this location shall include a mix of uses such as shop, crèche, medical centre, other non-retail uses such as personal and professional services along with office use. The proportion of non-residential uses can be greater than that of residential but in the mix of uses proposed on the land there shall be a significant proportion devoted to residential use. Any development proposal on this site shall address the entire block”.
1.5 Under Register Reference 09/318 planning permission was granted for the development of an Aldi discount foodstore, associated signage and car parking on the subject site. This development has been implemented on the site.
1.6 The residential zoning objectives as set out within the 2008 City and Environs Development Plan is carried forward to the 2014 Draft Plan. Specific Objective Z7 of the draft plan is reworded as follows to reflect the development of the discount foodstore on the site:
“Having regard to the location of the land at the junction of Waterford Road (Regional Road), Bohernatounish Road and Nuncio Road and notwithstanding the development of a discount retail store on the lands and having regard to residential zoning on the site, further development at this location can include for a mix of uses such as crèche, medical centre, other non-retail uses such as personal and professional services along with office use. The proportion of non-residential uses can be greater than that of residential but in the mix of uses proposed on the land there shall be a significant proportion devoted to residential use. Any development proposal on this site shall address the entire block. No additional retailing shall be considered for the site”.
1.7 It is respectfully submitted that the Kilkenny City and Environs Development Plan 2014 – 2020 should ensure that the policies, objectives and zoning of un-used or under-utilised residual land adjacent to existing discount foodstores or other retail or commercial development is reviewed and is subject to an appropriate zoning objective which would allow for complementary and viable uses, such as offices, café, etc. to be delivered.
1.8 It is respectfully submitted that lands which present these development opportunities, such as those adjoining the Aldi site at Waterford Road, should not be subject to specific objectives requiring the delivery of residential development.
1.9 The development of an Aldi discount foodstore on lands in the ownership of our client at Waterford Road Kilkenny has resulted in residual lands that may be appropriate for future commercial development. However the residential zoning objective pertaining to the site as set out within both the existing and draft City and Environs Development Plan together with the Z7 specific objective envisage the future development of the residual lands for residential development.
1.10 The retention of this specific objective requiring a significant amount of residential development would be likely to leave the development of the residual lands unviable and would result in the sterilisation of the lands for the foreseeable future. Given the current lack of demand for residential development, it is considered that a ‘General Business’ zoning on the site would be more appropriate. Uses such as café, restaurant or medical uses, would be more viable uses in this current economic climate. Our client has been in contact with a coffee shop operator who has an interest in the site subject to the appropriate planning framework being in place to support this format of development on the lands.
1.11 In this regard this submission requests that a ‘General Business’ zoning should be considered for this site and the specific objective Z7 be removed in the forthcoming City and Environs Development Plan. This zoning is in accordance with the zoning objectives of the existing Lidl discount foodstore and mixed use development in the vicinity of the site.
1.12 It is furthermore requested that the use “coffee shop” is listed as a uses which is “permitted in principle” on lands zoned for General Business purposes within the forthcoming City and Environs Development Plan. In this context it is noted that the vast majority of lands within Kilkenny City are zoned for General Business purposes and it is considered that a “coffee shop” use is clearly a form of development which would be appropriate for the City Centre. The use “coffee shop” is currently only listed as a permitted use on lands zoned for Neighbourhood Centre purposes.
2.0 Site Location and Description
2.1 The subject site is located at the junction of the Waterford Road and the Bohernatounish Roads approximately 1 km to the southeast of the City Centre core retail area.
2.2 Part of the site is currently occupied by an Aldi discount foodstore and the reminder of the site remains undeveloped. The location of the Aldi discount foodstore site on Waterford Road and the residual lands in the ownership of Aldi at this location are identified on Figure 2 below.
2.3 The area in the vicinity of the site is primarily urban with the predominant land uses being residential and commercial. The site is located adjacent to a Lidl discount foodstore (at the opposite side of the Waterford Road), opposite Castle Downs, with additional road frontage to Nuncio Road and Bohernatounish Road. The Loughboy Shopping Centre is located a short distance further to the east to site. Loughboy Shopping Centre is a neighbourhood centre, anchored by a Supervalu supermarket.
3.0 PLANNING HISTORY
Register Reference 09/318
3.1 Under Register Reference 09/318 planning permission was granted for the development of an Aldi discount foodstore, signage and associated car parking on part of the subject site in accordance with the following reasons and considerations:
“Having regard to the current Kilkenny City and Environs Development Plan 2008-2014, to Zoning Objective Z7 pertaining to the site, the review of the Kilkenny City & County Retail Strategy, to the use and design of the proposed development, referral reports on the file and all other material considerations, it is considered that the proposed development, subject to conditions, would not seriously injure the amenities of the area and would therefore be in accordance with the proper planning and sustainable development of the area”.
3.2 An indicative Masterplan for the remainder of the site was submitted in conjunction with this planning application. Future uses which were indicated on the lands included a medical centre and residential development.
4.0 KILKENNY CITY AND ENVIORNS DEVELOPMENT PLAN 2008-2014
4.1 The subject site is located within the administrative area of Kilkenny County Council. The statutory development plan for the area is the Kilkenny City and Environs Development Plan 2008-2014.
Zoning Objectives
4.2 The subject site is zoned for residential purposes with an objective to “protect, provide and improve residential amenities”.
4.3 The lands are also subject to specific objective Z7. In this regard the development highlights that:
“Having regard to the location of the land at the junction of Waterford Road (Regional Road), Bohernatounish Road and Nuncio Road and notwithstanding the residential zoning on the site, development at this location shall include a mix of uses such as shop, crèche, medical centre, other non-retail uses such as personal and professional services along with office use. The proportion of non-residential uses can be greater than that of residential but in the mix of uses proposed on the land there shall be a significant proportion devoted to residential use. Any development proposal on this site shall address the entire block”.
5.0 DRAFT KILKENNY CITY AND ENVIRONS DEVELOPMENT PLAN 2014-2020
5.1 The subject site retains its residential zoning within the 2014 Draft City and Environs Development Plan.
5.2 The following range of uses are listed as “permitted” and “open for consideration” on lands zoned for residential purposes:
“Permitted Uses: Dwellings, open spaces, places of worship, community facilities, halting sites, public service installations, childcare facilities, nursing homes, bed and breakfast establishments and guesthouses, home-based economic activity, parks and open spaces, playing fields, local convenience shop, nursing homes, and medical centre”.
“Open for Consideration: public house, hotel, restaurant”.
5.3 The site is also subject to specific Objective Z7 within the Draft Plan. This specific objective sets out the following guidance for the future development of the site:
“Having regard to the location of the land at the junction of Waterford Road (Regional Road), Bohernatounish Road and Nuncio Road and notwithstanding the development of a discount retail store on the lands and having regard to residential zoning on the site, further development at this location can include for a mix of uses such as crèche, medical centre, other non-retail uses such as personal and professional services along with office use. The proportion of non-residential uses can be greater than that of residential but in the mix of uses proposed on the land there shall be a significant proportion devoted to residential use. Any development proposal on this site shall address the entire block. No additional retailing shall be considered for the site”.
6.0 GROUNDS OF SUBMISSION
6.1 It is submitted that the Kilkenny City and Environs Development Plan 2014 – 2020 should ensure that the policies, objectives and zoning of sites adjacent to retail and commercial developments is appropriate, particularly where residual lands remain following the development of a discount foodstore or other development.
6.2 It is respectfully submitted that a systematic review of zoning objectives should take place to ensure that residual or under-used lands are subject to an appropriate zoning objective which would facilitate their future development, particularly where such sites offer good connections to, and potential synergy with, existing retail facilities.
6.3 It is respectfully submitted that residual lands such as lands in the ownership of our client at Waterford Road would more appropriately be zoned for commercial purposes, and in this regard it is considered that a ‘General Business’ zoning on the site would be appropriate.
6.4 Reg. Ref: 09/318 identified Phases 2 and 3 of the development of these lands to include a medical centre and residential development on the subject site. Given the current lack of demand for residential development, it is considered that a ‘General Business’ zoning on the site would be more appropriate. Such a zoning would allow for the delivery of uses such as the medical centre, and would allow the consideration of other uses such as offices and restaurant which would offer synergy with the adjacent discount foodstore and Loughboy Shopping Centre and other neighbouring uses.
6.5 The retention of this specific objective requiring a significant amount of residential development on the subject site would be likely to leave the development of the residual lands unviable and would result in the sterilisation of the lands for the foreseeable future. Uses such as café, restaurant or medical uses, would be more viable uses in this current economic climate. Our client has been in contact with a coffee shop operator who has an interest in the site subject to the appropriate planning framework being in place to support this format of development on the lands.
6.6 Having regard to the above, it is respectfully submitted that the Kilkenny City & Environs Development Plan 2014 – 2020 should ensure that un-used or under-utilised lands within the plan area which are well related to existing retail or commercial development, should be subject to appropriate zoning objectives which would allow their location to be utilised and for an appropriate range of services to be provided for the catchment community, and should not be subject to specific objectives requiring the delivery of residential development.
6.7 It is respectfully submitted that the site in the ownership of our client at Waterford Road is zoned for “General Business” purposes within the forthcoming Development Plan to allow the development of the residual lands to be utilised to their full potential and for synergy to be created with existing adjoining development. The specific objective Z7 should be removed from the Waterford Road site.
6.8 It is furthermore requested that the use “coffee shop” is listed as a uses which is “permitted in principle” on lands zoned for General Business purposes within the forthcoming City and Environs Development Plan. In this context it is noted that the vast majority of lands within Kilkenny City are zoned for General Business purposes and it is considered that a “coffee shop” use is clearly a form of development which would be appropriate for the City Centre. The use “coffee shop” is currently only listed as a permitted use on lands zoned for Neighbourhood Centre purposes.
7.0 SUMMARY AND CONCLUSIONS
7.1 This submission is made on behalf of our client, Aldi Stores (Ireland) Ltd, Newbridge Road, Naas, Co. Kildare as it relates to lands in their ownership at Waterford Road, Kilkenny.
7.2 It is respectfully submitted that the Kilkenny City and Environs Development Plan 2014 – 2020 should ensure that the policies, objectives and zoning of un-used or under-utilised residual land adjacent to existing discount foodstores or other retail or commercial development is reviewed and is subject to an appropriate zoning objective which would allow for complementary and viable uses, such as offices, café, etc. to be delivered.
7.3 It is respectfully submitted that lands which present these development opportunities should not be subject to specific objectives requiring the delivery of residential development.
7.4 The development of an Aldi discount foodstore on lands in the ownership of our client at Waterford Road Kilkenny has resulted in residual lands that may be appropriate for future commercial development. Our client has been in contact with a coffee shop operator who has an interest in the site subject to the appropriate planning framework being in place to support this format of development on the lands. The purpose of this submission is to ensure that the appropriate planning framework is in place to support the future development of the lands.
7.5 The existing residential zoning objective pertaining to the site as set out within both the existing and draft City and Environs Development Plan together with the Z7 specific objective envisage the future development of the residual lands for residential development.
7.6 The retention of this specific objective requiring a significant amount of residential development would be likely to leave the development of the residual lands unviable and would result in the sterilisation of the lands for the foreseeable future. Uses such as café, restaurant or medical uses, would be more viable uses in this current economic climate.
7.7 In this regard this submission requests that a ‘General Business’ zoning should be considered for this site and the specific objective Z7 be removed in the forthcoming City and Environs Development Plan.
7.8 It is furthermore requested that the use “coffee shop” is listed as a uses which is “permitted in principle” on lands zoned for General Business purposes within the forthcoming City and Environs Development Plan.
7.9 It would be appreciated if this submission could be taken into account in the preparation of Amendments to the Kilkenny City and Environs Development Plan 2014 – 2020.
