RE: SUBMISSION TO THE DRAFT KILKENNY COUNTY DEVELOPMENT PLAN 2014-2020
The Port of Waterford Company (POWC) welcomes the opportunity to participate in the review of the Kilkenny County Development Plan and the opportunity to comment on emerging policies and objectives in the Draft Plan 2014-2022. The following are the observations of the POWC in this regard.
Port of National Significance
The Port of Waterford at Belview is seen as a critical piece of infrastructure nationally, regionally and locally and its strategic importance is reflected in a number of national and regional policy documents. The NSS believes there is substantial potential for the enhancement of critical mass through the further expansion of the designated gateway of Waterford including the Port at Belview.
The National Ports Policy 2013 also contributes to that vision and identifies Belview Port as a Port of National Significance (Tier 2). The core objective of the National Ports Policy is to facilitate a competitive and effective market for maritime transport services. The South East Regional Planning Guidelines 2010-2022 also states that Belview Port is a significant access point to the region and it is of regional and national importance for import and export trade. The Guidelines further promote the potential that exists at Belview for the development of an industrial park of regional and national importance that should be exploited by developing it as a flagship location for regional industrial development initiatives.
The POWC welcomes reference to strengthening the role and status of the port nationally and regionally in Section 4.6.2 of the Draft Plan. The POWC also notes and welcomes the commitment outlined in the Draft Plan to deliver high speed broadband and to assist in the provision of natural gas supply to the Belview Port area within the lifetime of the plan.
Land Use Objectives
The POWC notes the commitment outlined in the Draft Plan to review the Ferrybank Belview Local Area Plan (LAP) in 2015 and looks forward to consultation in due course on the review of the LAP having regard to the strategic national and regional importance of Belview Port. The POWC is aware the land use zoning objectives pertaining to Belview Port are almost exclusively regulated by the Ferrybank Belview LAP and that there is very limited scope to influence the zoning objectives of the site during this current review process.
Nonetheless, the POWC is concerned about the policy constraints presented by the extant ‘Belview Residential Amenity’ and ‘Passive Open Space/Green Links and Biodiversity Conservation’ zoning objectives present on the site.
Whilst the POWC accepts that the policy rationale of the ‘Belview Residential Amenity’ zoning objective is to protect existing residences in proximity to Belview Port, the POWC contends that there should be no net increase in residential development in this area. Indeed, the POWC would also argue that regardless of this zoning objective, residential amenity as a material planning consideration would be secured following the assessment of any future planning application in this area.
The POWC contend that in order to meet the core objective of national port policy (i.e. to facilitate a competitive and effective market for maritime transport services), the zoning objectives of the Port need to be flexible in terms of accommodating the expansion of port related development and specialist industries in the area. Whilst the retention and provision of significant amounts of passive open space within the LAP area, where appropriately justified, is commended, the POWC is concerned that the irregular pockets of designated ‘Passive Open Space/Green Links and Biodiversity Conservation’ impedes the development of a coherent masterplan to enable the Port to achieve its full potential. In this regard, the POWC would also wish to have the extant areas of ‘Passive Open Space/Green Links and Biodiversity Conservation’ within the area reconsidered as part of the LAP review process so as to facilitate the future development of Belview Port in a coherent manner.
N29 Traffic Management
The POWC acknowledges that the Council has identified in the Draft Plan the intention to develop and agree a policy response for access to Belview Port from the N29 national route with the NRA.
Section 2.6 of the Spatial Planning and National Roads Guidelines provides for exceptional circumstances, where planning authorities may identify stretches of national roads where a less restrictive speed limit may be applied. Such a less restrictive approach may be adopted in the case of developments of national and regional strategic importance, which by their nature are most appropriately located outside urban areas, and where the locations concerned have specific characteristics that make them particularly suitable for the developments proposed. As set out in the Regional Planning Guidelines, Belview Port is of strategic importance to the region. Given the site’s location and strategic importance, Belview Port satisfies the criteria of exceptional circumstances set out in Section 2.6 of the Spatial Planning and National Roads Guidelines.
The POWC supports the intention of the Planning Authority to develop and agree a less restrictive speed limit policy for the N29 in this location in conjunction with the NRA.
Engaging with the Planning System
The relationship and interaction between the commercial ports sector and the planning system is extremely important in ensuring continued sustainable development of the ports sector. National policy encourages port companies to engage with the relevant planning authorities to ensure that port masterplans and relevant planning and development strategies are complementary and consistent. The POWC confirms its commitment and availability to work collaboratively with the Council to progress the development of a strategic development framework and masterplan for Belview Port.
Foreshore and Marine Area Development Bill
The Council will also be aware that the current Programme for Government contains a number of commitments in relation to the marine sector and in particular the foreshore consent regime, including the development of an integrated marine and coastal planning process; key elements of which are intended to be advanced by the development of legislation in the form of a Foreshore and Marine Area Development Bill.
The main purpose of the proposed Foreshore and Marine Area Development Bill will be to modernise the current foreshore consent regime for certain projects and management of development activities on the foreshore. It proposes to do this by integrating the foreshore consent process within the existing consent system under the Planning Acts 2000-2012.
At present the Planning and Development Acts provide for a discretionary development plan objective in relation to “regulating, restricting, and controlling development on the foreshore”. The Foreshore and Marine Area Development Bill proposes that any new legislation would require mandatory objectives within the Development Plan relating to managing all aspects of the coastal zone, including both terrestrial and marine elements. POWC supports a plan-led approach to development on the foreshore and as outlined above, the POWC is available to work collaboratively with the Council to develop these objectives for managing the coastal zone, under any new legislation which may emerge in this regard.
It is requested that the foregoing comments and observations are taken into consideration in the review and subsequent adoption of the Kilkenny County Development Plan, 2014 – 2020, and we would welcome the opportunity to discuss any of the points raised.
Yours sincerely
SLR Consulting Limited
Aislinn O’Brien
Associate
