Planning Policy Unit,
Cork County Council,
County Hall,
Cork.

21st November, 2019.

To whom it may concern.

Please consider this submission as my strong objection to the proposed Variation No. 2 of the Cork County Development Plan 2014.

1. National and regional policy as outlined in the National Planning Framework 2018, the South West Regional Planning Guidelines 2010, the South East Regional Planning Guidelines and the Southern Region Spatial & Economic Strategy 2018 (in draft) all contain one clear message with regard to the primacy of urban centres as regional and metropolitan drivers, compact and sustainable development, a focus on regeneration and, particularly in the context of the draft DSRSES, the importance of retail in enhancing the vibrancy and vitality of urban centres, large and small. The proposed Variation No. 2 does not support these national and regional policy aims.
2. The Guidelines for Planning Authorities – Retail Planning (2012) also place a clear priority on developing all aspects of the vibrancy and vitality of urban centres. They encourage a sequential approach to retail planning. They have a general presumption against retail outlet centres and caution how they can negatively affect existing retail centres with the possible exception of a their establishing a beneficially synergistic relationship with an adjacent urban centre should they be developed immediately adjacent to that urban centre. In the case of the ROC that Variation No. 2 would facilitate, that means that, at best, Carrigtwohill or Midleton may benefit to the detriment of Cork City and other county towns. This is contrary to the aims of the national retail planning guidelines.
3. The most recent Metropolitan retail policy for Cork is the Metropolitan Cork Joint Retail Strategy 2015. It has a stated policy of maintaining Cork City Centre as the primary location for comparison shopping and that if proposals in locations outside the city centre are being considered for comparison development, the potential implications for the regeneration of key opportunity sites in the city centre need to be considered. Although 45% of the custom for the proposed ROC that would be enabled by Variation No. 2 is estimated as originating from the city, those potential implications have not been considered as part of the Study on the Requirement for Retail Outlet Centres in the Cork Metropolitan Area (SRROCCMA).
4. The Joint Retail Strategy 2015 states that when considering the future allocation of comparison floorspace, regard must be had to the extent of existing vacancy within the core areas of towns in the Metropolitan area. An examination of existing vacancy did not form any part of the SRROCCMA. The Study simply states that the necessary data was not available to undertake a health check of town centres. It quotes vacancy data for Cork City Centre from 2014 – 2017. The basic information on commercial vacancy available through Geodirectory is as recent as Q2 2019 for Cork City Centre and for a number of other Metropolitan towns.
5. TCR 9-1 of the Cork County Development Plan 2014 has an objective of reducing the amount of vacant floorspace in core retail areas by 50% in the short term. This objective has not been close to achieved. According to Geodirectory, in Q2 2014 Cork’s commercial vacancy rate was 11.5%. In Q2 2019, again according to Geodirectory, Cork’s commercial vacancy rate was 11.6%. Overall vacancy in Munster is calculated at 12.9%. Vacancy in Co. Kerry is up from 9% in Q2 2014 to 10.6% in Q2 2019. Vacancy in Counties Limerick and Waterford is similarly up in the same period from 13.9% to 15.3% and from 13.3% to 14.1% respectively.
6. The SRROCCMA indicates the threat that an ROC could pose to current and future retailing in urban centres throughout the region. Whilst the level of available expenditure within the catchment is calculated to help justify an ROC in Metropolitan Cork, the reality is that in the absence of an ROC, that available expenditure would be spent in retail outlets in urban centres. The SRROCCMA predicts that 45% of trips to an ROC in Carrigtwohill/Midleton would come from Cork City. This would clearly impose a negative impact on the primacy of Cork City Centre for comparison retailing. Similarly if (as identified in Paragraph 3.4.3 of the SRROCCMA) passengers on visiting cruise liners spend an average of 42% of their money on shopping, an ROC adjacent to the Cobh cruise terminal would be in direct competition with existing town centre retail outlets.
7. Our town centres are our greatest assets. All of our county towns have mammoth potential to fill the retail and tourism roles that Variation No. 2 proposes for this ROC. Given the funding, support and opportunity, all of them could do so in a way that is in accordance with stated national and regional policy. Paragraph 3.4.4 of the SRROCCMA notes that while the Cork Strategic Tourism Task Force report identifies plenty of visitor attractions throughout the county, it also considers that there is a general lack of awareness of the county’s assets. In my opinion, Cork County Council’s finances and energies would be far better placed in enhancing those visitor attractions and building awareness than in supporting the development of a new retail attraction that has the potential to impact negatively on existing attractions and town centres.
8. An ROC would be an entirely car-focused development. The SRROCCMA assumes it would serve a catchment delineated by a two-hour drive time. The modal split assumes the same 90% car share profiled in the Kildare Tourist Village Outlet. In this time of acute climate awareness, to encourage development that relies so heavily on the private car is entirely contrary to national policy. The introduction to Cork County Council’s own Budget 2020 states that “climate change is the defining issue of our time and it is a problem which requires commitment from all parties to an integrated approach to address the challenges posed”.
9. The SRROCCMA contains no assessment of the carbon impact associated with an ROC development. Yet earlier this month, all local authorities in Ireland signed a charter committing to decarbonising their activities, pursuing sustainable development and putting in place a process for carbon-proofing decisions, programmes and projects. There is no indication of this commitment here.
10. This proposed Variation has effectively received no meaningful Strategic Environmental Assessment. In the SEA Screening, it is stated more than once that “the proposed Variation will not give rise to any environmental effects”. The SRROCCMA predicts that the ROC enabled by the Variation would potentially generate some 35,000 customer trips each week. Again, in this time of climate sensitivity, this is a very clear and significant environmental effect. It is not acceptable to consider adopting the proposed Variation No. 2 without calculating the carbon impact associated with the ROC that the Variation is enabling.
11. Only one of the bodies consulted in the course of the SRROCCMA is supportive of the concept of a ROC in Metropolitan Cork. All but that one have expressed the same concerns I have outlined above.
12. My interpretation of paragraph 2.6 of the SRROCCMA is very clear: the Study’s relatively comprehensive policy review reaffirms that the city/town centre is a priority for new retail development. That policy is also in accordance with advice outlined in the Retail Policy Guidelines. However, if an ROC were to be introduced in Metropolitan Cork in contravention of national, regional and retail policy, because Cork County Council adopted Variation No. 1 in 2018, the ROC would be in accordance with local planning policy objectives. The reference to ROCs in Variation No. 1 was presented as three pages within a 52 page document, the first 39 of which deal specifically with housing-related matters. If those three pages pertaining to ROCs are contrary to national retail policy, we as a Council need to re-examine them in the context of the forthcoming review of the County Development Plan.
13. Variation No. 1 commits Cork County Council to undertaking a “detailed evidence-based assessment” to confirm the need for an ROC. In its failure to include any consideration of existing commercial vacancy in either town centres or in Cork City Centre, the SSROCCMA fails to fulfil this commitment. Also, in failing to undertake any meaningful SEA of the environmental impacts including carbon footprint of a potential ROC, Cork County Council is in breach of the requirements of Directive 2001/42/EC as transposed and as amended.
14. Finally, I cannot let this submission pass without commenting on the SRROCCMA’s reference to my own town of Passage West. Despite the ongoing efforts of its residents and businesses, Passage West exhibits extensive dereliction and commercial vacancy. The SRROCCMA explains this “decline” as being “due to the loss of traditional industries and the dockyards”. The dockyard and its associated industries were in decline since the 1870s and although the Royal Victoria Dockyard is still an operating entity under the ownership of the Doyle Shipping Group, shipbuilding ceased in 1931. That is nearly a century ago. We long for regeneration of our town centre, we work continually to improve its appearance and we are forever frustrated by Cork County Council’s ongoing reluctance to use both its powers of Compulsory Purchase and the Derelict Sites Act to help clean up our built heritage. We long for an architect-assisted streetscape enhancement that will encourage tourists to stop in our waterside town. We long for holistic management of Cobh and Passage West such that even some of the cruise passengers might make their way across the West Passage to engage with some the rich maritime heritage our town proudly boasts. We long for Cork County Council to grasp the potential of our town and work energetically with us to realise even some of what it could offer. That the SRROCCMA attributes our town’s lack of commercial activity to events which are now a century old is a very strong illustration of the need for the Council’s time and energy to be focused on building up its existing town centres, not on facilitating the development of an ROC.

Yours faithfully,

Marcia D’Alton
Independent Member, Cork County Council