Category Archives: Personal Submissions

My submission to planning application 19/6562 for development of 40 No. apartments in 2 separate 3 and 4 storey blocks at Drake’s Point, Knocknagore, Crosshaven, Co. Cork

This was a planning application lodged by O’Flynn Construction. O’Flynn’s has been developing Drake’s Point since 2017. Much local concern has been expressed about the proximity of earthworks to some magnificent and very mature trees close to the development and on the edge of Crosshaven Woods. I have been trying to engage with the planning department of Cork County Council to improve protection of these trees for many months without success. O’Flynn’s proposed apartment development is also to be adjacent to mature trees. I prepared this submission in the hope of a) finally getting a response from the planning department and b) helping to prevent against a repeat of the disregard for mature trees that we have observed to date. The workload being particularly heavy in this recent period, I lodged my submission by email on the closing date (28th November). Having confirmed in advance with Cork County Council that my submission would be valid if received by them before midnight, I sent it at 22:41. However Cork County Council refused to accept it as valid, saying that their server indicated that my submission was received at 03:43.

Submission to proposed material variation No. 2 of the cork county development plan 2014 (as varied)

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

Irish Water’s consultation on selecting sludge hubs

Irish Water Uisce Éireann has just finished a public consultation on what has the unattractive title of “Site Selection Methodology Report for Sludge Hub Centres”. Seriously not a title that is likely to attract public interest. Parts of it are equally dry to wade through to the extent that even I, with a background in this area, found the going tough.

That old maxim that matter cannot be destroyed but is converted from one form into another was never truer than for wastewater. The byproduct from sewage or any other form of wastewater treatment is sludge. Managing that sludge is the least spoken about part of wastewater treatment.

Sludge from municipal wastewater is organic and, as long as one is careful about what goes into the sewer, can be reasonably clean. In Ireland we haven’t developed many options for how to deal with it. Being nutrient-rich, sludge from urban centres is generally reused as a fertiliser in agriculture (with a whole dose of quality control measures attached). Sludge from chemical-based industries wouldn’t be an equally nice product and is usually either sent to landfill or burned.
Before being used in agriculture, sludge must be treated to pasteurisation standard so it is guaranteed to be disease-free. This involves expensive capital works and so treatment is most financially viable in big centres or “sludge hubs”.

Irish Water proposes to centralise treatment of all municipal sludge arising in Counties Cork and Kerry in one (or maybe two) sludge hubs. The three locations being evaluated to perform as these sludge hubs are 1) Carrigrennan (Little Island), 2) Tralee and (yes, you guessed it!) 3) Shanbally. The consultation wasn’t about this approach or about where the sludge hubs might be but rather about what factors each of these three locations might be evaluated against to see which was best. I call that public consultation Irish-style and am sick to the teeth of it. Where is the environmental logic in transporting sludge from places like Castletownbere to here??? This brings the concept of centralisation to a whole new level.

My submission to the consultation is here …

My submission to the Further Information request on the proposed Ringaskiddy incinerator

An Bord Pleanála invited Indaver Ireland to submit Further Information on their planning application for a proposed incinerator in Ringaskiddy.

Specifically, the Board asked Indaver to address:

  1. “Possible discrepancies” in the dioxin modelling data
  2. The Department of Defence’s submission which stated that the incinerator would impact on helicopter navigation safety at the Haulbowline Island Naval Base.

Indaver submitted a number of reports in response to this Further Information: one from their air modelling expert, another from their dioxin modelling expert, one from an academic which peer-reviewed the work of the dioxin modelling expert, one from their aviation consultant, another from a new aviation consultant and a report on a site visit to a UK Naval Base with helicopter capability immediately adjacent to an operational incinerator.

Because this information was deemed to be significant, the Board threw it open to the public for their comments.  Today was the last day by which those comments would be received.

There have been some wonderfully competent submissions made by CHASE and others, the import of at least some of which will undoubtedly leak out over the next few weeks.  Below is a link to my own.  It poses deeply concerning questions about the air dispersion modelling carried out by Indaver to which I would dearly love – but will probably never get – answers.

Submission to ABP, 21-07-2017

My submission to the consultation on the National Clean Air Strategy

Another gruesomely last minute submission to what was too important a consultation not to have an input to.  Submissions on the National Clean Air Strategy were invited by the Department of Communications, Climate Action and the Environment.  It would be rewarding if even some of the actions asked for below were given credence in the final Strategy.

From:
Cllr Marcia D’Alton
22 Hillcrest,
Pembroke Wood,
Passage West,
Co. Cork.

To whom it may concern

I should be grateful if the following comments would be taken into account in the drafting of the National Clean Air Strategy.

All Environmental Impact Statements accompanying planning applications should be required to measure down to at least PM1.  At present, planning applications rarely discuss particulates smaller than PM2.5.

Establish a network of units monitoring air pollution in real time so that communities can be informed of air quality in their local area.  At present, the network of real time monitoring is abysmal and not at all in compliance with Ireland’s requirements under European legislation.  Critical parameters would include PM10, PM2.5, PM1 and ozone.  Real time results would be made fully accessible to all through the internet.

Install comprehensive ambient air monitoring units in all Strategic Employment Areas and zones of industrial development.

Through the planning process, establish a minimum acceptable distance of 300 metres between schools and busy roads.

Develop a policy of constructing ring roads around cities, thereby keeping traffic from travelling unnecessarily through residential areas.  Urban motorways through residential areas must be discouraged at all costs.  As mentioned in the discussion document, residential areas already deal with the build-up of residential pollutants.  It is absolutely unacceptable that they would also have to deal with pollutants from traffic on urban motorways.

Encourage dense planting of mature trees along major roads to act both as a visual/psychological barrier between traffic and residential homes and as a pollutant sink.

Extend the financing of significantly enhanced public transport to areas outside of Dublin.  At present, many living in suburban homes in cities outside of Dublin cannot take their cars off the road long enough to get them valeted.  A congestion charge as suggested in the discussion document would be entirely unacceptable when no reasonable alternative to the private car is on offer.  That is the case for those living in most urban areas outside of Dublin.

Facilitate the development of cycling as a real alternative to the private car.  Policy and funding needs to stop considering cycling within periurban as recreational.  In my Ballincollig-Carrigaline Municipal District of County Cork, greenways compete for the same tiny funding pot as tourism routes such as the Waterford Greenway.  Yet the level of bicycle/pedestrian traffic they are expected to carry in what are generally more restricted spaces is vast multiples of that which the more rural routes carry.  They need separate consideration and additional, dedicated investment.

Most major ports are adjacent to residential areas.  Yet there is never any independent ambient air monitoring to assuage affected residents.  This is especially critical for ports handling bulk cargo.  It is imperative that all major ports would be obliged to install real-time ambient air monitoring to measure parameters representative of the by-products of engine and generator emissions.  It is equally imperative that all ports, regardless of size, which handle bulk cargo would be obliged to install real-time monitoring to measure levels of particulate in ambient air.

Shoreside electrical power to be provided at all ports which ships berthing overnight should be obliged to use in preference to their own generators.

Often the most polluting offenders in a port situation are partner companies conveying, handling and storing dusty bulk cargo in warehouses and grain stores adjacent to the port.  These companies are not subject to any form of monitoring either by the Environmental Protection Agency or the local authority.  Nor at the time of planning application are they considered to be potential pollutors under the Air Pollution Act.  This must change.

Disappointing to see that waste to energy gets only a glancing mention in the discussion document.  National waste policy sets an upper acceptable limit for the combined capacity of waste to energy facilities to be provided in Ireland.  Taking both constructed and permitted facilities into account, this national upper capacity limit has been reached.  Therefore in accordance with current waste policy, planning permission should not be granted for any additional waste to energy facilities in Ireland.  Energy from the combustion of residual waste is not clean energy.  Feedstock is unpredictable and dirty.  Emissions quality is utterly dependent on the efficacy of a series of scrubbers and other pollution control equipment.  Energy conversion into electricity is grossly inefficient.

European policy is that waste combustion in incinerators must always be classified as waste disposal (D10) unless it can prove that it is energy recovery (R1).  In Ireland, we grant planning permission to incinerators merely on the promise of their delivering R1.  It is essential that Irish policy reflects European policy in this regard and that the infrastructure necessary to efficiently use both the heat and electricity generated by the waste combustion process would form an integral part of the planning application for any new incineration facility.

Vastly improved resourcing for local authorities to carry out their functions under the Air Pollution Act is essential.  At present, they are barely struggling.  Perhaps consider an environmental fund at national level financed via pollution levies which could, over a defined period of time, be used to fund the setting up of properly resourced air monitoring functions within local authorities.

We have no strategies in place in this country by which to tackle existing pollution.  For example, ambient air monitoring in the village of Monkstown on the shores of Cork Harbour, was conducted by the EPA over a 7 month period during 2007/2008.  It found that levels of PM10 were high.  The resulting recommendation was that PM10 would be monitored continuously.  In the following 12 years, traffic has multiplied, permission has been granted for a major port facility nearby, third party grain storage and handling has increased, new industrial facilities have established and planning permission is now being sought to convey all port goods by road via an urban motorway.  Yet ambient levels of any size of particulate matter have never been measured again.

I attach a motion I proposed to Cork County Council in February 2016 requesting real-time ambient air monitoring in Cork Harbour.

Air monitoring in Cork Harbour

Regards,

Marcia D’Alton.
Independent Member, Cork County Council

Mobile: 085 – 7333852
Website: www.marciadalton.net
Facebook: www.facebook.com/cllrmarciadalton
Twitter: @marciadalton

My submission to the OPW’s proposed Lower Lee (Cork City) Flood Relief Scheme

I lodged a short submission to the proposed Cork City Flood Relief Scheme at the very last minute on Friday.  We had been given a brief presentation on the scheme by the consultants working on behalf of the OPW, had been given an opportunity to ask questions and were assured that the proposed scheme was being misrepresented in an unfair way by those opposed to it.

Nonetheless, I have my own concerns.  They are fuelled by the enormous professional respect I hold for many who are vocal in their opposition to the scheme as proposed.  Including indeed, my own professor in UCC when I was an undergraduate.

So I put the basis of my (very untechnical!) concerns in the following note to the OPW which they graciously acknowledged Continue reading My submission to the OPW’s proposed Lower Lee (Cork City) Flood Relief Scheme

Shannonpark’s new Janeville development

Yesterday was the official sod-turning on Astra Construction’s new Janeville development at Shannonpark.  This is the first of Cork County Council’s Masterplan sites to be developed, so it was a big day for the Council.  The Masterplan approach is intended to play a significant role in the Council’s response to the current need for housing.

However, there are significant infrastructural deficits in and around Carrigaline.  These have been commented on in the context of yesterday’s sod-turning.  I too commented on them in my submissions to both the Masterplan and to the Astra planning application.   Continue reading Shannonpark’s new Janeville development