Category Archives: Personal Submissions

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

Evidence to oral hearing on proposed Ringaskiddy incinerator

 INDAVER WASTE FACILITY AT RINGASKIDDY 

STRATEGIC INFRASTRUCTURE DEVELOPMENT
APPLICATION TO AN BORD PLEANÁLA

REG. NO. 04.PA0045

 

 

BRIEF OF EVIDENCE

APRIL 2015

 

MARCIA K. D’ALTON B.E., M.ENG.SC.
MEMBER, CORK COUNTY COUNCIL


 My name is Marcia D’Alton.

I am a resident of Cork Harbour. My family and I currently live in Passage West. We formerly lived in Monkstown. I have sailed in Cork Harbour all my life and have been a member of Monkstown Bay Sailing Club for many years. I have five children, all of whom live beside, sail in and love Cork Harbour.

I hold a Bachelors Degree in Engineering and a Masters Degree of Engineering Science from University College Cork. I have worked as an environmental consultant specialising in the fields of treatment and management of non-hazardous, agricultural and sludge wastes, nutrient management, renewable energy development, catchment water quality management, waste water treatment, the licensing and permitting of waste handling facilities and Integrated Pollution Control licensing. Continue reading Evidence to oral hearing on proposed Ringaskiddy incinerator

My submission to Indaver Ireland’s planning application to develop a contract incinerator at Ringaskiddy

Below you will find a link to my submission to An Bord Pleanála in relation to Indaver Ireland’s planning application to develop a 240,000 tonne contract incinerator to burn a combination of hazardous and non-hazardous waste in Ringaskiddy.

The proposed development was regarded as Strategic Infrastructural Development within the meaning of the Strategic Infrastructure Act 2006.  This is a piece of legislation the primary purpose of which is basically to fast-track major items of infrastructure through the planning process.  Any project that is determined to be strategic infrastructure applies for planning permission directly to An Bord Pleanála.

As many of you will know, this is the third time Indaver has applied to built a hazardous and non-hazardous contract incinerator on this site.  The previous two applications were in 2003 and 2008.  I have been involved in opposing this proposal from the outset and have, once again, made a submission to An Bord Pleanála against the proposed development:

My objection to An BP, 06-03-2016

My submission to the Preliminary Consultation on the Local Area Plan

Cork County Council,
Floor 13,
County Hall,
Cork.

24th January, 2015.

RE: Preliminary Consultation on Ballincollig-Carrigaline Municipal District Local Area Plan

Dear Sir,

I welcome this Preliminary Consultation on the review of the Ballincollig-Carrigaline Municipal District Local Area Plan. I should be grateful if my comments would be given consideration when the first draft of the Local Area Plan is being drawn up.

Although I represent the Ballincollig-Carrigaline Municipal District, I live in Passage West. I spent the first 30 years of my life in Douglas. I have a child attending school in Carrigaline and regularly walk recreationally in Ringaskiddy. So as my particular familiarity is with the eastern/southern area of the Municipal District, my submission focuses on this area.

The development of both Ballincollig and Carrigaline as satellite towns of Cork City was a defined aim of Cork County Council in the 1970s. That strategy has worked and both towns are now the largest in the county. The concept of the Metropolitan town is well defined in Paragraph 3.3.1.1 of the Preliminary Consultation. Paragraph 3.1.1 identifies Ballincollig, Carrigaline and Passage West as being the three Main Towns in the Municipal District.

Although all three towns serve a similar function and the development of Ballincollig and Carrigaline was encouraged concurrently, there is woeful inequity between the quality of residential amenity and environment provided for in Ballincollig against that provided for in Carrigaline and Passage West. This difference is highlighted even by a comparison between the opening paragraphs of Sections 3.2 and 3.3. Paragraph 3.2.1.1 on Ballincollig describes the town as being “modern”, “well provided for in terms of schools, community facilities and amenities … enjoys excellent access to the national road network … an attractive and convenient residential and employment location”. By comparison, paragraph 3.3.1.1 on Carrigaline simply describes the strategic aims of large Metropolitan towns. Carrigaline and Passage West have simply not been serviced by community facilities, amenities, infrastructural capacity and integrated public transport as Ballincollig has. This Local Area Plan must be grabbed as an opportunity to set this inequity right for the 30,000 people living in the greater Carrigaline area.

Throughout my comments in this submission, I am mindful of the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas produced by the Department of the Environment, Community & Local Government in 2009. They describe high quality residential areas as being those which:

  • Prioritise walking, cycling and public transport and minimise the need to use cars
  • Deliver a quality of life which residents and visitors are entitle to expect in terms of amenity, safety and convenience
  • Provide a good range of community and support facilities, where and when they are needed and that are easily accessible
  • Present an attractive, well-maintained appearance, with a distinct sense of place and a quality public realm that is easily maintained
  • Are easy to access for all and to find one’s way around
  • Promote the efficient use of land and of energy and minimise greenhouse gas emissions
  • Provide a mix of land uses to minimise transport demand
  • Promote social integration and provide accommodation for a diverse range of household types and age groups
  • Enhance and protect the green infrastructure and biodiversity
  • Enhance and protect the built heritage.

 

Passage West

  • Being sister towns, it is understandable that Passage West and Monkstown are always thrown into the same pot when it comes to planning. But the reality is, both are socially so far removed from one another that the coalescing of the two settlements does neither town any particular service.
  • Yet despite these assets, Passage West is a dark, narrow town where there is little employment, less commerce and much dereliction. It does not even begin to reflect Cork County Council’s strategic aims for large Metropolitan towns.
  • Passage West has many assets that are incontrovertibly valuable. It is beside Cork Harbour. It has magnificent architecture. It has a rich industrial and maritime heritage. These assets should make it one of the most desirable places to live in the county.
  • Passage West’s fortunes have always been related to the sea. In the 1700s, Passage West was the port of Cork. The channel from Passage West to the city was undredged and shallow, so ships moored off Passage West to discharge their cargo. The first quay in Cork Harbour was opened in Passage West in 1836. In the 1800s, Passage West was an industrial hive of shipbuilding of European importance. Since the decline of shipbuilding in the early twentieth century, Passage West has turned its back on the sea. If this town is to reinvent itself, it is most likely to succeed by once again being mindful of its age-old relationship with Cork Harbour.
  • So it is vital that particular emphasis is put in the Local Area Plan on:
    • creating visual and physical links between the town and the water
    • enhancing marine-related infrastructure
  • Too much emphasis was placed in the existing Local Area Plan on the Dockyard site. It is true that the future of the Dockyard site is critical to the future of Passage West, but there are several other brownfield sites in the town centre which are also extremely influential. The convent and convent school dominate the town and have been derelict for far too long. Steampacket Quay, once the heart of Passage West, is adjacent to Penny’s Dock and is an embarrassment at the end of the very popular Railway Line. The pocket of land at the end of Beach Road is, whilst small, predominant and influential. These key sites also deserve attention within the Local Area Plan.
  • To this end, it is helpful that the Preliminary Consultation proposes incorporating the convent within the town centre core. As the convent and its site have been recently purchased, I hope it is not too late for this inclusion to positively influence whatever development is proposed over the coming months.
  • I very strongly support the Paragraph 3.4.3.2 suggestion of a non-statutory planning brief for both the Dockyard and the convent. Together, both occupy a large portion of Strand Street. However my fear is that as the Dockyard is also for sale at present, the non-statutory planning brief will be delivered too late to be of any real benefit.
  • I also support very strongly the suggestions made in Paragraph 3.4.5.5 in relation to:
    • Providing greater connectivity between the town centre and the water
    • Developing an urban design/public realm strategy for the town centre
  • The Town Team concept as recommended by Retail Ireland (Retail Ireland Town Centres Policy Paper, 2012) would be tremendously beneficial to Passage West. The Town Team concept came from the UK. It would involve Cork County Council’s identifying Passage West as a pilot town where new partnerships between retailers, landlords, the local authority, representative groups, etc. would be formed to establish targets and achieve demonstrable improvements in town centre locations. With its paucity of commercial outlets, Passage West would be the ideal town to include in such a pilot.
  • In the absence of commercial outlets on the main street, many of the older on-street buildings have been converted into apartments. These have no dedicated parking. If there is to ever be enhancement of the streetscape within Passage West town centre, it is important to consider where off-street parking might be developed for the residents of these apartments.
  • Paragraph 3.4.3.2 describes Passage West as being a “commuter settlement with good access to the employment nodes of Ringaskiddy and Cork City”. This is not true. Roads may be provided, but the roads are intolerably congested. A journey to Cork City along the R610 in the morning can take up to an hour. Tailbacks in the am peak through Rochestown reach Hop Island and beyond. Poor drainage on the R610 past the Suez Pond coupled with the speed and volume of traffic makes this section of the road increasingly dangerous. I am aware of several families who have moved from Passage West to Cork City because they are simply no longer able to take the frustration of the morning’s commute.
  • Congestion on the R610 has not been mentioned anywhere in the Preliminary Consultation. It is no longer acceptable to brush over this legacy of overdevelopment of lands all dependent on a single linear road. I would really welcome any suggestions the first draft of the Local Area Plan might propose to go even some small way towards resolving this issue.
  • Although a small settlement, Passage West is highly car dependent. Both the primary and secondary schools are situated a considerable way up Church Hill. The topography of the town is steep and few wish to climb Church Hill in the morning. In addition, the main retail outlet (Eurospar) is on the eastern end of the town. This makes it inaccessible other than by car to most residents. To be fair, whilst congestion in Passage West is incomparably better than in other Metropolitan towns, poor planning decisions have led to dependence on the private car in a way that is most unsustainable.
  • It would be a positive aim for the Local Area Plan to enhance walking routes to both the primary and secondary schools. Whilst Church Hill will always remain a challenge, placing a handrail close to the wall along the footpath would assist those who are less able-bodied. Although significant residential development has been permitted at the northern end of the town, there is no footpath along Church Hill to connect these residential developments to the school. The provision of this footpath is long overdue.
  • Paragraph 3.4.4.3 inaccurately implies that the Railway Walk will be extended from where it ends at present in Fr. O’Flynn Park through Passage West, Glenbrook, Monkstown and on down to Carrigaline. My understanding is that this will not be the case. As far as I am aware, the intention is that the proposed Greenway will be developed from the ferry at Glenbrook through Monkstown and on south. Passage West and Glenbrook will be excluded. This is significant because, as mentioned in Paragraph 3.4.5.5, the town centre environment is restricted and “difficult to navigate as a pedestrian, cyclist and by car”. It is important that the Local Area Plan would give consideration as to how cyclists visiting and passing through Passage West would best and safely be accommodated.
  • I have had many discussions with the relevant sections of Cork County Council about how best to bring bicycles through Passage West town centre. There are really only two options. The first is to create a boardwalk-type extension to the Greenway on the water side of the Dockyard. This would be very attractive but will clearly work only in the context of a redeveloped Dockyard. Furthermore, it would lead to a winding Greenway which would come along Steampacket Quay to Penny’s Dock, divert to the boardwalk, rejoin the road at the end of Dock Terrace and share a carriageway with cars until it rejoins the dedicated Greenway at the Cross River Ferry. The second option is to examine the feasibility of reopening the tunnel built to serve the Cork Blackrock and Passage Railway.
  • This 450 metre-long tunnel currently lies disused and boarded up at one end. Nonetheless, it is a remarkable and quite unique piece of industrial heritage. The first 50 metres at the Passage end was built by a process called “cut and cover”. At the Glenbrook end, the construction necessitated blasting through solid rock. It incorporates a large shaft to permit the release of smoke and steam and cavities along its length to allow anyone trapped inside to escape the path of an oncoming train. This tunnel is the only one of its kind on a narrow gauge track in the whole country. Cork County Council has recently surveyed the tunnel and found it to be in sound condition. Whilst its opening for public access would call for thought, particularly with regard to safety, the tunnel would be a fantastic and novel addition to the Greenway and an attraction in its own right.
  • Paragraph 3.4.6.3 is not correct. There is a marina in Monkstown. It is privately owned. There is no marina in Passage West. There is, however, a public pontoon in Passage West. Whilst this is very welcome and of great assistance to small boat handling, it does not and will never function as a marina.
  • In general in Passage West, although as mentioned above the pontoon is hugely welcome, access to water needs to be greatly enhanced. There are several slipways in the town but not one of them has vehicular access. Many are in poor condition. It is vital that provision of a slipway with vehicular access for Passage West and associated parking is a particular aim of the Local Area Plan.
  • The proposed dezoning of R6, R7 and R8 is welcome. In the context of existing infrastructure, these lands should never have been zoned. But the same concerns apply to the proposed zoning of lands around Monkstown Golf Course. Any houses built on these lands into the future would rely on an inadequate country road network for connection to the R610 and would be so remote from schools and services in the closest centre of population that their residents would be utterly dependent on the car. This would be unsustainable.
  • The Preliminary Consultation has no mention of either community facilities or dereliction. Both are critical to Passage West. It is really important that the Local Area Plan would contain a strong commitment to improved community facilities and to tackling dereliction.
  • The pleasant residential environment of Monkstown is threatened by the high volume and speed of through traffic. Parking becomes a particular issue during the summer in the vicinity of the Sandquay and marina. On-street parking by users of the marina creates a dangerous bottleneck in an area of particularly poor visibility around Carlisle Place. A traffic calming scheme and interim parking arrangements to serve the marina were prepared several years ago. Their provision would enhance the residential environment of Monkstown, improve the amenity that is the riverside walk and deliver vastly improved safety for the village generally. Provision of traffic calming and parking in Monkstown needs to be an aim of the Local Area Plan.

 

Carrigaline

  • The existing Local Area Plan had an aim towards improving Carrigaline’s town centre and residential amenities. In reality, there has been little progress in this regard throughout that period. It is now critical that these deficits are addressed.
  • Although it is true that housing is urgently needed nationally, infrastructural improvements, traffic management, diversification of transportation options, provision of amenity space and community facilities and upgrading of the streetscape for existing residents are all critically urgent in the context of Carrigaline. It is my opinion that there should be no further rezoning of land for housing in or close to the Carrigaline development boundary until these issues are prioritised and addressed comprehensively.
  • Section 3.3.2.6 suggests considering rezoning of lands between Carrigaline and Ringaskiddy for residential housing. This would be entirely retrograde. Any development on lands here would be disconnected from Carrigaline town to the extent that they could never form part of the Carrigaline community. This would be sprawling, inefficient land use which would create yet further reliance on unsustainable forms of transportation.
  • Section 3.3.3.1 comments on the limited employment supply in Carrigaline because of its proximity to the Ringaskiddy Strategic Industrial Zone. If Carrigaline was designed to act as the residential hub for the Ringaskiddy Strategic Industrial Zone, then this is all the more reason to enhance infrastructural links between Carrigaline and Ringaskiddy. There isn’t even a bus service between the two settlements. However, the reality is shown in Paragraph 3.3.3.3, which tells us that actually only 21% of employees living in Carrigaline are working in Ringaskiddy. So it is critical that further employment is created within the Carrigaline development boundary and that infrastructural links between Carrigaline, the city and the Metropolitan area generally are enhanced and diversified.
  • Traffic congestion in and around Carrigaline is almost untenable. This applies equally to traffic from housing estates in the northern end of the town going towards the town centre and to traffic from Carrigaline generally to Cork City. The upgraded N28 will assist with the latter. But it is critical that there is greater ease of movement in and around Carrigaline town. Otherwise, the town will stagnate and lose business to the more easily negotiable southern suburbs of Cork City. To this end, I ask that the Local Area Plan would have an aim of updating the 2007 Carrigaline Area Transportation Study. I ask also that the study would examine the best ways of delivering all modes of transportation in and around Carrigaline.
  • Paragraph 3.3.3.4 recognises the “opportunities” to address the high car dependency rates between Carrigaline and Ringaskiddy. Frankly, it is not sufficient to recognise these opportunities. They need to be delivered on. Building a greenway between Carrigaline and Ringaskiddy is of vital importance in the short-medium term. I am aware that the County Council believes this will be more straightforward after the N28 upgrade. But for the present, there is a hard shoulder almost all the way along the N28 from the Shannonpark roundabout to Ringaskiddy. Cycling is reasonably safe. What is not safe is negotiation of the Shannonpark roundabout. If in the immediate term the County Council could address safe access for bicycles to the N28, it would be of significant assistance.
  • I agree strongly with locating significant retail developments within the town core as proposed in Paragraph 3.3.4.5. However, we must not forget that those who are shopping – in particular grocery shopping – need to travel by car. So again, freeing up road space into the town centre is vital. At present, it is somewhat of a challenge to make it across the Bothar Guidel to the significant retail developments on the other side of the river.
  • I also agree strongly with the aims of Paragraph 3.3.5.7 in relation to enhancing the town centre streetscape. At present, Carrigaline main street is narrow, colourless and dominated by the car (both moving and stationary). Whilst I appreciate that delivery of the inner relief road would expand opportunities and options for streetscape enhancement, the wait for the inner relief road has been long and it is no longer practical to link streetscape enhancement to its delivery. Carrigaline and its people deserve better.
  • Both as part of the streetscape enhancement and further into the future, the provision of open space as suggested in Paragraph 3.3.5.5 is very welcome and badly needed. I ask that this network of open space would be designed in such a way as to also act as a corridor for wildlife, thereby making its purpose doubly valuable.
  • In summary for Carrigaline, I think it well past time that quality of life and environment for existing residents is given priority over provision of extra residential housing. Carrigaline has massive potential as a place to live and work but has been allow to lag well behind governmental recommendations for high quality residential areas.

 

Ringaskiddy

  • I am entirely aware that development of the Strategic Industrial Zone at Ringaskiddy has been an aim of Cork County Council, the Industrial Development Authority and the Irish government over many years. However, sadly, so many aspects of Ringaskiddy epitomise what is now regarded as unsustainable development. This review of the Local Area Plan presents an excellent opportunity to challenge and address those failings.
  • The Ringaskiddy Strategic Industrial Zone is located at the end of a peninsula into which there is simply one road. That there is no alternative to the private car for all those employed there has led to the horrendous peak hour traffic congestion that has come to characterise the N28. The upgrade of the N28 will be welcome in this regard when it comes, but realistically, it only touches addressing the unsustainability of traffic and transport arrangements to this Strategic Industrial Zone. I have already spoken above about the need for a Greenway from Carrigaline to Ringaskiddy. This must link with the Greenway which we anticipate will come as far as the Raffeen junction with the existing N28. An enhanced bus service to Ringaskiddy is essential. If Bus Éireann does not co-operate in this regard, then Cork County Council might, in conjunction with the industries, explore the possibility of shuttle buses from designated car parks to coincide with the factory shifts.
  • Paragraph 3.5.3.1 has a stated intention of not providing for any significant population growth in Ringaskiddy. The irony is that this approach makes traffic congestion worse. It is not possible for either employees of industry or, in particular, students of the National Maritime College, the Beaufort Institute or Imerc to get residence anywhere that involves not needing a car. Realistically, there is only one development in Ringaskiddy where students can rent a house. So either student/visitor accommodation should be considered in Ringaskiddy or interconnectivity between Carrigaline and Ringaskiddy should be significantly improved.
  • Cork County Council and the IDA have an aim of attracting high quality industry to Ringaskiddy. This is laudable. However, it is so often forgotten that high quality industry demands a high quality environment for its employees. Ringaskiddy does not represent that high quality environment and yet has immense potential to do so. Industry and warehousing is given land right out to the edge of the water, whilst factory employees and students are relegated to exercising on the footpath along the N28 that runs between the industries and the road. It is so important that a strip of land along the water’s edge is kept such that it can be developed as public amenity. That such an amenity can be offered to its employees will make Ringaskiddy more attractive, not less attractive, to high quality industry. This needs to be a policy of the Local Area Plan.
  • The Local Area Plan zoning maps should show Paddy’s Point as being an amenity area dedicated to the public. This was a commitment of the Port of Cork’s planning application.
  • When industry is given planning permission, visual screening from the water must be regarded with the same importance as zoning from the land. Cork Harbour is finally developing as a unique tourism offering and, whilst it is quite possible to accommodate tourism and industry side by side in our multi-faceted harbour, it is essential that the visual impact of the industrial zone would be softened whenever possible.
  • It would be of tremendous benefit to the sensitive harbour landscape if industrial development on high ground visible from the harbour were kept to a minimum. Equally important is that the Local Area Plan would have a policy of no high building or stack developments between the water and heritage buildings such as the Ringaskiddy Martello Tower. The Martello Tower runs the risk of becoming an island in the midst of industrial development. This would destroy its potential to fulfil its role as a critical element of the valuable heritage triangle formed by Forts Camden, Carlisle and Westmoreland. To this end, it would be of potential tourism value if the land between the Martello Tower and the sea were considered for dezoning.
  • I ask that a particular aim of the Local Area Plan would be to develop a sports complex/sports hall in Ringaskiddy village. This would be of tremendous benefit to residents, students and employees of industry. The Local Area Plan could show particular commitment to this suggestion by zoning a patch of ground for this purpose. The Cork Area Strategic Plan (CASP) has long since recognised the need to provide high quality open space and amenities for workers.
  • It is appropriate that the Local Area Plan would indicate what land in the Ringaskiddy/Shanbally catchment is to be zoned for development of the new amalgamated Ringaskiddy/Shanbally school.
  • The recent trend towards development of a university/research hub at the eastern end of the Ringaskiddy peninsula is hugely positive and very welcome. This trend should be reinforced by the Local Area Plan. To do so is clearly in line with the long-held CASP aim for Ringaskiddy: “The Cork Harbour Area would offer a superb environment for a Cork Technopole”.   To that end, I ask that the Local Area Plan would have as a specific aim that further development at the eastern end of the Ringaskiddy peninsula would compliment and build on this trending university campus.
  • I welcome the commitment of Paragraph 3.5.5.1 to giving greater recognition to the needs of the established residential population in Shanbally/Ringaskiddy. For far too long, residents of Ringaskiddy have felt like intruders in the Strategic Industrial Zone. Yet there is such a gulf between this commitment and that of Paragraph 3.5.3.2, which states the need to ensure that the amenity and quality of life experienced by the residents will not be compromised by development of Ringaskiddy as a strategic employment centre. However, both of these commitments are well worth incorporating in the Local Area Plan. Even the provision of high quality recreational spaces would go such a long way towards improving the facilities for Ringaskiddy residents.
  • In this regard, there is a particular need to monitor and control noise, dust and air quality in Ringaskiddy. There is also a need to control night-time port-related traffic movement. The quality of life enjoyed by some residents in Ringaskiddy has been very badly impacted by their proximity to the port. There is a concern that this impact may be magnified by the new and expanded facilities for which the Port of Cork has been given planning permission. It is critical that the Local Area Plan would state its awareness of this issue and its commitment to work with the Port and the residents on ensuring port impact is reduced rather than amplified.
  • Ringaskiddy village and its people are tremendous assets to the Strategic Industrial Zone. They are essentially markers for port and industrial performance. They are permanent, on-the-ground adjudicators of whether port and industry are delivering that high quality environment so essential to optimising the marketability of Ringaskiddy. Additionally, an attractive, welcoming Ringaskiddy will enhance use of the ferry terminal, encouraging tourists to spend some time enjoying the village offerings before moving on to pursue the remainder of their trip.
  • CASP is clear that “greater emphasis should be given to promoting and developing the harbour as a facility for water-based sport and leisure activity”. Some of the most valuable access points for dinghy sailing and windsurfing are on the eastern end of the Ringaskiddy peninsula. Gobby Beach is an undeveloped gem. Lands to the east of the Haulbowline Island bridge are equally valuable. Access to the water for development of watersports centres is increasingly difficult to find. Most harbourside land is in private ownership. But a watersports centre on the eastern shores of the Ringaskiddy peninsula offers shelter for inexperienced participants whilst permitting those who are more adept almost immediate access to the wider expanse of Cork Harbour without crossing shipping lanes. I ask that the Local Area Plan would, at a minimum, mention this potential for the eastern shores of the Ringaskiddy peninsula and would, preferably, identify the most suitable area(s) where such development might be supported.
  • The same issue of restricted access to waterside sites is a real impediment to the development of public water transport between Cobh and Ringaskiddy. However, the concept would be a highly sustainable one, would relieve the congested road network of many trips and should be a stated desire of the Local Area Plan.

 

Cork City South Environs including Douglas

  • All of the issues pertaining to the Cork City South Environs addressed by the Preliminary Consultation are worthy of addressing in the Local Area Plan.
  • Where I consider the approach of the Preliminary Consultation to fall down is in the way it coalesces all of the neighbourhoods in those southern suburbs. Togher and Douglas, for example, do not consider themselves to be part of the same town and for the Local Area Plan to do so demeans their unique residential identities. In fact, to take consider all these neighbourhoods as simply being suburbs of the city reinforces the argument that they should indeed be part of city rather than county territory.
  • I feel very strongly that the Local Area Plan needs to give more attention to the potential offered by the Tramore Valley Park and Vernon Mount complex. The Cork City South Environs comprises the largest population in this Municipal District. It deserves a regional park of import equal to that in Ballincollig. The Tramore Valley Park and Mount Vernon complex offers the ideal opportunity to develop such a landmark facility.
  • The dense, linear development of the Rochestown area leaves residents heavily reliant on the private car. The road network struggles to accommodate demand, particularly at peak. It is critical that the upgrade of the existing N28 would increase rather than reduce travel routes and transportation options for residents of Rochestown and Maryborough.
  • When planning permission was granted for the development of Mount Oval, a long-term commitment was made to provide an on-ramp to the N28. This commitment needs now to be reflected in the Local Area Plan. Provision of this on-ramp would relieve demand for the R610 and Douglas village and offer increased options to residents.
  • Upgrading of Clarke’s Hill and Coach Hill must be a stated priority of the Local Area Plan. These are bus routes which take more than their fair share of traffic and offer poor to no pedestrian facilities.

 

Cork Harbour 

  • Cork Harbour has not been mentioned at all in the Ballincollig-Carrigaline Preliminary Consultation document. Yet the harbour is one of the area’s greatest assets. It is critical that consideration for its future development forms an integral part of this Local Area Plan.
  • Maximising accessibility to Cork Harbour is vital. In this regard, I refer to visual accessibility as much as physical accessibility. Public footpaths along the harbour’s edge must be prioritised. This, as suggested in the context of Ringaskiddy, would be a welcome stated objective of the Local Area Plan. Of course it will not be possible to provide for such footpaths in every location, but it is important to have a conscious aim to provide them wherever possible. Highly developed facilities are not necessary; accessibility is the priority.
  • It would be welcome stated aim of the Local Area Plan to accommodate and encourage services/facilities along such amenities as the Hop Island – Passage West Railway Line. Such services/facilities include toilets, coffee docks, seats and picnic stations.
  • Cork Harbour is common and equally valuable to four of the Municipal Districts in County Cork: Ballincollig-Carrigaline, Cobh, East Cork and Bandon-Kinsale. I ask that the Local Area Plan would have a stated aim of the development of a plan specific to Cork Harbour. This plan would build on the draft Cork Harbour Study and set out the best means by which all stakeholder interests in our multi-faceted harbour can be most advantageously and sustainably accommodated into the future. The findings and conclusions of this plan would then be incorporated into the Local Area Plans for each of the four surrounding Municipal Districts.

Yours faithfully,
Marcia D’Alton
Independent Member, Cork County Council

 

 

 

 

 

Submission to the Department of the Environment, Community & Local Government on the next round of River Basin Management Planning

WFD SWMI Consultation,
Water Quality Section,
Department of the Environment, Community & Local Government,
Newtown Road,
Wexford.

3rd December, 2015.

 

RE: Significant Water Management Issues in Ireland – Public Consultation

 

Dear Sir/Madam,

Thank you for the opportunity to input into the preliminary consultation for the next cycle of River Basin Management Planning in Ireland.

I have read the Significant Water Management Issues in Ireland document in full. It identifies most of the primary issues affecting water quality in Ireland. The introduction of the Integrated Catchment Management Concept is welcome. I support it strongly as the only way by which good water quality management will be achieved. The increased focus on community involvement is long overdue and also very welcome.

However, like so many of our responses to European Directives in Ireland, the document is very strong on identifying targets to be achieved, problems to be tackled and not so strong on the ways in which we in Ireland must change our modus operandi by which to achieve these targets. But we will never hit the environmental targets we set with a “business as usual” approach.

 

  • Agriculture

One of the aims of Food Harvest 2020 is to increase milk production by 50% now that milk quotas have been abolished. Cork County Council has also spoken positively about the potential the rich grasslands of the county offer for massively increased dairy production. Significant Water Management mentions the difficulty of achieving the Water Framework Directive targets in the context of Food Harvest 2020. It does not dwell on this issue, other than to comment on how research work currently underway will identify better how agriculture impacts on water at a catchment level.

Whilst research is always valuable, we already know how agriculture impacts on water quality, both at the individual stream level and at catchment level. The fact is that to increase the numbers of cows is to increase the volume of slurry produced. It is to increase poaching along riverbanks where cattle get direct access to flowing water. It is to increase the need to intensify grassland management. There is no getting away from this and if we are to attempt Food Harvest 2020 with any cognisance of the Water Framework Directive, Ireland will need to invest heavily in farmer education, slurry treatment and guidelines to protect watercourses from direct access by cattle. It will also be necessary to build centralised biogas plants similar to those in Denmark and Germany for improved management of agricultural slurries. These could offer tremendous potential to rural communities but have never been incentivised in Ireland.

Incentives such as planting of riparian zones and the designation of buffer zones for water source protection are only ever offered to farmers availing of agri-environmental schemes. It is necessary to introduce them across the board. Most farmers are stewards of the countryside. With education and guidance, they will be happy to work towards achieving better water quality. But it is no longer good enough that such agri-related water quality measures are conducted only on farms participating in agri-environmental schemes.

 

  • Urban Wastewater Treatment Discharges

Irish Water is putting investment into several of the major wastewater treatment schemes without which Ireland continues to fail the requirements of the Urban Wastewater Treatment Directive. The Cork Lower Harbour wastewater treatment plant is a stark example of a long-awaited wastewater treatment scheme which, when delivered, will end the discharge of significant volumes of raw sewerage.

However, the discussion of urban wastewater in the Sustainable Water Management Issues document does not link wastewater with land use policy. I believe this link is critical. We as a country need to carefully examine our policy of one-off house construction. In particular, we need to consider the impact on the environment of disparate house-building in rural areas. Haphazard siting of houses requires installation of a septic tank or biocycle unit. Treatment of wastewater in discrete units in this way is less effective, less efficient and more difficult to monitor than treatment of wastewater in a communal treatment plant. Planning houses in clusters rather than scattered or in a linear form along a country roadside would allow far greater control of domestic wastewater treatment and discharge.

We are also culpable at all planning levels of building on flood plains. Flood plains perform an essential riparian function. Not merely do they allow vast areas onto which a full river can spill. They also soak rainwater running towards a river, filtering sediment and other pollutants from it before it reaches the water. Yet because they have been constructed on, many floodplains in our larger towns are no longer available to perform this essential function. It is critical that the impact of building on floodplains would be acknowledged as being highly retrograde in terms of water quality.

 

  • Hazardous chemicals

Issue 13 discusses hazardous chemicals, particularly heavy metals and PAHs, in our watercourses. It is essential that endocrine disruptors would also be considered. These insidious chemicals strike at the heart of many of the most fundamental aspects of nature.

It is critical that we examine the source of these chemicals in our discharges to water.

One of the key contributors to hazardous chemicals in the water environment is urban wastewater. When wastewater is treated, much of the hazardous content is captured in the sludge. Irish government policy is for the beneficial use of sewage sludge (biosolids) in agriculture. Although the Code of Best Practice advises for the spreading of sludge at a rate which optimises the trapping of these hazardous compounds in soil, it is an indisputable fact that the sludge to land policy may permit levels of hazardous compounds in our agricultural environment to accumulate. The assimilative capacity of soil is limited and so, ultimately, these compounds will make their way to watercourses.

Ireland’s sludge to land policy was drawn up almost 20 years ago. It is well past time that it was revisited. In 2013, almost 24,000 tonnes of untreated sludge was landspread in Ireland. Septic tank sludges are regularly disposed of by landspreading. Research, technology and the microchemical composition of sewage sludge have all moved on. The Sustainable Water Management Issues document needs to identify this sludge policy as being in need of updating.

The Sustainable Water Management Issues document does not identify the link between industry and hazardous chemicals in our watercourses. Producer responsibility dictates that industry must take cognisance of the ingredients of cosmetics, pharmaceuticals, etc. It is time that Ireland focused on this link with a view to reducing the ongoing build-up of hazardous compounds such as these in our environment generally.

 

  • Road drainage

Runoff from roads is not mentioned at all in the Sustainable Water Management Issues document. Yet this is a significant source of water pollution. Rainwater running off our impervious urban surfaces contains petrol, oil, heavy metals and PAHs. Fertiliser use on golf courses and residential gardens increases the nutrient load of runoff. Runoff also raises the temperature of smaller water bodies, often with adverse effects on fish life.

Drainage in Ireland typically involves collecting as much stormwater as possible and removing it quickly to avoid flooding. But this approach not just maximises the direct introduction of these pollutants into surface water, it also causes flooding further downstream.

There are many best practice methods by which road drainage and stormwater generally can be more effectively managed. Many local level policy changes can make a real difference. These include incentives towards the installation of green roofs, the development of neighbourhood-constructed wetlands, bioretention systems and infiltration basins.

Sustainable Urban Drainage Systems need to become the norm rather than the exception in Ireland if we are to combat the unsustainable effects of our “collect and dispose” method of stormwater management.

 

  • Determination and the allocation of resources

The very first issue listed for consideration in the Sustainable Water Management Issues document is affordability. If the starting point towards achieving any targets is what we cannot afford, then we will never achieve those targets.

The hesitancy of the “Can we really do it?” ethos is reflected throughout the document. Thus the document lacks determination, punch and the will to succeed. It is essential that resources are dedicated to achieving compliance with the Water Framework Directive. It is essential that if additional tasks are to be undertaken by local authorities, they would be adequately staffed and financed. It is essential that all community stakeholders buy into achieving Ireland’s targets under the Water Framework Directive.

But equally and perhaps more important is that the same level of buy-in is committed to by both industry and the government. Industry is the source of much of the cyclical and difficult to treat compounds found in Ireland’s rivers and lakes. Policies and strategies of other governmental departments have the potential to significantly impact on achieving the targets of the Water Framework Directive. It is not sufficient to address achieving these targets in an integrated way merely at catchment level. A multi-sectoral, cross-departmental approach is also essential.

Yours faithfully,

______________________________________

Marcia D’Alton, B.E., M.Eng,Sc.,
Independent Member, Cork County Council