My submission to the proposed change to Objective TM5-2 of the Draft County Development Plan

Mr. Andrew Hind,
Senior Planner,
Planning Policy Unit,
Cork County Council,
County Hall,

24th October, 2014.

RE: Proposed Change No. 10.17 Objective TM5-2: Cork and Other Ports

Dear Andrew,

You will be aware from our discussions in the Council Chamber that I do not support the approach Cork County Council has taken in the Draft County Development Plan 2013 in specifying the locations which it regards as most favourable for the Port of Cork’s proposed relocation to the Lower Harbour.

I have particular reservations about the Draft County Development Plan’s recommending the type of Port activity which should take place at these locations.  In this regard, I refer particularly to Paragraph 6.6.4 of the Draft Plan.

Cork County Council has never undertaken any work of its own to confirm that these activities in these locations are the most sustainable from a Cork Harbour perspective.  It has merely relied on the Port of Cork’s own Strategic Development Plans 2002 and 2010.  The conclusion of the Port’s Strategic Development Plan 2002 was that Ringaskiddy was preferred for relocation and expansion of the Port’s container business.  This conclusion was resoundingly disagreed with by An Bord Pleanala in its refusal of planning application PL04.PA0003.  The Board’s reason was clear:

…It is considered that the proposed development would:

(a) result in much of the port related traffic traversing the city road network which would adversely impact on the carrying capacity of the strategic road network in and around Cork city and in particular the carrying capacity of the strategic interchanges at Bloomfield, Dunkettle and Kinsale Road and the Jack Lynch Tunnel which it is necessary to preserve; the proposed development would exacerbate serious traffic congestion at these strategic interchanges; and

(b) be unable to make use of rail freight carrying facilities in the future and would, therefore, represent a retrograde step in terms of sustainable transport planning.”

Although this is the first County Development Plan to be redrafted since that An Bord Pleanala decision, neither the Port of Cork nor Cork County Council has undertaken any holistic climate change assessment to ascertain whether relocation of the existing container terminal at Tivoli to Ringaskiddy and its consequent expansion in the coming years is actually sustainable in the context of an increasingly carbon-conscious world.

By omitting to undertake this assessment, Cork County Council is culpable in two ways.  Firstly, it is removing the need for the Port to undertake that crucial step in the Environmental Impact process: the assessment of alternatives.  The Environmental Protection Agency’s regard for the importance of this step is clear:

The consideration of alternative routes, sites, alignments, layouts, processes, designs or strategies is the single most effective means of avoiding environmental impacts”.
[Guidelines on the Information to be contained in EnvironmentalImpact Statements, EPA, 2002]

Secondly, Ireland is expected to bring about a 20% reduction on 2005 greenhouse gas emissions by 2020.  Our country is unlikely to achieve this target.  There is a risk that significant fines may result.  Perhaps the even greater risk is the global damage to Ireland’s clean environmental image.  Even in the Environmental Impact Statement accompanying its most recent planning application for relocation of its container activity to Ringaskiddy (PL04.PA0035), the Port of Cork had undertaken no climate change assessment.  So in supporting the concept of a container terminal at Ringaskiddy and thereby indefinite relegation of all container traffic to road transport, Cork County Council is tacitly approving of what is described as national strategic development with a potentially massive, and as yet unassessed, carbon footprint.

This aspect of the Draft County Development Plan 2013 had already been drafted and assessed by the time I was elected to the Council Chamber.  I am fully aware that the statutory time has passed for any of my comments here to make changes to this substance of the Draft Plan.  I do not dispute that it may be necessary for the Port of Cork to move its City-based operations downstream.  However, I wish to have my opinion on record that it is unsustainable for a County Development Plan to be as specific as the Draft Cork County Development Plan 2013 is with regard to the relocation of those Port activities without independent and comprehensive assessment.

The legislative process does, however, permit me to comment on my serious concerns with regard to proposed amendment 10.17 to Objective TM5-2: Cork and Other Ports.

Objective TM5-2 indicates that relocation of Port activities to the Lower Harbour should have regard for “residential amenity, tourism and recreation” around Marino Point.  It indicates no regard for residential amenity, tourism and recreation considerations arising from potential Port relocation to Ringskiddy.

Yet Port development at Ringaskiddy would be overlooked by the hills of Monkstown and Cobh, would be directly across from Blackpoint and would be in the midst of the Ringaskiddy community.  It would directly affect the well-developed tourism industry in Cobh, be directly in the line of vision of the cruise liner terminal at Cobh and would be in real proximity to the promising world-class tourism attractions of Spike Island.  It takes little familiarity with the Harbour to recognise that the Lower Harbour from Monkstown downstream is that area of the Harbour most widely used for recreation.

It is totally unacceptable that while Objective TM5-2 as proposed expresses direct consideration of the residential amenity, tourism and recreation around Marino Point, it makes no mention of residential amenity, tourism and recreation around Ringaskiddy.

The proposed text of TM5-2 confers considerations relating to an adequate road network serving Port activities to Ringaskiddy only.  It is of course vital that the N28 should be upgraded; it is already severely congested at peak times.  But it is equally vital that the R624 serving the Great Island should be upgraded.

The R624 is already severely over capacity.  It is dark and unlit as it passes through Foaty Island.  It exhibits dangerous bends all along its length to Cobh.  It has but a single, 200-year old bridge on and off the Great Island.  It is totally inappropriate to suggest that further development of any kind on the Great Island would be supported by the existing road network.  Plans to upgrade the R624 have been in place for several years.  Their implementation is hampered only by restrictions in funding.

Whilst it is clear that the Port is promoting Marino Point as an appropriate location for Port activity because of its rail link, it is equally clear that rail cargoes would be specialised and limited, at least in the shorter to medium term.  Any cargo not being transported up the country by rail would be transported by road.  The existing road network cannot support Port relocation of any kind to Marino Point.

So the proposed text of Objective TM5-2 is inappropriate and unsustainable on two counts:

  1. Upgrading of the road network to both Ringaskiddy and Marino Point is essential.
  2. Potential impact on residental amenity, tourism and recreation arising from Port relocation is a concern at both Ringaskiddy and Marino Point.

It is incumbent on Cork County Council as the planning authority to change the proposed text of TM5-2 to reflect these concerns in accordance with the “proper planning and sustainable development” requirements of existing planning legislation.

I suggest wording such as the following might suffice:

Support Ringaskiddy as the preferred location for the relocation of the majority of port related activities.  Also recognising the key role that Marino Point can play in providing an alternative relocation option for some of the port related uses that could best be served by rail transport.  It is acknowledged that there is need for significant improvement to the road network serving both Ringaskiddy and Marino Point and that account must be taken of residential amenity, tourism and recreation.  The Council is committed to engage with the Port of Cork and other relevant stakeholders in achieving this objective.   See also Objective EE 6-2 Cork Harbour.”

I acknowledge that general reference to residential, amenity, tourism and recreation is given in Objective EE6-2 (Proposed Change No. 6.10).  This is welcome but not sufficient.  I anticipate Cork County Council’s giving the same regard to sustainability concerns in Objective TM5-2 as it does in Objective EE6-2.

All the best,

Marcia D’Alton,
Member, Cork County Council.