Category Archives: Personal Submissions

My submission to the Novartis planning application

Novartis #Ringaskiddy operates two incinerators on site. One is a liquid vapour incinerator and the other is a solid waste incinerator. Both were installed to dispose of manufacturing waste generated on site. Heat recovered from the incinerators is used in the manufacturing process. But Novartis has reduced processing over the past couple of years and plans to reduce it yet further. As a result, there isn’t enough on-site waste being generated to power the incinerators and they have had to burn fossil fuels to generate the necessary heat to continue processing.

Novartis has recently lodged a planning application with Cork County Council seeking permission to accept liquid and solid hazardous wastes from other manufacturing sites around the country to burn in their on-site incinerators. The application says that this would supplement the waste lost by the reduced manufacturing, would allow a move away from the burning of virgin fossil fuel and would reduce hazardous waste currently exported from Ireland for treatment/disposal. It says the proposed wastes would be of a type similar to what is (or was) already on site and would therefore be suitable for burning in their incinerators. It also says that this move would help them sustain the Ringaskiddy operation.

I put considerable work into preparing a submission to this planning application. At face value, the logic of optimising existing under-used infrastructure makes perfect sense. However having been part of the 20-year campaign to keep merchant incineration out of Cork Harbour, I felt it was necessary that there would be crystal clear understanding of the proposed Novartis operation. You can read my submission at this link:

Submissions to a proposed IDA pumping station/outfall in loughbeg, ringaskiddy

The IDA has lodged a planning application to develop a pumping station at Loughbeg. It would pump wastewater and surface water. The planning application also seeks approval for a storage tank for wastewater, a building to house controls, an ESB substation and mobile lifting gantry. It also seeks approval to provide a chemical dosing unit, a standby generator, an air handling unit placed behind an acoustic barrier and to install two new concrete manholes on an existing pipeline. It seeks approval to lay new pipelines from these pumping stations through fields and along roads from Loughbeg to the Shanbally wastewater treatment plant for a distance of some 3 km. The pumping stations will serve 75 ha of industrially zoned land, as yet undeveloped. Wastewater of unknown composition from an unknown process is to discharge to the underground storage tank from industrial development of as yet unknown characteristics. All going well, it is to be pumped to a wastewater treatment plant some 3 km away, although the wastewater treatment plant does as yet not have the capacity to accept industrial loading. All not going according to plan, the wastewater will be pumped into Loughbeg. Stormwater with as yet unknown characteristics from car parks and process areas of the as yet unknown industries will flow to the stormwater pumping station in as yet unknown quantities to be pumped into Loughbeg. Lougbeg is an integral part of the Cork Harbour SPA which supports wintering waterfowl in numbers of national and international importance.

I supported the appeal to An Bord Pleanála by lodging an observation. You can read that here:

The Board agreed there was a possibility that the proposed development would do harm so it asked the IDA to produce an NIS (Natura Impact Statement). The NIS produced by the IDA’s consultants is available here:

My commentary on the above NIS is here:

Planning Application for Marino Point

Anything that happens at Marino Point affects Passage West. The Marino Point jetty is merely 500 metres directly across the water from Passage West town centre. The site has lain derelict since IFI ceased operating in 2002. Some clearance has taken place under the guidance of the EPA but many of the old structures still remain. The Port of Cork has purchased the site in partnership with Lanber Holdings to form the new Belvelly Marino Development Company. They have applied to Cork County Council for planning permission to clear these old structures, to install a new surface and foul drainage system, to infill the lagoon, construct flood defences and essentially prepare serviced sites for industrial development. Gouldings fertilisers is expected to move their operations on Centre Park Road to Marino Point and a planning application for this is due in early 2020.

It’s good to see life at Marino Point but I’m also conscious that anything taking place there will likely have an impact on Passage West. Marino Point is in the Cobh Municipal District and there is a risk that because water rather than land separates us, the vulnerability of Passage West may be underplayed or overlooked during the planning process. So I made a submission to the Port of Cork/Belvelly Marino Development Company’s planning application. A local residents group in Passage West also made a submission and I have been given permission to make it generally available. You will find links to both here …

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,

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