Chief Executive's Report on the Draft Plan Consultation Volume 1
Preparation of Cork City Development Plan 2022-2028
Chief Executive’s Report on Draft Cork City Development Plan 2022-2028 Consultation
Volume 1 Issues raised and Chief Executive’s Response & Recommendations
Report to Council Under Section 12 (4)(a) Of the Planning and Development Act, 2000 (as amended)
December 2021
Volume 1
Issues raised and Chief Executive’s Response & Recommendations
This Volume
Volume 2
Summary of Submissions Received
Contents of Volume 1 High-Level Overview
5
Structure of Report
9
Part 1
Introduction to Chief Executive’s Report
10
1.1 1.2 1.3 1.4 1.5
The Process to Date
11 13 13 14 14
The Draft Plan Consultation Process Purpose of this Chief Executive’s Report
Legislative Context
The Next Steps
Part 2
Summary of submissions fromOffice of the Planning Regulator, Southern Regional Assembly, National Transport Authority and Transport Infrastructure Ireland and the Chief Executive’s response and recommendations
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Section 1 Section 2 Section 3 Section 4
Submission from the Office of the Planning Regulator Submission from the Southern Regional Assembly Submission from the National Transport Authority Submission from Transport Infrastructure Ireland
17 74 98
118
Part 3
Summary of key issues raised in the submissions and observations by Other Persons and the Chief Executive’s Response and Recommendations
132
Chapter 1 Chapter 2
Introduction Core Strategy
133 137
3
Chapter 3 Chapter 4 Chapter 5 Chapter 6 Chapter 7 Chapter 8 Chapter 9 Chapter 10 Chapter 11 Chapter 12 Chapter 13 Appendices
Delivering Homes & Communities
201 235 257 276 310 333 348 373 397 416 418 421
Transport & Mobility
Climate Change & Environment
Green and Blue Infrastructure, Open Space & Biodiversity
Economy & Employment Heritage, Arts & Culture Environmental Infrastructure
Key Growth Areas & Neighbourhood Development Sites
Placemaking & Managing Development
Land Use Zoning Objectives
Implementation
Including SEA, AA & SFRA
Part 4
Land Use Zoning and Mapping
454
Section 1 Section 2 Section 3 Section 4 Section 5 Section 6 Section 7 Section 8 Section 9 Section 10 Section 11
City Centre & Cork Docklands
455 467 474 487 497 504 523 536 550 564 567
Ballincollig
Blarney / Tower
Glanmire
Cork Airport
North Eastern Suburbs & Hinterland North Western Suburbs & Hinterland South Western Suburb s& Hinterland South Eastern Suburbs & Hinterland Statutory Body Zoning Requests
Miscellaneous
Appendices
Appendices
570
Appendix 1 Appendix 2 Appendix 3
List of Submissions received (in numerical order) List of Persons and Bodies consulted (alphabetical order)
571 584 590
Acronyms
4
Executive Summary
HIGH-LEVEL OVERVIEW
This table provides a high-level overview of the issues raised. It does not purport to reflect every issue raised, the report should be read in full.
Section
Key Issues Raised
High-level Summary of Main Recommended Amendments
Chapter 1 Introduction
Minor amendments recommended
General support for the Plan vision
•
• Suggestions for amending strategic provisions
Chapter 2 Core Strategy
Support for focus on 15-minute City
• Amended calculation of Housing Supply Targets
•
Support for 9 Strategic Objectives
• Confirmation that City Capacity Study will be published
•
Housing Supply Targets
• Redesignation of Tier 3 to Longer Term Strategic Development Land
•
City Capacity Study
•
Additional objective on local planning
•
Tier 3 Zoning
•
• Increased density balanced with service delivery
Local planning
•
Chapter 3 Delivering Homes & Communities
• Need for refined housing supply and enhanced social and affordable housing supply • Strong support for the Compact City measures and 15-Minute City and increasing densities
• Updated Social and Affordable Housing Targets following update to Joint Housing Strategy • Additional school sites have been zoned and objectives included to secure schools where sites not identified • Enhanced Traveller Accommodation site development strategy and additional objectives
• Additional community infrastructure required
• Traveller Accommodation policy enhancement
• Community Infrastructure Audit proposed
• Child-friendly, age-friendly & safe development
• Additional objectives to ensure development supports child-friendly and age-friendly environments
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Executive Summary
Section
Key Issues Raised
High-level Summary of Main Recommended Amendments
Chapter 4 Transport & Mobility
Modal shifts targets
• Clarification that targets for modal share will be continuously reviewed during the lifetime of Plan • Additional objective on protection of national road network
•
Cycling and cycling facilities
•
Protection of national road network
•
Strengthen reference to use of ABTAs
•
Additional objective on ABTAs
•
• CMATS, BusConnects, Light Rail Transport (LRT)
• Additional references to public transport incl. BusConnects • Reference to potential amendments to accommodate final BusConnects and LRT
• Accessible public transport and segregated cycling and pedestrian facilities
Chapter 5 Climate Change & Environment
Flood Protection and management
• Additional text and objectives on renewable energy
•
• Support for climate adaptation and need for additional actions and targets • Request to strengthen text on renewable energy
Additional reference to climate justice
•
Additional reference to climate justice
•
Chapter 6 Green and Blue Infrastructure, Open Space & Biodiversity
Minor amendments recommended
• Strong support for the Lee to Sea greenway
• Requests for additional tree planting, parks, green spaces and recreational activities • Requests for increased access and recreational use of the river • Strengthen reference to metropolitan open space strategy
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Executive Summary
Section
Key Issues Raised
High-level Summary of Main Recommended Amendments
Chapter 7 Economy & Employment
Strategic Employment Sites
• Modifications to some Strategic Employment Sites
•
• Balanced employment development in the city
• Additional text supporting entrepreneurship
Entrepreneurship
• Additional text and objectives on innovation corridors
•
• Strengthen content on innovation corridors
Chapter 8 Heritage, Arts & Culture
• Safeguarding of historical character sites
• Additional text on safeguarding Cork City’s built heritage • Include additional text to support Cork’s Arts strategy and Cultural Capacity
• Support the establishment of a ‘sense of place’ in the city, through better management of older buildings and public spaces across the city • Revival and maintenance of Cork's Historical Centre • Retain and reuse of buildings in city centre to facilitate business and residential needs • The quay walls should be restored and protected
Chapter 9 Environmental Infrastructure
Enhance content on renewable energy
• Additional text and objectives on renewable energy
•
• Updates required to Irish Water plans, projects
• Content on Irish Water plans and projects updated
• Reference to National Waste Management Plan for a Circular Economy
• New reference to National Waste Management Plan for a Circular Economy
Chapter 10 Key Growth Areas & Neighbourhood Development Sites
Numerous issues raised in relation to various key growth areas and neighbourhood development sites
Individual issue addressed in Part 4 of this Report.
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Executive Summary
Section
Key Issues Raised
High-level Summary of Main Recommended Amendments
Chapter 11 Placemaking & Managing Development
• Densities for outer suburban areas need to be increased to realise “15 - Minute City”
• Density targets for the Outer Suburbs are being increased from 35-60 to 40-60 dwellings per hectare
• Lack of policy direction for digital signage
• New section on “Digital Advertising/Signage”
• Include reference to Design Manual for Urban Roads and Streets (DMURS) Quality Audits
• Additional text reference to “Other Design Audits” such as “Pedestrian and Cycling Audits”
Chapter 12 Land Use Zoning Objectives
Numerous land use zoning and mapping requests (just under half of all submissions)
Individual recommendations for each request provided in Part 4 of this report
Chapter 13 Implementation
Clarity required on how Development Plan objectives will be monitored
Further detail on monitoring the implementation of Development Plan objectives will be provided at Material Amendment and final Plan stages
Appendices including SEA, AA & SFRA
• Reference Cork Harbour Planning Framework
• New objective on Cork Harbour Planning Framework
Reference geothermal energy
New objective on geothermal energy
•
•
• Strengthen reference to protected European Sites
• Amended objectives in relation to European Sites
• Finer granularity on Justification Tests will be provided
• Additional Justification Tests for SFRA required
• Additional text on flooding and climate change will be provided
• Additional text on flooding and climate change
• Geological Survey Ireland (GSI) recommend inclusion of datasets.
• Recommend datasets to be included in the SEA ER.
• Flood zones will be overlain onto land use zoning maps
• Overlaying of flood zones onto zoning maps
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Structure of Report
STRUCTURE OF REPORT
This report is structured in 2 Volumes. You are now reading Volume 1 .
Volume 1 Issues raised and Chief Executive’s Response & Recommendations
Volume 2 Summary of Submissions Received
HIGH-LEVEL OVERVIEW STRUCTURE OF REPORT PART 1
PART 1
Introduction and Context
PART 2
Summary of the main issues raised in the each of the submissions received* * except the submissions of the Office of the Planning Regulator, Southern Regional Assembly, National Transport Authority and Transport infrastructure Ireland.
Introduction to Chief Executive’s Report This Part contains information on the plan-making process, the Draft Plan consultation process, the purpose of this Report, the relevant legislative context and the next steps. Summary of submissions from OPR, SRA, NTA and TII, and the Chief Executive’s respo nse and recommendations This Part contains a summary of the OPR and SRA submissions and the Chief Executive’s response and recommendations. Summary of key issues raised in the submissions and observations by Other Persons and the Chief Executive’s Response and Recommendations This Part contains a summary of the main issues raised in the submissions by all other parties and the Chief Executive’s response and recommendations. The issues raised are grouped under headings that align with the Draft Plan chapters. Land Use Zoning and Mapping This Part contains the land use zoning mapping and requests.
PART 2
APPENDICES
PART 3
PART 4
APPENDICES
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Part 1 Introduction to the Chief Executive’s Report
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Introduction to the Chief Executive’s Report
1.1 The Process to Date
Cork City Council is in the process of reviewing and preparing a new City Development Plan.
Pre-draft Stage
This process began with the publication of the Cork City Development Plan 2022-2028 Stage 1: Pre-Plan consultation Issues Paper: Our City, Our Future in June 2020. The Issues Paper provided the context of the new City Development Plan and explained how it fits into the national hierarchy of plans with the National Planning Framework (NPF), Southern Regional Spatial and Economic Strategy (RSES) and Cork Metropolitan Area Strategic Plan (MASP), as well as the Cork Metropolitan Area Transport Strategy (CMATS) and the Cork City Climate Adaptation Plan 2019. It set out a series of themes and questions that need to be considered in the preparation of the new City Development Plan. There was a significant response to the consultation process, which ran from 26 June until 21 August 2020, with 390 submissions received. Details of the submissions and the issues raised are included in the Chief Executive’s Report Volumes I and II of the pre-draft consultation dated October 2020. Cork City Council consulted considerably during the period October 2020 and July 2021 with statutory bodies and other stakeholders as part of the plan- making process. 16 workshops between the Executive and Elected Members were held relating to the City Development Plan review.
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Introduction to the Chief Executive’s Report
Draft Plan Stage
On 26 July 2021 the Draft Cork City Development Plan 2022-2028 was published for consultation. This is the first City Development Plan prepared for the expanded Cork City1. For the first time, a single statutory development plan will encompass Cork City and all its suburbs, towns, villages and hinterland. The Draft Plan sets out how Cork City will deliver on the National ambitions and growth targets for the City.
The Draft Plan comprised three volumes: • Volume 1 Written Statement • Volume 2 Mapped Objectives • Volume 3 Built Heritage Objectives
The Draft Plan also comprised: • Strategic Environmental Assessment Report • Natura Impact Report • Strategic Flood Risk Assessment
The Draft Plan was accompanied by a series of supporting documents and studies, including: • Cork City Neighbourhood Profile • Green and Blue Infrastructure Strategy • Draft Joint Housing Strategy (with Cork County Council) • Urban Density, Building Height and Tall Building Strategy
1 On 31 May 2019 Cork City expanded to nearly five times its former size and the population of the city grew by 85,000 to 210,000: https://www.corkcity.ie/en/council-services/public-info/boundary-extension/
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Introduction to the Chief Executive’s Report
1.2 Draft Plan Consultation Process
There was a significant response to the consultation process with 449 submissions received.
The Draft Plan consultation is a legal requirement as part of the City Development Plan process. The Draft Cork City Development Plan 2022-2028 consultation period ran from 26 July 2021 to 4 October 2021 . The documents published as part of the consultation are detailed under section 1.1 above. The ongoing public health crisis and the related restrictions on public gatherings provided a significant challenge to the consultation process. Notwithstanding this challenge, the Council engaged with the public and other stakeholders in a number of ways. Aside from the required statutory newspaper notice, the consultation was widely promoted via the City Council’s website, radio, newspapers and on social media platforms, under the “Our City, Our Future” banner. A bespoke website was created for the Draft Plan along with a consultation portal. A 5- minute video on the Cork City Development Plan review was produced and made available on the City Council’s website, and the full video and a series of short-form versions were circulated on social media such as YouTube, Vimeo, Facebook and Twitter. There was a high level of engagement which is a tangible indication of the genuine interest that the residents of Cork and stakeholder groups have in the future of their city. Over 40, mostly virtual, stakeholder meetings were held during the consultation period, and staff were available to answer queries via phone or email. Further consultation was carried out via the Public Participation Network (PPN), and there was specific consultation with young people including the Freedom of the City project. The Draft Plan, its appendices and accompanying documents were made available online in the accessible FlippingBook format and were collectively viewed over 7,300 times during the consultation period.
Of the 449 submissions 386 (86%) were submitted online via the consultation portal, with the remaining submissions being submitted via mail, post or by hand. Further details are set out in Volume 2 of this Report. Cork City Council wish to sincerely thank all those who took the time and effort to participate in this process by making a submission. Cork City Council would also like to acknowledge the efforts and thank the Public Participation Network, all stakeholders, colleagues across Cork City Council and associated bodies, and the Elected Members of Cork City Council, who supported the consultation process. A wide range of issues were raised in the submissions received. These are summarised, and addressed by the Chief Executive, and form the bulk of the content of this report. A list of all those who made a submission is included in Appendix 1 this Chief Executive’s Report.
1.3 Purpose of this Chief Executive’s Report
This report forms part of the statutory process to make a new City Development Plan. Its primary function is to list and summarise the main issues raised in the submissions received during the consultation process, including those of the Office of the Planning Regulator and Southern Regional Assembly, and to provide the response of the Chief Executive on the issues raised. This report must follow a prescribed statutory framework and is submitted to the Elected Members for their consideration.
In this Report, where recommendations propose amendments to text in the Draft Plan, proposed new text is in bold, text to be deleted in strikethrough.
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Introduction to the Chief Executive’s Report
1.4 Legislative Context
Where a proposed amendment to the plan would be a material alteration , the planning authority must publish a notice of the proposed amendment in at least one newspaper circulating in its area and send notice and a copy of the proposed amendment to the Minister, the Office of the Planning Regulator, the Board and the prescribed authorities. Material alterations to the draft plan are also subject to Strategic Environmental Assessment, Appropriate Assessment and Strategic Flood Risk Assessment. The proposed material alterations are published for public consultation for a period of at least 4 weeks, following which a Chief Executive’s Report on the material alterations consultation is prepared. In making the development plan, the Members are restricted to considering: • the proper planning and sustainable development of the area, • the statutory obligations of any local authority in the area, • any relevant Government or Ministerial policies or objectives for the time being. Where the planning authority decides not to comply with any recommendation of the Minster, Office of the Planning Regulator or Southern Regional Assembly, it is required to inform the Minister, Office of the Planning Regulator or Southern Regional Assembly as soon as practicable by notice in writing outlining the reasons for the decision.
The legislative basis for this part of the process is set out under section 12 of the Planning and Development Act, 2000 as amended. In accordance with section 12(4), this Chief Executive’s report is required to: (i) list the persons or bodies who made submissions or observations to the Draft Plan consultation, (ii) provide a summary of the recommendations and observations made by the Office of the Planning Regulator and Southern Regional Assembly, (iii) provide a summary of all other submissions and observations, (iv) give the response of the Chief Executive to the issues raised, taking account of: — • any directions of the Members under section 11(4), • the proper planning and sustainable development of the area, • the statutory obligations2 of any local authority in the area, • any relevant Government or Ministerial policies or objectives and, any observations made by the Minister section 12(3)(b)(iv).
1.5 The Next Steps
The Elected Members of Cork City Council have up to 12 weeks to consider the Draft Cork City Development Plan 2022-2028 and this Chief Executive’s report following which, where it appears to the Members that the Draft should be accepted or amended, they may by resolution accept or amend the Draft and make the Development Plan accordingly.
2 Section 12(18) of the Act defines ‘statutory obligations’ as including the obligation to ensure that the development plan is consistent with the National Planning Framework, Regional Spatial Economic Strategy and any section 28 Specific Planning Policy Requirements.
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Introduction to the Chief Executive’s Report
This Report represents Stage 7 of the process, as illustrated in this diagram. It is envisaged that the process will conclude in mid-2022.
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Part 2 Summary of submissions from the Office of the Planning Regulator, Southern Regional Assembly, National Transport Authority and Transport Infrastructure Ireland, and the Chief Executive’s response and recommendations
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Section 1 Submission from the Office of the Planning Regulator
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Submission from the Office of the Planning Regulator (Submission No 426)
The Office of the Planning Regulator (OPR) has a statutory role in evaluating and assessing development plans and draft development plans to ensure consistency with legislative and policy requirements relating to planning. The submission by the OPR comprises three categories of observations:
• Recommendations which relate to clear breaches of legislative provisions, the national or regional planning framework or the policy of Government as set out in section 28 Ministerial Guidelines. The planning authority is required to implement or address recommendations to ensure consistency with policy and legislative provisions. The OPR submission includes 12 recommendations .
Recommendation 1: Core Strategy Housing and Population Targets
Recommendation 7: Retail
Recommendation 2: Distribution of Growth
Recommendation 8: Modal shift targets
Recommendation 3: Core Strategy and Zoning for Residential Use
Recommendation 9: Strategic National Road Network
Recommendation 4: Tiered Approach to Zoning Infrastructure Assessment
Recommendation 10: Renewable Energy
Recommendation 5: Tiered Approach to Zoning
Recommendation 11: Flood Risk Management
Recommendation 6: Development Approach for Settlements
Recommendation 12: Public Rights of Way
• Observations which take the form of a request for further information, justification on a particular matter, or clarification regarding particular provisions of a plan on issues that are required to ensure alignment with policy and legislative provisions. The planning authority is requested by the Office to action an observation. The OPR submission includes 8 observations .
Observation 1: Development Approach for Settlements
Observation 5: Parking standards
Observation 2: Local Area Plans
Observation 6: Quarries and Aggregate Resources
Observation 3: Compact growth
Observation 7: Climate Action
Observation 4: Residential Density
Observation 8: Implementation and Monitoring
• Advice on matters that the OPR considers would contribute positively to the proper planning and sustainable development of the area. The planning authority is requested to give full consideration to the advice contained in a submission. The OPR provides advice throughout the submission.
The planning authority is required to provide a summary of the recommendations and observations made by the OPR in this report.
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Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
1.1. Overview
The OPR welcomes the approach taken in preparing the draft Plan which proactively embraces the challenges and opportunities identified in the NPF and the RSES through clear and concise policies and objectives in a well- structured draft Plan. Welcomes the strategic approach taken in the draft Plan which recognises that although growth must be planned for now, much of it will not take place within the proposed Plan period but in the two subsequent plans to 2040. Strongly supports this approach. The setting out of nine strategic objectives for growth provides clarity in strategic approach and is a very positive format. Strongly commends the strong emphasis on the development of the 15- minute City, which is clearly integrated across the Plan. The draft Plan provides an appropriate focus for regeneration of strategic docklands areas, infill and brownfield development in the existing built-up area. The proposed active land management approach has the potential to revitalise urban areas through regeneration of brownfield sites. The draft Plan provides a coherent strategy for climate action, including mitigation and adaptation. While there are some concerns with land use zoning objectives, the OPR commends the approach to setting out a well-considered, integrated land use transport and mobility strategy.
Cork City Council welcomes the comments from the OPR and the acknowledgement of the considerable work undertaken by the local authority in the preparation of the Draft Plan against the backdrop of the evolving national and regional planning policy and regulatory context. Cork City Council would like to acknowledge the detailed submission made in response to the Draft Plan, which helps to inform to the plan-making process. Recommendation: No change to the Draft Plan.
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Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
1.2. Core Strategy & Settlement Strategy
1.2.1. Core Strategy Housing & Population Targets
The Office also supports the overall form of the Core Strategy and Settlement Hierarchy, which is rational and evidence-based and has the potential to support sustainable transport and modal shift. Although there are some issues that need to be addressed in terms of housing supply targets and zoning to ensure consistency with National Strategic Objective 1 compact growth. The Office estimates the housing supply target for your authority calculated in accordance with Guidelines as c.14,800 for the plan period (under adjustment E of the Guidelines). While the population projection to 2028 in Table 2.2 of the Core Strategy is considered to be consistent with the RSES, the Core Strategy does not include housing supply targets, as required by the Guidelines. This will require a review of the draft Plan in order to plan to provide for housing to the extent identified in the Guidelines and the accompanying Circular in the Core Strategy, settlement strategy and associated identification of development potential and zoning exercises. Housing supply targets will also be necessary should the planning authority wish to employ the ‘ Additional Provision ’ mechanism as per secti on 4.4.3 of the draft Guidelines. Recommendation 1 - Core Strategy Housing and Population Targets In accordance with Section 10(2A) of the Planning and Development Act 2000 (as amended), and having regard to the Section 28 Guidelines: Housing Supply Target Methodology for Development Planning (2020), the Guidance Note on Core Strategies (2010), and the Development Plans, Guidelines for
Cork City Council welcomes the OPR’s overall support for the rational and evidence- based approach adopted to deliver the Draft Plan’s Core Strategy and Settlement Hierarchy. The Draft City Development Plan and associated supporting studies have largely been prepared in the absence of the Draft Development Plan Guidelines for Planning Authorities (Draft DPGPAs), recently published in August 2021. However, the detailed approach applied to deliver the Core Strategy and the Draft Plan aligns with the methodologies and objectives set out in the draft DPGAs – further detail is set out in other responses contained below. In response to the issues raised in “ Recommendation 1 ” , this Report further clarifies how the multiple outputs from the supporting studies have played a key role in developing the Core Strategy by using a practical, logical and evidenced based approach. The City Capacity Study, referred to section 2.31-2.33 of the Draft Plan is being used to inform the formulation of the Core Strategy, and its subsequent implementation. A City Capacity Study report will be included in the Material Amendments that will be placed on public consultation in April 2022. This “Cork City Capacity Study 2021” report will outline a two-year evidence based and iterative process, which includes ongoing input from key internal and external stakeholder. The report will set out the following key phases:
• Phase 1: Identification of Underutilised sites
Phase 2: General Viability Assessment
•
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Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
Planning Authorities, Draft for Consultation (2021), the planning authority is required to review the Core Strategy and to revise as necessary to: (i) comply with the requirements of the Section 28 Guidelines: Housing Supply Target Methodology for Development Planning (2020) and Appendix 1 of the accompanying Ministerial Letter to Local Authorities of 18/12/20; (ii) provide a single core strategy table for the planning authority area as a whole which clearly identifies population growth and housing targets for each tier across the settlement hierarchy, including for each individual urban town (tier 4) and the rural hinterland (tier 5). Note: Appendix A of the Development Plans, Guidelines for Planning Authorities, Draft for Consultation (August 2021) provides a useful reference and illustrative example of a core strategy table.
• Phase 3: Capacity Constraints Assessment
• Phase 4: Application of Strategic Planning Issues
Phase 5: Identification of City Capacity
•
• Phase 6: Recommendations for the Core Strategy
Having regard to the request to provide a single core strategy table for each tier across the settlement hierarchy, a revised, single core strategy table will be provided at Material Amendment stage. This table will combine the outputs of the existing Tables 2.2, 2.3 and 2.4 of the Draft Plan, as amended herein. It should be noted that the Draft Plan uses three tables in order to avoid overcomplication of detailed population and housing targets at sub-city level. The Cork Joint Housing Strategy and HNDA November 2021 was updated in November 2021 to take account of the dynamic policy context in the form of the s28 Guidelines for Planning Authorities pertaining to Housing Supply and Housing Need and Demand Assessment, as well as those for the Development Plan in draft form. Cork City Council’s proposed housing supply target has been amended to define a Housing Supply Target of 16,238 homes during the Plan period. Cork City Council’s Table 1 is set out in Table 4.7 of the Joint Housing Strategy (see below).
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Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
Cork City Council are not pursuing the optional adjustment ‘E’ set o ut in the Section 28 Guidelines to facilitate convergence to NPF strategy to 2026. This adjustment is optional and exists to enable planning authorities to more gradually transition from the baseline or ‘business as usual’ scenario to the NPF ‘50:50 City’ scenario where necessary and justified. It is the position of Cork City Council that the Draft Cork City Development Plan 2022-2028 aligns fully with the NPF and its associated population and household scenarios Adjustment F is not considered applicable as recent supply (row B) is not close to or exceeding demand (row D). As highlighted by the OPR, Cork City Council also proposes to apply the facility for the “Additional Provision” of zoned land in order to provide local choice set out in 4.4.3 of the Draft Development Plan Guidelines for Planning Authorities. The justification for the application of the Additional Provision for each settlement will be set out in the revised Core Strategy. The justification for the
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Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
application of the Additional Provision is rooted in the justification tests (a-h) set out in 4.4.3 of the Draft GPA, including: sites zoned support Compact Growth and integrated land use and transportation; and are serviced or serviceable within the Plan period. Recommendation: (i) The Draft Plan will include a coherent Core Strategy based on the requirements of the Section 28 Guidelines: Housing Supply Target Methodology for Development Planning (2020) and Appendix 1. (ii) A single core strategy table that identifies updated population growth and housing targets for each tier across the settlement hierarchy will be provided at Material Amendment stage.
1.2.2. Settlement Strategy
The OPR’s overall support for the settlement hierarchy is welcomed.
The settlement hierarchy is generally appropriate and consistent with national and regional policy. The identification of three tiers within the city, comprising the (1) city centre, (2) docklands and (3) city suburbs, is considered to be consistent with the draft Development Plan Guidelines. The draft Plan also appropriately defines (4) the urban towns and (5) the rural hinterland as separate tiers.
Recommendation: No change.
1.2.3. Distribution of Growth
The OPR acknowledges that much of the anticipated growth is dependent on infrastructure that will come on stream towards the end of, or after the current plan period. The OPR also notes the rationale set out in the draft Plan regarding the need to develop sufficient population in Ballincollig to justify the proposed Light
Cork City Council welcomes the OPR’s recognition that much of the anticipated growth is dependent on infrastructure that will come on stream towards the end of, or after the current plan period. Sections 2.34 – 2.38 of the Draft Plan show that, while a recent increase in planning activity is a progressive step, the implementation of planning
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Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
Rail Transit (LRT) route, which is included in the National Development Plan, and is satisfied that the overall balance is reasonable for the plan period. Concerns are expressed in relation to the growth allocations for Blarney / Stoneview – in light of the current uncertainty in the timeframe for delivery of key enabling infrastructure including addressing strategic water services infrastructure constraints over the plan period – and Tower – in view of it being a less accessible location by sustainable modes. Recommendation 2 – Distribution of Growth Having regard to the NPO3b and NSO 3, the planning authority is required to review the proposed distribution of population and housing allocation in its Core Strategy to: (i) ensure that the level of growth proposed for Blarney/Stoneview is aligned to with the level of services, including water services infrastructure and public transport services upgrades, anticipated to become available over the Plan period or within a reasonable period thereafter. (ii) Where there is uncertainty on infrastructure delivery timelines, phasing should be provided for growth in tandem with the delivery of key enabling services and infrastructure. (iii) Review the level of growth for Tower to reflect its less accessible location and redistribute the growth to locations that are consistent with compact growth and sustainable mobility.
permissions and the actual delivery of residential units in Cork City remains fundamentally dependent on the market. This low delivery of granted planning permissions is not singular to Cork City Council, reflecting a national trend. The timely delivery of key national, regional and local infrastructure will be the key determinant to ensure the housing market in Cork City can deliver the required housing stock to meet ambitious NPF population growth targets. In this regard, attention is also drawn to the following objectives set out in Chapter 2 (Core Strategy) of the Draft Plan. These objectives will require substantial support from a range of key external stakeholders at national, regional and local levels. Cork City Council also welcomes the OPR’s recognition that sufficient population growth is required in Ballincollig to justify the proposed Light Rail Transit (LRT) route. In relation to (i), as outlined in the Draft Plan, Stoneview which is situated 1.9 km northwest of Blarney town centre, has been identified in successive plans as a major residential expansion for the town. It occupies a strategic position on the Cork suburban railway line and the development of a large site in close proximity to the suburban rail network offers a major opportunity to achieve high modal shift by providing new homes at a location where residents can gain easy access to high quality rail. However, there are a number of infrastructural constraints which will prohibit development of this site in the short term, primarily water services and the need for major local road upgrades, the identification of the location of a railway station and the route of the N/M20. During the lifetime of this Development Plan, Cork City Council will collaborate with key stakeholders including Irish Water, NTA, Irish Rail and TII to develop solutions to these constraints and provide a Framework Masterplan for the coordinated development of this site which is considered paramount in delivering on the ambitions for both Blarney and Cork City in the National Planning Framework.
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Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
Taking into account recommendations set out elsewhere in this report, in relation to the application of “ZO 3 Tier 3 Residential Neighbourhoods” (see “ Recommendation 5 ” below), i t is proposed to omit the “ZO 3” zoning objective and designate all “ZO 3” lands as “Longer Term Strategic Development Lands”. Cork City Council acknowledges that similar constraints at Ringwood immediately east of Blarney and a similar approach to that being applied at Stoneview is proposed. It is envisaged that the lands currently zoned “ZO 2 New Residential Neighbourhoods” in Stoneview and the site in Ringwood, Blarney adjoining the N20 to the south will be rezoned to “ZO 3” and consequently redesignat ed as “ Longer Term Strategic Development Lands”. The remaining “ZO 2” lands in Ringwood align with the principle of compact growth taking into account their location and context within the town. The Planning Authority is satisfied that the remaining residential zonings to the west and north of the town centre can be facilitated through minor infrastructural interventions during the lifetime of this plan. In relation to (iii), the level of growth allocated to Tower is considered reasonable given its location in an area proposed to be served by BusConnects and Active Travel measures including a cycleway and a new public transport connections to Ballincollig and Strategic employment areas at Holyhill. Recently planning permission has been granted for 73 units on lands to the west of Tower, in line with current land use planning objectives. Recommendation: Change the zoning of the lands currently zoned “ZO 2 New Residential Neighbourhoods” in Stoneview and the site in Ringwood, Blarney adjoining the N20 to the south to “ZO 3” and redesignate to “Longer Term Strategic Development Lands” (see “ Recommendation 5 ” below).
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Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
1.2.4. Core Strategy & Zoning for Residential Use
The Core Strategy sets out the estimated housing yield from proposed tier 1 and tier 2 zoned land (18,741 housing units). Although this is higher than the housing supply target calculated by the Office, the Office would draw attention to section 4.4.3 of the draft DPGs, which allows for ‘Additional Provision’ of residential lands, not exceeding 20-25% of the required quantum of zoned land and sites in any settlements, for the six year plan period, subject to justification. However it is not clear whether the quantum of zoned land referred to in the Core Strategy Table takes account of lands zoned primarily residential and lands zoned for residential and a mix of uses. This should be clarified and the figures amended as necessary to take account of all lands with residential potential. It is also unclear whether the core strategy potential yield takes account of all lands zoned ZO 01 Sustainable Res Neighbourhoods (effectively ‘existing residential’) in addition to ZO 02 New Res Neighbourhoods (new residential). the densities applied to the City Suburbs and to the Urban Towns appear very low, calculated at 24.5uph and 26.4uph, respectively, from Table 2.3 of the Core Strategy. The Office fully accepts that it is reasonable for the draft Plan to provide a tailored approach to densities when estimating the requirement for zoned land depending on the size and character/function of individual settlements or areas. It is nonetheless important that the assumptions used are consistent with the ranges advised in the Section 28 Guidelines on Sustainable Residential Development in Urban Areas (2009) and Circular NRUP 02/2021 Residential Densities in Towns and Villages.
While the Draft Plan and associated supporting studies have largely been prepared in the absence of the recently published (August 2021) Draft Development Plan Guidelines for Planning Authorities, it is consistent with the methodologies set out in these guidelines, in particular that: • The process of preparing a county or city development plan must be informed by local experience of planning over time. The draft Cork City Development Plan has been realistically informed by the delivery and outcome of previous plans and planning objectives for the area. (see Section 1.6 of the guidelines). • While the Draft Plan makes provision for zoned and serviced sites that will come forward over the period of the Plan, the Draft Plan also recognises the need for some degree of competition and choice in the residential development land market and thus zones more land for residential (or a mixture of residential or other uses) than would equate to meeting precisely the projected housing demand for Cork City. The Council’s objective is to avoid restricting the supply of new housing development through inactivity on particular landholdings or sites, which has been the experience in some development areas of Cork. Therefore, the Draft Plan sets out the mechanism to employ for ‘Additional Provision’ for additional land in accordance with the Draft Guidelines. The Core Strategy will be amended to clearly set out this requirement. (Section 4.4). To achieve the NPF targets for Cork City in a planned way, Cork City Council has identified sites will be developed as ‘Long Term Strategic and Sustainable Development Sites’. Cork City Council will advance planning of these sites so
26
Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
that they can be developed within the medium to long term in accordance with Section 4.4.4 of the Guidelines. The Core Strategy will be revised, as outlined below, to reflect the points above. In relation to Recommendations (i) and (ii), given the detailed assessments carried out as spart of the Capacity Study referred to above, the quantum of zoned land referred to in the Core Strategy has taken account of all underutilised zoned lands. This includes potential residential yields for lands zoned ZO 1 Sustainable Res Neighbourhoods (effectively ‘existing residential’ zoned lands). As set out in section 2.52 of the Draft Plan, reasonable and realistic assumptions are used to ensure the Core Strategy targets are grounded to ensure deliverable outcomes. The City Capacity Study details how these assumptions are applied on a site-by-site basis. Extracting calculations for different areas of the city from Table 2.3 of the Core Strategy, therefore, results in the appearance of low densities. This is however not the case, and the density ranges allowable for different areas of the City are as set out in Chapters 3 and 11 of the Draft Plan. The Core Strategy does not set out density-related outputs showing the full build out of every zoned site identified for future development in the city as this would form part of the Development Management and Active Land Management Process, which is informed by the density policies of the plan. The Core Strategy presents realistic and grounded targets (based on capacity constraints, complex build out timeframes, etc) that align with the NPF. Given the complexities associated with urban development (as set in more detail above), this evidence-based and grounded approach is particularly relevant to Cork City. In the context of the RSES for the Southern Region 2031, it is also important to note the SRA submission no 400, including reference to the requirement for advance planning to achieve the growth targets set for Cork City under the NPF and Cork MASP.
Recommendation 3 - Core Strategy and Zoning for Residential Use Having regard to sections 10(2A)(c) and (d) of the Act and to the provisions of the Development Plans, Guidelines for Planning Authorities, Draft for Consultation (August, 2021), the planning authority is required to review the core strategy to: (i) Provide details of the existing area (ha) and associated housing yield for residential use and for lands zoned for residential and a mixture of other uses, as required under s.10(2A)(c)). (ii) Take account of all lands proposed to be zoned under the Plan which have potential to accommodate residential development. This includes not only ZO 02 New Res Neighbourhoods, but lands zoned Z0 01 Sustainable Res Neighbourhoods and all lands proposed to be zoned to accommodate residential uses and a mixture of other uses. (iii) Review the density assumptions in Table 2.3 of the Core Strategy to ensure that residential densities within the ranges advised in the Sustainable Residential Development in Urban Areas Guidelines (2009) and Circular NRUP 02/2021 Residential Densities in Towns and Villages have been applied.
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Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
In relation to (iii), Table 2.3 will be updated to illustrate the density targets in response to the illustrative Core Strategy Table set out in Appendix One of the Draft Development Plans Guidelines for Planning Authorities on (August 2021). Densities have been expressed on the basis of the gross site areas. The density targets in the Draft Plan are much more ambitious than that set out in s28 Guidelines, and are based upon the Cork City Urban Density, Building Height and Tall Building Study (2021). Density targets for the City have been prepared in response to the attributes of the City, its settlements and neighbourhoods with four density bands identified (refer to Volume 1, Figure 3.3 and Table 11.2 and Volume 2: Mapped Objectives of the Draft Plan for the relevant detail). Framework Plans will be prepared for all key development areas, and the more detailed consideration of sites and their attributes and capacity is very likely to lead to increases in the yield of sites when compared to the density assumptions applied across the Core Strategy. Refer to Part 3, Chapter 2 for details of revisions to the Core Strategy. The “Cork City Capacity Study 2021” will be included in the Material Amendments that will be placed on public consultation in April 2022. This report will outline a two-year evidence based and iterative process, which includes ongoing input from key internal and external stakeholder. (ii) The quantum of zoned land referred to in the Core Strategy has taken account of all underutilised zoned lands. See (i) above. Recommendation: (i) (iii) Table 2.3 will be updated to illustrate the density targets in response to the illustrative Core Strategy Table set out in Appendix One of the Draft Guidelines for Planning Authorities on Development Plans (August 2021).
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Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
1.2.5. Tiered Approach to Zoning
The preparation of a City Capacity Study to assess the capacity of Cork City for future development within existing underutilised zoned lands is welcomed. However, this study has not been included as part of the draft Plan and cannot be evaluated for consistency with the specific requirements of NPF. Figure 2.2 Growth Strategy Map and Figure 2.22 Built Up Footprint and Greenfield Growth Target Locations 2022-2028 are welcomed as they identify the existing built up area and Tier 1 serviced and Tier 2 serviceable lands. The requirement for tiered approach to zoning refers to all proposed zonings as the planning and provision of infrastructure has to be carried out for all development lands. Recommendation 4 - Tiered Approach to Zoning Infrastructure Assessment Having regard to NPOs 72a to 72c and to the provisions of the Development Plans, Guidelines for Planning Authorities, Draft for Consultation (August 2021), the planning authority is required to complete and publish as part of the draft Plan, an infrastructure assessment / Settlement Capacity Audit consistent with the requirements of the National Planning Framework for a standardised approach to the tiered approach to zoning and the provisions of the draft Development Plan Guidelines for Planning Authorities (2021) concerning settlement capacity audits. The assessment is required to address all relevant development lands proposed to be zoned under the Plan. The Office would advise that the planning authority should, in particular, consider the capacity constraints affecting Blarney/Stoneview and how they may best be resolved during the Plan period to ensure the delivery of the housing supply targets.
As detailed under Recommendation 3 above, to add further clarity to Cork City Council’s plan making approach, “Cork City Capacity Study 2021” will be issued as an additional supporting document. This report seeks to further clarify how the multiple outputs from the plans supporting studies have played a key role in developing the Core Strategy by using a practical, logical and iterative approach. Recommendation: (i) Include a City Capacity Study report in the Material Amendments that will be placed on public consultation in April 2022. In relation to Blarney / Stoneview, see “ Recommendation 2 ” above.
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