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
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