Submission from the Office of the Planning Regulator (Submission No 426)
Issues / Recommendations / Observations
Chief Executive’s Resp onse & Recommendation
1.2.6. Tier 3 Lands
It is good practice to identify Tier 3 brown and greenfield lands in the Plan, or as part of the infrastructure assessment informing the Plan, as part of the longer term strategic planning approach in line with the NPF and the RSES. However, the current policy has the potential to create an additional bank of zoned lands that have not been subject to a full infrastructural assessment under the tier-approach to zoning and for which there is no basis in national or regional policy. The City Docks is an exception in his regard due to its highly strategic location and nature as a major strategic brownfield regeneration site. Recommendation 5 - Tiered Approach to Zoning Having regard to NPO 72c and to the provisions of the Development Plans, Guidelines for Planning Authorities , Draft for Consultation (2021) concerning the mechanism for ‘ Additional Provision’ , the planning authority is required to omit the zoning objective ZO 3 Tier 3 Res Neighbourhoods and to not zone tier 3 lands in the final Plan. The planning authority may consider other objectives in the Plan and associated maps to ensure that longer term development lands are identified as it may consider necessary for strategic purposes.
Cork City Council welcomes the OPRs recognition of the need for a longer-term strategic planning approach in the Draft Plan in order to deliver on the overriding RSES and NPF objects. Cork City Council also welcome the OPR’s response and recommendation that City Docks is a major strategic and long term brownfield regeneration site. Cork City Council is committed to planning for the strategic growth of Cork City, beyond the life of the next City Development Plan, to achieve the ambitious national growth targets for the city. Part of this strategic approach taken towards planning for Cork City 2040 is the inclusion of a Tier 3 land-use zoning. This generally correspo nds with the OPR’s view on identifying key longer-term strategic development lands. However, Tier 3 as proposed in the Draft Plan includes a caveat that may facilitate development on some Tier 3 lands subject to certain criteria being met, as a more applied method of securing development that can be delivered in the next Plan period. Tier 3 was also introduced to address legacy issues relating to the 2019 boundary extension and the quantum of lands currently zoned in the existing suite of Cork City Council and Cork County Council statutory land use plans. The Tier 3 lands represent a sizeable proportion of the lands likely to be required to achieve the growth ambitions over the next three plan periods. The timely delivery of key national, regional and local infrastructure will be the key determinant to ensure the housing market in the city can deliver the required housing stock to meet the ambitious NPF population growth targets set out in the Draft Plan. It is important that there is sufficient flexibility in the land use zoning strategy to ensure adequate lands are made available to meet the housing needs of the city during the life of this plan, and also the two subsequent plans leading up to 2040. It is also important to secure a sustainable growth pattern by preparing
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