Celbridge Local Area Plan – Submission
The Case for deferring the Celbridge Plan:
The Celbridge Local Area Plan is part of a subset of plans linked to the County Development Plan. Section 10 of the Planning & Development Act, 2000 (1) states “A development plan shall set out an overall strategy for the proper planning and sustainable development of the area of the development plan.
The 2005 County Development Plan, which has not been varied, lists Celbridge as a Moderate Growth Town, defined as meaning a population of between 5,000 and 15,000.
Section 19 (2) of The Planning and Development Act, 2000 states:
A local area plan shall be consistent with the objectives of the development plan….
The 2009 Draft Celbridge Local Area Plan currently on display is not consistent with the 2005 County Development Plan in that the 2006 Census revealed Celbridge had a population of 17,262 and the plan proposed zoning a further 28.6ha to accommodate 3,222 persons during the lifetime of this plan. This is in addition to land zoned in the last plan for residential and not as yet built on.
The planning guidelines for the Greater Dublin Area which are prepared by the Dublin and Mid East Regional Authorities are currently under review. The Planning and Development Act, 2000 section 23 states:
(1)
(a) the objective of regional planning guidelines shall be to provide a long-term strategic planning framework for the development of the region for which the guidelines are prepared.
(b) The planning framework referred to in paragraph (a) shall consider the future development of the region for which the guidelines are prepared for a period of not less that 12 years and not more than 20 years.
Given the changed economic environment it would be safer to defer the making of the Celbridge Local Area Plan until (a) the new Planning Guidelines are in place (b) until the new Development Plan is either adopted or the 2005 Kildare County Development Plan is varied.
The Planning and Development (Amendment) Bill 2009, section 10 seeks to change the law in relation to the making of Local Area Plans, the explanatory memorandum states;
Section 10 states…..In order to ensure LAP’s are comprehensively linked to the City or County Development Plan (which is reviewed every 6 years), the lifespan of the LAPs is increased to 10 years, although where an LAP is no longer consistent with the City or County Development Plan (where that plan has been reviewed or varied) there is a requirement to vary or review the LAP within 1 year….”
Delaying the making of the Local Area Plan would streamline the development process in the County.
Section 23 proposes to extend the lifespan of existing planning permissions as follows;
This section seeks to amend section 42 of the Principal Act (2000 Planning and Development Act, 2000) as follows; currently provides that the duration of a planning permission must be extended, subject to certain conditions, where substantial works have been carried out before the expiration f the original permission. The proposed amendment provides for the extension of permission (for a period of up to 5 years) in circumstances where substantial works have not been carried out, but there were commercial, economic or technical considerations, beyond the control of the applicant, which substantially mitigated against either the commencement of development or the carrying out of substantial works. The previous provision is also amended by removing the possibility of a second extension of permission.
Clearly planning laws are being changed to take account of the changed economic environment, deferring consideration on Local Area Plans
Section 5 of the Bill states; The core strategy shall also provide the policy framework for Local Area Plans, particularly in relation to zoning at LAP level. The location, quantum and phasing of proposed development must be shown as well as growth scenarios, details of transport plans and retail development….
In the current economically unstable environment where there is an excess rather than a shortage of housing stock, zoned land etc. and where the provision of new schools, water/wastewater infrastructure; transport infrastructure, community facilities etc will place new demands on scarce national finances, together with the absence of local finances where a local contribution is mandatory, seeking to delay zoning further lands through LAP’s makes both economic and planning sense until the broader strategic issues have been considered which should be somewhat clearer when the Regional Guidelines have been finalised.
In the absence of the arguments included above succeeding I wish to make the following points in relation to the Celbridge LAP 2009.
PLANNING HISTORY
The planning history prior to 2006 seems to have been ignored in the current review of the LAP. Celbridge has experienced some of the most rapid population growth in the state which can be seen in the table below. Zoning further lands may result in that growth continuing. The figures in the last two columns are taken from page 13 of the Celbridge LAP.
Population profile of Celbridge
| 1971 |
1979 |
1981 |
1986 |
1991 |
1996 |
2002 |
2006 |
2011 |
2016 |
| Estimate |
Estimate |
|
|
|
|
|
|
|
|
| 1,579 |
3,324 |
4,583 |
7,199 |
9,629 |
12,289 |
16,016 |
17,262 |
20,727 |
24,192 |
In order that infrastructure and facilities in the town could catch up with residential development the County Strategy for the 1999 County Development Plan included zero zoning for Celbridge for the following Celbridge LAP. There was evidence of pressure on schools, lack of community facilities particularly for the disproportionately young population and there were substantial traffic management problems with key pieces of infrastructure missing or under construction.
The subsequent Celbridge Plan deviated from the County Strategy and in addition to land that was zoned but not as yet developed or under development, zoned a further 87 acres of land for housing in two distinct strips; north of Castle Village, and along the Ardclough road. In addition 11.96 ha was zoned for low density residential in Donaghcumper Demesne, the town centre expansion was also included, however, this was to be the subject of an Action Area Plan, the expectation was that there would be some limited residential here also. In response to a question from myself recorded in the Minutes 30th July 2001 Kevin Kelly stated; There was about 100 acres zoned residential plus the low-density acreage at Donaghcumper.
At the Council meeting to deal with the draft and final plan Each of the Celbridge Area Councillors (Deputy Emmet Stagg, Cllr Geradline Conway and Cllr Kate Walsh) stressed the benefits that would accrue to Celbridge from the 87 acres of new residential zoning (estimated at the time this would produce c800 residential units). Nowhere in this plan was it expressed by council officials or Councillors that the Donaghcumper Lands would provide accommodation for 1260 people in 500 residential units (page 13 of current draft Celbridge LAP). What was stressed was that one piece of land was to be zoned for low density housing at 4 houses to the acre.
Chairperson of the Area Committee summed up the plan as follows;
“This is a positive, sustainable plan, limiting new housing to the bare minimum, with roads planned and things in place before developments are sanctioned further. In short, this plan offers a massive community payback.”
Given the under provision of school facilities, the continued problems with traffic management, the under provision of social infrastructure etc its difficult to see how the community of Celbridge will agree there has been significant payback for the extent of land zoned in 2001.
When the 87 acres of land were proposed for rezoning that was measured against the adequacy or otherwise of the local schools. There was no expectation of large scale housing development in the Donaghcumper and no account was taken for schooling needs. Indeed it appears the extent of residential provision included in the current LAP follows the planning application made by Devondale and are driven by commercial considerations rather than led by any planning rationale.
Draft Local Area Plan 2009 – Section 7 POPULATION
7.1 Background
According to the 2006 census County Kildare has a population of 186,335 persons. Celbridge accounted for 17,262 or 9.26% of the County’s total population…..
Having regard to the proportion of the County’s population resident in Celbridge from the 2006 Census, it is assumed that Celbridge will continue to account for 9.26 of the revised RPG figures, which would equate to a total additional population figure of 6,930 between 2006 and 2016.
This assumption justifies the inclusion of 29.6 Ha of new residential at a population density higher in some cases of between 35 and 50 units per hectare. With section 10.2 stating the Residential Quantum of new Residential zoning in the 2009 Draft Local Area Plan is 52.1 ha (128.7 acres).
The shortage of school places, the absence of funds to deliver on key issues such as the recently adopted Traffic Management Plan, the significant lack of social infrastructure particularly for young people in Celbridge to assume a continued pattern of 9.26 does not take account of the reality of life in Celbridge. It further highlights the deficiency with the narrow focus of social infrastructure assessments which don’t measure in any meaningful way the adequacy of community, leisure and sporting facilities or the level of public services it possible to fund such as public transport, additional Gardai, community health related services etc.
Part B Objectives of the 2009 Celbridge Development Plan states
The overall vision for Celbridge is for its growth as a “Moderate Growth Town” within the metropolitan area of the Greater Dublin Area……That according to the current County Development Plan means the town will not exceed a population of 15,000.
This statement conflicts with the assumption for continued growth in Celbridge. Given that the settlement strategy is the cornerstone of any development plan it is essential that there is a firm basis for the assumptions being made. The availability of zoned/serviced land, the cost of housing etc were the primary basis of the 9.26% growth pattern, the collapse in the property market undermines the assumption that the growth pattern will continue over the lifetime of this plan at 9.26%.
LIFFEY VALLEY
4.12Lifey Valley Strategy Page 10
In Celbridge the projects include the creation of a public park in the Donaghcumper lands and the creation of river based linkages with Castletown estate (it is not made clear if that relates to Castletown Demesne or Castletown Housing Estate the wording requires a small amendment)
The other proposal is the enhancement of the Celbridge town centre and its industrial heritage. In addition the refurbishment of the pedestrian bridge adjacent to the Mill is also recommended
The Liffey Valley Strategy Document Page 67 also recommends a single distinctive brand for the Liffey Valley defined as meaning
Liffey Valley Special Area Conservation Order
Towards a Liffey Valley Park – Strategy Document
Enhanced works to the town centre with a particular emphasis on the Industrial Heritage at the Mill is recommended. Page 67 of the strategy also recommends a single distinctive brand defined as meaning signage and high quality interpretative boards. This should be included in the Celbridge LAP as an objective.
P33 H11 does not list Liffey Valley
Ensure that developers for any developments in the vicinity of or affecting a designated candidate Special Area of Conservation or National Heritage Area provides sufficient information on how it will impact upon the site and what measures will be put in place to remedy same. An Appropriate Assessment will be required for developments that may impact on the Rye Water Valley/Carton SAC and the Royal Canal.
The Celbridge LAP refers in section 9.1.1. to Natural Heritage Area’s and Special Areas of Conservation specifically
9 Conservation “The Liffey Valley (pNHA Site code: 000128) lies within 3km east of Celbridge.” It will come as a surprise to many that the Liffey which dominates life in Celbridge is proposed for conservation 3km east of the town. The area in question is within Fingal and has been subject to a Special Area Order since 1990. While there has been an aspiration to extend that order into Kildare, such an order has to date not been made. I am now proposing that such an order is made in Kildare and is referred to as an objective in the Celbridge LAP. The aim of the special area amenity order is to protect, preserve and enhance the character and special features of the Liffey Valley
Consideration is also underway towards development of a Liffey Valley Regional Park, this should be referred to in the Celbridge LAP.
9 Amenity and Recreation Objectives Part B
AR2 Any development along the Liffey valley will be required to take cognizance of the Liffey Valley Strategy “Towards a Liffey Valley Park” and in particular to the vision and objectives set out in the Strategy….. as set out above.
It is recommended that in the case of large planning applications and where areas of application fall within the visual catchment of the River, such application should be accompanied with a visual impact assessment….
AR5 it is an objective of the Council to:
(a) Protect and preserve views from the bridge over the Liffey, upstream and down stream.
(b) Protect and preserve views from “Rock” footbridge, upstream and down steam.
It is not possible to protect the views when lands at Donaghcumper have been set aside for development and where building of 4 and 5 stories are permitted.
DONAGHCUMPER
Planning and Development Act, 2000 Section 10 (8) states;
“There shall be no presumption in law that any land zoned in a particular development plan (including a development plan that has been varied) shall remain so zoned in any subsequent development plan.
In a submission to planning application 08/439 the Department of the Environment stated; “It is in our opinion unfortunate that the said lands were rezoned for residential use”.
For the following reasons I am seeking a reversal of the rezoning of the Donaghcumper Lands.
Donaghcumper Demesne was recently added to the list of protected structures by Kildare County Council. The supporting documentation for that decision states:
“Donaghcumper, is a possible early eighteenth century house with a Tudor revival extension circa. 1835. It has social historical links to adjacent demesnes of Castletown, St Wolstans, the Liffey and Celbridge. Thomas Conolly acquired it in 1801 to extend the boundaries of his estate. This allowed the Connolly’s to enhance the setting of Castletown demesne with neighbouring estates. The Liffey combined all of those adjacent demesnes under Connolly control…..”
Part B Objectives of the 2009 Celbridge Development Plan states
The overall vision for Celbridge is for its growth as a “Moderate Growth Town” within the metropolitan area of the Greater Dublin Area……
Particular attention shall be paid to protecting and enhancing the natural, built and archaeological heritage of the town…
Chapter 20 Architectural Heritage of the County Development Plan states;
20.4.2
“It is an objective of the council to prohibit development in gardens or landscapes which are deemed to be an important part of the setting of a protected structure.”
20.5.2.
“any development within the curtilage and or attendant grounds must demonstrate that it is part of an overall strategy for the future conservation of the entire complex including the structures, demesne and or attendant grounds”
Celbridge LAP
Section 4.4. Kildare 2012 – an Economic, Social and Cultural Strategy
The Kildare County Development Board Strategy “Kildare 2012 – an Economic, Social and Cultural Strategy” sets the framework within which the Kildare County Development Board will operate for the next 10 years. The vision of the strategy is to make
“Kildare – the first choice as a place to live, learn, work, visit and do business.”
The strategy focuses on six key objectives, which are vital to ensuring this vision.
These are to
1) Develop transport and communications
2) Respond to new settlement patterns
3) Respond to contrasts within the county and towns
4) Protect the environment
5) Develop education, training and capacity building and
6) Develop a sense of place.
Given the population of Celbridge in 1971 and the rate of development that has occurred since then, building a sense of place requires understanding of why it was their chosen destination. The New Urban Living project did some valuable work we can draw on in that regard.
The New Urban Living project conducted in NUI Maynooth studied the emerging social fabrics of four new suburbs and satellite towns in the greater Dublin region, Lucan, Leixlip, Mullingar and Ratoath, which were considered to be representative of development patterns occurring throughout much of Ireland’s cities and towns. The study found that the ‘attachment to place’ of local residents was influenced by four main factors: the built and natural environment, the cultural character and life of the area; the quality of informal associational life and ‘elective belonging’ – reasons why people had chosen to live in their place of residence. The study found evidence of strong attachment of residents to their town and locality even though they may have moved there from outside the county. Coupled with CSO figures showing that in 2006 around 40% of people living Kildare were born in-county (a decrease from 60-70% in 1996), a more dynamic picture of identity-formation below county-level is emerging.
Celbridge is listed as a level 3 in Kildare’s retail hierarchy. The Retail Strategy identifies Collinstown as a Level 2 Major Town Centre to provide for the North Kildare Area. Collinstown is not referred to in the Celbridge LAP. Despite the fact that Celbridge has been designated level 3 which provides for local need 11.96 acres have been zoned for an extension to the existing town centre. This is in addition to other retail outlets in the town. The designation of Collinstown as level 2 followed sequential testing of Celbridge, Leixlip, Maynooth and Kilcock, their ability to absorb traffic associated with such a large development ruled all out as a preferred level 2 location.
Development Principles state;
Clear connections between the existing town centre and the Donaghcumper lands are essential. A road bridge and a pedestrian bridge are of high importance applying high quality design standards due to the close proximity to Castletown gates and nearby protected structures. It is not just the physical environment that requires consideration, traffic management in such a confined area together with the need for a complex signaled controlled junction to manage both pedestrian and vehicular traffic including HGV’s will need to take account of nearby protected structures.
The Environmental Impact Statement for planning application 09/665 states It is estimated in the associated EIS the “New Town Centre” will generate 25,008 daily two way trips.
Amendment
9.3 Built heritage
Amend CE37 to read Donaghcumper House and Demesne, rather than just referring to the Building.
Development Principles states
Donaghcumper house is of historic and architectural importance and is now a protected structure…. This statement should be revised as follows, Donaghcumper House together with its demesne is a protected structure.
Master Plan image – included in submission to Kildare County Council
Below is an image of the Master Plan for Donaghcumper submitted as part of planning application 09/663. The Dublin Road visible on the left hand side will if permitted dramatically change the historic entrance to Celbridge with the demolition of the boundary wall at Donaghcumper and the erection of a high density mixed modern development.
HERITAGE
3. Development Goals include
• To protect and enhance the unique architectural and archaeological heritage of the town.
HE1 to protect, conserve and enhance the natural, built an archaeological heritage.
HE 2 to ensure the maintenance of the historic character and built form of the town centre of ‘Celbridge by respecting building heights…..
NH8 to preserve views and prospect the from the bridge over the River Liffey, upstream and downstream and to ensure that further development along either of the water systems does not affect the quality of either the scenic viewpoint or the waterways amenity. New development adjacent to the riverside amenity area shall be restricted where such development could present a negative visual effect or disrupt the vistas available.
The proposed extension to the Town would change the unique architectural heritage of Celbridge, would result in the demolition of the demesne wall on the Dublin road and up it up to high rise modern development, would create the need to provide a number of traffic signal columns on Main Street in close proximity to protected structures such as Castletown Gates.
Retail
Retail Strategy adopted in 2004 included health checks and had done considerable survey work about retail requirements. This strategy is about to be revised, Celbridge would benefit from a postponement until that new strategy is in place. The new economic situation has reduced the need for commercial/retail space it is difficult to foresee how that will manifest itself into the future however adding new retail may lead to unused or underused buildings in key area’s such as Main Street. The new retail strategy will include some up to date survey’s that would help to inform policy.
10.1Retail/Commercial
“The Celbridge Development Plan 2002 zoned a total of 18.7 hectares (46.2 acres) of land as Retail/Commercial.”
Transportation Objectives
The new Celbridge Traffic Management Plan is not referred to and needs to be included. It also needs to be amended for example there is no provision for overcoming difficulties of access to and from Crodaun Forest Park Estate (both entrances).
An improved footpath should be included as a objective from Temple Manor to the Bridge.
Traffic calming is needed at Shakelton road.
TR6 We need to be shown possible routes, it is not clear if indicative rotes will be mapped and there is no opportunity for public consultation without this information.
TR10 seeks to investigate the provision of additional off street public car parking in the town centre, planning application 09/665 seeks a reduction of 52% in non residential parking standards. If agreed this will continue the pressure on the Main Street and provide a more favorable retail environment for car users which may result in the following (1) Main Street becoming less attractive for car users (2) the new retail locations (if granted permission) will be more car dependent which conflicts with the sustainable transportation aspects raised in the EIS.
Public Transport
The section of public transportation is poor and requires considerable amendment for example there is no connection between Celbridge and Leixlip despite the fact that there is considerable industrial development in the neighboring town. Second level school’s in Leixlip are also a destination for some Celbridge pupils for two reasons, (a) capacity in Celbridge schools and (b) both are coeducational schools. New orbital routes or possible destinations are referred to. The adequacy of current bus and rail services is not referred to. Developments on the Rail Line and feeder bus services are not referred to. Turning Circles for new routes within the town are not provided for. The plan has a stronger focus on the car as the main mode of transport. This section is so poor that it requires to be completely re written.
Social Infrastructure
The reason for the zero zoning for Celbridge, which was included in the 1999 County Development Plan was to assist in building a community rather than building more residential units. There is a disproportionately young population in Celbridge, the accompanying social/community infrastructure has not been adequately provided for. The additional development pressure has not assisted. Too often the focus is reactive i.e. seeking more Gardai the numbers of whom incidentally have not grown in proportion to the expansion of the town. The Social Infrastructure assessment is much too narrowly focused and a baseline study of social infrastructure including its deficits needs to be done. Planning applications for more then 50 residential units are required to produce a social infrastructure assessment.
This should include details regarding the type and location of facilities available in the locality including education, childcare, health recreational facilities and other facilities such as shops and post offices. It should be demonstrated, as part of any planning application that deficiencies, found to be arising in the availability of such services in the locality, shall be provided as part of the proposed scheme together with the type and location of same. In addition the onus shall be on the developer to satisfactorily demonstrate how the proposed increase in population will be accommodated in terms of education provision. In this regard, it shall be noted that 12% and 8.5% of population at any time is assumed to be of primary and secondary school going age respectively (Dept Ed)
(ii) Provide details of the total available places and the current spare capacity in local schools (a letter from the principal of the schools shall be required as part of the planning application)
6 Community, Educational, Childcare and Cultural Facilities
Survey of deficiencies needs to be included
• To ensure that adequate recreational facilities are available to the residents of the town.
This primarily relates to public facilities and has a specific requirement in relation to school place deficits. While the Development Contribution scheme did ring fence funds for community facilities, Celbridge had already amassed significant needs and the fund has now diminished considerably. The chapter dealing with population and growth also needs to consider the demographics i.e. a town with a young age profile will differ in needs to a town with an aging population. Following a baseline study it would be possible to include a social infrastructure matrix.
INDUSTRIAL
10.4 Industrial and Warehousing
Land was zoned for this use on the Maynooth Road close to the Celbridge Interchange. This is now one of the primary entrances to the town. In order to achieve an attractive entrance consideration should be given to the type of building that would be permitted here.
10.5 Residential/Commercial
This zoning provides for “Residential/Commercial” This area is in close proximity to Beatty Park, Ash Grove etc. Given the constraints for widening the Maynooth Road including a commercial zoning here would produce HGV traffic which simply cannot be accommodated. This area should be zoned residential only.
Management Companies
Kildare County Council recognises that certain development types, (such as apartment blocks or developments that consist predominantly of apartment blocks and where it would not be practical to isolate the infrastructure serving the apartment blocks from the conventional housing element of the development) require the creation of management companies to manage and maintain communal areas in the development.
Recommend this needs to be less proscriptive for example on the Continent some apartment blocks are managed by co operatives. Management Companies carry considerable legal obligations that might be less onerous with a different type of arrangement.
FLOODING
8.3 Surface Water
SEA Page 28 5.4.5 Flooding has been identified at a number of locations with the study area. These locations are illustrated in Figure 5.4. Mitigation measures should be included as objectives for each area where flooding has occurred in the recent past.
WASTE -SOLID
8.4 Waste
This section states that “refuse collection is currently carried out by a private contractor on behalf of Kildare County Council”. No reference is made to the licensing of other contractors so this section is factually incorrect and requires amendment.
DESIGN AND LAYOUTS – MAPPING
Objectives Part B Layout:
Need to include an new objective about quality linkages that do not become magnets for anti social behavior.
Layout (v) page 24 Objectives Part B
“Development shall not be permitted on designated areas of open space that form part of a site layout for previously permitted development.”
The zoning map should not be shown exclusively as existing residential, the map should show the green spaces as amenity. Prior to a policy change in the mid 1990’s Kildare County Council did not require developers to vest open spaces in the Council, the original developers of many mature housing estates are still listed as the land owner. Attempts have been made to return and seek further residential development. The maximum protection should be afforded in addition to the written statement the map should reflect the reality.
PARKING – LAYOUT
Layout (vi) Objectives Part B
Parking areas shall be sensitively designed, appropriately landscaped and carefully integrated into the overall development scheme.
High density schemes are a recent experience for Kildare County Council. One complaint that seems to emerge is where surface car parking is provided some distance from the entrance to the residential unit. Getting children safely from the car to their home which might include buggies, shopping etc. has been identified as a problem. The same situation arises for people with limited mobility or those who are disabled. Problems with recent estates should not be repeated. There is also an issue with visitor parking in high density estates. Should additional provision be made it will be necessary to avoid HGV parking.
RESIDENTIAL DIVERSITY
Design: Objectives Part B
(ix) Consideration should be given to the requirements of the elderly in the design of development schemes.
Many current residents who are aging may wish to relocate within the town. With heating costs set to accelerate because we are at or near peak oil production. Providing for those who wish to trade down will have the benefit of freeing up larger family type homes. Low maintenance apartments are often not seen as attractive for elderly people who have been connected to an area, they are often seen as transient in nature and more appropriate for a younger age range. Balconies are often the only private open space often resulting in complaints about noise. If we are to produce a housing stock that caters for the diversity of needs design of living communities needs greater consideration.
TELECOMMUNICATIONS
Objectives Part B
The visual impact of Masts needs an objective.
ERROR
T4 Error this refers to the Leixlip and not the Celbridge Plan.
To liaise with the ESB to investigate and encourage where possible the ducting and continued underground routing of overhead power lines in Leixlip, in tandem with other work programs, such as road resurfacing and footpath construction works.
New statement needs to be written it might also include interim initiatives such as tidying up cables.
ZONING PROPOSALS
There are three area’s proposed for rezoning for residential.
The Ardclough Road at Simmonstown
Some of the land at this location was zoned new residential and community and education in 2002. Given the economic environment it is unlikely funds will be provided for the construction of a school in this location within the lifetime of the plan. Given the level of development in close proximity in recent years I question how advisable it is to add further residential zoning here in this plan. The footpaths to the village are totally inadequate, the Ardclough Road is narrow and there is no provision for cycle ways. The new link road through Simmonstown Manor which links the Ardclough and Hazelhatch Roads does not provide an alternative route to the village. Given the availability of quality paths and cycle ways, and modern school buildings in close proximity, which are surrounded by housing estates that are slightly older perhaps freeing up space in the schools as a consequence. I question the rationale in preferring the Simmonstown option.
Shinkeen Road – The site is to the rear of the Cemetery and stretches to Primrose Gate.
The land is currently zoned Agricultural the proposal is to rezone it to “New Residential and Community and Education” . While I acknowledge the need for an extension to the cemetery and support the community and education zoning. I have questions as to the density proposed at this location between 30 and 50 units per hectare. The experience has been that developers tend to read maximum figures as minimum so applications are likely to be at the top rather than the bottom end of the range. The densities don’t improve the diversity of housing options in this part of the town and they should be reduced.
OBJECTIVES
Planning and Development Act 2000 Section 15
(1) It shall be the duty of a planning authority to take such steps within its powers as may be necessary for securing the objectives of the development plan.
Given the collapse in the development contribution fund and the proposed reduction in the local government fund I question if some of the costly objectives included in this plan are deliverable. It is one more reason why the adoption of the plan should be deferred.
OPEN SPACE AND AMENITY
10.6 Open Space and Amenity
“The council has recently approved the establishment of a parks department to develop and maintain public open spaces within the county.”
Town Centre
TC 9 Policy in relation to takeaway’s should also limit hours of opening