Port of Cork Company (POCC) Comments on the Draft National Planning Framework (NPF)

Transcription

1 Prt f Crk Cmpany (POCC) Cmments n the Draft Natinal Planning Framewrk (NPF) Intrductin The Prt Of Crk Cmpany (POCC) welcme the pprtunity t prvide cmments fr cnsideratin t the Draft Natinal Planning Framewrk (NPF). The POCC is very supprtive f the NPF initiative. POCC acknwledge that the Draft NPF is supprtive f Prt requirements and has cnsidered many aspects f the POCC riginal submissin. Nnetheless, minr amendments and / r additins t the Draft NPF wuld prvide further clarity n plicies and initiatives required t facilitate sustainable grwth f critical strategic prt related develpment and the ptential f maritime ecnmic and leisure activities. The Prt f Crk is a key asset in facilitating natinal and reginal grwth and can psitively cntribute t the bjectives identified in Crk 2050 and the NPF. POCC Strategic Plan has identified future prt lcatins in Crk s lwer harbur, as fllws: Ringaskiddy Marin Pint Cbh Aghada / Whitegate Cnsent is in place fr the redevelpment f Ringaskiddy t accmmdate cntainer activities, and in the lnger-term Rll-n Rll-ff freight trade. Hwever, further investment in prt facilities in the Crk Harbur and assciated infrastructure is required t supprt the bjectives f the Draft NPF fr the sustainable grwth f Crk and its regin. There is als a need fr further plicy supprt t facilitate prt related develpment; realise Ireland s full maritime ptential; and streamline maritime and prt related develpment cnsent prcedures. Submissin Request - Overview POCC request that the draft NPF is amended t facilitate the full ptential f Prt Infrastructure and activities; supprt the upper harbur redevelpment lands in Crk; and facilitate Maritime Resurces as key grwth enablers fr the Suthern Regin. In verview, the amendments sught by POCC relate t planning plicy bjectives; infrastructure pririties; enabling renewable & sustainable develpment; implementatin; and maritime ptential, as fllws: Planning Plicy Objectives The Prt f Crk Strategic Develpment Plan shuld be a key cnsideratin f the RSES review fr the Suthern Regin. Prt Cmpanies shuld be recgnised as prescribed bdies within the planning apprval system. Crk Dcks (including Crk s City Quays) and Tivli are key Tier 1 Zned lands f strategic significance t the city s grwth targets. Strnger and clearer plicies shuld be put in place t enable their regeneratin and sustainable develpment, including: Relcatin f Seves sites frm the Crks City Quays and Tivli; Supprting enhanced public transprt system including BRT t Tivli and river ferries. - Suitably zned lands shuld be made available adjacent t prt facilities t meet the landside requirements f Prts; and Prt & Maritime related industries. The strategic imprtance f these zned lands shuld be recgnised and prtected at reginal and lcal planning plicy level.

2 Infrastructure Pririties - Suitable rad / rail cnnectivity is required t supprt the relcatin f current upper harbur & City Quays peratins t the lwer harbur. - Enhanced reginal cnnectivity t Cre Prts (under Eurpean Cmmissin s TEN-T Guidelines) and Natinal Tier 1 Prts, including rad netwrks such as: M28 Dunkettle Interchange M20 & Nrthern Ring rad R624 Cbh Rad Rail cnnectivity t Marin Pint Enabling Renewable & Sustainable Develpment Prvisin f prt infrastructure and facilities is a key enabler fr the renewable energy sectr, such as wind, wave and tidal. Identificatin and prvisin f prt infrastructure t supprt ptential LPG regasificatin installatin will enhance Irelands energy security. Implementatin Requirement fr an Integrated land and maritime planning & freshre cnsenting prcess with streamlined apprval mechanisms & timeframes particularly fr Strategic Infrastructural Develpments, thus remving duplicatin. The POCC supprts Objective 69 which related t a centrally managed apprach t develping state wned / influenced lands and cnsidered that the same pwers and strategies shuld be explicitly put frward fr the delivery f required natinal infrastructure. Ecnmic & Maritime Ptential The prts imprtance in areas f turism, marine leisure and cruise is nt fully identified in the draft NPF dcument, exemplars include Cbh Cruise Terminal and Bantry Inner Harbur Inner Harbur Develpment. Prts have a vital rle t play in rural regeneratin as lcal ecnmic drivers e.g. marine aquaculture, fishing, marine turism, health and wellbeing, exemplars include Bantry Inner Harbur Inner Harbur Develpment. In the cntext f the abve bullet pints, POCC request that the fllwing specific amendments and additins are made t the Draft NPF.

3 Submissin Request Specific Amendments / Additins Prt f Crk Cmpany requests fr amendments and additins are detailed belw in Blue Bld Italic Type; Sectin 3.5 Ireland s Cities Page 48 Crk City and suburbs are identified fr strng ppulatin and emplyment grwth, with circa. 50% f develpment t be delivered n Brwnfield r Infill develpment sites. Crk City Dcks and Tivli are identified as key develpment pprtunity sites and have the mst ptential t deliver urban develpment within the city s bundary. The imprtance f bth the City Dcks and Tivli shuld be further emphasised within the NPF. Suggested additin t paragraph 2: Tw specific areas fr higher rate grwth have been identified in Crk City: - City Dcks and Tivli Dcks which can cater fr significant ppulatin grwth within the city bundary. Lcal Area Plans are currently being prepared fr these lcatins. These sites already are well serviced with key infrastructure and shuld be facilitated as Tier 1 zned lands. Sectin 3.9 Crk Page 55 In the sectin n Crk, P.55 f the NPF Draft Dcument the Key future grwth enablers fr Crk are identified. The fllwing amendments are prpsed t recgnise existing and future ptential f the Prt as a grwth enabler, and explicitly reference necessary infrastructure. Suggested Amendments t Sectin 3.9: Large scale regeneratin prjects in Crk Dcklands (City Dcks and Tivli), including the relcatin f tw Seves sites frm the City Dcks... Crrectin; the relcatin f tw Seves sites frm Tivli (Flgas LPG and Calr Gas LPG) and ne Seves site frm City Dcklands area (Guldings Ferlilizer). Prgressing sustainable develpment n greenfield sites n public transprt crridrs, such as Mnard. Prgressing sustainable develpment n brwnfield regeneratin sites such as Nrth and Suth City Dcks and Tivli Dcks. Identifying infill and regeneratin pprtunities. Enabling enhanced pprtunities fr existing cmmunities (thrugh emplyment, learning and educatin supprt). Develpment f the new Science Park at Curraheen. Expansin f the 3 rd level educatin institutins. Develpment f much enhanced Citywide public transprt system fr an east-west crridr frm Mahn, thrugh the City Centre t Ballincllig and a nrth-suth crridr with a link t the Airprt including a BRT link t the Tivli site and river ferries. M8 / N25 / N40 Dunkettle Junctin upgrade (apprved) and imprved Ringaskiddy prt access i.e. delivery f the M28 mtrway t Ringaskiddy Prt as part f the Cre TEN-T netwrk. Upgrade f the R624 t Cbh Prt facilities t Natinal Rad status.

4 Enhanced reginal cnnectivity thrugh imprved average jurney times by rad. Delivery f the M28 t Ringaskiddy, the M20 Crk t Limerick Mtrway, Nrthern Ring Rad in Crk and re-designatin and upgrade f the R624 Cbh rad. Imprved traffic flw arund the city, which culd include the upgrade f the N40, and / r alternatives such as the Nrthern Ring Rad which may include enhanced public transprt. Imprved rail jurney times t Dublin and cnsideratin f imprved nward direct netwrk cnnectins. Upgrade f the rail netwrk t cater fr freight frm the Crk area, particularly frm Cbh (Marin Pint). Ensuring water supply and waste-water needs are met by new natinal prjects t enhance Crk s water supply and increase waste water treatment capacity. Imprving sustainability in terms f energy, waste & water. Ensuring the Prt facilities have the expansin capabilities and access t supprt the renewable energy industry such as deep-water berth facilities, adjacent laydwn & assembly lands and suitable rad access fr versize lads such as wind turbine blades, transfrmers, etc. Enabling the expansin f Prt facilities at Ringaskiddy. Marin Pint, Cbh and Whitegate / Aghada and relcatin f shipping and prt activities t lwer harbur lcatins as a key grwth enabler. Prviding adjacent lands zned fr prt-related activities and suitable rad/ rail cnnectivity t these facilities will allw relcatin f carg and prt related industries frm the upper harbur and City Dcks. Sectin 3.9 Limerick Page 57 In the sectin n Limerick, (P.57) Key future grwth enablers fr Limerick. It is submitted that bullet pint 11 shuld be amended t specifically reference the need t deliver the M20. Suggested Additin t Sectin 3.9 Enhanced reginal cnnectivity thrugh imprved average jurney times by rad t Crk by delivery f the M20 and t Waterfrd. Sectin 6 Realising ur Island and Marine Ptential Page Integrated Land and Maritime Planning / Freshre Licensing The need fr integrated land and Maritime Planning is identified in the NPF and there is an bjective t ensure that Reginal and lcal develpment plans integrate relevant maritime spatial planning issues. There is als reference t the need fr C-rdinatin f Departments and Sectral Issues in a plan-led manner ; and Cnsistency between maritime and terrestrial planning in areas f cmmn interest. Hwever, the NPF stps shrt f stating that there will be any change in the arrangements fr apprving planning n the freshre. The current freshre cnsenting prcess des nt have pre-set timelines r clear terms f engagement fr applicants. This leads t risk and uncertainty fr funders f infrastructural prjects which have a freshre requirement. This is a key risk area fr Strategic Develpment prjects which have a freshre element. In tables n Page 92 and 93, POCC welcmes the bjective t prmte integratin between land and maritime planning but it is nt clarified hw the freshre licenses / permitting system will be changed r imprved in the future.

5 The current freshre cnsenting prcess is nt aligned with the planning prcess and cnditins impsed under the tw prcesses may nt be mutually cmpatible nr cmplementary. POCC submit that the statutry apprval prcess must be streamlined if prjects are t be prgressed in an efficient manner, therefre POCC seek an bjective in the NPF fr freshre planning respnsibility t be transferred t relevant Planning Authrity r ABP. POCC als request additinal text in sectin 6.1 t recgnise the significance f landside requirements in realising Ireland s maritime ptential. Suggested Additins t Sectin 6.1 and Natinal Plicy Objective 40 An Integrated prcess fr Freshre permitting, in parallel with the land based planning prcess, wuld be beneficial fr risk mitigatin and prject timeline certainty. This is particularly the case fr Strategic Infrastructure Develpment prjects which have a Freshre element. Natinal Objective 40: Reginal and lcal develpment plans will take accunt f and integrate relevant maritime spatial planning issues and an integrated planning and freshre cnsent prcess will be develped. As the key link between land and sea, suitable Prt facilities with available capacity, rad netwrk cnnectivity and adjacent suitably zned land banks, are required fr the delivery f prjects t make ur maritime ecnmy a reality.

6 6.2 Maritime Ecnmy Page 93. Marine leisure, marine sprts, and cruise turism are key elements f ur marine ptential but are nt captured explicitly in this sectin. POCC submit that text shuld be added t page 90 f the dcument t recgnise these elements f the maritime ecnmy. POCC wuld like t put frward Bantry Inner Harbur Prt Re-develpment prject, undertaken by Bantry Bay Prt Cmpany and Prt f Crk Cmpany, as a gd example f best practice f marine aquaculture, marine leisure and cruise turism enhancement in a rural twn, all delivered in the cntext f a large cmmercial prt peratin. (See best practice f Bantry Inner Harbur Develpment belw) Pht 1. Cnstructin stage pht shwing twn fishing pier extensin, quayside marina and breakwater / amenity area develped frm envirnmentally re-engineered cntaminated dredge material. Pht 2.

7 Marina Opening day f Bantry Marina, August 11 th Pht 3. Pht shws the Hlland America Line s Cruise Vessel Prinsendam mred in Bantry Inner Harbur, Jun 2017, with Bantry Huse in the fregrund and Whiddy Island Oil Strage Terminal in the backgrund. Suggested Additins t Sectin 6.2 Marine leisure, maritime sprts and cruise turism are key areas f ptential market grwth which can grw sustainably in cnjunctin with maritime aquaculture, fishing, and cmmercial prt activities.

8 6.3 Prts Page 94 The Natinal Prts Plicy 2013 identifies Dublin, Crk, and Shannn / Fynes as Tier 1 Prts f Natinal Significance. It is imprtant that the NPF als recgnises that Dublin and Crk Prts are designated as Eurpean Cre prts and are part f the Cre TEN-T Netwrk. Cnnectins t the TEN-T netwrk will becme mre significant in the light f Brexit and natinal plicy shuld seek t strengthen direct cnnectins t Eurpe. In the cntext f Crk, the EU Prt designatin means that, as well as the delivery f the M28 t Ringaskiddy, the R624 t Cbh shuld be re-designated as a Natinal Rad, as this rad currently serves three main prt sites in the Prt f Crk as fllws; Cbh Cruise Terminal (100 cruise vessels expected in 2018) Marin Pint (ex IFI) site (newly acquired by a JV which includes the Prt f Crk Cmpany with plans fr future Prt activity) Crk Dckyard (ship repair & imprt and exprt f gds) The suggested amendments t Sectin 3.9 address this issue, but there is als a need t amend sectin 6.3 t highlight the need fr develpment f the Cre TEN-T Netwrk. Accrdingly, it is submitted that paragraph 5 shuld be amended and that additinal text is prvided. Paragraph 6 deals with Prt strategic planning in the cntext f city regins. In the case f Prt f Crk and Shannn-Fynes, the new prt areas are in their respective Cunties and fall under the Cunty Cuncil planning plicy cntext. This needs t be reflected in the text by referencing Cunty plans as well as City plans in paragraph 6. In the case f the Prt f Crk, the sustainable develpment f the city regin is inextricably linked with the rderly and planned relcatin f prt activities t lcatins in the lwer harbur area, lcated in the Cunty regin. Additinal text is suggested t ensure that Reginal, City and Cunty planning bjectives facilitate the relcatin r prt activities frm upper harbur city areas as apprpriate. The requirements fr Prts t relcate t lwer harbur lcatins are being driven by internatinal shipping trends, as well as the demand fr the centrally lcated develpment f lands t supprt urban develpment. Additinal text is suggested n page 94 t identify the trends in internatinal shipping and the cnsequent plicy implicatins. Objective 42 prvides strng plicy steer that RSES shuld cnsider the strategic develpment requirements f Tier 1 and Tier 2 prts. Additinal text is suggested t specifically reference the need t have cnsideratin t the strategic develpment plans f Prt Cmpanies. Prts have a key rle t play in the strategic and ecnmic develpment f Ireland and its regins, as recgnised by the Natinal Prts Plicy and the draft NPF. Prt Cmpanies have a unique insight n cnnectivity t internatinal markets; natinal / reginal ecnmies and infrastructure requirements. This insight shuld be harnessed during the planning appraisal f strategic develpment prpsals. Accrdingly, POCC submit that Prt Cmpanies shuld be recgnised within the planning system as a prescribed bdy fr relevant develpment prjects. An additinal bjective is suggested within sectin 6.3. Suggested Amendments t Sectin 6.3 Paragraph 5: Tier 1 prts are lcated within clse prximity t Dublin, Crk and Limerick respectively and the rle f these prts will be cnsidered and addressed in tandem with lng-term infrastructural requirements as part f the relevant Reginal Spatial and Ecnmic Strategy (RSES) and any cncurrent r subsequent metrplitan area r city / cunty develpment plan prcess. Dublin and Crk Prts are als designated as Eurpean Cre prts as part f the Cre TEN-T Netwrk and the imprtance f strengthening direct cnnectins t Eurpe will be addressed by the relevant RSES.

9 Insertin f additinal text after paragraph 5: The EU Cre Prt designatin pens up the pprtunity fr EU grant aid and funding fr qualifying Prt develpment, as well as funding develpment f the access and cnnectivity such as rad and rail cnnectins t the Cre Prts. All rads cnnecting EU Designated Cre Prts and Natinal Tier 1 prts t the natinal rad netwrk shuld be designated as Natinal Rads. Additinal text t paragraph 6: Strategic plans fr Tier 1 prts City and Cunty grwth strategies shuld align and be cnsistent with the brader aims and plicies f the City and Cunty plans fr the effective and sustainable develpment f the regin. Additinal text after paragraph 6: The City and Cunty strategies shuld recgnise the rle that prts play as a key ecnmic driver fr the regin. The relcatin f prt facilities frm city areas shuld be jintly facilitated by City and Cunty Cuncil planning plicy. Develpment Plans shuld reflect the key ecnmic rle that prts play as utlined in the Natinal Prts Plicy. Additinal text n page 94: The lng-term internatinal trend in prts and shipping is tward increased cnslidatin f resurces t achieve ptimum efficiencies f scale. This has knckn effects in terms f vessel size, the depths f water required at prts, the type and scale f prt hinterland transprt cnnectins, and landside requirements t accmmdate prt and prt related activities. Prt facilities require suitably zned lands adjacent t Prt facilities and a cmprehensive cnnectin t the rad netwrk. All rads cnnecting EU Designated Cre Prts and Natinal Tier 1 prts t the natinal rad netwrk shuld be designated as Natinal Rads and be upgraded accrdingly. Additinal Text t Natinal Plicy Objective 42: Ensure that the strategic develpment requirements and Strategic Develpment Plans f Tier 1 and 2 Prts are cnsidered and addressed as part f the Reginal Spatial and Ecnmic Strategy (RSES) and that any cncurrent r subsequent metrplitan area f city/ cunty develpment plans and strategic plans fr the Tier 1 and Tier 2 prts are aligned t ensure the effective grwth and sustainable develpment f the city regins. Additinal Natinal Plicy Objective 42(a): Given their unique insight t internatinal, natinal and reginal markets and infrastructure requirements, Prt Cmpanies will be identified as a prescribed bdy in the planning cnsultatin prcess, fr relevant develpment prjects.

10 6.5 Offshre Renewable Energy P96. Sectin 6.5 f the draft NPF recgnises the ptential f ff-shre renewable energy, but des nt reference the imprtant f Prt infrastructure and landside requirements in unlcking this ptential. Irish Prts have a key rle t play in facilitating the infrastructural requirement fr the ff-shre industry, as demnstrated by Prts such as Hull Greenprt, and the Dng facility in Belfast Harbur. file:///c:/users/hkingstn/dwnlads/37833%20bhc%20ff%20shre%20wind%20reprt %20Web.pdf Additinal text is suggested t recgnise the imprtance f prt infrastructure and landside requirements in enabling ffshre renewable energy. Suggested Amendments t Sectin 6.5 Additinal text after paragraph three: Irish Prts have a key rle t play in facilitating the infrastructural requirements fr the ffshre energy industry. The renewable ffshre energy sectr requires, deep-water serviced prts t deply wind, tide and wave energy generating installatins int suitable pen sea lcatins. These renewable energy generatrs (wind turbines, tidal turbines, & wave generatrs) require suitably zned land adjacent t prt facilities fr manufacture, assembly, testing, and mbilisatin f these large machines.

11 7.1 Ireland and the Eurpean Unin Page 99 Ireland s current ver reliance n landbridge acrss the UK and the Dver Calais link t Eurpean markets is a key risk fr Brexit. The existing landbridge cnnectin is illustrated in Figure 1. Figure 1: UK Landbridge The Prt f Crk is well lcated t further develp direct sea links with ther EU cuntries, as illustrated by Figure 2. Figure 2: Prt f Crk Cnnectivity The recgnitin f the imprtance f the cnnectedness f Prts t the EU cuntries utlined in paragraph 3 f page 99 is acknwledged, and further text is suggested t reinfrce this issue. Suggested Amendments t Sectin 7.1, page 99 Additinal text after paragraph 3 f page 99: The increased peripherally f the Irish ecnmy in a pst-brexit scenari places an increased reliance n independent transprt links t the Eurpean market which d nt rely n transit thrugh the UK. Building capacity int ur existing ferry prts and cntainer prts will allw the shipping and lgistics chain t react t changing external cnditins and maintain Irish cmpetitiveness.

12 7.4 Energy Page 104 The imprtance f energy infrastructure cnnectins is paramunt in a Pst-Brexit scenari. There is emerging ptential fr imprting Liquid Natural Gas (LNG) thrugh Irish prts and its regassificatin t existing shreside infrastructure. This has the ptential t extend the utilisatin f the natinal gas netwrk as the Kinsale natural gas field is depleted. Opprtunities in this field are currently being explred by Shannn-Fynes and POCC and the ptential f this energy surce shuld be reflected within the NPF, as highlighted in the links belw: Additinal text is suggested n page 104 t recgnise the ptential fr LNG. Suggested Amendments t Sectin 7, page 104 Additinal text after paragraph 3: The ptential fr a Liquid Natural Gas (LNG) imprtatin facility at ne f Ireland s majr prts is recgnised as a methd f extending the utilisatin f the natinal gas netwrk as the Kinsale natural gas field is depleted. The availability and transprtatin f natural gas by ship and its re-gasificatin t shreside facilities is prven technlgy and wuld prvide anther surce fr energy security and resilience fr the island whilst extending the life f the existing natural gas transmissin netwrk assets in a sustainable manner.

13 7.4 Turism Page105 Sectin 7 addresses all Island turism, but des nt emphasise the ptential f marine turism. Fr example, the Suth cast and examples such as Bantry Bay prt ffer excellent marine turism pprtunities, which culd be bundled and marketed n an All-Ireland castal basis. Examples f existing activities in Bantry Bay are prvided in the fllwing links: rails ays%20bantry%20map%20bklet%20vs.3.pdf Suggested Amendments t Sectin 7, page 105 Additinal text after paragraph 2: Marine turism initiatives which ffer an alternative t land based activities such as castal kayaking (Bantry Blueway), cruising sailing, yacht racing events, bating, adventure races, rwing, and surfing, etc. can be bundled and marketed n an All-Ireland, castal basis. As the cruise industry is grws and expands further int nrthern Eurpean destinatins, remte destinatins such as the cast f Ireland are an attractive prpsitin fr cruise passengers. These marine turism activities can be integrated int ur marine cultural and natural heritage. 9 Investing in Ireland 2040 Implementatin Page 123 Enhanced reginal Accessibility

14 POCC supprt the NPF s emphasise n the imprtance f cnnectivity between Crk and Limerick and the Atlantic Ecnmic Crridr. Imprving the cnnectivity f the tw cities and particularly the link between the agricultural heartland f mid Crk and the prt will add t the efficiency and t the ability t imprve the density f the urban areas. High Quality Internatinal Cnnectivity The need fr investment in ur Prts t vercme the difficulties f Brexit is agreed and POCC nte the examples given f signature prjects such as the secnd runway fr Dublin Airprt and the Dublin Prt Masterplan. In the cntext f the Suthern Regin, the redevelpment f Ringaskiddy terminal is a signature prject. The Prt f Crk is embarking n a 80 Millin develpment f a new cntainer prt in Ringaskiddy. This prject has full planning and funding in place with cnstructin cmmencing in 2018 and pening in It is supprted by the EU with Tens-T grant aid and a Eurpean Investment Bank lan, and is the biggest single investment prject in prt infrastructure in Ireland. See prject website here: Additinal text is suggested fr the first bullet pint t highlight a signature prject in the Suthern Regin. T prepare fr Brexit, the need fr investment in cnnecting rads and rail t ur prts and zning f adjacent land banks is equally as imprtant t enable signature prjects. Additinal text is suggested t emphasise this pint. Suggested Amendments t Sectin 9, page 124, first bullet pint and signature prjects such as the secnd runway fr Dublin Airprt, the Dublin Prt Masterplan, and the Prt f Crk Cmpany Strategic Develpment Plan. Additinal Text n Page 124: The ability t accmmdate mdal shift f cargs frm rad transprt / ferries t cntainers and establishing new direct links t Nrthern Spain and Western France Eurpe as an alternative t land-bridge acrss the UK is a pririty in preparing fr Brexit. Investment in Prts needs t be accmpanied with suitable investment in the cnnecting rads and rails netwrks t prvide sufficient advance infrastructural capacity which will serve t vercme external disruptins such as Brexit r ther unfreseen events. Resilient and alternative rutes t the EU and wrldwide market fr raw materials and fr finished prduct is imprtant fr an island natin.

15 9.2 Gvernance / Priritising Develpment Lands Page 129 POCC welcmes the Natinal Plicy Objectives 68 & 69 t priritise develpment lands and prmte state-led strategic land develpment. Hwever, these bjectives appear t be drafted twards satisfying husing needs. POCC suggests that the same pwers and strategies be explicitly put frward fr use in the delivery f required natinal infrastructure such as Prts, waste management facilities, rads, energy installatins, Seves zned sites, etc Suggested Amendments t Objective 69, page 129 Additinal text t Objective 69: A mre effective strategic and centrally managed apprach will be taken t realise the develpment ptential f the verall prtfli f state wned and / r influenced lands in the five main cities and ptentially ther majr urban areas as a pririty, t deliver strategic husing and infrastructure prjects. Natinal Strategic Outcme, High-Quality Internatinal Cnnectivity Page 134 POCC strategic plan has identified future prt lcatins & infrastructure required in Crk s lwer harbur t cater fr expansin as fllws: Ringaskiddy Marin Pint Cbh Aghada / Whitegate The delivery f the M28 is required befre the permitted develpment at Ringaskiddy can be fully implemented. Further, the R624 rad t Cbh requires upgrading befre the full ptential f future prt lcatins at Marin and Cbh can be achieved. In recgnitin f these requirements, POCC submit that tw further bullet pints be added under the Prts heading n Page 134. Suggested Amendments t Prts heading, page 134 Additinal Bullet Pints: Delivery f the M28 rad t Ringaskiddy Prt Redesignatin f the R624 rad t Cbh t Natinal Rad status and upgrade t a standard capable f accmmdating three majr Tier 1 prt installatins: Cbh Cruise Terminal; Marin Pint Prt Terminal; and Crk Dckyard. Natinal Strategic Outcme, Empwered Rural Cmmunities Page 136 Prts and harburs can be significant ecnmic drivers fr rural cmmunities. In prmting rural develpment it is submitted that the NPF shuld acknwledge this ptential and prvide a plicy cmmitment t future investment. An additinal bullet pint t the Rural Develpment Outcmes detailed n p. 136 is suggested. Suggested additinal bullet pint, Page 136: Additinal Bullet Pint, Rural Develpment: Investment in smaller castal prts as key ecnmic drivers fr rural cmmunities and surces f jbs t facilitate fishing, aquaculture, active marine sprts, and marine turism.

16 Transitin t Sustainable Energy Page 138 Prts have a key rle t play in the transitin t sustainable energy and t prviding energy security fr Ireland. It is submitted that the sectin n Transitin t Sustainable Energy shuld make reference t the ptential fr a Liquid Natural Gas (LNG) imprtatin facility at ne f Ireland s majr prts (see link fr details); and that the rle f prts in facilitating the ffshre energy sectr is highlighted. Prts such as Hull Greenprt and the Dng Prt facility in Belfast harbur are best practice examples in this field: Additinal text is suggested t the sectin. Suggested Amendments, Transitin t Sustainable Energy Additinal text, after Paragraph 3: The renewable ffshre energy sectr requires, deep-water serviced prts t deply wind, tide and wave energy generating installatins int suitable pen sea lcatins. Irish Prts have a key rle t play in facilitating the infrastructural requirements fr the ffshre energy industry. These renewable energy generatrs (wind turbines, tidal turbines, & wave generatrs) require suitably zned land adjacent t prt facilities fr manufacture, assembly, testing, and mbilisatin f these large machines. Additinal text, after Paragraph 5: The ptential fr a Liquid Natural Gas (LNG) imprtatin facility at ne f Ireland s majr prts is recgnised as a methd f extending the utilisatin f the natinal gas netwrk as the Kinsale natural gas field is depleted. The availability and transprtatin f natural gas by ship and its re-gasificatin t shreside facilities is prven technlgy and wuld prvide anther surce fr energy security and resilience fr the island whilst extending the life f the existing natural gas transmissin netwrk assets in a sustainable manner. Additinal Bullet Pints, Green Energy: - Facilitate the capacity f Irish Prts t service the renewable ffshre energy sectr. - Supprt the develpment f a LNG imprtatin facility at ne f Ireland s majr prts.

17 Summary POCC welcmes the draft NPF and its recgnitin f the strategic imprtance f Prts t Ireland s ecnmic vitality and grwth ptential. POCC s Strategic Develpment Plan has identified lcatins fr future prt expansin and relcatin f trades frm the upper harbur. Successful implementatin f the Strategic Plan will supprt the NPF grwth bjectives fr the Regin. POCC has suggested amendments and additins t the draft NPF with a view t maximising the full ptential f Prt Infrastructure and activities; facilitating the redevelpment f lands lcated in the upper harbur f Crk City; and supprting Maritime Resurces as key grwth enablers fr the Suthern Regin. Thank yu fr yur cnsideratin f this submissin. Regards, Henry Kingstn, Senir Engineer / Acting Manager f Engineering Services, Prt f Crk Cmpany. Tel; Mb;