Cork Chamber BLARNEY-MACROOM LAP Submission Cork Chamber Submission to the Local Area Plan for Blarney Macroom Municipal District 1
INTRODUCTION Introduction & Context Cork Chamber consider it an opportune time to revaluate the strategic planning role of different settlements in this part of the county and related policies for the delivery of economic development, population growth and the achievement of employment and housing targets contained within the adopted Cork County Development Plan (CDP) 2014. Cork Chamber is the leading business organisation for the promotion and development of economic and commercial activity in the region. The Chamber represents over 1,100 companies employing over 100,000 people across Cork, and as such, occupies a vital role in leading and developing business activity. This role extends to the identification of the future needs of start-ups, SME s, large indigenous businesses and FDI companies across the majority of business sectors. At a time of significant long term national, regional and local planning, it is critical that the appropriate conditions are created to nurture growth in the county. On the basis of scale, return on investment, ability and track record of delivery as well as collective ambition, Cork needs to move forward and needs to do so in a significant rather than incremental manner. We note the contents of the Draft LAP as well as the previous area-based public consultation document produced by Cork County Council to inform the review process. This submission has been framed in the context of these documents as well as via the input of key business industry professionals. 2
AREA PROFILE BLARNEY MACROOM MUNICIPAL DISTRICT AREA PROFILE COUNTY CORK BLARNEY MACROOM MD 519,032 persons 43,398 persons 8% OF CORK POPULATION COUNTY CORK BLARNEY MACROOM MD Target 602,622 persons Target 49,973 persons Growth of 20% Growth of 8% DRAFT LAP IDENTIFIES BLARNEY TOWN AS THE CRITICAL GROWTH CENTRE 3
AREA PROFILE HOUSING REQUIRED COUNTY CORK BLARNEY MACROOM MD 56,284 Units 5,880 Units BLARNEY MACROOM MUNICIPAL DISTRICT AREA PROFILE 10% OF THE COUNTY S HOUSING REQUIREMENT COUNTY CORK BLARNEY MACROOM MD Business 846.01 ha Business 54.52 ha Industrial 801.59 ha Industrial 16.8 ha Enterprise 476.58 ha 6% OF COUNTY S BUSINESS LAND 16.1% Manufacturing Mining/Waste 9.7% Agriculture/ Forestry/Fishing 12.2% Information/ Communication/Financial 20.4% Wholesale/ Retail/Accomodation 41.3% of population in work 31.5% in MD 17,703 jobs 46.8% in Other Areas 26.1% in City 21.8% Education Human Health 4
ASSESSMENT Assessment Housing Delivery The timely provision of new homes is critical to the future economic growth of Cork and its businesses. Population and unit growth targets set within the Cork County Development Plan (CDP) 2014 require the delivery of an ambitious housing output of 8,700 units per annum between 2016 to 2022. The Blarney Macroom Municipal District (MD) is spread across three strategic planning areas, for which the County Development Plan sets out differing objectives. The majority of the MD, including the main town of Macroom, is located within the Greater Cork Ring Strategic Planning Area, where it is an objective to accelerate the rate of growth and achieve a critical mass of population to maximise potential to attract new investment in employment, services and public transport. Some areas are located in the West Cork Strategic Planning Area where the overriding objectives is to channel development to the urban areas and achieve a sustainable balance of development in smaller settlements. The eastern portion of the MD which includes the main town of Blarney is located within Metropolitan Cork which is identified as the principal growth engine for the city and wider region. These hierarchical relationships are reflected in the scale of development apportioned to the main settlements in the district, with the majority (85%) of future residential development in the two main towns earmarked for Blarney (2,566 units) relative to Macroom (468 units). Independent of this, the district is very rural in nature, demonstrating the highest rural to urban population ratio of all the MDs. This presents challenges in terms of the delivery of concentrated housing and employment growth which necessitates a targeted response to issues. Distribution of Population within Municipal Districts 2011 Municipal District % in Towns and Villages % in Rural Areas Ballincollig Carrigaline 92% 8% Bandon Kinsale 59% 41% Blarney Macroom 35% 65% East Cork 69% 31% Fermoy 55% 45% Mallow Kanturk 51% 49% West Cork 44% 56% Cobh 69% 31% While we welcome the Council s recognition of the need to zone additional lands in the MD and specifically in Metropolitan Cork, we have some concerns that the devised plan does not presently provide for sufficient certainty in terms of future housing delivery. Table B.9 1 of the CDP sets out the Core Strategy population and housing delivery figures for the Blarney Macroom MD. The estimated land requirement for Blarney is 103 ha of zoned land comparable to an estimated zoning of 92 ha, a deficit of 11 ha. The Government s Development Management Guidelines 2007 state that in order to ensure continuity of supply in zoned and serviced residential land, planning authorities should ensure that enough land is available to meet residential need for at least 9 years. This translates into a direct need to provide a minimum 50% strategic land reserve to ensure that a shortage of development land does not occur during the lifetime of plans. Based on this requirement, there is actually a need to zone 154.5 ha to achieve required headroom. Alongside this, Stoneview Masterplan has an extimated capacity of 5,000 units, with a 2,566 units target output by 2022. We note that the Council s Planning Policy Unit have previously estimated the housing yield at a more realistic 1,200 units by this time. This leaves a balance of 1,366 units to be provided elsewhere in Blarney by 2022. On an average basis of 25 1 See Appendix B. 5
ASSESSMENT dwellings per hectare, this equates to a need for approximately 55 hectares of additional land to achieve population targets. Having regard to the above, we have strong concerns that the forthcoming plan period will be characterised by a significant undersupply of much needed new homes in this part of Metropolitan Cork. The shortfall is further exacerbated when land requirements in village centres are included. The level of development targeted for Blarney town coupled with the likelihood that it will not be achieved means there will be significant development pressures on smaller settlements. Based on an assessment of the Council s presented numbers, the total land requirement in villages is 158 hectares compared to an availability of 76 hectares resulting in a substantial shortfall of 82 hectares in additional land requirements. We note that the LAP process in general seeks to inject an element of contingency in terms of future housing provision via the establishment of a strategic land reserve (SLR) of one third of the overall requirement for new housing. 12 no. SLR sites are put forward in the draft plan, none of which are located in the Blarney Macroon MD. It follows that in addition to the identified significant shortfall in zoned residential lands in the district, suitable provision has not been made to address any possibility of further non-delivery. Given the primacy of housing to the economic development of the area, it is critical that the final LAP addresses this matter in full. The draft plan has a strong focus on the delivery of housing numbers. It is critical that both existing and future housing growth areas are supported by an appropriate range of social infrastructure including schools, health, sports and recreation, community and other facilities which contribute to quality of life. These are a key part of the fabric of every area, not just in in terms of wellbeing, but also in terms of sense of place, a part of our local identity. It is at the very crux of the success of an area, its attractiveness, and a critical enabler of its economic prospects. We note the recent preparation of a social infrastructure audit to appropriately inform the development of Dublin Docklands, which follows similar proactive initiatives in major urban areas in the UK, of assessing the need for the different facilities commensurate with growth projections. A study of this nature is required for each MD in Cork County to examine the current context with respect to social infrastructure provision, to determine future requirements and make recommendations on priority areas for investment. This should be advanced in close partnership with infrastructure providers themselves. Economy/Employment The Planning and Development (Amendment) Act 2010 introduced important new legal obligations on planning authorities to ensure that LAPs comply with devised Core Strategies contained in the relevant county/city development plan. This duty extends to the provision of employment and jobs as highlighted in the national guidelines on the preparation of LAPS - Local Area Plans Guidelines for Planning Authorities 2013, Department of Environment, Community and Local Government. In relation to the content of LAPs, specifically, Section 5 of these guidelines identifies the explicit need to promote local economic development and employment growth by focusing on the prevalent issues in an area. Neither the CDP or emerging LAPs are supported by a considered economic development strategy and this represents a fundamental weakness in approach to providing for future employment needs. The draft LAPs are overtly focused on population and housing growth only to the disadvantage of other key strategic planning areas. These plans do not establish general employment targets or seek to identify existing or future sectoral growth needs locally. The Government prepared Action Plan For Jobs 2015-2017 South West Region establishes the need to have a further 10-15% at work in counties Cork and Kerry by 2018 and to ensure the unemployment rate is within 1% of the State average. The plan establishes tangible targets such as 20% increase in export-led jobs by 2020, 40-50% start-ups, scaling and survival, and a quantified increase of 30-40% (additional 139) FDI investment projects. It recognises that this can only be achieved by collaboration among key stakeholders in the region working to achieve common goals. The Action Plan was developed under the auspices of a project delivery group comprising public bodies in the south west region, which included Cork County Council, and a failure to align the LAP production process with this wider network constitutes a missed opportunity. We also note the established practice of other local authorities such as Meath County Council who have prepared an economic strategy to identify key strategic employment requirements and marry these needs with traditional land use planning practices. A similar approach should be advanced here. With a daytime working population of 2,109 people, Blarney is the largest centre of employment within the MD. According to the 2011 census, the equivalent working figure for Macroom is 330. As such, only 25% of total recorded jobs within the district (9,887) are located within the two main towns. This presents significant challenges which include accessibility to employment and reliance on car-based transport for the purposes of accessing jobs. The distributed 6
ASSESSMENT nature of employment means that 70% of employees who live in the area travel to work by car, a point underlined by the fact that only 31.5% of the working population work in Blarney Macroom MD. While the draft LAP acknowledges these issues, it does not present any considered framework for tackling related issues. Again, this arises from the absence of a targeted economic strategy, the production of which should be prioritised. This should acknowledge the role of smaller key village settlements such as Ballineen/Enniskeane which benefit from regional road linkages and the existing presence of national and international employers such as Carbery Milk Products Ltd and Graingers Sawmills, among others. Provision should be made to ensure good commercial development opportunities continue to be available in such areas. Vital to any concentrated efforts to achieve employment growth in the MD is the continued development and expansion of Blarney Business Park, which will help arrest the spatial imbalance in employment estates which presently exists in the county, which is skewed towards the east. We note that the Stoneview development will also include provision for 12.5 hectares of additional business development lands. The release/phasing of these lands relative to residential components and required infrastructure services should be investigated to provide certainty in approach. Table 3.4 identifies an extensive list of infrastructure requirements associated with same and the availability of ready to go development sites is at the heart of maximising market advantage and securing inward investment. The Cork County Development Plan, and in particular, Policy Objective ZU 3-8, promotes the provision of mixed use developments within town and neighbourhood centres. Alongside residential and retail uses, suitably scaled commercial office and other business uses must be provided for to achieve vibrancy in centres and a compact urban form. It is critical that flexibility of future uses is also extended to designated enterprise, business and industrial areas recognising that it is not always possible to pigeon hole some businesses into one classification over another and separately that there are often synergies and other mutual benefits to be accrued in providing for different uses within an employment zone. At a strategic scale, this will assist greatly in future proofing Cork County s employment land offer. Infrastructure Infrastructure planning is an essential element in ensuring economic growth objectives are realised. It is critical that resources are targeted to deal with existing deficiencies and cater for a growing and changing resident as well as working populations. Any LAP must be capable of being delivered to specified timescales, in a way which proactively addresses constraints and properly meets the needs and expectations of developers and commercial business investors. The LAPs have identified a significant portion of land that is subject to infrastructure constraints, such that the timescale for development is envisaged as being greater than 6 years. In the County Metropolitan area approximately 374 ha of land falls within this category, representing almost 30% of the current zoned land available in the strategic planning area. A further, approximately 26% of land is identified as having constraints such that the timescale for development is envisaged as being between 2-6 years. Only approximately 44% of the existing zoned land is identified as being sufficiently serviced (at least in terms of water infrastructure) to facilitate development within 2 years. In some cases the amount of development that can be achieved on these lands is, however, limited by requirements for further road infrastructure. As highlighted above, the Blarney Macroom MD is very rural in nature. The total residential development target in the district is 4,560 units by 2022. Of these, 1,526 units are planned for village settlements. A review of related available water and wastewater infrastructure services within these villages confirms that infrastructure capacity only exits to deliver 182 no. units. These exacerbates the potential for a future shortfall in residential delivery. The LAPs assume that identified Urban Expansion Areas will deliver 11,000 units in Metropolitan Cork during the lifetime of these plans. These are new development areas which require substantial upfront investment in infrastructure to leverage development opportunities. Blarney includes one such area in Stoneview, as identified above which in particular has road and traffic capacity issues. The upfront strategic infrastructure and service requirements present significant obstacles both in terms of time of provision and the viability of delivery itself. The financing and economic climate for both residential and employment developers has changed drastically in recent years to the extent that it is not feasible to access the same level of finance up-front to fund required infrastructure. We note the recent practices of Dublin City Council (Dublin Docklands) and South Dublin County Council (Clonburris) whereby land use zoning decisions were viability tested at macro and micro scales to ensure that the development of critical sites could be 7
achieved within specified timescales. We note the comments of Section 2.5.12 of the each LAP which states generally that these plans should seek to ensure that lands identified for employment use can be readily developed. No further commentary is offered on how this will be achieved. A practical approach to investigating viability and the realistic development of sites must be pursued to provide improved clarity and certainty that development and economic growth will occur across all Municipal Districts. The overreliance on private car-based journeys for the purposes of trips to/from places of employment is a critical issue in the district, one which is compounded by poor public transport options in many areas. While we support the objectives to achieve modal shift towards buses, cycling and walking in the two principal towns, this needs to be supported by targeted measures to achieve same. We welcome the suggested Movement and Public Realm Strategy for Blarney. Given that plans are being advanced for the delivery of a number of large development sites, we request that this be given formal effect immediately as part of a proactive rather than reactive approach to framework delivery. In particular, the development of sustainable public transport and other access options should be a key tenant in the masterplanning of identified urban expansion areas such as Stoneview. The topography in this area presents significant challenges in terms of access and as a targeted employment growth area, suitable provision must be made for commuters as well as local resident to improve its attractiveness for investment. This needs to go beyond discussions on hard infrastructure (engineering of roads etc) only and include upfront engagement with service providers, to ensure planned infrastructure is utilised and the return on costs maximised. The LAP references that a new General Development Contributions scheme is now being prepared. This should be considered in the context of viability issues and the need to deliver critical infrastructure in different areas. It is preferable that contributions related to infrastructure investment for an identified Urban Expansion Area is used towards development for that specific Urban Expansion Area, and also that this scheme is subject to ongoing review so as to ensure that the scheme does not place an onerous burden across the County to the effect of slowing or stalling planned developments. We welcome the Council s decision to establish a specialist housing and infrastructure delivery team. At present, we understand that this is an internal working group. In lieu of the issues raised above, it is important that this group is developed into a wider task force which includes relevant representation from external agencies and the private sector. The outputs of such a group should feed into a formal infrastructure delivery plan as part of targeted measures to achieve growth projections. This should be kept under review with regular reporting as part of a formal plan-monitormanage approach to LAP delivery. Flooding The inclusion of updated flood zone mapping within the draft LAPs is noted and it is acknowledged that the approach to flooding is to avoid development in areas at risk of flooding; and to approach flood risk management based on avoidance, reduction and mitigation of risk, however the flood zones identified do not currently take account of the presence of flood protection structures. Cork Chamber contends that the flood protection structures should be taken into account in the determination of flood zones, and that there should be recognition of the locations that have the benefit of flood defences. The national regional and local planning policy guiding the development of town centres should prevail, with the onus on the developer to satisfy the requirements of the Planning and Flood Risk Management Guidelines 2009 and the relevant objectives of the Cork County Development Plan 2014 including through the use of S47 agreements/ Special Development Contributions as appropriate, to ensure the ongoing maintenance of such flood defence infrastructure. 8
SUMMARY OBSERVATIONS Summary Observations The Blarney Macroom MD spans 3 no. strategic planning areas and with the exception of the two main towns is very rural in nature. The draft LAP identifies Blarney as the critical growth centre for housing and employment over the plan period; From a review of presented Council figures, it is evident that there is considerable shortfall in zoned lands for residential development in Blarney (154 hectares). There is a sufficient amount of zoned land in Macroom, but a deficit of 82 hectares in village settlements across the district; There are also serious question marks over the deliverability of the Stoneview Urban Expansion Area over the plan period which will result in a quantified shortfall of 1,366 units on this site alone to 2022; The draft LAP is overtly focused on population and housing to the disadvantage of other key strategic planning issues including employment, sustainable transport, infrastructure; The plan is not supported by a suitable economic development strategy which represents a fundamental weakness in approach. The non-inclusion of tangible employment targets renders it difficult to quantify the appropriateness of land use zoning requirements; There is a critical need to better align land use and transportation requirements in existing and planned strategic employment as well as residential growth areas. In particular, more targeted measures are needed to foster improved modal shift from private car usage to public transport, cycling and walking; The LAPs have identified a significant proportion of land that is subject to infrastructure constraints, such that the timeline for development envisaged is beyond the 6 year plan period; The plans have not been viability tested and significant concerns exist about the costs of associated infrastructure to release development lands; There is a need to develop a task force or equivalent delivery agent to implement the delivery of each LAP, including proactive intervention and management of issues as required. 9