EPA Submission to Draft Cork City Development Plan 2022-2028

We acknowledge your notice, dated 26th July 2021, in relation to the Draft Cork City Development Plan 2022-2029 (the ‘Plan’) and SEA Environmental Report.

The EPA is one of the statutory environmental authorities under the SEA Regulations. In our role as an SEA environmental authority, we focus on promoting the full and transparent integration of the findings of the Environmental Assessment into the Plan and advocating that the key environmental challenges for Ireland are addressed as relevant and appropriate to the plan. Our functions as an SEA environmental authority do not include approving or enforcing SEAs or plans.

As a priority, we focus our efforts on reviewing and commenting on key sector plans. For land use plans at county and local level, we provide a ‘self-service approach’ via the attached guidance document ‘SEA of Local Authority Land Use Plans – EPA Recommendations and Resources’.

This document is updated regularly and sets out our key recommendations for integrating environmental considerations into Local Authority Land Use Plans. We suggest that you take this guidance document into account and incorporate the relevant recommendations, in finalising and implementing the Plan. We refer you to our previous submission, dated 5th November 2020, which we attach, and which should also be taken into account at this time

Cork City Council should also ensure that the Plan aligns with key relevant higher-level plans and programmes and is consistent with the relevant objectives and policy commitments of the National Planning Framework and the Southern Regional Spatial and Economic Strategy.

Content of the Draft Plan

Cork Harbour Strategic Integrated Framework Plan Initiative

We acknowledge the reference in Section 1.22 to the Cork Harbour Strategic Integrated Framework Plan Initiative and the link to Objective RP079 of the Southern Regional Spatial and Economic Strategy…’ to promote the Shannon Integrated Framework Plan initiative as a good practice model for the Southern Region and to seek the preparation of similar initiatives for Cork Harbour and Waterford Harbour between the relevant stakeholders…’. There is merit to clarifying if the Cork Harbour Strategic Integrated Framework Plan Initiative will be progressed during the lifetime of the Plan.

Content of the Environmental Report

Mitigation Measures

Where you have identified the potential for likely significant effects, you should provide appropriate mitigation measures to avoid or minimise these. You should ensure that the Plan includes clear commitments to implement the mitigation measures.

Monitoring

The Monitoring Programme should be flexible to take account of specific environmental issues and unforeseen adverse impacts should they arise. It should consider and deal with the possibility of cumulative effects. Monitoring of both positive and negative effects should be considered. The monitoring programme should set out the various data sources, monitoring frequencies and responsibilities.

If the monitoring identifies adverse impacts during the implementation of the Plan, Cork City Council should ensure that suitable and effective remedial action is taken.

Guidance on SEA-related monitoring is available on the EPA website at https://www.epa.ie/publications/research/environmental-technologies/research-306-guidance.php

State of the Environment Report – Ireland’s Environment 2020

In finalising the Plan and integrating the findings of the SEA into the Plan, the recommendations, key issues and challenges described in our State of the Environment Report Ireland’s Environment – An Integrated Assessment 2020 (EPA, 2020) should be considered, as relevant and appropriate. This should also be taken into account, in preparing the Plan and SEA.

Future Amendments to the Plan

You should screen any future amendments to the Plan for likely significant effects, using the same method of assessment applied in the “environmental assessment” of the Plan.

SEA Statement – “Information on the Decision”

Once the Plan is adopted, you should prepare an SEA Statement that summarises:

• How environmental considerations have been integrated into the Plan;

• How the Environmental Report, submissions, observations and consultations have been taken into account during the preparation of the Plan;

• The reasons for choosing the Plan adopted in the light of other reasonable alternatives dealt with; and,

• The measures decided upon to monitor the significant environmental effects of implementation of the Plan.

You should send a copy of the SEA Statement with the above information to any environmental authority consulted during the SEA process.

Guidance on preparing SEA Statements is available on the EPA website at the following link: https://www.epa.ie/publications/research/environmental-technologies/research-306-guidance.php

Environmental Authorities

Under the SEA Regulations, you should consult with:

• Environmental Protection Agency;

• Minister for Housing, Local Government and Heritage;

• Minister for Tourism, Culture, Arts, Gaeltacht, Sport and Media (formerly Minister for Culture, Heritage and the Gaeltacht (functions transferred from Minister for Environment, Heritage and Local Government/ Minister for Housing, Planning and Local Government to Minister for Culture, Heritage and the Gaeltacht by S.I. 192 of 2011);

• Minister for Environment, Climate and Communications; and

• Minister for Agriculture, Food and the Marine.

• any adjoining planning authority whose area is contiguous to the area of a planning authority which prepared a draft plan, proposed variation or local area plan.

If you have any queries or need further information in relation to this submission, please contact me directly. I would be grateful if you could send an email confirming receipt of this submission to: sea@epa.ie.