Submission on the objectives affecting transport and Mobility in other chapters on behalf of the Cork Transport & Mobility Forum Appendix to main submission

Chapter 3

Delivering Homes and Communities

Main points

 

• We strongly support the vast majority of aims and objectives laid out in chapter 3 particularly the focus on compact growth and the 15-minutes City
• The quality of vision and execution of the draught chapter is to be commended
• We have suggested some slight modification/strengthening of some objectives to better support the provision of infill development.

 

We Strongly support the following objectives unchanged as they are in the current draft

 

Objective 3.1

Objective 3.2

Objective 3.5 (not withstanding our comments on chapter 11 standards referred to in the objective)

Objective 3.6

Objective 3.8

Objective 3.11                  

Objective 3.12

Objective 3.14

Objective 3.15

Objective 3.16

Objective 3.17  

Objective 3.18

Objective 3.19  

Objective 3.20

Objective 3.21

Objective 3.22

Objective 3.25

Objective 3.26

Objective 3.27

Objective 3.28

Objective 3.29

Objective 3.31  

Objective 3.32

Objective 3.33

 

 

 

We support the following objectives and suggest the following modification/additions to strengthen their effectiveness in achieving the Strategic objectives laid out at the beginning of Chapter 2

 

Objective 3.3     

New Housing Supply

We Strongly support the parts a, b, c, d, e, f & g of this objective unchanged as they are in the current draft.

We request the follow addition to strengthen its effectiveness

 

Existing text

Objective 3.3     

New Housing Supply

Provision will be made for at least 17,118 new homes to be built in Cork over the Development Plan period. This will be achieved by:

a. Zoning sufficient lands for residential or a mix of residential and other uses to facilitate the delivery of housing;

b. Designating Transformational sites capable of delivering new homes;

c. Utilising the Cork City Capacity Study prepared as an input into this Plan to identify the development potential of sites capable of residential development;

d. Active land management utilising the provisions of the Derelict Sites Act 1990 and Urban Regeneration and Housing Act 2015;

e. Optimising the potential of brownfield sites (see Objective 3.4);                               

 f. Actively encouraging the re-use of vacant space within existing buildings (especially built heritage assets and those in the City Centre) and vacant homes by utilising all instruments at Cork City Council’s disposal;

g. Ensuring that all new housing developments contribute to the creation and / or maintenance of successful neighbourhoods and are designed to the highest standards (see Chapter 11: Placemaking and Managing Development).

 

 

Suggested Strengthening

Objective 3.3     

New Housing Supply

 

Provision will be made for at minimum of 17,118 new homes to be built in Cork over the Development Plan period. This will be achieved by:

a. Zoning sufficient lands for residential or a mix of residential and other uses to facilitate the delivery of housing;

b. Designating Transformational sites capable of delivering new homes;

c. Utilising the Cork City Capacity Study prepared as an input into this Plan to identify the development potential of sites capable of residential development;

d. Active land management utilising the provisions of the Derelict Sites Act 1990 and Urban Regeneration and Housing Act 2015;

e. Optimising the potential of brownfield sites (see Objective 3.4);                               

 f. Actively encouraging the re-use of vacant space within existing buildings (especially built heritage assets and those in the City Centre) and vacant homes by utilising all instruments at Cork City Council’s disposal;

g. Ensuring that all new housing developments contribute to the creation and / or maintenance of successful neighbourhoods and are designed to the highest standards (see Chapter 11: Placemaking and Managing Development).

h. Actively encouraging the re-use of underutilised public and private space, such as parking areas and large gardens, in existing low-density suburbs for infill housing.

i. Actively encouraging the division of large residential sites in existing low-density suburbs into two or more small sites.

 

 

Objective 3.4     

Compact Growth

We support in the strongest possible terms the objective of compact growth, all of the measures a to o which are part of this objective and acknowledge the substantial progress towards that objective in this draft.

However, given the already large footprint of Cork City, even if 100% of projected population growth was to occur within the existing footprint of the city the majority of Communities would still suffer from population densities far below that which constitute compact settlement or which allow a 15-minute city to be a reality. Therefore, it is vital to achieving the strategic objectives set out in chapter 1 that sufficient new housing development take place within the existing footprint to allow compact growth and the achievement of a 15 min city, any development outside the existing footprint delays this for existing communities. In this context we cannot support the 66% target for housing within in the existing footprint. While recognising the challenges of providing sufficient housing to meet the necessarily ambitious targets for home building and the significant problems associated with lack of supply, we request that this 66% target is revised substantially up, to ensure compact growth and the greatest possible number of existing communities are developed sufficiently to allow the 15-minute city to become a reality within those communities.

In particular we ask that measures are included to encourage and more ambitious targets are set for small scale infill in existing low density suburbs particularly old inner suburbs, one off houses in the suburbs where suburban houses on inappropriately large plots could have an extra dwelling built in the rear or to the side and where older suburban housing on large plots is to be demolished and redeveloped that there would be a presumption that planning would only be given for higher urban appropriate densities.

We cannot overemphasize how important it is that existing communities with no available undeveloped land are able host infill development in order to increase residential density to a level where a 15 min city is possible. With out this infill and subsequent increase in density the majority of existing suburban communities in the city will never be able to move away from car dependence and isolation so risk becoming the ghettos of the future where those unable to afford to move to “new” walkable communities will be also for saddled with higher transport costs, isolation and exclusion from opportunities and services.

 

Existing text

Objective 3.4     

Compact Growth

Cork City Council will seek to ensure that at least 66% of all new homes will be provided within the existing footprint of Cork. Cork City Council will seek to ensure that at least 33% of all new homes will be provided within brownfield sites in Cork. Optimising the potential for housing delivery on all suitable and available brownfield sites will be achieved by:

a. Cork City Council acting as a development agency to kickstart regeneration of sites and buildings, utilising acquisition as required;

b. Progress housing and employment delivery in urban centres and strategic regeneration sites;

c. Active land management utilising the range of tools available (including the Derelict Sites Act 1990 and the Urban Regeneration and Housing Act 2015);

d. The redevelopment of surplus utility and public sector owned sites;

e. The development of small sites and the re-use of existing designated and undesignated built heritage assets on those sites;

f. The utilisation of planning and urban design tools to provide a framework for the development of sites (e.g. masterplanning, framework plans, neighbourhood strategies, historic area regeneration strategies, site specific briefs);                                                            

g. Optimising the use of land (see PO HSC3: Density of development, below);

h. Establishing ambitious and achievable buildout rates at the planning stage to help ensure that homes are built quickly and to reduce the likelihood of permissions being sought to sell land on at a higher value;

i. Influencing Government to update the legislative, guidance, fiscal and financial framework to the benefit of housing delivery on brownfield sites;

j. Combining its role as planning authority and housing authority to bring about residential development to meet demand and need;

k. Where new sustainable transport infrastructure is planned land use designations will be reviewed and updated, where appropriate to provide for housing or mixed use development (including housing);

l. Unlock the development potential of brownfield sites to be used as an evidence base and business case for intervention; and

m. Ensuring that all new housing developments contribute to the creation and / or maintenance of successful neighbourhoods.

n. Identify and promote the development potential of brownfield, small sites, regeneration areas and infrastructure packages to enable progress towards achieving compact growth targets.             

o. Encourage the retrofitting and reuse of existing buildings, rather than their demolition and reconstruction

 

 

Suggested Strengthening

 

Objective 3.4     

Compact Growth

Cork City Council will seek to ensure that at least 90% of all new homes will be provided within the existing footprint of Cork. Cork City Council will seek to ensure that at least 50% of all new homes will be provided within brownfield (including subdivision of existing suburban residential sites) sites in Cork. Optimising the potential for housing delivery on all suitable and available brownfield sites will be achieved by:

a. Cork City Council acting as a development agency to kickstart regeneration of sites and buildings, utilising acquisition as required;

b. Progress housing and employment delivery in urban centres and strategic regeneration sites;

c. Active land management utilising the range of tools available (including the Derelict Sites Act 1990 and the Urban Regeneration and Housing Act 2015);

d. The redevelopment of surplus utility and public sector owned sites;

e. The development of small sites and the re-use of existing designated and undesignated built heritage assets on those sites;

f. The utilisation of planning and urban design tools to provide a framework for the development of sites (e.g. masterplanning, framework plans, neighbourhood strategies, historic area regeneration strategies, site specific briefs);                                                            

g. Optimising the use of land (see PO HSC3: Density of development, below);

h. Establishing ambitious and achievable buildout rates at the planning stage to help ensure that homes are built quickly and to reduce the likelihood of permissions being sought to sell land on at a higher value;

i. Influencing Government to update the legislative, guidance, fiscal and financial framework to the benefit of housing delivery on brownfield sites;

j. Combining its role as planning authority and housing authority to bring about residential development to meet demand and need;

k. Where new sustainable transport infrastructure is planned land use designations will be reviewed and updated, where appropriate to provide for housing or mixed use development (including housing);

l. Unlock the development potential of brownfield sites to be used as an evidence base and business case for intervention; and

m. Ensuring that all new housing developments contribute to the creation and / or maintenance of successful neighbourhoods.

n. Identify and promote the development potential of brownfield, small sites, regeneration areas and infrastructure packages to enable progress towards achieving compact growth targets.            

o. Encourage the retrofitting and reuse of existing buildings, rather than their demolition and reconstruction

p. Actively encouraging the re-use of underutilised public and private space, such as parking areas and large gardens, in existing low-density suburbs for infill housing.

q. Actively encouraging the division of large residential sites in existing low-density suburbs into two or more small sites.

 

 

 

Objective 3.9

Adaptation of Existing Homes Infill Development and Conversion of Upper Floors

 

This objective references NPO 34 (National Policy Objective 34 Support the provision of lifetime adaptable homes that can accommodate the changing needs of a household over time.) but appears to support both NPO 34 & NPO 35 (National Policy Objective 35 Increase residential density in settlements, through a range of measures including reductions in vacancy, re-use of existing buildings, infill development schemes, area or site-based regeneration and increased building heights.)

We strongly support NPO 34, NPO 35 as well as the intent of Objective 3.9 and suggest the following rewording for clarity and to full reflect both NPO 34 & NPO 35.

 

Existing text

Objective 3.9

Adaptation of Existing Homes Infill Development and Conversion of Upper Floors

Cork City Council will support and encourage the adaptation of existing homes consistent with NPO 34 of the NPF infill development and the conversion of upper floors in commercial areas in principle to ensure that homes small sites and vacant space are utilised for new housing supply whilst still ensuring high standards of residential amenity for existing adjoining homes.

 

Suggested Strengthening

Objective 3.9

Adaptation of Existing Homes Infill Development and Conversion of Upper Floors

Cork City Council will support and encourage the adaptation of existing homes and communities consistent with NPO 34 & NPO 35 of the NPF by:

a. Supporting and encouraging the adaptation of existing homes to reflect an aging population and changing communities

b. Supporting and encouraging infill development to ensure that homes small sites and vacant space are utilised for new housing supply whilst still ensuring high standards of residential amenity for existing adjoining homes.

c. Supporting and encouraging the conversion of upper floors in commercial areas in principle.

 

Objective 3.13

Rural Generated

 

Existing text

Objective 3.13

Rural Generated

Housing

a. To sustain and renew established rural communities, by facilitating those with a rural generated housing need to live within their rural community.

b. To discourage urban generated housing in the City Hinterland.

c. The City Hinterland is the area under strongest urban generated pressure for rural housing. Therefore, single rural housing applicants must satisfy Cork City Council that their proposal constitutes an exceptional rural generated housing need and satisfies all the requirements of this

 

Suggested Strengthening

Objective 3.13

Rural Generated

Housing

a. To sustain and renew established rural communities, by facilitating those with a rural generated housing need to live within their rural community.

b. To discourage urban generated housing in the City Hinterland.

c. The City Hinterland is the area under strongest urban generated pressure for rural housing. Therefore, single rural housing applicants must satisfy Cork City Council that their proposal constitutes an exceptional rural generated housing need and satisfies all the requirements of this Plan. Any application for the development of a single rural dwelling must set out a comprehensive and conclusive demonstrable economic or social need to live in a rural area, including demonstrating that the dwelling will prevent the need to commute to the location rather than result in commuting from the dwelling.

 

Objective 3.30

               

Social Inclusion

 

Existing text

Objective 3.30

               

Social Inclusion

a. To support policies, strategies and plans that address social inclusion.

b. To actively engage with all sectors of the community to encourage public participation;

c. To support economic development, urban regeneration, lifelong learning and the development of community facilities in more socially and economically disadvantaged parts of the City.

Suggested Strengthening

Objective 3.30

               

Social Inclusion

a. To support policies, strategies and plans that address social inclusion.

b. To actively engage with all sectors of the community to encourage public participation;

c. To support economic development, urban regeneration, lifelong learning and the development of community facilities in more socially and economically disadvantaged parts of the City.

d. To ensure that disadvantaged communities do not suffer from isolation, health, social and economic damage from car dependency and lack of access to public and active travel opportunities.

 

Objective 3.23

School Facilities

 

Existing text

Objective 3.23

School Facilities

a. To work closely with the Department of Education in planning for the delivery of new schools in-step with new housing development within the city.

b. To ensure that new school sites are made available in accordance with the requirements of the Department of Education.

c. To encourage the co-location of schools as part of education campuses and with other community uses to create community hubs. This could facilitate the sharing of halls, playing fields and courts where feasible.

 

Suggested Strengthening

Objective 3.23

School Facilities

a. To work closely with the Department of Education in planning for the delivery of new schools in-step with new housing development within the city.

b. To ensure that new school sites are made available in accordance with the requirements of the Department of Education.

c. To encourage the co-location of schools as part of education campuses and with other community uses to create community hubs. This could facilitate the sharing of halls, playing fields and courts where feasible.

d. To ensure that new school sites are safely and conveniently accessible via waking and cycling.

e. To encourage new school sites to minimises access via private cars.

d. To ensure that the vicinity of new school sites is free from traffic risk including a 30kph speed limit and other measure to reduce traffic.

 

 

Objective 3.24

Third-Level Education and Further Education

 

Existing text

Objective 3.24

Third-Level Education and Further Education

a. To support the ongoing development and provision of third level education, further education and lifelong learning in the City.

b. To work with the education providers to ensure their facilities can be upgraded and expanded to meet their requirements.

c. To work with the education providers in promoting and facilitating measures (such as the Higher Education Access Route and ACCESS+) which seek to extend education opportunities to representatives from socially and economically disadvantaged backgrounds.

d. To facilitate and promote synergies between education, industry and entrepreneurship with an emphasis on retaining talent in the City, facilitating the expansion of existing economic clusters and the establishment of new clusters, and increasing participation in the City’s labour force.

 

Suggested Strengthening

Objective 3.24

Third-Level Education and Further Education

a. To support the ongoing development and provision of third level education, further education and lifelong learning in the City.

b. To work with the education providers to ensure their facilities can be upgraded and expanded to meet their requirements.

c. To work with the education providers in promoting and facilitating measures (such as the Higher Education Access Route and ACCESS+) which seek to extend education opportunities to representatives from socially and economically disadvantaged backgrounds.

d. To facilitate and promote synergies between education, industry and entrepreneurship with an emphasis on retaining talent in the City, facilitating the expansion of existing economic clusters and the establishment of new clusters, and increasing participation in the City’s labour force.

e. To ensure that new educational developments are safely and conveniently accessible via waking and cycling.

f. To encourage new educational developments to minimises access via private cars.

g. To ensure that the vicinity of new educational developments is free from traffic risk including a 30kph speed limit and other measure to reduce traffic.

 

Objective 3.34  

Safe and Secure City

 

Existing text

Objective 3.34  

Safe and Secure City

a. To ensure a well-integrated urban form that provides a safe environment for all users by maximising visibility and surveillance, increasing pedestrian activity and maximising connections between areas.

b. To encourage buildings and spaces to be designed with safety and security in mind to avoid anti-social behaviour, reduce and prevent crime and create safe places for all.

c. To encourage the ongoing maintenance and upkeep of the public realm, keeping spaces free of graffiti and litter etc.

 

Suggested Strengthening                            

Objective 3.34  

Safe and Secure City

a. To ensure a well-integrated urban form that provides a safe environment for all users by maximising visibility and surveillance, increasing pedestrian activity and maximising connections between areas.

b. To encourage buildings and spaces to be designed with safety and security in mind to avoid anti-social behaviour, reduce and prevent crime and create safe places for all.

c. To encourage the ongoing maintenance and upkeep of the public realm, keeping spaces free of graffiti and litter etc.

d. To ensure all ages and all abilities can safely walk, cycle, socialise and play on the city’s streets without fear of traffic or harassment from drivers.

 

 

 

 

Chapter 7

Economy and Employment

Main points

 

• We support the consideration of mobility given to commercial development and employment centres
• We support the clear preference given to public and active transport in the planning of  commercial development and employment centres.
• We support preference shown towards location large office developments in the city centre docklands and district centres and have suggested slight modification/strengthening of the objectives referring to large office developments and strategic employment zones to make this clearer.

 

 

Mobility Management

 

We feel that mobility management plans are an important tool in ensuring that we achieve compact growth, the strategic objectives outlined in chapter 1 and the vision for a 15-minute City.

We therefore strongly support objective 7.8

 

Objective 7.8

Mobility Management Plans

In addition to traffic impact assessments, Cork City Council will encourage all planning applications for new employment uses, or extensions to existing commercial premises, for 100 or more employees to prepare mobility management plans which promote and prioritise the use of more sustainable transport modes.

 

We request that consideration is given to lowering the criteria for drawing up mobility management plans from 100 to 50 employees

We also request that another objective is inserted objective 7.x

There will be presumption against developments providing free or subsidised parking for staff or customers, except for disabled parking and loading bays.

The subsidization of parking by businesses is paid for by everybody not just those who drive and incentivises driving as the cost is borne by everybody not just those driving and is in conflict with the strategic objective outlined in chapter 1.

 

 

 

Strategic employment zones

 

There needs to be a general assumption that retail, general office accommodation, call centres etc the located in the centre of dense walkable neighbourhoods such as the city centre, the Docklands but also in the district centres outlined in this plan. We welcome that this is clearly envisioned in the draft plan and suggest a slight strengthening in the flowing objectives to ensure this overall objective is reached.

The core goal of the Cork transport and mobility forum is enabling people to travel in a way that is more sustainable and has less of a negative impact on their health and quality of life. This is to a large degree dependent on enabling people to switch from private motor vehicles to public and active transport. But it is also so about ensuring that people do not have to travel excessive distances to meet their everyday needs. Improving mobility is not about increasing the number of kilometres people can travel easily rather it is about minimising the number of kilometres you need to travel to make all the journeys you desire. By bringing trip generators closer together and improving permeability people can make more trips per day living more fulfilling and productive lives at the same time as spending less time and resources on travel.

The key determinant of this vision of improved mobility, which is well supported throughout this draft plan, comes to pass is not any dedicated transport intervention but rather ensuring homes and services are built closer together. This requires ensuring that commercial developments which have a high density of customers or employees visiting the site are located in mixed-use communities not in low density or purely commercial zones together with light industry or distribution hubs which have an inherently low density of employment and trip generation but rather in compact mixed-use communities together with homes services and amenities.

The proposed light industrial zones are highly appropriate for light industry, distribution and other commercial uses which have a low density of trip generation or hazardous noxious or are otherwise unsuitable for locating together with residential, service and amenity developments or where the majority of trips generated require the use of heavier vehicles such as HGVs, light trucks or vans.

An exception to this is large campuses which are of a scale too large to be accommodated within mixed-use developments these should be by located within the city centre or Docklands if they are of sufficient density and a suitable site can be identified otherwise they should be subject to a separate more stringent Mobility Management Plan than that outlined in objective 7.8 and located on a key public transport route preferably a rail line or the route of the proposed light rail scheme.

The following objectives need modified to reflect this

 

Objective 7.10

New Strategic

Employment Sites

Existing text      

Objective 7.10

New Strategic

Employment Sites

 

To support the sustainable delivery of high quality employment facilities taking into account other Development Plan objectives relating to zoning, transport and movement, urban design and placemaking, climate action, environmental management and sustainability, biodiversity, protecting cultural and built heritage and taking into account site specific objectives below:

a. Blarney Business Park Extension: To provide for a high-quality extension to Blarney Business Park using the existing access to the Park. Any proposed development needs to safeguard the M/N20 (navy) route option which traverses part of the land until such time as a preferred route is chosen and the requirement lapses if the navy route is not identified as the preferred route.

b. Clogheen Business Park Extension: To provide for a high-quality extension to the business park where care is needed to preserve the residential amenity of nearby residential properties.

c. Land at Ballyvolane: To provide for a high-quality employment scheme that integrates with wider development, specifically the Ballyvolane expansion area to the south.

d. Land at Glanmire: To provide for a high quality employment development that will primarily service logistics or logistics related uses. No more than 30% of the zoned land shall be developed for non logistics related employment uses.

e. Land at South Link Industrial Estate: To provide for a natural extension to the existing industrial estate where, owing to the proposed intensification of use, an alternative access strategy through the industrial estate should be prioritised.

f. Land at Fairhill: To provide for a high quality light industrial development scheme that is accessed from Upper Fairhill and suitably responds to the site topography, the site’s frontage onto Nash’s Boreen and the need to protect residential amenity of nearby residential priorities.

g. Land at Hollyhill: To provide for a high quality business and technology scheme capable of accommodating expansion and other strategic investment in a manner that seeks to protect the surrounding landscape setting.

 

Suggested Strengthening

Objective 7.10

New Strategic Employment Sites

 

To support the sustainable delivery of high-quality employment facilities for light industry, distribution and other commercial uses which have a low density of trip generation or hazardous noxious or are otherwise unsuitable for locating together with residential, service and amenity developments or where the majority of trips generated require the use of heavier vehicles such as HGVs, light trucks or vans. There will be presumption against development of general office space, call centres, retail and other high density commercial uses which can be accommodated in mix use communities. Taking into account other Development Plan objectives relating to zoning, transport and movement, urban design and placemaking, climate action, environmental management and sustainability, biodiversity, protecting cultural and built heritage and taking into account site specific objectives below:

a. Blarney Business Park Extension: To provide for a high-quality extension to Blarney Business Park using the existing access to the Park. Any proposed development needs to safeguard the M/N20 (navy) route option which traverses part of the land until such time as a preferred route is chosen and the requirement lapses if the navy route is not identified as the preferred route.

b. Clogheen Business Park Extension: To provide for a high-quality extension to the business park where care is needed to preserve the residential amenity of nearby residential properties.

c. Land at Ballyvolane: To provide for a high-quality employment scheme that integrates with wider development, specifically the Ballyvolane expansion area to the south.

d. Land at Glanmire: To provide for a high quality employment development that will primarily service logistics or logistics related uses. No more than 30% of the zoned land shall be developed for non logistics related employment uses.

e. Land at South Link Industrial Estate: To provide for a natural extension to the existing industrial estate where, owing to the proposed intensification of use, an alternative access strategy through the industrial estate should be prioritised.

f. Land at Fairhill: To provide for a high quality light industrial development scheme that is accessed from Upper Fairhill and suitably responds to the site topography, the site’s frontage onto Nash’s Boreen and the need to protect residential amenity of nearby residential priorities.

g. Land at Hollyhill: To provide for a high quality business and technology scheme capable of accommodating expansion and other strategic investment in a manner that seeks to protect the surrounding landscape setting.

 

Objective 7.13

 Suburban General Offices

Existing text      

Objective 7.13

 Suburban General Offices

a. General offices units over 1,000 sqm will be open for consideration in suburban Business and Technology Zones, with due consideration given to the employment strategy, availability of alternative suitable sites in the City Centre and adjoining mixed use areas in Docklands, and assessment of the potential impact of the development on the City Centre. Availability of high-quality public transport will also be a factor in determining the capacity of these locations to take more intensive office development.

b. General offices will be open for consideration in District Centres provided each office unit is in excess of 1,000 sqm and the total area of offices is appropriate to the scale of the individual centre, subject to a general maximum of 20,000 sqm of offices in any one centre.

Suggested Strengthening

Objective 7.13

 Suburban General Offices

a. General offices units over 10,000 sqm will be open for consideration in suburban Business and Technology Zones, with due consideration given to the employment strategy, availability of alternative suitable sites in the City Centre and adjoining mixed use areas in Docklands, and assessment of the potential impact of the development on the City Centre. Such developments will be required to demonstrate in their mobility management plan how employees will be able to travel by public or active transport must not prove free or subsidised employee parking.  Availability of high-quality and capacity public and active transport links will also be a factor in determining the capacity of these locations to take more intensive office development.

b. General offices will be open for consideration in District Centres provided each office unit is in excess of 1,000 sqm and the total area of offices is appropriate to the scale of the individual centre, subject to a general maximum of 20,000 sqm of offices in any one centre.