Draft County Development Plan 2011 -2017

Stan Nangle

The closing date for submissions to the Draft County Development Plan 2011 -2017 is next Tuesday, May 4th.

http://www.waterfordcoco.ie/en/services/planning/draftcountydevelopmentplan2011-2017/

If you're not in you can't win!

alicec

Once again I am writing waterford Co Co to complain of the lack of a Tramore map in the development plan.
I strongly object to this plan being passed without an opportunity for the citizens of Tramore to see how the land in and around Tramore is designated.
Should the development plan be passed without this critical flaw being altered , I am putting it here on public record that should any future development proposal, particularly in housing, infrastructure or industry adversely affect a resident of Tramore , then Waterford County council will be deemed negligent and be liable in any legal proceedings. I urge other residents of Tramore to register their critisim with Waterford CoCo.

Stan Nangle

Tramore has its own plan, the Tramore Local Area Plan, which runs until 2013.

http://www.waterfordcoco.ie/en/media/planning/pdfs/Tramore.pdf

Sully

This is what the Garrus Golf organisation are recommending you send in.

You can make submissions online::
# Type ‘submission to WCDP 2011 – 2017’ in the subject box
# State that you would like the council to consider the following as you submission to the new development plan 2011 – 2017
# Insert your name and address at the end of document (important).
# Send to: countydevplan@waterfordcoco.ie

Development Plan Review,

Planning Section,

Waterford County Council,

Civic Offices,

Davitts Quay,

Dungarvan,

County Waterford



28th April 2010



Dear Sirs,



Under the Planning and Development Act 2000 (as amended) I welcome the opportunity to make the following submissions as part of the review of the Waterford Co. Development Plan 2005 - 2011 and the preparation of a new County Development Plan 2011 - 2017.



In an increasingly urbanised society there is a real need to preserve our natural resources as an antidote to the stresses of modern life in which people are removed from the influence and exposure to nature and undeveloped countryside. It is essential that we retain large elements of unspoilt countryside for tranquil recreation that is independent of personal wealth for access or enjoyment. As importantly there is a onus on our generation to act as guardians of this resource for future generations.



A landscape once developed is forever altered and a single ill-considered development can irrevocably and irredeemably undermine a historic landscape and view. In the current economic climate it is important to consider and protect valuable resources such as landscape and naturally occurring local amenities such as beaches, headlands, wooded and upland areas. The coastline, rivers and mountains of County Waterford must rank highly in this respect. Such resources within the county have significant economic potential within the tourism economy but the sensitivity of such landscapes in terms of how they might be preserved and made accessible to the public necessitates careful management and strict planning controls. Failure to implement such careful management and strict planning controls will erode their potential as tourism resources.



County Waterford is for the most part a county of unspoilt natural beauty and special character with a diverse range of natural interests including birds, flora, fauna, wildlife, geology and archaeology. The Waterford coastline has largely escaped the damaging effects of over-development and maintains an open, rural elevated landscape of exceptional quality and character.



The Planning Authorities of Counties Clare and Donegal have, through poor planning and settlement policies, significantly compromised the visual amenity of the natural heritage of these counties. County Waterford is similarly vulnerable to such destruction of the visual amenity and it must be the aim of Waterford County Council Planning Authority to ensure that this does not take place.



The aim of Waterford County Council Planning Authority must be then to promote sustainable development in environmental, landscape, tourism and settlement terms while protecting the unique and vulnerable natural resources that make Waterford County unique and extraordinary both nationally and internationally. Maintaining the county’s vulnerable, but largely unspoilt, natural landscapes—especially its coastal landscape— in their current state should be a core objective of the new CDP.



I wish to propose a number of simple strategies which will allow for the protection of such places within County Waterford:



Removal of inconsistent and incompatible Polices ECD 24 & ECD 25 from the Draft CDP

* Policies ECD 24 & ECD 25 detailing integrated rural tourism and recreational complexes (IRTRCs) should be withdrawn from the new CDP 2011 – 2017 as they allow for the unrestricted entitlement by commercial developers to develop on unzoned lands which can lead to the exploitation of Greenfield sites. Policies ECD 24 & ECD 25 could be described as the antithesis of the vision statement which pledges that Waterford County Planning Authority is committed to developing Waterford as a county:



where the wellbeing of the community is enhanced through balanced economic development, the creation of attractive places to live and work and through the sustainable management of our natural assets as we strive to become a Green County (Waterford County Development Plan 2011 -2017 Draft, p. 1)



In fact Policies ECD 24 & ECD 25 have the potential to compromise the Draft CDP by introducing ambiguity in their interpretation and threatening the natural assets referred to in the vision statement quoted above. Policies ECD 24 & ECD 25, as they are currently articulated within the Draft CDP, allow for the development and potential exploitation of protected natural assets through inappropriate and unsustainable development. Such exploitation of a specially protected and vulnerable site was demonstrated in planning file 08/55. The development proposed highlighted the damaging potential of such policies which would have permitted a housing and leisure complex in an area of extraordinary environmental and visual significance. The An Bord Pleanála Inspector’s Report was highly critical of such policies (ABP ref.: 232989) and the comments of the Bord’s inspector should act as a guide to the Planning Authority to remove these flawed policies. The Manager’s Report indicated that the IRTRC policy would be reviewed subsequent to the An Bord Pleanála decision on file 08/55 and this review has not occurred.





Future variation policies to the CDP 2011 – 2017

* It should be clearly stated within the new CDP that any proposed variation policies must undergo a rigorous compatibility & consistency assessment with the policies and objectives already contained in the Plan.



* It should also be explicitly stated in the new CDP 2011 – 2017 that any proposed variation policies to the CDP will be read in conjunction with existing or established policies rather than being considered as a possible means of compromising these established policies.





Sustainable tourism

* There are currently no safeguards within the Draft CDP in relation to what constitutes sustainable tourism development. The CDP should define what constitutes sustainable tourism development so as to ensure that an appropriate and sustainable tourism sector is established and supported. This definition of what might be considered as sustainable tourism development must emanate from a nationally recognised tourism body such as Failte Ireland.



* With regard to promoting sustainable tourism and particularly in relation to any developments that contain hotel and/or self-catering apartments/lodges/chalets etc. Waterford County Planning Authority must take into account the recent report by Peter Bacon and Associates commissioned by the Irish Hotel’s Federation. This report outlines the insolvency within a large part of the hotel industry particularly within the four and five star hotel segment. The report states that there has been a 384% increase in 4/5 star hotels since 2002 and this proliferation threatens the viability of established hotels. The report recommends that the hotel sector should now prepare a strategy for the orderly elimination of approximately 15,000 rooms and admits that while the solution is clear that the practicalities of this are extremely problematic. Therefore within the life of the new CDP any mention of encouraging the development of hotels (which is a mandatory element of the IRTRC), particularly high quality hotels, is irresponsible as it fails to recognize the current crisis within the hotel sector. To promote the development of hotels within the next five years would not only risk initiating unsustainable development in the form of “zombie” hotels but also risk undermining the existing hotel industry.



* With regard to developing sustainable tourism complexes the new CDP should insist that all such development proposals comply with the SPRITE initiative created by the European Union which supports and promotes integrated tourism projects and developments in Europe’s rural regions[1].





Greenbelt areas

* Land zoned for housing within existing settlement nodes should be fully utilized before there is any rezoning of lands within Greenbelt areas.



* There should be no development within Greenbelt areas. This point should be reinforced within the new CDP 2011 - 2017 and strictly adhered to.



* The current scenic landscape appendix to the current CDP should be revised, strengthened and strictly adhered to in the new CDP 2011 - 2017.



* Wording and terminology within the new CDP 2011 - 2017, particularly in relation to protected areas or greenbelts should be as clear and precise as possible with strict and unambiguous terminology employed to protect such areas from exploitation by those advocating commercial development of such sites.





Coastal zones

* Development should not be allowed under any circumstances between the nearest road to the coastline and the coastline itself except in designated settlement nodes as set out in the current Development Plan.





Settlement nodes

* Development being considered within designated settlement nodes should only be considered in very exceptional circumstances and only permitted after an independent landscape impact evaluation has been carried out. This should be the case irrespective of the size of the proposed development and in all areas of scenic value.





Areas of special protection and scenic value

* In the case of development near areas of special protection or scenic value, strict design criteria should be demanded of the developer of this site. Criteria should include limitations on building height, material colour, screening and orientation and should insist that hedgerows are left intact where possible.



* Designated areas such as pNHAs, SACs and SPAs should be respected and protected within the new development plan with the full rigour of international best practice guidelines.



* Likewise other categories which have protection in the current Development Plan such as archaeological areas, geological areas of scientific interest, protected landscapes, visually vulnerable areas, and coastal zones must be given the same respect and protection in the CDP 2011 – 2017. Under no circumstances should there be any building allowed on these sites which are some of the most scenic and valuable natural resources of our county.



* The Council should strengthen the language within the Draft CDP eradicating references to “protecting where possible” natural resources, such as landscapes, rivers, mountains, beaches, headlands, wooded and upland areas. The new CDP should include an explicit recognition that the county will prohibit development within these areas.





Other points to note

* Any statements that are made within the new CDP 2011 – 2017 should be reinforced with evidence and argument in order to create a plan that is based upon the principles of good research and national and international best planning practice.









Yours sincerely,