Aldi Stores (Ireland) Ltd - Submission to inform the draft Cork City Development Plan 2022-2028
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Submission
to inform the draft Cork City Development Plan
2022-2028
Prepared in August, 2020 on behalf of
Aldi Stores (Ireland) Ltd
Coakley O’Neill Town Planning Ltd.
NSC Campus, Mahon, Cork 021 2307000 info@coakleyoneill.ie www.coakleyoneill.ieDocument Control Sheet
Client Aldi Stores (Ireland) Ltd
Project Title Cork City Development Plan 2022-2028
Job No. CON20175
Document Title Submission to inform the draft Cork City Development Plan 2022-2028
Number of Pages 6
Revision Status Date of Issue Authored Checked Signed
1 Draft 20th August, 2020 AON JS
2 Final 20th August, 2020 AON
Confidentiality Statement
This report has been produced for the exclusive use of the commissioning party and unless otherwise agreed in writing by Coak ley
O’Neill Town Planning Ltd., no other party may copy, reproduce, distribute, make use of, or rely on the contents of the report. No
liability is accepted by Coakley O’Neill Town Planning Ltd. for any use of this report, other than for the purposes for which it was
originally prepared and provided. Opinions and information provided in this report are on the basis of Coakley O’Neill using due skill,
care and diligence in the preparation of same and no explicit warranty is provided as to their accuracy. It should be noted and is
expressly stated that no independent verification of any of the documents or information supplied to Coakley O’Neill Town Planning
Ltd. has been made.
Maps reproduced under Ordnance Survey Ireland Licence Number EN 0089019P a g e |3
1.0 Introduction and Purpose
1.1 We, Coakley O’Neill Town Planning Ltd., NSC Campus, Mahon, Cork, on behalf of Aldi Stores (Ireland)
Ltd, Limerick Road, Mitchelstown, Co. Cork have prepared this submission to inform the preparation of
updated convenience retail policies in the draft Cork City Development Plan 2022-2028, hereafter
referred to as the ‘new Plan’.
2.0 Aldi in Cork City
2.1 The following are the key relevant facts for this submission:
Aldi was first established in Ireland in 1999, and currently operates over 142 stores in the country, of
which there are only 11 (8%) in Cork City1.
Based on the 2016 population, this equates to just 1 store per 19,200 people, whereas a catchment
10,000 people would be generally required to support a store. There is a clear underprovision in
the City, which will only be more pronounced in the context of an expanded population to at least
315,000 persons by 2040.
Aldi stores are typically of medium scale, up to 1,315m2 net retail floorspace.
The basis of Aldi’s success is a philosophy of offering customers a carefully selected range of high-
quality products at heavily discounted prices and guaranteeing these discounted prices week in
week out. This includes weekly “specials”. Every week throughout the year different goods are on
offer on a once off basis at heavily discounted prices, attracting considerable repeat custom across
the socio-economic groupings.
Aldi only sells approximately 1,000 lines, compared for example with up to 15,000 lines in a large
supermarket. Therefore, it is the case that Aldi stores only meet a proportion of a customer’s
convenience needs. The discount foodstore concept therefore interacts closely with other shops.
These are important guiding principles for this submission to inform the direction of the new Cork City
Development Plan.
1
Glanmire, Mayfield, Blackpool, Ballincolling (2), Wilton, Tory Top Road, Blackrock, Grange and the Elysian. The Douglas store, which is included, is
under construction.
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3.0 Strategic Planning Context
3.1 As noted in the Pre-plan consultation Issues Paper on Cork City Development Plan 2022-2028 issued on
26th June, 2020, the National Planning Framework (NPF) 2018, as endorsed in the Regional Spatial and
Economic Strategy for the Southern Region (RSES) 2020, sets a target for Cork City of an additional
125,000 people by 2040, an increase of almost 60% on the population recorded in Census 2016 (c.
211,000 persons).
3.2 This equates to an average additional population of 6,250 people to 2040, which, represents a
challenging task for the City to deliver a higher density of development, compact growth, and improved
liveability, as well as additional social, community (including retail) and environmental infrastructure over
the next 20 years.
3.3 In the context of this submission, the Retail Planning Guidelines 2012 and associated Retail Design
Manual are focused on:
o Ensuring that the planning system continues to play its role in supporting competitiveness and
choice in the retail sector commensurate with promoting the vitality and viability of city and
town centres
o Ensuring that the development management process supports applications for retail
development which are in line with the role and function of the city or town in the settlement
hierarchy of the relevant development plan, and accord with the scale and type of retailing
identified for that location in the development plan and relevant retail strategy
o Promoting Retail Impact Assessment and Sequential Test as the tools to be used in determining
the suitability of a retail proposal
o Emphasising the importance of placemaking and good urban design and public realm.
3.4 Policy objective RPO55 of the Regional Spatial and Economic Strategy (RSES) for the Southern Region,
endorses the provisions of national retail policy. In articulating what makes good placemaking, the RSES
identifies that consideration should be given to the regenerative effects of retail, and the function of the
retail sector to service a growing population and contribute to compact growth in urban settlements.
3.5 Consistent with national retail policy, the current Cork City Development Plan 2015 places emphasis on
the retail hierarchy of the City Centre, District Centre and Neighbourhood/Local Centre in locating new
retail uses. There is also policy support through Objective 4.6 for new neighbourhood centres. The
existing operational centres at Blackrock Hall and Tory Top Road are examples of such an approach.
Aldi Stores (Ireland) Ltd Submission to inform the draft Cork City Development Plan August 2020P a g e |5
4.0 Submission
4.1 This submission is premised on the need to reconsider the current retail strategy for the expanded City
in light of recent experiences during the COVID-19 pandemic, the control measures for which are likely
to remain for some time.
4.2 The importance of facilitating a range of good quality, small to medium scale, accessible convenience
retail options within easy reach of local residential communities, particularly for the vulnerable and less
able, is a key issue that needs to be addressed in the new Plan, noting that current restrictions on the
use of public transport are also likely to remain in place for the foreseeable future.
4.3 This approach is, in fact, endorsed by Objective 4.1(c) of the current Plan, which supports the provision of
good quality and accessible convenience goods shopping to all residents of the city, and also Objective 4.9,
which seeks to improve the quality of convenience retail floorspace throughout the City and environs.
4.4 In practice, however, planning history, e.g. TP 11/34853 and PL 28.238439 (TP 10/34663) (Lidl Skehard
Road) would indicate that medium-scale convenience retail development in residential areas outside
designated centres are generally not supported.
4.5 This is distinctly different to the approach taken in the County, as evidenced, for example, by the
operational Aldi store permitted on lands zoned ‘Existing Built Up Area’ in an established residential area
of Hazelwood, Glanmire (PL04 .242004 (12/06420) which is now part of the expanded City.
4.6 In that instance, the Board found that, having regard to the central location of the site within Riverstown,
the existing Built-Up zoning of the site in the Glanmire Local Area Plan, the Retail Objectives and Policies
set out in the Cork County Development Plan 2009-2015, the Blarney Electoral Area Local Area Plan 2011
and the Glanmire Local Area Plan contained therein, and the Cork Strategic Retail Study for Cork City
and County 2008, the proposed development would not adversely affect the Glanmire settlement centre
as the prime shopping centre for the area, would not seriously injure the residential or visual amenities
of the area or of property in the vicinity and would be acceptable in terms of traffic safety and
convenience.
4.7 This is not to say that a laissez-faire approach to convenience retail should be adopted. Rather, a more
flexible approach to the location of small to medium scale convenience retail uses (up to 1,315m2 net
retail floorspace), including stand-alone convenience retail uses (or a convenience retail use with a
smaller supporting retail/retail services use, e.g. pharmacy/coffee shop) is suggested, particularly in
residential areas, where it can be justified on retail impact, sequential test, and placemaking grounds,
and without significant impact on residential amenity.
4.8 The effect of this would to remove the current restriction that generally limits new small to medium scale
convenience retail uses to designated centres (i.e. City Centre, District Centre, Neighbourhood/Local
Centre).
Aldi Stores (Ireland) Ltd Submission to inform the draft Cork City Development Plan August 2020P a g e |6
4.9 Not only will this facilitate the provision of appropriately-located and appropriately-sized convenience
retail uses throughout the City, but it will also assist in enabling small to medium scale operators such as
Aldi to increase their presence in the City in line with Objective 4.1(c) and Objective 4.9 of the current
Plan. Operators such as Aldi are currently constrained from increasing their presence in the City as a
consequence of the lack of suitable sites and the restrictions imposed by current retail policies, which are
really only appropriate for, and applicable to, large-scale retailers, particularly comparison retailers.
5.0 Conclusion
5.1 This submission on behalf of Aldi Stores (Ireland) Ltd, sets out a number of issues that merit
consideration in progressing the preparation of the new Plan.
5.2 This submission seeks support in principle for the provision of small to medium scale convenience retail
uses (up to 1,315m2 net retail floorspace) outside designated centres (i.e. City Centre, District Centre,
Neighbourhood/Local Centre), particularly in residential areas, subject to justification in terms of retail
impact, sequential test, contribution to placemaking, and demonstrating no significant impacts on
residential amenity.
5.3 These suggestions are in line with the national and regional policy which promotes compact
development, improved competitiveness and choice in the retail sector, liveability, sustainable
transportation, particularly by walking and cycling, and good placemaking in our urban areas.
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