Cork Chamber Submission to the Local Area Plan for Blarney Macroom Municipal District
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Cork Chamber BLARNEY-MACROOM LAP Submission
Cork Chamber Submission to the Local Area Plan for
Submission developed by McCutcheon Halley at the request of Cork Chamber January 2017 1
Blarney Macroom Municipal District
Cork Chamber BLARNEY-MACROOM LAP Submission 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.
Submission developed by McCutcheon Halley at the request of Cork Chamber January 2017 2
Cork Chamber BLARNEY-MACROOM LAP Submission AREA PROFILE
B L A R N E Y MAC R O O M M U N I C I PA L D I S T R I C T 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
Submission developed by McCutcheon Halley at the request of Cork Chamber January 2017 3
Cork Chamber BLARNEY-MACROOM LAP Submission AREA PROFILE
HOUSING REQUIRED
COUNTY CORK BLARNEY MACROOM MD
5,880 Units
“
56,284 Units
10% OF THE COUNTY’S HOUSING REQUIREMENT
B L A R N E Y MAC R O O M M U N I C I PA L D I S T R I C T AREA PROFILE
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
41.3% of population in work
9.7% Agriculture/
Forestry/Fishing
17,703 jobs
31.5% in MD 26.1% in
City
12.2% Information/
Communication/Financial
46.8% in
Other Areas
20.4% Wholesale/
Retail/Accomodation
21.8% Education
Human Health
Submission developed by McCutcheon Halley at the request of Cork Chamber January 2017 4
Cork Chamber BLARNEY-MACROOM LAP Submission 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.91of 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.
Submission developed by McCutcheon Halley at the request of Cork Chamber January 2017 5
Cork Chamber BLARNEY-MACROOM LAP Submission 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
Submission developed by McCutcheon Halley at the request of Cork Chamber January 2017 6
Cork Chamber BLARNEY-MACROOM LAP Submission 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
Submission developed by McCutcheon Halley at the request of Cork Chamber January 2017 7
Cork Chamber BLARNEY-MACROOM LAP Submission
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-monitor-
manage 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.
Submission developed by McCutcheon Halley at the request of Cork Chamber January 2017 8
Cork Chamber BLARNEY-MACROOM LAP Submission 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.
Submission developed by McCutcheon Halley at the request of Cork Chamber January 2017 9
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