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Dear Sir/Madam,
1.0 INTRODUCTION
On behalf of our clients, Bernie Craughan, Puckane Development Association
(“the Boreen” Puckane, Nenagh, County Tipperary ) we hereby lodge a third party
submission in respect of the above mentioned proposed development.
Our client’s object to the proposed development. The full grounds of our clients’
objection are set out below. We enclose the prescribed statutory fee of €20.00.
We have perused in detail the plans and particulars submitted in support of this
planning application and we submit to the Planning Authority that a number of
important issues have not been adequately addressed by the applicant, these
include:
Cumulative Impact
We respectfully submit to the Planning Authority that the indirect and cumulative
impact of wider development within the site has not been assessed with respect to
such issues as traffic impact, flooding, foul effluent and community and social
infrastructure provision.
National planning policy, including the National Spatial Strategy, Guidelines for
Sustainable Residential Development in Urban Areas and the Development Plan
Guidelines require that the urban extension of established settlements should take
place in a coherently planned and sequential manner. The proposed development
does not accord with this principle and will result in piecemeal and uncoordinated
development and the inefficient provision of infrastructure.
The planning authority will be aware of the major oversupply of zoned land and
housing nationally together with Government policy as articulated in the National
Spatial Strategy and the Regional Planning Guidelines for the Mid-West Region to
focus new residential development in larger urban centres and serviced
settlements. Owing to the severe economic downturn brought about substantially
by major regulatory weaknesses in our planning system and property development
sector, national planning policy and legislation together with transport policy has
moved on markedly in the intervening period since these lands were speculatively
zoned for development. The planning authority will be aware that the Planning &
Development (Amendment) Act 2010 is now law and that within one-year a
Variation of the North Tipperary County Development Plan will be required to
address the oversupply of zoned land in inappropriate locations.
• The Board considered that the expansion of the town of Dunmore East
should be planned in tandem with the provision of the services and
infrastructure necessary to sustain new development and that the
provision of individual waste water systems to facilitate individual housing
schemes was neither an economical nor environmentally sustainable
approach.
• Having regard to the scale of the proposed development (Phase 1 of a
much larger development) in relation to the town of Dunmore East, it
appears to the Board that the development is, to a substantial degree,
aimed at attracting commuters, rather than responding to likely local
needs. The proposed development would, therefore, promote an
unsustainable development pattern contrary to the National Spatial
Strategy and other general policies of the Government in relation to
sustainable development.
• Also the Board considered that the lay-out and design of the proposed
development was generally of a suburban character and likely to detract
from the distinctive character of the town.
The Puckane settlement plan included within the Western Area Local Area Plan
provides a clear development brief for the subject site. This Masterplan states:
“To provide low density cluster style development 10.5 acres of land situated west
of the GAA pitch on the Dromineer Road as follows
Also within the specific objectives of the Puckane settlement Plan, the following
items are listed:
The Planning Authority will note that the Department of Environment, Heritage and
Local Government has published Guidelines for the Provision of Schools and the
Planning System. The Guidelines provide that the future location and capacity of
school infrastructure must be identified in all planning applications for major new
urban development. The future school location is not indicated anywhere within the
plans and particulars submitted by the applicant.
There are no proposals submitted to provide road widening, footpath and public
lighting along the Dromineer Road to link the Village centre as requested in the
Masterplan 3.
The Planning Authority will be aware of its obligations under the Waste Water
Discharge (Authorisation) Regulations SI No. 684 of 2007 as outlined in Circular Letter PD 7/09
It is noted from the plans and particulars submitted that the applicant intends to
connect to the public sewer within Puckane. However the existing sewerage
treatment plant is currently operating at capacity. The Planning Authority will be
also aware of the implications of the Water Framework Directive and Ireland’s
obligations under this Directive to achieve ‘Good’ status in all water bodies by 2015.
This is confirmed within the Western Area local Area Plan which states;
Objective SO 13: “The existing sewerage treatment plant is at capacity and will
require an upgrade to accommodate the planned expansion of the village.
Developers will be required to enter partnerships towards the provision of an
improved facility. This may be dealt with through a number of options that include
a public private partnership, a serviced land initiative or through special
development contribution scheme”.
And also Item 2.6 on page 5 of the Puckane Village Design Statement states;
“the existing sewerage system has limited capacity. This is of serious concern to the
community. Prior to the addition of new housing to the village sewage issues need
to be addressed.”
There are no proposals submitted to upgrade the sewerage treatment plant within
Puckane and therefore contravenes the objectives of the Western Area Local Area
Plan.
During the Western Area Local Area Plan consultation and the Village Design
Statement process both Mr. Pat Slattery & Mr. Brian Beck of North Tipperary County
Council gave assurances to the residents of Puckane that no development will take
place on zoned lands within the Village until the capacity of the sewerage treatment
plant has been adequately increased.
Within the Village of Puckane there is a serious issue relating to the disposal of
storm water particularly within Ballycraggan. During times of heavy rains flooding
occurs within the hurling field and within Ballycraggan estate itself. The Planning
Authority will be aware of the published Flood Guidelines for Planning Authorities.
No justification has been provided within the plans and particulars submitted to
address the issue of flooding within Puckane.
This will be further exacerbating an existing problem as the proposed entrance to
the proposed development is the LOWEST point in the Village as per OS Maps and
Data.
The proposed vehicular access junction from the proposed development to the
L5006 Dromineer/Urra Road is substandard in both road width and sufficient lines of
sight. The L5006 Dromineer/Urra road adjacent the subject site has a substandard
vertical and horizontal alignment is circa 4 meters in width and does not allow for
two cars to pass simultaneously. The proposed development for the subject site
does not contain proposals to upgrade this road. The proposed development
together with the cumulative impacts of the overall development of the subject
lands will generate significant additional traffic movements on the adjacent road
network and would constitute a traffic hazard.
The applicant companies have also failed to indicate the required sightlines from
the proposed access junction. We submit that the proposed junction in its current
format has substandard sightlines. Sightlines from the entrance to the proposed
development must be measured using standards from the NRA Design Manual for
Roads and Bridges and the DOE Traffic Management Guidelines. This requires the
“x” point of the site line to be taken from the centre point of the access 4.5 metres
from the edge of the carriageway. The standards allow for a relaxation in the
standards to 2.4 metres for individual residential units. This relaxation does not
apply in this instance. The standards require that the Y-distance measurement to
the right of the entrance was taken to the near side of the carriageway, while the Y-
distance to the left of the site betaken to the centre of the carriageway as per the
requirements contained in the NRA Addendum to TD 42/95. These are reproduced
as Figures 1 & 2 detailed below.
Owing to the substandard nature of the adjacent road network and access junction
the development the development as submitted would constitute a traffic hazard
and would endanger the safety of the existing road users.
Conclusion
The proposed development contravenes national and local planning policy guidance
and particularly the policies and objectives of the Western Local Area Plan. The
proposed development by reason of substandard vehicular sightlines and the
overall cumulative impact of the future phased development of the subject lands
would have an adverse impact on the capacity of the local road network and would
constitute a traffic hazard.