North Tipperary County CouncilPlanning & Development DepartmentCivic OfficesLimerick RoadNenaghCo. Tipperary18

of August 2010Dear Sir/Madam,

RE:12 No. SINGLE STOREY HOUSES, NEW ENTRANCE AND INTERNALROADWAYS, STORM WATER ATTENUATION SYSTEM, CONNECTION TOFOUL SEWER, LANDSCAPING AND ALL ASSOCIATES SITE WORKS.PHASE 1 OF THREE PHASE DEVELOPMENT @ BALLYCRAGAN, PUCKANE,NENAGH, CO. TIPPERARY REGISTER REFERENCE: 105103281.0I

NTRODUCTION

On behalf of our clients, Bernie Craughan, Puckane Development Association(“the Boreen” Puckane, Nenagh, County Tipperary ) we hereby lodge a third partysubmission 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.

2.0G

ROUNDS

BJECTION

We have perused in detail the plans and particulars submitted in support of thisplanning application and we submit to the Planning Authority that a number of important issues have not been adequately addressed by the applicant, theseinclude:



The adverse cumulative impact of the overall development of the subjectlands has not been assessed;



The proposed development does noty comply with Smarter Travel: ASustainable Transport Future – A New Transport Policy for Ireland 2009 - 2020



Non-Compliance with the Masterplan 3 of the Western Area Local AreaPlan;



Inadequate regard to the Puckane Village Design Statement.



The capacity constraints of service infrastructure within Puckane village toaccommodate the proposed development is inadequate.



Lack of pedestrian links between the subject site and the village centre.



Traffic Impacts & Road Safety

Having regard to the above and the applicant’s failure to address the abovementioned issues, we respectfully submit that this planning application should berefused.

Cumulative Impact

We respectfully submit to the Planning Authority that the indirect and cumulativeimpact of wider development within the site has not been assessed with respect tosuch issues as traffic impact, flooding, foul effluent and community and socialinfrastructure provision.It is stated by the applicant that the proposed development is Phase 1 of an overallthree phase development. However there are insufficient details provided within theplanning documentation submitted as to what the future additional phases of development will include. Accordingly, the cumulative impacts of the developmentof the subject site cannot be assessed. We therefore submit that this planningapplication represents project splitting and should be refused.National planning policy, including the National Spatial Strategy, Guidelines forSustainable Residential Development in Urban Areas and the Development PlanGuidelines require that the urban extension of established settlements should takeplace in a coherently planned and sequential manner. The proposed developmentdoes not accord with this principle and will result in piecemeal and uncoordinateddevelopment and the inefficient provision of infrastructure.Sustainable Planning & Travel The planning authority will be aware of the major oversupply of zoned land andhousing nationally together with Government policy as articulated in the NationalSpatial Strategy and the Regional Planning Guidelines for the Mid-West Region tofocus new residential development in larger urban centres and servicedsettlements. Owing to the severe economic downturn brought about substantiallyby major regulatory weaknesses in our planning system and property developmentsector, national planning policy and legislation together with transport policy hasmoved on markedly in the intervening period since these lands were speculativelyzoned for development. The planning authority will be aware that the Planning &Development (Amendment) Act 2010 is now law and that within one-year aVariation of the North Tipperary County Development Plan will be required toaddress the oversupply of zoned land in inappropriate locations. The proposed development is entirely car dependent and as a consequencecontravenes Government’s current transport policy – Smarter Travel: A Sustainable Transport Future. We would respectfully refer the Planning Authority to a recentlandmark decision by An Bord Pleanala with respect to a proposed phasedresidential development in Dunmore East, County Waterford (

PL 24.234725).In deciding to refuse planning permission the Board noted:

•

The Board considered that the expansion of the town of Dunmore Eastshould be planned in tandem with the provision of the services and

infrastructure necessary to sustain new development and that theprovision of individual waste water systems to facilitate individual housingschemes was neither an economical nor environmentally sustainableapproach.

•

Having regard to the scale of the proposed development (Phase 1 of amuch larger development) in relation to the town of Dunmore East, itappears to the Board that the development is, to a substantial degree,aimed at attracting commuters, rather than responding to likely localneeds. The proposed development would, therefore, promote anunsustainable development pattern contrary to the National SpatialStrategy and other general policies of the Government in relation tosustainable development.

•

Also the Board considered that the lay-out and design of the proposeddevelopment was generally of a suburban character and likely to detractfrom the distinctive character of the town.

Non-Compliance with Masterplan (MP) 3

The Puckane settlement plan included within the Western Area Local Area Planprovides 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 follows1.To provide 20% serviced sites as part of low density housing. Housingshall be single storey to protect views to and from the lake.2.To provide an internal access road via the open space/amenity areaand reserve an access to the rear of the GAA pitch to link with thetennis courts; the open space shall be provided as part of the overallmaster plan and as a community benefit.3.To provide an open space/park as part of the development;4.The overall layout housing to be designed to Arcadian principles, suchthat all boundaries forward of the dwellings shall be soft landscapingand not concrete walls, with internal roads designed to be rural incharacter.5.To provide road widening, footpath and public lighting along theDromineer Road to link to the village centre”

Also within the specific objectives of the Puckane settlement Plan, the followingitems are listed:1.“To provide and improve roads, footpaths, traffic calming, publiclighting and signage within the village as finances allow and asdevelopments take place. To provide new and improved footpaths onthe Urra Road from the Cuan Deirg housing to the junction with theR493. To extend this footpath to Killdangan GAA club and Ballycragganas part of new development along the Urra Road. Development onsites MP1 and MP3 will be required to make a special contribution tothis required infrastructure”