Senior Planner,
Kilkenny County Council,
John Street,
Kilkenny.
By e-mail: ourplan@kilkennycoco.ie
27th June 2025

Re: Proposed Variation No.5 to the Kilkenny City & County Development Plan 2021 - 2027

Dear Sir/Madam,
The National Transport Authority (‘the NTA’) has reviewed Proposed Variation no.5 of the Kilkenny City & County Development Plan 2021-2027 (CCDP). Based on its role as the body responsible for public transport service planning and for funding of the national active travel programme, the NTA wishes to submit the following observations and recommendations for the consideration of the planning authority.

Volume 1 County
Section 12.5 Cycling and Walking
The NTA notes the proposed revision to Section 12.5, Sub-section v, regarding cycle parking for residential/commercial or mixed-use developments, which would be amended to include the following statement:
‘For any new housing schemes, cycle storage facilities should be provided in a dedicated facility of permanent construction, within the building footprint or, where not feasible, within an adjacent or adjoining purpose-built structure of permanent construction. Cycle parking areas shall be designed so that cyclists feel safe. It is best practice that either secure cycle cage/compound or preferably locker facilities are provided.’
While the NTA would be supportive of this amendment as it relates to apartment or other multi-unit developments, including e.g. compact terraced housing without external access to rear gardens, such a requirement may not be appropriate in the case of residential developments comprising detached or semi-detached houses only. Where such dwellings are provided with accessible private open space, dedicated, stand-alone cycle parking facilities may be less attractive to users than the option of in-curtilage cycle parking, and the space that would have been required for such facilities would then be available as public open space within the development.

Recommendation:
The NTA recommends that this proposed amendment would merit further consideration, to distinguish between multi-unit developments where such facilities would be required, and more traditional housing development types with capacity for cycle parking/storage within the curtilage of each unit.

Volume 3 Settlement Plans
The NTA is supportive of the preparation of a Settlement Plan for Castlecomer, to ensure that the development of the town occurs in a sustainable manner and in accordance with the provisions of the Sustainable Residential Development and Compact Settlements Guidelines for Planning Authorities (DHLGH, 2024). The NTA also notes and is supportive of the preparation of the Transport Assessment in support of the Castlecomer Settlement Plan, which was based on the Area Based Transport Assessment (ABTA) methodology published by the NTA and Transport Infrastructure Ireland, and which provided the basis for the Movement and Mobility objectives set out in the draft Castlecomer Settlement Plan.

Section 1.11 Movement and Mobility
This Section of the draft Settlement Plan states that ‘The transport and land use policy for the Plan is to promote modal shift away from the car, by appropriate zoning and by increasing permeability for pedestrians and cyclists, with a particular focus on access to schools.’ The NTA is supportive of this overarching policy and notes the range of measures proposed to achieve this policy goal.

The presence of a national road, the N78, in the town presents a challenge to the delivery of in-line active travel measures owing to the requirement to protect the function of this road, which therefore requires the examination of off-line active travel interventions. The draft Settlement Plan proposes a number of measures in this regard.

To the east of Kilkenny Street at Key Site 5 along the River Dinin, Objective V3CC15 proposes ‘To explore all possible opportunities to increase permeability in this area, including access to the River Dinin to the rear of Kilkenny Street, and connecting through Mill Lane to High Street/The Square.’ Section 1.7.1 notes the importance of this route in providing improved pedestrian and cycle access to the school cluster at the Presentation Convent. However, Section 1.12.5 describes this link as ‘a walkway along the River Dinin’ and does not refer to cycling. The NTA recommends that the development of this route should provide for both walking and cycling, and that Objective V3CC15 should be revised to make reference to both modes.

To the west of Kilkenny Street, a number of discrete active travel measures are proposed in order to provide a continuous route for walking and cycling from Barrack Hill to Ballyhimmin. These include Objectives PC1, PC6, PC7, PC8, PC9 and PC10, and further objectives set out in Section 1.12 related to Key Site 2 The Barracks and Key Site 3 the Boys’ School. At Key Site 3, it is proposed to provide a connection to the Donaguile Heights open space, linking to the Community School, and a connection north-south through the site to improve overall permeability in the area. Given the extent of the Barracks lands, it is proposed to prepare a Masterplan for the full site (Objective V3CC13) which would include pedestrian and cyclist linkages through the site from Barrack Hill to Donaguile/Maryville and a link to Kilkenny Street.

The NTA is supportive of the objective to prepare a Masterplan for the Barracks site and of the discrete measures that would, in combination, provide a continuous north-south route for active travel to the west of Kilkenny Street. A critical element of active travel provision in this area would be the link to Kilkenny Street, given the presence of the school cluster at the Presentation Convent, but there would appear to be limited options for such a link owing to the continuous building line on the west side of Kilkenny Street. As a result, it may be necessary to provide a cycling connection along the N78 between the existing pedestrian crossing at the Convent and the link to Kilkenny Street proposed as part of the Barracks Masterplan, depending on where this link would emerge from the Masterplan lands. The NTA therefore recommends that an additional active travel measure is included in the list of Transport and Mobility Objectives addressing the requirement to connect the pedestrian crossing at the Convent to the Masterplan link to Kilkenny Street.

In addition, while the discrete objectives are included in Figure CC5 Transport Objectives as points, there may be merit in providing a graphical representation of the suite of Objectives west of Kilkenny Street, to illustrate the full continuous route from Barrack Hill to Ballyhimmin in linear form.

Recommendations:
For the lands east of Kilkenny Street, the NTA recommends that the development of the route along the River Dinin should provide for both walking and cycling, and that Objective V3CC15 should be revised to make reference to both modes.

For the lands west of Kilkenny Street, the NTA recommends that an additional Objective should be included, requiring the examination of a connection between the Presentation Convent pedestrian crossing and the proposed link from the Barracks Masterplan lands to Kilkenny Street. Furthermore, the NTA recommends consideration of a map illustrating the continuous north-south active travel route from Barrack Hill to Ballyhimmin.

Provision for Bus
While the draft Settlement Plan sets out a comprehensive suite of objectives related to active travel within the town, the NTA notes that no objectives regarding public transport are included in the draft Plan. The town is currently served by a number of bus routes with stops on Kilkenny Street and at The Square, and the NTA’s Connecting Ireland programme proposes to retain these services. Given the proposal to prepare a Public Realm Plan for the Square (Objective V3CC14) and the potential for changes to the cross section of Kilkenny Street/N78 to provide for active travel, the NTA recommends that the Settlement Plan should include an objective to ensure that adequate provision is made for public transport in the town. This would include the identification of stopping locations and the potential for shelters, in consultation with the NTA.

Recommendation:

The NTA recommends that the finalised Settlement Plan should include an objective to ensure that bus is provided for adequately in the town, and to engage with the NTA in the event that new or revised bus stops and/or shelters would be considered.

I trust that the views of the NTA will be taken into account in the consideration of the proposed Variation to the City & County Development Plan.
Yours sincerely,

Michael MacAree
Head of Strategic Planning

Proposed Variation 5 to the Kilkenny City and County Development Plan - Castlecomer Settlement Plan - Submissions

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