Dear Sir/Madam
RE: KILKENNY COUNTY DEVELOPMENT PLAN 2020 - 2026
PRE-DRAFT ISSUES PAPER CONSULATION: SUBMISSION
SLR Consulting Ireland acts as planning and environmental advisors to Roadstone Limited, Fortunestown, Dublin 24.
Roadstone has a number of landholdings in County Kilkenny, namely:
• Bennettsbridge, in the townland of Dunbell Big;
• Kilmacow, in the townlands of Granny and Aglish North;
• Grannagh, in the townland of Granny;
• Greywood, in the townlands of Castlegannon and Kilkeasy.
This submission relates to the pre-draft issues paper of the Kilkenny County Development Plan 2020 – 2026.
BASIS OF THIS SUBMISSION
Importance of the Extractive Industries
The importance of the extractive industries to the wider economy and the need to protect the operations of working quarries and proven aggregate resources is firmly established in regional planning policy.
Section 4.5.4 of the Regional Planning Guidelines for the South-East Region 2010 – 2020 states that mineral exploitation is necessary for economic development and states that planning authorities should have regard to social and environmental impacts and to the need to safeguard deposits.
Planning authorities should also have regard to the Department of Environment, Heritage and Local Government guidelines. The relevant objective states:
“PPO 4.5 Planning Authorities should adopt policies to facilitate the economic exploitation of mineral and aggregate deposits, having regard to the environmental and social impact of such operations and to any affected public rights of way and traditional walking routes. Planning authorities are encouraged to adopt appropriate policies to safeguard viable unworked deposits for future extraction”.
The text also states:
“It is also important that housing in rural areas should not impede rural enterprise, e.g. mineral extraction or quarrying activity”. The extractive industry provides the necessary raw materials for the majority of building and infrastructure development in Ireland. Roads, motorways, homes, schools, hospitals, colleges,
factories, water and sewerage systems are all constructed with construction aggregates and concrete products. The construction of power stations, railways, wastewater and water treatment plants and sporting stadia is heavily dependent on the supply of crushed stone, concrete and other building materials made from aggregates.
Aggregate extraction can only take place where suitable aggregate resources exist; they are a ‘tied’ resource. It is considered, therefore, that planning policies should be carefully constructed to avoid adverse effects on aggregate resources and the related extractive industries and added-value production that are essential for our built environment, infrastructure and future economic development.
Current Development Plan Policies
The Importance of Extractive Industries
The current development plan provides a relatively balanced approach to facilitating extractive industries and protecting the environment from significant adverse effects, as per the following text:
“There are numerous sand and gravel and stone resources within the County currently in operation. The Council recognises the importance of extractive industries to the local and national economy as valuable sources of raw material for industry in general and the construction industry in particular and as an important source of employment. However the industry can have serious detrimental impacts on the landscape and amenities generally, including traffic generation, vibration, dust, noise, water pollution and visual intrusion.”
Like many forms of development, extractive industries have the potential to cause harm to the environment, heritage and the landscape if not appropriately designed and managed. However, aggregates are a necessary resource and are of great importance to the economy and society. In addition, well managed and designed quarry sites minimise environmental effects. There is also the potential for habitat creation and increased biodiversity through the restoration of quarry sites following the cessation of operations. Given that it is not generally viable to transport aggregates over long distances, each county and
region, including Kilkenny, should have its own sources of aggregates in order to achieve many of the housing, development and infrastructure projects that will be envisaged in the draft development plan.
Archaeological Heritage
The development management standards in relation to archaeological heritage (section 8.3.1) refer to the preservation of recorded monuments and previously unknown archaeological heritage in situ. It should that it is not always possible to preserve archaeological heritage in situ and that preservation by record is also identified as appropriate under the relevant guidelines. The current county development plan refers to the ICF’s archaeological code of practice3. This should
also be incorporated into the draft county development plan.
Proposed Policies
In order to ensure that existing and any future proposed extractive industry schemes are feasible under the development plan for the period 2020 - 2026, we recommend that the forthcoming draft development plan refers to:
i. The important role of the extractive industry in providing the construction materials for the delivery of infrastructure, housing and other social and economic benefits.
ii. The importance of avoiding the sterilisation of important aggregate/mineral reserves by inappropriate development in or adjacent to the relevant sites.
iii. The potential for quarries and pits to deliver environmental benefits in the form of habitat creation and increased biodiversity.
iv. Securing of long-term future supply of aggregates and value-added products including concrete products, blacktop etc.
In addition, it is recommended that the following polices, or similar, should be included:
To support the necessary and important role of the extractive industries in the delivery of building materials for infrastructural and other development and to recognise the need to develop extractive industries for the benefit of society and the economy.
and
To secure the long-term supply of value-added products (such as concrete products and asphalt) within the county, which are often, but not always, produced in conjunction with aggregate extraction.
CONCLUSION
The extractive industry provides essential construction materials for residential development, infrastructure, health care facilities, education facilities and all other forms of built development. Extraction can only take place where resources occur and it is, therefore, tied to certain locations. Aggregate extraction, without the implementation of appropriate mitigation measures, has the potential to cause adverse effects on the environment, visual amenity and residential amenity. These effects can be mitigated during the operational and restoration phases of extraction. It is considered that the economic and social benefits of aggregate extraction, a long-term secure supply of aggregates and valued added products should be balanced carefully against the potential for
environmental and other effects.
The forthcoming draft county development plan should ensure that the extraction of aggregates can take place in suitable locations where resources exist without undue environmental effects. It is important to ensure that the future interpretation of county development plan policies does not result in the sterilisation of aggregate resources and does not prevent the secure, long-term supply of construction aggregates and value-added products such as concrete blocks and road making materials.
Through this submission, Roadstone requests that the considerations set out in this submission are incorporated into the forthcoming draft development plan.
We trust this is in order; should you require any further information, please do not hesitate to contact the undersigned.
Yours sincerely
SLR Consulting Ireland