Kilkenny City and County Draft Development Plan 2021-2027
To whom it may concern,
With regard to the Kilkenny City and County Draft Development Plan 2021 – 2027, we wish to tender our concerns and objections regarding certain items contained in the draft plan.
The main cause of our concern is the change from the current designated low-density housing development for Rath Ullórd contained in the existing Kilkenny City and Environs Development Plan 2014-2020, to a higher-density residential housing development in the Draft Plan.
The main points for consideration are as follows:
Rath Ullórd is located at the outer urban edge of Kilkenny City and presents as an attractive low density residential area adjoining the outer boundary of the City (N77 Ring Road) and alongside extensive rural lands to the North East and the Kilkenny Golf Club amenity to the North West.
- Section 6.5 of the Draft Plan (Housing Strategy) supports low density residential uses: 'Although not precluded but discouraged from central areas, lower density three to four bedroom semi-detached and detached family homes are best suited towards the urban periphery...It is important that private households are able to find a range of opportunities to express their lifestyle needs through housing within the City's boundaries and town and villages and not only through one-off rural houses'.
- A number of planning permissions exist which seek the consolidated development of a predominately low-density landholding. A change to permissible densities via the new proposed land-use zoning objective will undermine this overall plan for the site through subsequent applications for high density development.
The dilution of an established low density residential estate will not accord with the following provisions of the Draft Plan:
- Section 13 of the Draft Plan strategic aim: 'to conserve and build upon positive elements in the built and natural environment, and to protect amenities'
Section 13.3 – The Council seeks to:
- 'ensure that all new developments enrich the quality of its surroundings which means encouraging a distinctive response which complements the setting...Creating a distinctive sense of place, taking into account site history and setting, is important.'
The current development is not suitable for higher residential density given the relative distance to the City Centre and lack of significant public transport investment.:
- There is no frequent public transport directly from Rath Ullórd to the City Centre which would be required to support a higher population density.
- Rath Ullórd remains outside the '10 minute' walkable City and is thus not suitable for high density of development.
- National Guidance remains that residential development should be planned and provided in close proximity to the main employment generators where possible with some low-density residential land required to meet latent demand for larger development sites within the City.
As residents of Rath Ullord, we invested heavily in our property for the simple reason that it was marketed as a low-density housing development, and we are very concerned that the proposed Draft Plan will now designate the land-use within the estate for a higher-density housing/residential scheme. We feel that the proposed re-zoning directly contravenes Section 6.5 in that it does not provide private households with ‘the range of opportunities to express their lifestyle needs through housing within the City's boundaries’, thus contravening what the Draft Plan is trying to achieve.
In addition, there are no major employment sources at this side of the City and with the absence of investment in public transport, this will result in a substantial increase in traffic volumes using the existing roadways and Ring-road (N77) to access other areas of the City to get to work, local amenities etc…
We are not against further development of the area and we are cognisant of the current housing crisis, however, Kilkenny is currently able to meet its housing demands with planned developments in the Abbey Quarter, Breagagh, Loughmakask etc without having to develop high-density residential developments at Rath Ullórd. We are of the opinion that given the above-mentioned concerns, the use of the available lands within the development could be better used to improve the living conditions for all existing residents, not only those of Rath Ullórd but also of the adjacent estates of Ashfield, The Orchard and others, in that a retail/commercial usage would benefit the entire community much better and provide a solution to the “10-minute” walkable City whilst maintaining the existing low-density designation. This would be particularly advantageous given that there is no public transport route at this side of the City. With high-density developments already planned for other parts of the City we feel that changing the land-use designation in Rath Ullórd only adds to the amount of high-density developments in the City and has no real advantage for the inhabitants of the City in that it gives individuals no option to buy properties in a low-density scheme.
We hope you consider our concerns and recommendations, and we are available to discuss our concerns with you at your convenience.
Padraic and Yvonne Treacy
47 Rose Drive,