Southern Regional Assembly Assembly House O'connell Street Waterford X91 K256

Southern Regional Assembly Assembly House O'Connell Street Waterford X91 K256

Date: March 8th, 2019

Ref No: Ref No: 2.2.23.003

Dear Sir/Madam,

RE: SUBMISSION TO THE DRAFT SOUTHERN REGIONAL SPATIAL AND ECONOMIC STRATEGY.

Cork Airport welcomes publication of the Draft Southern Regional Spatial and Economic Strategy (‘Draft SRSES’) by the Southern Regional Assembly (‘SRA’). The draft document represents a robust response to the requirement for a regional level strategic planning document. On adoption, it will provide a positive framework to foster economic prosperity and drive regional growth.

Cork Airport welcomes this opportunity to provide further comment to shape the final strategy. By way of context, Cork Airport requested the following recommendations be considered in the preceding pre-draft submission:

• Support for strong growth in movements and connectivity at Cork Airport • Support for the required infrastructure to facilitate this growth, particularly in terms of surface access and public transport to Cork Airport • Land use planning which provides the appropriate framework to manage safeguarding zones around Cork Airport and the communities that it serves; • Support full alignment between employment and population growth through the strategic designation of key employment sites, such as that available at Cork Airport.

The Draft SRSES addressed and acknowledged these considerations and in so doing, will provide a positive planning policy platform on which Cork Airport can

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continue to grow to meet the needs of the regional population in terms of international connectivity and as an economic enabler.

The following submission is made with the intention of highlighting some suggested additions to the text to expand on the draft policies. Notwithstanding suggestions made herein, we acknowledge the recognition given by the Draft Southern RSES to the important role of Cork Airport, and we consider the proposed regional policies will provide a positive framework for Cork Airport to continue in that role.

RECOMMENDATIONS FOR THE FINAL SOUTHERN RSES

The following recommendations are made using the existing text within the Draft SRSES to form the basis of the suggested changes. Suggested changes are colour coded to indicate:

• Existing Text: Italic typeface • Insertions: Green bold italics • Omissions: Red strikethrough italics • Relocation: Blue Bold italics

Recommendations are made in the order in which the text appears in the Draft Southern RSES and are not presented in any order of priority.

RECOMMENDATION 1: SURFACE ACCESS AND INTERNATIONAL CONNECTIVITY.

Section 6.3.4 of the Draft SRSES provides direction in respect of airport growth and international connectivity, setting key planning policies for the future development of the national and regional airports within the Southern Region.

Surface access to Cork Airport is exceptionally important to ensure passengers can access the airport on a high-quality road or public transport network, as well as accessing the surrounding region from the airport on arrival. This is captured in policy objectives on National Aviation Policy1, on High Quality International Connectivity for Airports2 and is further reinforced in the Cork Metropolitan Area Plan (MASP) Policy Objective 9, which seeks the delivery of improved connectivity from Cork City to Cork Airport.

Recognising that international connectivity extends beyond the boundaries of any particular region, this policy objective could be further developed to include the need for expanding airport facilities to provide the operational efficiencies and service required for airlines to expand their fleets, increase the range of

1 RPO 143(b) (page148) 2 RPO 145(a) (page 149)

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destinations to which they will travel from Cork Airport or increase the frequency of existing successful air routes.

International connectivity is a driver of economic, social and tourism growth and fostering this connectivity, as the National Aviation Policy (NAP) for Ireland requires, necessitates an increase in aircraft movements and passengers to support these routes. Facilities that will support the competitiveness and appeal of Cork Airport for airline operators and passengers will assist in achieving this policy objective. Strengthening Policy RPO 145 to include support for growth of air traffic movements and passengers will expand on the policy position of the NAP and will translate this national policy objective to a regional context. We ask that a separate safeguarding policy objective is created providing further clarity on the assessment of development proposals located within the Airport safeguarding zones.

Suggested Amendment: High Quality Connectivity - Airports RPO 145: To achieve NSO: High Quality International Connectivity, the following airport development actions for the Region are identified subject to required appraisal, planning and environmental assessment processes:

a. Continued development and improvement of employment and economic activity, enterprise assets, access infrastructure, airport infrastructure and services at Cork and Shannon Airports by the relevant responsible commercial State-Owned Enterprises as key economic drivers, national tourism and national business gateways consistent with sectoral priorities defined through National Aviation Policy;

b. Continued support for improved international connectivity through p149 the growth of air traffic movements and passengers at Cork Airport. This will necessitate the development and expansion of the aviation infrastructure at Cork Airport and the safeguarding of the necessary surrounding lands particularly from proximate housing development to achieve this.

c. Continued exchequer support for smaller regional airports under the Regional Airports Programme for Waterford and Kerry Airports and develop their potential as key tourism and business gateways for their regions as a complement to the services provided by the region’s national airport gateways of Cork and Shannon.

Given the importance of safeguarding to the operation of Cork Airport, we ask that a separate safeguarding policy objective is created providing further clarity on the assessment of development proposals located within the Airport safeguarding zones.

Suggested Amendment: MASP POLICY OBJECTIVE 14 Ref page Support the sustainable development of the airport and seek investment in infrastructure and facilities that promote the role of Cork Airport as an p295 international gateway, employment location and economic driver for the region

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including the following subject to the outcome of required feasibility, assessment and environmental processes:

• Support the sustainable development and investment in infrastructure and facilities under the Cork Airport Masterplan. • Support the sustainable development of enhanced public transport connectivity to the airport including the provision of bus priority lanes on the N27 and an improvement in the alignment of the R600 south of the Airport. • Safeguard Public Safety Zones by way of land use planning under the relevant County Development Plan and Local Area Plans. Airport safeguarding priorities required include: °° Airport Noise Zones (Inner and Outer Zones). °° Airport Public Safety Zones °° General Airport Safeguarding [Relocate safeguarding policy]

Development Plans should incorporate policies to control inappropriate development which could adversely impact the potential for growth in either airport infrastructure or expansion of routes to international destinations.

RECOMMENDATION 2: SAFEGUARDING ZONES AROUND CORK AIRPORT

Firstly, Cork Airport recognise and welcome that the Draft SRSES has reflected our recommendations in terms of airport safeguarding to support the safe and effective operation of Cork Airport. Having taken on board the pre-draft submission by Cork Airport, we would be grateful if further clarification could be provided in a separate Cork MASP Policy Objective in respect of the existing safeguarding zones to reinforce and clarify the importance of public safety zones, noise zones and general safeguarding zones around Cork Airport.

In the pre-draft submission, the following policies were recommended for inclusion in the SRSES to support the continued safe and effective operation of Cork Airport. The strengthening of the policy objectives below will underline their importance and will provide a consistent approach to airport safeguarding by the relevant regional spatial and economic strategies. This will play a key role in guiding this spatial policy and importantly, will streamline safeguarding policy approach across administrative boundaries.

Suggested Amendments: MASP POLICY OBJECTIVE 14(b) Ref page • Safeguard the operation of Cork Airport Public Safety Zones by way of land use planning under the relevant County Development Plan and Local Area Plans. Airport safeguarding priorities required include:

°° Airport Noise Zones (Inner and Outer Zones). Spatial planning policies in the vicinity of the airport shall recognise and p295 reflect the noise zones associated with Cork Airport. In particular within the Inner Airport Noise Zone provision of new residential and/or other noise sensitive development shall be actively resisted. Within the Outer Noise Zone provision of new residential and/or other noise sensitive development shall be strictly controlled such that future airport expansion on a 24/7 basis is anticipated and planned.

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°° Airport Public Safety Zones In assessing applications for development falling within Public Safety Zones, regard shall be had to the recommendations of the ERM Report “Public Safety Zones, 2005” (or any update thereof) commissioned by the Department of Transport and the Department of Environment, Heritage and Local Government, in assessing proposals for development falling within Airport Public Safety Zones.

°° General Airport Safeguarding In assessing applications for development within the vicinity of Cork Airport, regard will be had to the precautionary principle concerning potential risk to aircraft safety. This includes avoidance of: any bird attracting feature or use; unacceptable glint and glare impact towards key airport infrastructure; or intrusion into/infringing of airspace which might create an obstacle or danger to aircraft in flight.

Airport Noise Zones are areas around airports most susceptible to aircraft noise. Careful land use planning can avoid the location of noise sensitive uses within these zones, or, where appropriate, can require noise attenuation to mitigate the negative effects. Including this policy in the SRSES will pre-empt unacceptable aviation noise impacts on newly planned communities and other noise sensitive uses.

Public Safety Zones (‘PSZs’) represent areas around an airport where risk of an aircraft crash is highest. The Inner PSZ represents the higher risk, lying closest to the airport, with less risk being associated with the Outer PSZs. They indicate areas where population density should be minimised in the interests of public safety. Through appropriate spatial policy, the SRSES can direct higher-density developments away from Public Safety Zones, where probability of accidents is highest.

Good land use management practices should also be implemented to facilitate the safe operation of aircraft in flight on approach to and also departing from the airport.

SUMMARY AND CONCLUSION

The strategic importance of Cork Airport, the growth of which is critically linked with the Irish economy, is well represented within the Draft SRSES. Furthermore, it provides a strong framework for land use policies guiding development in the vicinity of the airport. This will ensure continued safety and security of aircraft in flight and the continued expansion in accordance with the anticipated population growth of the region under Project Ireland 2040. Cork Airport welcomes and fully support the effort which has been made to protect and build on the State’s second largest airport, which has potential to provide a world-class gateway that allows the region to compete globally for new routes and connectivity. It is critical that the importance of Cork Airport in supporting the growth of the Cork Region is underpinned in the final Southern RSES.

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This submission principally aims to secure the future growth of Cork Airport on a 24/7 basis through the mechanism of the RSES. Growth in passenger numbers and air traffic movements is critical to achieve international connectivity as envisaged in the NPF, and in this respect, the above proposed amendments will provide a platform for an airport of greater scale. Expanding routes and movements will provide social and cultural links, foster economic growth, improve accessibility for inbound tourism, and, critically, increase the attractiveness of the region and country to international businesses looking to invest.

I would welcome any opportunity to present the recommendations made in this submission to you by way of a meeting or through further discussions. Should you require any further information on any aspect of this submission, please do not hesitate to contact me.

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Appendix 1: Summary Table of Recommended Draft SRSES Amendments

SRSES Recommendations Ref page

RECOMMENDATION 1: SURFACE ACCESS AND INTERNATIONAL CONNECTIVITY.

High Quality Connectivity – Airports RPO 145: To achieve NSO: High Quality International Connectivity, the following airport development actions for the Region are identified subject to required appraisal, planning and environmental assessment processes:

b. Continued support for improved international connectivity through the growth of air traffic movements and passengers at Cork Airport. This will necessitate the development and expansion of the aviation infrastructure at Cork Airport and the safeguarding of the necessary surrounding lands particularly from proximate housing development to achieve this.

RECOMMENDATION 2:

MASP Policy Objective 14: Support the sustainable development of the airport and seek investment in infrastructure and facilities that promote the role of Cork Airport as an international gateway, employment location and economic driver for the region including the following subject to the outcome of required feasibility, assessment and environmental processes:

• Support the sustainable development and investment in infrastructure and facilities under the Cork Airport Masterplan. • Support the sustainable development of enhanced public transport connectivity to the airport including the provision of bus priority lanes on the N27 and an improvement in the alignment of the R600 south of the Airport. p295 • Safeguard Public Safety Zones by way of land use planning under the relevant County Development Plan and Local Area Plans. Airport safeguarding priorities required include: °° Airport Noise Zones (Inner and Outer Zones). °° Airport Public Safety Zones °° General Airport Safeguarding

• Development Plans should incorporate policies to control inappropriate development which could adversely impact the potential for growth in either airport infrastructure or expansion of routes to international destinations.

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RECOMMENDATION 3: SAFEGUARDING ZONES AROUND CORK AIRPORT • Safeguard the operation of Cork Airport Public Safety Zones by way of land use planning under the relevant County Development Plan and Local Area Plans. Airport safeguarding priorities required include:

°° Airport Noise Zones (Inner and Outer Zones). Spatial planning policies in the vicinity of the airport shall recognise and reflect the noise zones associated with Cork Airport. In particular within the Inner Airport Noise Zone provision of new residential and/or other noise sensitive development shall be actively resisted. Within the Outer Noise Zone provision of new residential and/or other noise sensitive development shall be strictly controlled such that future airport expansion on a 24/7 basis is anticipated and planned.

°° General Airport Safeguarding p295 In assessing applications for development within the vicinity of Cork Airport, regard will be had to the precautionary principle concerning potential risk to aircraft safety. This includes avoidance of: any bird attracting feature or use; unacceptable glint and glare impact towards key airport infrastructure; or intrusion into/infringing of airspace which might create an obstacle or danger to aircraft in flight.

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