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Brady Hughes Consulting, 26 Magdalene Street, Drogheda, Co

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Brady Hughes Consulting, 26 Magdalene Street, Drogheda, Co Frank Pentony Director of Services Development Plan Review Forward Planning Unit Louth County Council Town Hall, Crowe Street, Dundalk, Co Louth. A91 W20C 25th November 2019 RE: Louth County Development Plan Review Submission on behalf of Gerry Kelly and Maire Milner Dear Sir/Madam, With reference to the above, and further to your invitation to the public to make submissions in respect of the making of a new development plan for County Louth, please note that we have been appointed by Gerry Kelly and Maire Milner to make this submission on their behalf. Please find attached contact details for our client separately as directed. Background Our clients live in Clogherhead, and they are active members of the community there. In the past year Louth County Council, with a local community organisation as a co-sponsor have attempted to secure funding for a public walkway and cycleway across and through my clients lands. The effect of this would have been to annex the summit and a sizeable portion of land. Our clients have a keen interest in the preservation of the Headland of Clogherhead for future generations, and in the responsible planning and development of the area. The Headland is a unique and unspoilt area with a timeless and peaceful quality, associated with a fragile habitat designated for the highest level of conservation. The beauty and timelessness of the Headland is renowned: this balance is vulnerable and if upset would be lost for ever. Key Issues On behalf of our client, we would respectfully suggest that Louth Co Co liaise with the local landowners and members of the community and develop a set of objectives and policies in relation to Clogherhead, Village, Beach, Pier and surrounding area that, along with usual planning considerations takes account of the following matters: • Land ownership, and property rights • Protection of the SAC and SPA • Protection of ecology and habitats • Health and safety of walkers and users of any amenities to be provided. Brady Hughes Consulting, 26 Magdalene Street, Drogheda, Co. Louth 041 9839379, [email protected] • Responsibility for Public Liability on private lands • How the development of amenities at Clogherhead link to a county and regional strategy. National and Regional Policy The National Planning Framework (NPF), Ireland 2040 has a number of policies and objectives relevant to Clogherhead. Drogheda’s new position as a Regional Growth Centre with targeted city status by 2031 will result in significant population growth targeted nearby. There will likely be spill over into smaller satellite settlements like Clogherhead and demand for the amenities provided by a settlement like Clogherhead will increase as population locally rises. The NPF promotes developing a ‘ more integrated network of greenways, blueways and peatways to support the diversification of rural and regional economies and promote more sustainable forms of travel and activity-based recreation’ . National Policy Objective 22 relates. The NPF acknowledges that ‘ the support and buy-in of local communities, landowners, local authorities and State Agencies is critical to successful implementation’. An investment and co- ordination plan is required to deliver an integrated network of ‘ways’, and to deliver a National Strategy as per NPO22. National Policy Objective 46 is also relevant: National Strategic Outcome 3 on Page 141 acknowledges that a strong start has been made in the development of a national greenway network. The network, including rural walking ways have shown potential to bring new life and business to rural areas and this can be a ‘win-win’ scenario with increased tourism and healthier travel. Regional Spatial and Economic Strategy (RSES) for East Midlands Region also supports the role that greenways can play as Growth enablers. There are numerous references in the RSES document to greenways and almost all of them reference ‘an integrated network of Greenways’. Example excerpt below Brady Hughes Consulting, 26 Magdalene Street, Drogheda, Co. Louth 041 9839379, [email protected] Current Development Plan Policy The current C.D.P. says in its vision statement at Section 1.3 that Clogherhead is a substantial town/village grouped with Ardee, Dunleer and Carlingford. The settlement strategy hierarchy defines it as a Level 3 Settlement, along with Carlingford and below tier 2 settlements of Dunleer and Ardee. Drogheda and Dundalk share top spot as Large Growth Towns. The land use zoning map includes the Headland and the connection of the village to the pier. Section 2.11.1 states that Clogherhead is suitable for ‘small scale business and enterprise’ and notes that land for employment uses has been identified (coloured pink on map above). Policy CS6 actively seek to promote the attraction of economic activity to Clogherhead in a rather general way. Section 3.5.1 is relevant w.r.t. coastal areas, and the SAC and SPAs. – Brady Hughes Consulting, 26 Magdalene Street, Drogheda, Co. Louth 041 9839379, [email protected] Table 5.1 lists the SAC at Clogherhead and Table 5.3 referenced the Natural Heritage area. Table 5.13 references the fact that Clogherhead is an area of outstanding natural beauty – see except from pg. 174 below. Suffice to say, Clogherhead is very important from a Heritage (natural & Built) perspective Please note too that Heritage Policy 69 says that all coastal walkways should comply with Habitats, SEA and all EIA Directives There’s a scenic route and a number of scenic viewpoints identified in the CDP too. Chapter 6 of the CDP relates to Economic Development, Tourism and Retail. The very first paragraph of the chapter references the fact that ‘ The existing fishing port of Clogherhead is also of national importance’. A number of economic development policies relate to the provision of walkways and cycleways: Brady Hughes Consulting, 26 Magdalene Street, Drogheda, Co. Louth 041 9839379, [email protected] Chapter 7 on transport, includes a specific objective relating to expansion of the ports in the county including Clogherhead, and references the preparation of a masterplan and compliance with relevant SEA and Habitats directives. I am not aware of any such masterplan having been prepared for the port of Clogherhead. Please also refer to Transport Policy 28: Appendix 2 Chapter 6 of the plan includes a written statement for Clogherhead. The first objective of that statement is CLOG1 – as follows: We note that there is an objective to improve pedestrian and cycling mobility through the village centre and that there is no such objective with respect to the headland. Rather, the following objectives are pertinent in this regard: Brady Hughes Consulting, 26 Magdalene Street, Drogheda, Co. Louth 041 9839379, [email protected] Discussion The Headland at Clogherhead has always been a destination rather than part of a journey. Currently the footfall through our clients’ lands approaches the outer limit of sustainability, and a regional greenway carrying all traffic would make for a huge increase which would threaten the habitat. In the last three years, the hare population has disappeared on the South side of the Headland, which our clients attribute to increased footfall and dogs, as hares survive on the North side. Consideration needs to be given to the management of greenway traffic in the area: our clients’ lands and the habitat therein will not survive if it is to be the sole conduit. Likewise, development of tourist facilities e.g. bus tours, or caravan park would represent major intensification of footfall over the SAC area. A cycleway is not possible over the Headland because of the steep terrain, and the traffic considerations above. There is no history of cycling over these lands. The way forward here is to consider the Headland & coastal path as a special ‘add-on’ or adjunct to a greenway. Walkers must have a number of options through and around the village to distribute the many-fold increase in footfall, and direct it away from the Headland. Cyclists must have the facility to leave their bicycles both at the beach and the harbour, if they wish to walk over the Headland. It is my understanding that no real progress has been made with respect to many of the aspirational development objectives in the current CDP. In particular, the masterplan referred to in TC 41, an integrated plan to deliver the Costal Walk referenced in TC28 or the Nature Reserve investigation at CLOG 7. Our clients support the objective set out in Clog 1 which recognises the importance of its natural and built environment. Our clients support the objectives of the National and Regional policies to develop an ‘integrated network’ of greenways. However, the Headland & coastal path should be considered as an adjunct, whereby it is only one of a number of options for walkers, & footfall through the SAC is managed sustainably. They support the development of the coastal path as an adjunct, whereby it is only one of a number of options for walkers, and footfall through the SAC is managed sustainably. Our clients request that the new county development plan include a written statement for Clogherhead which develops and sets out a strategy for the economic development of the village that respects the natural heritage and the designated SAC. Implementation objectives should be included to ensure that any development of amenities or intensification of the use of the headland is subject to the appropriate public consultation, SEA, NIS, EIA and any other sustainability protections that can apply. Recent attempts to turn the informal walkways from the Beach to the Pier without due consideration should be resisted. Specific policy objectives should be put in place to protect the headland, flora and fauna, and the scenic quality, and to establish these protections as the key overriding policies that any such planned development must comply with. Brady Hughes Consulting, 26 Magdalene Street, Drogheda, Co.
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