Title of Report: Officer Presenting:

Item 9 - Consultation from County Senior Planning Officer Council on Draft Development Plan 2018-2024 & associated Environmental Report

1 Purpose of Report/Recommendations 1.1 The purpose of this Paper is to advise Members of a public consultation recently received from on the Draft County Donegal Development Plan 2018 – 2024 and associated Environmental Report. The consultation runs from 19th May to 31st July 2017.

2 Background 2.1 The consultation consists of three documents:

 Document 1-Part A: The Strategic Contents & Part B: Objectives and Policies of the Plan;  Document 2-Part C: Objectives and Policies of the Towns;  Document 3-Environmental Report (SEA & AA).

The documents can be viewed at: http://www.donegalcoco.ie/services/planning/developmentplansbuiltheritageincludinggrants/draft% 20county%20donegal%20development%20plan%202018-2024/

2.2 The purpose of the Draft County Donegal Development Plan 2018-2024 and Environmental Report is to set out a land use planning policy framework to guide the way in which County Donegal will be developed into the future. When adopted, it will be a material consideration in making decisions on planning applications. It is the first consolidated plan for the entire functional area of Donegal County Council, including the former Town Council areas of , and Bundoran. 2.3 The County Donegal Development Plan is the principal statutory land use plan for the County and it sets out a strategic vision for the future growth and development of the County over the 6 year life of the Plan (to 2024) and beyond to a 20 year timeframe (to 2038). This spatially-based strategic and framework seeks to manage and co-ordinate change in land-use in the County, setting out a clear view ahead in development terms together with clear priorities to drive growth. 2.4 The Vision of the draft plan states that by 2038, County Donegal will be a connected place with a strong, competitive and innovative economy that is attracting and sustaining a population of upwards of 200,000 people, offering a quality of life ranked highest in the country and asserting a key role in the context of the North West City Region and within the area of the Northern and Western Regional Assembly (NWRA). 2.5 The draft Plan acknowledges that within the wider context of the region, there are firmly established partnerships that are to be developed further in order to support a coordinated approach to deliver on regional priorities that are critical to facilitate the priorities of County Donegal. In the context of the North West City Region, this comprises all of Donegal County Council (DCC) and City & Strabane District Council (DCSDC) areas, with Letterkenny and the City of Derry-Londonderry as its linked metropolitan areas. This Initiative has secured the establishment of a local government partnership between DCC and DCSDC and has been endorsed by both local authorities and, significantly, by both of the respective national governments.

2.6 The draft Plan states that capacity in the Region is evidenced through both the regional response to consultation on the National Planning Framework coordinated through NWRA and the joint work of DCC and DCSDC which is underpinned by the establishment of the North West Strategic Growth Partnership. The County Development Plan therefore provides the statutory spatial planning framework for County Donegal within which the coordination and management of the North West City Region vision and their ambition as a County is expressed. 2.7 The Planning and Development Act 2010 requires that a Strategic Environmental Assessment (SEA), (pursuant to the SEA Directive) and an Appropriate Assessment (AA) (pursuant to the EU Habitats Directive) be carried out as part of the development plan process. Accordingly, the draft County Development Plan is also accompanied by an Environmental Report. It sets out how the SEA process was carried out for the review of the draft Plan, and includes a description of the current environment along with an assessment of the effects of implementing the policies and objectives of the Draft Plan, necessary changes and considerations and mitigation and monitoring proposals going forward. 2.8 The AA is a separate but parallel process that has overlapped significantly with the SEA process in the drafting of the new Development Plan, not least because of the large land area of the County covered by Natura 2000 sites. The AA specifically assesses the potential impact on Natura 2000 sites (and their conservation objectives) as a result of the implementation of the Plan based on the Natura Impact Report and other supplementary information; the ultimate aim being to avoid significant adverse impacts on these sites. The Natura Impact Report determined that there is no requirement to proceed to Stage 3 of the AA as there is no significant detrimental effect identified, as the result of implementation of the Plan, to the integrity of any European Site.

3 Key Issues Draft Co. Donegal Development Plan

3.1 Planning officials at Derry City and Strabane District Council (DCSDC) have reviewed all the necessary documents in relation to this public consultation. It is noted that the stated national economic context for the Development Plan is one of demonstrating a return to economic growth together with a period of uncertainty in the light of the UK decision to exit the EU. The draft Plan acknowledges the significant work that has been undertaken by both Councils to-date to consider the challenges and opportunities that are presented by Brexit, including the publication in February 2017 of a draft report entitled, ‘Initial Analysis of the Challengers and Opportunities of Brexit for the Derry City & Strabane and Donegal County Council areas - The North West City Region.’ 3.2 The draft Plan identifies that there may be opportunities for Donegal in terms of securing inward investment from firms wishing to have a presence within one of the only predominantly English-speaking countries within the EU, particularly those firms and businesses that are currently based in Northern . The geographical proximity of Donegal to the border with , the similarities in how business is conducted in both jurisdictions, the prime office rents available in the County and the fact that salary costs are lower than Dublin, London and much of Western Europe will, it is stated, position Donegal as a prime and convenient location for businesses wishing to avail of relocation opportunities 3.3 The draft Plan stresses that the outputs of this report demonstrate that there is an even greater imperative to ensure that key, regionally-significant growth priorities are realised such as the A5 and A6 roads projects. Strategically, the enabling role of the draft Development Plan in identifying, coordinating and prioritising critical infrastructural investment, together with appropriately guiding the location of economic development, is seen as a critical component of economic recovery in County Donegal. 3.4 DCSDC Planning officials note that the Plan highlights a role for settlements in driving significant economic development of the County by emphasising the importance of renewal and regeneration of County Donegal towns and villages where there are particular niche sectors, enterprise clusters or particular strengths, opportunities or assets that can be harnessed in a balanced manner. Furthermore, the Plan aims to strengthen rural communities by supporting agricultural- diversification, tourism and opportunities for rural economic development of an appropriate nature and scale, where local employment opportunities can be provided. 3.5 DCSDC Planning officials acknowledge the inclusion of a specific section within the draft Plan on the significant daily border movements that take place within the North West City region. When taken in the regional context of the area of the North West City region, the regional population comprises approximately 350,000 people. The movement, interactions and activities of this critical mass of population across and within both sides of the border are complex. A total of 326,577 journeys are made per week across the three major crossings at Derry/Bridgend, Derry/Muff and Strabane/. This evidences the high levels of cross border interactions that are occurring across the region in many areas of social and economic life. 3.6 From a Planning perspective, the following additional themes are also directly relevant to our District:

 3 Layers of Settlements:  Layer 1 – Letterkenny. As the largest town, it provides a broad range of services across the sectors including employment, education, health, cultural services, community services, entertainment and many more. Its growth and strengthening as a major centre of population together with its wider metropolitan area is important in the regional context particularly in terms of its relationship with Derry City. A strong, vibrant, connected Letterkenny with growing population will provide benefits across the County and within the region in terms attracting private sector investment in jobs and the economy and in securing investment in infrastructure that is critical to the County as a whole.  It is proposed that Letterkenny will have a large town centre, which will include the traditional centre based at Main St, the retail park at Port Road, the Letterkenny IT site and large areas of undeveloped to the north and south of the by-pass.  The Plan proposes that retail will be suitable within the town centre as well as employment uses such as commercial (described as non- industrial employment uses). To support the development of this site, there is a proposal for an urban development framework, which sets out a number of new urban blocks and streets. This land would be particularly attractive to office and high-tech uses and this would make Letterkenny more attractive to investors and of regional importance.  Layer 2a – Strategic Towns, due to their Housing Land Supply and Special Economic Function: Buncrana, / and Donegal Town are those most closely related to our District.  Layer 2b - Strategic Towns, due to their Special Economic Function: the closest being Bridgend and Lifford, as well as and several in north . Emphasis in Layer 2b is to enhance the environment for “economic activity and enable their growth. Whilst there is no detailed text in relation to land uses, etc. in the documents, there are a number of maps outlining proposed development limits, opportunity sites, etc. A proposed extension of Bridgend towards Derry is shown and it appears that this would be earmarked for economic uses. Lifford has a large ‘mixed use’ opportunity site to the north of the town, park land to the north east and a large unspecified site to the south west.  Layer 3 - Rural Towns and rural countryside: this layer includes Muff, Killea and approx. 9 other settlements that are close to this District. The Draft Plan suggests that these settlements are being relatively contained.

 Demographics – Growing the County:  Current 2016 population is 158, 755. Phase 1 2018-2024 providing for the growth rate of 1.1% annual increase to 2024 leading potentially to population reaching 173, 000. Phase 2 2024-2038 providing for the growth rate of 1.5% annual increase to 2024 leading potentially to population reaching 209, 000. This considerable growth will involve natural increase and also migration into the County, and will be very much dependent on the nature of any eventual ‘post-Brexit flows’ across the border.

 Economic intent: o The draft plan seeks to ensure that sufficient land is provided at appropriate locations for employment generating uses and that such land will be protected from inappropriate development that would prejudice its long-term development. In addition to Letterkenny, this would include border locations such as Lifford and Bridgend. DCSDC Planning officials note several references throughout the document acknowledging the need for planning officials in Co Donegal to work with DCSDC in relation to the North West City Region concept.

o The draft plan also states the need to support the further development of appropriate third level educational and research and development centres within the county, as well as maximising the potential of Project Kelvin, Metropolitan Area Networks and all ICT resources and infrastructure throughout the County to facilitate appropriate, sustainable economic development.  Rural Housing Issues:

o The draft Plan recognises a number of development pressure areas, categorised as ‘stronger rural areas’, ‘structurally weak rural areas’ and ‘areas under strong urban influence’. It is proposed that different rural housing policies will apply in those areas. Much of the border area is classified as an ‘area under strong urban influence’ and as such a stricter rural planning policy has been applied in these areas to curb the influence of development in the countryside.

 Landscape / Environmental Issues:  In relation to Wind Energy, there are also a number of spatial designations outlined as followed: ‘not acceptable’, ‘open to consideration’ and ‘suitable for augmentation in relation to existing wind farms’. Much of the border area is identified as ‘not acceptable’, however there are notable exceptions in relation to parts of south Inishowen (which provides an important backdrop to Derry City) and along the border with Tyrone, which have the potential to have cross border landscape implications should any wind energy developments be proposed. 3.7 It will be important that DCSDC Planning officials continue to liaise with their Donegal Planning counterparts to ensure that both Plans are developed holistically. Specifically, officials will consider how best to ensure that Letterkenny and Derry’s growth complement each other, opportunities to plan our settlements closest to the border, co-ordinate our population growths, complementary economic development lands, rural housing policies and also approaches to larger scale landscape impacts including renewable energy.

4 Environmental Report 4.1 DCSDC Planning Officials have reviewed the Environmental Report and are largely satisfied with the level of scope, detail and findings. A copy of the Report has been forwarded to Shared Environmental Services. Officials are currently awaiting their response and any pertinent comments will be forwarded in due course to Planning officials in Co Donegal. It is noted from the draft Plan text that much of the County and many offshore islands are covered by Natura 2000 sites that are susceptible to environmental degradation, as a result of developments. 4.2 The stated environmental pressures recognised in Co Donegal include shellfish growing areas potentially posing threats to protected habitats and water quality; on-shore renewable energy developments; infrastructural schemes such as the committed road line of the proposed A5/N2 dual carriageway, upgrade to the TEN- T network and the potential routes for proposed new rail links; one-off housing in the countryside and associated proliferation of septic tanks; tourism-associated development particularly in coastal locations and increased afforestation 4.3 The draft Plan recognises that measures are required to protect the environment and mitigate for any potential adverse effects as a result of its implementation. Planning officials note that this has been iteratively addressed by the appropriate drafting of objectives and policies contained within the Draft Plan, and also by amending, adding and replacing objectives and policies to ensure mitigation at implementation stage through best practice in the development management process and implementation of the Plan. In addition, it is also recognised that certain individual applications for developments within the County may be subject to individual Environmental Impact Assessments (EIA) and Appropriate Assessments (AA).

5 Financial, Equality, Legal, HR, Improvement and Other Implications 5.1 There are no financial, equality, legal, HR, Improvement or other implications arising from this report.

6 Recommendations 6.1 Members are requested to note the contents of this Paper and agree to issue the attached response from this Council to Donegal County Council Planning officials as attached at Appendix 21. Background Papers

Appendix 21 – Draft Planning Committee response, to issue to Donegal County Council Planning Officials.