River of Opportunity, Environmental Park for Flood Plain Management in Skibbereen

If I may please let me outline my views on flood management in Skibbereen and my vision for an Environmental Park in the marsh area of the town; a project that aims to protect the town from future flooding while providing an innovative community space that would transform Skibbereen into a model for sustainable development.

This approach to the flood management of Skibbereen looks to open up new management options that explore the potential for innovative partnerships between the Planning Authority, the Office of Public Works as well as environmental and community groups.

The concept must be a community lead approach accommodating flood defence with environmental protection while simultaneously enhancing the urban environment.

With environmentally sympathetic designs, radical concepts, technological interventions and a shift in perception we can create an environment that will serve to both protect and enhance the town of Skibbereen while also creating a unique sense of place for the community and visitor.

CREATING PLACES NOT EMPTY SPACES

The area of the marsh can be developed to create a new meeting ground between nature and people in creating a new vision for Skibbereen.

It can involve the transformation of the town providing an educational, recreational and amenity area for the community. The whole area could include an amphitheatre, walking areas, community gardens, public walkways, streams, constructed wetlands and outdoor spaces that integrate the town with nature while offering a unique long term protection to the town from future risk of flooding and sea level risk.

The development plan would include riverside seating, picnic areas and allow for public works of art within the public realm while also providing an array of natural environments from constructed wetlands to woodland, meadows, marshland and shallow and deep ponds with varying aquatic margins.

RIVER OF OPPORTUNITY

Land and water are intrinsically linked and nowhere more so than in Skibbereen where the River Ilen meanders its way to the sea. Preserving the riverside land areas is not only crucial to future generations but also to the long term sustainability of the town.

The core aims of any flood management plan must be first and foremost the protection of Skibbereen from future flooding. Secondly, the creation of an innovative community space that will provide new amenities for the town, and also offer alternative landscapes that will be a visitor attraction while developing a new pedestrian gateway to the town of Skibbereen.

The ability of this new park to meet the urgent needs of the town to alleviate flooding while aspiring to be something of wider importance is a key starting point to the Enviro Park vision.

INTELLIGENT DESIGN

The site would be set out in various sections to provide a multifunctional park, creating new open public spaces, fulfilling the need for additional car parking spaces, while allowing a variety of amenity uses, nature conservation and community gardens. The themes of environment and sustainability in the 21^st century are appropriate to underpin such multi-facetted proposals applicable as it is to all society.

A diverse landscape of hills, valleys, waterbodies, woodland, and open fields can give a variety of habitats and enclosure providing opportunities for recreation, relaxation, inspiration, sculpture, craft, wildlife trails, fitness trails, adventure play, walks, meeting and performance space with an integrated drainage system to protect the town from future floods. Ideas could include, trail bike riding areas a skateboarding arena, public amphitheatre, a famine commemoration park, a mini golf or pitch and putt course providing a variety of themes and uses while also promoting Skibbereen as a visitor attraction.

Its immediate proximity to the town offers enormous opportunities in particular the potential to refocus the town on the river and its immediate environment. The local community and the town stand to benefit greatly from such an inclusive vision for a new Enviro Park while also giving the potential for a new focus for the southern part of the town.

The park needs to be multifunctional, providing flood relief while also offering new opportunities to culturally enhance the town and improve its environment. Such a park would illustrate the human ability to reciprocate with nature.

The methodology of creating an Enviro Park must be one of inclusive community involvement in designing, implementation and managing elements within it.

BUILDING FOR THE FUTURE

Firstly, as follows is a conceptual outline for the Enviro Park.

Funding from the OPW for flood relief study should be used to fund the production of a feasibility study that would include consultation with the local authority, landowners, business associations, community groups, schools and environmental interest groups.

The next phase of the plan’s implementation would involve constructing river embankments to act as flood water retainers. The design of the embankments would include a number of automated sluice gates to redirect flood waters within the Enviro Park when the town is at risk of flooding.

The ground level within the park would be reduced and designed to retain substantial volumes of water by creating a series of undulating low hills and valleys. The existing pumping station on the lands would be re-designed and equipped to allow for dewatering the Park when flood waters reside in the river Ilen.

LOCAL ENHANCEMENT

The extended park can be accessed by four bridges, with the new pedestrian bridge acting as the focal point for pedestrian entry into the town. Limited parking could be provided on raised parking lots thereby securing additional parking for the town.

The Enviro Park would be the first of its kind in Ireland reshaping and redesigning Skibbereen for the 21^st Century. This unique opportunity has the potential to create activities for old and young that will draw people to the park and the town while providing new visitor attractions for Skibbereen.

I believe, that the way in which we as a community design and ultimately use these lands will be a defining moment for planning in Ireland. The very future of the town depends on it. As a community we must face up to the challenges and risks that will impact on the town and none is more alarming than climate change, flooding and the inevitability of sea level rises in the coming decades.

This concept offers the possibility for the community of Skibbereen to engage with nature, rather than fight against it. It requires imagination, community inspiration and co-operation with nature.

ON THE WATERFRONT

What if in the future the predictions of climate change are correct and we will witness sea level rise, continued and increased flooding and extreme weather events such as the extreme flooding of 2009. If history is anything to go by, we will be ready for neither unless we learn from our mistakes and design innovative solutions now to work with nature and support our communities.

The idea that future sea levels will rise is now a certainty; this will impact on coastal and inland tidal river communities such as Skibbereen which has an established history of flooding.

How could the landscape look if the urban area was designed to help alleviate future flooding? The future scenario is particularly relevant now to Skibbereen as it’s commences yet another flood impact study and attempts to design future flood alleviation for the town.

It is my belief that the conversion of the marsh area into an innovative EnviroPark could achieve just this and breathe new life into Skibbereen.

AFTER THE FLOODS

We don’t have to cast our minds back that far to remember the extraordinarily difficult circumstances that Skibbereen was in twenty years ago when it had the largest level of emigration of any community in Ireland. I have been privileged to have a long association with the town and remember the terrible floods in 1987 that closed some businesses permanently such as the wholesale shrubbery and nursery business which was located on the marsh.

We are now in the grips of another major recession, one that may last longer and have deeper social and economic implications for this country and particularly the younger generation who are faced with little prospect of employment. On top of that we have witnessed major social and economic impacts associated with extreme weather events on a scale not previously experienced in this country in the past century. Catastrophic flooding was experienced across Ireland and in particular in Skibbereen, Bandon and Cork City. The cost to the insurance industry for the recent unprecedented flooding and extremely cold spell that Ireland endured was in excess of €550 million. T his figure does not portray the true economic cost in jobs and added indebtedness to businesses and householders for repair and renovation to damaged property and many of them will be unable to get insurance in the future.

Enormous and painful lessons are being learned, we are dealing with people and communities and must protect ourselves from the destructive power of nature which we cannot control.

If we want a future for Skibbereen town, we must be creative. If we want to protect our community from future flooding, we must provide innovative and cost-effective solutions to manage the environment in a more sustainable manner.

ON THE EDGE OF POSSIBILITY

The risks associated with flooding in Skibbereen offer what is probably the greatest new landscape opportunity of our generation.

To reduce vulnerability and future risks of flooding we must seize the opportunity to redesign urban spaces, to work with nature and to forge innovative lasting solutions that build a sustainable future.

I believe that the development of an Environmental Park could provide a showcase for creative, innovative, urban landscape flood alleviation design.

Objection to Proposed Retail Commercial Development on a Flood Plain in Skibbereen Town

MAIN GROUNDS OF OBJECTION

The full grounds of objection together with the arguments, reasons and considerations upon which these are based are set out below. For clarity and ease of reference we propose to deal with each individual element of the grounds for our clients’ objection and outline our response to each in turn.

2.1 Development on Floodplain

We respectfully submit that a moratorium on any such development should exist until the Office of Public Works (OPPW) complete the flood impact assessment and alleviation plan for the town of Skibbereen.

It is clear that the proposed site is located on a flood plain and under no circumstances should planning and development be considered until a thorough appraisal of the potential impact of such a development on a flood plain is examined in light of recent flooding of the town and in particular in the absence of OPW flood mitigation works for the town of Skibbereen. The applicants have clearly failed to address this major planning consideration in their application.

The Draft Planning System and Flood Risk Management Guidelines require the planning system at national, regional and local levels to:

• avoid development in areas at risk of flooding, such as floodplains, unless there are wider sustainability grounds that justify appropriate development; and where the flood risk can be reduced or managed to an acceptable level without increasing flood risk elsewhere;
• adopt a sequential approach to flood risk management and guide development away from areas that have been identified as being at risk through flood risk assessment. In areas of high risk, for example, you should see water-compatible developments such as docks and marinas, amenity open space, outdoor sports and recreation, while other more vulnerable development should be directed towards areas of minimal or no flood risk.
• incorporate flood risk assessment into the process of making decisions on planning applications and planning appeals.

We respectfully submit that the applicants have clearly failed to address these issues in their application.

2.2 Traffic Implications

Such a large scale development will attract large volumes of car-borne customers and require a high quality road network with spare capacity. Furthermore, it is clear that the proposed mixed-use retail and commercial development will result in traffic that would result in significant traffic congestion at the already busy access and link road to Skibbereen town as well as within the town centre.

The planning application has not examined the traffic implications and existing infrastructure to support this development.

The site of the proposed development does not serve the mobility needs of the wider community including the needs of pedestrian shoppers. No traffic mobility assessment has been undertaken for the proposed development which must ensure a high standard of access both by public transport, foot and private car so that the proposal is easily accessible by all sections of society, especially those that do not have access to a private car and of course the elderly.

This is particularly relevant where the site does not provide for public bus set-down or bus service in the vicinity of the proposed development. The site is neither accessible nor convenient for public transport facilities and contrary to the information provided in the planning report submitted, the site is located approximately 700m from the established town centre not less than 200m.

The applicants have clearly misrepresented the distance of the site for the proposed development from the established town centre. The established guidelines clearly state that the distance considered to be convenient for such a development is unlikely to be much more than 300-400 metres from the edge of the prime shopping area. The applicants have clearly failed to address these issues in their application.

Prior to even considering such a development a thorough traffic mobility and impact assessment must be undertaken in addition to a socio-economic impact assessment of the impact of such a development on the viability of the town centre to survive such a development.

The proposal is likely to result in a back-up of traffic onto the access road in and out of the retail development as well as onto the link road and roundabout thereby obstructing the free flow of traffic at this location and endangering public safety by reason of traffic hazard.

The applicants have clearly failed to address this issue in their application.

We further respectively submit that in the absence of a traffic impact assessment or mobility management plan for such a large-scale commercial retail development the planning application should be refused.

2.3 Retail Impact

It is our respectful submission that the applicants have failed to provide any reasonable grounds that would allow the Planning Authority to grant permission for the proposed development. We respectfully contend that the submitted documents do not demonstrate the true impact of the proposed development on the established commercial business centre of the town and local stores within the catchment area and the materially negative impact that the proposal will have on the business community which has already been substantially degraded in recent years due to the economic recession.

We respectfully submit that the assessment of current retail provision for the town is based on the Cork Strategic Retail Study, a survey of existing retail floor space conducted in the summer of 2007. The report does not examine the level of empty commercial retail space currently in the town and the impact of the proposed development on the remaining established businesses.

We respectfully submit that the retail impact assessment has based current expenditure in the town at 2006 levels set during the height of the economic boom in Ireland and is not based on current expenditure during the worst economic downturn in the history of the state. The applicants have clearly failed to address this issue in their application.

We respectfully submit that the retail impact assessment has not examined the cumulative impact of the proposed development with other recent retail developments such as Lidl on the commercial town centre. We respectfully submit that the cumulative impact would cause an adverse impact on the commercial viability and vitality of the town centre sufficient to undermine the quality of the town centre or its role in the economic ands social life of the community. Furthermore, the creation of 490 additional car parking spaces at this location outside the town would clearly not serve the need of the town centre as a whole but rather the exclusive use of this development. The introduction of pay parking in the town would subsequently encourage business drift from the town centre to where free parking was available and further commercially damage the viability of the established town centre businesses leading to inevitable closure and increased economic hardship for the business community in an already deepening period of economic recession. The applicants have clearly failed to address this issue in their application.

We respectfully submit that the proposed development does not support the development of the town centre as a viable business centre, does not address the current problems facing business in the commercial town centre nor present a realistic vision of how the community want the town centre to be developed.

We respectfully submit that the proposed development must be based on realistic appraisal of the need for such a development and the impact of such a development on existing businesses within the town.

In dealing with these matters, the Planning Authority should take account of the views of retailers, shoppers, property owners and the National Roads Authority. We respectfully submit that no such consultation has been undertaken. The purpose of the planning system includes the promotion of healthy town centres in the public interest. We respectfully submit that the proposed development does not support this objective.

In submitting evidence in relation to retail impact the applicant is required to address the following criteria and demonstrate whether or not the proposal would:

• Support the long-term strategy for town centres as established in the development plan and not materially diminish the prospect of attracting private sector investment into one or more town centres.
• Cause an adverse impact on one or more town centres, either singly or cumulatively with recent developments or other outstanding planning permissions, sufficient to undermine the quality of the centre or its role in the economic and social life of the community.
• Diminish the range of activities and services that a town centre can support.
• Cause an increase in the number of vacant properties in the primary retail area that is likely to persist in the long term.
• Ensure a high standard of access both by public transport, foot and private car so that the proposal is easily accessible by all sections of society.
• Link effectively with an existing town centre so that there is likely to be commercial synergy.

We respectfully submit that the proposed development does not comply with these criteria. The proposed development will not support the long-term strategy for town centres, will materially diminish private sector investment into the town centre, will cause adverse impact on one or more town centres in West Cork, will undermine the commercial viability of the town centre and its role in the economic and social life of the community.

We respectfully submit that the proposed development will diminish the range of activities and services that a town centre can support and cause an increase in the number of vacant properties in the primary retail area that is likely to persist in the long-term.

We respectfully submit that the proposed development does not provide a high standard of access both by public transport, foot and private car so that the proposal is easily accessible by all sections of society.

We respectfully submit that the proposed development does not link effectively with an existing town centre so that there is likely to be commercial synergy.

We respectfully submit that there is a significant unused retail space in the town at present and that the market cannot support the proposed development.

We respectfully submit that the proposed development will support the development of an unacceptable local monopoly effect on smaller retail shops in the established commercial town centre.

We respectfully submit that this proposal will clearly have a detrimental impact on the provision of services in the established town centre and is therefore inappropriate development for the sustainable development of the town.

In assessing the need for additional development as proposed it is important that the assessments are based on a realistic appraisal of both expenditure change and market requirements. Plans should be based on up-to-date information regarding existing retail floorspace and shopping patterns in the area.

We respectfully submit that the applicants have clearly failed to address these issues in their application. Furthermore, the development of additional large-scale regional retail centres on greenfield sites or outside established centres is not regarded as sustainable in relation to transport objectives. Consequently, there should be a general presumption against large-scale out-of-centre retail development such as that proposed.

We respectfully submit that the proposed development would be contrary to the proper planning and sustainable development of the area.

2.4 Critical Infrastructure:

We respectfully submit that a moratorium on any such development should exist until the critical waste management infrastructure is provided for the town of Skibbereen.

We respectfully submit that the planning application has not examined the potential pollution load from such a development “population equivalent load’.

We respectfully submit that where no sewage treatment works have been built for the town there is an inability to treat the wastes arising.

We respectfully submit that the implications for waste management, in particular foul sewage treatment and storm water run-off have not been addressed.

We respectfully submit that major developments such as that proposed should not be permitted where the waste water treatment infrastructure is not available.

2.5 Planning precedent

We respectfully submit that there is a clear and unambiguous precedent set for the determination of the proposed development by the Planning Authority. An Bord Pleanála and Planning Authorities have refused a number of applications for developments on floodplains around the country, which should act as precedent for the refusal of the proposed development. Where planning was granted for such a development it would introduce a risk of potential liability on behalf of the Planning Authority for future damage.

2.6 Environmental Assessment

We respectfully submit that no environmental assessment has been undertaken on the site to establish the likely impact of the proposed development on the environment.

Factors such as biodiversity, species or flora and fauna on the site have not been examined.

No ambient noise assessment has been undertaken to examine the likely impact of the development on neighboring residential houses.

We respectfully submit that planning should be refused in light of the inadequacy of information provided.

3. CONCLUSION

The proposed development is located on a floodplain and was under several feet of water during the November 2009 flood of Skibbereen. We respectfully submit that a moratorium on any such development should exist until the OPW complete the flood impact assessment and alleviation plan for the town of Skibbereen.

The proposal will have an adversely negative impact on the existing established commercial town centre. The site location of the proposed development is in excess of 700m from the commercial town centre and is not accessible nor convenient for public transport facilities. The site of the proposed development does not serve the mobility needs of the wider community including the needs of pedestrian shoppers. We respectfully submit that a moratorium on any such development should exist until the critical waste management infrastructure is provided for the town of Skibbereen. We respectfully submit that the implications for waste management, in particular foul sewage treatment and storm water run-off have not been addressed for the development. We respectfully submit that major developments such as that proposed should not be permitted where the waste water treatment infrastructure is not available.

No traffic impact assessment has been provided for the proposed development. The creation of 490 additional car parking spaces at this location outside the town would clearly not serve the need of the town centre as a whole but rather the exclusive use of this development.

The introduction of pay-parking in the town would subsequently encourage business drift from the town centre to where free parking was available and further commercially damage the viability of the established town centre businesses leading to inevitable closure and increased economic hardship for the business community in an already deepening period of economic recession.

The proposal is likely to result in a back-up of traffic onto the access road in and out of the retail development as well as onto the link road and roundabout thereby obstructing the free flow of traffic at this location and endangering public safety by reason of traffic hazard.

We request the Planning Authority to conclude therefore that the proposal is contrary to the provisions of sections 90-95 of the Retail Planning Guidelines and therefore not in the interest of the proper planning and sustainable development of the area nor in the interest of the common good.

The application has failed to address our clients’ concerns in terms of its material impact on the viability of the existing commercial town centre and their associated stores, as well as its cumulative negative impact, due to its direct association with the Lidl supermarket, located outside the town centre. The proposal will adversely impact on the residential community adjacent to the development creating the potential for ambient light and noise nuisance. Furthermore, factors such as biodiversity, species or flora and fauna on the site have not been examined.

For all of the above reasons, to permit the proposed development would be contrary to the proper planning and sustainable development of the area including the protection of amenities therein.

We therefore respectfully request that Cork County Council refuse this current application on the grounds set out above.

Yours sincerely

Declan Waugh BSc. C.WEM. CEnv. MCIWEM. MIEMA. MCIWM. MIOA. Grad EI. ALI

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