TII notes that the Proposed Amendments collectively address Rural Housing Objectives in the Development Plan. TII acknowledges that rural areas play an important role in County Mayo and the Authority supports the need to sustain these rural communities.
Having regard to the extensive and largely rural nature of the strategic national road network in Mayo, it is considered that development proposals addressed in the Rural Housing Policies of the Development Plan have the potential to result in a demand for access to the strategic national road network.

The Council will be aware that the National Development Plan, 2021 – 2030, outlines the key sectoral priority of maintaining Ireland’s existing national road network to a robust and safe standard for users. This position is further reflected in the publication of the National Investment Framework for Transport in Ireland. The DoECLG Spatial Planning and National Roads Guidelines also emphasis the critical importance of ensuring high standards of road safety on national roads which is addressed by managing access and intensification of access to national roads and guarding against a proliferation of roadside development accessing national roads to which speed limits greater than 50 – 60kph apply.
The creation of new access or intensification of existing direct access to a national road outside 50-60kph urban speed limit locations, in such circumstances, would conflict with the provisions of official policy included in the Section 28 Ministerial Guidelines ‘Spatial Planning and National Roads Guidelines for Planning Authorities’ (DoECLG, 2012).

Therefore, in the interests of clarity, TII would welcome a cross reference included in Section 3.4.8 Rural Single Housing of the Draft Plan referring to Section 6.4.2.1 National Roads and Policy MTP 16 which reflects Government policy and outlines the Councils policy on the management of development access to national roads to which speed limits greater than 50 - 60 kph apply.

TII is if the opinion that such a cross reference would provide clarification and early assistance to applicants in the preparation of any planning application where there may be implications for the strategic national road network in the area and clearly identify, at an early stage, any policy conflicts related to access to national roads for applicants to consider.
Recommendation

TII would welcome consideration by the Council of the following:
▪ Include a cross reference in Section 3.4.8 of the Draft Plan, and associated Policy Objectives, referring to Proposed Policy MTP 16 in the interests of providing clarification and early assistance to applicants in the preparation of any rural housing planning application where there may be implications for the strategic national road network in the area.

Proposed Amendments; Volume III Book of Maps

Chapter:

Volume 3: Book of Maps

The Authority acknowledges and welcomes the close alignment of development plan zoning and settlement boundary designations with existing speed limits on the national road network contained in Draft Plan Volume III, including the Proposed Amendments; Section 2.11 of the DoECLG Spatial Planning and National Roads Guidelines refers.

However, it appears that one proposed zoning/development amendment in Claremorris (‘Rezone lands along the N60 from Agriculture to Strategic Residential Reserve Tier II’) adjoins the N60 at 100kph location, although it is noted that an alternative local road access may be available and should be clarified.

Recommendation
▪ In the interests of consistency with the application of official policy, TII recommends review of the proposed zoning amendment in Claremorris adjoining the N60 to ensure access to the subject lands can be facilitated in accordance with the provisions of official policy outlined in the DoECLG Spatial Planning and National Roads Guidelines.

Proposed Amendment CH 6.16 & 6.17

Chapter:

Volume One - Written Statement » 06. Movement & Transport

It is noted that Proposed Amendment CH 6.16 seeks to amend Policy MTP 16 of the Draft Plan. TII is of the opinion that Policy MTP 16 of the Draft Plan reflected the provisions of Section 2.5 of the Section 28 Ministerial Guidelines ‘Spatial Planning and National Roads Guidelines for Planning Authorities’ (DoECLG, 2012).

The alteration proposed in Amendment CH 6.16, including allowing exceptions to access national roads for ‘economic or social reasons’ is not considered to adhere to the provisions of foregoing official policy. The Council will be aware that Section 2.5 of the DoECLG Guidelines require the policy of the planning authority to avoid the creation of any additional access point from new development or the generation of increased traffic from existing accesses to national roads to which speed limits greater than 60 kmh apply. This provision applies to all categories of development.

The proposed amendment conflicts with the foregoing Government policy and TII does not support its adoption.

Recommendation
▪ TII does not support the proposed amendment to Policy MTP 16. TII considers the proposed amendment conflicts with the provisions of Section 2.5 of the Section 28 Ministerial Guidelines ‘Spatial Planning and National Roads Guidelines for Planning Authorities’ (DoECLG, 2012). TII does not support the proposed amendment.

Proposed Amendment CH 6.17

TII notes that Proposed Amendment CH 6.17 addresses the provision of ‘exceptional circumstances’. TII supports the proposed amendment whereby it reflects that ‘exceptional circumstances’ cases are required to be identified for incorporation into the Development Plan, i.e. plan-led. TII welcomes that the Proposed Amendment confirms that the Council will undertake a survey to identify such sites and agree cases in consultation with TII, in accordance with the provisions of Section 2.6 of the DoECLG Spatial Planning and National Roads Guidelines.

Nevertheless, TII notes that Proposed Amendment CH 6.17 includes that a site has been identified at the IDA Site, Quignashee, Ballina (off the N59).

TII’s records indicate that a 100kph speed limit applies to the N59, national secondary road, at the location of the proposed access. The N59 is a strategic national road and provides important strategic linkages within the North Mayo region. In accordance with official Government policy objectives, it is critical that the safety, capacity and strategic function of the existing national road is safeguarded.
TII advises that no consultation has been undertaken in relation to this proposed ‘exceptional circumstances’ case for inclusion in the Development Plan. TII is also unaware of any evidence base developed in support of the proposal to address the requirements of Section 2.6 of the DoECLG Spatial Planning and National Roads Guidelines.

TII is of the opinion that including the proposed ‘exceptional circumstances’ in the Development Plan in the form currently presented and in advance of undertaking an evidence-based analysis is inappropriate and in conflict with the provisions of Section 2.6 of the Section 28 Ministerial Guidelines ‘Spatial Planning and National Roads Guidelines for Planning Authorities’ (DoECLG, 2012).

Recommendation
TII would welcome consideration by the Council of the following:
▪ TII supports the proposed amendment whereby it reflects that ‘exceptional circumstances’ cases are required to be identified for incorporation into the Development Plan, i.e. plan-led. TII welcomes that the Proposed Amendment confirms that the Council will undertake a survey to identify such sites and agree cases in consultation with TII, in accordance with the provisions of Section 2.6 of the DoECLG Spatial Planning and National Roads Guidelines.
▪ However TII does not support the inclusion of the IDA Site, Quignashee, Ballina in its current form as part of this amendment. In TII’s opinion the proposal is premature pending and should be omitted until the proposal outlined by the Council to undertake a survey to identify ‘exceptional circumstances’ sites and agree cases in consultation with TII, in accordance with the provisions of Section 2.6 of the DoECLG Spatial Planning and National Roads Guidelines for Planning Authorities.
▪ TII is available to assist the Council in the development of proposals for consideration as ‘exceptional circumstances’ cases in accordance with the provisions of the DoECLG Guidelines.

TII Submission

Cover Letter

Observations

Information

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