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Review to Renew the public consultation of the Review of the National Development Plan Submission | February 19, 2021
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CORK CHAMBER SUBMISSION
Introduction
Cork Chamber is the leading business representative organisation in Cork, proactively working to identify and progress developments that are facilitative of sustainable economic development. Representing an employer base of close to 1,200 businesses and over 100,000 employees across the region, Cork Chamber is the largest business representation organisation in the south of Ireland. At the outset we take this opportunity to strongly urge the continued commitment from Government to the delivery on the objectives of the National Development Plan. The need for investment now and the continued delivery of enabling economic and social infrastructure, that addresses national imbalances, and years of underinvestment, which supports a shift in our national carbon profile to dramatically reducing greenhouse gas emissions, will define our collective futures and those of future generations. The National Development Plan has the potential to be transformational, and we must take this opportunity to embed the strong foundations for a future that aligns seamlessly with the sustainable development goals. This submission has been guided by our commitment to the UN Sustainable Development Goals. Five specific goals have been identified which we actively advocate for throughout our work;
RE VIE W TO RENE W - THE PUBLIC CONSULTATION OF THE RE VIE W OF THE NATIONAL DE VELOPMENT PL AN
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This commitment is supplemented and further developed through our Sustainable Cork Programme (SCP) which focusses on the sustainable and resilient recovery of the Irish economy and society in the short to medium term, but also the longer term as we transition to a low to zero carbon society. Developed in considerable detail through significant member and community engagement, the Building Economic Resilience report1 sets forth a strong and sustainable vision for the future of Cork and clearly indicates the appetite of the business community to engage and be progressive in addressing social and environmental concerns and identifying the pivotal infrastructure needed to enable and advance the sustainable development of the region. It is the role of Government to enable this ambition. The following graphic illustrates the clarity of vision displayed in the findings of the SCP Building Economic Resilience Report.
Your Top 3 asks for what you want to see more of in the next 5 years: 1. Connected public transport networks (bus, light rail, and suburban rail)
2. Cycleways, greenways & enhanced walking environment
3. Green spaces, trees, wildflower planting & green infrastructure such as living walls This is followed by more outdoor dining, amenity access to the river and coastline from Cork City, enhanced resourcing for An Garda Síochána for urban centres.
The differentiators for living and working in Cork
57%
Quality of life
42%
The tourism, cultural & hospitality scene (café, theatre, gallery, restaurants, heritage)
34%
Diverse business types & activities (from indigenous home grown to large multinational)
1 https://www.corkchamber.ie/wp-content/uploads/2020/07/Sustainable-Cork-Programme-Building-Economic-Resilience.pdf
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CORK CHAMBER SUBMISSION
Review of the National Development Plan
Is the overall level of public spending on capital investment correct? Answer In the wake of the current pandemic, and the infrastructural deficit created by the severe austerity measures triggered by the 2008 economic crash, it is essential that investment in capital projects continues to be increased to meet capacity constraints and to realise the full potential of Cork, as set out in the National Planning Framework2, RSES3 and Cork 2050, the complementary vision set by Cork stakeholders.4 Capital investment must be directed to regional growth centres, and be reflective in level of investment to the current scale and future growth projections set out in national policy. It is the role of Government to gauge the level of national spend that is appropriate relevant to barometers such as sovereign credit ratings. However, Cork Chamber recommends that the most ambitious approach is taken to capital investment spending.
Rationale Failure to invest appropriately, will lead to serious capacity constraints that will damage economic resilience and recovery. There are significant infrastructural deficits resulting from the previous approach to austerity. There is also significant economic stimulus associated with capital expenditure, providing the most proactive and legacy inducing form of government support available. If Cork is to remain globally competitive and fulfil it’s role nationally, significant Government investment in areas from the Cork Metropolitan Area Transport Strategy, to regional & international connectivity, housing, health, culture, education, energy, water, climate mitigation, URDF & RRDF will be required. Priority given to capital expenditure would also support the NPF objective of delivering infrastructure led development. This approach would provide Ireland with an opportunity to apply international best practice to the development of our cities and towns as attractive places to live. In 2018 Ireland had one of the lowest public spending to GDP ratios in the OECD spend per capita behind the average for the EU. We must move apace not only to correct for previous austerity, but to keep pace with ongoing international capital spend profiles.
2 https://npf.ie/ 3 https://www.southernassembly.ie/regional-planning/regional-spatial-and-economic-strategy 4 https://www.corkcoco.ie/sites/default/files/2017-08/Cork%202050%20Main%20Report.pdf
RE VIE W TO RENE W - THE PUBLIC CONSULTATION OF THE RE VIE W OF THE NATIONAL DE VELOPMENT PL AN
What should the capital budget be spent on? Answer If Cork is to remain globally competitive and fulfil it’s role nationally as set out in the National Planning Framework, significant Government investment in areas from the Cork Metropolitan Area Transport Strategy, to regional & international connectivity, housing, health, culture, education & innovation, energy, water, resilience, climate mitigation, URDF & RRDF will be required. • The Cork Metropolitan Area Transport Strategy5 will deliver multi modal connectivity that is fit for purpose for a contemporary metropolitan area. It is essential that all streams are progressed with urgency through design and planning, enabling timely final investment decisions as each project progresses successfully. Intensity of approach across all streams of CMATS is required to ensure adequate levels of delivery. • Regional connectivity still bears the scars of austerity. The M28, N22, Dunkettle Interchange, N25 and M20 route corridors must all be significantly improved in capacity, not soley for private vehicles but in terms of multimodal connectivity also. • International connectivity from Cork Airport has been severely curtailed by the pandemic. Significant capital investment is required to ensure that the infrastructure, including the runway is poised for the return of significant volume. Research tells us that full recovery will take up to five years in the sector and Cork Airport must be supported by multi-year operational and capitals supports under the Regional Airports Capex Programme.
• International connectivity from the Port of Cork continues to grow with new routes to the US, Belgium and France proving market demand. Investment in Customs and Border infrastructure at the Port would deliver a major boost in operational potential as new patterns continue to be established post EU-UK TCA. • The viability of apartments continues to be a major challenge for the delivery of density targets set out in Ireland 2040. The lack of viability of apartments continues to be a major challenge for the delivery of density targets set out in Ireland 2040, consigning the region exclusively to reliance on lower density models of development. It is also a significant economic inhibitor, damaging talent attraction, regeneration and the quality of life appeal of the region. A Cork Chamber report, from July 2020 centring on economic recovery, presents quality of life as the characteristic that will define the future of Cork.6 The lack of apartment viability is documented alongside a range of solutions in an EY-DKM report commissioned by CIF Southern Region and Cork Chamber.7 Integrating the concept of compact growth into all investment decisions will improve quality of life and help to address climate action. Housing commitments such as Help to Buy and Shared Ownership must continue to be pursued. LIHAF has delivered for Cork and equivalent models should be retained and enhanced.
5 https://www.nationaltransport.ie/planning-and-investment/strategic-planning/regional-transport-strategies/cork-metropolitan- area-transport-strategy/ 6 https://www.corkchamber.ie/wp-content/uploads/2020/12/10793-Anaerobic-Digestion-report_final.pdf 7 https://www.corkchamber.ie/wp-content/uploads/2019/09/Viability-and-Affordability-of-Apartment-Building-in-Cork-City.pdf
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• The Urban Regeneration and Development Fund and the Rural Regeneration and Development Fund must be strengthened further and align to the National Planning Framework, delivering proportionately for the vision set for Cork. The mechanism for funding must provide stronger multiannual commitment and certainty. • The provision of water infrastructure, both in terms of supply, and wastewater management, is a significant inhibiting factor in the rollout of multiple infrastructural ventures from housing to industry in Cork. Investment must be targeted in growth areas with clear plans and timelines set out. It is essential not only for development, but for the environmental and amenity assets of our rivers, lakes and unrivalled harbour. • With population growth and population aging, the necessity for significant health infrastructure is certain. Commitment to a new elective hospital and acute hospital in Cork must be strengthened and progressed with urgency. • Culture and creativity remain deeply intertwined with innovation, quality of life, mental health and civic pride. The commitments to the Cork Event Centre, Crawford Art Gallery, and to creative funds and supports must be strengthened as the sector will play a significant role not only economically, but psychologically as we seek positivity and inspiration on the road to recovery.
8 https://www.solas.ie/f/70398/x/64d0718c9e/solas_fet_strategy_web.pdf 9 https://assets.gov.ie/36601/25e3ce496dd64dfaa986d7105f2a5cb1.pdf
CORK CHAMBER SUBMISSION
• There should be discretion for adding creative and innovative new projects to the scope of the NDP. Outdoor, quality of life-oriented infrastructure is increasingly important. For example, in Cork, there is a growing body of support for a lido or outdoor swimming baths. Public outdoor baths were once a focal point of culture and community in the city, and now that demand has returned. Feasibility and conceptual support should be on offer for this or other initiatives and the multiple benefits they would bring to amenity, civic pride and quality of life. • Further Education and Training requires significant capital investment in the infrastructure for apprenticeships, which is currently at capacity, and expects a significant increase. Capital investment for online delivery, to support individuals and communities where access (physical) to Further and Higher Education should be improved. • Capital funding to support the development of the FET College model as set out in the National Further Education and Training Strategy8, through investment in existing and new FET facilities is required. • The current level of funding is not sufficient for additional accommodation at both primary and secondary level. The overall demographic peak is currently passing through the post primary system and will reach a peak in 20259. This combines with a major shift in the location of the population towards larger urban areas leading to acute demand.
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• At primary and second level the funding currently provided to meet additional school accommodation is insufficient. As result, it is the norm that new schools are opened in temporary accommodation. The NDP should commit additional funds to the building of schools. For example, Cork ETB is dealing with areas where the level of accommodation is significantly insufficient in East Cork, Ballincollig, Bandon and Buttevant. • Research and Development funding must be increased to 2.5% of GNP as set out in Innovation 2020, and the prioritisation of a replacement strategy, and implementation programme as this expires.10 • Support for capital projects critical to the longterm competitiveness of the MTU and UCC, including the UCC Business School, Tyndall, the sports facilities at the MTU Bishopstown Campus must be strengthened in line with the planned growth and ambition of each institution. • Cork is home to Ireland’s Energy cluster, Energy Cork11 and has significant potential to develop further. National policy should support the deepening of ambition for this energy cluster and support the significant growth potential of renewables such as floating offshore wind anaerobic digestion12, green hydrogen, solar PV and wind which have potential to generate significant economic value and employment, and contribute immeasurably to the sustainable credentials of the region and nationally. The recent public consultation on a Microgeneration Subsidy Scheme for Ireland has the potential to be a crucial step in achieving the target of 70% renewable electricity by 2030 set out in the 2019 Climate Action Plan. It is crucial that an ambitious scheme is delivered.
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• The recommendations of the Cork Harbour 2025 Ready to Float Offshore Wind should be implemented by supporting Cork as a strategic hub for floating offshore wind and accelerating development of floating offshore wind farms.13 • National, and international energy transmission infrastructure investment such as the Celtic Interconnector will continue to be essential. • The rollout of the National Broadband Plan is welcome and essential in the context of the pandemic and shift in working preferences that will ensue. The delivery speed of the NBP in Cork should be increased to meet this demand. Certain sections of the central business district of Cork are not covered by high quality fibre connectivity and this must be addressed. Fine grain appraisal of this urban connectivity must be undertaken and addressed in the context of overall national broadband provision. • Support the implementation of the IDA Ireland Strategic Plan alignment to Ireland 2040 by providing further strategic employment sites in Cork. • Continue to support and strengthen the Regional Enterprise Fund.
Rationale Cork is the fastest growing region in Ireland as set out in the National Planning Framework. To invest in Cork is to ensure the success of the Planning Framework and the success of the economic driver of the Southern region. Conversely, failure to align capital investment with the region, would severely undermine the Planning Framework, and damage the potential of the region to deliver on it’s national role.
https://www.gov.ie/en/publication/7287b-innovation-2020/ http://www.energycork.ie/ https://www.corkchamber.ie/wp-content/uploads/2020/12/10793-Anaerobic-Digestion-report_final.pdf https://www.corkchamber.ie/wp-content/uploads/2021/02/Cork-Harbour-2025-Ready-to-Float-Offshore-Wind.pdf
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What types of capital investment should be prioritised? Answer Capital investment across all sectors should be aligned to the growth centres set out in Ireland 2040.
Rationale To successfully deliver on the national planning framework and all aligned national and local Government policy.
CORK CHAMBER SUBMISSION
• Local Authorities should receive a multi-annual capital envelope to ensure a more streamlined, consistent and certain planning and procurement process. The current application process to central Government Departments for capital investment projects can be slow, uncertain and lacks certainty. • Multiannual commitment for significant projects. For example, for the docklands to reach its potential the URDF would benefit from significant total commitment on a staggered investment basis. • Use of PPP models for appropriate projects. • Ensure alignment with the National Planning Framework and the regional centres identified. • Alignment of investment priorities of Infrastructure Delivery Agencies.
How can the management and governance of public investment be improved? Answer • Periodical quarterly review and assessment of capital investment in line with national policy. • Ensuring transparency of timelines and funding gateways.
• Visibility of the location (region) where the money is being spent. • Alignment of all investment with the United Nations Sustainable Development Goals. • Alignment of all investment with a positive outcome in the Happiness Index ranking through the setting and reporting on a progressive set of national societal wellbeing indicators. • Consideration of climate change, extreme weather events, and future pandemics in infrastructural planning and design. • Seeking the best possible outcome in public procurement rather than being defined by the lowest possible price.
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• Regional private sector and senior Government representation on the Ireland 2040 delivery board.
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• Emphasis on planned and infrastructure led development.
In the wake of the current pandemic, it is critical to ensure that delivery is the focal point, with all associated processes and mechanisms open to further streamlining and urgency. Lack of delivery will damage confidence in the whole of the Ireland 2040.
Rationale
Rationale:
To ensure clarity, certainty, support and capacity for delivery.
NA
How is the NDP is affecting your region?
What is your feedback on Project Ireland 2040 communications?
Answer In alignment with the National Planning Framework, the NDP provides spatial and investment policy certainty to the region, creating a predictable environment in which built environment and commercial investment decisions can be made. With further momentum, refinement, expansion and precision it can deliver for the region. However, delivery of significant NDP projects to date has been frustrated by planning processes which have delayed projects and by piecemeal funding application and decision-making processes. The effects of prior approaches to austerity are still causing capacity constraints. For example, significant investment in Cork, in projects such as the N22 and Dunkettle Interchange are now only commencing, following more than a decade of anaemic regional investment.
Answer It is essential that Ireland 2040, the National Planning Framework and the National Development Plan, are committed to thoroughly by the current and successive Governments. It is the job of each Government to deliver on milestones for the vision set forth for Ireland in 2040. Acknowledging impediments to the vison of Ireland 2040, such as brownfield viability, planning and funding mechanisms, in parallel with implementing solutions is fundamentally important to communications, confidence and support for Ireland 2040. Without this the credibility of the plan will be undermined over time.
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Stronger engagement with business groups such as Chambers is essential to effectively communicate the merits of planned capital investment and spatial planning alignment set out in Ireland 2040. The maintenance of an active and detailed project tracker is essential to certainty and transparency.14
Rationale The alignment of a national planning framework, made strong by a national development plan, regional economic and spatial strategies, and local authority development plans, each backed by statutory instruments and established protocols offers a stability and tenacity of vision that is quite unique internationally. It creates a stable and predictable environment for investment. With the right Government interventions to provide market confidence and project viability, in parallel with a strong private sector, there is every reason for delivery to be successful. It is essential that the vision and delivery of this vision is carefully and relentlessly communicated in a clear manner to ensure stakeholder understanding, support and success.
CORK CHAMBER SUBMISSION
Is there anything else you would like to add? Answer The 2:1 public transport spend ratio identified in the Programme for Government15 offers a great opportunity for Cork in terms of the progression of long-standing strategic roads projects, and the commitment to the Cork Metropolitan Area Transport Strategy, which includes rail, light rail, bus connects, cycle, greenway, and pedestrian investment. It is clear that all new projects must incorporate multi modal elements, to meet with dynamic user preferences and climate obligations. The Cork region has been one of the fastest growing regions in the state in terms of population and employment growth over the last 20 years. Between 1996-2016 the population of Cork has grown by 122,000 people. Unfortunately investment in transport and water services infrastructure in particular has not kept pace with this level of growth and therefore in the prioritisation of projects the analysis of projects must include an analysis of the historical as well current infrastructural spending profiles. A prioritisation analysis of the spending Departments must also align with the aims of the National Planning Framework to develop a major urban centre outside of Dublin that can act as a counterbalance.
14 https://www.gov.ie/en/publication/6db7c4-investment-projects-and-programmes-tracker/ 15 https://assets.gov.ie/94092/50f892b9-a93e-43fc-81d1-778ff9954d9f.pdf
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Cork’s Metropolitan area has a population of 305,000 at the 2016 census and population growth has accelerated. It is the only regional urban centre of this scale and therefore should be prioritised for infrastructural investment. In our view the investments identified in the Cork Metropolitan Area Transport Study and those in the National Development Plan must be accelerated. It is also clear that long standing strategic road projects play a critical role in a functional multi modal region. The M28 for example, not only unlocks the potential of the Port of Cork and IDA lands, but unlocks the city docklands and Tivoli for high density brownfield regeneration. The M20 corridor upgrade will support multimodal transport connecting Ireland’s second and third largest city regions, while removing intense traffic levels and HGV’s from town centres along the existing route. Following European examples of urbanism it must be acknowledged the role that certain types of road projects can play in developing a more sustainable urban environment by facilitating the relocation of Ports and associated heavy goods vehicles, the construction of ring roads to facilitate the removal of trucks and other heavy goods vehicles from the City Centre which in turn creates the space for large scale urban regeneration, the construction of parks, cycle ways and other active travel measures.
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Rationale It is clear that a significant shift to multi modal is required and that significant investment in CMATS and strategic transport corridors will ensure that Cork meets demand and is globally competitive across the diversity of transport modes required for a functioning, thriving, contemporary city region.
Conclusion Cork Chamber strongly supports the broadranging and positive economic, societal, and environmental impacts of the delivery of the National Development Plan. We believe that the proactive engagement with the business community can be instrumental to facilitate fully representative discussions of future pathways and actions that are informed via ground up engagement.
CORK CHAMBER SUBMISSION
Fitzgerald House, Summerhill North, Cork, T23 TD90, Ireland. T +353 (021) 4509044 E info@corkchamber.ie
CorkChamber.ie