D28a Kilcreen zoning

Dear Sir/Madam,

We wish to make a submission to the proposed Development Plan under the heading of Zoning particularly Residential (Low Density) at Kilcreen Lodge, Kilkenny.

The area in question is outlined on the enclosed maps (Development Plan 2008-2014) Zoning Objectives Map. ( a hard copy of the map will be lodged before the 23rd.August) This site which is part of the Kilcreen Lodge Estate is zoned Residential (Low Density) in the 2008- 2014 Development Plan and subsequently Zoned for Phase 2 development in Variation 1 on the Zoning Objectives Map of the 2008-2014 Development Plan.

This land is now proposed to be Zoned as Residential (Low Density) Phase 2 in the proposed City and Environs Development Plan 2014-2020.

Phase 2 Zoning is described in Proposed Housing Land and Phasing as,

‘developments for multiple housing will not be permitted on Phase 2 lands during the lifetime of this plan. Expansion of existing land uses within the Phase 2 lands will be considered on a case by case having regard to the potential impacts on the strategic nature of the Phase 1 lands and general planning considerations………. and provision of adequate services. The proposed phasing is based on the principals of sustainable development including a sequential approach to the expansion of the city, the planning histories of the area, the likelihood of sites coming forward for development…’ 

The following reasons set out our submission and reasons for these lands to be rezoned as Phase 1 in the new Development Plan.    

Chapter 1 of the Planning Guidelines under the heading of National Policy Objectives  states under Sustainable Residential Development 1.9.

‘ The range of relevant national policies summarised above can be distilled into a series of high-level aims for successful and sustainable residential development in urban areas. Housing developers, their design teams, the planning system, and the community they serve, share a common goal to create high quality places which:

Prioritise walking, cycling and public transport and minimise the need to use cars. The subject site of all of the zoned sites is the only one which is within walking distance of the City Core.

Deliver a quality of life which residents and visitors are entitled to expect in terms of amenity, safety and convenience. The subject site is the most beautiful site available within the City with mature trees and views of the lakes in the grounds of Kilcreen Lodge all of which would be very attractive for senior company and professional newcomers to the City.

Provide a good range of community and support facilities, where and when they are needed and that are easily accessible. All of the community and support facilities are already established in the area.

Present an attractive, well maintained appearance, with a distinct sense of place and a quality public realm which is easily maintained.

Are easy to access for all and to find one’s way around.

Promote the efficient use of land and of energy and minimise greenhouse gas emissions.

Provide a mix of land uses to minimise transport demand.

Promote social integration and provide accommodation for a diverse range of household types and age groups.


Enhance and protect the green infrastructure and biodiversity and

Enhance and protect the built and natural heritage.’        


Chapter 2 of the Planning Guidelines (2009) states under ‘Role of development plans and local area plans’ at  2.2.

‘Fundamental questions to be addressed at the outset of the planning process include:

The amount and type of new housing required to meet the needs of the wider area, including the provision of social and affordable housing, and the range of different dwelling types and sizes, including live/work units.

The need to adapt a sequential approach to the zoning of residential lands, extending outwards from the centre of an urban area, as recommended in the development plan guidelines (DoEHLG, 2007)

The subject site is closer to the City Core than all of the other Phase 1 Residential (low density) zoned sites.

Adequate existing public transport capacity available or likely to be available within a reasonable development timescale;

The relationship and linkages between the area to be (re)developed and established neighbourhoods including the availability of existing community facilities, and the provision of pedestrian and cycle networks.

The benefits that mixed use developments can bring.

The need to create an overall design framework for the (re)development are and the potential for non statutory guidance – such as design briefs- to supplement the local area plan.

The scale, location and type of public open space. The gardens of Kilcreen lodge which is a private home are proposed to be zoned as open space and are by far the most attractive landscaped space within the City which will provide very desirable sites for which there is considerable demand..

The setting of appropriate density levels within the area.

Protection and enhancement of biodiversity and the green infrastructure.

Adaption to impacts of climate change; and

The avoidance of natural hazards such as flood risk and avoidance of increased flood risk for downstream areas.


under ‘Sequential approach’ at


When land is zoned in a development plan without the benefit of a more detailed local area plan designation, the development plan should identify where practicable the sequential and co-ordinated manner in which zoned lands will be developed, so as to avoid a haphazard and costly approach to the provision of social and physical infrastructure. The sequential approach as set out in the Department’s Development Plan Guidelines (DoEHLG 2007) specifies that zoning shall extend outwards from the centre of an urban area, with undeveloped lands closest to the core and public transport routes being given preference, encouraging infill opportunities and that areas to be zoned shall be contiguous to existing zoned development lands and that any exception must be clearly justified in the written statement of the development plan.

The subject site should be the first of the residential zoned (Low Density) sites to be developed with reference to the above national policies.


The provision of water and sewerage investment programmes by planning authorities must also be related to the sequencing of residential lands and must also be integrated with the provision of public transport, schools, community and leisure facilities etc. This will involve keeping up the close contact with other agencies, which would have occurred during the plan making period.

The subject site has all of the necessary infrastructure on site including water, gas, foul and storm drainage.




‘ The purpose of phasing is to ensure that the physical and social infrastructure required is provided in tandem with the residential development.’

Low Density Residential is described in the Draft Plan as;

‘ Low density housing is defined as not more than 10 units per hectare (4 units per acre) on average and must have regard to the character of the area’.

There are 5 sites designated Low Density Residential in the Draft Plan. ( See enclosed map.)

  1. Talbots Inch.
  2. Cnoc Baun.
  3. Rath Ullard.
  4. Dublin Road.
  5. Sion Road.


  1. Talbots Inch. This site consists of approximately half an acre and appears to be completely developed which does not appear to leave any opportunities for development.
  2. Cnoc Baun. This site is approximately 1 acre with the possibility of developing approximately 4 houses. This site is over one and a half kilometres from the City Core with no prospect of public transport.
  3. Rath Ullard . This is a site of approximately 7-8 acres most of which appears to have been developed or has permitted development of a much higher density than residential (Low Density) The remaining 4 acres would provide development for approximately 16 houses. This site is over one and a half kilometres from the City Core with some prospect of public transport as it is adjacent to much higher density development.
  4. Dublin Road. This is a mature development area with opportunities for approximately 2-3 houses. This site is over one and a half kilometres from the City Core with no prospect of public transport.
  5. Sion Road. This is a site of approximately 1 acre with potential for approximately 4 houses. The site is over 1 kilometre from the City Core with no prospect of public transport. 


The site which is the subject of this submission is 800m from the City Core and is within walking and cycling distance of all of the city’s facilities.

The subject site was designated Phase 2 as part of variation 1 to Kilkenny City and Environs Development Plan. The reduction in zoning it states is based on a ‘compact city’ with one of its principals being:


‘ Sequential approach ( zoning should extend outwards from the core of an urban area, with undeveloped lands closest to the core and public transport routes being given preference.’ 


With this in mind the subject site should be the first of the low density sites to be developed and not relegated to Phase 2 for development after 2020.

 again ;

‘The proposed Phasing is based on the principals of sustainable development including a sequential approach to the expansion of the city, the planning histories of the area, the likelihood of the sites coming forward for development and the criteria outlined above.’

The sites furthest away from the City Core have been promoted to Phase 1 and the site closest to the City Core relegated to Phase 2 of the proposed development plan which the enclosed map shows.

The County Managers submission states

‘ You need a business location with exceptional global connectivity and the capacity to attract high calibre people to live and work……’

As you are aware Kilcreen Lodge is a large protected structure with a complex landscape including several water features for which the cost of upkeep is considerable. We propose that the proposed Low Density Residential development becomes a managed estate with annual contributions coming from the occupants to pay for the upkeep of the gardens and lakes etc. This will ensure that the landscape is maintained to a very high standard into the future.

We enclose for your information a map with a detailed proposal for the zoning of the Site. (a hard copy of the map will be sent under a different cover).

See also our submission regarding zoning for wedding receptions etc. at Kilcreen Lodge.

A survey of the major auctioneers in Kilkenny confirms that there is a considerable demand for houses in Kilkenny in the €1,000.000.00 bracket.

Given the limited options to meet the housing needs of high performing individuals in key positions who can develop essential facilities and create employment and who have a track record in achievement in areas beneficial to the City we ask that the opportunity to make the subject site which meets all of the criteria for sustainable development, available for inclusion in Phase 1 residential ( low density) zoning of the proposed development Plan.

Martin Larkin BA Dip. Arch. RIAI. 

First Name: 
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