1. Introduction
I welcome the presentation to the public of the Draft Development Plans and the opportunity to make my submission. A great deal of work by the County Council and its agents is evidenced in the Draft Plan and its four volumes.
2. Submission
I would like to submit the following to the Development Plan process as part of the process of the partnership process referred to in the mission statement and in respect of the promotion of Kilkenny's sustainable economic, social and cultural development for current and future generations.
Note: I have numbered my submission points A to C for ease of reading.
A. Consultation and partnership
Kilkenny County Council states its mission as
" ... to work in partnership with the people of Kilkenny and relevant agencies to deliver quality services and to promote sustainable economic, social and cultural development for current and future generations."
Kilkenny Draft County Development Plan 2014 - 2020, 1.7, page 6
At time of writing, five thousand signatories have signed an online and street petition calling for the Ring Road to be completed (from the Castlecomer to Callan Roads) as a priority over the Central Access Scheme. The numbers of signatures has continued to grow since the
petition signatures were presented to both the County and Borough Councils (June, 2013).
Signatories to both the online and street petitions are unanimous in calling for the heritage of Kilkenny to be enhanced and preserved in situ and not deconstructed or demolished. They call for the proposed degradation of Kilkenny heritage through construction of the CAS bridge
and route to stop. They call for the medieval streetscape of the outer Cathedral Close and The Irishtown to be preserved. The common response to the proposal to construct the CAS is that this project is nonsensical and goes against international, European, national and
common sense modem principles and practice for planning for both heritage conservation and city traffic management.
A 1 I submit that the council, as a matter of urgency, ensure that the call by over 5,000 people reflecting the voices of Kilkenny city and county residents, visitors from Ireland and overseas, experts and heritage professionals, is taken into account in proceeding to complete the Ring Road from the Castlecomer to Callan roads as a priority over the CAS.
A2 I submit that the council put into practice the aspirations of the mission statement by responding in good faith to the call to Prioritise completion of the Ring road over the Central Access Scheme.
B. Traffic
The Draft County Development Plan 2014 - 2020 refers under 11.7.6 (Page 188) to Road Improvement Projects including Regional Planning Guidelines and priorities to
• Support the completion of the Kilkenny Ring Road
Completion of the Ring Road from the Castlecomer to Callan roads is supported by large numbers of people who are concerned that proposals to complete the 7 Km of the Ring Road are not prioritised. They express serious concern that in the absence of the completed ring road, traffic will be pressed into the city via the Central Access Scheme. There is especially serious concern at the numbers of HGVs that will continue to be pressed into the city's residential areas if the Ring road and its spokes are not developed.
The Revised EIS shows traffic estimates for 2015 and 2030 (Volume 4 - Appendices, pages
132 - 135). Very large numbers of HGVs are estimated to travel through Freshford road north of Grange road, between Kenny's Well road and Black Mill Street, on the R909 between the N76 and Circular road and on the R909 between Circular road and Old Callan road. See table
of traffic estimates below.
The estimates show that between N76 and Circular Road there will be an estimated 377 HGVs daily in 2015 if no change is made to the roads system and 516 HWs daily by 2030. These figures increase to 408 and 559 HGVs daily for the years in question if a change is made to the road system. Estimated HGV traffic for the R909 between Circular road and Old Callan road are also extremely high as shown in the revised EIS and in appendix 1 below. The estimated numbers of HGVs between Kenny's Well road and Black Mill Street are much smaller than for Circular road and Old Callan road. The estimated numbers of HGVs on the R695 east of Circular road (Kenny's Well road) is 51 daily by 2015 and zero by 2030 if no change is made. This becomes 104 by 2015 and 0.03 by 2030 if a change is made.
These figures are in contradiction with traffic counts carried out by residents of Kenny's Well road and environs. Up to fifty (50) HGVs per hour have been counted by residents of the area at certain times of the day. These HGVs are travelling to and from the N76 and from other depots such as Belview Port via the N76 (Ring road and Callan roads) through Circular road and Kenny's Well road to continue to Lord Edward Street and the Tullaroan road or to the Freshford road via Butts Green. HGVs are not permitted to travel through the Stephen's Street and Dominic Street routes. The large numbers of HGVs estimated in the CAS revised EIS to be travelling through the Old Callan road and through Circular road are travelling via Circular road and Kenny's Well road. This is not reflected in the estimates. Indeed the estimates appear to show no onward route for these HGVs unless they are travelling into the city streets of John Street, High Street, etc.
B1 I submit that the traffic estimates which informed the councils planning for the Central Access Scheme are out of date and do not reflect the actual traffic and HGV situation in the areas referenced. They do not adequately account for the numbers of HGVs that would be directed through the CAS and Dean Street in both directions. The estimated smaller numbers of HGVs pressing into the route between Abbey Street and Water Barrack fails to take into account the HGVs that would travel via the CAS and Dean Street en route to the N76 via Circular road and Kenny's Well road, to the Tullaroan road via Lord Edward Street and to the Freshford road.
B2 I submit that the Outer Ring road between the Castlecomer and Callan roads should be completed in order to relieve inappropriate HGV and heavy traffic through residential streets of Circular road, Kenny's Well road, Black Mill Street, Butts Green, Lord Edward Street and Grange road.
B3 I submit that Kilkenny County Council work with the relevant authorities to prioritise the completion of the Ring Road from the Castlecomer to Callan roads. I submit the consequent routeing of heavy traffic and HGVs through the CAS and Dean Street.
B4 I submit that the routing of traffic through the significant heritage areas of Kilkenny city and through residential areas is contrary to international, European and national policies and directives and should not proceed.
C Heritage
The Department of Environment, Heritage and Local Government requirement in the Framework and Principles for the Protection of the Archaeological Heritage (DoEHLG 1999, 3.8.5ii) is that 'development must (except in exceptional circumstances) be carried out in such
a way as to preserve existing street patterns'.
The proposed CAS project and the Environmental Impact Assessment (May, 2008) do not adhere to the requirement as set out by the department's Framework. The Chief Archaeologist at the Department of Arts, Heritage and Gaeltacht stated in a letter to
the County and Borough Council's consultants in July 2007 that:
"It will completely alter the street pattern in the Parliament Streetllrishtown area. It cuts though the precinct of St Canice's Cathedral. This precinct has been altered in an unsympathetic way already and this further impact would be unacceptable."
6 'Drisceoil, Coilin (2008) The Central Access Scheme for the City of Kilkenny, An Bard Pleanala oral Hearing December 2008. Statement of Evidence by the Conservation Committee of the Kilkenny Archaeological Society, Appendix 1, item 1. Kilkenny Archaeological Society.
C1 I submit that the CAS as referred to in the Kilkenny Draft City & Environs Development Plan 2014 - 2020 and the initial (2008) and revised Environmental Impact Assessment (2011) does not adequately address the preservation of existing street patterns.
C2 I call on the County Council to stop all plans to proceed with the destruction and degradation of the existing street pattern at Vicar Street and St Canice's Place. 

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