Transport Infrastructure Ireland

Dear Sir/Madam,

Transport Infrastructure Ireland (TII) welcomes consultation on the Draft County Development Plan, 2021 – 2027, and the opportunity to comment on emerging policies and development objectives scheduled in the Draft Plan.

TII’s observations, provided in the following submission, seek to address the safety, capacity and strategic function of the national road network in accordance with TII’s statutory function and the provisions of official policy. To that effect TII provides the following comments for the Council’s consideration.

1. MANAGING EXCHEQUER INVESTMENT AND STATUTORY GUIDANCE

As outlined in observations made by TII in relation to the County Development Plan pre-draft consultation stage, the Trans-European Transport Networks (EU TEN-T) are a planned set of transport networks across Europe. The EU TEN-T Regulations target a gradual development of the transport network with the core network a priority (by 2030) followed by the remainder of the comprehensive network (by 2050). The EU TEN-T Regulations define the objective of increasing the benefits for road users by ensuring safe, secure and high-quality standards for road users and freight transport co-ordinated to achieve integrated and intermodal long-distance travel routes across Europe.

In Ireland, the core network currently consists of the route from Northern Ireland via Dublin to both Cork/Ringaskiddy and Limerick/Foynes. As a result of this directive, the M7 and M8 through Laois have been identified as part of the EU TEN-T Core Network which has repercussions and action requirements for policies and objectives which should be considered in the preparation of the new County Development Plan.

In addition to the M7 and M8, the N77, N78 and N80, national secondary roads, facilitate important regional and inter-regional connectivity within and through County Laois.

Project Ireland 2040|National Development Plan, 2018 – 2027, outlines the investment priority to ensure that the existing extensive transport networks, which have been greatly enhanced over the last two decades, are maintained to a high level to ensure quality levels of service, accessibility and connectivity to transport users. Government also includes the objective to maintain the strategic capacity and safety of the national roads network, including planning for future capacity enhancements, in National Strategic Outcome 2 of the National Planning Framework.

The routes identified above are important strategic national roads and give access to regional and international markets, including through strategic airport and port locations as well as linking with other strategic national roads.

In this regard the Authority welcomes Objective TRANS 1, which aims to protect the safety, capacity and efficiency of the National Roads Network in accordance with the SPNRG (2012) and the Trans-European Networks (TEN-T) Regulations. However, the Authority respectfully suggests a slight modification of the wording of this objective as follows (suggested text annotated in red blow):

TRANS 1: Maintain improve and protect the safety, capacity and efficiency of Laois’s roads network and associated junctions in accordance with the Spatial Planning and National Roads Guidelines for Planning Authorities, DECLG, (2012) and the Trans-European Networks (TEN- T) Regulations and safeguard the strategic function of the national road network.

 

The Authority also welcomes Objective TRANS 4, which aims to prevent inappropriate development on lands adjacent to the existing national road network inter alia. However, the Authority respectfully suggests the following modification (suggested text annotated in red blow):

TRANS 4: Prevent inappropriate development including intensification of use on lands adjacent to the existing national road network, which would adversely affect the safety, current and future capacity and function of national roads and having regard to possible future upgrades of the national roads and junctions.

Within the above strategic context, the Authority requests that a review and amendment of these sections is undertaken to account for the strategic issues identified for inclusion in the Development Plan prior to formal adoption.

2.  SECTION 28 GUIDANCE: DoECLG SPATIAL PLANNING AND NATIONAL ROADS GUIDELINES FOR PLANNING AUTHORITIES/GENERAL POLICY

2.1 Access to National Roads

TII notes and welcomes Section 10.1.3.2 referring to National Roads.

The Authority notes that TRANS 4 above refers to adjacent development to national roads, safety, capacity and national roads’ junctions inter alia. However, TII would welcome a specific objective, which would specifically address the issue of protection of national road junctions in addition to motorway junctions. In this regard, the Authority respectfully suggests the modification of the following objective (Suggested text annotated in red blow):

TRANS 16: Prohibit development seeking access onto the National Roads and Motorway network and associated junctions through the implementation of the ‘Spatial Planning and National Roads – Guidelines for Planning Authorities’.

2.2 Exemptions

TII would highlight that the Spatial Planning and National Road Guidelines for Planning Authorities states that the provisions related to national roads applies to all categories of development, including individual houses in rural areas, regardless of the housing circumstances of the applicant.

Related to the above point, it is noted that Objective TRANS 19 includes provision for replacement houses in relation to development on national roads.

TII advises that there are issues relating to the potential implications of intensification of access and road safety concerns, which need to be addressed to ensure compliance with the Section 28 Ministerial Guidelines relating to Spatial Planning and National Roads Guidelines for Planning Authorities.

It is noted that otherwise the draft plan includes no provisions with reference to ‘exceptional circumstances’ as per Section 2.6 of the Spatial Planning and National Roads Guidelines. TII remains 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.

2.3 Local Area Planning

TII notes that local area planning for Portlaoise and Mountmellick are deferred to future local area planning under Objective CS08. Also, Objective CS09 refers that a Joint Local Area Plan will be prepared for Carlow/Graigecullen in conjunction with Carlow County Council. TII would welcome consultation on the above Local Area Plan processes having regard to the significant national road interactions that exist in relation to the towns identified.

The Draft Plan also refers to an objective under TRANS 5 which aims to Prepare a Local Transport Plan for Portlaoise in compliance with RPO 8.6 of the RSES. TII would welcome consultation on the Local Transport Plan processes having regard to the significant national road interactions that exist in relation Portlaoise.

It is noted that Objective TRANS 5 includes reference to supporting the vision of the J17 National Enterprise Park Masterplan within the context of preparing the Portlaoise Local Transport Plan. TII considers it critical that local area planning and transport integration in the Togher Masterplan area should continue to be co-ordinated within the strategic context of the Portlaoise Local Area Plan. In that regard, comments previously made in relation to the Togher Masterplan remain the position of TII.

In addition, TII previously advised the Council of concern that zoned Enterprise and Employment lands to the south of Portlaoise at the existing ‘Midway’ site in Togher, adjoins the national road, N77 national secondary road, outside the reduced 50 – 60kph urban speed limit.

The Togher Masterplan in 2010 identified that further development of this area will require upgrades to the junction on the Abbeyleix Road. Therefore, in TII’s opinion, it is important that access to the Midway lands and adjoining zoned lands are also fully addressed as part of the Local Area Plan Review and having regard to the Councils previous commitments in relation to this matter.

The Draft Plan under Table 2.3 of Core Settlement and Strategy includes the commitment to undertake the preparation of the Local Transport Plans with respect of other towns and villages which have routes for roads objectives for future development. TII would welcome consultation on the preparation of the Local Transport Plans where there may be implications for the strategic national road network in the area. TII considers that the preparation of the Local Transport Plans should occur in advance of the Land Use Plans and therefore, fully inform Council decisions related to zoning and development objectives.

TII advises that the DoECLG Spatial Planning and National Roads Guidelines for Planning Authorities require that planning authorities exercise particular care in their assessment and management of development proposals in the Development Plan relating to the zoning of locations at or close to junctions on the national road network where such development could generate significant additional traffic, thereby potentially compromising the capacity and efficiency of the national road/associated junctions and possibly leading to the premature and unacceptable reduction in the level of service available to road users.

Therefore, in relation to the preparation of such plans, TII requests that where there are implications for the safe and efficient operation of the national road network, existing and proposed, that appropriate consultation with TII would occur.

2.4 Master Plans

Associated with the Local Area Plans above, TII notes that the Draft Development Plan refers in Section 2.10.1.1 to a Master Plan for lands at Togher with regard to a Strategic Employment Zone, referred to as the J17 National Enterprise Park Masterplan.

In addition, Policy objective HPO 19 refers that opportunity sites identified in the County Development Plan shall be subject of a Masterplan for each site.

As referred in the Authority’s previous submission to this plan TII welcomes the approach adopted with respect of the Togher lands (J17 National Enterprise Park Masterplan document), which was adopted under the Portlaoise Local Area Plan 2018 – 2024. However, with respect of the proposal under HPO 19, which refers that said opportunity sites will be subject of a masterplan for each site, the Authority respectfully draws the Councils attention to the provisions of both the DoECLG Local Area Plan Guidelines and DoECLG Sustainable Residential Development in Urban Areas Guidelines.

The Guidelines advise that such plans can supplement or complement but not replace statutory plans. Also, the DoECLG Sustainable Residential Development in Urban Areas Guidelines advise that if it is intended to use such

non-statutory documents for development management, planning authorities should incorporate them in the development plan or local area plan for the area by way of variation and where possible, public consultation should be integrated into the preparation on non-statutory frameworks.

Where such Masterplan proposals have implications for the strategic national road network in the area, TII would welcome consultation. The Authority also requests that any masterplan proposed for Opportunity Sites or any other Masterplans proposed to be adopted by the Planning Authority, shall have regard to the above policy requirements, the provisions of the DoECLG Spatial Planning and National Roads Guidelines, where relevant, and be subject to appropriate stakeholder consultation.

2.5 Retailing

TII acknowledges the support for concentrating retail uses in established town centres, the presumption against large scale out of town retailing and the application of the sequential test included under Section 7.2.7 of the draft plan. TII welcomes the above approach. However, TII would welcome the following objective being included in the retail/town and village centre management objectives:

 

RTP 18: There will be an explicit presumption against large out of town retail centres located adjacent or close to existing, new or planned national roads/motorways having regard to policy outlined in the Retail Planning Guidelines, 2012.

 

TII advises that the planning authority will also be aware that Section 2.8 of the DoECLG Spatial Planning and National Roads Guidelines indicates the requirement for a forward planning approach to the provision of off-line motorway service areas at national road junctions and also addresses road-side service facilities on non-motorway national roads and their junctions.

The Authority would welcome the above provisions of the DoECLG Guidelines reflected in the County Development Plan, prior to adoption, in the interests of safety and adherence to the provisions of official policy.

2.6 Rural Development

It is noted that Section 3: Climate Change & Energy, Section 6: Economic Development, Section 9: Rural Issues and Section 10: Infrastructure of the Draft Plan outline a number of policies associated with rural development which understandably seek to facilitate residential, enterprise and employment, etc. proposals in a rural environment. TII acknowledges and supports the need to sustain rural communities.

As already highlighted, TII would welcome inclusion in the Draft Plan, in the interest of clarification and as an advisory to potential applicants for development in rural areas, of the requirement to adhere to the provisions of official policy in relation to development accessing national roads. An appropriate cross reference in these Sections with Objective TRANS 16 and TRANS 17 of the Draft Plan would be welcome as it is considered important to give early assistance to applicants in the preparation of any subsequent planning application where there may be implications for the strategic national road network in the area.

3. TRANSPORT PLANNING AND NATIONAL ROAD SCHEMES

3.1 National Road Scheme Planning

The Authority’s priorities in relation to national roads in County Laois includes the maintenance of the existing national road network, including junctions, and safeguarding the Exchequer investment in national roads to date.

While minor national road schemes may be identified for inclusion in the Plan, the Council will be aware that any additional improvements relating to national roads identified at a local level should be done so in consultation with and subject to the agreement of TII. The Council will be aware that TII may not be responsible for the funding of any such schemes or improvements, their implementation may be subject to budgetary constraints, prioritisation and the adequacy of the funding resource available to the Authority. While proposals should be developed complementary to safeguarding the strategic function of the national road network, proposals impacting on the national road network should be developed in consultation with and subject to the agreement of TII.

4. ANCILLARY POLICY PROVISIONS AND ISSUES

4.1 Safeguarding National Road Drainage Regimes

TII would welcome consideration being given to including a new objective associated with Section 10.1.3.2 National Roads relating to protection of national road drainage regimes.

Significant improvements to the national road network have been overseen by Laois County Council. There is an onus and a policy requirement on road and planning authorities to safeguard the national investment made. In that regard, TII has experienced a number of instances nationally where private development proposals have accessed or sought to access national road drainage regimes to dispose of surface water drainage.

National road surface water drainage regimes are constructed with the objective of disposing of national road surface water, it is important that capacity in the drainage regime is retained to address this function.

Having regard to the extensive national road and motorway network in Laois, TII would welcome a new Objective included in the Development Plan outlining that;

‘The capacity and efficiency of the national road network drainage regimes in County Laois will be safeguarded for national road drainage purposes’.

4.2 Renewable Energy and Grid Connection

Section 3 of the Draft Plan refers to Climate Action & Energy. In relation to Solar PV development proposals, TII requires the submission of Glint and Glare Assessment to assess impacts on, among other matters, roads.

TII would particularly emphasise the importance of such assessments where there may be implications for the safety and efficiency of the strategic national road network given the high speed and highly trafficked nature of such roads. It is important that mitigation proposed is robust from the earliest stages of construction and/or commissioning and is sufficient to function on a year-round basis.

In addition, for all renewable energy developments requiring grid connection to the national grid, TII recommends that an assessment of all alternatives for grid connection routing should be undertaken. It is considered inappropriate to only consider utilising the strategic national road network as a grid connection route when alternatives are available.

In TII’s experience, grid connection accommodated on national roads has the potential, inter alia, to result in technical road safety issues such as differential settlement due to backfilling trenches and can impact on ability and cost of general maintenance and safety works to existing roads. Constraints and costs arise to on-line national road improvements and upgrades also.

Having regard to the foregoing, TII would welcome an objective included in the adopted Development Plan, in relation to renewable energy and in relation to safeguarding the national road network, indicating that it should be demonstrated that an assessment of all alternative grid connection routing options have been undertaken prior to any proposals being brought forward for grid connection routing utilising the national road network.

5. OTHER SPECIFIC POLICIES AND OBJECTIVES

5.1 TII Publications

In relation Section 7.3.2, TII advises that Design Manual for Roads and Bridges (DMRB) has been superseded and all standards are now detailed as TII Publications.

The Authority recommends including reference to TII Publications as the relevant technical design standard that will be applied to development impacting national roads.

5.2 Traffic and Transport Assessment (TTA)

TII acknowledges that the requirement for TTA is outlined in under Transportation Development Management Standard; DM TRANS 4. While reference to the (TII) Traffic and Transportation Guidelines is welcome, TII would also welcome the Draft Plan including reference to Table 2.3 of the TTA Guidelines. Table 2.3 addresses the application of sub-threshold criteria for Traffic and Transport Assessment, particularly where national roads are impacted.

TII would welcome the Draft Plan being updated to reflect the requirements of Table 2.3 of the TII Traffic and Transport Assessment Guidelines that address the requirement for TTA in relation to sub-threshold development.

The TII TTA Guidelines relate specifically to development proposals with implications for the national road network and outline appropriate thresholds and sub-threshold limits at which TTA are required where there may be implications for the national road network.

5.3 Road Safety

TII’s initial observations on pre-draft consultation outlined the requirement for Road Safety Audit (RSA) and Road Safety Impact Assessment (RSIA).

In the interests of clarification;

• • • Road Safety Audit (RSA) involves the evaluation of road schemes during design, construction and early operation to identify potential hazards to all road users. RSA is to be carried out on all new national road infrastructure projects and on any schemes/proposal which results in a permanent change to the layout of a national road (refer to TII Publications GE-STY-01024 Road Safety Audit).
    • Road Safety Impact Assessment (RSIA) is described in the EU Directive on Road Infrastructure Safety Management (EU RISM) 2008/96/EC as a strategic comparative analysis of the impact of a new road, or for substantial modifications to an existing road, on the safety performance of the road network (refer to TII Publications PE-PMG-02001 Road Safety Impact Assessment).

TII welcomes reference to the requirement for RSA in Section 10.1.4.2. This section also refers to the Design Manual for Roads and Bridges. Reference to the DMRB should be updated to TII Publications.

TII would welcome the Draft Plan clarifying that any development proposal that results in alteration to a national road will be subject to RSA in accordance with TII Publications GE-STY-01024 Road Safety Audit.

5.4 Signage

TII has published the Policy on the Provision of Tourist & Leisure Signage on National Roads (March 2011). The purpose of this document is to outline TII’s policy on the provision of tourist and leisure information signs on national primary and national secondary roads in Ireland.

TII notes and welcomes the intention to collaborate with TII regarding signage under Objective IAE 2 and the Authority notes that Sections 4, 5, 9 and 10 of the Draft Plan also refer to signage. However, TII recommends that where there are implications for the national roads network regard should be had to TII’s Policy on the Provision of Tourist & Leisure Signage on National Roads (March 2011) in addition to Section 3.8 of the DoECLG’s Spatial Planning and National Roads Guidelines. TII would welcome Objective IAE 2 to be modified to reflect this requirement. (Suggested text annotated in red below).

IAE2 (a)	Collaborate with Fáilte Ireland, the Transport Infrastructure Ireland (TII) and other key stakeholders in the development and implementation of a signage programme associated with Ireland’s Ancient East to include branded orientation signage and roadside signage
IAE2 (b)	Have regard to TII’s Policy on the Provision of Tourist & Leisure Signage on National Roads (March 2011) in addition to Section 3.8 of the DoECLG’s Spatial Planning and National Roads Guidelines.

It is requested that the Draft Plan is updated to incorporate reference to TII’s Policy on the Provision of Tourist & Leisure Signage on National Roads (March 2011).

5.5 Noise

TII notes and welcomes that the Draft Plan includes specific reference to the requirements of S.I. No. 140 of 2006 Environmental Noise Regulations in Policy NEP 24.

5.6 Transition Zones

The Council will be aware of TII Publication ‘The Treatment of Transition Zones to Towns and Villages on National Roads’ (TII Publications DN-GEO-03084), which should be referenced in the Draft Plan.

The TII Publications Standard describes the requirements that shall be implemented on National Roads on the approaches to towns and villages in terms of the provision of traffic calming measures and pedestrian crossings. National Roads within 60km/h zones can traverse many areas with very different characteristics such as low- density residential areas, industrial areas, mixed use neighbourhoods and town and village centres. This requires different design solutions within each of these different contexts.

In that regard, TII requests that the Draft Plan acknowledges that TII Publication ‘The Treatment of Transition Zones to Towns and Villages on National Roads’ (TII Publications DN-GEO-03084) will be applied in combination with DMURS principles on national roads in urban areas.

TII welcomes the reference to Transition Zones under TRANS 18, however, it is respectfully requested that this objective be modified as follows (Suggested text annotated in red below):

TRANS 18

a. Facilitate a limited level of new accesses or the intensified use of existing accesses to the national road network on the approaches to or exit from urban centres that are subject to a speed limit zone between 50kmph and 60kmph otherwise known as the transition zone. Such accesses will be considered where they facilitate orderly urban development and would not result in a proliferation of such entrances, leading to a diminution in the role of these transitional zones. A Road Safety Audit, prepared in accordance with TII Publications: GE-STY-01024 Road Safety Audit, shall be submitted where appropriate.   b. Have regard to the TII Publication ‘The Treatment of Transition Zones to Towns and Villages on National Roads’ (TII Publications DN-GEO-03084).

CONCLUSION

The Authority acknowledges the significant undertaking for the Council in drafting a Development Plan and the requirement to consider and address a multiplicity of factors in developing a sustainable spatial planning framework not just issues relating to national roads.

The Authority acknowledges and welcomes the generally positive alignment in the Draft Plan with official policy concerning development planning and development management and national roads and compliments the Council in this regard. Notwithstanding this there are a number of specific interactions between land use policy and development objectives included in the Draft Plan and the strategic national road network in County Laois that the Authority considers require review prior to the adoption of the Development Plan to ensure consistency with official policy and in order to safeguard the strategic function of the national road network in the area.

The Authority is available to meet the Executive of the Council to discuss any issues arising in the foregoing or other matters related to the Development Plan and national roads.

It is respectfully requested that the above observations are taken into consideration prior to the adoption of the Laois County Development Plan, 2021 – 2027.