Introduction and Background
RE: DRAFT LAOIS COUNTY DEVELOPMENT PLAN 2021-2027
SLR Consulting Ireland acts as planning and environmental advisors to Roadstone Limited, Fortunestown, Tallaght, Dublin 24. This submission relating to the Draft Laois County Development Plan 2021 – 2027 has been prepared on their behalf.
ROADSTONE LIMITED
Roadstone Ltd. was formed in 2009 by the amalgamation of three of the construction materials businesses operated by CRH in Ireland, which were Roadstone Dublin Ltd., Roadstone Provinces Ltd. and John A. Wood Ltd.
The company is Ireland’s leading supplier of aggregates, construction and road building materials and it employs several hundred people throughout the country.
Roadstone forms part of CRH, which is an international building materials group. It was founded in the 1930s and became part of Cement Roadstone Holdings (CRH) plc in 1970, following the merger of Roadstone and Cement Ltd. CRH is the leading global diversified building materials business, employing 79,200 people in 30 Countries across the globe.
Roadstone Limited has property assets within the Laois County Council administrative area, refer to Figure 1 below. These are located at:
- Lisduff; and
- Ballyadams.
These property assets contain aggregate resources with the potential to support the local, regional, and national economy.
BASIS OF THE SUBMISSION
National and Regional Policy Context
The importance of the extractive industries to the wider economy and the need to protect the operations of working quarries and proven aggregate resources is firmly established in national and regional planning policy.
Project Ireland 2040, the National Planning Framework (NPF) refers to the following National Policy Objective which is supportive of the extractive economy. National Policy Objective 23 states that it is the intention of the NPF to (emphasis added):
‘Facilitate the development of the rural economy through supporting a sustainable and economically efficient agricultural and food sector, together with forestry, fishing and aquaculture, energy and extractive industries, the bio-economy and diversification into alternative on-farm and off-farm activities, while at the same time noting the importance of maintaining and protecting the natural landscape and built heritage which are vital to rural tourism.’
The principal purpose of Regional Spatial and Economic Strategies (RSES) is to support the implementation of the NPF and the economic policies and objectives of the Government as contained in the National Development Plan (NDP) by providing the long-term strategic planning and economic framework for development of Ireland’s regions.
Regional Spatial and Economic Strategy 2019-2031 for the Eastern and Midland Regional Assembly also acknowledges the role of the extractive industry and ‘recognises that the rejuvenation of rural towns and villages requires that appropriate job creation in rural areas and that traditional sectors such as agriculture, tourism, extractive industries and forestry are complemented by diversification in sectors such as food, renewable energy and opportunities provided from improved digital connectivity’.
The RSES acknowledges that minerals form part of the region’s natural capital and presents regional
policy objective 6.7 in support of the extractive industry in relation to economy and employment.
RPO 6.7
Support local authorities to develop sustainable and economically efficient rural economies through initiatives to enhance sectors such as agricultural and food, forestry, fishing and aquaculture, energy and extractive industries, the bioeconomy, tourism, and diversification into alternative on-farm and off-farm activities, while at the same time noting the importance of maintaining and protecting the natural landscape and built heritage.
Importance of Extractive Industries
In preparing policies that reflect the importance of the extractive industries, the planning authority should consider the recently published Essential Aggregates – Providing for Ireland’s Needs to 20401 prepared by the Irish Concrete Federation (refer to copy appended to this submission).
The objective of this document is to highlight to Government the need for a national planning policy for aggregates, which will underpin local and regional planning policy and ensure the sustainable
supply of aggregates for Project Ireland 2040 and beyond. The document provides further detail on the role of locally supplied aggregates in supporting the demand for new homes, new schools and better infrastructure. In meeting the demand arising from the projected population increase of an additional 1 million people as identified in the National Planning Framework, it is worth noting that every new home typically requires up to 400 tonnes of aggregates and every new school typically requires some 3,000 tonnes of aggregates. These requirements are most sustainably met by local sources and suppliers.
The document also makes recommendations to ensure that Government’s stated objectives on aggregates within the National Planning Framework 2018 are implemented, not just for the benefit of the extractive industry, but also for the achievement of the ambitious goals of Project Ireland 2040. It highlights three important points that statutory planning policy needs to address at all spatial scales. These are:
- Importance of Extractive Industries and Aggregates
- Identifying and Protecting Reserves
- Enabling Extraction of Aggregates
DRAFT LAOIS COUNTY DEVELOPMENT PLAN 2021 - 2027
The Draft Laois County Development Plan 2021 – 2027 (CDP) describes that The County Development Plan has been prepared in accordance with the provisions of Planning and Development Act 2000, as amended, and replaces the Laois County Development Plan 2017 - 2023. It states that the main purpose of the Plan is to set out a framework for the sustainable spatial and physical development of County Laois while considering the conservation and protection of the built and natural environment, over the period of the Plan and beyond. It also aims to carefully consider all the needs of society, its individuals, and groups. It is described that, key to this endeavour, is ensuring that equal opportunities are promoted under all the various themes of the Plan.
It is further described that the CDP provides a positive vision for Laois which will enable the county to continue to make a significant contribution to national economic recovery by promoting sustainable development. The Strategic Vision of the Development Plan is as follows,
“To improve the quality of life for all citizens in County Laois by creating sustainable communities and an environment that supports a vibrant, growing and well connected economy, making it a County where people want to live, work, visit and do business, without compromising the environmental integrity of the county.”
In order to achieve this, the County Development Plan has the following objectives,
- To provide a framework for the future sustainable development of the county, defining acceptable forms of development and where they should be directed;
- To support and facilitate and promote a transition to a low carbon society;
- To provide a detailed basis for the promotion and management of development;
- To implement National and Regional development policy provisions at a county level;
- To promote and assist Laois’s economic development opportunity and encourage increased
resilience in the County’s enterprise.
Significant to this submission, Chapter 2 Core and Settlement Strategy, which provides population projections for the county to 2027 and 2031. It is projected that by 2027, the population of the county
will increase to 94,700 people and that by 2031, the population will increase to 97,500 people. As per the 2016 census, the population of the County was 84,500 people. The 2027 and 2031 projections represent an increase of 10,200 people, and 13,000 people, respectively.
Section 6.10 Rural Business within chapter 6 Economic Development makes the first reference within the Draft CDP to the Quarry and Extractive Industry. It describes that the rejuvenation of rural towns and villages in County Laois requires that appropriate job creation can be supported in rural areas. Traditional sectors such as agriculture, tourism, extractive industries and forestry are complemented by diversification in sectors such as food, renewable energy and opportunities provided from improved digital connectivity.
Significant to this submission, section 9.5 Mining and Aggregates of chapter 9 Rural Laois provides a dedicated section to the industry. It is stated that the Council recognises that the aggregate and concrete products industry contribute to the development of the national, regional and local economies by the proper use and management of natural resources for the benefit of the community and the creation of employment opportunities. These products are required as essential building materials in the social and economic development process including the provision of housing and infrastructure. It is further stated that Laois County Council will seek to safeguard these valuable resources for future extraction.
In addition is described that aggregate extraction can only take place where suitable aggregate resources exist; they are a ‘tied’ resource. Therefore, it is considered by the Council that planning policies should be carefully constructed to avoid adverse effects on aggregate resources and the related extractive industries and added value production that are essential for the built environment, infrastructure, and future economic development.
Notably, it is stated that like many forms of development, extractive industries have the potential to cause harm to the environment, heritage, and the landscape if not appropriately designed and managed. However, it is acknowledged that aggregates are a necessary resource and are of great importance to the economy and society. The Draft CDP further states that well managed and designed quarry sites minimise environmental effects. There is also the potential for habitat creation through the restoration of quarry sites following the cessation of operations.
It is stated in the Draft CDP that in order to provide a holistic consideration of policies and objectives, each chapter provides specific policy objectives, followed by development management standards. In the case of the section 9.5 Mining and Aggregates, it is stated that the following National Guidelines (as may be superseded and/or updated) should be complied with. These seem to be provided in place of specific development management standards for the sector. The guidelines are listed below,
- Environmental Management (EPA 2006);
- Quarries and Ancillary Activities: DOECLG Guidelines 2004);
- Environmental Code (ICF 2006);
- Geological Heritage Guidelines (ICF & GSI 2008);
- Archaeological Code of Practice ((ICF & DOECLG 2009);
- Sections 261 & 261A Planning and Development Acts 2000 – 2013.
Section 9.6 Commercial Developments in Rural Areas is also of relevance as it provides the following policy objectives for rural development, relevant to the sector,
RL 14
Support in principle the expansion of the aggregates and concrete products industry which offers opportunity for employment and economic development generally subject to environmental, traffic and planning considerations and ensure that any plan or project associated with extractive industry is subject to Appropriate assessment screening in compliance with the Habitats Direction and subsequent assessment as required, applicants for planning permission shall have regard to the GSI- ICF Quarrying Guidelines.
RL 15
To secure the long-term supply of value-added products (such as concrete products and asphalt), which are often, but not always, produced in conjunction with aggregate extraction.
RL 16
To support the necessary role of the extractive industries in the delivery of building materials for infrastructural and other development and to recognise the need to develop extractive industries for the benefit of society and the economy.
RL 17
Support in principle the processing of minerals to produce cement, bitumen or other products in the vicinity of the source of the aggregate, where the transport network is suitable to reduce trip generation.
Section 11.11 Geology, within chapter 11 Biodiversity and Natural Heritage, also provides a policy objective related to Eskers, relevant to the sector,
GEO 6
Assess applications for quarrying activity and gravel extraction and other development in proximity to eskers, with respect to their landscape importance or amenity value and the need to conserve them free from inappropriate development and to conserve their environmental character values and the extent to which proposals would damage these qualities.