Whilst I understand the need to protect the integrity of the National Road network, a blanket policy approach to ban access onto National Routes cannot be applied. There does not appear to be any provision for new development in areas that are served solely by national routes, including large tracts of lands along the N86 Tralee to Dingle, the N70 Ring of Kerry route and the N69 Tralee to Listowel. Proposals for development in these areas need to be considered in detail, and on the merits of each application, including the nature of the development and the housing circumstances of the applicant. For example, developments related to any farm or land-based enterprise require due consideration as a refusal for a new residence in such instances will likely lead to increased traffic movements and hence hazard in these areas where the farmer or custodian of the land will be forced to live elsewhere, generating additional journeys back and forth to the land on a regular basis.
There is an onus on Planning Authorities to ensure that the policies adopted are fair and proportionate, our Development Plan must ensure the future of rural Ireland and pay attention to the needs, in particular, of our farming community.
The policy adopted should be cognisant of fact that large tracts of land in rural parts of our County are only accessible from national routes outside of a 50 or 60km/h speed limit. Policy at plan level should not preclude development in these areas. In particular where all other planning criteria are met, and the proposed development is in accordance with normal road safety and design criteria, I respectively suggest that sustainable and safe development can be achieved in these areas, by giving careful consideration to the merits of individual applications at a local development level.
Considerations at a development / site level would include the following: Is there an existing access? How long has it been in use? Is the existing junction safe? What level of traffic currently use the access? Will extra traffic be generated, if so what level of traffic will be generated? What is the type of development? Does the applicant currently reside there e.g. living with parents in the family home, and if so for how long? Is it to support a farm or other land-based enterprise? Will refusal lead to additional journeys generated by a need to travel to the farm / land on a frequent basis?
My submission requests that the policies included in the Draft County Development Plan under Chapter 14 are amended to allow for a practical and pragmatic approach be applied to planning decisions at a local site level.