Kerry Public Participation Network (PPN) – Response to Draft County Development Plan (2022-2028), February 2022.
Preamble
The Kerry Public Participation Network (PPN) welcomes the publication of the draft Kerry County Development Plan (2022-2028). We welcome the opportunities, underpinned in legislation, for citizens and communities to feed into the process of formulating a county development plan, and we encourage people across Kerry to exercise their rights in this regard. This submission, which sets out our responses to the draft document, is part of our wider and ongoing engagement with Kerry County Council and we look forward to continuing to work with the local authority and other bodies over the lifetime of the forthcoming county development plan.
A Public Participation Network (PPN) is a structure that brings together Community and Voluntary, Environmental and Social Inclusion groups in each local authority area.
Public Participation Networks were established on foot of the report of the Working Group on Citizen Engagement with Local Government published in 2014, which recommended greater input by communities into decision- making at local government level. The Local Government Reform Act 2014 provided for the formal establishment of PPNs, and they are now operational in all local authority areas.
The primary purpose of the PPN is to enable the PPN member groups to input into and have their voices heard within the formal decision- making structures of the local authority. The PPN is now the main way that local authorities connect with groups active in their area. Whenever the local authority needs people to participate in consultations or sit on the committees like Local Community Development Committees and Strategic Policy Committees, it is obliged to call on the PPN to select representatives from within its membership to serve on those committees. PPNs therefore provide a mechanism to facilitate the two-way flow of information between the local authority and their groups to influence policy development and the delivery of services to the wider community.
Another of the main roles of the PPN is to provide a space for community groups to grow and develop through various training supports. They also act as an information hub, keeping the community informed of relevant local issues, news, events, resources and supports. PPNs collaborate with a host of organisations and service providers e.g., Education and Training Boards, Volunteer Centres or Local Development Companies to facilitate, devise and deliver support to its member organisations. PPNs are above politics with membership open to all volunteer-led/not for profit groups which are non-party political and that fulfil membership criteria. PPNs are wholly independent entities. The key decision-making body of each PPN is its Plenary, which is made up of representatives of all the registered member groups of the PPN. Every PPN also has a group called a Secretariat whose members are independent of the local authority. The Secretariat’s main roles is to carry out the decisions made by the Plenary and along with coordinating the activities of the PPN, ensure the proper functioning of the PPN between Plenaries (Kerry PPN Handbook 2020).
The Kerry PPN is network of community & voluntary, social inclusion and environmental groups; these pillars are set down in the 2014 Local Government Act (as presented in the image on page 1). The combined membership of our affiliated groups exceeds twenty thousand, and several thousand more people engage directly and indirectly with our groups. We have a reach into all communities across the county – urban and rural, and we represent a wide range of interests, expertise and sectors – economic, social, cultural, environmental, heritage and special interest. Our members, and in particular our secretariat, are obliged to be in a constant listening mode, and we are proactive in consulting with, listening to, and supporting volunteers in all types of settings. Consequently, our responses to the draft CDP are wide ranging and extensive, as we seek to respond to, and act in accordance with, the diversity of our membership and the groups we represent and support.
As an organisation, we are represented on most of Kerry County Council’s sub-structures, and we have been active and constructive in promoting the formulation of policies, processes and practices that seek to make Kerry a more inclusive, ambitious, balanced and progressive county. We also participate in regional and national networks, and we are proud to represent Kerry in various fora. Our local roots and our external engagements combine to give us a strong suite of insights and perspectives, and we draw on these in presenting this submission.
By way of our contributions to strengthening Kerry’s competitiveness, we recently (2021) produced an issues paper, which we submitted to Kerry County Council. The topics, challenges and opportunities we identified in that paper remain relevant today, and they will be relevant for the lifetime of the forthcoming county development plan. Specifically, we call on Kerry County Council to ensure that the forthcoming plan:
• Be strategically ambitious for Kerry and its people, and set targets for the plan’s lifetime;
• Promote sustainable, inclusive and balanced development – to redress current spatial and social inequalities and to ensure that no community or cohort is left behind over the next six years;
• Strike an appropriate balance between the local authority’s regulatory obligations and the need for promotive approaches to the county’s sustainable development; and
• Include and resource mechanisms for review and evaluation, within fixed timeframes, and for ongoing inputs from citizens, communities and those affect by the plan’s rollout.
Specific Responses to the draft plan
We welcome the reference (1.9.1.2) to the UN Sustainable Development Goals 2030, and we respectfully recommend that the second sentence in this paragraph be amended, so that the second dimension of sustainable development is identified as ‘socio-cultural’ - not just ‘social’, thereby ensuring better alignment between the county development plan and contemporary UN thinking and policies . Cultural aspects of sustainable development are particularly important in the County Kerry context, and in community development terms, they relate to our indigenous culture and to the merits of inter-culturalism and diversity.
We note the reference (1.9.1.5) to the KCC Climate Change Adaptation Strategy 2019-2024. This core strategy will be due for renewal during the lifetime of the forthcoming county development plan. As we have considerably more scientific knowledge and a stronger legislative framework than we had when it was devised (in 2019), we recommend that the CDP make specific provision for its strengthening and futureproofing.
Kerry PPN contribution to the Climate Action Conversations consultation which took place in 2021 suggested that Analysis of responses to the online Conversation clearly showed an expectation that KCC should facilitate system changes that help the public make behaviour changes and to take climate action at an individual or community level.
A mix of policy interventions is therefore required across the following policy intervention types: Enable – KCC needs to understand the practical and structural barriers that people face and enable people to take action by changing the systems in which they live e.g., investing in infrastructure and services, developing skills.
Encourage – KCC needs to consider the appropriate incentives and disincentives to encourage behaviour change alongside traditional measures such as regulation, legislation, standards or social marketing.
Engage – KCC needs to look at methods of engaging the public to explore what actions are socially acceptable, what measures work, and to gain legitimacy for climate policies. Exemplify –KCC needs to be seen to lead by example and ensure that there is consistency between policy and what the public sees through services, planning and development.
This can involve ensuring messages are consistent across agencies. Across these four areas, the most dominant policy demands were for: 1. Provision of infrastructure and services (e.g., public transport and segregated cycle lanes) 2. Finance and improving the affordability of measures (e.g., Retrofitting finance) 3. Supporting community action (e.g., Building local capacity) 4. Providing alternative options and ensuring supply (e.g., Lower carbon food and products)
For further information , see full report CLIMATE CONVERSATIONS SUMMARY REPORT, Independent summary report of responses from a series of public engagement activities - ‘Climate conversations’ to inform the design of Ireland’s ‘National Climate Action Plan’ 20219 (https://www.gov.ie/en/consultation/5bd95-climate-conversation-climate-action-plan-2021/ )
We welcome the prominence the plan affords (Chapter 2) to addressing the climate emergency, and we encourage KCC to more fully operationalise these principles throughout the plan. Paragraph 2.3.4 refers to the National Adaption Framework (NAF 2018), including to the need for ‘ongoing engagement with civil society’. In this context, we note the need for subsequent sections (of the plan) to be much more explicit in this regard, as organisations such as the PPN are keen to participate such engagements, not just with KCC, but with public bodies more generally.
Sections 2.6 and 9.3 make strong plays regarding the importance and the potential of the bio-economy, but these are not sufficiently pursued in terms of specific actions or commitments. The only policy commitment to mention the bio-economy is KCDP 9-3, and this simply commits to facilitate and support employment opportunities. We recommend more specific, deeper and broader commitments, so that Kerry can avail of the associated opportunities.
The draft CDP’s references to ‘place-making’ (e.g., 2.6.2.1) require a systematic and meaningful engagement with civil society, and we recommend that the plan make specific references to the PPN’s three pillars as essential actors in this space.
The plan’s commitments in respect of sustainable energy generation note the required mix of energy sources. We welcome the specific inclusion of ‘micro generation’, and we encourage KCC to work with us and other stakeholders in this regard, as PPN members / groups can and should be facilitated to be energy suppliers.
The core strategy map (map 3.1) ought to have a legend, so that readers can understand the significance of the various arrows (and their colours). The rail line needs to be extended – via Rathmore to Mallow, and the N22 should be shown (as the N21 is). The ‘Kerry Hub and knowledge Triangle’ is a carryover from previous plans. The merits of this carryover have to be questioned given Kerry’s relatively poor demographic performance (as noted in Section 3.8). At the very least, and in line with best international practice, this strategy ought to be subject to an independent external evaluation (preferably by a university). It is essential that we learn the lessons from the ‘Kerry Hub and Knowledge Triangle’ experience, over the past decade, in order to inform the development of the North Kerry/West Limerick/Shannon Estuary/Clare Settlement Network (3.5.1.4).
Section 3.5.1 lists the strategic economic drivers within the county, but it fails to mention the railway. This is a glaring omission, and it undermines the principles outlined in Chapter Two. Despite under-investment, the railway is a very important driver of development, particularly for bringing tourists to the county. We call on KCC to assert the significance of the railway (in section 3.5.1) and to provide for its development and expansion – specifically a dual track from Mallow to Tralee, the upgrading of the rolling stock and the development of a commuter service between Tralee and Killarney. As is occurring throughout Europe, freight is increasingly being transferred from road to rail, and there is considerable scope to do so in County Kerry and beyond.
Map 3.2 is of limited value as it relates to a five-year timeframe. It is necessary to illustrate trends / patterns over a longer timeframe e.g. 20 years. A revised map (at ED-level) should be accompanied by a small-area (SA) level map – as many neighbourhoods in Tralee and some in Killarney (that are more disadvantaged) have similar structural weaknesses to rural areas (and their demographic patterns are masked by an ED-level map). The neighbourhood effect needs to be appreciated and understood, particularly in order to provide pointers for place-making (which the plan acknowledges is important).
The settlement hierarchy (Tables 3.5 and 3.6) is largely in line with that presented in previous plans, but the descriptors of the settlements (right-hand column) need to be overhauled in line with contemporary thinking and principles on the roles and functions of urban spaces and places. The description of a key town as ‘self-sustaining’ is deeply problematic, particularly in the Kerry context, as it flies in the face of previous good work in developing functional urban spaces and urban networks. The description of a regional town needs to be broadened in order to provide for greater multi-functionality. The settlement strategy needs to acknowledge and promote the merits of inter-town collaboration and urban-rural partnerships. It is no longer the case that towns provide services for rural areas, as planning policy now recognises the many important services (e.g. the supply of water, food and fuel) that rural areas play for urban communities. Service provision is multi-directional and dynamic. Therefore, the use of the word hinterland should be completely avoided and replaced with references to multi-functional and networked spaces. The text at the end of page 47 is more useful in this regard.
The housing targets (Table 3.7) need to be accompanied by targets and commitments in respect of excellent building quality and attractive neighbourhoods. It would be useful to refer to housing units as ‘homes’ and to commit to supporting residents’ wellbeing.
Ballyduff is listed among the villages, although it is larger and has an arguably greater carrying capacity than some of the settlements that are classified as ‘district towns’. We recommend upgrading Ballyduff to the status of ‘district town’ and ensuring that interventions there pay particular attention to the promotion of social inclusion and community development.
The housing targets (Table 3.7), for some communities, do not appear to stack up against local evidence. The allocation to Cahersiveen is smaller than the allocation to Milltown, although the former has a greater carrying capacity (e.g., more school places). A similar observation may be made in respect of Ballylongford and Barraduff, among many others. Yet, Farranfore, which is well served by public transport, has a relatively low allocation. The criteria on which the allocations are based are listed on page 44, but the plan needs, in the in the interest of transparency, to present the full details as to how the allocations were calculated. The modelling that was applied ought to be presented in full in an annex. Sustainable development criteria, especially socio-cultural sustainability ought to feature more prominently and receive due weighting in the criteria and their application.
We welcome the commitment (4.2.1) to pursuing a town centres first approach, in order to prevent any further sprawl of our towns and villages. The drift towards the suburbs has not been good for Kerry’s towns and rural communities and a strengthening of settlement cores – with multi-functional remits – is important in harnessing their potential. The urban regeneration and compact growth objectives (page 49) should also refer to ‘quality of life’ and ‘wellbeing’, and they ought to give explicit effect to the recommendations presented in the Access for All report, which was published by Kerry PPN and launched in March 2020. This notes the need to ensure equality of access for all persons with disabilities (not just wheelchair users).
We recommend a strengthening of the statement (page 48, paragraph 2) that public services like education, health and government offices ‘should be located in town centres’. Town centres should be the default locations, rather than the suburbs, as was allowed to happen in Tralee (e.g., National Driving Licence Service – Manor West; MTU – Dromthacker; and HSE and TUSLA offices in Rathass) – all of which have had an undermining effect on the town centre. All new offices should only be in town centres, and their development ought to be accompanied by investment in walkable infrastructure.
Page 49 notes that a number of town centre health checks have already been carried out. We call for the immediate publication of the Dingle Town Health Check, as the survey was conducted in 2019, and there needs to be a joining up of the commonalities between them. Town centre health checks are only useful as part of the overall strategic approach to town development, including the promotion of interfaces and collaborations between towns. Thus, KCDP 4-5 needs to be strengthened to ensure KCC (or appointed body) undertake a review of the various town centre health checks to bring them together in a coherent manner, thereby promoting inter-urban synergies and enabling a systemic sharing of information and transfer of best practices. We recommend that KCC desist from using the generic Heritage Council model of town centre health checks and develop a bespoke one that is more appropriate to Kerry and gives clear effect to the UNSDGs.
The NPF statement (4.2.4) in respect of place-making ought to be strengthened by reference to the importance of accessibility (in the design and engineering) of public, social and commercial spaces.
The draft presents principles of place-making (page 50). This list ought to be extended to include community development and citizen participation. Place-making strategies need to be shaped by local oversight (by communities) and active citizenship – in partnership with KCC and other agencies.
We welcome the commitment (page 51) to work closely with communities in implementing village design plans, and we contend that KCC should also work with the PPN in developing / formulating them and in reviewing / evaluating them. Village (and town) design needs to give effect to the Access for All recommendations – ensuring equity of movement and safety for all. Objective KCDP 4-7 ought to include the adjectives ‘accessible’ and ‘safe’ (places and spaces).
The Urban Design Manual (page 51) dates from 2009, and we recommend a more contemporary approach e.g. The Place Standard (as used by Scottish local authorities) and the inclusion of ‘accessibility’ as a dimension. Paragraph 2 (on this page) should also refer to ‘social gatherings / interactions. Paragraph 5 ought to acknowledge the role of the community and voluntary sector here, and it should refer to the various biodiversity and citizen science initiatives that are underway across the county.
Page 52, first sentence: Please add accessibility to the list of needs. Add the word ‘accessible’ before the word streetscapes (in KCDP 4-8). Move paragraph 4.2.6 to before the preceding set of objectives.
KCDP objectives 4-13 to 4-15 provide opportunities to reference access to the county’s four railway stations and the development of a connecting gateway / door (not having to go through our around the Outlet Centre) between Killarney Bus and Train stations.
The statements in respect of enterprise development (4.2.9) rightly connect place-making with economic development, and in this regard, we recommend the expansion of KCDP 4-21 to include the social economy and community enterprise. We recommend adding EU and private sector funds to the sources listed in the final paragraph of section 4.3.
Section 4.3.1: The second sentence in the first paragraph should also factor in ‘liveability, quality of life and wellbeing’.
The draft CDP refers to the vacant sites levy. This statutory instrument is essential in tackling the scourge of dereliction and property hoarding that are blighting our towns. The associated powers need to be applied in full. The second last paragraph (page 55) uses the verb ‘explore’ to describe the proposed approach to the register. This is inadequate, and ought to be replaced with the words ‘will fully utilise’. The term ‘large’ should be deleted (in this same sentence) and replaced with the words ‘all premises, sites, and tracts’.
The objectives KCDP 4-22 to 4-34 have the potential to apply to villages and rural areas, as well as to towns. The text should be amended accordingly.
In relation to the requirements that are necessary to reinvigorate the retail sector (4.4.1.1), we recommend adding accessibility (to the list of bullets) and we strongly recommend including bicycle parking (car parking is already on this list).
The attainment of the objectives presented in paragraph 4.4.2.3 are consistent with those of the Purple Flag Initiative, and KCC’s support for its consolidation and expansion ought to be stated here.
The final sentence in relation to outdoor dining (4.4.2.4) should also include wheelchair users and cyclists.
Support for farmers’ markets is warmly welcomed.
Objective KCDP 4-37 should insert the words ‘and village’ after town i.e. town and village centres.
We welcome the commitment (4.4.3) to preventing out-of-town retail parks and renewed support for town centres, and this needs to be repeated in the subsequent set of objectives.
We welcome the commitment (4-43) to a town centre and retail strategy.
In Table 4.1 (Appropriate Level of Retail Development), it is necessary to consider that some settlements in levels 3, 4 and 5 cater for passing trade and tourist influxes (particularly during the summer). These metrics ought to be factored into the calculations (of appropriate levels) in addition to the local and surrounding population. Thus, Objectives KCDP 4-58 to 4-60 ought to be amended to reflect this.
Considering its location (in the centre of North Kerry) and its size (relative to the other regional towns), there is a strong case for including Listowel in the Objectives KCDP 4-53 to 4-55. It should also be noted that Listowel attracts customers from West Limerick. Towns and villages also have functions beyond commercial and service provision, and it is important to invest in their functions in respect of social inclusion and community development.
The attempt, in the draft, to link retail functions to town size does not make good business sense. Many towns e.g. Sneem and Kenmare have a retail function that goes beyond their size. This is appropriate given their tourism functions, and such expansive approaches ought to be encouraged, regardless of population bases. Potential customer volumes are more significant, in business terms, that are population / catchment sizes. Moreover, Kerry has a number of towns with recognised retail specialisms (e.g., Castleisland is a regional centre of excellence for fashion and electrical goods). The CDP ought to support and build-on such specialisms and encourage the development of linked human capital – thereby sustaining and creating jobs and improving the quality of employment offerings.
Page 68, Paragraph 5: There are two errors in this paragraph. Line 2 states that 8% of the population is employed in the agriculture, forestry and fishing sector. This is inaccurate, as the figure relates to the workforce (not the population). Additionally, the word ‘only’ before the 8% should be deleted, as it’s subjective. Line 3 refers to ‘relatively low employment figures’. This should read ‘relatively high’ as the County Kerry value is the eight highest among the thirty-one local authority areas in Ireland. The text refers to the hectares of farmed land, but it neglects to refer to the number of people working in the primary sector i.e. n=4,913 jobs. Additionally, since the mechanisation of agriculture (from the 1960s), the convention in economics is to assess agriculture in relation to both direct and indirect employment. The latter is particularly significant in County Kerry, especially in the north of the county. Thus, supporting agriculture-based industries and services (food processing, environmental monitoring, contracting, sales and repairs, plant / machinery hire, farm stores etc.) needs to be integral to the county development plan.
Principle 3 (bottom of page 68) should also refer to the associated socio-cultural assets. People and culture i.e. A Living Countryside (Cork Declaration, 2016) are integral to Kerry’s tourism offering. This point should also be reflected in Objective KCDP 5-1.
The final sentence in section 5.1 correctly notes the need for balance (although the word is repeated in the sentence), and while there is a narrative that rural housing detracts from the development of towns and villages, the reality in Kerry has been that the major pull (from the town centres) has been from sprawl, and it is certainly not associated with housing in peripheral rural areas.
We welcome the references to Our Rural Future, and in particular to the merits of a place-based approach that meets the needs of different rural areas. The LAPs that will be developed, over the lifetime of this CDP, will be highly significant in ensuring differentiated approaches at sub-county level.
Objective KCDP 5-6 ought to refer to the ecological functions (in addition to food supply) performed by rural areas.
Paragraph 5.4 needs to add (at the end) ‘urban sprawl and the development of housing estates on the peripheries of some settlements’.
The reliance on Irish Water (p. 72) to provide water and wastewater treatment facilities is a great pity, given the progress that KCC had been making in this regard. This underscores the need for the transfer, back to KCC, of responsibility for water services. In the interim, the approach suggested in Table 5.1 is sensible, although in addition, KCC and other stakeholders ought to be developing nature-based wastewater treatment systems (e.g. reed beds), which would also double-up as biodiversity and recreational spaces.
The stipulations in KDCP 5-13, while they may be well motivated, do not recognise the range of economic activities that take place in a rural area. The text refers to farmers, but it should also include other rural-based workers, including agricultural contractors, market gardeners, nursery workers, welders and fabricators, fishers, various tourism providers (e.g., ghillies, sports instructors) some therapists / clinicians, artists and all others whose livelihoods are intertwined with living in the countryside. For many workers, other than farmers, the countryside is their laboratory, canvas, inspiration, product / offering and source of raw material, and by living in the countryside, they eliminate the need to travel out from a town (reverse commuting), thereby ensuring they minimise their carbon footprint. Having a living countryside with a diversified economic base and mixed socio-cultural profile is integral to Kerry’s identity and it underpins our tourism offering. Therefore, this stipulation needs to be revised so that it accurately reflects Kerry’s current profile and the people who sustain our living countryside. Additionally, the reference to ‘full-time’ farmers is outdated, given the low levels of income generated by agriculture and the obligation on most farmers to have an off-farm job. This provision might be appropriate in other counties, but it is not suitable for Kerry.
Objective KCDP 5-15 is welcome, as is provides an opportunity to take stock of environmental impacts. This monitoring should include an assessment of the carbon footprints of a representative sample of household types and locations, across the county, as behaviours, other than settlement pattern, can have a significant environmental consequences.
The enforcement of Objective 5-20 (particularly in respect of planting / landscaping) has been limited, in the past, and this has led to some of the problems associated with rural housing. Therefore, there needs to be a stronger commitment to enforcement, and this commitment needs to be properly resourced.
The policies in respect of holiday and second homes are very welcome, although they are long overdue. Any homes build in line with Objective KCDP 5-21 ought to be on brownfield sites and should not comprise more than three units.
We welcome the support (5.8) for the renovation and restoration of vacant buildings in rural areas. The council is correct to recognise their significance in respect of vernacular architecture, and owners (current and incoming) ought to be facilitated, to the greatest extent possible in renovating and restoring uninhabited and unused properties.
The condition (page 81) that a roof be intact, to make a property eligible for restoration, is problematic given the exposed nature of parts of the county. Furthermore, it is problematic in respect of buildings with traditional roofs e.g. thatch. A more bespoke and practical approach ought to apply.
Chapter 6 asserts welcome principles in respect of sustainable communities. The opening sentence (of this chapter) needs to include ‘environmental and recreational’ infrastructure’ along with the others that are specified here.
To this end, KCC should establish a dedicated social inclusion sub department of the Community Department, whereby community work building sustainable and inclusive communities can be done in a planned strategic way and that Age Friendly, Sports Recreation, Healthy Kerry and Kerry PPN have synergy and complement and collaborate with each other on service delivery to ensure that there is added value, reduce duplication and ensure best use of resources and best practices.
Additionally, when services are delivered in a socially inclusive way, they take into account barriers that people might experience, and adapt the service to meet the needs of the community either collectively or individually. That appropriate language and various types of communication are used to ensure that all members of the community are considered as part of the service delivery. Social Inclusion is making sure that everyone in society has an equal chance to a good quality of life.
It’s about:
• Treating people equally regardless of their background
• Making sure people have equal access to goods and services
• Removing barriers and helping those that may need it more, for example older persons, disabled persons, Travellers, the unemployed and so on
• Targeting resources where they are most needed
• Challenging discrimination
• Changing attitudes and ways of working
The model (Fig. 6.1) should be replaced with more contemporary thinking and evidence in respect of sustainable communities. This model is too silo-ed, as it fails to show the relationships and complementarities between the various elements of place. Thus, the corresponding text needs to be revised in order to convey greater ambition and a more holistic and strategic thinking, and less fragmented, approach to the attainment of sustainable communities. Moreover, the language here (on page 84) needs to acknowledge and promote the role of community stakeholders and community participation / engagement in bringing about sustainable communities. Therefore, objective KCDP 6-1 needs to be amended, so the words ‘in partnership with communities’ are inserted (immediately after the word ‘support’).
Fig. 6.2: Please specify the date (year).
We welcome the recognition (in Section 6.2.1) of the PPN’s role in awareness raising, real authentic community participation and engagement, and we look forward to co-delivering in this regard. The scope of the measures / actions set out in the section focuses largely on the consumption / use of energy. It needs to be supplemented by references to production, so that Kerry can become a leader in community-led energy generation.
We recommend adding ‘green spaces’ to the list of amenities listed in Objective KCDP 6-3. The recent pandemic has certainly highlighted their value.
We recommend that the delivery of KCDP 6-8 be grounded in an end-of-term independent evaluation of the current LECP – in line with best practice in project management and strategic planning.
We welcome the specific section (6.1.5) in relation to the Public Participation Network (PPN), and we recommend expanding Objective KCDP 6-9, so that it goes beyond the delivery of infrastructure and services – to ‘the co-development and co-delivery of responses that meet the needs of communities (geographical and issue-based) particularly those who are most affected by social exclusion or other manifestations of disadvantage.’ This requires supporting and enabling deliberative democracy and giving full effect to the County Wellbeing Vision.
Delivering Deliberative Democracy
Recommendation 1: A dialogue between the Local Authorities and the other PPN Stakeholders to establish practical, best-practice approaches to implementing the principles of participation and working towards increasing partnership across all stages of the decision-making process.
Recommendation 2: Review the Local Authority Structures against the Council of Europe’s Framework and dedicate resources from within the Department of Housing, Local Government and Heritage, of at least Principal Officer grade, to ensure meaningful engagement.
Recommendation 3: Further qualitative research to explore best practice solutions.
Visions for Community Wellbeing
The Vision for Community Wellbeing were developed across six interconnected domains. These are Health (Physical and Mental); Economy and Resources; Social and Community Development; Participation, Democracy and Good Governance; Values, Culture and Meaning; and Environment and Sustainability
Image: Domains for a Vision for Community Wellbeing
The extensive consultative process undertaken by the PPNs was a key factor in developing Visions for Community Wellbeing that are robust and reflective of the communities in which the PPNs are situated.
The Community Wellbeing developed by Kerry PPN indicates that areas of particular importance to these communities are Sustainability; Inclusion and Diversity; Local Economies that support society; Civic Engagement; and Social Connectedness. There is significant cross-over between domains, for example the health (Physical and Mental) went far beyond the need for decent healthcare, to the importance of the environment, infrastructure and social connection, and this is the case for all domains.
Section 6.2 concludes with the statement ‘Community led economic development strategies are needed…,’ but this acknowledgement needs to be further developed by specifying the nature of the strategies KCC envisages and how stakeholders, including the PPN, will be involved in devising and delivering them.
The objectives presented in section 6.2.1 are laudable, but Kerry County Council needs to list other economic drivers (not just ‘digital hubs’) e.g. offices of public bodies (in line with Chapter 4). It also needs to provide for enhanced public transport nodes and connections. Indeed, the singular emphasis on digital hubs (in this section) is worrying, given that these are likely to be eclipsed by the rollout of the National Broadband Plan, so that people can work from home, without incurring the costs and other challenges (e.g confidentiality) associated with digital hubs.
The commitments in respect of healthy communities focus largely on traditional local authority functions – most notably the provision of infrastructure. These need to be complemented by an emphasis on soft supports and capacity-building. The PPN is a willing partner in this regard.
Please add ‘green spaces’ to the list at the bottom of page 91. For coastal communities and those that are close to rivers and lakes, access to ‘blue spaces’ should also be promoted.
The Travelling Community must, as a priority, feature in the policies that are presented on pages 91 and 92.
The policies listed on pages 91 and 92 need to be linked more overtly to the principles and objectives presented earlier in the draft plan in relation to the attainment of more balanced (geographical and social) development in County Kerry. These are also relevant to the promotion of demographic vitality in peripheral rural communities. Specific mention ought to be made of community-level solutions and approaches.
Strategic Objectives 6-19 to 6-22 ought to be modernised with reference to the opportunities associated with smart villages and smart regions. The provision of infrastructure must be accompanied by the rollout of soft supports (including training and capacity-building), and the PPN, among others, can play an active part in this regard.
The PPN can be specifically named (on page 94) as among the consultees in relation to the development of services and infrastructure for people with disabilities.
The commitment (KCDP 6-24) to support a successor Age-Friendly Strategy ought to be underpinned by an evaluation of the existing strategy, and the PPN looks forward to making a dedicated submission in this regard and to having its recommendations pursued.
Section 6.2.7 must commit, as a matter of urgency, to the formulation of an integration and inter-cultural strategy (as specified in national policy since 2017). The text in this section is generic, and it needs to be revised so that it relates more specifically to County Kerry. The text should also recognise the importance of community development in promoting integration and inclusion, and organisations such as the PPN are integral in this regard. To this end, KCC should establish a dedicated social inclusion sub department of the Community Department, whereby community work building sustainable and inclusive communities can be done in a planned strategic way and that Age Friendly, Sports Recreation, Healthy Kerry and Kerry PPN have synergy and complement and collaborate with each other on service delivery to ensure that there is added value, reduce duplication and ensure best use of resources and best practices.
The section on age-friendly communities references the traditional local authority functions including the development of infrastructure, but it also needs to commit to working in partnership with older people and with services and agencies to ensure older people are enabled and supported to influence the decisions that affect their lives. This section should also refer to carers.
Objective KCDP 6-29 needs to include political and governance integration. Migrants and those from ethnic minorities are under-represented in the body politic and in the senior management of most agencies / public bodies. Thus, there is a need for real and concrete steps to break the glass ceilings they encounter.
Section 6.3 should include the development of a social economy strategy for the county, although we acknowledge that this is mentioned subsequently in the document.
The sections in respect of libraries and health services (6.3.2 and 6.3.3) need to make specific mentions of their roles in supporting the aforementioned age-friendly strategy (connect the sections) and the forthcoming integration and inter-cultural strategy. The text on libraries should also dovetail with the strategic objectives presented in Chapter 7 (in respect of culture and heritage). As currently drafted, there is a lack of connection and synergy between chapters four, six and seven.
Section 6.3.5 is remarkably short given the importance of children and young people. The text here is underwhelming, and it needs to incorporate specific strategic actions that promote active citizenship among Kerry’s children and young people. There are several active citizenship initiatives underway in schools and communities, across Kerry, that would benefit from support through the county development plan – so that children and young people are active agents (not just passive bystanders) in planning and development processes. Moreover, the references to place-making (earlier in the document) would certainly benefit from commitments to promoting child-friendly spaces and places.
In all, Chapter 6 ought to relate more specifically to the policies and objectives that are presented in Chapter 4; there is the potential for more synergies between these two chapters.
Chapter 7 takes a pragmatic approach in respect of alignment with national-level housing policy. The commitments in respect of eliminating homelessness and the provision of accommodation for Travellers are only meaningful if they are accompanied by specific targets and indicators.
The polices presented on page 105 are welcome, but these need to be applied to existing housing, in addition to developments that may come on stream.
KCDP 7-12: insert the definite / indefinite article in this sentence and specify the timeframe.
The provisions and policies set out in respect of people with disabilities, older people and the Travelling community (sections 7.5, 7.6 and 7.7) need to refer to consultations and dialogue with these population cohorts and the NGOs who work with, and for, them.
Chapter 8 (Gaeltacht Areas, Culture and Heritage) contains valuable information and useful strategies. These need to be linked to the material and strategies presented earlier in the document (especially chapters 4 and 6) and subsequently Chapter 9 (economic development) – given their core strategic importance to the county’s economy.
This chapter neglects to reference the National Landscape Strategy, which presents several leverage opportunities for County Kerry. This national framework ought to be interwoven into this chapter. The National Landscape Strategy is not referenced until Section 11.6.1, although it is relevant to several of the preceding sections.
Please correct the spelling of Uíbh Ráthach in Map 8.1.
Section 8.1 rightly acknowledges the need to support Gaeltacht communities, but in practice, however, it is not the Gaeltacht communities who are found wanting in promoting the language, it is those with whom they interface. Therefore, the promotion of the Irish language, both inside and outside, the Gaeltacht needs to base itself on working with the full set of agencies and actors with which Gaeltacht communities interact.
Page 114 rightly acknowledges the damage done to Gaeltacht communities by holiday homes, and while it outlines ways in which the planning process will not make the mistakes it made in the past, it does not offer any measures by way of mitigating its legacies.
The statement (on page 115) in relation to housing people in Gaeltacht areas, regardless of their disposition to the Irish language, is deeply problematic, and it should be removed from the plan.
The provisions in respect of the economic development of the Gaeltacht should include supports for the social economy / community businesses and the Gaeltacht cooperatives.
Section 8.1.4.4 should also reference Dingle’s Smart Village status, and the plan ought to commit to supporting it.
The chapter on economic development (Chapter 9) is one of the most extensive in the document, in line with the council’s statutory responsibilities in this respect. The opening sentence commits to a spatial planning framework, but this is the only reference in the entire chapter to such an arrangement or mechanism. While there are references to other and external frameworks (e.g. NPF and marine) and to the Shannon Estuary, the commitment presented in the first sentence does not materialise in the chapter. Indeed, the extent to which the chapter references external frameworks suggest that Kerry is being reactive to national policy, rather than shaping the factors that influence the county’s economic development. The term ‘regional areas’ (line 4) is unclear; does this refer to NUTS II or NUTS III regions, and how many of the related assets are Kerry-based?
Section 9.1.1: The opening sentence should include reference to opportunities and potential and to the capacity of actors. The United Nations has identified ‘governance’ as the fourth dimension of sustainable development, and, as such, it should be referenced here, and the chapter needs to put forward mechanisms for the development and strengthening of the governance frameworks and arrangements that would further Kerry’s economic development. This would tie in with the aforementioned importance of deliberative democracy.
The reference to Brexit-related opportunities is unclear.
The paragraph on opportunities (beginning with the text: Policy formulation….) should refer, not just to generic opportunities, but to those that are based on, and harness Kerry’s economic resources. These include many of the assets that are referenced in other chapters (including landscape, heritage and human capital).
The chapter fails to mention the Local Enterprise Office (LEO), although it offers valuable supports to businesses. LEADER also merits mention in this regard.
The chapter needs to outline how it relates to objectives that are presented earlier in the plan, particularly those in Chapter 4 and in the KCC retail strategy.
Town Centres First ought to be listed among the relevant policies, as it affords opportunities in addition to those referenced in Chapter 4.
Section 9.2.3.1 lists KCC’s partners in respect of economic development. This listing includes ‘community development agencies’, but it does not mention the PPN and / or community and / or voluntary groups. We recommend that the PPN and community and voluntary sector be included in our own right, rather than through agencies. Direct collaboration with the PPN and with our sector is integral to the delivery of the national strategy on the social economy, which is already a significant driver of economic development in the county and which can be further developed.
The second paragraph in this section refers to external community bodies. The PPN would prefer to see the primary emphasis being on internal community bodies – as we are the lead actor in this regard (in line with the 2014 legislation), although we are very open to collaborations with external bodies too.
We welcome the last paragraph, in this section, in respect of the economic value of environmental resources.
Section 9.2.3.1.1 refers to a review of the LECP 2016-2016. This text should be corrected to refer to a review of the next LECP, as a plan cannot be reviewed after it has lapsed, and a date should be specified as to when this would take place. We recommend 2024, as that would be just prior to its mid-term (2022-2028). We welcome the commitment (line 2 and reiterated in KCDP 9-14) to a review of the county development plan. The PPN is willing to engage constructively in both reviews, and we encourage all stakeholders to do so. Stakeholders should ensure the involvement of independent external experts, in both reviews, and that the processes are inclusive, objective and transparent.
The high-level goals (as presented) include attracting investment into County Kerry. We recommend an additional goal that seeks to retain capital within the county. The wording of the high-level goals is inconsistent; some are presented as actions (e.g. diversifying the Kerry economy), while others are lists of sectors (e.g. energy). We recommend presenting all as actions and we also request KCC to elaborate specific actions in all cases.
The supports outlined (page 135) in respect of environmental integration into economic development are welcome, and they need to be strengthened e.g. the second bullet point should say ‘ensure’, rather than ‘encourage’; this is consistent with KCC’s statutory responsibilities as the planning authority. The commitments in respect of travel-to-work patterns (that are presented here) need to be reflected in the chapter about that deals with transport. As currently drafted, the latter fails to take sufficient cognisance of environmental imperatives.
Map 9.1 requires a legend so that readers can make sense of the arrows. The map appears to show connectivity between Kerry, Cork and Shannon Airports although no direct connections exist. There is a label in North Cork entitled ‘Regional Airport Strategy’ although there is no detail in the plan about this or its relevance. Kerry’s outward connections to the Greater Dublin Area (as suggested by the green arrows) are via the Limerick and Cork metropolitan zones, which ignores the Tralee – Mallow – Dublin rail line – a more direct and sustainable option and one which reflects the principles outlined in page 135.
The area shown within the Knowledge Triangle is smaller than that advocated and presented in previous documents produced by Kerry County Council. It is noteworthy that the MTU and Tom Crean Business Park, which the draft plan identifies as key elements of the triangle, are located outside the boundary shown in Map 9.1. Given that they are closer to Listowel than to Killarney, there is a case for including Listowel under this strategy. Indeed, there is ample evidence to suggest that Killarney is exhibiting agglomeration effects, which indicate that it no longer needs to be within the triangle. Had the ‘Triangle’ strategy been effective, up to now, it would be expanding – in line with positive spillover effects, as specified in the previous county development plan. Yet, this chapter does not present any data to support its continuity. Furthermore, it does not present any targets or indicators for it. The impacts of this policy on the communities within the triangle (particularly Firies and Milltown) need to be considered, as they are increasingly becoming car-dependent commuter settlements and they risk losing their vibrancy.
The supports for economic development ought not just to address emerging and burgeoning sectors (such as the digital economy), but should also, and in particular, seek to retain jobs in sectors that have been contracting (as enumerated in Table 9.1). Retaining / safeguarding jobs is often more cost effective than seeking to create new ones.
Section 9.6 needs to refer to, and leverage, the National Landscape Strategy.
This section (9.6) refers to the Knowledge Triangle, but it fails to mention the Shannon Area Coastal Network’.
The objective in respect of land-use planning for economic development ought to include provision for KCC purchase of lands – for medium- and long-term strategic development.
Appraisal criteria in respect of developments on the Shannon Estuary ought to include impacts on agriculture, including the livelihoods of local farmers and the quality and safety of the food they produce.
Climate change imperatives and biodiversity impacts should be included in the appraisal criteria in respect of all proposed developments along the Shannon Estuary.
Section 9.6.2, Line 3: Kerry needs to be included here (not just Cork and Limerick).
Section 9.7 identifies a number of economic opportunities. Chapter 4 has committed, in line with national policy, to the rejuvenation of town centres. These two parts of the plan need to be intertwined and made mutually re-enforcing. New economic activities should be in town and village centres, rather than in suburban industrial parks, and the plan needs to incorporate specific objectives to arrest the haemorrhage from Tralee Town Centre to Dromthacker and Manor.
The realisation of town centre first objectives requires incentivising student accommodation over commercial premises in town centres. Previous initiatives to encourage family living over shops have not succeeded (mainly due to lifestyle choices and patterns e.g. second-floor dwellings not being large enough to have individual bedrooms for children or storage spaces for family items). Over-the-shop student accommodation would be more likely to succeed, and student apartments could be holiday lets in the summer. This approach would benefit town centres, and it would put money in the pockets of local families, unlike the large-scale student apartment blocks, some of which benefit external investors more than Tralee. Indeed, the promotion of student living in town centres needs to be accompanied by a ban on the construction of any new student apartment blocks. The latter have also displaced accommodation in digs, which traditionally benefited host families / households and the local economy.
KCDP 9-34 needs to include the hospitality sector.
Section 9.7.3 ought to include the creative and arts sector, given its strong connections with rural resources.
Support for LEADER and the work of local development companies ought to be stated in relation to the development of the rural economy.
Table 9.4 lists the locations of digital hubs. It is worth noting that only one of these is in North Kerry (north of Tralee). The plan needs to incorporate an objective to redress this deficit.
The strategic objectives in respect of agriculture, agri-food and agri-tech (page 153) ought to include expressed support for ‘high-nature-value farming’, given its importance to farm households (especially on the three peninsulas and Sliabh Luachra) and its role in supporting tourism (by safeguarding the resources that attract tourists to Kerry). This would also support the objectives, presented in Chapter 13 in respect of water quality.
The objectives presented in respect of natural resources (9.7.6.2) must include commitments to ‘conserve’ and ‘protect’. As the planning authority, KCC is obliged to take a lead in these respects.
The figures presented in Fig. 9.3 appear to be for Ireland. The Kerry figures and targets are required, and Map 9.2 needs to be consistent with the graph, so that it distinguishes between broadleaf and conifer plantations. The former are far more valuable in respect of the attributes presented on page 155.
This section (on forestry) does not present any data in respect of Kerry-based economic activities. At present, Kerry is being treated as the supplier of raw materials, while other counties are benefiting (generating added value). The plan needs to commit to ensuring value adding takes place in Kerry.
This section (and other parts of the plan) needs to explicitly reflect the principles of the Berne Convention on the Conservation of European Wildlife and Natural Habitats.
We welcome the breadth and scope of activities listed in Chapter 10 (especially KCDP 10-2).
We recommend the inclusion of NGOs and the PPN in KCDP 10-3.
Chapter 10 ought to commit to supporting the collection, collation and dissemination of Kerry-specific data (across all indicators), so that tourism-related decision-making is more strongly evidence based.
Section 11.1 (in relation to environmental assets) refers to moorlands. This should also include Kerry’s bogs. Indeed, there is only one reference to bogs in this entire chapter, despite their prominence in County Kerry. Given the significance of bogs (in terms of heritage and as carbon stores), they merit much greater attention, preservation and sustainable development. The Irish Peatland Conservation Council provides useful pointers in this regard.
KCDP 11-11 ought to include Cork County Council, as the biosphere bounds County Cork, and the integrity of its habitats are contingent on Cork County Council and Cork-based actors sharing the values presented in this chapter and the specific text in section 11.2.2.
Section 11.3 refers to light pollution. This is an opportunity to support the (geographical) expansion of the Kerry International Dark Sky Reserve, the importance of which is noted in the previous chapter and in 11.3.3.1. Furthermore, KCC should commit to preventing the installation of LED lights in the outdoors given their detrimental impacts on biodiversity. The emphasis needs to be on the overall reduction in artificial lighting.
Chapter 11 ought to acknowledge the current and potential contributions of the PPN to environmental conservation, and the plan should more firmly commit KCC to supporting our sector’s efforts in this regard. There is considerable scope to support and increase citizen-science initiatives.
The commitments in respect of landscape protection are welcome, and these need to be accompanied by due enforcement of the terms of planning permissions, including the screening of buildings.
Chapter 12 ought to include an objective to ensure the undergrounding of electricity cables to the greatest extent possible.
We welcome the commitment (end of section 13.1) to waste minimisation, and we recommend that the education and community sectors be added to the partners mentioned here (in addition to agencies).
The objectives set out in relation to water quality / protection ought to acknowledge the importance of working collaboratively with stakeholders, particularly farmers and other businesses.
Map 13.2 highlights the need for civic amenity sites in North Kerry, and this ought to be specified in KCDP 13-29.
We welcome the commitments to the circular economy, and we encourage KCC to pursue partnership with the PPN in its development.
Section 14.2 needs to dovetail more explicitly with the material presented in Chapters 1 and 2.
We welcome the modal and intervention hierarchy presented in Fig. 14.1, but we need to see this following through more explicitly and consistently throughout this chapter.
This model interlinks with the attainment of several objectives presented in Chapters 4 and 6, and the content of Chapter 14 needs to link with the earlier sections.
The chapter (Table 14.3) is very specific in respect of roads projects, but the same detail is not provided in respect of active and sustainable travel and /or public transport; this runs counter to the chapter’s opening statements and Fig. 4.1, and it contradicts the opening two chapters of the draft plan.
Map 14.3 is entitled ‘tourist routes’, although it only shows coastal routes. The well-trodden Sneem to Moll’s Gap road, among others, is missing. As the map is within a plan (not a baseline report), it should show routes that ought to be developed over the plan’s lifetime. These should be in areas that have low volumes to date, particularly in North and East Kerry.
Section 14.4.3 ought to commit to supporting free parking at train and bus stations for public transport passengers.
The plan has only one objective (14-41) in relation to public transport, and it has eight (14-23 to 14-26 and 14-32 to 14-35) relating to roads. This imbalance needs to be addressed.
The commitments in respect of rail are welcome, but they need to be expanded by ensuring increased frequency.
KCDP 14-42 should also use the word ‘facilitate’ in relation to the development of the rail network.
KCDP 14-44 should insert the word ‘and /’ before ‘or’, so as not to close off the possibility of re-opening any part of the rail network. Other local authorities e.g. Cork and Meath have played important supportive and facilitative roles in this respect.
We welcome the commitment (KCDP 14-45) to supporting local link.
Map 14.4 highlights the need for broadband connection points in North Kerry, and this ought to be catered for in the objectives presented on page 261. Additionally, the Dingle / Corca Dhuibhne Smart Village strategy merits support in this context.
