The following is An Taisce’s submission to Limerick City & County Council opposing the plans by Limerick Institute of Technology to develop a campus at Coonagh Cross.
An Taisce objects to the proposed application on a number of grounds. The application constitutes peripheral development of the city and therefore contravenes the stated objectives of the Limerick City Development Plan and the Limerick 2030 plan. The proposed development is situated on a flood plain, and although it refers to a change of use of existing buildings, the applicant makes clear that it intends to develop the site significantly in line with its Master Plan. The plan will lead to an increased dependence on car transport. There is insufficient public transport provision at the proposed location, and the applicant’s own data shows that the majority of journeys to the proposed development will be undertaken by private car. We agree with the Limerick 2030 plan that:
Attracting the best academics and the best students requires the provision of a quality higher education offer embedded in a high quality urban living environment…Providing a range of well linked facilities both in the higher education institutions and in the City can create an urban environment that is greater than the sum of its parts
and we believe that approval of this application would work against these aims.
This submission objects to the proposed development on the following grounds:
- Serious flood risk
- Insufficient assessment of alternatives
- Precursor to future inappropriate developments
- Inadequate public transport accessibility
- Current commuting patterns of LIT students and staff
- Inadequate parking provision
- Feasibility of proposed ‘Action plan’
- Contravention of Limerick City and County Development Plans
1. Serious flood risk
We acknowledge the assessment of the applicant that:
The Limerick City Development Plan 2010-2016 has identified the Coonagh Cross Shopping Centre as being in a Flood Plain Zone A area. This is the highest flood zone category available and identifies the area as being at high risk.
We consider that the mitigation measures detailed by the applicant to be inadequate. In particular, the commitments detailed in the application that:
- “removable flood barriers will be installed at all door openings. These barriers will be min of 1m in height”
- “it is proposed that sensitive infrastructure such as comms rooms and servers will be located on the first floor”
show that this development on a flood plain requires mitigation measures that are reliant on human intervention to deal with 100-year flood situations. We do not believe that such development is appropriate given the flood risks associated with the Shannon basin and the increased risks posed by climate change.
2. Insufficient assessment of alternatives
The applicant has not sufficiently demonstrated that the site of this development, on the very outskirts of Limerick City, is preferable to other sites in the city centre which would better align with the Limerick City Development Plan. The only statement in the applicant’s submission that indicates any reference to the assessment of alternatives is the following:
“There are no appropriate alternative structures with spans of the scale required, within the city centre or closer to the existing Moylish campus, which could be converted to appropriate educational spaces”
The applicant does not detail the “spans of the scale required”, or provide any other information that would indicate that city centre sites were considered in the site selection.
3. Precursor to future inappropriate developments
While we acknowledge that the planning application is solely restricted to the change of use of an existing building, the applicant has acknowledged that:
“the current long-term plan is that the wider Coonagh Cross landholding may accommodate further buildings and sports facilities as the campus is expanded”
As the applicant has indicated that their Masterplan involves building on areas north of the current development (which currently have a zoning of Public Open Space), we believe that approval of this application would encourage pressure on lands that are currently zoned as Public Open Space, as well as further encroaching on the existing flood plain.
4. Inadequate Public transport accessibility
The LIT campus at Moylish is served by Bus Éireann route 302 which has a service frequency of 20 mins from 07:20 to 19:00 and 30 mins thereafter until 2300.
Although the 302 route is referenced in the Mobility Management Plan, the applicant notes that the development is “approximately 1km from the nearest bus stop on route 302”. We do not consider that route 302 can be considered to “serve” the proposed development, especially given the circuitous route that the 302 takes from the city centre through the housing estates of Caherdavin before reaching its final stop which would be the closest to the proposed development.
The proposed development would be served by Bus Éireann route 343 which runs from Limerick to Ennis. The closest bus stop is approximately 500m from the entrance of the proposed development. Accessing the proposed development from the bus stop would involve crossing a busy road at a roundabout with no pedestrian signals. The service frequency is every 60 minutes from one extra service in the evening and two in the morning: a third of the level currently experienced by the Moylish campus. There is no evidence from the application of any consultation with the bus operator when preparing this application.
5. Current commuting patterns of LIT students and staff
The Mobility Management Plan submitted as part of the application refers to a study carried out by Limerick Smarter Travel of the commuting patterns of staff and students at LIT. The figures were presented in pie chart form in the application, these are reproduced in the table below for clarity, together with a numerical prediction based on a peak level of 800 students and 80 staff stated in the application:
|Commuting mode||Staff share (%)||Number of staff based on 80 peak||Student share (%)||Number of students based on 800 peak|
|Driving a car||84.1%||67||39.8%||318|
|Passenger in a car going to same destination||1.9%||2||7.7%||62|
|Passenger in a car going to a different destination||1.2%||1||4.8%||38|
|Lorry or van||0.8%||1||0.9%||7|
|Motorcycle or scooter||1.2%||1||0.4%||3|
We believe that, despite the ‘soft’ measures included in the Mobility Management Plan to encourage more sustainable transport modes, that the modal share of bus, train, walking and bicycle journeys will decrease from the current baseline in Moylish, for the following reasons:
- The proposed development is 4.1 km walking distance from the city centre (O’Connell St), compared to 2.6km for the Moylish campus, representing nearly 60% increase in distance and journey time. Walking from the city centre would take 50 minutes at average walking speed.
- The bus frequency will drop from 20 minutes at Moylish to 60 minutes at the proposed development. A frequency of 60 minutes is low enough that arrival times may not suit the timetables of students and staff, encouraging a shift to other transport modes
- The main cycle route along Condell Road is along a route originally designated as a National Primary Route with high design speeds, which is less safe for cyclists than the more urban route towards the current campus at Moylish. This suggests that fewer people will cycle to the proposed development
6. Inadequate parking provision
Even if the modal share of different transport modes remains the same as at the current campus in Moylish, the car parking provisions detailed in the application provide for less than half what is necessary based on current patterns.
The application estimates that there will be a peak usage of 80 staff and 800 students, and that 214 car parking spaces will be provided. The table below shows the projected car needs of the proposed development based on figures from the applicant:
|Modal share||Staff share (%)||Number of staff based on 80 peak||Student share (%)||Number of students based on 800 peak||Total demand for car parking||Car parking spaces provided||Excess of parking demand vs spaces|
|Driving a car||84.1%||67||39.8%||318||385||216||78%|
The application also notes that 80 out of the proposed car parking spaces would be reserved for staff and visitors. This would result in only 136 car parking spaces available for students, which would result in a 133% underprovision of car parking spaces based on current commuting patterns, which, as explained earlier, is only likely to increase due to the proposed site’s inaccessibility by more sustainable transport modes.
7. Feasibility of proposed ‘Action plan’
The Mobility Management plan submitted with the application includes an ‘action plan’. We do not believe that this action plan will have a significant impact on modal share for the following reasons:
- The action plan consists of largely aspirational measures to persuade people to switch transport mode, such as “provide umbrella for employees on wet days”, “participate in national cycle week”, “display a local area map with public transport stops / route numbers marked”, “raffle travel mugs, vouchers etc. for car sharers”
- The applicant provides no evidence of the estimated effectiveness of these measures
- The applicant states that LIT have had an ‘Action plan’ under the Limerick Smarter Travel Workplaces Programme for their Moylish campus since January 2014. We would expect that the applicant would be able to demonstrate the effectiveness, if any, of these kind of measures after two years of implementation of their action plan.
- Inducements to change behaviour will be outweighed by the significantly poorer access (60% increase in walking/cycling distance, 33% reduction in bus frequency) offered at the proposed development
8. Contravention of Limerick City and County Development Plans
We consider that this application contravenes various statutory planning guidelines as detailed below:
Limerick City Development Plan p3.1
It is the objective of Limerick City Council:…To ensure new locations for employment have access to public transport.
Reason: This development does not have access to public transport apart from an infrequent hourly bus service.
Limerick City Development Plan p5.1
The key features of a more sustainable form of spatial development for the Limerick Area are:
Development that is concentrated rather than dispersed allowing for it to be served more efficiently by public transport.
Improved access to locations of employment, education, health, leisure and residence through the provision of a high quality sustainable public transport system.
Reason: This development is at the very edge of the Limerick Metropolitan area and is surrounded by land of agricultural uses on three sides. The application represents a dispersed rather than concentrated development which will disimprove access to a location of education and is not optimal for serving with a high quality sustainable public transport system.
Limerick City Development Plan p5.3
The key targets of Smarter Travel are to reduce work-related commuting by car from 65% to 45%, and increase other modes such as walking, cycling, public transport and car pooling to 55%.
Reason: The current car commuting levels at LIT in Moylish are over 80% for staff and will increase due to the site’s inaccessibility by more sustainable transport modes.
Limerick City Development Plan p5.6
Policy TR.9 Cycling & Walking
It is the policy of Limerick City Council to prioritize the provision of safe facilities for Pedestrians and Cyclists throughout the City….Require planning applicants to demonstrate that their development proposals will be easily accessible by pedestrians, cyclists and public transport users.
Reason: The applicant has failed to demonstrate that the proposed development will be easily accessible by sustainable transport modes
Limerick City Development Plan p13.4
The 2030 Economic and Spatial plan proposed a series of co-ordinated investment programmes to enhance the City centre. Central to this is the preparation of a City Centre Transport Strategy that would:…Accommodate improved access to / from the third level institutions for pedestrians,
cyclists and public transport users.
Reason: This development would result in less favourable access for pedestrians, cyclists and public transport users, with a 60% increase in walking/cycling distance, and a 33% decrease in bus service frequency, over the current provision at the LIT campus in Moylish.
Limerick City Development Plan p2.4
Policy SC.2 It is the policy of Limerick City Council to have regard to local strategies in particular the Limerick 2030 Economic and Spatial Plan.
Reason: The proposed development is in contradiction with specific proposals under the Limerick 2030 plan, as detailed below
Limerick 2030 plan p18
The Economic Strategy of the Plan will be delivered and implemented through the pursuit of five interrelated objectives…4. Create a vibrant City Centre economy with a new mix of economic uses and a strong education presence
Reason: The proposed development involves a new education presence on the very outskirts of the city, far from the city centre
Limerick 2030 plan p30
Project 1: The City Centre Higher Education Campus…This project is a major catalytic project which involves the creation of a new Higher Education facility in Limerick City Centre involving the University of Limerick, Limerick Institute of Technology and Mary Immaculate College….Increasingly, students and higher education staff are placing more value on the quality and diversity of their wider living environment rather than focusing on the immediate academic facilities. Furthermore, students are demanding universities that are more connected socially and physically, not just to the surrounding urban area but to national and international locations…In response to this, the anti-urban bias traditionally held by higher education institutions is being reversed. It is no longer the intention for teaching, research, accommodation and ancillary social activities to be concentrated in self-contained campus environments. Attracting the best academics and the best students requires the provision of a quality higher education offer embedded in a high quality urban living environment…Providing a range of well linked facilities both in the higher education institutions and in the City can create an urban environment that is greater than the sum of its parts…. In embracing the sustainability opportunities provided by the City Centre locations, new facilities should not provide significant parking that breaks-up and disjoints the physical landscape.
Reason: Given that a major new city centre campus is planned involving the applicant as one of the lead partners, this will free up space at the applicant’s current campus in Moylish, rendering the development unnecessary. If the proposed development is approved, it will undermine the case for the City Centre Higher Education Campus as there will be more space on the applicant’s current Moylish campus for future developments.
Limerick 2030 plan p69
The most successful Cities have a City Centre higher education facility or cluster. Limerick has international quality 3rd level education institutions on the edge of, and outside the City Centre. This means that much of this potential is lost. City Centre facilities would go a considerable way towards redressing this balance.
Reason: The proposed development would result in a 3rd level education institution having a presence at a location even more peripheral to the city centre than the current situation.
Mid-West Regional Planning Guidelines p101
Development Plans should include policies to ensure that adequate land is available for the provision of additional research and education facilities in the vicinity of the principal third-level institutes, that the infrastructure necessary to serve such developments are facilitated, where sustainable, and that access by both public and private transport is facilitated.
Reason: There is not enough facilitation of public transport at the current location