Submission to ABP on Ringaskiddy Strategic Infrastructure Application

19th April 2016
Submission Summary

Ringaskiddy Strategic Infrastructure Application

Key Issues:

Given the scale of the proposal, we suggest four key considerations to be explored and taken into account, as outlined in our original appeal;

  1. Planning history
  2. Site suitability – sea level rise
  3. Visual and amenity impacts
  4. Meeting climate targets

Planning History:

This is the third application for this type of development at this site.

The first application was submitted to Cork County Council in 2011. It was considered that the development would contravene the 2003 Cork County Development Plan and was refused by Cork County Council.

Following refusal by Cork County Council, the applicant appealed to An Bord Pleanála. Following a 13 day Oral hearing in Oct. 2003, Inspector for the Board, Philip Jones recommended refusal on fourteen grounds. Notwithstanding the recommendation for refusal, An Bord Pleanála purported to grant planning permission. Judicial Review proceedings were commenced against the Board’s decision. The parties to the litigation agreed to treat the proceedings as at an end and not to continue to trial.

A second application was lodged in 2008 with the Board as a Strategic Infrastructure. The inspector recommended refusal and on 9th June 2002, the Board refused the application. Judicial Review proceedings were initiated by the applicant. The week before the hearing was due to be heard, the Applicant advised that they were not proceeding any further with its case.

The current application fails to properly address grounds of refusal on previous An Bord Pleanála decision for a 240,000 tonnes pa. incinerator.

Sea level rise:

The impact of sea level rise of water tables is inadequately assessed. The considerations outlined in the Inspectors Report on PA0010 remain applicable to the current proposed application.

Adverse Impacts on the surrounding environment and Martello Tower Protected Structure:

The proposed development would have an impact on amenity, including in views across the harbour and from Cobh. The concerns raised in the Inspector's report on PA0010 remain relevant and the application has failed to mitigate these issues.

Furthermore, the proposal directly affects the setting of the Napoleonic Martello Tower and its relation to other historic monuments and features in the harbour, including Spike Island.

Meeting Climate Emission Targets:

The application is presented as contributing to alternative energy production.

While use of waste as a resource for energy production is accepted in principle, and supported by policy and guidance, the most efficient use of this energy is through use of the steam for district heating, rather than electricity production which is significantly less efficient. The process of energy recovery proposed is for electricity generation and the application site is not suitable for district heating connection.

An Bord Pleanála reference http://www.pleanala.ie/casenum/PA0010.htm

An Taisce's submission here: