Consultation on the Retail Strategy for County Louth An Taisce welcomes the preparation of a Retail Strategy. It is noted that this consultation is running concurrent to the review of the County Development Plan (CDP). It is considered the CDP, notwithstanding the above strategy, should adopt the Retail Strategy and include a section entitled Retail modeled on the outcome of this strategy. In any case, An Taisce would like to make the following comments which we request the Planning Authority (PA) take into consideration in the finalisation and adoption of the strategy, including the accompanying Strategic Environmental Assessment (SEA) and Article 6 Habitats Directive Assessment (HDA). We would also request that the PA make An Taisce known of any further consultation periods regarding the making of this strategy and issue An Taisce with notification of any future proposed amendments to the Draft Retail Strategy and notification of the final adopted Retail Strategy Recommendations Approach to Economic Development: Continued GDP economic growth in the Irish economy is unlikely and, in any event, is unsustainable in the long-term. It is prudent to plan now for a different economic future including low-growth, no-growth or contraction scenarios. The Retail Strategy must include policies which support the development of a vibrant local manufacturing base that is based on the sustainable use of local indigenous resources and local markets will make the locality more resilient in long run e.g. food processing, basic manufacturing etc. The Retail Strategy must plan for higher and more volatile energy prices (and high material costs too) over the period of the Retail Strategy and to use this window of opportunity to transition the Retail Strategy area into a post-carbon, low energy, low consumption and resilient locality. Critical Mass or ‘Development at All Costs’?: The Retail Strategy must set out a carefully crafted strategy and form a binding contract between the PA and the community based on proper planning principles. The current economic climate must not be used as a short-sighted opportunity to loosen proper planning regulation. Following any future precedential decision from An Bord Pleanála which overturns a PA decision, a review should be undertaken to examine the basis on which the decision was made, and a report presented to Councilors on required amendments to the Retail Strategy required. Rural Enterprise Ireland’s principle resource is our abundant availability of fertile agricultural land. The Retail Strategy must include policies to promote the sustainable local exploitation of natural resources for local markets. The Retail Strategy should include a policy for the promotion of local farmers markets and identify locations where farmers markets can take place. Retail Development: The Retail Strategy must include policies for the prohibition of out-of-centre retail development. The PA must take an active role in site assembly for new retail development on brownfield and infill sites, including using CPO powers where necessary to provide for the sensitive revitalisation of town centres. The PA must require the introduction of car parking charges for out-of-centre retail development and introduce a corresponding S.48 waiver for development contribution levies in lieu of off-street car parking for new retail development in town centre locations. The Retail Strategy must include a specific policy that explicitly provides that the change of use of retail warehouse units to non-bulky goods comparison and/or convenience uses will not be permitted. The Retail Strategy should include a policy which restricts large floor-plate multiples, which are dependent on complex oil-dependent supply chains, in favour of smaller floor-plate local shops. Physical Infrastructure: The Retail Strategy must include a detailed audit of all physical infrastructure (i.e. waste-water, potable water, ICT, transport, electricity etc) including location and capacity, to be used as a key criteria in determining the appropriate quantum and location of future new development. Develop an Infrastructure Delivery Plan - The Retail Strategy must include a clear programme of implementation which links the delivery of key pieces of social, physical and environmental infrastructure with the sequential and phases development of zoned land. It must clearly and transparently inform the citizen and manages expectations about the future development of an area. It does not include policies and objectives unless the PA is confident of their successful implementation. The Physical Infrastructure Audit should include an “Oil Vulnerability & Carbon Price Impact Assessment” to explore the threats from inflated and volatile oil prices together with the future (shadow) price of carbon. This should be undertaken for both capital and operational municipal functions (e.g. sewage treatment, water supply, road developments, road repair, flood defences etc). New road objectives in the CDP must be discontinued. Investing further public monies on oil dependent transport infrastructure is wasteful. Implementation & Monitoring: Targets & Monitoring: The Retail Strategy must include a detailed implementation and monitoring schedule which outlines the manner in which the Retail Strategy envisages the future development of the area. A designated implementation officer must be appointed to oversee the implementation of the Retail Strategy and ensure joined up thinking between development management, forward planning, environment, service, infrastructure provision etc. Conclusion The key priority of the Retail Strategy must be transition to a low-carbon society and economy and to mitigate the significant risks associated with rising energy costs and climate change adaptation. Business as usual is no longer an option, we can no longer afford to continue the pursuit of the failed short-sighted policy approaches of the past and that our collective future must be different. The international and national economic recession has provided a narrow window of opportunity to take action to concentrate investment and focus policy on the transition to a post-oil low-carbon locally resilient society. This is the major challenge of our time and will require urgent understanding of the nature of the challenges; no shortage of decisive political leadership, a radical change of direction together with robust and, in some instances, policy implementation which will be politically unpopular in the short-term. The statutory planning system, through the regulation of physical development and land use, has the most critical role to play in facilitating this transition. The success or otherwise of the forthcoming Retail Strategy can only be judged against verifiable and implementable criteria which are subject to ongoing monitoring. We look forward to making further submissions to the Retail Strategy in due course. Download the submission here.