Proposed Motorway Plaza at Jn 12 – In my view – Right idea – wrong location – wrong size.
Some background to my submission to object to proposed off-line large Motorway Service Area (MSA) at Jn 12 in the attached ClareFM podcast . I agree that an MSA needs to be built in Clare but in a correct location that will not further lead to depopulation & decline in Rural Clare . It refers to my support for a correctly sized on-line MSA between Jn 10 and Jn 11 . This site near Carrigoran has been identified following extensive feasibility studies & public consultation being carried out by the independent agency , Transport Infrastructure Ireland (TII) , that builds the motorway system on behalf of the State . I proposed that if TII do not proceed to build an on-line MSA between Jn 10 and Jn 11 that the Pat McDonagh should be given the option to build there.
Submission to Clare County Council planning section objecting to Motorway Plaza planning application to be built at Junction 12 on the M18
Dear Senior Planner ,
Please accept this as my objection. Apologies ignore earlier versions sent
“ On-line MSA “ are the preferred type in terms of proper planning and sustainable development as they are constructed on the Motorway between existing junctions and not at existing junctions. If a MSA is built at motorway junctions they are are termed “off-line “ as they not alone survive motorway traffic but also become a retail and hospitality destination in its own right competing for local business with adjoining towns and villages as the local roads are very confidently connected to the junction location.
I am lodging an objection to the planning application on the grounds of
Bad planning and development in terms of location and scale of the development in terms of threat to urban businesses and rural population
Detailed grounds of objection.
1. Contrary to Clare County Development Plan ( CCDP) 2017-2023 .
This is a statutory document which forms a contract between the planning Authority and it’s citizens. It
sets out the planning policy framework within which the stated vision for Clare will be realized by 2023. The CCDP has high 18 level goals with associated aims and objectives . The proposed development in my opinion is contrary to goal numbers 2 ,4, 6, 8, 9,15,16, 18 and the associated aims and objectives. It could be argued that the proposed development is not longterm Plan Led as the relatively recent zoning of the subject rural site demonstrates.
The proposed development is contrary to the CCDP stated Core Strategy and - in particular with reference to the Core Strategy map - will have a negative impact on shops and associated petrol stations in Service & small towns and large villages in West , North Mid & East Clare but also in small villages located in the identified “ Structurally weak “ areas within the catchment and commuter area of the proposed development.
2. Clare Rural Development Strategy.
As a member of the Clare Rural Develoment Forum I believe that the impact of the proposed development would be contrary to the 2017 adopted Clare Rural Development Strategy.
As this planning application is for an off-line MSA I wish to object on the grounds of
(1) bad planning due to the huge negative impact on existing retail , food and fuel services located both in urban and rural Clare that service the commuter to Shannon/Limerick.
(2) Due to the impact on viability of rural petrol stations will lead to further erosion of services in Rural Clare and subsequently to retail depopulation. Clare Digital Strategy (CDS) 2023 at page 5 states that “ between 1981 and 2016 , Rural Clare’s share of the County’s population declined from 40% to 29% while Ennis/Shannon/ limerick urban corridor experienced population growth of 61%. “ .
Having worked in Clare as a Fire Officer for a period in the 1980s I was involved in inspecting petrol stations in the County under Dangerous Substances Regulations. From my knowledge since the 1980s over 20 small petrol stations closed in Clare with the majority in rural villages. Fuel sales in village petrol stations which are associated with local shops are between 4,000 to 10,000 litres a week.( averaged 7,000 l per week ) The fuel sales in a MSA as proposed are estimated at around 135,000 litres a week ie sales of circa 7 million litres a year . This is nearly the combined weekly fuel sales of 20 rural petrol stations.
Even if the MSA only achieves a 10% “turn off “rate for commuters from Rural Clare using the M18 it will reduce the turnover at village petrol stations and associated shops to unsustainable level resulting in closure and further erosion of services in the rural areas
(2) Environmental damage due to additional journeys and traffic generation to the proposed MSA junction from local consumers
(3) Clare County Council is due to engage consultants to prepare a Strategy in order to better plan to address the social , economic and environmental needs/benefits and impacts of Tourism for County Clare . This development which is heavily focusing on the attracting Coach and bus business is premature until that strategy has been adopted .
I note that in UK the trend is for hotels to be planned and built at MSA which if such a development occurred in Clare would again take further business and activity from the Local Tourist sector in adjoining towns and villages.
Action 1.4 : Rollout of Innovation Hubs and Micro-Hubs across the County.
3. Proposed development is contrary to Council adopted Clare Digital Strategy 2023.
Based on what has happened at Obama Plaza ( 6 meeting rooms with business conference with capacity ranging from 9 to 120 occupants ) at Jn 24 future Potential conferencing/meeting facilities in the much larger proposed development at Jun 12 would undermine the Council investment in Digital hubs as part of the Clare Digital Strategy 2023 .https://www.youtube.com/watch?v=ZbmM7b7W1ls
Clare County Council launched a Clare Digital Strategy 2023 , in a Council issued pr piece 23/3/18 the CE explained “the overarching theme of which is supporting Rural, Community and Economic Development. Its key aim will be to bridge the digital divide as well as creating digitally intelligent communities in Clare. While a strategy in its own right, this Digital blueprint is a critical facilitator. It will enable Clare County Council to further the objectives of the Clare Rural Development Strategy across the county."
The pr piece went on to state
“ Three digital hub facilities developed by Clare County Council were officially opened in Kilrush, Miltown Malbay and Feakle today by Pat Breen, T.D., Minister of State for Trade, Employment, Business, EU Digital Single Market and Data Protection.
The facilities, which are part of the Local Authority’s DigiClare.ie initiative and are among the actions identified in the Clare Rural Development Strategy 2026, will support rural social enterprises and the wider community by providing flexible, affordable hot-desks, co-working, conference and training facilities for residents, visitors and entrepreneurs for as little as €10 per day.
Over the next 12 months, Clare County Council will be furthering its plans to develop a large-scale Broadband Hub in Ennis, including a hot desk facility and incubation units. A multi-service centre incorporating a Broadband Hub and other social and community services is also planned for Ennistymon.”
The proposed development if it included what has been done in Jon 24 Obama Plaza could undermine the uptake on the use of meeting conference facilities at the future ENNIS Hub . In addition
For more information and to view a tube showing the business meeting facilities the Digital Hubs, visit www.DigiClare.ie .
The scale and location of this planned “off-Line “ MSA in the Centre Geographically and from a Roads network point of view on the Shannon/Limerick commuter route of the County is the worst possible development in terms of ; keeping the lights on in Rural Clare ; for residents in rural & small village being able to get basics locally such as petrol and local shops ; Getting the County and it’s citizens “On-line “ in digital terms.
A. Clare County Council through it Development plan , it’s Rural Strategy and it’s Digital Strategy is committted to the protection of existing rural settlements , to the increase in rural services in order to reverse Rural depopulation and as one of the 5 Key Strategic Digital Action of “ improving access to of digital infrastructure “ by investing in the provision of Digital Hubs to bring activity into late towns and villages for work and meetings.
This proposed development in its scale and location in my view will lead to job and services losses in large areas of Rural Clare and undermine the Ennis Coach Park provided by the Local Authority.
B Proposed Compromise to meeting Motorway traffic needs whilst protecting Rural Clare.
In the interest of Proper Planning and Development I wish to make the following suggestion as a possible compromise sustainable solution to the provision of a Clare motorway drivers rest and fuel solution needs though a combination of
(1) provision of an on-line MSA to service motorway drivers needs at the site located between junction 10 and 11 which has been identified following a feasibility study by TII . If TII do not intend developing this site I would suggest that Pat McDonagh be given the opportunity to do so.
(2)support for & recognition of existing off-line fuel and food facilities in both Bunratty and Crusheen villages which are located immediately beside the National Road network with access slip roads already provided .
Johnny Flynn , Cllr