we wish to make the following points:
In relation to Chapter 3 Part 3.15 (pg 46), Objective HO056 would be problematic in many cases as it talks of an absolute density of 25 houses per square kilometer.
Part 3.16, objective HOP26 would be problematic for agricultural/ rural housing development where the only access is via a regional road.
Part 3.13 (pg 30-43) Sets out rural housing guidelines. On the economic needs, the 15ha idea is too specific. For example, there are several operators who do not own any land and still have significant farm operations. These should fall into part (ii). But it is not clear if you need to own land. We would also see a problem with the 7 years prior ownership. It shouldn't cause an issue for most but a person who had to move for example, due to compulsory purchase would not be able to provide themselves with a house for 7 years.
In relation to the social side of things, 16 years is unnecessarily long and the emphasis should be on establishing genuine cases from those which are not. We welcome objective HO045 (Page 37) which puts a minimum term of occupancy to 10 years from a previous 7 years. Enforcement of the same would be more appropriate than putting extra restrictions on genuine people who have a genuine requirement to live in their home (not their property).
Chapter 15 Part 7.7 has minimum building guidelines for rural development. A setback distance of 91 metres is given to national roads and motorways. This was also in the previous Development Plan. In some cases, this means a farmer could have a motorway go through their land and then when they want to add additional buildings a significant portion of their land is effectively frozen. This would not have been included in the compensation given for the same lands.
This chapter is relatively positive towards agriculture, however page 6 outlines guidelines for new rural enterprises which could be supplying agriculture. A maximum 200m2 size is quite small and in the wording expansion of existing enterprises will be encouraged to move to new serviced sites. Many agri-merchants are located in rural areas, so they could be affected when scaling up. Enterprises such as these would not always be suited to town settings. Section 9.4 -9.7 deals with agriculture, equine and horticulture. Just to emphasize, we are noticing a recognition of the importance of agriculture and food security at national and EU level since the Russian invasion.
Part 9.8 sets objectives for rewetting of bogs. There should be an objective that the same does not interfere with existing drainage of surrounding lands.
In recent years, road alterations have little consideration for agricultural vehicles traversing country roads. Kildare County Council should take account of the vehicles which are needed to access farms when carrying out alterations. All too often roads are made narrower as a traffic calming measure resulting in wide vehicles being unable to safely manoeuvre. Basically, the vehicles that need to use the road need to be taken into account when designing new junctions, putting in cycle lanes etc. Most roads will have farms along them. Designs need to be practical.