Submission against the proposed Retail Outlet Centre in Carrigtwohill

A lot has been said already about the proposed Retail Outlet Centre and CBA President Eoin O'Sullivan and CEO Lawrence Owens have commented on several media on the subject. We believe that the City Centre and the existing shopping centers should be further developed and thriving before we should want another large retail centre that will take away from an already struggling retail sector in the city.

This was the case before COVID-19 and even more so now. Underneath you will find the full submission from the CBA to Cork County Council which further explains our reasoning behind opposing this development.

 

Executive Summary

On 6th March, 2020, the Minister for Housing and Urban Planning notified Cork County Council of his intention to issue a Direction pursuant to Section 31 of the Planning and Development Act 2000 (as amended). The draft Ministerial Direction related to Variation No. 2 of the Cork County Development Plan 2014 (Retail Outlet Centres).

The reasons given for the draft Direction were as follows:

  1. Variation No. 2 has not been made in a manner consistent with the recommendations of the Office of the Planning Regulator under section 31AM(8).
  2. The Cork County Development Plan 2014 as varied by Variation No. 2 purports to identify a preferred location for a retail outlet centre to serve the Cork Metropolitan Area in advance of the preparation of a joint retail strategy as required under the Guidelines on Retail Planning published by the Minister in April 2012 under Section 28 of the Act and is inconsistent with the Guidelines on Spatial Planning and National Roads published by the Minister in January 2012 under Section 28 of the Act, and therefore fails to set out an overall strategy for the proper planning and sustainable development of the area.

The CBA is of the view that the recent decision by Cork County Council to proceed with this change to the Cork County Development Plan 2014 is not in accordance with the proper planning and sustainable development of Cork and should not, in any case, be contemplated prior to the preparation by both local authorities in Cork of an updated retail strategy for the Cork region as required under retail planning guidelines.

The CBA echoes the concerns articulated by the Planning Regulator that the council’s decision was premature and resulted in a Development Plan that fails to set out an overall strategy for the proper planning and sustainable development of Cork which represents a breach of the legislation.

 

Introduction 

The CBA welcomes the opportunity to make a submission to the draft Directive and as a key stakeholder representing over 200 businesses in the Cork City functional area [including Cork City and the retail centres of Ballincollig, Ballyvolane, Mahon, Wilton and Douglas] considers active engagement between Local Authorities and businesses as an imperative component of successful governance. Maintaining the health and viability of these key retail centres whilst ensuring the city centre is protected and safeguarded as the prime retail area and economic heart of the region is a key aim of the CBA as a high quality retail environment is a key ingredient to a successful city centre.

In keeping with the core mission and objectives of the CBA, the CBA strongly advocates any new initiatives which will create a better business environment for traders, employers, customers and tourists. With this in mind, the CBA places a high level of importance on supporting developments that serve to strengthen and enhance the city and wider city region’s retail position but equally places a high degree of importance on opposing developments which it deems will have a negative impact on the ability of the existing retail sector to remain competitive.

The CBA welcomes an evidence-based approach to new developments and welcomes the fact that a study was commissioned to examine the evidence for an Outlet Centre in the Cork Metropolitan Area.

The Study on the Requirement for Retail Outlet Centre(s) in the Cork Metropolitan Area was prepared by MacCabe Durney Barnes and Transport Insights who were appointed initially by Cork County and City Councils to prepare a Retail Study on the requirement for a Large Retail Warehouse Development in Metropolitan Cork.  The brief for the study was agreed following two meetings with Cork County Council and Cork City Council in late 2018.   Sometime after that, there was a suggestion that the study consider the need for a Retail Outlet Centre(s) specifically within the Cork Metropolitan Strategic Planning Area and Cork City. Following this transition from Warehousing to Retail Outlet, it is understood by the CBA that the study was solely commissioned by Cork County Council. This is extremely regrettable from the viewpoint of achieving the proper planning and sustainable development of the Cork Metropolitan Area as the premise for retail strategies in Cork City and County is that they are joint strategies, intended to be adopted and implemented by both local authorities, and that new developments should be measured against a set of jointly agreed principles and quantitative benchmarks.  As such, in the opinion of the CBA, the study from its inception was flawed.

 

Moreover, the entire approach to the proposed development by Cork County Council is extremely questionable: 

 

Firstly, there is no provision in the existing Joint Retail Strategy for a Retail Outlet Centre to be developed, so this proposal is completely without substantive policy support.  

 

Secondly, following the recent boundary extension of Cork city, Cork County lost a significant proportion of its rates base to the City and the revised study commissioned [without the involvement of the City Council] appears to be a concerted attempt to reclaim the revenues lost as a result of the boundary extension. 

 

Thirdly, following a clear developer-led proposal made to the council at pre planning stage for a development of a Retail Outlet Centre at Carrigtwohill, the brief of the study was changed to ‘Outlet Centre’ demonstrating the County Council’s reactive rather than proactive attitude to such a major strategic development that will have far reaching consequences for the City Centre as well as the nearby county towns in particular Midleton.  

 

There are a number of caveats as well as flaws in the report:

Site Selection Coincided with a Developer-Led Proposal

  • the report was intended to be a ‘high level strategic assessment of whether or not there is sufficient headroom to support the provision of a retail warehouse initially and retail outlet centre subsequently in the Metropolitan Cork Area and if so identify at a strategic level the sub catchment within Metropolitan Cork that is most suitable to accommodate such a facility’.

What is questionable in this instance is that a site near Carrigtwohill was brought forward by a developer at around the same time as the MDB ‘brief’ was changed from a Retail Warehouse to a Retail Outlet Centre. It is suspiciously coincidental that the study just happened to recommend the site in question in Carrigtwohill as the most suitable location for a Retail Outlet Centre, whilst blatantly omitting the city centre from the study area.

 

Loose interpretation of Policy

  • It is considered that a very loose interpretation of policy was applied in the policy review section of the MDB report. according to the report:

“The policy review has reaffirmed that the city centre/town centre first is the priority for new retail development which is in accordance with the GRP 2012 tests of the sequential approach. However, as has been highlighted, the 2018 Variation 1 of the CCoDP 2014 and in a select number of the 2017 MDLAPs introduce the policy potential for ROC/Outlet Centres being part of innovative retail formats in centres around the County. Therefore, whether the need for a ROC(s) is confirmed or otherwise in the study, the introduction of one or more could be in compliance with retail planning policy objectives.” 

This is an interpretation of current policy which is not substantiated by any evidence. There is no weighting given to the primacy of the city centre or recognition that it is the ‘first priority for new retail development’ in the consideration of locations in the city – this is a clearly not in accordance with current from policy. The relative ‘health’ of the city centre is also not considered.

 

The Exclusion of the City Centre

  • Perhaps the biggest flaw of the report is the fact that the City Centre was excluded from the site selection process when the study brief was for it to include the entire Cork Metropolitan Area [CMA],  of which the city centre is the heart.  The report suggests that the sequential test should be undertaken to ensure the city centre is recognised as the prime retail destination but fails to adequately consider same. 

There is in excess of 150 hectares of land at the docklands which was not considered, a ‘do nothing approach’ was not considered [which is a key element of any meaningful assessment of need]. Given that there is a reported 18% vacancy level in the city centre [taken from the MDB Report] – it is remarkable that the scope for the city centre to accommodate the floorspace proposed was not considered. The recent announcement that a major anchor store on Saint Patrick’s Street [Debenhams] has closed [which is estimated between at 30%-25% the size of the proposed ROC] and the fact that a number of units in the Savoy Shopping Centre and Merchants Quay Shopping Centre are vacant, as well as the entirety of the North Main Street Shopping Centre, the CBA considers that there is ample space within the city centre to accommodate the quantum of comparison retail earmarked for the site in Carrigtwohill, the sequential test mandates that it should not diverted elsewhere. 

Had the city centre been included in the study area it is almost certain that an ROC could not have been justified on the basis of the sequential test, given the availability and superior suitability of city centre locations. It is clear a sequential approach to retail provision was not considered at all.   Page 61 of the MDB report states that Cork City was excluded due to its “central location, assumed limited suitable site availability and limited reserve capacity on the City’s road network”. This is an extremely weak justification for excluding a city centre where reported and obvious largescale opportunity sites exist including large vacant shopping centres.  As vacant space in the city exists, so this development could be delivered with significantly less capital investment, in a manner which supports and not competes with the existing retail sector in Cork, and in an area that benefits from being the hub of a high quality public transport network.

 

Modal Split/Car Dependency

  • According to Table 6.3 of the Macabe Durney Barnes Report the proposed Retail Outlet Centre will be heavily car dependent with 90% of the visitors travelling to the Centre travelling by car. This is completely unsustainable and serves to undermine the €300million spent on reopening the Cork City to Midleton rail line and the recently announced CMATS [Cork Metropolitan Area Transportation Strategy] which indicates a coherent strategy for travelling to the city through the implementation of a number of park and rides and a proposed west to east light rail corridor. 

In consideration of national and international best practice, there is no policy basis or justification for a proposal which is reliant upon 90% of the visitors to the proposed development travelling by private car.  Notwithstanding the completely unsustainable nature of the proposed development, when considering traffic impact, the traffic congestion on routes leading up to the Kilcoolishal roundabout  - at times which coincide with the beginning and finishing of shifts in the factories at the IDA, Carrigtwohill Business Park and Fota Business Park - is currently bad. The network is in need of improvement and will only be significantly worsened if 90% of the proposed visitors to the Retail Outlet Centre are using the currently strained infrastructure. 

Cannot be justified on the basis of Tourism

  • In a study of Kildare Village Outlet, it was found that only 5% of people visiting Kildare Village Outlet Centre stayed in hotels yet this proposal is being justified on the basis that it will substantially increase tourism and benefit many sectors such as the hotel sector.  Given the figures from Kildare it is extremely questionable that the proposed development can be justified on that basis.  There is only 2 hotels within a kilometre radius of the site and 5 hotels within a 5km radius so if 5% of the total number of visitors is spread across those 5 hotels it will only result in a marginal increase in tourism revenue. There will likely be a food offering on site also [according to the recommendations of the report] which limits the potential overspill benefit to local restaurants.

Trade Draw

  • The application and overview of the trade draw with reference to Kildare Village Outlet Centre contained in the MDB report noted that from Kildare Town itself the trade draw was 5%, while it was 15% from Newbridge and 30% from Kildare County as a whole. 30% is a substantial figure. Based on this assumption, it suggests that the entire extended KTOV there would be a trade diversion of c9% from Newbridge. A recent health check for Newbridge suggests that the town was performing relatively well, and that vacancy rate was just under 10% of units, which were situated in the main part away from Main Street. This is compared with a current vacancy rate in Cork City centre of 18% and an assertion in the MDB report that the retail impact will only be 0.5% on the City Centre and only 0.3% on Midleton – we find this very hard to believe and the basis for calculation is questioned.  Furthermore in light of the Covid-19 crisis there is absolutely no scope to further draw any retail trade away from any of the existing retailers particularly in Cork City Centre and Midleton.

Retail Impact taken from the MDB Report

 

The need for further study

  • The study indicates that there is scope and comparison retail potential capacity to accommodate a quantum of additional comparison retail floorspace within the CMA and region at 2023. The report notes that there are issues around the rapidly changing retail environment and the impact, in particular, of online retailing on floor space demand. The report notes that in order to fully assess the recent trends [and an timely insertion would be recent economic circumstances] on future retail floorspace requirements the MDB study suggests a comprehensive householder survey of expenditure patterns in the CMA would be required.   The study illustrates through the Annual Services Inquiry than online shopping continued to hit comparison expenditure available for the high street. The capacity assessment concludes that there is a requirement for between 90,000 and 100,000 sqm of net retail comparison floor area up to 2023 within the wider catchment. It notes that the subject proposed development would account for between 13-15% of this demand. There is however only capacity for one such outlet in the CMA – given that the city centre should be the first location for new retail developments and the fact that there is space in the city to accommodate this the CBA view the proposals as premature.

 

Incorrect Assumptions 

  • The assumption made about the 2 hour catchment is questionable – Kildare Village is a 2 hour drive time away from the subject site so it is extremely questionable that an ROC could be justified on the basis of a drive time which includes a significant overlap of the catchment to another Retail Outlet Centre.  The catchment appears too generous and as such skewed the need for the ROC.

The % diversion of trade from each centre is completely questionable Midleton which is 5 minutes away and the closest town is not going to be affected the same as Ballincollig [which is on the opposite side of the city centre] as the study asserts. 

The City is already experiencing increased pressures from outside influences and in particular nearby competing centres which have improved their retail offer and attraction dramatically over the past number of years. Cork City retains a distinctive character, yet despite an attractive and vibrant city centre, the City has not benefited to the degree it should from the process of rejuvenation and redevelopment as seen in some other major urban centres. The City has not fully realised its potential to develop into a major retail centre for the region with Mahon Point in particular affecting retail trade. Whilst the City contains a good range of shops and services, and in particular independent retailers, the choice, diversity and overall mix of retail could be greatly improved, in particular the City lacks many major retail anchors and national and international fashion multiples that would normally be found in a City of this scale for example Zara, Massimo Dutti, Cos, Reiss and Bershka. The retail profile of the City is not commensurate with its status of a Gateway and significant City Centre. It is evident that the City has the potential to develop much further, if given the necessary range of actions, policy framework and economic conditions this needs to be recognised by both the City and County Councils.

 

Conclusion

Cork City is the primary tier in the retail hierarchy and the most significant urban centre in the County and region. However, the retail role of the City is vulnerable and it is envisaged that its role and function as the major retail destination in the region will continue to erode unless there is significant investment and redevelopment in the prime city centre retail core in the short term. 

In consideration of this, the CBA supports the draft Directive of the Minister pursuant to Section 31 of the Planning and Development Act 2000 (as amended) relating to Variation No. 2 of the Cork County Development Plan 2014 (Retail Outlet Centres). The CBA is of the view that the recent decision by Cork County Council to proceed with a change to the Cork County Development Plan 2014 is not in accordance with the proper planning and sustainable development and should not be made prior to the preparation by both local authorities in Cork of an updated retail strategy for the Cork region, as required under retail planning guidelines.

The CBA echoes the concerns articulated by the Planning Regulator that the council’s decision was premature and resulted in a Development Plan that fails to set out an overall strategy for the proper planning and sustainable development of Cork which represents a breach of the legislation. In the interest of the viability, prosperity and well-being of the entire region the primacy of the City Centre should be paramount in any decision-making process and to make all future policy decisions pertaining to retail developments with the best interests of the city and consequently the entire region in mind.

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