Ms Louise O’Meara
Malone O’Regan
Consulting Engineers
2B, Richview Office Park
Clonskeagh
Dublin 13
Ireland
1st August 2007
[By Email and Post]
Dear Ms O’Meara
Re: Proposed Kilkenny Inner Relief Road (KIRR)
1.0

Introduction and Review of Consultation Report (June 2007)

1.1

Purpose of Submission
I am writing on behalf of the Heritage Council, to formally submit our response
to the consultation report issued recently in relation to the proposed Inner Relief
Road within the historic city of Kilkenny. In line with our statutory duties under
the Planning and Development Act 2000 and the Planning and Development
Regulations 2001 and 2006, the Heritage Council is keen to provide a written
comment and to open up discussions and debate with the project team in
relation, specifically, to the eastern section of the proposed inner relief road and
its likely detrimental impact in the short, medium and long-term, on a compact
and historic urban core, of national importance.
It should be stressed, from the outset, that the Heritage Council has no objection
in principle, to the western section of the inner relief road within the Kilkenny
Western Environs. However, we would submit that a new river crossing may be
more ideally suited to a location to the north of the historic city centre to link up
with the planned outer relief road i.e. away from the historic city centre core,
which dates back to early medieval times (12th century).

 1.2

KIRR Consultation Report (June 2007) and Structure of Submission
According to the consultation report, the proposed KIRR is a road development,
which has been a stated objective of Kilkenny County Council dating back to
1978.
Council would highlight that alternatives to inner relief roads, particularly in the
core of historic towns and cities, have developed considerably since 1978 in
many European towns, including, but not limited to, various travel demand
management (TDM) measures such as improved school-based initiatives (Safe
Routes to School), cycle-friendly workplaces, delivery restrictions on important
routes, park and ride, car-pooling, traffic separation, improved public
transport/cycle paths, preparation of Local Authority bike plans, in parallel with
transport oriented development (TOD), etc.
Council would also refer the consultants to An Bord Pleanála’s decision on the
Athy Inner Ring Road. This decision is discussed in detail in Section 7 below.
The consultation report has been ‘specifically prepared to consult with all
relevant stakeholders on the scope of the EIS that is currently being prepared
for the proposed KIRR in order to ensure that a robust assessment is completed
in accordance with best practice guidelines’.
The Heritage Council’s response to the Consultation Report is structured, as
follows:
Section 2 provides an overview of Kilkenny City and reviews recent Councilsponsored conservation publications, which examine the importance and
significance of the historic city, which has evolved and developed from the
medieval period onwards;
Section 3 examines the EIA process and the aspects of the environment that
should be addressed during this project;
Section 4 reviews International and National Best Practice for the sustainable
development of historic towns;
Section 5 provides a brief review of the existing and emerging policy
framework and the need to examine the proposal’s overall ‘policy fit’;
Section 6 examines the likely environmental impacts and constraints associated
with the proposal;
Section 7 reviews the important legal precedent created by the N78 Athy Inner
Relief Road; and
Section 8 deals with the next steps and includes a request for a consultation
meeting with the EIA project team.

2.0

Overview of the historic City of Kilkenny
The importance of Kilkenny City, which dates back to the early 12 th century, as
one of the most important heritage towns in Ireland is well documented.
According to the Heritage Conservation Plan for the Kilkenny City Walls
(2005):

The Heritage Council

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KIRR, Submission 010807

 ‘Kilkenny is one of the major towns of Medieval Ireland. To a considerable
degree, it preserves the topography and fabric of the historic city. Kilkenny
occupies a ridge above the River Nore, on a bridging point [and possible head
of navigation]. The City has two bridges (Green’s Bridge and St. John’s Bridge)
and two foci: St Canice’s Cathedral, on an ancient ecclesiastical site at the
north end; and the Castle, as the feudal stronghold of the liberty, at the south
end….The size and prominence of the city and its lords made it one of the most
important towns in Ireland. It is the survival of the medieval town plan – with
ancient houses, churches and monastic remains, the castle and defences and
historic records and associations – that makes Kilkenny of particular
importance.’
(Source: The Kilkenny City Walls Conservation Plan, The Heritage Council, 2005, page 48).

Rocque’s Map of Kilkenny (1758) illustrates the unique and historic street
pattern and urban form and fabric. This map is reproduced below as Figure 1.

Figure 1: Roque’s Map of Kilkenny, 1758
(Source: Kilkenny City Walls Conservation Plan, page 18)

Indeed, the Kilkenny City Centre Local Area Plan, 2005 states that:

The Heritage Council

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KIRR, Submission 010807

 ‘Kilkenny is unique among similar sized cities and towns in Ireland. Its
magnificent heritage, its ambient medieval core and its thriving cultural and
artistic base make it a major tourist and visitor destination, as well as an
attractive place to live and work.
The importance of Kilkenny in terms of the architectural, historical/
archaeological and natural heritage is clearly evident in the number of heritage
designations: the city includes seven designated architectural conservation areas:
1. City Centre, 2. Kilkenny Castle, 3. St. Canice’s, 4. John Street, 5. Patrick
Street, 6. Michael Street, and 7. St Mary’s, a zone of archaeological potential
(ZAP), as defined in the Urban Archaeological Survey of County Kilkenny
(1993) and a designated cSAC along the River Nore (Site Code 2162).
It is submitted that the proposed road scheme, particularly the eastern section
running through Irishtown, will have a detrimental impact on a historic
townscape and street pattern. The likely environmental impacts of this section of
the road scheme are examined in Section 6 below.
3.0

Environmental Impact Assessment (EIA) and the preparation of an
Environmental Impact Statement (EIS) and Non-Technical Summary
In accordance with the provisions of the Planning and Development Act 2000,
the Planning and Development Regulations 2001 and 2006, the Roads Act 1993,
and the Road Regulations 1994, the Heritage Council would highlight that any
EIA prepared for the road proposal must examine and provide a robust
assessment of the proposal route including lands in the immediate and
surrounding environment (including an assessment of physical features and a
review of the existing and emerging policy framework (discussed in Section 5
below)) and give due weight to environmental factors including the short,
medium and long-term effects/impact of the proposal on:
•

•
•
•
•
•

Human beings, building and man-made features - e.g. visual impact,
impact on the architectural, historic and cultural heritage, archaeological
features and other human artefacts;
Flora, fauna and geology – e.g. loss of and damage to habitats and plant
and animal species;
Land – e.g. quality and quantity of land to be taken, change in local
topography, effect of earth-moving, effect on surrounding land uses;
Water – e.g. effect on river hydrology and water quality;
Air and climate – e.g. level and concentration of chemical emissions and
their environmental effects, offensive odours, other climatic effects; and
Other Indirect or Secondary Effects associated with the project – e.g.
effects arising from the extraction and consumption of materials, water,
energy or other resources by the development.

The EIA must also include, where adverse significant effects are identified, a
full and detailed description of the proposed mitigation measures to be
undertaken or employed to avoid, reduce or remedy those effects, e.g. site
planning, technical measures, aesthetic and ecological measures. An assessment
of the likely effectiveness of mitigation measures must also be included.

The Heritage Council

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KIRR, Submission 010807

 It is further submitted that the environmental impact assessment process must
have due cognisance of the rich and varied heritage of Kilkenny City and, in
particular, the intactness of the historic core running from St Canices Cathedral
to the Castle.
The EIA should also adequately provide evidence of the various alternatives
considered to this proposed inner relief road route within the wider context of
historic, present-day and emerging land-use patterns, street patterns and historic
townscape, pedestrian movement and environmental constraints, and provide a
robust appraisal, along with a reasonable rationale, for the proposed final route
selection.
4.0

International and National Best Practice

4.1

ICOMOS Bruges Resolutions
The Heritage Council recommends that the EIA process consider ICOMOS’s
Bruges Resolutions, which have specific relevance “to historic towns where
distinctive qualities and value are deemed as being worthy of retention and
enhancement. ICOMOS recommends that planning in small historic towns,
such as Kilkenny should endeavour to:
•

•

•

•

4.2

Observe the existing scale of the town in all new developments, to
respect its character, its dominant buildings and its relation to the
landscape;
Retain the specific visual qualities of urban spaces, streets and
squares not only in isolated ‘tradition islands’ but throughout the
town’s fabric, so as to provide at the very least, a continuous network
linking the main points of interest;
Avoid the destruction of historic elements which at first sight, might
seem to be of minor importance but whose cumulative loss would be
irretrievable; and
Search for appropriate new uses for empty buildings, which would
otherwise be threatened with decay.

Irish Walled Towns Network (IWTN)
It should be highlighted that ‘Kilkenny’ is a member of the Irish Walled Towns
Network1, which was set up by the Heritage Council in April 2005, to unite and
co-ordinate the strategic efforts of local authorities involved in the management,
conservation and enhancement of 20 historic walled towns in Ireland, both
North and South. The IWTN’s Draft 3-Year Action Plan 2006-2008 can be
downloaded
from
the
Network’s
webpage
at
http://www.heritagecouncil.ie/walled_towns/index.html

1

http://www.heritagecouncil.ie/walled_towns/index.html

The Heritage Council

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KIRR, Submission 010807

 The Irish Walled Towns Network is formally linked to the International Walled
Towns Friendship Circle (IWTFC), which is the international association for the
sustainable development of walled towns, walled cities and fortified historic
towns. It is submitted that the proposal is contrary to the tenets of sustainable
development and fails to uphold the spirit of the Friendship Circle’s Piran
Declaration 2003, which states that:

‘Walled Towns are unique inheritances from times long past and should
be treasured, maintained and safeguarded from neglect and destruction
and passed on to perpetuity as irreplaceable Time-stones of History’.

As noted in Section 2.0 above, the Heritage Council funded the preparation of
Conservation and Management Plan for the Medieval Walls of Kilkenny,
which was launched in Kilkenny Castle in November 2005. The Irish Walled
Towns Network allocated funding of €170,000 in April 20072 to restore and
conserve parts of the historic City Walls of Kilkenny. This work is due to be
undertaken and completed by the end of 2007. It should be noted that it is
planned that further restoration and presentation works will be undertaken on the
historic city Walls and other related built heritage projects within the city centre
over the next 3-5 years.
The current road proposal would appear to compromise the integrity of a local
[and national] programme aimed at highlighting the significance of Kilkenny’s
medieval city walls as a key environmental and economic driver in the overall
evolution of the historic city.
5.0

Existing and Emerging ‘Policy Framework’
It is submitted that the EIA for the KIRR should review the existing and
emerging international, national, regional, county and local policy framework
e.g. Architectural Conservation Areas (ACAs), Protected Structures, Recorded
Monuments, and zones of archaeological potential, to establish the extent of the
proposal’s ‘policy fit’. It is submitted that the following architectural and
planning guidelines and development plans should be reviewed and assessed
along with any other plans and strategies identified during the EIA process:

5.1

National Heritage Plan 2002 (currently under review)
The Department of the Environment, Heritage and Local Government is
currently undertaking a major review of the National Heritage Plan 2002. It is
envisaged that the results of the review will be published in late 2007.

2

The IWTN budget in 2007 is €2.016m.

The Heritage Council

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KIRR, Submission 010807

 5.2

Kilkenny City and Environs Development Plan 2002
Council strongly supports the policies contained in the Kilkenny City and
Environs Development Plan 2002 in relation to the protection, preservation and
enhancement of the medieval city of Kilkenny and its environs. According to
the introduction chapter, the Kilkenny City and Environs Development Plan
2002 has five basic aims. These are:
i.
ii.
iii.
iv.
v.

To promote sustainable, local economic and employment growth in
Kilkenny City and Environs;
To promote social inclusion in all aspects of life;
To promote environmental sustainability;
To preserve and enhance the historical character of the medieval City
and environs, natural and man-made; and
To retain the status of Kilkenny City as a Borough and to enhance its
status by an extension of the Borough Boundary.
(Source: Kilkenny City and Environs Development Plan 2002, page 2.)

The following paragraphs, objectives and policies have relevance to the
environmental impact assessment process for the proposal, namely:
Policy/Section/Objectives
Policy 4.2.1 – Tourism

Policy 7.3 – Roads

Policy 9.4.1 The Riverside

Objectives 9.15 and Policy
9.15.1 Views and Prospects

Description
It is the policy of Kilkenny Borough Council and Kilkenny
County Council to protect, enhance and develop the
architectural and historical heritage of the City and its
general amenities through the implementation of the policies
contained in the Plan.
It will be the policy of the Kilkenny Borough Council and
Kilkenny County Council to:
- discourage the use of the city centre streets by through
traffic
- preserve the medieval street patterns within
conservation areas
- to use street furniture, including lighting standards,
which are appropriate to the character of their
surroundings
- to cater for the safety of pedestrians and cyclists as a
priority…
It is the policy of Kilkenny Borough Council to conserve and
enhance the amenity of the River Nore corridor, including
the landscape, water environment and wildlife habitats and
where consistent with this, to encourage increased public
access and water-related recreation opportunities.
Kilkenny has a number of sites, areas and vantage points on
the margins of the city and in the environs, from which fine
views of the city can be had. There are also a number of
vantage points within the city from which particularly good
views of the City’s most important public buildings and
natural landscape features may be obtained. Of particular
importance are views to and from the Castle, John’s Bridge,
Greens Bridge, Ossary Bridge, the Cathedral and the
riverbanks.
It is the policy of Kilkenny Borough Council and Kilkenny
County Council to preserve views and prospects of special
amenity value or interest and improve the views from the
main approach roads to the city.

The Heritage Council

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KIRR, Submission 010807

 main approach roads to the city.
Section 11 - Architectural Heritage, Conservation and Archaeology:
11.2 – Urban Structure
The centre cannot continually accommodate large-scale
development, particularly if the result is the erosion of
historic building plots.

11.3 Public Spaces

11.4 Views and Prospects

11.6 Archaeology

11.8 Architectural Conservation
Areas (ACAs)

The future policy of the Borough Council will be to protect
the historic building plots and to encourage small-scale
incremental type development, as opposed to major
projects.
The effects of proposed developments on the quality of the
adjacent public spaces and the possibilities of creating
new spaces will be an important factor in assessing
planning applications. Pedestrians will be afforded
priority in the use of the public realm throughout the
historic city.
There are a number of sites, areas and vantage points
within the City and in the Environs, from which fine views
of the City can be had. There are also vantage points
within the City from which particularly good views of the
City’s most important public buildings and natural
landscape features may be obtained. Of particular
importance are views of, and from, the Castle, Cathedrals
and the River Nore.
In assessing development proposals, the impact on existing
views and prospects will be taken into account by the
Borough Council and Kilkenny County Council.
The zones of archaeological importance are outline on the
accompanying map (Map B)…Kilkenny has been identified
as an Historic Town and appears in the Record of
Monuments and Places (RMP). Historic towns have been
identified by the Minister for Arts, Heritage, the Gaeltacht
and the Islands for general protection (This Dept was reorganised in June 2003.). The guideline boundaries for
historic towns are illustrated within the RMP as zones of
archaeological potential and area areas where intense
archaeology is present.
The Plan provides for 9 designated conservation areas, 7 of
which are located within the city centre:
1 City Centre
2 Kilkenny Castle
3 St Canice’s
4 John Street
5 Patrick Street
6 Michael Street
7 St Mary’s
The plan describes St Canice’s ACA as follows:
The district is dominated by the 13th century cathedral,
which overlooks the northern end of the city. Surrounding
it are the remains of its close, including the Bishop’s
Palace, Deanery, St. Canice’s Library and other buildings.
St. Canice’s Church is another landmark building in the
area.

The Heritage Council

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KIRR, Submission 010807

 The Cathedral district is bounded by narrow streets, which
run around the base of the mound on which the Cathedral
is built – Dean Street, St. Canice’s Place, Vicar Street and
Troy’s Lane. The district is traversed by a number of small
laneways, which are enclosed by high stonewalls. The
building types in the area have traditionally been
institutional, housing and small-scale shopping and these
have given the district its special quiet character. In recent
years, Dean Street has been redeveloped with a mixture of
residential and commercial uses.
Green Street is an area of mixed uses bounded between
Vicar Street and the River Nore. Part of the Brewery
extends into the southern section of the district, including
the remnants of St. Canice’s Church.
It should be noted that the plan’s description of the St.
Canice’s ACA pre-dates the publication of the Kilkenny
City Walls Conservation Plan in November 2005 and the
publication of Architectural Heritage Protection
Guidelines for Planning Authorities (DoEHLG, 2005)
and the Planning and Development Act 2000.
The City Walls Conservation Plan details the location
of the medieval city walls (a national monument),
extant sections and sections below ground in this
historic area of the city centre.

11.11 Special Conservation
Objectives

5.3

We would recommend that a full character appraisal
and suite of policies, in relation to the protection of the
character of St Canice’s ACA and other relevant ACAs
impacted on by this proposal, be carried out by
Kilkenny Borough Council in advance of the
development of the road proposal and EIA.
The Plan sets out three special conservation objectives:
1 The protection, conservation and, where necessary,
restoration and enhancement of the quality and
distinctiveness of Kilkenny’s architectural heritage,
monuments and archaeological sites and objects.
2 The protection, management and improvement of
access to, and understanding of, the architectural
heritage, monuments and archaeological sites and
objects.
3 The protection and enhancement of the distinctive
character of the designated Conservation Areas, as
described above.

South-East Regional Authority: Regional Planning Guidelines (RPGs), May
2004
The Built Heritage section (Section 8.4.2) of the South East Regional
Authority’s RPGs state that Planning Authorities within the region should:
•
•

Adopt policies that will protect and enhance the architectural character
and landscape settings of settlements in their area;
Give consideration to identifying areas of townscape character and
quality and develop urban design frameworks for these areas;

The Heritage Council

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KIRR, Submission 010807

 •
•

•

Secure the regeneration of historic urban areas in accordance with
agreed urban design frameworks;
Preserve and protect all protected archaeological sites and monuments,
protected structures, conservation areas, and their settings to degree
appropriate to the need to safeguard their historic integrity; and
Preserve and protect architectural heritage and encourage the
sympathetic re-use and/or development thereof.

In relation to the protection of vernacular architecture, the RPGs state that
planning authorities should:
•
•

•

Seek to re-use and protect vernacular heritage and to encourage the
sympathetic re-use and/or development thereof;
Seek to preserve, protect and retain the local historical settlement
patterns, which include street patterns, existing plot sizes and historic
street furniture in-situ; and
Have regard to the heritage implications of all local authority plans and
policies in accordance with relevant statutes and national policies, such
as the National Heritage Plan.

It is submitted that the road proposal is contrary to the key tenets of the Regional
Planning Guidelines for the South East Region and will result in the destruction
of a significant element of the city’s built heritage. We examine the likely
impact on the built heritage in Section 6 below.
5.4

Architectural Heritage Protection Guidelines for Planning Authorities, The
Department of the Environment, 2005
Section 3.1.1 of the Architectural Heritage Protection Guidelines for Planning
Authorities 2005, includes the definition of an ACA for inclusion in
development plans, as provided for under Section 81 of the Planning and
Development Act 2000:
‘An Architectural Conservation Area (ACA) is a place, area, group of structures
or townscape, taking account of building lines and heights, that is of special
architectural, historical, archaeological, artistic, cultural, scientific, social or
technical interest or that contributes to the appreciation of a protected
structure, and whose character it is an objective of a development plan to
protect’
As noted above, Kilkenny city has seven designated ACAs. It is vital that any
large-scale infrastructural proposals do not lead to the destruction of these
unique ACAs and their component parts. It should be noted that the Guidelines
also state that the planning authority should consider taking an active
approach to the conservation and management of ACAs, in particular
through works carried out by the planning authority itself and by public
utilities.

The Heritage Council

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KIRR, Submission 010807

 We would recommend that the EIA should fully and robustly consider all the
likely impacts (individual and cumulatively) of the road scheme on the seven
designated ACAs in Kilkenny, particularly in the vicinity of St Canice’s
Cathedral and the cathedral precinct (St Canice’s ACA). In particular, the longterm impact on Dean Street and Vicar Street.
5.5

Kilkenny City Centre Local Area Plan (LAP), 2005
In terms of the local policy framework, the Council would draw the consultants’
attention to the following policies contained within the Kilkenny City Local Area
Plan (LAP), 2005.
The Heritage Council strongly supports the policies contained in the Kilkenny
City Centre Local Area Plan (LAP) 2005 in relation to the development of a
walkable and safe city centre, which contains many fine structures and
monuments of national value, significance and importance. The following
paragraphs, objectives and policies have relevance to the environmental impact
assessment process for the proposal, namely:
Policy/Section
2.1.3 – Road and Street
Hierarchy

2.1.4 – City Centre Gateways

2.1.6 – Cycle Network

2.1.7 – Pedestrian Linkages

The Heritage Council

Description
The inner relief road will provide for strategic vehicular
movement around the city centre. However, the route
could potentially act as a barrier to access for pedestrians
and cyclists to the City Centre from residential areas
surrounding the City Centre.
The centre of the City is an area of high pedestrian activity
and, to a lesser extent, cyclist activity. In the context of
the historical form and predominantly narrow
streetscape, the movement of pedestrians and cyclists
should, in overall terms, take precedence over the
movement of vehicular traffic.
Kilkenny is a relatively flat and compact City with a
significant proportion of its population living within 2
kilometres of the City Centre. These characteristics
contribute towards making Kilkenny City an ideal location
for commuting to work or school by bicycle. A unique
opportunity also exists in Kilkenny to promote leisure
cycling, by the creation of high-quality cycle routes linking
places of local and national interest. (This section also
includes the proposed new pedestrian and cyclist bridge at
John’s Quay – see below).
In addition to links on the existing street network, new
pedestrian links can be developed on the east side of the
river from Wolfe Tone Street to John’s Quay to Bateman
Quay. These will create new streetscapes in the western
city centre and will improve linkages to the retail core
from the John’s Green area….

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KIRR, Submission 010807

 5.6

Fáilte Ireland’s Product Development Strategy 2007-2013
Fáilte Ireland’s Product Development Strategy 2007-2013 was launched in
Dublin Castle in April 2007. A grant programme is available under the strategy,
to maximise the tourism potential of 100 key historic cities, towns and villages
within Ireland3. The funding aims to improve the visitor experience of historic
urban areas through:
•
•
•
•
•

Specified improvement in the quality of public spaces/the public realm;
Prioritisation of the pedestrian and cyclist over the car in streets
within the historic core;
Provision of an integrated tourist signage system;
Improvement of access to the built and cultural heritage; and
Improvement of the presentation of the historic urban area and
visitor facilities and services.

The Strategy makes funding provision for the improvement and upgrade of the
physical urban environments in Ireland’s historic towns and cities. It should be
noted that Kilkenny is one of the 100 towns and cities identified in Fáilte
Ireland’s Historic Towns Study, which promotes and supports specific measures
and capital funding to preserve, protect and promote unique, historic town/city
centres.
6.0

Likely Environmental Impacts

6.1

Human Beings, Buildings and Man-Made Features
The potential impacts of the proposed road scheme are likely to be considerable
and include the severing (both physical and psychological) of local communities
and distinctive townscape and areas of archaeological importance including the
Historic Cathedral Precinct (ACA) from the remaining urban core to the south
of the road proposal.
The Heritage Council is particularly concerned with the likely severing of the
Historic Cathedral Precinct, where the former Bishop’s Palace and Gardens are
located (original tower at the Palace is circa 16th century) 4, as well as parts of
Irishtown, from other parts of the historic urban core. The proposal would have
a significant impact on businesses and organisations located in this historic area,
including the day-to-day operations of the Heritage Council in their new
national headquarters.

3

Identified by research undertaken for the Product Development Strategy (Historic Towns Study), as
part of the National Development Plan 2007-2013.
4
The former Bishop’s Palace and Gardens, now known as The Palace, is currently be refurbished by
the OPW on behalf of the Heritage Council. It is envisaged that the Heritage Council will move into its
new National Headquarters in early 2008.

The Heritage Council

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KIRR, Submission 010807

 Existing traffic volumes in the Dean Street area are not conducive to easy
pedestrian movement from the High Street/Parliament Street area and Council is
of the opinion that the provision of a new, vehicular river-crossing and linkage
with planned new developments on the east bank of the Nore will further
increase traffic volumes within the historic core, e.g. the proposal will suck in
additional traffic.
The Historic Cathedral Precinct, which is an important ‘historic zone’ and is of
enormous tourist, amenity and emerging functional value and significance,
should be linked, as closely as possible in the long-term, to the historic urban
core.
Council is also of the opinion that this proposal does not assist with the creation
of sustainable and walkable, urban communities and will do little to enhance the
overall ‘quality of life’ of residents and visitors alike in Kilkenny.
We would also recommend that the planning authority prepares a collaborative
Urban Design Framework Plan for the Historic Cathedral Precinct of Kilkenny,
in order to examine how permeability and movement between, and within, this
important historic area and the rest of the city can be improved by means, other
than a busy, car-oriented relief road, whose origins date back to the late 1970s.
6.2

Flora and Fauna
It is important that the EIA provides a robust assessment of the likely impacts of
the proposal on the River Nore cSAC. It is Council’s opinion that the road
proposal has the potential to have a significant impact on the existing habitats,
mammals, bird species and aquatic ecosystem located in the cSAC, particularly
during the construction phase of the project.
Council is heavily involved in promoting the natural heritage associated with
Ireland’s riverbanks and inland waterway ecosystems. Council would
recommend that the EIA project team consult with the National Biological
Records Centre’s senior management to ensure that the EIA ‘baseline’ contains
up-to-date information.

6.3

Water Quality
In relating to the impact of the road proposal on water quality, the Council
would refer the Consultants to An Bord Pleanála recent decision in relation to a
proposed large-scale development, which included a proposed river crossing in
Athenry, Co. Galway – Reference Number PL07.214418.
In addition, Council would recommend that the EIA assess the likely impact of
the proposal on the wider ‘River Nore Corridor’ and overall riverscape and
towpaths/and proposed cyclepaths, and not just at the site of the crossing or
proposed road corridor width of 100m. The River Nore Corridor is an important
amenity and tourist attraction and also contains Atlantic Salmon, along with
Crayfish, etc. (Annex II species).

The Heritage Council

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KIRR, Submission 010807

 The River Nore aquatic ecosystem has had a number of upheavals in recent
years, including spillages from industrial premises located adjacent to the river,
as well as the Flood Relief works, and it is important that the EIA addresses the
impact of the road scheme on the aquatic ecology e.g. from surface water runoff on the overall river corridor area.
The EIA should also address the risks and likely impacts resulting from a major
accident associated with the bridge/river crossing.
6.4

Noise and Vibration
Council would recommend that the noise and vibration section of the EIA must
assess the short, medium and long-term impact of the proposal on numerous
protected structures and national monuments in the locality of the proposal,
particularly within Irishtown.
Council would be concerned that the resulting ambient/ background noise and
vibration levels (daytime and night-time) may be unacceptable in such a tranquil
and historic location and that the impact on historic buildings/structures and
monuments would be detrimental to their survival in the long-term.
Council would submit that resulting noise and vibration levels should not
materially or adversely affect the character of this part of the historic city centre.

6.5

Landscape and Visual Impact
It is Council’s opinion that the proposal is contrary to the objectives contained in
the County Development Plan regarding urban landscape and historic
streetscape/ townscape/ riverscape. The provision of a new vehicular river
crossing has the potential to impact adversely upon some of Kilkenny’s finest
views and vistas, in particular those of the River Nore, the River Bregagh, the
city’s historic bridges (both Protected Structures) and landmark public/civic
buildings.
As noted above, Section 9.15 of the Kilkenny City and Environs Development
Plan 2002 deals with this issue:
‘Kilkenny has a number of sites, areas and vantage points on the margins of the
city and in the environs, from which fine views of the city can be had. There are
also a number of vantage points within the city from which particularly good
views of the City’s most important public buildings and natural landscape
features may be obtained. Of particular importance are views to and from the
Castle, John’s Bridge, Greens Bridge, Ossary Bridge, the Cathedral and the
riverbanks.
(Section 9.15: ‘Views and Prospects’)

The proposal to construct a new north-south aligned road from Parliament Street
across to Vicar Street will result in a negative impact on historic plot
boundaries.
The Heritage Council

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KIRR, Submission 010807

 This proposed roadway is an unwelcome proposal, as it pays little or no respect,
to the historic streetscape or fine grain of the built fabric in this area. This will
also entail a new crossing of the River Breagagh and the scale of impact upon
the historic Irishtown Bridge and any sub-surface remains of Irishtown Gate will
potentially be adverse and irreversible. Such a development will also result in a
new crossing of the historic line of the medieval city walls at Irishtown (a
National Monument). As such, this element of the proposed road scheme is an
unwelcome intrusion into the fabric of the medieval city.
It is difficult to reconcile this proposal with the following measures of the
Kilkenny City and Environs Development Plan 2002, as noted above:
‘The centre cannot continually accommodate large-scale development,
particularly if the result is the erosion of historic building plots. The future
policy of the Borough Council will be to protect the historic building plots and
to encourage small-scale incremental type development as opposed to major
projects’.
(Policy 11.2 Urban Structure)

6.6

Cultural Heritage
The impact of the proposed roadway, in particular the stretch from the Butts
Roundabout as far as Wolfe Tone Street, has the potential to impact adversely
upon buried archaeological remains and upon important elements of our built
heritage within a designated Architectural Conservation Area (ACA). Council is
particularly concerned with the impact upon the ‘built heritage’ at the following
locations within the historic city core, namely:
•
•
•

•
•
•
•
•

Canice’s Place;
Irishtown Bridge;
The line of the Medieval City Walls (extant and site of) on the southern
side of the Bregagh ((Areas 10.1-10.5 contained in the Kilkenny City Walls
Conservation Plan), in particular the tower known as Evan’s Turret or
Tower and Wall (Area 10.1), River Bregagh Wall section (Area 10.2), the
site of Irishtown/Hightown Gate (Area 10.3), Irishtown Gate – site of Mill
Race (Area 10.4) and River Bregagh Frontage (Area 10.5) At the rear of
the eastern side of the street known as Irishtown;
Vicar Street;
John’s Green;
Green’s Bridge;
Peace Park/St Maul’s Graveyard; and
Former hospital at Wolfe Tone Street.

There is also a strong likelihood of an adverse impact upon below-ground
archaeological stratigraphy in the historic Irishtown area and at Peace Park/St
Maul’s Graveyard. The consultation document states that there are a ‘number of
RMP sites in close proximity to the proposed KIRR’ whereas an examination of
the RMP for County Kilkenny indicates that a considerable part of the KIRR
runs through an actual Zone of Archaeological Importance/Potential for
Kilkenny City.

The Heritage Council

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KIRR, Submission 010807

 The Council would also recommend that submerged archaeological remains
must be examined and assessed.
7.0

Important Legal Precedent Established by N78 Athy Inner Relief Road
Council would also refer the consultants to An Bord Pleanála’s decision in 2005
in relation to the proposed N78 Athy Inner Relief Road (09ER2035), which
originated in the 1970s to serve the town in the context of traffic flow patterns
identified in surveys carried out in July 1975. Planning permission was refused
due to three reasons (in summary):
Reason No. 1: The inner relief road route would fail both as a street and as a
relief road because it would continue to bring traffic, including heavy
commercial vehicles, through the town centre;
Reason No. 2: …it is considered that the proposed road development would
materially and adversely affect the character of the town centre of Athy and
would detract from its townscape qualities…proximity to protected structures,
including Cromaboo Bridge and the modern Dominican Church on the west side
of the river, and intrusion on a Zone of Archaeological Protection. The
proposed road development would conflict with the provisions relating to the
preservation, conservation and the improvement of amenities contained within
the current Athy Development Plan and would therefore, be contrary to the
proper planning and sustainable development of the area.
Reason No. 3: it is considered that the environmental impact statement is
deficient in not adequately addressing the alternatives to this inner relief route
in the context of present land use patterns, traffic movements, road
developments and environmental constraints.
A copy of An Bord Pleanála’s decision in relation to the proposed N78 Athy
Inner Relief Road is provided at Appendix A.

8.0

Next Steps - Request for Consultation Meeting with the EIA Project Team
The Heritage Council team would welcome the opportunity to meet with the
EIA Project Team to discuss the scoping of the EIA, the various options being
considered along with the issues raised in this submission.
I look forward to hearing from you at your earliest convenience.
Yours sincerely
Alison Harvey
BSc (Hons) MSc MIPI
Planning and Development Officer

The Heritage Council

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KIRR, Submission 010807