2017
Development at Island Mills, Mill Road, Fermoy, Co. Cork. Town Planning Report Planning Report to accompany planning application lodged on behalf of UHPC with Cork County Council. This application seeks permission to develop a Primary Care Centre at Island Mills, Mill Road, Fermoy, Co. Cork.
Manahan Planners 38 Dawson Street, Dublin 2 12/12/2017
Introduction This Planning Report has been prepared in connection with a planning application to Cork County Council by UHPC International Limited for the development of a primary health care facility with ancillary services on a site at Mill Road in Fermoy.
Site Context The site is a former flour mill of historic significance and forms a visual landmark in the town’s landscape, prominently located along the southern banks of the Blackwater River and visible to those passing across the Thomas Kent Bridge.
Figure 1: Site Location aerial Map
There are two large structures currently located on the site. One is the old mill building, which is a Protected Structure, and the other a more recently constructed two storey office building. The site is adjacent to the adjoining river and takes access from the Mill Road. The site has an area of approximately 1.4 hectares and is currently vacant. Its most recent occupier was BUPA Healthcare, who used the buildings as offices for their 300 (approx.) staff members. There were approximately 274 on-site car parking spaces associated with this use. This spaces were located in surfacing car parking adjoining the mill building and the adjoining more modern office building on site.
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Figure 2: Aerial photo of site in previous ownership with layout of the (approx) 364 on site car parking spaces visible
These buildings are in two, self-contained office premises, joined by an internal corridor and have a total floor space of approximately 3,065 sq. m. The southern building is a two-storey block of approx. 1,950 sq. m, mostly open-plan, with some private offices and service rooms. The northern building, is a renovated, five-storey stone 19th century industrial property of approx. 1,115 sq. m. It was converted and upgraded to office use around 1990. Occupiers since then have included Metropolitan Life, Bupa Healthcare and Quinn Healthcare, among others.
Planning Policy Context The subject site is zoned as part of the Existing Built-Up Area in the Fermoy Electoral Local Area Plan Second Edition January 2015. Objective ZU 3-1: Existing Built Up Area seeks to encourage "development that supports in general the primary land use of the surrounding existing built up area. Development that does not support, or threatens the vitality or integrity of, the primary use of these existing built up areas will be resisted." Manahan Planners
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Figure 3: Extract of zoning map from Fermoy Electoral Area Local Area Plan Second Edition January 2015 identifying the zoning of the subject site
Figure 4: Excerpt from Map 2 of the Fermoy Development Plan 2010-2016 with the red line identifying flood defence walls in place.
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Figure 5: Excerpt from Map 3 of the Fermoy Development Plan 2010-2016 showing the site zoned for Commercial use.
Figure 6: Excerpt from Map 3 of the Fermoy Development Plan 2010-2016 locating the site within an Architectural Conservation Area.
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The Mill building has been recorded as an archaeological site and monument “Corn Mill CO035-025". The site is also located within an Architectural Conservation Area (as shown in Figure 2 above). Proposals in this area will be permitted "only where it can be demonstrated that the development will reflect scale, massing and proportions and reflects the character of the area and streetscape, retains important exterior architectural features and makes use of traditional materials". The former mill building is a Protected Structure (as identified in the Fermoy Development Plan 2010-2016 - Register Number 200) and is also listed on the National Inventory of Architectural Heritage (Reg. No. 20821055). Flooding The site is also included in an Area Susceptible to Flooding: Zone A designation. This is an area that has a 'high probability of flooding'. The LAP states that in areas such as the subject sites' "most types of development would be considered inappropriate. Development in this zone should be avoided and/or only considered in exceptional circumstances, such as in major urban or town centres, or in the case of essential infrastructure that cannot be located elsewhere. A Justification Test set out in Ministerial Guidelines applies to proposals in this zone. Only water-compatible development, such as docks and marinas, dockside activities that require a waterside location, amenity open space, outdoor sports and recreation, would be considered appropriate in this zone." Objective FD 1-4 states that proposals for development on sites such as the subject site will need to be supported by a site-specific flood risk assessment prepared in line with paragraph 1.8.19 of the LAP. Policy FD 1-5 states that if the Council is satisfied with the above assessment that the proposed development and its infrastructure, will "avoid significant risks of flooding in line with the principles set out in the Ministerial Guidelines, then, subject to other relevant proper planning considerations, permission may be granted for the development." Guidance Relating to Fermoy Chapter 1 of the LAP contains specific guidance relating to Fermoy and its environs. It identifies the strategic aims for Fermoy as being the developing the town as a "attractive work destination adjacent to the M8 Corridor by diversifying and expanding the employment base of the town, and to improve quality of life for its residents by providing the required social infrastructure to support the planned population growth". Identifying a population growth of 1,569 persons (2006-2020) the LAP seeks the creation of approximately 2,500 additional jobs between 2015 and 2025 to be provided Manahan Planners
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on a cross-sectoral basis in order "to attract population and boost the existing low employment base of the town." In terms of the proposed land-use, paragraph 1.2.17 of the LAP states that "it is considered that the first choice of location for any future primary health care facilities should be in or adjoining the town centre." Built Heritage Paragraph 1.2.32.of the LAP describes the influence Fermoy's military history has had on the design and layout of the town. It also discusses the significance of its architectural heritage, citing the large part of the town covered by an Architectural Conservation Area and the fact that 210 buildings or other structures are included in the Record of Protected Structures. Healthcare Facilities Paragraph 5.6.8 of The Cork County Development Plan 2014 states that the Planning Authority will support the provision of Primary Healthcare Centres (PHC's) such as the proposed, subject to a number of locational factors such as:
PHC’s should generally be located in town centres in the first instance or if a suitable site is not available then the alternative site selection process should be based on the sequential approach. PHC’s should be accessible to pedestrians and accessible by public transport and private car in order to maximise access for both urban and rural populations. Proposals will need to be made for parking but location will be a determining factor in the amount to be provided. In cases where accessible public parking is provided off site a reduced standard may be acceptable. All proposals must address parking as part of an overall mobility management plan.
The Development Plan also states that future Primary Healthcare Facilities should be provided in the County's main settlements subject to the criteria outlined above. It contains the following two objectives: Objective SC 6-1: Healthcare Facilities - "support the Health Service Executive and other statutory and voluntary agencies and private healthcare providers in the provision of healthcare facilities to all sections of the community, at appropriate locations, with good public transport links and parking facilities." Objective SC 6-2: Provision of Primary Healthcare Centre’s - "support the provision of Primary Healthcare Facilities inappropriate locations across the county subject to proper planning and sustainable development requirements."
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Planning History An application was submitted by Douglas Development Ltd. for development on the Mart site on the opposite side of Mill Road in 2008 (Reg. Ref. 0851009) for the development of a retail complex, a 7 screen cinema, 21 apartments, 3 office blocks, a number of cafe's and restaurants and parking for 1,026 cars. The application was refused by Cork County Council and was not appealed to An Bord Pleanála. An application was submitted (Reg. Ref. 0851021) for development on a site near the corner of Courthouse Road and Mill Road for the development of a mixed use retail, office and residential development incorporating 8 retail units (874 sq. m), 8 office units (1,624sqm) and 17 apartment units and ancillary car parking. The application was refused by Cork County Council and was not appealed to An Bord Pleanála.
The Proposal The Statutory Notices lodged with the application states the proposal involves the following. Cork County Council: "UHPC International Ltd is applying for permission for a development at a site known as Island Mills, Mill Road, Fermoy, County Cork. The development will consist of the following: Change of Use of existing buildings on site (older Mill building (Protected Structure) and newer office building known as Block A) from a previous office use to use as a Primary Healthcare Centre for the Health Service Executive (HSE) and general medical doctors. The work requires demolition of an existing single story link, staff catering building and sections of Block A (220m²) adjoining the Mill. The development will also include a two storey extension to Block A of ( 395m²) to a total of (2408m²), a new double height entrance lobby with coffee shop, 4 story lift serving the Mill and external steps together with a new two building of (408m²), sq. m which will be used a dispensary and medical aid area. Block A will also be altered by the removal of central floor area in the middle of the building to create a light well for improved ventilation and light. (Area included in above demolition Calculation) The Mill building, which is a Protected Structure, will be refurbished. Work to the building will include services, replacement windows and construction of a new slate roof. The total existing floor area of the buildings on site is 3,223 sq. m. Following these changes it will be 4,112 sq. m. The existing surface car park containing space for 274 cars will be resurfaced and laid out with parking spaces for 217 cars. The existing ESB substation will be Manahan Planners
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retained. New building signage and new site signage will be installed. The existing vehicle access will adjusted to allow for both pedestrian and cycle access and a new Mill Road boundary treatment and landscaping will remain as at present.� In brief the site will be entered from the same entrance and the existing office building Block A will be refurbished and altered as described above. The link building will be demolished and replaced by a new building, see image below.
Figure 7 Entrance to the site
This new link building will give access to the historic Mill Building on site which is a Protected Structure. It will be refurbished to best Conservation practice. A replacement roof will be constructed on the Mill building. See report from Conservation Architect.
Figure 8 View of development from car park
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Finally the existing surface car park on site will be resurfaced and the parking spaces will be marked. The image above shows the new link building and Mill from the upgraded car park.
Planning Assessment Land Use The site has previously been in use as offices for healthcare insurance providers and is zoned as Existing Built Up Area. It is submitted that the provision of a Primary Healthcare Facility is in keeping with the objectives of the zoning and "supports in general the primary land use of the surrounding existing built up area". As per policy guidance above, the site is an ideal location for use as a Primary Healthcare Facility given Fermoy is one of the County's main settlements, the site is centrally located within Fermoy and with good access to the public transport network that serves the town (including the Cork to Dublin CIE service) as well as having adequate parking facilities (as detailed below). Built Form There are no significant interventions proposed for the 5 storey Mill building, apart from reinstating the roof (using slate tiles) that was previously removed and also carrying out internal retrofitting. The existing two storey office building (Block A) is proposed to be modified by hollowing out an internal area of approximately 200 sq. m to allow for ventilation and penetration of light into the rooms at the centre of the building. An extension is also proposed along the eastern edge of Block A to create a new entrance area that will also connect Block A with the Mill building. A new single storey building of approximately 210 sq. m is to be constructed to the south of the Mill building, and adjoining Block A, to accommodate a dispensary unit and a medical aids area. Visual Impact The built interventions, as described above, are minimal in scope with new construction being limited to the new single storey dispensary and medical aids area as well as the eastern extension of Block A. However, within the context of the broader complex and the visual primacy of the Mill building, it is argued that the visual impact of the new interventions will be minimal and will not be adverse.
Other Studies Parking and Access
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The proposed development involves providing a new surface to the existing car park and marking out parking spaces to Development management standards. Cronin & Sutton Consulting Engineers were commissioned to prepare a Traffic Generation Report for the proposed development. The report finds that an adequate amount of car parking spaces is being supplied and that the "proposed development trip generation is less than the previously provided car parking spaces." This will lead to a reduction in car parking numbers from those previously on the site from 274 spaces to 217 spaces, in excess of the 205 spaces required as per the Cork County Development Plan. Heritage Impact A Heritage Impact Assessment was conducted by David Slattery Conservation Architects Ltd to assess the likely impact of the proposed development on the integrity of the heritage building. The report notes that the mill building has been designated as a Protected Structure as well as having being included in the National Inventory of Architectural Heritage. It states that the mill building is the last remnant of a much larger mill complex, which was once among the largest flour mills in the country and that it holds an important place in the transformation of Fermoy but that the significance of the property was greatly diminished following the destruction of the 1968 fire. It states that internally there are no surviving historic features, and that the interiors of the building are insignificant. The report identifies that the proposed development seeks to remove the existing modern metal flat roof. It states that the proposed reinstatement of a hipped slate roof "will restore its historic character externally". Archaeological Impact An Archaeological Impact Assessment was carried out by Rubicon Heritage Services Ltd. The archaeological assessment has found that the site was once the location of an extensive Mill complex, only a portion of which remains visible above ground. The Assessment recommends a series of mitigation measures to be undertaken so as to minimise any impact on the archaeological integrity of the subject site. These include a programme of "archaeological testing to be carried out where the proposed dispensary and medical aids area building are to be located to ascertain the nature and extent of any surviving archaeology associated with the wider mill complex" and also "a programme of archaeological monitoring will be carried out by Manahan Planners
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a suitably qualified archaeologist under license and in accordance with the provisions of the National Monuments Acts 1930-2004". Ecological Study An Ecological Study was carried out by Scott Cawley. Their report concludes that the proposal has the potential to cause “significant effects on freshwater pearl mussel within the Blackwater River main channel either on its own or cumulatively with other projects in the area, based on the recent annual environmental report for Fermoy WWTP. Discharge from the plant is having an observable impact on surface water quality in the receiving environment. All other potential impacts have been identified and mitigation has been applied. After mitigation is applied these impacts are not considered to be significant either alone or cumulatively with other plans and projects in the locality�. Drainage Assessment Cronin & Sutton Consulting Engineers were commissioned to prepare a Engineering Services Report for the proposed development. The report states that the proposed re-development will require the foul effluent to be discharged into the existing public sewer located in Mill Road. It also outlines that the proposed re-development will require SuDs measures to be incorporated into the design. It states that the scheme will install "an attenuation system to limit extreme water run-off rates to undeveloped greenfield rates, and a series of water quality improvements will be incorporated into the scheme". Flood Risk Assessment Cronin & Sutton Consulting Engineers were also commissioned to prepare a Flood Risk Assessment for the proposed development. The report outlines that while the site historically has flooded from past events, the potential for the River Blackwater to flood the subject lands in the future has been significantly reduced by the construction of flood defences along the River. It states that there will remain an inherent risk of flooding from this source and as such flood mitigation measures will be required to be reviewed and maintained regularly. In terms of the proposed redevelopment of the site, the report finds that "the risk of the site contributing to offsite flooding or the sites vulnerability to flooding from the public drainage network is mitigated by the installation of an attenuation tank to retain the storm volumes experienced on site during high intensity storm events".
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Screening for Appropriate Assessment Screening for Appropriate Assessment was carried out by Scott Cawley. Their report finds that with appropriate mitigation measures followed, the integrity of the European Site will not be adversely affected: “Following an examination, analysis and evaluation of the relevant information including, in particular, the nature of the proposed development and the potential relationship between the proposed development and the relevant European sites and, applying the precautionary principle, it is the professional opinion of the authors of this report that there will be no adverse impact on the integrity of any European sites. In the case of the relevant European Site, the Blackwater River (Cork/Waterford) SAC (002170), the only potentially (pre-mitigation) significant risk (in the absence of mitigation) arises from potential changes to water quality from a pollution incident. However, with the full implementation of the mitigation measures outlined in this report these risks will be avoided. Consequently there will be no risk of adverse effects on habitats or species that are listed as qualifying interests, nor the attainment of specific conservation objectives, either alone or in-combination with other plans or projects, for the relevant European Site. Accordingly, in the professional opinion of the authors of this report, whilst it has been acknowledged that there is the potential in the absence of mitigation for the proposed development to have significant direct or indirect impacts on the Blackwater River (Cork/Waterford) SAC (002170), with the implementation of the detailed mitigation measures identified in this report, the integrity of this European Site will not be adversely affected.� Construction Management A construction Management Plan will be conducted once a builder is engaged by the Applicant.
Conclusion In conclusion it is submitted that the proposal is consistent with the provisions of the Cork County Development Plan 2014, the Fermoy Electoral Area Local Area Plan Second Edition January 2015 and national policy guidance, is an appropriate design response to a such a well located site and it is consistent with the proper planning and sustainable development of the area. As such it is requested that the Cork County Council proceed to grant permission for this worthy and much needed development. The proposed development will cater to a catchment area extending across North Munster. As such the majority of its patrons will drive to the centre. In view of that the facility needs to be located on a site with sufficient parking available to it. Such a site is not available within the fine grain of the town centre. Manahan Planners
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In addition patrons using the facility may require the services of a dispensing chemist before undertaking the return journey home. It is considered appropriate to provide a modest facility on site that caters to patrons. This would allow them to avail of the facility rather than getting into their cars, travelling to the town centre and searching for a parking space in order to use pharmacies in the town centre. This will provide a convenience to users and a reduction in the number of additional journeys that patrons have to make and is therefore sustainable on that account. Lobby groups for existing pharmacies within the town centre may seek to dispute this for their own ends. It is not the function of the planning system to inhibit competition or to favour one group of businesses as against another. In this case the provision of a facility on-site has clear planning benefits as well as benefits for users of the facility. It should be approved on that account. In conclusion the proposal provides a very necessary and important facility for people in North Munster, it provides a use for an existing office building and permits the conservation and refurbishment of an important protected structure. In view of this it is submitted that the proposal is consistent with the proper planning and sustainable development of the area and accordingly we request that the planning authority grant permission for this welcome and appropriate development. We look forward to a Decision in due course.
Manahan Planners 14th February 2018
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