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9. Transport Infrastructure Ireland Forward Planning Team Monaghan County Council Planning Offices 1 Dublin Street Monaghan H18 X982 by e.mail; devplan@monaghancoco.ie. Dáta|Date Ár dTag|Our Ref. 30 June, 2023 TII23-122973 Re. Review of the Monaghan County Development Plan, 2019 - 2025 Preparation of the Monaghan County Development Plan, 2025 - 2031 Dear Sir/Madam, The Authority welcomes consultation on the review of the Council’s Development Plan and the preparation of a new County Development Plan. The Authority submits the following observations for the Councils consideration which may inform the preparation of the Draft County Development Plan. 1. MANAGING EXCHEQUER INVESTMENT AND STATUTORY GUIDANCE The EU Trans-European Transport Networks (EU TEN-T) are a planned set of transport networks across Europe. The EU TEN-T regulations target a gradual development of the transport network with the core network a priority (by 2030) followed by the remainder of the comprehensive network (by 2050). The EU TEN-T regulations define the objective of increasing the benefits for road users by ensuring safe, secure and high-quality standards for road users and freight transport, co-ordinated to achieve integrated and intermodal long-distance travel routes across Europe. The Council will be aware that the N2, national primary road, through Monaghan is identified as part of the EU TEN-T Comprehensive Network. Such designations have repercussions and action requirements for policies and objectives for consideration in the preparation of the new County Development Plan. In addition, the N12, national primary road, and the N53 and N54, national secondary roads, provide important regional and inter-regional connectivity within the County. Combined, the national routes, provide onward connectivity to international port and airport locations as well as connection with other strategic national roads. Project Ireland 2040|National Development Plan, 2021 – 2030, outlines the key sectoral priority of maintaining Ireland’s existing national road network to a robust and safe standard for users. Government also includes the objective to maintain the strategic capacity and safety of the national roads network, including planning for future capacity enhancements, in National Strategic Outcome 2 of the National Planning Framework. This requirement is further reflected in the National Investment Framework for Transport in Ireland and also the existing Statutory Section 28 Spatial Planning and National Roads Guidelines for Planning Authorities. The routes identified above are important strategic national roads and give access to regional and international markets, including through strategic airport and port locations as well as linking with other strategic national roads. It is of particular importance that policies and objectives are drafted which allow the network of national roads to continue to play the intended strategic role in catering for inter-urban and inter-regional transport requirements that will serve economic competitiveness and regional accessibility by providing faster, more efficient and safer access to and from our major ports, airports, cities and large towns. There is a critical need to manage these assets in accordance with national and regional policy as outlined in the provisions of the Section 28 DoECLG Spatial Planning and National Roads Guidelines for Planning Authorities (2012), Project Ireland 2040, the National Investment Framework for Transport in Ireland and the Northern and Western Regional Assembly Regional Spatial and Economic Strategy (NWRA RSES). The NWRA RSES includes Regional Policy Objectives concerning national roads. Regional Policy Objective RPO 6.5 outlines; The capacity and safety of the region’s land transport networks will be managed and enhanced to ensure their optimal use, thus giving effect to National Strategic Outcome No.2 and maintaining the strategic capacity and safety of the national roads network including planning for future capacity enhancements. Recommendation Having regard to the foregoing, TII would welcome consideration by the Council of the following:  Inclusion as a Core Strategy Objective in the proposed Core Strategy of the Draft Development Plan strategic objectives to reflect the foregoing official policy requirements, summarised as; a) to maintain the strategic function, capacity and safety of the national roads network, including planning for future capacity enhancements, and, b) to ensure that the existing extensive transport networks, which have been greatly enhanced over the last two decades, are maintained to a high level to ensure quality levels of service, safety, accessibility and connectivity to transport users. While it is noted that the Strategic Issues and Options Consultation Paper does not appear to consider this matter, TII requests that the preparation of the County Development Plan reflects the foregoing provisions of official policy and national and regional objectives in relation to spatial planning and national roads. 2. DEVELOPMENT AND CORE STRATEGY As demonstrated in this submission, the Authority seeks to ensure that the carrying capacity, operational efficiency, safety and national investment made in national roads in County Monaghan continue to be safeguarded and that the relevant policies/objectives included in the County Development Plan are developed to reflect this. In particular, the Authority requests that the Council consider the implications of land use policies on the strategic national road network in the area as a criterion in determining the future land use zoning strategy to be outlined in the Draft Development Plan and the respective Core Strategy. The Authority respectively points out that although a requirement may be identified for the development of a particular location, any local transport function of national roads in respect of such areas is, and must continue to be, secondary to the role of these roads in catering for strategic traffic. Such an approach, consistent with the provisions of official policy, supports access to markets and economic growth. In addition, proposals should not be developed that are to the detriment of the investment in national road infrastructure, by eroding or undermining that investment, which is required to service the Country’s major inter-urban and inter-regional transport requirements and underpins economic competitiveness. Policies and objectives in identified urban growth areas can be developed and adopted so as to avoid undermining the strategic transport function of national roads. Measures to cater for the needs of local traffic and local development related traffic are appropriately addressed within a framework of providing an adequate local transportation infrastructure. The Development Plan is the policy document to set this framework at county level. 2.1 Local Transport Plans / Sustainable Mobility The North and West Regional Assembly Regional Spatial and Economic Strategy includes Objective RPO 6.27 outlining support for the collaborative preparation of Local Transport Plans by local authorities for a number of key regional towns, including Monaghan Town. The RSES consider Local Transport Plans will inform the urban area plans, development plans, local area plans and other planning framework documents. The Monaghan Town LTP will be a key component in facilitating compact growth and sustainable transport in the Monaghan Town and Environs area. TII concurs with the requirements of the RSES which specifies that the LTP will inform the development plan, local area plans and any other planning framework documents. Having regard to the significant national road interactions in the area, TII would welcome consultation and collaboration with the Council and the NTA in the preparation of the LTP prepared in accordance with the TII/NTA Area Based Transport Assessment Guidance (TII Publications PE-PDV-02046). In addition to the review of the extent and location of residential lands in accordance with core strategy requirements, the Council may consider it appropriate to review the extent and location of industry, employment and other commercial type land uses to prepare a co-ordinated and integrated land use pattern; the Guidance Note on Core Strategies published by the DoECLG (2010) contains advice on this requirement, page 8 refers. The requirement to consider extent and location of industry, employment and other commercial type land uses should also extend to existing locations and proposals to better serve established employment/commercial areas with more sustainable transport options. Such consideration relates not only to Monaghan Town which can be addressed in the Local Transport Plan but other main towns in County Monaghan that have significant employment lands identified in the vicinity of the strategic national road network. The Authority recommends that residential, retail, and employment objectives especially zoning objectives should guide developers to design for sustainable transportation requirements at the earliest stages of development design. An integrated approach to the design of development areas should include a set of principles and criteria designed to ensure a high standard of access by public transport, foot and private car so that the variety of residential, enterprise and employment zones/areas can be easily accessible by all modes of transport and all sections of society. As indicated in the Spatial Planning and National Roads Guidelines for Planning Authorities (DoECLG, 2012) where planning authorities propose large scale development in urban areas and or areas adjoining national roads, including major junctions and interchanges, development plans should ensure that the capacity on national roads is utilised appropriately and that such roads can continue to perform their intended function into the future by:  protecting undeveloped lands adjoining national roads and junctions from development to cater for potential capacity enhancements;  ensuring that capacity enhancements and or traffic management measures will be put in place to facilitate new development; and  improving operational efficiency of the regional and local road and transportation infrastructure – e.g., where appropriate, promoting new regional and local road networks and alternative modes. The Council is also advised that any costs such as land acquisition, additional road infrastructure and environmental mitigation measures arising to the national roads network to accommodate local development proposals will be borne by the local authority and will not be funded by TII and thus should be integrated into future local development contributions schemes. In TII’s opinion, the co-ordination of land use planning and transportation is critical to achieving the complementary objectives of compact urban growth and sustainable mobility while safeguarding the strategic function of the national road corridors in County Monaghan. Recommendation TII would welcome consideration by the Council of the following:  In the review of the extent and location of residential lands in accordance with core strategy requirements, the Council may consider it appropriate to review the extent and location of industry, employment and other commercial type land uses that give rise to significant trip generation to prepare a co-ordinated and integrated land use pattern; the Guidance Note on Core Strategies published by the DoECLG (2010) contains advice on this requirement, page 8 refers.  TII would welcome consultation and collaboration with the Council and the NTA in the preparation of the Monaghan Town Local Transport Plan having regard to the extent of the existing and planned national road network in the area. 2.2 Development at national road junctions In addition to the Core Strategy and general development strategy safeguarding the strategic inter-urban and inter- regional function of national roads, as outlined above, it will be important for the Council to exercise particular care in their assessment and management of development proposals in the Development Plan relating to the zoning of locations at or close to junctions on the national road network where such development could generate significant additional traffic, thereby potentially compromising the capacity and efficiency of the national road/associated junctions and possibly leading to the premature and unacceptable reduction in the level of service available to road users. Proposals for development and land use zoning designations at national road interchanges and junctions require careful consideration and any proposals should be prepared in the context of the provisions of Section 2.7 of the DoECLG Spatial Planning and National Roads Guidelines. TII remains available to assist the Council in preparing Strategic Transport Assessments to address development proposals in the proximity of national roads where such proposals are demonstrated as being in accordance with the provisions of official policy in the first instance. The Council will be aware that Section 2.7 of the DoECLG Guidelines do not extend to include retail and residential development. Where such frameworks are already in place for developing areas, development principles and investment requirements should be reflected in the Development Plan. As outlined, Draft Development Plan policies should reflect and safeguard the strategic role of the national road network and associated junctions in catering for the safe and efficient movement of inter-urban and inter-regional traffic. Planning authorities, in considering proposals for zonings adjacent or close to existing or planned national roads/motorways and junctions, should give special attention to the preferences expressed in the Retail Planning Guidelines for locating developments that attract many trips within established towns and district centres. It should be noted that whilst the Authority recommends that traffic and transport assessments be carried out for individual planning applications as part of the development management process, this is not a substitute for a prior overall transport assessment of areas where the planning authority is determining fundamental issues of land use and transportation. Leaving the overall transport assessment of areas to individual applicants' transport assessments is considered highly inappropriate and would lead to a piecemeal and unsustainable approach to development in the vicinity of the strategic national road network. Such an approach is relevant for planned growth areas in Monaghan, particularly within the higher tiered settlements in the County. In the context of official policy there is a requirement to carefully consider zoning and development proposals in the vicinity of the strategic national road network and associated junctions. In addition to the requirement to undertake a Local Transport Plan for Monaghan Town, it is the Authority’s opinion that the Council should give consideration to undertaking appropriate Area Based Transport Assessment and/or Strategic Transport Assessment (STA) to support the preparation of the Draft County Development Plan, particularly, in relation to areas of planned development which have an interface with the national road network. Section 1.4 of the NRA/TII Traffic and Transport Assessment Guidelines (2014) refers and TII notes the incidence of employment lands located in the vicinity of national road junctions included in current Settlement/Town Plans for Carrickmacross, Castleblayney as well as Monaghan Town, etc. which should be supported by an appropriate evidence-base in accordance with the requirements with the provisions of official policy. TII remains available to assist the Council and is available for consultation in relation to matters impacting the strategic national road network in the County. Recommendation TII would welcome consideration by the Council of the following:  In accordance with Section 2.7 of the DoECLG Spatial Planning and National Roads Guidelines for Planning Authorities, particular care must be exercised in the assessment and management of development proposals in the Development Plan relating to development objectives or the zoning of locations at or close to junctions on the national road network which should be subject to an appropriate evidence-base in accordance with the provisions of official policy.  TII would welcome the inclusion of a specific policy/objective in the Draft Plan to include specific reference to safeguarding the national road network, including associated junctions, as follows; ‘It is a policy of the Council to protect the capacity and strategic function of the national road network and associated junctions, having regard to all relevant Government Guidance, including DoECLG Spatial Planning and National Roads Guidelines (DoECLG, 2012) in the carrying out of local authority functions’. 2.3 Access to national roads The DoECLG Spatial Planning and National Roads Guidelines advise, Section 2.5 refers, that development plans should make it clear that the policy of the planning authority will be to avoid the creation of additional access points from new development or the generation of increased traffic from existing accesses to national roads to which speed limits greater than 50kph apply. It is requested that this official policy provision is reflected in the Development Plan having regard to the extensive national road network in the County and in the interests of advising applicants/developers of such policy provisions at the earliest stage of their pre-planning. This also creates the requirement to co-ordinate proposed zoning designations and/or access strategies in the Development Plan and accompanying settlement plans, as appropriate, with speed limits on national roads. Recommendation TII would welcome consideration by the Council of the following:  To include a specific policy/objective in the Draft Plan consistent with Section 2.5 of the DoECLG Spatial Planning and National Roads Guidelines as follows; ‘To avoid the creation of any additional access point from new development or the generation of increased traffic from existing accesses to national roads to which speed limits greater than 60kmph apply, in accordance with the requirements of the Section 28 Ministerial Guidelines ‘Spatial Planning and National Roads Guidelines for Planning Authorities’ (DoECLG, 2012)’. 2.4 ‘Exceptional Circumstances’ Where the planning authority proposes to exercise a less restrictive approach to the control of development accessing national roads, this should be plan led, done in consultation with and subject to the agreement of TII in accordance with the provisions of Section 2.6 of the DoECLG Spatial Planning and National Roads Guidelines. The Council may also wish to consider cases relating to any planned strategic infrastructure development proposals. TII remains available to discuss proposals in relation to Section 2.6 of the Guidelines with the Executive of Monaghan County Council for incorporation into the new Development Plan. It will be important that the appropriate evidence base is developed to support any proposals in this regard. Recommendation TII would welcome consideration by the Council of the following:  TII remains available to continue to assist the Council in the development of proposals for consideration as plan-led ‘exceptional circumstances’ cases in accordance with the provisions of the DoECLG Guidelines. 2.5 Retailing In the interests of clarity, TII would welcome a policy/objective included in the Draft Development Plan to reference the explicit presumption against large out of town retail centres located adjacent or close to existing, new or planned national roads/motorways reflecting policy outlined in the Retail Planning Guidelines, 2012. Recommendation TII would welcome consideration by the Council of the following:  The inclusion of a policy objective included in the Draft Development Plan to include the explicit presumption against large out of town retail centres located adjacent or close to existing, new or planned national roads/motorways reflecting policy outlined in the Retail Planning Guidelines, 2012. 3. TRANSPORT PLANNING AND NATIONAL ROAD SCHEMES 3.1 National Road Scheme Planning TII in collaboration with the Council, is developing/progressing national road schemes and improvements within County Monaghan in accordance with National Development Plan investment commitments. Details of the Schemes should be considered for inclusion in the Development Plan including policies and objectives to safeguard scheme planning and route (options) free from adverse development that could prejudice scheme delivery. The following schemes are identified, subject to further approvals, under the National Development Plan, 2021 - 2030;  N2 Ardee to South of Castleblaney  N2 Clontibret to the Border Planning authority policies and objectives, including rezoning of lands, should not compromise the road planning and route option evaluation process in circumstances where road scheme planning is underway and potential routes have been identified and brought to the attention of the planning authority, including schemes that may currently be suspended. Similarly, development strategies or rezoning proposals should not have the effect of altering the function of these routes or importantly, increase the cost of land to be acquired or under active consideration as a route option for a national road scheme. Such proposals, while potentially bringing major financial gains to the property owners involved, would be at variance with the broader public interest and would, by significantly increasing the cost of the land to be acquired for road schemes, reduce the funding available to the Authority for road construction and improvement work generally. There are other national road improvement schemes in development that the Council may consider relevant for inclusion in the Draft Development Plan. TII recommends consultation with the Councils Road Design Office or local National Road Design Office to ensure the inclusion of up to date information in the Draft Plan, noting that the status of schemes can alter during the course of a Development Plan and development plan preparation. The Authority’s other priorities in relation to national roads are the maintenance of the existing national road network, including junctions, and safeguarding the Exchequer investment in national roads to date, in accordance with the provisions of official policy identified in the foregoing. In addition to schemes addressed in the foregoing, TII advises that any additional improvements relating to national roads identified at a local level should be done so in consultation with and subject to the agreement of TII. The Council will be aware that TII may not be responsible for the funding of any additional schemes or improvements. Any additional connectivity to national roads should be developed in accordance with the requirements of Section 2.7 of the DoECLG Spatial Planning and National Roads Guidelines (2012). Related to the foregoing, the Authority requests the inclusion of policies and objectives in the Development Plan that provide for the following:  objectives providing for development of relevant national road schemes,  a policy to protect national road schemes free from adverse development that may compromise the development of route options or the construction of preferred routes, or add to the overall costs associated with proposed schemes. The Council will be aware that the implementation of all national road schemes is subject to budgetary constraints and is subject to prioritisation and adequacy of the funding resource available to the Authority. In these circumstances and taking account of the Exchequer financial position and levels of funding available to the Authority, the relative priority or timeframe for national road schemes may be subject to alteration. Recommendation TII would welcome consideration by the Council of the following:  TII recommends that national road schemes should be considered for inclusion in the Development Plan in accordance with National Development Plan investment objectives giving effect to National Planning Framework National Strategic Outcome no. 2 ‘Enhanced Regional Accessibility’.  TII strongly recommends that consideration should be given to incorporating a specific policy/objective, in accordance with the proposed wording outlined below or similar, to conform to the provisions of official policy and safeguard national road schemes in planning; ‘To protect the study area, route corridor options and thereafter the preferred route corridor selected for the national road schemes being progressed in the Development Plan in accordance with National Development Plan Objectives and to prohibit development that could prejudice their future delivery’. 3.2 Appropriate Assessment Requirements Associated with the delivery of national road improvements is the requirement to adhere to relevant environmental regulations, including Appropriate Assessment (AA). Therefore, TII recommends that the Council carefully consider the wording associated with AA requirements in the Draft Plan to ensure conformance with Article 6(3) and 6(4) of the Habitats Directive in the interests of consistency and clarity. The Council will be aware that all national road projects are funded, developed and implemented in accordance with TII Publications, Standards and Codes of Practice. Schemes also progress in accordance with all EU and National environmental legislative requirements. In TII’s opinion, applying alternative corridor or scheme assessment requirements, in addition to the Habitats Directive and the above requirements, can result in ambiguity and lack of consistency in scheme planning and design. Recommendation TII would welcome consideration by the Council of the following:  TII recommends that text should be included in the Draft Plan to ensure that Appropriate Assessment of national road scheme planning is undertaken in accordance with the requirements of Article 6(3) and Article 6(4) of the Habitats Directive. 4. OTHER SPECIFIC POLICIES AND OBJECTIVES 4.1 Road Safety The Road Safety Authority’s Road Safety Strategy, 2021 – 2030, builds on existing road safety interventions, but reframes the way in which road safety is viewed and managed in the community. It addresses all elements of the road transport system in an integrated way with the aim of ensuring collision energy levels are below what would cause fatal or serious injury. It requires acceptance of shared overall responsibilities and accountability between system designers and road users and it stimulates the development of innovative interventions and new partnerships necessary to achieve ambitious long term road safety targets. Therefore, the design of development proposals must address the functionality and safety of road needs. Two processes address these design concerns: Road Safety Impact Assessment (RSIA) and Road Safety Audit (RSA).  Road Safety Impact Assessment (RSIA) is described in the EU Directive on Road Infrastructure Safety Management (EU RISM) 2008/96/EC as a strategic comparative analysis of the impact of a new road, or for substantial modifications to an existing road, on the safety performance of the road network (refer to TII Publications Planning and Evaluation PE-PMG-02001 Road Safety Impact Assessment).  Road Safety Audit (RSA) involves the evaluation of road schemes during design, construction and early operation to identify potential hazards to all road users. RSA is to be carried out on all new national road infrastructure projects and on any schemes/proposal which results in a permanent change to the layout of a national road (refer to TII Publications GE-STY-01024 Road Safety Audit). RSIA is a separate process to RSA. While RSA examines the safety aspects within a scheme, RSIA considers the safety impact of a scheme on the surrounding road network. RSIA and RSA both work to improve the safety performance of new roads and existing roads that require modifications due to projects or proposals. Both have consequences for the design and layout of any project. Recommendation TII would welcome consideration by the Council of the following:  The Council is requested to reference RSA and RSIA requirements in the Draft Development Plan relating to development proposals with implications for the national road network. 4.2 Traffic and Transport Assessment (TTA) As referenced in the observations above, the Authority recommends that planning applications for significant development proposals should be accompanied with TTA to be carried out by suitably competent consultants, which are assessed in association with their cumulative impact with other relevant developments on the road network. Guidance in relation to TTA is given in the “Traffic Management Guidelines”. To assist with TTA, TII has prepared the Traffic and Transport Assessment Guidelines (2014), which are available at www.tii.ie and could be referenced in the Draft Plan as appropriate guidance. The Guidelines also include recommendations on the requirement for sub-threshold traffic and transport assessments. Recommendation TII would welcome consideration by the Council of the following:  The Council is requested to reference the TII Traffic & Transport Assessment Guidelines (2014) in the Draft Development Plan relating to development proposals with implications for the national road network. Thresholds advised in the TII Traffic & Transport Assessment Guidelines (2014), including sub-threshold TTA requirements, relate specifically to development proposals affecting national roads. 4.3 Service Areas The planning authority will be aware that Section 2.8 of the DoECLG Spatial Planning and National Roads Guidelines indicates the requirement for a forward planning approach to the provision of off-line motorway service areas at national road junctions and also addresses road side service facilities on non-motorway national roads and their junctions. Comments, above, in relation to development at national road junctions may also be pertinent in the case of such development proposals. The Council will be aware that the Authority has issued the TII Policy on Service Areas (August, 2014). Section 1.4 of the Policy outlines the roles of the Authority and planning authorities in relation to the provision of service areas. Recommendation TII would welcome consideration by the Council of the following:  TII recommends that the Council considers the requirements of Section 2.8 of the DoECLG Spatial Planning and National Roads Guidelines, in particular, in relation to the provision of road side service facilities on non-motorway national roads and their junctions. 4.4 Signage TII has also issued the Policy on the Provision of Tourist & Leisure Signage on National Roads (March 2011). The purpose of this document is to outline TII’s policy on the provision of tourist and leisure information signs on national primary and national secondary roads in Ireland. With respect to the new Development Plan, the Planning Authority is also referred to Section 3.8 of the DoECLG’s Spatial Planning and National Roads Guidelines which indicates a requirement to control the proliferation of non- road traffic signage on and adjacent to national roads. Recommendation TII would welcome consideration by the Council of the following:  In relation to signage impacting national roads, TII would welcome the provisions of the TII Policy and the DoECLG Guidelines incorporated into the new Development Plan. 4.5 Noise The Council is also requested to refer to the requirements of S.I. No. 140 of 2006 Environmental Noise Regulations in the Draft Plan. The Authority advises that it requires that development proposals identify and implement noise mitigation measures when introducing noise sensitive uses in the environs of existing and planned national roads, where such mitigation is warranted. The costs of implementing mitigation measures shall be borne by the developer, as the Authority will not be responsible for the provision of additional noise mitigation. Recommendation TII would welcome consideration by the Council of the following:  The Council is requested to address and refer to the requirements of S.I. No. 140 of 2006 Environmental Noise Regulations in the Draft Plan. 4.6 Safeguarding national road drainage regimes TII would welcome consideration being given to including a new objective associated with safeguarding investment in the national road network relating to protection of national road drainage regimes. Significant improvements to the national road network have been overseen by Monaghan County Council. There is an onus and a policy requirement on road and planning authorities to safeguard the national investment made. In that regard, TII has experienced a number of instances nationally where private development proposals have accessed or sought to access national road drainage regimes to dispose of surface water drainage. National road surface water drainage regimes are constructed with the objective of disposing of national road surface water, it is important that capacity in the drainage regime is retained to address this function. Recommendation TII would welcome consideration by the Council of the following:  Having regard to the extensive national road network in Monaghan, TII would welcome consideration of a new Objective included in the Development Plan outlining that; ‘The capacity and efficiency of the national road network drainage regimes in County Monaghan will be safeguarded for national road drainage purposes’. 4.7 Renewable Energy TII appreciates that the availability of a safe, secure and reliable supply of electricity is an essential requirement for Ireland’s current and future economic wellbeing. The greening of energy generation via the transition from conventional fossil fuel power generation to sustainable forms of renewable energy supply such as wind and solar power is an essential development if Ireland is to meet its obligations to cut greenhouse gas emissions as we move towards a zero carbon economy and TII fully supports Government policy in this regard. In TII’s experience, the dispersed nature of renewable energy resources generally has the potential to result in interactions, to varying degrees, with the strategic national road network that require careful consideration and management. In accordance with the National Planning Framework National Strategic Outcome no. 2 ‘Enhanced Regional Accessibility’, there is a requirement to maintain the strategic capacity and safety of the national road network. This requirement is further reflected in the National Development Plan, the recent publication of the National Investment Framework for Transport in Ireland and also the existing Statutory Section 28 Spatial Planning and National Roads Guidelines for Planning Authorities. The dispersed and rural nature of the location of renewable energy resources requires the development of associated grid connection development. Grid connections accommodated on national roads have the potential, inter alia, to result in technical road safety issues such as differential settlement due to backfilling trenches and can impact on ability and cost of general maintenance and safety works to existing roads. Constraints and costs arise to on-line national road improvements and upgrades also. In that regard and having regard to the requirement to maintain the strategic capacity and safety of the national road network in accordance with official policy provisions, TII recommends that grid connection proposals should be developed which safeguard the strategic function of the national road network by utilising available alternatives in the first instance. TII would welcome this matter being considered as a policy provision in the Draft Development Plan. TII also recommends that PV Farm Renewable Energy Development proposals in the vicinity of the strategic national road network should be accompanied by glint and glare assessments and that such a requirement should be included as a provision of the Draft Development Plan. Recommendation TII would welcome consideration by the Council of the following:  TII would welcome an objective included in the Draft Development Plan in relation to renewable energy and in relation to safeguarding the national road network, indicating that grid connection routing options should be developed to safeguard the strategic function of the national road network in accordance with Government policy by utilising available alternative routes.  Applications for PV Farm developments should be accompanied by glint and glare assessments and such a requirement should be included as a provision of the Draft Development Plan. 4.8 TII Publications (Standards) While the Design Manual for Urban Roads and Streets (DMURS) is the applicable standard to apply in an urban context, TII would highlight that any works to the national road network and national road junctions will continue to require adherence to TII Publications (Standards) as well. The Council will also be aware that TII has published complementary TII Publication ‘The Treatment of Transition Zones to Towns and Villages on National Roads’ (TII Publications DN-GEO-03084). This TII Publications Standard describes the requirements that shall be implemented on National Roads on the approaches to towns and villages in terms of the provision of traffic calming measures and pedestrian crossings. National Roads within 60km/h zones can traverse many areas with very different characteristics such as low density residential areas, industrial areas, mixed use neighbourhoods and town and village centres. This requires different design solutions within each of these different contexts. Recommendation TII would welcome consideration by the Council of the following:  TII requests acknowledgment of complementary TII Publication ‘The Treatment of Transition Zones to Towns and Villages on National Roads’ (TII Publications DN-GEO-03084) in relation to design standards to be applied to national roads and national road junctions in the Draft Development Plan. The Draft Plan should also acknowledge that works to national roads in urban areas are required to adhere to TII Publications (Standards) as well as the Design Manual for Roads and Streets (DMURS).  As well as the foregoing, the Council will be aware that it remains the requirement that a Design Report is completed and submitted for works to national roads in accordance with TII Publications DN-GEO-03030 (Design Phase Procedure for Road Safety Improvement Schemes, Urban Renewal Schemes and Local Improvement Schemes). 4.9 Greenways and Active Travel In relation to Greenway proposals, consultation with the Councils own internal project and/or design staff is recommended. CONCLUSION Having regard to the foregoing, the Authority recommends that the development objectives included in the Draft Development Plan reflect the provisions of the DoECLG’s Spatial Planning and National Roads Guidelines which indicates the importance of developing an evidence based approach at development plan stage for proposals with implications for the on-going safe and efficient operation of national roads. In summary, the Planning Authority is advised to ensure in the review of the County Development Plan:  The protection of the safety, carrying capacity and efficiency of the existing and future national roads network is maintained,  Future National Road Scheme planning is provided for and schemes are safeguarded, and;  An integrated approach to land use and transportation solutions throughout the County should be undertaken such that local traffic generated by developments is catered for primarily within the framework of the local (i.e. non-national) road network. The Authority is available to meet the Executive of the Council to discuss the issues raised in this correspondence as an aid to devising an appropriate and sustainable development strategy for County Monaghan. Yours sincerely, ____________________ Michael McCormack Senior Land Use Planner