24th January 2008

The Secretary

An Bord Pleanála

64 Marlborough Street

Dublin 1


Your ref:  PL04.PA0003


Re:  Application by the Port of Cork Company for demolition of public pier and slipway, and development of facilities at Ringaskiddy requiring, inter alia, acquisition by the company of 18 hectares of the Oyster Bank in Cork Harbour and development of a container facility.

Dear Secretary

I write on behalf of myself as a resident of Cork Harbour, and on behalf of the members of the Green Party in the constituency of Cork East, which borders Cork Harbour.  This letter will outline our principal objections to the proposed development by the Port of Cork Company adjacent to Ringaskiddy, Co. Cork, but we also wish to rely on all of the arguments and observations presented to the Board by objectors to this application.


1)    Introduction
I urge the Board to refuse this development for the many reasons outlined below.  This development would turn the Lower Harbour of Cork into a port, operating 24 hours a day, rather than a harbour, and would seriously impact in a negative way on the many other uses and users of the harbour.  This proposal is little more than a land grab by a private company, albeit with a public remit, and is contrary to the sustainable development of Cork Harbour and the harbour towns of Cobh, Monkstown, Passage West and Ringaskiddy, as well as any future developments on Haulbowline Island and Spike Island.

This development is akin to many bad decisions made in the latter part of the twentieth century in this country, where economic considerations were allowed to overshadow social and environmental issues.  While this proposal might appear to make economic sense to the Port of Cork Company, it makes no sense in either social or environmental terms, or even in economic terms, for the wider community who would have to live alongside this development.

The Port of Cork provides an essential service to the Cork region and to much of Munster, and it is of huge economic significance to the region.  While fully recognising the necessity of having port facilities within Cork Harbour, it is important that there is a reasonable balance struck between the competing users of the harbour.  This development could not be construed as striking a reasonable balance.  The Lower Harbour has borne a huge amount of industrial development over many decades, including the country’s only oil refinery, a power station (and soon to be more), a large number of chemical plants and a crematorium.  It also used to have a steelworks, a fertilizer factory and a shipyard, and it still remains to be seen what will be proposed to be developed on these brownfield sites.  With the commitment to open up Spike Island as a heritage site, and with mixed use residential / commercial / marina / tourism developments proposed or possible at a number of sites around the lower harbour, including Passage West dockyard, Haulbowline Island and Rushbrooke shipyard, it is clear that there is an impetus for development in the lower harbour to move away from the industrial and to develop the harbour into the tourism and leisure destination it should be.  The proposals of the Port of Cork to expand their operations in the Lower Harbour are in direct conflict with these potential developments.

2)    Need for This Proposed Development
The traffic volumes cited by the Port in their application are, to say the least, fanciful.  In the last fifteen years or so, Ireland has gone through an unprecedented level of economic growth, the so-called “Celtic Tiger”.  During this period, container traffic in Cork only grew by about 3 or 4% per annum, to a current figure of approximately 200,000 TEU per annum to 400,000 TEU per annum initially and then on to 600,000 TEU.  These figures cannot be justified by projected growth in the Cork economy, which could not reasonably be expected to exceed 250,000 TEU in the next decade, and due to the impending downturn in the global economy may in fact diminish.  They can only be justified in the context of the Port of Cork seeking to enter the transatlantic conference port business, of which they make no mention in their documentation.  In the absence of a national strategy for ports and shipping (see below) this is at best premature, and at worst contrary to the best interests of the country as a whole.  If such a conference port facility is to be developed in Ireland, there must be a site selection process on a national scale, and surely such a facility would have to be located well away from large residential areas, which would almost certainly eliminate Cork Harbour from consideration due to the high levels of residential development all the way around the harbour.

The need to move the container terminal from its present location in Tivoli is not justified.  While the current facility is close to its maximum capacity, this is due to the handling equipment employed and not due to the availability of suitable storage space.  In fact there is more space available at Tivoli than they are proposing for the new facility at Ringaskiddy.  Upgrading the container handling equipment employed could substantially increase the capacity at Tivoli.

The Port of Cork claim that they need to move the container terminal out of Tivoli due to the limit on the size of ship which can dock there, due to the depth restrictions in the River Lee.  There is insufficient documentation to back up this stated need, and there is also the possibility of increasing the size of ship which can access Tivoli by undertaking further dredging and /or blasting of rocks from the channel.

Overall, due to the long established use of Tivoli for port purposes, the possibilities there must be exhausted before other areas need to be considered.  I believe that there is still much more capacity available to the Port of Cork at Tivoli, and that this capacity is nowhere near exhausted.

3)    Lack of Adequate Site Selection Process
If the Port of Cork can justify, and I contend that they cannot, the necessity to move the container terminal from Tivoli, then there are many possible sites around Cork Harbour which could be suitable.  The proposed site is unsuitable in many ways, and while the Port say they have considered a number of sites around the harbour, they have given almost no detail as to why they consider the Oyster Bank site to be the most suitable, and as to why the other potential sites are less suitable.  Many of the potential sites would require little or no reclamation and / or dredging.  It seems that the Oyster Bank site was chosen for purely economic reasons, as it relatively cheap to reclaim given the availability of abundant fill material on the Curlane Bank.  Before this development proceeds, at the minimum, a proper and detailed public site selection process must be gone through.

4)    Lack of Clarity with regard to Port’s Overall Strategy
It is clear from the Port’s submission, and from discussions with the Port Company, that they propose to ultimately vacate both the Tivoli area and the City Quays in Cork, and move all their port operations to the lower harbour.  It is clear that they wish to sell off all their lands at Tivoli, and to use the money from this to fund their land grabbing exercise in the lower harbour.  It is not clear where in the lower harbour they propose to move many of the port operations, and there is a real fear among the residents of the lower harbour that this is just the first phase of many.  While they have outlined in the current application their proposals for phase 2, to deal with the bulk cargoes dislodged from the City Quays, there is absolutely no indication as to where they intend moving the other operations currently taking place in Tivoli, such as the oil and gas facilities (which are Seveso II sites) and the export of lead and zinc ores from Lisheen mine.  Therefore this application should be considered premature, as it is impossible to properly assess the implications without getting a clear idea of the complete extent to which the port propose to develop the lower harbour.  Consideration of this proposal should be deferred until the port has published its complete plans for development in the lower harbour.

5)    Lack of National Plan for Ports and Shipping
There is no national plan or strategy for ports and shipping, and all of the port companies are set up to effectively compete with each other for business.  This is in direct conflict with the National Spatial Strategy, which aims for the Cork. Limerick and Waterford counties to work together as a region to try to compete with the economic dominance of the Dublin region in the Irish economy.  Surely it is better for the ports in the region to work together to maximise their collective potential and to provide the best possible port facilities for the region, rather than blindly competing with each other for business, with all the duplication of facilities that that entails.  With regard to the Port of Cork’s apparent proposals to seek to enter the transatlantic conference port business, surely this is premature, and the site of such a facility in Ireland should be decided at the national level as part of a national strategy for ports and shipping.

6)    Foreshore Development and Loss of Public Amenity
The proposed reclamation of 18 hectares of Cork Harbour, which is public property, to become the property of a private company is completely contrary to reason and natural justice, and therefore should not be allowed to happen.  The Oyster Bank is a public amenity, and is used by many for sailing, fishing, rowing and other aquatic leisure pursuits.  It is also used as a visual amenity for the many who walk in the area, including the many thousands who walk annually between Monkstown and Raffeen, and also those who walk along from Cobh to Whitepoint.  There is absolutely no proposal within this plan to compensate the public in any way for this loss of a precious amenity.

Monkstown Bay Sailing Club, who use the area regularly as a safe area in which thousands of young people have learned to sail, would particularly feel the loss of the Oyster Bank.  If it is allowed to be reclaimed, and with the consequent increase in ship movements in the area and the narrowing of the channel, this has the potential to make dinghy sailing in Monkstown a thing of the past.  This would be criminal in an era when the levels of childhood obesity are growing, and when there is a huge need to improve facilities for young people in the area, as well as to improve access to the harbour for leisure purposes.  As someone who spent the summers of his teenage years dinghy sailing on a daily basis, including being a national champion, I am fully aware of how good and healthy a pursuit sailing is for our young population, as well as our adult population, and any loss of this amenity is quite simply wrong.

7)    Negative Effects on Adjoining Facilities
There are two significant national institutions in close proximity to the proposed development, and on which this development will have a significant impact.  The naval base on Haulbowline Island, the country’s only naval base, is in very close proximity to this development, and will inevitably be impacted by it.  However the Naval Service, as part of our Defence Forces, are not permitted to comment directly on this planning application.  With the naval base being manned 24 hours a day, and with sailors effectively living there, whether on board ship or on shore, the naval base should be considered a residential area, and it should be treated as such in this planning application.  Because of its very close proximity, many of the impacts discussed in this submission will be very strongly felt on the naval base, such as the noise impact, the light impact and the visual impact, as well as the traffic implications and possible hydrological problems.

Similarly the National Maritime College of Ireland (NMCI) in Ringaskiddy, which is the cornerstone of the developing Maritime Campus Ireland in the Ringaskiddy and Haulbowline area, is in very close proximity to the proposed development.  With the naval service already in the area, and UCC are planning to move the HMRC (Hydrological and Marine Research Centre) to the Ringaskiddy area as part of Maritime Campus Ireland.  The effects on the maritime college will be very similar to those on the naval base, and the college would not benefit from being in such close proximity to such a large port operation.  With the recent announcement of a raft of grants and supports for the wave energy sector announced at the NMCI by the Minister for Communications, Energy and Natural Resources, which envisages Cork Harbour becoming the global centre for the exciting emerging wave energy sector, it is vital than Maritime Campus Ireland is allowed to grow and flourish unencumbered by noisy land-grabbing neighbours.

8)    Contrary to the Future Development of Tourism in Cork Harbour
For many years now there has been a growing impetus for the tourism and leisure infrastructure of Cork Harbour to be developed.  As the second largest natural harbour in the world, second only to Sydney Harbour in Australia, Cork Harbour has not figured in any significant manner on the tourist map.  With the closure of Irish Steel / ISPAT on Haulbowline Island, many believe that now is the time for Cork Harbour to enhance its appeal as a destination for tourism and leisure.  This has been identified in all the major plans for the area.  In particular the town of Cobh has pinned its economic future to developing a significant tourism and leisure industry. 
With the proposals to open up Spike Island as a heritage site, the planning applications before Cork County Council for a river ferry service and for the mixed use residential / commercial / hotel / marina development on the Passage West dockyard, and with developments in the offing for Fort Camden, Haulbowline Island and Rushbrooke Dockyard, among others, there is much energy going in to develop Cork Harbour as a centre for leisure and tourism. 

This proposed development is completely contrary to this growing impetus, and has the potential to stop it in its tracks.  If the leisure and tourism sector reaches its full potential in the harbour, it will employ thousands.  For example it is projected that the development on the Passage West dockyard will employ approximately one thousand people when completed on its own.  The development of the tourism and leisure industry in the harbour should quite simply allowed to be jeopardised by this development, which has minimal employment possibilities and negative economic implications for the area.  While fully recognising the port’s strategic economic importance for the region, there are plenty of other locations that must be considered, and which do not have such a devastating impact on the future development of Cork Harbour.

9)    Visual and Light Impact
This development would be visible from a very wide area around the harbour, and would have a negative visual impact on a very large number of people living in the harbour, as well as thousands of visitors to the harbour, including tourists coming in to the Cobh Cruise Liner Terminal.  This visual impact would not just be during daylight, but also at night as the container terminal would be very well lit at night, and those lights would be visible from a very large area.  The area affected includes all of Monkstown, all of Ringaskiddy, and in Cobh an area from the centre of the town out to Rushbrooke, and Blackpoint and Whitepoint in particular, and including the large residential areas of Rushbrooke Manor, Rushbrooke Links and Norwood Park.  All in all this site would be visible from probably a couple of thousand houses, with huge negative consequences and loss of visual amenity for the thousands of people living in those houses.

There would also be huge visual and lighting impacts for the thousands of visitor to the lower harbour, whether they be walking in Monkstown, coming in to Cobh on cruise liner, or coming in to Ringaskiddy by ferry, to give just some examples.  As already discussed, with plans to increase the number of visitors to the lower harbour, this loss of visual amenity alone could jeopardise the potential for tourism development, as the Irish Steel / ISPAT plant did for many decades previously.

10) Noise Impact
With previous noise monitoring in the area having shown that the EPA noise guidelines, particularly at night, are being currently exceeded in certain parts of the harbour, particularly in Blackpoint, Monkstown and Haulbowline, it would foolhardy in the extreme to allow this development to proceed, with the inevitable increase in background noise levels which would entail, and which would bring a wider area of the harbour in breach of the current noise guidelines.  These EPA noise guidelines are likely to be put on a legislative footing within the next year or so as there is a commitment to publish a bill on noise pollution in the current Programme for Government. (see http://www.greenparty.ie/en/library/agreed_programme_for_government/agreed_programme_for_government).  This bill will make breaches of noise pollution an offence, and with the lower harbour already being at or above the guidelines, all efforts should be made to reduce the background noise levels in the harbour, and not add to them.

As well as the issue of background noise, there is the issue of one off noise events like dropped containers, or repairs being made on the deck of ships.  In certain weather conditions, particularly at night, there is a very strong basin effect in the area of the Oyster Bank, where any noise gets echoed around the harbour.  In such conditions an event like a container being dropped would echo around the harbour and have everybody in the area awake.  People have a right to a peaceful night’s sleep, and putting a facility such as a container terminal which has the potential to make a lot of noise in such close proximity to large residential areas, is just wrong.

11) Contrary to Integrated Transport Planning
Shipping has a very important role to play in the international transport market, and particularly for Ireland as an island nation.  However shipping cannot usually provide a point to point transport service, and onward transportation is usually necessary, and always necessary in the container sector.  Therefore it is vital that shipping integrates as fully as possible with the other modes of transport so as to facilitate the onward transportation of goods, including containers. 

It would be hard to find a site better integrated into other transport networks in Cork Harbour than Tivoli.  It has easy access to the three main road arteries out of Cork City to Waterford, Dublin and Limerick, the N25, the N8 and the N20.  While it is not currently in use, it also has the possibility of a rail hub, being adjacent to the Cork – Cobh / Midleton line. 

It would also be hard to find a site worse integrated into other transport networks in Cork Harbour than Ringaskiddy, which is completely dependent on an already overcrowded N28, and from which the vast bulk of traffic would have to go through the Jack Lynch Tunnel, which is already recognised as being at full capacity in peak hours.  There is also no realistic hope of there ever being a rail link to Ringaskiddy, as the cost of bridging the River Lee to link it to the existing rail network would be prohibitive.  Ringaskiddy is quite simply on the wrong side of the harbour, and should have been ruled out as a potential location for this facility on this point alone.

This proposal to move the Port of Cork’s container terminal takes absolutely no account of the realities of peak oil.  Some reports suggest that world oil production peaked in 2006 (see http://www.aspo-ireland.org/index.cfm?page=viewNews&newsId=56), and while the International Energy Agency denies this, nobody disputes that if we haven’t yet reached peak oil, it cannot be far away.  Once peak oil is reached, the price of oil will sky rocket, and the availability of oil as a transport fuel will decline, as it will become so expensive.  Many world economists and experts are predicting dire consequences unless positive action is taken fast.  The moving of the container terminal to Ringaskiddy would, de facto, cause a substantial increase in the overall consumption of oil for every container moved, as it would have to travel an extra eight miles or so on the back of a truck in very heavy traffic from Ringaskiddy to Cork, rather than on a ship up river to Tivoli.  In the peak oil situation, which is either already upon us, or very nearly so, it will become critical that the container terminal is able to integrate efficiently with other transport networks, as the cost of transportation will rise dramatically due to the cost of oil-based fuels.

12) Contrary to Government Climate Change Strategy
This application, or its accompanying EIS, takes no account of the realities of climate change, or of the Government’s or EU’s Climate Change Strategies, which are fast becoming the cornerstones of decision making.  For an application of this magnitude to take no account of climate change is utterly arrogant and shows that the mindset of those proposing this development is very much stuck in the twentieth century, when cheap energy was abundant, and that they have not caught up with the realities of the twenty-first century, when energy prices will rise dramatically, and we will have to become energy conscious in everything we do.  For an Environmental Impact Statement to not take account of this critical area of environmental impact really negates any value the document might otherwise have, and makes its production nothing more than a feeble attempt at window dressing.

With the issuing of a Carbon Budget by the Government last year for the first time as an indication of the way things are going, for this application to have made no attempt or even acknowledgement that we must reduce our emissions of greenhouse gases, particularly CO2 is negligent in the extreme, and this proposal should be rejected on that basis alone.  The transport sector in Ireland is the fastest growing sector in terms of CO2 emissions, and if we are to be serious about addressing climate change, we must radically reduce our CO2 emissions, particularly in the transport sector.  The fact that, in CO2 terms, it is far more efficient to bring containers to Tivoli on a ship for onward transportation by road or rail, than it is to bring those containers from Ringaskiddy to Cork on the back of a truck, seems completely lost on the Port of Cork Company. 

The fact that colossal amounts of energy (and therefore CO2 emissions) would be expended in reclaiming 18 hectares from the sea in Ringaskiddy gets no mention in this application or its EIS, when all that is really required is an upgrading of the handling equipment at the Tivoli container terminal.

If we are to leave the planet in any kind of fit state for our children and our grandchildren it is encumbent on all of us, including the Port of Cork Company, to consider climate change issues in all our decision making.  To not consider climate change in our decision making is akin to having one’s head very firmly buried in the sand.  We must, as a matter of intergenerational justice, take responsibility for our actions now, something the Port of Cork is clearly failing to do.

13) Contrary to the Long-Term Best Interests of the Port itself and of the Commercial Interests of the Region
It is my contention, as a long time environmental activist and student of how environmental issues will affect the future, that in fact the proposal by the Port of Cork to move their container terminal to Ringaskiddy is actually contrary to the long term best interests of the port company itself, with knock on negative consequences for the economic wellbeing of the whole region.  The move to Ringaskiddy will entail an increase in the overall energy consumption per container transported due to the extra miles every container will have to be transported on the back of a truck.  It has long been the case that transport by ship is the most energy efficient, followed by rail, with road transport being the least energy efficient mode of transport.  This is why in the industrialised countries canals and railways were built.  With the cost of oil set to rise dramatically due to peak oil and the problem of climate change demanding a reduction in oil usage, this will substantially increase the cost of road transport.  In this eventuality, rail transport of containers will become much more cost effective, particularly as there is the possibility of trains being powered electrically (from renewable sources ultimately) or being run on sustainable biofuels.  To have moved the container terminal to a location utterly dependent on road transport, and a location at the end of a peninsula and well away from the major routes to boot, will, I contend, be seen to have been akin to the decision to close railway lines in the early and mid twentieth century, i.e. ridiculously short-sighted.  Such a situation would make the whole region less competitive, and this would be extremely dangerous for the economy, given that Ireland has built itself up to be a completely open trading economy, based on the trading of goods internationally.

14) Hydrological Issues
This proposal would involve a substantial narrowing (by about half) of the channel of the River Lee between Ringaskiddy and Cobh.  While the bulk of the water flows through the deeper part of the channel which would remain, the Oyster Bank provides a useful ‘flood plain’ for excess water to flow in times of flood and high tides.  With many areas around the harbour prone to regular flooding, such as parts of Cobh and Glenbrook, the removal of the Oyster Bank and the consequent narrowing of the channel will lead to faster flow rates in the river, which have the potential to exacerbate the potential of various areas to flood.  There is also the potential for areas currently used for shipping to suffer from increased siltation due to changing flow patterns, which would therefore require increased dredging.  Without access to sophisticated models, which are not widely available and are very expensive, it is hard to predict what the exact effects will be, but, given the scale of the reclamation proposed, it is highly unlikely that there will not be significant hydrological consequences.  I believe that a reclamation on this scale requires the greatest extent of modelling possible, which I do not believe has been done.

15) Wildlife Considerations
There is in general, inadequate information on the wildlife in Cork Harbour.  A development of this scale, which removes such a large tract of water, is bound to have substantial effect on the wildlife in the harbour.  Very little is known about the fauna in the harbour, and what role the Oyster Bank plays.  Is it a significant spawning ground for fish or significant feeding ground for wildfowl?  It is certain that there are seals living in the area, as they are regularly seen from Ringaskiddy pier.  The effect this development would have on the many herons which nest around Blackpoint is not clear, but their nesting is bound to be disrupted by the increased activity and noise in the vicinity and the level of lighting at night.  In the absence of a comprehensive study on the substantial fauna of Cork Harbour, and a much deeper understanding of the fish and marine mammal populations in particular, I believe such a large scale reclamation should not take place.  With SAC’s in place at Belvelly and Monkstwon Creek largely to protect wading bird populations, it is high time that the fish and marine mammal populations of the harbour were afforded the same level of attention and protection.  In order for this to happen, we must first gain a much deeper understanding of their lives, feeding patterns and breeding patterns.

16) No Acceptance from the Residents of the Lower Harbour
Probably the strongest argument against this development is the fact that almost no-one living in the area of the lower harbour wants this development to come to Ringaskiddy.  There is no gain to be had for anyone, except possibly those directly involved in the shipping industry (and it is questionable whether there is any gain for them).  On the other hand, as outlined above, there are substantial negative implications for the resident population of the lower harbour.  This population has grown substantially over the past decade or so, with large numbers of houses built on the hills above Rushbrooke, as well as smaller developments in Monkstown and Ringaskiddy, and with the likelihood of substantial developments with a residential component along the harbour, in Cobh, Rushbrooke, Haulbowline, Passge West and Ballynoe in the near future.  I had the privilege to chair two public meetings in the last two months about this development, one in Monkstown and one in Cobh (Rushbrooke), on behalf of Cork Harbour Environmental Protection Association (CHEPA), both of which were packed, and with the overwhelming consensus of both meetings that this development was a bad thing, and severely detrimental to those of us who live in the harbour.  The only voice in favour of this development at either of these meetings came from someone with a vested interest in the shipping industry.  It is interesting to note that not one of the directors of the Port of Cork company lives in the lower harbour, and I believe this is very telling in their attitude to the lower harbour.

There is a very strong movement among the residents of the lower harbour, and a movement which is growing strength apace, against this development.  When the port company first published its proposals for Ringaskiddy, there was very little understanding of the extent of their proposals.  It has been left to those of us with a knowledge of what was at stake, in a voluntary unpaid capacity, to spread the word about what was really at stake.  As soon as people realise what is really at stake for them, they are unanimously opposed to this development.  They have no intention in standing idly by while they see the harbour they know and love being destroyed by land-grabbing greed. 

Cork Harbour is a jewel to be protected and enjoyed by all, and there is a growing army of those of us who will stand and fight to protect our harbour, and we will not allow it to be abused by anyone.  As always in these situations, there is somewhat of a David and Goliath situation at play here, with the port being Goliath and the residents of the harbour being David.  We, the residents, must give generously of our time and money to mount a reasonable defence of our harbour and of our rights and interests.  The Port of Cork is a highly successful and profitable company, and has ample resources available to it to hire the best so-called expertise money can buy.  However what the residents may lack in money and professional expertise, we make up for in passion and commitment.

There are so many compelling arguments as to why this proposal is wrong as outlined above, and the only argument really in its favour is the short-term bottom line of the Port of Cork Company, which should not be the concern of An Bord Pleanála or of the wider public, that I see that the Board has no option but to reject this foolhardy application.  To do otherwise would be, in my opinion, negligent in the extreme.

 Yours faithfully,

 Cllr. Dominick Donnelly, B.A., B.A.I., H.Dip.Ed.

Secretary, Cork East Green Party

Chairperson, CHEPA (Monkstown)

Mayor of Passage West

National Co-ordinator, Green Party / Comhaontas Glas

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May 2023

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