Feedback to the draft Policy Guidance For Fuel Stations
Having fought long and hard for a revision of the 2015 Fuel Service Station Policy, Moviment Graffitti welcomes several proposed changes in the draft Policy published for public consultation. However, we also note a number of points of concern.
Above all, we stress that it has taken the Planning Authority (PA) a ridiculously long time to publish a draft of the revised Policy. Any further delay in implementing the new Policy would be totally unacceptable. Thus, the revised Policy should be approved and implemented after no longer than two weeks after the end of the public consultation period on the 14th June 2019.
Moreover, Moviment Graffitti calls on the PA to suspend all applications for fuel service stations until the proposed Policy comes into effect. There is no sense in proposing a change while allowing applications already submitted to continue being decided according to the old Policy.
Moviment Graffitti is also raising the following specific points:
1. The scope of the Policy is unclear. The background note to the draft Policy states that it will guide the evaluation of “…planning applications related ONLY to the relocation of existing fuel stations…” However, the actual text of the draft Policy states that “A new fuel Station shall be the relocation of an existing fuel station only”, implying that no new fuel stations will be permitted, anywhere.
This ambiguity should be removed so that the Policy clearly states that no new fuel stations are to be approved, anywhere. It is evident that our country does not need more fuel stations, also in view of the planned shift to electric cars.
2. Point 2 of the policy outlines designated sites which will be considered suitable for the relocation of fuel stations. Point 2.g allows such relocations on “…permitted/legally established site ODZ…”
This point should be removed so that no fuel stations are allowed in such areas. Moviment Graffitti stresses that ODZ should remain ODZ, and land already committed should not continue to be degraded, but should be returned to its natural state or used for agriculture. A similar loophole has led to the loss of a lot of ODZ land for residential purposes; the same will happen if the proposed policy goes through as is.
3. Point 2.f allows for an increase in the footprint of already existing ODZ fuel stations for the upgrading of ancillary facilities. This seems to open the door for fuel stations to expand for reasons unrelated to the fuel dispensing function, providing a loophole that can be exploited.
No further take-up of land for ancillary facilities from existing ODZ fuel-stations should be allowed.
4. It is of great concern that point 5 of the Policy states that there shall be no footprint limit for fuel stations on: a) Designated Industrial Areas b) Small and Medium Enterprise Sites c) Areas of Containment d) Open Storage sites and e) areas designated for development in the local plan.
Whilst highlighting the fact that some of the above categories (such as Areas of Containment) are ODZ sites, we also note that allowing an unlimited footprint on such sites will pave the way to massive complexes of commercial services for cars, using the excuse of dispensing fuel to justify the take-up of large parcels of land. Moviment Graffitti maintains that fuel stations should be limited in size, with other commercial activities related to car servicing operating under a commercial policy. The current and proposed policies both allow this abuse.
Thus, all relocated fuel stations should have a reasonable footprint limit which ensures 1) that land will be primarily used for dispensing fuel, not other uses and 2) that the total amount of land taken for fuel stations is not excessive, since this would be taking up space needed for more important uses.
5. The policy sets no minimum distance between fuel stations.
As it makes no sense to have many fuel stations next to each other, a minimum distance should be set.
Together with presenting its feedback to this policy revision, Moviment Graffitti does not exclude carrying out further actions related to the fuel stations policy if the issues highlighted above are not tackled in an adequate manner.