Submission to Draft National Planning Framework 10/11/2017

10th November 2017
Submission Summary

The substance of An Taisce’s submission is to climate proof the 4 over-riding goals, the 70 objectives, the 10 points of strategic infrastructure and 8 listed visions, pointing to the inconsistencies and the dangerous impact some of the policies will have on increasing rather than reducing greenhouse gas emissions, on damaging biodiversity and on being wasteful of scarce resources.

The challenges of climate change cannot be addressed through technology alone, but require thoroughgoing societal change and the implementation of robust, proactive planning measures for the creation of alternative kinds of places. As a strategy which aims to shape Ireland well into the 21st Century, it is essential, therefore, that the entire worldview sustaining the Draft NPF vision be critically re-thought, along the lines of the following key principles:

  1. Equity: Rather than the promotion of economic growth as the primary aim and aspiration of Ireland 2040, An Taisce argues for the creation of a better society through a planning and land system that spreads public goods to meet societal needs and works in the long-term public interest to secure wider social well-being over the next generations. People have a right to live in places that provide them with opportunities to live a good life, individually and collectively, provided this is done within the limits of justice, intergenerational equity and environmental sustainability (e.g. that our pursuit of the good life does not prevent others, or future generations, from living well).
  2. Localisation: In order to achieve a national commitment to equivalent living conditions, a core NPF objective should be that no new housing development shall be permissible which is greater than 15-minute walking distance from basic services and infrastructure e.g. public transport, supermarket, childcare facilities, school, post offices, etc. Regional and local plans should be charged with determining such services and locations, and where there is a deficit, they must be upgraded in tandem with housing development. This simple principle, rigorously enforced, is possible and would go furthest in achieving the objectives of smart, compact growth espoused in the Draft NPF and in regenerating our rural towns and villages.
  3. Pragmatism: Imagining the future is one thing, but to achieve it we need to be honest and correctly diagnose where we are now. Successive national spatial strategies have sought to achieve balanced regional development and compact settlement patterns. These have all failed and there is simply no evidence that the current political culture and structure with its pre-eminent focus on the parochial and local has the capacity to achieve regional parity in population growth. We must be pragmatic and realise that our current settlement patterns are ‘locked in’ and represent ‘facts on the ground’. Instead of redirecting scarce resources towards achieving implausible regional population targets, the focus of the Draft NPF should therefore be the adaptation task and retrofitting our inherited and widely dispersed settlement structures to make them more resilient and adaptive for the stresses and challenges that lie ahead with climate change and resource depletion.
  4. Land Reform: In the absence of a firm political commitment to national planning, the market produces the places in which we live, in ways which meet a concern for individualism and profit rather than the needs of society. Land reform is therefore essential to give the public and communities a stake in development and future value. To acquire land to meet public need, Land Value Tax, CPOs and other powers must be used as levers to transfer ownership from private landowners and developers who will not build, to communities, local authorities and other accountable bodies who will. Extending democratic and community ownership of land whether by leasehold, trust ownership, or outright purchase is crucial to economic revival, to the effective delivery of house building and community regeneration. Taking a public stake in land is not a cost but an essential long-term infrastructure investment.
  5. Decarbonising Infrastructure: The Draft NPF is replete with contradictory objectives which, on the one hand, advocate the decarbonisation of society but, on the other hand, promote the development of airports, motorways, data centres etc., which are carbon and energy intensive infrastructures. As current national policy has effectively precluded any contribution from agriculture in future emission reduction efforts, it is absolutely essential that all future investment in transport infrastructure is redirected exclusively to public transport.
  6. A New Rurality: The current policy approach to Ireland’s rural areas is productivism, either in large-scale agri-business or suburbanised housing. Ireland’s low population density and rural areas can be our most precious resource for a post-carbon world in terms of sustainable local food production, native forestry, and decentralised energy generation through, for example, small-scale wind, hydro, biomass, geothermal, combined heat and power, and solar. If planned correctly, this opportunity could be a significant boon for rural communities, help increase their resilience and buffer them from the vulnerabilities of global uncertainty and energy price inflation. However, in order to achieve this, the Draft NPF must advocate a decisive shift away from current polluting and carbon-intensive agriculture and settlement patterns towards a new relocalised vision for rural Ireland focused on our historic network of rural towns and villages.