An Taisce’s take on the National Planning Framework
The draft National Planning Framework (NPF) aims to identify the best way to accommodate a million more people in Ireland by 2040, as well as catering for the existing aging population in a world facing increased climate change impact and biodiversity loss.
The time for people to make submission has past but shortly after publication there have been endless newspaper reports, mainly in regional newspapers, of local politicians who are highly critical of the essential theme of the plan.
The central proposition of the plan is that the country cannot afford to pay for the necessary physical and social infrastructure for modern society everywhere. Choices have to be made and the facts tell us that it is most efficient to service compact settlements above a certain size of around 10,000 inhabitants and primarily in 5 cities. Smaller settlements should not grow by more than around 15% in the next 20 years – a figure not so different from the original intention of the previous National Spatial Strategy that was never implemented.
In contrast to this outpouring of disdain, An Taisce strongly supports these principles, which we have promoted in many previous submissions. Scattering people thinly cross the country brings with it many problems:
- social isolation
- the difficulty in finding sites for critical infrastructure and renewable energy projects that don’t fit well close to where people live
- it is a lost opportunity to develop strong villages and towns which can provide the range of amenities that we all seem to seek these days as well as a critical mass of population that modern businesses, both local and international, need to thrive.
We only need to see many small towns failing and main streets half closed to recognize that they lack the population within easy reach that they need to survive.
Rather than being a ‘crazy attack’ on rural Ireland as portrayed in the local press, this is rural Ireland’s only hope for survival. The draft NPF endorses the measures set out in the Action Plan for Rural Development. This provides a well-considered and appropriate focus on strengthening rural towns and villages which An Taisce fully endorses. Indeed, An Taisce has been a long-standing, but ignored, advocate for our rural towns and villages as linchpins for the rural economy and society.
The decline that has occurred in many Irish towns has been caused in part by the building of one off houses in the open countryside, which has been seen as a cost effective option for people. However, dispersed housing externalises very significant hidden costs to society at large. If the true costs were accounted for, settlement in isolated locations would be generally unaffordable for households. An Taisce supports the proposals that seek to improve the alternatives for house buyers, for example by providing serviced sites in the villages and other land reforms.
An Taisce supports the integration of the National Investment Plan with the NPF plan to ensure that communities are not encouraged to grow by zoning land for housing and employment without the necessary funding to fully support their needs. This happened in the past couple of decades when we nearly doubled our housing stock and has led to more and more people needing to commute to work and amenities absorbing precious personal time for home and family, producing congestion, air pollution and carbon emissions. (even electric cars won’t remedy all that!)
There are many objectives that An Taisce support throughout the draft plan, which is clearly informed by contemporary thinking on urban and rural design. This mainly stems from the need to create walkable communities with access to work and living. This facilitates a healthy lifestyle, reducing obesity and good physical and mental well being; it reduces the reliance on private motor transport and facilitates the option of public transport. The policy objective of building on brownfield sites, even public purchase of underused sites, is surely obvious to stop the sprawl.
But…and there’s always a ‘but’, that is not to say that An Taisce is happy with the plan. The chief concern is that it will not work. The primary goals are incomplete (not even mentioning the Sustainable Development Goals ). Apart from the population, regional distribution and urban location targets, only a small number of the remaining objectives contain specific targets and there are no mitigation measures to deal with negative impacts of the proposals. In particular it will not produce a country that can function within the planetary boundaries that must constrain growth to the resources available. Neither will it prevent seriously damaging the mainstay of our economy and society - that is a healthy environment, full of biodiversity, clean air and water. Nor will lead to the required reduction of carbon emissions that will ultimately be our downfall if not STOPPED.
“Realising our Sustainable Future” sets out nine National Policy objectives embracing the circular and bio-economy, sprawl, carbon footprint, renewable energy and green infrastructure in the preparation of land use plans. None of these objectives contain any specific percentage-based or timetabled targets. All are phrased as vague general objectives to “support” “promote” or “improve”, or in the case of climate to “reduce our carbon footprint”.
An Taisce’s submission  goes through all the key goals and objectives pointing out the inconsistencies with current government policy and proposing policies and planning measures for the creation of alternative kinds of places.
A recurring theme in An Taisce’s submission is the need to create walkable communities and so no new housing development should be allowed if it is greater than 15- minute walking distance from basic services and infrastructure e.g. public transport, supermarket, childcare facilities, school, post offices, etc. The corollary to this is the need to adopt national targets for the major percentage of new housing and employment locations to be located with walkable access to public transport and safe cycling and walking routes.
All new buildings must be either ‘energy positive’ or ‘Zero Energy’; but even more importantly, a rapid programme of deep retrofit (to near zero energy) of the existing national building stock must be activated without delay.
Naturally An Taisce is also concerned that the draft NPF contains no national policy objectives in relation to our cultural heritage, including architectural and archaeological heritage, and landscape. Historic Urban Centres are an irreplaceably social and cultural focus of identity and economic resources, which should not be compromised by high rise or other inappropriate development. High density is not synonymous with high rise.
An Taisce’s prescribed status also includes a special brief to review and comment on planning applications that may impact on the natural environment, that is areas that are designated as special protection areas for their value in safeguarding biodiversity etc. Biodiversity and natural heritage are not given the status of any specific National Policy Objective or National Strategic Outcome measure in the Draft NPF. This is a major omission and An Taisce calls for it to be redressed.
Similarly current agricultural practices are known to be a major source of water pollution. Yet the current annual cattle herd increase of 6% per annum is being accommodated by the planning system in granting permission for additional animal housing and poor enforcement control of wetland drainage. The overlapping impact of slurry and fertilizer run-off is affecting water quality. The conflict between the provisions for “Ongoing Support through a well-funded Common Agricultural Policy for the Agri flood sector” and meeting climate and biodiversity targets as well as food security is not addressed. 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.
Inevitably there is still much to be done to ensure we reduce our reliance on private motor transport if we are to make any headway in reducing our carbon emissions but this plan isn’t going to be the driver of that outcome! There is no target of reducing per capita car ownership or use, or increase in modal share of interregional passenger /bus use, or rail freight. Without targets the fine words can come to nothing and indeed there are worrying objectives regarding ‘connectivity’ and the indication that this will mean new roads. An Taisce’s proposals are different. All further road investment must be limited to locations where urban and village bypassing and enhanced safety provision is required and the interregional rail network should be maximized in capacity for passenger and freight use, including travel speed enhancement.
Perhaps more controversial is An Taisce’s claim that airport capacity targets must be revised in accordance with climate emissions capacity limits whilst initiating Ireland-UK co-operation of development of low carbon sail/rail connectivity capacity and maximizing the potential of rail freight connectivity to ports, including reopening of Foynes Limerick freight rail line. Controversial perhaps but sooner rather than later we will have reduce the amount of flying, particularly of frequent fliers who make up the bulk of demand, if we are to live within the planets capacity to provide the resources needed and to reduce the damage we are doing to the climate.
Finally we quote in brief directly from An Taisce’s submission:
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:
- 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.
- Localisation: 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.
- Pragmatism: 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
- 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.
- 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.
- 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.
For a plan to be something we intend to do, it requires clearly stated, implementable and legally enforceable targets to meet these objectives with commensurate mitigation targets. If the draft NPF does not proceed on this basis, it could be exposed to legal action at national and EU level.
 UN Sustainable Development Goals http://www.undp.org/content/undp/en/home/sustainable-development-goals.html
 An Taisce’s submission to the draft National Planning Framework http://www.antaisce.org/sites/antaisce.org/files/20171011-npf.pdf
About An Taisce
An Taisce is a charity that works to preserve and protect Ireland's natural and built heritage. We are an independent charitable voice for the environment and for heritage issues. We are not a government body, semi-state or agency. Founded in 1948, we are one of Ireland’s oldest and largest environmental organisations.