How does the National Planning Framework & National Development Plan 2018-2027 measure up?
Ireland is badly missing its EU climate action targets, and will face increasing exposure and cost from storm and flood impact. Decades of bad planning have left a legacy of car based dispersed sprawl, with climate, air pollution, congestion and other adverse social, economic environmental impacts.
The previous attempt at national strategic planning the 2002 National Spatial Strategy designated too many regional growth centres as gateways and hubs, and failed to control one off rural housing dispersal.
How then Does the National Planning Framework (NPF) and National Development Plan 2018 - 2027 (NDP) measure up?
What is to be welcomed?
The published National Planning Framework opens with a reiteration and incorporation of the UN Sustainable Development Goals (SDGs 2015). The National Planning Framework NPF affirms ”a major new policy emphasis on renewing and developing existing settlements”
The 10 “Strategic Outcomes” set out in the 2016 draft have been amended to give a new provision for a “Transition to a Low Carbon and Climate Resilient Society" and to the protection of “Amenity and Heritage”, resolving some of the deficiencies in consideration of heritage in the 2016 Draft.
What is to be questioned?
Rural development and housing
The NPF provides extensive and welcome policies on strengthening the status of rural towns and villages, and the importance of villages as rural service bases, With emphasis on “Compact Growth” and a fight against sprawl.
This is undermined by a general “National Policy Objective 19” to accommodate one off housing in rural areas base only on design and siting consideration and vague provision of “having regard to the viability of smaller town and rural settlements”. Only in a “rural area under urban influence" is consideration of “demonstrable social and economic need“ the insertion of “social” occurring since the Draft.
These new provisions seriously undermine rural village and town objectives of the NPF.
This is despite the NPF stating "..... in some locations, almost all recent single housing in the countryside has been developed privately, with social housing provided largely in settlements. In many parts of rural Ireland, where a significant majority of housing output is in the countryside, this has contributed to spatial and social imbalance and the decline in population of smaller settlements. As a result, many key services have closed, in part due to population decline, leaving more marginalised and vulnerable citizens without access to those services."
Implementation and unresolved role and effectiveness of Planning Regulator.
The implementation of the NPF is predicated on the establishment of the Planning Regulator, the legislation for which remains at Bill stage in the Oireachtas. Unless effective regulation achieved and public transport and cycling investment is provide to achieve sustainable settlement and mobility Ireland sprawl will continue and worsen.
The NDP provides a 7.6 billion exchequer allocation with an additional 14.2 billion from the private and semi state sector under Climate.
The plan does not quantify the level of emission reductions which would be achieved by the level of investment proposed, including the housing retrofitting targets 30,000 to 45,000 per annum from 2021. However, we welcome the increase in housing retrofitting but it needs to be closer to 100,000 per annum.
Ireland needs clear timetabled targets for advancing decarbonisation, to achieve the scale and impact needed in energy efficiency, building retro fitting and alternative renewable energy provision. Climate action is undermined by:
- the uncritical endorsement by the NPF of the industry led Foodwise 2025 strategy which is increasing dairy and beef production emissions.
- the overwhelming focus of transport investment outside Dublin on Motorway and road building
- the proposed 320 million funding by the NDP of the additional Dublin Airport runway which does not address the increased impact of aviation emissions, for which there is no current mitigation.
There is a provision of 940 million for flood protection, but no consideration of the level of threat and cost from Ireland’s future exposure to increasing storm and flood impact, including on critical infrastructure.
The NPF seeks to promote more compact development with sustainable transport, but no targets are set out for any shifting of the current level of car journeys to public transport and cycling. The 2020 sustainable transport targets in 2009 the Department of Transport Smarter Travel policy are ignored.
There are no public transport investment proposals of any significance outside Dublin, with bus investment measures proposed for Cork and Galway only. Most of the public transport measure projected for Dublin are for after 2027 beyond the life of the NPF. There is no strategy for the maintenance and enhanced use of the national rail network both for passengers and freight. The NDP funding allocation for rail is only for maintenance and safety to maintain in a “steady state”.
The NDP provisions for Enhance Regional Accessibility are unsustainable road investment based including reactivation of the A5 cross border proposal and 3 significant road projects:
- 850-900 million euro Cork Limerick Motorway which will increase car based sprawl patterns of development and travel. This disregards the concerns set out in the draft NPF (page 123) and omitted in the todays publication that :” Investment in connectivity first without urban consolidation measures will likely worsen the current trends towards sprawl”
- 550- 600 million Galway Ring Road which will not solve the city’s unsustainable car dependence and congestion.
- The provision of extra lanes on the M7 from Nass to Newbridge which will increase congestion on the already overcrowded M50
For further information, contact:
Ian Lumley, An Taisce Advocacy Officer: +353 1 454 1786
Charles Stanley-Smith, Communications, An Taisce. Tel: +353 87 241 1995
An Taisce The National Trust for Ireland
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.