I was invited to speak at the IPI’s conference last week. The rough notes for my speech are below and the powerpoint I used is here.
A councillor’s perspective on the plan-making process
Contents (slide 2)
- Community organisations and “Nimbys”
- Transport objections to housing; the importance of public transport and design for walking and cycling as well as density
- Aspects of the Regional Spatial and Economic Strategy including
- riparian setbacks,
- climate assessment and
- the conflict between the Regional Assembly and the Minister for Housing and Planning over additional rail infrastructure
Community organisations and “Nimbys”
I’ll give a Councillor’s perspective; but I would also like to mention the perspectives of community organisations and environmental organisations.
Remember the organisations which resisted the road building plans in Dublin for decades, such as the Living City Group in Dublin, who eventually prevented the worst of Dublin Corporations’ road plans. (Slide 3, Slide 4)
I’m thinking of the community organisations in a whole ring all around Dublin who exposed the corruption in the planning system in the 1990s. Indeed some of the worst affected areas were active and successful as early as 1991, when Liam Lawlor lost his Council seat. In my area the Baldoyle Community Association defeated Frank Dunlop’s speculative rezoning in 1993 and has kept active in subsequent decades, making important contributions especially to the Local Area Plan for the new development at Stapolin, enriching the planning system with their local knowledge, all on an entirely voluntary basis.
And I have to mention the vital role of journalists, especially investigative journalists, in cleaning up planning in the 1990s. (Slide 5)
The Special Amenity Area Order which has protected Howth for the last two decades is due to the work of local volunteers in Howth Sutton 2000 who convinced Environment Minister Brendan Howlin to require the Council to initiate the SAAO process. (Slide 6)
So it can be difficult to read criticism by planners of community organisations and politicians as being nimbys, reported by contemporary journalists.
Transport Objections to Housing
It’s not that that criticism is always incorrect. We do have difficulties with people who don’t want development near them, and I disagree strongly with some of my own constituents who think that because we have too much traffic in the area we shouldn’t have more houses. I explain that in an area with a rail service An Bord Pleanála will not refuse permission for housing simply because there’s too much traffic. And I emphasise that I think An Bord Pleanála is absolutely right when they take these decisions.
But we’ve experienced decades in which planning was about providing houses for people to drive to and from. So we shouldn’t be surprised that people now stuck in traffic are complaining that the system we’ve put together doesn’t work.
So I support more dense developments near railway stations, and I have 7 railway stations in my constituency. But I do want to put a caveat on the analysis that density is the key ingredient for sustainable transport. Newman and Kenworthy in their famous research Cities and Automobile Dependence made a very strong case. (The case for density’s importance to walking and cycling is equally strong and probably more obvious.) (Slide 7)
But that message about density being the key to public transport has been overblown. Density is not everything. A more important determining factor also, and in fact it’s obvious, is about the quality of service provided the public transport system, especially about public transport operating as an integrated network. Another Australian Paul Mees set this out very clearly in his book Transport for Suburbia. (Slide 8)
Now, we’re very fortunate that the NTA has set about redesigning Dublin’s bus network in their Bus Connects plan, with Jarrett Walker of Human Transit. The plan isn’t doing enough to integrate bus with heavy and light rail, which would includes pulse timetabling on the lower frequency routes – but I’m hopeful that these elements will be fixed. (Slide 9)
Recognising that public transport is not all about density, what about walking and cycling?
We’ve now got all the text in our Development Plans and Local Area Plans, in the Design Manual for Urban Roads and Streets, the National Cycle Manual, saying priority to walking and cycling. But on the ground, we’re giving permission for schools without planning the walking and cycling access. We’re giving planning permission for housing developments with cycling facilities which in design terms are nonsense, in breach of DMURS and the NCM, again and again. (Slide 10)
We’ve a new housing area only a few miles from here, one mile as the crow flies from a train station. The road to the station is a narrow country road with no footpath. The Councillors have insisted on a greenway link to the station in the Local Area Plan, but the question is where will the funding come from. (Slides 11, 12)
What has this to do with criticism of “nimbys” and of politicians agreeing with them? It’s that some of the fears of ‘nimbys’ are justified. People are living in places where they can’t get to where they need to by public transport or it’s not safe for them to get around by foot or bicycle. And naturally they see more houses with other people in the same condition as making that worse.
Of course, providing walkable, cyclable environments and good public transport is the solution, not refusing to provide more houses until that happens.
And it’s other community groups who for decades have been driving the sustainable solutions. People who campaigned for light rail when they were told it was ridiculous. In more recent years, the Dublin Cycling Campaign, and other cycling campaigns around the country, pedestrians’ groups, disability advocates.
I was set to thinking of all this this week as I read the deeply researched 50 page submission by the volunteers of Clongriffin Community Association on the SHD applications in their community. And I’ll admit I was annoyed. The City Development Plan and the Local Area Plan are very clear. Clongriffin is to be a high density mixed use area; think about the North or South Lotts areas, maybe Sandyford or Cherrywood based on a railway station, with people living and working locally, and people travelling in for work as well as travelling out for work. Despite this the applications are effectively for only residential use, with a few ancillary retail units. One other development is due with about 40% non-residential. Overall, the mixed use goal is abandoned. How can this clear breach of the City Development Plan get through pre-application consultations in the SHD system?
The current situation in Clongriffin is worrying. 82% of the retail units are empty. Why? Because there’s very little local employment, everyone leaves during the day, and the custom simply isn’t there. (Slide 13)
That table is from a study commissioned by Dublin City Council in 2018 “Economic and Retail Study Belmayne and Clongriffin”. And of course it’s the voluntary Community Association who have put it before the Board.
If you prefer fantasy you can read the planning application:
“The combination of walkable streets and a pedestrian and cycle focussed streetscape has resulted in a thriving economy of small businesses.” (Slide 14)
So just a plea to recognise that community organisations are doing amazing work and that many of them, especially the ones in areas suffering from our boom bust system are certainly not Nimbys.
Regional Spatial and Economic Strategy
I want to move on more specifically to the planmaking process, with my hat as a member of the Eastern and Midland Regional Assembly, which has just made the Regional Spatial and Economic Strategy.
We made important changes to the Strategy after it went on public display and I’d like to mention three of them. One about setbacks from water courses, one about climate assessment, and one about public transport.
REGIONAL POLICY OBJECTIVE: Riparian setbacks RPO 7.26 Support the development of guidance for assessment of proposed land zonings in order to achieve appropriate riparian setback distances that support the attainment of high ecological status for waterbodies, the conservation of biodiversity and good ecosystem health, and buffer zones from flood plains. (Slide 15)
There was a bit of doubt about this when it was first proposed, but the Assembly generally recognised that it was worth pushing in this area, particularly with the requirements of the Weser case as regards compliance with the Water Framework Directive in mind.
Quantitiative assessment of climate impacts
In relation to climate, we had an interesting process. Right from the start, as members we asked for the Strategy to be assessed for its climate impacts. We thought this was a requirement of the Strategic Environmental Assessment (SEA) Directive as well as of the Climate Action and Low Carbon Development Act. The planners and Director of the Assembly took this to the consultants who were doing the SEA.
Now it seems obvious to me that the way it is done hadn’t gotten us very far in reducing emissions. And my interpretation of the legal obligation under the SEA Directive is that if it looks practical to do a quantitative assessment then you should try to do.
And we know that at least for the transport emissions resulting from the combination of population employment patterns together with transport infrastructure, there is already a model, run by the NTA which will give emissions results. (Slide 16)
We also know, and the NTA recognises this openly, that their model doesn’t have a way to represent improvements to conditions for walking and cycling. At least for cycling there is a model, which has been applied in England and Wales which could be applied here – the Propensity to Cycle Tool. (Slide 17)
Plus in the Eastern and Midland Region there’s another vast land use with enormous greenhouse gas emissions – degraded peatlands. There are scientists, in UCD, TCD, and independent who could advise on the climate impact of policies to reduce emissions from peatlands. (Slide 18)
So it seemed to us that there was real work that the consultants could do, and the Assembly’s planners put this to them. There was back and forth for some time, and eventually we asked for them to attend at a meeting of the Assembly. They made it clear that they weren’t willing to do it and that they considered that the sort of vague analysis they are used to where they put ticks down to indicate slight negative, slight positive, strongly positive, was “the way it is done”.
We remained convinced that it can be done and should be done, though we had failed to do it ourselves. So we put it in the draft that it should be done in City and County Development Plans. This is quite a step from the SEA consultants’ formulaic assessment, so we got a bit of push back. Eventually what is in the Strategy is the following:
RPO 3.6: City and county development plans shall undergo assessment of their impact on carbon reduction targets and shall include measures to monitor and review progress towards carbon reduction targets. (Slide 19)
It’s a bit constrained by the accompanying text:
Guidelines, prepared by The Department of Housing, Planning and Local Government (DHPLG), will provide clarification around the development of a suitable methodology for measuring carbon emissions… (Slide 20
but we do believe the Department is serious about this and our officials are looking forward to working with them on this.
In the meantime however, the Assembly has put together a project together with Scottish Government, the Northern Ireland Planning Directorate and the Regional Council of Kymenlaakso in Finland for funding through ESPON, an EU institution supporting territorial research. It’s entitled
Quantitative Greenhouse Gas Impact Assessment Method for Spatial Planning Policy. (Slide 21)
Hopefully this will be a major determinant of development plans from now on.
The conflict between the Regional Assembly and the Minister for Housing and Planning over rail infrastructure
Finally we made amendments as regards public transport.
The first draft of the RSES basically took the public transport infrastructure in the Greater Dublin Area Transport Strategy 2016-2035, which was more or less copied into the National Development Plan.
But when it came back from display, we started to consider the climate implications of that Transport Strategy. The predictions from the NTA themselves are for a 30% increase in greenhouse gas emissions from transport in the region over the 20 years of the Strategy. We thought that this wasn’t in keeping with our obligations to work towards the National Transition Objective. (Slide 22)
And we weren’t clear how to interpret the legislative provisions which require the Assembly to make a Strategy consistent with the NTA’s Transport Strategy, but at the same time require the NTA to make a Strategy consistent with the Regional Assembly’s Regional Spatial and Economic Strategy.
Does this really mean we can’t change our strategies? We think a more practical interpretation is that we can go further in our strategy as long as it goes in the same direction, so we can go further in the NTA’s stated goal of achieving a shift from cars to active and public transport.
So we considered the public transport options and decided that the NTA strategy is seriously inadequate, as it has dropped proposals which were in train 15 years ago. We’re facing a central government which seems incapable of understanding the importance of rail and entirely unwilling to invest in it. So we added a number of rail infrastructure proposals back in, and we kept them in after they went on public display.
The result is that the Minister has now produced a draft direction, which went on public display for two weeks in August and nonetheless generated 131 responses, 130 of which supported our greater ambition for rail transport in the Region.
We’ve written back to the Minister, in what we think is a conciliatory manner, amending a number of our proposals to be more exploratory but still ambitious, and keeping as a firm objective the reopening of the Navan railway line, included in the capital programming in Transport 21 in 2005, and explicitly postponed not cancelled in the words of then transport Minister Varadkar in 2011.
We’ve reminded the Minister that he, like us, is legally bound to pursue an objective of transition to a low carbon economy. And we’ve asked the Minister if he’ll meet with us to discuss it. Indications so far are that he won’t, which is a pity.