October-November 2024 57
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Junction t the edge of Rthnew, Wicklow 2019
NonPerFormance
Ireland’s revised National Planning
Framework lacks the teeth to curtail
unsustainable, sprawl-driven, car-dependent
development and fails adequately to consider
climate consequences
T
his is a synopsis of An Taisce’s
recent critique of the revised
National Planning Framework (NPF )
which is the overarching strategy
for the social, economic and cultural
development of Ireland. Despite little debate
the NPF will be finalised in October.
1. Climate Obligations and
Implementation Challenges
While the revised NPF is better on climate than
the 2018 version, it still falls far short on our
pressing climate obligations. The framework
lacks the ambition needed to meet legally
binding carbon-reduction requirements and
does not reconcile high-emission
infrastructure projects, such as airports and
motorways, with these obligations.
Ireland is legally bound by carbon budgets
under national legislation as well as by EU
targets. Given that we are likely to exceed
these budgets, immediate adjustments are
needed. The revised NPF fails to align its
objectives with the carbon budgets.
2. Rethinking Growth and
Doughnut Economics
The premise of the NPF remains rooted in
economic growth, which is increasingly
untenable given the global environmental
challenges. An Taisce advocates for the
integration of the Doughnut Economics
framework by Kate Raworth, which balances
societal needs (housing, energy, education)
with ecological boundaries (biodiversity,
water quality, and air). The NPF should set out
the framework for a planning and land use
system that provides public goods to meet
societal needs and works in the long-term
public interest to secure wider social and
environmental wellbeing. People have a right
to live in places that provide them with
opportunities to live a good life, individually
and collectively, while remaining within the
limits of justice, intergenerational equity and
environmental sustainability.
3. Public Participation
Public consultation for the revised NPF was
conducted during a summer holiday period,
limiting effective engagement.
4. Biodiversity
The 2019 report on The Status of EU
Protected Habitats and Species in Ireland
(prepared every six years as required by
Article 17 of the EU Habitats Directive)
illustrates the poor condition of Ireland’s
biodiversity. Out of Ireland’s 59 European
protected habitats, 85% were assessed as
being in unfavourable conservation status
and 46% suffering from ongoing declines.
This situation has remained largely
unchanged since Ireland’s initial assessment
in 2007. Bird declines are accelerating, and
monitoring of wintering waterbirds by
BirdWatch Ireland have found that numbers
have declined by almost 40% since the mid-
1990s. Insect species, including crucial
pollinators, are also facing similar declines.
In light of that, we consider it to be a major
omission that there is still no National
Strategic Objective on biodiversity protection
and nature restoration in the Draft Revised
NPF. While some of the themes of the ten
NSOs are related to biodiversity, we consider
that the scale of the biodiversity crises and
the extent to which the state of our biodiversity
is influenced by planning warrants it a
standalone NSO on protecting biodiversity
and restoring nature.
5. Sustainable Settlements
and Transport
The development pattern of low-density
suburban sprawl is unsustainable, locking
Ireland into car dependency and inefficient
land use. Compact growth and higher-density
urban development, combined with robust
public transport infrastructure, must be
central to the NPF’s vision. An Taisce proposes
that all new residential developments be
within a 15-minute walking distance from
essential services, fostering sustainable and
liveable communities.
Compact Settlements
The gap between compact settlement policies
and their actual implementation is a critical
flaw. Without stricter enforcement,
unsustainable, car-dependent sprawl will
persist.
The NPF acknowledges that low-density
sprawl has characterised much of Irelands
recent development and is unsustainable. The
NPF must prioritise better-designed,
ENVIRONMENT
By Phoebe Duvall
VillageOctNov24.indb 57 03/10/2024 14:27
58 October-November 2024
carbon sink. Monoculture plantations,
particularly of non-native species like Sitka
spruce, should be limited in favour of
continuous cover forestry that prioritises
native species.
10. Tourism
Tourism development must move away from
car-centric models. A focus on sustainable,
long-stay tourism that integrates well with
public transport and active travel is essential
for reducing the environmental impact of
tourism.
11. Housing and Climate
There is little consideration of the carbon
footprint associated with large-scale housing
construction. Low-carbon building materials,
reuse of existing structures, and more
sustainable construction methods must be
prioritised to meet both housing and climate
goals.
12. Implementation,
Monitoring and SEA
A recurring issue throughout the NPF is the
lack of clear, measurable targets. The NPF
must go beyond vague objectives and
establish rigorous, legally-binding
implementation mechanisms. This includes
effective and ongoing monitoring via the
Strategic Environmental Assessment (SEA)
process to ensure that the NPF’s policies
translate into action.
We consider that the SEA Environmental
Report should be updated with more clearly
identified and timetabled and targeted
mitigation measures, effective monitoring
proposals in all areas, and a legal
implementation regime to take remedial
action where adverse effects are identified
through monitoring.
It is acknowledged and welcomed that
the draft monitoring programme proposed
in the SEA Environmental Report is more
detailed than the programme in the 2018
NPF SEA but it must be expanded further
and carried out.
Crucially, we also note that the SEA does
not contain analysis of the carbon emissions
associated with the Draft Revised NPF.
There is no assessment of these against the
legal requirements of the national carbon
budgets and sectoral emissions ceilings.
We consider that this analysis should
underpin the entire NPF and should be
provided before the SEA and Revised NPF
are finalised.
Phoebe Duvall is An Taisce’s Planning and
Environmental Policy Officer
higher-density urban areas with active and
public transport connectivity to services,
employment, and amenities.
Successive national spatial strategies have
aimed for balanced regional development and
compact settlements. Yet, much development
remains uncoordinated, with leapfrog, low-
density land use, which diminishes liveability,
lacks adequate public facilities and
infrastructure, and fosters car dependency for
long commutes.
An example from Rathnew, County Wicklow,
illustrates the continued approval of car-
based edge-of-town developments, despite
national and local policies supporting
compact, walkable, and cyclable places.
An Taisce recommends amending the Draft
Revised NPF to incorporate and enhance the
seven-location test standards for new housing
in urban areas outlined in the National Spatial
Strategy 2002. These standards require
planning authority decisions to consider
integration with existing communities,
housing affordability, access to local services
and schools, and transport links to
employment and recreation facilities.
One-ohousing
With regard to the consideration of one-o
housing in the countryside, we consider that
the Draft Revised NPF has not improved on the
2018 NPF and will not be able to curtail further
unsustainable spread of one-odwellings.
There are no caps placed on the number or
proportion of houses that can be
accommodated in the open countryside or
policies to prevent further unsustainable
ribbon development patterns. The Draft
Revised NPF continues the existing policy:
“In rural areas under urban influence,
facilitate the provision of single housing in
the countryside based on the core
consideration of demonstrable economic or
social need to live in a rural area and
siting and design criteria for rural housing
in statutory guidelines and plans, having
regard to the viability of smaller towns and
rural settlements;
In rural areas elsewhere, facilitate the
provision of single housing in the
countryside based on siting and design
criteria for rural housing in statutory
guidelines and plans, having regard to
the viability of smaller towns and rural
settlements”.
This does not set any targets to curtail
further one-off housing spread. This,
combined with the weak targets for directing
new development to built-up areas,
undermines the overall sustainable
settlement strategy, undermines the service
basis of smaller towns and villages,
exacerbates traffic generation and car
dependence, and undermines the needed
modal shift to sustainable travel.
6. Linking Land Use and
Transport
New residential developments often fail to
link effectively with existing public transport
and active travel infrastructure. While internal
foot and cycle paths may be provided, these
often terminate at the boundary of the
development, leaving residents reliant on
cars for daily transport. A stronger focus on
Transport-Oriented Development (TOD) is
necessary, ensuring active travel links and
proper bicycle facilities at key transport hubs.
Residential schemes often include strong
walking and cycling permeability within the
boundary of the site itself, but they are
frequently located on the fringes of cities and
towns at a significant remove from existing
transport links or services (grocery stores,
health facilities, etc.). They also often lack
permeability with surrounding areas and are
often sited in areas with very limited existing
public transport routes and capacity or
pedestrian and cycling infrastructure.
Therefore, although a new residential
development may provide high quality foot
and cycle permeability around the dwellings,
these often terminate or become disconnected
immediately outside the site boundary.
7. Built Heritage
The Draft Revised NPF more generally would
benefit from more detail on how heritage
protection will be achieved via planning.
There remains an ongoing issue of the
endangerment of our heritage buildings and
Protected Structures. Cases are consistently
arising across the country where Protected
Structures and buildings in Architectural
Conservation Areas are suffering
abandonment; maintenance neglect; loss of
major architectural features; and exposure to
theft, vandalism, and arson. The NPF should
include consideration of this alongside its
consideration of adaptive reuse. This should
include an objective for improved monitoring
of buildings at risk of endangerment.
8. Agriculture
The agricultural system in Ireland is currently
unsustainable. The NPF must support a
transition to a more environmentally-friendly
model that aligns with climate and water
quality goals. Policies promoting intensive
agricultural practices are not compatible with
the climate action plan, and more focus
should be placed on supporting farmers in
sustainable, local food production.
9. Forest Management
Forests can be key to climate mitigation, but
afforested lands in Ireland are in fact
becoming a carbon source rather than a
VillageOctNov24.indb 58 03/10/2024 14:27

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