“Ireland 2040 – Our Plan”, better known to most as the draft National Planning Framework, was published by the government in September this year, its purpose to set out a road map for future planning and development across the country for a generation to come.
As early as the first paragraph, An Taoiseach Leo Varadkar exhorts “every citizen, every community, every organisation” to be aware of and engaged with it. That may not quite be the outcome as the (extended) call for public submissions on it closes this Friday, 10 November.
But now is the time to have a say in what might, just might, be a critical document for Dublin’s future.
Planning can have a big impact if we get the policies right and implement them.
The Urban Renewal Acts of the 1990s brought 45,000 people back to live in the blighted inner city of Dublin. The Temple Bar and Docklands Acts kick-started urban regeneration in places far too easily taken for granted. DIT Grangegorman and its surrounding communities are being profoundly transformed by a strategic plan, which is being implemented by a committed planning and design team.
So is the National Planning Framework (or NPF for short) a false dawn or a brave new day? Will it join the dusty book piles in planning libraries or might it mean something for Dublin and the lives of Dubliners?
Where the NPF really differs from what has gone before is a real focus on Ireland’s five main urban centres. All the economic evidence says, perhaps counter-intuitively to many, that this will also benefit those remoter towns and rural areas which, with justification, feel the most left out of Ireland’s second economic boom in modern times (this one uniquely without houses). Regions are dynamic, spatially linked economies and without strong centres they will certainly perish.
Absolutely central to this is a brand-new innovation in Irish planning: the use of the term “city & suburbs”. This concept has been spoken about in this column before so it is good to see it as a cornerstone of the proposed new national planning policy.
The term “city and suburbs” refers to the continuous and contiguous built-up urban area. It is, if you like, the “whole city and only the city”. It is a good basis for urban planning because it deals with the city properly as a cohesive unit.
It is a further advantage that the “city and suburb” boundary definition is governed objectively by a very independent agency, the Central Statistics Office. They in turn use the UN principle of the “100-metre rule” to determine where the boundary is drawn.
Fifty percent of development is targeted to take place within the five “city and suburb” boundaries, of Dublin, Cork, Galway, Limerick and Waterford, according to the draft NPF. In the case of Dublin, this is a genuine opportunity for the city and its future.
In spite of Housing Minister Eoghan Murphy’s exasperating contention that development is being held back by overly restrictive planning regulations, Dublin City and Suburbs contains at least 2,700 hectares of zoned, mostly serviced, brownfield development land. Many of these land banks are rail-based and even have advanced urban design plans approved and ready to go.
Including the Docklands area, there is at least enough development land available in Dublin to accommodate 300,000 people, at medium densities using these large sites alone. This is comfortably more than the 265,000 forecast by the draft NPF.
The NPF could provide for this and even go so far as to determine the need for a dedicated multi-disciplinary planning and design team for each, something kernel to the success of places like Grangegorman and Adamstown (before development ground to a halt in the latter).
But there is one significant snag in the works.
To support this compact development, each of the five cities is to have a new kind of plan drawn up: a “Metropolitan Area Strategic Plan”. These plans, whose purpose is to consolidate and coordinate growth in the main urban areas, are to be aligned with the “city and suburb” boundaries.
Except for Dublin’s.
In an unusual slight, Dublin’s metropolitan plan is to cover a far wider area, most of which is rural and which takes in several outlying towns with contrasting settlement and travel patterns to Dublin. This wider boundary area is neither fish nor fowl, and is doomed to failure as a mechanism for compact sustainable planning, if that is its intent.
This anomaly was also pointed out by John O’Hara, acting City Planner in Dublin City Council, in a special sitting of the Planning and Property Development Strategic Policy Committee on the topic of the NPF. It is literally buried in a footnote (footnote 32, if you care) on page 149 of the draft report. Sadly, unless it is dropped, the NPF is likely to be a “nothing” document for Dublin.
There is a wider question, not fully addressed in the draft NPF, as to who would decide and implement such metropolitan plans. This column has already suggested an extension of the Dublin City Council administrative boundary to encapsulate all of Dublin City and Suburbs, to give the lord mayor a five-year term, and have the chief executive officer report to her or him.
It would then be a very simple thing to make the lord mayor responsible for the new Metropolitan Area Strategic Plan, which it is assumed would deal with all aspects of community, culture, parks, transport, and housing. (This could be done, by the way, for any and all of the five main cities.)
But most of all, the focus on cities should be sincere, especially for Dublin. The best way to do this would be to stick to the area defined as Dublin City and Suburbs, and not any other area, for the making of future metropolitan plans.
As to how the public has engaged, what response there has been, has been disappointing to say the least.
A lot of the dialogue appears to be taking place without any apparent reference to what is even in the document. According to Laois county councillors, the framework could be biased against Portlaoise, in favour of Athlone. But neither place is even mentioned in the document.
In a Tipperary municipal district, the plan is said to be all stacked up against them. But there are whole chapters devoted to small towns and rural development, with apparently serious commitments to investment in both.
The NPF has not been without its criticisms from informed sources either. Gavin Daly of ESPON, a European planning research agency, believes there is devil in the detail which will allow continued, uncontrolled sprawl, in turn leading to poorer public health, increased carbon emissions and a more vulnerable economy.
He could well be right about this. The very complexity of the arrangements tells its own story. Daly reckons that provisions for the control of one-off housing are effectively meaningless.
Eamon Ryan TD, leader of the Green Party, for whom the need for a national spatial planning vision has been a long-standing party mantra, thinks similarly. He maintains that the draft National Planning Framework is a recipe for the ongoing sprawl of Irish society.
What commitments exist for sustainable urban development need to be backed up by effective governance, such as directly elected mayors for cities like Dublin.
And maybe it’s a case of who cares anyway, when, as Brian Hughes, a Dublin Institute of Technology academic, maintains Ireland’s largest city is not Dublin, but the “city of one-off houses” scattered around the countryside. Its population: over 1.4 million people. What kind of society and landscape do we, as a people, actually want to have?
Perhaps the biggest problem is, for all its eloquence, good intentions and excellent production, it may simply be too long. Planning should not be a conspiracy against the layman – anything but.
To make the NPF accessible, a synopsis or clear setting-out of what it really means may help. Perhaps, at 151 pages of dense text and diagrams, this document is simply too cumbersome for busy people to grasp and enjoin in the coherent debate that is desperately needed.