The DDPA aims to put the needs of the citizen and the community at the centre of housing and development for a liveable Dublin.
The DDPA wants to reinstate democratic procedures which are supported by national and international legislation (United Nations Sustainable Development Goals, EU legislation, the Aarhus Convention and Ireland's own constitution):
rights of participation for the citizens
right to a liveable environment
The DDPA is proactively progressing its mission through meetings with politicians, housing committees and discussions with leading Irish housing academics.
RETURN TO THE DEVELOPMENT PLANS
Local authority Development Plans enable democratic principles through the involvement of inhabitants and elected representatives. (Set out in the Planning Act 2000). It makes for a successful city, sustainable and coherent growth, appropriate levels of density and green space, infrastructure, affordability and long term strategy.
Dublin's development plan is being over-ridden by Ministerial Guidelines. Intended to provide housing faster, they invalidate the voice of local authorities and diminishes public participation.
We fully support
the re-empowerment of the Development Plans
the development of affordable housing
secure rental in our communities that meets the needs of our citizens
housing which supports existing and new communities
housing which addresses climate change and loss of biodiversity
STRENGTHEN THE LOCAL VOICE
NIMBYism? There is no evidence that the planning system has delayed the supply of housing in Ireland. There is, however, plenty of evidence that, if the voice of the citizen is either unheard or ignored, it leads to poor outcomes. For this reason, subsidiarity is a core value of the European Union. Engaging the local community at an early stage leads to new, successful development with and for the communities.
REMOVE UNDEMOCRATIC SHORTCUT APPROACHES
We do not support the current system of random, profit-driven, developer-led planning. The trust of the citizen has been lost in the new processes of centralised planning which overrides the city development plan and is a danger to the quality of the city.
SOLVING THE HOUSING CRISIS: PROMOTING SUSTAINABLE AND AFFORDABLE DEVELOPMENT
The DDPA supports supply of quality affordable housing through a wide variety of models:
converting existing under-utilised buildings
flexible sub-division of existing dwellings
intensification of existing housing development
new development at a scale that improves existing areas
funding models for social housing such as State and approved housing bodies
long-term and low-yield private investment for quality housing rather than short-term speculative investment
THE 15-MINUTE CITY
We believe that the affordable 15-minute city is in reach. Population densities sustain social and physical infrastructure. They address the existential crises of climate change and loss of biodiversity in cities. We support appropriate development driven by social needs and empirical evidence.
Carefully established local development plans (for example Dublin City Development Plan 2016-2022) have been undermined since 2015 when the planning process became much more centralised. Due to changes of consecutive Ministers for Housing, planning decisions for large scale housing developments are no longer the remit of local authorities.
Strategic Housing Developments: Following lobbying from property industry groups, the Strategic Housing Development (SHD) regulations were introduced in 2017 to 'fast-track' the planning process for large residential developments (100 units minimum). It removed the local planning authority. Decisions on planning are now made directly to An Bord Pleanála, with no right of appeal against its decisions. The only action that is available to the citizen is Judicial Review, which is expensive and can only address procedural shortcomings of An Bord Pleanála decision making. The DDPA has reviewed over 250 decisions made by An Bord Pleanála since 2017. Many of those granted permission by An Bord Pleanála will irreversibly damage their areas in social, spatial and visual terms. Dense, large-scale developments with multiple floor levels are very expensive to build. Therefore, they will not provide any affordable housing.
Section 28: The Planning Acts set up a system of area planning which is based on democracy and realised through Development Plans. These are approved by elected representatives after public consultation. Mandatory Ministerial Directives - Section 28(1)(c) - are new rules introduced by ministers which override the Development Plan, called 'SPPRs' ( Special Planning Policy Requirements). These force planning authorities and An Bord Pleanála with the SPPRs being 'required to be applied' rather than having to 'have regard to' ministerial guidance. Examples of these forced rules are lower space standards, mixes of types, reduced aspect and open space requirements, elimination on building height controls, to name just a few.
RESULTS OF THE SHORTCUTS
WRONG HOUSES: too many rent-only studio and one-bedroom units, with no potential for diversity or flexibility; High carbon construction and footprints which are complex to maintain; Downgraded space standards of 'Build-to-Rent' schemes are highly profitable and encourage developers to build large scale rental schemes over owner occupied apartments.
WRONG PLACES: all SHD development densities and building heights are far in excess of those permitted by development plans. They overwhelm their localities. There is no strategic plan for location within existing communities and they frequently disregard the qualities of the existing urban fabric.
WRONG PRICE: 20% of the units built must be sold to the local authority for social, voluntary or 'affordable' housing. Recent permissions show ranges between €500,000 and €775,000 per apartment. At around €10,000 per square metre this is expensive and unaffordable for the ordinary citizen and represents poor value for money as social housing.
LACK OF DEMOCRACY: by forbidding the right to appeal, another democratic balance has been removed. The only action available to the citizen is Judicial Review through the High Court, which is complex, expensive and can only address procedure.
The SHD process is not transparent. The entire application is managed by the developer. The citizen has no access to view the procedure.
When the decisions are made, the ABP case file can only be viewed by request and the developer may remove all online application data after 8 weeks. This violates the right of citizens to information that is of vital interest to them.
What it all means.
In practice, the drive to higher densities through erosion of the citizens' rights and faster planning has not delivered what we need – affordable housing for a generation denied of it. Instead, developers are seeking increasingly higher returns as the rules change, pushing for high rise and high density against the provisions of the Development Plans, and focussing on housing typologies that bring most profit, rather than addressing local housing needs. In failing to address local needs, disregarding good urban design and the process understandably meets significant local opposition and often impedes the delivery of housing. It eradicates democratic possibilities of the citizen. Meanwhile planning permission is granted with no right of appeal to build highly problematic super structures.
We need to restore the citizens' faith in the planning system by allowing local authorities to make decisions at a local level. We need good urban design, rather than profit, to drive the density and height of new housing developments, particularly where they are proposed on tight urban sites. We need to remove broad brushstroke decisions by the past and current Housing Ministers and look at sustainable means of delivering a large quantity of housing in our cities.