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Policy Submissions

Policy submissions the DDPA has made, including submissions for public consultations. 

Draft Development Plan Guidelines for Planning Authorities

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The DDPA made a submission to the public consultation on the Government's Draft Development Plan Guidelines for Planning Authorities. This consultation commenced on 13 August 2021 and closed on 8 October 2021. Our full submission can be downloaded here.

Key points in our submission:

  • Special Planning Policy Requirements (SPPRs) under Section 28.1(c) of the Planning and Development Act hugely undermine Development Planning and references to these should be removed.

  • Stakeholder engagement and securing local support should be encouraged, but Section 28.1(c) undermines these.

  • We support the stages and timelines set out in the draft, but an "Issues and Options" paper should not be an SPPR.

  • We support the integration of the core strategies based on ESRI, CSO and HNDA data.

  • "Sustainable development" should be explicitly defined.

Draft Dublin City Development Plan 2022 -2028

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The DDPA made a submission to the public consultation on Dublin City Council's Draft Dublin City Development Plan 2022 - 2028. This consultation commenced on 25 November 2021 and closed on 14 February 2022. Our full submission can be downloaded here.

Key points in our submission:

  • Support the re-empowerment of Development Plans.

  • Support the HNDA in the sufficient amount of zoned land.

  • To tailor the scale and nature of future housing to the size and type of the settlement where it is planned to be located.

  • Support climate action chapter.

  • To insist on high quality urban and architectural design.

  • To support densities similar to other European capitals in peer countries.

  • To remove the references to SPPRs.

Planning and Development (Amendment) (LSRD) Bill 2021

The DDPA was hosted at the Oireachtas Joint Committee on Housing, Local Government & Heritage meeting on the Large Scale Residential Development Bill to provide input on this bill. This meeting was held on 9th September, 2021. The presentation slides can be found here.

We followed this up with a letter addressed to the Committee in which we emphasised our observations and opinions on the Bill.

The DDPA's submissions were added to the Bill's pre-legislative scrutiny report.

Key points in our submission:

  • The SHD system was highly problematic and was a direct cause of the large increase in Judicial Reviews, leading to delays in housing delivery.

  • The DDPA welcomes the return of the local authority as the primary planning authority.

  • However, the DDPA believes that the intention of the Bill is to reduce public participation in the planning system.

  • Its intention is also to make any legal challenges to decisions by An Bord Pleanála prohibitively
    expensive.

  • It rolls back the legislation that was passed to comply with our obligations under the Aarhus
    Convention it will therefore be in contravention of it and its provisions for access to justice.

  • It attempts to treat the symptoms, not the causes of challenges to planning decisions.

  • As witnessed by the numbers of JRs that lead to the decisions being quashed, it will reduce the level
    of scrutiny, oversight and accountability of the decisions of An Bord Pleanála.

  • In this era of climate and biodiversity crisis any reduction in access to justice could be catastrophic.