The National Planning Framework (NPF) is the overarching policy and planning framework for the social, economic and cultural development of Ireland to 2040. It is noted that the NPF review is being carried out at a time of new governance and legislative arrangements in relation to the planning system. This includes the finalisation of the new Planning Bill, which will clarify the status of Planning Policy and Guidelines, amend the focus and lifespan for Development Plans and restructure An Bord Pleanála among other initiatives. 

RTPI Ireland broadly supports the overall approach to spatial planning outlined in the Draft First Revision to the NPF. We welcome the opportunity to make a submission to the NPF and our comments and observations are set out below.

The Government has published a draft of the first 6-year revision of the NPF. While the Draft retains the core elements of the NPF, it captures updates in Government policy including climate transition, regional development, demographics (Census 2022), digitalisation, investment and prioritisation. It will inform the Regional Spatial and Economic Strategies (RSES) and City and County Development Plans (DPs) including for example housing, renewable energy targets etc. as set out in the relevant chapters which will then be reflected in lower tier plans – effectively putting in place budgets / targets for DPs.

Section 8, Working with our Neighbours captures key strategic initiatives at the core of the cross-Government approach to harness the benefits of an all-island economy.  This collaborative approach is welcomed and it will continue to build a more connected, prosperous and sustainable island. 

The NPF includes 103 National Planning Objectives (NPOs) focused on delivering 10 National Strategic Outcomes. The NPF states in s.1.1 Setting out the Vision that by necessity as a framework document; it cannot determine every detail now, as to do so would limit our flexibility to adapt as circumstances change…. However, as clarified in s.1.2, the NPF has full legislative support within the planning system, including provisions for regular review and update, to reflect changing circumstances and make adjustments where necessary. RTPI Ireland supports the stated ambition of the NPF (s.1.3); to create a single vision, a shared set of goals for the country (expressed as National Strategic Outcomes). This vision requires an NPF with the correct balance in terms of detail, targets and timelines to support the timely achievement of key objectives.

A key role for the NPF is to bring together and reconcile the objectives of various other strategies published by the Government and its agencies, including those covering, for example, employment, public services, transport, low carbon, environment, energy strategy etc.  In doing so, the NPF will need to be an overarching Framework with sufficient detail to provide clear and well-defined objectives for each region.

While the NPF (NPO 43) has a requirement for 50,000 homes to be completed per year, The Housing Commission Report (2024) indicates 60,000 homes p.a. are required. Based on The Housing Commission figures, the NPF in accounting for this deficit will need to include circa 235,000 additional units in any updated housing targets.  Housing completion target figures are broadly a result of population growth targets divided by household size; however, the household size used is not set out.  In the interests of transparency, it is suggested that the basis for such calculations should be included within the NPF.

Achieving these targets is a very significant challenge. RTPI Ireland suggests that an updated NPF will need to ensure that:

• LAs are compelled to provide sufficient zoned and serviced land for approximately 50,000 additional homes per year to 2040 and beyond.
• The Construction Sector is able to raise output significantly. There were 32,695 new dwelling completions in 2023; up from 21,087 in 2019. During this period the government had increased supports for both public and private housing delivery and apartment units accounted for c.70% of the increased output.
• We address the reasons for construction on sites not commencing as identified, in the Department of Finance Report, Economic Insights – Summer (July 2023) which include viability, limited debt financing options for certain projects and the level of judicial reviews resulting in costly delays and increased risk.

Revisions to the NPF provide the opportunity to include summary details of the analysis of progress in achieving key objectives and how the learnings from these studies inform future strategies.

In line with the Economic and Social Research Institute’s (ESRI) baseline population projections (July 2024), the NPF National Population Growth Target is increased from 5.8 million to 6.1 million by 2040. This represents an additional 300,000 people compared with the original NPF and would result in a total increase of 950,000 people over 2022 Census population figures.

NPO 2 restates the NPF commitment to the core objective of Balanced Regional Development (development away from Dublin). The level of population and employment growth proposed in the Eastern and Midland Assembly Area will be at least matched by the other two regions - Northern Region and Western and Southern Regions.  NPO 3 provides the projected population growth for each region between 2022 – 2040 with the Eastern and Midland Assembly Area increasing by 470,000 people and the Northern and Western and Southern Regions combined increasing by 480,000. 

Some evidential analyses and clarity around how the targets for the geographic spread of future growth will be achieved would greatly enhance the effectiveness of the NPF in informing future strategies at regional level.  While National Strategic Outcome 6 provides a good overview of the approach to providing employment in the regions, reporting on the assessment of progress and potential impacts are required regarding:

• The objective of a 50/50 split has not been achieved to date. It should be reviewed considering the increased prevalence of urban sprawl around Dublin and resulting increases in commuting times and other negative impacts on hinterland counties.
• The National Development Plan (NDP) and overall state investment per capita is weighted towards the Dublin City Region and currently does not align with NPF policy.
• The economic risks and mitigating measures for the NPF ‘50:50 balanced growth’ scenario for the Dublin City Region which is constraining growth in the capital city.

The Dublin City Region contributes significantly to Ireland’s economy and is a major economic driver for the country.  Dublin is the economic powerhouse driving Ireland’s competitiveness abroad, it is among the Foreign Direct Investment (FDI) elite of Europe and accounts for 42% of national GDP.

Under NPO 8, the policy directing half of national growth amongst Ireland’s five cities of Dublin, Cork, Limerick, Galway and Waterford is retained.  The targets specified are:

• 50% of all new homes located in the five cities within their existing built-up footprints.
• 30% in other urban settlements within their existing built-up footprints.
• 20% potentially in non-urban (i.e. rural) locations.

There is the specific population growth target (40% between 2022 – 2040) for each of the five cities but no schematics or mapping to provide perspectives to support the vision.  The definition of existing urban footprints is not fully clear and for the main centres of growth delineation of these areas within the NPF should also be considered.

S.2.2 - Compact Growth specifies that 40% of new housing development is to be within the existing footprint of built-up areas. There is much emphasis on the need for ambitious large-scale regeneration areas on brownfield lands, infill and State-owned lands for the provision of new housing and employment. To achieve this 40% target the following must be considered:

• The difficulties and constraints in the delivery of housing on brownfield lands and infill sites must be recognised (e.g., contamination, remediation, access, land assembly etc.,).
• The Housing Commission calls for Development of brownfield sites in towns and villages supported by engineered investment by the State to address viability - such clarity would reinforce the NPF housing objectives.
• There is a need to identify the infill and brownfield sites in our main urban centres and establish the housing numbers that can be achieved to lead national, regional and local plans.

NPOs 101 and 102 reference zoned land, infrastructure, infill and brownfield sites, and the requirement to develop and implement new approaches to measuring and monitoring compact growth in cities and larger settlements, aligned to greater digitalisation of the planning system.  RTPI Ireland suggest that the NPOs 101 and 102 include a target timeframe, methodology (e.g. centralised database updated by LA’s?) and assign responsibility for implementation. This would be a positive step towards implementing the NPF.

The NPF retains the provision for 20% of housing capacity to be in rural areas and one-off housing.  Based on the projected figures of 50,000 new dwellings p.a. over the period 2025 to 2040 inclusive, this equates to 800,000 new dwellings in total comprising 160,000 dwellings in rural areas i.e. 10,000 per year. 

CSO statistics for 2022 indicate that of a total of 29,851 units completed, 15.9% or 4,746 new dwellings were constructed in rural areas.  For the projected levels in the NPF, on a pro rata basis this would equate to c. 7,950 units per annum or 127,000 (15.9%) in total of new housing units over the life of the plan. One-off housing unrelated to the rural economy, is inherently unsustainable. The 20% of new dwellings target could result in increased levels of one-off housing while a target of c. 15% of dwelling units would maintain the status quo.

Based on the principles of compact growth, sustainability and environmental protection promoted throughout the NPF, it is not clear if the rural housing target of 20% is consistent with the key objectives of the NPF.

It is important to recognise that Ireland continues to make progress in climate transition. Ireland’s greenhouse gas emissions in 2023 were the lowest that greenhouse gas emissions have been in three decades, and below the 1990 baseline.

However, Ireland’s Climate Act ambition of a 51% emissions reduction by 2030 is not projected to be achieved. The Environmental Protection Agency (EPA) projections (May 2024) show that implemented policies and measures can only deliver an 11% reduction in greenhouse gas emissions by 2030. The scenario, including policies and measures from the 2024 Climate Action Plan, is projected to deliver a 29% emissions reduction over the same period. For a number of years, the EPA has called for urgent implementation of all climate plans and policies, plus further new measures to meet the 51 per cent emissions reduction target and put Ireland on track for climate neutrality by 2050.

Failure to meet these targets has wider implications for the state, particularly in relation to security of supply, as Ireland's continued reliance on insecure imports exposes us to global market disruptions and fuel price volatility.  Extending our dependence on fossil fuel generated power is also delaying our progress in reducing carbon emissions. 

Table 9.1 allocates the 2030 targets for Renewable Electricity Capacity for Onshore Wind and Solar PV on a regional basis. Delivery of the ambitious increase in onshore renewable electricity capacity within the timelines proposed requires immediate interventions and supports. The NPF has determined that RSES must plan for this capacity and identify allocations for each local authority. With 2030 looming, the timeline of the NPF review process, followed by the lengthy sequential reviews of the RSESs and DPs must be factored into having a plan-led and evidence based framework to facilitate the accelerated delivery of substantial renewable electricity across the country.

In line with the National Planning Policy Statement (2015) - Objectives of Planning, the NPF has a role to set out a cohesive vision for the future and in supporting the transition to a low carbon economy. It is also acknowledged (p.134, NPF) that renewable energy has the potential to significantly boost economic development in communities by creating jobs, generating revenue through commercial rates, and supporting Community Benefit Funds. Emerging industries such as the renewable energy sector are critical to achieving the NPF objective of balanced regional growth.

Providing clear direction, including information on potential areas and locations attached to renewables development, would help establish this vision and align with EU policy. 

Sectoral interests cite that delays in the planning process and a shortage of grid connections are among the reasons why the 51% emissions reduction benchmark will not be hit. EU policy on renewables is supportive of streamlining the planning processes and providing definitive information for investment in renewable capacity and grid infrastructure in order to meet our climate commitments.

• Council Regulation (EU) 2022/257715 (December 2022) sets out to impose maximum deadlines on the permit-granting processes for renewable energy projects designating them as in the “overriding public interest”, which often provides priority over local environmental or nature concerns.
• Under the EU Renewable Energy Directive III (RED III), Ireland is under an obligation to carry out a coordinated mapping exercise for the deployment of renewable energy by 21st May 2025. Ireland is required to designate ‘renewables acceleration areas’ where there will be a simplified fast track procedure for approving new renewable energy projects by 21st February 2026.

The first key deadline under RED III (art. 16) – to ensure a two-year timeframe applies to renewable project permitting - was to be in place by July 1^st, 2024. Taking the planning actions necessary in line with EU Directive Red III would inform the NPF and support the state in achieving its legally binding Climate Action targets.

The NPF places significant emphasis on the accelerated delivery of transport orientated development (TOD) opportunities at greenfield and brownfield sites adjacent to major public transport hubs in the five cities, suburbs and metropolitan towns. This reflects an enhanced focus on GHG emissions reductions and the broader policy changes since the publication of the original NPF including European Directives, National Climate Action Plans and the Sectoral Emissions Ceilings agreed in 2022.

New Sustainable Communities are identified as a new element of strategy. This initiative is seen as critical to address the potential requirement to plan for population growth in line with high migration scenario (ESRI estimate of 6.3m people by 2040). These communities will be delivered in line with longer term strategic planning for TOD in Ireland’s five Cities in the period between 2030 and 2040.

While TOD will form an essential element of forward planning, does it still result in in moving people significant distances to access jobs/services?   Aligning the provision of housing with the Geneva UN Charter on Sustainable Housing provides a response to ensure that housing will be put on a more resilient and sustainable path. There should be more references and targets with regard to working/living/services within close proximity at neighbourhood scale. 

NPO 93 states that the Metropolitan Area Strategic Plans shall include provision for large scale TOD opportunities.  This is further supported by NPO 94 which references Integrating Spatial and Transport Planning: It is proposed to extend the statutory arrangements that are already in place for transport planning in the GDA to all of Ireland’s cities, thereby strengthening the levels of integration between spatial planning and transport planning across the country, to the benefit of the economy and society.  There is no evident target timeline for this or that it is set as a short-term or long-term goal.

For integration of safe and convenient alternatives to the car, NPO 38 could be strengthened by expressing the hierarchy of users as noted in the Design Manual for Urban Roads and Streets (2023), active travel first, public transport next, and then the private motor vehicle.  In order to reduce greenhouse gas emissions and promote healthier lifestyles, streets must facilitate more sustainable forms of transportation so the need for car-borne trips is minimised. NPF proposals for substantial infill development offer a significant opportunity to prioritise Active Travel in the planning process.

RTPI Ireland welcomes approaches to ensure that the NPF and the National Marine Planning Framework (NMPF) will be used as forward planning documents which help support a plan led approach to development and conservation in the sea and on land.

We are pleased to see the recognition of a need for a strong link between marine and terrestrial planning and that efforts are being made to ensure that these are more integrated. Implications are arising from development and decisions made in the marine environment, on land, and vice versa. This means approaches to developing a NPF and NMPF must be taken forward hand in hand. We need to ensure that the frameworks put in place complement and support one another.

The correlation between both National strategic documents is largely confined to Section 7 – Realising our Island and Marine Potential and references in NSO 4, High-Quality International Connectivity, to ongoing development plans for our major ports. There is no reference to the additional 2GW target of offshore wind in support non-grid limited generation. 

Offshore wind development requires onshore infrastructure, which includes improving grid connectivity both domestically and internationally, non-grid transmission elements, port facilities for the assembly and operation of wind turbine components, as well as the maintenance of offshore renewable energy initiatives. There are also plans for large scale hydrogen production in Ireland using offshore wind.  Development of renewables will require significant shift in land-use and infrastructure management across all sectors, supporting delivery of critical infrastructure for electricity generation, distribution and transmission and enabling infrastructure including ports and transportation hubs.

The NPF and NMPF should combine to lead, rather than follow. They should be prepared simultaneously, be fully integrated and should be seen as the key spatial plans that influence the priorities and resource allocation of Government. This cohesive planning framework should also promote a collaborative approach between the Government, stage agencies and the private sector in achieving the commercial and social benefits of all our resources while supporting marine life and biodiversity more generally.

RTPI Ireland support the overall approach of the NPF focussing on policies, actions and investment to deliver 10 National Strategic Outcomes. 

For the protection of biodiversity across all future development, we suggest strengthening NPO 85 by aligning it with the objectives of the National Biodiversity Action Plan where planning authorities are required to ensure no net loss of biodiversity within their plan making functions.

The NPF will be taken forward in different ways across Ireland, reflecting the diverse character, assets and challenges of our places. Twenty-three new Case Studies are included in the revised NPF. While all are laudable, it is unclear how these studies contribute to a long-term strategy addressing critical planning issues of national significance. Inclusion of case studies, for future large-scale projects, which would contribute to establishing regional spatial priorities and inform the broader forward planning activity within the three regions would be more beneficial.  High level representations or outline proposals for strategic large-scale projects would provide greater certainty in decision making, aid the preparation of RSESs and LDPs, help expedite the delivery of selected landmark schemes which in turn will facilitate local ancillary development.  RTPI Ireland suggests that any case study examples are presented in a supporting annex or webpage, rather than inserted into the NPF itself. This will enable case studies to be updated in line with interim reporting on implementation.

The planning legislation underpinning the NPF also led to the creation of an independent Office of the Planning Regulator (OPR) in 2019, which is responsible for monitoring implementation of the NPF.  RTPI Ireland suggest that the revised NPF clearly states how monitoring and evaluation of the implementation of the NPF is to be carried out and reported.  RTPI Ireland is of the view that a sound and transparent evidence base must be in place to demonstrate why policy directions and priorities have been taken in the NPF. The final NPF should include short-, medium- and long-term milestones that are tracked transparently to report annually on progress being made and implications of changing contexts.

There is a need to ensure that the ambitions of the NPF are backed up with the resources to allow for the drafting, engagement, publication and delivery of statutory plans at regional and local level. The requirements for the NPF implementation to be overseen by the OPR and compliance with EU Directives, at a time when new governance and legislative arrangements in relation to the planning system are ongoing, are placing a huge demand on scare resources.  The focus must be on delivery and the means to achieve the targets outlined.

Initiatives such as Strategic Development Zones for housing, coordinating all the different aspects of housing delivery ecosystems including active land management, services, infrastructure, utilities etc., are essential to achieving the NPF housing targets. RTPI fully supports The Housing Commission Report which called for a much stronger and better resourced role for Local Authorities.

As a professional body for planners in Ireland, we very much welcome the fact that the Government has recognised the need for training and support.  This allows officials to learn about the specific issues encountered in terrestrial and marine spatial planning, along with any new regime and processes which are put in place to manage the significant challenges that are now upon us. We would be very pleased explore how we can work with the Government, the OPR, other bodies and educational institutions to support this work.