WDC submission to Ireland 2040-Our Plan, the Draft National Planning Framework

Below is a summary of the key comments contained in the Western Development Commission (WDC) submission on Ireland 2040-Our Plan, the Draft National Planning Framework, the closing date for submissions is today Friday 10th November.

In general, the WDC would have hoped for a more focused document with clearer commitments although the WDC strongly supports a strategy to drive a better spatial balance of economic activity across Ireland.

Particular areas of concern for the WDC are:

  • The WDC welcomes the inclusion of regional targets but considers there is very little in Ireland 2040-Our Plan which can help to deliver on targets either for the Northern and Western region or that will move Ireland beyond the ‘business as usual’ scenario.
  • The focus of Ireland 2040-Our Plan is on city led development in the five named cities. As there is no city in the north west the strategic development needs of the area, including Donegal, Sligo, Mayo, Leitrim, and Roscommon, are not envisaged or prioritised. An urban centre such as Sligo should be identified and resourced to drive the development of the wider region.
  • Ireland 2040-Our Plan has seventy ‘National Policy Objectives’ but little detail on how many of the seventy will be implemented. Despite these National Policy Objectives, the Ireland 2040-Our Plan is quite general and aspirational and the real detail is only in the target population growth and jobs growth and in details of planning mechanisms.
  • Ireland 2040-Our Plan does not address the stated need for enhanced regional accessibility for the north west. Accessibility is only referred to in the context of ‘incremental improvement’ and ‘only after compact growth in urban areas’ is achieved.
  • In relation to Ireland and Northern Ireland, too much priority is given to the development of the Dublin-Belfast corridor compared with the important and significant cross border interactions in the Derry/Letterkenny North West City Region.
  • There is a serious definitional issue with ‘rural’ as areas as outside towns with a population of 10,000. This covers 80% of the population in the Western Region and 50% nationally. These are very significant proportions of the population and their needs should be addressed clearly and specifically.
  • Under discussion of rural infrastructure there is no mention of transport (public transport, regional and local roads), or connection to primary and secondary roads, air access, rail or energy infrastructure for residents or enterprises in these locations.
  • Much responsibility has been passed to RSESs and the NWRA has most challenging population growth target to meet. Beyond the five cities, it is suggested the RSESs will cover the broader regions and rural areas, without clarity about what will be committed for the regions, resourcing the RSESs and how they will ensure policy aligns with them.
  • While Ireland 2040-Our Plan gives some indication of how the NPF will be implemented (mainly in terms of planning and capital investment, although the detail of that is not yet available) there is little reference to how ‘sectoral’ policy will be aligned with the NPF. There needs to be a clear implementation and monitoring structure put in place to ensure sectoral policies are aligned with the NPF, beyond that for capital investment and planning.
  • Where conventional evaluation and appraisal techniques, like cost benefits analysis (CBA) methods are used to determine investment priorities, this ultimately supports ‘business as usual’ outcomes. Therefore a change to the conventional appraisal and evaluation methodologies used is needed in order to determine what projects become priorities.
  • There is excessive focus in Ireland 2040-Our Plan on attracting international companies and insufficient consideration of indigenous sector, SMEs, micro-enterprises and sole traders. Similarly the focus on growing demand for a highly skilled workforce does not acknowledge the concurrent growth of low skill, low paid employment, meaning it fails to recognise the needs of this group.
  • Employment growth in urban areas beyond the cities is very much presented as an afterthought and primarily for ‘accessible towns’ with a large catchment. What is the role or future for towns that do not meet these criteria? The NPF must address all types of spatial areas especially those areas that face greater challenges and therefore require greater public intervention, as private sector led development will be attracted to the stronger centres.
  • There is a lack of clarity on the relationship between, and priority given, to the ‘Metropolitan Area Strategic Plans’ and the ‘Regional Spatial and Economic Strategies’. It is not clear if the MASPs are to be developed subsequent to the RSESs, implementing the RSES at the metro level, or if they are to be developed concurrently.
  • Though the role of third level education in supporting regional development is acknowledged, along with the development potential of Technological Universities, the only facility mentioned is Grangeorman in Dublin. The Institutes of Technology in the west and north and proposed Technological University there are important drivers and need to be named as such.
  • There is a very significant focus on city led development but little explanation of how this will give rise to broader regional development. Given the timeline for publication of the NPF and the 10-year National Investment Plan, failure to designate any urban centres other than the five cities in the NPF means that regionally important large towns are unlikely to be prioritised for investment.
  • Ireland 2040-Our Plan is based on one projection of future population and jobs growth which is presented as a certainty and given the time period to 2040, the certainty of projections is very limited. The NPF strategy should not be based on a single projection, but should include a number of possible scenarios for future low, medium and high growth There is no detail provided on the of the assumptions underpinning the ESRI’s projections.

Deirdre Frost