I thank members for inviting me and my colleagues to appear and I hope we will be of help to the committee.
The DDPA is an alliance of civic groups such as District 7 and the Rathmines Initiative. We are also involved with 60 residents' associations representing more than 200,000 citizens. We have housing and planning specialists, architects, statisticians, academics, social professionals and individual citizens. That is our alliance. We seek to be their voice and the voice of those who need housing and whose voice is not heard in any of the debates. We support development that is sustainable, planning that is democratic and housing that is affordable.
Reportedly at the behest of the property industry, two fundamental legislative changes were made to the planning process since 2015 which have undermined the development plan process and citizens’ trust in the planning system. Large-scale residential development, LSRD, is part of the end of that element and we hope we might be able to address it. The first of these changes was made when the then Government changed the planning system in order to speed up grants of planning permission through the SHD process. This was done on the false premise that it would increase housing supply through the SHD legislation. However, all it has done is increase the cost of housing and land. As of 1 September, 70,866 units had permission and commencement notices had been served on only 10,711 apartments or houses. The number under construction is fewer. Members should remember that this is the situation after five years of this process that was supposed to fast-track delivery.
The second change was the insertion into planning legislation of ministerial directives, rather than guidance, under section 28(1C). These have opened the floodgates for material contraventions through development plans, making those plans redundant. These special planning policy requirements, SPPRs, have facilitated applicants for permission to drive a coach and four through any democratically constructed development plan, thereby alienating the citizen, who is now left without a voice.
Massive damage will be caused to the inhabitants of these SHDs or SPPRs through: the lowering of standards; the monotony of social mix; the extremely high cost of construction, with Part V costs, for example, averaging approximately €500,000 for each of these units; the anti-social nature for families of excessive height; and the damage caused by excessive densities that are far beyond those of the slums and tenements of the 20th century. One scheme of which I am aware has more than 600 units per hectare, which is ten times the average in Copenhagen, for example, and four times more than that in Paris, which is the densest city in the world. It is even beyond the density in Dhaka in Bangladesh. Paris has no high-rise development. Not only is the new construction inadequate, its impact on the receiving environment will destroy the qualities of the places in which we will live, which is contrary to the core values of the national planning framework.
What we now have is a system run by developers and their agents. The independent reports that accompany and justify material contraventions, and which are all supportive of the applications, are exercises in advocacy rather than assessment. In other countries, assessments such as these are carried out by the planning authorities rather than the applicant. We see the solutions to housing need and sustainability, both physical and social, as being through holistic planning based on empiric data and public participation. We support densification and the compact city, neither of which require height, reduced living standards or unaffordable costs for rental or purchase.
I refer to the heads of the Bill that are to hand and the regulatory impact assessment.
It saddens me that, in my opinion, the RIA fails to use any empirical data, analysis or assessment to justify its preferred option of LSRD. The simple option of reverting to the pre-SHD regime is dismissed without due consideration. There is no recognition that there is no connection between fast-track planning and the delivery of housing. There has never been evidence to support that theory and the attempts to prime the market have failed in terms of supply, as well as in the damage inflicted on the receiving environments and trust in the planning system.
The heads of the general scheme are analysed in the document we have. In principle, we welcome the reversion of decision-making to local planning authorities, which will need more resources.
We believe the problems of the planning system are rooted in the centralisation of power through policy and ministerial directives that supersede development plans and alienate the citizen from the planning process. The proposed LSRD process will allow for the continuation of this alienation to the detriment of society, nor will the cost of this alienation result in any affordable housing for our population.
There is no need to have any replacement for SHD. It was brought in as a temporary measure for two years to expire in 2019, and was extended to expire in 2022. It should, at worst, wither or, at best, be guillotined as the failure it is. It will be a huge breach of trust to the citizen to see this failed process replaced as a permanent feature of the planning system.
I thank the Chairman for allowing us to give our perspective on the legislation. We hope to be able to engage with the joint committee again in the future. We believe we have a lot to contribute. Our message is simple: we do not need any fast-track process to supply affordable housing. There is no need for a fast-track process in any part of our planning system. Complying with development plans gives us that; contravening them delays the system. All planning for everybody should be open, transparent, equitable, efficient and suitably resourced. It is important for us to say that, other than the transitional arrangements for SHD, there is no need for the legislation. We should revert to the properly resourced planning system for all with the timelines included in this legislation. I thank members for their time and welcome any questions.