I thank the Chairman and committee members for offering us the opportunity to meet them today on the national planning framework and climate targets. I am vice president of the IPI and I am accompanied by Dr. Seán O’Leary, senior planner with the institute.
The planning process provides an established means through which to implement and integrate climate change mitigation and adaptation objectives and our members have extensive experience in relevant climate action implementation matters at policy, strategy and project level. Climate action, sustainable development, the achievement of the sustainable development goals, SDGs, and the centrality of the planning system in achieving them should be more explicit throughout the national planning framework and also future climate action plans. The institute welcomes the review of the national planning framework but this cannot delay essential progress in delivering both compact growth and renewable energy priorities. Both the NPF and Climate Action Plan 2024 would benefit from strengthening the commitment to balanced regional economic development, which is central to national and regional policy. This must be underpinned by the required level of infrastructure investment and project delivery, especially enhanced inter-regional connectivity across multimodal transport, digital connectivity, energy grid and skills development.
We agree with the expert group for the first revision of the national planning framework that the revised framework should seek to name the principles for identifying priority locations for the deployment of infrastructure, including that necessary for decarbonisation, at a strategic scale throughout the country. The absence of mapping, including of potentially overlapping or competing policies, designations and objectives, was identified as a weakness in the national planning framework at draft stage by the institute, and we would support addressing this. The national planning framework also requires a strategy for delivering infrastructure, such as port and harbour infrastructure capacity, to develop, service and maintain offshore renewable capacity and supply-chain economic activities. A plan-led coherent approach must extend to corridors for infrastructure for connections to the grid for both onshore and offshore renewables to prevent a piecemeal approach to the application, consenting and delivery of individual connections to the grid. For all renewables, onshore and offshore, it is critical that policy provide a clear pathway for industry and communities and that it retain and provide confidence and certainty to all stakeholders in the current system.
The revised wind energy guidelines are urgently needed. Planning policy needs to be specific about noise standards for wind turbines to ensure that both the communities that might be affected and the developers of wind energy infrastructure know the criteria expected, while recognising the need for appropriate flexibility within defined parameters. After demonstrating good design, an application still needs to be assessed for context-specific impacts. In general, planning legislation and policy also need to consider the rapid pace of technological innovation. The overdue national landscape character assessment is also essential to addressing some potential conflicts and inconsistencies in dealing with renewable considerations. The need for a national wind energy strategy that has been subject to strategic environmental assessment and is mapped to a sufficient scale is essential.
REPowerEU discusses the possibility of having ready-to-go areas for renewable energy, meaning areas that could avail of a streamlined process. In an offshore context, this requires that designated marine protected areas to be prioritised and resourced to ensure certainty, that is, what is and is not protected, with data available. There should also be consideration of introducing a presumption in favour of renewable energy production in development plan zoning objectives and climate action measures in development management.
More consideration should be given to locating renewable development on brownfield sites such as industrial areas that have capacity to absorb it. The revised national planning framework also needs to engage with the strategic national approach to a range of decarbonisation technologies such as biogas, hydrogen and anaerobic digestion.
Turning to the issue of compact growth and transport-orientated development, the institute is currently preparing a submission on the draft sustainable and compact settlement guidelines, which are out for public consultation. Transport-oriented development is key, and the IPI believes there should be a greater focus on retrofitting the existing urban environment to enhance connectivity and permeability. Investment in a specific mode of transport is of benefit only where it can be demonstrated its usage will also increase. All new developments should provide for optimal levels of connectivity and permeability, especially for pedestrians and cyclists, through smart design.
While addressing mitigation priorities, however, compact growth should also recognise climate impacts, not least those associated with increased impermeable surfaces and building design in respect of indoor solar gain, as well as microclimate impacts and the use of green infrastructure, to address flood risks and overheating. If the sunlight and daylight guidance were applied literally, to require 100% compliance in apartment guidelines, that would, as we understand it, militate against passive housing. Complex aspects within the policy documents need to be ironed out.
The planning system is central to dealing with both the legacy of unsustainable, carbon-intensive development and delivering the strategically critical infrastructure required to meet our climate targets, all at a time of significant population growth and housing demand, but there will be significant challenges to meeting our carbon budgets without an appropriately resourced planning system that is equipped to implement reformed legislation.
The alignment of public policy is a key issue. The ambition of the new national climate objective and the implications of carbon budgets have not yet been fully mapped into planning policy and practice, and the hierarchy of planning policies needs to be better aligned to meet mitigation and adaptation goals. The implications of carbon pricing for the planning system, and the role of planning authorities in quantifying the impact of decisions on greenhouse gas emissions in a consistent manner, require engagement with practitioners. It is also unclear how the 2022 permitting regulations were reflected in national guidance, and the planning system must also be prepared for the amended renewable energy directive, which reflects the ambition of this regulation and REPowerEU.
The planning policy hierarchy requires different levels of the planning process to address climate change. The implications, however, of the forthcoming local authority climate action plans on recently adopted development plans remain unclear. The forthcoming renewable electricity strategy, regional renewable electricity strategies, local authority renewable energy strategies and the accompanying methodology will create a complex framework that will be challenging to integrate into existing plans and policies, particularly given current resource constraints.
Our members are well aware of the national, European and international obligations Ireland now has to address the climate and biodiversity crisis, including the impending adoption of the fourth national biodiversity action plan, and want to ensure policy and decision-makers reflect these. However, this requires the support of others to tackle misinformation and create a stronger sense of the common good among communities. Elected representatives have a key role to play in this.
The plan-making process provides excellent vehicles for community engagement and education for climate action and sustainable development. Constructive engagement with communities, who may have legitimate concerns regarding decarbonisation interventions and projects, is required at a much deeper level than heretofore.
We will be happy to address any questions the committee may have should members wish to engage further with the institute on any aspect of our submission.
