Mr. James Benson:

Perhaps I might be able to answer Deputies Higgins and Ó Broin's questions at the same time. Some of our comments are contained within our submission - on pages 4, 5 and 7 - and relate to commencements. We share equal frustration regarding the level of commencements.

That brings me to a point on the economic viability assessments that we do. Everyone will recognise that planning is not a guarantee of viability in our current market. A large number of external factors and unknown costs that are revealed through the planning process become apparent. Unfortunately, we get to a stage where a large number of granted permissions are no longer viable. That is the reason they have not commenced.

It also needs to be recognised that while the scheme has been in place since 2017, there is a five-year span for commencement of a number of activities. A grant of permission, in itself, does not mean one is likely to see a commencement within a six-month period. It can take 12 months, and 18 months in some cases, to meet one’s obligations, ensure the infrastructure is in place and secure the funding that is often critical for the delivery of these projects. That is one key area.

The economic viability assessment, while it should not be the ultimate reason or rationale for granting or refusing any project or application, needs to come in to an earlier part of the conversation, potentially at pre-application stage. It is an inefficient use of resources, time and expertise on the part of both parties and all sides to go through a process at the end of which something is not built or brought forward. In order to ensure that the application deals with the requirements set out in national policy, the development plan, the local area plan, the local development plan, or whatever the case may be, similar to an outline permission, all of the requirements should be out in the open and set out at an early stage. These include the requirements of the prescribed bodies or of the internal departments within the planning authority. It could be seen at that point in time whether a project would be viable and worthwhile bringing forward. That is a key area.

On judicial reviews, which were raised by Deputy Ó Broin, we agree that the process should be very robust and there should be an opportunity for everyone to be consulted. That is only right and proper and we would not have any objection to that. We believe there is an education piece here for the general public. While the early stages of county development plan drafting can be quite abstract, these should be an opportunity for people to get involved in the consultation. Councillors, the elected members, make the development plan, the planning authorities are the policymakers and the making of decisions on the application are delegated by the executive. However, at that very early stage, we need to see public consultation so that members of the public are aware what will happen when a particular area of land is zoned for a particular purpose and have an opportunity to be consulted.