Mr. Conor O'Connell:

The points asked for are in our submission, but some of the key points have been mentioned already. HNDA in particular is a very key one and we should zone for the minimum, not the maximum and restricting it.

The legislation should enclose a practice, developed through case law, that the appropriate time to raise planning issues is during the planning process, and that the 11 grounds of challenge raised during judicial reviews that could have and should have been submitted and raised before the commission and local authority cannot be submitted and raised for the first time in judicial review proceedings.

Another point is the ability of a local authority to deviate from some of the suggestions or recommendations from the Office of the Planning Regulator, OPR. Observations and deviations should be permissible if supported by the council executive and a majority of the members pursuant to a statement of compliance with the principles of proper planning and development.

I emphasise that point on timelines. The Construction Industry Federation believes there should be a mandatory period of 16 weeks.