Ms Valerie Brennan:

I thank the Cathaoirleach for the invitation to meet with the committee. I am chair of the Royal Town Planning Institute Ireland, and I am joined by Mr. Niall Byrne, our vice chair, and Mr. Craig McLaren, our director.

The institute's charter is to advance the science and art of planning for the benefit of the public. Our institute, also known by the acronym RTPI, has 27,000 members worldwide and it is Europe’s largest professional body for town planners, of which around 350 members are based in Ireland covering the private, public and voluntary sectors, academia and students. We set standards for education in planning and currently we accredit planning courses in University College Dublin, University College Cork, Technological University Dublin, Queen's University Belfast and Ulster University. Our members need to abide by our code of professional conduct, and we have a rigorous complaints procedure. We are engaged in a comprehensive research programme that strives to learn from good planning practice from across the world.

The RTPI welcomes the planning and development Bill 2022. The Bill provides an opportunity to pronounce a clear sense of the purpose of planning: that planning generates long-term benefits that help to tackle the climate emergency and stimulate a post-Covid-19 economic recovery with good quality and sustainable homes and communities. We have concerns over the length of the Bill and would suggest that it is sense-checked to assess whether all its provisions need to be included in primary legislation, or would be better included in regulations or policies.

We believe the planning system needs to be delivery and outcome focused. The Bill should signal a shift towards an outcomes-based approach to measuring planning performance by moving beyond simple metrics such as the speed of processing applications. Accordingly, the Government should work with the Office of the Planning Regulator to develop a performance measurement regime for planning authorities that focuses on the quality of the outcomes that are achieved on the ground. We believe, therefore, the Bill should include a new statement on its front page that clearly sets out that the purpose of planning is the long-term common good. We do not believe it is appropriate to introduce fines for planning authorities if they do not meet arbitrary deadlines. Approaches to performance improvement should be incentivised rather than penalised.

Planning should be a corporate function within local authorities and Government, which maximises the benefits for places with different characteristics. We would, therefore, like to see the Bill incorporate provisions for establishing statutory city planner or county planner roles, as appropriate, in each local authority to ensure that planning has influence when corporate decisions are made in local authorities to allow for place-based approaches which appreciate short-, medium- and long-term impacts.

We would also like to see provisions in the Bill for the RTPI, and other key professional bodies such as the IPI and the Royal Institute of Architects of Ireland, RIAI, to have a role in supporting the promotion and assessment of new board members of An Bord Pleanála. Similarly, we would welcome being specifically mentioned under section 20 of the Bill in terms of having a consultation role in the review of the national planning framework.

We want to see a truly plan-led approach that promotes the primacy of the development plan, incorporating upstreamed community and stakeholder engagement that builds consensus. Community engagement should be seen as a core part of planning, and funding should be allocated to support this and help to create a less adversarial approach. This approach would allow a more proactive discussion at the start of the planning process which lessens the need for appeal and judicial review at the end. We are firmly of the view that decision making on planning issues should be made within the planning system as often as possible.

We believe there is chronic underfunding in the planning service, which often results in planning staff being unable to meet the current demands placed upon them. The system must have the resources it requires. We need to ensure planners are equipped with necessary skills, and that the importance of professional qualifications and experience is recognised. Key to this will be the introduction of digital planning approaches.

Accordingly, we urge the Government to undertake or commission research to identify the number of planners in place across the country and the demands that are being placed upon them. This research should explore the trends over previous years; current planning department budgets; and the extent to which the costs of planning application fees meet the processing costs. There should be a stated goal of ensuring that planning fees cover the full costs and that these are ring-fenced and reinvested in the planning service.

The Bill should include provisions to allow planning departments to have the power to introduce discretionary charges for activities they undertake as part of the consenting process. We believe the likely increased role of planners in tackling climate change and supporting housing delivery will create increased demands on planning authorities. Given this, we ask the Government to undertake or commission research to explore the future demands on the planning service, and the number of new entrants required to meet these. The Government should also undertake a detailed analysis of the costs of any new duties which may be introduced through the Bill, and make sure that these are fully funded for implementation. We also have concerns about the lack of detail and costs of the transition arrangements that will need to be put in place to implement the Bill.

RTPI Ireland stands ready to help shape the Bill by providing the expertise of our members and staff, sharing evidence we have gathered through our research, and highlighting good practice from our interaction and network outside of Ireland.