Eoin Ó Broin (Dublin Mid West, Sinn Fein) | Oireachtas source

I am not convinced that is a credible answer, although I appreciate it is the one the Minister of State has been given. Let us think about it for a second. A large-scale planning application goes in and there are significant fees on behalf of the applicant which, if the application is to the board is reflective of the cost but if it is to the local authority, it is not. That is why we have the report and the Minister is considering that. If, however, a third party makes a single-page or a two-page submission, there is virtually no increase in the administrative impact in the overall decision-making process. Very often there might be groups of people who put in similar submissions. In fact, the €20 or the €50 is not really related to any extra administrative costs.

I presume somebody somewhere decided that if we do not have some kind of charge, we could get all sorts of submissions just thrown in and that this could be a terrible waste of time. In fact, for those people who have reasonable or above reasonable means, it is not really a big cost for them to do it, but for those people with very limited means, as Deputy O'Callaghan has said, then it is €20. We must keep in mind that if a person wants to go to An Bord Pleanála afterwards, then he or she must also have made a submission at the first stage, so it is €70 overall. Is it really the case that if we lift those fees, there will be a dramatic increase in third party observations? It is almost as if we are saying that the person's ability to participate as a third party - and he or she may have some very reasonable contributions to make to the process - is really income related?

There will be a group of people for whom any fee, but particularly a combined fee of €70 between the two stages, is prohibitive. The more I think about it, the less I understand why we have the fees there other than somebody just thought we would get lots of vexatious third parties observations. Arguably, if we go by the "RTÉ Investigates" programme, it is people with very significant means who are the ones using the planning process. For them, €20 or €50 does not cause any difficulty whatsoever. Groups such as the northside Community Law and Mediation network and other organisations will often make the point in correspondence with the committee that fees of any kind act as a barrier to low-income groups participating. These are groups of people who already have very limited opportunity to engage in the process.

I do not believe that even the Minister of State, Deputy Dillon, will be convinced that €20 is really a contribution to the administrative costs. Was any consideration given, or analysis done, during the decision not to change some of this to a no-fee structure, for example, or on the introduction of a waiver for people of certain incomes, without complicating it?