Ms Sinead Guckian:

I am grateful for the opportunity to address the committee. I will make particular reference to head 5, which enables local authorities to incentivise the development of vacant sites. As is clear from our written submission, our members acknowledge the good intentions behind this proposal. There are vacant sites in the centre of towns in every county. They are not only unsightly but they also hinder our development plans. Most councils outside of the largest urban centres are trying to bring life and vibrancy back to the smaller town centres. A core objective of our county development plans and local area plans is to seek the development of the lands we have zoned. In that regard we broadly welcome the proposed levy. We also welcome the proposal that the introduction of levies will be decided locally as a reserved function under the development plans. As we believe in retaining and strengthening local democracy, we would like to see a greater emphasis on allowing decisions to be made at a local level where this is possible.

While the vacant site levy will have the greatest impact on large urban centres like Dublin, the proposed population threshold of 3,000 means that it will have limited applicability in smaller counties. In my own county of Leitrim, the only town that meets the criteria is Carrick-on-Shannon. That means many towns and large villages around the county will get no benefit from this provision. I am sure that will be the situation in other counties. In regard to the potential for implementing the levy in Carrick-on-Shannon, the land that we would like to see developed, which is in the centre of the town, is likely to be exempted under the provision as proposed because parts of it are tied up with title or financial difficulties.

We were unable to ascertain from the heads how agricultural land would be treated in respect of towns with a population of more than 3,000. Carrick-on-Shannon is more than 400 years old and history as much as local government has dictated its development plan. In our case, agricultural land is zoned general, which permits agricultural use. However, the introduction of the vacant sites levy may put the land into a grey area. By taking out a pocket of land, would the council open up the possibility of other land owners coming forward to make a case for their own properties?

From the perspective of implementing the levy in a more rural county, very few local authorities have managed to overcome the obstacles to implementing the derelict sites levy. We are concerned that the introduction of a vacant site levy would face similar obstacles.

There are concerns about whether local authorities would have the resources or expertise to carry out the work to introduce any levy. There is a question about how local authorities would be expected to establish the status of sites. I imagine many committee members are aware that many sites can have complex ownership or legal questions. Our members have suggested that each planning department would need dedicated properly-resourced enforcement offices and officers to carry out any implementation of a vacant site levy.