Mr. David Minton:

We are grateful for the invitation to participate in today's meeting.

Internationally, the discourse on regional development has evolved rapidly, recognising that successful economies are organised on a regional basis. The regional assemblies represent the regional tier of government in Ireland and play a central role in the new planning system. This role is largely enabled through regional spatial and economic planning.

We acknowledge the prominence of regional planning in the draft legislation and the new responsibilities under consideration. This is a confident signalling for regional planning and each of the regional assemblies and reflects the impact of the regional tier within the Irish planning system and the positive statutory alignment that now exists between the national, regional and local planning.

The assemblies welcome the opportunity to input to the legislative process and acknowledge the invitation by the committee and the chairperson today, as well as the invitation by the Minister to actively participate in the planning advisory forum over the past 12 to 18 months. In the context of today, our comments are limited to high-level observations and a more detailed submission will follow.

We have four salient or primary points to make. The assemblies welcome the continued focus on plan-led development. At national level, the draft Bill at section 18 (1) is a highly positive signalling for the role of the regions. We also welcome the prescribed role set out for the assemblies in the national planning framework review. Section 28 further enhances and embeds the importance of the regional spatial and economic plans in the planning hierarchy and we welcome this strengthened responsibility. In particular, it expands on land use and transport planning integration, with a strengthened alignment of the National Transport Authority, NTA, with regional policy which is substantially positive. There are also additional welcome responsibilities in the areas of housing, climate action, renewable energy strategies, marine spatial planning and coastal management. Again, this reflects the move to mirror more regionally organised land use planning.

The overarching concern of the regional assemblies is that any review of the Bill should safeguard and strengthen the strategic regional planning content of the planning of national policy. In addition, we have some observations on areas of the Bill that we feel require further consideration. First, the regional assemblies strongly welcome the reference to metropolitan area strategic plans, MASPs, in section 28. Given the strategic importance of the MASPs, the review of the Bill should ensure they are an effective mechanism for the delivery of transformative change required under the national planning framework, NPF. We note that the relevant content is light by contrast to other plans and strategies in the Bill, like the guidance included for urban area plans, and believe that greater emphasis should be given to the MASPs in the legislation. Subsections (4) and (5) refer to the designation of boundaries for each MASP by the regional assemblies and provide that this means the area consisting of the city and its surrounding area, approximating to the extent of its commuting zone. Any designation or re-designation of existing MASP boundaries should require clear and strict rationale not necessarily limited to commuting zones. Safeguards should be included to ensure that consistent criteria are used for identification of all MASP areas.

On the cross-boundary joint area plans, the regional assemblies welcome the inclusion of the definition of a principal planning authority in section 13. Section 28(12) clarifies how a principal planning authority shall be determined by the regional assemblies. Furthermore, the provisions regarding joint area plans in sections 70, 71, and 73 to 75, inclusive, are welcome. However, there are instances where a joint area plan will cross the boundaries of more than one planning area. Athlone, for example, is located within the administrative areas of counties Westmeath and Roscommon and across the eastern and midland region and the northern and western region. The regional assemblies would welcome a definition of a "principal regional assembly" and the criteria of the determination of a principal regional assembly, particularly where a joint area plan is being prepared.

The third area, which is critical, is implementation and delivery. The role of public bodies in reporting on regional implementation has been removed from the draft Bill. Section 25(A)(2) of the current Planning Act requires the regional assembly to prepare a report monitoring progress made in implementing the regional spatial and economic strategy every two years. The monitoring report specifies the progress made in securing the overall objectives of the regional spatial and economic strategy, including actions specific to the public bodies. This relies on the co-operation of public bodies such as Irish Water, Enterprise Ireland and Fáilte Ireland. Section 34 extends the reporting cycle to a four-year implementation report. The assemblies consider that this period is too long and should remain at two years. We also hold that the existing requirement for public bodies to report on specific actions regionally should be maintained.

On governance, section 30(4)(b) states that when notified by the assembly of the intention to review or make a regional spatial and economic strategy, local authorities shall co-operate, especially for the establishment of committees to oversee and consider the preparation of the strategy or its revision. Section 30(4)(d) states that the role of these committees will include considering observations received, including under section 31, preparation of the draft or draft revision. The introduction of the two sections is a retrograde step. It erodes the reserved function of the assembly members and introduces a risk to the process, given that many of the submissions will come from the local authority sector itself. The preferred option is continued co-operation with local authorities through the use of technical working groups to assist and provide content to prepare the regional spatial and economic strategy.

As indicated, the regional assemblies have prepared detailed comments to assist the legislative review process and will formally submit these to the committee and the Minister. Finally, we would like to highlight one concern relating to the limited references to regional development within the Bill. This is at odds with the NPF and a number of national strategic outcomes. Our assessment indicates that there are only two references to regional development. That said, we congratulate the drafting team and the Minister for bringing forward such progressive legislation. We also thank the committee for the invitation to participate in this meeting.