Mr. Gavin Lawlor:

We are talking about things like SPPRs, where there is a directive that thou shalt not do anything other than has been directed, and an argument that that should be directed towards plans rather than towards development. It is still really important to have guidelines that give a range of applicability. Planning authorities need to have some availability of discretion. Dublin city centre docklands is not the same as west Cork, so we cannot say one size fits all in terms of height or density, for that matter. There has to be some discretion in that regard. A national planning statement that talks about height or density has to recognise that there is a range and where those ranges should be applied. That prevents people abusing the system.

On the flip side of that, one of the things that we say is much more important is community engagement. One of the big problems with local area plans, LAPs, or any other form of plan is that if you do not engage with the community that you are trying to impose a plan on - and I use the word "impose" because if you have not engaged with the community, you are imposing the plan and it is not agreeing with it - or you do not manage to get the community to engage with you, then the people have no clue about what is planned for their community. It does not matter whether three, four, six or ten storeys are planned for a site, or whether the shape or colour of it has been defined or otherwise. If the community has not engaged in that process, the people are going to feel disenfranchised and are going to get upset. Public engagement is key if you are going to move to a plan-led approach. We are very protective of our third-party system in the development management side, and rightly so. We believe that communities should be able to engage in planning applications. Why are they not engaging at the same level in development plans? If we want to move from a system where the development management side has more certainty because there is more specificity in our plans, we are going to have to engage communities and encourage more engagement with communities at development plan stages. That is a timing and a resourcing issue, and it is a huge problem. If you make a submission in a development plan - and I do not know if many councillors have done so and have felt just as disenfranchised as members of the public do - it is really disheartening to read in a manager's report that there is no change, and there is no engagement with the argument that is being made. That is what happens. Sometimes it is because the manager does not have time to explain why there is no change. It is not just simply a case of saying: "good luck with that one".

Community engagement is a key part of getting acceptance. It is a key part of how national policy is implemented. That is why we, at the institute, would say that if we are going to have the equivalent of SPPRs in a national policy framework, where there are directives to planning authorities, they should be dealt with at plan level. That does not mean that there should not be any other guidance. There should be guidance outside of that as well, but it is guidance, as opposed to directives.