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Submission to City Development Plan

Dublin City Development Plan Submission

This is a vital opportunity to create a new vision for our city that meets head-on the local and the global challenges which we face. We need to reimagine our city for a period of transformative change.

Learnings from the Covid Experience

The experience of Covid has crystallised some elements which need to be built into the future planning of our city:

  • Enhancement of our open spaces, seafronts and natural amenities to create more opportunities for public enjoyment in a safe and secure way
  • Consolidation of the opportunity of working from home which improves lifestyle and its sustainability, by planning new supporting structures and the design of physical environments( serviced hubs, play areas, exercise areas etc.)
  • Recognition of gaps in community amenities which must be more effectively delivered for fast growing communities to be more fully integrated( sports provision, neighbourhood security, earlier delivery of amenities and services etc.)
  • The integration of active travel and sustainable transport into every public institution schools, hospitals etc. and into private enterprise
  • The capacity to repurpose our urban villages and central city areas
  • The need to balance more compact development with an enhancement of the quality of building design, of landscaping and of community spaces for integrated living.

Tackling the Climate Crisis

A top priority in the new plan must be to embed changes in response to the Climate Crisis. This will require transformative change: in how we build but also in planning for the repurposing of buildings; in how we travel; in how we heat our homes; in how we use resources and handle waste.

The city must build 30,000 new homes in the next five year period, which must be built in a compact and sustainable manner. This will require better design for quality community living. Arguably, an even greater challenge will be to adapt existing homes and other buildings to break carbon dependency and to increase the efficiency of usage. At present over 80% of homes in Dublin City have an energy rating which is inconsistent with our Climate Action ambitions. The city needs to plan for a wave of retrofitting, concentrating on upgrading large swathes of the older parts of our city in a coordinated campaign.

There is a need to hardwire low carbon dependency into every dimension of city policy and city life. This will require this plan to address adaptation in a way that has never been addressed in a previous plan, which have concentrated on the incremental change in the coming five years, not on transformative change. Speedy planning solutions must be found for challenges such as:-

  • Retrofitting an electric vehicle charging network potentially to every home and business
  • Fitting upgraded insulation for walls, windows and roofs and better heating methods in a retrofitting wave
  • Improving the environment for safe active travel
  • Ensuring every home has access to full waste segregation options
  • Considering the scope for District Heating in all new developments

Policies in all these areas are often characterised by lengthy delays, and complex procedures. While due respect to individual difficulties is necessary, they cannot be confined to move at the pace of the slowest mover.

Confronting the Housing Challenge

The continuing acute shortage of homes across all types of tenancy requires the Council to be innovative in how it facilitates development, both on its own land, on other state-owned land and on private lands. The City Council has not itself had the land bank necessary to Masterplan development to the scale necessary nor with the speed necessary.

The State and the City must forge a new partnership that sees closer integration of planning by each to ensure that communities do not face long gaps before key services are in place. The City must now actively form partnership with the new Land Development Agency, and with professional associations involved in private planning to put in place not just the policy objectives familiar to Development Plans, but also establish the regulatory standards and funded actions needed to make them a reality. There is a need to rezone lands within the M50 in order to ensure compact development. Rezoning should in future carry with it obligations to deliver sustainable and affordable obligations. This will ensure that a high proportion of any windfall gains will serve the common good.

New Models of Compact Living

The existence of a National Planning Framework and  the National Development Plan provides for the first time give grounds for confidence that a new partnership framework can emerge with the necessary impetus for change to bring planning objectives to life. However, that will require government Departments and their agencies delivering services to enter into closer Memoranda of Understanding with the Council  designed to confront the delays which have characterised public investment delivery by the national sectoral agencies preventing the availability of needed services in a timely manner. The model of such understandings must be part of the Development Plan.

It is now clear that building compact living for all family types in a sustainable manner requires a level of upfront planning and investment which is well beyond the capacity of first time buyers’ purchasing power. The ambition of compact living requires new funding models on the supply side. Models of high density without so much high rise which we see in some other European cities must be explored. Up to now the city has allowed the purchasing power of the marketplace alone to drive patterns of development. Now is the opportunity to develop the integrated design and the funding models, so that new developments do not spend the first decade of their existence with only take-aways, bookies and hairdressers.

While Development Plans have traditionally focused on new building, it is clear that even a very successful building programme only adds 1-2% to housing stock each year. In view of both the pressure of new demand and the requirements of Climate Action, we need to examine policy which can promote more effective use of existing building stock. Recent statistics show that 70% of households are in homes that are larger than their needs. This is twice the proportion in the rest of Europe. Among persons over 65, this proportion rises to 92%. Combined with the expectation that the older population is set to grow far more rapidly than any other group, it is clear that the new Plan must now assess how that growing older population can be accommodated in a way that promotes independent living with good access to essential services. This should inform the mix in new developments but also the pattern of renewal of our urban villages which represent a great potential setting. While for many, staying in their existing home is their preference, it is equally the case, that many don’t see any option that preserves their links in the community. There is a need to identify policies that can assist trading down to well appointed alternatives in the heart of communities. To achieve this will require explicit policies in the Development Plan to evaluate the scale of need its location and the strategies which best meet the challenge.

Thriving City Villages

The concept of a “ A City of Villages” has often been advocated as the key to sustainable urban design. However policies have never been sufficiently integrated to deliver that vision. Now is the time to elevate this to be a core element of the Development Plan. There has been a consistent pattern of transformation in retail goods and services, which has seen closures and suboptimal use of space. The Covid crisis has accelerated that change, which if not addressed will see further decay. The key is to plan new hearts in our urban villages and centre city areas where people want to live and spend time. This Development Plan must commit to undertake an urgent audit of our urban centres, to develop their assets, repurpose buildings at risk of falling into disuse, enhance the public realm within. The changing face of retail must be harnessed to make these cores more attractive for living and leisure.

Creating a Circular Economy

A much stronger approach to Waste Management Policy and the enshrining the concept of the Circular Economy is now needed. Some communities have had to put up with an unacceptable level of illegal dumping. Excessive waste materials are being created because of an inadequate regulatory frame work. Huge volumes of waste which could be recycled or composted goes to incineration. Many are denied the full range of segregation facilities, particularly in the compact development settings. Far too many materials which cannot be recycled are still in use. Major change in these patterns must now be created through the plan. The principles of the Circular Economy must inform all Council policies, particularly those governing procurement and planning. The new regulatory obligations, new incentive structures, new facilities and new infrastructural needs of the Circular Economy should be enshrined in specific Objectives of this Development Plan.

Submission to NDP Review

NDP Review

As we exit the Covid crisis, there will be a real risk that elevated levels of current spending will be difficult to roll back. The line of least resistance could be to shy away from a further step up in planned infrastructural investment. That is the opposite of what is now needed and must be explicitly confronted in the NDP Review now underway. 


At the heart of the Review must be a recognition of the need for a major overhaul of our infrastructure to meet the challenges of the future. This entails infrastructural adaptation for Climate Action, for Public Services, for demographic growth and aging, and the facilities and policies to build Human Resource capacity and Enterprise competitiveness in our key sectors. The Ireland of 2040 must become a very different place. 


Project 2040 was a very ambitious plan to reshape the pattern of population growth in a regionally balanced and sustainable way. However, with the new pressures of a post Covid response, a higher Climate ambition, we need to see transformative change frontloaded. This in turn requires a more ambitious NDP. To inspire the confidence of those who buy Irish Debt, there must be some very clear objectives set out of what infrastructural changes are required in these areas; how they are integral to a prosperous, sustainable, competitive, stable society; and how they can optimally be funded.

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