Joint Committee on Housing, Local Government and Heritage debate -
Tuesday, 5 Nov 2024

I welcome everybody to the meeting, the purpose of which is to discuss the national planning framework further. From the Climate Change Advisory Council, I welcome: Professor Edgar Morgenroth, council member and professor of economics at DCU; Mr. George Hussey, secretariat manager; and Ms Gina Kelly, scientific officer. We have received their opening statement. From the Department of Housing, Local Government and Heritage, I welcome: Mr. Paul Hogan, assistant secretary in the planning division; Ms Claragh Mulhern, acting principal planning advisor; Ms Alma Walsh, senior planning advisor; and Mr. David Dalton, principal officer.

The national planning framework is the document that sits at the pinnacle of our planning system and everything else emanates from it with regard to regional planning, county development plans and local area plans. It is a critical piece of work which is in progress at present.

This is most likely the last public meeting of the committee in this Dáil term. I thank our secretariat team for all of the work they have done for us over the past four and a half years. I thank Anne-Marie, Tommy, Seamus and Sue. We would not have got through the considerable workload that we had without their work and support. I acknowledge the co-operation of members through what most people would agree was a fairly intense four and a half years of legislating. This has been quite a collegiate committee, and we have done some good work.

I invite Professor Morgenroth to make his opening statement.

I thank the committee for the opportunity to attend and to speak on the national planning framework. The Climate Change Advisory Council is an independent advisory body tasked with assessing and advising on how Ireland can achieve the transition to a climate-resilient, biodiversity-rich, environmentally sustainable and climate-neutral economy.

The council was invited to a discussion with the committee in September 2023 on the review of the national planning framework, and the secretariat to the council, of which Mr. Hussey and Ms Kelly are staff, has attended meetings of the planning advisory forum throughout 2024. The council published the eighth and final part of its annual review in October in which it highlighted the need for urgency when it comes to concluding the national planning framework review this year. We reiterate this message to the committee today, given the dependence of many sectors on planning policy to achieve decarbonisation and adaptation objectives.

Planning is fundamental to the fulfilment of national climate goals and the council considers the NPF, including regional targets for renewable electricity generation deployment, to be a pivotal policy document.

This is a critical policy area that the council has consistently highlighted the importance of. In its 2023 annual review, the council noted that planning reform will be required to remove barriers to policy implementation across a number of sectors with a need for the new national planning framework, in particular, to better reflect our climate ambitions. The council also wrote to the heads of Government in May 2023 in relation to a number of elements of the planning system focusing on deployment of renewable electricity, spatial development and resourcing.

In September, the council wrote to the Minister for Housing, Local Government and Heritage to express its views on the draft revision to the NPF and to emphasise a number of areas where the plan could impact on achieving Ireland’s climate targets. I will set these out briefly. To ensure that Ireland reaches its full renewable energy potential, the council stressed the importance of providing maximum clarity to local authorities on their contributions to national targets. It also urged the finalisation of the long overdue wind energy guidelines at the earliest opportunity. The council urged a stronger focus on managing development to ensure genuine compact growth. This includes setting more ambitious targets, prioritising the use of brownfield and infill sites, urban regeneration and finalising the rural housing guidelines that align with overall targets.

The letter highlighted the need to enable and support the roll-out of district heating in tandem with the roll-out of other low-carbon heat sources. An increased focus on transport-oriented development within the national planning framework is necessary to maximise the benefits of increased compact growth. The role of the National Transport Authority in planning for transport delivery should be enhanced across Ireland’s cities. The council highlighted the need for a renewed focus on climate resilience and biodiversity, and it reiterated its call for a detailed coastal management plan to enable local authorities to begin planning for the impacts of sea level rise. Additionally, there needs to be a greater emphasis on nature-based solutions and increased awareness of the biodiversity impacts of development more generally. Finally, the Government must regularly measure and report on progress across these and other indicators.

It is imperative that the new national planning framework is adopted before the dissolution of the Dáil or at the earliest possible date following the election, which looks like it is going to be called soon. As set out in our opening statement to this committee in 2023, once the NPF review has concluded, a number of parties across the broader system will be critical to ensure implementation aligns with our climate goals. This will, for example, include the further development of regional spatial and economic strategies by the regional assemblies. The Office of the Planning Regulator will also play a crucial role in the assessment of local authority and regional assembly statutory plans to ensure alignment with the objectives of the revised NPF and to ensure that plans provide for planning and sustainable development. Strong political support at all levels will be required to ensure there is strong oversight and implementation of the principles of the NPF. Community engagement will also be essential.

We are in year 4 of the first carbon budget. While recent reductions in emissions have brought Ireland closer to achieving its first carbon budget, the lack of significant progress makes it unlikely that Ireland will meet its second carbon budget in the period from 2026 to 2030. The NPF will have a critical role in enabling the transition and must be implemented swiftly. Insofar as possible at this stage of finalisation, the council recommends that the current draft should be further strengthened to support the expansion of wind and solar generation. As set out in the council’s 2024 cross-sectoral review, this should address key areas such as ensuring that Ireland’s full renewables potential is achieved; managing development for genuine compact growth to help to enable climate solutions such as district heating, active travel modes and public transport; and preparing for the impacts of climate change such as sea level rise while further developing the potential for the implementation of nature-based solutions.

The council is happy to assist this committee in supporting the achievement of Ireland’s climate objectives and provide any further assistance or advice as required. I look forward to our discussions today.

We welcome this opportunity to provide an update to members of the committee on the draft first revision of the NPF since our last engagement with the committee on 11 July. I will start with the issue of public consultation. When the Department engaged with this committee in July, the draft revised national planning framework had just been published for public consultation. The national consultation period commenced on 10 July 2024 for a nine-week period and concluded on 12 September. Members of the public were invited to make a submission on the first draft revision of the NPF document and accompanying environmental assessments via the online consultation portal and by post. The online consultation portal was the primary interface for the public to make submissions on the draft revised NPF based on the fact that it provided a convenient, low-cost, transparent and efficient means of public participation to drive increased public engagement.

An information campaign raised awareness of the consultation process to encourage the public to engage with the draft revision. This campaign included national and regional newspaper advertisements, a national and regional radio campaign and digital and social media advertising. Cumulatively, these channels of communication ensured that notice of the revision process reached the widest possible audience to ensure the public were made aware of this consultation and to actively encourage participation. A total of 272 submissions were received on the draft revised NPF. More than 90% of all submissions made were received via the online consultation portal.

I turn now to the key issues raised in the public consultation. The number of submissions were received. The range of topics raised in the submissions meant some matters raised fell outside the scope of the NPF as a national policy framework document. This was particularly true where the focus of submissions related to investment, expenditure, delivery and inclusion concerning specific projects, notably infrastructural projects. The core thematic areas raised, with the majority of submissions received, can be summarised under various headings, the first of which is balanced regional development. A significant number of submissions addressed the core objective of the NPF relating to balanced regional development, which is concerned with achieving more regionally balanced population growth, split roughly 50:50 between the eastern and midlands region and the rest of the country, namely, the southern region and the northern and western region.

The strategy seeks to promote continued growth in the Eastern and Midland Regional Assembly area, but with substantial growth also occurring in the Southern Regional Assembly and Northern and Western Regional Assembly areas. Divergent opinions were expressed, with some submissions arguing that the strategy could result in a downgrading of Dublin and its hinterland at the expense of other regions that could negatively affect economic development and, therefore, damage the national interest. Other submissions argued in favour of an increased share for the other regions as a means to grow the regional cities to cities of scale and thereby provide viable alternatives to Dublin. A wide range of submissions were also received relating to specific population targets for cities and regions, with contrasting views expressed, including, for example, that the targets for Dublin were not ambitious enough.

Other submissions argued for a much greater emphasis on the regional cities. A number of submissions argued that this key objective of the strategy is not being achieved having regard to the results of the 2022 census and other indicators and that a range of additional measures will be required if the objective is to be delivered.

On population and housing targets, a significant number of submissions addressed the issue of population and housing. Many submissions made reference to overall housing targets, with some suggesting that a notional target of 50,000 residential units underestimates the projected need and that the issue of pent-up demand will result in a significantly higher target. Various targets were suggested in submissions. Most suggested 60,000 to 70,000 homes per annum but some ranged to 100,000 per annum. Many submissions offered alternative assumptions to those underpinning the ESRI population and housing projections with regard to household size and housing obsolescence.

On zoned land requirements, a number of submissions asserted that there is an underprovision of zoned serviced land in parts of the country, particularly in the eastern region, and that the revised NPF should indicate to local authorities that significant additional rezoning will be required to meet housing demand. It was submitted that the biggest capacity constraints for accelerated delivery of housing are capacity constraints in the supply of zoned land with infrastructure and planning.

With regard to implementation and infrastructure delivery, a substantial number of submissions raised the matter of investment in and delivery of infrastructure, with particular regard to transport, water and wastewater services. Strong representations were made for specific projects at local, regional and national scale. The key enablers listed in the draft revised NPF for the cities were also the focus of a number of submissions. From a regional development perspective, submissions set out the differential in expenditure between the regions as a means to highlight the need for specific targeted investment to address identified infrastructure gaps and to support the regions in reaching the ambitious targets set out for growth, particularly for the four regional cities.

A significant number of submissions addressed the issue of compact growth targets for urban areas, with particular regard to delivery against these targets. Some submissions suggested that the NPF overemphasises compact growth when the country needs a mixture of compact growth in town and city centres and more traditional forms of housing at the periphery of our towns and cities, especially those towns and cities with high levels of employment. Other submissions sought more ambition on compact growth in the interests of climate change mitigation.

On climate and the environment, a substantial number of submissions welcomed and supported the additional policies and comprehensive update regarding the climate transition in the draft revised NPF. The importance of ensuring that climate action is integrated into the planning system was specified in a number of submissions. Calls were also made to ensure the requisite procedural and funding arrangements are in place to enable delivery on the climate targets.

On foot of reviewing the submissions received, a draft schedule of amendments was agreed by the Government to be progressed this morning, 5 November 2024. It is not subject to environmental assessment. The majority of the proposed amendments relate to the inclusion or deletion of text to address minor modifications, clarifications and updates to the main body of the document. One example is the updating of the reference to the all-island strategic rail review, which was published since the draft revised NPF itself was published. A number of specific amendments to some of the national policy objectives are also to be included, for example, a specific NPO relating to flood risk management and another to develop and implement a new programme of monitoring of the implementation of the NPF with a focus on monitoring outcomes relative to the key strategic objectives of the NPF, including more balanced regional development, city-based growth, compact growth and infrastructure delivery. More generally, the theme of infrastructure and implementation across the submissions reaffirms the significant role of the national development plan in enabling the implementation of the NPF and the need for that collaboration to continue. However, the critical need to continue the alignment of NPF policy with expenditure is not solely confined to the NDP. There is a broader requirement for the NPF strategy to be considered more centrally to decision-making processes across government, the relevant State agencies and other bodies.

With regard to the next steps, further to the conclusion of the environmental assessments, which will include strategic environmental assessment, a Natura impact statement, an appropriate assessment determination and a strategic flood risk assessment, the final draft revised national planning framework and associated environmental reports will require the approval of the Government to submit them to the Houses of the Oireachtas for the approval of both Houses before the final revised national planning framework can be published, in accordance with section 20C of the Planning and Development Act 2000, as amended. Once finalised, the revised national planning framework will be incorporated into the regional spatial and economic strategies and city and county development plans. The proposed amendments have been drafted to build on and update the draft revised NPF strategy while retaining many of the key elements of the NPF such as regional balance, city-focused growth and the continued development of rural communities. We thank the members of the committee for their time and engagement.

I thank Mr. Hogan very much. May I clarify something? The draft went out for public consultation and that process is now finished. Amendments have been made to the draft that went out. These are currently undergoing SEAs or environmental assessments. What is the next step? What happens when those assessments are done? Does it go back out to public consultation if it is significantly amended?

No. Right now, we plan to publish the amendments. That was agreed by the Government this morning. The intention is to issue an updated draft document that incorporates those amendments. That will be published this week. Given likely events, it will be for an incoming government to finally determine the NPF, assuming it is in accordance with the legislation under which the process commenced, the 2000 Act. That requires the Government to decide to finalise the document with the full environmental assessments completed and to then bring the document to the Oireachtas. I presume that will involve engagement with a future committee at that stage.

I thank everybody for their presentations. While today's session is obviously primarily on the national planning framework and climate change, given that the Cabinet agreed the revised housing targets and that those targets were the subject of my last exchange with Mr. Hogan when he was with us on the national planning framework in July, I will start with some questions on that area.

It is interesting that in his description of the public consultation, Mr. Hogan noted that there were a lot of submissions indicating that an annual average target of 50,000 was too low and suggesting targets of 60,000 to 70,000, which is in line with the recommendations of the Housing Commission. Looking at the figures agreed by the Cabinet today - 41,000 new homes in 2025, 43,000 in 2026 and 48,000 in 2027 - it is really only in 2027 or early 2028 that the NPF proposes to move beyond the emerging demand identified by the ESRI. There is really no consideration of unmet demand or the deficit outlined by the Housing Commission until we hit 2028 and 2029. Taking just those first five years, an annual average of 50,000 will not even be reached. It will be 48,600. I just do not understand the rationale behind those figures.

I will pick up where we left off in July. When I asked Mr. Hogan to justify an annual average of 50,000, he seemed to indicate that this was based on the 44,000 the ESRI assessed to be the emerging demand and a reasonable assessment of unmet demand. This is even poorer than our previous discussion in its attention to unmet demand. What methodology was followed to come up with these numbers? Why were the Housing Commission's mid-range recommendations of approximately 15,000 for unmet demand not taken on board? It is clear a decision was taken not to include it. I am not going to have a row with Mr. Hogan about whether it should or should not have been included. I just want to understand why we have the figures we now have because, for every year unmet demand is not met, that unmet demand grows.

Therefore, we could be in a situation where, if the targets agreed by Cabinet today become the targets of the future Government and are met, unmet demand will continue to grow certainly until the second half of the next term of the Government and probably right to the end. That is very concerning. I am at a loss to understand the rationale behind the figures. That is the first question.

The first thing I would say is there are two elements to this. The first is the national planning framework to 2040. The national planning framework to 2040, as published, refers to approximately 50,000 because that was where our calculations were at when drafting it. Since then, we have worked with our housing policy colleagues to further assess and estimate what we believe to be unmet demand. That is based on the methodology that I will ask my colleague, Mr. David Dalton, to come in on in a minute.

The decision to publish figures with regard to housing supply to 2030 is separate to the national planning framework. The national planning framework is based on an annual average over the full period to 2040. We have firmed up on our assessment of that figure to just under 54,000 over the full period, and as the Deputy rightly said, that has to be worked up to. As you are working up to it, clearly there is a continuing unmet demand that has to be addressed then post achieving the target. We are looking at the NPF as an overarching national document to cover the full period. Once finalised, that will then enable the targets to be broken down for local government delivery or across the different planning authorities, while also factoring in the range of sources of housing, for example, vacancies.

Obviously, I understand the difference between setting a macro target to 2040 and then what an individual Government does with regard to how it meets those targets within a five-year cycle. Given the statutory importance of the national planning framework, and given the fact that if you are not meeting unmet demand over a number of years unmet demand grows and therefore what you will need is your annualised average to be larger going forward, would it not make more sense for the national planning framework to speak to that directly? The Housing Commission is very clear because it goes out to 2037 but it wants the deficit frontloaded in the first five, six or seven years. I assume the bulk of the submissions that Mr. Hogan made reference to take a similar view. It seems to me that by not actually naming in that section of the national planning framework review document not only what the target should be on average out to 2050 but that it needs to be frontloaded, you are creating a situation where unmet demand will continue to grow. Even if you meet that 50,000, we will not be in a much better position in terms of meeting housing need. Clearly, a decision was taken not to support the recommendations of the commission. I would have thought the right place for that to be was actually in the planning framework itself.

I will get to that in a minute but the first thing I would say is this is a national target. Second is the fact that the Government has decided to set a target within that for the first period to 2030. That builds on the momentum of growth in terms of housing numbers to date, and it reflects the fact that we are starting from a particular point to get to 60,000 new homes by 2030.

To address the gap the Deputy has identified, it will mean maintaining at least 60,000 units for most of the decade. It is quite an ambitious ramp-up to maintain or sustain an ambitious target.

That would give you the average of 54,000 but we have to reflect on the fact that we have come from a relatively low base. There has been considerable momentum with respect to the build-up every year. Housing numbers have grown year on year, and that is projected to continue. Certainly, the projections for the next few years are strong.

In case we do not get to the detail of this, Mr. Hogan mentioned there was a methodology with regard to both the 50,000 but also in the numbers we have heard today. Is that a methodology Mr. Hogan can share with this committee in writing before the Dáil is dissolved later this week? A lot of us really want to try and understand this. When we read the commission's report, the methodology is set out. When we read the ESRI report, the methodology is set out. We have no idea, either in the NPF review or in the leaks to the newspapers today - nothing has been published by the Department so far - what the methodology is for the figures in front of us for this discussion. Can that be shared with us in writing before Thursday?

As the Deputy knows, we have taken a very much evidence-based approach to the development of the targets. It is based largely on the ESRI research and modelling on population growth and structural demand. That said, we did have a very strong eye to the Housing Commission's analysis and its estimation of unmet demand, which is somewhere between 212,000 and 256,000.

We presented a range of scenarios to the Minister and to the Government based on the 12 scenarios that were presented by the ESRI. The Government decided to choose that scenario which it felt was ambitious but the most credible over that period from 2025-----

It actually chose the high migration, high obsolescence, low household size. We did that for the very reason that we felt it encompasses a very significant element of the unmet demand that needs to be delivered over the period. If you take any of the constant household size scenarios and you then compare that to the low household size scenarios, that gives you a difference of about 170,000 households. There is an element of unmet demand. Not all of that equates to unmet demand because household size will change as the population ages naturally. An element of that 170,000 is unmet demand, and probably a very significant element of it.

We also have a proxy sense check, which we think is around 110,000 at the lower end. It looks at the level of undersupply we believe has resulted since 2017, plus the number of homeless households, which is currently in and around 8,000 to 9,000, plus those households that are overcrowded and living with others. That gives us around 110,000 at the bottom end. Somewhere between that 110,000 and 170,000 we have a figure for unmet demand, and that is factored into the scenario that the Government has based its housing target profile on for 2025 to 2030.

It is not strictly correct that it does not account for unmet demand. What the ESRI said was that it did not explicitly examine it and it was not tasked with explicitly examining it. However, there is an element of unmet demand incorporated into the projections. It has to be because if we get down to that low household size of 2.44, which we have chosen-----

The difference is between 1.9 household size, which is what the Housing Commission has based it on. That is just based on a set of assumptions. There is no analysis or evidence base behind that. We are taking a household size of, I think, 2.44. That is evidence-based and based on research by the ESRI, which has also been peer-reviewed and published.

I thank Deputy Ó Broin. I want to clarify something. With regard to the housing target, it is not a cap as such, it is a target. We have seen in Housing for All where the targets have been achieved and over. Where you are setting out that target, it is not saying that it shall be 50,000 and only that.

Many things can change in an economy, such as interest, capacity and household sizes. To fixate on just one figure is probably incorrect. Would that be correct?

Yes, that would be correct. It also reflects the capacity we think is within the sector to deliver and not just the current capacity. The observed current capacity is an additional 3,000 units per year on average over the lifetime. We are setting out a range of targets that are actually an increase of 4,500 on them. That is a 50% increase. To get to that 60,000 the Department of further and higher education has done an analysis of the skills needed. I think it is an increase of around 50% in the skilled workforce required to deliver that. It is a very significant step up. The targets for 2025 and 2026 reflect a modest start and then a very significant increase thereafter. That reflects the time needed to make that step change in the measures needed to get there.

I will focus more on that last conversation and also Mr. Hogan’s opening statement. The issues raised in the submission included capacity constraints and the supply of zoned land. In light of the conversation we had about housing targets – we are well aware of the hierarchy of the MPF down to the RSES and to the local authorities' development plans and we are also acutely aware of demand on the ground – it would be helpful if the Department could set out the timeline from now and where that hierarchy stands for feeding into local authority development plans. That has to happen sooner rather than later. I appreciate the way we have structured it. It is important we have that structure of national to regional to local but there is that capacity constraint. I know we have had this discussion about a different view of availability of zoned land but I feel we need more zoned land not willy-nilly everywhere but targeted in our growth centres and the ability of our towns and villages to grow. Where are we from today, 5 November?

It is important to point out that the decision today provides a degree of clarity for anyone involved in land, building and housing. It does move things on. It points to the general direction for the future. It enables an incoming government to address the MPF relatively quickly should it wish to do so.

It is important to say that there probably will be a need for more zoned land because we are looking at bigger targets over a longer period in every case for county development plans now that the Planning Act has been enacted and will soon be commenced, or certainly next year. There is a cascade through the planning system from finalisation of the national planning framework through the regional strategies to the local county development plans. There is time for most county development plans because the current six-year plans do not start to run out for the bulk of local authorities until 2026 or 2027 or thereabouts. Obviously they will have to start work in some cases before that. One of the items that the Planning and Development Act includes is an ability for expedited changes to be given effect so there may be instances where there is a need for certain things to be done more quickly. I suggest, without any specific identification of locations, that if there is a situation where a clear level of demand is identified for an area and there is patently not enough zoned land, it may be that the Minister could issue some sort of expedited instruction – I am not sure if the term is a direction – to the local authority to consider zoning more land. Zoning is not the only means or source of scope for housing. People are obviously very interested in that but there are also very significant objectives in the MPF and other documents with regard to vacancy, re-use of existing brownfield sites, transport and intensification of use. There is a lot of scope for further consideration that the planning system will look at.

I agree. I will not talk about any specific area but we all know there are areas in the country without sufficient zoned land. Is Mr. Hogan saying for that to happen without following through MPF into RSES, into local development plans, the best case is 12 to 18 months out the other side of the process? Is that fair?

The other area I spoke about was the metropolitan area strategic plans, MASPs, and how they were designated. Originally they were handed down by the Department and the regional assemblies did not have scope to be able to adjust those. This is a bone of contention for me and rightly so. It is not a parochial issue. It relates to Waterford and how Tramore, which is 8 km out the road, is not included in the Waterford MASP. That is incredible when one looks at Cork, Galway and Limerick which go far in excess of 8 km, 10 km and 15 km in some places. That feeds into the transport elements which have to be factored into planning. To only look at the city and suburbs and not looking at Tramore which is a de facto suburb of Waterford city is incredible to me. Is that addressed or will it be addressed going into this process? That is so important for me.

I thank the Senator for his question. It is something that was raised at our engagement in July. The background, as the Senator will be familiar with, is that the MASP boundaries and areas more generally were formed on the basis of a particular methodology that is based on the OECD definition and in particular mapping the commuter patterns within a city area where they are greater than 50%. The POWSCAR data we have from the CSO in 2016 informed the initial boundaries that were prepared for the three cities of Waterford, Limerick and Galway. The Cork city boundary had already been established as had the Dublin one prior to that. An exercise was undertaken in conjunction with officials within the regional assemblies and with the Department around preparing the MASP boundary and drafting those on the basis of that particular methodology. Further to our engagement in July, we have undertaken some further research to examine the 2022 POWSCAR data. Because of the time the census was undertaken and the certain element of lockdown associated with remote working and blended working was in force, the snapshot from the 2022 POWSCAR data indicates a contraction of some of those EDs which are now less than 50%.

Like I said, it is a snapshot so we have to consider that in the round because initially the MASP boundaries were primarily informed by that particular methodology around the functional urban area and then consideration around density of the existing settlement of other towns and villages within the catchment of the cities. Importantly for the NPF and where it gives real effect to the metropolitan area strategic plan, MASP, and what is has provided for is to plan for the five cities through the regional spatial and economic strategies and that is one area the regional assemblies have included in their adopted regional spatial and economic strategies, RSESs. The role of the NPF is not necessarily to now amend those boundaries on the basis of that information because the function for that lies with the regional assemblies.

The Southern Regional Assembly sat in this very room in the context of the planning Bill and stated on the record of the House that it felt the Tramore area should absolutely be in the Waterford metropolitan area strategic plan. Is Ms Walsh saying the regional assemblies will have the ability to be able to do that then?

The regional assemblies, in the preparation of their RSESs, will be informed by an evidence-base to make that decision. They have the capacity to consider it. Obviously, the MASPS are at an early stage of implementation, more generally, and because the number of those across the three regional spatial and economic strategies being adopted in 2020 and 2021, we are only now really able to see how they are given effect to. There are questions asked of the cities which has become apparent through the revision process in terms of the level of ambition and the actual additional measures that need to be taken to support the cities.

I am not hearing that the regional assemblies do have the ability to be able to make the change and I am not hearing from the witness that she will say that such a common sense change should be made in this instance. In my view, it was an error that it was never included in the first place. Anyone who has any knowledge of Waterford knows that Tramore essentially operates as a suburb of Waterford city. For Tramore not to be included in the MASP, for Ms Walsh to say now that she will not stipulate it nor does the regional assembly have the ability to make that decision, what I hear from Ms Walsh's response and correct me if I am wrong, is that the existing MASP remains.

I think the Department certainly supports an evidence-based approach to any policy changes that need to be made to the RSES, inclusive of the MASP boundaries. However, as I have said from our initial analysis, the place of work, school or college census of anonymised records, POWSCAR, data from 2022 is indicating a different scenario-----

I love what Ms Walsh says about an evidence-based approach. I will keep that line because it is right, it is correct and it is consistent. I was interested to see that engagement there and how Ms Walsh stuck to the line so I fully agree with her on that. These are funny times, in Parliament and in this committee. We are now discussing these issues, which are important. I do not have many question but I thank the Climate Change Advisory Council for its input. We might come back to the Climate Change Advisory Council regarding the critical and important role it sees for the national planning regulator.

First, I turn to the Department. I welcome the Department officials. We all know of the importance of the national planning framework and we have debated this inside-out and upside-down. We have had debates in here on the new Planning and Development Bill. We are literally exhausted. I have been a member of this committee for two terms so it has been for a long time. I have not lost my enthusiasm for it but we have been talking about planning for a long time. I recognise the importance of a strong economy, building competitiveness, innovation, productivity and all of that. That is really important in a society and critical to proper planning and sustainable development going forward.

I sit on the Oireachtas Joint Committee for Agriculture, Food and the Marine and I am always conscious we need to strengthen rural economies and communities and that is something we might have somewhat lost. I have not seen all of the submissions. If I am right, I understand the submissions from the Department will be published. Will Mr. Hogan come back to me on that? That is important because what we are hearing from the stakeholders who advocate for the strengthening of rural communities and economies, which go hand in hand, is that it is about quality of life issues. It is about diversity of the rural areas and all of that. In that context I want to yet again use the opportunity to raise rural planning guidelines. They have been going on for years. This very morning I received a letter from the Minister, Deputy Darragh O'Brien, referring to correspondence he received on 30 November, 2024 about rural housing guidelines. He stated:

The draft guidelines are subject to legal review and Ministerial approval, following which it is intended that they would be published for a period of public consultation. The current Sustainable Rural Housing Guidelines for local authorities 2005 continue to have effect and remain in place until advised otherwise ...

The witnesses may have very well have written that or had some act or part drafting it. I do not know, and I do not need to know. What it illustrates for years the promises we have had for years. We have had officials in here week in and week out and we have had Ministers write to us to tell us about rural housing guidelines. We are now heading into a general election but rural communities want to know what is happening about rural planning guidelines. They want to build homes for their young people. They want sustainable, rural communities. They want their siblings to live close by them, with them, near to them. They want to see their parishes, schools and sports clubs survive. They want to go hand in hand and make their rural communities, their land of origin where they are deeply rooted, sustainable. Despite all of the talk we cannot get a commitment from anyone in government since 2005, other than to tell us the rural planning guidelines are being looked at and being drafted. The other side of it is, sure it is the terrible oul' Greens who are holding this up, no disrespect to the Chair, and I do not buy that at all but that is the line, off the record and down in the Customs House, that the Department can do nothing but that we will be out of that loop soon. That is the unofficial talk.

Will the witnesses comment on that? There are rural communities, TDs and Senators who will be going out door-to-door in the coming days and weeks and they will be put to it. The IFA, ICMSA and farm organisations have asked for this. All groups have said privately here that it should happen but it has not happened. Why has it not happened and is there a place for all of that in here?

I welcome the idea that the submissions will be published. We are somewhat in a vacuum here today in that the Government made decisions this morning and here we are meeting this afternoon. We do not really have details and I agree with Deputy Ó Broin on that. We are at a slight disadvantage and vacuum on that.

The Climate Change Advisory Council referenced that the Office of the Planning Regulator will also play a critical role and it is seen as being important in terms of assessing the local and regional plans but more importantly ensuring these plans provide the sustainable development and key objectives. Will the Climate Change Advisory Council representatives touch on that because I see they are sitting there quietly and I thought I had better ask a question?

Will Mr. Hogan touch on the regional planning guidelines? It is not tenable and it is not acceptable that we should be fobbed off for years and years about this. That might have been facilitated and aided by the politicos around but the people of this country who live in rural communities will now have an opportunity on their doors to demand to know what is happening there.

Chapter 5 certainly enables rural development, including rural housing. It sets up the possibility of having guidelines, or it will be a national planning statement for rural areas or rural housing, or for both as the case may be. There is nothing in the national planning framework which precludes rural housing. Certainly, over the course of the six year lifetime of the NPF to date, approximately 5,000 rural houses have been completed every year. It has been a fairly consistent element of housing supply in Ireland and has been spread across rural areas across throughout the country. Every local authority has a rural housing policy in its development plan. Admittedly, there may be some inconsistencies and differences of approach. If we were to publish rural housing guidelines, we would seek to encourage a degree of fairness and consistency across the board which would be an objective. This will be a matter for an incoming government at this stage.

We now know from this confirmation, yet again - which is one of about 50 letters I have in my office - that these guidelines are subject to legal review. We have been talking about this review for a long time, and ministerial approval. The Minister of course did move after I had put the pressure on and asked that they go to a period of public consultation. The Minister has now added the period of public consultation. Hang on, however, because the Government is coming to the end of its tether. It is finished and out of here in a few days time. This has been on the Minister's desk and has been on Mr. Hogan's and the Department's desk. Can Mr. Hogan tell me here in this committee today what he knows of these current ministerial guidelines that are sitting on the Minister's desk waiting for approval, given Mr. Hogan's very significant and important role and, no doubt a greater role in the future within the Department?

I thank Senator Boyhan very much for the question. In looking at the national planning framework review, one element we were looking at, across a number of elements such as sustainable transport, sustainable heating and also the deployment of renewable electricity, was on the side of implementation. We were acknowledging the critical role that the Office of Planning Regulator, OPR, would play there in implementation and in ensuring consistency across the regional and local authority plans but also in a broader sense, in capacity-building in the sector. This is some of the important research that it has carried out in this space also.

One area, for example, recently was a very useful report on brownfield and infill development with some recommendations in order to ensure land activation and consolidation. We were pointing to a number of issues there.

I thank Ms Kelly very much.

Just before I go, I want to take this opportunity at what will possibly be our last meeting to acknowledge the enormous work the Cathaoirleach has done in leading this committee which is exceptionally hard working. There is no question but that he has given it his all and I want to put that on the record. I know that others will join me in that. It has been a very busy committee and I want to thank, in particular, the officials from the Department who have really engaged with us. We have got to know them, in a way, at this stage over a long period. I thank the Cathaoirleach for his hands-on approach, his leadership, direction and tight control where he always kept us in line and focused on what was proper planning and sustainable development, local government and, of course, heritage which was also very important.

I do not want to let this opportunity go to also thank the committee clerk and her team that ably serve the Cathaoirleach and this committee. We could simply not have done this job without them as it was an enormous task, with an equally enormous amount of correspondence and legislation to be read, to be in touch and to be going on with. We are in very regular contact and it is an exceptionally busy committee that has met twice today and three times in a week. Well done to all of the people. We have always been courteous and have got on reasonably well, kept to the focus and have really tried to do our best to deliver on what really is one of the most challenging areas for the Government which is the delivery of housing. It is also about proper planning and sustainable development.

As well as living in an economy, we live in an environment which has to be protected, minded and nurtured. That has been the key element of the Cathaoirleach's work, his leadership and the work of this committee. I just want to thank all involved.

----- as they may wonder why I have been in the basement for the past four years.

The next speaking slot is my own. I want to turn to the Climate Change Advisory Council first. It states that it is critical to complete this very important document this year. Obviously, it will not be passed in this Oireachtas term as we are going into an election. There will be the formation of a government and a programme for government. Perhaps, a different government comes back which has different ideas on a national planning framework, and it all goes back into the mix again. The critical areas which the Climate Change Advisory Council has been concentrating on are compact growth, renewable energies and it also highlights a lack of definition of transport-oriented development, TOD, in the national planning framework document. We had long discussions on TOD in the planning Bill, where I had put forward a definition of TOD. Would the Climate Change Advisory Council share with the committee what it considers TOD to be? There is one train of thought which says it should be high-capacity, high frequency, high level and almost heavy rail transit whereas others would be of the view that it can represent anything from safe walking ways, cycling and active travel and, of course, public transport buses and trains, etc. Can the council share with the committee its definition of what TOD should be?

Yes, I can take that question. We would have been looking at examples of implementation of transport-oriented development and looked firstly at the National Economic and Social Council, NESC, study and the definition it uses, which is a good starting point. Then we would have looked at the application of that in the first study that was carried out looking at the four local authorities in the Dublin region with regard to specific projects which could be identified there for the progression of transport-oriented development. That considered multiple types of transport looking at BusConnects as well as high-capacity transport corridors. One critical element of it is not just that the public transport is there, or in planning, but that it can be delivered in tandem with those developments in a timely fashion so that transport behaviours, unsustainable versus sustainable, can have time to be bed in. The NESC definition is a good starting point. The Cathaoireach's point in looking at broader active travel, permeability and at active travel infrastructure is also useful.

Another critical piece we would see is looking at the monitoring of the implementation of transport-oriented development and at how we can use the tools that are available through Central Statistics Office, CSO, data, for example, regarding access to services and how long it takes to access services from different areas. We also look at tools and developments by the likes of the National Transport Authority, NTA, to look at accessibility to public transport in areas. There would be a few elements we would bring in there to it. Our point in recommending a definition is included in the revised NPF was simply to assist with when that feeds through into the regional and local strategies, and that that can help with decision-making if it is quantifiable and is easier to define.

I know that the Department of Transport has done TOD work also. If a definition of TOD were to be produced, an official government-wide accepted definition, is it best utilised in the renewable energy support schemes and then into the development plans? Is that where the Climate Change Advisory Council is coming from?

One of the criticisms about transport planning and land use planning is that sometimes they do not align with each other, where one has the National Transport Authority, NTA, responsible for, for example, the greater Dublin area transport strategy.

There are development plans as well. The planners, the local authorities and the councillors do not have control over transport capacity or transport delivery. Do you see that there has been better alignment in recent years in transport planning and land use planning?

One of the things the council pointed to in its sectoral review of the transport sector this year was the expansion of the statutory role of the NTA in metropolitan area transport strategies and expansion to the other cities. We have seen the development of transport plans on a non-statutory basis that, I think, has improved that alignment. We think that is a critical action to progress within the climate action plan to expand that legislative basis, to ensure that role is there for the interaction between metropolitan area strategic plans and transport plans.

As regards the wind energy guidelines, I do not want to have a repeat of the conversation on rural housing that Senator Boyhan spoke about. I will make the point, however, on rural housing that the Planning Regulator issued its report in 2021 or 2022, highlighting that more than a quarter - I think it was 27% - of housing planning permissions were for one-off housing, so it is obviously not as problematic in some parts of the country as some people make it out to be. I think the Planning Regulator, to paraphrase it, said it is a worrying trend. Those rural housing guidelines would be very welcome as soon as possible to give clarity to that situation.

The witnesses talk about more ambitious targets for compact growth. At the moment, we are saying in the national planning framework that about 40% would be within the settlement boundaries as regards compact growth. Did the witnesses have in mind a figure that would be greater? I think that is not an ambitious enough target. We need to have more compact growth. It will be problematic because people do not like blocks of stuff being built around them once they are settled in an area, and we will have to accept that. We cannot make more land and we cannot have continuous sprawl. We know that cannot work for climate reasons, social reasons and many other reasons. Did the witnesses have a figure in mind or was it just that they felt it was not ambitious enough and they were going to leave it open-ended?

No, I do not have a figure in mind. Rather, it certainly ought to be more ambitious than the current numbers suggest. The current CSO data seems to suggest that, in fact, we are exceeding those targets in any event. For any objective to be ambitious, it should be a stretch from where we were rather than allowing us to fall back to some position which we might have been in maybe ten years ago, when there was a much lower level of overall development.

In terms of the new built-up areas, the CSO data for new dwelling completions show something of the order of 70% in the past year - I am sorry; I cannot remember the precise number - were within one of the many built-up areas there. We do not have a specific figure in mind but we do have a body of evidence that suggests we need to be pushing harder for higher levels. There are a very significant number of built-up areas in the CSO definition. I think there are 860-something built-up areas in the definition.

I would agree with that. The witnesses talk about missing the carbon budgets for the second carbon budget. Despite almost achieving the 7% cut this year and in the first quarter, I think we see a 2.2% cut. I know you cannot extrapolate that out of the four quarters to say we will reach 8.8% because that is not the way it works, but it is certainly heading in the right direction, despite a growing population, a booming economy and many people saying it could not be done. It is mentioned in the opening statement that there is a lack of significant progress in certain areas. Will the witnesses outline those areas for me? I know agriculture has managed to cut to some extent. Energy has cut to a certain extent for various reasons. Transport is still problematic.

Transport is probably the most problematic of them all in the sense it has been growing since returning to relatively normal post-Covid practices. Even in the past year and in that quarterly update from the EPA, it was still seeing growth in transport emissions at this stage, so it is an unavoidable conclusion for us to link these two issues of planning and transport together. Despite our best efforts and despite the gradual decarbonisation of the fleet, emissions are still on the rise, unfortunately, rather than falling, which is what we need to see.

Sectors can be good and can be bad, and sometimes there are falls in emissions that are temporary and that rebound. The reduction in emissions in electricity last year was a star performer if looked at it in a purely mechanical, quantitative sense, but we know the level of implementation of onshore wind and solar is nowhere near the levels it needs to be to get us to the point of 80% renewables by 2030. It is great to see reductions, but if it is a reduction that could rebound very easily for whatever reason, whether structural, price-related or other, that is tricky and not great. With transport, it seems like it is a more sticky structural problem we have. That is one of the main reasons the council is so interested in the area of the NPF to try to move us gradually towards more sustainable travel patterns and so on.

I thank the Chair for all his work, lest this be our last meeting of this term, and thank very much the secretariat and the staff and the Department for all its engagement. It is very much appreciated. I have a couple of questions for the Department and then the Climate Change Advisory Council.

I was interested to hear Mr. Hogan talk about the rural housing guidelines. Was he suggesting they may take the form of a national planning statement or policy statement on rural housing? That might be the way in which they come out. Is that the case?

It is our intention from now on, where we issue new guidelines or what would typically have been guidelines, to try to introduce a new format, the national planning statements, once that is commenced. We would certainly draft any new guidelines in that format. It is our intention to seek to provide the clarity that was promised with the planning Act through a series of easy-to-follow planning statements that identify what should be consistent nationally, but also enabling that local discretion we have talked about, whereby local authorities can then apply that overriding national policy situation to their local circumstances through a variety of appropriate means.

I will hand over to my colleague Mr. Dalton on that. There is a range of sources and Mr. Dalton has highlighted that the ESRI is an independent provider of expert advice to the Government and others. Its work is scrutinised and peer-reviewed. That is the baseline starting point. There are other assumptions brought to bear. The work we have from the ESRI does not cover unmet demand, so we have done other work to assess that. There is a range of assumptions brought to bear. I mentioned the starting point earlier and, in other words, that is the capacity of the construction industry at present and what is realistic in terms of a ramp-up. I will hand over to Mr. Dalton on that.

First, the Department does not produce its own formal projections. We rely very much on what we get from the various sectoral experts on that, as well as our own engagement with home builders. As the Deputy is aware, there is a range of projections. These go from a projection of 32,000 provided by BNP Paribas up to a projection of in excess of 40,000 by Deutsche Numis Research earlier this year. We anticipate being somewhere between the target and close to 40,000 at this stage. It very much depends on what gets delivered towards the end of the year. It is complicated by the fact that we saw a significant increase in commencements in the back end of last year and into January and February. Many of those were scheme houses and, if they come on stream towards the back end of the year, they could actually push us towards the mid to high 30,000s. It is inherently difficult to forecast actual delivery. That is reflected in the fact that the forecasts we saw in the first and second quarters, even from the likes of the ESRI, the Central Bank and others, have been changed in the most recent quarter and moved back to some extent. Others are still maintaining that it will be in the high 30,000s and close to 40,000. It is very difficult to know at this stage.

There are a lot of challenges for compact growth, two of which are affordability and viability. There are also issues in respect of homeownership. We see a certain amount of housing development pushed out of urban areas into rural areas. There is obviously rural housing need but there can be urban-generated housing in rural areas that is pushed out for affordability reasons and because people may not have the opportunity for homeownership elsewhere. An apartment constructed in Dublin and costing €550,000 may not even be put on the market for individuals or families to buy. Prospective purchasers may be able to self-build in a rural area for much less than that and get somewhere much bigger. That creates problems in terms of the impact on the environment, car-dependent trave and utility connection costs. We have very high utility costs in Ireland. Given those pressures, are there specific measures in the national planning framework that address those issues relating to affordability, homeownership and compact growth? I have previously put forward resolutions, such as affordable housing zoning, which have not been politically accepted as yet, but is there anything within the NPF which will address that?

There is a range of measures which have recently been applied. The first thing from a planning perspective is the compact development guidelines, which review density and housing standards to enable more own-door-type housing to be produced in a wider range of scenarios throughout the country. There is also a range of other supports, such as the first home and help-to-buy schemes and, indeed, the LDA , with its own direct delivery through Project Tosaigh focused more on higher-density schemes. There is a degree of support there for compact growth.

Moving on to the NPF and the transport-orientated development concept, and building on what was asked earlier, the amendments we brought forward include the NESC definition of transport-orientated development. We certainly believe that, particularly around the big cities, where there is a challenge to step up large numbers of affordable housing units, TOD is a very important way to achieve that as it overcomes some of the viability constraints within urban areas. That said, we also believe some TOD sites could be redeveloped urban areas too. The concept of being able to build more places like Clonburris or Adamstown, using, for example, the urban development zone concept we introduced in the planning Act, more rapidly, with a wide range of housing types, many of them affordable, is a very significant spatial development or planning response to the need that is identified for a step-up or ramp-up in the number of housing units.

I thank Mr. Hogan. I have two questions for the Climate Change Advisory Council. The fact is that 30% of housing development is taking place outside of built-up areas and that is a very high percentage. We have also problems with affordability issues related to homeownership in more compact areas. If we want to get to the levels of compact growth we need, those problems have to be addressed. More has to be done in that regard.

In his opening statement, Professor Morgenroth referred to a letter the council sent to the Minister for housing to highlight the need to enable and support the roll-out of district heating in tandem with the roll-out of other low-carbon heat sources. What needs to be done in the national planning framework to ensure this happens? For many years, there has been a lot of talk about district heating, yet it is rare to see it happen. Indeed, there have been issues in the areas where there are district heating systems. What needs to be done to ensure this happens?

The council welcomed the inclusion in the draft NPF of a new national planning objective specifically focusing on district heating and also in going through developments for a number of regions. It highlights areas in specific cities for district heating growth and development. As regards the broader policy development piece to enable district heating, we saw in the past few days the progression of the heat (networks and miscellaneous provisions) Bill, which is a very welcome development in terms of putting in place that regulatory and legislative framework for district heating. Linked to the point we made in the opening statement regarding the interaction of district heating with other low carbon heat sources, that is pointing to the national heat policy statement, which is a follow-on from the heat study carried out by the SEAI. What we are getting at there is the interaction between zones that are most appropriate for district heating deployment. That is also linked to compact growth targets and delivery of compact growth, which makes district heating networks more effective and deliverable. As regards the interaction between areas that are most suitable for heat pumps, for example, or other low-carbon heat sources, rather than district heating, the way it is currently developing is that we are seeing deployment of heat pumps within areas that might be suitable for district heating networks and that may be eroding some of the business cases for district heating. The SEAI published its updated national energy projections this morning and they raise significant concerns, which the council also raised in its sectoral review for the built environment earlier this year, on the delivery and deployment of district heating schemes on the ground to meet the targets within the climate action plan for 2030.

Going back to the NPF, the inclusion of a national policy objective on district heating is very welcome as a starting point.

It will need to be linked to broader policy development to progress it, however.

There are really good objectives and policy in this area but it seems we have been poor at delivery. For example, a huge number of data centres have been constructed but we have not realised the potential for district heating from that in terms of the heat generated. Is there something missing that needs to be in the NPF to ensure we start delivering on making use of excess heat from data centres and other potential sources? There is something missing in that we have good policy and aspirations but they are not being delivered in a number of instances.

I apologise for having to leave shortly. I put on record my thanks to the Chair and the committee secretariat for their work and to everyone who has come in here and engaged with us over the past four and a half years. We members have all worked well together, across all parties and none. I also thank the officials and Ministers who have served in the Department. It certainly has been a good experience to be on this committee, which deals with really hard issues. I thank everybody who has participated.

I return to the issue of compact growth and will pick up where Mr. Hussey left off. It seems part of the problem is the definition within the NPF. Looking, for example, at recent residential development in the greater Dublin area, GDA, one could argue that the vast majority of it is compact growth as per the definitions in the NPF. However, most of it is not really compact growth in terms of the urban core of the cities in which people are living and working. I represent Dublin Mid-West, which is on the other side of the M50. While the densities of developments in Adamstown and Clonburris are very welcome and they are compact, not everybody who is buying there, or buying further afield in Meath and Kildare, lives in those compact growth settlements. That probably relates in some ways to the transport emissions issue Mr. Hussey raised earlier.

From the point of view of the advisory council, are both the definitions of and targets for compact growth clear enough? Would it not be better to try to define much more fully what we mean, such that when we say we want compact growth, we are getting genuine compact growth? Is there some other way of measuring it other than measuring it within built-up areas? We had a very good conversation in a meeting with representatives of the Central Statistics Office, CSO, in which we considered that if all development is at the edge of built-up areas, that is not really compact growth because it is contributing to suburban sprawl. From the point of view of the CCAC, could we do better? Is the council looking forward to the amendments to the NPF Mr. Hogan mentioned to see whether these are areas that could be strengthened? We are saying that 75% of new residential development meets the existing compact growth definitions but when we look at the very good mapping by the Chartered Institute of Building of everything built in the past five or six years in Dublin and the GDA, it shows it is all still suburban sprawl, albeit at the edges of existing settlements. Do the council witnesses have a view on how we can improve that?

I know from a previous employment that considerable effort was put into changing from settlement to built-up area. However, as the Deputy said, it still seems to miss out on some of the intricacies of what we are trying to achieve. It definitely is an improvement on what was there previously but there is still room to do more. We have said in all our submissions on this issue that it is not just about the number but the definitions themselves as well. There is still considerable scope for improvement in this area.

I have laboured with this every once in a while in my day job. It is difficult to come up with a really hard definition that really captures what we are trying to achieve. The example the Deputy gave is a very good one. If all the development is on the edge, is that really compact growth? Probably not. If we compare the highest-density areas with the least-density areas, there are substantial differences in emissions, both from residential sources and from transport. The aim should be to get more of the highest-density development, which then has its own implications in terms of brownfield development, etc. We know that is difficult but it is what we need to do to achieve greater reductions in emissions.

I hope Mr. Hogan and his team have an open ear as they finalise their amendments on any of these issues. In terms of going beyond just raising some concerns, are there either forms of language or ways of measuring this that could assist in improving it further? I take Mr. Hussey's point that it is an improvement on what was there previously but, thinking about Dublin again, there is a problem if much of the residential development that people living and working in Dublin are currently buying is outside Dublin, in the commuter belt, which we can see is where a lot of the development is happening, and if large numbers of those people are still commuting into the centre of Dublin for work, school places, recreation or leisure. The idea of compact growth is not just to have higher levels of density but that people are living in greater proximity to all those other key aspects of their lives. We could end up having large volumes of compact growth but not necessarily getting the emission reductions bang for the buck we want because people are still being forced to commute from a compact growth centre in one location to a centre of life or interest elsewhere.

How can we help Mr. Hogan and his colleagues to think through that? I am conscious that in the most recent completion figures, Clondalkin had the highest volume of completions. Some of that is genuine compact growth because, as Mr. Hogan will know from his time on the council, lots of those people are living locally and there are services and amenities within the developments. However, we know from talking to people that many of them did not live anywhere close to where they bought but it was the only place they could afford, even with the very high prices to be found there. How do we resolve that or at least move it on a bit?

I totally agree with the Deputy that compact residential development is just one dimension. If people live far away from where they do their other activities, there will be what transport engineers call trip generation. At least if development is compact, we have a bigger chance of moving people towards public transport. There is a benefit even if we do not achieve the spatial match terribly well. This goes back to the earlier discussion on transport-orientated growth. We need to think about that match between activities. When it comes to transport, commuting is only a smaller fraction of a whole. It is the other activities that generate more trips. We must think about how we link up those elements. If we are building compact developments without shopping, social and other kinds of facilities, we will generate more traffic. We need to look at the issue as a whole. Again, that is where the national planning framework comes in. If it does not cover that well and ensure the right decisions are achieved at the local authority level, where a lot of the relevant decisions are taken, then we have a problem.

Going back to an earlier point raised by the Chairman, a really important consideration is that with any decision, whether to build a house, apartment block or whatever, once it is there, it is there for a long time.

This is one of the reasons our transport problems are hard to solve. Patterns take an awfully long time to unwind. Every time we make a bad decision in one particular development, we will be stuck with that for a long time. That makes it even harder to achieve our targets. We must have taken some poor decisions in the past.

I have one final question which might act as a segue onto what Deputy Leddin is likely to raise, and rightly so. There is also an interaction between compact growth and balanced regional development as it is set out. Has the advisory committee a view on how those things should best interact? Are there areas within the current draft where it would like to see further movement or change to get that balance right? This is separate from whether the actual targets are right or wrong. Deputy Leddin will deal with that. This is more about the interaction between those two things.

In my day job I would have looked and continue to research balanced regional development. It is clear that the two are actually complements, the compact growth and balanced regional development. Ultimately, that is what has informed the NPF in its focus. It would be important not to lose that focus on developing the critical mass in the larger places, which ultimately has to be compact to be effective, to facilitate those regions. That includes outside of Dublin. If we want to have strong regions outside, we need to get that critical mass going. That by necessity requires compact growth, so they are complements.

Deputy Ó Broin is correct in guessing where I am going to go with this. I want to have a talk about balanced regional development. Before that, I echo Senator Cummins's thanks to the Cathaoirleach for his work as Chair of this committee. I am not a member of this committee but, as Chair, he has been very welcoming to non-members like me who take an interest in matters like the one we are discussing today. He has always been generous with time to non-members. I thank him for that.

I did not have the benefit of the earlier part of the discussion, so apologies if I am going over issues that have been thrashed out in depth already. From reading the statement from the Climate Change Advisory Council, it endorses the draft NPF review as is. Is that correct? Is it also the case it is saying it should be nailed down or implemented, essentially, as soon as possible?

I thank Mr. Hussey for that. I would certainly be concerned that we are at the end of the road with the draft. It is regarding how we achieve true balanced regional development. That is a term, like sustainability, whose meaning has been diluted over the years to the point that it does not really mean so much anymore. We do not talk about it in the kind of detail we should. I strongly feel from the draft NPF review I have seen that the population targets for the regional cities are not ambitious enough to justify the kind of infrastructure and investment that would be needed to drive the fast and sustainable growth, particularly in the area of rail. In the narrative and in the numbers in the draft, the ambition is quite low for the regional cities, such that if the State is pursuing the NPF as a strategic vision for what the country should be, it is not going to support the case for metropolitan rail systems in the regional cities.

On the other hand, it names road projects which will really pull these cities in the direction of low-density sprawl at the periphery and beyond, and not just sprawl but dispersed settlement as well. I believe 30% of all new development is allowed for outside of built-up areas. It is a huge concern of mine that the ambition within the NPF does not support the State investment in rail infrastructure in particular, which is this kind of infrastructure that supports density and developing density quickly more than any other kind of transport infrastructure. Has the CCAC any comment on that?

I do not think we really addressed or looked at that issue in great detail. We focused on the issues that are in our letter and in the submission, which are more around issues of what better, more compact growth will enable us to do in the areas of heating and better transport. We did not really get into the nuts and bolts of the regional balance element.

From 2018, when the original NPF was published, we saw lower densities being stitched into city and county development plans outside of Dublin than we saw in Dublin. We saw far less ambition for the kind of infrastructure investment that would lead to the right kind of density to support the right kind of sustainable growth. It is a real concern for me that the current draft of the NPF again misses the net. While I acknowledge both the 2018 document and this draft are absolutely a step in the right direction, six years on from the original, we should be taking quite a few more steps in the right direction. I do not see the draft as being this. This is the strategic vision for the development of the country through to 2040 and beyond. It is going to lead to some of the problems Deputies Ó Broin and O'Callaghan outlined, that we are going to get more dispersed, more peripheral and lower density settlement, which is going to drive transport emissions particularly. I hope the CCAC could look at that and offer a view to the Department and to the Minister such that we get the right kind of infrastructural investment in the regional cities.

In real numbers, it is not actually. We are talking about a 300,000 increase in population in the Dublin and eastern region. That is 1.5 times the size of Cork that is going to be targeted for this part of the country. If we speak about population in terms relative to the existing low population of the regional cities, it sounds like a lot, but actually it is not a lot in real numbers.

When we assess performance against that, we can already see a gap opening up. As a result, we have to be realistic. We have been accused of centralising policy. We are very clear that it is up to the region and the local authorities to determine how to achieve growth. We would very much welcome a compact growth strategy for any of the regional cities. Again, to talk about Limerick, there is a directly elected mayor who has ambitions for the city and would have views in regard to this sort of thing. It is something that we feel needs to be seriously considered locally.

The question was asked previously about how we achieve a more compact city or more compact development generally. A wise person said to me some years ago that density enables amenity and amenity makes density irrelevant. We have to create good places, they have to be attractive and people have to, I suppose, trade off living in a smaller, denser house for excellent amenities on the doorstep. A modern interpretation of that is the 15-minute city. Again, I strongly agree with the transport planning research. If people do not travel by sustainable means for the main commute of the day, they are unlikely to do that for other journeys or trips. Therefore, the really important thing is to get people on a bus or a train or, if possible, making local journeys on foot or by bike, whether to bring kids to activities or going to the shops. That can be achieved through compact master planning.

Of course they do. However, looking at the numbers relative to the current populations of the regional cities is not the right way to do it. We will have 1 million extra people in the country by 2040. The question is where those people are going to live. It is not right to say that Dublin will increase by something more than 20% and Cork by 30% or 40%. In reality, the potential for growth and the potential to close the gap in population and economic development terms between the regional cities and the capital is there, but that ambition is set by those numbers and targets. In the context of the current draft, the ambition simply is not there. As a result of that, we are not going to get the kind of State spending on infrastructure that can support the kind of growth that will lead us to a more sustainable society.

There are two things. One is that they are minimum target populations. We are talking about a minimum of 50% growth in regional cities in a little over 20 years. The second is that it is a function of local planning. These are very large and ambitious targets. That has to be related to the scale of the place because there are serious capacity constraints if a settlement grows by 50% in 20 years. It can be configured locally in a certain way along, for example, a railway line, a rail corridor, a bus route or a bus corridor, and that may be achieved sustainably. Nonetheless, it requires choices and strategies locally.

On that point and on the focus on population projections more generally, overall, part of the role of the NPF is around planning for and enabling a policy framework that can cater for a population of 5.7 million by 2030 and between 6.1 million and 6.3 million by 2040. That is an evidence base that has informed those projections that are included in the revised NPF. Not to labour the point, but one of the clear challenges for some of the regional cities will be the requirement for them to grow by 10% every intercensal period in order to reach that target. I appreciate that the baseline population is different for the regional cities but in terms of the scale and their capacity to grow, that has to be factored in not just in terms of what the targets are for the cities, but their role within the regions. Overall, what the NPF is seeking is a rebalancing or addressing of that unsustainable pattern, focus and concentration of growth that has taken place within the eastern and mid-east area around Dublin, and to address that by ensuring the regional cities are capable, attractive and viable alternatives for development more generally.

The NPF is also a key policy enabler for the cities to avail of those infrastructure projects the Deputy is referring to and the investment piece alongside it. There are numerous national policy objectives, NPOs, that reflect that, as well as key enablers in the metropolitan area transport strategies that clearly indicate there is a whole sequence of delivery and investment that is also enabled by other State bodies and agencies and which the NPF brings together. It is not just a case of the population not necessarily being ambitious enough. There is a series of interventions and policy areas that the NPF co-ordinates. Part of its role is to enable all of this to be integrated at a regional tier of plan-making, and thereafter into a local tier of plan-making, to ensure there is complete clarity and alignment around what the vision is for our regional cities.

I will make an observation and then put two questions to Mr. Hogan. I have a lot of sympathy with Deputy Leddin’s point. My colleagues from the regional cities will be making exactly the same point. I want to add an additional observation for Mr. Hogan and his team and it builds on my questions to the Climate Change Advisory Council. It is that there is also an issue about where the growth is within the city. One of the big concerns I have about Dublin, and I represent the suburbs, is that we are seeing very little meaningful residential growth within the urban core of the city and that is causing all sorts of problems, whether social, economic or environmental. For me, it is not just that we get balanced regional growth, about which Deputy Leddin is correct, but we also need to make sure it is compact growth in the truest sense of the term.

I am almost talking against my constituency by arguing for greater levels of development in the urban core of Dublin. I am sure there is nothing in what I am saying that Mr. Hogan disagrees with, and a lot of this has more to do with implementation than with what is in the planning framework. However, in the amendments, we need to have some way of differentiating even the grades of compact growth. Adamstown and Clondalkin, which I represent, are not the same as the urban core of Dublin between the canals. We need to see far greater residential development in those areas. One of the things the core has that we are struggling with in Dublin Mid-West is the other amenities. For example, there is significant residential growth in Dublin Mid-West but the vital public services that should be going in there in parallel are not going in, and the significant lag in school places, GPs and all of those additional journeys that Mr. Morgenroth mentioned are causing real problems. People in Adamstown are travelling to Meath and Kildare to get GP services, for example, and their children cannot get schools within the general election constituency. Again, that is not something the NPF, as a document, can fix and it has to do with the implementation and alignment of capital programmes. However, if there was a way of grading or almost heat-mapping the compact growth, as is done in the census, it would be useful. I just say that as an observation.

I have two questions for Mr. Hogan. Can he give a summary of the areas of the amendments? Obviously, we eagerly await their publication. At this stage, can he give us headline summaries of the amendments that the Department is working on, given there was an amendment timeline? As Mr. Hogan knows, I was pleasantly surprised when he told us at the last meeting that there would be an Oireachtas vote on the NPF because that is the right approach. However, if the relevant section of the new Planning and Development Act that removes that requirement is enacted between now and whenever the next government is formed, will it be that new section of the Act that governs the decision of the Government or will it still have the option of proceeding as was set out by this Government? Ultimately, it is a political question. I have a strong view that given the importance of this document having the democratic legitimacy of an Oireachtas vote, it is politically, but also probably legally, a much stronger position to be in.

Will Mr. Hogan clarify where it leaves an Oireachtas vote if that section is enacted at some stage early next year?

I will take the second question first and then hand over to colleagues for the first one. I have asked the same question. As it is a legal question, I have had preliminary legal discussions on it. This is therefore not definitive but it is my understanding as of now. As the process commenced under the 2000 Act, it would have to be concluded before the 2024 is commenced. If we were to seek to conclude it under the 2024 Act, we would probably have to start again. There is a clear distinction between the two processes.

In response to the general summary of the draft schedule of amendments, the opening statement alluded to the fact that a number of amendments are minor in nature, providing clarifications and so on. We have already touched on the inclusion of the definition of transport-orientated development as part of that. One of the main areas for which amendments have been drafted or proposed more generally relates to the strategic environmental assessment and that ongoing element of this particular area of work. Amendments are proposed for Chapter 9 to reflect on the climate challenge more generally, which will certainly be of relevance from this committee's perspective. There is a lot of strengthening of language, particularly in the national strategic outcomes included in Chapter 10, but also within Chapter 9. Further emphasis is given to the biodiversity crisis. Subsequent to the NPF going on display, we are now into the preparation of the nature restoration plan more generally and the integration and implementation of the national biodiversity action plan. The nature restoration legislation has also been enacted. There is a very specific response to that within the draft schedule of amendments in Chapter 9.

Another element to flag comes back to the discussion we have just had. It relates to acknowledging the requirement to establish a more structured and strengthened monitoring element of the NPF, covering those thematic areas related to compact growth in particular. There have been very helpful developments such as the housing delivery tracker being made available, which allows us to observe some of the raw data in this regard. We are certainly into the phase of building that monitoring element so that it can be durable and remain live for the duration of the NPF, a phase that accompanies the finalisation of the NPF. We see our colleagues across Departments as having a role in that in addition to the environmental monitoring piece that is also to accompany it.

I thank Ms Walsh for that. I might conclude with a request for whomever is on the next committee, because none of us may be here at that stage. The version the Department gave us after our previous meeting, which included the tracked changes, was brilliant. It made our lives so much easier. I really urge the Department to provide the members of the committee under the Thirty-fourth Dáil with the tracked-changes version with the amendments because it makes it much easier to get a sense of it. If there was a way of colour-coding amendments to the amended version, that would be particularly helpful for any of us who are back here again.

Does Deputy Leddin wish to come back in? No. I am supposed to take a break after two hours but I have one or two more questions to ask. Does anybody wish to take a break or will I just continue? I will continue. I will ask about national objectives 75 and 76 in the draft I have. They relate to renewable energy targets. This is one of the very positive parts of this NPF. There is a lot of good stuff in the NPF, notwithstanding what Deputy Leddin said about regional balance. I do not think we are achieving regional balance. We are continuing on the same route and may end up back here in five or ten years doing another national planning framework and saying we did not achieve it. I do not think we are going to achieve it with this plan. My question on objectives 75 and 76 is similar to the one I asked about housing figures earlier on. It is on page 135 of the draft. Objective 75 states that each regional assembly must identify and allocate a level of renewable energy within its region. Will they then allocate that to each county or is it up to the counties? How does that process work?

I can come in on that. Objectives 75 and 76 are effectively to be read in conjunction. Reflecting the discussion we had earlier with Senator Cummins on the tiered approach, the idea is that capacity allocations are first broken down on a regional basis in the NPF and that the regions would then break them down further in the RSESs for their constituent local authorities. That is where NPO 76 picks up the baton. Each local authority would then take that approach, working back up towards the overall national target.

There is one additional point to mention. While it is not specifically addressed in the NPF itself, there is also a need for further policy support to build on this objective and approach in the NPF. The intention is to do that through the wind energy development guidelines or a national planning statement. The NPF is a high-level strategic document. It would not be appropriate for all of the detail to be included in it. The clarity and further detail will come in the national planning statement. When you get to the local authority, the intention is to provide further clarity through the national planning statement as to how to approach identifying certain lands as regards their suitability for, for example, wind energy development. There will be a classification system for land based on areas that are acceptable and those that are less acceptable for various reasons. There is a methodology to be applied in doing that. We have been working with our colleagues in the Department of the environment on developing that methodology for both the regional assemblies and the local authorities, when it gets to that level of plan-making. This is all to reflect the plan-led approach we have been discussing with the committee over the course of the year in respect of the legislation. That will provide a much greater degree of clarity within the development plans as to the capacity within each local authority area for these types of renewable energy developments and what lands are considered to be appropriate. Local communities and those wishing to undertake renewable energy developments can then progress applications based on those plans.

To be clear, when this NPF is passed, whenever that might be although we hope it will happen by the end of the year, a round of RSESs will then have to be done by the three regional assemblies. At that stage, there will be guidance for them to allocate that capacity. That will then feed into zoning under the development plans. Some areas will be considered most appropriate. That is the type of language will be used. That is critically important. Looking at table 9.1, which relates to onshore wind, the eastern and midlands area currently has 284 MW. The target is almost an additional 2 GW of onshore wind energy. Are these targets like housing targets in that they are not a cap? Can we go further and exceed these targets? We are quite good at onshore development in this country. We are only starting into offshore development but we will make good progress on that as well. We can do more than that.

We have been discussing that further with our colleagues in the Department of the environment. Looking at it from the perspective of housing targets, through both the draft revised NPF and the legislation, there has been a great deal of discussion of targets. It is clearly the intention not to see them as caps.

In the context of the renewable electricity capacity allocations set out here, it is not to be seen as a cap but as something to work towards. In terms of the further detail that will come with the national planning statement, we will look at how that is set out to be applied by the regional assemblies and local authorities in how it is considered in the plan-making and, ultimately, the decision-making processes. I will again give the parallel example of housing. When you look at the NPF and the housing supply target methodology that is already in use, there is a methodology for applying a certain amount of headroom. There is further detail to be worked through on these particular allocations, but it is the direction of travel. These are to be worked towards and they are not caps.

We spoke about compact growth. It was stated that building high-density apartments or compact developments is expensive. It is so much easier to build a three-bed semi on a greenfield site. It can be done in a certain amount of time, almost by the numbers. However, there is another cost saving when it comes to compact growth. Consider what the State has to do in providing roads, power, lighting, transport, water and so on to sprawl development. That is looking at compact growth as part of a bigger picture. It is not looking at a four- or three-bed semi-detached that under construction costs produced recently costs €450,000 to build. When do we start looking at these things in the round, and not just the environmental, societal and climate cost savings of compact growth versus the cost when it is sprawl development? When do we start looking at the real long-term costs?

There are also the energy efficiency increases relating to housing. Houses are expensive to build. There is no getting round it. However, the house you buy today is nothing compared with the house built in 1980, which people say was more affordable, and it was. The two are not comparable in terms of long-term running costs and the services that should be in place with good compact growth and proper planning. When do we start looking at it in overall economic terms instead of just looking at the price tag for the purchaser?

This is something that has arisen again and again. When we drafted the original NPF in 2018, we had to rely on international studies from Canada and Australia. This time around, there is more research locally. The Housing Commission looked at this issue and compared parts of Lucan with Leixlip in terms of theoretical expansion, and one way of doing it versus another. We did something similar. We commissioned research to back up the compact growth approach in the NPF, which, as can be seen from the range of submissions, has been criticised in some quarters. I will ask Ms Mulhern or Ms Walsh to summarise what we did. The cost differential between compact and non-compact growth is significant, and that is a preliminary bricks-and-mortar and service-provision view. It does not take into account things like carbon emissions.

To build on that compact growth research, we are reviewing a finalised draft report, which examines the cost of greenfield versus brownfield or infill with respect to development. It is to get to the nub of the question as to the long-term cost to the State, utility providers and infrastructure agencies more generally. There is a breakdown applied and I can source the figure if the Chair will bear with me. However, it indicates there is a substantial differential between the short-term affordability seen for greenfield development versus the longer term cost that accrues to the State over time. It absolutely feeds back into decision-making around where development should be targeted and focused. That all links back, and it is an important cost element that had not previously been to the fore in discussions in the way it should have. This has certainly arisen with our colleagues across government and has brought a sense of perspective to some of it.

The research is at draft stage, but it has been commissioned to support the revision process more generally and it would be the intention that it be published once signed off. It indicates that construction for hard infrastructure, which includes roads, landscaping, water services, public open space, and so on, costs €115,900 more per unit on greenfield lands compared with infill development in an existing built-up area.

The cost to the State is €115,000 in terms of compact versus greenfield sprawl. This is a kind of political question, so the witnesses do not need to answer it. With measures brought in to help to make apartments affordable for people availing of the Tosaigh or Croi Cónaithe schemes, is the State spending money to encourage compact growth and get more people to live in those types of developments? That is a climate measure as well as a housing measure. It is interesting.

It is a like for like cost. It took a green urban site, which was a former golf course and compared it with a greenfield suburban site outside the city. It is comparing like with like on the basis of infrastructure. It does not take into consideration the additional benefits of agglomeration, density, people's time and carbon emissions, etc. You could go a lot further, but this is a tangible and defensible figure on a like for like basis. That figure could be added to depending on further assumptions.

I make the link back to how this particular piece of research is not entirely unrelated to the next steps around what Deputy Ó Broin referred to with the gradation of compact growth, or in some way establishing typologies or particular areas for providing further clarity in that space. It is just to make that connection.

I would love more questions, but I will wind up shortly. Let us look at the 2030 figure for Housing for All, which is approximately 40,500. Now, all parties and none are saying it is 50,000, 55,000, 60,000 or whatever it might be. We are exceeding the Housing for All target by a little each year.

To increase the projected figure by an extra 10,000 by 2030 is an incredible leap to make in a very short space of time. There are so many aspects to feed into that as well. There needs to be investment in Irish Water, the grid and transport infrastructure. We also need people to build those extra houses. It is probably a matter for the Climate Change Advisory Council but there are considerable challenges there. It is easy to pick a figure based on research showing expected population growth, household occupancy rates, obsolescence rates and so on and say this is the figure the computer will spit out based on the evidence. However, it is about trying to construct those units in the right places. Building apartments is very expensive and we need 200,000 of them by 2030. It is a massive challenge. Maybe the right way to wrap up this session is to say it is not as straightforward as people make it out to be.

To add to that, the climate targets are fixed and the 2018 levels are there. The population is increasing consistently and there is economic growth. It comes back to the point that we must do this right because it will be impossible to achieve our legally binding targets unless we do it right. That is why this document is so important. I do not think it is right at the moment. It allows for far too much wiggle room and emissions-inducing settlement. It needs to be tightened up.

I will make a few comments. I will go back to the previous conversation on the research that is being conducted by the Department on the comparative cost of greenfield and brownfield development. That is really welcome. The figures we discussed align with what we had seen in the report I mentioned from the Office of the Planning Regulator on brownfield land activation. That looked at the international norms and suggested there is an additional cost to the State of between €100,000 and €150,000 for servicing a greenfield site versus a brownfield site. There is, therefore, also an economic argument to build on what was discussed around compact growth.

I will go back to the points raised on the renewable electricity capacity allocation targets and the Climate Change Advisory Council's opening statement and response to the MPF consultation. That was a big driver for the council to call for this to be progressed urgently and as soon as possible. The council sees that as a key enabler of progression of renewable electricity targets. What we have seen from looking at planning applications for renewable electricity in terms of onshore wind and solar this year is that it has not been progressing at the pace that is required to meet our targets.

Then, in terms of the-----

It would seem from the numbers we are looking at that the pipeline is there, but it is not progressing through the planning system fast enough.

The other point I want to make is on the national planning statement that would replace the wind energy guidelines. We would point to the need for guidelines that account for solar generation as well. There could be a little bit more in that because, as we discussed, not everything can be in the national planning framework. It is also about looking at the issue of the repowering of existing renewables because without looking at that, while the current regional targets that have been set out in the MPF meet the targets for new renewables in the climate action plan, if we lose a significant amount of capacity between now and 2030, it will not meet the targets either. I am just pointing out that document should maybe look at that as well.

Objective 75 is aimed at addressing that to make sure every county has its allocation, knows what it is going to do and stops what we have heard about anecdotally, whereby how halfway through a process or an assessment, with the zoning done, the wind development does not go ahead. We need to tighten up on that.

I thank everyone for their time today. It has been very helpful to us. Hopefully, some of us will be back to pass the national planning framework at some point in the future. I thank everybody for their attendance today. I also thank the Department officials, with whom we have had considerable engagement in recent years. They have always been very willing to attend and have been of great assistance to us. I thank them for that. I thank the representatives from the Climate Change Advisory Council. We badly need them to keep pushing us to do more and to keep issuing research and guidance to us.

The committee will meet in private session at 11 a.m. on Tuesday, 12 November.