Planning for Growth A City for Better Business, Better Lives - Submission to the Draft Dublin City Development Plan 2022-28 - Dublin City ...
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Planning for Growth A City for Better Business, Better Lives Submission to the Draft Dublin City Development Plan 2022-28 February 2022
Dublin & Eastern REC Secretariat
Aidan Sweeney Moya Cassidy
Senior Executive: Policy Executive
Government, Enterprise Ibec
& Regulatory Affairs T: +353 (01) 6051555
Ibec E: moya.cassidy@ibec.ie
T: +353 (01) 6051642
E: aidan.sweeney@ibec.ie
2 Ibec Dubln & Eastern REC
Contents Contents 3 Key recommendations 5 Introduction: The Ibec Dublin & Eastern Regional Committee 11 Strategic context and vision (Chapter 1) 13 Housing: Core strategy (Chapter 2), quality housing and sustainable neighbourhoods (Chapter 5) and appendix 1 14 Housing Dublin’s growing population 14 A changing household and tenure mix 15 Affordable housing supply 15 Enhanced delivery of social housing 16 Housing requirements for an ageing population 16 Student accommodation 16 Build-to-rent 17 Increased housing supply requires availability of zones and serviceable land 18 Planning to deliver 19 Sustainability: Climate action (Chapter 3) 20 Pathway to the decarbonisation of the city 20 Promoting effective urbanisation: Shape and structure of the city (Chapter 4) 21 Increase density to promote urbanisation 21 A sensible approach to building heights 23 The ‘15-minute city’ requires sustainable neighbourhoods 25 The enterprising city: City economy and enterprise (Chapter 6) and the city centre, urban villages, and retail (Chapter 7) 26 Strategy for reimagining and rethinking Dublin 26 Supporting retail through the mix of uses within the city core 27 Supporting the development and enhancement of Dublin’s experience economy 28 The night-time economy 28 Tourism in the context of local economic development 30 Equity and Inclusion 30 Address safety and security concerns 31 The student-friendly city 31 Smart cities can enhance quality of life 32 Accessibility to world-class digital infrastructure 32 Advance the Dublin-Belfast Economic Corridor 33 Keeping Dublin moving: Sustainable movement and transport (Chapter 8) 34 Sustainable mobility and travel contribute to improved quality of life 34 Draft Dublin City Development Plan 2022-28 3
Active travel & accessibility 35
Dublin Port connects the city to global economy 36
Sustainable environmental infrastructure and flood risk (Chapter 9) 37
Dublin’s potential must not dry-up 37
4 Ibec Dubln & Eastern REC
Key recommendations
Housing: Core strategy (Chapter 2), quality housing and sustainable neighbourhoods
(Chapter 5) and appendix 1
➢ Avoid conservative population and housing projections: The projections in the
draft should be the absolute minimum expected growth between 2022 and 2028.
They must not hold back future growth, nor prevent Dublin from addressing the
demand for housing.
➢ Urgently review the Housing Needs Demand Assessment: The draft states that
40,000 housing units are needed over the lifetime of the development plan. This
target does not adequately account for pent-up demand resulting from a lack of
supply over the past decade, which has been exacerbated by the impact of Covid
on housing construction. The result is the city being held back meeting the
demand for housing.
➢ Focus on the right housing mix: Tackle the current mismatch between what
housing is suitable and what is available, which affects affordability of housing.
The housing approach set out in the Dublin City Development Plan 2022-28 must
account for the required change in household mix and tenure. It must reflect
demand such as the growing need for one-bed apartments. This is in line with
Housing for All, a New Housing Plan for Ireland. The plan must support the
delivery appropriate and affordable stock, including affordable purchase, social
housing and cost-rental, across a broad range of living solutions that meet the
needs of everyone (e.g. students, young professionals, families, older people etc).
➢ Dublin must have an adequate stock of rental accommodation: The specific
Build-To-Rent standards set out in the draft plan must be revised so not to
exacerbate the current shortage of rental properties. The proposal for a minimum
of 40% of a large-scale development (>100 units) to be Build-To-Sell is likely to
make such development unviable to construct. This would exacerbate, not
alleviate, the city’s housing crisis. Smaller developments (Sustainability: Climate action (Chapter 3)
➢ Ensure Ireland’s long-term emission reduction obligations are considered: More
effective land planning and development will be needed to increase Dublin city’s
resilience to climate change, reduce emissions and support the delivery of vital
energy infrastructure.
Promoting effective urbanisation: Shape and structure of the city (Chapter 4)
➢ Provide for a significant increase in density: Champion pro-urbanisation policies
and end the pattern of suburbanisation policies that resulted in sprawl. Density
must be part of planning for a post-COVID world. The Development Plan 2022-28
must be steadfast in its commitment to support the sustainable development
objectives at the heart of the NPF. Compact, urban growth, not ineffective low-
density measures, must be implemented through effective alignment of the local
development plan with the NPF.
➢ A sensible approach to building heights: Average building heights in Dublin are
lower than other cities across Europe. It is both important and appropriate that
the new Dublin City Development Plan 2022-28 allows for increased height in
developments. Research shows that two-thirds of the adult population is in
favour of the development of 6 to 12 storey buildings in appropriate areas. Taller
buildings should be strategically located to support densification and urban infill
objectives.
➢ Support the ‘15-minute city’ and sustainable neighbourhoods: Seize the
opportunity to develop a new long-term strategy for urban spaces across Dublin
city based on accessibility to amenities and services. This replaces previous
thinking of designing the city from solely the logic of mobility, which has led to
unsustainable commuting patterns. Sustainable neighbourhoods across the city
should be able to access a range of facilities by walking, cycling, or high-quality
public transport.
The enterprising city: City economy and enterprise (Chapter 6) and the city centre,
urban villages and retail (Chapter 7)
➢ Strategy for reimagining and rethinking Dublin city: The post-Covid economic
fate of the Dublin city area cannot be left to chance. It must be planned for and
invested in to ensure growth is sustainable and resilient. There is a strong
interdependence between the planning, development and creation of an
attractive environment and enterprise development. The focus must be on re-
intensification of existing business locations. This strategy aims to create the right
conditions for enterprise to thrive, to create wealth and improve quality of life for
all.
➢ Achieving a greater mix of uses in the city centre: Dublin city will have to work
harder than ever before to entice people into its urban core. Increasing footfall is
one priority. Higher density within our towns will also help. Achieving a greater
mix in uses within urban areas will lead to sustainable rejuvenation occurring. It
requires achieving a better and more appropriate balance between residential,
6 Ibec Dubln & Eastern RECretail, and other commercial or business activity. This will require a collaborative
approach between local business, the local authority and Government to be
successful.
➢ Support development and enhancement of the experience economy: The
Development Plan 2022-28 must make the city centre, towns and villages across
Dublin safer, family-friendly, and more attractive destinations supported by a
greater mix of commercial activities and experiences. It is important that positive
and constructive engagement (e.g. outdoor dining) between Dublin City Council,
other public stakeholders and local businesses continues post-Covid.
➢ Develop a common understanding of the night-time economy: The starting
point to transforming the night-time economy is defining the range of activities
between 6pm and 6am, employment and businesses involved. These include:
cultural and leisure activities; activities which support night-time cultural and
leisure activities; 24-hour health and personal social services; and activities which
support wider social and economic activities.
➢ A vision for the night-time economy: Each local authority must have their own
vision for the night-time economy, which rethinks the use of public space;
reimagines under-utilised spaces; develops a register of creative assets; connects
to creative and cultural strategies; engages the community; and amends the
urban design policy to incorporate the needs of the night-time economy into the
plan-making process.
➢ Tourism is part of the sustainable recovery and growth of the city: Dublin must
continue to be seen as an attractive and welcoming location for tourists,
conferences, and events. The anti-tourism rhetoric must be challenged. The
Development Plan 2022-28 must support investment in the sector across
accommodation provision, visitor experience development, visitor awareness and
accessibility, and other critical enablers. It should also continue to advance
projects that leverage placed-based assets and catchments sustainably.
➢ Equity and inclusion: Cities are incubators of social change, and Dublin City’s
development strategy must adopt an inclusive approach and adequately
remediate past inequities that have been exacerbated by the crisis to enhance
the city’s resilience. Given the significant social, economic, political, and cultural
costs of inequity, there is the opportunity to integrate and mainstream equity
into the Development Plan 2022-28 to ensure Dublin is an attractive place to live
and work for all.
➢ Address safety and security concerns: Safety concerns limit access to the city,
including to employment, health, education, political and recreational facilities.
Dublin’s public spaces must be safe and useable for all inhabitants, and at all
times of the day. People must be free from real and perceived danger in the city
centre, especially women, ethnic minorities, and marginalised groups. Safety and
security will influence the attractiveness of the city centre to those wishing to
live, work or visit.
➢ The student-friendly city: Higher education institutions and the student
population make a significant contribution to the vibrancy and diversity of Dublin.
They are a foundation of the innovative and creative economy that the city
requires. A vibrant student population is an important aspect of both the
economic and social life of the city centre. This ecosystem is interlinked with
Dublin’s future economic development. The Development Plan 2022-28 must
Draft Dublin City Development Plan 2022-28 7reflect this, including contributing to the provision of quality and affordable
student accommodation.
➢ Fully integrate the ‘smart city’ into the future development of Dublin: The
‘smart city’ approach can support high quality of life and economic development
within the city core and supports sustainable neighbourhoods. Dublin must lead
in the rapid rollout of 5G and ensuring accessibility to and deployment of cutting-
edge infrastructure for businesses and inhabitants alike. Dublin is a global
technology hub. The Development Plan 2022-28 must continue to underpin the
city’s competitiveness across a range of areas from skills to housing to data
centres.
➢ Advance the Dublin-Belfast Economic Corridor: The development of the Dublin-
Belfast Economic Corridor must be fully integrated into the Development Plan
2022-28 to support sustainable growth of metropolitan Dublin and the wider all-
island economy. The development plans for each of the eight local authorities
along the corridor must be coordinated to support its advancement. This will
assist in the prioritisation of investment in the necessary underpinning and
supporting infrastructure to build out the Dublin-Belfast Corridor.
Keeping Dublin moving: Sustainable movement and transport (Chapter 8)
➢ Improved quality of life through sustainable mobility and travel: The
Development Plan 2022-2028 must make Dublin city’s transport network more
connected, integrated, and efficient. Successfully connecting transport to land
use policies to allow people to choose where they want to live and work, rather
than having these decisions dictated by circumstance.
➢ Active travel & accessibility: A whole-sale return to pre-Covid commuting
patterns will be unsustainable. Dublin is far too car dependent for most of its
journeys. More sustainable modes of transport such as walking, cycling, and
public transport must be prioritised. The maintenance and development of high-
quality walking and cycling infrastructure is necessary to support active travel and
to ensure that every aspect of a commuter’s journey is safe. The Development
Plan 2022-28 should support the use of e-scooters and mobility-as-a-service
initiatives, and their safe and satisfactory deployment across the city. Secure
storage facilities for both bicycles and e-scooters are also essential.
➢ Involve stakeholders early in the design of schemes: Installation of new cycle
lanes, pedestrianisation or projects involving the reorientation of traffic and/or
access routes should occur after consultation with the local businesses have been
carried out. The priority should be accessibility for all. This includes provisions for
delivery to/from businesses in the vicinity as well as the individuals with specific
accessibility requirements.
➢ Underpin global connectivity through Dublin Port: Supporting the growth of
Dublin Port’s infrastructure and operations are key to supporting supply chains
and economic activity across the region and throughout Ireland. The
Development Plan 2022-28 must facilitate the delivery of the 3FM Project and the
associated development of the Southern Port Access Route by Dublin Port itself in
advance of this route potentially becoming a Transport Infrastructure
Ireland/Dublin City Council public road if justified in future. The construction of
8 Ibec Dubln & Eastern RECthe SPAR, a private road for port-related HGV traffic, is time critical and central to
increasing port capacity.
➢ Facilitate sustainable port operations and freight movement throughout
Ireland: Dublin City Council must support the development of a rail terminal at
Iarnród Éireann’s land on East Wall Road to service Dublin Port. This development
is required to enhance container rail freight in Dublin Port and the increased
movement of freight via rail can potentially lessen the reliance on HGVs for port-
related freight movement. This would reduce emissions and further remove HGVs
from the city.
Sustainable environmental infrastructure and flood risk (Chapter 9)
➢ Dublin’s potential must not dry up: Dublin City Council must be a strong
advocate for the need to investment in water and wastewater infrastructure in
the city. This supporting infrastructure, such as the Water Supply Project for the
Eastern & Midland Region, so that housing targets can be met, other key projects
delivered, and that Dublin continues to secure inward investment.
Draft Dublin City Development Plan 2022-28 91
Introduction
10 Ibec Dubln & Eastern RECIntroduction: The Ibec Dublin & Eastern
Regional Executive Committee
Ibec is a national organisation with a strong regional structure. The Dublin & Eastern REC
is made up of nominees from Ibec member companies operating within Dublin, Kildare,
Louth, Meath, and Wicklow. It includes both multinational and indigenous companies and
reflects the diversity of business in terms of sectors and company size. The committee
works to shape, guide and influence business policy priorities for the region that
contribute to sustainable economic growth and employment.
The REC has contributed to the development of the National Planning Framework, the
Eastern & Midland Regional Spatial and Economic Strategy, as well as the National
Development Plan and the GDA Transport Strategy. We also made a submission to the
City Recovery Taskforce, as well as Ibec having a representative on the Finance, and
Economic Development & Enterprise SPCs within Dublin City Council. Ibec also chaired
the placemaking sub-group informing the forthcoming Dublin Regional Enterprise Plan.
The Dublin and Eastern REC is committed to shaping policy that supports quality of life
and a resilient and sustainable recovery across our region, as we continue to navigate the
changes associated with the global pandemic.
The REC strategy for 2022 is shaped by three priority strands:
1. The Enterprising Region
2. Planning for Growth and
3. A Region that Works.
Two cross-cutting themes – Quality of Life, and a Resilient & Sustainable Recovery –
underpin our regional priorities. These have informed and guided the preparation of this
response to the Draft Dublin City Development Plan 2022-2028.
The response has been structured in accordance with the chapter headings set out in the
draft plan.
Draft Dublin City Development Plan 2022-28 112
Discussion
12 Ibec Dubln & Eastern RECStrategic context and vision (Chapter 1) The Dublin City Development Plan must ensure that the city is an attractive place to live and work. Talent is mobile; it is not just businesses that invest in an area, people do too. Dublin is now ranked 51st in the latest Global Liveability Index, falling 22 in its position on 2020 because of the pandemic. Housing and climate change are the two biggest challenges facing the economy and society over the coming years. Planning for the Dublin region must focus on building back better to improve the resilience of the city and to develop a wider metropolitan that works in the long term. Competition for talent is growing and city development must be designed to support the retention of our young and active population while attracting inward investment and skill. There is a strong interdependence between the planning, development and creation of an attractive environment and enterprise development. Companies are attracted to invest in locations where they can access skills, where people will want to live and work and where the surrounding infrastructure is supportive of business (including, for example, transport and broadband networks; education and training facilities, retail etc.). Establishing a strong sense of place contributes to the attractiveness factors for entrepreneurship, for business investment, for foreign direct investment (FDI), talent and tourism. In an increasingly competitive environment in Europe, Dublin has proven that it can be an engine for growth for the whole country. With the right focus, investment and planning, Dublin can continue to grow and be successful, providing a vibrant and sustainable environment where future generations can live and work. More people living in the city will leverage much needed investment in the public transport system and in active travel. The Dublin City Development Plan 2022-28 should be accompanied by a clear statement on its alignment with the National Planning Framework (NPF), the Eastern & Midland Region’s Regional Spatial and Economic Strategy (RSES) and crucially the Metropolitan Area Strategic Plan (MASP) for the Greater Dublin Area. A lack of cooperation and collaboration between authorities in many areas has led to unsustainable development patterns and urban sprawl. Institutionalising collaboration and coordination between local authorities on economic and spatial development is to be welcomed. Draft Dublin City Development Plan 2022-28 13
Housing: Core strategy (Chapter 2), quality housing and sustainable neighbourhoods (Chapter 5) and appendix 1 Housing Dublin’s growing population The biggest single domestic driver of competitiveness pressures is the lack of housing supply. Continued shortages of affordable housing in Dublin city threatens to undermine the achievement of many of our economic policy goals – including the attraction of overseas investment into Ireland, the promotion of third-level education, the reduction of emissions and the improvement of household incomes and wellbeing. In addition, the lack of housing is a key driver of an acute social crisis. There is a clear link between housing availability, affordability, and our economic competitiveness. The cost of accommodation is a key factor in the decision to come to, or to remain in, Dublin. Dublin city will see a steady increase in the number of new households being formed, reflecting the growth in population coupled with a decline in average household size. The draft plan sets out the six-year population projection for Dublin city. It states that the population will increase between 625,750 and 640,00 by 2028. The population targets will guide the location of housing and population growth across the city. The projections are in line with those set out in Eastern & Midland RSES and the Implementation Roadmap for the National Planning Framework (July 2018), which informed Ireland’s future population should be apportioned at regional, local, and metropolitan level across the country. The draft states that at least 40,000 new housing units are needed over the coming six years. This represents a fifth of all new housing units targeted for construction under Government’s Housing for All strategy will be built in Dublin city. However, this target does not adequately account for pent-up demand resulting from a lack of supply over the past decade, which has been exacerbated by the impact of Covid on housing construction. The provision of a 20% “headroom” or the potential for an additional 8,500 units could still be insufficient in satisfying the demand for affordable and quality housing in the city. The projections in the draft should be the absolute minimum expected growth between 2022 and 2028. The core objective must be to plan for effective, sustainable, and inclusive growth, not business as usual. The target figures were identified in the Housing Need Demand Assessment (HNDA) for the city. An urgent and independent review of the HNDA should be conducted to ensure that the evidence-base is robust, and that Dublin city meet its long-term housing needs in the Development Plan 2022-28. 14 Ibec Dubln & Eastern REC
A changing household and tenure mix Dublin city will see a steady increase in the number of new households being formed, reflecting the growth in population coupled with a decline in average household size. Each of these households will need a home. This will involve a combination of owner- occupied and renting households. There is currently a mismatch between what housing is suitable and what is available. This affects affordability of housing and ultimately Ireland’s ability to attract and retain people. The housing approach set out in the Dublin City Development Plan 2022-28 must account for the required change in household mix and tenure. We need the right mix of housing in the right areas, in accordance with suitable and sustainable development practices. It is important that the county’s housing policy adequately accounts for the expected demographic changes that will impact the housing stock and mix required over the coming years. The demand for homes is also driven by changes in the average household size. Standard floor size does not adequately reflect the different housing types needed. The demand for one-bed apartments is re-emerging and will grow stronger. The Development Plan 2022- 28 should not underestimate the growing demand for quality and affordable one-bed apartments due to lifestyle choice. Additionally, there is an over-estimation in the demand for three-bed apartments in certain locations. Delivering these may be unviable from a cost and affordability perspective, and as such that these may not be delivered without significant fiscal supports. A holistic view of housing is required, allowing for an appropriate mix of location, type, tenure, and accommodation. Students, young professionals, families, and an older population all have different housing needs. Affordable housing supply Affordable housing must make a greater contribution to Ireland’s housing mix. Funding is available to support the rollout of affordable purchase and cost-rental housing schemes. Additionally, ‘First Home’, the state-backed shared equity scheme could help families who are able to pay back a mortgage but fail to meet the Central Bank macro-prudential rules to buy a new home. This would free up rental accommodation and provide certainty for homebuilders. Dublin City Council should use the Development Plan 2022-28 to leverage innovative and diversified funding streams to support the provision of affordable housing within the city. This includes strategic pursuit of competitive funding under Project Ireland 2040 such as the Urban Regeneration and Development Fund (URDF) and the new funding streams announces such as Croí Cónaithe (Cities) Fund and Project Tosaigh. Additionally, it should work with Central Government to access European funding. The St. Michael’s Estate pilot cost-rental scheme received investment from the European Investment Bank. Draft Dublin City Development Plan 2022-28 15
Enhanced delivery of social housing Increased housing provision by the local authority sector, directly and not just through the approved housing body model, would provide immediate economic and social benefits. Over the next few years, the maintenance and refurbishment of the existing social housing stock will come to the fore. The social housing stock is ageing in key urban areas. By 2030, for example, a considerable share of social housing units across Dublin city will be between 80 and 100 years old. Maintenance, refurbishment, and potential replacement will become an increasing focus of Dublin City Council. The age and condition of units impact the reletting time of social housing. The social housing stock will also require deep and substantial retrofitting. Housing requirements for an ageing population Ireland’s population is ageing rapidly with the share of the population aged 65 and over projected to increase from one in eight to one in six by 2030, and the number aged 85 and over projected to almost double. This will have implications for long-term care services and will also require new models of living and support within communities. UCD research found that most people would prefer to remain living at home for as long as possible and receive care when it is needed in their home. Care in the home can also lead to more positive health and social outcomes. Encouraging people to trade down requires availability of suitable housing within our urban areas, particularly within their local community. This could be in the form of new built apartments, smaller existing properties, or adapted housing developments for older people. These are in addition to sheltered or supported housing options. Student accommodation Dublin is a global education hub and naturally has a higher density of students than other parts of the country. Students need access to affordable, quality, and safe accommodation throughout their college life. Housing for All and the National Student Accommodation Strategy explicitly call out the need for on-campus and/or close to campus specialist accommodation for students. This should be reflected in the Development Plan 2022-28. Not everyone can commute to college from home. Instead, students are left to compete for an ever-shrinking supply of student residence places, or for the sparse availability in the private rental sector, often far from campus. Housing four students in purpose-built accommodation would free up one additional housing unit, alleviating some of the burden in the over-crowded and expensive rental market. Specialist student housing will crucially play a part in addressing the Dublin’s chronic housing shortage. Above all, we must ensure that Dublin remains an attractive city to live, work and study in. 16 Ibec Dubln & Eastern REC
Build-to-rent Business urgently needs to see a better functioning rental market in Dublin city. The dysfunctionality of Ireland’s housing market can be seen in the rental sector. High rents impact quality of life, particularly for younger workers living in the city. Supply has been eroded at the same time that demand has rapidly increased. Small and/or accidental landlords have exited the market, disposing of their rental properties in large numbers. It is estimated that the country has lost more than 20,000 rental properties since 2016. Most of these would be in our large urban centres, including Dublin city. The draft Development Plan 2022-28 is likely to exacerbate the rental shortages through proposed measures impacting Build-To-Rent (BTR) development. This will have a direct knock-on effect to the wider housing crisis. The proposed changes have not undergone a cost-benefit analysis nor been subjected to serious scrutiny. They appear to be reactionary measures and will do little to address the real issue of the viability of apartment construction within the urban core. Successful BTR schemes result in purpose-built rental accommodation with greater security of tenure and more transparent rental increases. The draft Development Plan does not adequately reflect nor consider the distinct characteristics of the BTR sector incorporating differentiated apartment design standards such as a reduction in car- parking and open space provisions and increased heights. This omission is likely to impact on the provision of rental accommodation as well as Dublin’s ability to meet its overall housing target. The proposal for a minimum of 40% of a large-scale development (>100 units) to be Build- To-Sell (BTS) should be of concern to Dublin City Council. First, the proposal would require the two different tenures (BTR and BTS) to be entirely physically separated within the same development to allow the rental element to be appropriately managed. More worryingly, it fails to take account of the fact that such BTS apartment development is often unviable to construct. Thus, it is highly unlikely that it will lead to an increase in affordable homes for purchase. The Development Plan 2022-28 must prioritise the development of apartments in the city where the greatest level of demand comes from renters. This is wholly consistent with the NPF, the RSES and the MASP. There is a strong demand for rental accommodation to reflect those living and working in the city. The proposal to demonstrate that there is not an over-concentration of BTR development within 3km of the subject site is misguided. People should be able to choose to live close to where they work. This requires Dublin City Council not to adopt policies that, intended or not, result in pushing people further from the city core. Not everyone wants to live in a rented apartment, that’s true. But an increasing number of people do. This is often overlooked in public commentary. The draft plan states that BTR is no longer permitted in principle under the ‘Residential’ use category, but it is open for consideration on Z1, Z2, Z4, Z5, Z10, Z12 and Z14 lands. This arbitrary restriction should be revisited in the final plan. If left unchecked, it has real potential to exacerbate the housing crisis further. Draft Dublin City Development Plan 2022-28 17
The draft plan sets out that BTR schemes with fewer than 100 units will not generally be
supported. The rationale for this proposal is not justified. It appears to be based on the
general experience of small management companies of legacy BTS apartments. Such a
value judgement is outside the bounds of the development plan process. It could also be
attached to BTS developments of 100 units or less. Finally, it is not consistent with the
NPF in terms of promoting urban infill. Innovative BTR developments could provide
housing on smaller or non-traditional sites, be well-managed and within proximity to the
city centre and enterprise hubs. For example, it could support the sustainable
intensification of land-use within laneways across the city centre core.
Increased housing supply requires availability of zones and
serviceable land
The draft Development Plan states that there is approximately 550 hectares available to
develop during its lifetime. Whilst this land is zoned, it must also be serviceable to meet
the city’s projected housing need. Demand will be highest for land that is ready-to-go for
development, starting with land that has already been granted planning permission.
It is critical that funding is available to ensure sites can be provided with the necessary
supporting utilities and infrastructure. Only 45% of the cost of delivering a new home is
accounted for by the build cost. Additional measures such as a bridging finance scheme
will be required to better utilise the supply of zoned and serviceable land suitable for
housing.
Three separate lists of zoned land for housing should be categorised and prioritised in the
local development plans:
➢ Lands located near, and accessible to, adequate services to permit housing
development within a three-year timeframe.
➢ Lands which require services and infrastructure installation to make development
possible within three to seven years.
➢ Lands which require significant infrastructure and services installation to make
development possible beyond seven years.
Zoning decisions within the Development Plan 2022-28 should inform capital expenditure
decisions on supporting infrastructure to unlock development sites. In addition,
Government initiatives such as the URDF, Croí Cónaithe, and Project Tosaigh should be
actively targeted at advancing the serviceability of zoned land and to address site viability
issues, especially for apartment construction. The Development Plan 2022-28 should be
the basis of Dublin City Council’s interaction to strategically target national and European
investment funds to increase housing supply. This will require strong engagement with
property industry stakeholders.
18 Ibec Dubln & Eastern RECPlanning to deliver More than ever, there is a need for greater certainty for housing delivery. Problems associated with the planning process threatens the ability to deliver the target of 40,000 homes in Dublin city over the next six years. This housing target is the minimum required to address the housing requirements for the city. The use of judicial reviews has become excessive and has undermined the ability to provide key housing projects for Dublin in recent years. Projects are either halted or severely delayed. Legislative changes are urgently needed to ensure judicial reviews become the exception, not the norm. Government is to reform the judicial review process. This includes the introduction of a new division of the High Court for Planning and Environmental cases to reduce planning delays. Work is underway to overhaul and simplify planning legislation to ensure certainty and stability. Finally, Dublin City Council will be required to work constructively with all stakeholders to ensure that the new planning process for Large- Scale Residential Developments is an effective replacement for the Strategic Housing Development process. Uncertainty must be removed because of its impact on the investment climate for housing delivery. Planning capabilities at local authority level have been reduced over recent years. Yet, Dublin City Council is usually the first point of call on planning matters. The local development plan making process, National Development Plan commitments and private sector investment will compound the demand for planners and other key skills further. Resources must be directed to the planning functions to allow Dublin City Council to meet the demand set out in the Development Plan 2022-28. A programme to upskill existing local authority staff is needed to provide a more active role in performing the planning including forward planning, regulatory policy, development management and enforcement. In addition, sharing of planners and other specialist skills between local authorities in the region must be encouraged. This will ensure professional and timely planning operations can be maintained. It would allow an individual local authority scale to meet short-term or immediate pressures because planning applications can vary in size, complexity, and timeframe. This is in addition to the required investment in e- planning. Draft Dublin City Development Plan 2022-28 19
Sustainability: Climate action (Chapter 3) Pathway to the decarbonisation of the city As of July 2021, Ireland is legally bound by the European Climate Law to take the necessary action to achieve net zero greenhouse gas emissions by 2050. Government’s Climate Action Plan 2021 outlines a plan for Ireland to meet its climate targets under the Climate Act 2021 and the European Climate Law. A key commitment is the 51% reduction of greenhouse gas emissions by 2030. This increase in ambition reflects a greater understanding of the threat posed by climate change and the closing window for an effective response. Ireland’s climate targets pose an enormous challenge as progress remains slow on reducing emissions; the 2021 Climate Change Performance Index ranked Ireland 46th out of 60 countries. The temporary 6% fall in emissions during the 2020 lockdown reveals the full extent to which our economy remains wedded to carbon, and our lack of progress in recent years. Sustainability must underpin the plan to ensure that the development of the city over the years leading to 2030 is conducive to meeting our environmental targets. Only through an escalation in sustainable investment, and a major transformation of Irish society, will we be able to deliver the emissions reduction needed to meet our new targets and play our part in the global effort to combat climate change. A cleaner and more resilient environment brings both societal and economic benefits. Climate proofing is critical to ensure that the Dublin City Development Plan is effective and to allow the delivery of a low carbon, climate resilient, and environmentally sustainable economy. The Development Plan will need to facilitate the incorporation of long-term emissions considerations in planning and infrastructure decisions across Dublin city. Many infrastructure and development decisions are effective over several decades and hence decisions in the 2020s could affect Ireland’s emissions profile in 2050. More effective land planning and development will be needed to increase Dublin city’s resilience to climate change, reduce emissions and support the delivery of vital energy infrastructure. 20 Ibec Dubln & Eastern REC
Promoting effective urbanisation: Shape and
structure of the city (Chapter 4)
Increase density to promote urbanisation
Ireland is a low-density country. This has significant implications for policy making.
Dispersed development affects the cost of transport infrastructure and service provision,
as well as impacting sustainability and our quality of life. There are environmental,
economic, and social benefits of denser living, which Ireland has not yet fully harnessed in
urban, suburban, or rural areas.
Table 1: Density measures across Irish cities
Households per km² Households per ha
Dublin City and suburbs 1468 15
Cork City and suburbs 495 5
Limerick City and suburbs 677 7
Galway City and suburbs 633 6
Waterford City and suburbs 508 5
Total City and suburbs 998 10
Transport infrastructure, the cost of living, sustainability, and the built environment are
all affected by how well space is utilised and they play a role in determining the quality of
life. The pattern of dispersed development across the wider Dublin metropolitan area and
beyond must be countered. Globally, the past 50 years has been a period favouring
suburbanisation and urban sprawl. More recently the trend has been reversed. There is a
return to focusing on the city core as the focal point for growth. It is important that the
new Development Plan 2022-28 demonstrates strong commitment to urbanisation
polices, ending the pattern of pro-suburbanisation in practice.
Paris has double the population density per square kilometre than Dublin, and it’s five
times greater in London. Why is density important? Cities concentrate productivity,
innovation, and creativity. Higher density cities are more successful across these areas.
Therefore, increased density is crucial to a metropolitan region’s economic future. It can
enrich character, place, and identity, which boosts attractiveness and overall
competitiveness.
Draft Dublin City Development Plan 2022-28 21Dublin will require a significant increase in density. A new pragmatic approach must be taken by its constituent local authorities, supported by all appropriate national guidance to ensure well-designed higher density development can be delivered in specific locations. Higher density development can encourage more affordable housing by spreading construction costs across more housing units within a development, which also increases the viability of site development and works. The Metropolitan Area Strategic Plan (MASP) should champion well designed and higher density developments within the metropolitan areas without loss of high-amenity green spaces. The MASP’s active land management strategy ranging from metropolitan through to local implementation must fully support the objectives of compact, smart growth through urban infill. Table 2: Population density in European cities, people per km² (Source: OECD) Density must be part of planning for a post-COVID world. Restricting movement, reducing daily interactions, and social distancing practices have been mistakenly confused as arguments against density and urbanisation. Political, media and general commentary on an exodus from cities due to infection risk is concerning. The OECD found that the “health problem is not related to urban density but rather to structural inequalities and the quality of urbanisation; and the urban premium will likely not turn into an urban penalty as agglomeration benefits continue to prevail”. The Development Plan 2022-28 must be steadfast in its commitment to support the sustainable development objectives at the heart of the NPF. Compact, urban growth, not ineffective low-density measures, must be implemented through effective alignment of the local development plan with the NPF. The “foundation of modern city planning” remains true, the planning system must “continue to practice and advocate for compact places rather than sprawling ones due to several environmental, transportation, health, and economic benefits of compact development confirmed by dozens of empirical studies” (Hamidi et al, June 2020). 22 Ibec Dubln & Eastern REC
A sensible approach to building heights
A sensible approach to urban building height limits will make a significant contribution to
delivering the core objective of compact, urban growth. A focus on height will allow us to
address the problems of urban sprawl, housing and commercial space shortages and
improved densification.
Average building heights in Dublin are lower than other cities across Europe, including
comparably sized cities like Amsterdam, Copenhagen, and Stockholm. Paris is regularly
cited as an example of a city that is low-rise. However, Paris’s building height average is
30% higher than here in Dublin. It also has double the population density through taking a
consistent approach to development across the city.
Table 3: Average building heights (Source: Copernicus Urban Atlas)
12
10
8
Metres
6
4
2
0
The approach taken by local authorities is inconsistent and incoherent. Developments in
Cork City and Dún Laoghaire-Rathdown (e.g. Sandyford) are taller than projects initiated
in the Dublin City Council area. Blanket restrictions on height in local development plans
have resulted in sites within areas in need of redevelopment and regeneration, being
underutilised, sterilised, or inadvertently making a proposed development financially
unviable.
It is both important and appropriate that the new Dublin City Development Plan 2022-28
allows for increased height in developments. This includes incorporating the Urban
Development and Building Heights Guidelines for Planning Authorities (December 2018)
into the development plan. This ranges from default minimum height standards such as
six storeys within central urban areas. The ‘comply or explain’ principle should apply,
where developments lower in height must be justifiable.
Dublin city requires a specific tall buildings strategy, earmarking locations for such
development. The Council on Tall Buildings and Urban Habitat considers ‘a building of 14
or more storeys – or more than 50m in height – could typically be used as a threshold for
Draft Dublin City Development Plan 2022-28 23a “tall building”’. This is double the permissible height for residential developments in
central Dublin. Of the current 14 specific areas identified for mid-rise (up to 50m) and
taller (above 50m) buildings, we already have examples of failed planning applications in
these areas despite their designation in policy.
Development plans must include a clear statement on taller buildings in relation to
sustainable development, within appropriate locations within the metropolitan area. In
developing policy on building height, attention should be paid to international best
practice in urban design and regeneration. There should also be acknowledgement that
clusters of well-designed taller buildings can provide housing and make a beneficial
contribution to their surrounding streetscape and skyline. The focus should be on actively
promoting good design within the context of place-making.
Ibec commissioned research undertaken by Behaviour & Attitudes on Irish adults’ views
and opinion of the Irish housing market. This national survey of 760 adults (sample
representative of 3.71 million adults aged 18+) was conducted in April 2021. The research
shows the public appetite exists to revisit the existing approach to low building heights.
Whilst a significant generational gap exists in attitudes towards building heights, the
research found that two-thirds of the adult population is in favour of buildings over six
storeys in height. Other key findings from the research include:
• 62% of all respondents in favour of increasing number of tall buildings
• Two-thirds of the adult population is in favour of the development of 6 to 12
storey buildings in appropriate areas
• The proportion in favour of 6 to 12 storey buildings in appropriate areas, rises to
circa three-quarters of those planning to purchase a home at some stage over the
next ten years.
• 69% of 18–34-year-olds favour increasing the number of tall buildings in Irish
cities.
• Of those who are currently living in their family home, 73% are supportive of
increasing the number of tall buildings.
• Regarding 6-12 storey buildings in appropriate areas, support amongst those
planning to purchase a home at some stage over the next ten years stands at just
below three-quarters.
• 82% of those in the pre-family life stage favour 6-12 storey buildings in
appropriate areas.
Building for height and density often attracts opposition from local homeowners.
However, it is key to the sustainable growth of cities and is necessary for increasing
housing supply in urban areas. The research shows that two-thirds of the adult population
is in favour of the development of 6 to 12 storey buildings in appropriate areas. This is in
line with default minimum height standard of six storeys set out in the Urban
Development and Building Heights Guidelines for Planning Authorities (December 2018).
24 Ibec Dubln & Eastern RECThe ‘15-minute city’ requires sustainable neighbourhoods Achieving greater diversity of land use within urban areas will aid sustainable rejuvenation. This requires a better and more appropriate balance between residential, retail, and other commercial or business activity. According to the OECD, the crisis provides an opportunity to develop a new long-term strategy for urban spaces based on accessibility to amenities and services. This replaces previous thinking of designing cities from solely the logic of mobility, which has led to unsustainable commuting patterns. It requires a focus on the ‘localisation of the Sustainable Development Goals’, ‘tactical urbanism’ and of course, the ‘15-minute city’. The 15-minute city concept is not new. It has been core to good placemaking for decades. However, the lived experience of metropolitan inhabitants across the globe during Covid brought a renewed focus on attractive, adaptive, and healthy placemaking. Merely “bouncing back” is not sufficient, globally cities are looking to build back better. Dublin city must follow suit. Encouraging higher density within the city centre core is important. It on its own will not sufficiently lead to the achievement of the ‘15-minute city’ for Dublin. The Development Plan 2022-28 must place a strong emphasis on creating sustainable neighbourhoods. This requires ensuring that neighbourhoods across the city can access a range of facilities by walking, cycling, or high-quality public transport. Focusing on neighbourhoods is key. Some parts of the city may be ‘10-minute’ or even ‘5- minute’ cities, whereas other areas have inefficient or poorer access to transport or social infrastructure. We need to understand how each neighbourhood functions within a city that works. The Development Plan 2022-28 can support this through better integration of land use and transport planning, as well as informing decisions on the location of essential services. This approach would enhance the liveability of Dublin as well as boosting its attractiveness as a place to do business. Draft Dublin City Development Plan 2022-28 25
The enterprising city: City economy and enterprise (Chapter 6) and the city centre, urban villages, and retail (Chapter 7) Strategy for reimagining and rethinking Dublin The post-Covid economic fate of the Dublin city area cannot be left to chance. It must be planned for and invested in. The Development Plan 2022-28 takes on added importance in promoting growth that is sustainable and resilient. Immediate challenges, if not mitigated or addressed, will cause lasting damage, and undermine the sustainable recovery agenda. Dublin city centre particularly has been deeply affected by the crisis. The city requires a fundamental rethink so it can realise its full potential once more. There is a strong interdependence between the planning, development and creation of an attractive environment and enterprise development. Companies are attracted to invest in locations where they access skills, where people will want to live and work and where the surrounding infrastructure is supportive of business (including, for example, transport and broadband networks; education and training facilities etc.). Establishing a strong sense of place contributes to the attractiveness factors for entrepreneurship, for business investment, for foreign direct investment (FDI), talent and tourism. The focus must be on re-intensification of existing business locations. This strategy aims to create the right conditions for enterprise to thrive, to create wealth and improve quality of life for all. Key aspects are orderly growth, placemaking, smart specialisation and clustering. Consideration is given to future proofing risk management so that growth is sustainable, competitive, inclusive, and resilient. Skills, talent, and innovation are identified as drivers for resilient and sustainable growth. Dublin city must be developed in terms of its economic self-sufficiency to minimise the need for commuting and support the development of surrounding areas. This would support locally generated employment and create prospects for growth. Employment creation will come from a broad base of possible activities; it is critical that potential is recognised and supported across a range of possible sources both indigenous and from overseas. We must help firms: attract and retain scarce talent; maintain a greater focus on supporting indigenous enterprises; and commit to underscore Ireland as a beacon of certainty for mobile investment in an increasingly uncertain global economy. Employment, along with social protection and pension systems, needs to support easy career transitions. The city centre will have to be rejuvenated but it will also need to be reimagined. They must be able to adequately respond to trends that have accelerated over recent years, including those that experienced hyper-acceleration at the outset of the crisis. These include the effects of continued growth in hybrid working and online retail on town centres. Increasing footfall is one priority and is important to helping town centre businesses navigate the current crisis. For example, there are approximately 270,000 office-workers in Dublin. This represents over half a million potential trips to and from 26 Ibec Dubln & Eastern REC
work each day. These people would pass by shops, cafes, bars, or restaurants. This does not factor lunchtime into this equation, nor does it include the 110,000 students studying in the region or the impact tourists have on footfall in Dublin city. The rapid acceleration of remote working will present challenges to encouraging “reverse commuting” in attracting people into the urban centres from home after work. Traditional hubs of the experience economy clustered close to employment centres are now faced with competition from local experiences or neighbouring centres closer to home. Town centres will have to be reimagined to maintain their attractiveness and to compete harder for custom than before. COVID-19 has driven “hyper-localism”; with people exploring, re-discovering, and more importantly experiencing, their local neighbourhoods. These neighbourhoods have their own identity and if effectively supported, these could complement the growth of a sustainable economic activity across the city and the wider Dublin metropolitan area. Supporting retail through the mix of uses within the city core Dublin city will have to work harder than ever before to entice people into its urban core. Increasing footfall is one priority. Higher density within our towns will also make a beneficial contribution. Achieving a greater mix in uses within urban areas will lead to sustainable rejuvenation occurring. It requires achieving a better and more appropriate balance between residential, retail, and other commercial or business activity. This will require a collaborative approach between local business, the local authority and Government to be successful. Over the years, peoples’ shopping habits have shifted. Retailers across the city are facing challenges of online shopping, new shopping destinations in neighbouring local authority areas and people who want to shop later in the day and after work. The priority from the NPF is on urban infill, providing more housing on brownfield sites and in the urban core. However, mores homes will require more amenities across all times of the day. The commercial mix requirements of our Dublin city centre and towns within the local authority are changing, in addition to providing more housing within our urban centres. Zoning decisions must be pragmatic in supporting the development of cultural and leisure activities, as well as supporting activities such as restaurants, takeaways, night-clubs and increasing late-night premises, including those providing an alcohol-free alternative such as cafés and coffee-shops. A diversity of activities needs to be supported to ensure our cities, towns and villages are attractive, safe, and vibrant. Draft Dublin City Development Plan 2022-28 27
Supporting the development and enhancement of Dublin’s experience economy Dublin’s experience economy encompasses hospitality, retail, travel, food, drink, tourism, entertainment, technology, events, and organisations in the arts, cultural, sporting and heritage sectors. It reaches deep into the supply chain supporting business and employment encompassing many of hard to reach but critical elements of the economy and society: young people, small medium enterprises, regional and rural development, with real, tangible benefits for the entire country. Dublin City Council must support the support the development and enhancement of the city’s experience economy. This can be achieved through the Development Plan 2022-28 and other local initiatives. It is interconnected with other measures such as tourism, the night-time economy and addressing the commercial mix within the city core. Ultimately, Dublin city must be safe, family- friendly and attractive for inhabitants and visitors alike. The pragmatic response of Dublin City Council to Covid in terms of actively supporting outdoor seating and the use of the public realm should be become a positive legacy of the crisis. Efforts such as this, pedestrianisation initiatives, and the creation of new public spaces will improve local destinations. It is important that positive and constructive engagement between the local authority, other public stakeholders and local businesses continues over the lifetime of the Development Plan 2022-28. The night-time economy The night-time economy is a core component of the wider Experience Economy and will be key to revitalisation and growth of the cities, towns, and villages across the country. Local authorities will play a key role in ensuring policies, planning and local regulations will support the growth of the night-time economy, across a local authority area in addition to conserving core aspects of the night-time economy during this challenging period. Dublin City Council is far more advanced than most local authorities in considering this part of the economy. It held a Night-Time Economy Forum and had established a working group on tourism, city markets including the night-time economy under its Economic Development and Enterprise SPC. Through the Lord Mayor and senior officials, the city was strongly represented in the work of the Government’s Night-Time Economy Taskforce. Dublin City has been designated one of the six pilot local authorities by the Night-time Economy Taskforce. A specific night-time economy for the city is to be development. It is envisaged that the position of a night-time economy advisor will be established to coordinate delivery of the strategy. The Development Plan 2022-28 must take the broadest view of the night-time economy. This is in keeping with work done in cities across the globe. The starting point must be to define the constituent parts of the night-time economy. This includes defining the range of activities, employment and businesses involved. This was the starting point for both Manchester and London in their respective approaches to transforming the night-time 28 Ibec Dubln & Eastern REC
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