Feasta & Smart Taxes
14 St Stephen’s Green
Dublin 2
Emer O’Siochru
Tel: 086 8267555
Email: e...@smarttaxes.org
Submission re Regional Planning Guidelines for Greater Dublin Area.
26.3.2010
Chapter 1:
The challenges listed does not include the threat to fossil fuel energy supply and its financial and economic consequences. The Regional Planning Guidelines should have included considerations of the outcome of the National Renewable Energy Action Plan (NREAP) due to be finalised in June as it will impact considerably on planning issues and economic incentives.
The Regional Waste Management Plans fall into no less than 4 different regions none contiguous with the borders of this Regional Plan. This situation can only lead to confusion and inefficiency. Household waste is mainly generated in settlements particularly urban settlements so it follows that Waste Management Plans should be urban centric. Agricultural waste is generated in more even distribution but nevertheless benefits from consideration in tandem with food wastes when landspread is included.
There should be a general requirement to size waste facilities to optimise their functioning – scale does not always deliver economies in an energy scarce future. There should be strong direction to local authorities to encourage more integration of household food and agriculture wastes processing with energy generation and nutrient recycling. The strategic elements listed divide the subject into artificial areas for policy and implementation that closes off whole avenues of potential solutions. A concentration on waste to energy systems disadvantaging anaerobic digestion of agricultural wastes which do not deliver high energy outputs but do deliver important and valuable environmental services.
Chapter 2: The vision should include an objective of building resilience in the face of reasonably predictable endogenous and exogenous shocks. Sustainability should be cited first before the economic objective so that the three components of sustainability, environmental, social and economic guides the monitoring and accounting systems proposed by the Regional Planning Guidelines for local authorities.
Chapter 3: This section does not refer to the very constrained public and private financial environment suffering unprecedented levels of debt which will have extraordinary impacts on investment levels, not only in the greater Dublin region but in the entire nation. Thus it does not contain useful guidance on measures to address the challenge. The financial services sector for instance, is unlikely to be the key driver of growth contrary to the prediction by the ESRI Mid Term Review, if there is sovereign default which is not unfortunately, beyond the bounds of possibility. Reform of the current Money system or/and complementary money systems supporting local economic activity are not explored or encouraged.
Discussion of the utilities in this chapter is very un-ambitious given the earlier paragraphs emphasis on innovation and technological excellence.
3.5.8 The lack of direction is very apparent in the discussion of waste treatment and of water supply issues. The option of investing in reduction of demand for potable water by retrofitting low flush or vacuum toilets and vacuum pipe work systems is missing entirely. The logic of expensive treatment and long distance transportation of potable water only to dump biological waste into it is unchallenged. Rainwater harvesting and grey water recycling is absent in policies for infrastructural provision although they is now well recognised in good practice building construction.
Chapter 4: Population trends and targets appear high in light of the increasing immigration of young people form both native and new Irish cohorts. A contingency study for a lower population projection might be wise so that capital investment is not wasted in underused infrastructure and facilities that carry a high burden of maintenance and operation costs.
The cited MOLAND modelling tool would be considerably enhanced by the addition of land ownership information and of land values trends. The guidelines should emphasise to local authorities the value of Geographical Information Systems (GIS) coupled with economic information on land for monitoring and feedback purposes.
The settlement hierarchy does not give sufficient attention to villages, leaving them to be defined by the tender mercies of local authority Development Plans. There is no guidance for the creation of new villages to replace those lost due to misguided anti-village policies of the past. Rapid growth of villages is unlikely for some time but when pressure builds again, it should be met by the creation of new villages planned and developed not-for-profit in partnership with local authorities to cater for a clear demand for self-build housing in rural areas. As the village is the only form of rural settlement that can be considered sustainable in a low carbon and energy constrained future, this omission is unacceptable in this Regional Guidance document.
No direction is given to local authorities on the NAMA estates on the outskirts of many villages and towns. Are they to be left to market forces, left empty and derelict or become social /immigrant housing centres or should they be demolished? Could they be enhanced by nearby embedded energy projects using local biomass and waste resources? Could they be given to elderly residents to entice them to relocate from their remote single rural houses so that the burden of servicing them is gradually reduced (see also below).
Chapter 5: Rural development centres on the topic of rural housing rather than the more appropriate topics of stimulating and supporting food and energy production in rural areas. Rural housing should be covered by the settlement strategy under villages in Chapter 4. New housing in the open countryside outside of a village should only be permitted if ancillary to a rural activity. The current ‘Sustainable Rural Housing Guidelines’ should not be cited but be reviewed as a priority in light of their manifest failure to impact on dispersed housing in the countryside which is now comprises 75% of all new housing construction.
Furthermore, there appears to be no guidance provision to address the poor planning control of previous years that has left a legacy of expensive to service and social segregated single houses in the countryside.
Para 5.4.4 requires policy guidance that recognises the important role of anaerobic digestion in rural areas to reduce greenhouse gases and nitrogen pollution of groundwater’s as well as energy generation. The Greater Dublin Area has far more and better renewable resources in bioenergy than it has in wind a fact not acknowledged anywhere in this document.
Chapter 6: The Greater Dublin Regional Guidelines refers to integrated delivery of infrastructure with settlement and economic strategy, which is commendable and the least one would expect. However, it does not address the potential synergies in the integration of types of infrastructure. Key Infrastructure provision is treated under separate headings i.e. Water Supply is discussed separately from Surface Water Treatment ; Ditto Waste Water, Waste Management and Energy. This institutionalises linear process engineering that leads to costly externalities. It prevent innovation and technological advancement in developing closed looped systems more in sympathy with ecological systems and more likely to deliver breakthrough cost savings.
6.3.6 There is no guidance to local authorities on making walking and cycling safer in rural areas where most fatalities actually occur. In particular, speed limits on back roads should be substantially reduced form the current unsafe level. Rural single houses are homes to a higher percentage of overweight children than their urban counterparts due to lack of safe walks. Local authorities should be directed to designate ‘green roads’ where people may safely walk and cycle and where speed is discouraged by bends, hills and trees and hedgerows that also supports biodiversity and environmental services.
6.7.1 The promotion of economies of scale in waste management should be deleted and replaced by appropriate scale for the waste process proposed in consideration of environmental impacts of transport movements and of the benefits of distributed ownerships of energy assets.
A new recommendation relating to biological waste to agricultural objectives should be inserted as follows: -
Biological waste especially energy dense food waste should be cleaned and pasteurised in a suitably large, appropriately-zoned site. However, the final processing of pasteurised bio waste should be carried out in small plants in rural areas in conjunction with agricultural wastes such as slurry near their final destination for land spread. This would also facilitate the financing of anaerobic digesters in rural areas for renewable energy, orgnaic fertilizers and valuable environmental services. It also completes the food nutrient cycle enabling the long term agricultural production without eventual soil depletion.
Chapter 7: This chapter should cover the built heritage as environmental consideration should have been built into all of the other chapter subjects. Environmental considerations are not an added issue having set economic and other goals but are the arena in which the other goals and strategies are developed and implemented. Green infrastructure should be an redundant description.
Chapter 8: This chapter purports to support the others in terms of design quality, arts culture, social inclusion and participative governance systems. It fails to address underlying equality and justice issues than in turn underlie these ‘softer’ issues. These issues are fundamentally about who pays for and who benefits from the main sources of human wealth, the natural and cultural commons. Local taxation is the counterpart of local representation in government, whether central or local. The role and structure of local charges and taxes such as site value taxation and water charges (included of the agreed programme for government) should have been incorporated so that citizens and local representatives could understand how planning, democracy, social inclusion and culture is supported by these invisible but nevertheless powerful systems.
Chapter 9: We welcome the increased attention to flood risk part of the required adaptation strategy to unavoidable climate change. However, it does not address other potential natural risks such as storms, heavy snowfalls, drought and disease. Many of the measures to mitigate flood risk will be useful for to mitigate the impact of these other events but many are unique and need specialised responses. Risks of financial and monetary breakdown are not addressed at all. In preparing and planning for future shocks, local people should have enhanced and affordable access to spatial information about their environment so that they can augment local authority emergency planning with their own at local level.
Chapter 10: The set of indicators proposed by the Regional Planning guide does not include land valuation mapping. Land valuation changes provide an index of how environmental, social and economic forces affect the location whether positive of negative. When combined with the other spatial data required for environmental monitoring, agricultural productivity and carbon accounting, they give decision-makers a perspective no other form of indicators such as lists, scores and reports can offer.
