Office of the Planning Regulator Submission

A Chara, 
Thank you for your authority’s work in preparing the Draft Laois County Development Plan 2021- 2027 (the Draft Plan).  
The Office of the Planning Regulator (the Office) wishes to acknowledge the considerable work your authority has undertaken in the preparation of the Draft Plan against the backdrop of an evolving national and regional planning policy and regulatory context. In particular, the Office commends the preparation of a Housing Need Demand Assessment (HNDA) (dated November 2020) to inform the Core Strategy and Housing Strategy in Appendix 3.  

More recently, you will have been notified of the Ministerial Circular relating to Structural Housing Demand in Ireland and Housing Supply Targets, and the associated Section 28 Guidelines: Housing Supply Target Methodology for Development Planning. The planning authority will, therefore, be required to review the Draft Plan, and in particular the Core Strategy, in the context of this guidance which issued subsequent to the Draft Plan. Further advice in relation to this matter is provided below. 

As your authority will be aware, one of the key functions of the Office includes strategic evaluation and assessment of statutory plans to ensure consistency with legislative and policy requirements relating to planning. In this regard, the Office has evaluated and assessed the Draft Plan, under the provisions of sections 31AM(1) and (2) of the Planning and Development Act 2000, (as amended) (the Act). 
Recommendations issued by the Office relate to clear breaches of the relevant legislative provisions, of the national or regional policy framework and/or of the policy of Government, as set out in the Ministerial guidelines under section 28. The planning authority is required to implement or address recommendation(s) made by the Office. 

Observations take the form of a request for further information, justification on a particular matter, or clarification regarding particular provisions of a plan on issues that are required to ensure alignment with policy and legislative provisions. The planning authority is requested by the Office to action an observation.  

A submission also can include advice on matters that the Office considers would contribute positively to the proper planning and sustainable development of the area. The planning authority is requested by the Office to give full consideration to the advice contained in a submission.  

OVERVIEW 
The Draft Plan is being prepared at a crucial time following the preparation of the National Planning Framework (NPF) and the Eastern and Midland Regional Assembly Regional Spatial and Economic Strategy (RSES) which seek to promote the rebalancing of regional development in a sustainable manner. The Draft Plan has proactively embraced many of the challenges and opportunities identified in the NPF and the RSES through the identification of opportunity / regeneration sites in the county’s settlements and the promotion of economic initiatives such as the J17 National Enterprise Park and the CUBE as a Low Carbon Centre of Excellence in Portlaoise. Other measures including those addressing climate change, which are promoted throughout the Draft Plan, are welcomed. 

The Office commends the planning authority for the visual quality and comprehensive nature of the Core Strategy map and settlement plans which translate a number of the key policy objectives contains in the Draft Plan.  

The Office supports the overall intended strategic approach of the Draft Plan in terms of population and economic growth which is supported with strong policy commitments for the regeneration and renewal of the county’s towns and villages, and a more integrated transport system.  
The planning authority will be aware that the Office’s evaluation of the plan is required under section 31AM(2)(a) to address, in particular, matters within the scope of section 10(2)(n) of the Act in relation to climate change. In this regard, the planning authority is commended for the approach used to integrate climate action into the Draft Plan, which identifies the local county targets in the context of national targets for climate action under four action areas. Notwithstanding, the Office has identified specific matters below that will need to be addressed including the absence of a county target for potential wind energy generation and the inclusion of a requirement for separation (setback) distances in the Wind Energy Strategy, which is contained in an appendix to the Draft Plan and not translated into a policy objective or development management standard in the written statement. Further, the Office raises concern with the adequacy of the Strategic Flood Risk Assessment which underpins the policies and zoning maps in the Draft Plan. 

The submission below and attached sets out 15 recommendations and 7 observations under following themes: 

See attachment for full submission