EMRA Submission

The Assembly acknowledge the work that has gone into the preparation of Chapter 2 which details the Core Strategy and Settlement Strategy.  
As part of Chapter 2, the Assembly welcome the inclusion of the chapter aim, that is to ‘Provide for the growth of County Laois in line with the National Planning Framework/ Regional Spatial and Economic Strategy (RSES)’. In addition, the clear indication at Section 2.1. of the Draft Plan, that Planning Authorities are required to prepare and incorporate a Core Strategy that shows the Development Plan is consistent with national and regional objectives under the National Planning Framework (NPF) and the relevant Regional Spatial and Economic Strategy (RSES), is welcome.  

2.1 Statutory Requirements 
Laois County Council are reminded of their obligations to prepare a Core Strategy in accordance with the provisions of Section 10 of the Act. Relating specifically to this chapter of the Draft Plan, the Assembly draws the attention of the Council to the contents of Section 10 (2A), (2B) and (2C) of the Act and asks Laois County Council to ensure consistency in this regard.  

2.2 Core Strategy 
2.2.1 Core Strategy Policy 
Section 2.2. of the Draft Plan outlines a number of Strategic Aims that relate to the advancement of the plan. These are supported by a number of Core Strategy Policy Objectives at Section 2.8. These are considered to provide a robust framework for the Core Strategy and includes, alignment with the NPF and RSES, achieving sustainable compact growth targets of 30% of all new homes that are targeted in settlements within their existing built-up footprints, acceleration of the transition to a greener, low carbon and climate resilient county, and, the preparation of supporting Local Area Plans. 

The inclusion of Strategic Aim VII which outlines that the Planning Authority will monitor and maintain a record of residential development permitted in settlements designated under the Settlement Hierarchy in order to ensure compliance with the population allocations defined by the Core Strategy, is welcomed. It is recommended that this should be amended to also include the monitoring of residential development permitted as single rural houses. This is reflective of NPO 36 of the NPF which outlines that ‘New statutory guidelines, supported by wider methodologies and data sources, will be put in place under Section 28 of the Planning and Development Act to improve the evidence base, effectiveness and consistency of the planning process for housing provision at regional, metropolitan and local authority levels. This will be supported by the provision of standardised requirements by regulation for the recording of planning and housing data by the local authorities in order to provide a consistent and robust evidence base for housing policy formulation.’  

2.2.2 Population Allocations 
The Core Strategy Table indicates a population increase for County Laois of 10,003 people until 2027 from the 2016 baseline population. This level of overall population growth is considered to be in keeping with the population prescribed for the County at Appendix 2 of the NPF Implementation Roadmap, which details a high-level population projection of 94,000 (high) to 2026 and 97,500 (high) to 2031.  
The Assembly also notes and welcomes the graded approach to the allocation of population in line with the Settlement Hierarchy. Notwithstanding the information provided, it is recommended that the Draft Plan be strengthened through the inclusion of a robust evidence base justification for the percentage allocation of growth to each of the tiers identified as part of the Core Strategy.  

2.2.3 Table Structure 
Notwithstanding the content of the Core Strategy Table, the Assembly consider that further clarification is required to ensure consistency and transparency. As part of the Table, there is no indication as to the quantum of residential land that is zoned as part of the Draft Plan and Local Area Plans. It is therefore recommended that the Core Strategy Table is amended to clearly demonstrate the quantum of land that is zoned for residential purposes in each of the respective settlement categories, across all zoning categories that provide for residential development in accordance with the provisions of Section 10 (2A) (c) and (d) of the Act.  

National Policy Objective 3c of the NPF requires that local authorities deliver at least 30% of all new homes that are targeted in settlements other than the five Cities and their suburbs, within their existing built-up footprints. This is reinforced by Regional Policy Objective (RPO) 3.2 of the RSES. Section 2.8 of the Draft Plan and The Core Strategy Table indicates that 33% of Laois’ housing need can be delivered on infill and brownfield land. It is noted however, as part of the Core Strategy Table, that this will not be achieved in some settlements. In light of the aforementioned policies, it is therefore recommended that the Draft Plan be amended to clearly provide an evidence-based rationale and justification for same.  

2.3 Settlement Strategy 
The Assembly notes and welcomes the inclusion of Section 2.4 of the Draft Plan, which details the strategic development of County Laois in the regional context of the Eastern and Midland Region. This includes building on the settlement strategy and hierarchy set out as part of the RSES, to define the settlement hierarchy for County Laois.  
It is noted that the Settlement Strategy for the County is also documented at ‘Volume 2- Settlement Strategy’ of the Draft Plan. The level of detail provided as part of Volume 2, serves to enhance the robustness of the Settlement Strategy of the Draft Plan. It is considered, however, that elements of Volume 2 should be included as part of the Settlement Strategy section within ‘Volume 1- Written Statement’. This includes for instance the stated Settlement Strategy policy objectives. In addition, the Local Authority may wish to consider changing the name of Volume 2 to ‘Town and Village Planning Statements’ or similar, to enhance the comprehensibility of the Draft Plan for users.  

2.3.1 Settlement Hierarchy 
The Assembly welcome the stated utilisation of an approach similar to the RSES’s ‘Asset Based Approach’ in determining the Settlement Strategy for County Laois, as per Section 2.4.2 of the Draft Plan. This is in keeping with RPOs 4.1 and 4.2 of the RSES which outline that the hierarchy of settlements in development plans shall be determined in accordance with the hierarchy, guiding principles and typology of settlements as set out in the RSES. 

The use of consistent terminology, reflective of that contained in the RSES, is appropriate and welcome. The Hierarchy is tiered as follows; Key Towns (Portlaoise and Graigecullen/ Carlow), Self-Sustaining Growth Town (Portarlington), Self-Sustaining Towns (Mountmellick, Abbeyleix, Stradbally, Mountrath), Towns and Villages, Villages, and Rural Remainder which includes the open countryside. 
Given the location of Portarlington, that straddles the administrative boundaries of both Laois and Offaly, the Assembly consider that this is an apt moment to engage with Offaly County Council on determining the future of Portarlington as a Self- Sustaining Growth Town.   

2.3.2 Settlement Strategy Policy 
The overarching Settlement Strategy policies are found at Volume 2 of the Draft Plan. As previously mentioned, the Assembly consider that it would improve the document if some of these policy objectives were incorporated into Chapter 2, Volume 1 of the Draft Plan.  

Notwithstanding this, the Assembly consider that the inclusion of policy related to particular settlement tiers, at Section 2.10 of the Draft Plan, is an extremely positive addition to the Draft Plan. It is noted that this section is reinforcing of policy contained within the RSES, and in particular policies 4.71 to 4.74 relating to Portlaoise.   

2.4 Housing Requirements 
2.4.1 Future Housing Requirements and Housing Need Demand Assessment 
The Assembly welcomes the inclusion of housing policy that has been informed by the Housing Strategy that includes a Housing Need Demand Assessment (HNDA) as indicated at Section 2.3.2 of the Draft Plan. The HNDA ensures that the draft plan is supported by a robust methodology to inform policies and funding initiatives around housing and land requirements, whilst supporting the preparation of the housing strategy and other related housing policy outputs. It is acknowledged that Laois County Council have undertaken a HNDA, as part of the Housing Strategy, in accordance with National Policy Objective (NPO) 37 and Regional Policy Objective (RPO) 9.5, during a time when the finalised HNDA guidance at national level was still to be confirmed. The initiative of the Council in this regard is extremely welcome. Notwithstanding this, the Local Authority will be aware of the recent publication ‘Housing Supply Target Methodology for Development Planning’ issued as Guidelines for Planning Authorities under Section 28 of the Planning and Development Act, 2000 (as amended) in December 2020.  In light of the content of this publication it is recommended that the Draft Plan, (including Sections 2.7, 2.8, the Core Strategy Table and Chapter 4) is updated to reflect the contents of this recent publication. Please note that officials within the Department of Housing, Local Government and Heritage have indicated that they are available to assist Local Authorities in applying these Guidelines to their respective areas.   

2.4.2 Residential Densities 
It is noted that provisions within the Draft Plan, including for instance, the Core Strategy Table and Policy Objectives CS 15, 20 and 24, provide for a graded reduction in residential densities in line with the Settlement Hierarchy, reflective of the existing character of the settlement and linked to infrastructural capacity. This is in keeping with the RSES and NPF, including for instance page 73 of the NPF which states ‘Rural town living requires a proportionate and tailored approach to residential development. This means that it is necessary to tailor the scale, design and layout of housing in rural towns to ensure that a suburban or high-density urban approach is not applied to a rural setting and that development responds to the character, scale and density of the town’.   

The inclusion of a chapter dedicated to the provision of housing within County Laois is a positive addition to the Plan, underpinned by the chapter aim that seeks ‘To facilitate the provision of housing in a range of locations to meet the needs of the County’s population, with particular emphasis on facilitating access to housing to suit different household and tenure needs in a sustainable manner and in appropriate locations.’ The Assembly acknowledges the extensive work that has gone into the preparation of this chapter in order to secure the implementation of the Laois County Housing Strategy.

 
As stated above at Section 2.4 of this submission, The Department of Housing, Local Government and Heritage, in December 2020, published ‘Housing Supply Target Methodology for Development Planning Guidelines for Planning Authorities’, under Section 28 of the Planning and Development Act, 2000 (as amended). Accordingly, it is recommended that the Draft Plan be updated to comply with the aforementioned guidelines prior to the finalisation of the Laois County Development Plan.   

4.1 Housing Policy 
The inclusion of a number of housing development policy objectives to ensure the provision of housing needs within County Laois is welcome. This includes, for example, policy and objectives related to the provision of an appropriate mix of housing types and sizes, the provision of appropriate residential densities, provision of specific housing needs for groups including the elderly, and securing the implementation of the Laois County Housing Strategy in accordance with the provision of national legislation and relevant policies and standards. 

In order to strengthen the Draft Plan, Laois County Council should give consideration to the inclusion of a clearly presented summary of the entire housing need in County Laois, which includes the housing need broken down across tenures, what is required in terms of new housing supply and why this is the case, including social and affordable needs, housing types and sizes. This will present a clear and concise guide as to what is required to successfully deliver the housing requirement for the County over the plan period. 

The assembly note the inclusion of policy objective HPO 4 which states ‘To engage in active land management and site activation measures, including the implementation of the vacant site levy on all vacant residential and regeneration lands, and address dereliction and vacancy to ensure the viability of towns and village centres, i.e. Portlaoise, Portarlington, Mountmellick and Graiguecullen.’ This policy objective is supported by Section 4.5.1 of the Draft Plan which identifies a number of regeneration sites, including key sites in Portlaoise and Portarlington. This is in keeping with RSO 2 and RPO 3.3 of the RSES.   

4.2 Open Countryside and Rural Housing 
The Assembly notes the inclusion of a rural development strategy as part of this section of the Draft Plan. It is indicated that this is based on ‘promoting sustainable rural development aimed at maintaining vibrant and viable rural communities while also seeking to transition to a low carbon society and protect the amenity, recreational and heritage value of the rural landscapes and countryside of the county.’ This approach, underpinned by 23 (no.) rural housing policy objectives, is welcome by the Assembly. 

The Assembly also consider the inclusion of Section 4.6.5 and rural housing policy RH23, which support the ‘Serviced Site Initiative’, as positive additions to the Plan. This is in keeping with RPO 4.78 which states that “Development plans should support the development of a ‘New Homes in Small Towns and Villages’ initiative which would augment the delivery of actions by local authorities, Irish Water, communities and other stakeholders in the provision of services and serviced sites to create ‘build your own home’ opportunities within the existing footprint of rural settlements to provide new homes to meet housing demand.” 

It is noted that included as part of this section of the chapter, is criteria detailing the requirement for housing in the open countryside. The intention of the Council to support the sustainable development of rural areas in Laois by encouraging growth and arresting decline in areas that have experienced low population growth or decline in recent decades and by managing the growth of areas that are under strong urban influence to avoid over-development, while sustaining vibrant rural communities, is noted and welcomed by the Assembly. Notwithstanding this, it is recommended that prior to the finalisation of the Draft Plan, the Council ensure that related policy in this regard is consistent with RPOs 4.80 and 4.81, NPO 19 of the NPF and the content of Circular Letter PL 2/2017 “Sustainable Rural Housing Guidelines for Planning Authorities 2005 – Local Needs Criteria in Development Plans.”  
It should be noted that the NPF requires that development plans quantify the demand for single housing in the countryside with National Policy Objective 20 outlining the requirement to ‘Project the need for single housing in the countryside through the local authority’s overall Housing Need Demand Assessment (HNDA) tool and county development plan core strategy processes.’ In this regard, it is recommended that the Council include the provision of same in line with any revisions undertaken to the Draft Plan resulting from the publication of the ‘Housing Supply Target Methodology for Development Planning- Guidelines for Planning Authorities’ published in December 2020.  

The Economic Development Chapter presented as part of the Draft Plan is welcomed by the Assembly. The overall aim of the chapter is ‘To promote and develop Laois’ economy and create a viable and favourable economic environment for business and enterprise to thrive both in urban and rural areas whilst delivering sustainable jobs, employment opportunity both within the County and beyond.’   

Notwithstanding the inclusion of the policy context at Section 6.2, it is considered that the Council should consult with Chapter Six of the RSES, including Figure 6.3, in advance of finalising this chapter in order to strengthen the chapter structure and content. This includes reference, for instance, to the provision of policy relating to smart specialisation, clustering, placemaking, orderly growth and future proofing.  

The inclusion of an economic profile of County Laois is a positive addition to the Plan. However, it is considered that this economic profile could be further developed in order to create a strong and robust evidence base for the formulation of related economic policy.  
The Assembly welcomes the inclusion of Section 6.9 related to Climate Action and Jobs. This is reflective of RPO 6.9 of the RSES which seeks to ensure that the Midlands is well positioned to address the challenges posed by the transition to a low carbon economy and renewable energy. The Assembly welcomes the inclusion of reference to the CUBE at Portlaoise, a Low Carbon Centre of Excellence, that will act as a focal point for the development of new business and economic activity and that in turn will support and assist a transition to a low carbon economy. This is a timely development and its inclusion is supportive of RPO 4.72 which supports the transition of Portlaoise to a low carbon town centre.  

As part of the related ‘Climate Action and Jobs’ theme, it is recommended that the Council address the concept of Just Transition given its substantial policy and financial support, both nationally and at EU level, and that it is a significant catalyst for economic and social change in the Midlands representing a significant step forward in the transition towards a low carbon economy.  

As part of Section 6.11, the Assembly welcomes the indication that the primary place for job creation will be in the Key Town of Portlaoise and also in the Key Town of Graiguecullen/ Carlow, where job creation and investment opportunities will be developed in collaboration with the Carlow County Council. This is to be supported by job creation in Portarlington. Notwithstanding this, it is considered that the final plan should include an explicit policy objective that reinforces the spatial expression for the development of the County in line with the Core Strategy, ensuring that the economic development hierarchy is reflective of the settlement hierarchy presented.   

The Assembly notes and welcomes the inclusion of Policy Objective ED 2 which aims to support the development of J17-National Enterprise Park in line with RPO 4.73 of RSES. In addition, the inclusion of Policy ED 3 which aims to ‘provide a landing space for businesses who wish to establish a second site in a more competitively priced location’ is noted. Notwithstanding this, and related policy inclusions, a Midland Economic Paper currently being prepared by the Eastern and Midland Regional Assembly, has found a shortage of appropriately sized land banks and FDI/IDA appropriate business premises throughout the Region, including in Portlaoise. In this regard, the Assembly ask that the Local Authority consider the inclusion of a complimentary policy and/or objective, to enable the delivery of same. The addition of a policy to this effect, shall ensure that the inclusion and quantum of any related lands is in accordance with the provisions of the Core Strategy and evidence based. The Midland Economic Paper is forthcoming and may assist the council in the finalisation of the content of this chapter.  

The inclusion of a stand-alone Tourism Chapter is a welcome addition to the Draft Plan. The overall aim of this chapter, outlining the role of the tourism sector as an economic driver, is welcomed. It is considered that the aim, however, could be strengthened through recognising additional benefits of tourism for County Laois that includes environmental and cultural advantages for instances.  

The RSES recognises the important role that tourism plays in County Laois, including as a Growth Enabler for the Gateway Region as identified at Section 3.2 of the RSES, as a means to enable and sustain the rural economy as per Section 4.8 of the RSES, and as a sectoral opportunity for the Midlands as per Section 6.4 of the RSES. It is considered that the content of the Tourism Chapter is reflective of the RSES, including the suite of related policies, namely RPOs 6.8, 6.15-6.18 and 6.21, that seek to enhance the Tourism Sector, and RPO 6.19 that specially deals with tourism development in County Laois.  

The inclusion of Map 8.1 as part of the Draft Plan provides an excellent and visually appealing demonstration of the tourist attractions within the County, which is supported by Key Tourism Initiatives listed at Table 8.1 including reference to the Slieve Bloom Mountains, events and festivals, greenways and blueways, rural tourism and the wealth of heritage attractions the County has to offer such as the Rock of Dunamaise, Aghaboe Abbey, Stradbally Hall, Timahoe Round Tower, Abbeyleix Heritage House and others such as Emo Court and Donaghmore Famine Workhouse Museum. Specific policy objectives relating to Climate Change and Tourism are positive and timely additions to the Draft Plan.  

The Infrastructure Chapter provided as part of the Draft Plan, with the stated aim to ‘to achieve a sustainable, integrated and low carbon transport system for the county and to protect, improve and extend water services and other enabling infrastructure in line with national, regional and local population and economic growth for the county’, provides a robust and overarching foundation for the development of infrastructure services in County Laois.

  
10.1 Transportation 
The Assembly welcome the inclusion of the transportation section of Chapter 10 of the Draft Plan, which coincides with Chapter 8 Connectivity of the RSES. Policies such as those relating to integrated transport and land use planning, roads infrastructure, car and cycle parking, electric vehicles, pedestrian and cyclists, and public transport are all positive additions to the Plan.   
RPO 8.6 identifies that in order to give local expression to the regional level Transport Strategy within the Region, in conjunction with the NTA, Local Transport Plans (LTP) will be prepared for selected settlements in the Region. This includes the settlement of Portlaoise and in this regard policy objective TRANS 5, which reflects this policy, is welcome. The Local Authority may also consider the identification of other settlements within the County, in line with the Settlement Hierarchy, that would benefit from a similar and coordinated approach. This may include Portarlington, for instance, which straddles the administrative boundaries of both County Laois and County Offaly, and is currently subject to a regeneration strategy.  

The inclusion of Section 10.1.7.1 relating to Greenways is a positive addition to the Plan. It is considered that this section of the Draft Plan, including policies related to the Barrow Blueway, the Slieve Blooms and South Laois, is in keeping with Section 7.7 of the RSES.  

10.2 Water and Waste Water Infrastructure 
The inclusion of this section is in keeping with Chapter 10 Infrastructure of the RSES. RPO 4.2 is relevant in this regard, requiring Infrastructure investment and priority alignment with the spatial planning strategy of the RSES whereby all residential and employment developments shall be planned on a phased basis in collaboration with infrastructure providers so as to ensure availability of adequate capacity for services (e.g. water supply, wastewater, transport, broadband) to match projected demand and so that the assimilative capacity of the receiving environment is not exceeded.  

Having regard to the aforementioned RPO, the inclusion of policies such as WS 1, WS 4 and WS 15 for instance, which promote co-operation with Irish Water during the lifetime of the Plan in the provision, upgrading or extension of wastewater collection and treatment systems in the County, and, to protect existing water infrastructure, to serve existing and planned future populations and enterprise in accordance with the requirements of the Core Strategy, are welcome inclusions within the Draft Plan. 

10.3 Environmental Services 
The Regional Assembly note the content of this section of the Draft Plan which details Waste Management (Waste Recovery, and Disposal and Enforcement) and Environmental Protection (Water Quality, Air Pollution and Noise) under the heading of Environmental Services.  

10.3.1 Waste Management 
The Assembly welcomes that the section of the draft plan dedicated to waste management that is framed by the concept of the Circular Economy. This is in keeping with the RSES including RSO 7 with respect to waste and ensuring greater resource efficiency to realise the benefits of the circular economy, and RPO 10.25 which outlines that development plans shall identify how waste will be reduced, in line with the principles of the circular economy 

10.4 Telecommunications 
The Regional Assembly welcome the recognition in the Draft Plan that the provision of high-quality telecommunications infrastructure is critical to advance the economic and social development of the County. The specific reference to broadband is in keeping with RPOs 8.25 and 8.26 of the RSES which supports the roll out of the National Broadband Plan.  
The incorporation into the Draft Plan of reference to the Laois Digital Strategy and provision of public Wi-Fi zones throughout the County, recognises the role of communication infrastructure and services in attracting inward investment and increasing competitiveness, and are considered to be positive additions to the Draft Plan. 

The Draft Plan outlines that the vision of Laois Digital Strategy is twofold and includes meeting the needs and aspirations of the people of County Laois in enabling them to benefit from digital technologies and infrastructures throughout the county, and to enable people to carry out their business in a more resilient manner, across all aspects of life including education, public services and entertainment. In keeping with this, it should be noted that the EMRA is participating in an Interreg Europe Project, Next2Met, that seeks to increase the attractiveness of the Midlands using soft digitalisation measures. The Assembly are currently preparing a funding application to enable the roll out of pilot actions, as part of this EU Project, in consultation with Laois, Longford, Offaly and Westmeath County Councils.   

The inclusion of this chapter with regard to the Built and Cultural Heritage of County Laois is welcome. In finalising this chapter, the Council should consult with Section 9.7 of the RSES. It is considered that the policies and objectives of the Draft Plan are in keeping with same, including for instance, a suite of policies that support the protection, reuse and refurbishment of Protected Structures, in line with RPO 9.30 of the RSES.  

The Assembly welcome the inclusion of the chapter detailing the Implementation and Monitoring of the CDP over its lifespan. The recognition and reference to the numerous funding streams available are positive additions. Chapter 12 of the RSES and Chapter 10 of the NPF, which detail implementation and monitoring measures, may provide further assistance in this regard.