This amendment will create huge uncertainly as to the zoning status of zoned land in every LAP area in the County, including Bray. A large planning application generally takes at least a year to prepare and may take up to another year to work its way through the planning system. Certainty of the planning policy environment is therefore of critical importance both for an applicant and for the general public.
Land is only zoned in a Development Plan or Local Area Plan if it is serviced and capable of being developed and if its development is in accordance with the proper planning and sustainable development of the area. Developers buy zoned land in the expectation that the land continues to be developable for the life of the plan.
The effect of the proposed amendment will be to massively increase the uncertainly around the planning process. An applicant (or third party) will have no way of knowing whether the housing target has been hit at the time the application is being assessed and therefore whether the permission will be granted or not.
Furthermore, its widely understood that the grant of a planning permission does not guarantee that a scheme will be built. Indeed, the perceived ‘hoarding’ of planning permissions in recent years has been widely criticised and is perceived to be contributing to the housing crisis. The Croí Cónaithe scheme (cited below) has identified the fact that 70,000 ‘uncommenced planning permissions’ exist in the five cities. The effect of this proposed amendment will be to exacerbate this problem. It will increase the risk of planning applications being made simply to ‘bank’ a quota of the housing target for a particular town.
While Ballymore agrees with the concept of compact growth, the idea that a planning application that is otherwise entirely consistent with the proper planning and sustainable development of a town, and will go towards addressing the housing crisis, might be refused planning permission only because it might breach a notional ‘housing target’ is extraordinary and very hard to understand.
If implemented, it would undermine confidence in the entire planning system. If there is no intention of implementing it, it should not be included in the Plan.