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OPR Case Study Paper CSP05
Climate Action and the Local
Authority Development Plan
March 2022
Climate Action and the Local Authority Development Plan Authors: Alexandra Revez, Connor McGookin, Mary Noll Venables, Barry O’Dwyer & Brian Ó Gallachóir
OPR Case Study Paper CSP05
Table of Contents
Tables ii
Figures ii
Acronym List iv
Acknowledgements vi
1.0 Introduction 1
2.0 Summary of Policy and Legislative Context 6
3.0 Framework to Understand Local Authority Climate Action Planning 11
4.0 High-level Review of City/County Development Plans 16
5.0 Local Authority Climate Action Planning Case Studies 30
6.0 Engagement with Planning Authorities 52
7.0 Conclusion 60
8.0 Guiding Principles Checklist 66
References 68
Appendices
A.1 - Identifying Elements of Good Practice 72
A.2 - Summary of Previous Baseline Emission Inventories 77
A.3 - Key Performance Indicators for the Local Government Sector 80
OPR Case Study Papers (CSP) provide investigative research and analysis on specific areas of
the planning system for practitioners, elected members and the public. The intention of the
Case Study Papers is to support planning authorities in the performance of their duties. For
the avoidance of doubt, Case Study Papers do not have the status of Ministerial Guidelines
under Section 28 of the Planning and Development Act 2000, as amended.* They are issued to
promote shared learning and highlight best practice, in accordance with the OPR’s statutory
remit to engage in education, training and research activities. Case Study Papers cannot be
relied upon as containing, or as a substitute for, legal advice. Legal or other professional advice
on specific issues may be required in any particular case. Any comments/feedback in relation
to this Case Study Paper may be sent to research@opr.ie.
*hereinafter referred to as the ‘2000 Act’.
i
Climate Action and the Local Authority Development Plan
Tables
Table 1-1. List of complementary projects and resources dealing with different
elements of local authority climate action planning 2
Table 4-1. Key activities and review insights of leading climate mitigation criteria 21
Table 4-2. Key activities and review insights of emerging climate mitigation criteria 25
Table 5-1. Dublin City (Draft CDP 2022-2028) - Climate action energy statement 46
Table 5-2. Dublin City (Draft CDP 2022-2028) - District heating enabled outline 47
Table 5-3. Wexford (Draft CDP 2021-2027) - List of considerations for solar PV
planning applications 48
Table 6-1. Emerging themes from the interviews on climate action integration
into planning 53
Figures
Figure 1-1. Definition of climate adaptation and mitigation 3
Figure 2-1. Timeline of climate legislation relevant to the local authority between
2010-2021 7
Figure 2-2. Overlapping timeframes of National Planning Framework, Regional
Spatial and Economic Strategies, LA development plans and LA
Climate Action Plans 10
Figure 3-1. EPA latest emissions data - Ireland’s greenhouse gas emissions share
by sector in 2020 [22] 11
Figure 3-2. The role of the local authority in climate action planning 12
Figure 3-3. Examples of climate action mapped to the framework on the role
of the local authority 13
Figure 4-1. Cross-cutting issues found from high-level review of development plans 18
Figure 4-2. Content analysis of climate mitigation criteria across 31 CDPs
and colour coded indication of average mentions 19
Figure 5-1. Laois (Draft CDP 2021-2027) - Table of climate action measures 31
Figure 5-2. South Dublin County (Draft CDP 2022-2028) - Climate action audit 32
ii
OPR Case Study Paper CSP05
Figure 5-3. Clare (Existing CDP 2017-2023) - Energy demand by fuel and sector 34
Figure 5-4. Clare (Existing CDP 2017-2023) - Resource potential by renewable
source maximum and planned 34
Figure 5-5. Carlow (Draft CDP 2022-2028) - Direct and indirect job creation
from renewable energy in Ireland 35
Figure 5-6. Carlow (Draft CDP 2022-2028) - Areas identified for solar development 35
Figure 5-7. South Dublin (Draft CDP 2022-2028) - Proposed cycle routes and projects 37
Figure 5-8. South Dublin (Draft CDP 2022-2028) – Sustainable mobility objectives,
modal share current and target 38
Figure 5-9. Cork City (Draft CDP2022-2028) - Walkable neighbourhoods graphic 39
Figure 5-10. Cork City (Draft CDP2022-2028) - Sustainable transport projects with
expected delivery timeline 40
Figure 5-11. Cork City (Draft CDP2022-2028) - 5-year cycle route plan 40
Figure 5-12. Roscommon (Draft CDP 2021-2027) - Core strategy table 42
Figure 5-13. Cork City (Draft CDP 2022-2028) - Strategic objectives for Cork City
2022-2028 43
Figure 5-14. Cork City (Draft CDP 2022-2028) - Density and building heights strategy 44
Figure 5-15. Carlow BEI - Example of CO2 emissions by sector [33] 51
Figure 5-16. Dublin City Spatial Energy Demand Analysis - Heat energy demand
density map [34] 51
Figure 6-1. Visual depiction of some key opportunities from interviews with local
authorities 55
Figure 6-2. The different stages of climate action planning in the context of the
preparation of a development plan 59
Figure 7-1. South Dublin Development Plan (Draft 2022-2028) - Benefits of
District Heating 64
iii
Climate Action and the Local Authority Development Plan
Acronym List
> 3CEA: 3 Counties Energy Agency
> AA: Appropriate Assessment
> BEI: Baseline Emissions Inventory
> BER: Building Energy Rating
> BU: Bottom-up Approach
> CAP: Climate Action Plan
> CARO: Climate Action Regional Office
> CDP: City or County Development Plan
> CHP: Combined Heat and Power
> CSO: Central Statistics Office
> CSP: Case Study Paper
> DAFM: Department of Agriculture, Food and the Marine
> DH: District Heating
> EMRA: Eastern and Midland Regional Assembly
> EPA: Environmental Protection Agency
> ERDF: European Regional Development Funds
> EU: European Union
> EV: Electric Vehicle
> GHG: Greenhouse Gas
> GI: Green Infrastructure
> HNDA: Housing Need and Demand Assessment
> IPCC: Intergovernmental Panel on Climate Change
> KPI: Key Performance Indicator
> LA: Local Authority
> LAP: Local Area Plan
> LARES: Local Authority Renewable Energy Strategies
> LECP: Local Economic and Community Plan
> LGMA: Local Government Management Agency
> M&R: Monitoring and Reporting
> MaREI: SFI Research Centre for Energy, Climate and Marine Research and Innovation
iv
OPR Case Study Paper CSP05
> MASP: Metropolitan Area Strategic Plan
> MW: Megawatt
> NAF: National Adaption Framework
> NBS: Nature Based Solutions
> NCCAF: National Climate Change Adaption Framework
> NDP: National Development Plan
> NIR: National Inventory Report
> NPF: National Planning Framework
> NTA: National Transport Agency
> NZEB: Near Zero Energy Building
> OPR: Office of the Planning Regulator
> PA: Planning Authority
> PV: Photovoltaic
> RE: Renewable Energy
> RES: Renewable Energy Strategy
> RMS: Regional Modelling System
> RPO: Regional Policy Objectives
> RSES: Regional Spatial and Economic Strategy
> SEA: Strategic Environmental Assessment
> SEAI: Sustainable Energy Authority of Ireland
> SEAP: Sustainable Energy Action Plan
> SECAP: Sustainable Energy and Climate Action Plan
> SFI: Science Foundation Ireland
> SFRA: Strategic Flood Risk Assessment
> SPPR: Specific Planning Policy Requirement
> SuDS: Sustainable Urban Drainage Systems
> UNFCC: United Nations Framework Convention on Climate Change
v
Climate Action and the Local Authority Development Plan
Acknowledgements
The authors are grateful to the eleven local authority officials from seven local authorities
who were interviewed during this research, and for the very positive engagement. The
authors are also grateful to the Office of the Planning Regulator (OPR) for the useful
discussions and feedback provided during the course of this project.
The authors also acknowledge funding support provided by the OPR and Science
Foundation Ireland (SFI) through the MaREI Centre for Energy, Climate and Marine (Grant
no. 12/RC/2302_P2).
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OPR Case Study Paper CSP05
1.0 Introduction
Climate action has become a major influence on planning
policy. Climate action includes both the mitigation and
adaptation sides. While policies needed in adapting to the
effects of climate change have received much focus in recent
times (e.g. flood risk), what planning policies can do on the
mitigation side has received much less focus.
This Case Study Paper (CSP) therefore The main objective of this case study
offers insights into the challenges paper is to provide practical comparative
local authorities currently experience information that local authorities can learn
incorporating climate mitigation into from and use in incorporating evidence-
development plans and highlights based and realistic climate mitigation
exemplary aspects of existing development measures into their development plans.
plans that include climate mitigation
The research was undertaken by the MaREI
measures. This is achieved firstly by
Centre and was funded by the Office of the
reviewing emerging and existing
Planning Regulator (OPR).
examples of how local authorities have
incorporated and integrated Renewable
Energy Strategies (RES) and other
climate mitigation measures into their
development plans, secondly identifying
‘pathfinder’ local authorities before thirdly
engaging with a number of officials from
‘pathfinder’ local authorities in order to
gather reflections on their learnings.
1
Climate Action and the Local Authority Development Plan
1.1 Structure of the case study paper
SECTION OUTLINE
1 Introduces the research and case study paper.
2 Outlines current policy and legislative context, and the evolving local
authority role in climate action planning.
3 Introduces a framework to understand local authority climate action
planning including the challenges associated with bridging national
policy with local authority delivery and explains the role of the
development plan.
4 Summarizes the findings from the high-level review of development
plans.
5 Provides a more detailed look at six elements of climate action planning,
drawing on case study examples from development plans.
6 Offers insights on the challenges faced by local authority officials, and
practical steps they have taken, in incorporating climate action into
development plans.
7 Concludes with what needs to change, and common elements of good
practice identified.
8 Provides a guiding principles checklist.
1.2 Context
The policy making and implementation Under Ireland’s Climate Action and Low
role of local authorities in support of overall Carbon Development (Amendment) Act
national and international climate action (2021) (hereafter referred to as the 2021
has been greatly expanded in recent times, Climate Action Act) each local authority has
enabled in part by legislative requirements been mandated to develop Climate Action
that place greater emphasis on climate Plans (CAPs) addressing both mitigation
matters within the planning system. and adaptation measures [2].
For example, the Planning and Local Authority CAPs further enhance
Development (Amendment) Act 2010 local authorities’ ability to lead, engage,
requires that development plans include coordinate, and become agents of change
objectives to promote sustainable in response to the ongoing climate
settlement and transportation strategies, change crisis; they also represent a new
including reducing energy demand, opportunity to embed climate mitigation
reducing anthropogenic greenhouse in local authority spatial planning.
gas (GHG) emissions, and addressing the
necessity of adapting to climate change [1].
2OPR Case Study Paper CSP05
The mitigation dimension of climate action Compliance with the requirements of
focuses on GHG emissions reduction, this new legislation presents significant
including energy use and efficiency, opportunities in the formulation and
fossil and renewable energy supply, implementation of well-informed CAPs at
transportation, settlement patterns, the local level.
consumption, and agriculture.
To date, local authorities have made
1.3 What is climate action?
considerable progress in accounting for The term Climate Action refers to the
their internal carbon footprint, energy combined effort of both preventing
efficiency improvements in public climate change (mitigation) and managing
buildings, and developing climate the impact of it (adaptation). The United
adaptation plans. However, local authorities Nations body for assessing the science
have made limited progress in climate related to climate change known as the
mitigation beyond their internal carbon Intergovernmental Panel on Climate
footprint. Change (IPCC) provides the following
The new statutory requirement in the definitions [3].
2021 Climate Action Act, allied to the
Climate mitigation involves
pre-existing planning legislation climate
provisions, presents an opportunity A human intervention to reduce the
to strengthen local authority climate sources or enhance the sinks of GHG.
mitigation planning and develop better
Climate adaptation involves
coordination between local authorities
to ensure our emissions reduction goals. The process of adjustment to actual or
expected climate and its effects.
Figure 1-1 - Definition of climate adaptation and mitigation.
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3Climate Action and the Local Authority Development Plan
1.3.1 Strengthening climate mitigation
within the planning system
Climate action is an umbrella term that To ensure local development plans
brings together a suite of approaches to integrate climate action policy, it is
tackle climate change. Policy development, essential to strengthen practical guidance
research and action distinguishes between and information on mitigation, as in many
climate adaptation and climate mitigation. ways such action represents an important
This distinction is important to recognise as primary form of climate action.
adaptation is comparatively ahead in terms
The extent of GHG emission reductions is
of strategies and guidance in place to
crucial to our ability to cope with climate
support local authority led climate action.
change, and while some impacts are now
For example, Local Authority Adaptation inevitable into the future, staying within
Strategy Development Guidelines were certain limits is vital. Thus, this case study
published in 2019, which seek to climate paper explores good practice and suggests
proof local plans and policies, as well as some guiding principles to support the
offer information on how to achieve this. embedding of climate mitigation within
local authority climate action planning.
However, to date no such guidelines exist
from a mitigation standpoint. This case
study paper focuses specifically on climate
mitigation to address this gap.
4OPR Case Study Paper CSP05
1.4 Complementary resources on the topic of local
authority climate action planning
This work complements the ongoing research and policy guidelines outlined
in Table 1-1 below.
Table 1-1 - List of complementary projects and resources dealing with different elements of local
authority climate action planning.
PROJECT LEAD DESCRIPTION
Office of the Planning Through the OPR’s statutory development plan
Regulator evaluation function.
Eastern and Midland The project considers methods for quantifying GHG
Regional Assembly emissions of different spatial plans with the goal of
informing policy decisions. Under EMRA’s leadership,
Quantitative Greenhouse
the Scottish Government’s Planning and Architecture
Gas Impact Assessment
Division, the Northern Ireland Regional Planning
Method for Spatial
Directorate and the Regional Council of Kymenlaakso
Planning Policy (QGasSP)
(Finland) are also participating in the project.
Project
Local Government In a series of publications, the LGMA has examined
Management Agency climate change, national policy, and local action
publications with case studies of local authority responses to
energy efficiency, transport, flood risk management,
emergency response to flooding, waste management,
water conservation, nature-based solutions and public
engagement, as well as a literature review of key
performance indicators for climate action.
Department of The EPA, CAROs and MaREI with the support of a
Environment, Climate project advisory group formed with experts from the
and Communications, sector are preparing draft guidelines for Local Authority
Ministerial Guidelines on Climate Action Plans covering both adaptation and
Local Authority Climate mitigation planning expected Q1 2022.
Action Plans
Climate Ireland The Climate Ireland platform was developed by
MaREI through funding from the EPA to support
capacity building for local authority climate adaptation
planning. It provides a number of useful resources as
well as the delivery of training in collaboration with the
CAROs.
5Climate Action and the Local Authority Development Plan
2.0 Summary of Policy
and Legislative Context
2.1 Local authority In addition, the Strategic Environmental
Assessment (SEA) process, during the
development plans making of the development plan, is
The development plan is the mechanism required to provide a formal, systematic
that seeks to integrate international and evaluation of the likely significant
EU climate agreements and policy, national environmental effects of implementing
climate legislation and policy, national and the development plan, including climate
regional planning policies, and community factors. The SEA process integrates
input into an overall strategy for the proper environmental considerations at all
planning and sustainable development of stages of the development plan process
the local authority. from preparation to implementation
and monitoring. Under the Planning and
The development plan is recognised as
Development Regulations 2004 (SI No. 436
‘the principal policy document of a local
of 2004) as amended, planning authorities
authority’ and ‘the main policy document
must conduct a SEA [7].
for each planning authority’ [4], [5]. The
courts have consistently upheld the Therefore, from deciding on small planning
importance of the development plan. applications to guiding local authority
development to standing up in a court of
The number of objectives to be included
law, the development plan is the means
in the development plan has grown since
local authorities use to require, encourage,
the 1963 Local Government (Planning
request, and influence sustainable
and Development) Act [6]. The Planning
development and climate action in their
and Development 2000 Act introduced
areas.
the concept of sustainable development
to the regulatory framework for planning
and the Planning and Development
2.2 Legislative and policy
(Amendment) Act 2010 introduced developments linked to
a further mandatory requirement for climate mitigation 2010
statutory development plans to include
to present
objectives to promote reduced energy use,
reduced GHG emissions and adaptation Climate policy and legislation in Ireland
to climate change, as well as promoting relative to local authorities has accelerated
sustainable settlement and transportation since 2010. These new requirements are
strategies [1]. designed to ensure that developments
plans have clear climate action measures,
which are aligned with national strategies
and targets.
6OPR Case Study Paper CSP05
As shown in the timeline provided in Figure 2-1 below there have been some important
developments that highlight the increased significance of climate action planning at the
local level.
Figure 2-1 - Timeline of climate legislation relevant to the local authority between 2010-2021.
2.2.1 Climate action within planning
legislation
The Planning and Development ii. reduce anthropogenic greenhouse gas
(Amendment) Act 2010 (Section 10(2)(n))1,2 emissions and address the necessity of
requires that development plans include adaptation to climate change, taking
objectives for [1]: account of the local authority climate
action plan (within the meaning of
“the promotion of sustainable settlement
Section 14B of the Climate Action and
and transportation strategies in urban
Low Carbon Development Act 2015),
and rural areas including the promotion of
where such a plan has been made for
measures to—
the area in question;
i. reduce energy demand in response to
in particular, having regard to location,
the likelihood of increases in energy and
layout and design of new development”.
other costs due to long-term decline in
non-renewable resources;
1
Section 10(2) of the Act does not specifically apply to Local Area Plans.
2
The Climate Action and Low Carbon Development (Amendment) Act 2021 in Section 19, amends
Section 10 (2) of the Planning and Development Act 2000, in paragraph (n)—it includes the substitution
of subparagraph (ii) and deletion of subparagraph (iii).
7Climate Action and the Local Authority Development Plan
Such objectives ensure that climate In addition, the Interim Guidelines for
action is provided for in development Planning Authorities on Statutory Plans,
plans. In addition, local authority CAPs, Renewable Energy and Climate Change
when adopted, will have to be taken into (July 2017) included a Specific Planning
consideration in development plans [2]. Policy Requirement (SPPR) for local
The Climate Action Plan (2021) adds authorities to:
further emphasis on the ‘pivotal role’
“Indicate how the implementation of the
that local authorities play in achieving
relevant development plan or local area
decarbonisation targets through
plan over its effective period will contribute
spatial planning, the provision of public
to realising overall national targets on
housing, transport infrastructure and the
renewable energy and climate change
maintenance of biodiversity [8].
mitigation, and in particular wind energy
Emphasis on the link between climate production and the potential wind energy
action and the planning system is also resource (in megawatts)” [12, p. 2].
stated in the National Planning Framework
In the Strategy for Renewable Energy
(NPF) where it specifies under National
(2012-2020), a key action under Strategic
Policy Objective 54 the integration of
Goal 1 to increase the share of on
climate action into planning in support
and offshore wind energy, was the
of national targets for climate policy
development by Sustainable Energy
mitigation and adaptation [9].
Authority of Ireland (SEAI) of a template
This is an area that the OPR is required to to assist local authorities to prepare
focus upon in its statutory role strategically renewable energy strategies [13].
evaluating local authority development
The Methodology for Local Authority
plans for their fit with national and regional
Renewable Energy Strategies (LARES)
planning policy – including climate action.
was published by SEAI the following year in
This is provided for under Section 31 AM(2)
2013 [14] and an updated version is now in
(a) of the Planning and Development Act
development.
2000 as amended in 2018 [10].
The 2012 European Energy Efficiency
2.2.2 Local authority climate Directive encouraged the public sector
action responsibilities to lead by example in efforts to improve
energy performance, setting a target for
The legislative foundation for local
energy efficiency improvements of 33%
authority climate mitigation is perhaps
by 2020 [15]. This introduced a need for
clearest in relation to renewable energy
a monitoring system to track progress
generally and wind energy specifically. This
against the energy efficiency targets.
is based on the planning guidelines from
Within Ireland, local authorities submit
2006 that set a requirement to identify
their energy data to the monitoring and
on development plan maps the key areas
reporting system maintained by the SEAI
where “wind energy development will be
[16]. This covers direct emissions from
acceptable in principle” [11, p. 10].
local authority owned property such as
buildings, vehicles and public lighting.
8OPR Case Study Paper CSP05
However, with the introduction in the 2021 In the National Climate Action Plan 2021,
Climate Action Act of local authority CAPs, in contrast to the 2021 Climate Action
local authorities will now need to prepare a Act, there is much less mention of the
Baseline Emissions Inventory (BEI) for the local authority sector. The focus is on how
entire administrative area. This is discussed the public sector will lead by example,
further in Sections 2.2.3 and 5.6. which refer to the local authority CAPs
introduced in the 2021 Climate Action Act
The Climate Action and Low Carbon
and the development of decarbonisation
Development Act (2015) introduced the
zones, taking forward the Portlaoise
National Adaptation Framework (NAF)
De-carbonising Zone example from the
to “specify the national strategy for the
previous CAP 2019 [20].
application of adaptation measures in
different sectors and by a local authority in The recently launched Community
its administrative area” [17, p. 9]. Climate Action Programme will see a
significant strand of funding delivered
The NAF was published in 2018, and was
through local authorities. During its first
followed by Local Authority Adaptation
phase €30 million will be allocated. The
Strategy Development Guidelines which
vast majority of the funding delivered
importantly note that “Completed local
under Strand 1-Action: Building Low
strategies should then be used to inform
Carbon Communities, will see €24 million
development plans and other statutory
being provided to local authorities “to
plans and policies of the local authority”
support communities – large and small,
[18, p. 7].
rural and urban – to build low carbon
2.2.3 Emerging areas for consideration communities in a considered and
structured way” [21].
The publication of the Local Authority
Climate Action Charter and the Climate The central focus of this case study paper
Action Plan in 2019 placed a significant is to explore how development plans
responsibility on local authorities to lead on have been integrating climate action to
climate action [19]. This was strengthened date. The development plan is the policy
in the 2021 Climate Action Act, which setter for decisions on individual planning
greatly enhanced the role of local applications and is guided by the SEA
authorities in delivering climate action [2]. process. In turn, individual planning
Most significantly, the introduction of local applications, particularly applications
authority climate action plans dealing with that require an Environmental Impact
both mitigation and adaptation measures. Assessment (EIA), must address climate
With regards planning, a key element factors.
of the 2021 Climate Action Act is the
additional requirement for development
plans to have regard to the actions set out
in the CAPs.
9Climate Action and the Local Authority Development Plan
The SEA process considers zoning 2.3 Ireland’s planning
and development objectives from
system hierarchy
a sustainability perspective which
enables a more coherent examination The 2021 Climate Action Act promises
of the environmental impacts of future to integrate spatial planning and
developments. Where there may be climate legislation for the first time.
conflict with other development concerns Upon commencement of the legislative
such as population growth, increased provisions (which at the time of writing is
demand for amenities, or industry it should expected to be imminent) local authorities
result in the incorporation of countering will be required to write CAPs within 12
measures to help mitigate against months, meaning that local authority
potential impacts. CAPs will potentially be prepared nearly
It is vitally important that future at the mid-way point of the life of current
developments are ‘climate proof’ development plans (most development
and support the achievement of plans were written after Regional Spatial
ambitious emission reduction targets and Economic Strategies (RSES) came
set at the national level. How proposed into force in 2019 and 2020). The result is a
developments will impact future emissions collection of overlapping timeframes in the
will likely become a key planning national planning hierarchy as shown in
consideration as carbon budgets place Figure 2-2 below.
increasingly stringent limits on emissions.
Figure 2-2 - Overlapping timeframes of National Planning Framework, Regional Spatial
and Economic Strategies, LA Development Plans and LA Climate Action Plans.
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10OPR Case Study Paper CSP05
3.0 Framework to
Understand Local
Authority Climate
Action Planning
3.1 Ireland’s GHG The most recent 2021 emissions inventory
provides a breakdown of GHG sources
emissions profile by sector in 2020, as shown in Figure
Ireland’s GHG emissions are recorded 3-1. Currently in Ireland, the largest
annually by the Environmental contributing sector is agriculture (~37%),
Protection Agency (EPA) through the followed by transport (~18%), energy
National Inventory Report (NIR), which industries (~15%), and residential (~12%).
is submitted to the United Nations Public services, which include local
Framework Convention on Climate authority operations (excluding social
Change (UNFCCC) [22]. housing), make up less than 2% of overall
GHG emissions.
Figure 3-1 - EPA latest emissions data - Ireland’s greenhouse gas emissions share
by sector in 2020 [22].
11Climate Action and the Local Authority Development Plan
As noted in Section 2.2.2, under the It positions actions across three areas. In
current monitoring and reporting system the inner circle, direct responsibilities of
maintained by the SEAI, local authorities the local authority, on from this indirect
keep a record of their direct emissions, responsibilities and finally, areas of limited
which will likely be only 1 - 2 % of total GHG influence where leadership is shown.
emissions in their administrative area.
Local authorities, in their planning
However, the new local authority CAPs
functions have limited influence on
will additionally need to outline actions for
agriculture bar certain larger intensive
all sectors within the administrative area.
agriculture development proposals, but
This raises questions on the responsibility
they can more greatly influence patterns
of local authorities and their ability to
of development that drive demand for
enact change, particularly in key sectors
transport, energy related development and
such as agriculture and transport that are
residential emissions.
coordinated more by national government
departments, bodies, and their policies. It is generally accepted that promoting
compact patterns in future development
3.2 Framework to understand can lead to shorter trips to employment,
education, shops, social contacts and
local authority climate activities, creating more possibilities for
action planning active and sustainable travel. Compact
patterns of development also support
Addressing the question of local authority
moves towards district heating, reducing
influence on different elements of climate
household emissions.
action planning, the framework within
Figure 3-2 was developed.
Figure 3-2 - The role of the local authority in climate action planning.
12OPR Case Study Paper CSP05
Figure 3-3 - Examples of climate action mapped to the framework on the role of the local authority.
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A
energvze-mrax:nn.IarClimate Action and the Local Authority Development Plan
Delivering local authority CAPs will The engagement with local authorities (see
require sufficient personnel (dedicated Section 6) revealed both positive intent
climate action teams), and access to and challenges in meeting the ambitious
appropriate and necessary tools (e.g. national goal of a 51% reduction in GHG
baseline emissions), methods (e.g. to emissions by 2030 revolving around
model emissions reduction strategies) and coherence between national targets and
knowledge to carry out the tasks required. the enabling steps and ‘shares’ of the ask
at local level. Climate action policy in key
It also requires timely and detailed national
sectors like transport and agriculture are
guidelines on different aspects of climate
the responsibility of national organisations/
mitigation. In addition, there is a clear
government departments and clarity on
need for a facilitatory role to support the
the role of local authorities is needed.
setting up and coordination of sub-county
governance structures, offering advice Major policy measures are set out via the
to people interested in energy/climate NPF and National CAP, again with more
projects, and also providing new forums clarity required on where the role of local
for discussing the alignment of local needs authorities fits in.
and national objectives. Going further,
Finally, the role of regional assemblies
with greater autonomy, a benefit of this
as a bridge between national and local
role could be a clearer link between local
policy is a potential bright point on the
deliberations and the content of local and
horizon. Improving the coherence between
regional plans.
national, regional, and local climate action
policy is critical to meet Ireland’s strong
3.3.2 Improving coherence between
climate mitigation ambitions and could
national, regional and local policy
be a key ‘raison d’etre’ for the regional
National climate policy has advanced dimension of local government.
considerably over the past two years with
significant increases in ambition in the 3.4 The role of the CDP
two-year period from the Climate Action
Plan 2019, through to the 2021 Climate The research undertaken has
Action Act, and the Climate Action Plan demonstrated that development plans
2021. that tackle the climate issue are the ones
that clearly, succinctly, and effectively
In addition, the role of local authorities in
document the local aspects of climate
climate action has grown, in particular as
action facing that local authority area.
a result of Section 16 of the 2021 Climate
Action Act. The analysis within this case Baseline emissions profiling is a major
study paper (in particular Sections 4 and 5) part of the above. While not suggesting
clearly shows positive development in the that everything such profiling may identify
evolution of development plans towards is within the scope of the development
increased climate action, but not in a plan and planning legislation-based
consistent manner, with strong leadership policies to address, nevertheless it sets
demonstrated in some local authorities out the context for the communities and
relative to others. local authority in the various areas better
understanding their specific contribution
through the planning process in tackling
climate action.
14OPR Case Study Paper CSP05
So, within the context of clear and effective > Adapting to the known effects of the
national ‘roadmaps’ to a carbon-free changes in our climate that have already
future, the local development plan can set been set in train and with contingency
out the local roadmaps that cumulatively for the continuation of such effects.
reach the national targets, drawing
While wider sectors are directly outside
out the specific contributions that the
the scope of the development plan and
implementation of specific planning
planning policies, there is much benefit in
policies can make including:
the plan being able to set out its specific
> Reducing energy demands because of contribution in context – accepting that
the implementation of a much more wider actions are the responsibilities of
energy efficient overall strategic pattern their wider policy owners.
of development.
> Realising potential for alternative sources
of renewable energy by identifying the
sources and areas of such potential and
laying down a policy framework that will
facilitate the activation of that resource;
and
15Climate Action and the Local Authority Development Plan
4.0 High-level Review
of City/County
Development Plans
As we have outlined in Section 2 of The review includes an analysis of
this case study paper, there have been development plans pertaining to all thirty-
some important legislative and policy one local authorities in the Republic of
developments in the last ten years Ireland. This involved development plans
concerning climate action and the role of in adopted and draft stages3. This study
local authorities in promoting sustainable recognises that the preparation of draft
settlement patterns, reducing GHG development plans by the executive
emissions and more recently accounting of local authorities tends to reflect the
for the upcoming requirement to produce policy ambition at national level, whereas
local authority CAPs. material amendments proposed by elected
members can vary that ambition taking
We carried out a high-level content
into account local issues and concerns.
analysis of the CDP’s in order to explore
how these new requirements are being This section is developed in three parts.
introduced. Content analysis is a research First, we provide a situational analysis,
technique which allows for a systematic which offers some relevant definitions
description of data drawing from of the main issues currently framing
quantitative and qualitative insights. This development plans in Ireland. Secondly,
process of analysis involved establishing we identify and explore the prevalence of
the prevalence of words, themes and climate criteria in current development
concepts associated with climate action plans. Thirdly, we review a selection of
and mitigation, as well as exploring their climate criteria, and provide examples of
context and changes over time. Together trending and emergent practices with
with the subsequent pathfinder analysis a view to showcasing pathfinder local
(Section 5) of particularly innovative plans authorities.
on climate, the analysis highlights a trend-
line in the incorporation of climate issues in
development plan policies.
3
Because of the timeframe of reviewing and writing development plans, there were 10 adopted and
21 draft development plans examined. More draft development plans are due to be published over
the next few months; this study considers all that were published before 1 August 2021. To carry out a
cross sectional analysis of the content of the plans we reviewed a further 5 adopted plans to enable a
comparison between older and CDPs published post 2021.
16OPR Case Study Paper CSP05
4.1 Situational analysis: Furthermore, we observed a higher
incidence in the use of climate adaptation,
current issues framing CDP’s
climate mitigation and sustainability
in Ireland applied in multiple contexts which indicate
a level of maturing of these concepts and
4.1.1 Climate action in development plans their application from a local planning
A significant feature in the plans surveyed perspective. Another notable variation
was their inclusion of climate change/ when comparing older and newer CDPs
action as a dedicated chapter. Of the initial is that longer term targets and objectives
thirty-one plans surveyed, 22 (around 70%) associated with 2040 and 2050 time
included a chapter on climate change/ horizons are now a feature of the more
action. In six additional plans, climate recent plans.
change and/or climate action formed Largely due to the influence of the NPF
a part of a chapter. Only three (10%) and the CAP (2019) the use of long-
development plans did not have a chapter term goals and visions provides an
or section of a chapter on climate change/ important bridge between the big-vision
action. These three plans are reaching the sustainability narrative of national plans
end of their validity; they were adopted in and the more practical local solutions
2015, 2017 and 2018 and prepared before within the CDPs. The adoption of larger
the UN IPCC issued its stark warnings time-horizons in the CDPs is an important
in 2018 that there were only 12 years left feature in this new role of local authorities
before a global warming of 1.5° C [23]. as key agents of change.
Whether devoting a chapter to climate
or seeking to integrate it into the whole 4.2 Cross-cutting issues
of the development plan, over the last six
years, the topic has come to much greater
relating to local authorities
prominence in development plans. Local authorities produce CDPs for the
whole of their area seeking to guide
4.1.2 Changes in CDP content over time
future growth and development. These
To consider changes over time in more plans commonly focus their strategy on
depth we also carried a comparative cross- addressing issues within the context of
sectional analysis of five older CDPs (those their locality. However, we have observed
published pre-2016) and compared these a number of cross-cutting issues framing
to their replacements in draft form CDPs the manner in which strategies and key
(those published in 2021 and pertaining issues are defined. There are illustrated in
to the same five local authorities). This Figure 4-1.
analysis shows that concepts such as
energy and settlement patterns have
significantly increased in prevalence in the
new draft plans.
17Climate Action and the Local Authority Development Plan
Figure 4-1 - Cross-cutting issues found from high-level review of development plans.
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These cross-cutting issues not only have 4.3 An overview of emerging
direct implications to how climate action
climate action and climate
and climate mitigation are integrated into
a complex set of social, economic and mitigation criteria
environmental dimensions within the To survey the adopted and draft
local context, but also suggest a range development plans, we developed a list
of commonalities that can be addressed of search terms taken primarily from the
through stronger regional partnerships or Local Authorities Climate Action Charter
cross-sectoral collaborations. and the government’s CAP (2019). The
Climate policies in development search terms take into consideration social,
plans necessarily need to be flexible in economic and environmental drivers of
addressing different geographical contexts sustainability.
and this can present challenges and Local authorities have different levels of
opportunities for local authorities in terms influence relative to different sectors and
of introducing wider climate mitigation climate actions. However, the opportunities
interventions. to encourage change through the
Some of these issues for instance development plan are diverse and growing.
point to the opportunity to introduce Thus, in our search terms we chose to
compact growth innovations as a way to offer a broad overview of relevant issues
promote more efficient use of land and which consider not just areas that can be
infrastructure and avoid sprawl. Yet, while zoned, mapped, or spatially applied but
there are opportunities arising from the also other actions that can be championed,
cross-cutting issues they also introduce supported, or extended through
new and ambitious climate mitigation partnerships or through collaboration with
targets that can present added challenges. other local authority statutory functions.
18OPR Case Study Paper CSP05
4.3.1 Which climate mitigation criteria As Figure 4-2 illustrates there are some
feature more strongly in CDPs? criteria which feature more strongly than
others in current development plans. We
We identified 34 mitigation criteria, the list
quantify the presence of these criteria
is not exhaustive but seeks to offer a broad
across the development plans. Criteria
exploration of actions from the perspective
such as renewable energy, wind energy,
of local planning, land use regulation and
green infrastructure and energy efficiency
other development synergies. It also seeks
appear in all the development plans.
to consider multiple dimensions of climate
Because development plans have a six year
mitigation including energy, transport,
life the older plans understandably do not
economy, society and environment. Given
include references to more recent planning
the evolving and complex nature of climate
policies and concepts like just transition,
action and climate mitigation it is possible
compact growth, solar energy, etc.
elements were omitted unintentionally.
Figure 4-2 - Content analysis of climate mitigation criteria across 31 CDPs and colour coded
indication of average mentions.
Renewable Energy 31
Wind Energy 31
District Heating 24
Energy Efficiency
Energy
31
Solar Energy 29
Off-shore wind 7
Energy Demand 28
Smart Grid 4
Sustainable Energy Communities 13
Sustainable Mobility/transport 31
Permeability 31
Modal Shift 30
Transport
Walkability 22
Cycling Infrastructure 22 Top average mentions
Compact Growth 21
EV Charging 23 Higher average mentions
Proximity to Services OR Access to Services 29
Circular Economy 23 Low average mentions
Broadband 31
Economy
Data Centres 18
Remote Working 17
Marine Planning 9
Green Public Procurement 5
Consultation 31
Just Transition 14
Society
Public Engagement 11
Near Zero Energy Building (NZEB) 21
Emissions Reduction 8
Decarbonisation Zone 5
Climate Action Toolkit 3
Green Infrastructure 31
Environment
Peatlands 28
Nature Based Solutions 13
Afforestation 26
19Climate Action and the Local Authority Development Plan
It is clear from our research that these Similarly, peatlands are not likely to appear
policies are now being introduced in the as an issue for Dublin City or for Fingal.
newer plans. Finally, as a varied portfolio of solutions the
findings above and in the section below
We also found a variation in the number
stress the importance of innovation and
of mentions of some of these criteria and
adoption of emerging policy but indicate
we colour coded these in Figure 4-2. This
clearly that local authorities bring their own
reflects the fact that while criteria may be
capacities and resources which emerge as
present in development plans the degree
strengths in some areas and weaknesses in
to which it is embedded or develops in the
others.
plan may be weaker. The colour coding in
the table indicates in a darker shade those
4.3.2 Review of selected climate
with top average mentions (those with
mitigation criteria
62-57 mentions across the plans reviewed),
higher mentions (those with 25-10 average In this section we offer a characterization
mentions across the plans reviewed) and of selected climate mitigation criteria
in a lighter shade those with lower average drawing from insights into their prevalence
mentions across all CDPs (those with 9-1 in the CDPs. We acknowledge significant
mentions). differences in the way that some
interventions are incorporated (or not) in
It is particularly useful to note that lower
CDPs. Some criteria are subject to stronger
level of mentions also suggests that these
policy or statutory requirements than
criteria are often referenced as part of
others, differences due to geographical
a wider definition, indicating interest
location or other contextual issues also
in these themes is in a very aspirational
influence the way interventions are
way that is seldom set into practice in a
incorporated. Despite these differences we
measurable form. For instance, emerging
also found evidence of best practice and
criteria such as ‘off-shore wind’, ‘modal
innovation in the leveraging of these ideas.
shift’ or ‘just transition’ are incorporated in
Table 4-1 outlines the key characteristics
the narrative of the plan but they are not
and features of the most prevalent climate
always identified within an objective or
mitigation criteria. We also identify
policy.
pathfinder local authorities who appear
Thus, the list of criteria we offer, explores a strongest relative to specific criteria.
range of practices and criteria in support
The characterization that we offer is based
of a broader portfolio of practical solutions
on a review of the practical application of
and measures for CDPs in promoting
these criteria within the CDPs. Given the
climate action. We explore these criteria
fact that terminologies can vary, items
in the context of shifting legislative and
in this review should be considered as
societal conditions, which are likely to
an indicative set of steps and not as a
lead to evolving use of concepts and
comprehensive protocol. Thus, the aim is
terminologies. It is also important to
to consider the various ways in which these
note that some criteria may not apply to
items appear within the development plan
all contexts, for instance offshore wind
taking into account different regulatory
mentions are not likely to appear in some
forms where they emerge as relevant.
counties such as Longford or Laois.
20OPR Case Study Paper CSP05
Table 4-1 - Key activities and review insights of leading climate mitigation criteria.
CRITERIA KEY COMPONENTS REVIEW INSIGHTS
Renewable > Assessment of current status. RE is mentioned in all CDPs
Energy (RE) reviewed. This is a strongly
> Identification of strategic energy
developed criteria.
zones.
Pathfinder LAs include: Cork
> Setting targets.
County (2022-2028 Draft),
> Renewable energy mix options Carlow County (2022-2028
and hybrid systems. Draft), and Clare County
> Wind Energy Strategy. (2017-2023).
> List of key issues and processes Strong CDPs ensure
for emerging technologies objective consistency by
(where there are no available aligning these with clearly
guidelines). demarcated strategic
energy zones and targets.
> Options for large-scale, small-
For instance, Cork County
scale and micro-energy
outlines and maps key areas
generation.
for RE, and in the absence
> Implementation plan with clear of guidelines it defines
targets. key processes and issues
> Landscape and environmental regarding the development
impact assessments. of solar energy projects.
> Access to grid and storage
capacity.
21Climate Action and the Local Authority Development Plan
CRITERIA KEY COMPONENTS REVIEW INSIGHTS
Wind Energy > Mapping analysis of suitable Wind Energy is mentioned
areas for wind energy. in all CDPs reviewed and
is the most prevalent
> Coordinated Regional Strategy.
renewable energy
> Identification of suitable areas for technology mentioned
wind energy deployment. within all CDPs.
> Landscape sensitivity. Pathfinder LAs include: Cork
> Implementation plan with clear County (2022-2028 Draft),
targets. Kilkenny (2021-2027) and
Offaly (2021-2027).
> Applying national separation
distances from dwellings or other Cork County sets out a
sensitive structures. detailed strategy for off-
shore wind, mapping out
> Access to distribution grid.
key steps and partnership
> Strategic use of legacy opportunities. Offaly
infrastructure. provides useful detail on
> Potential for off-shore wind the strategic use of legacy
energy. infrastructure. Common
issues include lack of
regional coordination
and inconsistent use
of separation distances
between wind turbines
and dwellings. Other issues
include the lack of targets
consistent with the Interim
Guidelines SPPR, and
other constraints (such
as maximum output or
number of turbines).
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