Ireland 2040 – A Framework for Public Investment?

The Ireland 2040 National Planning Framework (NPF) currently under preparation, is tasked with providing a ‘framework for future development and investment in Ireland’ (Issues and Choices Consultation Paper). The consultation document makes clear that the NPF is intended to provide a high-level strategic policy document, working to coordinate the spatial aspects of a wide range of sectoral policies concerned with ‘housing, jobs, transport, education, health, environment, energy and communications’. The potential of strategic spatial policy to be provide a frame for the coordination of broad-scale policy objectives such as quality of life, prosperity and environmental sustainability and the development of place-based policy is explicitly addressed. It is evident that the NPF is intended to provide more than a reformulation of the politically-sensitive issue of balanced or effective regional development. It is also evident that it is not to be understood as ‘national plan’, prescribing where development should take place, as discussed previously on this blog here). Whereas the NPF will hopefully provide a central guiding framework for planning authorities, informing their decision-making and placing their work in a wider strategic context, this should not be understood as its primary function.

The NPF is asking to be taken seriously as cross-sectoral overarching framework for investment, rather than treated as a national plan to be ‘implemented’ by local authorities. These strategic cross-sectoral policy coordination policy coordination objectives are to be welcomed. The current context of Brexit-induced uncertainty calls for open dialogue, cross-sectoral communication and strategic stakeholder engagement, as Ireland-UK and by default, Ireland-EU and North-South relations are simultaneously re-ordered and re-worked. Indeed, this period of uncertainty calls for spatial public diplomacy. The NPF can play an important function in this context providing in particular a framework for working out island-of-Ireland perspectives and reaffirming existing commitments to cooperation in matters of spatial planning and regional development on a North-South basis.

The experiences of Wales and Scotland with strategic spatial planning furthermore demonstrate the potential of spatial strategies with strong cross-sectoral ambitions. The Scottish National Planning Frameworks build on a strong Scottish tradition of strategic planning and have played an important role as part of a broader ‘national conversation’ post-devolution. More importantly, they have served to focus policy attention on key projects of national importance and ‘spatial priorities for change’. The Wales Spatial Plan similarly was designed from the outset as an over-arching cross-sectoral framework, placing the work of the then newly established Welsh Assembly in a strategic spatial context and supporting joined-up thinking at a sub-regional level.

In order to be taken seriously and to have relevance as a framework at a strategic policy level outside of the Department of Housing, Planning Community and Local Government, however, the NPF needs to be explicitly linked to public sector investment decision-making. The National Spatial Strategy was of course, designed to give spatial expression to the National Development Plan with the Gateway Investment Fund as the bridge linking spatial and capital investment planning. Unfortunately, the GIF was one of the first items to go when budgets were cut and the decentralisation fiasco characteristically served to make the worst out of a bad situation. We should nevertheless expect and demand that the NPF contain explicit commitments regarding major infrastructure projects of national and regional importance, aligning the spatial framework with national transportation policy and other key sectoral policies. Debate on the NPF should focus on concrete substantive issues of strategic spatial significance such as outstanding commitments under Transport 21, sustainable energy and climate adaptation policy and the future of the border region in a time of uncertainty. NPF scenarios could focus on the spatial development implications of infrastructure investments and policy choices, providing informed insights into possible regional development dynamics in Ireland 2040. This of course is based on the perhaps naive assumption that the Irish Government is prepared to commit public funds to strategic investment projects rather than relying on private sector investment.

The NPF might also be expected to make funding commitments to support innovative regional development initiatives emerging from the bottom-up. It is possible to envisage a scenario where local authorities, business and community stakeholders could apply for capacity-building or small-scale investment funding on a competitive basis from funds administered by the three regional assemblies. Projects would be required to support the objectives of the NPF and to cross local authority boundaries, working with ‘functional territories’ in order to ensure strategic regional importance. Lessons can be learnt from urban-rural partnership programmes organised on a similar basis in Germany which have challenged metropolitan and rural districts to identify potential synergies and means of working together. Closer to home, the experiences of three Border Area Networks and work of ICLRD in developing common projects and strategies on a cross-border basis demonstrate the potential of this approach in the Irish context.

It is time for a mature debate on the substantive issues the NPF can and should address on a cross-sectoral basis, and time for the Government to commit to public investment aligned with national spatial policy.

Reminder: Submissions on the NPF consultation can be made until this Thursday 16^th March (12 noon).

Cormac Walsh

To make a submission about the proposed NPF go to the website and follow the instructions provided; or email npf@housing.gov.ie; or write to:

NPF Submissions, Forward Planning Section, Department of Housing, Planning, Community and Local Government, Custom House, Dublin, D01 W6X0

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Thoughts on the initial consultation document for ‘Ireland 2040: National Planning Framework’

The National Spatial Strategy was officially scrapped in 2013 by then Minister, Phil Hogan TD.  Soon after, the development of a replacement strategy, the National Planning Framework, was announced.  On Thursday the initial consultation document was published by the Department of Housing, Planning, Community and Local Government, and launched at Maynooth University by the Taoiseach, Enda Kenny TD, the Minister for DHPCLG, Simon Coveney TD, and Minister for State for Housing and Urban Renewal, Damien English TD.  It sets out the process and timeline for formulating the full NPF and provides an initial framing of government thinking with respect to what should be included in the plan.

The NSS was widely considered an unmitigated failure for a number of reasons: there were too many gateways and hubs; it was misaligned with its funding stream the NDP; it was not supported by government, agencies and local authorities and was actively undermined; and it was not implemented on a statutory basis (see this post for a full history and explanation). So have lessons been learned?  The Taoiseach would like to think so, stating at the launch that in the NSS, ‘towns were placed against towns, politics against politics … and we are not going there again.’ Instead, the NPF will seek to be more cooperative, coordinated, and regionally based.

The rationale for the NPF is broadly the same as the NSS.  It is to coordinate spatially the development of sectoral areas (economy, transport, housing, energy, education, health) and guide and drive balanced regional development as the population continues to grow.  If development is not managed and it is left to business is usual to deliver shared national goals, then Dublin will continue to expand, the regional cities will have modest growth, and smaller towns and rural areas will stagnate or decline, the document argues.  Instead, the document argues that there needs to be:

• a coordinated, strategic approach with a twenty year time horizon;
• this approach needs to be backed by government across departments/agencies;
• be aligned with public/private investment, including capital spend;
• a focus on health and well-being, the environment, North-South relations, as well as economic and property development;
• a recognition that it is a strategy, not a wish list and that it will involve making hard choices;
• address all parts of Ireland, avoid the perception of ‘winners’ and ‘losers’, but avoid unrealistically seeking to treat all parts of the Country in the same way;
• include a particular focus on implementation and evaluation, with capacity for review.

The proposed approach to organize and operationalize the NPF through the regional assemblies and in alignment with regional spatial economic strategies that are presently being prepared.  Rather than towns competing within a region, they should cooperate and work together as clusters.  And there should be stronger urban-rural interdependence, with large and small towns supporting rural communities.  Nonetheless, it is argued that there is a need for concentrated development of the five principal cities – Dublin, Cork, Galway, Limerick and Waterford – and the towns around them, to create strong growth polls for business and to realise agglomeration effects and to create scales of economy/critical mass for service and infrastructure delivery.  Unlike other countries with a similar sized population – Scotland, Denmark, Finland, New Zealand – Ireland has a weak city structure with just five cities with a population above 50,000 (and only two above 100,000), that limits the ability to create balanced growth.  More modest growth will be sought in regional towns.  While growth would be welcome in rural areas, the priority is to stop further decline and to create resilience, sustainability and to improve quality of life.

There are a couple of big challenges in preparing the full NPF and getting it put on a statutory basis.  The first is the seeming paradox between ‘making hard choices’ and ‘addressing all parts of Ireland and avoiding the perception of winners and losers’.  The plan needs to make strategic decisions and prioritize areas for development and investment while also persuading everybody that those decisions are for the ‘national/regional good’ and that there is something there for them.  Given the legacy of the NSS, the localist/clientelist nature of Irish politics, and the siloed nature of government depts/agencies, that will be a challenge.  Second, and related, is given that the proposers are a minority government, the process of getting political support may involve a watering down of the plans aims, or the plan being tweaked in a way that undermines the plan’s logic to curry favour or ensure votes.  Third, in preparing the plan, it needs to be made clear how it will be implemented in practice, how it will be resourced, and how its progress will be tracked and steered back onto course if it falters, to persuade people to have faith that this isn’t a NSS v.2, but a strategic plan that will actually work in practice.

As someone who is in favour of a planned and coordinated approach – through a guiding framework, not a heavy-handed roadmap – the publication of the consultation documents for the NPF is a welcome first step.  The next step is to develop a full plan that can achieve political and public buy-in.  Part of the process to try and ensure this is, on the one hand, to produce a detailed evidence-base and various scenarios, and on the other to invite submissions as part of a consultative phase.

To make a submission about the proposed NPF go to the website and follow the instructions provided; or npf@housing.gov.ie; or write to:

NPF Submissions,

Forward Planning Section,

Department of Housing, Planning, Community and Local Government,

Custom House,

Dublin D01 W6X0

The deadline for receipt of all submissions is 12 noon on Thursday 16th March 2017.

Some related media commentary: RTE 1, Drivetime interview; RTE Radio 1 News at One; RTE 1 Primetime.

For additional information see the Ireland 2040 website.

Rob Kitchin

 

Recent Demographic Growth in Ireland: Implications for future Spatial Planning and Housing Provision

Extended precis (PDF of full paper)

The publication of the Department of the Environment, Community and Local Government’s ‘non-statutory’ Planning Policy Statement (PPS) in January 2015, heralds the prospect of the replacement of the National Spatial Strategy (2002-2020) with a National Planning Framework (NPF). The PPS emphasises that future Planning Strategy should be both evidence-based and plan-led.

As a contribution to these developments, this paper presents a demographic approach applied to the spatial planning context for current housing needs and points to compelling reasons for developing Ireland’s cities whilst curtailing the ongoing proliferation of villages, small towns and one-off housing, and for services provision, infrastructural priorities and related policy issues.

The paper’s first consideration is that of Ireland’s imperative for its emerging housing strategy: to improve its economic competitiveness which is compromised by its small-scale urban content. The State’s modest-sized settlements, with their inevitable diseconomies of scale, present economic handicaps to the provision of both public and private sector services. Unsurprisingly, they are the subject of current services-rationalisation, often of a controversial nature.

The outgoing spatial NSS planning policy is based on the definition of Balanced Regional Development (BRD) which is self-contradictory. In a modern economy, the optimal performance of the State is critically dependent on that of its primary contributors and of their large settlements’ ability to generate urban agglomerative spill-over: not on the BRD definitional illusion of achieving the full potential of each area. BRD is the opposite to achieving settlements of ‘Concentrated Lumpiness’, which would be characterised as centripetal agglomeration: of dense, efficient centres of population and their associated clusters of employment.

The outcome from the 2002-2020 National Spatial Strategy is that its BRD policy has encouraged excessive village and small-town proliferation. Over a fifteen year period to the last census, there has been a 30.6% growth in the proliferation of settlements of less than 5,000 since 1996, but especially so in for smaller town and village categories. Thus future spatial planning should place emphasis on the selective locations for new housing so as to complement and promote urban agglomeration. New house types are likely to introduce double-duplex and other innovative features of urban design, reducing the need for car ownership whilst encouraging more sustainable forms of transportation, suitable for short commutes.

The paper also differentiates between the requirements of the two principal areas of State: the Greater Dublin Area (GDA) and the Rest of State (RoS) areas. It finds that in 2011 there are many striking contrasts between the two areas. Dublin has nearly eleven times the average population size of the four RoS cities. The overall average settlement size for each of the seven categories of towns and villages is also greater in the GDA.

GDA house vacancy rates in 2011 were between just one-third and one half of those of the RoS areas, a contrast that has increased since then. This places an increasing need for focused housing supply-demand research. The wastefulness and inefficiencies of higher levels of current housing vacancy, directly corresponds to the remoteness of a county from its nearest city and particularly so in its further distance from Dublin.

Given the fragile sizes of Irish urban settlements, the emerging spatial planning and development imperative should especially facilitate the growth of larger, selected, populated towns and some cities, so as to counteract the extent of small-settlement proliferation in the RoS villages and Non-Nucleated populations. The housing crisis and affordability issue is also linked to the unsustainability of long and medium-distance commuting, given the census evidence and the geography of daytime working population and to Ireland’s economic competitiveness.

The research notes that from the most recent indications of prospective developments in Ireland’s spatial planning strategy, there is still little evidence that the authorities recognise or appreciate the need for an urban agglomeration ‘top-down’ approach, where the alternative focus continues to be dominated by rural generated ‘bottom-up’ strategies, making the task of achieving urban agglomeration difficult. Thus there have been few opportunities in the RoS area to exploit and take advantage of urban agglomeration forces.

Unfortunately, Ireland has always had a spatial record of eschewing its cities. In 1969 the first ‘modern’ spatial strategy, the Buchanan Plan’s objective of achieving an accelerated growth of fifteen or so of the provincial cities and larger towns was politically rejected. Subsequent ‘politically dominated’ planning strategies have sought to ‘give a little to everyone in the audience’ instead of implementing a policy of concentrating the State’s limited capital resources to a few chosen locations which have the potential to grow at a much faster rate than the norm and thereby ‘capture’ the benefits of scale, of critical mass and of urban agglomeration.

The irony is that if today’s Ireland had such ‘concentrated lumpiness’, this policy direction would have considerably mitigated the depth of the recession that has visited so many of its small towns, villages and open countryside. Agglomerative ‘spillovers’ from larger Regional cities and large towns remains the only certain way to counteract rural decline. Ireland has yet to learn that painful urban economic lesson.

Because of the bias favouring town growth, exacerbated by the population deflection from unaffordable housing in the cities, especially for Dublin, their aggregate growth has been much lower than might otherwise have been expected. During 1996-2011 the State population increased by 26.53% whereas the cities grew by just 16.42%, – i.e. even less than the 17.72% for the non-nucleated rural areas and towns/ villages of 5,000 and under.

This paper concludes that the capacity to generate ‘spill-overs’ are currently constrained, limited perhaps to Dublin and to the CASP area surrounding Cork City. Thus, it should come as no surprise that due to the defects of past strategic spatial planning policies, rural emigration is rife and economic downturn is magnified for regions which do not have large towns but especially cities.

Full paper

Dr Brian Hughes, DIT

 

 

A road map for planning, development, construction and related job creation in Ireland

Many of the posts on this blog have been critiques of the planning system, the construction sector/developers, the banking sector, and government policy or lack of.  A critique of the blog is that it doesn’t do enough to put forward solutions and a positive path forward, especially given widespread unemployment amongst former construction workers and development residing at the bottom of a deep slump rather than being a productive part of the economy.

In this context, a key challenge for Ireland is to re-grow the construction sector back to a normal, sustainable level as a productive part of the economy and to get construction workers back to work without exacerbating existing issues and problems with respect to property.  This is no easy task, but here is my suggested road map.

First, any attempt to resurrect construction activity in Ireland has to take place within a strategic approach to planning and property that strongly guides any development takes place.  The adoption of core strategies and revisions to the Planning Act are a step in the right direction, but are specific tactics, not strategic visions.

To this end, the government needs to put in place a strategic planning and development framework that combines spatial planning (what used to be the National Spatial Strategy, NSS) and sectoral planning (what used to be the National Development Plan, NDP).  The present NDP expires end of 2013; the NSS is hollow and in review.  The proposed Medium-Term Economic Strategy (MTES) 2014 to 2020 will focus on macroeconomic strategy and policy actions for achieving sustainable economic and employment growth, not planning and development.  The MTES needs to be complemented with a new NDP to run 2014-2020 to guide investment, underpinned by a NSS that will ensure coordination across sectors and locales.  In other words, it should consist of joined-up thinking.  The danger is that without a strategic approach, the development that does occur will be ad hoc, poorly linked, weakly leveraged and will slow recovery.

Both the new NDP and NSS need to be based on an evidence-informed analysis of the present state of property (housing, office, industrial, agricultural, etc), planning/zoning, and models of projected demand based on demographics, economic growth, labour market demand, etc.  This requires decent property data (we have some limited housing data; no independent commercial sector data) that have temporal and spatial resolution.

This strategic framework needs to be prepared to be selective.  Rather than trying to encourage growth everywhere, it should aim to grow selectively to create agglomerations and critical mass.  Agglomeration is important for growing jobs and the economy.  Employ a smart consolidation approach elsewhere (focus on quality of life and sustainability, rather than growth).  Limit further one-off housing: it is unsustainable in service terms (utility and service provision) and environmentally (water pollution, commuting, etc) and contra to popular belief evidence suggests weakens rural communities.

Part of the strategic framework should focus specifically on housing and produce a comprehensive housing strategy.  As well as planning for the future, this strategy needs to address all the issues affecting housing at present:

• vacancy and oversupply in most of the country and pockets of undersupply in specific locales
• large numbers of unfinished estates and poor build quality (issues of pyrite, etc.) that need to be retrofitted
• huge numbers on the social housing waiting list, stalled regeneration schemes, collapsed PPPs
• extensive mortgage arrears and negative equity
• the lack of mortgage credit and a large proportion of cash buyers
• the lack of finance for development and the lack of active developers
• Supply of land.  Land has to be made available sensibly: land bank through NAMA, Site Value Tax/Kenny Report to get derelict/brownfield sites back into productive use, bring on strategic greenfield sites, and limit future land speculation.

Development needs to follow best practice planning principles and should be integrated in nature.  Residential development cannot be simply houses but also needs to be utilities, schools, creches, public transport, etc.  Piecemeal planning undermines formation of sustainable communities.  When housing construction occurs, all the other elements also need to occur at the same time (not several years later).

Second, the creation and delivery of any strategic plan needs to be properly resourced in terms of staffing and finance.

Proper planning requires administrative units capable of delivering: the Department of Environment is severely understaffed with respect to planning; regional planning authorities are shells; local planning authorities are emasculated; NAMA should be part of this coalition.

Development requires finance — there is a need to source investment capital given the Irish banks are not lending.  NAMA should fill the void where possible.  If there is true demand the market does not need stimulating and tax incentives/subsidies should be avoided.  The construction/development sector needs access to finance through loans not incentives.  Do not sacrifice measures such as Part V Social and Affordable Housing provisions of the Planning Act (we need social and affordable housing).

Third, we need new entrants into the sector to replace failed enterprises.

Encourage new developers through loans/grants — many of the older ones are bust, tied up in legal cases, or cannot access investment capital.  We need new entrepreneurs to enter the market who have fresh ideas and energy and do not have any of the bad habits and institutional memory of the old set.

Encourage new, large rental companies into the market and professionalize the rental sector.  The rental sector is under-regulated and is dominated by amateur landlords (70% own 1 or 2 properties).  Encourage cooperative and association housing and make finance available to them for new projects.

Specific ideas to re-grow the construction sector back to a normal, sustainable level and to get construction workers back to work

Invest in capital projects that will stimulate the economy beyond construction jobs (i.e. will provide the conditions that will attract inward investment and indigenous growth)  — public transport, utilities (electricity grid, water system, broadband), public infrastructure (e.g. school building — 1 in 3 schools still have prefabs and the number of children is growing; hospitals; universities, etc), selective road building, etc.

Proactively address the housing issues detailed above.  (1) complete viable unfinished estates and deconstruct the others; (2) address build quality and pyrite-infected homes; (3) restart regeneration projects and revive PPPs with new partners; (4) refurbish existing social housing.

Enable private housing in very select locations where there is a demonstrated demand/projected demand based on hard evidence.

Enable office development in very select locations where there is a demonstrated demand/projected demand based on hard evidence (remember >20% of office space in Dublin is vacant; in some parts >40%; similarly lots of empty retail/industrial space in Dublin and throughout the country).

Curtail speculative development of all kinds where there is no demonstrated need/demand. Under no circumstances create additional supply in areas where there is already oversupply as it will flat-line any recovery and extend related problems.

I am open to suggestions and debate with respect to this road map.  We need these kinds of conversations.  What I do not think is sensible is to have no strategy and plan and to simply try and muddle through and hope that inaction and the present lack of policies and direction will somehow solve our various issues.  They won’t; they are more likely to cause additional problems.

Rob Kitchin

 

A New Vision for Irish Planning

At the recent AESOP/ACSP conference in University College Dublin, which brought together 1,200 planning academics and scholars from all over the world, Minister Jan O’Sullivan announced her intention to shortly bring forward a new planning policy statement setting out a new vision for the Irish planning system.

After the past few years of fire fighting, whereby the Government was desperately attempting to reign in the excesses of the Celtic tiger era and impose some control on the often reckless conduct of planning authorities, there is no doubt that such a vision is now sorely needed so that we can begin to effectively plan for the future. Earlier posts on this blog pointed to the current period of crisis as an opportunity for rethinking accepted ideas, policies and practices in relation to future planning and development in Ireland.

According to Minister O’Sullivan “…if the public doesn’t understand how the planning system works, why certain things are permitted and certain other things aren’t, then your planning system isn’t doing its job.” It is true to say that other than a vague comprehension of the legacy costs of ‘bad planning’, the public appreciation of what purpose planning serves in society has hit rock bottom, mired as it is in a perception of corruption, cronyism and ineptitude. This has not been helped by the complete failure of both the professional institutes and academia to effectively communicate a cogent mission and rationale for planning.

Planning is, at least in the public mind, typically reduced to development control i.e. planning applications. This is demonstrated by each and every time surveys are published showing a drop in the number of planning applications, which are inevitably accompanied by a chorus of calls for a reduction in public planners. This narrow technocratic interpretation (such as that conveyed in the BBC documentary ‘The Planners’) is something to which many public planners have grown both resigned and accustomed to. To be fair, this state of affairs has also been created in no small part by a deep cultural antipathy to planning in Ireland and an unfettered attitude to private property rights.

In a famous 1973 critique of planning, Aaron Wildavsky mused “if planning is everything, maybe it’s nothing” and there is more than a modicum of truth in this observation. In recent years the planning system has been lumbered with an ever more complex range of regulatory functions. Planners have had to come to grips with a whole host of new skills as well as grappling with the novel challenges brought about by the recession, most of which they plainly have no training for. A review of any county or city development plan will quickly show that planning is now the vanguard for an ever growing and diverse range of complex agendas such as housing policy, nature protection, flood risk management, vacant housing, renewable energy production, water quality protection, retail impact assessment, town centre management, economic development, climate change mitigation, landscape protection, heritage, infrastructure delivery etc.

Planning has now become so large and complex that the public planner cannot encompass its dimensions. As a result, county and city development plans are largely obscure and voluminous documents extending to hundreds of pages with vague policies often wrapped up in impenetrable jargon and mutually exclusive policy goals. Planners now find themselves at the nexus of so many contentious and contested policy debates and it is little wonder that the profession has retreated to the high moral ground of blaming politicians and sought cover in the banality of development control. I do not argue that mediating competing economic, social and environmental agendas should not be a core function of planning into the future. However, we must be aware that extending planning to cover so much merely serves to obfuscate what it is precisely that planning is attempting to achieve. A cynical critique would indeed conclude that maybe that is indeed nothing.

Of course, collapsing the purpose of planning down to a core agenda is a process fraught with danger. This was well demonstrated by the England’s recently published National Planning Framework (NPF). The function of the new NPF is ostensibly to simplify the planning code. However, the real rationale is clearly the perennial Tory neoliberal agenda of planning retrenchment and foreclosing all but a narrow debate around the economic growth agenda and boosting housing supply.

If there is one thing that any new planning vision for Ireland should definitely not be about is economic growth. This may appear a rather taboo notion in an environment where the consensus demands that every public policy is compelled to fully justify itself on the basis of the economy. However, it is readily obvious with even a cursory analysis that it is not within the gift of planning to grow the economy. Including growth as a core goal of planning tends towards overproduction (e.g. housing, zoning etc.); heightens competitive pressures between regions favouring larger urban centres; and systematically excludes qualitative social and ecological considerations which must be at the heart of planning thinking. Indeed the origins of planning were in mitigating the crisis conditions brought about by rapid economic growth.

In order to avoid mission creep and reassert the relevance of planning for the daunting challenges of the coming 21^st Century we must therefore firmly place the horse back at the front of the cart. Rebuilding public trust in the battered image of the planning system compels us to create a new mission for planning which is realistic, relevant and serves to build a shared public understanding of its value. This must first start with an explicit recognition that planning involves making choices – planning is politics.

Any future vision for Irish planning must therefore return to the welfare state origins upon which modern planning was founded, rooted in concepts of social and spatial justice. This requires an explicit move away from the depoliticised, entrepreneurial growth agenda aimed at boosting supply side activities such as housing and infrastructure provision. A new vision for planning must be centred upon the public goods and services for which the spatial distribution is within the remit of the State to achieve. The delivery of public services requires certain infrastructure networks including, for example, transport, waste, energy and communications infrastructure as well as facilities and services related to health, education, culture and recreation – all of which require an integrated approach to settlement planning. A simple mission for this new planning vision could be: “To ensure that a certain socially agreed and necessary base level of services that people need are provided when and where that need occurs”.

In many ways the disconnect between public service delivery on the one hand and the spatial distribution of population on the other sums up the failures of the Irish planning system over the past few decades. This was laid starkly evident with, for example, the debacle in west Dublin where little consideration was given to the fact that a rapid increase in new housing would soon yield a requirement for new schools. Equally, in many rural areas, the collapse of the Celtic tiger artifice and the accompanying severe programme of public service retrenchment has left many communities without necessary services. In many cases these are areas where a massive ad hoc proliferation of scattered housing was permitted necessitating many people to travel large distances to access services and employment opportunities, or to live without.

In Germany, for example, the overarching aim in the development of the spatial structure of the national territory is to establish equivalent living conditions in all parts of the country. The Iceland 2020 strategy, which was forged after the economic collapse of the state, similarly puts the welfare and quality of life of its citizens at the centre of its national planning policy. In effect, a policy of equivalent living conditions would primarily benefit peripheral regions, since there are usually greater structural weaknesses and imbalances in these regions. Equivalency, however, does not mean that all regions must have identical infrastructure or that the income of all people must be the same everywhere, which is neither practicable nor reasonable. Regional equivalence of living conditions means that as many citizens as possible are able to participate equally in development of society. To approach equality of opportunity it is necessary to ensure certain minimum standards with respect to access to and the availability of services of public interest, to options for earning a living, to infrastructure and environmental qualities.

Placing social security and the equality of citizens to the fore of the agenda for a new planning vision would require a fundamental rethink of how we plan and provide a compelling rationale for promoting public acceptance as to why we plan. Upholding this principle at a time when public resources are limited could help inform a, heretofore absent, rational national dialogue on settlement planning. Importantly, it could also help close the gaping lacuna which has been the achilles heel of the Irish planning system for decades – the dichotomy between planning policy decisions made by local authorities and the opportunity costs to society associated with those decisions. The model underpinning the Local Property Tax, for example, comprises numerous spatially derived variables including relative distance to services and amenities. Therefore, in theory, the more households with good accessibility to local services, the greater the return to the local authority to maintain those services, thus creating a virtuous circle.

Such a vision should not be alien to Jan O’Sullivan who is after all a Labour Party minister. However, in an era of consensus-seeking where planning has become a depoliticised, stage-managed process which attempts to please everyone through ‘win-win-win’ policy solutions, I have no doubt that when published the new vision will be the usual fuzzy policy muddle of irreconcilable policy goals which superficially offers something to everyone but achieves very little.

Gavin Daly

 

Scrapping of the National Spatial Strategy

Yesterday Minister Phil Hogan announced that the National Spatial Strategy (NSS) is to be scrapped and replaced by a new policy in about a year’s time.  He said that said the present ‘strategy had failed’ because ‘the gateway and hub cities and towns never received the resources to ensure their development and “nothing has happened” in the ten years since they were designated.’  Continuing that ‘there was no point in having a designation without the resources.’

It is certainly the case that the NSS did not live up to its expectations, despite its promise and intent.  The initiative failed for a number of reasons, of which resourcing is just one.

First, there were flaws in its initial design with respect to the designation of too many hubs and gateways and there were accusations of stroke politics in location selection.

Second, because it was introduced in 2002 it missed its logical initial resourcing stream, the National Development Plan (NDP) 2000-06.  It did underpin the NDP 2007-13, but then the crisis hit and the NDP got quitely dropped and funding for NSS initiatives, such as the gateways fund, was one of the first things the DECLG dropped from its programme.

Third, there was weak political buy-in across the board, especially within government.  This was made abundantely clear by the decentralisation programme introduced by Charlie McCreevy in 2003 that sought to move government departments and state agencies to just about every location except gateways and hubs.  Decentralisation seriously undermined the rationale and impetus of the NSS.

Fourth, the NSS was not put on a statutory basis and up until 2010 planning authorities only had to give ‘due regard’ to it, rather than complying with it.  In a period of developer-led, laissez faire, localist planning this was a license to largely ignore it.

What this meant was a very partial implementation, though the NSS did have some effects on other policy (e.g. NDP, Transport 21, Rural Ireland 2020, etc) and was significantly boosted by the introduction of regional planning guidelines and the Planning and Development Act (2010) and the introduction of core strategies (in which planning decisions have to demonstrate they fit local, county, regional and national policy objectives).

So what happens now? Is this the end of spatial planning in Ireland?

Well one would hope not. If Ireland ever needed a strategic plan to make the most of limited resources in order to facilitate inward investment, stimulate and support indigenous growth, produce sustainable development and create of better places, it is now.

The logic of spatial planning is to align and coordinate sectoral initiatives (such as transport, energy, jobs, property, utilities, communications, public services, etc) across territory in order to leverage complementarities, reduce redundancy and duplication, increase competitiveness, and create multiplier effects (where the sum is greater than the simple addition of parts).  It does this by selectively prioritising areas for different kinds of activities in line with its demographics and local resources and distributing funds suitable to enable targetted investment and coordinating development across sectors.

Rather than abandoning spatial planning and the NSS, we need to do a fundamental rethink and produce a new NSS that is suitable to the present context. Localism and ad-hocism is not the solution to the economic and social crisis and will not create a sustainable, competitive country into the long term.

The challenge over the next year is to produce a new NSS based on a robust evidence base, learning from international best practice, and involving detailed stakeholder consultation, that is strategic and is prepared to make difficult decisions given limited resources.  Once agreed upon, the new NSS needs to be put on a statutory basis, as advocated in the Mahon Report, and it needs to be implemented through a series of interlocking programmes and initiatives.

My hope is that we can rise to this challenge and produce a spatial planning framework that will serve us well.

Rob Kitchin

 

For a good introduction to the present NSS, see the recent special edition of Administration 60(3), The National Spatial Strategy: Ten Years On, guest edited by David Meredith and Chris van Egeraat.

Revisiting the National Spatial Strategy ten years on – David Meredith & Chris van Egeraat

 

The National Spatial Strategy: Rationale, process, performance and prospects – James A. Walsh

Economics – The missing link in the National Spatial Strategy – Edgar Morgenroth

Perspectives on Ireland’s economic geography: An evaluation of spatial structures – David Meredith, Jim Walsh & Ronan Foley

Gateways, hubs and regional specialisation in the National Spatial Strategy – Chris van Egeraat, Proinnsias Breathnach & Declan Curran

Urban specialisation, complementarity and spatial development strategies on the island of Ireland – Des McCafferty, Chris van Egeraat, Justin Gleeson & Brendan Bartley

Governance and the National Spatial Strategy – Placing spatial policy at the heart of the diagonal public service – Séan O’Riordáin

Shrink smarter? Planning for spatial selectivity in population growth in Ireland – Gavin Daly & Rob Kitchin

 

Some Thoughts on the Introduction of a Planning Regulator

Yesterday, Minister Jan O’Sullivan appeared before the Oireachtas Joint Committee on the Environment, Culture and the Gaeltacht to outline her Department’s proposals to legislate for the introduction of a Planning Regulator in 2013. The introduction of an Independent Planning Regulator was a key recommendation of the Mahon Tribunal Report published last year. The Tribunal recommended that the Minister for the Environment’s planning policy enforcement powers be transferred to an Independent Planning Regulator who should also be charged with carrying out investigations into systemic problems in the planning system as well as educational and research functions.

The introduction of an independent Planning Regulator, which the Minister has publicly committed to, does not entail a simple ‘bolt-on’ addition to the planning system. It will profoundly alter and transform the entire way in which planning policy has to-date been implemented in Ireland. It is clear from the text of the Minister’s speech that in framing their policy proposals for the forthcoming legislation, the Department is grappling with the many complexities and difficulties at the heart of the problem – that is, that planning is fundamentally a political activity which does not lend itself neatly to simple bureaucratic regulation. In guiding the discussion at the JOC, the Minister posed a series of questions as follows:

• Should the Minister’s powers be fully transferred to an independent regulator or should the final forward planning decisions remain political in nature (i.e. to be taken by the Minister / Government / Oireachtas) with a regulator providing an independent advisory / supervisory role?
• If power is to be fully transferred, how can we ensure accountability by an independent regulator?
• What would be the limits of the regulator’s powers vis-à-vis the planning process and elected members? Is the regulator’s decision final?
• Should the role of a regulator be confined only to situations where a dispute arises over a plan?
• What is the most suitable institutional arrangement for delivery on the recommendation (e.g. new authority or some type of recast of existing framework)?
• If a new authority is to be established how would it interface with the existing institutional framework (planning authorities, regional authorities, An Bord Pleanála)?
• If existing structures are to be used, what entity could take on the function and how can the new function be taken on without eroding capacity to discharge existing roles or without being detrimental or damaging to well established and publicly accepted independent role’? For example, if the plan-making regulatory function is to reside in an existing body such as An Bord Pleanála, might that affect the other functions of the board creating an inherent tension between making the Board making decisions on forward planning, development plans and local area plans as well as individual planning cases?
• Is there not a case for the Regulator to be the person who conducts the fundamental assessment of the performance of the planning system, including an assessment of the effectiveness of the Minister, local authorities and so on rather than becoming a super-non accountable national planning body?

Firstly, it is worth commenting on what the Minister did not say in her speech to the JOC, but which is absolutely critical in framing this debate. It is essential that, as also recommended in the Mahon Tribunal Report, both the National Spatial Strategy and National Development Plan be placed on an explicit statutory footing (as is the case in Scotland, for example). The forthcoming legislation should specify that both the NSS and NDP be reviewed in parallel and be subject to Oireachtas approval. The legislation should place a mandatory obligation on government to jointly review both the NSS and NDP at a minimum each and every eight years; outline precisely what is required to be included in both plans (including delivery and implementation); the procedure by which they are to jointly be reviewed; and provide for transparent public involvement in the process i.e. a staged process similar to that required of local authorities in adopting development plans. The placing of the NSS/NDP on a statutory footing will require both plans to be subject to Strategic Environmental Assessment and Habitats Directive Assessment, – including an analysis of alternative future scenarios – and allow for a public and political debate which is desperately needed.

The placing of the NSS/NDP on a statutory footing will ensure that that national planning policy remains a political activity. However, the regulation and oversight of the system should be independent. There has been considerable reform and improvement of the planning system in recent years with the introduction of multi-level and multi-agency oversight. As a result, the scope for local authorities and/or regional planning authorities to deviate from national policy has been considerably reduced. However, the current system whereby the Department reviews, comments and potentially ‘calls – in’ local authority development plans through Section 31 of the Act needs to be replaced with a system of independent oversight. Planning in Ireland is mired in a public perception of corruption, cronyism and political interference and only an independent regulatory authority will suffice in undoing this perception. In doing this, the Department can get on with the important business of plan-making.

Accountability can be ensured by designing the system so as to be fully transparent through, for example, the full application of the Access to Information on the Environment Directive, requirement for the Planning Regulator to attend at Joint Oireachtas Committees as necessary, an open and transparent appointment process for a fixed term, full publication of all reports within mandatory time limits, and strong legal deterrents against lobbying, etc. The decision of the Planning Regulator should be final. This does not imply that the role of the Planning Regulator is designed so as to be inflexible. As is currently the case between, for example, the Department, the National Transport Authority, the Regional Planning Authorities and local authorities, the regulatory system can be designed so as to allow formal interaction with the Planning Regulator to reach consensual solutions where possible. It is accepted that there could be rare occasions whereby the Planning Regulator fails to act or acts inappropriately and a fail-safe mechanism is required. In such situations the Minister must remain ultimately accountable and the power should rest with the Minister to override the decision of the Regulator. Again, the legislation could be crafted such that, in such rare circumstances, a draft order be required to be laid out before each house of the Oireachtas and could only be proceeded with following a resolution approving of the draft has been passed by each house.

It is not appropriate that the proposed Planning Regulator be merged with An Bord Pleanála. In the same way as the Minister is precluded from commenting on any specific planning application and An Bord Pleanála has no role in the forward planning system, there should be a strict separation of powers. The role of the Planning Regulator should be confined to ensuring that national planning policy is correctly implemented and overseeing complaints against planning authorities. This should include complaints on allegations of corruption, improper procedures or systemic problems and undertaking periodic audits of the planning functions of local authorities – but not extending to a role in reviewing a decision on any specific planning application. For example, the Local Government Ombudsman currently has the powers to examine complaints about how local authority staff carry out their everyday executive and administrative activities in relation to the planning system. These include complaints about delays or failing to take action in relation to, for example, planning enforcement matters. These oversight powers should be transferred to the Planning Regulator.

The introduction of the Planning Regulator does not necessitate the creation of another expensive QUANGO. Throughout the ‘Celtic tiger’ period local authorities employed significant numbers of planners and other professionals to deal with the huge volume of planning applications. With the dramatic fall-off in new development proposals and the proposed reforms of local and regional governance structures, there is considerable scope for suitable professional staff to be seconded from elsewhere in the public service. There is also a plethora of agencies with some responsibilities in oversight, such as the Regional Planning Authorities, the National Transport Authority, the Local Government Ombudsman and the Office of Environmental Enforcement. An innovative and rationalised approach to oversight could yield significant savings and the establishment of a more coherent system. For example, the Planning Regulator could be housed as a sub-unit of the Local Government Ombudsman to ensure administrative synergies are maximised.

Finally, a further important recommendation of the Mahon Tribunal Report, also not referred to in the Minister’s speech, was that the Planning Regulator should be mandated to undertake educational and research functions. There is no doubt that heretofore planning education and public/political awareness of the important role of land-use planning in society has been abjectly lacking in Ireland. The abolition of An Foras Forbartha (similar to the Design Council in the UK) in 1988, the abolition of local rates and political cronyism and ineptitude all contributed to this end. The evidence-base for planning has improved dramatically with the development of tools such as MyPlan and AIRO. However, I am not convinced that a regulatory authority is best positioned to undertake planning education and research. It should be the role of the Department, unburdened by oversight responsibilities and with a new and focused national planning mandate, to lead in this important task drawing on the existing capacities within universities and other private and public bodies. For example, could the Housing Agency be reformulated as the ‘Housing & Planning Agency’ to provide a 21^st Century An Foras Forbartha?

2013 has the potential to be a landmark year. In the aftermath of the economic collapse, exactly fifty years after the introduction of the first planning acts in 1963, twenty-five years after the short-sighted abolition of An Foras Forbarhta and ten-years after the publication of the NSS, we have a once in a generation opportunity to reform the planning system, rethink the role of national planning for our long-term prosperity and to foster a new consensus in the public and political consciousness as to the value of planning in building a nation for the common good. We shouldn’t waste it.

Gavin Daly

 

The need for a land banking strategy

There was an article in Tuesday’s Irish Times concerning the land aggregation scheme run by the Department of Environment. To date, 47 sites with a loan book of €110 million has been transferred to the Housing and Sustainable Communities Agency, which has responsibility for the management and maintenance of the land.  There have been 115 sites submitted, with loan debts of €260 million and interest accruing.  The local authorities can only redeem the loans if they have fallen due for repayment, and local authorities have housing loans totalling €499.5 million which could possibly all transfer at when the loans mature.  Nearly all loans are for more than was originally paid due to interest payments.  For example, Fingal County Council owed c.€26.5 million for a 24-hectare plot near Balbriggan, originally bought in 2000 for c.€19 million (one wonders why it didn’t manage to use it between 2000-2007 given it was gaining interest every year, they had a very rapidly growing population, and there was a pressing need for affordable and social housing).

This land, and the land in NAMA, represents the best opportunity the State has had, probably in its history, to create a national land bank.  Such a land bank would enable the state to control at a reasonable cost the provision of land for key developments such as social and affordable housing, schools, hospitals, play areas, community facilities, transport routes and so on.  Because there has been no carry forward costs to holding land (such as property tax), and the recommendations of the Kenny Report were never implemented, the state has been held to ransom by land speculators for development.  As a result, land costs have been a significant percentage of overall cost in state-led development, for example, in road building programmes.

And because the land is only in the hands of two agencies, it should be relatively straightforward to consolidate and coordinate.  The Irish Times piece suggests that this might be occurring to a certain extent: “The agency [HSCA] will consult the National Asset Management Agency to determine the best use of all land banks controlled or owned by the State. In some cases, Nama may advise that lands originally bought by private developers could be combined with adjacent lands bought by local authorities, for better returns. It is also possible that some of the land will be used for social housing in the future, the department has said.”  I have three concerns, however, with present arrangements and practices.

The first is that I do not believe that either HSCA or NAMA have either the mandate or requiste staff with the required skill set to determine the best use for land banks.  Long term spatial planning is not in the remit of either agency and yet they are being asked to manage a key component necessary for it.  How exactly are they making decisions about ‘best use’ of land banks?  How is this evaluated?  Against what criteria?  In consultation with whom?  NAMA has one full-time planner and a planning committee that includes three planners.  All very experienced, but this task requires an interagency team of experts with regional/national spatial planning knowledge working on it in a concerted fashion inconjunction with the regional and local authorities.  HSCA similarly does not have the in-house expertise.

Second, long term landbanking requires long term planning.  In the Netherlands, who have built up a considerable land bank and use it to good effect, they have long term spatial masterplans that detail anticipated development over the next 30-40 years.  They have worked out in principal where they want to concentrate population, build transport infrastructure, place industry, retail, utilities, schools, hospitals, services, etc under different demographic scenarios and organised land accordingly.  We have no such masterplan.  We have a broad spatial strategy that has no specifics and 400 generally uncoordinated local and county development plans administered by 88 planning authorities.  Making long-term land banking decisions means have a good sense of what development land the various parts of the state are going to require well into the future.

Third, that the need for a return in the short-term in order to reduce state overhead will mean that the land will be sold back to private developers at a massively discounted price (75-98%) of its value in 2007 or the amount it cost the state.  In the future we will need to buy this land back at market prices which will be much more than it is now.  The result will be speculators making a fast buck at the taxpayer expense, and in the absence of proper property tax will have little overhead for doing so.  This will be a disaster for the tax payer, especially given the opportunity we presently have.

In my view, NAMA and HSCA should produce (1) a public strategy document on how it proposes to manage the land bank it presently has, (2) should then put in place the structures needed to implement this strategy which is properly resourced and staffed.  To make decisions about land banking in the absence of such a strategy, with no public oversight or public knowledge as to what is planned (or rather not planned) is shortsighted and foolish and will lead to costly mistakes being made.  We have a unique opportunity to make long term gains through land banking, let’s not waste that opportunity by not managing it properly and frittering it away.

Rob Kitchin

 

Shanghai on Shannon: Will it happen?

We first posted on possibility of a Chinese trading hub in Athlone in Nov 2010, noting how the idea for the development managed to achieve some momentum through political networks.  Interestingly, those networks were predominately Fianna Fail-centric and reeked of the ‘Galway tent’ mode of doing business, but are now a lot of less potent.  Yesterday An Bord Pleanala gave planning permission for the first phase of the development – to include three major exhibition halls, nine minor ones and other facilities totalling 102,348sq m (1.1 million sq ft), as well as underground parking for more than 1,300 cars.  There are a number of questions that the proposed development raises.

How big is the development?

Very big.  The site is 337 acres.  An Taisce estimates that development once complete will be 14 times the combined size of Liffey Valley and Blanchardstown shopping centres.  It aims to attract 1.5 million international buyers and visitors annually when fully completed and employ up to 9,000 people.  It would be one of the largest exhibition spaces in Europe.  The main issue with regards to this size will be servicing – adequate utility and transport infrastructure to ensure smooth running; this is feasible with good planning though there are some site issues as discussed below.

Does it align with spatial planning policy?

Yes.  Athlone is a gateway town in the National Spatial Strategy.  This means it is designated as a preferred site for population growth and economic investment.

Will it happen?

The key issues here are finance, political and state backing, other local development, and external competition.  If the project is going to be backed purely by Chinese capital looking for a spatial fix in Europe then the project is solely dependent on that finance being made available to fund the development.  This seems, however, to be unlikely.  Private investment is going to want to leverage finance and resources from the local and national state through in-kind provision of infrastructure and state aid to companies via IDA and others as with other FDI-backed ventures.  The state, and its various agencies then, is going to need to decide whether it wants to provide matching monies to help seed the larger investment.  Clearly local agencies are already backing the project with some resourcing.  The developers are also likely to need other private investors to spread the risk and its not clear if such investors have already signed up or will need to be found.

Beyond the project site itself, as an international trading hub transport infrastructure is going to be key.  Athlone is some distance from the two main international airports, Dublin and Shannon, and the travel to the site by coach/rail is a hindering factor for both the visitors and goods.  The solution proposed locally, as we posted about previously, is the development of an airport near to Athlone.  This has already been granted ‘strategic infrastructure’ status by An Bord Pleanala in Sept 2010.  The same questions about finance and state backing arise with respect to this project, but the two developments do seem co-dependent.

There are other competing locations for such a Chinese trading hub, with other sites being explored in Britain and continental Europe.  It is unlikely that there will be multiple such dedicated sites, so the consortium is going to have to convince investors that Athlone is the best location.

Is it the right location?

Athlone is a gateway town and it would be a fantastic development for the area if it happens.  However, location and particularly transport connections are an issue.  In a European context, Ireland is on the periphery of the continent and is dependent on air/sea for travel.  Whilst other FDI has been able to thrive here with such dependencies, these companies are not solely reliant on massive, daily international flows of visitors and goods.  That’s one of the reasons we do not already have a large, thriving, international exhibition sector. In an Irish context, it would make sense to locate the site nearer to already existing air/sea infrastructure.  The obvious location would be Limerick/Shannon/Ennis where there is already an established international airport and sea port for container shipping.  Clearly this will not suit the Athlone backers, but might be a determinate as to whether investors think the scheme is viable.

In my opinion, the Athlone project is largely a Field of Dreams idea that has managed to gain some momentum.  Whether it materialises into the development envisaged is certainly not assured and there is a long way to go to make the dream a reality.

Rob Kitchin

 

 

Future framework for higher education: Regional clusters

The Hunt report – A National Strategy for Higher Education – was published yesterday.  It covers a lot of ground with respect to teaching/learning, research, engagement, internationalisation, funding, governance and so on, and here I’m just going to focus on what it has to say about the relationships between institutions and possible rationalisations.  As with other HEA initiatives such as PRTLI and SIF, the report strongly advocates inter-institutional cooperation between “diverse, responsive and sustainable institutions”, “each of appropriate scale and capacity”, that increasingly have “distinct and well-defined roles, responsibilities and interrelationships”.  As such, institutions will on the one hand seek to develop core, niche competences, and on the other work with each other with respect to shared areas of interest in order to gain critical mass and pool “expertise, knowledge and resources”.

Interestingly, the method envisaged to facilitate such cooperation is a regional clusters model, wherein collaboration is fostered “between clusters of geographically proximate institutions, to ensure that individual, enterprise and societal needs are addressed in a planned, coherent and efficient way”.  Rather than paraphrase, I’ll quote from the report itself on the logic at play here, which – if this route is to be pursued – I think has merit as an approach.

“Clusters will be characterised by close coordination and cooperation between various types of independent higher education institutions. Together they will determine and meet the needs of a wide range of students, communities and enterprises in their region. This will require joint programme planning, collaborative research and outreach initiatives, agreements on mutual recognition and progression, and joint strategies for advancing regional economic and social development. The institutions will also engage with other statutory providers of education and training, such as FÁS and the VECs, to develop integrated regional learning strategies. The HEA should promote such regional clusters by providing incentives and by requiring institutions to build regional collaboration into their strategic plans.

The cluster model complements the National Spatial Strategy, and will benefit from the ongoing improvements in regional governance structures. These offer the potential to enhance engagement between higher education institutions and local authorities, local State agencies and other stakeholders, and to assist in developing shared solutions to local and regional needs.”

I think an alignment with the NSS, regional development and the concept of learning regions makes much sense as it places these kinds of arrangements within a larger strategic developmental framework rather than allowing the evolution of the higher education sector to unfold in an ad hoc manner.  And institutions have already recognised this and started to organize themselves into clusters that are regionally grounded – e.g., TCD/UCD alliance, Atlantic Gateways alliance between UCC, UL and NUIG, the strategic partnership between NUIM, DCU and RCSI, the Dublin Regional Higher Education Alliance (DRHEA).  Given this regionally focused approach, the report argues against a single federal national technological university as advocated by some IoTs.

Where such collaboration has not already happened or is piecemeal or slow to develop the report suggests the use of incentives to encourage “the development of regional clusters and institutional consolidation. This would result in a smaller number of institutions and a greater level of collaboration across the system.”  Interestingly, it’s here where we come across the idea of institutional consolidation and a shrinkage in the number of institutions.  It is argued that Ireland has too many higher education institutions, many that are too small in scale.  However, it is envisaged that any consolidation will happen either within the university sector or the Institutes of Technology sector, but not between universities and IoTs, although universities and IoTs will be encouraged to increasingly work with each other and share programmes.  The emphasis here really seems to be on the merging of IoTs to gain scale and critical mass.  The report also maps out a route for some IoTs to progress to becoming technological universities, which again involves criteria with respect to the contribution or effects on a regional clusters model.

Of course, whilst the report suggests a strategic framework for the creation of regional clusters of aligned HEIs, and some moves in this direction can be undertaken without significant funding, the major issue facing the sector is chronic underfunding and the loss of staff at a time when student numbers are increasing.  The government has consistently argued for a smart economy predicated on smart citizens and at a time when it should be increasing education spend, it has been cutting it from an already low base – the proportion of GDP spend on education is poor in comparison to other European countries (30^th out of 33).  There’s not much that’s very smart about that policy.  Our future is our youth.  We need to invest in education, not just reorganise the chairs on the deck as the boat sinks lower.  Regional clusters seems like a sensible way forward if the strategy in the Hunt Report is to be pursued, the bottom line however remains the bottom line.

Rob Kitchin