The extension of the tax incentives to the BORDER, MIDLANDS AND THE WEST
Rural Renewal Scheme for the Upper Shannon
15 July 1999.
Mr. Liam Murphy,
Budget and Economic Division,
Department of Finance,
Upper Merrion Street,
Dear Mr. Murphy,
Last January, the Heritage Council expressed a number of concerns about the pilot Rural Renewal Scheme for the Upper Shannon, in relation to its potential impact on the national heritage, to the Minister for Finance. Following this submission, the Council is pleased to note that a number of amendments were made to the scheme. In particular, amendments were made to the provisions relating to the size of eligible developments, the application of the incentives to derelict and unoccupied housing, and their application to owner-occupied residential developments.
The concerns and recommendations of the Council relating to the lack of an overall strategic plan for the pilot area were not addressed at this time, and Council wishes to address this issue once again with both the Department of Finance and the Department of the Environment & Local Government.
The area encompassed by the pilot scheme is one that is particularly susceptible to irreversible damage of its heritage and environmental resources due to insensitive and inappropriate development. It is essential, therefore, that all development within the area, and particularly, that which takes place as part of the incentive scheme, adheres to the principles of sustainable development. Given the abundant water resource that exists in the area, there is enormous potential for the sustainable use of amenities, but this is an objective that has to be planned for in a structured way, rather than hoping that market forces will identify and realise development which is sustainable.
The two major concerns of the Heritage Council in relation to the operation of the pilot Rural Renewal Scheme for the Upper Shannon, are as follows, and are expanded upon below:
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- The lack of a strategic spatial plan for the area designated for the purposes of the pilot scheme to determine what development is most appropriate where and at what pace.
- The failure to appoint a government department or agency with responsibility for the monitoring and evaluation of the scheme with respect to its sustainability.
1. The lack of a single strategic plan for the area designated for the purposes of the pilot scheme
The five counties involved in the pilot scheme are Longford (entire), Leitrim (entire), Cavan (part), Roscommon (part) and Sligo (part). These counties straddle the boundaries of three Regional Authorities: Border (Leitrim, Cavan & Sligo), Midland (West), and West (Roscommon). One of the functions of the Regional Authorities is to co-ordinate the Development Plans of its constituent authorities. In this case, with three regional authorities involved, there is unlikely to be a great deal of co-ordination between the current Development Plans of the five counties. In effect, a new region has been identified, and one which requires a strategic plan to guide and co-ordinate its future spatial development. The combined Development Plans of the five local authorities in question is not a sufficient strategic planning tool with which to ensure that the development, which will take place within this 'region' as a result of the pilot scheme, will be in line with the principles of sustainable development.
Following the KPMG report on the first ten years of the Urban Renewal Scheme (1996) and the results of the Seaside Resort Scheme of the past several years, we can no longer afford to embark upon a scheme which offers lucrative financial incentives for property developers, without first putting in place a strategic plan which simply identifies what type of development is most appropriate where, and indicates an acceptable limit to the various types of development. One of the main recommendations of the KPMG report in 1996 in relation to the Urban Renewal Scheme, was that in any future scheme, local authorities should be required to prepare Integrated Area Plans for their designated areas. The same principle should apply to the pilot Rural Renewal Scheme. It is no longer acceptable to adopt a laissez faire approach to socio-economic regeneration, allowing the market to dictate what kind of development takes place where and at what pace.
The Council notes from the Minister for Finance's response to a Parliamentary Question on 1 July 1999, that "the aim of this pilot scheme is to improve the economic and social condition of this deprives rural area‚Ä¶‚Ä¶". The approach being taken to address this condition, however, is solely concerned with the enhancement of economic growth. This form of issue-specific planning response fails to grasp the essential characteristic of good planning: the establishment of a comprehensive and balanced solution applied to all sectors of activity and interest on a continuous basis over time. The government's strategy for sustainable development states that "spatial planning and land use policies, which of necessity have long time frames, seek to promote orderly development to support socio-economic policies concerned with, for example, balanced regional development, social integration, urban renewal and the maintenance of strong rural communities", yet strategic planning has been given no place in this scheme. The Heritage Council is calling for the promotion of a strategic vision and a commitment to the principles of sustainable development in the implementation of the pilot scheme.
The Heritage Council recommends that such a strategic framework should be prepared by a group constituted of the following bodies:
- the five local authorities
- Department of the Environment and Local Government
- Department of Finance.
2. The failure to appoint a government department with the monitoring and evaluation of the scheme in respect of its sustainability
The Department of Finance has alone been appointed to oversee the implementation and review of the pilot scheme. This again reflects the single-issue approach of the government to this scheme, and the Heritage Council is not aware of any evidence to suggest that the indicators to be used in measuring the performance of the scheme will be any other than economically-based. This is clearly not in line with the principles of sustainable development, nor is it in line with the thrust of the government's strategy for sustainable development in Ireland, as outlined in the document Sustainable Development - A Strategy for Ireland. An integrated approach should be adopted to the monitoring and evaluation of the scheme, co-ordinated by the Department of the Environment and Local Government, as the government department responsible for spatial planning.
In light of these concerns, the Heritage Council requests a meeting with representatives of both the Department of the Environment and Local Government, and the Department of Finance, to discuss these issues further.