Public Participation in the Development Plan Process Effectiveness in Reaching the New Irish Population in Dublin

Public Participation in the Development Plan Process: Effectiveness in Reaching the New
Irish Population in Dublin
By Michael Blackwell
D05102932
B.Sc. Spatial Planning
Supervised by Lorcan McDermott
27th April 2009

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Table of Contents
Acknowledgements...................................................................................................................v
Abstract.....................................................................................................................................vi
Chapter 1: Introduction.............................................................................................................1
Chapter 2: Literature Review....................................................................................................4
Nature and Purpose of Public Participation...........................................................................4
Terminology ...............................................................................................................................4
Levels of Participation and their effectiveness in engaging the community.............................4
Participation in a multi-cultural environment ...........................................................................6
Planning Theory .......................................................................................................................10
Summary of key issues arising from the literature ..................................................................11
Legislative Framework for Public Participation....................................................................12
Overview of the process of making a development plan in Ireland........................................12
Legislative requirements for participation in the development plan process in Ireland ....17
International convention on public participation....................................................................17
Irish Domestic legislation.........................................................................................................18
DoEHLG Guidelines on participation in the Development Plan in Ireland ..........................18
Preparation of an Issues Paper................................................................................................18
Inclusion of the New Irish ........................................................................................................19
The guidelines contain a section called Making Development Plans and the New Irish, which
is set out below:.......................................................................................................................19
Statement of Community Involvement ...................................................................................19
Commitments to public participation in other planning documents ..................................20
Legislative framework in England and Wales ......................................................................24
Planning Policy Statement 12 ..................................................................................................24
Statement of Community Involvement ...................................................................................25
Benchmarking Irish legislation and guidelines against the nature and purpose of public
participation and legislative standards in the UK ................................................................26
Current Practice ...................................................................................................................28
Introduction .............................................................................................................................28
Current practice in Irish City Councils......................................................................................29

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Current practice elsewhere .....................................................................................................32
Benchmarking of current practice against the nature and purpose of public participation
..............................................................................................................................................34
Comparison of involvement tools............................................................................................34
Depth and inclusiveness of participatory processes ...............................................................34
The New Irish – background and issues...............................................................................35
Statistical Profile of the Non-Irish Population .........................................................................35
Emerging Issues for the New Irish ...........................................................................................47
Summary: The New Irish and their needs................................................................................50
Chapter 3: Methodology.........................................................................................................51
Methodological Approach....................................................................................................51
Develop Concept Through Literature Review..........................................................................51
Research and Selection of Case Study Areas ...........................................................................51
Conduct Desktop Research on Case Study Areas and International Practice .........................51
Conduct Field Research on Case Study Areas..........................................................................52
Analysis, Conclusions and Recommendations.........................................................................52
Stakeholder Interviews ........................................................................................................53
The Planners.............................................................................................................................53
The Councillors.........................................................................................................................54
Community Representatives....................................................................................................55
Chapter 4: Results and Analysis..............................................................................................56
Stakeholder Interviews ........................................................................................................56
The Planners.............................................................................................................................56
The Councillors.........................................................................................................................58
Chapter 5: Conclusions and Recommendations.....................................................................62
Existing position regarding participation and the New Irish................................................62
Depth of the participation process in practice........................................................................62
Breadth of the participation process in practice.....................................................................62
Adequacy of the legislative framework ...................................................................................63
Adequacy of the guidelines......................................................................................................64
Budgetary constraints ..............................................................................................................64

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Satisfaction of the stakeholders ..............................................................................................64
Required steps to ensure adequate inclusion of the New Irish in the Development Plan
process .................................................................................................................................66
Stronger legislation and guidelines..........................................................................................66
More structured inclusion of Stakeholders .............................................................................66
Housing strategy process.........................................................................................................67
Funding.....................................................................................................................................67
Bibliography.............................................................................................................................69
Appendices..............................................................................................................................72
List of Interviewees ..............................................................................................................72
Interview Questions .............................................................................................................73
Planners....................................................................................................................................73
Councillors................................................................................................................................74
List of Tables
Table 1: Public Participation: Irish Legislation and Guidelines................................................28
Table 2: Comparison of Involvement Tools used in Participation Programmes .....................34
Table 3 Change in Persons Usually Resident in the State 2002-2006, classified by Nationality
..................................................................................................................................................37

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List of Maps
Map 1: Percentage of Non-Irish Nationals in the Electoral Divisions of Dublin City Council ..39
Map 2: Percent of population accounted for by those outside the State year previously .....40
Map 3: Percent of population accounted for by non-Irish......................................................41
Map 4: Percent of population accounted for by non-EU citizens ...........................................42
Map 5: Percent of population accounted for by new-EU citizens...........................................43
Map 6: Percent of Irish in each ward.......................................................................................44
Map 7: Absolute number of non-Irish in each ward...............................................................45
Map 8: Percent of dwellings privately rented, furnished........................................................46
List of Figures
Figure 1: Development Plan Timetable for Dublin City Council ..............................................17
List of Charts
Chart 1: Immigrants and Emigrants - Ireland 1996-2007 ........................................................35
Chart 2: Immigration 2003-2008 by Nationality......................................................................36

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Acknowledgements
I would like to thank all the Councillors and Community Representatives for their help
throughout the course of my research. I would especially like to thank the Planners in Dublin
City Council for taking time out of their busy schedules reviewing the Development Plan in
order to help me.
I would like to thank my parents, especially my Father, for his help and encouragement
along the way.
Most of all, I would like to thank my supervisor, Lorcan McDermott, for his invaluable
guidance throughout the process.

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Abstract
Non-nationals in Ireland increased by 87.1 percent between 2002 and 2006, and in Dublin
City, they now account for fifteen percent of the population, concentrated in inner areas. A
disproportionate number occupy private rented, furnished accommodation. Their presence
gives a new dimension to the development plan consultation process.
Literature on participation includes work by Arnstein, who defines levels of participation on
a scale ranging from manipulation, at the lowest, to citizen control, at the highest;
Sandercock, who stresses cultural inclusiveness; and Thompson, who focuses on the role of
the planner as a culturally aware campaigner for social justice. Elements of all of these are
embraced by communicative planning theory, focused on the interaction between planners
and the public.
Irish legislation provides little detail on the breadth and depth of consultation to be carried
out by local authorities. Though development plan guidelines suggest how local authorities
could involve groups who might not normally engage in the process, there is little evidence
of a comprehensive approach to this task in the review of the Dublin City Development Plan
– the chosen case study for this work.
Councillors believe that ethnic minority groups do not participate largely because of a lack
of awareness; mechanisms are in place to provide citizen control, but are not used
effectively. Community representatives indicated that many members of ethnic minority
communities do not integrate effectively into their local communities, and therefore are not

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involved in the planning process. Both Councillors and community representatives, highlight
language barriers and housing needs as key issues for immigrants.
Ethnic minorities should be consulted on issues of particular relevance, including housing.
The framework for such consultation should be given a legislative basis, and this should
include a requirement to draw up a Statement of Community Involvement. Dublin City
Council should provide information on important processes in languages other than English.

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Chapter 1: Introduction
Brooke (2003) notes that:
Economic, cultural and social diversity make for a vibrant city. Cities dependent on
a single economic sector are always going to be vulnerable during an economic
downturn. Diversifying its economic base must, therefore, be a top priority for any
city. Moreover, cities that embrace diversity in all its forms - including cultural and
ethnic diversity- seem better equipped to generate the creativity that cities need,
making themselves attractive to the skilled migrants that have been so integral to
the economic success of cities around the world (Brooke, 2003).
In the last two decades, Ireland has gone from being a relatively mono-ethnic culture to a
very diverse culture indeed. The number of foreign citizens in Ireland increased by 87.1
percent between 2002 and 2006 (NCCRI, 2008 p.25). For many Eastern Europeans, the
promise of jobs in the construction sector was what first drew them to Ireland, and although
the downturn in the economy has meant that employment has not been as easy to find, a
large number of Poles, Lithuanians and Latvians have remained in the country. With
immigrants in Dublin accounting for around one person in every ten, it is clear that they
have played, and will continue to play, an important role in the growth of Dublin’s and
Ireland’s economy.

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Because of Dublin’s new diversity, it is essential that provision is made for the proper
involvement of all members of society. If Dublin’s development is to be sustainable and lead
it to becoming a global city in the future, then the immigrant community needs to be
incorporated fully into all aspects of society.
If Ireland is to continue to attract people into the country, a culture of acceptance and
effective community participation will have to be built. This must be done to give people a
place where they feel comfortable living, and where they know that their opinion counts.
This dissertation will examine the effectiveness of the scope and depth of the process of
public consultation which takes place during development plan preparation, with a
particular focus on issues relating to ethnic minority groups. This will be done with the
following objectives in mind:
 Examine the methods used by Dublin City Council (DCC) during the consultation
stage of the development plan;
 Identify the issues relating to ethnic minority groups;
 Analyse the extent to which DCC addresses such issues; and
 Using experiences from elsewhere, make recommendations outlining more
effective means of incorporating ethnic minorities into the planning process.
To consult an individual or group of people is to ‘ask the advice or opinion of’ them
(Merriam-Webster, 2009). Simply consulting somebody does not guarantee that their

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opinion will be taken into account, whereas if a member of the public is to participate in a
process, it implies that they ‘have a part or share in something’ (Merriam-Webster, 2009).
Although it is a minor detail, using the term ‘public participation’ instead of ‘public
consultation’ conveys more of a sense of shared decision making.
The paper will seek to identify the difference between consultation and participation. It will
call on international experience of plan making, as well as focusing on the Irish experience.
It will compare and contrast different systems and demonstrate how different methods of
engaging the public can enhance community involvement.

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Chapter 2: Literature Review
Nature and Purpose of Public Participation
TERMINOLOGY
A number of different terms are used in academic literature, government legislation and
guidelines relating to the subject of public involvement in the planning process. These
include “consultation”, “participation”, “involvement” and “engagement”. In legislation in
Ireland, the term “public consultation” is used extensively. However, this word only
describes a process of opening up planning decisions to the public. It does not address the
issue of how effective this consultation is likely to be, or the processes that should be
followed. In contrast, writers on this subject, which are reviewed below, focus on the
effectiveness of the consultation process in terms of participation, engagement,
involvement and ultimately, citizen control.
LEVELS OFPARTICIPATION ANDTHEIR EFFECTIVENESSIN ENGAGINGTHE COMMUNITY
Arnstein (1969) discusses the idea of ‘citizen control’ with reference to process of public
consultation and participation. One of the main points Arnstein is trying to get across is the
shallowness of many forms of public participation.
There is a critical difference between going through the empty ritual of
participation and having the real power needed to affect the outcome of the
process (Arnstein, 1969 p.246).

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The point that Arnstein is trying to make is that a lot of participation is undertaken for the
sole purpose of being able to say that it has in fact happened. She uses the illustration of a
ladder to convey different levels of public participation:
 Citizen Control
 Delegated Power
 Partnership
 Placation
 Consultation
 Informing
 Therapy
 Manipulation
The two lowest rungs on the ladder, manipulation and therapy, represent nonparticipation.
The fourth rung on the ladder represents the act of consultation as part of the participation
process. While Arnstein (1969) believes that consultation, or ‘inviting citizens’ opinions’, can
be ‘…a legitimate step toward their full participation’ (1969 p.220), she makes the point that
if it is not combined with other forms of participation then there is no guarantee that their
opinions will be taken into account, and this is why the author refers to this level of
participation as ‘a sham’ (1969 p.220). According to Arnstein (1969), the only true forms of
public participation are the top three rungs on the ladder: Partnership, Delegated Power
and Citizen Control. These three levels of participation give power back to the citizens.

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PARTICIPATION IN AMULTI-CULTURALENVIRONMENT
Whilst Arnstein is principally concerned with the depth of participation, Leonie Sandercock
(2003) tackles the issue of the breadth of the process, or cultural inclusiveness. Sandercock
explores the subject of multicultural cities in the 21st century, a century that will be a
‘…struggle for equality and diversity’ (2003).
Sandercock (2003) states in Chapter 8 that planning is performed through story (2003 p.183).
The section explaining ‘how stories work’ gives us an example of a story that can be seen in
planning:
The conflict between settlers and indigenous peoples in New World countries over
land uses and land rights. For indigenous people there is a core story that is about
paradise lost, or an expulsion from paradise. For the settlers, the core story is the
pioneer’s tale of bravery and persistence in the face of adversity (Sandercock, 2003
p.184).
Although not all of this illustration is applicable to the planning process and the extent to
which ethnic minorities are consulted with, and provided for, during the making and
delivery of plans, the final point can certainly ring true in this case. The pioneer’s ‘adversity’
could easily be a lack of understanding of the planning system, or indeed it could simply be a
fight to be heard.
Sandercock explains that there are two types of stories in planning; the first being ‘story as
process’, and the second being ‘story being used to facilitate process’(2003 p.186). The

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public consultation process allows as many people as possible to tell their own story. If the
public consultation serves as a means of beginning a process, then it is likely that the stories
told will be used to establish common interests within the given community. If, however,
there is a problem that needs solving, the parties consulted will be those raising the issue,
and those with whom the issue has been raised. In this case, the common denominator has
already been established and the consultation is merely acting as a means of resolving the
issue. Sandercock goes on to explain the importance of allowing everyone the opportunity
to tell their own story (2003, p.186). Sandercock refers to Sarkissian, who undertook a very
thorough consultation process, not necessarily to hear about the issues in the community,
but to ensure that each member of the community felt like they had been listened to and
heard (Forester, 2000, cited in Sandercock, 2003 p.187).
In telling stories, parties tell who they are, what they care about, and what deeper
concerns they may have that underlie the issues at hand (Forester, 2000 p.166).
Sandercock (2003) also refers to a story that Forester tells about a mediator, Shirley
Solomon (p.187). It was Solomon’s job to bring together Native Americans with non-Natives
to discuss land disputes. In order to do this, Solomon had to find a ‘safe space’ where both
parties would feel comfortable telling their stories. Forester talks about how finding this
‘safe space’ was key to the process, because it gave people the confidence to speak about
how they really felt (2003 p.187).
Looking at Sandercock’s views on participation in the context of Arnstein’s ladder, it appears
that she does not actually examine the conditions necessary for true participation.

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Sandercock has created an axis of diversity which allows every social class and minority
group to share their stories and negotiate solutions to conflict. It is possible to move across
this horizontal axis, but the axis is also free to move up and down the ladder, removing any
guarantee that true participation has occurred.
Susan Thompson (2003) finds more of a balance between the two. She makes the point that
it is not just about what the public opinions are, but it is also down to the planner and his
interpretation of them, as well as his role as a ‘campaigner for social justice’ (Thompson,
2003 p.290). Thompson (2003) explores the response of some Australian planners to
cultural diversity. Her paper demonstrates some of the ways that cultural diversity is
addressed by what Thompson refers to as a ‘culturally inclusive planner’ (2003 p.276). A
‘culturally inclusive planner’ is ‘…one who positively and equitably responds to cultural
diversity’ (Thompson, 2003 p.276).
Thompson begins by explaining five of the main issues that have become points of
discussion in Australia:
 There is an exploration of the ways in which the voices of marginalized groups
have been, until recently, subjugated and ignored.
 There is an ongoing discussion about the need to incorporate a broader view
of socio-cultural processes in planning theory and practice.
 It is argued that modernist planning approaches fail to adequately deal with
the landscape of difference and that “culturally diverse cities and regions are a

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challenge to planning systems, policies and practices…[and consequently]
difference comes to be seen as a problem” (Sandercock, 2000, p. 15).
 There is a growing body of literature which focuses on the diverse nature of
contemporary stakeholders, advocating that their ‘difference’ must be
acknowledged, understood and accommodated in the planning process.
 The demands of cultural diversity for planning are filtering into the academy
forcing educators to engage with the challenge that this poses for them and
their students. (Thompson, 2003 p.276-277)
Thompson then goes on to describe how the local government has reacted to these issues,
and the overall issue of cultural diversity. The author suggests that local government has not
been overly enthusiastic about dealing with these issues. Instead, they have often remained
focused on ‘…the basic service delivery of ‘roads, rates and rubbish’’ (Dollery and Marshall
1997, cited in Thompson 2003 p.278). Australian local authorities are relatively underfunded
in comparison to those in the UK and the USA. They also have less power which makes it
more difficult to carry out a thorough public participation process. The paper reports
surveys that Thompson and colleagues carried out in local authorities around Australia. Case
studies were undertaken in the cities of Canterbury and Fairfield. These cities are among the
most ethnically diverse in the country. The study showed that it was possible to apply
policies and principles that ‘…address cultural diversity as part of mainstream planning
activity’ (Thompson, 2003 p.289).
Finally, the paper outlines the attributes required of a planner to be ‘culturally inclusive’:
 A reflective practitioner;

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 A culturally aware practitioner;
 An informed problem solver; and
 A campaigner for social justice (Thompson, 2003 p.289-291).
Thus the planner must not only be culturally aware (the horizontal axis), but also a
‘campaigner for social justice’ (Arnstein’s ladder).
Thompson concludes by stating:
The reality of the profound diversity that is contemporary Australia demands a
culturally aware and inclusive planning practice, as well as practitioners with the
capabilities above…This planner is able to support citizens in their struggle to
contribute to their local communities, partnering the professional in creating a
meaningful sense of belonging in spaces of difference and diversity (Thompson,
2003 p.291).
PLANNINGTHEORY
Communicative planning theory has a role to play in the consultation process. In essence,
this theory justifies a thorough consultation process. Planners spend much of their time
talking and interacting, and the communicative theory is focused on the interaction
between planners and the public. The aim of communicative planning is to provide
democratic participation and decision making. Contrasting this, advocates of the Foucauldan

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theory will claimthat a more strategic approach will provide more effective planning.
Alexander (2001), however, believes that a compromise needs to be found between the two
theories. ‘The recognition of interdependence reconciles these conflicting prescriptions,
showing why planning situations, involving interdependent actors, demand both’ (Alexander,
2001 p.311).
SUMMARY OFKEY ISSUESARISINGFROMTHE LITERATURE
The literature reviewed above raises a number of issues which can be put under the
categories of the process and the planner. The structure of the process of public
participation is one of two vital ingredients that must be right for the participation to be
effective. As has been outlined already, there needs to be a certain breadth and depth to
the process. It needs not only to offer effective citizen control, where the consultation is not
simply undertaken to fulfill requirements (tokenism); it also needs to include every section
of the community. Public participation cannot be deemed to be a voice for the community if
there are sections of the community which have been left out.
The second key ingredient is the planner. It is the job of the planner to work with the
process and ensure that it is implemented in the most effective way possible. This means
that planners must be aware of the diversity around them. The planner needs to gain
insights into all sections of the community, and arrive at innovative ideas to inform and
encourage the public to become involved.

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Legislative Framework for Public Participation
OVERVIEWOFTHE PROCESS OFMAKINGADEVELOPMENTPLAN IN IRELAND
The Planning and Development Act, 2000, consolidates The Local Government Planning and
Development Acts, 1963 to 1999, by repealing them and re-enacting them with
amendments. The 2000 Act is the backbone of planning in Ireland today. The Act sets out all
the legislative requirements of local authorities, from the obligation to make a development
plan, to such areas as general obligations with regard to safety at events.
Part II, chapter 1, of the 2000 Act, sets out the legislation concerning development plans.
Sections 9 and 10 deal with the obligation to make a development plan and the content of a
plan, as summarised below.
Section 9 – Obligation to make development plan.
This section requires planning authorities to make a development plan every six years.
Planning authorities must have regard to the development plans of adjoining authorities,
and in some cases may be required by the Minister to co-ordinate their respective plans.
9(6) – A development plan shall in so far as is practicable be consistent with such
national plans, policies or strategies as the Minister determines relate to proper
planning and sustainable development (Planning and Development Act, 2000).

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Section 10 – Content of development plans.
10(1) – A development plan shall set out an overall strategy for the proper planning
and sustainable development of the area of the development plan and shall consist
of a written statement and a plan or plans indicating the development objectives
for the area in question (Planning and Development Act, 2000).
A development plan must make objectives for the following areas:
 The zoning of land;
 The provision of infrastructure including transport, energy, communication facilities,
water supplies, waste recovery and disposal facilities;
 The conservation and protection of the environment;
 The integration of the planning and sustainable development with the social,
community and cultural requirements of the area and its population;
 The preservation of the character of the landscape and of architectural conservation
areas;
 The protection of structures of special architectural, historical, archaeological,
artistic, cultural, scientific, social or technical interest;
 The preservation of the character of Architectural Conservation Areas;
 The development and renewal of areas in need of regeneration;
 The provision of accommodation for travellers;
 The preservation, improvement and extension of recreational amenities;
 The control of establishments under the E.U. Major Accidents Directive; and
 The provision of community services including schools, crèches and other education
and childcare facilities (Planning and Development Act, 2000).

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Section 11 deals with the process of preparing a draft development plan, and Section 12
with making a development plan. These processes incorporate a specified programme of
consultation at a number of stages.
Section 11 – Preparation of draft development plan.
11(1) – Not later than 4 years after the making of a development plan, a planning
authority shall give notice of its intention to review its existing development plan
and to prepare a new development plan for its area (Planning and Development
Act, 2000).
Section 94 of the Act requires a housing strategy to be included in the development plan
‘…for the purpose of ensuring that the proper planning and sustainable development of the
area of the development plan provides for the housing of the existing and future population
of the area in the manner set out in the strategy’.
According to section 94(3), a housing strategy must take into account:
 The existing need and the likely future need for housing to which subsection (4)(a)
applies;
 The need to ensure that housing is available for persons who have different levels of
income;
 The need to ensure that a mixture of house types and sizes is developed to
reasonably match the requirements of the different categories of households, as

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may be determined by the planning authority, and including the special
requirements of elderly persons and persons with disabilities; and
 The need to counteract undue segregation in housing between persons of different
social backgrounds (Planning and Development Act, 2000).
Section 94(4)(a)(ii) states that a housing strategy must include an estimate of the amount of
affordable housing required in the area for the development plan period.
Regarding elements of the Act (2000) that relate to public participation, it is the
responsibility of the planning authority to publish a notice in ‘…one or more newspapers
circulating in the area to which the development plan relates’ stating the following:
a) ‘…the planning authority intends to review the existing development plan and to
prepare a new development plan.’
b) ‘submissions or observations…may be made in writing to the planning authority
within a specified period (which shall not be less than 8 weeks).’
c) ‘…the time during which and the place or places where any background papers or
draft proposals (if any) regarding the review of the existing plan and the preparation
of the new development plan may be inspected.’ (Planning and Development Act,
2000)
The Act (2000) then stipulates that as soon as is possible after giving the aforementioned
notice, ‘…a planning authority shall take whatever additional measures it considers
necessary to consult with the general public and other interested bodies’ (11(3)(a)). Section
11(3)(b) states that ‘…a planning authority shall hold public meetings and seek written

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submissions regarding all or any aspect of the proposed development plan and may invite
oral submissions to the made to the planning authority regarding the plan’ (italics added).
Section 11(4)(a) indicates that not later than sixteen weeks after giving notice of intention to
review the plan, a manager of a planning authority shall prepare a report on any
submissions or observations. The Elected Members then have ten weeks to issue directions
to a manager regarding the development plan. Following this, the manager then has twelve
weeks to complete the draft plan and submit it to the members. The Elected Members then
have eight weeks to amend the draft plan, if desired.
The draft plan goes on public display for ten weeks, and members of the public are again
permitted to make submissions regarding the plan during this period. The Manager again
writes a report on submissions made during this period, and circulates it to the Elected
Members.
At this stage, the Elected Members may accept or amend the draft plan and make the
Development Plan. If, however, the amendment is a material alteration of the draft, then
the proposed amendment must go on public display for a minimum of four weeks. The
Manager must circulate a report on any submissions to the Elected Members, who must
then, by resolution, make the development plan.
An example of this timetable in practice is set out overleaf in relation to Dublin City Council.

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Figure 1: Development Plan Timetable for Dublin City Council
Legislative requirements for participation in the development plan process in
Ireland
INTERNATIONALCONVENTIONON PUBLICPARTICIPATION
In 1998, the UNECE (United Nations Economic Commission for Europe) Convention on
Access to Information, Public Participation in Decision-Making and Access to Justice in
Environmental Matters (AARHUS Convention) was signed.
Article 7 of the convention states:
Each Party shall make the appropriate practical and/or other provisions for the
public to participate during the preparation of plans and programmes relating to
the environment, within a transparent and fair framework, having provided the
necessary information to the public (UNECE, 1998 p.11).

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Ireland is a signatory to this convention. However, it is the only signatory yet to ratify the
convention, and as a result, has yet to include the principles set out in the convention in
national legislation.
IRISHDOMESTICLEGISLATION
The elements of public participation within the development plan process have already
been summarised above. The opportunities for public participation may be summarised
thus:
 A minimum of eight weeks at the beginning of the review process;
 Ten weeks during the display of the draft plan; and
 A further four weeks if the draft plan is amended.
DoEHLG Guidelines on participation in the Development Plan in Ireland
PREPARATION OFAN ISSUESPAPER
Section 5 of the Development Plan Guidelines (2007) deals with the ‘Process and
Presentation’ of development plans. Early on in the section, an emphasis is put on involving
citizens in the plan making process who ‘…may not normally contribute or engage in the
process’ (DoEHLG, p.56). The guidelines encourage councils to ‘…consider innovative
methods to encourage as wide a public consultation as possible’ (p.56). The elected
members are urged to formulate an ‘Issues and Options Paper’ early on in the consultation
process, in order that focus can be put on specific issues (DoEHLG, 2007 p.56). Legislation
does not require the preparation of an ‘Issues Paper’ prior to the pre-draft public

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consultation, however the guidelines strongly recommend it at this stage ‘…as a means of
presenting key information on strategic planning and heritage issues and inviting public
submissions on differing policy approaches’ (p.56).
INCLUSION OFTHE NEWIRISH
THE GUIDELINES CONTAINA SECTIONCALLED MAKING DEVELOPMENT PLANS AND THE NEW IRISH,WHICHIS SET
OUT BELOW:
Ireland has experienced significant in-migration over the past decade and will
experience significant further in-migration into the future. Many cities and towns
across Ireland now contain significant migrant communities. The process of
consultation and engagement with local communities in the preparation of a
development plan should, at an early stage, identify any special arrangements
necessary to facilitate interaction with migrant communities including;
 Identification of immigrant community organisations from for example the list of
contacts in the register of the Immigrant Council of Ireland (www.immigrantcouncil.ie);
 Assessment of any special needs regarding translation of issues papers; and
 Holding special information evenings using interpreters. (DoEHLG, 2007 p.56)
STATEMENTOF COMMUNITY INVOLVEMENT
The guidelines point out that the Planning and Development Act 2000 gives ‘…considerable
discretion to planning authorities in selecting the type of public consultation most
appropriate to the circumstances of their area’ (DoEHLG, 2007 p.57). However, it states that
the inclusion of a ‘statement of community and stakeholder involvement’ in the

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development plans would be helpful (p.57). The inclusion of this document would be a
good indication of the level of consultation that was undertaken.
Commitments to public participation in other planning documents
Examination of other relevant planning documents shows that there is an emerging
commitment to the process of public consultation across a wide range of plan-making
processes.
The National Action Plan Against Racism (NPAR) (2005) came about as a result of the
commitments made by the Irish government at the United Nations World Conference
Against Racismin Durban, South Africa, in 2001. The impetus to develop the plan was later
reaffirmed in the Social Partnership Agreement 2003-2005. The whole concept of the plan
was to build a foundation on which a more inclusive and intercultural society might be built.
This means that the needs of every person should be taken into account during the design
stage, and not as an afterthought. The NPAR (2005) talks about how the concept of ‘one size
fits all’ is not applicable at all in these circumstances, and that in fact ‘one size does not fit
all’ (p.38).
The overall aimof the Plan is to provide strategic direction to combat racismand to
develop a more inclusive, intercultural society in Ireland based on a commitment to
inclusion by design, not as an add-on or afterthought and based on policies that
promote interaction, equality of opportunity, understanding and respect (NPAR,
2005 p.27).

21
Objective 5 of the plan (2005) is ‘…concerned with full participation in Irish society including
a focus on the political level, the policy level and the community level’ (p.35).
It was hoped that the outcomes of the plan (2005) would ‘…enhance the participation of
cultural and ethnic minorities in political processes’, including ‘policy consultative forums
and research’ and ‘community and local development’ (p.35). It was also anticipated that an
‘Intercultural Forum’ would be developed ‘…to give further consideration of issues related
to cultural diversity in Ireland’ (p.148).
Following on from the NPAR, the Dublin City Development Board published Towards
Integration – A City Framework, in order to:
 promote and strengthen understanding and implementation of the principles of the
National Action Plan Against Racismon a citywide basis;
 increase awareness of the value of diversity in a changing city; and
 progress the development of integration measures and enhance social cohesion
(DCDB, 2008 p.19).
The project set out five objectives:
 consult and liaise with the relevant actors regarding barriers, challenges and
approaches to promoting integration;
 facilitate a Steering Group on Integration that would address among other things,
antiracismand diversity strategies for the city;

22
 conduct research into city wide anti-racism and diversity actions in other
jurisdictions;
 draft an Integration Strategy; and
 embed the objectives contained in the Strategy in the service provision of relevant
stakeholders (DCDB, 2008, p.19).
Section four deals with consultation with members of new communities, describing focus
groups that were set up for the purpose of identifying ‘challenges to integration in Dublin
City’ (DCDB, 2008 p.37). Five focus groups, totaling around sixty people in all, were
organized through:
 Migrant Right Centre Ireland,
 Immigrant Council of Ireland,
 New Communities Partnership,
 Pavee Point; and
 Dublin City Council Office for Integration (p.15).
The groups were asked to discuss the following questions:
 What are the challenges to integration in Dublin and how they could be addressed?
 What are their experiences regarding access and participation related to any public
services, social and political life of the city, safety and security?
 What in their view are the essential elements of good practice in organizations?

23
 How can barriers in access and participation be addressed by Dublin City
Development Board?
 How should information on their experiences be gathered? (p.15)
In terms of participation in social and political life, it emerged that many immigrants
‘…experienced difficulty in engaging and understanding the political system’ (p.41). The
focus groups laid emphasis on the steps needing to be taken in order for the integration
framework to be a success. They felt that it was important to ‘develop inclusive decision-
making systems, train staff, develop integration policies and plans and review progress’
(p.42). If integration is to be attained, it cannot be done without the ‘…involvement of
people from new communities’ (p.42). Facilities such as meeting rooms need to be
accessible to all members of the community. Non-English speakers need to be provided with
information in a range of languages. The aimof the framework is to provide equal
opportunities for all to be involved in all aspects of their own community.
Local Agenda 21 (DoELG, 1995) also addresses the public consultation process. It
recommends that local authorities ‘…enter into a dialogue with its citizens, local
organizations and private enterprises and adopt a local ‘Agenda 21’’ (p.16 italics added).
Agenda 21 suggests using existing community organizations as a basis for consultation. A
variety of ways of including the public are also suggested, including setting up a forum to
allow discussion to take place between all groups (p.17), echoing the work of Sandercock.

24
Making Ireland’s Development Sustainable (DoELG, 2002) acknowledges that it is not
possible for the government to achieve its goals unaided. In order for objectives to be
achieved, all members of society must be fully informed and accepting of the measures
which will need to be put in place.
When the National Anti-Poverty Strategy was established, a committee was put in place to
meet twice a year to assess the effectiveness of the strategies plan for social inclusiveness.
This idea carried over to the National Action Plan for Social Inclusion 2007-2016. The plan
acknowledges that in order for it to be a success, it needs to be a flexible plan, open to an
ever changing customer base, and with constant updating of forms of public consultation.
Legislative framework in England and Wales
PLANNINGPOLICY STATEMENT12
The UK government signed up to the 1998 UNECE Convention on access to information,
public participation and decision making and access to justice in environmental matters, and
so committed itself to the declaration set out earlier in this chapter. In Planning Policy
Statement 12 (PPS12), issued in June 2008, the UK Government sets out a number of
principles which it expects planning authorities to adhere to during the preparation of ‘core
strategies’.
Involvement should be:
 appropriate to the level of planning;
 leading from the outset to a sense of ownership of local policy decisions;

25
 continuous – part of ongoing programme, not a one-off event, with clearly
articulated opportunities for continuing involvement;
 transparent and accessible – using methods appropriate to the communities
concerned; and
 planned – as an integral part of the process for making plans
(Communities and Local Govt, 2008 p.11).
STATEMENTOF COMMUNITY INVOLVEMENT
It is the responsibility of the Council to produce a Statement of Community Involvement
(SCI). The SCI should follow the principles above. PPS12 encourages councils to be very
strategic in their public participation, suggesting that they incorporate the community
consultation on planning issues with other community activities that might be taking place
(2008 p.11).
An SCI should:
• Explain clearly the process and methods for community involvement for different
types of local development documents and for the different stages of plan
preparation. This needs to include details of how the diverse sections of the
community are engaged, in particular those groups which have been
underrepresented in previous consultation exercises.
• Identify which umbrella organisations and community groups need be involved at
different stages of the planning process, with special consideration given to those
groups not normally involved.

26
• Explain the process and appropriate methods for effective community involvement
in the determination of planning applications and, where appropriate, refer to
Planning Performance Agreements.
• Include details of the LPAs approach to pre-application discussions.
• Include the LPAs approach to community involvement in planning obligations (S106
agreements).
• Include information on how the SCI will be monitored, evaluated and scrutinized at
the local level.
• Include details of where community groups can get more information on the
planning process, for example, from Planning Aid and other voluntary organisations.
• Identify how landowner and developer interests will be engaged.
(Communities and Local Govt, 2008 p.12)
Benchmarking Irish legislation and guidelines against the nature and purpose of
public participation and legislative standards in the UK
The work by Arnstein, Sandercock and Thompson, examined at the beginning of this chapter,
demonstrates the great depth and breadth that is necessary in order to achieve full and
meaningful public participation.
Irish legislation, however, allows authorities an almost free rein when it comes to involving
the public, and certainly does not give any precise indication as to how a local authority is to

27
go about it. DoEHLG guidelines do offer suggestions to councils as to how they might
become more inclusive, but as these guidelines are not mandatory, there is limited pressure
on the councils to undertake this important task with any vigour or innovation.
Requirements of Irish legislation and the recommendations of the guidelines are
summarized in Table 1 overleaf.
In short, there is in Ireland no guidance, still less compulsion, in terms of either Arnstein’s
vertical ladder of meaningful participation, or the horizontal axis defining inclusion of a
diversity of social groups, including ethnic minorities.
Compared to the legislative requirements of the UK system, therefore the Irish system is
seen to be lacking. Since the completion of an SCI became mandatory in the UK in 2004, the
requirements facing UK local authorities provide a much more thorough participation
process than those of the Irish system. Whilst the Irish guidelines do recommend the
completion of an SCI, the UK guidelines set out in PPS12 on SCIs provide the authorities with
a much more solid structure to work from.

28
Table 1: Public Participation: Irish Legislation and Guidelines
Irish Legislation Irish Guidelines
Writtensubmissions Considerinnovative methodstoencourage as
wide a publicconsultationaspossible
No provisionforlanguagesotherthanEnglish
or Irish
IssuesPaper
Must holdpublicmeetingsandseekwritten
submissions
Cater forspecial language needs/Interpreter
May invite oral submissions Statementof CommunityInvolvement
Must place notice innewspaper –onlyone
required
Identifyalistof Immigrantcommunity
organisations
Current Practice
INTRODUCTION
Because the 2000 Act leaves much to the discretion of the local authorities, it is inevitable
that public consultation processes will differ not only to those in other countries, but also
within Ireland itself. The minimum requirements of all councils in Ireland are the same, but
because the demographic profile will vary greatly even within cities, some councils feel the
need to take different steps during their own consultation period, based on the
circumstances at hand. In the following sections, the current practice of DCC, Galway City
Council and Haringey Borough Council are reviewed.

29
CURRENTPRACTICE IN IRISHCITY COUNCILS
Dublin City Council
As noted already, during the public consultation stage of a development plan, the planning
authority has certain legislative obligations. These obligations include giving notice to the
Minister, any prescribed authorities, any adjoining planning authorities, the Board, and any
other relevant regional authorities, commissioners, and development boards. The notice
must state that the planning authority plans to review the development plan, indicate
where and when the public can make submissions or observations, and where and when
any background papers may be inspected. Planning authorities are also required to hold
public meetings. They must invite written, and may invite oral, submissions regarding the
plan.
Aside from these obligations, the Act leaves much of the public consultation to the
discretion of the planning authorities, challenging them to ‘take whatever additional
measures it considers necessary to consult with the general public and other interested
bodies’ (Planning and Development Act, 2000 p.35).
At the beginning of the current review process (see Figure 1), DCC invited prescribed bodies,
community bodies, voluntary bodies and any major stakeholders to make submissions
outlining what they felt were the big issues which needed to be dealt with in the new
development plan. The planning authority then published an ‘Issues Paper’. DCC contacted
the appropriate community and voluntary bodies through the Community Forum
organisation. Around seven hundred groups are registered with the Community Forum. The

30
Council consider that it is up to the groups themselves to register with the Forum to ensure
they are informed.
The purpose of an ‘Issues Paper’ is to ‘…kick-start public debate on what broad planning and
development matters should be included in the new Plan’ (DCC, 2009 p.5). The ‘Issues Paper’
contains what Dublin City Council feels are the main development issues that Dublin is
facing. The issues set out in the paper were simply a guide, and the Council welcomed any
input from the public on any particular ‘big picture’ issues they think are significant.
The ‘Issues Paper’ was on public display for eight weeks and the Council stressed that during
this period, only ‘big picture’ issues were to be discussed (p.5). Much of the discussion of
these issues took place at the public meetings organised by DCC. The public meetings took
the form of Public Information Workshops, ten of which were held around the city. These
workshops gave the public a platform to discuss their feelings about the ‘big picture’ issues.
The meetings began with a presentation from DCC staff, after which the members of the
public were split up into smaller discussion groups. The groups then came back together and
had an opportunity to discuss the issues with the planners.
Regarding the inclusion of the New Irish, Chapter 4 of the ‘Issues Paper’ addresses
population and the housing strategy. The section on housing acknowledges the need for
DCC to improve the quality of housing and management in the City. It anticipates the
number of houses that need to be built each year of the development plan. It also states

31
that in order to encourage diversity in the City, new housing developments should be
designed to cater for all sectors, including ethnic groups (p.12).
Chapter 7 deals with community development. At the outset, this chapter indicates what is
necessary to achieve successful, sustainable neighbourhoods. The paper states that the
provision of key facilities such as schools, community centres and cultural spaces in strategic
locations can ‘…have significant positive impacts on social inclusion’ (p.18). The final part of
the chapter addresses integration. It points out that there has been a significant change in
the profile of the population since the last development plan was implemented. The
increase in ethnic populations has been rapid and they now account for 15 percent of the
City’s population.
Galway City Council
Galway City Council are also currently in the process of reviewing their development plan.
The public consultation undertaken by Galway City Council is more in depth than that of
Dublin. As in Dublin, prior to publishing the ‘Issues Paper’, letters were sent to the
appropriate groups - over two hundred in the case of Galway - inviting these groups to make
submissions. The Council does this with the help of the Community and Enterprise group,
who play a significant role in social inclusion in the city. Two notices are placed in locally
circulated newspapers. Radio advertisements are also used to inform the public about the
development plan, and how they can get involved. After publishing the ‘Issues Paper’,
information leaflets were distributed in English and Irish explaining how members of the
public can make observations and submissions. One day of each week of the consultation

32
period, there is a half day to give members of the public the opportunity to go into the
council offices and make verbal submissions. They dictate to a planner, who in turn reads it
back to them. GCC have yet to receive any submissions from ethnic minority groups.
However, during the pre-Issues Paper consultation, the need to encourage ethnic diversity
in sports was raised.
CURRENTPRACTICE ELSEWHERE
London Borough of Haringey
The backbone of public consultation in the UK is the Statement of Community Involvement.
Planning Authorities are required to produce an SCI as part of the development plan. ‘The
SCI is intended to help the Council ensure that community involvement and consultation is
an integral part of planning activities.’ (Haringey Council, 2008 p.1)
The London Borough of Haringey has a larger percentage of immigrants than any other
borough in London. Around 55% of Haringey’s population are from ethnic minority
communities. There are over 160 languages and dialects in the borough. Around 50% of the
population do not have access to the internet (Haringey Council, 2008 p.9).
.
Prior to consultation, the Council undertakes an awareness campaign. This simply lets
people know about the planning process and how they can become involved. It includes
open days, exhibitions at local events, visiting schools and colleges, and presentations to
groups at a neighbourhood level (p.11).

33
The Council recognises that there are groups that find it difficult to get involved in the
planning process and so will attempt to cater for them by:
 Producing clear, concise documents in plain English;
 Ensuring documents are available in different languages, Braille, audio-format and
large print;
 Ensuring meetings are held at times and places convenient to all;
 Working with agencies such as Youth Service as a means of involving children and
young people;
 Working with the council’s older people groups in the borough;
 Making a Portable Hearing Loop available at particular involvement events; and
 Making translators available for public meetings
(Haringey Council, 2008 p.12).
The SCI for Haringey sets out principles and methods for community involvement, including
involving the community at the earliest stage possible. For example, the Council plan to use
local Turkish and Greek radio stations to explain the planning process to the public, and
appeal for them to get involved. The Council also has plans to place advertisements on
billboards, buses and on the Tube. Planners in Haringey Council have observed a noticeable
improvement in public involvement since the SCI has been introduced.

34
Benchmarking of current practice against the nature and purpose of public
participation
COMPARISON OFINVOLVEMENTTOOLS
Table 2: Comparison of Involvement Tools used in Participation Programmes
PublicParticipation
Tools
DublinCity
Council
GalwayCity Haringey
Council
NewspaperNotice y y y
PublicMeetings y y y
Radio n y y
WebNotice y y y
NoticesinPublic
Libraries
y y y
Translatorat
Meetings
On request On request y
NewspaperNotice
(Non-English
newspapers)
n n n
WebDiscussion
Forum
y y y
Billboards n n y
Braille n n y
AudioBook n n y
Submissionsin
language otherthan
English
y y y
Oral Submissions On request y On request
DocumentsinPlain
English
n n y
SCI n n y
DEPTHAND INCLUSIVENESSOFPARTICIPATORY PROCESSES
As can be seen in Table 2, the depth of DCC’s consultation process is lacking somewhat in
comparison to that Haringey’s. It is inevitable, given the extraordinarily high percentage of
ethnic minorities in the borough of Haringey, that their consultation process will be wider
than most. However, it also demonstrates greater citizen control, particularly I relation to
the use of an SCI. The levels of public participation undertaken by Dublin and Galway are

35
less extensive than that of Haringey. This is a problem in and of itself, but especially so for
Dublin with its areas with high levels of ethnic minorities.
The completion of an SCI appears to have a big impact on the depth and breadth of a public
participation process. Because stakeholders are consulted before an SCI is published, it
allows them to have an input and give suggestions as to the best means of inviting
participation from all sections of the community. The completion of an SCI makes the
process very transparent, and allows the public to have more faith in the process.
The New Irish – background and issues
STATISTICAL PROFILE OFTHE NON-IRISHPOPULATION
Recent Patterns of immigration
Chart 1 shows the rapid rise in Immigration since 1997. Although emigration has remained
somewhat stable since 1991 at around 30,000, the number of immigrants climbed steeply to
reach a peak of in excess of 100,000 per annum in the last two years.
Chart 1: Immigrants and Emigrants - Ireland 1996-2007
Source: CSO Populationand Migration Estimates April2008
0.0
20.0
40.0
60.0
80.0
100.0
120.0
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
ThousandsofPersons
Year
Immigrants
Emigrants

36
Chart 2 below shows the composition of Immigrants by nationality. Of the total of 504,000
immigrants over the six year period, one third were from the EU 12 category – the 10
accession countries who joined the EU on 1 May 2004 (Cyprus, Czech Republic, Estonia,
Hungary, Latvia, Lithuania, Malta, Poland, Slovakia, Slovenia), and the two who joined on 1
January 2007 (Bulgaria and Romania). A further 20 per cent were from the rest of the world
excluding the EU and the USA.
Chart 2: Immigration 2003-2008 by Nationality
Source: CSO Population and Migration Estimates April 2008
Volume and composition of the non-Irish population in 2006
In 2006, there were 414,512 persons in Ireland of non-Irish citizenship. Of this total, some
112,548 had UK citizenship and may be excluded. Of the remaining 301,964, some 76,329
live in Dublin City – some 25.3% of the total. These account for 15.5 percent of the
population of the city – more than one person in seven. Indeed, excluding the USA element,
0.0
10.0
20.0
30.0
40.0
50.0
60.0
2003 2004 2005 2006 2007 2008
ThousandsofPersons
Year
Irish
UK
Rest of EU 15
EU 12
USA
Rest of world

37
it means that for 1 in 8 of the Dublin City population, English is not their mother tongue 1. In
2006, there were a total of nearly 70,000 residents of Black, Asian or mixed ethnic
background. In the period 2005-2006, the gross inward flow into Dublin from outside the
State was 121,739 persons. We do not know how many of these were non-Irish, but we can
examine the net changes by nationality for Dublin City and County between 2002 and 2006,
as set in Table 3.
Table 3 Change in Persons Usually Resident in the State 2002-2006, classified by Nationality
CountyofUsual
Residence
Total
TotalIrish
Irish
Irish-Other
UK
EU15excluding
IrelandandUK
EU15toEU25
accessionstates
OtherEuropean
Nationality
America(United
States)
Africa
Asia
Other
Nationalities
MuftiNationality
NoNationality
NotStated
2002 1,105,134 1,004,958 990,077 14,881 21,978 14,174 10,803 3,211 9,427 13,412 5,156 1,073 221 20,721
2006 1,162,831 994,015 981,760 12,255 20,932 20,831 38,161 13,007 3,674 17,105 28,084 8,102 1,037 454 17,429
Change 57,697 -10,943 -8,317 -2,626 -1,046 6,657 40,365 463 7,678 14,672 2,946 -36 233 -3,292
% Change 5.2 -1.1 -0.8 -17.6 -4.8 47.0 373.6 14.4 81.4 109.4 57.1 -3.4 105.4 -15.9
Sources: COP2002Vol 4,Table 36a, COP2006 Vol 4 Table35a
The percentage of the population of Dublin City and County accounted for by nationalities
other than Irish or UK, rose from 5.8% in 2002 to 10.9% in 2006 – increasing from 78,000 to
148,000, or by an average of some 17,500 per annum, at a time when the Irish and UK
nationalities were declining by some 3,000 per annum. This trend is likely to have been
more marked within the City of Dublin, though no data are available on this trend. We may
infer something from the fact that 23,865 persons resident in the City were living outside
1 Assumingthat South Asians do not have English as a mother tongue. Also,7,768 persons speak Irish daily.
Assumingthat only half regard Irish as their mother tongue, this suggests that there are20 times as many
persons in Dublin City who have a mother tongue other than English,than those who have Irish as their
mother tongue, yet there is no legislativeprovision for these residents.

38
the State a year earlier. This suggests that the City was taking a large share of the gross in-
migrants. Further, these in-migrant figures are concentrated in the wards with the highest
levels of non-nationals, with high correlation coefficient between them (r2 = 0.95).
Outlook
The outlook for the growth of these persons living in Dublin City is that the number would
grow from 76,329 in 2006 to 91,451 in 2016 and 96,269 in 2021 based on natural increase
alone and assuming fertility rates and mortality relates reflect that of the population as a
whole 2. The extent to which this will be added to by in-migration can only be speculated
upon.
Distribution of Non-Irish in Dublin City Wards
This section will use maps to illustrate the distribution of the immigrant population around
Dublin City.
Map 1 summarises the percentage of non-Irish nationals in the wards of Dublin City Council.
Maps 2 – 8 provide more detail of this pattern. Map 2 shows the percentage of population
in each ward, resident outside of Ireland a year previously. Many of the wards with the
highest of these percentages are also the wards with the highest percentages of non-Irish
nationalities (Map 3). The wards containing the highest percentages of non-EU nationals are
all close to the city centre (Map 4), whereas citizens of recent accession EU states are
2 Source: Adapted from CSO Regional Population and Labour Force Projections 2011-2026 Published:Dec 2008

39
slightly more dispersed (Map 5). In stark contrast to non-Irish nationals, the wards with the
highest percentage of Irish in them are on the outskirts of Dublin City, with the city centre
home to some of the lowest levels of Irish (Map 6). Map 7 illustrates the absolute numbers
of non-Irish nationals living in each ward. Once again, the highest numbers are in and
around the city centre. Map 8 shows the distribution of the private rented, furnished
accommodation in the city, with highest concentration almost exactly mirroring the
distribution of the non-Irish population.
Map 1: Percentage of non-Irish nationals in the Wards of Dublin City Council
Source: NCCRI,2008p.85

47
EMERGINGISSUES FOR THE NEWIRISH
As the numbers of the New Irish increase, and their clustering in particular areas of Dublin
becomes evident, a number of policy issues are emerging, not the least of which relates to
housing, and which therefore is of particular relevance to the planning process.
In Dublin today, economic factors play a leading role in the formation of ghettos. As
opposed to many earlier ghettos in the USA, modern day ghettos in Ireland are usually not
made up exclusively of one ethnic group. Housing is probably the biggest factor affecting the
settlement of ethnic minorities in Dublin. The National Consultative Committee on Racism
and Interculturalism (NCCRI, 2008) published a report on Ireland’s diverse culture and how
housing policy deals with it.
Between 2002 and 2006, the number of foreign citizens resident in the country increased by
87.1 percent (NCCRI, 2008 p.25). This has brought the number of non-nationals in Ireland up
to about the same level as most other European countries, but the change in Ireland has
happened in a much shorter timeframe. The NCCRI document explores both national and
international experience in terms of housing policies and practices pertaining to ethnic
minorities.
Research has shown that the housing experiences of ethnic minorities have generally been
worse than those of natives. These experiences were measured in terms of housing choice,
quality, affordability and location. This research has shown that these experiences are more
prevalent in the cases of newly arrived immigrants. Because housing is such an important

48
factor in Ireland’s culture, both socially and economically, ‘…inadequate housing impedes
their successful integration into the host community’ (NCCRI, 2008 p.32).
The paper (NCCRI, 2008) sets out some of the problems that minority groups face in terms
of housing. One of the main problems is the poor condition of much of the housing. In
Canada, Toronto specifically, ‘…24 percent of immigrants are in core need compared to 17
percent of non immigrants’ (p.32). Core housing need represents over-crowded housing, or
housing that is in poor condition. The number of immigrants in core need rises to 42 percent
for recently arrived immigrants (p.32). The problem is further accentuated by the fact that
much of the poorer quality housing is clustered together, and that quite often members of
minority groups like to live close to each other. The forming of these ghettos makes it very
difficult for successful integration into the host city.
In terms of the quality of accommodation, housing in Ireland is generally considered to be of
high quality. An ESRI report on the subject showed that those purchasing housing are the
most likely to be most satisfied with their accommodation, with the percentage of those
satisfied at 96 percent, whereas those occupying private rented and local authority rented
are the least likely to be satisfied, with percentages at 83 and 74, respectively (NCCRI, 2008
p.57).
The document (NCCRI, 2008) goes on to give a statistical profile of ethnic minorities and
housing in Ireland. Much of the information in this section is taken from the census. Some
significant figures on type of accommodation and quality of accommodation are included in
this section. For example, in Ireland, only thirteen percent of Asians, and 16 percent of

49
Africans live in detached houses, as opposed to forty-eight percent of Irish, UK and US
nationals. When it comes to living in flats, only 6 percent of the total population of the State
is represented, but the percentages among Asians and Africans are as high as 38 percent
and 35 percent respectively. In terms of private rented accommodation, which is where
much of the poor management occurs, figures rise to 56.1 percent for Africans in this
category, as opposed to 7.2 percent for the Irish. Property being bought from a local
authority is highest among the Irish at 3.7 percent. This figure falls to 1.6 percent for UK
nationals, and below 1 percent for all other non-Irish nationals. However, when it comes to
renting local authority housing the levels are fairly similar, with the Africans and the Asians
at 7.4 and 9.2 percent, respectively. (p.62)
In Dublin, the city centre has the highest percentage of non-Irish. The high number of
immigrants in Ireland, in particular Dublin, leads to number of challenges for local
authorities. The NCCRI (2008) document addresses these issues and offers some
recommendations which they feel need to be put in place to aid in the successful
integration of minority communities. Some of the recommendations for central government
are:
 Develop an intercultural approach to integration and housing policy in Ireland,
which means avoiding a ‘one cap fits all approach’;
 Develop a comprehensive proactive intercultural policy to maximize the potential
housing and neighbourhood policy to contribute to the integration process; and

50
 Build an intercultural dimension into housing strategy, including the following
elements:
o Ensuring immigrants have access to affordable home ownership schemes and
social housing schemes and are not overly concentrated in the private rented
sector;
o Housing should form a key part of an overall local integration strategy;
o Effective monitoring and enforcement of regulation in the private rented
sector;
o Housing integration policies should be focused on the main urban areas with
the most minority communities;
o Housing Forum should consider the inclusion of the NCCRI; and
o Asylum seeker specific accommodation should be included in an overall
intercultural approach to housing and neighbourhood planning.
(NCCRI, 2008)
SUMMARY:THE NEWIRISHANDTHEIR NEEDS
Maps 2-8 demonstrate that most of the New Irish are clustered in the City Centre. A large
number of the New Irish are living in private rented accommodation, and this is an issue
which clearly needs to be addressed. It is evident that a more thorough consultation process,
which specifically addresses housing, needs to be developed. This consultation should have
a definite focus on the New Irish, ensuring that there is not such heavy reliance on the
private rented sector. This needs to take place on a city wide basis, but also at local plan
level.

51
Chapter 3: Methodology
Methodological Approach
DEVELOP CONCEPTTHROUGHLITERATUREREVIEW
The literature review portion of this dissertation has been dealt with earlier in the paper.
The importance of the literature review was to gather information on what research had
already been done on the topic area. A thorough literature review can be helpful in
pinpointing certain topics in the area which are of great significance.
RESEARCHAND SELECTION OF CASE STUDY AREAS
A case study is ‘an intensive analysis of an individual unit (as a person or community)
stressing developmental factors in relation to environment.’ (Merriam-Webster)
‘The essence of a case study, the central tendency among all types of case study, is
that it tries to illuminate a decision or set of decisions: why they were taken, how
they were implemented, and with what result’ (Yin, 2002).
Case studies are a very thorough research strategy, and provide more of an insight into a
topic area than perhaps a survey might. A case study was very appropriate for this
dissertation because of the nature of the research. Dublin City Council and the current
review of the development plan was chosen.
CONDUCTDESKTOP RESEARCHON CASE STUDY AREAS AND INTERNATIONAL PRACTICE
Before conducting field research on the study areas, it is necessary to gather basic
information about the areas in order to allow the field research to be efficient and effective

52
as possible. The desktop research for this dissertation was mainly concerned with gathering
statistical data relating to the case study areas. The Central Statistics Office was the main
source of this information. The desktop research also consisted of contacting planners from
around Ireland, and also London.
CONDUCTFIELDRESEARCHON CASE STUDY AREAS
The field research accounted for the majority of the research on the case study areas. For
this dissertation the research took the form of interviews. The advantage of an interview is
that the interviewee has the opportunity to elaborate on their answers, and offer an
individual opinion. Interviews are a more personal form of information gathering than
questionnaires, and this was important for some of the more social aspects of this paper.
For this reason, it was necessary to gather information from multiple sources, using
different stakeholders in the community. Community leaders, councillors, and planners
were interviewed.
ANALYSIS,CONCLUSIONSAND RECOMMENDATIONS
This section will break down the results of the research that has been undertaken. After
analysis of the desktop and field research has been completed, it will be possible to draw
conclusions about the effectiveness of planning policies operating in different locations. The
desktop and field research will make it possible to compare the tools which are employed by
different authorities in trying to achieve their goal of meaningful public participation. It will
then be possible to make recommendations to local authorities about how they might be

53
able to improve their levels of public participation by adopting methods used by authorities
elsewhere.
Stakeholder Interviews
A total of seventeen semi-structured interviews were undertaken, including six planners, six
councillors and five community representatives.
THE PLANNERS
The following Planners were interviewed:
 Fidelma Fahey – Dublin City Council
 Shane Dineen – Assistant Planner for the Development Plan, Dublin City Council
 Ruari Mahoney – Dublin City Council
 Ann Bogan – Cork City Council
 Caroline Phelan – Galway City Council
 Clodagh O’Donnell – Borough of Haringey Council, London
The interviews held with the planners were not as in depth as those held with other
stakeholders, because the much of the information being sought was readily available in
published documents.
The matters raised with the Planners were as follows:
 The steps the local authority takes during the public consultation process;
 The preparation of a Statement of Community Involvement;

54
 The extent of the contribution from ethnic minority groups; and
 The facilities in place to accommodate ethnic minority groups.
THE COUNCILLORS
The following Councillors were interviewed:
 Councillor Aodhan O Rhiordain
 Councillor Mary O’Shea
 Councillor Mary Freehill
 Councillor Mary Fitzpatrick
 Councillor Oisin Quinn
 Councillor Michael Donnelly
Some of the topics raised with the councillors were:
 Whether certain groups were targeted more so than others during the public
consultation process;
 Whether DCC does enough to try and include all sectors of the community in the
development plan process;
 If the planning process provides effective citizen control; and
 Whether ethnic minority groups in their respective constituencies have a good
understanding of the planning process.

55
COMMUNITY REPRESENTATIVES
The following community representatives were interviewed:
 Slawek Norberczack – Irish Polish Society
 Vasile Ros – Former President of the Romanian Society of Ireland
 Pastor Thywill Bankole – The Redeemed Christian Church of God
 Rev. Dr. Cedric Chau – Chinese Gospel Church of Dublin
 Sr. Breege Keenan – Vincentian Refugee Centre
The list includes representatives from the Polish, Romanian, African and Chinese
communities.
Some of the topics raised with the representatives were:
 Whether their organisation had ever been invited by DCC to contribute to the
Development Plan;
 Whether members of their communities are aware of the Development Plan
process, and the opportunity to contribute;
 The extent to which members of their communities are integrated into their
communities; and
 If there are any specific issues relating to ethnic minorities which need to be
addressed in both the Development Plan process and the Development Plan itself.

56
Chapter 4: Results and Analysis
Stakeholder Interviews
THE PLANNERS
The Planners were asked about the steps that their local authority takes during the
consultation stages of a development plan. These steps have been set out earlier in the
paper.
In terms of including ethnic minorities at the public consultation stage, there were a number
of bodies which DCC contacted, including The Immigrant Council of Ireland. They were
informed that the plan was being reviewed, and were provided with all the relevant
information.
DCC set up a blog on boards.ie and invited discussion from the public regarding the matters
raised in the ‘Issues Paper’. DCC is only required to publish material in English and Irish, and
there was no material printed in any other language. Translators do not attend the public
meetings, but a DCC planner indicated that if there were a need for translation, a separate
meeting would be arranged with this facility. The same situation would apply for an illiterate
person. In the case of a written submission in a language other than English, a translator
would be arranged.

57
A Statement of Community Involvement in the same form as the UK SCIs is not envisaged.
However, the Manager’s report will summarise all the issues raised and offer an opinion on
them. This report will be made available to the public on dublincity.ie when it is published.
It is difficult, if not impossible, to tell whether or not there have been any written
submissions from non-Irish, because respondents are not required to divulge their
nationality in the submission. However, to date, there have been no written submissions
from organisations representing an ethnic minority group. Nor have there been any
submissions in languages other than English.
One difference between the Irish planners’ experiences and the London planner’s
experience relates to finance. Local authorities in Ireland often struggle to find the finances
to fund projects, and this limits the steps that are able to be taken during the process. This
becomes clear on examination of the lengths to which Councils like Haringey are prepared
to go. Most Irish local authorities do not have the means to spend money on billboards, for
example.
At the same time, money may not be spent on advertisements of this type simply because
the local authority feels that it will not have a significant impact on the levels of
participation. There is a feeling among some of the planners that many members of society,
not just ethnic minorities, are not interested in getting involved, and that even if they were
made aware of it, very few would bother to attend meetings or make submissions. The Irish
planners believe that it is a very select group of people who choose to participate, and that

58
quite often this group is made up of people who have lived in the area for most of their lives.
All of the planners noted that at many of the public meetings, the number of people in
attendance was small - sometimes as low as four persons.
THE COUNCILLORS
Three of the Councillors work in the North of the city, and three of them work in the South
of the city.
The fist issue that was raised with the Councillors was whether or not DCC targeted some
groups more than others during the consultation process. All of the councillors felt that DCC
did not favour one group over another, but rather just contacted established groups and
organisations in the communities.
When asked whether DCC did enough to inform the public about the development plan and
how they could get involved, four of the councillors said that they did not do enough. One
councillor believed that they did do enough. The sixth councillor stated that he believed
much of the responsibility for making the public aware of the plans and processes falls on
the shoulders of the councillors. “Councillors are the stepping stone between planners and
the public.” The four who believed that DCC did not do enough said that it was simply a
matter of more effective advertisement.

59
All six of the councillors believe that the majority of residents in ethnic minority groups are
not aware of the Dublin City Development Plan, or that it is being reviewed. This, in turn,
means that the same people will also not be aware that they have the opportunity to get
involved in the planning process. However, the councillors all agreed that the problem is not
limited to ethnic minority groups. Many Irish people are not aware of the Development Plan
and how to get involved.
The councillors were then asked if they believe that the public consultation in place provides
any effective citizen control, or is simply complying with the minimal legal requirements.
Five of the councillors agreed that the mechanisms in place provide effective citizen control.
The fact that immigrants are allowed to vote in local elections after six months in the
country gives them a good opportunity to elect a candidate who they feel will represent
their needs. They also feel that the public are given ample time to inspect the plan and
make submissions. The sixth councillor believes that the planners ultimately have too much
power, and so there cannot be effective citizen control in the development plan process.
The final matter raised with the councillors was whether they were aware of any issues in
their constituency that relate directly to ethnic minorities. Four of the six felt that the
biggest issue was housing. New immigrants are most at risk when it comes to housing. High
prices force immigrants into what are often overcrowded and rundown flats. Although no
councillor saw it as a major issue, all six agreed that language could provide a potential
barrier to becoming more involved in the community.

60
In general, the councillors believed that the biggest problem facing DCC in trying to engage
the community in the development plan process was actually making them aware of such
plans. They acknowledged that although complete involvement would not be possible, an
increase in the awareness and understanding of the planning process would encourage
better participation.
COMMUNITY REPRESENTATIVES
First, the community representatives were asked whether they had ever been contacted by
DCC in relation to a development plan. Four of the five had not been contacted at any stage
of a development plan. The Vincentian Refugee Centre had been invited to attend public
meetings during the initial public consultation period.
Secondly they were asked whether they felt their clients or members of their congregation
were aware that there is a development plan for Dublin City, and that it was being reviewed.
Again, four out of five said that they believed the majority of the communities they
represent are not aware of the development plan, or that it is being reviewed at this time.
Pastor Thywill Bankole believed that many of the members of his congregation, which is
made up mostly of Africans, are aware of the planning process and development plans, but
that they are not aware of the opportunity to contribute.
They were then asked the extent to which their clients and congregation were integrated
into their local communities. Slawek Norberczack believes that the Polish in Dublin are very
well integrated into their communities. According to Pastor Chau, the Chinese in Dublin

61
tend not to make the effort to become involved with the community, because many do not
consider Ireland to be their home. Vasile Ros believes that the Romanians in Dublin are also
well integrated into their communities, although they do have a tendency to cluster. Sr.
Breenan believes that many of the clients she comes in contact with at her centre are more
concerned with finding a job and place to live than the social and political efforts of
becoming an active member of a community. Pastor Bankole stated that the members of his
congregation have found it difficult to integrate themselves into their local communities. A
major reason for this is because of the questionable legality of many of the congregations’
status in the country. They do not feel safe in the country, and believe that getting involved
in the community is futile because of the uncertainty of their length of stay here.
All five interviewees said that there is widespread knowledge of the fact that voting in local
elections is possible. They said that this was down to canvassing by councillors, and the
promotional posters in multiple languages. Mr. Norberczack, Pastor Bankole, and Sr.
Breenan all ran campaigns within their organisations raising awareness of voting rights.
The final issue raised with the representatives was the nature of problems facing newly
arriving immigrants. The two biggest problems are the language barrier and housing. Many
of those arriving do not qualify for local authority housing, and those who do, face a long
waiting list. As a result of this, many end up clustered in areas of poorly managed,
dilapidated accommodation.

62
Chapter 5: Conclusions and Recommendations
Existing position regarding participation and the New Irish
Depth of the participation process in practice
It is clear that despite the recommendations of the DoEHLG guidelines, Dublin still lacks
some of the tools for consultation that are in place elsewhere, including an SCI and non-
English literature. Using the medium of radio to spread awareness of the development plan
process, as is done in both Haringey and Galway, is an ideal way to reach large sections of
the community. DCC does use the internet as a means of consultation, but the example of
Haringey shows us that there are large sections of communities who do not have access to
the internet, and even if it was accessible, in order for the user to deliberately navigate to
the appropriate site, prior knowledge of such a site would have to have been gained
through some other medium. It seems that the consultation process has skipped a level.
Having facilities such as translators is of little value if the general consultation process does
not reach that level of involvement. The first level of the process is missing, and that level is
simply increasing public awareness that development plans even exist. If the public do not
know that a plan exists, then how are they supposed to know about the existence of a
platform to participate?
BREADTHOF THE PARTICIPATION PROCESSIN PRACTICE
The breadth of participation becomes more complicated when immigrants are involved. For
some immigrants, the legality of their status in the country is questionable. For this reason,
they may try to avoid identification. For other immigrants, the idea of becoming actively
involved in a community seems pointless. For these reasons, DCC finds it hard to contact

63
certain groups. An invitation for contributions from community and voluntary groups
excludes those with no organised representation. Having said this, there are some groups,
such as the Vincentian Refugee Centre, who appear to be an ideal candidate for
consultation based on their work with immigrants - and yet they were not contacted. The
Immigrant Council of Ireland is consulted, but an ideal way of widening the scope would be
to take advantage of organisations closer to the people, such as ethnic churches for example.
ADEQUACY OF THE LEGISLATIVE FRAMEWORK
It is evident that Irish legislation leaves too much to the discretion of the local authorities.
There is little evidence that the recommendations of the NCCRI, and of the DoEHLG
guidelines, form a central plank of the consultation procedures being adopted for
development plan review in Dublin. If proper integration of the New Irish is a policy aim of
government, then steps to ensure targeted participation of these groups must include
requirements based on legislation. The legislative requirements do give the public the
opportunity to have their say, but once again it comes down to getting to the stage of public
meetings. The requirement to simply place a notice in a newspaper is clearly not an
effective enough method of informing the public. To ensure that local authorities go to
further lengths than this to make it known to the public, the requirement to do so must be
compulsory.

64
ADEQUACY OF THE GUIDELINES
The guidelines set out a good template for local authorities to follow for the development
plan process. They are, however, lacking in some areas. They provide some examples of the
ways in which local authorities can attempt to gain input from the public, but a more
detailed set of ideas would make it easier for local authorities, and encourage them to go
the extra mile to include a hard to reach groups. Recommendations in this regard are set
out later in this chapter.
BUDGETARY CONSTRAINTS
The current position in DCC is that no specific financial provision is made for the following
areas of the consultation process:
 Translation of Issues Paper into languages other than English and Irish.
 Translators at public meetings.
 Radio advertisements languages other than English.
SATISFACTION OFTHE STAKEHOLDERS
The general consensus of the councillors was that DCC could do more to make the public
aware of the development plan, but that at the same time much of the responsibility lies on
the shoulders of the councillors themselves. All but one of the councillors believe that the
public meetings and opportunities to submit are an adequate means to allow for effective
citizen control. However, the fact that there is little knowledge among the public about
these processes, and the low numbers of in attendance at these meetings, mean that this
system has never really been tested.

65
In terms of the satisfaction of the ethnic minority groups themselves, Rev. Chau believes
that although most of the Chinese community do not get involved, they do not feel
aggrieved about it, and most of the time they choose not to get involved. This is probably
true of other ethnic groups. Many non-Irish hold no opinion of the consultation process,
either because they are not aware of it, or because they have more pressing issues on their
minds.
The matter that planners find most frustrating is the level of attendance at many public
meetings. This often leads to the belief that doing more to try to involve the public would be
a waste of time and effort, because of the lack of enthusiasm from the public to become
involved. For the local authorities, the belief is that the mechanisms are in place, but they
can only do so much to involve the public, after which the onus is on the public to involve
themselves. The experience of Haringey, however, where a noticeable increase in the level
of public participation was observed, following the adoption of an SCI, and concerted efforts
to communicate in languages other than English, again suggests that the public’s willingness
to participate in Dublin has not yet been adequately tested.

66
Required steps to ensure adequate inclusion of the New Irish in the Development
Plan process
STRONGER LEGISLATIONANDGUIDELINES
In order for the consultation process in Ireland to become more effective, there is a need to
add to the legislation that is already in place. Rather than simply requiring that the local
authority take whatever measures it feels necessary, there needs to be detailed legislation,
in the form of regulations, outlining exactly steps that need to be taken to involve the public
in the development plan process. The development plan guidelines also need to become
more detailed. A mandatory SCI, similar to that in the UK, would allow the public the
opportunity to decide how they would like to be consulted in the future, and this in turn
would provide a good template for future public participation.
MORE STRUCTUREDINCLUSION OFSTAKEHOLDERS
Full public participation will not be possible without an effective means of including every
section of the community. Meetings which are attended by planners, councillors and the
public are ideal. Having a planner present allows questions to be answered there and then.
The difficulty is organising these meetings to suit all of the stakeholders. The biggest change
that is needed is in relation to the initial informing of the public. A thorough awareness
campaign explaining how the planning process works, and how and why the public should
become involved, would be a big step in increasing the levels of public participation in
general. When focused on ethnic minorities through appropriate use of languages other
than English, and channelled through community networks such as nationality associations
and churches, such awareness campaigns will serve to empower groups currently left on the
margin of city planning. This has particular relevance to the issue of housing, set out below.

67
An awareness campaign for voter registration was run, with posters in multiple languages,
but to date there has been no equivalent campaign for the Development Plan review. The
ethnic minority community was a driving force in Ireland’s economy during the boom years,
and it is imperative that their needs are taken in account, because they are in effect a new
generation of Irish, the New Irish.
HOUSINGSTRATEGY PROCESS
Preparation of a new housing strategy under section 94 of the Planning and Development
Act 2000 is now an intrinsic element of the Development Plan review process. Housing
issues are of particular relevance to the immigrant community, and most especially policies
relating to the private rented housing sector, as well as the provision of social and
affordable housing. Section 94(3)(d) requires that the housing strategy shall take into
account the need to counteract undue segregation (Planning and Development Act, 2000).
The reliance of the immigrant community on private rented housing, and their
concentration in particular wards underscores the need for a focused process of
participation of such groups in these areas during the preparation of the housing strategy as
part of the Development Plan review.
FUNDING
The scale of the overall effort required for the Development Plan review in a city the size of
Dublin, means that the necessary resources to give voice to sections of society normally not
heard may often be overlooked. If monies are ring-fenced for these tasks, there is a greater
likelihood of success. Funding is specifically required for the provision of written material at

68
all stages of the review process in languages other than English (including Polish, Latvian,
Lithuanian, Chinese, Romanian and Tagalog). These languages alone represent the mother
tongue of 45,000 residents of Dublin City and Suburbs (CSO, 2008).3 Resources will also be
required for the translation of submissions made by these groups in languages other than
English. The ethnic groups themselves should be able to provide interpretation at public
meetings called for their benefit, at no additional cost to Dublin City Council.
3 This figure relates to non-Irish,thus excludingIrish citizens with these mother tongues.

Public Participation in the Development Plan Process Effectiveness in Reaching the New Irish Population in Dublin

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