Settlement Boundaries
The omission of specific 'zoning maps' as had been included in the 2014 - 2020 Development Plan is a concern and will in my opinion compromise the Planning Authority in exercising it's development management control function. In that context the following Guidelines, 'Sustainable Residential Development in Urban Areas - Guidelines for Planning Authorities' are referred to in the Draft Plan. Chapter 6 - Small Town and Villages of those Guidelines is of particular interest where it states in para 6.3 (a) that "development in smaller towns and villages must be plan led" and that "for towns and villages under 2000 in population, planning authorities can prepare either an LAP or prepare such supplementary local development frameworks as is appropriate and necessary to guide any new development proposals". Further guidance is given in para 6.5 where it states "The County Development Plan should indicate where such frameworks will be prepared over the lifetime of the plan". Given that many of the smaller towns and villages scheduled in the Draft Plan already have had LAPs prepared and which it seems reasonable to assume remain relevant to the respective locations and communities, it would seem prudent, in the absence of any alternative objective development management control measures for "development in smaller towns and villages " as scheduled in the Draft Plan or commitments to the preparation of "supplementary local development frameworks", to at least retain the Zoning Maps as the Settlement Boundaries subject, if necessary, to a review in consultation with the respective local communities during the lifetime of the 2021 - 2027 Development Plan. One other point worth noting in relation to the matter of smaller towns and villages is the distinction between "rural" and "urban" given in the NPF (2018) and the Regional Spatial and Economic Strategy for the Southern Region as categorised by the CSO. All of the smaller towns and villages scheduled in the Draft Plan should be categorised as rural.