Submission 2001

National Spatial Strategy

Introduction

Comhairle is the national support agency responsible for the provision of information, advice and advocacy services to members of the public on social services. We are pleased to contribute to the consultation process being conducted in respect of the National Spatial Strategy (NSS).

We recognise that the NSS is mainly concerned with economic development and balanced regional development. While we recognise the central importance of these concerns, we confine our submission to those areas with which we and our customers are mainly concerned. Our contribution is, therefore, concerned with the role of the NSS in the future development of public social services, in the integration, co-ordination, accessibility (geographic, physical and intellectual access) and social inclusiveness of those services, in the implementation structures which may be required if the NSS is to be effective and the involvement of citizens in those structures.

This submission sets out the role of Comhairle with emphasis on those aspects which concern the NSS. We then make some general observations on the NSS consultation paper and, finally, attempt to answer the questions posed in that paper.

Comhairle

Comhairle was set up under the Comhairle Act, 2000 and was established in June 2000. It took over the functions of the National Social Service Board and relevant functions of the National Rehabilitation Board. Comhairle has a number of functions, of which the following are the most relevant in the context of the National Spatial Strategy:

• to support the provision of or, where the Board considers it appropriate, to provide directly independent information, advice and advocacy services so as to ensure that individuals have access to accurate, comprehensive and clear information relating to social services and are referred to the relevant services,
• to assist and support individuals, in particular those with disabilities, in identifying and understanding their needs and options and in accessing their entitlements to social services,
• to promote greater accessibility, co-ordination and public awareness of social services and of information, advice and advocacy services provided in relation to such services whether by a statutory body or a voluntary body,
• to support, promote and develop the provision of information on the effectiveness of current social policy and services and to highlight issues which are of concern to users of those services,

Comhairle has 5 regional offices and nine local offices throughout the country.

The Comhairle activity which is most relevant to the NSS is the development and support of independent information services throughout the country. Comhairle supports and funds a network of 85 Citizens Information Centres (CICs). CICs are independent voluntary bodies whose primary function is to provide a free, confidential and impartial information service to members of the public on the full range of citizens rights and social services. The 35 key CICs provide a full time service in county towns and urban areas while local CICs provide a more limited service.

The regional offices of Comhairle are involved in the development and support of CICs within their area. Development plans are agreed between Comhairle and each key CIC. These plans are implemented by the CIC with support and monitoring by Comhairle staff.

It is the policy of Comhairle in line with its strategy (following the previous strategy of the National Social Service Board) to develop and support Key CICs on a countywide and urban basis to deliver a range of information, advice and advocacy services and support local CICs and outreach services within their catchment areas. Local CICs are also supported by Comhairle at present but the policy is to promote the integration of local CICs into Key CICs, thus moving away from direct support of local CICs. In effect, although we do not use the precise words, Key CICs are gateways or hubs for information provision.

The regional staff of Comhairle are involved with local government and local development agencies including City/County Development Boards in promoting greater co-ordination of services at local level and the identification of gaps in service provision.

Among the values espoused by Comhairle in its first Strategy statement are:

• Access to information is a basic right of all individuals.
• Each individual should have equal access to state services.
• Information, advice and advocacy should be of a high quality, customer focused and developed in consultation with customers.

We believe that the basic principle of equal access to high quality, customer focused services, developed in consultation with customers is applicable to all state services and this submission is informed by that belief.

National Spatial Strategy Consultation Paper

The consultation paper on the National Spatial Strategy “Indications For The Way Ahead” is largely concerned with the requirements of economic development and the, to date, unbalanced spatial distribution of economic progress.

Comhairle does not propose to comment on the proposals in so far as they affect economic development and national competitiveness. We accept that economic growth and balanced regional development are essential for the development of high quality integrated, co-ordinated and accessible social services. However, as can be seen from the problems with housing and health services, economic growth does not guarantee the development of services, much less the development of integrated and accessible services.

We also consider that the development of such services contributes to economic growth and balanced regional development. So, plans and policies for economic growth must take account of, and operate in tandem with, the development of services.

Earlier documents in the NSS consultation process placed more emphasis on social inclusion and enhancing the quality of life. The latest consultation paper does not indicate how the NSS will meet these objectives. It also does not clarify what is meant by enhancing the quality of life - other than increased economic activity and consequent wealth. We regard enhancing the quality of life as including improved access to services such as housing, transport, education, health and social services generally.

The central gateway concept proposed in the consultation document is one which has already been put forward, under different titles, in proposals as varied as the 1960's Buchanan report on regional development and the Fitzgerald Report on General Hospital Services. As is clear from Comhairle's own organisation of services, we find that concept of service delivery useful.

Clearly, specialist services such as higher education and cancer treatment facilities cannot be available in every town and must be concentrated in certain centres. However, it is vitally important that there be easy and equitable access to these services from all parts of the country.

The selection of the gateway centres is likely to be contentious because people living in other places may regard the concept as a downgrading for their areas. The use of the term a “hierarchy of centres” is likely to reinforce that view. The concept is much more likely to get general acceptance if people can be assured that access to the gateways will not be a problem.

Public services can only be delivered to all our citizens if they are co-ordinated and integrated. Neither national nor regional organisations can deliver an equitable, accessible service without adequate transport, telecommunications and other infrastructural arrangements.

The NSS and other development plans

The NSS is being drawn up at a time when a range of other development plans are being drawn up or implemented. The consultation document recognises that consistency between the NSS, regional planning guidelines and city/county development plans is required. It also states that the NSS is to guide government departments and agencies in formulating and implementing policies which have a strong spatial dimension.

There are very few government policies that do not have a strong spatial dimension. We would argue that consistency is also required with, for example, the forthcoming Health Strategy, with plans for education developments, with the White Paper on Rural Development, with agricultural policy, with transport policy, tourism policy, policy on decentralisation of state services and with property taxation policies.

We are concerned that the NSS is being developed after much of the work on other economic and social plans has been completed. The National Development Plan is already being implemented. The Integrated Action Plans under the urban and rural development schemes are being implemented. The Regional Planning Guidelines are already in force in the Greater Dublin Area and are being developed in the other regions. The City/county development plans are due for completion at around the same time as the NSS is to be completed. We are not clear on how it is proposed to ensure the necessary consistency or, where there is no consistency, on which plan is to have priority - we address this issue further below under Question 4.

The consultation paper does not address the issues of incentives for particular developments - for example, the seaside towns and rural incentive tax schemes. We consider that these should be addressed in the strategy itself.

It also does not address concerns raised in plans issued by other development bodies. For example, the Western Development Commission plan strongly argues that the policy of privatisation of essential services operates against the interests of the regions. We are not expressing any opinion on the validity of this view but it is an issue that should be addressed in the NSS.

Similarly, we consider that the government's decentralisation policy should be addressed in the strategy. There is currently an absence of clear criteria for decisions about decentralisation. The choice of gateway centres should inform and direct the government's decentralisation plans. There is no doubt that the location of a government department or agency contributes to economic and social development in that area.

Questions posed in consultation paper

Question 1 - Do the guiding vision and principles set out in section 1 represent a basis for balanced spatial development to which you can subscribe?

Yes. We consider that an additional principle of equal and equitable geographic, physical and intellectual access to high quality public services should be added. Integrated service measures (such as the local authority initiatives) and mainstreaming of delivery of services should inform the strategy. The strategy should also reflect the potential of e-government to impact on access and social inclusion issues.

The strategy should elaborate on what is meant by a high quality of life - it could be spelt out to clarify a concern for high quality health, education, leisure and social services, including personal social services.

Question 2 - Does viewing Ireland in terms of Functional Areas, as set out in this paper, each of which has different characteristics and within each of which different issues arise, provide a useful explanation for the basis on which the country functions spatially?

As a consequence, is it a valid proposition that different kinds of responses will be needed in different areas to achieve more balanced regional development?

The consultation paper does not clarify how the functional areas were designated. They may well provide an explanation for the basis on which the country functions spatially but the more relevant questions may be

• do they provide a basis for the future economic and social development of the country and
• are they appropriate areas for service delivery

We do not have the answer to these questions but we would raise the following issues:

All of the functional areas outlined have at least one large town, although some have several such towns which may engage in competition for the role of gateway. All have at least one third level educational establishment but a number of them do not have a major hospital. One - North Border - has an economically thriving town with an Institute of Technology but it has a disproportionately large number of older people and of medical card holders and no major hospital. It has no rail connection at all, the air connections are poor and there is a problem with its access to electricity. It is difficult to see how it can be described as a functional area from the point of view of public services.

We are concerned that the number of local and regional development bodies leads to problems with the delivery of services and with citizens' ability to distinguish who does what. At present, the following organisations are involved in making policy and/or delivery services at a regional and local level in policy areas which would be affected by the NSS:

• 15 Government departments, many of which have local offices but all of which have a centralised decision making system.
• 34 city or county councils
• 80 towns including borough corporations, urban district councils and town commissioners
• 8 regional authorities
• 2 regional assemblies.
• Strategic Policy Committees of local authorities
• City/County Development Boards
• County enterprise boards
• Area partnerships
• Leader groups
• RAPID areas
• Regional Tourism Authorities
• Teagasc
• National Roads Authority
• Údarás na Gaeltachta
• Shannon Development
• Dublin Docklands Development Authority (DDDA)
• Temple Bar Properties
• Western Development Commission
• Ballymun Regeneration Co. Ltd.
• Vocational Education Committees
• Health Boards
• FAS
• An Bord Pleanala
• Environmental Protection Agency

There is also a range of bodies with a very specific remit in a particular area of services e.g. while health boards have responsibility for the local delivery of health services, decisions on hospitals, the level of consultant service etc is made by the Minister for Health and/or Comhairle na n-Ospideal.

We recognise that city/county development boards should have the effect of co-ordinating the activities of many of these organisations but they cannot, for example, override the statutory responsibilities of agencies such as An Bord Pleanala, EPA or the NRA.

We are concerned that the creation of the concept of “functional areas” will further complicate the already overly complex organisational arrangements. This will make it very difficult for citizens, not only to access services, but to know where responsibility for services lies.

We also doubt that policies such as rural development policies, energy policy, tourism development policy can all be dealt with in the spatial context described.

Question 3 - Will the development of Functional Areas be best served by a spatial planning approach that seeks to energise them by focusing on the strengths of a limited number of places in a way which, at the same time, allows all parts of Functional Areas to realise their potential?

As already indicated, we find the gateway concept useful but are not convinced about the functional areas. The development of gateways must be accompanied by the development of accessible services for all citizens. Balanced regional development must ensure balance within as well as between regions.

Question 4 - Is the range of indications for finalising the form and detail of the National Spatial Strategy appropriate and comprehensive?

As already indicated, we consider that there is a problem in that the timing of the completion of the NSS is not optimal from the point of view of the existence and implementation of other relevant plans.

We consider that a legislative basis is essential if the NSS is to be effective. The planning system is highly legalistic and cannot be affected by the NSS unless there is legislation to require that the NSS be taken into account when the planning authorities are making decisions on what constitutes “proper planning and development”.

If the NSS is simply to be government policy and not have any statutory backing, it cannot succeed. In order to succeed, it will have to have some legal standing with respect to local authorities, ABP, health boards etc.