I wish to make a submission on Proposed Variation No. 3 of the Kildare County Development Plan 2023–2029, which seeks to give effect to Ministerial Guidelines issued under Section 28 of the Planning and Development Act 2000 (as amended).

While the proposed variation introduces a number of important updates to ensure consistency with national policy, it is noted that no reference is made to acceptable or indicative densities for rural housing development.

The absence of any density guidance presents a significant risk that rural housing policies will be applied inconsistently across the county. Without defined parameters, assessments will continue to rely heavily on subjective interpretation by individual planners, leading to uncertainty for applicants and inconsistent decision-making outcomes.

As demonstrated in the empirical analysis included in my own planning submission (under file ref 201501), a review of rural housing permissions granted by Kildare County Council between 2017 and 2020 identified extreme variation in densities across rural areas—from approximately 1.27 to 341 houses per square kilometre. My own site, at 4.77 houses per km², was below the density of over 650 previously granted applications, indicating a clear lack of a consistent benchmark for what constitutes “appropriate” rural density.

Although the policies formerly referenced as RH9 and RH10 under the previous County Development Plan (2017–2023) are no longer in force, the same underlying issue remains: in the absence of a stated density framework, decision-making lacks measurable guidance. This results in policy application that varies by area, by planner, and over time—contrary to the objectives of transparency, equity, and proper planning and sustainable development.

Accordingly, I respectfully request that Kildare County Council:

Introduce an indicative range of acceptable rural housing densities within the forthcoming plan variation or its supporting text, reflective of existing settlement patterns and environmental sensitivities;
Provide explanatory guidance on how rural density should be considered in the assessment of planning applications, ensuring a consistent approach across all rural policy zones; and
Commit to a data-driven monitoring framework, drawing on Department of Housing and Ordnance Survey datasets, to track rural housing trends and inform future policy reviews.

Including clear density guidance would strengthen the Development Plan by improving consistency, reducing uncertainty for applicants, and aligning decision-making with the principles of fairness and transparency required under the Planning and Development Act.

Thank you for the opportunity to make this submission. I trust the Council will consider the importance of defining rural housing densities to ensure equitable, evidence-based application of rural housing policy throughout County Kildare.

Regards,

Fergus Mahon

Proposed Variation No. 3 of the Kildare County Development Plan 2023-2029 (as varied) to give effect to Ministerial Guidelines published in accordance with Section 28 of the Planning and Development Act 2000 (as amended) - Submissions

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