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What Are Valid Planning Grounds?

A submission supporting or objecting to an application must be based on planning considerations, not personal likes, dislikes or grievances. This guide sets out the difference.

Information, not advice. Much of the law described here is new and has not yet been tested in the courts or by An Coimisiún Pleanála, and it could be affected by challenge, amendment or further regulation. This page gives our reading of it. For a definitive answer on a particular property or application, engage with the relevant planning authority.
General guidance. This explains, in plain terms, the kinds of matters a planning authority can weigh. Whether a particular point carries weight depends on the site, the development plan and the facts. It's general information, not formal advice.

Anyone can make a submission on a planning application (within 5 weeks of it being lodged, for a €20 fee). But the authority can only take account of material planning considerations, so a well-aimed submission is likely to be more effective than a heartfelt one.

What Counts, Material Planning Considerations

  • ✓ National and regional guidelines and ministerial directives.
  • ✓ The policies and objectives of the development plan.
  • ✓ The policies and objectives of any local plan.
  • ✓ Local considerations, site density, parking provision, traffic hazards, overlooking, and effects on residential amenity.
  • ✓ Public health.
  • ✓ Environmental, amenity and shopping impacts.
  • ✓ Other material planning matters.

What Generally Doesn't Count

The authority is not deciding a dispute between neighbours. It typically cannot give weight to:

  • ✕ Personal likes and dislikes, or objections to the applicant themselves.
  • ✕ Effects on the value of a neighbouring property.
  • ✕ Private legal matters, boundaries, rights of way, land ownership or covenants.
  • ✕ Business competition (that a development would compete with the objector's own).
Keep it factual. A submission is a public document. Allegations against a person or organisation could be defamatory, argue the planning, not the personalities.

Turning a Concern into a Ground

Most genuine worries can be re-framed as a valid planning point. "It'll tower over us" becomes overlooking, overshadowing and loss of residential amenity, measured against the development plan's standards. "The road can't take it" becomes traffic hazard and inadequate access. That translation, from grievance to grounded planning argument, anchored in the development plan, is what tends to make a submission land.

Once Part 4 commences. For an application lodged on or after the day Part 4 commences, a submission to the planning authority is made under the Planning and Development Act 2024 and must be on the prescribed form, accompanied by a declaration that it is not made to delay the development or to obtain a payment (s.588; draft regulations, Forms No. 5 and 6). The draft form describes its rules as mandatory and states that a submission that breaks them is invalid: over 1,000 words it must open with a summary of not more than 300 words; it may not contain hyperlinks, embedded images or web addresses; it may not attach documents without the copyright holder's permission; and it must be confined to the relevant facts about the development. A submission received after the five weeks is returned with the fee (s.86(4)). The form states that the submission is published on the authority's website within five working days. On our reading, the grounds set out on this page are unchanged; what changes is how they must be presented. See making a submission once Part 4 commences.
Sources: Citizens Information, commenting on a planning application · Office of the Planning Regulator

A Public Information Service

These guides and tools are published as a public service and are kept to the primary legislation. They are not a free advice line, and individual queries are not answered by email or phone. For a general question about a particular property, the planning authority's planning department and Citizens Information are the starting points, and a declaration under section 5 is the formal answer. Where a matter needs professional work, the practice takes instructions on a fee basis: from developers, landowners, investors and public bodies, and from private clients, for example on retention or regularisation of unauthorised development or a change of use, and occasionally a one-off house, subject to capacity.

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