Across several new developments Homely has partnered with builders on, I’ve made a point of reading every planning observation lodged. In hindsight, this was probably not the best use of my time. But it has been surprisingly educational, and even a little cathartic.
After enough of them, you start to notice the same themes, arguments and even phrases appearing consistently. There’s a familiar cast of characters, a predictable running order and an odd, recurring format. Nobody seems to have written a rulebook for this and yet somehow everyone has read it.
A few things I’ve learned along the way:
1. Nobody objects any more. They observe.
The word “objection” has disappeared from Irish planning. I saw it in maybe 1 of 100 submissions. What we get instead are observations, submissions, representations and concerns. And almost all of them start the same way: the writer fully understands the housing crisis and, of course, supports residential development on appropriately zoned land.
Then comes the paragraph break.
Then comes the “However”.
And then comes a thousand-plus words about ridge heights.
The “However” is where the observation really begins. Everything before it is essentially a formality. The planner knows it, the developer knows it, and I suspect the person writing it knows it too. It is the planning equivalent of “with all due respect”. Everyone knows what is coming next.
2. The longer ones are a genre of their own.
Most observations I read were relatively snappy. But every so often I came across one that had clearly become a side project in itself. The longest I’ve read ran to 20 pages. It had headings, subheadings, numbered sections, carefully formatted bullet points and a level of structure that looked very like the first version of something you might ask ChatGPT to produce (*sigh*).
The galling part is that some of the longer ones can also be very good. If someone has legitimately spent that much time on an observation, there’s a chance they’ve read every drawing, report and appendix that came with the application.
On more than one occasion, an observer has picked up something buried in one of the consultants’ reports that nobody on the developer’s side had even noticed. Having your planning application quality checked — for free — by someone whose back garden happens to face the site is a fairly humbling experience.
3. Nothing causes more fear than the rat run.
Nothing seems to worry observers quite like the prospect of a new rat run. Not the houses themselves, the density, or the height. It is the idea that the cunning commuter will discover that this new development has created a shortcut.
This hypothetical driver is remarkably determined. They know every road in the area, have an encyclopaedic knowledge of all local traffic lights, and are apparently willing to crawl through a housing estate twice a day if it saves them a few minutes on the main road.
The beauty of the rat run as a planning argument is that it doesn’t actually have to exist. It just has to be theoretically possible at some point in the future. Which also makes it remarkably difficult to prove that it won’t.
4. A cul-de-sac is not just a road layout. It’s a contract.
I hadn’t fully appreciated the strength of feeling around cul-de-sacs until I started reading these observations. People bought their homes on a road that went nowhere, and there is a very strong view that it should continue to go nowhere, forever.
A pedestrian connection is one thing. The killer is the possibility that, one day, it might become a road for cars. Even where no road is proposed, observers want certainty that there will never, ever, under any circumstances be one. The traditional Irish answer to this is, of course, bollards. We place enormous faith in bollards.
Then there are e-scooters and scramblers, which are a newer and very real concern. But surely the answer is to regulate and enforce their use properly, rather than stop creating useful pedestrian links to schools, shops and bus stops. Otherwise we end up designing estates around the small number who might misuse them. The tail starts wagging the dog.
5. Sunlight was included in the purchase price.
This one I have more sympathy with. If you’ve bought a house with a sunny back garden and someone proposes building behind you, of course you’re going to care about what happens to the light. I would too. I’ve now read far more about sunlight, daylight, shadow paths and the movement of the sun across back gardens than I ever expected to.
But there can sometimes be a disconnect between the language used and what is actually being proposed. In the vast majority of these applications, we’re talking about houses being built beside other houses, not 40-storey skyscrapers appearing at the end of someone’s garden.
There has to be a reasonable balance. Existing homeowners are entitled to expect that new development won’t completely undermine the enjoyment of their homes. But buying a house beside zoned residential land probably can’t come with a guarantee that the evening sun will hit exactly the same patch of lawn until the end of time.
Sunlight matters. But so does the fact that we need to build homes — and yes, in most cases, that means building houses beside other houses.
6. Everyone is a land surveyor now.
“It’s too big” seems to be gone, and I sort of miss it. Now you’re more likely to get an observation quoting finished floor levels to two decimal places, referencing the exact drawing and revision, and pointing you to the relevant paragraph of the development plan.
Some of this is undoubtedly AI assisted, and that isn’t necessarily a bad thing. Detailed submissions used to require a planning consultant, solicitor, or an engineer living three doors down. AI is levelling that playing field, and “you used ChatGPT” doesn’t make a good point any less valid.
The flip side is the noise. You can usually spot the submission where the entire planning file has been uploaded and ChatGPT asked to find every possible reason the development shouldn’t go ahead. Suddenly there are fifteen pages covering everything from biodiversity and drainage to overlooking, density and half the county development plan. Some points will be legitimate; others are clearly there because the prompt said “find everything”. I have some hope that most planners can tell the difference.
Either way, it’s strange to see a small fortune spent producing a planning application, only for someone to download the lot from the planning website and interrogate it for €9.99 (a month).
7. The reliable cast always shows up.
A few things seem to appear in almost every planning file: rats, property values and wildlife.
Clear a site and the rats will apparently move next door. Build houses and surrounding property values will fall. And the ordinary-looking field turns out to be home to bats, badgers, foxes, geese and owls.
The wildlife point, though, is often worth listening to. Someone who has looked out at the same field every day for fifteen years may well know more about what lives there than a consultant who visited once on a wet Tuesday in March. A dated photograph of a protected species is pretty compelling evidence.
But it does leave us with the awkward question: if we can’t build houses on fields zoned for housing, where exactly are we going to build them?
8. Nobody believes the density wasn’t the builder’s idea.
One of the most common accusations is that the builder has tried to cram as many homes onto the site as physically possible to make more money.
The odd thing is that the reality is often the other way around.
On many sites, density isn’t really a number the builder gets to choose. National planning policy sets minimum densities depending on the location, so the scheme has to be designed around those requirements — whether the builder particularly likes them or not.
And commercially, more units doesn’t automatically mean more profit. Give a builder the same site without the density requirement and in plenty of situations, they would probably build fewer and larger houses with bigger gardens. They’re generally simpler and cheaper to build. Apartments and duplexes are often the expensive part, and outside the city markets the selling price can struggle to justify the cost of building them. It’s one of the reasons there are plenty of apartment permissions around the country that have never actually turned into apartments (and why our government have reduced the VAT on them!).
The problem is that “the builder would probably make more money building fewer homes” sounds exactly like something a builder would say. So nobody believes it.
9. What people write isn’t always what they actually think.
This is probably the main thing I’d pass on to anyone in the industry, and it’s why I now try to call people on the phone. In writing, it’s separation distances, traffic, precedent and development plan objectives. Structured, referenced and very formal.
On the phone, within about ninety seconds, it can become: “houses these days are made of cardboard”, and “the builder is being greedy”.
Neither point appears in the submission because neither carries any planning weight. So the real frustration gets translated into the language the planning system understands, and something quite human — but maybe wrong — ends up reading like the legal submission that it has morphed into.
On the cardboard point, the evidence runs the other way. Modern building regulations and energy standards mean new homes generally perform far better and are better built than the houses built in the 80s and 90s.
I’ve yet to successfully make that point to someone while they’re standing in a block house built in the 80s and 90s.
10. Most of it doesn’t really matter, and thank God.
Nobody really tells you this, but the word count matters far less than you’d think. Good planners will focus on the things they can actually assess: separation distances, levels and overlooking, access and sightlines, drainage, and anything that points to a specific standard or policy.
The rats, property values, construction noise, “not in keeping with the area” and the general sense that things were better before will usually be recorded, but they rarely decide an application.
So writing more doesn’t necessarily get you more. Four thousand words making the same technical point as four hundred words carry exactly the same weight. Which means a lot of wasted afternoons for the less AI-savvy observers, and a lot of wasted tokens and data-centre capacity for the more tech-savvy ones.
Either way, the good planner will still look for the same handful of points that actually matter.
So, what have I actually learned?
I still feel that planning observations are worth reading. Some are excellent, some spot things the professional team has missed. And some throw absolutely everything at stopping houses being built on land that has been zoned for housing for years, in the middle of a housing crisis.
But the biggest lesson is that what’s written down often isn’t the real concern. Behind the references to sightlines, density and development plans, there’s usually something much simpler: what is this going to mean for my home, my road and the place I live?
That human side is worth remembering throughout the planning process. Equally, in most cases the developer is trying to deliver the housing that the development plan already envisages for that land. The challenge for planners, developers and communities is finding the right balance between legitimate local concerns and actually getting those homes built.
For my part, I’ve learned to read the observations. And then, where I can, pick up the phone.
