HomeMy WebLinkAbout2560502 - F.I. Received Doc. - Plannng Statement
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PLANNING STATEMENT
In respect of
PERMISSION FOR RESIDENTIAL DEVELOPMENT
EMYVALE
PLANNING REFERENCE 25/60502
Prepared by
GENESIS PLANNING CONSULT AN TS
On behalf of
GEDA CONSTRUCTON LTD
MAY 2026RECEIVED: 09/07/2026
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TABLE OF CONTENTS PAGE NO
1 INTRODUCTION 3
1.1 Overview 3
1.2 Site location and context 4
1.3 Developer Background 5
2 HOUSING DEMAND AND POPULATION GROWTH 6
3 SUPPORT FOR SOCIAL HOUSING 12
4 PLANNING POLICY CONTEXT 13
4.1 Overview 13
4.2 National Planning Framework 13
4.3 Housing For All 15
4.4 RSES 16
4.5 Sustainable Rural Housing Guidelines 16
4.5 Monaghan County Development Plan 2025-2031 17
5 FURTHER INFORMATION RESPONSE 18
5.1 Overview 18
5.2 Matter One: Existing Context of the Village 18
5.3 Matter Two: Demand for the proposal 21
5.4 Matter Three: Sequential Development 22
5.5 Matter Four: Permission 2460235 23
5.6 Other Matters 24
6 SUMMARY & CONCLUSION 26
RECEIVED: 09/07/2026
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1 INTRODUCTION
1.1 Overview
1.1.1 This planning statement is in support of an application seeking permission for a residential
development under planning reference 25/60502 on subject lands at Scarnageeragh, Emyvale.
1.1.2 This statement sets out how the proposed development will be consistent with relevant
planning policies which include the NPF, Housing For All, Section 28 guidelines ‘Sustainable
Rural Housing: Guidelines for Planning Authorities’ and the pro visions of the Monaghan
County Development Plan 2025-2031.
1.1.3 Also matters raised as Further Information point 1 are addressed, with separate enclosures by
the project team addressing points 2-8 also addressed.
1.1.4 Further Information point one states:
‘It is noted the development seeks to rely on provisions under section 15.8.10 of the Monaghan
County Development Plan 2025-2031 which pertains to social housing only. Consequently, the
proposed development can only be justified at a location outside the settlement envelope if it is
clearly demonstrated that there is demand for social housing. On the basis of the information
provided, and noting an extant permission for residential development within the village
boundary (Ref. No. 24/60235), the Planning Authority are not satisfied that (a) there is a need
for the level of social housing proposed, and (b) the proposal contributes to sequential
development. The applicant is advised to provide robust justification for the proposed
development in accordance with Section 15.8.10 of the Development Plan.’
1.1.5 In response this statement addresses matters raised both in terms of policy context and
analysis of lands within the village to demonstrate how it is proper planning for the proposal to
be granted permission.
1.1.6 On review of matters raised we say material considerations support the proposal in terms of:
• Housing demand;
• Settlement context;
• Support for Social Housing;
• Policy Context;
• Other Matters: Precedent.
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1.2 Site Location and context
1.2.1 The subject lands are positioned in the core of the village, albeit not within the settlement limit
as defined under the Monaghan County Development Plan.
1.2.2 The lands are in a residential area and comprise a partly brownfield and undeveloped greenfield
parcel of lands.
Figure 1 Site location and context
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1.3 Developer background
1.3.1 We take this opportunity to highlight the prospective applicant GEDA Construction are industry
leading developers in the Country.
1.3.2 As per the company website:
‘First established in 1982, we now operate throughout Ireland and The East Midlands in
England.
We’ve built a huge legacy of Civil, Commercial and Building projects throughout these regions
and continue to maintain a strong reputation in the spaces we’ve transformed.’
1.3.3 Also relevant the applicant have delivered several housing schemes for Monaghan County
Council in recent years which include:
-Plas Lorcan, Contract with MCC 43 units social housing 2020
-Coil Darach, Castleblayney 30 units 2021
-Knockcarrick, Annyalla 40 units 2023
-Sli Na Coille Contract 21 units for MCC April 26
-Sli Lorcan Contract 49 units for MCC du delivery Jun 26
1.3.4 We refer to the applicant’s website for more background information:
www.geda.co.uk
1.3.5 This is relevant in that there is a clear intent to develop the proposed scheme and achieve
socio-economic betterment for Emyvale with the housing units proposed.
1.3.6 Also relevant is the provision of the Section 28 Guidelines ‘NPF Implementation: Housing
Growth Requirements’ which set out a need for:
‘a particular focus on the likelihood that the lands identified for residential development within
the plan will come forward for development within the remaining period of the plan.’
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2 HOUSING DEMAND & POPULATION GROWTH
2.1 As all Stakeholders are aware Ireland faces a critical need for increased housing due to a
combination of economic growth, population expansion and a legacy of underinvestment in
housing construction.
2.2 An adequate supply of social housing units is vital to ensure that people who are unable to
afford housing from their own resources can avail of appropriate housing. As the country
recovered from the economic downturn in the 2010s it’s population surged, particularly in urban
areas where job opportunities are concentrated.
2.3 We highlight this demographic shift has significantly outstripped the available housing supply,
leading to soaring property prices and rental costs, making housing unaffordable for many,
especially younger generations and lower-income households.
2.4 To set the context the housing shortage has severe adverse social implications, contributing to
increased homelessness, overcrowding and poorer health outcomes while also hampering
economic growth by deterring potential investment.
2.5 To address this issue, substantial efforts are required to accelerate the number of housing units
being built and ensure that housing remains both affordable and accessible to all segments of
the population. As a means of supporting those unable to secure housing through their own
resources, the Government has identified the provision of social housing as a key solution.
2.6 Indeed we highlight for the Planning Authority the Report of The Housing Commission,
published in 2024, estimates a deficit of between 212,500 and 256,000 homes in Ireland as of
the Census 2022.
2.7 The report states the following in relation to Ireland’s social housing deficit:
“After a decade of pent-up demand caused by chronic undersupply, a step-change in building
output is essential to address the housing deficit and to meet ongoing requirements…This
requires exceptional and radical measures to deliver a substantial amount of housing in the
shortest time practicable… There should be a targeted increase in the proportion of social and
cost-rental housing to 20% of the national stock, ensuring an appropriate tenure mix. This is
necessary to address the dearth of such housing. Nothing less is needed…Housing of all types
and tenures will only be put on a firm foundation with the stabilisation provided by redressing
the undersupply of social, affordable and cost-rental housing.”
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2.8 To set the context in terms of demand the graph below captures legacy deficit as house building
fell significantly from 2008.
Figure 2 Housing Units built by the Public Sector
2.9 Also the Housing Plan for Ireland, Housing for All, sets a core objective that:
“Everybody should have access to sustainable, good quality housing to purchase or rent at an
affordable price, built to a high standard, and located close to essential services, offering a high
quality of life.”
2.10 The Housing for All plan seeks to deliver a sufficient supply of housing to accommodate
Ireland’s growing population, ensuring that homes are available at prices and rents that are
genuinely affordable. The Plan aims to provide more than 10,000 social homes each year,
with an average 9,500 new build social housing homes to be delivered by 2026 . The plan
states that:
“Increased provision of social housing must involve more emphasis on new-builds by Local
Authorities and an ending of long-term leasing of private accommodation by Local Authorities
through phasing out new entrants and focusing on new-build to provide social homes.”
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2.11 Most recently the acute need for Housing has been set out in the report by the Housing
Commission report.
2.12 We summarise key extracts of relevance to this application:
Executive Summary:
• ‘A major issue of concern to the Commission is Ireland’s housing deficit. It is critical
that this housing deficit is addressed through emergency action. Coupled with this is
the need for a step change increase in the level of housing supply on an ongoing
basis.
• There should be a targeted increase in the proportion of social and cost -rental housing
to 20% of the national stock, ensuring an appropriate tenure mix. A long -term
commitment to stable levels of public financing will also be crucial, supplementing the
funding coming from private sources.’
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2.13 In addition to the National scenario and to establish the context in terms of local demand for the
proposal we have reviewed the delivery of Scheme Housing in the County over the last 6 years
since the 2019 CDP was adopted, as this is helpful to understand the legacy deficit in recent
years against population growth.
2.14 In summary 2.4 of the 2019 CDP identified a Core Strategy Target of 5141 units in the County;
reproduced below. For Towns and Villages we note the previous CDP had a Target to deliver
3910 units therein.
Figure 3 Table 2.4 of the Monaghan CDP 2019-2025
2.15 When CSO data is reviewed our analysis finds that across the County there was only 762
scheme and apartment units delivered in the lifespan of the previous CDP. We highlight this is
only 19.48% of the CDP target over the 6 year period.
Table 1 Scheme Housing and Apartments from Q2 2019-Q4 2025 in Monaghan
(source CSO)
2.16 This is highlighted as the delivery of scheme housing is intrinsically linked to the delivery of
Social and Affordable Housing in the County, through either Part V compliance or designated
Social and Affordable Housing schemes.
2.17 In summary our analysis finds that with the previous Core Strategy target not met this has
resulted in considerable pent-up-demand for residential units, which is accentuated by
population growth rates.
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2.18 Furthermore to inform population growth analysis we note the CSO data for 2022 show that
County Monaghan’s population has grown more significantly since the Census taken in 2016,
increasing by 3,902 persons to 65,288 persons. We note this represents an increase of 6.4%
over the intercensal period, an average annual increase of 1.06% compared to a state average
of 1.3%.
2.19 In terms of growth of the area the CSO map data set ‘Population Density and Area Size by
Electoral Division’ is helpful to gain an understanding on growth in the area.
2.20 As can be seen the N2 corridor and north Monaghan environs has experienced population
growth, and the connections to the wider area explain this alignment between connectivity, jobs
and locational principles for where homes are required. Indeed the cross-border travel patterns
also partly explain this growth along the N2 corridor.
Figure 4 Population growth by Electoral Division (source: CSO)
2.21 On assessment we consider the CSO population growth for the area is considered the most
reliable data source to determine population growth in a rural area such as Emyvale, as it best
captures the emerging population change at a local level.
2.22 In this context we submit the wholistic assessment of housing need and demand in the area is
therefore best achieved when including the trend of population growth against the low delivery
of scheme housing; particularly given the need to deliver sustainable development within
settlements rather than one-off rural housing.
2.23 Furthermore in relation to the 2025 Monaghan CDP we note the Core Strategy now sets out a
need for 6228 housing units to be delivered in the County; which recognises the population
growth and need to increase the delivery of housing. This is addressed in more detail under
the local policy context below.
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2.24 Finally at a local level in Emyvale our analysis finds that over the last 13 years since the 2013
CDP was adopted there has only 14no. scheme housing units delivered; permission 19/210
refers. These units were delivered for Monaghan County Council via a local developer in
conjunction with Tuath.
Figure 5 Site location and context
2.25 In this context it can be concluded there has been a low-delivery of village housing over two
consecutive development plans (ie. since 2016 census data) despite the growing population
of the area.
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3 SUPPORT FOR SOCIAL HOUSING
3.1 The over-arching project rationale is to deliver the proposed residential development as Social
Housing.
3.2 By way of background discussions have been held between the prospective applicant and Housing
Section in Monaghan County Council.
3.3 The enclosed cover letter sets out the planning background:
3.4 Also we refer to correspondence from Housing Section, Monaghan Co Council shown opposite
which clearly explains the social housing need in Emyvale and fully supports the proposal. This is
discussed in more detail below under policy responses.
Social Housing Need & Unit Type Overall Need Proposed Unit Mix
1bed units
22
0
2bed units
18
20
3bed units
8
2
4 bed units
4
8
Table 2 Housing Need and the Proposal RECEIVED: 09/07/2026
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4 POLICY CONTEXT
4.1 Overview
4.1.1 The key planning policy relative to proposal are as follows:
• National Planning Framework 2040
• Housing For All
• Regional Spatial Economic Strategy
• Sustainable Rural Housing Guidelines
• Monaghan County Development Plan 2025-2031
4.1.2 For reference we set out in this section key extract s from the policy and how the proposal is
compliant and supported.
4.2 National Planning Framework (NPF) 2040 (First Revision)
4.2.1 The NPF sets out the importance of development within existing urban areas by ‘making better
use of under-utilised land including ‘infill’ and ‘brownfield’ and publicly owned sites together with
higher housing and job densities, better services by existing facilities and public transport.’
4.2.2 In terms of specific objectives contained within the NPF we highlight the following:
• Objective 7 ‘Deliver at least 40% of all new homes nationally, within the built -up
footprint of existing settlements and ensure compact and sequential patterns of growth .’
• Objective 11 ‘Planned growth at a settlement level shall be determined at development
plan-making stage and addressed within the objectives of the plan. The consideration
of individual development proposals on zoned and serviced development land subject
of consenting processes under the Planning and Development Act shall have regard
to a broader set of considerations beyond the targets including, in particular, the
receiving capacity of the environment’.
• Objective 14 ‘Regenerate and rejuvenate cities, towns and villages of all types and
scale as environmental assets that can accommodate changing roles and functions,
increased residential population and employment activity, enhanced levels of amenity
and design and placemaking quality, in order to sustainably influence and support their
surrounding area to ensure progress toward national achievement of the UN
Sustainable Development Goal.’
• Objective 20 states that ‘there will be a presumption in favour of development that
encourages more people, jobs and activity within existing urban areas, subject to
development meeting appropriate planning standards and achieving targeted growth.’
4.2.3 Of note is section 4.5 of the NPF which states:
‘The NPF targets a significant proportion of future urban development on infill/brownfield
development sites within the built footprint of existing urban areas. This is applicable to all
scales of development, from the largest city to the smallest village.’
4.2.4 Response: The proposed development is consistent with the aforementioned objectives of the
NPF given the overarching national policy to increase residential development in settlements,
particularly so given the subject lands are brownfield, sequentially appropriate, serviced and
Tier 1 as defined under appendix 1 of the NPF.
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4.2.5 Overall a ‘presumption in favour’ of such an urban renewal scheme is required by the NPF in
terms of policy objectives to deliver increased housing in such towns and villages.
4.2.6 Also relevant to the NPF (Revised) is the accompanying Section 28 Guidelines:
4.2.7 As set out in the Guidelines they provide updated housing growth requirements to planning
authorities in order to facilitate the revision and update of development plans in accordance
with the National Planning Framework – First Revision (2025). The Guidelines interpret the
national housing growth requirements identified in the Revised National Planning Framework
for implementation through development plans.
4.2.8 Whilst the primary purpose of the Guidelines is to inform revised housing targets they are
relevant to assesssing need for increased housing, particularly as the Housing Target for
Monaghan has been allocated an uplift based on ESRI Population Forecasts. Section 1.2 of
the Guidelines sets out:
‘Comparing estimated demand as per the ESRI’s projections to actual delivery (new build plus
previously unfinished housing estates built out, as per the Central Statistics Office (CSO)
suggests unmet demand of approximately 140,000 arising over the period 2017 to 2024. The
methodology for deriving this figure involved applying alternative headship rates to the
population to estimate the number of households based on these headship rates. Assuming a
start year of 2025, and the objective of meeting unmet demand in the period to 2034,
thistranslates to an annual average of 13,900 dwellings per annum over the period.
This means an estimated total housing demand of c.55,000 dwellings per annum to 2034 and
an estimated total housing demand of c.41,000 dwellings per annum between 2034 and 2040.’
4.2.9 Page 8 of the Guidelines further sets out:
‘For the purposes of these Guidelines, planning authorities should address the scope for
additional provision of up to 50% in excess of the baseline housing growth requirement set out
in Appendix 1, in light of the urgent need to increase housing delivery and to optimise the ability
to deliver on the housing requirements of the Revised NPF. ‘Additional provision’ recognises
the fact that, for a variety of reasons, a relatively significant proportion of zoned lands
are not activated over the period of a development plan.’ (our emphasis)
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4.2.10 We note the provisions for County Monaghan is an uplift in Housing Targets; shown below.
4.2.11 In this context we say this further supports the proposal in that the Core Strategy under the
2025 CDP and housing allocation for villages such as Emyvale are not aligned with updated
population forecasts nor housing demand.
4.2.12 Notwithstanding these Guidelines are to inform the review of the Monaghan CDP we refer to
the Guidelines to set the planning context and weighting of material considerations in that there
is a clear need to increase housing delivery within the context of growing population levels along
with the reality that a relatively significant proportion of zoned lands are not activated over the
period of a development plan
4.2.13 Indeed also relevant are the provisions of the 2025 Planning Act wherein it expressly recognises
the need for Housing Targets and flexibility. Whilst not yet enacted we say this is also a
Material consideration to the proposal.
4.3 Housing For All
4.3.1 Housing For All was launched in 2021 with the objective that everybody should have access to
sustainable, good quality housing to purchase or rent at an affordable price, built to a high
standard and located close to essential services, offering a high quality of lif e.
4.3.2 Housing For All is based on four key pathways as below.
4.3.3 Also relevant are the following extracts: RECEIVED: 09/07/2026
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• Section 2.2.1: Deliver More Social Homes
‘The Government is committed to increasing social housing delivery and will work with our
delivery partners to ensure that housing is available to the most vulnerable in society. Local
Authorities have a key role in the delivery of homes and targets will b e set for delivery by
them with new Local Authority Housing Delivery Actions Plans, setting out how they plan
to deliver on the objectives of Housing for All.’
• Section 2.4.1: Expand the Housing Options for Older Persons
‘Under Housing for All, we will increase the housing options available to older people to
facilitate ageing in place with dignity and independence, including policies and operational
supports for older people considering right-sizing to smaller housing homes. .Local
Authorities must also consider the needs of older people in the wider planning process.’
4.3.4 Response: We submit the proposal is consistent with Housing For All in that it will improve the
supply of residential units for Emyvale in a sustainable manner.
4.4 Regional Spatial and Economic Strategy (RSES)
4.4.1 The RSES sets out the spatial growth strategy for the border region and sets out a broad range
of policies and objectives to encourage sustainable and economic growth of the region.
4.4.2 As set out in the RSES regarding smaller towns, villages and rural areas are home to almost
80% of the region’s population and as such represent a sizeable cohort of the population and
land area.
4.4.3 As stated in section 3.5 of the RSES:
‘the future role and function of our large network of smaller towns and villages across the region
needs to be reimagined, addressing economic, physical and social decline issues. The
regeneration of our smaller towns and villages is now a major priority action for our region. The
health of our villages, and towns can be significantly influenced through the delivery of new
housing through the utilisation of existing buildings, brownfield/infill sites or otherwise.’
4.4.4 The RSES continues to state:
‘The emphasis will change from place to place but in all cases the approach should be to provide
a range of attractive housing choices appropriate to the needs and character of the place,
including the provision of serviced sites and to provide for low den sity housing demand, as an
alternative to living in one off houses outside towns and villages.’
4.4.5 Key future priorities include supporting:
• ‘the regeneration and renewal of small towns and villages in rural areas.’
• RPO 3.3 ‘Deliver at least 20% of all new housing in rural areas on brownfield sites.’
4.4.6 Response: The proposed development is consistent with the policy objectives of the RSES;
in particular it’s emphasis on the promotion of villages in rural areas and development on
brownfield sites.
4.5 Sustainable Rural Housing Guidelines
4.5.1 The Guidelines recommend that Planning Authorities should respond positively to the housing
needs of rural communities as an integral part of the sustainable development of rural areas RECEIVED: 09/07/2026
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and accommodates applicants wishing to build houses in rural areas in support of that vital
national objective.
4.5.2 In terms of specific objectives contained within the guidelines we note section 2.3 ‘strengthening
rural villages & towns’ is relevant and states:
‘A range of different housing options in small towns, villages and in more rural areas is required
to meet the differing needs of the people who live in those communities, and that
‘Development of individual serviced sites or housing schemes of appropriate scale and
character, within, or in the vicinity of small rural towns and villages can be encouraged.’
4.5.3 Section 2.3 continues to state that
‘Using the development plan and local plan processes, planning authorities should therefore
make every effort to harness all of these measures to ensure that sufficient high quality, well
located and affordable development can take place.’
4.5.4 Response: In the context of the guidelines and policy context aforementioned we submit the
proposal is consistent with the approach set out under the guidelines for a residential scheme
of appropriate scale and character in Emyvale.
4.6 Monaghan County Development Plan 2025-2031
4.6.1 For conciseness the relevant sections and policies are set out below.
• 2.7 Regeneration of Existing Lands
It is considered appropriate to include for the reuse, regeneration and renewal of land through
active land management over this Plan period, having regard to legislative requirements, and
to national and regional policy. The NPF target of delivering 30% o f new housing within the
existing built-up footprint of settlements, on infill and brownfield lands and the principles
contained within the Town Centre First Policy are key considerations in this regard. The
regeneration of land (as defined by the Urban Regeneration and Housing Act 2015) and
buildings in need of development and renewal throughout the County, is an objective of this
development plan and Monaghan County Council will seek to develop and improve areas in
need of development and renewal, particularly within designated settlements.
It is therefore important to acknowledge that a proportion of future urban development will occur
on infill/brownfield/regeneration lands within the built envelope of existing settlements. In order
to encourage this type of development within the urban centres, a relaxation of some
development management standards will be considered where appropriate. Having regard to
this target, it is considered appropriate that up to 20% of the population growth could be provided
for through development of these sites. Therefore, the amount of greenfield lands required to
be zoned for residential use is based on 80% of the population growth. This has been reflected
in the Core Strategy Table 1.
• 15.8.10 Residential Development in Tier 4 Settlements
Residential development and serviced sites on suitable lands located within any of the defined
Tier 4 settlements which have capacity within existing public foul drainage systems, will be
considered subject to compliance with the following:
a) The submission of evidence to the satisfaction of the planning authority that there is
demand for the proposed residential development taking account of the extent, nature and
status of extant permissions for residential development, and vacant residential properties in
the settlement. RECEIVED: 09/07/2026
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b) The proposal contributes to the sequential development of land from the centre of the
settlement outwards and/or represents an infilling of the existing settlement envelope.
c) The scale and density of the development accords with the character of the village.
Notwithstanding the requirements of criteria a-c above for Tier 4 settlements and Section
15.8 ‘Multi Unit Residential Developments’ of the Monaghan County Development Plan
2025-2031, and taking into account the objectives of the ‘Housing for All Plan’ to address
the shortage of housing, the Planning Authority may favourably consider proposals for
social housing developments which are outside the defined Tier 4 settlement limit where
a clear demonstrable need is proven to the satisfaction of the Planning Au thority, and
where the lands are contiguous to the settlement limit and can be adequately serviced.
4.6.2 Response: In the context of the policy context aforementioned we submit the proposal is
consistent with the approach set out under the guidelines for a residential scheme of appropriate
scale and character in Emyvale. We address section 15.8.10 in more detail under Section five
below.
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5 FURTHER INFORMATION RESPONSE
5.1 Overview
5.1.1 Further Information point one states:
‘It is noted the development seeks to rely on provisions under section 15.8.10 of the Monaghan
County Development Plan 2025-2031 which pertains to social housing only. Consequently, the
proposed development can only be justified at a location outside the settlement envelope if it is
clearly demonstrated that there is demand for social housing. On the basis of the information
provided, and noting an extant permission for residential development within the village
boundary (Ref. No. 24/60235), the Planning Authority are not satisfied that (a) there is a need
for the level of social housing proposed, and (b) the proposal contributes to sequential
development. The applicant is advised to provide robust justification for the proposed
development in accordance with Section 15.8.10 of the Development Plan.’
5.1.2 In response this statement addresses matters raised which are:
(I) Existing context of the village
(II) Demand for the proposal and need for the level of social housing proposed
(III) How the proposal contributes to sequential development
(IV) Permission 2460235.
5.2 Matter One: Existing context of the village
5.2.1 As shown in the analysis below the built character of the village extends in a linear manner
along the roads and within the 50kph restrictions of the village limits.
5.2.2 The village does not have a centre per se, but rather is typical linear settlement pattern that has
developed historically along the roads.
5.2.3 As per the core strategy we submit the proposal is indeed ‘commensurate with the nature’ and
the historical linear settlement pattern in the village. It is also a sequentially appropriate site.
5.2.4 The proposal will therefore achieve consolidation of the village and result in a residential
scheme that is consistent with the existing settlement pattern.
5.2.5 In addition we highlight the existing settlement pattern has been developed to date in a manner
that has responded to development constraints, with there being parcels of lands elsewhere
being left undeveloped.
5.2.6 As shown in our analysis below there are several constraints that include flood zones, existing
business premises, backlands which are not accessible and a farm yard all of which have
influenced the settlement pattern and results in all lands within the settlement limit as being
either inappropriate or not available for development.
5.2.7 We submit these constraints are to be noted, in that sequential development is not to be
assessed in isolation but instead considered against the context of both what lands are suitable
for development and how to prioritise/direct development onto sequentially appropriate lands.
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5.2.8 In this context we submit the planning assessment has to have regard to these material
considerations and reach a balanced assessment that this is a scenario where other lands
within the village are either:
(i) not suitable for development;
(ii) not brownfield/serviced;
(iii) not available for development; and
(iv) not of adequate size to deliver social housing in a wholistic way and by a single developer
that will be of such socio-economic benefit to the area.
5.2.9 Of relevance we note there are two main tests in determining whether a consideration in
material and relevant:
(i) it should serve or be related to the purpose of planning- it should therefore relate to the
development and use of land; and
(ii) it should fairly and reasonably relate to the particular application.1
5.2.10 It is our considered view the above factors are key material considerations in assessment of
what lands are most suitable and should be prioritised for development in the village.
1 As defined under case law Cook J (Stringer V MHLG) RECEIVED: 09/07/2026
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RECEIVED: 09/07/2026
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5.3 Matter Two: Demand for the proposal and need for the level of social housing proposed
5.3.1 The over-arching project rationale is to deliver the proposed residential development as Social
Housing.
5.3.2 By way of background discussions have been held between the prospective applicant and
Housing Section in Monaghan County Council. The enclosed cover letter sets out the planning
background:
5.3.3 Also we refer to correspondence from the Housing Section which clearly explains the social
housing need in Emyvale and fully supports the proposal.
Social Housing Need & Unit Type Overall Need Proposed Unit Mix
1bed units
22
0
2bed units
18
20
3bed units
8
2
4 bed units
4
8
Table 3 Housing Need and the Proposal
5.3.4 On these basis the demand is evident and met.
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5.4 Matter three: How the proposal contributes to sequential developmen t
5.4.1 As shown the lands are within the CSO settlement boundary and in a central location.
5.4.2 We say the lands clearly represent the sequential development of the village and are contiguous to the settlement limit.
Figure 7 Sequential development of the village and environs RECEIVED: 09/07/2026
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5.5 Matter four: Permission 2460235
5.5.1 We note the extant permission 24/60235 was granted under the provisions of the previous
2019-2025 CDP and the previous Core Strategy.
5.5.2 Also on review of 24/60235 we note:
• It was not proposed as Social Housing;
• It has not commenced.
5.5.3 In this context we also highlight that notwithstanding permission 24/60235 the Housing Section
in Monaghan County Council are fully supportive of the 30no. units now proposed under
2560502 by GEDA.
5.5.4 Indeed it is to be noted that the Social Housing demand in isolation is 60 units for Emyvale, and
even with both permission 24/60235 and 25/60502 delivered will not meet this demand
combined.
5.5.5 Furthermore outside of the demand for Social Housing we also highlight that in terms of housing
units available we note there are no available housing units for sale in Emyvale. (source Daft.ie
reviewed 23rd April 2026).
5.5.6 This is a material consideration in that availability of housing in a village is proper planning to
cater for local population growth in a settlement rather than continued one-off rural housing to
meet local needs/demand for housing provision.
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5.6 Other Matters
5.6.1 To assist the Planning Authority we take this opportunity to highlight a comparable planning
scenario under permission reference 25/60326 for 21no. dwellings in Rockcorry.
Figure 8 Subject lands relative to Rockcorry Settlement Limit
5.6.2 As correctly noted in the planner’s report:
‘In principle and subject to (a) all housing being social (which can be conditioned) and (b)
evidence of housing demand, the Planning Authority is of the opinion that development at this
location is acceptable in principle and will help to secure objective S04 and policy RD SP1 of
the Monaghan County Development Plan 2025-2031.’
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5.6.3 In summary the same planning principles are applicable in terms of village housing proposed
on sequentially appropriate lands which were supported in terms of Social Housing and granted
permission.
5.6.4 In the context of the above we submit this precedent demonstrates how the correct planning
assessment has been made which take account of the wider constraints in Tier 4 villages and
how to achieve proper planning and sustainable development.
5.6.5 As the Planning Authority will note sections 6.7 and 7.15 of the Development Management
Guidelines set out:
‘6.7: All reasonable efforts should be made to research the planning history of sites and their
general environs, including details of any pre-application consultation, as this is very important
to help ensure planning authorities take a consistent approa ch to planning proposals in a
particular area over time.
‘7.15 A statement of objectives in a development plan should not be regarded as imposing a
blanket prohibition on particular classes of development and does not relieve the Planning
Authority of responsibility for considering the merits or otherwise of particular applications.’
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6 SUMMARY AND CONCLUSION
6.1 As detailed in our responses the relevant National, Regional and Local policy context provides
clear support for the proposal given:
• The policy context;
• The sequential nature of the lands;
• Existing pattern of development and constraints within Emyvale which means there are no other
lands of comparable size which can deliver the proposed scheme in a wholistic manner;
• The development being considered as a whole in terms of benefit to the area and overarching
policy at local and national level to deliver more social housing;
• Comparable precedents and material considerations under permission 25/60326.
6.2 We have demonstrated how Further Information point one is fully addressed.
6.3 In summary the proper planning and sustainable development of the area will be achieved by
permission being granted for the scheme.
6.4 Also the material considerations weigh in favour of the proposal.
6.5 As the Planning Authority will note all decisions are a matter of planning judgement. To achieve
increased urban consolidation and infill on sequentially appropriate lands requires schemes
such as this proposal to be supported. This is a clear policy direction set out in the Report of
the Housing Commision and all Government policies that seek to increase building of Social
Housing schemes.
6.6 We submit the over-arching policy objective and proper planning of what is an infill site is best
achieved by the proposed design. For reference we refer to how the Courts have set out in
recent years how development plan objectives are to be interpreted in broad terms and how
best to achieve good planning.
6.7 As set out in the High Court Judgement Alice O’Donnell V An Bord Pleanala, Minister for
Housing & Attorney General (2023, IEHC 381):
Para 69
‘There is no necessity or logic to reading the statute in an extremely inflexible manner that
would put councils in handcuffs, as being limited to the broad headings of recreational,
commercial, industrial, agricultural and so on alone, without any ability to make any more
specific decision as to the types of residential, commercial or other purposes that are
appropriate for a particular piece of land. That would be a massive intrusion on the autonomy
and freedom of the statutory decision-maker which would be unjustified by any clear basis in
the text. It would also be highly illogical in planning terms. Such an unwarranted interpretation
would conflict with the express statutory requirement of proper planning and sustainable
development, which imply that a decision-maker must have sufficient flexibility to achieve
those ends. We are not just playing with words here – this is about whether councils are to be
hamstrung in their assigned statutory mission to promote good planning.’
6.8 In the context of the attached details and over-arching government policies which all seek to
provide much needed social housing we trust that the application will meet with favourable
assessment by the Planning Authority.
Yours sincerely,
Ronan Woods
Ronan Woods
Director RECEIVED: 09/07/2026
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Appendix 1
Correspondence from applicant
RECEIVED: 09/07/2026
Ref: Proposed development site at Market House Lane, Emyvale, County Monaghan
23rd March 2026
Hi Ronan,
GEDA can confirm that preliminary talks took place before the planning application was made with
representatives from Monaghan County Council in which GEDA confirmed this housing scheme would be
designed in line with the Quality Homes For Sustainable Communities Policy to provide much needed social
housing in North Monaghan.
Regards
Philip Rowland
Design and development manager.
GEDA Construction Ltd
HEAD OFFICE:
36 Moor Road, Dungannon, County Tyrone, BT71 4QB
T: 028 8774 7600
RECEIVED: 09/07/2026