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NCI Response to the Consultation on the Draft Dublin City Development Plan

Last month, NCI submitted a response to the Public Consultation on the Draft Dublin City Development Plan 2022-2028, to demonstrate the relevance of incorporating the natural capital approach into planning - you can read the detail of our submission below:

Purple cover of the plan with cityscape at night image

TEXT FROM THE DRAFT DEVELOPMENT PLAN, CHAPTER 1 – STRATEGIC CONTEXT AND VISION: “The Dublin City Development Plan (2022–2028) sets out an integrated, coherent spatial framework to ensure our city is developed in an inclusive way which improves the quality of life for its citizens, and ensures that it is an attractive place to live, work and visit. The plan guides future growth and development, and provides the overall strategy to achieve proper planning and sustainable development, through a range of policies and objectives”.

NCI response:

Natural Capital Ireland appreciates Dublin City Council's recognition of the importance and value of Dublin City's natural assets for biodiversity protection, climate resilience, economic activity and the well-being of citizens. We also welcome Dublin City Council's firm commitment to protect and enhance Dublin City's natural assets (which are its natural capital) via a proactive green infrastructure strategy and ecologically sensitive development approach, both of which aim to protect and enhance urban ecological connectivity. The main aim of our submission is to inform on how valuable the natural capital approach would be for achieving the objectives of the Draft Dublin City Development Plan.

Natural capital approaches, and natural capital accounting specifically, present a means to support policy and decision-making with a much wider range of analysis/data than that offered by conventional approaches, because it builds in the fullest possible range of environmental – and cultural – costs and benefits in the assessment of any policy. It is also valuable because it can be used continuously to monitor the full cost-benefit performance of any policy into the future. The Natural Capital Approach should be embedded in the overarching philosophy of the Draft Dublin City Development Plan and could be considered with the application of each of the strategic principles set out in section 1.2 of the plan.

Why natural capital?

The topic of natural capital is growing in importance at the European level and nationally:

In late 2019, the European Green Deal was announced, which states that “all EU policies should contribute to preserving and restoring Europe’s natural capital”. In June 2020, the EU published its new Biodiversity Strategy, which states that by 2050, “the EU’s natural capital will be protected, valued and appropriately restored”. While not directly relevant to the DCDP, the Strategy sets a target to bring at least 10% of agricultural land under management for biodiversity, which could be easily achieved, with community support, on Dublin’s growing number of urban farms.

The economic benefits delivered by natural capital remain very undervalued and underrepresented in government policy. Properly accounting for natural capital can help make these values visible, revealing both Ireland’s hidden wealth, and also the hitherto invisible factors that, by degrading natural capital, impoverish us.

Natural capital concepts are already found in a range of flagship national policies, including the National Planning Framework, the National Biodiversity Action Plan 2017-2021, the National Adaptation Framework, and Heritage Ireland 2030 – but much more can be done to embed natural capital thinking in decision making.

The 4th National Biodiversity Action Plan 2022-2026 is currently being drafted and it is anticipated that the natural capital approach and natural capital accounting will be incorporated into the Plan, in line with EU-wide adoption of the UN System of Environmental Economic Accounting (SEEA) (information on the SEEA in the next section), and proposed changes to the EU Regulation on Environmental Economic Accounts.

The recent World Economic Forum’s Global Risks Report (2022), states that the top three most severe global risks are climate inaction, extreme weather, and biodiversity loss; all of which are inter-related risks that compound each other. These risks are a direct threat to our natural capital, and also stem largely from our failure to conserve and restore it.

How can the natural capital agenda support the Council’s Public Consultation on the Draft Dublin City Development Plan?

In order to protect, restore and enhance our natural capital, we must first understand the extent and condition of existing natural assets. In other words, we must establish a baseline upon which targets for improvement can be set.

NCI is a partner on the pioneering EPA-funded INCASE project ( which is the first project to apply Natural Capital Accounting principles to catchments in Ireland. Natural Capital Accounting reports across four main sets of ecosystem accounts - extent, condition, services and benefits - and presents a standardised platform to collate information and regularly report on progress in relation to climate actions, biodiversity conservation and restoration, protection of waterbodies, and general good environmental practices (as identified in cross-sectoral areas such as agriculture, energy, environment, forestry, nature, marine, planning and water supply/use policies).

The INCASE project is piloting this natural capital accounting approach in four river catchments across Ireland. The prevailing natural capital accounting approach at country level is the System of Environmental Economic Accounting (SEEA), which has been adopted by the UN and is in use by about 90 countries worldwide. The SEEA is a guide to integrating economic, environmental and social data into a single, coherent framework for holistic decision-making.

As part of natural capital accounting, Ecosystem Accounting (also known as SEEA-EA) aims to reorient policies to deliver sustainable development and improved human well-being by measuring and valuing the extent, condition and services of Irish ecosystems as part of the System of National Accounts. We encourage Dublin City Council to engage with the Ecosystem Accounts Division of the Central Statistics Office in order to contribute to the task of developing such Irish ecosystem accounts as part of the Dublin City Development Plan ( See

There are articles, blogs and supporting videos available from the INCASE website ( Evidence supporting the natural capital approach has been gathered through the INCASE project and a couple of recent articles relating to the natural capital approach and natural capital accounting relevant to this consultation are listed below:

- Natural capital approaches: shifting the UN Decade on Ecosystem Restoration from aspiration to reality. Restoration Ecology Farrell C, Aronson J, Daily G, Hein L, Obst C, Woodworth P, Stout J (2021)

This article highlights a number of initiatives globally that are applying natural capital approaches for national accounting, land use, business support and health and wellbeing.

- Stage 1 Feasibility Report. URL: Farrell CA, Stout JC (2020) Irish Natural Capital Accounting for Sustainable Environments

This report presents a good overview of the UN System of Environmental Economic Accounting Ecosystem Accounting and potential applications in the Irish context.

The INCASE project pilot can be built upon to develop a national strategy for the management and enhancement of Ireland’s natural capital. This would closely align with current government initiatives such as the National Land Use Review, the development of a National Soil Strategy, revision of the National Biodiversity Action Plan, and expansion of Ireland's Marine Protected Areas network; and Dublin City Council’s priorities such as sustainable, balanced development and sustainable management of water resources from source to sea under the EU Water Framework Directive.

Given the wide range of policy areas covered by the Council, a natural capital framing could provide the holistic approach that would strengthen policies and avoid duplication across policy areas. NCI calls on Dublin City Council to embed the natural capital approach as a core decision-making tool across all Council departments, and as part of broader cross-departmental co-ordination on the conservation and sustainable use of biodiversity. Its an opportunity to expand, deepen and co-ordinate policies across the whole range of economic, environmental, social and cultural values.

TEXT FROM DRAFT DEVELOPMENT PLAN RE CHAPTER 2: “The role of the Core Strategy is to ensure that there is sufficient zoned and serviced land to cater for future housing demand over the development plan period”

NCI suggests that all chapters and sections of the Draft Dublin City Development Plan be assessed through the lens of natural capital and employing natural capital accounting for policy development and decision making (please refer to our response to Chapter 1 for details on the natural capital approach and natural capital accounting).

As suggested in our response to Chapter 1, we encourage Dublin City Council to engage with the Ecosystem Accounts Division of the Central Statistics Office in order to contribute to the task of developing such Irish ecosystem accounts as part of the Dublin City Development Plan. (

You can read more on the Dublin City Development Plan on the Dublin City site:

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