Mainstreaming Climate Change Considerations for Coastal Areas into Spatial Planning Policies at

National and Regional Level; the Example of Ireland

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Authors

Paul Lawlor*, School of Architecture, Buildings & Environment, Technological University of Dublin,
Dublin, Ireland paul.lawlor@tudublin.ie

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J.A.G. Cooper, School of Geography and Environmental Sciences, Ulster University, Coleraine,
Northern Ireland, UK and Dept of Geological Sciences, University of KwaZulu-Natal, Durban, South
Africa jag.cooper@ulster.ac.uk

*Corresponding Author

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Key Words; Climate Change, Ireland, National & Regional Spatial Planning, Coastal adaptation,

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Mainstreaming, Policy integration, Implementation Gap

Abstract
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With impacts from our warming climate unavoidable, the need to adapt to our changed
circumstances has become much more urgent. While policy makers now favour the process of
mainstreaming climate change considerations into existing policy frameworks to build resilience, it
has been observed that mainstreaming climate adaptation requirements into development plans
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and policies has not led to an increase in the rolling out of physical adaptation responses or
measures at national or subnational level – and this clearly indicates that an ‘implementation gap’
exists between the commitments made and the actions undertaken for climate adaptation. Noting
that a strong policy framework is a critical factor for achieving effective mainstreaming, this research
investigates the extent to which Ireland has mainstreamed climate adaptation considerations for its
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extensive and vulnerable coastline into its national and regional spatial planning strategies. An
assessment of whether these spatial planning strategies can bridge the ‘implementation gap’ in
coastal adaptation planning and action is also made. The research reveals that despite the exposure
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of the Irish coastline to negative climate change effects, a weak policy framework has resulted in few
specific adaptation responses being proposed or prioritised to address coastal vulnerabilities. The
major contributory factors to the weakness of the policy framework are the lack of a national coastal
management strategy, the failure to adhere to existing guidance on coastal land use and the limited
ability of national and regional spatial planning strategies to comply with the guiding principles of
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the National Adaptation Framework. The weak policy framework is hindering the mainstreaming of
climate considerations into national and regional spatial planning policies and contributing to the
‘implementation gap’ that is visible between climate adaptation commitments and plans and robust
actions for Irish coastal areas.
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This preprint research paper has not been peer reviewed. Electronic copy available at: https://ssrn.com/abstract=4729469
 Mainstreaming Climate Change Considerations for Coastal Areas into Spatial Planning Policies at
National and Regional Level; the Example of Ireland

ed
Abstract

With impacts from our warming climate unavoidable, the need to adapt to our changed
circumstances has become much more urgent. While policy makers now favour the process of
mainstreaming climate change considerations into existing policy frameworks to build resilience, it

iew
has been observed that mainstreaming climate adaptation requirements into development plans
and policies has not led to an increase in the rolling out of physical adaptation responses or
measures at national or subnational level – and this clearly indicates that an ‘implementation gap’
exists between the commitments made and the actions undertaken for climate adaptation. Noting
that a strong policy framework is a critical factor for achieving effective mainstreaming, this research
investigates the extent to which Ireland has mainstreamed climate adaptation considerations for its

v
extensive and vulnerable coastline into its national and regional spatial planning strategies. An
assessment of whether these spatial planning strategies can bridge the ‘implementation gap’ in

re
coastal adaptation planning and action is also made. The research reveals that despite the exposure
of the Irish coastline to negative climate change effects, a weak policy framework has resulted in few
specific adaptation responses being proposed or prioritised to address coastal vulnerabilities. The
major contributory factors to the weakness of the policy framework are the lack of a national coastal
management strategy, the failure to adhere to existing guidance on coastal land use and the limited
er
ability of national and regional spatial planning strategies to comply with the guiding principles of
the National Adaptation Framework. The weak policy framework is hindering the mainstreaming of
climate considerations into national and regional spatial planning policies and contributing to the
‘implementation gap’ that is visible between climate adaptation commitments and plans and robust
pe
actions for Irish coastal areas.
1.0 Introduction

With average global surface temperature continuing to rise, the need to adapt to our changing
climate is growing more urgent. In 2023, the IPCC confirmed that the likely range of human induced
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global temperature increase since pre industrial times (1850 – 1900) was between 0.8°C and 1.3°C
(with an estimated increase was 1.07°C) (IPCC, 2023) and with the fastest increase in global surface
temperature occurring since 1970, further rises are anticipated in the years ahead. In addition, some
world regions have experienced higher than average surface temperature increases than others with
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European land temperatures for the 2007-2016 period recorded at 1.6°C warmer than in pre-
industrial times (EC, 2018) – a level that exceeds the 1.5°C threshold set in the 2015 Paris Agreement
(Allen et al, 2018). While higher average temperatures have driven the climate changes that have
caused widespread losses and damage to nature and people at a global level, these adverse impacts
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are unequally distributed across systems, regions and sectors (IPCC, 2023). With above average
temperature increases, Europe is one of the regions that has experienced significantly negative
impacts with a growing number of climate related extreme events such as heatwaves, droughts,
storms, wildfires and floods occurring. The coastline in Europe is considered to be particularly
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susceptible to negative climate change effects (EC, 2021) and as 40% of Europeans live in coastal
areas, they face immediate and future challenges from rising sea levels and more frequent and
intense storm surges that are expected to lead to coastal inundation and erosion (EC, 2018) that will
result in significant ecological damage, economic losses and other societal problems unless
additional adaptation measures are implemented (EEA, 2017). Outermost European regions, such as
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Ireland, are expected to be more negatively affected by climate change than others with immediate
and longer term challenges arising from sea level rise (EC, 2018) and climate-related extreme events
such as cyclones and hurricanes. With 7,000 km of coastline on the island of Ireland (DHLG&H, 2021)

This preprint research paper has not been peer reviewed. Electronic copy available at: https://ssrn.com/abstract=4729469
 and climate changes that in line with and similar to relevant global trends (Flood et al, 2020), Irish
coastal areas are particularly vulnerable to climate change effects with higher sea levels, coastal

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storms and flooding represent immediate national level risks that are anticipated to become more
severe over the longer term. The Irish National Risk Assessment (2019) states that Ireland is
expected to continue to experience effects arising from climate change with immediate risks (such
as floods, precipitation and storms) and future impacts (that include sea level rise, wildfires and
summer water shortages) identified (DT, 2019). The Interdepartmental group on National Coastal

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Change Management have also confirmed that sea level rise driven by the warming climate will
‘significantly change and could adversely impact on our coastal economy, society, heritage, culture
and environment’ unless it is managed appropriately (DHLG&H and OPW, 2023).

In recognising that adverse climate impacts will continue to happen, the need to respond to our
changing circumstances is unavoidable (Serrao-Neumann et al, 2023) and adaptation is required to

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enable adjustment to actual or expected climate change effects (EC, 2018). Significantly, a consensus
approach has emerged on the preferred means of implementing adaptation through existing policy

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frameworks. Known as mainstreaming, the approach enables the implementation of adaptation
policy at different levels and in different sectors by incorporating adaptation actions (that are
designed to deliver climate resilience) into broader strategies (Runhaar et al, 2018). The
mainstreaming approach is increasingly favoured by policy makers over a dedicated approach
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whereby adaptation actions are implemented as stand alone initiatives. According to the UN,
mainstreaming (or integrating) climate change considerations in planning and decision making
processes is a crucial tool for enabling climate change adaptation as it reduces vulnerabilities to
climate impacts, increases adaptive capacity and ensures sustainable development (UNDP, 2012).
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Evidence of the widespread use of the mainstreaming approach to embed climate change
considerations in planning is demonstrated by its inclusion in the 2023 IPCC Summary for Policy
Makers Report which calls for climate action to be mainstreamed across policy domains and levels
(2023). The EC have also committed to mainstreaming in the EU Strategy on Adaptation to Climate
Change (EC, 2021) and this is reflected in the first round of biennial reports on adaptation actions
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which found that most European Union member states have actively mainstreamed adaptation into
planning and decision-making processes (UNEP, 2022). The use of National Adaptation Plans as a
mechanism for responding to climate change has also helped to accelerate the mainstreaming of
adaptation (Runhaar et al, 2018) as 84% of countries have at least one adaptation planning
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instrument in place (such as a national adaptation plan [NAP], strategy, law or policy) (UNEP, 2022).

Despite the widespread acceptance of mainstreaming as a means of integrating climate adaptation

considerations into development plans and policies, it is noted that the approach has been slow to
translate into robust actions at national or subnational levels (Runhaar et al, 2018). At a global level,
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UNEP have confirmed that ‘planning for and investments in national- or project-level adaptation are
not found to be at the sufficient scale to keep up with the sharp acceleration of observed climate
impacts and projected climate risks’ (UNEP, 2022). The EC have also described progress in adaptation
planning in Europe as slow and implementation and monitoring even slower with particular
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problems noted with rolling out physical solutions to adaptation issues (EC, 2021). Similar difficulties
persist at EU member state level. In Ireland, the Climate Change Advisory Council (CCAC hereafter)
used a scorecard system to assess progress on sectoral adaptation and while there were
performance improvements in 2022 (in risk prioritisation and adaptive capacity), the Council
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concluded that ‘the very small number of areas where progress is good or advanced is worrying’
(CCAC, 2022). According to Mogelgaard, the divergence between commitments and plans to
implementation is hindering our ability to move from assessing vulnerabilities to focussing on
planning, implementing and evaluating climate adaptation responses (2018). Referred to as the

This preprint research paper has not been peer reviewed. Electronic copy available at: https://ssrn.com/abstract=4729469
 ‘implementation gap’, it can be ‘bridged’ by focussing on 5 factors (comprising of policy frameworks,
sustained persistent leadership, co-ordination mechanisms, information and tools and supportive

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financial processes). While all factors are significant, policy frameworks are seen as a critical factor in
embedding mainstreaming into planning and moving it from planning to action (Mogelgaard et al,
2018).

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Figure 1; The 5 factors that can help to bridge the implementation gap (Source; Mogelgaard et al,
2018)

Noting the importance of the policy framework for effective mainstreaming, this research paper
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focusses on the experience of Ireland and assesses whether the attempts to mainstream climate
adaptation considerations for its vulnerable coastal areas into national and regional spatial planning
strategies have been sufficient to bridge the ‘implementation gap’ in coastal adaptation planning
and action.

As a peripheral island nation to the north west of Europe, Ireland is susceptible to a range of
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immediate and longer term risks arising from climate change with particular challenges for Irish
coastal areas. The CCAC identifies the Irish coastline as being vulnerable to erosion, sea level rise and
coastal storm events – all of which are being magnified by the changing climate (CCAC, 2023). Like
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other EU countries (EEA, 2023), Ireland has a statutory National Adaptation Plan in place to respond
to actual and anticipated climate change effects. Launched in 2018, the National Adaptation
Framework (NAF hereafter) set out the national strategy to reduce vulnerability to the negative
effects of climate change and to avail of any positive effects that may occur. The uncertainty
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surrounding climate change impacts is acknowledged and the NAF recommends that this lack of
certainty around outcomes should be used as a motivation to adopt a precautionary approach
(DCCAE, 2018a). The NAF recognises that a range of adaptation actions are required to respond to
climate change effects such as grey measures (technical or engineering solutions), green measures
(such as nature-based solutions) and soft measures (including land management measures such as
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prohibiting development in certain areas). Some specific adaptation measures are suggested. For
example, Local Authorities are urged to consider policies to acquire flood prone land suitable, less
vulnerable land uses such as parks, gardens, green infrastructure and open space for natural
habitats’ – all of which have the potential to deliver ‘no regret’ benefits that create flood resilience
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(DCCAE, 2018a) it is recommended that all potential synergies should be considered when assessing
adaptation options. With respect to coastal areas, the NAF anticipates challenges from extreme
weather events, sea level rise and erosion and states that ‘managed retreat’ should be considered to

This preprint research paper has not been peer reviewed. Electronic copy available at: https://ssrn.com/abstract=4729469
 be a ‘win win’ adaptation response that provides a buffer against coastal erosion and can contribute
positively to ecosystem health and biodiversity (DCCAE, 2018a).

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The NAF provides a clear commitment to mainstreaming by stating that the purpose of the strategy
is ‘to ensure climate adaptation considerations are mainstreamed into all local, regional and national
policy making’ (DCCAE, 2018a). This is particularly relevant to Irelands hierarchial or top down
forward planning system where a national level spatial plan (the National Planning Framework

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(NPF)) provides guidance for the regional level strategies (Regional Spatial & Economic Strategies
(RSES’s)) – which translate the national level planning objectives to a regional level and provide the
link between national and local level spatial plans (EMRA, 2019). Oversight of planning policy
implementation across national, regional and local levels is the responsibility of the Office of the
Planning Regulator in Ireland (OPR, 2019).

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Figure 2; The forward planning system (for spatial plans) in Ireland (Source; Project Ireland 2040;
National Planning Framework)
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The centrality of the land use planning system for delivering adaptation is seen to be particularly
important in the mainstreaming process as it is stated in the NAF that the most effective strategy is
to integrate climate change considerations into statutory plans and guidelines, policy statements,
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programmes and projects at all levels of government (DCCAE, 2018a). As planning legislation
currently requires different levels of the planning process to address climate change (Flood et al,
2020), the forward planning system offers further potential to incorporate climate considerations. In
recognition of the fact that climate change adaptation is an iterative process that requires
mainstreaming at national, regional, local and sectoral level, the NAF sets out guiding principles to
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inform adaptation planning (DCCAE, 2018a) which are;

 Projecting Climate Change Impacts (national level and region-specific (where relevant))
 Engaging in Climate Change scenario planning
 Adherence to the precautionary principle
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 Vulnerability Assessment
 The options for adaptation (grey, green and soft measures)
 Proposed adaptation measures and the priorities assigned to them

This preprint research paper has not been peer reviewed. Electronic copy available at: https://ssrn.com/abstract=4729469
  Potential for synergies between adaptation measures and other objectives
 Prioritise adaptation measures

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 Monitoring Adaptation progress

This research paper investigates the extent to which national and regional level spatial planning
policies in Ireland can adhere to the guiding principles of the NAF for climate adaptation in coastal
areas. The research findings are then used to ascertain whether national and regional spatial

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planning policies can provide a sufficiently strong policy framework for delivering effective
mainstreaming or not. The findings are also used to assess if an ‘implementation gap’ between
adaptation plans and actions can be identified in Irish coastal areas.

2.0 Methods

In order to compete the research, a 3 step methodology was devised. The first step involved an

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assessment of the extent to which climate adaptation considerations have been integrated (i.e.
mainstreamed) into relevant national level planning and development guidelines as well as spatial

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planning policy for Irish coastal areas at national and regional level. This step comprises a review of
all national and regional level spatial planning strategies in order to ascertain if they could comply
with the guiding principles of the NAF with respect to adaptation to climate change effects in coastal
areas. In addition to the spatial planning strategies, the national level development plan (which is
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aligned to the National Planning Strategy) was assessed. In the second step of the methodology, the
results of the review were used to ascertain if Ireland can be considered to have a strong policy
framework for climate adaptation in coastal areas (which has been identified as a prerequisite for
effective mainstreaming). The third step involves an assessment of the results in order to see if an
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‘implementation gap’ exists in climate adaptation policy for coastal areas in the national and
regional level spatial planning strategies of Ireland.

3.0 Results

This section presents the results of the review of relevant Irish national level guidelines and the
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national and regional level spatial planning strategies. The national development plan (as it is aligned
to the national level planning strategy) is also included in the review.
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3.1 National Level Plans & Guidance on Managing Coastal Change prior to 2018

Concerns surrounding climate driven changes to Irish coastal areas were demonstrated in 1992 with
the formation of a National Coastal Erosion Committee which was set up following a series of
destructive storms that caused significant damage and accelerated coastal erosion rates in Ireland.
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In their report, the committee concluded that 1,500 km of Irelands 5800 km of coastline was at risk
from coastal erosion (Cummins et al, 2003) and a national coastal management policy was needed
along with 'a code of practice for coastal protection' (Dollard, 1998). Work on this issue continued
with the establishment of EU funded multi disciplinary project team who aimed to develop methods
for assessing, monitoring and devising appropriate responses to coastal erosion (Dollard, 1998). The
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resulting ECOPRO report (short for Environmentally Friendly Coastal Protection) was published in
1996 and it placed a firm emphasis on soft engineering techniques to protect the coastal
environment - such as marram grass planting, dune ridge re-contouring, sand trap fencing and beach
nourishment (Dollard, 1998). It was also recommended that development in coastal areas should be
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restricted by a setback line (Connolly et al, 2001). While it is not known how many Irish local
authorities adhered to this advice at this time, Connolly et al (2001) notes that aside from Wexford
(who adopted the 50 metre recommended setback), the approach was not considered to be widely

This preprint research paper has not been peer reviewed. Electronic copy available at: https://ssrn.com/abstract=4729469
 adopted – a point confirmed in a 2017 Coastal Erosion Policy and Practice audit (Cronin et al, 2017).
However, an acceptance of the need to plan for Irish coastal areas was demonstrated in 2001 by the

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commissioning of a research paper on Integrated Coastal Zone Management to inform the
preparation of the National Spatial Strategy (NSS hereafter) – Irelands first statutory national level
spatial plan. While the research paper considered the status (and implications) of policies and
coastal management in Ireland at that time, it also sought to identify coastal areas with special
policy and management requirements in relation to coastal erosion, sea level changes, amenity,

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tourism and aquaculture activities (Cummins et al, 2003). An urgent requirement for an ICZM policy
to guide Local Authority Development Plans was also identified in the paper and this led to a
commitment being included in the NSS to prepare an integrated coastal zone management strategy
(DE&LG, 2002). Despite this, the NSS adopted in 2002 did not include an ICZM strategy.

The impact on climate induced change in coastal areas was also considered by Fealy in a 2003 EPA

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Climate Scenarios Research Report with a blunt assessment given of the challenges facing coastlines.
It identified ‘an immediate requirement to put in place strategies that are consistent with assessing

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short and long-term impacts of sea level rise both at the local and national level. It was also stated
‘policy must not just address what the local implications of sea level rise impacts and responses are
but how these may affect surrounding areas’ (Sweeney et al, 2003). The recommendations for
coastal management (attributed to Carter, 1990 in Sweeney et al, 2003) were reiterated including;
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 No new building or new development within 50 m of ‘soft’ shorelines,
 No further reclamation of estuary land
 No removal of sand dunes, beach sand or gravel
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 All coastal defence measures to be assessed for environmental impact.

Stating that adopting setbacks for development from soft coasts was a sensible approach in the
context of rising sea levels and climate change, Fealy recommended that the 50 metre setback
should be increased to 100 metres and that the landward migration of coastal features (such as
dunes and salt marshes) should be facilitated as they provide protection against wave energy. Strict
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controls of human activities along coastlines to protect the coastal zone were also recommended
(Sweeney et al, 2003) while guidance on land use and management in coastal locations was given.
This guidance included a recommendation that ‘a policy of planned retreat in some areas, combined
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with prohibitions on new developments in vulnerable coastal zones offers the best economic solution
for most areas in Ireland’ (Sweeney et al, 2003). Consistent with this view, it was recommended that
‘hard engineering of the coastline should be viewed as a last resort and only if the benefits outweigh
the loss of land’ as these approaches can have dramatic effects further along the coastline (Sweeney
et al, 2003).
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An audit of Local Authority Coastal Erosion and Practice in 2017 provided a snap shot of how ‘local
level’ Development Plans in coastal Local Authorities in Ireland addressed coastal management. The
audit revealed that national policy and guidance on the related issues of coastal erosion and coastal
defence was generally weak with little clarity on the responsibilities of Local Authorities and others
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(such as land owners). As a result, approaches to managing coastal erosion differed between coastal
Local Authorities – with more than half (10 from 18) having no stated policy for managing coastal
erosion (Cronin et al, 2017). Local Authorities were also found to have differing approaches to
monitoring and recording coastal erosion – a surprising finding given that the OPW had produced
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guidance on the procedure to be followed for assessing and managing risk in 2012 (OPW, 2012). The
audit also revealed that there were few examples of Local Authorities adopting a joint approach to
the problem (Cronin et al, 2017). The audit concluded that guidance was required on coastal

This preprint research paper has not been peer reviewed. Electronic copy available at: https://ssrn.com/abstract=4729469
 monitoring by Local Authorities (in order to ensure a uniform approach) while land use planning was
seen as being a key tool in lowering the impact of future coastal erosion.

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Therefore, the review demonstrates a need for a national coastal management strategy and an
awareness of coastal climate change effects since at least 1992 with recommended guidance on land
use planning measures to deal with coastal erosion published in 1997, 2003 and in 2012. As these
recommendations were not widely adhered to by Local Authorities, it demonstrates poor integration

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between government guidelines on climate adaptation in coastal areas and spatial plans and
strategies between 1992 and 2017.

3.2 National Level Spatial Plans; Ireland 2040; The National Planning Framework (NPF) and the
National Development Plan

Adopted in 2018, the National Planning Framework (NPF hereafter) is considered to be particularly

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significant in Irish spatial planning as this statutory long-term, 22-year national level spatial planning
framework provides a vision for the future development of Ireland. This vision is to be achieved by

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realising 10 shared goals known as National Strategic Outcomes (NSO’s) which are enabled by 10
Strategic Investment Priorities (DHP&LG, 2018) - 3 of which are directly relevant to this research -
NSO 1 (compact (urban) growth), NSO 7 (enhanced amenity and heritage) and NSO 8 (climate
action). Noting that the 2010 Planning & Development Act (as amended) stipulates that all plans
must ‘be consistent’ with the NPF, (Figure 1), the NPF exerts a strong influence on the policies of all
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statutory plans at regional, county, local and city level. Therefore, as the NPF is a spatial expression
of government policy, the extent to that strategy takes account of climate change considerations is
particularly significant in this research as it represents an important starting point for embedding
climate change considerations in Irish spatial planning policy. This section considers the extent to
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which climate adaptation considerations for coastal areas have been mainstreamed in the NPF and
other national level plans by assessing their ability to comply with the guiding principles of the NAF.
With respect to mainstreaming, the NPF begins by reiterating the NAF assertion that the ‘planning
process provides an established means through which to implement and integrate climate change
objectives, including adaptation, at local level and that planning legislation also requires different
levels of the planning process to address climate change’ (DHP&LG, 2018). While there is no explicit
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reference to mainstreaming, National Policy Objective 54 provides a commitment to ‘integrating

climate action into the planning system in support of national targets for climate policy mitigation
and adaptation objectives’ (DHP&LG, 2018).
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The ability of the NPF to comply with the 9 guiding principles of the NAF was assessed and the
results are set out in table 1. Although anticipated climate change impacts are covered only in
general terms and different climate scenarios for Ireland are not presented, the NPF is consistent
with the NAF in its acceptance of the precautionary principle (DHP&LG, 2018). Similarly, the need
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for statutory spatial plans to provide assessments of climate change vulnerabilities is recognised
with the inclusion of a requirement to integrate ‘climate considerations into statutory plans and
guidelines in order to reduce vulnerability to negative effects and avoid inappropriate forms of
development in vulnerable areas’. The emphasis in the NPF on the challenges that are anticipated in
coastal areas arising from climate change is notable as it recognises that the distinctive and diverse
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coast accommodates a range of urban, rural and coastal communities and important economic
sectors, its ‘fragility’ and the need for its careful management is acknowledged in Policy 4a - which
seeks to ‘ensure that Ireland’s coastal resource is managed to sustain its physical character and
environmental quality (DHP&LG, 2018). However, how land sea interactions in coastal areas will be
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managed and the mechanisms for managing them are not made clear – particularly as no national
level ICZM strategy has been prepared and none of the sub national level coastal or maritime plans
that are expected to focus on land-sea interactions are in place (DHP&LG, 2018). The lack of clarity
has persisted since the publication of the NPF in 2018. While the 2023 report by the

This preprint research paper has not been peer reviewed. Electronic copy available at: https://ssrn.com/abstract=4729469
 interdepartmental committee on national coastal change management reiterates a commitment to
sub national coastal plans by recommending that a national set of coastal change management plans

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are produced (DHLG&H and OPW, 2023), no time frames are provided for preparing these plans and,
given that ‘regional level’ maritime policies are also required, it seems unlikely that these policies
will emerge in the short term.

References Included on; NPF

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1 Climate Change Impacts (National & Regional Level) YES
2 Climate Change Scenario Planning NO
3 Adherence to the precautionary principle YES
4 Vulnerability Assessment YES
5 Identify a range of adaptation options (grey, green and soft measures) LIMITED
6 Propose adaptation measures to boost resilience NO

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7 Potential for synergies between adaptation measures and other objectives NO
8 Prioritise Adaptation Measures NO

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9 Monitor Adaptation Progress NO
Table 1; Adherence of NPF to NAF key adaptation issues and guiding principles

In addition, guidance in the NPF on how coastal areas can adapt to climate change effects are scant.
Noting the coverage of anticipated climate change effects, the NPF predicts that ‘barrage or similar
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technologies’ may need to be considered to prevent the inundation of low-lying city centres during
extreme weather events and support is provided for grey and green adaptation measures to build
resilience (DHP&LG, 2018). However, there is little discussion of the potential of soft measures (such
as coastal land management controls and development setbacks) to positively contribute to
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adaptation –despite their inclusion in earlier national level guidance to deal with coastal erosion in
1996 and 2003. The need to align future planning with national policy on climate change adaptation
is emphasised by Policy 4b which makes it a priority of the framework to ‘address the effects of sea
level changes and coastal flooding and erosion and to support the implementation of adaptation
responses in vulnerable areas’ (DHP&LG, 2018). However, NPF guidance for the planning and
management of the coastline (and challenges arising from climate change effects) is limited and
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there is no reference to ‘coastal retreat’ or the other approaches advocated in the NAF. The NAF
statements on built environment and spatial planning which call for ‘deepening adaptation
considerations in planning and building standard processes’ (DCCAE, 2018a) and avoid ‘inappropriate
forms of development of vulnerable areas and promoting compact development in less vulnerable
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areas’, are also not addressed. The lack of connectivity is notable as the NPF presented an
opportunity to provide national level planning guidance to Local Authorities on the ‘deepening of
adaptation considerations’ when pursuing the active land management role that is envisaged for
them in the NAF. In addition, no ranking of priorities for adaptation are expressly identified and no
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indication is given on how adaptation progress will be monitored.

The National Development Plan (NDP hereafter) which sets out investment priorities and funding
streams for Ireland over the 2018 – 2027 period, is also of interest in the review. Published in 2018
(and reviewed in 2021), the NDP states that it is fully integrated with the new approach to spatial
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planning in Ireland in the NPF (DPE&R, 2018). This integration is achieved by linking the 10 shared
goals known as National Strategic Outcomes (NSO’s) in the NPF with 10 Strategic Investment
Priorities set out in the NDP (see table 2). Three of the NSOs are considered to be particularly
important to climate adaptation - (NSO 1 (Compact Growth), NSO 7 (Enhanced amenity and
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heritage) and NSO 8 (Climate Action)). With respect to NSO 1, €14.5 bn euro has been allocated to
the key government priority of increasing housing stock through the delivery of compact higher
density urban settlements with the vast majority (€11.6 bn) made available for social housing
provision and €2 bn for urban regeneration. However, there is no explicit reference to the NAF

This preprint research paper has not been peer reviewed. Electronic copy available at: https://ssrn.com/abstract=4729469
 requirement that compact growth be ‘promoted in less vulnerable areas’ (DCCAE, 2018a) and it is
not clear if any of the allocated funding for compact growth will made available to enable Local

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Authorities ‘to acquire flood prone land suitable for less vulnerable land uses …. such as parks,
gardens, green infrastructure and open space for natural habitats’ (DCCAE, 2018a). NSO 7 relates to
the delivery of enhanced amenity and heritage – through the provision of natural amenities, parks
and green infrastructure as these features can be used as effective climate change buffers in coastal
and other areas. However, the NDP reveals that this is a particularly broad funding category as it

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relates to ‘all elements of living space’ and it includes ‘streets, public spaces, built heritage and
natural amenity areas, cultural and sporting opportunities, sustainable transport networks and
Ireland’s national parks and nature reserves’ (DPE&R, 2018). Given the absence of specific
references to green infrastructure provision, the number of competing priorities and the limited
funding available for achieving NSO 7 (€1.4 bn or 1.2% of total NDP funding - table 3), it seems

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unlikely that sufficient provision has been made to acquire flood-prone land as suggested in the NAF.

National Strategic Outcomes Strategic Investment Priorities

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1 Compact Growth Housing & Sustainable Urban
Development
2 Enhanced Regional Accessibility National Road Network
3 Strengthened Rural Economies & Communities Rural Development
4 Sustainable Mobility Environmentally Sustainable Public
er Transport
5 A Strong Economy supported by Enterprise, Enterprise, Skills & Innovation Capacity
Innovation & Skills
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6 High Quality International Connectivity Airports & Ports
7 Enhanced Amenity & Heritage Culture, Heritage & Sport
8 Transition to a Low Carbon & Climate Resilient Climate Action
Society
9 Sustainable Management of Water, Waste and Water Infrastructure
other Environmental Resources
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10 Access to Quality Childcare, Education and Education, Health & Childcare

Health Services
Table 2; The National Strategic Objectives (NSO’s) and Strategic Investment Priorities identified in the
NPF.
tn

NSO 8 (which relates to the transition to a low carbon and climate resilient society) is also relevant.
However, the NDP places significant emphasis on mitigation actions and less attention is given to
adaptation. The emphasis on mitigation is clearly reflected in the funding allocations with €940
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million (or 4.3%) of the €21.8 billion in funding allocated to NSO 8 earmarked for adaptation actions.
It is also notable that a Climate Action Fund set up to fund climate action measures is not intended
for adaptation and will focus on ‘interventions in the transport sector’ (DPE&R, 2018). In addition to
limited funding provisions being made for climate adaptation in the NDP, the review has revealed
that the limited adaptation funding is heavily focussed on the provision of grey measures such as
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flood defences and flood risk management (DPE&R, 2018). The 2018 NDP was reviewed in 2021 with
the revised strategy providing for an 49% increase in funding from €116 bn to €165 bn (DPE&R,
2021). However, like for like comparisons between both plans is made difficult for two reasons.
Firstly, the 2021 Plan does not include a breakdown of budget allocations based on NSO’s and
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secondly, it uses ‘estimated cost ranges’ for individual projects – as they are deemed to be necessary
to take account of indepth and complicated project lifecycles. As result of the above, it is not

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 possible to conclude that additional funding has been made available for coastal adaptation in the
2021 – 2030 NDP.

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National Strategic Strategic Investment 2018 – 2027 NDP % of Total
Outcomes Priorities Allocation (€bn) Funding
1 Compact Growth Housing & Sustainable Urban 14.5 12.5
Development

iew
2 Enhanced Regional National Road Network 7.3 6.3
Accessibility
3 Strengthened Rural Rural Development 8.8 8.8
Economies &
Communities
4 Sustainable Mobility Environmentally Sustainable 8.6 7.6

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Public Transport
5 A Strong Economy Enterprise, Skills & Innovation 9.4 8.1
supported by Enterprise, Capacity

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Innovation & Skills
6 High Quality International Airports & Ports 4.8 4.1
Connectivity
7 Enhanced Amenity & Culture, Heritage & Sport
er 1.4 1.2
Heritage
8 Transition to a Low Climate Action 21.8 18.8
Carbon & Climate
Resilient Society
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9 Sustainable Management Water Infrastructure 8.8 7.6
of Water, Waste & other
Environmental Resources
10 Access to Quality Education, Health & Childcare 20.1 17.3
Childcare, Education and
Health Services
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11 Other Sectors - 3.0 2.6

12 Contingency/ Reserve - 7.4 6.4
Total 116 100.0
tn

Table 3; 2018 NDP Funding Allocations for the Strategic Investment Priorities to enable the
achievement of the 10 National Strategic Outcomes (NSO’s) in the NPF (Source; DPE&R, 2018)

3.3 The Regional Economic and Spatial Strategies (RSES’s)

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The regional level of governance in Ireland is important for translating national strategic planning
policies in the NPF to a regional level (DHP&LG, 2018). Regional governance in spatial planning is
administered by three regional assemblies, the Northern and Western Regional Assembly, the
Eastern and Midland Regional Assembly and the Southern Assembly – all of which have key
responsibilities, the most significant of which is the preparation, adoption and implementation of a
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Regional Economic and Spatial Strategy (RSES hereafter) for their relevant region. The RSES can be
described a long-term strategic planning and economic framework for each region (DECLG, 2012)
and the ‘link between the National Planning Framework, the City and County Development Plans and
the Local Economic and Community Plans (DCCAE, 2018b). Much like the NPF, each RSES sets out a
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shared vision for the future development of their respective regions and in each case, the vision is
underpinned by 16 Regional Strategic Outcomes (RSO’s hereafter) which are closely aligned to the
10 NSO’s in the NPF. In this review, the RSES for each of the three regional assembly areas are briefly

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 outlined and assessed to measure the extent to which they incorporate the NAF’s key adaptation
issues and guiding principles.

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v iew
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er
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Figure 3; The Map of Regional Assembly Areas in Ireland (Source; https://emra.ie/regional-spatial-

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and-economic-strategies-2/overview/ )

The Eastern Regional Assembly Regional Spatial and Economic Strategy (EMRA RSES hereafter);
While there is no reference to mainstreaming, it is demonstrated that climate considerations were
tn

taken into account in the EMRA RSES as it is stated that climate action is one of the 3 key cross
cutting principles that underpin the strategy (EMRA, 2019). In addition, 2 climate specific RSOs – RSO
8 and RSO 10 are included. RSO 8 is focussed on building Climate Resilience by ensuring ‘the long
term management of flood risk and by building resilience to increased risks of extreme weather
events, changes in sea level and patterns of coastal erosion to protect property, critical infrastructure
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and food security’. RSO 10 is also relevant – as it seeks to enhance green infrastructure by
identifying, protecting and enhancing green infrastructure and ecosystem services in the region and
promoting the sustainable management of strategic natural assets including coastlines (EMRA RSES,
2019). The EMRA RSES also identifies both national and regional level climate change impacts (EMRA
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RSES, 2019) but different climate scenarios are not covered and there is no reference to the
precautionary principle. With respect to assessing vulnerabilities, the EMRA RSES recognises that
challenges such as rising sea levels, increased sea temperatures, higher precipitation levels and
coastal flooding are emanating from our changing climate (EMRA RSES, 2019) and generating
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pressures on the coastline with a number of areas identified as being at a heightened risk of erosion
(EMRA RSES, 2019). Although the EMRA RSES notes a role for green measures (such as green
infrastructure) in responding to these coastal climate change effects, there is scant reference to
either grey or soft measures. Attention is drawn to the issue of coastal erosion and it is stated that

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 decision making on future development should be informed by existing guidance and the strategic
coastal erosion and flood maps in the Irish Coastal Protection Strategy Study (ICPSS hereafter). It is

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also stated (in RPO 7.4) that coastal erosion risks should be taken into account in land use plans as
new development in these areas should be avoided ‘to the greatest extent practicable’ (EMRA RSES,
2019). However, there is no reference to the NAF suggested approach of coastal retreat as a means
of creating coastal buffers (DCCAE, 2018a). Although the EMRA RSES is supportive of the ICZM
approach to coastal management (under RPO 7.3), no other climate adaptation measures are put

iew
forward with the Climate Action Regional Offices (CARO’s hereafter) being identified as responsible
for planning and for devising actions on Climate Change mitigation and adaptation in their regions
(EMRA RSES, 2019). The EMRA RSES also identifies the potential (and benefits) of synergies between
adaptation measures and other objectives by expressing support for the development of guidance
for assessing land zonings to achieve appropriate riparian setback distances as a means of creating

v
multi-purpose buffer zones (EMRA RSES, 2019). No adaptation measures are prioritised in the EMRA
RSES and there are no details on how adaptation will be monitored.

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The Southern Regional Assembly Regional Spatial and Economic Strategy (SRA RSES hereafter); The
SRA RSES begins by asserting that it prioritises action on climate change across all strategic areas and
in all sectors (SRA RSES, 2019) and a commitment is given to achieve NSO 8 of the NPF at regional
level (SRA RSES, 2019). The central role of the planning system in coastal and marine management
er
and climate change adaptation is also acknowledged (SRA RSES, 2019). The SRA RSES sets out the
effects anticipated for Ireland from our warming climate and while it notes that they will have a
stark impact on the southern region, scenario planning is not included (SRA RSES, 2019). A
commitment is given in the strategy to take the precautionary principle into account when managing
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flood risk and marine / coastal areas. Vulnerabilities to climate change are set out with coastal
erosion and flooding (SRA RSES, 2019) identified as challenges and while there is no reference to
grey or soft climate adaptation measures, the importance of green infrastructure for delivering
multiple benefits (including for flood control / climate action) is noted (SRA RSES, 2019). With
respect to addressing these coastal vulnerabilities, the SRA RSES (in RPO 120) is supportive of
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managing and protecting coastal resources and communities against coastal erosion and it is stated
that land use plans should take account of the risks that it poses (SRA RSES, 2019). Aside from this
measure, the SRA RSES relies on the NAF as the main policy response to building resilience to climate
change and under RPO 88, the SRA is committed to a partnership approach with the CARO’s and the
tn

Local Authorities to support the development of long-term solutions and extensive adaptation
measures (SRA RSES, 2019). According to RPO 89, the SRA also intends to support measures which
‘build resilience to climate change throughout the Region to address impact reduction, adaptive
capacity, awareness raising, provide for nature-based solutions and emergency planning’ (SRA RSES,
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2019). Under RPO 174, the potential of development setbacks for delivering synergies between
adaptation measures and other benefits is demonstrated by the inclusion of a specific objective to
maintain buffer distances between walking, cycling, greenway and blueway corridors and from
coastal areas subject to current and future erosion (SRA RSES, 2019). Adaptation measures are not
prioritised and no mechanisms are provided for monitoring their progress in the SRA EMRA.
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Northern & Western Regional Assembly Regional Spatial and Economic Strategy (NWRA RSES
hereafter). While the NWRA RSES makes no specific reference to mainstreaming climate adaptation
considerations, it states that the region has a major opportunity to play a leading role in Ireland’s
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adaptation to climate change (by utilising natural assets and networks) (NWRA RSES, 2020) It also
acknowledges that the responsibility for meeting the targets set out in the NAF will fall to the NWRA,
the Climate Action Regional Officers, and constituent local authorities. The risks arising from climate
change are set out in the NWRA RSES and they include a (likely) rise in sea levels, changes in rainfall

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 events, higher storm frequencies, air and soil temperature changes and increased drought periods
(NWRA RSES, 2020). While a number of area specific impacts from climate change are also identified

ed
(e.g. in Galway City), planning for different climate change scenarios is not included. With respect to
the precautionary principle, the NWRA RSES supports the integration of biodiversity considerations
in a positive, proactive and precautionary way, but no commitment is included to adopt the
precautionary principle when addressing climate change effects. The NWRA RSES notes the assertion
in the NAF that Ireland is vulnerable to the negative effects of climate change and it accepts its

iew
shared responsibility to manage these risks with national government, the CARO’s and Local
Authorities in the region. Noting the need to respond to climate change vulnerabilities, there is no
reference to the different types of adaptation measures set out in the NAF although the NWRA RSES
includes a presumption against development in areas vulnerable to flooding and rising sea levels (as
part of RPO 9.4) (NWRA RSES, 2020). However, the inclusion of RPO 5.1 demonstrates that the

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NWRA is relying on the CARO’s for the North and West Region to address climate vulnerabilities and
to provide prioritised actions at local level (NWRA RSES, 2020). No details appear to be included in

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the NWRA RSES on the potential for synergies between adaptation measures and other objectives.
In addition, no adaptation measures are prioritised and while a commitment is given to monitoring
the overall strategy (NWRA RSES, 2020), there is no reference to monitoring the progress of the
implementation of any adaptation measures that may arise.
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Assessment of Regional Spatial Strategies in accordance with NAF guiding principles of adaptation:
Each of RSESs were reviewed to assess the extent to which they adhered to the key adaptation
issues and guiding principles highlighted in the NAF and results are set out in table 4.
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References Included on; EMRA RSES SRA RSES NWRA RSES
1 Climate Change Impacts (at National & YES YES YES
Regional Level)
2 Climate Change Scenario Planning NO NO NO
3 Adhering to a precautionary approach NO YES LIMITED
4 Vulnerability Assessment LIMITED* LIMITED* LIMITED*
ot

5 Identify a range of adaptation options (grey, LIMITED LIMITED LIMITED

green and soft measures) (Green Only) (Green (Green Only)
Only)
6 Propose adaptation measures to boost LIMITED** LIMITED*** LIMITED****
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resilience (RPO 7.4) (RPO 120) (RPO 9.4)

7 Potential for synergies between adaptation YES YES NO
measures and other objectives
8 Prioritise Adaptation Measures NO NO NO
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9 Monitor Adaptation Progress NO NO NO

Table 4; Adherence of RSESs to NAF key adaptation issues and guiding principles

All of the RSES’s presented the anticipated impacts of climate change at national level, but to varying
degrees at regional level and none looked at scenario planning for climate change effects. The
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importance of taking a precautionary approach to climate change at regional level on the basis of
current evidence was confirmed in one RSES (SRA RSES). With respect to the assessment of regional
vulnerabilities, all RSES’s demonstrated a reliance on the existing flood management guidance in the
Catchment Flood Risk Assessment & Management Programmes (CFRAM’s hereafter). There was also
a limited discussion of the available options for adaptation in each of the RSES’s. While all referred
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to the desirability of incorporating green measures (such as green infrastructure and ecosystem
services approaches) into planning and development, none referred to grey infrastructure measures
or the potential of soft adaptation measures (such as land management controls) to enable climate

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 change adaptation. Two of the RSES’s (EMRA & SRA RSES) included measures with the potential to
achieve multipurpose ‘win win’ outcomes that is sought in the NAF with the EMRA RSES proposing

ed
buffering along rivers and watercourses and the SRA RSES seeking buffers along coastlines
vulnerable to erosion. None of the RSES’s recommended that Local Authorities adopt a more
proactive land management approach in coastal (or other) areas. Finally, 2 of the 3 RSES’s expressly
recognised the potential for delivering synergies between adaptation measures and other objectives
(such as biodiversity and habitat retention). In addition, no adaptation priorities were identified in

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the RSESs and none gave a commitment to monitor or review progress on adaptation.

4.0 Discussion & Conclusion

4.1 Discussion

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Although the immediate and longer term challenges facing Irelands coastline from a warming
climate are acknowledged and reflected in current strategies (such as the NAF), the review

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demonstrates that there have been repeated (but unheeded) calls for a national coastal
management strategy in addition to a national level awareness of coastal climate change effects
since at least 1992. With initial concerns about the coastline focussed on erosion, guidance
published in 1997 recommended that land use planning measures (in the form of development
setbacks) be adopted in coastal areas to respond to anticipated challenges arising from climate
er
change. Despite this recommendation, only a very small number of coastal Local Authorities used
development setbacks for protecting the coast and the guidance was not included in the first
national level spatial plan (the NSS) in 2002. While further recommendations on managing coastal
areas to cope with a changing climate were made in 2003, there is also scant evidence to suggest
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that these later recommendations were adhered to by Local Authorities. This illustrates that there
was weak integration between government guidelines and spatial planning strategies with respect to
managing Irelands coastline between 1992 and 2017.

The stated purpose of the 2018 statutory national adaptation plan (NAF) was to ensure that climate
considerations are mainstreamed into all local, regional and national level policy making. It included
ot

9 guiding principles which were intended to inform all statutory plans and guidance. However, the
level of adherence to these guiding principles by the Irish spatial planning strategies at national and
regional level has been found to be low. While the national level spatial plan (the NPF) provides a
tn

commitment to integrating climate action into the planning system, its adherence to the NAF guiding
principles with respect to adaptation planning in coastal areas is considered to be limited. Although
the NPF anticipates climate change effects, adheres to the precautionary principle and
acknowledges the vulnerability of the coastline, it does not set out the full range of adaptation
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options, propose measures to boost resilience or identify synergies between adaptation and other
objectives. In addition, no coastal adaptation measures are prioritised and no guidance is included
on monitoring progress on adaptation. This means that the NPF cannot comply with 5 of the 9 NAF
guiding principles with respect to adaptation. A further weakness at national policy level relates to
the lack of clarity on the sub national planning mechanism that will be used to deliver coastal
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management in Ireland – despite the urgency and severity of anticipated impacts on the coastline.
The capacity of the National Development Plan (NDP) to enable coastal adaptation is also limited
with few specified funding provisions identified in it for this purpose.
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The review also reveals that regional level planning policies could be improved as there are
significant differences in the extent to which each of the RSES’s adhere to the NAF’s guiding
principles for adaptation. The SRA RSES achieves full or partial compliance with the criteria in 6
categories (with full compliance in 3) while the EMRA RSES fully or partly satisfies the requirements

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 of 5 of the 9 criteria (with full compliance in 2). In contrast, the NWRA RSES is able to achieve full
compliance in one category and partial compliance in a further 4. The overall guidance on coastal

ed
adaptation at regional level is considered to be weak. While regional climate change effects are
(generally) covered, there is minimal identification of climate change vulnerabilities beyond the
flood risks identified in the CFRAMs and ICPSS. The range of adaptation options available to Local
Authorities are not fully presented and very few adaptation measures are proposed. Finally, no
adaptation priorities are identified. Given that planning legislation requires all levels of the planning

iew
process to address climate change (DHP&LG, 2018) and that it is a NAF requirement that the guiding
principles for adaptation must inform adaptation planning at regional (as well as sectoral, local and
individual) level, the implication of this finding is that the adaptation planning at regional level is
generally weak. This is despite the fact that it forms the middle tier of spatial planning governance
that links the NPF and the County, City Development Plans (DCCAE, 2018) at local level. This finding

v
undermines a key requirement of the NAF which is to mainstream climate change adaptation
policies at all levels of governance – national, regional and local. In addition, the absence of

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meaningful adaptation actions to mitigate against climate change vulnerabilities is a feature of the
national and regional spatial planning strategies covered in this review. Although the NAF urges
Local Authorities to seek ‘win win’ outcomes by adopting land management roles to acquire flood
prone lands (to enhance biodiversity and use as flooding buffers) as a means of delivering adaptation
solutions, this approach is not advocated in either the NPF or the RSES’s. Similarly, the opportunity
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identified in the NAF to adopt ‘no regrets’ approaches such as managed retreat in coastal areas at
risk of erosion is not presented in the NPF or the RSES as far less prescriptive and loosely worded
objectives are favoured.
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The findings reveal that a number of themes have persisted in coastal management in Ireland over
the period of interest in this research (1992 to 2023). The absence of a national coastal management
strategy over this extensive period is a key weakness and the mechanisms by which the
management of the coastline will be delivered (particularly at subnational level) remain unclear. In
addition, it is notable that where guidance on managing climate change impacts on the coastline (in
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the form of ‘soft’ measures such as development setbacks) has been provided, there is evidence to
demonstrate that it has not been adhered to in national, regional or local spatial planning policies. It
is further noted that despite the consensus view that the negative climate change effects on coastal
areas are already happening and will become more severe in the future, the measures that are
tn

proposed to deal with these threats have become more vague and less prescriptive over time. This
approach by the Irish government to dealing with coastal adaptation presents a sharp contrast with
their handling of other priority issues in Ireland such as climate mitigation and providing additional
housing. With climate mitigation, the approach in Ireland has evolved over time to become highly
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prescriptive and targeted with strenuous attempts to reduce carbon based emissions by requiring
mandatory reduction in fossil fuel usage, the imposition of statutory sectoral carbon budgets and
large budget allocations being made available to deliver these changes (DECC, 2023). The Irish
government response to the housing crisis has become similarly prescriptive with a clear focus on
ramping up the supply of all types of residential accommodation with significant budget allocations
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made to achieve this outcome (DHLG&H, 2021).

4.2 Conclusion

This research paper considers whether climate adaptation considerations have been mainstreamed
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into national and regional level spatial planning policies for coastal areas in Ireland – by measuring
the extent to which the national and regional level spatial plans can adhere to the guiding principles
of the NAF. Noting the importance of a strong policy framework for effective mainstreaming, the

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 findings of the research enable an assessment of whether Ireland has a sufficiently strong policy
framework in place to facilitate climate adaptation in coastal areas and if there is an

ed
‘implementation gap’ between climate adaptation commitments and plans and robust actions.

References Included on; NPF EMRA RSES SRA RSES NWRA RSES
1 Climate Change Impacts (at YES YES YES YES
National & Regional Level)

iew
2 Climate Change Scenario Planning NO NO NO NO
3 Adhering to a precautionary YES NO YES LIMITED
approach
4 Vulnerability Assessment YES LIMITED* LIMITED* LIMITED*
5 Identify a range of adaptation LIMITED LIMITED LIMITED LIMITED
options (grey, green and soft (Green (Green (Green Only)

v
measures) Only) Only)
6 Propose adaptation measures to NO LIMITED** LIMITED*** LIMITED****

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boost resilience (RPO 7.4) (RPO 120) (RPO 9.4)
7 Potential for synergies between NO YES YES NO
adaptation measures and other
objectives
8 Prioritise Adaptation Measures NO
er NO NO NO
9 Monitor Adaptation Progress NO NO NO NO
Table 5; Adherence of NPF and RSESs to NAF key adaptation issues and guiding principles

The review has revealed that current national and regional spatial planning policies cannot provide a
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sufficiently strong policy framework to facilitate effective climate adaptation in Irish coastal areas. It
is considered that the lack of a national coastal management strategy and the failure of current
national and regional spatial planning strategies to adhere to existing coastal land use management
guidance have weakened the policy framework for coastal areas and undermined the capacity of
stakeholders to make progress on planning and implementing coastal adaptation responses. The
weakness of the policy framework is compounded by the inability of the NPF and the RSES’s to fully
ot

adhere to the guiding principles of the NAF for climate change adaptation in coastal areas. It is also
significant to note that the guiding principles that the NPF and RSES’s can either fully or partially
comply with are all concentrated on presenting climate change impacts and identifying
tn

vulnerabilities with limited attention paid to proposing meaningful measures (or specific adaptation
actions) that could be construed as responses to challenges arising from climate change effects in
coastal areas (table 5). This feature of the NPF and RSES’s has two notable implications. Firstly, it
significantly limits the usefulness of the guidance on coastal adaptation that these national and
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regional spatial planning strategies can provide to other stakeholders (such as the Local Authorities
and the CARO’s) who are preparing statutory plans and climate action strategies at regional, county,
city and local level. Secondly, as few specific adaptation responses are proposed (or prioritised) to
address coastal climate change vulnerabilities, it hinders other stakeholders at regional, county, city
and local level who are required to plan, implement and monitor adaptation solutions. It also
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restricts their ability to bridge the implementation gap on climate adaptation and move from
planning to action. While the Irish experience is consistent with what is happening elsewhere in
Europe, it clearly demonstrates that the weak policy framework undermines the effective
mainstreaming of climate considerations into national and regional spatial planning strategies and
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that it is likely to be contributing to the ‘implementation gap’ that is visible between climate
adaptation commitments and plans and robust actions in Irish coastal areas.

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This preprint research paper has not been peer reviewed. Electronic copy available at: https://ssrn.com/abstract=4729469