The National Development Plan will have a mostly negative impact on the environment, the national trust body, Duchas, has warned.
In a submission to the Cabinet sub-committee monitoring implementation of the plan, the body said it had serious concerns about the impact of the plan on greenhouse gases, forestry, agriculture, transport, energy, waste and on the rural and urban environment. It also claimed elements of the plan may breach the minimum requirements of European Community law.
"Little or inadequate progress is evident in relation to transport demand management, the stabilisation and reduction of greenhouse gas emissions, the preparation of a timely and strategic physical planning framework and the application of the polluter-pays principle in relation to domestic water and waste treatment," the submission states.
Released under the Freedom of Information Act, the paper says the plan fails to integrate the "environmental agenda" into its key policies.
The chairman of Duchas, Mr Michael Smith, said its concerns were not addressed by the Department of Finance, which is managing expenditure of £40.59 billion in the 2000-2006 plan.
This was denied by a Department spokeswoman. "We wouldn't accept the contention that there has been no environmental assessment in the national development plan."
Mr Smith said: "The universal perception amongst environmentalist and non-governmental organisations is that the Department of Finance pays attention to the economic and social sectors and next to none to the environmental sector. We've got no substantive response from the Department of Finance to the document." The paper was presented to Government last April.
It said: "Despite the supposed commitment to regional democracy through devolution, the new regional bodies remain marginalised with no certainty that they will have teeth or significant spending powers. And the plan has not been subjected to a proper and comprehensive ex-ante evaluation with regard to the environmental dimension." On possible breaches of EU law, it claimed there was a "comprehensive failure" to appreciate obligations to assess the plan under new criteria. These included elements of the Treaty of Amsterdam and a General Regulation on Structural Funds for the 2000-2006 period.
Duchas said it could accept the goals of the plan: to lay the foundations for future growth; to make the economy more competitive; to foster balanced regional development and social inclusion.
However, it added: "Unfortunately environmental considerations and the potentially guiding principle of sustainable development have not imbued these strategies and were not made strategic objectives of the plan."
Among its overarching concerns, Duchas alleged the plan failed to integrate sustainability across all sectors.
"The Department of Finance does not seem to have been well-disposed towards formulation of environmental objectives for the new national development plan and thus an opportunity to develop indicators within the plan was missed."