Participation Under Pressure: Land Use Planning in Ireland and Serbia

Abstract

Public participation in planning, though a foundational democratic principle, faces persistent implementation challenges across diverse planning systems. This paper examines participatory planning practice in Ireland and Serbia—two countries representing distinct planning traditions (discretionary and conformance-based, respectively) yet confronting shared structural pressures. Through comparative analysis of four local land use planning instruments (the Development Plan and Local Area Plan in Ireland; the Municipal Spatial Plan and General Regulation Plan in Serbia), the study investigates how institutional design and legislative frameworks shape the depth and quality of participatory practice. Methodologically, the research triangulates statutory regulations, public hearing documentation, and non-statutory participation records across two planning scales (county/municipal and local/sub-municipal). A four-dimensional analytical framework—informing, consultation, collaboration, and monitoring—guides the systematic comparison of participatory mechanisms across the selected cases. Findings reveal that, while both systems remain predominantly at the informing and consultation levels, critical differences emerge in how participation is structured and documented in institutional practice. Ireland’s discretionary system enables multi-channel information dissemination, feedback-oriented consultation, and non-statutory collaborative experimentation beyond legal minimums. Serbia’s conformance-based system confines participation largely to statutory procedures, with objection-based consultation and limited collaborative mechanisms, though distinctive features, such as the public hearing session, provide direct opportunities for deliberation absent in the Irish context. The study contributes to European comparative planning scholarship by demonstrating that participatory depth is shaped less by the formal existence of legal provisions than by the interplay between institutional design, procedural arrangements, transparency, and responsiveness.

1. Introduction

Public participation in planning is widely recognised as a cornerstone of democratic governance and a fundamental mechanism for negotiating collective values and spatial futures [1,2,3]. Yet participation increasingly unfolds under conditions that systematically constrain its democratic potential: neoliberalisation reconfigures planning as market facilitation [4], democratic backsliding weakens accountability structures [5], and technocratic depoliticisation narrows participation to procedural compliance [6,7]. These pressures risk reducing participation to consultation fatigue or to the legitimation of predetermined development agendas [8].

However, global political-economic forces do not determine participatory outcomes in isolation. As the wider planning literature highlights, the form, quality, and effectiveness of participation depend fundamentally on institutional design, power relations, and democratic commitments embedded within specific planning systems [9]. Beyond external constraints, the internal dynamics of participation itself, i.e., the networks formed, relationships cultivated, knowledge exchanged, and power negotiated among planners, officials, and citizens, ultimately shape whether participatory processes enable genuine democratic engagement or reproduce existing hierarchies [10,11].

Strengthening participatory planning has gained prominence not only in scholarly debates but also in global policy frameworks. The United Nations Sustainable Development Goal 11.3.2 explicitly calls for monitoring the “proportion of cities with a direct participation structure of civil society in urban planning and management that operate regularly and democratically,” establishing participatory planning as a measurable commitment within the 2030 Agenda for Sustainable Development [12]. Similarly, the New Urban Agenda [13] emphasises inclusive urban governance and stakeholder participation as essential for sustainable urban development. European policy frameworks, including the Territorial Agenda 2030 [14], New Leipzig Charter [15] and the Urban Agenda for the EU [16], further reinforce participatory planning as a governance imperative.

Given the variety of planning traditions [17], planning systems [18,19,20,21,22,23] and planning cultures [24] in Europe, implementation of the previously mentioned policy commitments underscores the urgency of understanding how participation functions across diverse institutional contexts. Such a viewpoint is used as a cornerstone of this research: informed by transnational policy frameworks and burdened with globally adverse effects of urban neoliberalisation, land financialization, and democratic backsliding [25,26,27], European countries confront mounting demands for more inclusive and dialogical forms of participation [28,29,30,31]. However, it is precisely the structural conditions that fundamentally influence the degree of success of participatory planning. Despite growing comparative planning scholarship in Europe, systematic analyses of how contrasting planning system typologies shape the depth and quality of participatory practice remain scarce [32]. This gap limits our understanding of the structural conditions under which participation moves beyond procedural compliance toward genuine citizen influence.

To address such a gap, this paper examines local land use planning in Ireland and Serbia as two contrasting yet strategically comparable contexts. Ireland operates within a discretionary planning tradition characterised by formally institutionalised public consultation embedded in a hierarchical system of development plans with statutory procedures for public input [33,34]. Serbia’s planning system, conversely, inherits a post-socialist legacy in which participation was normatively embedded through self-management principles and legally mandated public hearings, yet implementation frequently fell short of enabling genuine citizen influence [35]. Despite their distinct planning traditions, both countries face analogous structural pressures from neoliberal development dynamics [28,36,37], financialisation of land [38,39], and growing public disillusionment with formal planning processes [31]. These pressures have increasingly oriented both planning systems toward market-led development—albeit with differing degrees of state control—shifting spatial planning toward a neo-performative domain, where project-driven logic prevails over plan-led governance [21]. Accordingly, the paper aims to examine how these shared contemporary pressures, mediated by distinct institutional logics [40,41,42], shape the depth and quality of participatory practice in the interplay among institutional design, procedural arrangements, transparency, and responsiveness. It addresses two core research questions: (1) How do institutional structures influence participatory practices in spatial planning? (2) To what extent do discretionary and conformance-based planning systems produce different forms of public participation? In answering these, the paper contributes to European comparative planning scholarship by identifying the institutional mechanisms through which planning systems enable or constrain democratic participation.

Several foundational frameworks conceptualise public participation as a continuum of citizen influence. Arnstein’s [43] ladder distinguishes non-participation, tokenism, and citizen power, demonstrating that formal compliance with participatory requirements often fails to deliver genuine citizen influence. Rowe and Frewer [44] refine this by distinguishing communication (one-way, sponsor-to-public), consultation (one-way, public-to-sponsor), and participation (two-way exchange). Fung’s [45] ‘democracy cube’ adds dimensionality through participant selection, communication modes, and authority wielded. The IAP2 [46] spectrum identifies five ascending levels, ranging from informing to empowerment, each linked to distinct institutional commitments and power-sharing arrangements.

Drawing on these frameworks, this study employs a four-level analytical framework—informing, consultation, collaboration, and monitoring—synthesising established typologies while adding monitoring as a distinct participatory dimension, i.e., recognising the importance of transparency in how input influenced decisions. Monitoring is introduced as a distinct dimension to capture the feedback loop between participation and decision-making. Unlike general participation, monitoring refers to mechanisms that demonstrate how public input is considered and integrated into planning outcomes, offering the public direct insight into final decisions on their formal submissions.

• Informing: one-way communication providing citizens with information about planning processes and involvement opportunities (e.g., public notices, plan documents, information sessions, digital communication).
• Consultation: two-way communication in which citizens provide feedback while decision-making authority remains with planning authorities (e.g., written submissions, public hearings, surveys, drop-in sessions).
• Collaboration: partnership with shared decision-making power in developing planning solutions (e.g., workshops/charrettes, working groups, participatory budgeting, co-design, consensus-building).
• Monitoring: mechanisms that ensure transparency about how inputs influence decisions and enable ongoing oversight of implementation (e.g., publication of submissions and responses, process reports, feedback to participants, accountability structures).

The paper is structured as follows. The introduction is followed by a brief methodological section. The central part of the paper first provides contextual background on the Irish and Serbian planning systems, tracing their institutional development, legal and regulatory frameworks, and participatory traditions, and then presents empirical analyses of Irish and Serbian cases, examining participation across the four dimensions. The discussion offers a comparative overview of context-specific characteristics, strengths, and limitations, while identifying cross-national patterns and divergences in enabling or constraining participation in planning.

2. Methodology

This study employs a comparative, multi-scalar analysis of public participation in spatial planning processes in Ireland and Serbia. These countries were selected as comparative cases based on their analytical complementarity across several dimensions. First, they represent traditionally contrasting planning system typologies: Ireland operates within a discretionary tradition, while Serbia follows a conformance-based model rooted in post-socialist institutional legacies [17]. This distinction is analytically productive because it allows examination of how different regulatory logics shape the scope and depth of participatory practice. Second, both systems formally mandate public participation in local land use planning yet exhibit persistent gaps between statutory provisions and participatory outcomes, suggesting that legal frameworks alone do not fully account for the depth of participation [31]. Third, within the latest classification of European planning system families [21] (with Ireland belonging to the so-called state-led planning system and Serbia to the proto-conformative system), both countries show signs of being currently overwhelmed by the rising trend of neo-performative planning. Providing sufficient common ground to make the comparison analytically meaningful, these criteria also enable the identification of how distinct institutional structures mediate participatory outcomes.

The research focuses on four representative planning instruments—the Development Plan and the Local Area Plans in Ireland, and the Municipal Spatial Plan and the General Regulation Plans in Serbia—selected as typical cases that reflect established participation practices across different planning levels (county/municipal and local/sub-municipal). These instruments were selected for their institutional relevance and comparability in framing citizen engagement within each country’s planning system.

The selection of case studies followed criteria to ensure comparability and consistency across the analysis. First, cases were selected by territorial level, focusing on plans developed at similar administrative scales. Second, cases were selected based on the plan typology. Thus, a Development Plan covers the County level, which is a local self-government unit, similar to the Municipal Spatial Plan in the Serbian context. At the same time, a Local Area Plan and a General Regulation Plan constitute sub-level plans, covering parts of a city. Third, alongside their representativeness of standard statutory practice, the selected plans also include instances of non-statutory participation that go beyond legal minimums, enabling the analysis to capture both mandatory procedures and voluntary participatory innovation.

The selected plans span two distinct but analytically compatible temporal windows: the Serbian cases date from 2009–2012 and 2015, while the Irish cases date from 2021 and 2024. Although these periods differ chronologically, both sets of plans were developed under the currently operative planning legislative frameworks in their respective countries, ensuring that the analysis captures participation practices under present institutional conditions. The temporal difference also offers analytical value, as it allows observation of whether more recently adopted plans demonstrate greater participatory ambition in response to evolving European policy commitments. At the same time, we acknowledge that comparisons across different temporal windows must be interpreted with caution: observed differences may partly reflect the distinct policy and reform contexts of each period rather than enduring features of the respective planning systems, and we have accordingly framed our comparative claims as indicative rather than definitive.

Data collection was carried out using publicly available sources in both case study contexts. In Ireland, planning documents and related materials were accessed through publicly available official websites. In Serbia, data were obtained from two main sources: the Central Registry of Planning Documents, which provides a database of spatial and urban plans, and the Index of Participation database, which includes information on participatory processes associated with planning documents. The core analysis focused on the four plan documents themselves and their accompanying participatory processes across the informing, consultation, and collaboration phases. Additional data, including records of public hearings held and documentation of submissions received—identifying which were adopted and which were rejected—were used to assess the depth and responsiveness of consultation and monitoring practices.

Methodologically, the study follows a narrative analysis of planning documents, situating each case within its broader governance and regulatory frameworks. The analysis integrates the legal, procedural, and discursive dimensions of participation, enabling a holistic understanding of how participatory mechanisms are structured and operationalised. Data triangulation was achieved through a systematic review of formal legislation and planning regulations, official records from public hearings, and available documentation of non-statutory participation practices.

The analytical process was guided by a conceptual model of participation encompassing four progressive levels—informing, consultation, collaboration, and monitoring—which served as an interpretive framework for identifying and comparing participatory practices. Within this framework, the study traced specific indicators across the selected documents, focusing on (1) mechanisms of information dissemination, (2) procedures and tools for public consultation, (3) evidence of collaborative planning activities, and (4) approaches to monitoring and feedback. To ensure systematic comparability, each case was analysed using an identical analytical template structured around these four dimensions, allowing consistent identification of practices across both national contexts despite differences in institutional terminology and procedural conventions. This systematic tracing enabled a comparative understanding of institutionalised participation and its contextual adaptations within the two contrasting governance systems.

As a qualitative comparative study based on four cases, the findings are not intended as statistical generalisations but rather as analytically transferable insights [47] into how institutional structures shape participatory practice. The cases illuminate mechanisms and patterns that can inform analysis of comparable planning systems across Europe, while recognising that case-specific circumstances inevitably shape individual outcomes.

3. Findings: Participatory Planning in Ireland and Serbia

The subsequent section provides an in-depth examination of the participatory planning process in the two selected countries. The analysis is structured around four key dimensions of participation in a planning process, as previously introduced in the conceptual overview: informing, consultation, collaboration, and monitoring, applied to four cases: two higher-tier plans (the Fingal County Council Development Plan and the Spatial Plan for the part of Surčin Municipality) and two lower-tier plans (the Flemington Local Area Plan and the General Regulation Plan of Palilula Municipality). To contextualise this multi-scalar analysis, we first present a concise overview of: (1) the societal context, (2) legal/regulatory frameworks of governing planning participation, and (3) the general public participation procedure, in both Ireland and Serbia.

3.1. Ireland: Participatory Planning in a Discretionary System

Contextual features. The country’s planning culture has been shaped by its post-colonial relationship with Britain and by its integration into the European Union from 1973 onwards, which introduced European spatial planning concepts and participatory governance norms [36]. The late 20th and early 21st centuries saw significant transformations in Irish planning practice. The ‘Celtic Tiger’ economic boom (1995–2007) brought rapid urbanisation and development pressures, characterised by pro-development policies and accelerated decision-making processes [48]. This was followed by the 2008 economic crisis and subsequent austerity measures imposed as conditions of the EU-IMF (European Union-International Monetary Fund) bailout [49]. This period exposed tensions between development-led growth policies and planning regulation, raising questions about the effectiveness of public participation mechanisms in moderating speculative development [50].

The post-crisis period has witnessed growing civic mobilisation around planning issues, particularly housing affordability, urban densification, and climate action, alongside debates about the balance between democratic input and efficient decision-making in the planning system [33]. Civil society organisations, residents’ associations, and community groups have become increasingly active in planning processes, utilising statutory consultation mechanisms and third-party appeal rights. However, participation remains uneven across different socio-economic groups and geographic areas, with concerns about the accessibility and inclusiveness of formal consultation procedures.

Planning legislation and regulations. Unlike the planning systems of continental Europe, the Irish planning system is discretionary in nature and most closely resembles the British typology [51]. The right to develop land or property is controlled by the state through the development management process, which requires applicants to lodge planning applications with the relevant local planning authority. However, Ireland’s planning legislation has been consolidated into a single comprehensive statute: the Planning and Development Act 2024 [52] governs the planning system and establishes statutory provisions for public participation, distinguishing between plan-making (a reserved function of elected councillors in creating city and county development plans) and development management (an executive function of planning officials in handling individual planning applications).

Complementing the primary legislation, statutory regulations provide detailed procedural requirements for public consultation, including notification methods, timeframes, and documentation standards. Government-wide Consultation Principles and Guidance [53] established overarching standards for public consultation processes across policy-making and legislative development, including planning. Additionally, sector-specific guidance documents, such as those issued by the Office of the Planning Regulator, provide best practice recommendations for conducting meaningful public engagement in plan-making processes. The statutory framework establishes mandatory consultation stages for both development plans (pre-draft consultation, draft plan display, and material alterations) and development management (public notice requirements and third-party appeal rights to An Bord Pleanála, the independent planning appeals board).

Public participation procedure. The 2024 Planning and Development Act [52] outlines the statutory process for public engagement and feedback on draft planning documents, varying by planning document type. County Development Plans involve public engagement in two main stages: both an 8-week pre-draft and draft phase, with an additional 4-week consultation if material amendments are proposed. Local Area Plans (LAPs) require a 6-week draft consultation period, followed by an additional 4 weeks for major post-draft changes. In practice, non-statutory pre-draft consultation phases for LAPs have become widely adopted by local authorities across Ireland, providing opportunities for early-stage citizen and community input to inform the preparation of draft plans [54]. For development management, applicants must publish site notices and newspaper notices inviting submissions within a specified period (typically 5 weeks). Those who submit to the local planning authority may appeal decisions to An Bord Pleanála, the independent planning appeals board, thereby providing third-party appellants with a mechanism to challenge decisions beyond the initial consultation phase.

During statutory consultation periods, the public can review draft plans online and at designated locations and may submit written observations and submissions. Local authorities publish all submissions received online. Upon the conclusion of each consultation phase, the Chief Executive prepares a statutory report that responds to all submissions and observations, together with recommendations on whether submissions should shape or modify the plan. The Chief Executive’s report does not provide individual replies; instead, it aggregates and analyses the issues raised, categorising submissions by theme or Development Plan chapter. Major statutory bodies receive detailed, standalone treatment. The report summarises key issues—for example, grouping recurring concerns under single headings—before presenting the Chief Executive’s formal opinion, citing relevant national policy or technical evidence, and clear recommendations indicating whether the plan should be amended or remain unchanged. Each recommendation is assessed for compliance with Specific Planning Policy Requirements and national guidelines; submissions may be rejected if they conflict with statutory obligations. Local elected councillors consider all submissions and the Chief Executive’s recommendations during the adoption process, deciding whether to accept, modify, or reject these recommendations.

Informal public consultation may occur alongside statutory procedures. A survey research indicates that Irish local authorities employ various informal consultation methods, including in-person public meetings (79% of authorities), community workshops (75%), social media engagement (71%), and online surveys (67%); however, only 44% of local authorities report following a recognised policy framework for non-statutory engagement, with innovation relying more on individual initiative than institutional strategy [54]. Finally, although being informal, public consultation is still regulated through various documents, such as the Development Plans Guidelines for Planning Authorities [55] and the Guide for Inclusive Community Engagement in Local Planning and Decision-Making [56].

3.1.1. Fingal County Council Development Plan

The Fingal County Development Plan, prepared in 2021, followed a two-stage statutory public participation process comprising an 8-week pre-draft phase and a 10-week draft phase, with an additional 4-week consultation period for material amendments. The participatory procedure, comprising four key phases (informing, consultation, collaboration, and monitoring), as well as the nature of participation (statutory/non-statutory), is described in

Table 1. Public participation in the Fingal County Development Plan. Source: Authors based on various sources.

Participation Level	Statutory Participation	Non-Statutory Participation
Informing	Pre-draft: Public notice: Fingal Independent, Irish Independent, The Herald, Gazette, North Side People, 12 March 2021 Draft: Public notice on plan-making Draft plan available digitally and in analogue format	Pre-draft: Strategic Issues Paper and Information Booklet: printed and online, circulated to all county households Dedicated webpage: www.fingal.ie/developmentplan (accessed on 26 March 2026) Social media campaign: Twitter, Facebook, Instagram, LinkedIn, YouTube (video clips, consultation updates, webinar recordings) Podcasts and article in Fingal News e-zine (Issue 18, pages 4–5) Four online thematic webinars: April 2021 (recordings available) Posters at bus stops throughout county Draft: Draft Development Plan webinar: 22 March 2022 (recording available online)
Consultation	Pre-draft: Online portal for themed submissions Public submissions: available in full via Fingal Consultation Portal Draft: Public submissions	Pre-draft: Online portal for themed submissions Draft: Drop-in sessions (4 p.m.–8 p.m.): County Hall Swords (31 March 2022), Blanchardstown Library (5 April 2022), Malahide Library (20 April 2022), Bracken Court Hotel Balbriggan (21 April 2022)
Collaboration	/	Pre-draft: Three councillor briefing workshops: 30 November 2020, 27 January 2021, 2 February 2021 (plan-making process, elected member role, environmental assessment) Consultation with prescribed bodies and other stakeholders Minecraft event for young people focused on Rogerstown Estuary area redesign (green spaces, bike paths, biodiversity, community facilities)
Monitoring	Chief Executive Report addressing submissions (pre-draft, draft and post-draft phases) Full submission published via Fingal Consultation Portal	Webmap: Fingal County Development Plan 2023–2029 [57]

.

Several observations warrant attention regarding Fingal’s participatory process. The statutory response process encompassed three formal Chief Executive’s Reports, each corresponding to a different consultation stage of the Development Plan 2023–2029. The first report addressed pre-draft submissions, outlined initial issues, and recommended policy directions [58]. The second report reviewed public and stakeholder feedback on the Draft Plan, including approximately 2000 submissions, and provided chapter-specific recommendations [59]. The third report evaluated submissions on the Proposed Material Alterations and provided refined recommendations prior to the plan’s adoption [60].

Fingal County Development Plan demonstrates a variety of non-statutory forms of participation. Notably, the Minecraft event for young people proved particularly successful, with high demand necessitating a second session with participants focused on design solutions for the Rogerstown Estuary area [58]. The geographically distributed drop-in sessions during the draft phase were scheduled from 4 pm to 8 pm to accommodate working residents [59]. The multi-channel information dissemination strategy, combining both digital and analogue formats, aimed to reach diverse demographic groups across the county. The publication of all written submissions in full through the Fingal Consultation Portal exceeded statutory transparency requirements.

Taken together, Fingal’s participatory process illustrates how a discretionary planning system enables layered participation that extends well beyond statutory minimums. The combination of multi-channel communication, digitally accessible submissions, and targeted engagement with harder-to-reach groups (notably young people through the Minecraft initiative) reflects an institutional culture oriented toward broadening both the reach and quality of participation. However, despite this breadth, the participatory architecture remained predominantly structured around informing and consultation: citizens could voice preferences and submit feedback, but collaborative mechanisms enabling shared decision-making authority over plan content were largely absent.

3.1.2. Flemington Local Area Plan

The Flemington Local Area Plan, prepared in 2024, followed a one-stage statutory public participation process comprising a 6-week draft phase, with no additional consultation period due to the low number of submissions received. Informal pre-draft participation was enabled. The participatory procedure, comprising four key phases (informing, consultation, collaboration, and monitoring), as well as the nature of participation (statutory/non-statutory), is described in

Table 2. Public participation in the Flemington Local Area Plan. Source: Authors based on various sources.

Participation Level	Statutory Participation	Non-Statutory Participation
Informing	Draft: Draft plan available for inspection: 10 September–22 October 2024 Physical locations: Civic Offices Blanchardstown, County Hall Swords (weekdays 9 a.m.–5 p.m., Fridays until 4:30 p.m.) Online portal [61]	Pre-draft: Issues Paper Leaflet Draft: Physical locations: Balbriggan Library (during opening hours)
Consultation	Draft: Submissions (online and written): 22 received [62]	Pre-draft: Public information drop-in session: Hamilton Suite, Bracken Court Hotel, Balbriggan, 13 February 2024 (4 p.m.–7 p.m.) Submissions (online and written): 16 received [63] Draft: Information day drop-in session: Flemington Community Centre, Hamlet Lane, Balbriggan, 18 September 2024 (4 p.m.–7 p.m.)
Collaboration	/	/
Monitoring	Chief Executive Report addressing submissions on the draft LAP Full submission published via Fingal Consultation Portal

.

The Flemington Local Area Plan demonstrates the widespread practice among Irish local authorities of conducting non-statutory pre-draft consultations for Local Area Plans, extending beyond statutory requirements to enable early-stage participation and feedback gathering. However, the participatory mechanisms employed remained primarily within the informing and consulting levels. While the Issues Paper, leaflets, and drop-in sessions enhanced transparency and enabled early-stage input, these tools primarily served to disseminate information and gather resident feedback rather than to enable collaborative decision-making or shared authority over planning outcomes. The statutory response process encompassed one formal Chief Executive’s Report on the draft Flemington LAP [64].

The modest increase in submissions from 16 (pre-draft) to 22 (draft) raises questions about the reach and effectiveness of engagement strategies, particularly given that Flemington is a growing area with substantial new residential development [62,63]. The reliance on traditional participation methods—physical inspection of documents, drop-in sessions, and written submissions—may limit accessibility for certain demographic groups, including younger residents, non-native English speakers, or those with limited time availability [61]. The absence of collaborative mechanisms, such as workshops, co-design sessions, or ongoing community forums, suggests that participation was structured to inform plan content rather than to empower residents as active partners in shaping the future development of their local area. This pattern suggests that even within a discretionary system that encourages participatory innovation, smaller-scale plans may default to conventional consultation formats, raising questions about whether institutional flexibility translates into participatory depth consistently across all planning levels.

3.2. Serbia: Participatory Planning in Transition

Contextual features. For most of the 20th century, Serbia (first as part of Yugoslavia and then as an independent state) was a socialist state with a centrally planned economy. During the socialist period, planning was characterised by technocratic, top-down decision-making with limited opportunities for public participation, though Yugoslavia’s self-management system did provide some channels for worker and local community involvement in certain development decisions [28,65].

In late 2000, Serbia established a democratically elected government for the first time in more than half a century, marking the start of a pluralist political culture and a re-decentralisation of power. The embrace of political pluralism and European integration processes created normative pressures to adopt international standards of public participation in planning [66]. However, the transition period was marked by the absence of appropriate measures, institutional capacity, and political reforms in embracing a market-driven economy, resulting in ‘growth without development’ [67]. In addition, Serbian society has been described as a ‘proto-democracy’ [68], with a legacy of technocratic planning culture, low trust in public institutions, and limited civil society capacity following decades of authoritarian rule, creating substantial challenges for the establishment of meaningful participatory mechanisms.

Planning legislation and regulations. The evolution of Serbia’s planning legislation reflects shifting approaches to public participation since 2000. The 2003 Planning Act [69] removed the requirement for expert debate and abolished provisions for informing the public of the commencement of public consultation procedures, leaving only deliberation among members of the Planning Commission, which is responsible for approving various planning instruments. This represented a significant reduction in the number of participatory mechanisms compared with previous legislation [70]. The 2009 Planning Act [71] maintained limited participatory provisions, with public participation primarily confined to statutory public hearing procedures during which citizens could submit written objections to draft plans. A 2014 amendment to the Planning Act [72] introduced ‘early public hearing’ as a new mechanism, allowing citizens to express opinions on planning issues during the initial phase of plan preparation, before formal drafting begins. In addition, the recent by-law introduces a digital early public hearing [73,74]. Recent policy developments have introduced frameworks addressing public policy formulation [75], enhanced citizen participation in local governance [76], municipal capacity development for European Union accession [77], and collaborative arrangements involving public institutions, private sector, civil society, and academic organisations based on multi-level and grassroots governance approaches [78]. However, as Serbian planning operates primarily on the principle of legal conformance rather than performance-based evaluation [42], legal adoption does not guarantee implementation, resulting in a persistent gap between formal participatory requirements and actual practice throughout the post-2000 period [29,79]. In addition to the legal provisions, the Sustainable Urban Development Strategy of the Republic of Serbia until 2030 includes measures to improve participation in planning [80], with its Action Plan and projects focused on building capacity to improve stakeholder participation in spatial and urban planning.

Public participation procedure. According to the relevant planning framework [72], the participation procedure has two steps (an early public hearing and a public hearing) and may be supported through informal participation. An early public hearing follows the formal decision to prepare a spatial or urban plan, prior to drafting. It lasts 15 days and is open to the public. Concurrently, mandatory inputs (“conditions”) are collected from public institutions. Both sources inform the draft planning document. Following the early public hearing, the institution preparing the plan produces a Report on Public Hearing, which the Planning Commission adopts. The plan is developed by a body selected through public procurement. The Planning Commission, established within national or local government, comprises spatial and urban planning experts, with one-third nominated by the ministry responsible for spatial and urban planning.

Public hearing occurs once the Planning Commission has verified the draft plan. The draft is presented to the public for 30 days (or 15 days for abridged procedures or repeated hearings). Abridged procedures apply when minor plan revisions are undertaken under the Planning Act. The public hearing is announced in print and online media, allowing the public to submit objections and comments. A report documenting all submissions is prepared. Before finalising this report, a public session is held at which each response is read aloud, and submitters may discuss their objections or comments with the planning institution and the responsible government body. Since the 2025 by-law amendments, online presentations of responses are permitted. This session has become increasingly well-attended and often serves as a forum for debating divergent viewpoints. Final responses to submissions inform revisions to the draft before plan adoption.

Informal public consultation may occur alongside or independently of statutory procedures. While not widespread in Serbia, informal consultation takes various forms [81]: public presentations at the sub-municipal level, local municipality websites, info-points, exhibitions, and printed promotional materials (information phase); discussion groups with stakeholders and public–private dialogue (consultation phase); workshops and visioning exercises (collaboration phase). These activities are not defined in legal acts but do not contradict them. Both statutory and non-statutory participation can be monitored and measured using the Index of Participation [82], inspired by the UN SDG indicator 11.3.2.

3.2.1. The Spatial Plan for the Part of Surčin Municipality

The Spatial Plan for the part of Surčin Municipality was developed between 2009 and 2012, and the respective participatory planning procedure was implemented under the 2009 Planning and Construction Act, prior to the 2014 amendments that introduced the early public hearing mechanism. Consequently, the participatory process comprised a single statutory stage: a 30-day public hearing on the draft plan, accompanied by a public session organised by the Planning Commission. This case, therefore, represents the participatory framework that preceded the introduction of the two-stage consultation model currently in force. The participatory procedure, comprising four key phases (informing, consultation, collaboration, and monitoring), as well as the nature of participation (statutory/non-statutory), is described in

Table 3. Public participation in the Spatial Plan for the part of Surčin Municipality. Source: Authors based on various sources.

Participation Level	Statutory Participation	Non-Statutory Participation
Informing	Public notice: daily newspaper Blic, 26 January 2015 Draft plan on public view: local self-government unit and urban municipality of Surčin premises, 26 January–26 February 2015 Direct notification to selected national and local public institutions	/
Consultation	Public session of the Planning Commission: 26 March 2015 Total submissions: 38 (13 from public institutions; 25 from individuals and private enterprises) Total objections: 122 (23 submissions with single objection; 15 submissions with multiple objections) Objection outcomes: 65 accepted, 24 partially accepted, 23 rejected, 10 irrelevant	/
Collaboration	/	/
Monitoring	Report on Public Hearing: verified by Planning Commission of the City of Belgrade, 26 March 2015 [83]	Report delivered to Central Registry of Planning Documents

.

Several observations merit attention. First, the public hearing was announced in the daily newspaper two days after its commencement. Second, the Report on Public Hearing bears the same date as the Planning Commission’s public session (26 March 2015), suggesting no revisions were incorporated following the session. This indicates the presentation functioned as information dissemination rather than consultation with feedback, representing a missed opportunity for meaningful exchange. Third, the report contains no information on attendance at the public session, leaving the extent of public engagement unclear.

The submission and objection process demonstrates consultation-level participation, where citizens provided input, but final decision-making authority remained with the Planning Commission. Of 122 objections raised, 53% were accepted (fully or partially), 19% were rejected, and 8% were deemed irrelevant. According to statutory requirements, every rejected or irrelevant objection should be explained in the report and during the public session, when interested parties may provide additional clarification to potentially alter the Planning Commission’s response. However, the absence of collaborative mechanisms—such as workshops, working groups, or co-design sessions—meant that participation was limited to submitting objections rather than to shared decision-making or partnership in plan development [83]. Further analysis of objection content would be valuable, including classification by submission type, objection topic, public versus private interest, and the justifications provided for acceptance or rejection.

The Surčin case exemplifies a conformance-based system operating at its statutory baseline: participation was structurally confined to a single, time-limited public hearing with no preparatory engagement phase. The procedural irregularities—late announcement, simultaneous dating of the public session and the hearing report—point not merely to administrative shortcomings but to a deeper institutional orientation in which participation functions as a procedural formality rather than a substantive input into plan-making. The relatively high acceptance rate of objections (53%) suggests that consultation did produce tangible outcomes; yet the absence of any mechanism for dialogue or deliberation prior to the submission of formal objections meant that citizens engaged reactively with a largely finalised plan rather than contributing to its formulation.

3.2.2. The General Regulation Plan of Palilula Municipality

The first draft of the General Regulation Plan of Palilula Municipality (of the City of Niš) was developed in 2015, so the respective participatory planning procedure was implemented under the 2014 Planning and Construction Act, which enabled a two-step public hearing process: an early public hearing was held in 2016, and the public hearing in 2021. The participatory procedure, comprising four key phases (informing, consultation, collaboration, and monitoring), as well as the nature of participation (statutory/non-statutory), is described in

Table 4. Public participation in the Plan of General Regulation of the Palilula Municipality. Source: Authors based on various sources.

Participation Level	Statutory Participation	Non-Statutory Participation
Informing	Early public hearing: Public call for early public hearing: daily newspaper Danas, 5 April 2016 Draft plan on public view: local self-government unit premises, 12–26 April 2016 Public hearing: Public call for public hearing: daily newspaper Srpski Telegraf, 20 January 2021 Draft plan on public view: local self-government unit premises, 20 January–18 February 2021 Updated draft plan on public view: local self-government unit premises, 11–25 February 2022	Poster with plan area boundary displayed in city administration building Information on public hearing posted on city administration information board Professional urban planner available during public hearing for stakeholder inquiries City assembly meeting agenda (including plan adoption) publicly available prior to meeting
Consultation	Early public hearing: No objections or suggestions submitted Public hearing: Public session: 24 February 2021 Public session for repeated public hearing: 9 March 2022 Total submissions: 14 in first procedure, 9 in repeated procedure Regular procedure: 1 submission from group of citizens (attorney-represented), 13 from individuals Repeated procedure: 9 submissions from individuals Objection outcomes: 12 accepted (first), 8 accepted (repeated); 1 rejected (first), 1 rejected (repeated); 1 irrelevant (first), 0 irrelevant (repeated)	Sessions attended by submitters, other interested parties, and media Iterative procedure (early, regular, repeated) enabled interaction and basic cooperation during plan elaboration
Collaboration	/	/
Monitoring	Report on Public Hearing: verified by Planning Commission of the City of Niš, 21 May 2021 [84] and 25 March 2022 [85]	Report delivered to Central Registry of Planning Documents and published on local self-government unit website

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Based on the General Regulation Plan of Palilula Municipality, several observations warrant attention. First, the plan’s elaboration spanned seven years (2015–2022) and involved three public hearing iterations—early, regular, and repeated—significantly exceeding the statutory minimum. This extended timeframe, while prolonging the planning process, provided expanded opportunities for public engagement. Second, divergent positions between the plan-maker (the Planning Department within the City of Niš) and the decision-maker (the Planning Commission) regarding objections raised during the first hearing were resolved through the repeated procedure, suggesting an institutional alignment process through iterative consultation. Third, the Planning Commission’s decision to require a second public hearing after incorporating accepted objections demonstrates responsiveness to public input, though this iterative approach also reflects the complexity of resolving changes in land ownership status between the public and private sectors. Fourth, the high acceptance rate of objections (12 of 14 in the first procedure and 8 of 9 in the repeated procedure) indicates substantial incorporation of public feedback into the consultation process. However, the absence of collaborative mechanisms (workshops, working groups, or co-design sessions) meant that participation remained within the informing and consulting levels rather than enabling shared decision-making or partnership in plan development [84,85]. Finally, the voluntary publication of the Report on Public Hearing on the local self-government unit’s website, beyond legal requirements, constitutes an additional measure of transparency.

The Palilula case reveals a more nuanced picture within the conformance-based system. The extended timeframe and iterative public hearing process—driven partly by institutional disagreement between the plan-maker and the Planning Commission—inadvertently created expanded participatory windows that exceeded statutory requirements. The high objection acceptance rate across both procedures indicates genuine institutional responsiveness to public input. Yet this responsiveness operated exclusively through the objection-response mechanism: participation remained structured as a reactive, adversarial process rather than a collaborative one. The voluntary online publication of hearing reports signals emerging commitments to transparency, but these remain individual institutional initiatives rather than systemic features of the Serbian planning framework.

4. Discussion

This paper has examined participatory planning practice in Ireland and Serbia through a comparative analysis of legislative frameworks and case studies of both higher-tier plans (the county development plan in Ireland and the municipal spatial plan in Serbia) and lower-tier plans (the local area plan in Ireland and the general regulation plan in Serbia). The selection of these two countries enables examination of how participatory mechanisms operate within distinct institutional contexts: Ireland’s established discretionary planning system, shaped by EU integration and democratic traditions, and Serbia’s post-socialist transition system, characterised by evolving legislative frameworks and emerging participatory cultures. The analysis reveals significant differences across multiple dimensions of participatory practice, from institutional arrangements to the treatment of public input. Interpreted through the foundational frameworks of participation theory, these differences illuminate not merely procedural variation but fundamentally distinct positions on the continuum of citizen influence.

Institutional frameworks and legislative approaches. The two systems exhibit fundamentally different approaches to planning legislation and institutional organisation. Ireland’s planning framework is consolidated within a single comprehensive statute—the 2024 Planning and Development Act [52]—providing unified provisions for both plan-making and development management. This consolidation, combined with complementary guidance documents such as the Development Plans Guidelines for Planning Authorities [55] and the Guide for Inclusive Community Engagement [56], creates a stable institutional environment that encourages local authorities to supplement statutory requirements with innovative participatory methods.

Serbia’s legislative framework has undergone multiple revisions since 2003, reflecting the country’s ongoing transition from technocratic planning traditions toward participatory governance models aligned with European integration goals. The introduction of early public insight in 2014 and recent policy frameworks addressing public participation (2018–2023) demonstrate evolving commitments to participatory planning. However, Serbian planning operates primarily on principles of legal conformance rather than performance-based evaluation, resulting in persistent gaps between formal participatory requirements and actual practice. The presence of a Planning Commission, composed of experts with one-third nominated by the national ministry, introduces multi-level governance oversight absent in the Irish system, where elected councillors exercise primary decision-making authority.

Viewed through Fung’s [45] democracy cube, this institutional difference has direct implications for the authority dimension of participation: in Ireland, democratically elected representatives retain decision-making power, creating a more direct link between citizen input and planning outcomes, while in Serbia, technocratic oversight filters public input through professional gatekeeping.

Information dissemination and accessibility. The depth and diversity of informing mechanisms differ substantially between the two systems. Irish planning authorities employ immersive, multi-channel communication strategies extending far beyond statutory requirements. Case studies demonstrate extensive use of printed materials delivered to households, dedicated plan websites and consultation portals, social media campaigns across multiple platforms, webinars with recordings, podcasts, virtual consultation rooms, and physical exhibitions. The Fingal County Development Plan exemplifies this approach through its comprehensive digital and analogue information strategy designed to reach diverse demographic groups.

Serbian informing practices remain largely limited to statutory notices published in daily newspapers and physical display of plan drafts in municipal buildings or on local municipality websites. While meeting formal legal requirements, these mechanisms offer limited accessibility compared to Irish multi-channel approaches, potentially reducing awareness and engagement among citizens with varying information-access patterns.

In terms of Rowe and Frewer’s [44] typology, both systems provide public communication at the informing level, yet the directionality and richness of information flow differ markedly: Ireland’s approach actively seeks to broaden the participant base—addressing Fung’s [45] ‘who participates’ dimension—whereas Serbia’s statutory-minimum approach effectively narrows the pool of informed citizens to those who actively seek out planning information.

Consultation mechanisms and dialogue quality. Both systems establish consultation mechanisms, but their format and deliberative quality differ markedly. Irish consultation combines statutory written submissions with non-statutory mechanisms designed to facilitate two-way communication. Public drop-in sessions, information days, and webinars enable direct interaction between planners and citizens, creating opportunities for clarification and dialogue. Themed submission portals allow structured feedback on specific planning topics. Ireland’s electoral system, where local councillors often have strong connections to community organisations and civil society [86,87], creates additional channels for community influence on planning decisions.

Serbian consultation operates primarily through formal public inquiry procedures, in which plans are presented, and objections are submitted in writing. A distinctive feature is the public session at which submitted objections are examined—a mechanism with no direct equivalent in Irish practice. This session provides a procedural opportunity for citizens to supplement and clarify their objections and to hear responses from professional planners, although final decisions are made in closed sessions among planning authorities. The Palilula case demonstrates emerging institutional responsiveness: the Planning Commission required repeated public hearings after accepting objections, suggesting evolving consultation practices despite formal constraints. However, interaction remains largely asynchronous and formal, with limited simultaneous communication between planners and the public. Irish consultation practices align more closely with feedback-oriented dialogue, while Serbian consultation remains procedurally focused with objection-based framing.

This distinction maps directly onto Arnstein’s [43] ladder: Irish consultation operates between the consultation and placation rungs, with mechanisms that genuinely seek to incorporate citizen perspectives into plan content, while Serbian practice, despite high objection acceptance rates, remains structurally positioned at the consultation rung, where citizens respond to pre-formulated proposals rather than shaping them.

Collaborative practices and non-statutory participation. The most pronounced difference appears at the level of collaboration. Irish planning demonstrates structured experimentation with collaborative methods, though these remain non-statutory. Examples include workshops with elected members, targeted engagement with prescribed bodies, and innovative youth engagement tools such as the Minecraft event in Fingal’s plan-making process, where young people co-designed solutions for the Rogerstown Estuary area. Irish planning authorities actively supplement statutory requirements, guided by national policy frameworks encouraging innovative participatory methods without requiring legislative change.

Collaboration during Serbian planning processes appears occasionally and might include public or private sector participation in rare cases but remains exceptional and dependent on institutional discretion rather than systematic practice. Non-statutory participation mechanisms are largely absent, and planning practice is tightly constrained by legal minimums. Where non-statutory methods occur, such as public presentations at the sub-municipal level, stakeholder meetings, or citizen guidance on how to submit objections, they are regarded as exceptions rather than standard practice [82,88].

Against the IAP2 [46] spectrum, neither system consistently reaches the collaborate or empower levels: Ireland approaches the collaborate level through non-statutory initiatives but has not institutionalised these practices legislatively, while Serbia remains largely within the inform–consult range. This shared limitation suggests that the challenge of embedding genuine collaboration within statutory planning frameworks transcends individual planning traditions and points to a broader structural tension in European planning governance between participatory aspirations and institutional path dependencies.

Treatment of public input and transparency. Both systems record public submissions but differ fundamentally in how input is processed, addressed, and communicated. Irish processes publish all submissions online and systematically address them in the Chief Executive’s Reports, i.e., comprehensive documents providing transparency and traceability between public input and planning decisions. These reports categorise submissions thematically, provide detailed responses with policy or technical justifications, and explicitly state whether recommendations will modify the plan.

Serbian Reports on Public Hearings include detailed statistics on accepted, partially accepted, rejected, and irrelevant objections, and set out the statutory requirements for explaining rejected or irrelevant objections. Although publicly available, these reports are not always readily accessible. Cases examined show acceptance rates ranging from 53% (Surčin) to substantial majorities (86% in the first procedure in Palilula, 89% in the repeated procedure), indicating meaningful incorporation of public feedback through consultation processes. Nevertheless, Irish processes emphasise procedural transparency throughout the participation cycle, whereas Serbian processes focus on the formal resolution of objections, thereby reinforcing an adversarial framing of participation.

These comparative findings reveal that participatory planning operates differently across institutional contexts shaped by distinct planning traditions, legislative frameworks, and democratic cultures. Ireland’s discretionary system enables the flexible adaptation of participatory practices beyond statutory minimums, supported by policy guidance that encourages innovation and experimentation. Serbia’s post-socialist transition context demonstrates evolving commitments to participation through legislative reform, yet implementation remains constrained by legacies of technocratic planning and conformance-based institutional cultures. Both systems face ongoing challenges in moving beyond consultation toward genuine collaboration, though they approach these challenges through different institutional pathways shaped by their respective governance contexts.

Finally, these findings carry implications beyond the Irish and Serbian cases. Discretionary systems may offer greater latitude for participatory experimentation, yet without legislative embedding, such innovations remain vulnerable to political change and institutional inconsistency. Conversely, conformance-based systems provide procedural certainty but risk confining participation to statutory minimums that satisfy legal requirements without enabling meaningful citizen influence. These insights suggest that strengthening participatory planning across Europe requires attention not only to legislative reform but also to the institutional cultures and governance structures.

5. Conclusions

This paper has examined participatory planning practice in Ireland and Serbia through a comparative analysis of legislative frameworks and four local land use planning cases. Across both contexts, participation remains predominantly situated at the informing and consultation levels, confirming broader concerns in the literature about the persistence of limited forms of engagement [6,43]. However, the comparison demonstrates that similar positions on the participation spectrum can mask qualitatively different participatory environments.

In Ireland, participation operates within a discretionary and adaptive governance framework, where statutory requirements are complemented by a wide range of non-statutory practices. This creates a broad participatory environment in which local authorities can employ diverse engagement formats. As a result, even where formal power-sharing remains limited, participation tends to be iterative, multi-channel, and embedded in broader communicative practices. In contrast, Serbia’s participation is strictly structured by legal provisions and largely confined to formal stages of objection and review. Although its participatory mechanisms are less diverse, the public hearing stands out as a distinctive feature: it enables third parties to present their views directly to the Planning Commission. This form of direct deliberation between the public and decision-makers in the final stages of planning is absent in the Irish context.

While both countries align with EU-level principles promoting participation, their implementation diverges significantly due to differences in administrative traditions, institutional cultures, and governance structures. This underscores the importance of understanding participation as context- and governance-sensitive rather than as a transferable set of toolkits. The study contributes to European comparative planning scholarship by demonstrating that the depth and quality of participatory practice are shaped not by legal provisions alone but by the interplay between planning system typology, institutional culture, and the policy space available for non-statutory innovation.

Several limitations should be acknowledged. First, the analysis relies primarily on documentary sources produced by planning authorities, which may present an institutional perspective on participation that does not fully capture the experiences and perceptions of participating citizens and communities. Second, the study does not include interviews with planners, decision-makers, or participants, which could provide deeper insight into the motivations, constraints, and informal dynamics underlying formal participatory procedures. Third, the findings are based on four case studies across two countries, which, while analytically revealing, limit the scope for broader generalisation. Future research could address these limitations by incorporating participant perspectives through interviews or surveys, expanding the number and diversity of cases, and examining participatory practice longitudinally to capture its evolution.

Looking ahead, the comparative methodology applied in this study—systematic analysis of participation practices across planning levels and institutional contexts—offers a replicable framework that could contribute toward a Compendium of Participatory Planning Practices at the European level. The measurement of participation, initiated at the global level through SDG 11.3.2 and adapted to national and local contexts in Serbia, represents a significant step toward evidence-based monitoring and improvement of participatory practice. The diversity of approaches, the similarity of challenges, and the constant evolution of governance contexts across Europe present both the need and the opportunity for sustained comparative research—not only in Ireland and Serbia, but also across the many planning systems that could benefit from the analytical framework advanced in this article.