CHI Pre Budget Submission 2025

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2025 Pre-Budget Submission

Department of Public Expenditure and Reform

Department of Housing, Local Government and Heritage 30th July 2024

Introduction

Co-operative Housing Ireland (CHI) is a leading Approved Housing Body (AHBs) in Ireland, providing more than 5,200 high quality homes to lower-income households, with nearly 16,000 member tenants. As a representative body, CHI champions co-operative principles in delivering homes and supporting communities. We work closely with various stakeholders in the housing sector, including Local Authorities, Government, and developers, to provide high quality socialrented homes across the country to lower-income households CHI has also supported owneroccupier housing co-operatives to additionally deliver 3,000 affordable homes in Ireland. The organizations’ mission is to provide homes co-operatively to meet the needs of our communities by working in partnership:

• to enable vibrant and sustainable communities

• to be a voice for delivering housing co-operatively and for those in housing need

• to support co-operative and other community-led housing initiatives

“The housing cooperative allows lone parents to have some hope about the future. Having somewhere to call home and providing stability for our children is the greatest gift. We should never under-estimate the positive impact CHI has on families.”

CHI member tenant

The above quote from a member-tenant is a powerful reminder as to why CHI is passionate about delivering high quality affordable social homes. We must keep this at the centre of our work and housing delivery programme. This member-tenant’s experience and many others like them are a key motivator as to why we do what we do, and this pre-budget submission will set out how CHI will continue to deliver high quality, affordable social housing and the State supports required to do so.

Investment proposals for a viable AHB housing delivery model

The purpose of CHI’s 2025 pre-budget submission is to advocate for specific expenditure proposals that will enable and support CHI and other AHBs to deliver more social and affordable housing in a financially viable and sustainable manner.

The investment proposals in this submission will protect future delivery of social and affordable housing through reduction in debt for AHBs, solutions to address legacy funding issues in the AHB sector, financial supports for retrofitting, as well as a proposal for an innovative housing model, Community Land Trusts, thereby freeing up expenditure to deliver more homes. Modern Methods of Construction, and an efficient and revised planning process will also contribute to greater savings to deliver more affordable and social homes that are high quality, more environmentally sustainable and with fairer rents for social housing tenants.

1. Increased delivery of social and affordable homes

While there has been an increase in the number of homes being funded and delivered since the Housing for All Strategy was launched in 2021, the recommendations for 33,000 housing units per year is not sufficient for a growing and changing Irish population and wider economy.

In CHI’s experience, research carried out by ESRI1 and other housing experts, comments made publicly by An Taoiseach, Simon Harris, and media reports, housing output needs to be increased to a minimum of 50,000 units per year.

The Housing Commission Report2 has recommended that 20% of housing stock should be comprised of social and cost rental. Currently, there are approximately 185,000 social homes3 in Ireland, which is 10% of all private households. To reach 20% social and cost rental housing stock, and to address this deficit and pent-up demand there needs to be another 185,000 social homes built and delivered.

To achieve this in a realistic time scale of 10 years, the previously established 33% of all housing delivery as social and cost rental in Housing for All will have to increase to 50%. This equates to 25,000 newly built social homes per annum. If the current ‘business as usual’ 2:1 ratio is applied to revised upward housing delivery figure of 50,000 homes per annum, this would equate to 16,666 social homes. This would mean that Ireland would reach the Housing Commission’s recommendation of 20% social and cost rental housing in approximately 15 years’ time, as shown in Table 1 below.

In the last 13 years AHB social housing delivery has increased to 40-50% of all social housing newly built homes. Any future social housing delivery programmes will need to account for this growing sector, and there will be a need for increased funding that is stable and diversified. These recommendations are also supported in the Housing Commission’s report and will enable the AHB sector to rely on this funding model, plan for future pipeline delivery and continue to deliver high quality and affordable new build social and cost rental homes.

Table 1’s estimates and projections model the different scenarios to achieve 20% social housing/ cost rental housing stock. Which, if realized would mean that Ireland would have one of the highest rates of social housing stock in Europe and we would be a leader in truly affordable housing and a desirable place to live, as well as being fairer and more equitable.

1 ESRI (2024) Population projections, the flow of new households and structural housing demand. Available at: https://www.esri.ie/system/files/publications/RS190.pdf

2 Housing Commission (2024) Report of The Housing Commission. Available at: https://www.gov.ie/pdf/?file=https://assets.gov.ie/294018/e1aae1ed-07c4-473d-811e-3426756321ee.pdf#page=null

3 Housing Europe (2023) The State of Housing in Europe 2023. Available at: https://www.stateofhousing.eu/#p=1

Table 1: Estimates for housing delivery numbers required to reach 20% social/ cost rental housing

Current social housing (SH) stock in Ireland and breakdown between local authority (LA) and AHB

SH stock needed to make up 20% of current private households

SH as 20% of revised overall housing delivery

per annum scenario

Delivery of SH until 2030 to reach 20% (6 years)

Formula: 185,000 / 6 years + 10,000 (current need)

Delivery of SH until 2034 to reach 20% (10 years)

Formula: 185,000 / 10 years + 10,000 (current need)

Delivery of SH until 2040 to reach 20% (15 years)

Formula: 185,000 / 15 years + 10,000 (current need)

(LA)

(AHB)

(per annum)

(per annum)

Key to addressing the housing affordability gap is more social housing as well as the necessary State support and funding. While the Housing Commission’s recent report and recommendations are ambitious CHI supports these findings and analysis. If Ireland is to address the gap in affordable and social housing supply from previous decades, overall housing delivery targets need to be revised upwards, to at least 50,000 new homes per annum

CHI’s 2025 pre-budget submission ask to increase social and affordable housing:

To reach the Housing Commission’s recommendation that 20% of the national housing stock are social and cost rental housing AHBs will require:

• Access to diversified funding sources.

• Gearing/ debt levels and legacy funding issues solved and addressed (point 2 below).

• Greater grant funding for deep energy retrofits and upgrades. This will reduce costs for AHBs to maintain current older housing stock and reach residential carbon reduction emissions, and therefore enable more funding and resourcing for delivering new build social homes.

• Off balance sheet funding and reclassification of AHBs.

• Prioritisation of social housing schemes and developments in the Irish planning system.

• Access to lower cost land to reduce overall costs to deliver social homes.

• Incentivising Modern Methods of Construction (MMC) to enable efficient, high quality, more environmentally friendly homes to be delivered quicker to address the scale of social and affordable housing deficit in Ireland and to meet future demand.

2. Unlocking the potential of AHBs – financial challenges faced by AHBs

2.1 Mounting Debt of AHBs

Co-operative Housing Ireland (CHI) has been proactively engaging with the Department of Housing, Local Government and Heritage (DHLGH) Working Group including the DHLGH consultants Indecon and other stakeholders on the challenges of high debt levels (gearing) for AHBs

More recently, as of July 2024, CHI’s Board of Management has again raised the issue of gearing in the AHB sector, which needs to be addressed urgently. In this recent submission CHI reiterated that the financial gearing levels of CHI and the other larger AHBs have grown rapidly over the past number of years and are now at a juncture where future delivery will be compromised if they continue to grow.

While this issue is a result of the sector’s success in delivering much-needed homes under the Housing for All plan, and CHI has a pipeline of opportunity for significant housing delivery in the short to medium term; the gearing issue risks compromising this if not resolved imminently. CHI asks the Department of Housing to announce interim measures and provide timelines for their implementation.

The Working Group is aware that as gearing (leverage) increases, both lenders and organisations shareholders are subjected to increased risk. As the level of debt increases, lenders require higher returns to compensate them for accepting increased risk. As gearing is increased, so too is the probability of financial distress. Organisations with very high gearing ratios may have difficulty raising funds in periods of tight money.

Gearing and income stability are best considered together. The underlying risk profile of the operating model being used by the AHB is a key factor in determining the impact of gearing levels. Gearing without an income financial underpin from the State is considered higher risk. AHB’s have different operating models and risk profiles.

If the AHB sector is to continue delivering new social homes at scale and sustain year-onyear growth, the State will have to consider the introduction of a formal State guarantee of AHB debt and debt alleviation measures such as grants, equity investment and debt conversion options.

Financial prudence and compliance with the Approved Housing Bodies Regulatory Authority (AHBRA) Regulatory Standards are important to CHI and AHBs. Without State intervention, in the short to medium all large AHBs will reach a gearing level that their Boards of Directors will need to assess in light of their borrowing limits and risk profiles. This may curtail or cease housing delivery from some AHBs.

Reducing the current high gearing levels will enable AHBs to continue growing, delivering more homes, as well as encourage other funders to lend to AHBs as the cost of funds will become more competitive by reducing the risk premia penalties for high gearing.

Diversifying sources of debt is a sound financial management practice for all borrowing organisations. It is to be noted that the diversification of funding sources for the delivery of social housing is a stated objective within Housing for All and has also been reiterated in the more recent Housing Commission report. However, this objective may not materialise under the recent CALF & PA programme revisions as the lending interest rate is capped at the Housing Finance Agency (HFA) prevailing rate. The current trajectory is one of higher gearing with the dominant senior debt from a single source, the HFA. The CALF and the HFA debt combined representing inter alia State debt.

The impact of gearing and raising funds for necessary capital projects will be required to address Capital Expenditure (CapEx) for older housing stock particularly the Capital Loan Subsidy Scheme (CLSS) housing stock. Currently this type of finance is not provided by the HFA. The high debt and gearing levels from housing acquisitions could be problematic when seeking funding from other third-party lenders. It is important therefore that high gearing is alleviated to enable other funders to lend to AHBs and to keep the cost of funds competitive without risk premia penalties for high gearing.

2.2 AHB Legacy Funding Deficits

Related to point 2 above is the legacy funding issues, particularly for the Capital Loan and Subsidy Scheme (CLSS). Historically social housing was supported through grant funded ‘loans’, with a small provision for management and maintenance. However, under this funding there is no provision for lifecycle, component replacement or deep energy retrofits,

and significant funding will be required to address Capital Expenditure (CapEx) for older housing stock.

The Capital Loan and Subsidy Scheme (CLSS) was introduced over 30-years ago in 1991. Since its inception over 10,100 homes were provided nationally under this scheme. In total, CLSS homes have successfully housed an estimated 26,000 people from social housing waiting lists. As far as CHI is aware the scheme has never been reviewed.

CHI was an active participant in the CLSS scheme up to its closure in 2009 and delivered 1,166 properties. This is a sizeable proportion of our overall housing stock and makes 22% of it, or approximately 1 in 5 CHI homes.

CHI submitted a paper to the Department of Housing in April 2024, which sought to highlight that the income derived from CLSS homes does not cover the management and maintenance and longer-term lifecycle capital costs associated with these properties and provides a funding model for their future sustainability. This is an extremely serious issue and needs to be addressed urgently. If not, it will have a major impact on CHI and other AHBs’ ability to deliver social housing to those most in need of safe and secure homes. While CHI believes in keeping social homes in ‘perpetuity’, if these financial difficulties are not resolved, in collaboration with the state, our Board may decide that the organisation has no other option but to sell a proportion of these homes once they are out of mortgage and void.

CHI as a regulated AHB carries out ongoing reviews of the financial sustainability of homes on a periodic basis, in line with financial regulatory standards and legal obligations operative in the sector. These reviews have increasingly concluded that the CLSS homes are inherently financially unviable under the funding model as it exists today.

CLSS originally conceived a cost recovery model where total revenue equals total cost, unfortunately, this has not been the reality for several years. Over the next 30-years, there will be a deficit of €117.4m in funding (€14.3m annual recurring costs, €103.1m capital), just over €100,000 for each of these 1,166 homes. This is despite an income of €178.5m from differential rent and an allowance of €543 per home per year.

The organisation’s growth has been well-managed and built on a sustainable footing. To continue this growth, the legacy issues around CLSS – currently being examined as part of the AHB Strategic Forum and through direct contact with the Department of Housing – and the gearing issue must be resolved.

Currently CHI is using de facto reserved income to manage running and capital costs of CLSS homes. Cross subsidising is not sustainable, firstly, this income has a specific future purpose and depleting these reserves will have very serious implications, and secondly, it is contrary to CLSS being self-sustaining. The scheme itself specifies that management and maintenance allowance ‘must be separately accounted for by the approved housing body and used only to meet its management and maintenance costs for the dwellings in each project funded under the Scheme’.

The initial Management and Maintenance (M&M) allowance from the relevant local authority was calculated based on costs and best practice prevalent at the inception of the scheme. This is not reflective of current circumstances of housing management and the allowances have not kept pace with inflation and other costs associated with professionalisation and

increased regulatory standards and expectations of the AHB sector. Add to this an ageing stock of homes which will increasingly need capital investment.

As larger AHBs started to record and project the accurate direct and indirect costs (including lifecycle component replacement) these deficiencies have become apparent and an issue of significant concern for the retention of the stock on a financially secure footing.

The underfunding of CLSS properties is further compounded by the fact that AHBs are unable to build up reserves or sinking funds from M&M and differential rent, to provide for lifecycle component replacement costs of these properties. This has resulted in AHBs in the sector only delivering essential and urgent lifecycle component replacement as and when required, and postponing non-essential lifecycle component replacement works.

It is imperative that CLSS homes are funded sustainably to ensure these homes meet required standards, are managed effectively, and maintained as social-rented homes. AHBs, including CHI, may be forced to either sell these homes when they come out of mortgage to bridge the funding deficit or seek member tenants who can pay a rent that allows for full cost recovery.

There is a commitment under Housing for All to strengthen the AHB sector and addressing the CLSS funding shortfall will significantly improve the health of the sector. CHI and the AHB sector have always worked in partnership with the State and are grateful for the support received so far and want to continue to deliver on social and affordable homes.

CHI’s 2025 pre-budget submission ask to address the legacy funding deficit:

• On an annual equivalent basis there is a shortfall of €3,350 per home (€117.4M/1,166 homes over 30-years) to cover ‘day to day’ (recurring and core expenses) and capital works (major repairs and component replacement).

• In order to address the funding shortfall CHI is proposing that there is:

1) An immediate increase in the management and maintenance allowance

Day-to-day costs: a CLSS operational cost payment model is key; this may involve straightforward adjustments to the existing management and maintenance payment. Taking this approach is in line with the funding principles of current social housing funding (the P&A model) in relation to cost coverage.

2) Funding for capital works through an ongoing application process (similar to existing state remediation schemes). This avoids an immediate up front capital commitment from the exchequer and can be closely managed.

Capital costs: investing in the social good, the home: establish a capital expenditure fund, accessible on an application basis to cover capital repairs and material works requirements. This includes the core requirement of replacing housing components that are at the end of their serviceable life on aging CLSS stock. From an operational standpoint, this can mirror comparable capital funding schemes already in place. It is a multi-year proposal, and ease of administrative application is central to the proposal.

3. Decarbonising the AHB sector

New homes dramatically reduce the carbon emissions from energy use in housing. We need to move our existing housing stock to zero carbon energy use and drive-up standards in new homes, reducing their embedded carbon and encouraging the use of modern methods of construction.

All new homes delivered by CHI have energy ratings of A2. Over the coming years, we aim to deep energy retrofit our older homes to a minimum B2 energy rating. As an Approved Housing Body, we are committed to retrofitting homes and reducing our carbon footprint.

The funding model for older social housing developments did not provide for deep energy retrofit. Greater grant funding is required if AHBs are to achieve the necessary level of upgrades

In addition to this:

1. The scale of funding required to complete the necessary energy upgrade works needs to be reviewed.

2. Funding and government guidelines for completing upgrades across multi-unit (multi ownership) dwellings needs to be implemented.

As the energy and retrofit programme has been rolling out across the AHB sector, apartment blocks have proven to be more complex and costly to upgrade, than a house. There are more requirements and equipment needed, therefore, due to these extra costs the percentage that SEAI grant funds decreases from an expected 50% down to 30%. Communal and shared spaces, such as an apartment block hallway also increases the costs for the AHB, as these communal areas still require energy and retrofit upgrades but are not eligible under the SEAI grant application. Enabling works such as scaffolding for apartment blocks are also not funded under the SEAI model.

SEAI grant funding is capped at 50% for the energy efficient measures for social housing through their various streams of housing retrofit funding. In a Cost Analysis report commissioned by the Irish Council of Social Housing in 2022, AHBs require 90% grant funding to cover retrofitting costs.

Table 2: Summary of Modelling Results (3 scenarios)

Loss/Net Gain where AHB & Tenant income streams are available to AHBs

Loss/Net Gain where AHB income streams are available to AHBs

(Source: Irish Council for Social Housing analysis)

CHI’s 2025 pre-budget submission ask to meet AHB retrofitting and carbon targets:

• A one-stop-shop scheme specifically for AHBs with grant funding of at least 90% is needed to make energy upgrades viable for AHBs. Currently, Local Authorities receive 100% funding for their retrofitting and energy upgrades. The deficit in grant funding risks cross subsidising from current CALF/P&A income which should be reserved for other purposes.

4. Housing Co-operatives and Community Land Trusts (CLTs)

The delivery of community led housing models, such as co-operatives and community land trusts (CLTs) is a long-term investment through ownership of local assets in perpetuity and the investment of surpluses back into the community. This model enables the delivery of genuinely affordable homes for local people to meet housing need and developed in a way that benefits the local community. It promotes community cohesion, accountability and a sense of connection leading to long term sustainability of a community.

Co-operative Housing Model

In the late 1970s 5% of all annual housing delivery was achieved through co-operative effort. This was delivered in the form of low-cost loans and land from the Local Authority. Currently in Ireland there are approximately 5,500 co-operative homes, housing 14,000 members. One of the main benefits of housing co-operatives is that it is more affordable, as it is a not-for-

profit model and is based on each member contributing to the project. It also offers choice to individuals and households in Ireland.

Under the Affordable Housing Act 2021 local authorities can support housing co-operatives, community led housing projects and CLTs, to provide affordable homes. Necessary policy, including funding and delivery mechanisms needs to be developed and implemented to facilitate these housing models. The current funding and financial systems in Ireland are not conducive for a co-operative or community led housing model to develop and scale up, however there is funding potential through alternative lending from the State, Credit Unions, Banks, and ethical pension funds.

If Credit Unions were allowed to lend to housing co-operatives it could be a mutually beneficial partnership as these organisations both have similar values. In 2023 deposits and investments totalled €14.58 billion4 for Irish Credit Unions, which could be used to lend to cooperatives and its members. This is already happening in Europe whereby co-op members pay back these loans, ensuring this remains a sustainable lending mechanism for cooperatives. Canadian research has also shown that co-ops are less likely to default on their mortgages and are lower risk to lend to.5

Community Land Trusts (CLT)

CLTs are non-profit, democratic, community-led organisations. They develop and manage homes that are affordable to lower- and median-income households, as well as other assets that contribute to thriving local communities. They act as long-term stewards of these assets, ensuring they remain permanently affordable. This is achieved through mechanisms that ensure that any additional value generated is retained within the CLT. 6

The CLT model is a solid base for developing new social and affordable housing delivery models that can respond to the need for affordable housing, as well as to social challenges such as population aging, gentrification, demand for informal care, or vulnerable communities. At the wider European level, the EU Urban Agenda on Housing now recognises CLTs as best practice,7 while the European Parliament Report on Housing for All calls on the EU and members states to support CLTs. A possible source of funding for CLTs is the recognition of these housing models in the yearly budget. An example of this is in Belgium, whereby the Community Land Trust Brussels (CLTB) has a dedicated budget of €2,500,000- €3,000,000, from State funding, which could also be replicated here in Ireland.

While CLTs are responsible for the stewardship of the land and it remains in perpetuity with them to be shared as a common resource, there is currently a gap in the legislation in Ireland related to this housing model. It is not legally possible to create new leaseholds on houses,

4 Central Bank of Ireland (2024) Financial Conditions of Credit Unions, 2023. Available at: https://www.centralbank.ie/docs/default-source/regulation/industry-market-sectors/creditunions/communications/financial-conditions-of-credit-unions/financial-conditions-of-credit-unions-2023-i.pdf

5 The Conversation (2022) Housing co-ops could solve Canada’s housing affordability crisis. Available at: https://theconversation.com/housing-co-ops-could-solve-canadas-housing-affordability-crisis-181104

6 Self-Organised Architecture (2023), SOA + Community Land Trusts (CLTs), Available at: https://soa.ie/shicc/ (Accessed: 29th August 2023).

7 European Community Land Trust Network (2023), Available at: https://www.clteurope.org/ (Accessed: 29th August 2023).

but this could be addressed if new legislation allowed for new leaseholds to be created by certain approved bodies, such as community land trusts and state bodies.8

In Ireland co-operatives and community land trusts are recognised as a potential provider of affordable housing under Section 6 of the Affordable Housing Act 20219 but need certain measures and interventions from the State to become operational. Utilising current initiatives and schemes such as Croi Conaithe and the Local Authority Home Loan could also support these alternative housing delivery models to make it more financially viable and operational.

CHI’s 2025 pre-budget submission ask to strengthen and develop community led housing models such as co-operatives and CLTs:

• Targeted low-interest loan products, for construction and long-term financing, which can support sustainable development and independent cooperatives.

• Low-cost sites should be made available from Local Authority to AHBs to develop mixed tenure schemes of 90% social housing and the other 10% for a registered co-operative.

• Empowerment of public agencies, by government, to adopt policies for sale or allocation by lease of public land for development on the basis of a competitive procedure, according to social value criteria and financial viability.

• Waiver the ‘one application per private residence’ under the Vacant Property Refurbishment Grant for registered co-operatives. This will allow them access to this funding scheme for refurbishment of larger vacant or derelict buildings for the purposes of community housing.

• Make the Ready to Build Scheme,10 where local authorities make serviced sites available in towns and villages at a discounted rate to individuals who want to build their own home, available and accessible to a registered co-operative or community led housing project.

• Make the Local Authority Home Loan11 available to registered co-operatives and community led housing projects. Like the Croi Conaithe schemes this is only available to individual households and not a member group such as a co-op. This scheme is for the purchase of new or second-hand residential properties and for self-builds and could be applied to a housing co-operative group. This grant could also be applied at a higher rate of 8%, with clawback measures as part of the terms of this scheme.

• Allocate specific budget and a commitment to developing Community Land Trusts through a pilot programme with a long-term goal to implement this as a mainstream housing option.

• Consider new legislation to allow for new leaseholds to be created by certain approved bodies, such as community land trusts and state bodies.

• A Community-Led Housing Fund to build capacity. A targeted fund can provide start-up grants for groups to build early-stage capacity.

• Make zoned residential land available at a reduced cost to a CLT for the development of lower cost homes.

8 Self Organised Architecture (2019) SOA Land Ownership & Development Zine. Available at: https://soa.ie/wpcontent/uploads/2019/06/SOA-Zine-2-Land-.pdf

9 Affordable Housing Act 2021. Available at: https://www.irishstatutebook.ie/eli/2021/act/25/enacted/en/pdf

10 DHLGH (2022) Ready to Build Scheme; Serviced Sites for New Homes Croí Cónaithe (Towns) Fund. Available at: https://www.gov.ie/pdf/?file=https://assets.gov.ie/234998/61591230-1129-4f8f-9d4b-c0d6b4e75ddd.pdf#page=null

11 Local Authority Home Loan: https://localauthorityhomeloan.ie/about/

5. Modern Methods of Construction (MMC)

Modern methods of construction (MMC) and off-site production are more environmentally friendly than traditional house building. We are committed to reducing our carbon footprint and believe that financial incentives should be provided to manufacturers and developers, including AHBs, to deliver more homes via modular construction methods. They are better for the environment and create more carbon-friendly and energy-efficient buildings, through sourcing green materials.

The incorporation of Design for Disassembly (DfD) into modern methods of construction should also be incentivised to ensure the materials and building components re-enter the supply chain at end of life, reducing waste, reusing embedded carbon, and promoting circularity.12 The added benefit of increasing modern methods of construction would be speedier delivery.

CHI’s 2025 pre-budget submission ask to scale MMC in the social housing sector:

Incentivise MMC and off-site production through:

• Reduced VAT rates

• Planning levy waivers.

• Additional funding multiplier for green modular construction projects.

6. Planning Process in Ireland

The planning process is one of the biggest challenges in delivering social housing and increasing supply. Two of the biggest issues with the planning system are the permission process and commencements.

Permission for projects is being held up by appeals, and it is a laborious and bureaucratic system to navigate. While it is important to ensure that the new reforms and legislation for the planning process in Ireland are well thought through, this policy area needs to be prioritised.

Many projects are receiving approval but are not commencing. The timeframe for a project to get through from start to finish is very lengthy and therefore slows down the delivery of social housing This process needs careful review to understand where these delays are happening, and solutions discussed with those involved to make it more efficient.

While the Planning and Development Bill 2023 is a vital piece of legislation for housing delivery and is welcomed by the various stakeholders in the housing sector, including AHBs, the Government still needs to ensure that this legislation is fit for purpose, provides policy stability and addresses the main bottlenecks with regards to the planning system. Since

12 TU Dublin (2023), Deep Energy Retrofit in Housing via Circular Modular Solutions, Available at: Drive O | TU Dublin (Accessed: 8th September 2023).

2020, 1,150 social homes in the pipeline have not progressed, for the most part due to bureaucracy and red tape in the planning system.13 This has meant that there are households in need who have been unable to avail of social housing and could be living in unsuitable or unsafe accommodation with their families. From the 2023 social housing waiting list data, nearly one in three households (32%) had been on the waiting list for five years or more. This is compared to the UK where only 9% of households were on the waiting list for 5 years or more before getting a social letting,

The 2023 Planning and Development Bill’s main tenets of ensuring consistency for all users of the planning system, greater certainty for timeframes for planning and simplifying the planning process for key regional areas should address the major issues within the current system. However, there is still the problem of spurious claims and the delays this causes to schemes and much needed developments, including social housing. An Bord Pleanála therefore needs to be appropriately resourced to meet targets and sanctions imposed if not to ensure a more efficient planning system is in place in Ireland.

CHI’s 2025 pre-budget submission ask to address the delays in the planning process:

• Prioritising social housing schemes planning permission requests and ensuring these projects are carried out in a timely manner.

• The Planning and Development Bill is progressed in a timely manner to ensure that the necessary changes are implemented effectively and provide clarity to the planning system in Ireland.

13 Irish Examiner (2024) More than 1,100 social homes stuck in planning system since Government came to power. Available at: https://www.irishexaminer.com/news/arid-41312344.html

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