MHC Built Environment Sector - In Brief - Q1 2024

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Built Environment Sector Update In Brief Q1 2024

Built Environment Sector Update - In Brief


Welcome to the latest edition of our Built Environment Sector Update - In Brief series. In this interactive magazine, we feature our most popular insights from the past month. We hope you find it informative. First up, in the above video, Real Estate partner, Jamie Fitzmaurice discusses Ireland’s housing crisis and, in particular, the private market’s struggle to meet social and affordable housing needs. Other most read insight include articles on: • • •

Review of Planning and Development Bill 2023 The Irish CRE Market – Can it Survive to 2025? Senior Living in Ireland

Key Contacts Vanessa Byrne Partner, Co-head of Real Estate

Michael Doran Partner, Co-head of Real Estate

Deirdre Nagle Partner, Head of Planning & Environment

Muireann Heron Partner, Financial Services

Contact our Built Environment team


Built Environment Sector Update - In Brief

Review of Planning and Development Bill 2023 Deirdre Nagle Partner, Head of Planning & Environment

The Planning and Development Bill 2023 was published at the end of 2023. It has been refined overall and certain provisions expanded upon since the previous draft of the Bill was published. In a previous article, we analysed the Government’s Guide to the Bill. In this article, we review the current text of the Bill and highlight some further points of interest.

National Planning Statement A new planning policy hierarchy will be introduced which will empower the Minister for Housing, Local Government & Heritage to issue, with Government approval, a National Planning Statement (NPS). The NPS will set policy and provide related guidance regarding planning matters. It will be mandatory for all other plans to be aligned with the NPS. However, the associated guidance outlining how the NPS should be implemented will be discretionary, allowing for some degree of flexibility. The NPS will replace section 28 Ministerial Guidelines and section 29 Ministerial Policy Directives which may currently be made under the Planning and Development Act 2000, as amended (PDA).

Material contravention of plans Sections 96 and 107 of the Bill relate to an application for permission for development in material contravention of certain plans. These sections narrow the ability of a planning authority and An Coimisiún Pleanála (the Commission), being

the rebranded An Bord Pleanála (Board), on appeal to grant permission that materially contravenes a development plan or other plans. For example, the rationale for granting permission in material contravention of a development plan available under the PDA, namely that “permission for the proposed development should be granted having regard to the pattern of development, and permissions granted, in the area since the making of the development plan”, has not been carried forward in the Bill. Instead, there will be greater focus on whether a proposed development is compliant with national and regional policies to justify granting the permission. In addition, the deciding authorities under the Bill appear to be bound by the development plan unless a material contravention is expressly sought, which is not presently the case for the Board for certain direct applications under the PDA.

Modification and extension of planning permission Chapter 5 of the Bill outlines the procedures for applications for alterations of, and extensions to the duration of, planning permissions. These procedures apply to both land and maritime based developments. When a request for the alteration or extension of planning permission is made, the deciding authority will consider whether it is material or not. Where a proposed modification requires an environmental impact assessment (EIA) and/or appropriate assessment (AA), or where the deciding authority is of the opinion that the amendment is a material alteration, then it will be 3

Built Environment Sector Update - In Brief

considered a material modification and will be subject to public consultation before a decision can be made. Where the modification is non-material, the deciding authority is obliged to grant the alteration or extension. There is no requirement in the Bill to have substantial works carried out to avail of an extension. This is a change from the current provisions of the PDA. In addition, planning permission may be extended, following public consultation, where an EIA/AA is required. This is also not currently permitted under the PDA.

Reform of section 5 procedure The existing process regarding declarations on exempted development under section 5 of the PDA will be substantially modified under sections 10 and 11 of the Bill. The Bill provides that a planning authority, or the Commission on appeal or referral, must give on request a declaration as to whether a project constitutes development and if so, whether it is exempted development. A request for such a declaration shall be determined within eight weeks of the date of the application or within three weeks of the date of expiration of the period specified in a notice where further information is requested. The Commission must generally determine a referral within 18 weeks of it being received. The principal changes to the process are:


Only the owner or occupier of land or a person with the owner/occupier’s consent may apply for a declaration

The declaration given is not binding on persons who were not involved in the application

The procedure may be used as a means of confirming whether any particular works are within the scope of a grant of planning permission

Section 10(5)(b)(ii) of the Bill provides that where a declaration is made, the planning authority must forward the declaration and the main reasons and considerations on which it is based to the person who made that request and to the owner or occupier of the land in question if different to the applicant. Section 10(11) of the Bill provides that a person is not entitled to make a request for a declaration regarding a question that is, in substance, the same as a question where the planning authority or the Commission has already made a declaration unless there has been a material change in circumstances since the making of the first declaration. Section 11 of the Bill also provides that a relevant declaration will be conclusive evidence of the matters stated therein in relevant proceedings brought by an enforcement authority or the Director of Public Prosecutions. However, this appears to apply only to a person who requested the relevant declaration. Particulars of every declaration of a planning authority or the Commission for a request will be entered in the register. In addition, where the planning authority or the Commission makes a decision, it will publish the relevant documents on its website and make them available for inspection and purchase by members of the public.

Built Environment Sector Update - In Brief

Judicial review reform Correction of errors In our previous article, we noted that the judicial review process will be streamlined. One way in which it is proposed to streamline the process is by permitting the Commission to correct an error of law or fact in a decision that is subject of judicial review proceedings. This was a controversial proposal at pre-legislative scrutiny stage. However, it has been retained in the current text of the Bill. There are two ways by which the Commission may correct such an error. However, both ways require the High Court to exercise its discretion: 1.


Where an applicant has succeeded on at least one ground and the High Court is satisfied that the ground concerned is based on an error with a decision or on the face of a document, and amending the decision or document would address the ground, render the ground moot in whole or in part, or act as a satisfactory remedy, and it is within the power of the relevant body to make the amendment Regarding a ground pleaded concerning an error, where the Commission or notice party in the proceedings admits or acknowledges that it made the error and the High Court is satisfied that the error is one where it is appropriate for it to exercise its powers

Where the High Court exercises its discretion, instead of quashing a decision, it may order the Commission to make the amendment. Alternatively, it can order an adjournment of the proceedings to allow the Commission to perform its function. It may also make such orders consequential on, or necessary to give effect to, a decision as it sees fit.

Unincorporated Residents Associations Unincorporated residents’ associations (URA) will be deemed to have sufficient interest to bring judicial review proceedings provided certain administrative conditions are met. This is a key change to the original draft of the Bill which proposed to exclude unincorporated bodies from bringing judicial review proceedings. The conditions which must be met are as follows:

• The URA is a partnership within the meaning of the Partnership Act 1890

• The URA is a limited partnership within the

meaning of the Limited Partnerships Act 1907

• The URA may sue or be sued in the High Court in its own name under Order 14 of the Rules of the Superior Courts (S.I. No. 15 of 1986), or

• The URA: • Has a constitution • Holds a vote among its members, in accordance with its constitution, on whether to apply for judicial review proceedings regarding the ground

• Is authorised to bring the proceedings

regarding the ground by no less than two thirds of the members casting a vote, and

• Provides, with its application for judicial

review proceedings, an affidavit sworn or attested to by a person on its behalf. The affidavit must confirm the URA’s compliance with the conditions. It must also confirm the total number of members of the URA, and exhibit a list of the names and addresses of the members of the URA who, in the vote authorising the URA to seek judicial review, cast a vote in favour of bringing the proceedings.


Built Environment Sector Update - In Brief

Environmental Legal Costs Financial Assistance Mechanism A significant reform which has been retained in the approved Bill is the introduction of the Environmental Legal Costs Financial Assistance Mechanism (ELCFAM). This will be a means-tested legal aid scheme for applicants in judicial review and other Aarhus Convention (environmental) cases where parties will be required to bear their own costs. Costs paid under the ELCFAM will be on a fixed scale established specifically for these type of cases. If an applicant is successful in its case, it will be able to recover its costs in line with the scale. If an applicant is unsuccessful, it may receive a contribution to its costs from the ELCFAM proportionate to the applicant’s means assessment.

Conclusion The Bill was referred to the Select Committee on Housing, Local Government and Heritage on 7 December 2023. The Select Committee will propose any further amendments to the Bill. These will then be debated after the Dáil resumes on 17 January 2024. It is hoped that the Bill will be enacted in the first quarter of 2024. Please get in touch with a member of our Planning and Environment team if you would like to discuss.


Built Environment Sector Update - In Brief

The Irish CRE Market – Can it Survive to 2025? Irene Nic Chárthaigh Partner, Financial Services

As 2023 came to a close the European Central Bank (ECB) predicted that the euro zone’s sinking commercial property sector could struggle for years to come, posing a threat to the banks and investors that financed it. We consider the causes and symptoms of the distress in the Irish commercial real estate (CRE) market, the lessons that can be learnt from the US and UK, and whether a further repricing of the market is likely. We will also examine the potential catalysts in bringing about a market correction and the investment opportunities that will result.

Neil Campbell Partner, Head of Financial Services

Current state of the Irish CRE market Rising funding costs, tightening credit standards and a deterioration in sentiment amongst market participants have caused investment activity in the Irish CRE sector to decrease. This slow down stood at nearly 60% by the end of the third quarter of 2023 compared to the same period in 2022. This has been accompanied by a sharp decline in property capital values, down 14% year-on-year according to 2023 Q3 data from the Central Bank of Ireland, bringing the cumulative fall to over 20% since late 2019. As of the time of writing, the Central 7

Built Environment Sector Update - In Brief

Bank of Ireland has not yet published its year end data, but it is predicted the CRE investment activity in 2023 will be significantly below the 10-year average. The office sector is currently the worst performing, with the largest price declines for lower quality, older and less energy efficient units. While rising interest rates have put downward pressure on prices in the Irish CRE market, waning tenant demand due to remote working policies and a change in Irish tech firms’ office requirements, has also played a significant role. CBRE report that the vacancy rate across all stock in the Dublin office market is now close to 15%, this is the highest point since 2014.

Distress in the commercial real estate market is not unique to Ireland. Globally, commercial property investment is at an all-time low. This is largely driven by the same factors: high interest rates and waning demand for office space. Despite this, there has not yet been a significant repricing of the CRE market. Sources indicate that in the 12 months up to the end of March 2023, US-listed real estate prices decreased by 14%, compared to 22% in the UK for the same period and 13% in Europe. Some of the reasons for this are:

On the finance side, lenders are reporting sizeable movement of CRE loans to stage 2 arrears. This is defined under accounting standards as a significant increase in credit risk. One bank’s half year results reported an increase of stage 2 loans from €2.3 billion to €3.7 billion in its property and construction portfolio, excluding residential mortgages. €1.6 billion of this was made up of commercial investment exposures, most of which were commercial investment office loans. For context, the bank cited potential interest cover breaches and an unlikelihood of these borrowers being able to meet refinance terms as causes of this movement.

• Assets being refinanced rather than repriced

On a more positive note, the Central Bank has recently reported that Irish banks’ CRE exposures are a much smaller portion of total lending than in the past. They had declined significantly since the 2008 financial crisis from just over 30% to under 10%. CRE borrowers now have loan-to-value (LTV) ratios that will allow for substantial price declines before losses are experienced, with the estimated weighted average current LTV of banks’ CRE investment exposures currently around 50%.

While it is clear the Irish CRE market is in need of further repricing, we must look to the potential solutions in making that happen, and whether they are likely to be borrower-led or lender-led.

However, the Central Bank now warns that LTV positions are subject to elevated risks relating to market liquidity when trying to realise collateral values in a stressed market.


Comparisons with the US and UK CRE markets

and sold, and

• Lack of willingness from sellers to accept low

offers, particularly in London where purchasers are seeking to pay over a quarter below the asking price

• As with the UK and US markets, there remains

unrealistic pricing in the Irish CRE sector. There needs to be a cyclical pricing correction in weaker CRE assets to bring liquidity back to the market.

Opportunities and solutions

The price gap between sellers and purchasers can, at least in part, be explained by timing of loan maturities and the “pretend and extend” phenomenon. The Central Bank reported in its most recent Quarterly Financial Stability Review that most commercial real estate loans owed to banks need to be repaid or refinanced by 2027, with a quarter due by the end of 2024.

Built Environment Energy Sector Update Sector - In Brief Update - In Brief

Despite this, the prevalent attitude among market participants is “survive to 2025”. We should expect to see extensions, modifications and a variety of other tactics as lenders and borrowers “hold-on” in the hope of “waiting- out” the high interest rates and for market conditions to improve. In the current market, enforcement makes little sense to lenders who will be hard-pressed to get more out of these assets than the current owners. However, if lenders are unwilling or unable to extend new credit or refinance the existing loans, owners will be forced to align their pricing to make assets more attractive. As the traditional banks look to keep their LTV and Non-Performing Exposure (NPE) ratios in line with ECB requirements, many CRE loans will be unable to refinance without creative solutions from borrowers and alternative lenders. KPMG’s recent Irish Real Estate Lending Survey paints a picture of the difference in attitude between senior banks and non-bank lenders regarding appetite for risk. In terms of lending for office projects, 50% of senior banks said that they would lend at an LTV ratio of up to 59%, while 50% would lend at an LTV ratio of up to 69%. When non-bank lenders were asked the same question, a third said they would lend at an LTV ratio of up to 69% and 44% said they would lend at an LTV ratio of up to 79%. The conservative approach of the traditional banks will require borrower-led resolutions. These might include:

by alternative lenders, as demand for alternative financing grows. Alternative financing solutions include additional sponsor equity, mezzanine and junior debt insertions and preferred equity lending, or a combination of these. Indeed, we are aware of private equity credit funds being set up for this purpose. If refinancing is not achievable, and owners do not elect to put their properties back on the market, an orderly sale of loans on a consensual basis with sponsors is the most likely course of action for banks as they look to protect their balance sheets. This approach is prevalent in the US market at the moment. This presents another opportunity for investors to purchase portfolios of non-performing loans or loans experiencing stress at a discount. Alternatively, investors experienced in asset restructurings may adopt a loan-to-own strategy and acquire discounted, non-performing debt to lead a restructuring, becoming the equity owner of a property at a discounted valuation. Receivership is an important tool for lenders if a borrower enters repayment difficulty. The Beckett Building formerly occupied by Meta is a recent high-profile example of a Dublin office put into receivership. Bought by Korea-based Kookmin Bank for €104 million, it was put back on the market at a significantly reduced price of €80 million.

• An injection of additional sponsor equity • Putting in place hedging agreements to

safeguard against interest rate rises, and

• Consensual sales This kind of creative capital structuring may plug the gap until interest rates start to level out. The ECB restrictions on the traditional banks have resulted in a widening of the debt-funding gap. It is defined as the gap to be bridged between the original debt amount due at loan maturity and new debt available to repay the original debt. The debt-funding gap presents an opportunity for lender-led resolutions in the form of investment


Built Environment Sector Update - In Brief

Even at €80 million, the owners were unable to find traction for a sale and, reportedly, the lender was in a position to accept an offer as low as €60 million. The repossession and potential sale of CRE assets by lenders has the potential to exacerbate price declines. Receivership numbers remain low. From the stock of outstanding balances owed by Irish CRE borrowers in June 2023, just 0.1 per cent of these balances are associated with a receivership initiation in 2023. This is broadly in line with an average of 0.2 per cent for the years 2020 to 2022, which suggests this trend is set to continue in the near term at least.

Conclusion Despite economists predicting cuts by Q2 2024, ECB interest rates remain stubbornly high and with Eurozone inflation rising again in December 2023, the economic outlook remains uncertain. If we do not see interest rates tapering off from Q2 2024 onwards, traditional lenders may be forced to take more aggressive action against borrowers in an effort to protect their balance sheets. This may come in the form of loan portfolio sales. Of course, these sales will offer an alternative entry point for investors and will also open the door to loan-toown strategies. We may also see increased levels of receiver sales if lenders decide to enforce.


Movement in the CRE market may be triggered if traditional lenders lose confidence in the value of CRE loans and borrowers’ resilience wanes in the current market conditions. If borrowers cannot refinance with the traditional lenders, they may look to alternative lenders with strong balance sheets to offer equity top-ups and other forms of alternative financing to help bridge the debt funding gap. While market participants have adopted the “survive to 2025” mantra, 2025 may seem a long way away for those borrowers due to refinance during 2024. For more information and expert advice on navigating the issues impacting the CRE market in 2024, contact a member of our Financial Services team.

Built Environment Update - In-Brief Built EnvironmentSector Sector Update In Brief

ESG in the Built Environment Sector Emer Shelly Partner, Corporate Governance

In the dynamic ESG landscape, 2024 will be another pivotal year. Recent and upcoming groundbreaking legislative developments will continue to reshape the corporate landscape in the built environment sector across the European Union. The ongoing paradigm shift towards increased transparency and accountability around the sustainability of business practices is set to continue at pace. As businesses in the built environment sector navigate their ever-evolving ESG obligations, we explore some key trends and developments set to unfold in 2024.

Taxonomy Regulation The Taxonomy Regulation entered into force on 12 July 2020. It lays down a classification system to determine whether an economic activity is “environmentally sustainable”. To be “environmentally sustainable”, an activity must: 1.


Contribute substantially to one or more environmental objectives, including climate change adaptation and climate change mitigation Not significantly harm any remaining environmental objectives

3. Be carried out in compliance with minimum social safeguards, and 4. Comply with technical screening criteria (TSC)

Jay Sattin Partner, Planning & Environment

Detailed TSC have been developed for real-estate activities, including “Acquisition and ownership of buildings” and “Construction of new buildings”, to determine if those activities may be considered “environmentally sustainable”. Companies obliged to make disclosures under Article 8 of the Taxonomy Regulation are required to assess how and to what extent their economic activities associated with real estate are considered “environmentally sustainable”, or, “taxonomy-aligned”. Continuing throughout 2024 and beyond, we expect to see an increased appetite from purchasers and developers to achieve taxonomyalignment for new builds. Funders of real estate activities, such as banks and real estate funds/asset managers, will also have an interest in assessing taxonomy-alignment to meet their disclosure requirements. In terms of practical implications, we expect to see:

• Involvement between all parties at an earlier

stage of construction to ensure taxonomyalignment is maintained up to the point of sale

• Specifications included in contractual

arrangements with subcontractors and suppliers to ensure taxonomy-alignment

• Assurances regarding taxonomy-alignment

included in contractual documentation, and

• Certificates regarding taxonomy-alignment provided upon completion


Built Environment Sector Update - In Brief

Corporate Sustainability Reporting Directive (CSRD) The CSRD introduces a comprehensive new framework aimed at enhancing the transparency, reliability and comparability of corporate sustainability disclosures across the EU. Under the CSRD, many large and listed companies will be required to make detailed annual disclosures on their impact and performance relating to a broad range of environmental, social and governance factors in line with new uniform reporting standards. With the CSRD having been brought into force at EU level last year, 2024 will be another landmark year on the path towards full implementation of the new framework. The transposition of the CSRD into Irish national law is expected by no later than July of this year. It will bring certainty to Irish in scope companies on the full extent of their legal obligations. The first phase of reporting obligations under the CSRD also commences this year. Any large company which is already subject to the NonFinancial Reporting Directive (NFRD) will be required to prepare its first CSRD-compliant sustainability report for its financial year commencing on or after 1 January 2024. All companies within the built environment sector which fall into that category therefore need to ensure that they are prepared for those reporting obligations. This means, for example:

• Ensuring that they have familiarised themselves with the reporting standards and conducted a “double materiality” analysis to identify their precise reporting requirements

• Identified and engaged with all relevant stakeholders on their double materiality analysis, and

• Put in place systems and practices to collect

reliable sustainability information for reporting purposes


Other large or listed companies within the built environment sector which will fall within the scope of reporting requirements for financial years commencing in 2025 or 2026 should continue their preparations for CSRD reporting in earnest. Throughout 2024 and beyond, all companies, whether or not subject to the CSRD, can expect to face an increased demand and expectation for stakeholder access to sustainability information. More detailed information on the CSRD is available from our ESG hub.

Corporate Sustainability Due Diligence Directive In another measure intended to complement the CSRD and further enhance the protection of the environment and human rights in the EU and more globally, the Council of the European Union and the European Parliament recently reached provisional political agreement on the proposed Corporate Sustainability Due Diligence Directive (CSDDD). The CSDDD is a far-reaching proposal which will oblige companies within its scope to carry out significant due diligence to identify actual or potential adverse impacts on the environment and human rights within their own operations and across their value chains and to then prevent, mitigate and/or bring an end to those adverse impacts. It is also proposed that certain companies will be required to implement a climate change transition plan to ensure that the company’s business model and strategy are aligned with the EU’s climate change targets under the Paris Agreement. The precise scope of the CSDDD is not yet final but it is expected to apply to large EU companies with more than 500 employees and a net worldwide turnover over €150 million. It is also likely to apply to certain smaller companies within high-risk sectors and to non-EU companies with significant turnover in the EU.

Built Environment Sector Update - In Brief

The provisional agreement includes agreement on enforcement measures, including injunctions and substantial fines, which may be as high as 5% of a company’s global turnover. We will provide further updates as the legislative process continues in 2024.

Deforestation Regulation The EU’s Deforestation Regulation entered into force on 29 June 2023. It will largely replace the EU’s Timber Regulation from 30 December 2024. Although the deadline is not impending, operators and traders such as developers, contractors, etc, that import relevant commodities , like wood or related products such as wood flooring, into the EU market will need to start reviewing their supply chain for such goods. The Deforestation Regulation will go much further than the Timber Regulation by prohibiting coffee, cocoa, soya, cattle, oil palm, rubber, wood and certain related products sourced from lands that have been deforested or forests that have been degraded after 31 December 2020. Related products are wide-ranging including:

• Sheets for veneering • Certain wood flooring • Particle board • Tools • Builders’ joinery and carpentry of wood • Tableware and kitchenware • Prefabricated buildings of wood • Vulcanised rubber • Unvulcanised rubber, and • Leather


They must be produced in accordance with relevant legislation of the country of production, and


Are covered by a valid statement certifying that extensive due diligence has been carried out as to the source of the timber or timber product

Enforcement powers are extensive including temporary exclusion from public procurement processes and confiscation of revenue gained from the trade of the relevant commodities or products.

Circular Economy The Government and the Environmental Protection Agency (EPA) have identified the construction and demolition sector as Ireland’s largest producer of waste. The level of recycling of waste produced by this sector is considered too low. This is in part due to the difficulties with re-classifying waste aggregates as reusable material. To address this issue, in October 2023 the EPA published National End-of-Waste Decision EoW-N001/2023. This establishes criteria for determining when recycled aggregate ceases to be waste under article 28 of the European Union (Waste Directive) Regulations 2011 – 2020. The criteria allow for the replacement of virgin aggregates with recycled aggregates in uses such as general fill, road construction, railway ballast and other non-structural uses. Aside from the publication of the EPA’s National End-of-Waste Decision EoW-N001/2023, it is expected that the Minister for Environment, Climate and Communications will make regulations regarding the re-classification and re-use of certain construction and demolition waste as recycled aggregates. This will provide further statutory footing to this practice and should provide reassurance for developers and contractors as to what waste can be reused on site.

To import and export timber and timber products from 30 December 2024, operators and traders will have to ensure that the relevant commodities and related products that they place or make available on the EU market are ‘deforestation free’:


Built Environment Sector Update - In Brief

The Government’s approach to construction and demolition waste is part of their “Waste Action Plan for a Circular Economy” and Circular Economy Strategy. Other waste streams have also been targeted under the schemes, such as the change in 2023 requiring certain producers of packaging material, packaging or packaged products, which could include certain developers and contractors, to become a member of Repak.

Conclusion In summary, 2024 will see not merely a continuation of ongoing trends but will see another defining year where legal frameworks and industry practices converge to usher in a new era of corporate responsibility. We recommend that those in the built environment sector take note of the upcoming legislative changes concerning ESG to ensure they ready to fully comply with the new requirements. For more information and expert advice, contact a member of our ESG team.


Built Environment Sector Update - In Brief


Built Environment Sector Update - In Brief

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