Mr. Michael Walsh:

Thank you. I am joined by my colleague here from Dublin City Council, Mr. Colm Smyth, principal environmental health officer and I will touch on some of the elements of the written statement considering the time issues.

First with myself and Mr. Smyth representing Waterford and Dublin respectively, we present a reasonable picture of the largest urban authority and a smaller urban authority in Waterford city, with a significant rural element in terms of the county area.

We broadly agree and are working with the Department on the current policy position which is to ramp up inspections as quickly as possible and we see 2021 as being the realistic position for reaching a 25% target in terms of inspections on an annual basis. We see that being prioritised. Our general view is that this would be very dependent on the data being generated, if we were to move to a risk-based approach, and a rate of around 20% may well achieve such compliance, as long as it is a targeted risk context.

There has been significant improvement over recent years. I note the Threshold reference to 2016, but the simple reality is that there has been in excess of a 50% increase in 2017. There will be a further 50% increase in the rate of inspections in the current year. There is a significant effort and resource going into this issue. Dublin City Council in the current year have employed 12 additional environmental enforcement officers to ramp up their activities. In my own instance, where I already had one with back office support, now we have increased that by employing a further inspector. We would see ourselves as moving to between 15% and 20% of inspections annually by next year. Right across the county there is a very significant additional resource being provided. We are working with the Department in terms of the areas that Mr. Dunne would have outlined already, and we will see that bringing about significant improvement.

Patently, we would accept the position as outlined by Threshold in some respects that there is an element of contravention and, human nature being what it is, we must strive to get the balance between enforcement and compliance right. The nature of contraventions vary very significantly, from nominal contraventions, that do not necessarily have a major impact on the living conditions for those tenants occupying the buildings, to things that are more serious, in terms of health and safety or otherwise. We want to gather this data ultimately and are currently looking to develop an ICT system that can report comprehensively in that context. We have listed some of the types of contraventions and I will not go through all of them. It is fair to say that pre-1963 properties are a particular difficulty. We are also finding difficulty with the most recent regulatory changes in 2017, where in regard to some of the elements provided for in terms of window restrictors or carbon monoxide detection or otherwise, people simply have not caught up with or may or may not be aware of them. There is certainly a need for the provision of further and continuing information to such landlords.

We have outlined a number of improvements that we would intend to achieve in the first instance in our statement and we would equally say there are spaces that we would certainly be open to dialogue on, and on which perhaps the Oireachtas or the Minister have a role in enhancing powers.

It is certain, and I would emphasise this, that the resource base around the inspection regime is very significant and has to be ramped up really significantly if there is going to be impact in this context.

At the end of the day, there are a number of choices. Who then pays for that? There is the landlord, the State, and the tenant, obviously. In general terms the landlord suffering these costs will ultimately pass them on to the tenant, which is the reality. We need to get to a point - which we are not at the moment - where full compliance is the norm. It is fair to say that the majority of landlords, particularly professional landlords, are compliant. It is equally the case that there is a minority where compliance is not the norm and the challenge for us, as regulators, is to ensure compliance. We welcome dialogue about how we get there. We are seeking continual improvement here and we welcome this committee's consideration of this issue because our common goal is very simple. We want to ensure we get to a point where compliance is absolutely the norm.