Dr. Donal McManus:

I thank the joint committee for the invitation to address it. I am CEO of the ICSH, the national federation of housing associations. Mr colleague Mr. O'Connor is CEO of the Túath Housing Association, one of our active tier 3 member bodies providing housing throughout the country. The ICSH has more than 250 members. Collectively, the sector manages more than 35,000 homes at affordable rents for families, older people, people with disabilities, the homeless and single people. The committee is probably familiar with our members as being more single purpose organisations dedicated to the management of homes and the building of sustainable communities. Housing associations work in partnership with local authorities and play their part collectively in meeting the housing needs of people assessed as being in need of housing by local authorities.

Approved housing bodies are to provide one third of the 50,000 homes to be supplied under Rebuilding Ireland until 2021, which equates to approximately 15,000 homes per year, with local authorities providing the bulk. In 2017 Approved housing bodies in the housing association sector delivered 2,330 long-term permanent social rented homes, that was the highest annual level the sector had ever recorded and accounted for around one third of the overall delivery of permanent social housing, with local authorities providing the remainder. As part of the increased delivery by approved housing bodies, a number of larger tier 3 bodies provided a significant number of homes and have ongoing development programmes for the coming years. Of the 2,330 homes delivered by the sector in 2017, 1,078 were delivered through new construction, 760 through acquisitions and 492 through long-term leasing.

In July the Department of Housing, Planning and Local Government, through the Housing Agency, issued a second call for proposals under the enhanced leasing scheme as part of its delivery under Rebuilding Ireland. Enhanced leasing appears to be targeted at developers and new builds, vacant properties and new homes to the market, with properties to be delivered at scale and at a minimum of 20 homes. Enhanced leasing is intended to complement the existing long-term measures available from local authorities. As structured, the scheme provides a long-term leasing arrangement, whereby property owners provide maintenance services and local authorities lease the units and take on landlord responsibilities. The property owner is paid rent of up to 95% of the market rent and the local authority collects differential rent from the tenants. Homes are provided by the properties' owners and the other stakeholders - the local authorities.

It has been suggested approved housing bodies could have a role under the scheme. To date, they have not been involved in its design. The enhanced leasing scheme could work in some cases where an approved housing body is contracted by the local authority under a service level agreement to provide landlord or tenant services as an agent. In our analysis, however, this scenario could present issues for the approved housing body. For example, it could only resolve issues on the ground such as rent arrears and the performance of the lessor in providing repairs and maintenance services through the local authority. In this scenario the role of the approved housing body is limited and where problems arise, the intervention of the local authority is key, as it is the contractual partner to the lessor.

Another possible arrangement that has been mooted but is not part of the scheme could see an approved housing body act as landlord, with the tenant signed up to the body's own tenancy agreement. The body would have the flexibility to take action as and when required.

The sector is open to different options for making the scheme work, but there are probably value for money issues with enhanced leasing and it does not provide permanent social housing. In our limited contact with stakeholders in the private sector they have indicated to us that there are issues with how properties would be managed. In a sense, how social housing is managed is not private developers' primary focus.

An investor-led lease that attracted pension and ethical funds and was provided by professional non-profit housing management could be delivered by approved housing bodies over the period of the lease and beyond.

It can be off balance sheet and typical of models in other EU member states, with both approved housing bodies and local authorities participating at scale.

Land initiatives are linked with local authorities in terms of the supply of land. For housing associations to increase the delivery of new social housing homes, access to sites is critical. To date, this has occurred on an ad hocbasis. A continuous supply of residential land and sites is central to having a development pipeline in the housing association sector being able to meet its social housing targets.

Up to 2010, approved housing bodies had access to land in local communities, which included land donated with covenants by charitable bodies, as well as land accessed below market value. In addition, one of the most successful schemes for approved housing bodies was the local authority low cost sites scheme, under which local authorities transferred sites to housing associations to allow them to provide housing and supports for people on local authority waiting lists. These options are now severely limited. Together with the sector having virtually no landbank of its own, this has meant that it has had in recent years to organise other routes to gain access to building sites. Some of them have necessitated housing associations working with the private sector through various turnkey and joint ventures to deliver housing. This has been important in being able to stimulate employment for local construction firms, as well as providing new homes. However, there are still several local authority sites being developed by approved housing bodies. Examples include Respond in Blackpool in Cork, Túath Housing in Crumlin in Dublin and and Clúid in Kinsale, County Cork. In addition, a number of local authority regeneration projects are being developed by approved housing bodies in partnership with the local authority. They include Clúid at St. Mary's Mansions in Dublin and Fold at Dolphins Park in Dublin.

Recently, there has been a call by the Housing Agency for expressions of interest to approved housing bodies for 37 sites they have available for social and other forms of housing. The sites include those assembled through the land aggregation scheme. This is welcome as it provides another option for approved housing bodies.

In our view, the new Land Development Agency can play a crucial role in enabling activation of suitable State-owned sites for both social and affordable rental housing in a strategic manner, as well as enabling delivery with landowners in the private sector. It is important that there be a strong focus on ensuring all suitable State land is made available for housing purposes. The onus should be on the public or State body to explain why the land should not be available to be prioritised for housing.

Public private partnerships have a limited role in this process. A small number of approved housing bodies have worked with PPPs in several ways through the social housing delivery programme as one of the partners. However, here is a long lead-in time in this process. The role tends to be more as a management agent. The social housing PPP bundles are based on the provision of services in developments over a 25-year period following construction that will include the maintenance and upkeep of housing, with the return of the asset after 25 years to the owner.

In contributing to the housing system the examples given are part of the menu of responses to compliment mainstream delivery by housing associations and local authorities. Land initiatives potentially can have the most significant and positive long-term impact on the housing and land markets. Nothing has been done since the Kenny report and the report of the all-party Oireachtas committee in 2003. This will assist in the provision of housing, both social housing and other tenures, where affordability is a key concern.