Mr. James Benson:

I thank the Chairman and committee members. I am accompanied today by the director general of the CIF, Mr. Tom Parlon. The Irish Home Builders Association, IHBA, is a constituent association of the CIF. We represent hundreds of homebuilders of all sizes across Ireland and support Irish homebuilders to deliver quality affordable homes to homebuyers. A priority for the CIF and the IHBA is to deliver much-needed homes for those struggling to access the market and find suitable accommodation.

The past number of years have been particularly difficult for aspiring homebuyers who have struggled against the challenges of a lack of supply and affordability. As members of the committee will be aware, much of this has been the result of well-documented issues with a lack of investment in infrastructure which created viability issues and ultimately placed an unfair onus on first-time buyers and new home purchasers to fund upgrades to the benefit of the wider community. Critically, our planning system has witnessed relatively little change in some 20 years and requires holistic reform. The lack of speed and certainty within the planning system led to the introduction by the then Government of the strategic housing development, SHD, process in 2017 to provide a fast-track mechanism for planning permission for housing schemes of 100-plus homes. Essentially, it was hoped that with mandatory timelines, together with seeking permission directly from An Bord Pleanála, it would lead to a greater number of applications for large-scale developments and a timelier commencement of planning permissions.

Prior to the Covid-19 pandemic, the construction industry was on an upward trajectory with substantial investment planned to result in a steady increase of annual housing numbers across all tenures. IHBA members continue to report strong demand not least due to the fact that we have seen the under-provision of some 80,000 homes over the past five years alone. However, despite pent-up demand, the industry is witnessing a concerning slowdown in planning permissions. The number of planning applications submitted during the first quarter of 2021 in terms of units is down 29%. While some of this significant decline is likely a direct result of the restrictions imposed over the first quarter of 2021 arising from the pandemic, it has also been caused by the uncertainty, risk and cost of planning, which means many homebuilders have had to take the decision to hold back potential applications.

Granted schemes were also down some 26% and commencement notices lodged down 44%. Well-documented factors impacting the planning system, most notably the substantial rise in the number of judicial reviews taken against SHDs, have resulted in many schemes being substantially delayed or quashed entirely in the courts. The processing of applications has also been impacted by recent referrals to the European Court of Justice and has resulted in many of our members being forced to indefinitely shelve large-scale housing projects. It is estimated that somewhere in the region of 75,000 potential family homes could be at risk as a result of these judicial reviews and referrals.

The industry welcomed the review of the SHD process and the Government’s recognition that further change is required. We are glad to see the draft planning and development (amendment) (large-scale residential development) Bill. It must be noted that the draft transition away from SHD and specified timelines do not currently align. The actual time taken by An Bord Pleanála to issue opinions does not allow sufficient time for applicants to review its comments and lodge an application in advance of February 2022.

The proposed new scheme needs to address the impact of appeals, which have hampered the SHD process. While no one would question the right of appeal and the need for a robust process for third parties, it is universally acknowledged that we are in desperate need of housing and the number of delayed or quashed developments speaks for itself. If the new scheme is to be effective, the local authorities and An Bord Pleanála should be fully resourced to meet the mandatory timelines set out within the Bill. Early interaction and mandatory response parameters from the prescribed bodies should be used to determine capacity and any technical issues at any early stage in the process.

Currently, planning permission is no guarantee of viability. While it may not be the ultimate rationale for grant or refusal, a discussion on economics and viability of any development is required at an early stage. It is for this reason that we have a high level of delayed permissions yet to commence on site. The issue of economic viability may be best addressed at the county development plan preparation stage or potentially at pre-application stage.

We welcome the recent publication of the Housing for All plan from the Government and believe it goes a long way towards meeting the challenges we currently face in terms of supply and affordability.

The numbers contained in the plan are ambitious, but we believe they are fully achievable. Many of the actions in the plan will require additional capacity within and outside the sector. The CIF and the Irish Home Builders Association are committed to delivering these much-needed quality and affordable homes across the country and our members will work hard to supply the homes. However, it is critical that issues such as planning and infrastructure, which are impeding delivery, are tackled.