Ms Orla Hegarty:

It is a difficult one to call. We saw what happened when it was deregulated. Some of the volume going through An Bord Pleanála in recent years relates to sites that had permission. There were sites that had ready-to-go permission for build-to-sell apartments at five to nine floors that were then knocked off track by the raising of height caps, SHDs and build-to-rent standards. These changes might seem simple on paper but they can be extremely disruptive in the market. That relates to my earlier point about a risk assessment of policy. I do not think policy has been risk assessed. The broader shaking out of this, including the what-ifs and making sure these things are closed off, is very important because in speculation the money will all follow what is most attractive. We saw what happened with ghost estates. Just because it was viable to build one estate of so many houses in an area, it did not mean it was viable to build 2,000 of those houses, yet people borrowed, got planning permissions and raised land values. We then saw it did not wash out.

There is now a concern that the implications of any changes need to be very carefully assessed. There needs to be a look at transition arrangements relating to that. My point is there are technical solutions to this affordability challenge and there are solutions to the capacity challenge, but they need to be technical solutions. It is not enough that there be high-level policy decisions. There has to be a technical solution involving the people who are delivering and who know where the blockages are. Broader high-level policy needs to have some vision. What is the intention for what the housing system will be in 2030 or 2040? Is it a model where the vast majority of people in Dublin rent, pay a very high rent and there is a Government subsidy for the long term? Is it the case that, again, we will have an issue with sprawl into the commuter belt? People do not find that attractive as what they want. Will we have a surplus of SHD high-density units that are not attractive and that maybe become large developments of social housing that do not have sufficient amenities for residents?

There is risk in all of this. The policy response has not often considered that what is right for one site may not be right for the city.