Mr. Dominic Stevens:

I am a lecturer in TU Dublin and, in private practice as an architect, a director in JFOC Architects, a company that has helped to deliver more than 10,000 homes over the past 35 years. During my involvement with JFOC over the past eight years, we have specialised exclusively in residential living in low-, medium- and high-density environments, with projects in planning and in construction across Ireland. I am here with Ms Claire McManus, who is the other director of JFOC. She sits on the Housing Agency's supply and affordability panel, the joint housing committee of the Department of Housing, Local Government and Heritage and the RIAI, the Central Statistics Office's housing statistical working group and Dublin City Council's special purpose housing committee, along with being the RIAI spokesperson on housing.

My early career was in Germany. Over the years, I have stayed in touch with practice there, in particular housing practice. This has provided me with insights into both systems. Modern methods of construction lie at the core of the production of German housing. Others have already discussed the technical and industry aspects of this matter, so I wish to discuss a number of other key issues related to design, planning and regulation.

By way of introduction, it is crucial for the planning and regulatory systems to adapt to be able to serve the production of affordable housing using MMC. It has to be understood that the future of MMC lies in off-site timber frame manufacture for both low-rise and high-rise buildings. This affords great potential for meeting our climate goals and for growing a domestic high-tech timber manufacturing industry. For the timber frame manufacturers who operate in Ireland, tooling up for large amounts of repetition across projects over a longer period could greatly increase efficiency and will reduce building costs.

There is a great deal of discussion around whether we should have national housing standards or allow local authorities to set their own standards. To have any hope of delivering MMC at scale, we need national standards. We should be proud of our housing standards as being among the highest in Europe, both in terms of space standards and building standards. We should not be afraid of Irish minimum standards. Indeed, we can be proud that the Irish minimum standard apartment is among the largest in Europe.

We will have considerable difficulty delivering these efficiencies through MMC without adaptation to planning and regulatory environments for two main reasons. First, the Irish planning system, where bespoke solutions are often insisted upon, and standards differ from county to county. Second, the guidelines and building regulations are constantly changing, particularly over the past six months or a year. To give an example in practice, we are currently working on designs for planning applications that are based on our winning Housing Unlocked competition design. We developed this design with timber frame manufacturers FastHouse to be an example of economic off-site construction. This design was selected as excellent by a jury of architects, urban designers and housing experts, so we can safely assert that it proposes high quality. Despite this, when we apply the solutions proposed in this design to individual local authorities in the planning process, it meets with resistance despite meeting all regulations. It simply does not seem "orthodox" to them, so they apply their own subjective opinions. This problem is added to because almost all housing projects of a certain scale end up being subject to third-party appeals and requests for further information, which often lead to further modifications.

It has been recognised that these and many other inefficiencies in planning bring uncertainty for investors, costly and unnecessary delays for delivery, missed opportunities for contractors and housing shortfalls for the population. From an MMC perspective where certainty is required in order to tool up for repetition, this lack of certainty in the planning process could be fatal.

Returning to my early career in Germany, when we compare the German and Irish planning systems, we find two democratic systems that are fundamental to our constitutions. Both have national, regional and local planning levels, which follow professional and political procedures. However, there are three fundamental lessons that we can learn from Germany about efficiency, accountability and certainty in development.

Regarding efficiency, the planning effort in Germany is applied first to larger master plan areas called B Plans. This process brings community involvement forward to the beginning of the process and is equivalent to an Irish strategic development zone, SDZ. The more contentious issues, such as building height and density, are decided at plan formation stage. These are as demanding to get in place, but once decided, they set a fixed rule for the development of an entire area. By complying with the established rules, all sites coming forward for development can get planning approval much faster, so much so that, as a young architect, I did not really think about planning permissions as being any kind of barrier in the process.

Regarding accountability, planning rules in Germany are not policy, but law, called the Bürgerliches Gesetzbuch, or BGB. In this sense, the pre-application advice is legally binding for the local planning authority. This allows certainty. Our entire economy works on accountability and performance, so there is no reason that a council should not behave in the same way.

Regarding certainty, development law in Germany translates ambiguity into rule-based formulas. These set clear rules for site coverage, building height, maximum floor area etc. You get all this confirmed via a pre-application and you know exactly where you are going. This certainty invites more smaller players who cannot afford to gamble hundreds of thousands of euro on planning applications, with high chances of refusal or overturning.

A question that arises when you speak to the man on the street about prefabrication and MMC is whether repetition is important to be able to do it effectively, whether repetition in housing is tantamount to poor quality and whether it constitutes prefabrication. In fact, repetition has always been crucial in the production of housing, even using traditional construction methods. Urban designers often refer to housing and offices as "fabric" as opposed to public buildings, which they call "monuments". If we step outside into Georgian Dublin, we are in a sea of similar house types. If we walk a little further into Portobello or the Liberties, we once again see repeating Victorian house types. We view these as being highly desirable. It is not the same with more recent housing, where each individual apartment building is, for some reason, unique. This has happened through the architecture profession responding to the demands of a planning system that seems to favour novelty and bespoke design. Using MMC, alterations to specific finishes, window styles and so forth remain possible, but the main thrust of the building design and form is best fixed.

Think of a Georgian house. They all have the same floor plan and the same logic.