Eoin Ó Broin (Dublin Mid West, Sinn Fein) | Oireachtas source

That does not address my question in the sense that I fully accept the phrase "substantial works", if it is just the phrase "substantial works" that is legally ambiguous. The Minister of State had one option, which would have been to provide regulations to clarify very explicitly what substantial works were. The Minister of State has chosen not to do that. Instead, he has used a different word, which is "commenced", and regulations will be used but it is not in any way clear that what the Minister of State is not doing is lowering the threshold. Yes, it will provide clarity.

The worry here is that there are two types of developers. Let us take the example of residential development. Somebody acquires land, gets planning permission and wants to build and whether they are building or not depends on all sorts of factors. Could there be other people who are speculatively sitting on land, for example? Maybe there has been a dip in house prices or an increase in interest rates. They want to hold on to that planning permission until it is more economically advantageous but that could have the detrimental impact of delaying the delivery of much-needed housing. Surely there should be a threshold which is not just "commenced"?