Mr. Francis Doherty:

I thank the Chairperson and members for the invitation extended to the Peter McVerry Trust to attend today. Much of the commentary on short-term lettings just focus on the letting platform Airbnb. What we would like to stress is that this is simply the largest concentration of short-term lettings online. There are many other businesses and individuals operating in the market who do not use the platform. The rise in the number of short-term lettings in such an unregulated manner is another symptom of a highly dysfunctional housing system, while short-term lettings do not have a major impact on the housing system as a whole, at present they can in specific small or local area systems have deeply negative and disruptive impacts. The rise can also disproportionately impact on specific groups within the housing system, such as people reliant on private rented units for their accommodation. It is also of concern that the use of short-term letting is growing in popularity as it does have the potential clearly to grow to such a point that the broader housing system is more deeply impacted. The manner in which short-term letting has grown also points to deeper problems with our planning system and particular shortcomings in how we monitor and enforce planning legislation.

In assessing the impact of short-term letting, the Peter McVerry Trust has framed this presentation around three critical issues - these are entire properties to rent; businesses or individuals engaged in multi-unit lettings; and, non-compliance with planning regulations. With respect to the negative impact on the availability of rental properties, the primary issue of concern to the Peter McVerry Trust is that the rapid rise in short-term lettings has caused a further decline in the number of properties to rent under a normal medium-term lease. This is critical because the private rental market remains the main access route for people leaving homelessness, particularly for single adults, who would otherwise face very long waits for social housing opportunities. The growth in short-term lettings has undoubtedly led to traditional rental properties transitioning to the short-term lettings market. This reduces overall supply. It impacts on Peter McVerry Trust's ability to move people out of homelessness and of course, most important, negatively impacts on people in homelessness. At any point in time, the rapid rise in the number of properties lost to short-term letting is concerning, given that supplies have been disrupted and reduced. It is of particular concern at the current time when the availability of rented properties in Dublin and other high needs areas is at a historically low level. Peter McVerry Trust is concerned that existing rental properties are being transitioned to short-term lettings. This means a tenant being evicted and displaced. At present sitting tenants are being evicted by property owners in order to facilitate a shift from medium-term to short-term letting. We do not have any record of specific instances and it is perfectly feasible that some tenants have ended up in homeless services as a result of property moving to the short-term lettings market. For the property owner, higher yields secured through short-term lease model and a commercial environment, devoid of any genuine regulation, make sense.

Short-term letting also has the potential to impact on new supply. It is likely to reduce the number of new properties to rent in the future and to also impact on the ability of potential home owners to buy homes. This arises because of a significant growth in the number of businesses and individuals engaged in large-scale commercial multi-unit lettings. In 2016, there was a significant increase in the number of multi-unit users of the Airbnb platform. Given the absence of regulation and the high yields available, many investors are now acquiring properties on the market to add to their short-term lettings portfolios. This means those same properties cannot be used as traditional rental properties or cannot be bought by home buyers or owner-occupiers.

We have tried to focus on one area to give an example of how short-term letting can impact on housing in an area. In this regard, we have taken Dublin 1, where the Petter McVerry Trust is based and has historical links. Currently, there are more short-term rental properties available in the Dublin 1 area than there are traditional rental units. In other words, there are approximately 40 traditional rental properties and in the region of 300 short-term lets available. As this is in an area in which there are significant levels of overcrowding in existing rental properties, acute levels of social housing need and almost a complete absence of affordable housing options, the impacts are clear. While a significant number of those short-term listings are found on Airbnb, the majority are not listed on that platform. One relatively new actor in the short-term lettings market in this area has converted a number of residential properties to commercial short-term lettings, without any record of planning approval. The Peter McVerry Trust estimates that within the immediate environs of Mountjoy Square, Dublin 1, at least 30 former rental units have been lost in the past 18 months as a result of illegal change of use for the purposes of short-term lets. The trust is aware that this is reflected across other residential buildings in other parts of Dublin 1 and Dublin 7. Some of these instances have been highlighted by us and others in the media this year.

We would like to place on record our recognition that for some owners the use of short-term letting is a means to afford their housing. This can be due to the need to address a legacy from the housing boom and financial crash, with many property owners stuck with devalued assets and crippling mortgages. Equally, many people are facing very real challenges in holding on to their accommodation and the use of short-term lettings may offer them the chance to retain their homes. The Peter McVerry Trust would hope that the committee would recognise these sensitivities when considering how best these individuals and home owners can be supported to comply with planning, health and safety and tax issues. It is almost a separate body of work to tackle the actions of commercial businesses and individuals operating full-time lettings of entire properties, which is a smaller but rapidly growing segment of the short-term lettings market.

As regards recommendations, previous speakers have pointed to the lack of data. Evidence is needed to boost of our understanding and to formulate policy. On planning enforcement, the Peter McVerry Trust believes that at the very least a proactive response from local authorities is needed to ensure full planning compliance regarding properties used for short-term leases. This may require a cultural shift because, as one local authority official stated, enforcement would, as a first, action-oriented step, lead to an immediate reduction in the use of illegal short-term lettings. We would also urge consideration of a term defined ban on residential to commercial change-of-use applications in respect of short-term lettings in light of the current housing crisis. This measure, when combined with an enforcement approach, would push the owners of properties who let them, in their entirety and on a full-time basis, to put them back into the housing system, thereby increasing the number of properties to rent or buy.

The committee should examine the need to review and, if necessary, amend the Planning and Development Act to ensure the imposition of adequate financial penalties on those found to be in breach of planning legislation . International evidence, particularly from the US, with respect to Airbnb hosts shows that this is the most effective deterrent to prevent illegal listings. It is important that we try to address the problem rather that the publicity. We would have serious reservations about an MoU with Airbnb. We believe that legislation and enforcement of existing legislation is the best course of action.