Dr. Donal McManus:

As I do not have Mr. Dunne's fluency, I will read my written submission, a lot of which is similar to what our colleagues in the Housing Alliance have submitted.

I thank the joint committee for inviting the Irish Council for Social Housing, ICSH, to engage with it on one of the most significant issues affecting the sector. I am joined by two colleagues, Ms Karen Murphy, director of policy, and Ms Tina Donaghy, elected vice president at the ICSH and head of development at Fold Ireland, a tier 3 body.

The ICSH is the national federation of 260 housing associations that collectively own and manage over 35,000 homes provided at affordable rents for families, older people, people with disabilities, the homeless and single people. The housing association sector in Ireland is part of the wider social housing sector in Europe which has over 22 million homes throughout the European Union. A common factor within these jurisdictions is state support, directly or indirectly, to house people in the social housing sector, including through housing associations or approved housing bodies, as they are referred to in Ireland. Without state support, it is unlikely that many of the households in the social housing sector would be housed in accommodation with affordable rents. Members of the ICSH include larger tier 3 bodies which are managing over 300 to 6,000 homes such as the Housing Alliance and local and regional tier 1 and tier 2 approved housing bodies which provide housing and related support services for vulnerable groups in local communities and respond to specific local housing needs. Overall, the sector is committed to developing and managing social housing in the long-term and addressing the changing needs of the population.

I turn to classification. It is now almost a year and a half since EUROSTAT reclassified 14 approved housing bodies, placing them within the local government sub-sector. At the time and repeatedly since, including at this Oireachtas committee, the sector has stated its major concerns at this development for housing associations and welcomed the commitment of the Minister, Deputy Eoghan Murphy, and the Minister of State, Deputy English, to work towards the return of all approved housing bodies to off-balance sheet status. Since 2018, the CSO has begun the process of examining tier 2 approved housing bodies which include a mixture of approved housing bodies which are providing general needs housing, as well as those which provide more specialist housing for the homeless, older people and people with disabilities. However, in the 18 months since the CSO's decision and its subsequent confirmation by EUROSTAT, there has been little concrete progress in the undertaking of a thorough review of the decision or a change management programme to reverse it. The ICSH and the Housing Alliance have made proposals to assist a policy review and requested the establishment of a working group comprising departmental representatives and with an input from sector representatives. However, that has not happened.

As a sector we have been working on proposals and have also commissioned research to assist in our work in this and related areas, including examining the scope of social and affordable housing as a service of general economic interest, SGEI, under EU rules. In addition, the ICSH undertook, with Housing Europe, in 2017, a survey of the classification status of the housing association sectors in other EU member states and found the vast majority were off balance sheet.

In our view classification remains a significant issue, which will have long-term effects on the sector. For now, the sector's ability to deliver homes under Rebuilding Ireland has not diminished in delivery terms, but this is under the current capital plan and in the context of a housing crisis. Our concern is that in the medium and long term, the current on-balance sheet status will restrict ability to deliver social housing in the event of either a sharp restriction in the availability of public finances and a lot of other competing Exchequer demands, or in the event of a shallowing out of the political support for social housing provision. It is our experience that the provision of homes for vulnerable and low-income households is a continuous requirement and the severe reduction of capital funding for social housing during the financial downturn has contributed to the lack of suitable, affordable housing now evident. As a spillover effect from classification, a number of other public bodies are making public policy decisions based on the sector being controlled by the State.

We are grateful to the committee for this discussion today and propose that a working group be established to report within a six-month timeframe on a change management platform, which will work proactively towards reversing the classification decision, in co-operation with the sector, within a reasonable timeframe of 18 months to two years. This would help to set a target to take approved housing bodies, AHBs, off balance sheet by budget 2021.

This change management programme could address contractual agreements, degree of financing and risk exposure, and will involve consideration of changes to legislation, regulation, financing, and housing management reform. In doing so we will be helping to build further the capacity of an independent, well-regulated AHB sector that provides quality housing for the long term. We are committed to working with all the key stakeholders to ensure the best outcome for social housing delivery.

Last year the sector provided 3,219 social homes, 38% of the national total, and took more than 4,000 households off the social housing waiting list. A total of 54% were new build social homes provided by ICSH members to households on the social housing waiting list, 33% were acquisitions and 13% were leased. As a sector, we have delivered 6,700 homes since Rebuilding Ireland was launched and we hope to reach our 2021 target of 15,000 social homes. Our current pipeline is almost 5,000 homes or projects actually on site and funding approved to go on site. This does not include many more homes currently planned and further back in the development pipeline.

The target for 2019 is approximately 2,500 homes, excluding leasing, which we expect to achieve. As a sector there are challenges to the continued delivery at a high level, including the classification issue, high concentration of one lending source, access to land for continuous delivery, and the need for additional affordable rental options beyond current pilots. The classification issue is the central part of these other key issues. The publication of the regulation Bill is expected shortly and we look forward to that.

As a sector we are committed to the provision of permanent, affordable homes for people whose needs are not met by the private housing market and for people with special needs requiring housing and support. We look forward to hearing any comments the committee has following this address, or indeed on the paper we forwarded previously to the committee.