Ms Karen Murphy:

I can speak to the Deputy's question about the change management programme and give some further detail on that. As Dr. McManus and Mr. Dunne have alluded to, the first question would be whether it was a cross-stakeholder working group that was leading on it.

The first job would be to scope what is required and what that change management programme might look like. We have drafted proposals containing our own ideas and submitted them, but it is somewhat of a vacuum at the moment in terms of the ones that would need to be progressed or what might need to be added.

In terms of our proposals, we would be looking at legislation. The regulation Bill is a significant part of that but other legislative change may be required, for example, in respect of approved housing body status, which will be dealt with by the regulation Bill, but also other aspects of funding that may need to be dealt with through legislation.

Another one is looking at the financing, for example, a move towards a greater stream of affordable rental coming into the sector. We can look at whether that would help in terms of the overall position and the criteria on which the CSO came to its decision. If we had a greater degree of rental income from affordable rents, for example, would that change the position?

These are our proposals or areas for discussion. We do not know, because we do not have any feedback, the extent to which one criterion is more important than another. Much of the ruling was quite subjective. It is about engaging with the other parties so that we know which elements of a change management programme should be prioritised.

There are other areas such as reform of the rental scheme. The CSO pointed to the differential rents and the fact that they were guided by local authorities, which would be similar to housing assistance payment, HAP, and rental accommodation scheme, RAS, rents, for example. To what extent is that a significant factor? If change is required in that respect, we need to deal with that. We would not see that as an insurmountable problem.

Another is in respect of the nominations process, which was pointed to in the decision. We have suggestions in our proposals around choice-based lettings, which are used in HAP.

Looking at dealing with the individual criteria the CSO ruled on and the extent to which we may or may not need to make changes, we need to have that conversation and scope out the elements that need to be addressed and those that are less important. There were some changes to the funding systems that we thought may need to be addressed also. For example, the CSO criteria looked at the degree of risk the State held through contractual agreements. Our view is that there is quite a lot of risk on the approved housing body, AHB, through some of the more recent agreements. However, we would need to consider whether any further changes are required to balance out that perceived risk in the CSO criteria in respect of the financing. There are some areas we believe could be on the table such as the historic debt and whether that could be dealt with in a way that would change the perception of the CSO and EUROSTAT of the way our sector is perceived to be controlled by local government.

Those are detailed, technical aspects of the programme that we believe could be brought in to address the CSO's concerns. One or two of those elements may be enough to deal with the reclassification decision. What we need to do is get into the detail of that.