Dr. David Duffy:

I thank the committee for inviting PII to attend. I am accompanied by Mr. John Spain, chair of PII's planning and development committee. PII is an independent and inclusive representative organisation for all subsectors of the Irish property industry. Membership of the organisation is open to all professional firms across the property industry.

PII views the SHD process as a key part of its planning system and recommends that consideration be given to making it a permanent feature. Whereas the supply of new homes has improved, it remains below estimated levels of new household formation. The scheme has contributed greatly to speeding up decision-making processes on major housing developments at a time of major shortages in housing supply in Dublin and around the country. Up to the end of June, out of the 71 applications decided by An Bord Pleanála, 49 cases of permission have been granted, leaving an approval rate of just under 70%. This has resulted in 11,388 housing units being approved, comprising 7,038 apartments and 4,350 houses, together with 7,981 student bed spaces.

Given the very significant increase in large-scale housing planning applications since the scheme was introduced in 2017, we expect to see a commensurate increase in construction activity over the next 12 months, feeding through to a further significant increase in new housing completions over the next few years. The SHD process has been particularly successful in encouraging apartment developments in the more central areas of our cities, which will greatly assist in regeneration and result in a more sustainable pattern of housing provision, reducing the dependence on car-based, low-density housing in peripheral locations. This is particularly important if we are to achieve the Government's climate change objectives as they relate to urban development. Much of this increase in activity is funded by overseas investors, who find the certainty of the timescale for decisions on strategic housing development applications particularly encouraging.

There is inevitably a time lag between a grant of permission and commencement of construction. This applies to cases of strategic housing development permission just as it does to standard planning permission. There are a number of reasons for this time lag, including the need to obtain compliance approval from the local authority with respect to pre-commencement conditions, the need to agree Part V social housing provision details and the need to agree water and drainage details with Irish Water.

In some cases, commencement is dependent on upgrades to local infrastructure by Irish Water or the local authority. In other cases, amendments to elements of the scheme are required prior to commencement due to changing market requirements or it can take time to finalise funding arrangements for construction. Typically, it may take six months or more to get responses from a local authority to pre-commencement compliance submissions. The time lag between permission being granted and commencement of construction may be anything from six months to two years for these reasons.

As part of PII’s submission to the SHD review, we made several recommendations aimed at improving the efficiency and impact of the scheme. In light of time constraints, I will list only these recommendations, but we are happy to discuss them in more detail. An Bord Pleanála should be permitted to request further information where the only alternative is a refusal of permission and the potential reason or reasons for refusal are capable of being addressed by further information. Further information is permitted in strategic infrastructure development applications and is often requested. The occasional use of similar provisions in normal planning appeals under section 132 of the Planning and Development Act has proven very effective.

A higher proportion of commercial use to complement residential use should be allowed, especially for larger schemes. Additional resources should be allocated to Irish Water to reduce the length of time it takes to produce documentation. Prescribed bodies should be required to engage at pre-application stage. The requirement to refer to material contravention in notices and on the application form should be removed. It would be of great assistance to applicants if there were more specific comments in An Bord Pleanála opinions at pre-application stage in respect of what is or is not considered acceptable and what changes may be required to make a scheme acceptable. An Bord Pleanála should be encouraged to review its approach to requiring a minimum density level for SHD sites. The SHD system should move fully online and a section of the An Bord Pleanála should be dedicated to SHD applications.

There is a need for clarity on the procedure for amendment applications to approved SHD schemes. Amendment applications are best dealt with by local planning authorities. Resourcing and capacity at local authority and An Bord Pleanála levels should be reviewed. The SHD process should be optional for applicants. There is a need to clarify the treatment of SHD applications in strategic development zone planning scheme areas.

We are happy to discuss our recommendations to the SHD review in more detail with the committee.