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Reaction to the draft Programme for Government
17th Jun, 2020

Clúid welcomes the recognition of the key role of Approved Housing Bodies (AHBs) in housing delivery within the Programme for Government. The range of commitments made in relation to affordable rental housing, a national differential rents scheme, the provision of age-friendly housing, the reclassification of AHBs and building defects is also very promising. AHBs, having supplied over 40% of all social housing in 2019, over 4,000 homes across the country, are willing and ready to work with Government and local authorities to deliver on these objectives.

Though the full extent of the impact of the global health crisis on the Irish economy has yet to fully materialise, it is quite clear that we are facing into challenging times. It is absolutely vital that spending on social and affordable housing is prioritised, both in order to meet continued high levels of demand and so that the construction sector maintains capacity in the coming years.

We look forward to collaborating with the new Government in continuing to provide high-quality, affordable housing throughout Ireland, to ensure that the innovative thinking demonstrated during the Covid-19 crisis is extended to housing.

Clúid welcomes the following initiatives outlined in the draft Programme for Government.

Affordable Home Ownership
We welcome all efforts to ensure housing is more affordable for households across Ireland. However, it is our view that the focus of an affordable housing programme should be on affordable rental housing, to allow for affordability for households in perpetuity. This would offer the opportunity of affordable housing across generations and acknowledges the reality that not everyone can or wants to own their own home. Security and affordability can be achieved outside of home ownership.

A greater focus on affordable rental would also allow for the build-up of housing stock, which would result in the potential for cost rental housing at an affordable level. In other words, at the point that costs of loan finance for the property are paid off, rents could be set at levels which would not necessarily require a Government subsidy in order to be affordable.

Land Development Agency – LDA
We support the role of the LDA set out in the Programme for Government. The work of the Agency will be important in ensuring that all available land reserves are used in an efficient and effective  banner. However, we strongly feel that the AHB sector has a large role to play in this regard. AHBs have a strong track-record of delivering high-quality, sustainable housing. We look forward to partnering with the LDA in delivering social and affordable housing throughout the country.

In addition, while maximum utilisation of public land should form a core aspect of the LDA’s strategy, we believe that the full potential of private land must also be explored, in order to allow us to meet existing need for housing in Ireland.

Part V
We support the commitment to explore expanding Part V to encompass affordable purchase and cost rental units. Part V has been an effective tool in delivering social housing within private residential developments throughout the country for two decades. However, the inclusion of affordable purchase and cost rental housing should come as a result of an expansion of the overall Part V requirement. In other words, that the current requirement would be increased beyond 10% perhaps to 20%. It is important that social housing delivery would not be displaced by affordable and cost rental housing, but expanding overall provision of social and affordable housing through increasing Part V.

Right to Housing
While a commitment to a referendum on the right to housing demonstrates an understanding of the importance of housing as an issue among the public, it would be important that efforts in this regard would serve to complement a drive to increase delivery of social and affordable housing. Indeed, it should not serve to delay or divert from the central issue of increasing housing output.

Retrofitting
Details regarding a National Retrofitting Plan are promising. In order to reap the full environment and social benefits, it is essential that the scheme would also apply to social landlords, like AHBs.

Commission on Housing
We endorse an evidence-based approach to housing policy in Ireland. It is essential that policy is informed by research and that a long-term view is applied reflecting the long term nature of housing. However, similarly to the right to housing, a Commission on Housing should not delay decisions key to the delivery of and commitment to the delivery of social and affordable housing in Ireland.

Reclassification
We greatly welcome a commitment in the Programme to Government to implementing a series of reforms in order to allow for AHBs to move off-balance sheet. Reclassification of the sector is key to allowing us to access funding and to maintain delivery. The current economic context, with increasing pressures on health and social welfare expenditure by Government, makes this all the more important.

Social Housing Passport
We welcome the reference to introducing a social housing passport, to allow for greater mobility of tenants. This is important in affording greater freedom to social housing tenants and will also allow for a more effective use of social housing stock.

National differential rent scheme
We welcome a commitment to a standardised differential rent scheme nationwide. This allow for greater equity among tenants and will also simplify rent collection processes for AHBs and local authorities, allowing us to devote more resources to the delivery of additional homes.

Choice based letting
Choice based letting, which has already been rolled out across a number of local authorities, allows for greater autonomy for social housing tenants, and can result in more rapid allocation of housing, ensuring that social homes do not remain vacant at a time when they are much-needed. We therefore welcome a commitment to a website to allow for choice-based letting on a nationwide basis.

Defects
We welcome a promise in the Programme for Government to examine the issue of housing defects in the first 12 months of Government. It is essential that the mistakes of the past in this regard can be learned from and that the impact of defects is fully acknowledged, remedied and mitigated.

Use it or Lose it
We welcome a reference to the introduction of a ‘use it or lose it’ condition for all planning applications of ten units or more. It is essential that initiatives to encourage the use of land and disincentivise the act of landhoarding are effective. While we look forward to further detail on this, it is hoped that it will have a tangibly effect on both land use and land prices. In addition, the commitment to strengthen enforcement of the Vacant Site Levy is welcomed.

Housing Need and Demand Assessments
While a commitment to Housing Need and Demand Assessments was already set out in the National Development Plan, its reference in the Programme for Government is positive. This will provide us with a far clearer view of the need and demand for social and affordable housing into the future across Ireland.

Housing for older people
The number of references to the importance of provision of age-friendly housing for older people is greatly welcomed. It is essential that older people are provided with a full range of residential options, from housing with support to independent living and that this is embedded into our planning system. This has become more critical following the issues raised regarding current models of provision as a result of COVID 19.

Management Companies
We welcome a commitment to a review of existing legislation relating to Owners’ Management Companies in Multi-Unit Developments. A 2018 report commissioned by Clúid Housing and the Housing Agency found deficiencies in relation to the functioning of OMCs in Ireland, including inadequate guidance regarding sinking fund levels. To achieve density required under national planning frameworks we need efficient functioning of owner management companies. A review of legislation would potentially lead to positive changes in this regard.

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