HOUSING AND ACCOMMODATION - SOCIAL JUSTICE IRELAND

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6.
Housing and Accommodation

    CORE POLICY OBJECTIVE: HOUSING & ACCOMMODATION
    To ensure that adequate and appropriate accommodation is available for all
    people and to develop an equitable system for allocating resources within the
    housing sector.

The provision of adequate, and appropriate accommodation is a key element of
Social Justice Ireland’s Social Charter framework as outlined in Chapter 2. To achieve
this objective in the years ahead, Social Justice Ireland believes that the Government
must:

•     Ensure that the current commitments in the Rebuilding Ireland Action Plan
      are achieved at a minimum, and that more ambitious targets are set;
•     Introduce measures to increase the supply of new social housing stock on the
      scale required to eliminate the current waiting list and to meet the needs of
      an expanding population, particularly in urban centres (that is, an increase
      substantially beyond what is planned for in the government’s current
      strategy);
•     Explore all funding options and financing structures to generate sufficient
      capital to adequately finance the social housing need;
•     Provide increased resources for homeless services, focusing on preventative
      measures and information for persons at risk of homelessness, and an increase
      in adequate social housing supply prioritised for those who are homeless
      or at risk of homelessness with appropriate supports to ensure a reasonable
      standard.

6.1 Current Housing Supply
Census 2016 puts the current housing stock at 2,003,645 in 2016, of which just
under 1.7 million are occupied and over 180,000 are vacant units, excluding
holiday homes (CSO, 2017(a)). Table 6.1 shows house completions in the various
sectors from 2001 to date using the metric of ESB Connections on which housing

116                                                          Social Justice Matters 2018
policy has been developed up to now (DHPLG, 2018(a)). The overall picture of
housing development identified by this data illustrates the disparity in housing
provision pre- and post- Recession. In the six-year period 2001-06, 24,257 local
authority houses were completed. In the same period the voluntary/non-profit
sector completed 8,427, giving a total of 32,684 social housing completions. In the
six-year period 2010-15, the total number of houses completed by local authorities
was 4,703 while voluntary/non-profit housing associations completed 3,108,
producing a total of 7,811 social housing units - a fall of almost 25,000 units (76 per
cent) compared to the 2001-06 period. The number of private houses completed
in the 2010-15 period fell to 60,499, a drop of 85 per cent compared to the 2001-06
period. While reported local authority completions increased to 247 in 2016, this
figure is less than 5 percent of those reported in 2007.

Table 6.1 - House Completions – ESB Connections, 2001-16
   Year                 Local          Voluntary /              Private                 Total
                    Authority           Non Profit             Housing
                     Housing              Housing
   2001                   3,622                1,253              47,727               52,602
   2002                   4,403                1,360              51,932               57,695
   2003                   4,516                1,617              62,686               68,819
   2004                   3,539                1,607              71,808               76,954
   2005                   4,209                1,350              75,398               80,957
   2006                   3,968                1,240              88,211               93,419
   2007                   4,986                1,685              71,356               78,027
   2008                   4,905                1,896              44,923               51,721
   2009                   3,362                2,011              21,076               26,420
   2010                   1,328                  741              12,533               14,602
   2011                     486                  745               9,295               10,480
   2012                     363                  653                7,472               8,488
   2013                     293                  211                7,797               8,301
   2014                     158                  357              10,501               11,016
   2015                      75                  401              12,901               12,666
   2016                     247                  331              14,354               14,932
Source: Department of Housing, Planning and Local Government Housing Statistics (2018(a)). Note:
Local authority house completions do not include second-hand houses acquired by them. New units
acquired under Part V, Planning & Development Acts 2000-2006 for local authority rental purposes
are included. Voluntary and co-operative housing consists of housing provided under the capital
loan & subsidy and capital assistance schemes.

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It is interesting to note that the Department of Housing, Planning and Local
Government (DHPLG) have amended their terminology in describing these
statistics from ‘house completions’ to ‘ESB Connections’, a more accurate reflection
of what they are as identified by Tom Healy, director of the Nevin Economic Research
Institute (NERI), in a blog post written in February 2017 highlighting the likelihood
that, with the crash in the property market, there was a stock of incomplete and
unoccupied dwellings lying idle for a number of years before an uplift in market
activity meant they were then connected to the ESB network, or which were
unoccupied for a period of more than two years before being reconnected to the
ESB network and then classified as ‘new dwellings’ using the old methodology.
These connections could not be accurately counted as ‘house completions’ in that
relevant year and the latter re-connections were being counted as constructed in at
least two different years.

According to the Building Construction Management System statistics, 4,844
commencement certificates were issued by local authorities in 2016 in respect of
13,234 residential units, of which 4,012 were single residential units. This brings
the total number of scheme units to just 9,222 (DHPLG, 2018(b)). The number of
Homebond Guarantee House Registrations reported in 2016 was just 5,626, rising
to 9,023 for the first 11 months of 201771.

Census 2016 reported just 2 per cent of householders (33,436) indicated that their
house was built between 2011 and 2016, an average of just 6,687 per year in that
time.

The latest Goodbody BER Tracker at time of writing puts total construction in the
first 11 months of 2017 at 8,659, based on new BER certificates issued in that time
(Irish Times, 2018).

There are multiple indices emerging which try to provide an accurate reflection of
construction in Ireland, each holding a piece of the puzzle. Social Justice Ireland calls
on Government to stop drafting housing policies on the basis of ESB Connections
and to review all existing datasets available to it to provide an accurate measure
of construction in the State, providing the starting point for policy aimed at
addressing the need. It is clear that increasing supply is necessary, but how much
that increase needs to be will depend on how much is currently available.

In Budget 2018, the Government allocated €1.9 billion for housing. While this
represents a welcome increase on previous allocations, a large proportion of this
€1.9 billion (€1.14 billion) will fund the construction of just 4,969 new homes
and the acquisition of a further 900. This means that less than 20 per cent of the
proposed 25,469 increase in social housing for 2018 will come from new supply.
71
     HomeBond provides a 10 year warranty on new homes to cover structural defects.
     According to the Department of Housing, Planning and Local Government,
     registrations are normally issued one month before work commences on the site.

118                                                           Social Justice Matters 2018
The Government’s Local Infrastructure Housing Activation Fund will also receive
€60 million to make available sites for the development of 20,000 homes by 2021,
with the aim that at least 10 per cent of homes built will be made available for social
housing. It is further intended that the majority of sites made available will have a
proportion of homes available for less than €320,000. Macroprudential mortgage
application measures introduced in 2015 means that a deposit of €32,000 (for first
time buyers) or €64,000 (for other borrowers) would be required before a borrower
could access a mortgage on a home worth €320,000. It is questionable how
affordable such deposits would be to those 85,799 families on the social housing
waiting list.

According to the most recent figures there were 183,312 (excluding holiday
homes) vacant properties on Census night 2016 (CSO, 2017(a)). Of these, 140,120
were houses and 43,192 were apartments. While this figure represents a decrease
in vacancy rates per population size in all counties when compared to Census
2011, when the preliminary figures for each county are compared to the county
breakdown of the Social Housing Needs Assessment 2017 (Housing Agency, 2017)
there are more vacant properties than households in need (Chart 6.1) in almost
every county (with the exception of Dublin and Kildare).

Chart 6.1: Vacant units 2016 v Social Housing Waiting Lists 2017, by County

Source: Census 2016, www.cso.ie and Housing Agency, Summary of Social Housing Assessments
2017, January 2018

Further, according to the DHPLG, over 8,500 voids were put back into use since
2014 with the introduction of the Vacant Properties (Voids) Programme (although
this figure has been called into question (Dáil Debates, 2017(a)).

Housing and Accommodation                                                                   119
6.2 Current Housing Need
Social Housing Output
Statistics on social housing output were updated and refined to remove reference
to completions which were deemed ‘In Progress’ and to include reference to
Regeneration and Voids in the Local Authority statistics; the Social Housing
Current Expenditure Programme (SCHEP) in the Voluntary and Co-operative
Housing statistics; and introduce statistics on two State payments to private
landlords - Rental Accommodation Scheme (RAS) and Housing Assistance Payment
(HAP) (Chart 6.2).

Chart 6.2: Social Housing Output 2004 to 2016

Source: Extracted from Department of the Housing, Planning and Local Government, Housing
Statistics, Overall Social Housing Statistics 2004 to 2016
Notes (as appear on DHPLG website with statistics): (Please note that capital and current
programme data are collected separately so may not appear at the same time)
1 Voluntary & co-operative housing consists of housing provided under the capital loan & subsidy
   and capital assistance schemes.
2 Includes some units acquired under Part V, Planning and Development Acts 2000-2015 for rental
   purposes. For the full overview of the Part V data for 2016 please refer to http://www.housing.gov.
   ie/housing/statistics/affordable-housing/affordable-housing-and-part-v-statistics.
3 Acquisitions by local authorities of second-hand houses.
4 RAS - New transfers is defined as the number of households which have moved from Rent
   Supplement to RAS in that specific year. It includes households who remained in their existing
   accommodation and those for whom the LA had to source new properties.
5 HAP - New Households Supported refers to the number of qualified households with an established
   housing need who are being accommodated under the HAP scheme for that year. The first phase of
   the statutory pilot for the HAP scheme commenced in September 2014 and the data for 2014 refers
   to new households supported between September and December 2014.
6 SCHEP - New units operational are defined as the number of new SHCEP units which the LA is
   claiming under this scheme in the given period. This program was previously known as long-term
   leasing until 2014.
7 Regeneration and Voids are included in this table from 2015 onwards only.

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Social Housing Needs Assessments
According to the Social Housing Needs Assessments published in January 2018,
there were 85,799 households on the waiting list for social housing, presenting as
a decrease of over six per cent on the previous year (Housing Agency, 2017, 2016),
however in real terms the reduction is half that amount. The counts for the 2016
and 2017 Social Housing Needs Assessments were conducted in September 2016
and June 2017 respectively. The number of households transferred to HAP from
Rent Supplement in Q4 2016 and Q1 and 2 of 2017 was 3,054, or almost 53 per cent
of the reported decrease. There is also almost 30,000 households in receipt of HAP,
deemed having their housing need met by way of a subsidy for increasing private
rent. Added together, there are at least 115,667 households in need of sustainable,
affordable, long-term housing.

There has also been some debate surrounding the methodology used by local
authorities in collecting information about those still on the housing list, namely
an ‘opt in’ letter requesting information on housing status which, if not returned,
resulted in automatic removal from the housing list. While discretion was given
to local authorities to make further contacts by telephone and text message, this
method of data collection adversely affects those with low literacy skills and
those with reduced capacity to engage in this manner, whether through stress or
other socio-economic factors, and therefore risks excluding the most vulnerable.
Another factor may be that while those in receipt of Rent Supplement are counted,
and account for 41 per cent of households on the social housing waiting list,
those in receipt of the HAP72, living in local authority rented accommodation,
accommodation under the Rental Accommodation Scheme, accommodation
provided under the Social Housing Capital Expenditure Programmes or any
households on the transfer list are not counted as in need of social housing
assistance. The number of new HAP tenancies created up to Q3 2017 was 13,375
(2,528 of which were transferred from Rent Supplement). When added to the total
number in receipt of HAP in 2016 (16,493) (DHCLG, 2018(c)), this amounts to
over 30,000 households. With Government policy to transfer those households in
receipt of Rent Supplement to HAP on a phased basis, it is probable that the real
72
     Rent Supplement is a means-test payment provided by the Department of Social
     Protection to people on low incomes living in private rented accommodation
     provided they have been living for six months out of the previous year in private
     rented accommodation, homeless accommodation or institutional accommodation
     or if the tenant has, within the last year, been assessed as being in need of social
     housing in the last year. The payment is usually made directly to the tenant who pays
     it, together with a contribution from their own income, to the landlord. Housing
     Assistance Payment is a means-tested payment for those in long-term housing need.
     It is provided by local authorities on a means-tested basis to tenants of private rented
     accommodation in receipt of Rent Supplement for a period of at least 12 months
     or to tenants who could originally have afforded their rent but due to a change in
     circumstances have found themselves unable to do so for a period of 183 days in the
     previous 12 months or to persons who were residing in homeless or institutional
     accommodation for a period of 183 days in the previous 12 months. The payment is
     made directly to the landlord.

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number of households in need of social housing is significantly higher than that
stated in 2017, and that statistics in this area will continue to be distorted by the
omission of key data from the count.

Of the 85,799 households on the waiting list, the highest percentage is in Dublin
(41.5 per cent), followed by Cork (almost 10.5 per cent), Kildare (almost 6 per cent)
and Galway (almost five per cent). The age profile of households on the waiting
list has changed little since the previous assessment in 2016, with the percentage
of those aged 30-39 years old remaining the same, an increase across each of the
age profiles from 40-49 and older, and a decrease in those less than 29 years old.
This is unsurprising, given the length of time households are waiting for social
housing, with exactly half waiting four years or more, and 24.2 per cent, or 20,803
households, waiting more than seven years, compared to 21.2 per cent in 2016 and
only 9 per cent in 2013.

The household composition of those on the social housing waiting list has changed
little since 2016, with families accounting for 55 per cent, 47,139 households, and
single person households making 44.5 per cent. The remaining 0.673 per cent is
multi-adult households. 3,544 households cited ‘overcrowding’ as the main need
for social housing in the Social Housing Needs Assessment, however overcrowding
(that is more persons per household than rooms) is an increasingly prevalent issue,
with Census 2016 reporting a 28 per cent increase in overcrowding (from 73,997
permanent households to 95,013) in the intercensal period from 2011 to 2016,
accounting for close to 10 per cent of the population (CSO, 2017(a)).

The majority of households on the social housing waiting list (64.6 per cent) are
living in private rented accommodation, with 41 per cent of households stating
‘Dependent on Rent Supplement’ as their main housing need. The remainder are
living with parents or other relatives, in emergency accommodation, or classified
as having ‘Other’ tenure. One per cent, or 1,119 households, are owner occupied.
The over-reliance on private rented accommodation to meet the housing demand
should cause concern when viewed in light of the failure of the private sector to
build housing on the scale required and the continuing housing need of those on
low incomes in such accommodation.

Mortgage Arrears
If long term sustainable solutions to mortgage arrears are not found, many more
families will find themselves in need of social housing. There are 72,489 home
mortgages in arrears (Q3 2017) with Central Bank regulated lenders, with 50,688
in arrears of more than 90 days (Central Bank of Ireland, 2017). 119,070 home
mortgages are in restructured arrangements, with almost 38 per cent on reduced
payments, 15.8 per cent classified as ‘Other’ (which can include reduced repayment
arrangements or temporary arrangements) and 23 per cent on ‘split mortgages’.
Households with ‘split mortgages’ are most precarious where it is unlikely that they
73
     This is an anomaly in the Housing Agency document, most likely due to rounding off

122                                                          Social Justice Matters 2018
will experience a change in financial circumstances over the term of the loan and
will therefore be dependent on realising the equity at the end of the warehoused
period in order to pay the amount due. These families will then be faced with the
prospect of selling their family home when they are at or close to retirement age.
By the end of Q3 2017, 1,717 mortgages were in possession of Central Bank lenders.
Non-bank entities held 48,868 mortgages over homes and investment properties,
37 per cent of which are held by unregulated loan owners. Due to this unregulated
status, the borrowers concerned, many of whom are in dire arrears situations (42 per
cent of home mortgages held by unregulated loan owners are 720 days in arrears,
more than 2.5 times the rate of home mortgages held by regulated retail credit
firms), have been stripped of even the most basic consumer protections. Due to the
nature of such funds, whose motives are profit-driven, repossessions are likely to
be more prevalent among this cohort, resulting in greater need for social housing.

According to the latest statistics released by DHPLG at time of writing, over 45 per
cent of all local authority mortgages were in arrears in Q3 2017, representing 7,328
low income families, 3,953 of which are in arrears of more than 90 days (DHPLG,
2018(d))74. The latest local authority repossession figures show 22 forced and 45
voluntary repossessions took place in 2016 (DHPLG, 2018(e)). The only option for
these families is adequate social housing, which this and previous Governments
have failed to provide.

Population Expansion
The latest Census data (CSO, 2017(b)) shows a population increase between 2011
and 2016 of 3.8 per cent, or 173,613 people (when migration is accounted for),
bringing the total population of the State to over 4.7 billion people. The natural
increase in population (births minus deaths) was 196,100, a reduction of 30,000 on
the previous intercensal period which is largely attributed to a fall in births (22,800
decrease on figures produced in Census 2011). 80 per cent of the net increase of
173,613 in population (138,899) was experienced in urban areas, with Dublin and
surrounding counties and parts of Munster experiencing the largest percentage
increases in population.

In addition to increased population, Census 2016 also noted an increase in
household formation (i.e. the number of new households is growing) of 2.9 per
cent compared to an increase in population of 3.7 per cent and has resulted in an
increase in average household size for the first time since 1996. This means that in
areas such as Fingal where the rate of population growth (8.1 per cent) was almost
twice that of household formation (4.4 per cent – based on preliminary figures),
further investment in construction is urgently needed to accommodate a young
and expanding community.

74
     It should be noted that the Department of Housing, Planning and Local Government
     changed their methodology and were revised in Q1 2017.

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A preliminary update of Housing Supply Requirements 2016 to 2020 prepared by
Future Analytics for the Housing Agency in February 2017 (Future Analytics, 2017)
indicated that the 445 urban settlements which were home to 500 people or more
in 2011 are predicted to experience a growth of 8.6 per cent to 2020; an increase of
262,000 people. Of these 445 urban settlements, 248 will experience a supply deficit
in the five years up to and including 2020 at the current rate of supply. Two-thirds
of those likely to experience a deficit are currently home to 1,000 people or more.
This update further identifies a minimum housing supply requirement of 81,118
homes nationally, with 79,215 of these needed in the largest population centres.
The average annual minimum home provision requirement is therefore 16,224
nationally, with 15,843 in the largest population centres (Future Analytics, 2017:1).
Dublin County is predicted to need the highest housing supply nationally, with
35,242 homes required each year, which is hardly surprising given the number of
households on the social housing waiting list and the number of homeless persons
in the county.

In their article on household formation, the ESRI (Duffy et al, 2014) projected
annual growth in household formation of up to 33,000 to 2030. While the figures
may vary to an extent, it is a reasonable extrapolation to predict a net demand
requirement of somewhere between 16,000 and 33,000. This is further supported
by a NERI Working Paper (Healy and Goldrick-Kelly, 2017:51) which cites demand
of 25,000 to 35,000 once population expansion and an obsolescence rate of 0.5 per
cent per annum is accounted for.

Homelessness
Ireland’s homelessness crisis continues to worsen. Figures for December 2017
indicate that 5,508 adults and 3,079 children accessed emergency accommodation
– a total of 8,587 people75 (Chart 6.3). The number of homeless children in Ireland
exceeded 3,000 for the first time in August 2017, having increased consistently
each month of the year, decreasing slightly in December as in previous years. The
most recent rough sleeper count, taken in Winter (November) 2017 (Dublin Region
Homeless Executive, 2017), confirmed 184 persons sleeping rough on the night of
the count, an increase of almost 30 per cent on the previous Winter and over twice
that of Winter 2015. After taking this number into account, the number of people
in need of emergency services in November 2017 (9,041) increased by over a quarter
(27 per cent) since November 2016, and that is without considering the number of
hidden homeless – those staying with friends and family or living in squats.

Continuing a trend in recent years, November 2017 was the month that saw a peak
in the number of families accessing emergency homeless accommodation in that
year, a total of 1,530 families (and 3,333 dependents), an increase of 27 per cent on
the previous year. Dublin continues to account for the majority of homelessness,
with 71 per cent of all homeless persons reported as accessing services there, and
may be said to have the most urgent need for affordable family accommodation.
75
     This number has since increased. In January 2018, 9,104 people accessed emergency
     accommodation, including 1,517 families and 3,267 children.

124                                                          Social Justice Matters 2018
The most prevalent accommodation type nationally is ‘Supported Temporary
Accommodation’ (STA) - hostel accommodation with onsite supports from NGOs
such as Focus Ireland, Simon Community Crosscare, and others, followed by
‘Private Emergency Accommodation’ (PEA) - accommodation rented directly from
landlords, B&Bs and hotels.

Chart 6.3: Homelessness January 2017 to December 2017

Source: extracted from Department of Housing, Planning and Local Government Homelessness
Statistics, www.environ.ie

The latest social housing waiting list figures, notwithstanding the methodological
anomalies referenced earlier in this chapter, show 85,799 households in need of
social housing. Add to this the dearth of social housing construction, the precarious
situation of many families in mortgage arrears and increasing private rents, and it is
clear that many more households are currently at risk of becoming homeless.

Security of tenure in the Private Rental Market
The latest Daft Rental Report (Lyons, 2018) indicates that rents are continuing to
rise across the country and while the rate of inflation has reduced from an average
of 13.5 per cent in 2016 to 10.4 per cent in 2017, the continued increases places
access to adequate private rent out of the reach of many. Rent inflation in Dublin
continues to outstrip that in the rest of the country, at 10.9 per cent, with rents in
all Dublin areas having increased by 70 per cent or more on their lowest in 2010
(Dublin City Centre rents have increased by more than 90 per cent). According to
the report, there were fewer than 3,150 properties available to rent nationally on
the 1st February 2018, representing a decrease of over 20 per cent on the previous
year. According to Census 2016, 497,111 households were renting on census night,
an increase of 22,323 (including those stated as living rent free in non-owner
occupied houses) since 2011.

Housing and Accommodation                                                           125
Notwithstanding the introduction of Rent Pressure Zones aimed at curbing rent
inflation, average monthly rent nationally in 2017 was €1,227, reaching a high of
€1,995 in South County Dublin (Lyons, 2018). Even with supports such as Rent
Supplement and HAP, this is outside the reach of those in receipt of social welfare
payments and substantially out of reach of those on the average wage. With this
market becoming more precarious, there are few alternatives for those no longer
able to afford to stay in their current homes, or whose tenure is uncertain.

Accommodation for Persons with Disabilities
In the breakdown of Accommodation Requirements on the social housing waiting
list, 4,326 reported a household member as having an enduring physical, sensory,
mental health or intellectual disability, a decrease of almost three per cent on the
previous year, but still ten per cent higher than 2013. A breakdown of the Main
Need for Social Housing Support (Housing Agency, 2017) (see Table 6.2) shows
a slight decrease across all health factors, with the exception of ‘Unsuitable
accommodation due to exceptional medical or compassionate grounds’ which
decreased by 25.4 per cent on the previous year.

The National Housing Strategy for People with a Disability 2011-2016 (Department
of the Environment, Community and Local Government, 2011) was established to
‘facilitate access, for people with disabilities, to the appropriate range of housing
and related support services, delivered in an integrated and sustainable manner,
which promotes equality of opportunity, individual choice and independent living’
(2011:7) through the achievement of nine strategic aims. This Strategy was affirmed
and extended to 2020 under the Government’s ‘Rebuilding Ireland’ programme.

In May 2017, €59.8 million was made available through the Exchequer (€47.8
million) and local authorities (€11.96 million) for the provision of housing
adaptation grants to older people and people with disabilities. Budget 2018
increased the Exchequer contribution to €53 million. Grants up to a maximum
value of €30,000 are available for an adaptation, €8,000 for housing aids for older
people, and €6,000 for mobility aids, all subject to a means test. According to the
most recent DHPLG statistics just over €40 million was provided in grants across
these three schemes from Exchequer funding and Local Property Tax allocation,
with just over half of that amount (€20.8 million) paid in respect of housing aid
for people with a disability. When the local authority contribution of €10 million
is accounted for, the total funding provided in 2016 amounts to €50 million across
the three schemes (DHPCLG, 2017(a)).

According to Census 2016 (CSO, 2017(c)) 19.3 per cent (112,904) of persons with a
disability were living alone, accounting for over a quarter (28 per cent) of all persons
living alone on Census night, almost 55 per cent of whom were over 65 years old.
Both the number of persons with a disability, and the rate of living alone among
those persons has increased since 2011. A further 44,531 persons with a disability
lived in communal establishments, a reduction of 421 (0.9 per cent) on 2011, with
the majority (69.6 per cent) being older people in nursing homes. 3,465 persons
with a disability were reported as living with religious institutions, shelters and
refuges on Census night 2016.

126                                                           Social Justice Matters 2018
Table 6.2: Main need for Social Housing Support
Main need for Social Housing                                                         Change
                                                  2016        2017     Change
Support                                                                                 (%)
Dependent on Rent Supplement                   39,296       35,204       -4,092      -10.4%
Unsuitable accommodation due to
                                                21,100      21,130           30        0.1%
particular household circumstances
Reasonable requirement for separate
                                                11,476      11,914          438        3.8%
accommodation
Homeless, living in an institution,
emergency accommodation or                       5,401       4,977         -424       -7.9%
hostel
Over crowded accommodation                       3,517       3,544           27        0.8%
Unfit accommodation                              2,304         948       -1,356      -58.9%
Household member has a physical
                                                 2,098       2,084          -14       -0.7%
disability
Unsuitable accommodation
due to exceptional medical or                    2,096       1,564         -532      -25.4%
compassionate grounds
Household member has a mental
                                                 1,687       1,691               4     0.2%
health disability
Household member has an
                                                 1,561       1,571           10        0.6%
intellectual disability
Unsustainable mortgage                             657         746           89       13.5%
Household member has a sensory
                                                   347         381           34        9.8%
disability
Houshold member has another form
                                                    60           45         -15      -25.0%
of disability
Total                                          91,600       85,799       -5,801       -6.3%
Source: Summary of Social Housing Needs Assessments 2017, Housing Agency, p.21

The labour force participation rate of persons with a disability reported in Census
2016 continued to be less than half that of the rest of the population (30.2 per cent
and 61.4 per cent respectively). Even when those over 65 years old are removed from
the equation, the labour force participation rates remain at least 20 percentage
points lower than for the rest of the population. The latest Survey on Income and
Living Conditions (SILC) data (CSO, 2017(c)) showed that households where the
principal economic status of the head of the household was ‘Unable to work due to
permanent sickness / disability’ earned the least of all economic groups, with the
exception of students. The median income of this group for 2016 was €22,492 and
while this represents an increase of over 10 per cent on 2015, the deprivation rate
of persons with a disability in 2016 continues to be the highest of all groups, at 46.7
per cent compared to 42.6 per cent unemployed and 12.6 per cent at work.

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Lack of availability of grants for home modifications coupled with low income,
lower levels of educational attainment (13.7 per cent had completed no more
than primary education (CSO, 2017(c)), compared to 4.2 per cent of the general
population) and a prevalence of poverty means that those with a disability are
unlikely to be able to afford adequate accommodation to support independent or
assisted living.

Social Justice Ireland believes that ensuring that people with a disability can live
independently where possible should be a key policy priority. Providing the
resources for this, including suitable housing and housing-related supports, must
be one of the foundations of such a policy.

Traveller Accommodation
According to Census 2016 (CSO, 2017(d)) the number of Irish Travellers increased
by 5.1 per cent since 2011 to 30,987. The majority of Travellers were living in
private homes, with only 639 reported as living in communal establishments.
While the use of caravans and other mobile temporary accommodation remains
below 2006 levels (which may be a result of a decrease in funding for Traveller-
specific accommodation), instances of over-crowding (more persons than rooms)
in Traveller households is, at 39.1 per cent, almost six times that of the general
population. The Traveller Community National Survey (O’Mahony, 2017) reported
that one third of Travellers had been forced to leave their accommodation at some
point, with 20 per cent for those below the age of 24. Of those who no longer travel,
19 per cent reported that they were prevented from doing so by law / not allowed to
anymore, while 18 per cent reported that there were less places for travellers to go.

The Government committed €9 million in capital allocation for the provision
of Traveller-specific accommodation in 2017, while this represents an increase of
€3.5 million on the previous year, it is still less than 25 per cent of the allocation
for 2008 (€40 million). Even at this relatively low rate, according to Deputy Eoin
O’Broin (Dáil Debates, 2017(b)) only €800,000 of this allocation was drawn down
by local authorities as of July 2017 – less than 9 per cent in the first half of the year.
The Housing Agency published its report in 2017, commissioned from RSM PACEC
ltd, on its review of funding for Traveller-specific accommodation (RSM, 2017). Key
challenges facing local authorities in implementing their Traveller Accommodation
Programmes (TAPs) were reported as planning issues (the most pervasive planning
challenges reported by local authorities and Traveller representatives were
objections raised by settled communities and Elected Representatives which tend
to delay the planning process); lack of effective assessment of need processes; and
lack of effective monitoring and reporting processes. All three key challenges are
within the gift of Government to rectify if they were serious about supporting
Travellers in Ireland to have access to suitable accommodation and maintain a
reasonable standard of living.

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Social Justice Ireland calls on Government to ensure that local authorities are
adhering to their own commitments to ensure adequate accommodation provision
for Traveller communities, with sanctions if necessary to encourage local authorities
to make the best use of the allocation for this accommodation provision.

6.3 Meeting the Need
Social Justice Ireland welcomes the Government’s commitment to tackling the
housing and homelessness crisis with the introduction in July 2016 of Rebuilding
Ireland Action Plan for Housing and Homelessness (DHPCLG, 2016) – the ‘Action
Plan’ – as the most comprehensive and focused plan for tackling this crisis to date.
Unfortunately, what the Action Plan has in common with previous Government
policies in this area is an over-reliance on the private rented sector and a lack of
support for the supply of additional homes and an adequate number of social
housing units.

The Action Plan contains five pillars:

•   Pillar One: Address Homelessness
•   Pillar Two: Accelerate Social Housing
•   Pillar Three: Build More Homes
•   Pillar Four: Improve the Rental Sector
•   Pillar Five: Utilise Existing Housing

Pillar One: Address Homelessness
The Action Plan commits to providing increased accommodation solutions for
homeless persons through:

•   the expansion of HAP homeless tenancies to 550 in 2016 and 1,200 in 2017;
•   the introduction of the ‘Rapid Build’ programme, building 1,500 rapid delivery
    homes by 2018;
•   sourcing by the Housing Agency of 1,600 vacant housing units from banks and
    investment funds, at a cost of €70 million, over the period to 2020;
•   increasing the ‘Housing First’ programme from 100 to 300;
•   increasing the number of beds available to rough sleepers by 2016;
•   increasing the HSEs annual budget for homeless services by approximately 20
    per cent; and
•   providing financial and legal support to households in mortgage arrears and a
    free nationwide phone service by end 2016 with the aim of keeping people in
    their homes.

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Budget 2018 provided an allocation of €116 million, an increase of €18 million on
2017, to homeless services. As this €18 million is intended to “support the wrap
around and running costs of the Family Hub programme” no additional allocation
has been made to the provision of long-term homes to homeless families by
way of increased supply, a move away from the original commitment to replace
emergency accommodation with ‘suitable permanent family accommodation by
delivering additional housing solutions including through an expanded Rapid-
Build Housing Programme’ (DHPCLG, 2016:34). The Family Hub programme,
while a welcome departure from hotel, B&B and hostel accommodation, is not a
permanent solution for families experiencing homelessness. The Irish Human
Rights and Equality Commission, in their report on the provision of emergency
accommodation to homeless families, expressed concern at the potential varied
experiences of families housed within these hubs throughout the country and
that these Family Hubs could normalise family homelessness causing families to
be institutionalised (IHREC, 2017:9) and recommended an amendment to section
10 of the Housing Act 1988 to limit the amount of time a family may spend there.

As of January 2018, there were 1,517 families living in emergency homeless
accommodation. Existing need outstrips the anticipated supply of new housing
under the Rapid Build programme to 2018. According to the Rebuilding Ireland
2017 Status Report, published in January 2018 (DHPLG, 2018(f)), delivery of the
anticipated 1,000 homes under the Rapid Build programme by the end of Q4 201776
was almost 80 per cent behind schedule, with only 208 of the promised 1,000 being
delivered within this period. The target of creating 300 Housing First tenancies in
2017 was 44 per cent behind schedule, with 170 tenancies created. Programmes
aimed at providing additional care and case management assessment for at risk
homeless persons expected to be in place by Q4 2016 ran into 2017 and is ‘ongoing’.

Pillar Two – Accelerate Social Housing
In response to a public consultation reviewing Rebuilding Ireland (the report of
which is as yet unpublished) (DHPCLG, 2017(c)), a number of key indices within
this Pillar were amended. These amended commitments include accelerating the
provision of 50,000 social housing units by 2021 under various schemes, again
including the expansion of the HAP scheme, in addition to:

•     Building 33,500 social housing units;
•     The acquisition by local authorities and Approved Housing Bodies (AHBs) of
      6,500 homes from the market or Housing Agency;
•     The leasing of 10,000 homes by local authorities and AHBs, 5,000 of which
      will be sourced through the National Treasury Management Agency’s Special
      Purpose Vehicle and a further 5,000 secured by way of a pilot Repair and Leasing
      Scheme and by long-term lease arrangements;
•     Streamlining approvals, planning and procurement to deliver efficiency;
76
     200 scheduled for end Q4 2016 and 800 scheduled for end Q4 2017

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•    Prioritisation of mixed developments of private, social and rented housing on
     State lands;
•    The delivery of more housing specifically for older people, people with
     disabilities, and Travellers.

Notwithstanding a welcome increase for housing in Budget 2018 to €1.9 billion,
once again the majority of this funding was not allocated for the increase of new
supply. Of the 25,469 units intended to be delivered by Budget 2018, 2,000 will
be through long-term leases and a further 17,600 will be through the Housing
Assistance Payment (HAP) and Rental Accommodation Scheme (RAS) which
received an additional €149 million, almost doubling expenditure in these areas
to €301 million. This ignores two facts: Long-term leases, HAP and RAS produce
no additional housing supply; and rents have escalated to such an extent that were
sufficient suitable accommodation available to rent, it would not be affordable
to most of those in receipt of even the highest rate of HAP. This is particularly an
issue in Dublin, which accounts for 41.5 per cent of the social housing waiting list,
where average rents in all council areas exceed the maximum HAP limits, one by
over 50 per cent77. Reliance on the private rented sector is not the answer to the
supply crisis. As previously discussed, rents have been increasing for 22 consecutive
quarters and while the rate of inflation has slowed slightly, it still remains resolutely
above 10 per cent. Furthermore, it is estimated that 36 per cent of private landlords
registered with the Residential Tenancies Board (RTB) are ‘accidental landlords’
who are more likely than other types of landlord to leave the sector as soon as they
can (RTB, 2014). The Working Group on the Tax and Fiscal Treatment of Landlords
published their report in September 2017 (Department of Finance, 2017), including
a range of short, medium and long-term options for retaining individual landlords
in the market. However subsidising both sides (by the provision of RAS/HAP/
Rent Supplement to the tenant and tax reliefs to the landlord) is not a sustainable
solution to a housing crisis where increased new supply of social housing is the
only answer.

As previously stated, the latest assessment of the social housing waiting list (Housing
Agency, 2017) places the number of households currently in need of social housing
supports at 85,799, more than 150 per cent of the delivery target of 50,000 set out
in this Pillar without factoring for future demand or the methodological anomalies
discussed earlier. While the measures aimed at providing Traveller-specific
accommodation are welcome, the independent review of local authority targets
and increased accountability where these targets have not been met are equally
important. Further, as part of the provision of social housing, infrastructure and
amenities must be secured to ensure long-term sustainability and development.

77
     The maximum HAP limit in Dun Laoghaire-Rathdown is €1,300 in respect of a family
     with three children. The average rent in South County Dublin, according to the latest
     Daft Rent Report is €1,995.

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According to the Rebuilding Ireland 2017 Status Report, published in January 2018
(DHPLG, 2018(f)), progress on key actions is not as advanced as may appear. The
proposed delivery of 47,00078 homes by 2021, particularly focusing on new direct-
build projects by local authorities and AHBs, has not advanced sufficiently in
terms of construction, but relies consistently on private rented accommodation
and while scheduled reviews have been undertaken and the €70 million Housing
Agency Fund has been put in place, these have generated no outputs for the
benefit of those in housing need. The inability to move forward with a special
purpose vehicle to activate ‘new residential construction for the broader build-
to-rent sector’ and engage in further long-term leases is hampering innovation in
construction funding. As well as this, delays in progressing regulation of Approved
Housing Bodies (AHBs), which is ‘fragmented, incomplete and not fit for purpose’
(Housing Agency, 2015:7), prevents AHBs from achieving their objective of
providing sustainable social housing.

Pillar Three – Build More Homes
This pillar aims to:

•     Ensure that an average of 25,000 homes are produced every year to 2021;
•     Invest €200 million in infrastructure and increasing supply of affordable homes
      for sale;
•     Accelerate the planning process by by-passing local authorities in some
      instances and submitting directly to An Bord Pleanála;
•     Run competitions aimed at fostering innovation housing design and delivery;
•     Work with other State agencies to fund and encourage increased construction
      activity;
•     Implement a 20-year National Planning Framework and land management
      strategy to make supply more stable and sustainable.

As seen earlier in this chapter, it is estimated that the net demand requirement
for new households is somewhere between 16,000 and 33,000 households per
annum to 2030. The current target of 25,000 completions per annum is just above
the median of the two assessments. Furthermore, while 25,000 completions per
annum may seem ambitious in light of the current dearth of construction, it is still
lower than the amount stated as completed in 2009, after the economic downturn.

The issue of State-driven supply was explored in a further report from the National
Economic and Social Council (NESC, 2015) which proposed three actions necessary
for achieving affordable, sustainable, and inclusive housing supply. The first of these
actions requires the State to optimise its available resources, such as the experience
and capabilities within the National Asset Management Agency (NAMA),
to develop an inter-organisational action plan for generating mixed income
78
     Figure revised in September 2017

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developments and thereby promoting inclusion of all income demographics,
and the introduction of a price ceiling for development land based on the market
value into the future. The second action requires an interrogation of the cost issues
involved in the development and supply of housing, reviewing the current costing
structures and utilising new and more efficient materials and technologies. This
should be done in conjunction with better management practices to drive costs
down, with a consequent focus on retraining within the construction sector,
thereby securing not only more sustainable, affordable and inclusive housing, but
an improved skill base and employment among Irish construction workers. And
the third action point requires taking a collaborative, institutional approach to
housing management by utilising and combining resources of all stakeholders to
provide a coherent strategic approach. The report concludes with the commentary
that an inclusive approach confined to one policy area will not be sufficient and
that an institutionalised collaboration that holds policy makers accountable is
required to provide a ‘recursive model’ for future development.

Given what we already know about construction levels (notwithstanding the
lack of definitive construction data), it is unsurprising that the Rebuilding Ireland
2017 Status Report, published in January 2018 (DHPLG, 2018(f)), indicates that this
Pillar is underperforming. Issues include a four times oversubscription from local
authorities in respect of the use of a €200 million Local Infrastructure Housing
Activation Fund for social, affordable rental and private housing delivery (of the
€800 million sought, approval has been given for €226.46 million, with the 13 per
cent overspend attributed to provision for planning issues or unforeseen delays);
delays in the development of online planning services for local authorities; and
while initial work has been done in respect of a competition to establish best
practice in the construction sector, little tangible engagement has been made.

Pillar Four – Improve the Rental Sector
The aim of this Pillar is sustainability and affordability within the rental sector
through:

•   Development of a national strategy for an attractive, viable and sustainable
    private rental sector;
•   Implementing legislation to prevent evictions in the event that 20 or more units
    (now 10 units) are sold in a single development and strengthening the powers of
    the Residential Tenancies Board to support landlords where significant arrears
    are owed;
•   The launch of an Affordable Rental Scheme to deliver at least 2,000 rental
    properties aimed at households on low or moderate incomes by 2018;
•   Encouraging purpose-built rented accommodation and facilitation of 7,000
    additional student accommodation places by 2019.

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The private rental market is not the solution to the housing crisis. Increased supply
and sustainable community development is urgently needed to accommodate an
increasing population and moderate rising house prices and market rents. Over
50,000 landlords left the private rented sector between 2012 and 2014, and while
there have been increases in the intervening years, at 176,251 in Q3 of 2017, this
number is still 35,000 below 2012 levels. This rate of fluctuation only underlines
the instability of the private rented sector and its inappropriateness as a long-term
solution to Ireland’s housing crisis.

Budget 2017 attempted to retain those landlords who remained with the provision
of a 5 per cent increase to mortgage interest relief from 75 to 80 per cent, with
further increases of 5 per cent per annum being introduced gradually in the
following years to attain 100 per cent over time. In 2014, it was estimated that 36
per cent of landlords were ‘accidental landlords’ who are more likely than other
types of landlord to leave the sector as soon as they can (RTB, 2014). An increase of
5 (or even 25) per cent on an existing tax relief is unlikely to incentivise those who
wish to leave.

Further relief will be available to landlords for renovations under an expansion of
the Living City initiative, which will be unavailable to the majority of apartment
landlords. Budget 2018 added little to develop this sector, with the exception of the
provision of €7 million to the Residential Tenancies Board, reflecting the expanded
role of the organisation and a commitment to annual inspection targets of 25 per
cent of all rented units.

According to the Rebuilding Ireland 2017 Status Report, published in January 2018
(DHPLG, 2018(f)), the Government remains active in this area, designating a
further 12 Rent Pressure Zones resulting in 57 per cent of tenancies being located
within these zones, reviewing incentives for landlords to remain in the sector, and
increasing provision for inspections by the RTB as discussed earlier. Social Justice
Ireland welcomes reform of the private rental sector and warns that in order for
these reforms to be effective, they must be properly resourced. In particular, with
reference to the standards of rental accommodation, the previous regulations in
this area failed not because of a lack of clarity on the standards themselves, but
because of a lack of inspection of relevant dwellings. The latest figures (NOAC, 2017)
indicate that only 13,603 dwellings were inspected out of a sector with 311,295
tenancies of which an average of 75 per cent were found to be non-compliant with
Standards Regulations (ranging from 2.8 to 100 per cent).

Pillar Five – Utilise Existing Housing
This Pillar aims to bring vacant stock into use and renew urban and rural areas by:

•     Providing funding to ensure that vacant social housing stock is rapidly re-let
      and put in a choice-based lettings approach for people on waiting lists;

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•   The purchase of 1,600 empty properties owned by banks and financial
    institutions for social housing;
•   Introducing a Vacant Housing Repair and Leasing Initiative to incentivise
    owners to refurbish and rent out vacant homes for social housing;
•   Facilitating the use of vacant commercial properties for residential use;
•   Encouraging town, village and rural renewal schemes.

Social Justice Ireland welcomes the plan to bring vacant properties into use. As
was seen earlier in this chapter, the number of vacant properties in each county
exceeds the number of households on the waiting list for social housing in almost
every county (with the exception of Dublin and Kildare), however the review of
the condition of these properties, their remoteness, local infrastructure and the
reasons why they are vacant has not yet been conducted.

Budget 2018 saw an increase in the vacant site levy from 3 per cent to 7 per cent
for landowners who fail to build on vacant sites during 2018 (the 3 per cent
levy remains as a liability from 2018, increasing to 7 per cent in the absence of
development during the year to January 2019), however while the levy applies to
vacant sites from January 2018, the levy will not be collected until at least 2019.

The Budget also introduced an allocation of €10 million to facilitate homes in
existing buildings, renovating derelict properties and improving amenities.
Social Justice Ireland welcomes these initiatives but is concerned at the slow pace
of their introduction. Social Justice Ireland has also previously proposed replacing
the current property tax scheme with a site value tax. This is a fairer way of taxing
accommodation which could curb spiralling housing costs and, in addition to the
levy on underdeveloped land, would incentivise developers to put development
land to use. The introduction of an empty dwelling tax, similar to those used in
other countries, would also go a long way to bringing some of the 183,312 vacant
properties identified in Census 2016 (exclusive of holiday homes) into use.

According to the Rebuilding Ireland 2017 Status Report, published in January 2018
(DHPLG, 2018(f)), a review of the ‘disparate’ systems in place for the provision
of social housing and a review of the planning process was behind schedule. It
is essential that Government address the disparities in social housing provision
to ensure that resources are channelled to provide the greatest number of
affordable, sustainable housing solutions possible. Subsidies paid for private rented
accommodation linked to double-digit rent inflation are not sustainable. In August
2017, the Minister announced actions being undertaken by the Department on
vacant homes, including the establishment of a Vacant Homes Unit within the
Department, and the post of vacant homes officers within local authorities. These
actions are mainly administrative in nature and do little to increase the availability
of homes to those in need.

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Housing Finance
Social Justice Ireland welcomed the increased allocation of €1.9 billion for housing,
however this is intended to provide less than 5,000 newly constructed social
housing units with the bulk of expenditure channelled into the private rented
sector through HAP, RAS and leasing initiatives. The National Development Plan
also committed to delivering 40,000 homes at a total cost of €4.2 billion, or just
€105,000 each. In July 2017, the Minister for Housing, in response to a Parliamentary
Question, indicated a range of construction-only costs from €137,709 for a 1-bed,
to €169,682 for a 4-bed, and ‘all-in’ costs (including land, professional fees, utility
connections etc.) from €175,271 to €211,062. This means one of two things:

1. The ‘delivery’ will include existing housing stock, acquired, leased or provided
   through HAP and other private market driven schemes, and limited new supply,
   or
2. The ‘delivery’ will be part of a Public Private Partnership, where profit margins
   and shareholders could influence affordability.

Fully financing the provision of adequate social housing ‘on the books’ is not
possible given the fiscal rules that were adopted since the crash, however the
Government balance sheet has improved exponentially so that greater provision
could now be made and either used directly to meet construction costs or invested
as part of a special purpose vehicle to raise finance for greater construction costs.
Social Justice Ireland has previously proposed two ‘off balance sheet’ mechanisms
that could be adopted to meet current and future need: invoking the structural
reform clause, and creating a Special Purpose Vehicle (SPV) to raise collateral for
further investment in social housing.

Acknowledging the need for further off-balance sheet funding, the Social Housing
Investment Proposals Clearing House Group, was established in 2015 to consider
proposals from private sector individuals or bodies who wish to invest in Social
Housing. This group consisted of representatives from the, the Department of
Finance, the Department of Public Expenditure and Reform, the Housing Agency,
NESC and NAMA who provide the Chair. The Clearing House Group reviewed
25 proposals received from private investors and reported to Government in
November 2015, following which revisions were made to existing schemes under
the Social Housing Current Expenditure Programme to expand the current leasing
arrangements of AHBs and local authorities with a view to introducing larger
property investment into the area.

In their report, Social Housing at the Crossroads: Possibilities for Investment, Provision
and Cost Rental, NESC (2014) reviewed current social housing policy in Ireland and
selected European countries and made a series of recommendations towards a
‘more unified, cost-effective and sustainable model in Ireland’. In order to achieve
this, NESC outline three main goals for Irish housing in the coming years (2014:42):

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