APPENDIX 10
Memorandum submitted by the Construction
Employers Federation
INTRODUCTION
This Construction Employers Federation (CEF)
is the employer's organisation and trade association for the Construction
Industry in Northern Ireland.
We represent some 450 individual construction
firms in Northern Ireland who operate in all sectors of the construction
industry. With our associated companies that provide insurance
backed warranties for domestic work together with an industry
wide pension and holiday pay scheme we represent in excess of
1,500 individual construction firms in the Province.
We welcome the opportunity to make a submission
to the Northern Ireland Affairs Committee on the provision of
social housing in Northern Ireland.
Our submission addresses some of the major issues
affecting the supply side of social housing. This is because it
is mainly our members who provide the supply of social housing
and there are a number of factors that are affecting their ability
to maintain the supply.
The CEF believes that the Province has an annual
requirement of between 1,400 and 1,700 social housing units. We
are concerned that there has been a decline in supply and that
this requirement is not being delivered. We believe that major
contributors to this failure include delays in the planning system
and particularly the lack of availability of a supply of suitable
development land.
We believe that the issues affecting demand
for social housing are best addressed by the Northern Ireland
Housing Executive who are the regional statutory housing authority
in Northern Ireland and by the Department for Social Development.
ISSUES AFFECTING
THE SUPPLY
OF SOCIAL
HOUSING
1. Planning delays
It is now widely recognised by government that
the planning system in Northern Ireland is overburdened and has
been under resourced. The CEF has made separate submissions on
these problems through the Planning Service consultation on "Modernising
Planning Processes".
There are major difficulties in the development
control process, particularly with regard to the statutory consultation
requirements. It is our belief that as a result of concern over
potential breaches of human rights, this consultation process
has become circuitous and extremely lengthy. The result has been
to create unacceptable delays in the processing of planning applications.
This in turn has created doubt and uncertainty in the process.
It is not unusual for a planning application
to take anything up to two years to complete. It is therefore
difficult for those trying to match the demand for social housing
with supply, to have any certainty at all about the volume of
output at any particular time.
2. Land availability
The programme of updating the suite of Area
Plans in Northern Ireland is significantly behind schedule. The
result is that most Area Plans have already expired or are about
to expire.
One outcome has been a significant reduction
in the amount of land available for development. This in turn
has pushed land prices up significantly and as a consequence has
made the development of some social housing schemes unviable.
3. Planning Policy Statement 12 (PPS12)
This is a very important document as it introduces
a number of new concepts, such as the "sequential test"
to determine the allocation of green field and brown field land
for development.
PPS12 is important in the context of the Regional
Development Strategy that has set an overall target of 60% of
development to be in brown field lands.
While the Federation supports fully the concept
of sustainable development, we believe that this 60% requirement
should not be rigid. We believe that the RDS should be a flexible
document, particularly as in many towns in Northern Ireland the
60% target will not be met due to a lack of available brown field
sites. Obviously this has also acted as an impediment to the output
of social housing.
4. Lack of suitable family type accommodation
As already stated, the Federation fully supports
the concept of sustainable development, however the introduction
of the "Quality Initiative" has created some practical
problems.
The majority of housing in Northern Ireland
has traditionally been the three bedroomed semi that provides
very suitable good family type accommodation.
The Quality Initiative requires developers to
set aside substantial tracts of prime development land for open
space and amenity use. The only way to make development viable
on land that now command premium prices is to increase densities.
This means more "town houses" and apartments. These
do not necessarily provide the best form of family accommodation.
5. Increasing costs of housing
Over the last number of years, Government has
adopted a policy of passing on a broad series of charges and levies
to developers that were traditionally met by the public service.
This has had the effect of unnecessarily pushing up the costs
of housing to the extent that private sector housing is unaffordable
to a large number of people. Once again this creates greater need
for the provision of affordable social housing.
6. The Barker Report
In December 2003, the Barker report was published.
This Report identified a number of important issues relating to
the difficulties of meeting housing demand. The CEF issued its
own Press Release in response to that Report. Some of those issues
have been highlighted in this submission.
29 March 2004
| 
