I thank the Chairman and committee members for inviting me to present on the topic of urban regeneration, including the issues of repair and lease, CPO, dereliction and vacancy. I am speaking today as a registered architect, an assistant professor in UCD school of
architecture, planning and environmental policy, and co-director of UCD's Centre for Irish Towns.
As a key policy objective of Project Ireland 2040, the national planning framework, compact urban settlement in towns and cities is acknowledged as fundamental to the future social and spatial sustainability of the country, for several reasons. First, it supports demographic growth, bearing in mind that the population is predicted to exceed 6 million by 2040. Second, it allows for the effective use of existing infrastructure, including for transport, water supply, sewage, energy and data. Third, it promotes the reuse of buildings already built — and their embodied carbon — over new build, with its associated carbon dioxide emissions. Finally, compact urban settlement can support social cohesion through the design of walkable neighbourhoods and good public spaces that link to well-used amenities and support inclusive multigenerational access to services, culture, education and business.
This objective is now embedded across policy at all scales in Ireland, including in Our Rural Future: Rural Development Policy 2021–2025; Housing for All: A New Housing Plan for Ireland; the Climate Action Plan 2021; regional spatial and economic strategies for the three regional assemblies; county development plans; local area plans; and as expected in the forthcoming town centre first policy.
What is less clear is how this policy objective is implemented on the ground, and how challenges facing our towns and cities in achieving this objective are addressed effectively. The challenge of vacancy and dereliction, which is the focus of this meeting, has more recently been broadly acknowledged as a barrier to achieving compact urban settlement.
Neither vacancy nor dereliction is a new phenomenon in Ireland. Several important recent studies have examined vacancy under different lenses. Dr. Philip Crowe's report, How data on vacancy is created and used: Case Studies from Scotland, Denmark and Philadelphia, analyses and compares methodologies for measuring and understanding vacancy internationally. The report offers clear descriptions of how vacancy is measured and highlights, in particular, the vacant property indicators model as used in Philadelphia to combine data sets to predict the likelihood of vacancy at any time. Dr. Kathleen Stokes and Dr. Cian O'Callaghan's report, Taking stock of Dublin's vacant sites and properties: A review of existing policies and measures, notes that vacancy and the reasons behind it are nuanced and that means and tools to measure it vary.
It recommends five key actions with a view to supporting "targeted and effective political responses".
Third, the town centre living initiative synthesis report, authored by SpaceEngagers, documents and analyses the Department of Rural and Community Development’s 2018 pilot town centre living initiative, whose aim was to test pilot strategies to understand the various causes of and measure vacancy in town centres in Ireland. The report recommends 15 key actions.
A summary of these studies is beyond the scope of this statement, but I draw the attention of the committee to them and the many recommendations contained therein. I would be happy to discuss these further, particularly those relating to finance, during the questions and answers.
Unfortunately, these reports and studies have not yet translated to action and implementation. It seems we have yet to comprehensively understand what we mean by vacancy and who should be charged with tackling it or how. Vacancy is not a blanket term and means different things to different people. It can vary over time and have many causes. It can be temporary or long term. It can apply to sites, whole buildings, or parts of buildings. It can apply to dwellings, but also to other types of building. It can be linked with dereliction, but is not always. A small percentage of building stock will always be vacant and needs to be to allow for regeneration, movement of people and businesses, change of ownership, etc. However, large volumes of long-term vacant space, which we have in Ireland, leading to potential dereliction and-or coupled with hoarding of built assets is neither normal, desirable nor sustainable.
I will look at data and how we measure it. How do we know the extent of these different types of vacancy? In 2018, as part of Rebuilding Ireland, the then Department of Housing, Planning and Local Government published the national vacant housing reuse strategy, which among other actions called for the establishment of “robust and reliable methods to identify and track vacant property and land". However, we have as yet no robust, comprehensive or dynamic system for tracking vacancy across types and time, despite having a range of disconnected modes, and this has tended to confuse the narrative around vacancy in the country.
What do we have? At the national scale, the census has the benefits of capturing data with a high degree of accuracy. However, it is periodic and only records data on dwellings. GeoDirectory’s quarterly residential building report and commercial vacancy report provide national snapshots of key metrics of national building stock, including vacancy, holiday homes and dereliction. VacantHomes.ie seeks to engage the public to record and report vacant buildings, although gathered data is not publicly available.
At county level, all local authorities are required to maintain separate registers of vacant sites and derelict buildings. In addition, the Heritage Council’s collaborative town centre health check programme has conducted baseline reporting of ground floor vacancy in 15 towns and developed a methodology and knowledge base for building collaboration and partnerships as sustainable methods for ongoing management of town centre regeneration. In the Government’s newest housing policy, Housing For All: A New Housing Plan for Ireland, action 19.12 requires the Department of Finance to “Collect data on vacancy levels in residential property with a view to introducing a vacant property tax”.v
Despite all of these data, reports and hundreds of pages of policy, there is still no Department or agency responsible for comprehensively co-ordinating a programme of mapping, documenting and understanding vacancy and land use patterns at the national, regional and local scale. The result is, unfortunately, a haphazard approach that leaves us still without a clear understanding of the scale of vacancy, its underlying causes and necessary actions to ameliorate it.
As Stokes and O’Callaghan point out, “Vacancy and dereliction are symptoms rather than causes of the unequal housing, property and development regimes [in] Irish [towns and] cities.”vi For example, as they point out, less visible forms of vacancy include short-term lets, which can have the effect of removing properties from the long-term rental market. At the date of writing, Westport, County Mayo had only two available dwellings to rent listed on Daft.ie, despite there being 252 available short-term let Airbnb options. This is under-the-radar vacancy, but it has a significant impact on the sustainability of the town.
This lack of a co-ordinated approach to town centres and city districts means that buildings, which are valuable assets connected to expensive infrastructure and stores of embodied carbon, and all of which are owned by someone, sit idle. Meanwhile long-term homeless figures are again rising, at 8,130 in Focus Ireland’s October report.
From ongoing research and experience in this area I would make a number of observations. First, we already have access to significant volumes of data, but are we asking the right questions? Are we asking the difficult questions? We also have ample legislation and policy but there is a curious lack of action and accountability. Why is this? Why is there a reluctance to collect vacant site levies? Why are the powers of the Derelict Sites Act 1990 and the Urban Regeneration and Housing Act 2015, which include CPO and levy powers, not used to their full capacity? Why is the ownership of all property not in the public domain, when in other countries this information is a matter of public record and interest? An outsider looking on might be justifiably confused and wonder whether it might be the case that the status quo of empty untaxed assets, be they vacant, derelict, used for short-term lets or buildings that are held onto and used as quasi-pensions, sometimes suits some of us? Otherwise, why would we not simply do the work that is already mandated in policy and legislation? Cui bono? Who benefits?
Second, a single point of responsibility and partnership is needed. A co-ordinated, supportive partnership approach, which Ireland currently lacks, is needed. We could learn from our neighbours in Scotland. Faced with similar challenges, they have developed an exemplary framework, informed by a town centre first approach, which combines a single comparative data platform, Understanding Scottish Places, with the USP Your Town Audit and place standard and town centre toolkits within a supportive mechanism of the Scotland’s Towns Partnership. Scottish Empty Homes Partnership and Scotland's Towns Partnership ensure knowledge is shared and comparable, actions are co-ordinated and a partnership approach to compact urban settlement is collaboratively developed and delivered at all scales, from national to local, while still respecting the unique character of towns and city districts. The Heritage Council and the UCD Centre for Irish Towns have built good relationships with colleagues in the Scotland’s Towns Partnership and the University of Edinburgh and they have generously shared their knowledge and experience and stand willing to help us.
Third is the need for a co-ordinated and collaborative approach. Towns and cities are unique places, and no one-size-fits-all solution will work for every place. Equally, fixing vacancy and dereliction on its own will not fix towns or city districts. However, a partnership approach, informed by publicly available, comparable data, could connect with local authorities and communities in towns to support common baseline audits, and, in parallel and of equal importance, help develop locally tailored, participatory vision plans that support compact urban places to be connected, climate resilient, healthy and beautiful places to live. Progress and action can then be managed and assessed relative to baseline checks and goals unique to each place but co-ordinated nationally. The recently announced town centre actions plans are welcomed, but it is suggested that they might be of more value, if co-ordinated by a partnership model and based on a common structure with inclusion, design and sustainability at its core.
We should be actively implementing all our CPO and levy powers. However, unless we understand our towns and cities at a granular scale, as well as the macro forces that continue to shape them, and can benchmark them in time and space relative to one another, we will remain unable to imagine to them as they could be. A co-ordinated approach, using common metrics, participatory tools and methodologies within an open, supportive and participatory framework that harnesses design skills to respond to the unique conditions of people and place is essential.