I have just a couple of supplementary questions. Ms Carroll said in her initial response that she would favour the idea of the annual registration and would have concerns about a criminal offence if a landlord did not notify of a change, be it a rent, tenancy change, etc. Does she think that having an annual registration with a possible civil offence, if that is not complied with, would be the ideal model for all the reasons she has just outlined? I would be interested in her view on that.
The approach outlined on the resource plan makes eminent sense. It gives us a much more realistic sense of the kind of timelines here. To pin Ms Carroll down on this, can she confirm that? It is important for us when we pass legislation and when we tell people about it that we can be honest and say that this is not something that is going to be available necessarily in September or October and that we are looking at the first quarter of next year. Is there a time scale around that?
Notwithstanding the fact that there will not be a set number of additional staff until the resource plan is produced, is the RTB getting any indication from the Government or the Department that they will support that? If there is an independent review, clearly the purpose of that is to give the best estimate of what is required. If that is what that independent advice says, then clearly there is an onus on us all to support it.
On the rent pressure zones, Ms Carroll mentioned places like Limerick and Waterford. We have asked on a number of occasions whether it is possible in those types of cases for the data to be looked at on an electoral division, ED, rather than on a local electoral area, LEA, basis, and not necessarily right across the country because I appreciate there might be a low level of rental properties at an ED level. However, particularly in Waterford and Limerick cities, there has to be enough data at an electoral division level that one could look at some kind of rent pressure zones being in operation at that level. I absolutely agree with Deputy Coppinger that the 4% over three years is 12.5%, but even if the people in Limerick and Waterford could get that basic level of protection, that would be something worth pursuing.
I also thought that what Ms Carroll said on purpose-built student accommodation was very interesting. I will try to pin her down on it. Is it Ms Carroll's view that purpose-built student accommodation, whether on or off campus, by universities or private sector interests, where a student has a nine month licence and has sole occupancy of that unit over those nine months, falls under the Residential Tenancies Act? Will she be clear about it in that case because that is important for us?
On defining buy-to-lets, and Ms Ward's comments were very interesting, the Focus Ireland amendment specifically proposed a definition and it was precisely for the reasons she said. Its reasons were that properties were purchased as buy-to-lets and not as principal private dwellings that were subsequently let out. Does she believe that it is in or around that that we might find a solution to it or has she some other ideas?
On the index, I listened very carefully to what Ms Carroll said on the quarterly changes. For example, the point at which rents started to increase dramatically was in the third quarter of 2013. The annual increases start to hit 6%, then up to 8%, then up 11% and so on. In the case of Dublin, if one looks at the quarterly increases, in each of the four years, 2014 to 2017, inclusive, there have always been at least two quarters where the quarterly increase is very low. In 2014, there is -0.1%, and 1.8% in 2015 and 2016. I am not convinced that the quarterly reading is telling us anything other than there is a dip in the first quarter, a jump in the second quarter, a dip again in the third quarter and a jump in the fourth quarter. One could argue that in 2017 it moderates a bit but surely the really worrying thing is that the annual quarterly increase does not show any real sign of moderation in the sense that the last quarter was 5.1% for Dublin but it is now 7.8%. I fully accept what was said that we do not have visibility regarding the properties with exemptions. However, there would have to an awful lot of exemptions for what should be in and around 4% to hit a 7.8% annual increase. Am I wrong about that?
What is also concerning me is that it is not just about exemptions. I believe that many tenants have now forgotten that even before the rent pressure zones, there was a limited level of protection regarding the rate of increase on the current market levels. I refer to my own constituency because I know it very well. On the basis of the quarterly figures, the average rent in Clondalkin is €1,500 per month. One will not get anywhere in Clondalkin today for €1,500 per month. Rents range from €1,800 to €2,000 to €2,200. In all those cases, whether they are first-time tenancies or new tenancies, there is a breach of the pre-2016 rules as well as a breach of the 2016 rules in terms of rent requests way above the RTB's index of averages. Is there a bit of work we could all do in trying to highlight the fact that even within a rent pressure zone, or even outside one, there is a level of increase that is unacceptable under the pre-2016 legislation? There is no new supply in Clondalkin; it is all existing properties. I do not believe a substantial number of renovations are going on. What I am seeing are a lot of people breaking both sets of rules, the RPZ and the pre-RPZ rules. My fear is that when one gets that visibility on the level of exemptions, it is still not going to account for the gap between what should be the 4% and, as Deputy Coppinger rightly pointed out in Dublin, what is really a doubling of that. If the witness have any thoughts on all that, I would a really appreciate hearing them.