Housing Data

Questions (228)

Eoin Ó Broin

Question:

228. Deputy Eoin Ó Broin asked the Minister for Housing, Local Government and Heritage the status of Call for Housing 2020; the number of properties offered for sale; the number purchased; and the number occupied by house size and local authority area. [2719/21]

View answer

Written answers (Question to Housing)

The “Call for Housing 2020” was launched on 21 July 2020 as a short-term intervention to stimulate interest in social housing delivery, through acquisitions and leasing from opportunities arising in the property market. The campaign has been run on behalf of my Department by the Housing Agency, in consultation with the local authorities.

Up to 15 January 2021, the total number of properties that were offered to the Housing Agency for sale was 308 (with a further 127 offered under leasing / Rental Accommodation Scheme arrangements). Of those properties offered for sale, 36 have had bids accepted and have progressed, 16 have closed. A number of properties submitted to the Housing Agency are being pursued by local authorities and approved housing bodies independently.

This measure was specifically developed as a temporary intervention in the context of addressing urgent Covid-19 related housing needs. My Department is currently considering the appropriate duration of the measure.

Environmental Policy

Questions (229)

Jennifer Whitmore

Question:

229. Deputy Jennifer Whitmore asked the Minister for Housing, Local Government and Heritage when the expert group report on marine protective areas will be published and made available; when the associated public consultation process will commence; the reason for the delay to date; and if he will make a statement on the matter. [2720/21]

View answer

Written answers (Question to Housing)

The Programme for Government - Our Shared Future contains a commitment to realise our outstanding target of 10% marine protected area (MPA) coverage in Ireland's waters as soon as is practicable, aiming for 30% by 2030. In this regard the Government has also committed in the Programme for Government to deliver comprehensive legislation for the identification, designation and management of MPAs in Ireland.

Regarding publication of the MPA Advisory Group report and the beginning of a public consultation on its content and findings, the report was received by myself and by Minister of State for Heritage and Electoral Reform Malcolm Noonan, TD, on 22 October during EU Green Week 2020. The delay in publication was due to the need to translate the report into Irish. The report is now in the final stages of translation and it is intended to make it publicly available online in Irish and English by 26 January 2021.

An public consultation process on the expert group’s report is expected to commence in the week beginning Monday 15 February 2021. This consultation process will run for five months and will encourage all stakeholders and the wider public to review the contents of the report, including its many recommendations, and to submit their views on how Ireland’s network of MPAs should be expanded.

Housing Data

Questions (230, 233)

Eoin Ó Broin

Question:

230. Deputy Eoin Ó Broin asked the Minister for Housing, Local Government and Heritage the figures for the quarter 4 social housing output; and if he will provide a report on the total social housing output for 2020, by categories (details supplied). [2721/21]

View answer

Eoin Ó Broin

Question:

233. Deputy Eoin Ó Broin asked the Minister for Housing, Local Government and Heritage the number of social housing developments currently in the new one stage approval process; and the number of units of accommodation in these schemes. [2724/21]

View answer

Written answers (Question to Housing)

I propose to take Questions Nos. 230 and 233 together.

Increasing the supply of housing, particularly new build social and affordable is a priority for my Department. The Programme for Government commits to increasing the social housing stock by more than 50,000, with an emphasis on new builds. In Budget 2021, we backed this objective with funding of €3.3 billion for the delivery of housing. The available funding will deliver 12,750 new social homes through build, acquisition and leasing. A major focus of this investment is the delivery of new build, with an overall target of 9,500 new homes and the increased build targets will see increased local authority build on local authority land.

In progressing this major construction programme it is important to pursue timely delivery while also ensuring value for money in terms of Exchequer funding. In this regard, social housing projects, like all publicly-funded construction projects, must comply with the Government’s Public Spending Code and Capital Works Management Framework (CWMF), the objectives of which are to ensure greater cost certainty, better value for money and financial accountability.

My Department, working with local authorities has sought to streamline the four-stage approval process for social housing and to introduce other measures to increase the pace of delivery. As a result of this work a pre-construction programme of 59 weeks was agreed, which includes design, Part 8 approval, detailed design, preparation of tender documentation, issuing tenders and tender reports. The 59-weeks includes 15 weeks for the requisite Department approvals, which occur in parallel with local authority activities where possible. Local authorities have been able to reduce this pre-construction timeline further using design and build frameworks. Off-site construction has also been used to reduce local authority construction timelines.

In September 2020 I increased the threshold for the Single-Stage Approval Process for local authority Social Housing Capital Construction Projects from €2m to €6m, to give further autonomy to local authorities to progress projects, under that Process which reduces the number of approvals sought from my Department from four to one. There are 21 projects (50 units) currently going through the single stage approval process. To date 35 projects (114 units) are on site or have completed having used the single stage process.

My Department publishes comprehensive programme level statistics on a quarterly basis on all social housing delivery activity. This is published on the statistics page of my Department’s website, at the following link: www.gov.ie/en/collection/6060e-overall-social-housing-provision/.

This data is complete to the end of Q3 2020. Data for Quarter 4 2020 is currently being complied and will be published when available.

The following revised reply was received on 1 February 2021.

I propose to take PQs 230 and 233 together.

Increasing the supply of housing, particularly new build social and affordable is a priority for my Department. The Programme for Government commits to increasing the social housing stock by more than 50,000, with an emphasis on new builds. In Budget 2021, we backed this objective with funding of €3.3 billion for the delivery of housing. The available funding will deliver 12,750 new social homes through build, acquisition and leasing. A major focus of this investment is the delivery of new build, with an overall target of 9,500 new homes and the increased build targets will see increased local authority build on local authority land.

In progressing this major construction programme it is important to pursue timely delivery while also ensuring value for money in terms of Exchequer funding. In this regard, social housing projects, like all publicly-funded construction projects, must comply with the Government’s Public Spending Code and Capital Works Management Framework (CWMF), the objectives of which are to ensure greater cost certainty, better value for money and financial accountability.

My Department, working with local authorities has sought to streamline the four-stage approval process for social housing and to introduce other measures to increase the pace of delivery. As a result of this work a pre-construction programme of 59 weeks was agreed, which includes design, Part 8 approval, detailed design, preparation of tender documentation, issuing tenders and tender reports. The 59-weeks includes 15 weeks for the requisite Department approvals, which occur in parallel with local authority activities where possible. Local authorities have been able to reduce this pre-construction timeline further using design and build frameworks. Off-site construction has also been used to reduce local authority construction timelines.

In September 2020 I increased the threshold for the Single-Stage Approval Process for local authority Social Housing Capital Construction Projects from €2m to €6m, to give further autonomy to local authorities to progress projects, under that Process which reduces the number of approvals sought from my Department from four to one. There are 21 projects (50 units) currently going through the single stage approval process. To date 37 projects (121 units) are on site or have completed having used the single stage process.

My Department publishes comprehensive programme level statistics on a quarterly basis on all social housing delivery activity. This is published on the statistics page of my Department’s website, at the following link: https://www.gov.ie/en/collection/6060e-overall-social-housing-provision/.

This data is complete to the end of Q3 2020. Data for Quarter 4 2020 is currently being complied and will be published when available.

Defective Building Materials

Questions (231)

Eoin Ó Broin

Question:

231. Deputy Eoin Ó Broin asked the Minister for Housing, Local Government and Heritage the detail of the working group established to examine the issue of latent defects including the membership of the group; the terms of reference of the group; the number of times the group has met; and if the group will be making a call for submissions from interested parties and members of the public. [2722/21]

View answer

Written answers (Question to Housing)

The Programme for Government sets out a number of commitments in respect of the important policy area of building defects and provides for an examination of defective housing, having regard to the recommendations of the Joint Oireachtas Committee on Housing report, "Safe as Houses".

In this regard, my Department is actively engaging with key stakeholders and I have had several meetings with stakeholder representative groups on this matter over recent months. My Department is currently working to establish the structures to examine the issue of defective housing, this will include apartment buildings, in line with the commitment in the Programme for Government.

I recently appointed Mr Seamus Neely, former Chief Executive of Donegal County Council, to the position of Chair to the independent working group to oversee the effective implementation of the group’s terms of reference which are currently being finalised.

It is intended to conclude the process of finalising measures, including membership and methodologies, to establish the independent working group in consultation with the key stakeholders in the coming weeks, with a view to holding the inaugural plenary working group meeting shortly thereafter.

Traveller Accommodation

Question No. 233 answered with Question No. 230.

Questions (232)

Eoin Ó Broin

Question:

232. Deputy Eoin Ó Broin asked the Minister for Housing, Local Government and Heritage the status of each of the recommendations of the Expert Review Group on Traveller Accommodation; and the status of the implementation of each of the recommendations by the group in tabular form. [2723/21]

View answer

Written answers (Question to Housing)

On the matter of the recommendations in the Traveller Accommodation Expert Review Report, there are 32 proposals aimed at:

- addressing research deficiencies, including how information is gathered and used;

- removing any potential delays and obstacles in the planning system in terms of delivery;

- increasing resources and delivery capacity; and

- strengthening governance arrangements.

The recommendations have been categorised into separate streams reflecting recommendations that can be completed within my Department, recommendations that require the assistance of other Government Departments and Agencies and recommendations that will require the commission of further independent research.

My Department is progressing a number of short term recommendations and working groups are working on others. For example, a review has been concluded of the arrangements for the disbursement of funding for the provision and refurbishment of Traveller specific accommodation and a new process implemented for the 2020 allocation of funding. Meetings have taken place with working groups within my Department and with other Government agencies and Departments.

Officials from my Department are reporting progress on the implementation of the recommendations of the Expert Group report at the National Traveller Accommodation Consultative Committee meetings along with seeking input from them as major stakeholders. In December 2020, I established a Programme Board to drive the implementation of the recommendations contained in the Traveller Accommodation Expert Review report. The Programme Board will meet shortly.

Question No. 233 answered with Question No. 230.

Home Loan Scheme

Questions (234)

Eoin Ó Broin

Question:

234. Deputy Eoin Ó Broin asked the Minister for Housing, Local Government and Heritage the breakdown of the costs for each year since 2016 for the design, hosting, branding and other media and communication-related costs arising from the Rebuilding Ireland plan, including the website, social media account (details supplied), events, publications and other related matters. [2725/21]

View answer

Written answers (Question to Housing)

The costs my Department incurred in relation to the communication related costs arising from the Rebuilding Ireland plan, including the website, social media account, events, publications and other related matters are set out in the following table.

Year

2016

€38,900.00

Rebuilding Ireland. The photography costs refer to videos and social media.

BigO

2016

€54,600.00

Rebuilding Ireland. The photography costs refer to videos and social media.

BigO

2017

€45,000.00

Development, management, Irish translation, text and graphic information and video presentations and social media for www.rebuildingireland.ie

BigO

2017

€3,462.00

Rebuilding Ireland Rental Market & AHB Reg Section

MediaVest Ltd.

2018

€9,109.90

Rebuilding Ireland Consultation, Communication and Engagement Strategy

2019

€2,632.20

Domain Name Renewal & Site Security Cert

BigO

2020

€14,441.35

ArcGIS Online Creator Term License

ESRI

Public Private Partnerships

Questions (235)

Eoin Ó Broin

Question:

235. Deputy Eoin Ó Broin asked the Minister for Housing, Local Government and Heritage if he will publish the public sector benchmarking exercise used in the first bundle of the social housing PPPs. [2726/21]

View answer

Written answers (Question to Housing)

As the Deputy will be aware, the Public Sector Benchmark (PSB) is an essential part of any PPP project. It contains commercially sensitive information in relation to the methodology used for costing public sector projects and for the pricing of risks by public sector bodies. In accordance with Department of Public Expenditure and Reform guidelines (Guidelines for the use of Public Private Partnerships), the final PSB, or any elements thereof, is not made public during the tendering process nor where it is intended to procure further similar projects in the near future (e.g. subsequent project bundles as part of an ongoing PPP programme).

Construction is currently continuing on the remaining homes from Bundles 1 and 2 of the PPP programme, and the remaining homes across both bundles scheduled for completion later this year. My Department and the National Development Finance Agency (NDFA) are currently working with the relevant Local Authorities to progress the third bundle of sites in this PPP programme. The NDFA, in its role as procuring authority and financial advisor, and Dublin City Council, as lead local authority and Sponsoring Agency, have commenced the design phase and planning for the tender process in conjunction with the relevant local authorities. It is planned that tenders will be invited from PPP consortia towards the end of this year.

As Bundle 3 will follow the same structure as Bundles 1 and 2 and given the potential impact on value for money for the State, it is not appropriate to release the PSB for Bundle 1 at this time. However, and in accordance with Department of Public Expenditure and Reform guidelines, once an appropriate period of time has elapsed and the commercial sensitivity of the information on the project is no longer an issue (having regard also to any other similar PPP projects which may be in pre-procurement), the PSB should be made public. My Department will follow these guidelines in relation to the social housing PPP programme.

Departmental Bodies

Questions (236)

Eoin Ó Broin

Question:

236. Deputy Eoin Ó Broin asked the Minister for Housing, Local Government and Heritage the number of times the homeless working group established by the Minister has met; the dates on which it has met; the outcomes of those meetings in terms of specific actions; if he will publish all minutes and other related documents from these meetings since it was established; and if he will publicise all future minutes and related documents for future meetings as they occur on his Department’s website. [2727/21]

View answer

Written answers (Question to Housing)

I have established a Homelessness Task Force, to provide a forum for engagement with key organisations working together to address homelessness and to provide input on the implementation of the commitments on homelessness in the Programme for Government.

The Group has met on eight occasions to date, on the 13th, 20th and 27th of July, on the 14th and 21st of September, and on October 19th, November 16th and December 14th, 2020.

The taskforce has discussed, inter alia, commitments on homelessness in the Programme for Government; Covid-19 homeless service; winter planning; Budget 2021 and co-ordination and co-operation with the Department of Health and HSE. The Task Force is informing my role as Minister in providing necessary policy supports and funding, and is facilitating engagement amongst key stakeholders and partners in tackling homelessness.

It is my intention to publish the agenda and minutes of meetings on my Department’s website on an ongoing basis.

Planning Issues

Questions (237)

Eoin Ó Broin

Question:

237. Deputy Eoin Ó Broin asked the Minister for Housing, Local Government and Heritage the status of the review of the national architecture policy. [2739/21]

View answer

Written answers (Question to Housing)

My Department is currently fine-tuning the drafting of a new National Policy on Architecture which will support long–term planning strategies and will assist in addressing key issues including societal well-being, climate change and urban regeneration. The adaptation of existing as well as the design of new buildings will, of course, be critical to meet the targets set by the Climate Action Plan. It is my intention that a new National Policy on Architecture will play an integral part in implementing our vision for the future providing policy actions that will encourage best quality in researching, understanding, managing, enhancing and reusing our existing built environment assets as well as delivering sustainable new places and spaces.

My Department, supported by a steering committee including officials from the Office of Public Works, the Department of Education and Skills, the Health Service Executive, the City and County Architects Association, the Royal Institute of the Architects of Ireland, the Arts Council, the Heritage Council, the schools of architecture and the Irish Architecture Foundation, undertook a public consultation process in 2020 allowing the opportunity for all communities, stakeholders and citizens to have their say on the proposed new Policy.

The consultation phase considered the main ways in which architecture and our built environment affect society, our health and well-being and our ability to prosper. These include climate adaptation and mitigation and sustainable development, the benefits for everyone of obtaining high quality in the built environment, the protection and reuse of our built heritage, ways we can demonstrate built environment leadership and the need to foster education about our built environment. As well as receiving online and written submissions and engaging on social media my Department held a series of workshops and meetings, including virtual workshops in line with public health restrictions, to allow wide-ranging involvement in the drafting of the new policy, as well as consideration of the effect of Covid-19 on our built environment.

The new Policy will be informed by the feedback from the consultation phase, with over 150 submissions received, as well as by a review of the previous Government Policy on Architecture and our involvement in a European Commission working group on high quality architecture and built environment. A report based on analysis of the consultation phase is to be completed this month. It is my intention that a draft policy will then be circulated to key stakeholders, including the Deputy, and Government Departments prior to finalisation.

National Parks and Wildlife Service

Questions (238)

Eoin Ó Broin

Question:

238. Deputy Eoin Ó Broin asked the Minister for Housing, Local Government and Heritage the status of the review of the National Parks and Wildlife Service. [2740/21]

View answer

Written answers (Question to Housing)

There is a commitment in the Programme for Government to review the remit, status and funding of the National Parks and Wildlife Service (NPWS) to ensure that it is playing an effective role in delivering its overall mandate and enforcement role in the protection of wildlife. As explained in my response to PQ 35989/20 in November 2020 I have decided that the review should be headed by an independent chairperson overseeing a triptych review process which will have a target completion date of Summer 2021. I am advancing the appointment of a Chair who will be instrumental in the finalising of the Terms of Reference for the Review and the stakeholder engagement process.

Departmental Bodies

Questions (239)

Eoin Ó Broin

Question:

239. Deputy Eoin Ó Broin asked the Minister for Housing, Local Government and Heritage the number of times the housing delivery group has met; the dates on which it has met; the members of the group; the specific outcomes of the group in terms of actions; if he will publish all minutes and documents arising from this group on the Department's website for meetings that have happened to date and any future meetings. [2742/21]

View answer

Written answers (Question to Housing)

I have established a High Level Housing Delivery Group to provide a forum for engagement with key housing delivery partners and to provide input on the implementation of the commitments on housing delivery in the Programme for Government.

The membership of the Group consists of representatives from the City and County Management Association, the Housing Agency, the Housing Delivery Coordination Office, Approved Housing Bodies and the Irish Council for Social Housing. The Group has met on seven occasions, on the following dates, 13 July 2020, 27 July 2020, 7 September 2020, 21 September 2020, 19 October 2020, 16 November 2020 and 14 December 2020.

The Group provides a very useful forum for open discussions between the key stakeholders. It is my intention to publish the agenda and minutes of meetings on my Department’s website on an ongoing basis.

Of course, separate to meeting with these key stakeholders in this forum, both I and my Department officials have continued and ongoing regular engagement with the members of the Delivery Group on housing delivery issues.

Housing Provision

Questions (240)

Cian O'Callaghan

Question:

240. Deputy Cian O'Callaghan asked the Minister for Housing, Local Government and Heritage his plans to expand housing first; and if he will make a statement on the matter. [2776/21]

View answer

Written answers (Question to Housing)

Housing First enables homeless individuals with high levels of complex needs to obtain permanent secure accommodation with the provision of intensive housing and health supports to help the individuals concerned maintain their tenancies.

The National Implementation Plan for Housing First was published in September 2018. The Plan includes an overall target of 663 tenancies in the period 2018-2021, with annual targets for each local authority. The Plan is a joint initiative of my Department, the Department of Health, the HSE and the local authorities. A copy of the National Implementation Plan is available on my Department's website at the following link:

www.gov.ie/en/publication/b19937-housing-first-national-implementation-plan-2018-2021. Contracts for the delivery of services have been put in place in each of the nine regions responsible for the delivery of homeless services with tenancies now in place in every region.

The regional targets contained in the Plan were agreed by local authorities based on a review of homelessness data and a national survey of the support needs of homeless individuals conducted with service providers. In this regard, it is important to note that the majority of individuals in emergency accommodation do not require the level of supports provided by Housing First.

The Programme for Government commits to an expansion of the Housing First targets. Research is being undertaken by the Housing Agency to carry out an assessment of need for the supports provided by Housing First which is being used to inform the expansion of the Programme. I expect this work to be complete and to be in a position to announce an expansion of the Programme during the first half of 2021.

Home Loan Scheme

Questions (241)

Cian O'Callaghan

Question:

241. Deputy Cian O'Callaghan asked the Minister for Housing, Local Government and Heritage if he has undertaken a review of the Rebuilding Ireland home loan to ascertain the reason for the high number of rejections of applications; if there is any analysis undertaken by his Department of the high rate of refusals; if so, the findings of the review or analysis carried out; and if he will make a statement on the matter. [2777/21]

View answer

Written answers (Question to Housing)

The Rebuilding Ireland Home Loan, is targeted at first time buyers who wish to own their own home, have access to an adequate deposit and have the capacity to repay a mortgage, but who are unable to access a mortgage sufficient for them to purchase their first home.

The Housing Agency provides a central support service which assesses applications for the Rebuilding Ireland Home Loan on behalf of local authorities and makes recommendations to the authorities to approve or refuse applications. Housing Agency recommendations are then considered by the Credit Committee in each local authority, which issues loan approvals.

I understand that the Housing Agency has assessed 7,367 valid applications from February 2018 to end December 2020. Of these, it recommended 3,640 applications for approval and 3,727 applications be declined.

The most common reasons for a recommendation to decline are as follows –

- Repayment Capacity Not Demonstrated

- Net Income Ratio Outside of Policy

- Unsatisfactory Savings Record

- Unsatisfactory ICB Report

- Outside Credit Policy

- Income Sustainability Not Evident

- Unsatisfactory Financial Management

The final decision on loan approval is a matter for each local authority and its Credit Committee on a case-by-case basis. Decisions on all housing loan applications must be made in accordance with the statutory credit policy that underpins the Scheme, in order to ensure consistency of treatment for all applicants.

Loan applicants who are dissatisfied with a loan application decision of a local authority Credit Committee may appeal that decision to the local authority. Details of the appeals process can be obtained from the relevant local authority.

In general terms, there is no indication that the proportion of loans recommended for decline by the Housing Agency is excessive. A review of the Rebuilding Ireland Home Loan carried out by the Economic and Social Research Institute (ESRI) noted that the decision regarding credit assessment by the Housing Agency were "in line with the rejection rate data the ESRI collected as part of its Economic Sentiment Monitor for renter households who applied for a mortgage". While there are some differences in the data used in the comparison, this finding would not support the view that the rejection rate is excessive.

The ESRI report can be found at www.esri.ie/system/files/publications/RS104_4.pdf.

Housing Data

Questions (242)

Cian O'Callaghan

Question:

242. Deputy Cian O'Callaghan asked the Minister for Housing, Local Government and Heritage the level of expenditure on the site services fund in 2019 and 2020; the way in which this level of expenditure compares to VAT receipts for housing units constructed with the assistance of this fund; and if he will make a statement on the matter. [2778/21]

View answer

Written answers (Question to Housing)

It is important to note that, rather than directly funding the construction costs of affordable homes, Serviced Site grant funding is provided to support the cost of infrastructure that will facilitate affordable housing provision on local authority lands.

The timeframe for the delivery of such projects entails the detailed design, consultation, planning, procurement and construction phases which, depending on the scale and scope of the project, can take a number of years. Reflecting the fact that the majority of Service Site Fund (SSF) projects approved in 2019 and 2020 are currently at the detailed design and planning stages, the funding drawdown to date for infrastructure construction costs is approximately €2.4 million and relates to 2020 expenditure. SSF funding drawdown will incrementally grow as projects move past the planning and procurement stages to construction.

VAT is liable on SSF projects on the same terms as any other construction project. Reimbursement of VAT costs paid by local authorities to contractors are eligible for funding under the SSF.

The Department does not collate figures on SSF VAT costs.

Housing Data

Questions (243)

Cian O'Callaghan

Question:

243. Deputy Cian O'Callaghan asked the Minister for Housing, Local Government and Heritage the number of applications for serviced sites funding; the locations and number of units in each application; the number of applications approved; the price range agreed with each local authority for the sale of these homes; and if he will make a statement on the matter. [2779/21]

View answer

Written answers (Question to Housing)

To date, my Department has issued two Serviced Sites Fund (SSF) calls for proposals to local authorities. Funding of almost €170 million has been approved in principle in support of 37 infrastructure projects in 14 local authority areas, which will assist in the delivery of almost 3,600 more affordable homes.

Details of 35 SSF projects which received approval in principle under the two SSF calls is available on the Rebuilding Ireland's website as follows;

Call 1 https://rebuildingireland.ie/news/minister-murphy-gives-the-go-ahead-for-ten-local-authority-sites-for-affordable-housing-under-the-serviced-sites-fund/.

Call 2 https://rebuildingireland.ie/news/minister-murphy-approves-funding-of-e84m-to-support-delivery-of-1770-affordable-homes-under-the-ssf/.

In addition to these projects, approval in principle has also been given to two further applications for SSF funding – details are provided in the following table:

Local Authority

Name of Project

Number of affordable homes

SSF Funding

Dublin City Council

Emmet Road

375 – all Cost Rental

€18.75m

Dublin City Council

Oscar Traynor Road

172 – Affordable Purchase

€8.7m

Total

-

-

€27.45m

It is important to note that SSF is provided to support the cost of facilitating infrastructure which will lead to development of new affordable purchase and cost rental homes on local authority lands. The timeframe for the delivery of such projects must accommodate detailed design, the consultation process, planning, procurement and construction. As with all large projects of this type, the nature and scale of the developments will generally evolve as plans are progressed by local authorities. In making an application for SSF, each local authority must demonstrate that an affordability issue exists in the area in question and a viability to deliver homes with a reduction of at least 10% on open market values.