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Wednesday, 18 Jan 2023

Written Answers Nos. 385-403

Mortgage Resolution Processes

Questions (386, 387)

Pearse Doherty

Question:

386. Deputy Pearse Doherty asked the Minister for Finance the average retail mortgage interest rate that is applied to non-performing mortgage loans and mortgage loans for which a tracker rate applies for the latest month for which information is available and June 2022 respectively; and if he will make a statement on the matter. [2404/23]

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Pearse Doherty

Question:

387. Deputy Pearse Doherty asked the Minister for Finance if his attention has been drawn to the fact that non-bank entities and investment funds holding mortgage loans are refusing to engage with borrowers or provide or discuss alternative repayment arrangements; his views on the growing disparity between mortgage interest rates that are being applied by retail banks and these entities; if the Code of Conduct on Mortgage Arrears is being adequately adhered to by these entities; and if he will make a statement on the matter. [2406/23]

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Written answers

I propose to take Questions Nos. 386 and 387 together.

The Central Bank has put in place a range of measures in order to protect consumers who take out or have a mortgage.  This consumer protection framework seeks to ensure that lenders are transparent and fair in all their dealings with borrowers and that borrowers are protected from the beginning to the end of the mortgage life cycle, for example, through protections at the initial marketing/advertising stage, in assessing the affordability and suitability of the mortgage and at a time when borrowers may find themselves in financial difficulties. 

This consumer protection framework includes the various Central Bank statutory Codes of Conduct such as the Consumer Protection Code 2012 (Code) and the Code of Conduct on Mortgage Arrears 2013 (CCMA) and all regulated entities, including retail credit firms and credit servicing firms, are required to comply with the provisions of these codes in their dealings with consumers.   

The CCMA provides specific protections for borrowers in arrears or facing a prospect of arrears on a loan secured on a primary residence.  In particular, a regulated entity must pro-actively encourage borrowers to engage with it about financial difficulties which may prevent the borrower from meeting his/her mortgage repayments. Also, where a borrower is experiencing repayment difficulty, a regulated entity must explore all of the options for alternative repayment arrangements (ARAs) offered by the entity to determine if a more suitable and sustainable repayment option is available based on the borrower’s individual circumstances. 

If a borrower is not satisfied with the options proposed, or if the regulated entity declines to offer an ARA, an appeals mechanism is provided for in the CCMA.  In addition, a regulated entity must review an ARA at intervals that are appropriate to the type and duration of the arrangement, including at least 30 calendar days in advance of an ARA coming to an end. 

In relation to the mortgage interest rates charged by different categories of Central Bank regulated entity it is, subject to the terms of the particular contract, a commercial matter for individual mortgage creditors to set their own lending rates. 

However, the Code, inter alia, requires that all regulated entities explain to borrowers how their variable interest rates have been set including in the event of an increase. Where a borrower is facing an increase in the rate of their mortgage, they can seek to move to another product at their existing lender or switch to a different lender, noting this will be subject to the lending criteria, terms and conditions of the lender to whom they apply.

In this respect, the Central Bank has advised that it has engaged with lenders to ensure the operational capacity is in place to facilitate people to switch at a system wide level. 

In terms of interest rates on non-performing loans, I have been informed by the Central Bank that it does not produce formal interest rate statistics that distinguish performing from non-performing loans. In respect of tracker mortgage interest rates, the Central Bank indicates that in respect of credit institutions the interest rate on tracker mortgages secured on a primary dwelling house was 2.13% in September 2022 (1.15% in June 2022) and for buy to let mortgages it was 2.19% (1.08% in June 2022).  The Central Bank advises that this data is published on a quarterly basis and the next set of this data, which will be for end December 2022, will be available in February.

The Central Bank also advises that the protection of mortgage loan borrowers, including those in arrears, is a key priority and that it will continue to supervise compliance by regulated entities with the CCMA and will investigate any issues that arise, including patterns of behaviour which suggest that the CCMA process is not being followed.

Question No. 388 answered with Question No. 378.

Insurance Coverage

Questions (389)

Holly Cairns

Question:

389. Deputy Holly Cairns asked the Minister for Finance the steps that he is taking to ensure insurance providers offer reasonable flood insurance to households and businesses within flood relief scheme areas. [2426/23]

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Written answers

As Minister for Finance, I have policy responsibility for the development of the legal framework governing financial services regulation, including for the insurance sector. Within this context, it should be noted that the provision of insurance cover and the price at which it is offered is a commercial matter for insurance companies providing the service and is based on an assessment of the risks that such companies are willing to accept. Therefore, under the EU Solvency II Directive, neither I, as the Minister for Finance, nor the Central Bank of Ireland can compel insurers to provide such cover. 

As the Deputy is aware, the Government has committed €1.3 billion to the delivery of these flood relief schemes over the lifetime of the National Development Plan to 2030. Responsibility for flood relief schemes is a matter for the Office of Public Works (OPW).  Building on this Government investment, there is a Memorandum of Understanding (MoU) between the OPW and Insurance Ireland. Under this MoU, the OPW provide information on all completed flood defence schemes to Insurance Ireland. In turn, its members take into account all of this information when assessing exposure to flood risk within these areas.

Arising from this, separate industry and Central Bank of Ireland surveys indicate there has been an overall increase in the provision of flood insurance over the last number of years and that the majority of policies in areas with fixed defences have flood cover. However, it is acknowledged that some households are still experiencing difficulties, particularly in areas with demountable flood defences - those defence systems that require action to be taken to prevent flooding.

This issue is the subject of the MoU working group between the Office of Public Works (OPW) and Insurance Ireland. Furthermore, officials from the Departments of Finance; Housing and Local Government; along with other stakeholders engage constructively with this process on how the levels of insurance cover might be improved in areas where flood defence works have been completed.

Finally, as has been the case, my Department will continue to monitor and assess any flood insurance matters, including through: its participation in the OPW and Insurance Ireland Working Group; actively encourage industry to have a more responsive approach to the matter; engage with the Central Bank of Ireland; and consider domestic and international policy developments to these issues as they arise.

Flood Risk Management

Questions (390)

Jackie Cahill

Question:

390. Deputy Jackie Cahill asked the Minister for Public Expenditure and Reform the plans that his Department has for the introduction of a grant system for the provision of flood gates for doors on properties in the Thurles area, County Tipperary, which are regularly flooded due to an inadequate flood water system locally; and if he will make a statement on the matter. [63137/22]

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Written answers

There is a proposed Flood Relief Scheme identified for Thurles as part of the Catchment Flood Risk Assessment and Management (CFRAM) Programme. The CFRAM Programme is the largest ever flood risk study carried out in the State and culminated with the launch in 2018 of 29 flood risk management plans which propose 118 new outline flood relief projects on top of the major projects already completed and the schemes that were ongoing at the time within the existing capital works programme of the Office of Public Works (OPW). All projects are being funded under the Government's flood risk investment programme of almost €1.3 billion under the National Development Plan to 2030.

Since 2018, the OPW has trebled the number of schemes, to 90, in the pipeline being designed and at construction. Given the highly specialised market for designing flood relief schemes it is not possible to progress all proposed new schemes at once.

While the proposed scheme in Thurles is not in the first tranche of projects to be progressed, the OPW continues to liaise closely with Tipperary County Council to ensure that the programme of flood relief projects identified for Tipperary is kept under review, and that all projects will be commenced as soon as possible and within the timeframe for the National Development Plan.

In the interim it is open to Tipperary County Council to make an application under the OPW’s Minor Works Scheme for funding for flood gates.

The Minor Works Scheme was introduced by the OPW on an administrative, non-statutory basis in 2009. The purpose of the scheme is to provide funding to Local Authorities to undertake minor flood mitigation works or studies to address localised fluvial flooding and coastal protection problems within their administrative areas. The scheme generally applies where a solution can be readily identified and achieved in a short time frame. The works to be funded are carried out under Local Authority powers and ongoing maintenance of the completed works is the responsibility of the Council.

Under the scheme, applications are considered for projects that are estimated to cost not more than €750,000 in each instance. Funding of up to 90% of the cost is available for approved projects. Applications are assessed by the OPW having regard to the specific economic, social and environmental criteria of the scheme, including a cost benefit ratio and having regard to the availability of funding for flood risk management. Full details of this scheme are available on: www.floodinfo.ie/.

Parking Provision

Questions (391)

Neasa Hourigan

Question:

391. Deputy Neasa Hourigan asked the Minister for Public Expenditure and Reform the cost to date associated with the development of a new parking strategy for the Phoenix Park, as recommended in the Phoenix Park Transport and Mobility Study 2021; and if he will make a statement on the matter. [63216/22]

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Written answers

The Office of Public Works engaged SYSTRA consultants, following a public procurement process, to develop a parking strategy for the Phoenix Park as recommended in the study referred to by the Deputy.

The contract value for this engagement is €77,840. No payments have been made to date by this Office as the work is ongoing.

Flood Risk Management

Questions (392, 393, 394)

Anne Rabbitte

Question:

392. Deputy Anne Rabbitte asked the Minister for Public Expenditure and Reform the status of the timeline to remove 'pinch points' from the River Shannon to alleviate flooding in the Callows region; the funding that has been set aside to complete these works; and if he will make a statement on the matter. [63231/22]

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Anne Rabbitte

Question:

393. Deputy Anne Rabbitte asked the Minister for Public Expenditure and Reform the work that is being carried out to marginally lower the statutory water levels on the River Shannon's three lakes; and if he will make a statement on the matter. [63232/22]

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Anne Rabbitte

Question:

394. Deputy Anne Rabbitte asked the Minister for Public Expenditure and Reform the works that are planned to alleviate flooding along the River Shannon over 2023; and if he will make a statement on the matter. [63233/22]

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Written answers

I propose to take Questions Nos. 392 to 394, inclusive, together.

The Deputy will be aware that the Shannon Flood Risk State Agency Co-ordination Working Group (the Group) was established by the Government in early 2016. The Group was established, at that time, following severe flooding arising from exceptional weather conditions between December 2015 and January 2016.

The Group’s purpose is to provide a forum where all statutory organisations with roles and responsibilities that involve the River Shannon catchment can further monitor and co-ordinate their respective work programmes to assist with managing flood risk along the Shannon catchment.

The Government has noted the decision of the Group to invest €4 million in a project for the removal of a series of ‘pinch points’ or restrictions through the Callows region between Athlone and Meelick weir. A Steering Group has been established to oversee this project and a brief is currently being finalised for the appointment of a consultant to carry out analysis and design work. The project will be subject to planning consent which will require Environmental Impact Assessment and Appropriate Assessment under the Birds and Habitats Directives. No work can commence in the absence of all appropriate consents.

The water level on the River Shannon is primarily the result of the amount of rain that falls on the river catchment area. While the ESB uses the water flowing in the river to generate electricity when it reaches Ardnacrusha, the rate at which the water travels to Ardnacrusha is primarily a result of the natural topography of the river and the natural restrictions in the river. It takes many days for water to travel down the Shannon. There have been times when there was flooding in the Callows area south of Athlone and further north yet only enough water in Ardnacrusha to operate the generating station at less than half the maximum output.

There are three lakes on the River Shannon - Lough Allen, Lough Ree and Lough Derg. Levels in Lough Allen and Lough Ree are managed to assist with navigation, to ensure minimum navigation levels in the river during dry periods and to ensure that floods are passed safely. The levels in between those lakes are also managed for navigation purposes.

In October 2016, the Group took a decision, within the existing statutory framework, to trial the lowering of the lake levels on Lough Allenduring the Winter period to help mitigate potential flood risk. A protocol was finalised by the ESB, Waterways Ireland and the OPW to lower the late Autumn and Winter minimum lake levels by approximately 0.7 metres. This was subject to the agreement of the National Parks and Wildlife Service.

The protocol was implemented on a trial basis from 2016 to 2018 and following that trial, the Group agreed to continue implementing the protocol on a temporary basis pending the completion of a flood relief scheme in Carrick-on-Shannon. The trial was operated most recently in 2021/2022, with ecological and hydrological monitoring, surveys and assessments being carried out in parallel. An application to allow the protocol to be implemented for 2022/2023 has been submitted to the National Parks and Wildlife Service and it is expected that this will be in place soon. It would not have been possible to achieve the protocol levels in October/November 2022, or recently, due to heavy rainfall on the Shannon Catchment.

While the ESB has an influence on water levels on some parts of the river as mentioned above, it does not control the water level of the River Shannon, nor was the Shannon Scheme designed for that purpose. The ESB can only manage the flow of water at Parteen weir as it arrives from Lough Derg. All of the water arriving at Parteen weir is discharged either via Ardnacrusha station or down the old Shannon channel. The ESB does not store any water upstream of Parteen weir in the Parteen Basin. Discharging more water than that which arrives at Parteen weir would result in lowering water levels in Parteen Basin and the Headrace canal below safe operating limits with the risk of causing stability issues to the Category A Earthen Embankment Dams that form Parteen Basin and the Headrace canal.

The water flow from Lough Derg to Parteen Basin is restricted by the flow capacity of the outlet channel from Lough Derg at Killaloe. The capacity restriction acts like a bottleneck limiting the discharge from Lough Derg. The ESB maximises the discharge of water from Lough Derg within its Dam Safety constraints during flood periods. It should be noted that operations at Ardnacrusha and Parteen Weir do not have an influence on water levels in the River Shannon upstream of Meelick weir.

The ESB is continuously monitoring the water levels throughout the Shannon and continues to operate in accordance with its regulations and guidelines for control of the River Shannon. The ESB engages with the local authorities and Waterways Ireland on a daily basis when Lough Derg, Lough Ree or Lough Allen is in flood. The ESB publishes its twice weekly predicted water levels and expected discharge amounts based on the latest Met Éireann forecast. The ESB also publishes the water levels throughout the three lakes and Ardnacrusha discharges on a daily basis. This information can be found on ESB’s website at: Hydrometric Information (esb.ie). The ESB also communicates discharges at Parteen weir to local stakeholders by text message on a daily basis when Lough Derg is in flood.

In terms of flood alleviation works, there are 13 completed schemes in the Shannon River Basin District (RBD) which provide protection to over 2,600 properties. There are a further 24 schemes currently being progressed in the Shannon RBD and these include two schemes, Athlone and Springfield/Clonlara (Co. Clare) which are currently at construction and expected to reach substantial completion in 2023. When completed, these two schemes will provide protection to over 570 properties.

The Springfield/Clonlara (Co. Clare) flood defence scheme is being progressed by Clare County Council, with funding and technical advice being provided as appropriate from the OPW. In addition to OPW funding the costs of the works, the majority of the construction works is being undertaken by the OPW via direct labour. The flood relief scheme involves the construction of a flood protection embankment, land raising, penstock/sluice, pump station and associated works at the townlands of Springfield, Cappavilla North, Cottage and Illaunyregan, Clonlara, Co Clare. The flood defence embankment is in place to protect Springfield/Clonlara from inundations from the River Shannon. A temporary pumping arrangement will be place this winter to provide pumping capacity until delivery and installation of the final scheme pumps in 2023.

In Athlone, Co. Westmeath, the OPW and Westmeath County Council (WCC) are already working together to advance flood relief works for the town with WCC acting as the Contracting Authority and OPW funding the costs of the works, in addition to undertaking the construction works with its own workforce. It is anticipated that the construction works for the Athlone Flood Alleviation Scheme will be completed in late 2023.

It is anticipated that construction will commence on the Kings Island Flood Relief Scheme in Q2 2023. It is estimated that the full scheme will protect approximately 450 residential and 23 commercial properties.

A further five schemes in the Shannon region are expected to be submitted for planning/statutory consent in 2023. These schemes are planned for Castleconnell, Adare, Carrick-on-Shannon, Kilkee and Ballinasloe.

Question No. 393 answered with Question No. 392.
Question No. 394 answered with Question No. 392.

Parking Provision

Questions (395)

Neasa Hourigan

Question:

395. Deputy Neasa Hourigan asked the Minister for Public Expenditure and Reform if he will outline any previous undertakings that a global engineering and transport infrastructure company (details supplied), engaged with the Phoenix Park parking strategy, has had with the Office of Public Works, in particular in relation to the national historic parks department and dealings related to listed architectural heritage buildings; and if he will make a statement on the matter. [63270/22]

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Written answers

The Office of Public Works awarded a contract to SYSTRA on 30 March 2022, further to an open tendering process following public procurement procedures, for consultancy services relating to the development of a parking strategy for the Phoenix Park.

SYSTRA has not previously been engaged by this Office. SYSTRA has provided consultancy services across the UK and Ireland to Local Authorities and the National Transport Agency. OPW Heritage Services are satisfied that this company is competent to undertake this project for the Phoenix Park.

Flood Risk Management

Questions (396)

Cathal Crowe

Question:

396. Deputy Cathal Crowe asked the Minister for Public Expenditure and Reform if clarity will be provided for a person (details supplied) in relation to when drainage works on a river will recommence; and if he will make a statement on the matter. [63308/22]

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Written answers

The Office of Public Works (OPW) is responsible for the maintenance of arterial drainage schemes and flood relief schemes completed under the Arterial Drainage Acts, 1945 and 1995, as amended. Each year, the OPW prepares an annual arterial drainage maintenance programme for each region that identifies the proposed maintenance locations within each arterial drainage scheme catchment area.

Under the annual programme of maintenance in 2022, officials from the OPW carried out maintenance in the Drumelihy area. The OPW has maintenance works planned for the Creegh Arterial Drainage Scheme for 2023.

The OPW wrote to the person concerned in October 2022 and asked that they make contact with the South West Regional Office to enable officials to investigate the issue of concern.

Legislative Measures

Questions (397)

Thomas Pringle

Question:

397. Deputy Thomas Pringle asked the Minister for Public Expenditure and Reform if all sections of all Acts passed in the past ten years have been commenced; the number of sections that are outstanding; the number of Acts that have review periods; if the reviews have taken place; and if he will make a statement on the matter. [63386/22]

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Written answers

I wish to advise the Deputy that with regard to my Department, all sections of the relevant Acts passed in the past ten years have been commenced.  The information requested regarding the Acts with provisions for review and the details of the reviews to date is set out in the table below.

Title of Act

Review period(s)

Protected Disclosures (Amendment) Act, 2022

Provision for Review to commence no later than 5 years after Act passed. Statutory Review will commence in 2027.

Regulation of Lobbying Act, 2015

Provision for Review every 3 years. Statutory Reviews to date were published in April 2017 and January 2020.

Protected Disclosures Act, 2014

Provision for Review to commence no later than 3 years after Act passed, with Review to be published within 12 months of commencement of Review. Statutory Review was published in July 2018.

Financial Emergency Measures in the Public Interest Act, 2013

Provision for an annual Review of the operation, effectiveness and impact of the FEMPI Acts, having regard to the overall economic conditions of the state and national competitiveness. Reviews have taken place and have been published each year since 2013.

The Deputy may also wish to note that the Freedom of Information Act, 2014 and the Ombudsman Acts 1980 to 2012 do not mandate periodic reviews by the Minister.  A review of the FOI legislation is currently in progress, which is being undertaken pursuant to Section 10(1)(d) of the Ministers and Secretaries Act, 2011, rather than under the terms of the 2014 Act itself.  No other reviews have been undertaken by the Minister in relation to these two provisions since the commencement of the 2014 Act and the amendment to the Ombudsman Act in 2012.

National Monuments

Questions (398)

Carol Nolan

Question:

398. Deputy Carol Nolan asked the Minister for Public Expenditure and Reform if his Department or the Office of Public Works has had any involvement in surveying or preserving the ruins of Tyone Abbey, Tyone, Nenagh, County Tipperary; if his Department or the Office of Public Works have engaged with Tipperary County Council or local landowners in relation to same; and if he will make a statement on the matter. [63441/22]

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Written answers

While Tyone Abbey is a recorded monument, it is not a National Monument as designated by legislation. As such, it falls outside the statutory remit of the Office of Public Works and this office has no role in the preservation of this property.

The matter of the acquisition of property for the National Monuments State Portfolio is one for the Department of Housing, Local Government and Heritage. If that Department were to consider bringing the Abbey into State care or ownership, the OPW would, of course, undertake the necessary surveys or assessments required to support the State's consideration of same.

Oireachtas Members' Remuneration

Questions (399)

Catherine Murphy

Question:

399. Deputy Catherine Murphy asked the Minister for Public Expenditure and Reform if he will provide an update in respect of his plans to reform and-or amend the various allowances payable to Members of the Houses of the Oireachtas; and if he has consulted with any other State body in respect of same. [63621/22]

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Written answers

As the Deputy will be aware, the allowances payable to Members of the Houses of the Oireachtas are managed and administered by the Houses of the Oireachtas Service. As Minister for Public Expenditure and Reform, I am the regulatory authority for some allowances as well as the general expenses scheme. 

Proposals to amend or reform the allowances available to members must be made, in the first instance, by the Houses of the Oireachtas.

There is ongoing engagement between my officials and the Houses of the Oireachtas Service on these matters, including in the context of recent security concerns that have been raised.

Budget Targets

Questions (400)

Mairéad Farrell

Question:

400. Deputy Mairéad Farrell asked the Minister for Public Expenditure and Reform the way that SDG budgeting has been incorporated into Ireland’s performance budgeting framework; the way that he intends to build on this; and if he will make a statement on the matter. [63953/22]

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Written answers

My Department’s ongoing work on SDG budgeting is being informed by the recently published working paper, 'Well-being and Public Policy: Utilising a well-being perspective to inform the budgetary process', which is available to download from the Irish Government Economic and Evaluation Service (IGEES) website (www.gov.ie/en/collection/a3f0b-igees-publications/#well-being). Over the course of this year, officials in my Department, in partnership with the Department of Environment, Climate & Communications, and in consultation with the Department of Finance, will continue to undertake a programme of work examining international best practice for SDG budgeting and assessing the potential for tracking expenditure on SDGs in the context of the approaches that are also being developed in the areas of green budgeting, equality budgeting and well-being budgeting.

Heritage Projects

Questions (401)

Seán Sherlock

Question:

401. Deputy Sean Sherlock asked the Minister for Public Expenditure and Reform the status of repair works at a site (details supplied); and when it will reopen to the public. [1107/23]

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Written answers

The Office of Public Works is committed to the conservation and repair of Barryscourt Castle. In this regard, the Deputy will be aware that a major conservation project at Barryscourt Castle was initiated in 2016. The works completed to date include the erection of scaffolding, pointing and regrouting, lead-work and works in relation to the lowering of the ground water level around the Castle. These works are labour-intensive and delivered by skilled stone masons in the OWP direct labour workforce. Regrettably, the pandemic and related restrictions resulted in delays to the projected delivery of the schedule of works.

The next stage of works, which will require ministerial consent upon application to the Department of Housing, Local Government and Heritage, includes the design of new mechanical and electrical systems for the Castle. The proposed mechanical and electrical installation works will commence when repointing and grouting work are complete on site and the building has sufficiently dried out.

To this end, OPW are currently working on the design for these new mechanical and electrical systems which will include the installation of new heating system, lighting system, fire alarm, emergency lighting, external lighting and CCTV. This work is at an advanced stage and it is hoped that a final design can be signed off before the end of the first quarter of 2023. It will then be necessary to go out to tender to engage the services of a suitably qualified contractor to undertake these works and, as pre-mentioned, to obtain the necessary Ministerial Consent, which is a pre-requisite to the commencement of any works on site.

I would like to reassure the Deputy that as soon as consent is granted, these works will be prioritised for completion. Regrettably, I cannot confirm an exact re-opening date for the Castle as year but the OPW is working towards a staggered reopening of the site to the public during the 2024 season.

Heritage Sites

Questions (402)

Seán Sherlock

Question:

402. Deputy Sean Sherlock asked the Minister for Public Expenditure and Reform the number of visitors at a site since it opened to the public after the pandemic (details supplied). [1108/23]

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Written answers

Doneraile Estate remained open to the public during the pandemic, providing an important outdoor resource for the community. It is estimated that the estate welcomes approximately 490,000 visitors each year. In 2021, following the easing of Covid-19 Government restrictions, the house re-opened to the public. 6,520 ticketed visitors took guided tours of the ground floor of the house and the gardens.

The house was closed for tours in 2022 as the OPW continued with the next phase of planned refurbishment of the house. These works included the conservation and furnishing of the first floor of the house, the installation of a lift and changing places facility and the re-plastering of the west gable. However, 2,505 ticketed visitors availed of guided garden tours.

Heritage Sites

Questions (403)

Peadar Tóibín

Question:

403. Deputy Peadar Tóibín asked the Minister for Public Expenditure and Reform the length of time that that cairn T in Loughcrew, County Meath been closed to the public; the length of time that an acrow prop has been in place to secure the roof; and the plans to restore this important megalithic tomb. [1190/23]

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Written answers

Cairn T in Loughcrew, County Meath has been closed to the public since October 2018 when the acrow prop was put in place to secure it's roof.

The Office of Public Works wish to confirm that resources will be allocated through the 2023 Business Planning process to commence the development of a Conservation Management Plan for the site. Any works to be carried out will be in the context of the recommendations that the Plan may make for the long-term protection of the monument.

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