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Iaosb Letter to T.D’s regarding Building Control (Amendment) S.I.9 of 2014
25th November 2014
Re: Building Control (Amendment) Regulation S.I.9 of 2014
I am writing to you following on from our letters earlier in January of the year about the impacts of the new building regulation BC(A)R SI.9 on self-builders.
A confidential stakeholder process entered into by former Minister Hogan following on from a public consultation in May 2012 resulted in SI.9 being implemented in March of this year. The small stakeholder group involved was comprised of groups with vested commercial interests- these were representative bodies for architects, engineers and chartered surveyors (RIAI, ACEI and SCSI respectively) along with the Construction industry Federation (CIF) only. Consumer groups such as ourselves were excluded from any discussions regarding the new regulations.
The regulation that resulted was of benefit to these vested interests, while impacting on many consumer groups such as ourselves with an array of unintended consequences. The RIAI, ACEI and SCSI now have protected positions with private registers, and adequately qualified non-members of these organisations are precluded from occupying new roles under SI.9.
The main restriction in SI.9 that continues to impact self-builders most is the restriction to use "competent" builders, which only seem to be members of the new privately owned CIF register CIRI. The Department of the Environment has in effect, given CIF a monopoly on all residential building in the state as a result. We would like to point out that there are other well-established industry standards for competence, such as RECI or the National Guild of Master Craftsmen.
We have received numerous estimates of SI.9 adding over €40,000 to the cost of a typical €180,000 self-built dwelling. The bulk of these costs are associated with the requirement to employ a CIF registered main contractor. SI.9 is pricing many lower-end self-builders out of the market. These are at the lower cost end, where owners were hoping to build better quality homes at a realistic cost, on a phased basis, than speculative housing. These are the real-world numbers our members are coming back to us with. We have undertaken surveys of members and to date, for this year, we estimate between 800 and 1,000 dwelling projects have been abandoned by self builders trying to build a home for their families.
Why the former Minister and DECLG would insist on CIF’s new register CIRI be written in to legislation at the expense of other proven and well-regarded similar registers of competent builders is a question that needs to be asked. CIRI has no track record. Why has the CIF, a private organisation, has been made the beneficiary of this restrictive practice by our elected representatives?
It would appear that the Minister and Department continue to have a very small circle of friends when it comes to matters pertaining to Building Control and the construction industry. What benefit do self-builders get for the huge costs of SI.9- The security of using a CIF contractor?
The IAOSB are supporters of greater professional involvement and oversight in the construction industry generally, and in the speculative residential sector in particular. Most self-builds employed professionals for planning, tender, site and other stages of the building process. We completed homes using industry standard contracts, and all work was undertaken in a safe fashion under current Health and Safety legislation.
There is no evidence that we are aware of to indicate that self-built homes were subject to the shoddy building practices of speculative built housing. We are insulted by CIF suggestions that self-builders were involved in the “black economy”. This is simply lobbyist propaganda. If the CIF are aware of instances where proper revenue practices were not adhered to they should then simply report the matter to the authorities. I would like to point out that If similar allegations were made by consumers against CIF members there would be outrage.
Why are ordinary citizens denied the age-old tradition of being able to build their own home, frequently on their family farms where they grew up, for a reasonable cost? In most cases, these are the only option available to them. Self-builders were not responsible for Priory Hall so why should we be punished for the mistake of others?
Many self-builders are experienced tradespersons themselves, members of RECI and also the National Guild of Master Craftsmen, itself a well-established register of builders with 7,500 members. We now have a situation where an experienced well regarded tradesperson has to employ a CIF registered main contractor at huge expense to oversee the build of their own house. Some members in CIRI may well have no building experience, or construction skills- they well may just be construction managers like an typical self-builder.
In March 2015 the CIF’S private register CIRI is due to be put on a statutory footing which means that a lot of self builders would no longer be able to participate in building their home for their families, In most of these cases these self builders are people who have children and are already struggling financially due to lack of jobs and extra charges and taxes brought in by this government.
BC(A)R SI.9 simply is not working. It needs to be revoked. We need a simple low cost system of independent inspections by Local Authorities similar to the UK where self-building is not only tolerated but encouraged.
Our members see their dreams falling away due to the casual introduction of a reckless regulation that not only makes no sense, but is being defended by civil servants and our political representatives.
Looking at another problem, there are a lot of people who are waiting on a very long housing list and in certain circumstances a house built by a self builder would leave a vacant house for these families in need.
Many public representatives have built their own homes, and if not they know of someone who has done so or plans to self-build. Many we have talked to are against the impacts of S.I.9. We are appealing again to you, our elected representatives, to hear the voices of self builders of today and thousands of others who are planning to build their own homes in the future. We need your help to stand up for the right of the Irish people that has been taken away from them by this amendment. You need to take action now before the construction industry in Ireland has been handed back to similar developers and contractors who got us in the mess in the first place.
According to the Central Statics Office a little over 1,300 dwellings were speculatively built out of a total of 8,300 dwellings completed in 2013. This means that almost 7,000 homes were once-off houses by owners, many self-built. SI.9 should be restricted to apply to speculative residential developments only, and removed for all other sectors. If necessary set up a simple system of Local Authority inspectors to inspect and approve self-built or once-off houses.
Minister Kelly this month at the Swords event “Future of Housing in Fingal” said that SI.9 was like “using a sledgehammer to crack a nut” and stated his intention to reform the regulations. Unless action is taken immediately to rectify the mess his predecessor former Minister Hogan left in his wake, we will be facing into another Irish Water as the huge costs and multitude of consequences of this legislation play out soon over the coming months.
Building Control (Amendment) Regulation S.I.9 of 2014 is a mistake by this government and we ask you as a representative of the people, to stand up and fight for the right of these people.
I look forward to hearing from you soon.
Irish Association of Self Builder