Category Archives: SI No.9

The Cost of SI.9 on SMEs (very small enterprises)

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02 December 2015

The omission of the significant costs associated with complex administrative building control procedures BC(A)R SI.9 is a frequent mistake, even by members of key stakeholder bodies involved in the formation of the regulations. The time and cost required for even modest SME projects is considerable.

For a minor SME fit-out with a construction budget of €25,000 for an  internal “change-of-use” fit-out, SI.9 building control procedures introduced in 2014 will cost €6,273 including Vat i.e. 25% of the value of the project. The Blog has received other SI.9 quotes for similar projects at over twice this cost (see end of post for full breakdown).

A recent Q+A in the property section of the Irish Times on 25th November 2015 gave incomplete advice for such a change of use scenario; see the extract below without any mention of BC(A)R SI.9 costs:

Extract:

“Change of use: I’m starting my own business within the next two years. I’ve got a concrete garage which is sound, but the roof is made of asbestos and is in bad repair. I’m thinking of converting the garage into a kitchen. Obviously it would need a new roof but I’m wondering if there was any other regulations or permission I need to have a kitchen in there. It already has access to water and electricity.

Planning permission is required for all developments… you will also be required to prepare…[a] Fire Safety Certificate Application; Disability Access Certificate Application; and a Commencement Notice (in advance of building works commencing on site)…” (Link to Full Article here)

Assuming a 30 Sqm internal area, a €25,000 (incl vat) fit-out budget and a 3 week construction period, here are the overall fees and charges one could expect. The following calculation does not include any of the additional administrative costs for the builder. The fit-out will take less than 3 weeks to complete.

Statutory permission fees

  • Measured survey (entire property, required for planning and FSC): €700
  • Initial planning, preparation of sketch proposals, meetings and pre-planning consultation with Planning Department (incl OS maps €40): €800
  • Preparation of Planning application (documentation, drawings, specifications): €2,000
  • Preparation of Fire Certificate application (FSC incl. drawings and reports):€900
  • Preparation of Disabled Access Certificate (DAC incl. drawings and reports):€900
  • Building Control Appointments: professional Design, Assigned and Ancillary Certifiers: €5,100 (see breakdown below*)
  • Health and Safety Appointments: Project Supervisor (Design Process): €700
  • Health and Safety Appointments: Project Supervisor (Construction Stage): included in Builder’s costs
  • Total professional fees: €11,600
  • SubTotal fees and costs incl Vat @23%= €14,268

 Local Authority Application fees & costs**:

  • Newspaper advertisement (planning): €220
  • Planning Fee €108
  • FSC application fee: €87
  • DAC application fee: €800
  • Sub-Total fees + costs: €1215

Total costs incl fees: €15,483

For a minor SME fit-out with a budget of construction budget of €25,000 incl vat for an internal “change-of-use” fit-out, no external modifications or extensions, planning and building control procedures will cost €15,483 incl vat, over 60% of the construction budget of the project.

40% of this figure relates to Building Control (Amendment) Regualtions SI.9 introduced in March 2015, at €6,273 incl. vat.

Notes:

*Building Control Costs (BC(A)R SI.9):

  • Preparing docs for upload; outline spec, notification plan etc: €1,500
  • Site Visits incl written reports for circulation & uploading to BCMS @ €400.00+VAT per visit and subsequent written report. Assume 4 visits: €1600
  • Completion Certificate Stage: €500
  • Ancillary certifiers (x 2 engineers): €1500
  • Subtotal BC(A)R SI.9 costs: €5,100 (minimum cost)
  • Total incl. vat @ 23%: €6,273

**All costs except statutory application fees are Plus VAT @ 23%.

Other posts of interest:

Building Regulations Amendments: 20 Feb 2014: Seanad debates (KildareStreet.com)

98% say “Building Regulations introduced in recent years are acting as a barrier to construction” | Knight Frank Survey

How much does Building Control cost in the UK (Northern Ireland) for apartments?

What do Building Control Regulations cost for a typical apartment?

“After 18 months of operation the industry view of SI.9 is pretty conclusive: it’s not working”

Inadequate Regulatory Impact Assessment for S.I.9- Look Back 2

Self-builder’s Letter to ISME & SFA: BC(A)R SI.9

Fire-fighting | Rush and Lusk School

RushandLuskSchool_large

 Rush and Lusk Educate Together School

In yesterday’s Examiner 26 October 2015  (Link:) journalist, Fiachra Ó Cionnaith, alleged that Ruairi Quinn refused fire-trap school repairs while he was Minister for Education. In the article Ó Cionnaith wrote:

“Former education minister Ruairi Quinn told school authorities that a 200-pupil facility built during the boom needed only “minor” repairs, a year before it was declared a severe fire safety hazard” 

Back in 2012, then Minister Quinn in reply ( Link:) to Terence Flanagan TD said that:

Officials in my Department have no role or statutory authority to undertake “fire safety checks” or sign off on “fire stopping” in new school buildings”

“Issues of health and safety are a matter for the school Board of Management (BOM). If the BOM is aware of potential health and safety risk associated with “fire stopping”, then they should contact the consultant who issued the certificate of compliance”

Following serious concerns raised in Rush & Lusk Educate Together School €800,000 had to be spent in emergency fire-safety works to upgrade the six year old building. Once the problems at a Rush & Lusk Educate Together School were identified this raised concerns about others schools when it emerged that 26 schools had been built by the same contractor under the RAPID delivery (design-build) Department of Education contracts.

These builders are still tendering and winning bids for new Department of Education Schools. A Department of Education spokesperson said (Link:) this is “in accordance with EU procurement regulations” which means the firm is “not precluded from tendering for building projects”.

There seems to have been a marked change in Department of Education policy under the current Minister Jan O’Sullivan. The safety of school children is a serious concern and it is not enough to advise inexperienced School Principals and Boards of Management to pursue builders and professionals through the courts. Minister O’Sullivan confirmed this week (Link:) to Jonathan O’Brien TD that:

“The Department is currently arranging fire safety assessments of five other schools constructed in 2008 to determine if there are any issues of concern. Without preempting the outcome of those assessments, I can assure the Deputy that funding will be available to deal with any fire safety issues which might arise”

Ironically, the government is learning at first hand that their own advice to buyers of defective apartments (that it is the owner who is primarily liable for defects) applies equally to themselves. Minister O’Sullivan is clearly well briefed on the problems on defective buildings and the defects in Irish law having previously had responsibility for ghost estates which she called “a very potent example of the destructive dalliance the previous Government had with the property market”

Other posts of interest:

Carrickmines Fire Fatalities

Ministerial Review into Fire Safety is “…a joke” | Irish Examiner

Is Limerick Hotel fire a 3rd “Lucky Escape”?

Further questions over Newbridge fire-trap houses that have ‘no resale value’

Framework for Building Control Authorities | June 2016

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01 September 2016

The Framework for Building Control Authorities Version 1.1 was launched in June 2016 (see link here).  This new Framework replaces Version 1.0  published in June 2014 (see link here).  

The 77 page document (up from 64 pages)  is the ‘manual’ produced by the City and County Managers Association (CCMA) for Building Control Authorities in applying Building Control Regulations and as such is essential reading for anyone involved in construction.  The most significant new sections are about Building Control appeals to An Bord Pleanala, phased completion and opt-out provisions.  The most interesting part of the new Framework document in on page 12:

“Chester Bowles concluded from his experience with the U.S. Office of Price Administration during World War II that 20 per cent of all firms would comply unconditionally with any government rule, five per cent would attempt to evade it and the remaining 75 per cent are also likely to comply, but only if the enforcement threat to the dishonest five per cent is credible. Source: improving regulatory compliance: strategies and practical applications in OECD countries, John Braithwaithe, 1993

The BRegs Blog have reported on a wide variation of interpretations and applications of BC(A)R SI.9 since implementation in March 2014, and as such this attempt to standardise approaches is welcome (albeit over 2 years following implementation of BCAR).  The BRegs Blog is not aware of any guidance from relevant stakeholders on this document.  Many commentators and industry experts are critical of the lack of enforcement by Local Authority Building Control since our current privatised system of “self-regulation” was introduced in 1992.  Extract from Framework document:

“Building Control apply generally to new buildings and to existing buildings which undergo an extension, a material alteration or a material change of use… The purpose of the Framework is to provide guidance for Building Control Authorities (BCAs) with respect to undertaking their functions under the Building Control Acts 1990 to 2014 and the Building Control Regulations 1997 to 2015.

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The ‘Enforcement Pyramid’ (source: Framework for BCAs,  June 2016 p5)

Standardisation and co-ordination nationally of the statutory building control processes, including those listed hereunder, i.e. Notices, Applications, Certificates of Compliances and

Building Control Register

  • Processing and validation of Commencement Notices (CNs);
  • Processing and validation of 7 Day Notices;
  • Inspections and assessments during construction;
  • Processing and validation of Certificates of Compliance on Completion (CCC);
  • Processing, validation and adjudicating on applications for Relaxation of and/or Dispensation from particular requirements of the building regulations.
  • Processing, validating, assessing and granting/refusing Fire Safety Certificate (FSCs) applications-including regularisation and revised fire safety certificate applications; and
  • Processing, validating, assessing and granting/refusing Disability Access Certificate (DACs) applications-including revised disability access certificate applications.
  • Maintenance of the Statutory Building Control Register.
  • Processing of Appeals under to the Board under section 7(1)(a) or 7(1)(b) of the Act”

Download PDF here: Framework for BCAs Version 1.1 June 2016p77.pdf [Converted]p77.pdf [Converted]

BCMS Steering Committee Members (source: Framework for BCAs,  June 2016)

Other posts of Interest:

Framework for Building Control Authorities – Version 1: July 2014

Firetrap Homes | “Fingal CoCo ‘head in the sand’ approach to building control”

Oireachtas Committee on Housing and Homelessness Report recommends Building Control Changes

“Building control regulations not fit for purpose” | Sunday Business Post

How much does Building Control cost in the UK (Northern Ireland) for apartments?

What do Building Control Regulations cost for a typical apartment?

Q + A: Local Authorities and Building Control Regulations | Eoin O’Cofaigh

An ounce of oversight or a pound of legal fees? | Building Control in Ireland 2015

What Building Control could learn from the NCT | Orla Hegarty MRIAI

One year on: Reflections on the Building Control Amendment Regulations (SI.9 of 2014) | Michael Collins FRIAI

Minister Kelly approves 200 staff: will any go to building control?

Additional Engineers’ fees for school projects | SI.9

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12th January 2015

Most professionals involved in Public Sector projects feel that the additional red tape of SI.9 that mirrors duties and documentation that were already required is unnecessary and a waste of public finances. Most contributors to this Blog have confirmed that applying the same methodology for the speculative residential sector (where full-service appointments are not the norm) to public sector procurement makes no sense.

Early in 2014 the RIAI met the Department of Education to progress the basis for additional fees for architects undertaking the roles of Assigned and Design Certifier on school projects (based on additional time required under BC(A)R SI.9). See previous post “Time needed for School Certifier“). Not only architects but other design team members, structural and services engineers, are also seeking an uplift in fees for less onerous ancillary certification roles. From industry sources we table approximate increased fees for school projects from engineers and summarise as follows:

  • Ancillary Certifiers (structural engineers) +/- 0.8%
  • Ancillary Certifiers (services engineers)    +/- 0.8%
  • Assigned/Design Certifiers (architects)     +/- 1.0 %
  • Additional fees for BC(A)R for schools      +/- 2.6%*

On a €3m value school project this translates into approximately €25,000 additional fees for EACH Ancillary Certifier (structural and services) while the more onerous role of Assigned Certifier /Design Certifier can expect a fee in the region of €35,000. We have heard of total consultants’ fees up to €100,000 on larger school projects for additional SI.9 duties. These fee levels may vary from project to project, and fees may be a larger percentage for smaller projects. Additional costs associated with SI.9 may be twice this figure when contractors and specification issues are factored in.

The following is a typical scope of services as noted by an engineer for duties associated with the Ancillary Certifier role. Interestingly we have not seen an architect’s scope of service or fee for the same role where the architect is only prepared to act as an Ancillary Certifier. Under SI.9 the statutory duties of Design Certifier may be undertaken by any designer on the project and the Assigned Certifier role by any competent registered professional.

ANCILLARY CERTIFIER ROLE (ENGINEER) ADDITIONAL DUTIES UNDER SI.9:

  • At Commencement stage :-In accordance with the Code of Practice (7.1.1 ) agree Preliminary Inspection plan with Design and Assigned Certifier. Agree final Inspection Plan with Assigned Certifier.
  • Provide General Arrangement drawings (structural and services) Design Reports, and any additional structural (or services) drawings and documentation for Commencement stage, including documents demonstrating compliance with Technical Guidance Documents, and any supporting documentation  particular to the engineer’s role
  • Identify all civil/ structural and M&E Specialists with design function and agree Ancillary Certificate requirements.
  • At site stage : In accordance with the Assigned Certifier’s agreed Inspection Plan carry out specific works inspections. Attend all agreed and scheduled inspections/ interim inspections and co-ordinate with the Assigned Certifier. Compile and keep records of all meeting minutes, correspondences, site inspections, site reports , contractor proposals/sketches, record observations, instructions for remedial works, contractor corrective action reports, issue any clarifications necessary, and re- inspect any remedial works as required. Maintain telephone records.
  • As required under SI 9, 2014 maintain file copies of all structural calculations. Retain site specific investigation / test reports.
  • Coordinate the production of as-built drawings for validation submission to Building Control Authority and BCMS at the completion stage of the project.
  • At Project Handover Stage / Works completion:- Provide required ancillary certification for validation submission to Building Control Authority and BCMS  at the completion stage of the project. Compile other ancillary certificates and issue to Assigned Certifier.
  • Issue a record of all compliance reports and assemble all ancillary structural and civil specialists and M&E specialists Ancillary design certificates.( Sd Sc and Si as agreed with Stakeholder bodies) to the Assigned Certifier.

The decision to adopt Statutory roles or not and any negotiation on fees and services is a matter for individuals as there is no collective bargaining.

*fee percentages normally increase for smaller projects. These consultants fees exclude additional costs for insurance, certification, professional indemnity exposure caused by the significantly greater risk as to liability, currently untested. We believe the additional costs for the work associated with contractor, sub-contractor and supplier costs, specification and inspection oversight will at between 3- 5% onto these costs. Total additional cost for SI.9 for school projects av. +7%.

Other posts of interest:

SI.9 stops Summer Works for schools in 2015!

Schools to suffer as Minister ignores Essential Works Scheme:

Is SI.9 necessary for Public Sector projects:

SI.9 causing major delays to school projects:

60 new schools delayed due to SI.9 | Independent.ie

Examiner – € 35.5 m unspent as Building Control Regulations delay school projects:

Summer Works 2014 Budget:

“30 % of self-builds in 2014 have been postponed or abandoned” | IAOSB

self-build10 January 2014

The Irish Association of Self-builders (IAOSB) conducted a survey of its members in 2014 and found that one third of self-build projects including one-off houses and extensions had either been abandoned or postponed. This figure could represent almost a quarter of the total for house building in Ireland. We reproduce below an interview Shane McCloud, of the IAOSB,  gave recently on this issue outlining some of the reasons for this collapse in self-build housing figures.

 1) What is your own background, are you a self builder, where are you from and when did you set up the Irish Association of Self Builders website?

I have built three houses here as a self builder on direct labour and project management route. Before that, I was a Civil Engineer graduated in USA and have previous experience in this field in the UK. Irish Association of Self Builder was officially launched on 1st of January 2004 and has constantly been ranked number one with all major search engines for “Building a house in Ireland” or similar phrases. Iaosb.com was never started as a business and the aim has always been to help and assist new self builders to understand the whole process from start to finish. The whole operation of the website is run by a team of volunteer self builders who have gone through the experience themselves and want to help others going through the process now.

2)  Did you get any response from Minister Alan Kelly following your letter calling for changes to the building regulations?

We have written to Minister Alan Kelly twice and have received no replies. Recent comments from Minister Alan Kelly mentioned amending SI9 to reduce impacts on self builders. The RIAI at an EGM on 4th November mentioned that they had been tasked with “sorting out” the self-builders. R.I.A.I President said at his meeting with Alan Kelly in early September he was asked for help in resolving the self-build problems under the regulations. We don’t know if the RIAI have proposed technical solutions to the minister in the last 3 months. The RIAI president raised this issue on SixOne in February when Phil Hogan was the Minister and nothing was ever done about it.

 3)  Can you provide details of the survey you did, which found that  1/3 of all self-builds this year have either been postponed or abandoned and could have led to up to 1,000 houses not being built? Was it an online survey?

Out of a representative sample canvassed  we had 40% replies. Based on membership profiles, we believe 30 % of self-builders in 2014 have been postponed or abandoned. The breakdown of respondents were as follows:

  • 1/3 at the upper end were able to assume 22%+ increased costs. These are at the upper cost end of the spectrum.
  • 1/3 in the middle band were still able to undertake projects but were reducing their scope to accommodate increased costs. For many this means reducing size, specification etc.
  • The bulk of respondents who have indefinitely postponed or abandoned self-builds (last 1/3) are at the lower cost end. Many here were hoping to build cheaper than speculative built housing. Normally savings to self-build at this end are around 30% on the sales price of similar standard spec- built housing. Quite a few self-builders are either on housing lists or in rental accommodation at this level.

We believe Bank lending has become much tighter this year , borrowing extra for more  ‘consultancy fees’ is very difficult.

We believe out of 8,300 completed housing units in 2013 around 1,300 were developer built housing units (CSO source). This means that 85% of the new homes built in Ireland in the last few years were ‘custom build’ or ‘self build’??

4) Is the problem right across the country, or is it more prevalent in rural areas?

Our membership is diverse and most individual self-builds are rural. However a significant proportion of members undertake significant extensions and alterations managing projects themselves. Direct labour is not limited to house building. Lots of small businesses in retail, hospitality, tourism and services sector do work through direct labour.

 5) Has the association had a meeting with the Department of the Environment on this issue and what was the outcome?

We have had no meeting with DECLG on this issue . We found out that Minister Hogan stated in a Seanad debate that he consulted with the IAOSB but this is incorrect (Link to Seanad speech). We have also noted the transcript of this debate has been altered to remove this factually incorrect statement. Senator Paschal Mooney has requested more information on this. Self Builders would welcome a meeting to propose solutions.

6) Have you been contacted by people complaining about the fees they are being quoted for having their self-build signed off under the new building regulations, and can you give any examples?

Yes many members have contacted us. One you could talk to is Amanda Gallagher. An RIAI architect (with a quantity surveyor) self-has completed a detailed breakdown of additional costs for SI.9 due to increased professional fees and increased costs to use a main contractor registered for a typical 1,350 4 bed detached house in suburban Dublin- see link here [SI9 costs for a typical dwelling]

The problem is that the regulations are very demanding- it’s understandable that someone won’t risk their own livelihood- if the regulations were clearer the cost would drop. The following is an extract from a member asking for help this morning:

“ To put into perspective I have received three quotations of €4,500, €12,000 and €32,000 all exc VAT for work. This has scared me immensely. I am open to admitting I know nothing about construction but I have two builders both of whom I trust having witnessed them build homes for my friends and family over the past 15 years. Either will do a great job for me with my families best interests at heart. I cannot engage either of them until I have a certifier picked who will need to re-draw my plans to meet their needs and start this process but how can I tell which is the right one to go with especially when each are saying ‘we are all learning about this process and trying to get our heads around it’. Am I really to pay up to €40,000 for something that my neighbour who started work in February (one month before the new regulation launched) is not having to do at all?”

The quotations are based on the work being done by a Building Contractor.

7) I’ve seen the statistic that 60 per cent of houses are self-builds- is this an old statistic because it seems very high?

It varies between 40- 60%. This excludes extensions many of which are self-built. Based on CSO figures for 2013, 8300 dwelling units (including apartments) were built in the year. Approximately 3,000 were once-off houses. Only 1,300 units were registered with house-building guarantee schemes (speculative WITH HOMEBOND) so the bulk of dwellings built were either commissioned or built by individuals rather than house building companies.

Private individuals and businesses with no experience commission buildings and extensions all the time- that’s normal in every country, it doesn’t mean shoddy work. Cowboys are more likely in speculative building where cutting corners can bring big profits,

A quick look at sites like link2plans (we think they may overestimate the number slightly) and the BCMS website (Department site where new commencements are recorder) to verify the extent.

In the UK self-building is very big, and the UK recently have launched a co-housing initiative, to supply low-cost sites to self-builders and decided that there’ll be no development levies for self-build. UK government see self-building this as a big part of solution to the housing crisis- sustainable well built homes, no cost or risk to tax payer.

8) Are the new building regulations having any impact on extensions (from the building regs forum, it seems that extensions under 40sqm are not affected)?

Apparently the Department have recently come back to recommend that many extensions previously under 40sqm that were considered exempt are no longer. The advice is very confusing and we believe the RIAI have written to the department to clarify. It is remarkable that professional architects currently are uncertain and in the dark as to whether extensions under 40Sqm are exempt or not. The BRegs Blog has written extensively on this. In the meantime many small extensions aren’t viable as the cost for inspections is more than the build.

If you need links to any of the statics or sites/ topics listed I can provide them for you.

As you can see from the attached Department of the Environment information there is little to suggest a  housing boom.

Bruce Shaw Annual Review for information on costs, trends and the construction industry:

http://www.bruceshaw.com/knowledgecentre/chapters/ireland

All our information are gathered by a self-build research team and if you have any further technical queries please do not hesitate to let us know and our team will endeavour to answer all your questions.

Kind regards,

Shane McCloud

Other posts of interest:

Self build: How to make your dream home come true

What is Cohousing? | Homebuilding & Renovating

Lobbying in the Construction Industry – Part 1

CorkCityAerialView_large

8th January 2014

In Tuesday’s Irish Examiner Rory Hearne suggests the housing market should serve the interests of all not just the few (Link to article). He also writes:

“We need a national debate about who really benefits from the current housing and property market based around home ownership, and spiraling house prices and rents.

The big beneficiaries remain the banks, developers, estate agents, solicitors, landlords, and increasingly, international capital and vulture fund investors who are buying up huge swathes of Irish residential property (often from and with Nama).

They all have a vested interest in a rising property market.

There has been widespread concern and criticism of some of the same vested interests being involved in the negotiations for the new building regulations, SI.9, introduced in March 2014. Seen as a paper exercise and ‘a political solution’, SI.9 creates a complicated ‘red-tape’ exercise in hands-off private regulation which is resulting in massive costs to consumer and industry. SI.9 was introduced by the former Minister for the Environment, Phil Hogan,  with little public or professional back-ups being in place, and no consumer input.

Following on from a public consultation in 2012 only a small circle of key stakeholders were invited to participate in the formation of SI.9.

The organisations invited to participate were representative bodies for architects, engineers and chartered surveyors (RIAI, ACEI and SCSI respectively) along with the Construction Industry Federation (CIF). Most of these bodies now have statutory roles and operate self-policing registers. The CIF register, CIRI, is due to be put on a statutory footing in March 2015.

Critically no consumer groups were involved.

Many consumers share this view and many perceive that the government has conveyed vested interest groups with a monopoly on various statutory roles within the construction process. This is most visible in the self-build sector, where owner/ builders legally are unable to build their own houses without the involvement of a contractor, preferably a Construction Industry Federation/CIRI registered one. This has resulted in significant cost increases, particularly for housing (see links below). The industry has observed a significant fall-off in new self-built homes being undertaken this year.

With Local Authorities already chronically under-resourced, with no additional training or staff allocated to operating the new system, problems such as rogue or cowboy builder/ developers and serious materials issues such as pyrite are set to remain with us for some time.

All these representative bodies are now set for a windfall in income as a result. In order to operate as a registered professional under the new SI9 one must be on a register, and a hefty registration fee must be paid annually to these representative/policing organisations. With 60,000 operatives involved in various roles in the construction sector annual registration fees represent a bonanza for these key stakeholder bodies.

A significant reason for all these organisations to be supportive of SI.9, even though most agree that the regulations bring little or no additional consumer protections to owners.

BRegs Blog Admin. Team

Other posts of interest:

Legal perspective: consumer benefit? BC(A)R SI.9 

€ 5 billion | The extraordinary cost of S.I.9 self-certification by 2020 

Government Reports + Professional Opinion Ignored in SI.9 | look back 5

Summary of Legal Posts- BC(A)R SI.9 

Pyrite legal dispute referred to European Court | Independent

World Bank Report 2015 | UK v Ireland the real cost of “Dealing with construction permits”

World Bank Report 2015 | Ireland’s poor construction regulations are the biggest drag on our ranking | BRegsForum

What’s happening with the RIAI? | Village Magazine

Village Cover

What’s happening with the RIAI? | Village Magazine

The Royal Institute of the Architects of Ireland (RIAI) has published a link on its website to the December 2014-January 2015 edition of Village Magazine containing a scathing critique of the organisation, one of the main stakeholder groups involved in negotiations on SI.9. In a no-hold barred two-page spread, the Village Editor Michael Smith, depicts a professional organisation in crisis with a series of allegations being made in relation to the CEO, President and members of Council of the RIAI.

These allegations include concerns regarding:

  • The additional regulatory and insurance implications of SI.9 on “economically traumatised” professional design firms seemingly ignored by the RIAI Executive;
  • The lack of transparency and accountability with the CEO “lobbying the Government behind the scenes”
  • The CEO involved with “too many, sometimes conflicting powers”
  • The potential conflict of interest for the CEO through the crossover engagements between his son’s website consultancy firm and other stakeholder organisations involved with SI.9.

The above allegations are refuted by the RIAI President, Robin Mandal in the article. The matters raised by the onerous imposition of SI.9 would appear “to be a side issue in the debate over propriety” at the RIAI. However the above items raise a legitimate concern for the professionals being represented by this body and whether those tasked with renegotiating SI.9 have their eye on the ball when there appear to be so many other fires to be put out. The RIAI President, writing in its official journal last month, said that he looked “forward with relish to 2015, the year of change” without actually identifying what specific changes he envisaged. It would appear, if the allegations in Village Magazine are correct, that a top-down change is urgently required at the RIAI.

The 2000-word article referred to above is available online on the RIAI website in the “RIAI in the News section”- Link: here. (Jpeg is attached below).

BRegs Blog Note: The 2-page December ’14/ January ’15 feature referred to above is now available on the Village website- for full article click title Hackles RIAIsed. | Village

Village Magazine is also available from most newsagents (€3.95).

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Other posts of interest:

John Graby – RIAI, CEO | “Phil Hogan did not bulldoze through SI.9′

RIAI Complainee investigates IAOSB Complaint

Radio Clips: RIAI and CIF differ on Building Control (Amendment) Regulation (SI.9 of 2014)

Legal perspective: consumer benefit? BC(A)R SI.9

RTÉ Radio- CIF: professionals to Guarantee under BC(A)R SI.9

Assigned Certifiers facing jail? BC(A)R SI.9

Alarming Legal opinion: BC(A)R SI.9

Should the Architectural Technology Profession stay within the RIAI?

The future for Architectural Technologists is outside the RIAI | Joe Byrne

10,500 housing units completed in 2014

Bubble-Burst

It would appear from recent media comment that some industry sources are trying to hype up a “construction housing boom”. Figures for 2014 released from the Department of the Environment (DECLG) confirm that housing completions remain at depressed levels. There are many factors affecting housing supply but the figures clearly indicate that one of the unintended consequences of the new building regulations introduced in March 2014 is additional “red-tape” costs and legal uncertainty which is further inhibiting new housing starts.

The following is a summary of residential completions from the DECLG. It lists monthly completions since 1975, from January to October 2014 inclusive. Data for November and December 2014, traditionally a low for completions, is unavailable at time of writing.

Based on the table below one can assume there will be approximately 10,500 houses completed in 2014, similar to the 2011 recession level.

8,796 housing units (houses and apartments) were completed for first 10 months of 2014. Although this figure exceeds the total for the previous year (8,300 dwelling units), it should be recalled that 2013 was the lowest ever residential completion total since records began in 1975.

monthly house completions 1975-2014 (oct)

TABLE: Monthly House Completions 1975-2014 (Oct)

An initial analysis of information, available from the DECLG and other sources, suggest that NAMA and ‘ghost estate’ completions account for a significant amount of the increased supply in 2014. These are likely to be apartments already completed or part-completed and vacant for some time that only obtained ESB live connections this year (this is the criteria for the DECLG completion statistics).

The ESRI estimate 12,500 units will be required in 2015. Based on information available from the the BCMS Building Register, Commencements to December 2014 were still down 25% year on year directly following the implementation of the new Building Control system in March. The ESRI 2015 target may not be achieved with consequences for consumers, affordability of new housing and rental prices adding to the current housing crisis.

A review of the impact of the new building regulations is to take place shortly.

Download pdf here: monthly house completions 1975-2014 (oct)

Housing Completions

House Completions 1975-2014 

Other posts of interest:

BCMS Commencement Notices | Nine Months On

CSO | Construction output increased by 0.1% in Q3 2014

Developer-Led projected Sales Price for a Typical House

So What is an Independent Building Inspector and How Can they add value?

Central Bank | More turbulence in housing market?

“House building costs are 17% more than 2003 despite recession” – Bruce Shaw

Soaring house prices and rising rents could damage economy | National Competitiveness Council

Ivan Yates | Vulture capitalists won’t build the 25,000 houses we need!

ivan-yates

 Ivan Yates

Writing in the first edition of the Independent newspaper for 2015, Ivan Yates clearly spelled out that he believes Ireland needs “real developers” to sort out the housing crisis and that it is naïve of the Government and others to believe that the problem will be sorted by the short-term thinking of vulture capitalists. He adds that if you are depending on the international vulture capitalists who invested €35bn in 2014 in Irish property to provide finance for new construction activity, you’re sadly mistaken as “these ‘bottom feeders’ aren’t interested in long-term Irish development or its society; they’re after a fast buck and a quick exit”.

He also writes:

“In Ireland, once we’ve articulated a problem, declared it a crisis, called a summit and announced the government package, we think it is resolved. It’s implementation where we repeatedly fall down.”

“Governments are great at big pronouncements: 110,000 homes will be in place by 2020; Nama will build 22,000 homes over the next five years; Nama will convert the Docklands into Canary Wharf. The reality is less exciting. In 2013, beyond Dublin City Council, how many new houses were completed on average by each council? Three!”

“Costs of building a new house are greater than existing ones, even if the site is for free. It’s a no-brainer therefore that there will be zero construction requirements in these areas, as no profit margins are attainable.”

Yates makes some valid points in the Independent article but he is proposing the ‘spec-build’ business model that has failed spectacularly in the past without addressing the core problems. A developer’s business is about driving building costs (and quality) as low as possible and controlling supply to sell into the market as high as possible.  Neither problem has been fixed…………yet.

You can read the full article here: (Link:)

Christmas Present(s)| We are where we are | Christmas Future

presents

Christmas Present(s):

The initiative to improve building standards in Ireland was welcomed by all sides as there is general  agreement that almost 25 years of Building Control has not been a success. There are many reasons for this but the political will to make improvements is to be applauded. After ten months of the new system, all sides acknowledge that further changes need to be made. There is an urgency about dealing with this because construction is a driver of the economy – we need houses and schools; more importantly we need jobs.

The challenge for 2015 is to deliver a robust system that does not compromise on standards with the resources available. A comprehensive review of SI.9 that includes some of the consumer groups overlooked in the drafting of the original legislation would indeed be a super Christmas and New Year present for consumers and professionals alike.

Christmas Future:

The Minister for the Environment, Alan Kelly T.D. has signaled recently an industry-wide review of the new building control regulations for early in the new year. Only last Thursday the Minister of State at the same Department, Paudie Coffey, replied to Barry Cowen TD in the Dáil that:

“Early in the New Year, the Department will commence its review of the first year of operation of the regulations in conjunction with local authorities and industry stakeholders. The impact, particularly in relation to cost, of the regulations on one-off housing will be a key element of this review which will inform future regulation in this critical area.”

We hope that the key stakeholders are prepared and will make informed representations concerning the unintended consequences of SI.9 on consumers as well as the impacts on their respective members. Over the holiday season the elves here at BReg Towers will continue working away on solid, workable, cost-effective solutions for the implementation problems of SI.9. We hope to report on these shortly.

Have a safe and happy holiday,

BRegs Blog Admin. Team

Other posts of interest:

SI.9 Review.. “early in the new year” | Minster Alan Kelly

Dáil | Minister Kelly may take steps to control SI.9 ‘exorbitant charges’

‘Onerous’ Building Regulations must be amended – Minister Kelly

Is the UK ‘approved inspector’ model a more transparent system, with better outcomes? | The Engineers Journal

BCMS Commencement Notices | Nine Months On