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Firstly, I want to say we don't full sail disagree with this idea at all.
We just have a few concerns and think it should be kind of thought through a bit more
before going forward. So our concerns are threefold.
Firstly, I would say we're quite concerned on the renting side of things. So
threshold is a renter's rights charity. So the type of stock or type of renting arrangement
this is bringing in would be of concern to us. To give a bit of backstory on that. So in Ireland,
there are two types of renters. There are tenants and there are licensees. So tenants who
they're who we usually think of, right? They have full protections under the residential
tenancies. Actually, they can go to the RTP if they have any issues. There are people who say rent
a whole place or go into a house share with a bunch of their friends in rent a whole place.
That sort of thing. However, there is another cohort, the licensees. So those are people like
in dig style accommodation. They actually do not have any protections under the residential
tenancies, actually renting legislation, and they do not have access to the RTV.
And people who've availed of the rent a room scheme would they be under the licensee category?
Exactly. So anyone in the rent a room scheme would be a licensee. So in these arrangements,
the licensee or the landlord could say, I need you out of this room tomorrow. And that would
be fine. That would be legal. That would be allowed. So no security. No security at all,
exactly. So this type of renting arrangement is not secure. It's not sustainable. So if that's
the type of thing we're bringing in, we're a bit concerned about that. We don't need more of these
insecure unsuitable tenancies, or they're not tenancies. Legally, they're not their license
arrangements. So that would be our chief concern from a renting point of view. So if you're saying,
saying all of these garden homes are going to be rented room, they're going to be licensees.
Well, that's a huge concern for us. That's a lot of insecurity. Secondly, we would be quite
concerned with the standard that's bringing in. So if we're getting rid of or relaxing the
planning permission requirements around this, what is the standard of home that we're bringing
into the private rental sector, but also just in general, fire safety and everything? And also,
what is the stress on the sewage system on the water reliance for the area? These are things
that the local government would no longer have data on. That's reliable if we're getting rid of
the planning permission for the area. Because we see so many developments turn down because there
isn't wastewater capacity. So it stands to reason that an additional unit like this on a property
is going to put some level of strain on the system. Exactly. And if the local government doesn't even
have the data to be able to anticipate or make changes to support it, I mean, I feel like that
puts us a detriment for the future. And then lastly, we would be quite concerned with the
potential for elder abuse. So like you said at the top there, we've gone in on this with
age action. And they would be more of the experts in this area. But this does open up older
relatives and homeowners to elder abuse. So someone could potentially influence or force their
older family member into one of these back garden homes as they take the main home themselves,
or potentially put in a garden home to rent out. And then that relative can get that tax
free income of up to 14 grand. So these are the concerns that we have that we think need to
be thought through and teased out a bit more. Again, we're not full sale of disagreeing with
this idea. It's just there are some concerns. And Claire Femmes spoke to a number of
auctioneers locally about this during the week to get their reaction. And both of them
to varying degrees welcomed the measure once said that any boost to supply is welcome
but the way he put it is the devil will be in the details. So this sounds like it could be
positive in that it brings more rental units into the market, but we'll just need to see
what the regulations are, which I think is perhaps what you're saying in some way as well,
that this could be positive, but we'll need to see what the details look like. And is that
with this comes down to making sure that those protections are in place so that fire safety is
looked after so that energy efficiency is looked after and so that this isn't
a substandard kind of a scheme. Completely, we were talking about this last August, September time
and we were told at that point, like, oh, these units will not be going into the
private rental sector. These are just four family members say if someone had a student that had
to move back home or something like that, you know, those were the circumstances that these
will be brought in, but we were concerned they would go into the private rental sector and now
we're being told, oh, actually, these should be like we should change it to be these are
under-rinter room even. So yeah, we're quite concerned with I guess the rights, protections,
and standards of those who would be living in these garden sheds. I shouldn't call them
garden sheds of these modular homes. Modular units, yeah, indeed, although we all know what we're
picturing when we hear small modular units and in fairness, just a final question for yourself
on this and perhaps on a slightly bleak note because we spoke to threshold about a month ago
when it had new data on evictions and we learned that 183 clear households were assisted by
threshold in the final quarter of 2025. These were households who had been issued notices to
or rather 60% of those. So the majority of those had been issued notices to quit. You mentioned
the lack of security that could be a part of this particular proposal, the so-called beds and
sheds proposal. Could we be seeing another rise in the level of notices to quit issued
particularly with the new renters legislation introduced at the beginning of last month?
I will make a distinction. Again, a lot of those who would be in these units in the back garden
there would be licensees. Not necessarily de facto. There could be room for interpretation
there, but a lot of them will be licensees. So we won't even know the number of notices
determination. They don't get the same type of notice that an actual renter or a tenant
for somebody in a tenancy agreement would get. Completely. It wouldn't have any sort of
protections that tenants would have. So there's no data on them. Our TV isn't tracking them.
We could tell you the number of people who have been asked to leave in license situations,
but that's just people who come to threshold. But anyway, those as a separate issue.
But with the legislation that came in last month, we would see there's no reason for there
to be a surge in notices to quit because any tenancy that started before March 1 is effectively
running under the same rules as it was beforehand. I mean, not effectively. It is running under
the same rules as it was beforehand. So there's no reason for a landlord to issue a notice to quit.
It has not changed for them. And then regarding if there's a new tenancy started on or after
March 1 of this year, then those are under the six year lease six year tenancy. So the grounds for
which a landlord could end a tenancy are severely limited. And really they can't evict someone
if the tenant has done nothing wrong. So we would hope to not see any sort of surge.
And then regarding if this were to go through, if the planning permissions were to be relaxed,
and we had a surge of folks in, I wouldn't call them tenants, I probably licensees in these
back garden units. Again, there's no there's no data on this. So no one's tracking these figures
because they're not tenants. So the RTB isn't tracking them. They would be
kind of without protection. And they could be asked to leave at any moment. There doesn't need to
be a paper trail necessarily. Or like if you're a tenant, you must get a notice determination
in writing. That's not the case for licensees. They can be told over a text message.
And that is just as solid as a piece of paper. So it's very hard to track and to be able to
to tell you these things because licensees, we call them the Wild West of renting. Like there's
no protections. There's no rules.



