That report, by economist Ronan Lyons, concludes that Ireland needs to build between 2.8 million and 3.4 million dwellings between 2016 and 2051.

That’s equivalent to between 38,000 and 61,000 a year, “which is somewhat higher than the 33,000 ESRI figure”, said Nama in a submission it made to Fingal County Council regarding the local authority’s new county development plan.

Nama has significant landholdings in Fingal suitable for residential development – next to the M50 at Dunsink and north of Swords at Lissenhall. Both areas are close to existing and proposed public transport options and each is capable of delivering 7,000 homes, the state agency notes in its submission.

In its submission, Nama urged the local authority to introduce local area plans as soon as possible for both sites to allow for the early development of thousands of homes.

It said it supported the new Fingal development plan approach of zoning more land than it needed to hit its targets because this would help to keep down the price of zoned land in what is the fastest growing area of the capital. 

“Specifically, while the plan zones more land than is required to meet the targeted 16,245 new homes, we understand and support your rationale for doing so,” said the submission. “This is a significant reduction on previous objectives – 23,500 new homes were targeted in the 2016-2022 plan.

“To reduce the quantum of land zonings to reflect such a reduction would result in serviced land being unavailable for development which is not in the public interest, particularly at a time of surging demand and chronic under-supply of housing. It would also undermine parallel objectives of Government to dampen land prices.”

Nama said that the approach set out in Fingal’s draft plan “ensures enough land is zoned not only to provide choice in the market, but also in the event that the targets issued by the department are underestimated”.

“This may not be improbable as the annual housing requirement of 33,000 units presented by the ESRI in its report underpinning the HSTs [housing supply targets] is much lower than reports prepared by other commentators including the Central Bank and indeed earlier ESRI reports,” it said.

“Because of concerns with the impact of the reduced December 2021 housing targets on land zonings, including on lands secured to Nama, we commissioned Ronan Lyons, economist, to undertake a review the assumptions/inputs used by the ESRI,” it said.

The Lyons report suggests the assumptions around fertility and mortality and international migration are conservative and as a result underestimate overall housing need, said the Nama submission.

“The report also makes the point that as one of the key objectives of the NPF [National Planning Framework] is to enable people to live close to where they work, additional housing needs to be constructed in Dublin.

“So instead of reducing the capital’s share of national population as presented in the ESRI model, the alternative Lyons scenario allows Dublin’s population to increase to 32pc of the whole.”

For Fingal, this alternative scenario also assumes that its share of the Dublin population continues to increase but at half its current trend, the report said.

That would result in 8.1pc of Ireland’s population living in Fingal compared to 6.2pc as currently envisaged in the ESRI model used by the Department of Housing, it said.

The Lyons report found that more than 2,600 units a year could be needed in Fingal, compared to the baseline figure of 1,400 in the Department’s Housing Need and Demand Assessment (HNDA) tool.

Nama continues to hold security over significant and mainly residential land assets in Fingal, primarily in the Swords, Dunsink and Belcamp areas.

Some are capable of short- and medium-term development, with others having a longer-term development horizon, it said in it submission.

“Historically, Nama has funded significant residential development in Fingal and continues to do so at Belcamp and in Oldtown and Mooretown. More phases of housing development are advancing on these sites with Nama-funded proposals for almost 3,300 homes currently in the planning system,” it said.

The Lissenhall land bank is more than 225 hectares, of which 40pc is secured to Nama, it said in its submission.

The alignment of the proposed Metrolink travels through the lands over which Nama has security which will also take in the proposed Estuary Station and a major park-and-ride facility.

“We welcome the inclusion of Lissenhall on the list of locations where an LAP [Local Area Plan] will be prepared and strongly urge the preparation of such a statutory context within the first year of the development plan cycle.

“Our concern is that the absence of an LAP will firstly undermine the continued identification of the area for mixed development and secondly, will dilute the business case for bringing Metrolink north of Swords,” it said.

The Nama submission noted that Fingal’s new draft plan does not include Dunsink as an area where an LAP will be prepared. “As with Lissenhall, we strongly urge the preparation of an LAP in the first year of the development plan cycle.

“Failure to prepare such a statutory context in the 2023-2029 cycle unnecessarily stalls development on this site until the 2030s at the earliest but possibly the early 2040s at a time when Dublin has a major housing shortage.

“This is at odds with principles of sustainable development.”

It argues that the lands at Dunsink are appropriate for development in the more immediate term given they adjoin an existing development at Ashtown/Pelletstown and have the benefit of existing public transport infrastructure.

“The nearby Maynooth rail line is to be upgraded to Dart standard and a planning application for this is due to be lodged in 2022.

“Nama welcomes the zoning of both of these land banks because not only does that comply with the many worthy strategic outcomes of the NPF such as: that local authorities develop a long-term strategic view of housing need; support compact growth; sustainable mobility; and the transition to a low-carbon and climate resilient society.

“It also supports the business case for Government considering investing in costly but essential public transport infrastructure.”