Clare PPN submission in respect of the preparation of a Draft Traveller Accommodation Programme 2019- 2024
August 23rd 2018
Clare Public Participation Network Submission in relation to the assessment of existing and projected Traveller accommodation needs and the preparation of a draft Traveller Accommodation Programme for 2019 – 2024 by Clare County Council.
Clare Public Participation Network welcomes this opportunity to make submissions in relation to the assessment of existing and projected need for accommodation for Travellers in Clare and the preparation of a Draft Traveller Accommodation Programme for 2019 – 2024.
At Clare PPN’s Plenary Meeting of November 30th 2017 the member groups of Clare PPN’s Social Inclusion College listed provision of support to the Travelling community and Traveller’s rights in County Clare as some of the key areas they wished the Clare PPN to focus on for the year ahead.
Clare PPN notes that at present it does not have a specific Traveller organisation amongst its membership and that such an organisation does not currently exist in Clare. Clare PPN further notes that whilst it continues its efforts to build relationships with the Traveller community in Clare that it does not have the resources to function as a community development organisation or to carry out extensive research into any specific community.
Clare PPN is represented on the Local Traveller Accommodation Consultative Committee (LTACC). It should be noted that the LTACC in Clare has not met since January 2018 and that it requires considerable work, support and flexibility on the part of the Local Authority to develop it into a forum where views can be exchanged and strategic progress made towards ensuring that Travellers have access to culturally appropriate long term accommodation in the county. Clare PPN also considers that it is necessary and beneficial for most settled people who are engaged in the provision of services to the Traveller and other minority communities to undergo some cultural awareness and anti-racism training and is willing to assist Clare County Council in arranging such training for staff in relevant departments in consultation with Traveller groups and other minorities in the County.
Clare PPN further notes that it requested (by email dated Wednesday 15th August 2018) two changes to this phase of Clare County Council’s consultation process and to date has not received a response from that request.
Clare PPN requested firstly that the process should be recommenced in September 2018 in order to take account of the August holiday period and to allow for a more substantial participation by the Travelling community and secondly that the notice of needs assessment should be separated from the call for submissions in relation to the preparation of a draft Traveller Accommodation Programme. Clare PPN requested that these separate aspects should be carried out in sequence rather than simultaneously- with Clare County Council’s accommodation needs assessment being made available to the LTACC and other interested bodies before the deadline for their submissions relating to the preparation of the Draft Traveller Accommodation Programme.
Clare PPN regrets that the above request was not facilitated and notes that in the absence of LTACC meetings it was not possible to request the above changes except within this consultation process.
Clare PPN notes that since the current Traveller Accommodation Programme 2014- 2018 was adopted, that the Traveller Community have been recognised as an Ethnic Minority group. Clare PPN notes that in 2017 a report commissioned by the Department of Justice and Equality found that Travellers as a group experience extreme disadvantage in terms of employment, housing and health and face exceptionally strong levels of prejudice. Clare PPN considers that it is incumbent upon every state organisation to work positively and proactively to improve the experiences and outcomes for Travellers when they access the state services to which they are entitled. The National Strategy for Traveller and Roma Inclusion 2017 states the following
‘There should be adequate provision of accessible, suitable and culturally appropriate accommodation available for Travellers. Delivery of Traveller accommodation should be underpinned by a robust monitoring and evaluation framework, with a view to ensuring full expenditure of funds allocated for Traveller specific accommodation.’’
Clare PPN notes that the Irish Human Rights and Equality Commission reported earlier this year that whilst Travellers make up less than 1% of the population in Ireland they account for 9% of the numbers of those experiencing homelessness. https://www.ihrec.ie/discrimination-and-inequality-in-housing-in-ireland
Clare PPN notes from its communications with Travellers and Traveller organisations that they are optimistic and ambitious for the future of their community and believe that issues such as poor access to secure homes and low levels of employment can be improved significantly within the next decade if there is cooperation and lack of opposition from government and local authorities. Clare PPN notes that the Traveller population in Clare as detailed in the last Census (2016) stands at 905 individuals or 271 families as documented in the Annual Estimates of Accommodation of Traveller Families 2017. As Traveller unemployment as surveyed in 2010 stood at 82% and has not significantly decreased since then, it is clear that the provision of homes and other forms of culturally appropriate housing support for some members of the Traveller Community will, for the life of this draft plan 2019 – 2024, continue to be a function of the local authority or national government either directly or through approved housing bodies.
Clare PPN believes that it should be possible to provide secure culturally appropriate homes for the Traveller community in Clare which would help them greatly to achieve their ambitions to progress across all aspects of their lives from education, health including mental health, employment and community resilience. Clare PPN hopes that in the drafting of this Traveller Accommodation Programme 2019- 2024 that Clare County Council will demonstrate their commitment to ensuring that Clare is a place where the Travelling community are valued, respected and are able to improve their own circumstances with the assistance of their local authority.
Clare PPN recommends that the new Draft Traveller Accommodation Programme would consider both accommodation and the wider living environment for Travellers when planning any new developments or when improving or maintaining existing ones. There should be access to services, transport, sufficient spaces for recreation and physical activity and attention paid to ensuring that Travellers have space to live in extended family groupings if they so wish and continue their hobbies, pastimes and trades as well as having access and opportunities to engage in the wider community and access education and employment. In order to address the severe disadvantage which Travellers experience it will be necessary to build secure sustainable culturally supportive living environments in which families, individuals and children can thrive.
Clare PPN wishes to have it noted that the new Traveller Accommodation Programme is being drafted in the context of a nation-wide housing ‘crisis’. It further notes that this is the first programme to be drafted since the introduction by the Department of Housing of the Housing Assistance Payment (HAP) scheme and that there has to date been no analysis of how HAP has served the needs of those from minority communities including the Traveller community. Clare PPN further notes that the provision of social housing by approved housing bodies has become a mainstay of social housing provision in County Clare and notes that according to reported figures as of 2017 only 4 Traveller families are listed as housed by approved housing bodies in the County.
Clare PPN recommendations for the assessment of existing and projected housing needs:
Clare PPN notes that work has been done this year on a peer to peer needs assessment in the county led Pavee Point and supported by the HSE’s Traveller Health Unit with assistance provided by Clare PPN and CLDC. Clare PPN recommends that if possible the Draft Traveller Accommodation Programme 2019- 2024 should be drafted in light of the findings of this needs assessment when it is complete and available.
Clare PPN also recommends that Clare County Council should make a concerted effort to ensure that the views and experiences in relation to accommodation of the Traveller community in Clare are canvassed before the completion of any assessment of existing and projected need. Clare PPN notes the following two directions from the guidelines issued by the Department that indicate that this is within the scope and remit of Clare County Council to organise-
‘Additional inquiries as may be necessary, including consultation with Traveller families and any relevant Traveller support groups within the functional area of the authority, to ascertain a comprehensive picture of the existing and projected need for housing accommodation of Traveller families within their area for the period 2019 to 2024 to update their assessment of needs of Traveller families within their area.’
‘’For example, local authority officials may attend or arrange public meetings on Traveller issues and arrange broadly based ad-hoc area committees to address problems arising.’’
Clare PPN recommends that statistics on the following issues should be gathered from the Travelling Community and that policies to address the findings included in the draft programme:
- Travellers experiencing over-crowding/forced sharing of accommodation.
- Travellers experiencing homelessness and their experiences of accessing emergency accommodation including bed and breakfasts and hotels.
- Travellers living in culturally inappropriate accommodation due to a lack of provision/poor standard of Traveller Specific Accommodation.
- Travellers living in private rental accommodation which does not meet their needs or has not been inspected.
- Travellers experiences of sourcing private rental accommodation under the current Housing Assistance Payment scheme.
- The projected needs of young Travellers who may be likely to form new families during the life of the plan.
- The particular accommodation needs of Travellers experiencing poor health and of people with disabilities within the Traveller Community.
- The particular and projected needs of ageing Travellers in relation to accommodation.
- Travellers in unofficial roadside accommodation should be surveyed for their preferences. Clare PPN notes that the guidelines for preparing the 5th Traveller Accommodation Programme include the following statement regarding unofficial or roadside sites:
‘Pending the provision of suitable permanent accommodation, local authorities should review the position of Travellers on the roadside or other unauthorised sites in their functional area in the light of the Guidelines on Basic Services and Facilities for Caravans and seek to improve the position of these families by considering making available such services, including water, toilets and waste removal if there are no significant legal, planning, environmental, social, technical or other restraints in so doing. The question of further closures of traditional or unofficial halting sites should also be reviewed pending the provision of adequate accommodation’.
Transient Sites– Following discussions with the Traveller representatives on the LTACC and with other advocacy groups Clare PPN strongly recommends that the provision of transient sites in Clare should be for the purposes of Travellers who are on the road and moving from place to place as is their tradition and that Transient sites should not be used as accommodation for Travellers who are ordinarily resident in County Clare.
Comments on the preparation of the Draft Traveller Accommodation Programme 2019- 2024.
Following the completion of a comprehensive assessment of existing and projected need by Clare County Council which is agreed between all stakeholders, Clare PPN calls on Clare County Council to draft a new Traveller Accommodation Programme that aims to fully meet all the identified needs.
Clare PPN calls on Clare County Council to zone and plan sufficient developments of all forms of Traveller Specific and general accommodation to meet Travellers’ needs and to immediately begin the process of applying for planning permission and funding for their completion. Clare PPN notes that throughout the current TAP Clare County Council had funding available to it specifically for Traveller Accommodation and that it failed to make full use of these funds. Clare PPN has noted the explanation that delays in planning processes are responsible for this repeated underspend and so calls on Clare County Council to ensure that following the completion of its agreed assessment that it should immediately commence the pre- construction processes for any developments planned and seek department funding for same. Clare PPN also calls on Clare County Council to ensure that its currently planned social housing developments do not change the designation of sites currently designated as Traveller Specific Accommodation without indicating how and where these will be replaced and seeking agreement from those affected.
Clare PPN further calls on Clare County Council to indicate in its Traveller Accommodation Programme whether it intends to continue its use of and funding of Approved Housing Bodies to provide social housing and if so how it intends to ensure that these bodies are resourced and required to provide accommodation to the Traveller Community and on what basis. Clare PPN would welcome a clear indication within the Traveller Accommodation Programme of which aspects of the programme it envisages being delivered by Approved Housing Bodies.
Clare PPN looks forward to continuing to engage in this process and welcomes any communications or queries in respect of this submission.
Note to Clare LTACC, following meeting on April 6th2017
Prepared by Fiona Neary, External Facilitator.
Firstly, thank-you to the members of the committee for your invitation to attend and facilitate this meeting. This note is intended as a reflection of key issues as they impressed upon me as an external facilitator.
It is evident that there is both a level of good will and also a level of frustration experienced by all members of the committee. The level of frustration could be gauged as quite high. It is interesting to note that the meeting, scheduled for 1 hour, in fact ran for over 2 hours and 30 minutes. The new Chief Executive, Pat Dowling, expressed the high value he places on this committee, the Councils’ commitment to it, and the opportunities now presented by the detailed audit that has recently commenced, and the uplift in the Irish economy.
Council staff present reported that they experience multiple daily contacts from members of the Traveller community in Co Clare regarding housing needs. The council described the significant level of resources they are investing a new audit of Traveller accommodation.
For Travellers and Traveller representatives on the committee there is a high level of concern for families currently living in roadside dwellings, on an on-going basis, without basic sanitation. Aside from this immediate concern there is frustration at the need for a long-term response to what is perceived as a growing crisis in Traveller accommodation needs. A report outlining the current emergency circumstances in Traveller accommodation in County Clare was circulated to the meeting.
Amongst elected representatives there is frustration that roadside dwellings continue, and high concern for the needs of Traveller children, including continuity of attendance in schools for example. There is a high level of support for workable, long-term solutions amongst the elected representatives on the committee.
It is unlikely that any committee, with such shared levels of various frustrations, can continue without significant disengagement by members, unless some shared success is forth-coming. The LTACC is likely therefore at a cross-roads in terms of its’ on-going sustainability, participation, continuity and role.
Current Issues facing LTACC.
It was very helpful that clarification was provided during the course of the meeting that the new audit by Clare County Council is an Audit of the Maintenance of Existing Traveller Accommodation. It is not an Audit of Current Traveller Housing Needs upon which a plan or strategy to address increasing needs can be based. Implementation of this Maintenance Audit, while of great value, will not go address the increasing Traveller Accommodation requirement in the coming 3 to 5 years and beyond. The new Maintenance Audit is in therefore in keeping with the current Clare County Council Traveller Accommodation Programme 2014 -2018, which summarised housing requirements at that time and then described the maintenance of existing traveller accommodation to be undertaken, but did not include proposals or plans for responding to the significant unmet needs which were identified at that time.
With regards to the roadside dwellings, Clare County Council proposes the construction of two new ‘Transient Sites’. It is not clear if this decision included consultation with Clare LTACC, or Traveller representatives. Traveller representatives present objected to the use of ‘Transient Sites’ for long term needs and proposed 3 -4 permanent sites, with some Traveller input into which occupants were likely to deliver the highest level of success of each permanent site. Traveller representatives gave reasons why Transient sites would not be a successful solution.
The response of Clare County Council to this feedback was unclear. It was also unclear, at this meeting, how Transient sites had been identified as a solution to current unmet needs and, on what basis.
Clare County Council communicated its reluctance to provide sanitation to the existing roadside dwellings. With regards to an eviction pending on one of the roadside dwellings, the council advised that no other options are available to those affected other than that they should approach the general homelessness services.
Role of LTACC Going Forward.
It would appear that the current, and foreseeable role, of the Clare LTACC is to engage in on-going meetings while Clare County Council complete the Audit and Implementation of Maintenance of Existing Traveller Accommodation and the construction of two Transient sites, as these are the main activities of Clare County Council for the foreseeable future. It was unclear if these commitments by Clare County Council involved prior consultation or agreement with the LTAAC.
Options for LTACC:
An option exists however for Clare County Council and the LTACC to take a broader, forward looking role including:
- Jointly agree TOR for a Traveller Housing and Social Needs Assessment
- Undertake the Housing and Social Needs Assessment
- Identify short, medium and longer-term solutions to address increasing Traveller Housing Needs
- Seek and commit the funding required towards achieving implementation of the Needs Assessment.
In the absence of under-taking the option above it is unlikely that Co Clare will experience any change, other than further deterioration in the housing needs of the relatively small number Traveller families in the County. In the absence of taking this option it is likely that the status quo, with the associated frustrations experienced by all LTACC members, and an on-going increasing housing crisis, will continue.
Clare Public Participation Network Statement: Date: 17/10/2017
Clare PPN calls for emergency plan to be put in place for roadside-dwelling Travellers during weather alerts.
Clare Public Participation Network’s Social Inclusion Representatives commend Clare County Council and the county’s emergency services for their swift actions and clear and frequent updates during the status red weather alert which accompanied ex hurricane Ophelia on the 15th of October. It came to the representatives’ attention however that there had been no provisions made to ensure the safety of the members of the Traveller community who live on the roadside in temporary dwellings. People contacting the Council’s emergency number were advised that no plan was in place for roadside dwelling Travellers and that they should ‘stay put’ until the storm abated. Clare PPN calls on the Council management and on elected representatives to ensure that a contingency plan is immediately put in place for any future such weather events which would at a minimum offer temporary secure shelter to all of those who need it. Clare PPN’s Social Inclusion Representatives are concerned that a failure to do this could result in injuries or fatalities which could be prevented by advance planning and so it calls on all those responsible to take action before the winter sets in fully.
Mary O’Donoghue, Local Community Development Committee.
Sarah Clancy, Local Traveller Accommodation Consultative Committee.
Dermot Hayes, Social Development Strategic Policy Committee.
George Atijohn, Clare Public Participation Network Secretariat.
Damon Matthew Wise Âû, Physical Development Strategic Policy Committee.
Details: Enquiries about anything to do with Clare PPN can be directed to firstname.lastname@example.org or 087 1617375.
Clare PPN is a network of community, voluntary, environmental and social inclusion groups from Clare. It exists to facilitate the formal participation by the community sector in Clare County Council’s decision making structures. It is funded jointly by the Department of Community and Rural Development and Clare County Council but is autonomous and its activities are directed by its members through an elected secretariat.
Clare PPN’s website is www.clareppn.ie and they are on twitter @clare_ppn and https://facebook.com/clareppn/
Report from Sarah Clancy Clare PPN’s representative on Clare County Council’s Local Traveller Accommodation Consultative Committee of meeting of September 19th 2017
Chair Mike McKee welcomed Siobhan Mulcahy to the role of representing Clare County Council’s Social Development Directorate on the LTACC. Siobhan took over from Sean Lenihan who has been moved.
Several actions which had been discussed at previous meetings were again discussed here and decisions were made as follows:
Traveller Needs Analysis: It was agreed by the LTACC that Sarah Clancy should investigate how Traveller Needs Analysis for other counties were carried out and at what cost. Following this she will report back via email to the chair and Siobhan Mulcahy and they will see if funding can be allocated or sourced elsewhere for this work to be carried out. The purpose of this project would be to make contact with all Travellers in Clare and to consult them as to their current and future housing needs and preferences and to ensure that all of those who are seeking accommodation from the Local Authority have applied through the correct channels in order to be considered for it and if not that they would be assisted to do so.
Sanitation for Roadside Sites: It was decided that the community, Traveller and Councillor representatives on this committee would once again make a request by letter to the CE of Clare County Council Pat Dowling, that provisions should be made for sanitation, waste disposal and electricity for Travellers currently living in unofficial sites around the county with particular reference to the onset of winter. Cllr Mike McKee is to draft this letter with the assistance of Bernie McDonagh.
It was decided that Sarah Clancy would write to the new traveller led Approved Housing Body CENA and invite them to present to Clare LTACC.
It was noted that due to the current market, relying on the private sector to provide housing for the Traveller community is not feasible or likely to be successful and on that basis it was agreed that a discussion about the possibility of using ethnic identifiers for Travellers applying for housing and the possibility of investigating whether a ‘positive discrimination’ approach where approved housing bodies working with Clare County Council could be requested/required and funded to provide Traveller specific or quotas for Travellers should take place at the next meeting.
The next meeting was scheduled for November 7th.
Submission to Rebuilding Ireland from Clare Public Participation Network:
August 10th 2017
Clare Public Participation Network wishes to make the following submissions to this review of Rebuilding Ireland:
- Clare PPN wishes in this submission to highlight and draw attention to the fact that a housing crisis exists in rural and regional areas and is not restricted to Ireland’s cities. Whilst the crisis may differ from region to region County Clare is experiencing an extreme shortage of all types of rental accommodation, an increase in homelessness, prevalent over- crowding as well as rural depopulation. There are more than 6000 houses vacant in the county and housing waiting lists stand at approximately 2500 households which when children are figured in means that more than 4,000 people are currently waiting for housing.
- Clare PPN calls for a renewed effort in ensuring accuracy and transparency in reporting of figures: Clare PPN notes the tendency of reports issued from the Department of Housing, Planning and Local Government to minimise the extent of the crisis and to maximise the figures in terms of improvements made. Clare PPN considers it of the utmost importance to proper budgeting and policy making that accurate inclusive figures should be maintained and published. We have noted that the following groups who all experience housing need and homelessness are frequently omitted from official figures:
- People living in the direct provision system who have received leave to remain in Ireland but who are unable to leave direct provision because there is no available affordable or supported accommodation for them.
- Travellers who are currently in overcrowded, roadside, or shared accommodation* due to difficulty in accessing social housing/Traveller specific accommodation and housing in the private rental sector.
- People with disabilities who are currently sharing with families, in residential care or living in nursing homes when their choice is to live independently. In Ireland 600,000 people have some form of disability and in County Clare alone there are 217 people on the housing waiting list in this category.
- On a national level, Clare PPN wishes to add its voice to that of the many other organisations who are calling for an end to the over-reliance on the private rental sector in addressing housing need in Ireland. Clare PPN notes and supports in particular the contribution to the debate made by TASC and the Nevin Institute, both of whom call for a significant change of direction in Irish housing policy and envisage a special purpose company set up by the government to build, purchase and maintain a large stock of state-owned housing which will be available on a cost rental model for long term rental to tenants of all income levels in Ireland. Even in the absence of a shift of direction in policy as described above Clare PPN wishes to stress that there is an urgent need for national and local authorities to invest in directly building or purchasing social housing for the long term secure use of those who cannot access the private rental sector or face barriers doing so. It should also be noted that figures recently released demonstrate that there are over 1200 properties vacant in Ennis where demand for social housing stands at approximately 1100 households. On this basis for sustainable town development it is clear that more emphasis must be placed on all programmes which will bring these properties back into use up to and including compulsory leasing and purchasing. Apart from the poor use of space, dereliction and urban blight which a concentration of empty properties causes in a town, the turnaround for getting such properties renovated and fit for use is in general much faster than bringing new developments from planning to completion.
- Clare PPN regards the following as essential to ensure that housing policy in Ireland in general and the Rebuilding Ireland programme specifically are effective for all groups who make up our diverse communities.
- The need for housing lists to be divided between those with a long term housing need and those with a short term need. People who qualify for housing assistance should be able to select which list they wish to belong to.
- There is an urgent need for a review of the effectiveness or otherwise of the Housing Assistance Payment particularly with regard to people with long term social housing needs. People identified with long term housing need should not be removed from Housing waiting lists even when they are in receipt of HAP. There is also a need for a review in each county and its urban areas as regards the availability of rental accommodation within HAP limits. In Clare, whilst there is housing for sale, there is a shortage of appropriate rental accommodation in almost all areas within the limits of the HAP scheme. This exposes people to greater risks of becoming homeless and of accepting substandard accommodation. Whilst HAP figures can indicate that people have accommodation, they do not provide any guarantee as to the quality or suitability of that accommodation.
- In Clare where Clare PPN is active there is no targeted scheme that addresses the difficulties that members of the Traveller Community face when accessing private rental accommodation even when they are approved for a Housing Assistance Payment. Attention to this issue is urgently needed at a national level, with there being obvious justification and need for an intervention designed through consultation with the Traveller community which obliges, finances and monitors local authorities, approved housing bodies, or private developers to provide appropriate accommodation for Travellers.
- Local Authorities should be held to account as regards their application for and draw down of the funding available for Traveller Accommodation. Local Authorities should jointly conduct an annual Traveller needs and future needs analysis with the Travelling community in each county. The results of this needs analysis should be agreed on by all parties and the Traveller Accommodation Plan should be developed on the basis of it. A realistic budget should be adopted for Traveller accommodation nationally and for each county’s Traveller Accommodation Plan. The Travelling community should be resourced to participate fully in all decisions which concern them and all Local Authority staff who engage with Travellers should be given training on diversity and on the particular challenges that face the Traveller Community. The Trespass Act should be repealed and where members of the Travelling Community who are on the Housing waiting list are dwelling in unofficial sites and the Local Authority has no other suitable accommodation available for them then the Local Authorities should be directed to provide emergency sanitation, waste disposal services and electricity to them for a reasonable fee within the means of the families in question. Local Authorities should be resourced and directed to conduct all of the above.
- Local Authorities should be required to make provision and account for the needs of people becoming homeless through situations of domestic violence. Local Authorities should be asked annually to demonstrate what steps they have taken to ensure that people in such circumstances are catered for.
- National Government needs to make provision for people in Direct Provision who have been granted leave to remain or refugee status but cannot secure accommodation in order to enable them to leave the direct provision centres. It should be noted that many of these people have become impoverished whilst in the asylum application process as a result of the Irish Government’s policies. Clare PPN calls for full social welfare payments to be made available immediately to every person who has been granted leave to remain. As part of its submission to this review of Rebuilding Ireland Clare PPN calls for a complete end to the system of Direct Provision as it fails to meet the housing needs of those in the asylum system. Clare PPN notes that in particular it fails to meet the basic needs of children.
- Clare PPN calls for the continued and increased provision of housing for people with disabilities and the need to include people with disabilities who are currently unable to secure their own independent accommodation in all planning processes and consultations.
Any enquiries regarding this submission may be directed to:
Public Participation Network Coordinator
Unit 1 Westgate Business Park
Phone: 087 1617375
Email: email@example.com Website: www.clareppn.ie Twitter: @clare_ppn Facebook: www.facebook.com/clareppn/
Reports from all representatives will be here.