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.