Mr. Pat Dennigan:

I thank the committee for the opportunity to address it. There will be a lot of repetition, as Mr. Stanley mentioned. Focus Ireland and the Simon Communities of Ireland welcome the opportunity to contribute to the committee's pre-legislative scrutiny of this legislation, which we believe would have really harmful consequences. The proposed legislation is presented as merely bringing housing legislation into line with the existing welfare legislation and being therefore of no great consequence. However, the welfare and housing systems operate in very different ways, and introducing this approach to housing could do far-reaching harm. If enacted as proposed, it would result in many more people being denied shelter and so forced to sleep rough.

There are four main reasons for this conclusion. Unlike the social welfare system, the housing system has no effective appeals mechanism and the decisions of housing officials are effectively final. Second, the lack of accountability is particularly problematic because habitual residence is a legally complex area where local authority officials currently do not have expertise.

Under the proposed legislation, rather than deciding eligibility on the basis of an assessment, an official may decline to make any assessment at all. These proposals link directly to rough sleeping because local authorities regularly decide not to offer individuals and families emergency shelter on the basis that they are not eligible for social housing. This legislation does not deal with any of the really pressing issues. Whether intentionally or otherwise, this proposed legislation would result more vulnerable people having to sleep rough. In addition to ill-health and risk of death, this would have serious detrimental consequences for our towns and cities and deepen social divisions.

Our full submission proposes amendments to ameliorate these harmful consequences and I direct the committee to that.