Ms Rose Wall:

I will echo some of the sentiments of my colleagues. Mr. Allen expressed the view that we need to be clear about which problem we are trying to fix before we come up with solutions. Let us define what the problem is and then let us then look for a solution. That is an important first step. A second step, as everybody has mentioned, is the need for a full and thorough consultation with those who work with the communities most impacted by the proposals. Once we get through that process, there are all the concerns we have raised, including compatibility with EU law. A thorough assessment is required to determine if the proposals are compatible with EU and other international and national law. Who is going to make the decision on the HRC? What is the appeals mechanism going to be? Are we sure the appeals mechanism is going to be compatible with natural and constitutional justice?

There is a lack of clarity as things stand as to whether the proposals are part of an overall eligibility assessment or are a precursor to an eligibility assessment, and that needs to be clarified. If it is the latter, we certainly need a more thorough and robust analysis.

The issue of household members who do not fulfil the residence requirement and how that impacts the household's ability to apply needs to be clarified. As has been said, we already know of the risk on the ground in terms of the conflation of eligibility for emergency accommodation with eligibility for social housing. We need to ensure it is clear that any requirements for social housing eligibility do not apply to emergency accommodation eligibility as they are two different systems.