Mr. Eugene Cummins:

On behalf of the CCMA, I thank the committee for its invitation. I look forward to assisting the committee in its deliberations on the review of Traveller accommodation by the expert group. The CCMA welcomes the reference to the implementation of the recommendations of the expert review group in Housing for All and recognises that Traveller accommodation is a priority that needs to be addressed. Local authorities are governed by the Housing (Traveller Accommodation) Act 1998 and have general responsibility for the provision of housing for adults who cannot afford to provide it for themselves, including the provision of Traveller accommodation at local level. This is done through the adoption and implementation of five-year Traveller accommodation programmes, TAPs. Each November, local authorities undertake an annual estimate of accommodation of Travellers, which assists in drawing up the TAPs. The Traveller accommodation expert review group was established in 2018 to review the Traveller Accommodation Act 1998 and other legislation that impacts on the provision and delivery of accommodation for Travellers. In advance of the finalisation of the report, the CCMA met and discussed the role of local government with the expert group. The report, which was published in July 2019, has 32 recommendations that can be broken down into four categories: delivery reflecting need; planning; capacity; and funding governance.

The CCMA broadly welcomes the report and is represented on the programme board established to drive the delivery of the recommendations of the report. The programme board has met a number of times since its establishment and has agreed a work programme for this year. The CCMA is committed to ensuring that these recommendations are prioritised and, through the programme board, will drive the priority projects currently being advanced regarding the CSO data, which is very important. The CCMA welcomes the current engagement by the Department of Housing, Local Government and Housing and the CSO in providing better representation of the Traveller community from census 2022. While this will inform policy, consideration will need to be given to research that has been carried out by other groups locally and nationally. The CCMA further agrees that a nationwide survey of Traveller demographics is important and that this could be performed by local authority staff in addition to, or in place of, the annual count. The CCMA believes that local authorities are best placed to provide this information, given their local knowledge of Traveller families, which enables more accurate reporting than could be provided by an independent body.

In terms of the Traveller identifier, the CCMA welcomes and supports the recommendation to formally record ethnicity on housing applications going forward. This will help to identify the housing needs of Travellers and assist local authorities to collate data on waiting lists relating to housing support and the types of accommodation sought. It should be noted that local authorities are currently only detailing information on social housing tenants and social housing applicants where ethnicity has been declared by them, as being members of the Traveller community. It should be highlighted that it is incumbent on the applicant, if he or she wants, to identify himself or herself as a Traveller. In the absence of any such declaration, local authorities are not classifying any person as being a member of the Traveller community. The CCMA believes that in order to implement an ethnic identifier,a whole-of-government approach is required as this complex issue stretches across many strategies and Departments.

Regarding the funding allocation scheme, the removal of the allocation of specific budgets to individual local authorities is a welcome development. This has enabled local authorities to apply for and draw down funds at any time during the year.

On the management and maintenance of Traveller-specific accommodation, the 50% increase in funding announced by the Minister of State, Deputy Peter Burke, for the management and maintenance of Traveller-specific accommodation earlier this year was welcomed by the CCMA. This allows local authorities to better utilise funding. It should be noted that, increasingly, greater expenditure from the maintenance budgets is being used to clean up increased levels of dumping on all sites. The CCMA does not agree with the recommendation that the role of the caretaker for Traveller-specific accommodation needs to be reviewed. The CCMA firmly believes that the role of the caretaker and estate manager should be kept separate, as they are two very distinct roles with a potential conflict of interest. The estate manager role is currently complex and will not benefit from further responsibilities.

The CCMA endorses the research on good practice on the design of Traveller-specific accommodation, including planning, design, management and maintenance of halting sites, as it will inform local authorities on future societal changes. The CCMA has already engaged with the Department on the design of Traveller-specific accommodation and looks forward to updated guidance for both local authorities and approved housing bodies, AHBs, in the design of Traveller-specific accommodation.

The all-Ireland approach to transient sites is broadly welcomed. The CCMA would highlight that the current legislation was implemented to curb the unlawful occupation of publicly owned lands. The CCMA wishes to highlight that the legislation is there to protect the rights of all and repealing it is an imposition on the rights of the entire community. It should be noted that our priority is to provide suitable permanent accommodation in the first instance.

The recommendation to report on the delivery of new Traveller-specific accommodation as part of the progress reporting under Housing for All is welcomed. In terms of the local authority role, the CCMA fully supports the progression of the projects as identified in the work programme for 2021 and is actively engaged with the NTACC and the various stakeholders. I will take this opportunity to provide some clarification from a local government perspective on some other areas identified in the report.

Local authorities provide a range of accommodation options to the Traveller community, including Traveller-specific accommodation. Accommodation is provided by local authorities through a range of options, such as standard local authority or approved housing body housing, group housing and halting sites. Accommodation is provided through subsidisation via the housing assistance payment and the rental accommodation scheme.

The option to transfer from Traveller-specific accommodation to standard housing, inclusive of private rental properties, is available to Travellers. Travellers can apply on both the standard housing list and Traveller-specific accommodation list, availing of whichever offer comes first. They, as is the case for all applicants on the standard housing list, can then choose up to three geographical areas of preference. Tenants can specify this preference, and this would be known, recorded and monitored by the social work team. They would also make such recommendations to the relevant officer, should accommodation become available. The CCMA notes with concern that the report fails to acknowledge that the demand for Traveller-specific accommodation is diminishing, especially among the younger generations, whose preference is not to live in halting site accommodation and who are increasingly seeking standard housing and group schemes.

A number of challenges arise from the reports. Where Traveller-specific accommodation is proposed, a significant amount of consultation with Traveller families and local communities is required to build trust, design the best housing solutions and create favourable conditions to facilitate the planning process. Such projects take additional time and significant resources. These projects are not suitable for external design teams as good communications need to be established and maintained in order to build confidence and trust with the Traveller families and the local communities. This is a complex area that requires significant collaboration with all stakeholders. It is not just a housing issue. The CCMA believes the recommendations around Part 8 proposals could lead to serious issues locally for local authorities which must engage openly and transparently with communities. The CCMA recommends that expert legal advice be sought for the benefit and protection of all stakeholders in this matter.

The recommendation that chief executives use emergency powers to bypass elected members could be viewed as undermining the planning and democratic process, which underpins all aspects of local and central government policy. This is an area that warrants legal opinion and careful consideration, especially in light of the potential for judicial review proceedings.

While there are some interesting proposals in the report, the CCMA wishes to highlight that some of the key reasons the delivery of Traveller accommodation is problematic do not seem to be fully considered. It is important to consider the potential reasons behind objections to the development of Traveller accommodation. Traveller accommodation sites tend to be associated with increased levels of crime, violence, anti-social behaviour, illegal dumping and burning, as well as with social issues such as addiction and early school leaving. These issues need to be tackled alongside the housing issues. It should be noted as well that compatibility in the allocation of accommodation to Traveller families brings additional complexity. The CCMA welcomes a collaborative approach with all the relevant stakeholders to overcome some of these obstacles.

It should be highlighted that while complying with Government policy, the practical approach taken by each local authority on the delivery of Traveller-specific accommodation varies. This variance is necessary to reflect local circumstances and, from experience, stems from a desire to look proactively after the housing support needs of Traveller families, many of whom have vulnerabilities.

The CCMA recognises the need for greater co-ordination among State service providers such as the HSE. Providing more and improved Traveller-specific accommodation is also a priority locally and nationally. The CCMA welcomes the continuation of the collaborative approach by all stakeholders in recent months. The CCMA is working with the Department on the development of the caravan loan scheme, which is being piloted in four local authorities. We welcome the report of the independent review of the role of social workers. There is a need for a more sustainable funding model for the retention and expansion of the social work service. There is also a need to reflect the wider role of the social worker within the housing department and across the local authority in general. The CCMA continues to work with the national Traveller accommodation consultative committee to help drive the expert review group recommendations. The CCMA will endeavour to work with the programme board to progress actions through ongoing engagement with the CCMA housing, building and land use committee.