Mr. Wayne Stanley:

Yes, we will split the time. I thank the committee for its time and for the opportunity to present on behalf of both the Simon Communities of Ireland and Focus Ireland. Given the shortage of time, I will make three points. I think there will be a lot of repetition in this room today because they are the three critical points.

First, the provisions, as set out, borrow from social protection legislation. There are so many differences between the administration of social protection and the administration of housing that there is a need for bespoke legislation if this legislation is to go forward. A consultation process by the Department is absolutely warranted too in developing this legislation.

Second, a stated aim of the proposed legislation is to establish consistency in how State entities access social entitlements. The lack of statutory provisions regarding decision-making and the appeals process within the heads of the housing Bill stand in contrast with such provisions outlined in the Social Welfare Consolidation Act, again reinforcing the need for bespoke legislation.

Finally, we need to emphasise that there is an experience of local authorities requiring eligibility to social housing to secure access to emergency accommodation for which there is no legal basis. We strongly submit to the committee that, at a minimum, there is a need to explicitly set out in the primary legislation that the habitual residency condition for the purposes of social housing does not and should not affect an individual's or a household's eligibility for access to emergency accommodation.