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TRAVELLER ACCOMMODATION PROGRAMME 2005 – 2008

INTRODUCTION

Mayo County Council has over the past number of years together with the Town Councils of Ballina, Castlebar and Westport expended considerable energy and resources on the provision of Traveller specific accommodation. At the time of the making of the first draft of the Traveller Accommodation Programme 2005 – 2008 a total of one hundred and eleven families are accommodated throughout the county. Over the period of the last Traveller Accommodation Programme 2000 – 2004 a total of forty eight units of accommodation were provided in County Mayo for Traveller families. A further twelve units of accommodation will come on stream in the near future.

There are however significant challenges still to be dealt with. A total of forty three families awaiting accommodation on the roadside, together with the demands which will be created by additional family formations up to the year 2008 constitute a considerable challenge for everyone involved. The Traveller Accommodation Programme 2005 – 2008 outlines the targets and strategies which will be necessary for all of us to respond to this challenge.

_______________________________________________________________________________________________________Traveller Accommodation Programme (2005 - 2008) As Adopted 11th April, 2005

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(01.) BACKGROUND / CONTEXT

The Housing (Traveller Accommodation) Act 1998 amends and extends the existing Housing Acts and places a statutory obligation on Mayo County Council in relation to, inter alia, the following;

To provide and adopt a four-year programme, subject to periodic review, for the provision of Traveller Accommodation in the county.

To provide for a public notification and consultation process in respect of the preparation of the Traveller Accommodation Programme, including an opportunity to comment on draft programmes.

To take reasonable steps to secure the implementation of the Traveller Accommodation Programme in the county.

To provide for the establishment of a Local Traveller Accommodation Consultative Committee to facilitate consultation with Travellers about the preparation and implementation of the Traveller Accommodation Programme.

Section 7 of the Act requires each relevant housing authority to adopt the Traveller Accommodation Programme by a date specified by the Minister for the Environment, Heritage and Local Government. The Minister has specified the 30th April 2005 as the date by which the Traveller Accommodation Programme 2005 – 2008 must be adopted.

Section 10 of the Act specifies that an Accommodation Programme be made in respect of a five year time period as was Mayo County Council’s previous Traveller Accommodation Programme 2000 – 2004. Provision has also been included in this section however that the plan be prepared in respect of a shorter period as the Minister may direct. The Minister has directed that this Programme be for a four year period 2005 – 2008.

To progress the implementation of the Programme, the Council in accordance with the Housing (Traveller Accommodation) Act 1992 has established a Traveller Accommodation Consultative Committee, which was duly set up in November 2004. The Committee includes representatives from the Traveller community, Local Elected Representatives and officials of Mayo County Council. The membership of the Committee is given at Appendix 2 and it should be noted that provision is included for alternates.

On the basis of the Assessment of need and projections on population increase for the period 2005 – 2008, a Traveller Accommodation Programme has been formulated to meet the Council’s statutory requirements. Notice of the formulation of the Draft Accommodation Programme was advertised in the local papers. The Draft Programme was also be circulated to the Local Traveller Accommodation Consultative Committee, any adjoining housing authority, members of Mayo County


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Council, the Health Services Executive - Western Region and any other relevant bodies with an interest in Traveller Accommodation issues.


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POLICY

General Policy

It is the Policy of Mayo County Council to provide for the accommodation needs of Travellers as far as is reasonable and feasible using the full range of housing options available to the Council. In the provision of accommodation, priority will be given to members of the Traveller community who were born in Mayo and who have lived in the county continuously, or who, having returned to the county have lived here for a period of one year or who having moved into the county have lived for a period of not less than three years.

Corporate Objectives

Corporate Plan - 2005 – 2009

In Mayo County Council’s Corporate Plan 2005 – 2009 advancing the implementation of the provisions contained in the Traveller Accommodation Programme is listed as a Corporate Strategy. This Strategy is included to ensure the delivery of a Corporate Objective, which is “to ensure that every Mayo family can live in a dwelling of good standard, located in an acceptable environment at a price or rent they can afford.”

County Development Strategy - 2003 - 2013

Addressing the Accommodation needs of Travellers is listed as a Strategic Action in Mayo County Development Board’s ten year Integrated Strategy for the Economic, Social and Cultural development of the county. One of the key Operational Actions listed to achieve this is to review and deliver the Local Authority Traveller Accommodation Programme.

County Development Plan – 2003 – 2009

Under current legal provisions the Traveller Accommodation Programme 2000 – 2004 automatically became part of the County Development Plan 2003 – 2009. The Development Plan states that it is an objective of the Council to provide Traveller accommodation in accordance with the Traveller Accommodation Programme and any subsequent reviews. This therefore includes provision for the Traveller Accommodation Programme 2005 – 2008 to replace the previous Traveller Accommodation Programme 2000 - 2004.

PolicyThe Council’s Policy in relation to the following matters is;-

HousingThe Council recognises and will have regard to the distinct cultural identity of Travellers in the provision, maintenance and management of accommodation for the Traveller community.

Accommodation in Social Housing will be allocated transparently and equitably on the basis of need and in accordance with the Council’s _______________________________________________________________________________________________________Traveller Accommodation Programme (2005 - 2008) As Adopted 11th April, 2005

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scheme of Letting Priorities. The Council will have regard to the specific housing needs of Travellers in the design of Social Housing Schemes.

In order to meet the housing needs of Travellers identified in the Programme, a minimum of one in eight houses in new Social Housing Schemes over eleven units in size, and one in five units in new Social Housing Schemes of up to ten units will be allocated to Traveller families in areas where the need exists.Casual vacancies in Social Housing will be allocated on the basis of the Council’s Scheme of Letting Priorities.

The programme will also provide social housing for Traveller families through:

o Group Schemes specifically developed for Traveller familieso Shared Ownership loans o Once-off housingo Social houses provided through the Voluntary Housing Programmes.

The Council will also actively encourage and facilitate Travellers who wish to avail of privately funded accommodation through Affordable Housing and Shared Ownership Programme. The Council will similarly promote the provision of housing for Travellers by voluntary Housing groups where appropriate.

New families forming within the county will be expected to make reasonable efforts to secure accommodation from within their own resources.

Families returning to live in the county will also be expected to make reasonable effort to secure accommodation.

Refusal of Housing Offers

It is the policy of Mayo County Council to set a limit regarding the offering of local authority accommodation following refusals. Mayo County Council propose to allow two refusals of offers of accommodation, following which the needs of other applicants on the waiting list will be accorded higher priority.

Transient Accommodation

To satisfy the requirements of the legislation, two transient sites are required and will be developed, one for East Mayo and one for West Mayo. It is envisaged that these sites will satisfy the requirement to accommodate transient Travellers in any location of the county. Provision of these sites will enable enforcement of court orders to deal with illegal occupation.

Halting Sites

Based on a survey carried out in May 2002 the expressed preference of the vast majority of Travellers is for accommodation in standard housing. This finding was confirmed by a further survey in March, 2005. It is the policy of Mayo County Council that their needs be met through the provision of standard housing, from the full range of sources as follows:_______________________________________________________________________________________________________Traveller Accommodation Programme (2005 - 2008) As Adopted 11th April, 2005

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o Housing provided as part of the council’s Social Housing Programmeo Group Schemes specifically for Traveller familieso Once-off housing o Shared Ownership loanso Social houses provided through the Voluntary Housing Programmes.

In the event that the projected need for any area of the County Council cannot be met by conventional housing from these sources, serviced Halting Sites will be provided.

(03.) ASSESSMENT OF NEED

Section 6 of the Housing Act requires that Mayo County Council, make an estimate of the number of Traveller families and households for whom accommodation will be required within the functional area for the four year period 2005 – 2008.

Current Need (Appendix 3)

An assessment of current need was undertaken. The assessment identified the following:

- Travellers currently accommodated by the four housing authorities; ie Mayo County Council, Ballina Town Council, Castlebar Town Council and Westport Town Council.

- The number of Traveller families currently on the roadside in Mayo.

- The number of Travellers currently renting private accommodation in Mayo.

Projected Need (Appendix 4)

An assessment of projected need was also undertaken. It should be noted that the assessment of Traveller numbers for the period 2005 – 2008 is an estimate based on current Traveller numbers, which will be reviewed annually. This assessment identified:

The need arising from the projected growth in the Traveller population over the period of the Programme. The projected need of returning families for the period 2005 – 2008.

Existing Traveller Families Accommodated

A total of one hundred and eleven families are presently accommodated in Council houses/halting sites throughout the county. The breakdown of the numbers for each area is attached in Appendix 2.

Traveller Families on the Roadside and Privately Renting

The number of Traveller families awaiting local authority accommodation at November 2004 is sixty three. This figure is subject to change but can be relied upon as an indicative figure for actual need at present. The breakdown of this figure is given in Appendix 3.

Additional Projected Accommodation_______________________________________________________________________________________________________Traveller Accommodation Programme (2005 - 2008) As Adopted 11th April, 2005

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A survey of the Traveller families in accommodation and on the roadside is used to predict the estimated number of families which will be seeking housing from the Council up to the end of the year 2008. The additional need is estimated at fifty-five and a breakdown is given in Appendix 4.

Total Requirement 2005 – 2008

With the existing need and projected need, plus those in halting sites having been established, the total need for the next four years is estimated at one hundred and eighteen units of accommodation.The breakdown of this figure is given in Appendix 5.

Temporary Serviced Sites

In addition to the obligation to provide units of accommodation for one hundred and eighteen families over the next four years the Council are required to establish the need for temporary serviced sites in areas where Travellers are allocated houses or are awaiting same and to provide serviced sites for the four year period.

It should be noted that it is the intention that the centres indicated in the assessment of need also include villages around the centre mentioned. It may be possible therefore to accommodate families within a reasonable distance of these centres.


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(04.) IMPLEMENTATION STRATEGY

Implementing Authorities

Mayo County Council is the body responsible for the implementation of the proposals contained in this Programme. It is the intention of Mayo County Council to co-ordinate efforts with the Town Councils of Ballina, Castlebar and Westport and to ensure the success of the Programme for the statutory period. To ensure effective delivery of the Programme we envisage a comprehensive partnership approach to involve all of the agencies which have a role to play in the areas of Traveller Accommodation, Education, Health and Welfare, including;

Local Traveller Accommodation Consultative Committee Mayo County Development Board Western Health Board Mayo Traveller Support Group Voluntary Housing Bodies

- Sonas- Respond!- Cluid- Local Voluntary Housing Associations

An Garda Siochana Local Community Groups Residents Associations.

Mayo County Council will work in co-operation with the above listed groups to secure the implementation of the Traveller Accommodation Programme. A consultation forum will be put in place to give all relevant bodies an opportunity to discuss issues and concerns regarding Traveller Accommodation.

Programme Delivery

- It is the intention of Mayo County Council to communicate the requirements of the Programme and to co-ordinate efforts with the Town Councils of Ballina, Castlebar and Westport to ensure the success of the plan for the statutory period.

- The Council will similarly promote the housing of Travellers by voluntary groups where appropriate.

- The projected cost of implementing the Programme is of the order of €20m. The success of the Programme will be dependent on the availability of appropriate resources throughout the course of the Programme.

- It is proposed that there will be an annual review of progress on the implementation of the Programme in addition to the statutory requirement for a three year review.

- It is proposed that a local monitoring committee be established in all Town Council areas in order to;


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o assist and liase with local communities to solve problems if they arise

o review the implementation and progress of the plan as it impacts on the community, in addition to statutory review over three years.

- The local monitoring committee will be made up of representatives from

o County and Town Councilo Traveller representativeso Chamber of Commerce representativeso Resident Association representativeso Garda Siochana.

Communication

In accordance with the requirements of the legislation and with directives issued by the Minister for the Environment, Heritage and Local Government, notice of the carrying out of the assessment of need and of the intention to prepare the draft Accommodation Programme was given to the following bodies:

Members of Mayo County Council Housing SPC Town Councils of Ballina, Castlebar and Westport Local Traveller Accommodation Consultative Committee Western Health Board Voluntary Housing Groups Adjoining Local Authorities Community and Enterprise Department

In addition public comment was invited by advertisements in the local press.

By the relevant date a total of four submissions were received from –

Mayo Traveller Support Group Irish Traveller Movement Annette Irving, Public Health Nurse, Traveller Health Mayo Mary Syron, Chairperson, Traveller Health Unit.

The content of these submissions has been considered and incorporated into the Draft Accommodation Programme 2005 – 2008.


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(05.) MANAGEMENT AND MAINTENANCE OF ACCOMMODATION

Policy

The Council will encourage and facilitate the participation of Travellers in the management and maintenance of Traveller specific Accommodation. The Council will have regard to models of good practice in the maintenance and management of Traveller accommodation to inform this initiative.

Anti-Social Behaviour

Anti-Social Behaviour is defined in Section 1 of the Housing (Miscellaneous Provisions) Act, 1997, as follows -:

(a ) the manufacture, production, preparation, importation, exportation, sale, supply, possession for the purposes of sale or supply, or distribution of a controlled drug (within the meaning of the Misuse of Drugs Acts, 1977 and 1984),(b ) any behaviour which causes or is likely to cause any significant or persistent danger, injury, damage, loss or fear to any person living, working or otherwise lawfully in or in the vicinity of a house provided by a housing authority under the Housing Acts, 1966 to 1997, or a housing estate in which the house is situated and, without prejudice to the foregoing, includes violence, threats, intimidation, coercion, harassment or serious obstruction of any person;

Under no circumstances will Mayo County Council, or Ballina, Castlebar and Westport Town Councils tolerate anti-social behaviour in any of the housing accommodation for which they have responsibility. Where instances of this occur, appropriate action will be taken to remove those tenants who engage in such anti-social activity. A tenant who is evicted from Council accommodation due to anti-social behaviour will be deemed to have rendered himself or herself ‘Homeless’. Applicants on Mayo County Council’s Housing lists who have previously engaged in anti-social behaviour will render themselves ineligible for local authority housing.

Mechanisms for Monitoring and Implementation

It is proposed that there will be an annual review of progress on the implementation of the Programme, in addition to the statutory requirement for a review within each three year period. The Mayo County Council Local Consultative Committee will oversee the monitoring of the implementation of the Programme on Traveller Accommodation.


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(06.) CONCLUSIONS AND RECOMMENDATIONS

The estimated number of units required for the period 2005 – 2008 has been established at one hundred and eighteen.

It has been established by the Council that –

The current and projected need will arise in the areas outlined in the report over the course of the programme 2005 – 2008.

It is the expressed preference of the majority of the Traveller Community that their housing needs be met by way of standard or group housing where practicable.

If the full compliment of houses cannot be provided by way of allocation on social housing scheme, specifically designed group housing, single houses or voluntary or affordable scheme, then permanent residential caravan parks will be provided in any location in the county where this established need prevails.

In order to meet the targets in this Programme, it will be Mayo County Council’s policy to encourage take-up of accommodation throughout the county. In the interest of balance and sustainability it is the intent of this Plan that all areas of the county will be available for Traveller Accommodation.


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Appendix 1Membership of Local Traveller Accommodation Consultative

Committee

Cllr. John CribbenCllr. Henry KennyCllr. Pat McHughCllr. Jarlath MunnellyCllr. Paddy McGuinnessCllr. Johnnie O MalleyCllr. Frank ChambersCllr. Cyril BurkeCllr. Tim Quinn

Peter Hynes, D/S – Housing West RegionSeamus Granahan, D/S – North East Region*Ray Norton, D/S – South West Region*John Coll, Director of Community and Enterprise*Patsy McNulty, Traveller Accommodation OfficerOrla Hughes, Social WorkerBernie Rowland, Social Worker

Patrick Conroy1 Martin McDonagh2 Bernadette CumiskeyMarie AllenRosemarie MaughanSandra Judge, Mayo Traveller Support Group3

1* Or Nominee1. Nominated Alternate……(Bridget Maughan)22. Nominated Alternate……(Mary Margaret McDonagh)33. Nominated Alternate……(Louise O’Malley)


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Appendix 2Families Currently in Local Authority Houses

Electoral Area Location Numbers (Families)

BallinaBallina 41

BallinrobeBallinrobe 21

CastlebarCastlebar 20Balla 1Ballyvary 1

ClaremorrisClaremorris 3Ballyhaunis 12Ballindine 1

SwinfordSwinford 3Charlestown 2Foxford 1

WestportWestport 2

TOTAL 108


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Appendix 3Families on Roadside and Privately Renting

Electoral Area

Location Type of Accommodation Numbers (Families)Roadside Halting

SitePrivate rented

BallinaBallina 4 9 13

BallinrobeBallinrobe 6 2 8

CastlebarCastlebar 13 3 6 22Balla 0 0 0Ballyvary 0 0 0

ClaremorrisClaremorris 4 0 4Ballyhaunis 6 0 6Ballindine 0 0 0

SwinfordSwinford 1 0 1Charlestown 7 0 7Foxford 0 0 0

WestportWestport 2 0 2

TOTAL 43 3 17 63


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Appendix 4Projected Additional need to 2008

Electoral Area

Location Away4 Projected Need5

Total

BallinaBallina 4 10 14

BallinrobeBallinrobe 3 5 8

CastlebarCastlebar 5 8 13Balla 0 0 0Ballyvary 0 0 0

ClaremorrisClaremorris 2 1 3Ballyhaunis 4 3 7Ballindine 1 1 2

SwinfordSwinford 2 1 3Charlestown 1 2 3Foxford 0 0 0

WestportWestport 0 2 2

TOTAL 22 33 55

4 Families Away – Based on an examination of Traveller families who have connections to County Mayo. Also with a predictaion for levels of return based on experience from the Traveller Acommodation Programme 2000 – 2004. 5 Projected Need – Based on 4% incease, as suggested in the Government Task Force Report on the Travelling Community in 1995._______________________________________________________________________________________________________Traveller Accommodation Programme (2005 - 2008) As Adopted 11th April, 2005

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Appendix 5Total Requirement 2005 – 2008

Electoral Area Location TotalOver

Plan PeriodBallina

Ballina 27Ballinrobe

Ballinrobe 16Castlebar

Castlebar 35Balla 0Ballyvary 0

ClaremorrisClaremorris 7Ballyhaunis 13Ballindine 2

SwinfordSwinford 4Charlestown 10Foxford 0

WestportWestport 4

TOTAL 118


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Appendix 5aAnnual Targets, by Electoral Area

Electoral Area Total Annual Target

Ballina 27 6-7Ballinrobe 16 4Belmullet 0Castlebar 35 8-9Claremorris 22 5-6Swinford 14 3-4Westport 4 1TOTAL: 118 29 - 30

Note 1:

In the delivery of units of accommodation at local level, consultation will be entered into with the families. Due regard will be had to their housing need and expressed preference of accommodation type, in as far as is practicable.

Note 2:

In order for the Traveller Accommodation Plan 2005 – 2008 to be effective it must be capable of ongoing modification and improvement over the period of the Plan. It is proposed that there would be an annual review of progress and a re-assessment of need which will be carried out at the same time as the Annual Count of Traveller Families in November each year. This will update the need as of 1st December in each year, and will set revised targets for accommodation provisions for the remaining years of the Plan, if appropriate.


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Appendix 6

Submissions Received and considered in formulating the Draft Traveller Accommodation Plan

2005 – 2008(Pre-Public Display)

1. Mary Syron, Chairperson, Traveller Health Unit, Western Health Board

Recommendations Traveller Families are consulted with re the planning and design

of their accommodation. Their particular needs as a family are taken into consideration. The resulting accommodation provided is in line with the current

best practice building regulations. Where considered appropriate work in partnership with the

Western Health Board staff to address relevant issues e.g. support and training for families moving to houses for the first time as provided by our Home Management Services.

A structure is put in place to facilitate ongoing liaison with the Traveller Health Unit as outlined in the National Traveller Health Strategy 2002 – 2005.

2. Annette Irving, Public Health Nurse for Travellers

Recommendations Accommodation Plan would include section on the resourcing and

facilitation of nomadism. Transient halting sites would provide areas that would include good sanitation, running water and safe environments for children.

Provision of further temporary and permanent halting sites. Traveller families are consulted in the planning and design of

their accommodation.


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A system that assesses need of families taking into account health outcomes that has a clear structure and consultative process.

Where problems arise with anti social behaviour and tenure difficulties that the process of conflict resolution and multi agency work be engaged to create a more unified approach.

Adopting a notion of networking organisations, agencies and practitioners to develop skills of collaborative practice.

3. Mayo Traveller Support Group

Recommendations

Respecting and Resourcing Traveller Culture Plan should include sections on how to resource and facilitate

nomadism, the Traveller economy, keeping of horses and caravans, Traveller extended family structures, Traveller norms.

MTSG suggest a study should be undertaken around patterns of nomadism and this study could be developed into a network of nomad friendly transient accommodation.

Assessment of Need The local authority should initiate a process of informed

assessment of preference and need taking into account that not all Travellers want housing. In some instances alternative forms of accommodation should be explored.

Allocation of Accommodation Accommodation should be allocated on the basis of need, not

identity. A points system of allocating houses should be adopted, not just

Traveller specific but for all those on the housing list.


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Training A section should be included in the Plan on provision of training

on Traveller issues for the LTACC and all staff, but particularly those who are responsible for provision of services to Travellers or policy in that area.

Management and Maintenance of Traveller Specific Accommodation The Plan should give details on how the Local Authority proposes

to manage and maintain Traveller Specific Accommodation. MTSG advocate an approach that encourages tenant

participation in such a process in order to foster a sense of ownership and interest in the accommodation.

This approach could involve the development of local site committees with tenants, MCC and MTSG.

A multi agency social work approach to anti social behaviour should become an explicit part of the new plan.

Emergency Accommodation It appears that the Local Authority have no emergency

accommodation stock. This should be clarified in the Plan and if it is the case the urgent steps that are required to be taken in order to have such a stock should be specified as part of the Plan.

The Plan should detail how services will be provided to Travellers on the roadside while awaiting accommodation.

Support of L.T.A.C.C. Representatives All reps should be provided financial supports to ensure their

participation such as childcare, travel and a per diem Payment Each Traveller rep should have an alternate to replace them if

they cannot be at meetings. Local traveller groups should be involved in the dissemination of

information regarding the L.T.A.C.C. and Traveller organisations should be involved in the selection process regarding the election of Traveller reps.


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Structures for development of Accommodation Proposals The Plan should include these details. Possibility of adopting a family specific model which means

Families in need of accommodation are identified, their individual needs are outlined and accommodation is provided on the basis of these needs.

MTSG propose that the LTACC or a subgroup thereof should devise a template for this process.


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4. Irish Traveller Movement

Consultation at a Local Level All locations for the development of Traveller accommodation

should be named and adopted during the stage where the Traveller Accommodation Programme is being developed.

Operation and Membership of the LTACC The ITM recommends the speedy establishment of the L.T.A.C.C.

to allow sufficient time for the committee to develop equal working relationships.

All reps on the LTACC should receive supports including travel and a per diem payment where appropriate.

Policy Statement All Programmes should include a policy statement, which has

been devised by the L.T.A.C.C., which sets out equality commitments to Travellers.

ITM recommend the discontinuation of the use of ‘quota’ systems for the allocation of Traveller accommodation and allocate equally on the basis of merit.

ITM recommend that Section 10 of the Housing (Misc. Provisions) Act 1992, as amended by Section 32 of the Housing (Traveller Accom.) Act 1998 and Section 21 of the Housing (Misc. Provisions) Act 2002 are not enforced on families who are part of the local TAP.

Assessing Traveller Accommodation Needs Surveys and figures compiled by local Traveller groups and the

Local Authority should complement one another to form the basis of the Accommodation Programme, which includes permanent and transient Accommodation.


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Sites with limited Facilities Existing temporary sites should be phased out in line with the

development of the Local T.A.P. No Traveller should have to live in ‘emergency temporary provision’ for a period longer than 2/3 years.

Provision of Transient / Traveller Specific Accommodation The T.A.P. should include clear policies regarding the treatment

of roadside families. Relevant Local Authorities should identify a number of sites that

would be ready for occupation, from within its own stock of property and if necessary rent additional property from other sources, including the private business sector, other state funded bodies, voluntary bodies and church authorities.

The Indigenous Clause The indigenous Clause is unacceptable and the ITM recommend

that Travellers should have their Accommodation needs assessed whatever the length of time they reside in a Local authority area. Local Authorities can then apply established criteria such as length of time on the housing list in deciding priority.

Tenant Participation in Accommodation Development Travellers should be involved in the development of

accommodation options and should play a full and meaningful role in the management of such. This is central to building and sustaining a successful Accommodation Programme.

Section 24 of the Housing (Misc. Provisions) Act, 2001 If the Local Authority does not take action to accommodate

families, they should, in the interest of fairness refrain in making requests to Gardaí to evict families.


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Appendix 7

Submissions Received and considered in formulating the Traveller Accommodation Plan 2005

– 2008(As a result of Public Display)

Pages 01 to 07 attached


SUBMISSIONS ON TRAVELLER ACCOMMODATION PLAN PUBLIC CONSULTATION - FEBRUARY 2005

SUMMARY OF SUBMISSION RESPONSE

(01) ST. CATHERINE’S EDUCATION AND RESOURCE CENTRES

Submission received and considered in reviewing The Draft Traveller Accommodation Plan 2005 – 2008 from St. Catherine’s Education and Resource Centres, Ballinrobe, Castlebar, Ballyhaunis

and Ballina on 1st February 2005.

OBSERVATIONS(1.1) Proposed transient/housing schemes should be made public, discussed and evaluated as to their suitability. All necessary sanitary/services should be installed.(1.2) Transient sites must be properly run with manager/supervisor on site.

(1.3) Local indigenous Travellers should be given preference for accommodation.

(1.4) More meaningful discussion/dialogue with proposed tenants in order to clarify what is expected from both sides.(1.5) Education required on rights/responsibilities of both Local Authority/Travellers on accommodation issues.

(1.6) Transparent system of priority is set up which is understood and agreed by Local Authority/Travellers.

(02 ) MARY SYRON, CHAIRPERSON, TRAVELLER HEALTH UNIT, WESTERN REGION HSE .

Submission received and considered in reviewing The Draft Traveller Accommodation Plan 2005 – 2008 from Mary Syron, Chairperson, Traveller Health Unit on 3 rd February 2005.

(1.1) All proposed housing and transient schemes will be made public as part of the planning process under Part 8 procedures. (1.2) Transient sites when developed will include appropriate management

and supervisory arrangements.(1.3) The Traveller Accommodation Plan will give priority to Traveller families

with a Mayo connection.(1.4) Training will be provided for Traveller families taking up local authority

accommodation. (1.5) The input of the Educational Resource Centres and the voluntary sector

will be essential in this area. Rights/responsibilities will be the subject of ongoing dialogue with the Traveller community over the course of the Plan.

(1.6) Mayo County Council will examine the feasibility of introducing a points based system as an indication of priority for allocations, having regard to experience gained in other local authority areas.

RESPONSE(2.1) Mayo County Council does consult with and seek support from all relevant

agencies and seeks

Traveller Accommodation Action Plan 2004 – 2008 February 2005.

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OBSERVATIONS(2.1) Before a family is removed from their accommodation and rendered

‘Homeless’ work should be undertaken with the family at the earliest possible opportunity in consultation with all the agencies with whom Mayo County Council is to work in partnership with, to secure the implementation of the Programme in an effort to avoid this happening as this could impact very negatively on the women and children in particular.

(03) MAYO TRAVELLER SUPPORT GROUP

Submission received and considered in reviewing The 03 Draft Mayo Traveller Accommodation Plan 2005 – 2008 from Mayo Traveller Support Group on 8 th February 2005.

OBSERVATIONS

(3.1) General PolicyThe allocation of housing should be on an equitable basis. The indigenous clause in the policy statement is discriminatory.

(3.2) Housing PolicyThe use of the quota system is contradictory to providing housing on the basis of need, as is the ratio system. A points system for housing allocation should be introduced. The same tenancy agreement should apply to all tenants

(3.3) Refusal of Housing Offers There should be a choice of 3 offers of accommodationCriteria outlining what constitutes a ‘reasonable offer’ should be based on cultural needs of Travellers.

(3.4)Transient AccommodationA Programme setting out timeframe for delivery and location is needed.The ‘boulder policy’ should be obliterated. A study on the nomadic needs of Travellers is required.

(3.5)Halting SiteThe halting site should not be used as a progressive approach to accommodate

to work in supportive partnership to deal with Traveller families prior to moving to the ultimate sanction of eviction which is very much a final resort.

(3.0)

The submission is essentially the same submission which was made by the Traveller Support Group and which was considered at the pre-Draft stage.

RESPONSE

(3.1) Housing Accommodation in Mayo is allocated on an equitable basis having regard to all of the

needs and circumstances of the approved applicants. The policy of prioritising families with a Mayo connection for the application of limited resources is sensible and is non-discriminatory.

(3.2) The Plan proposes the ring fencing of a minimum proportion of all social housing for Traveller families, to be allocated on the basis of need and of prudent estate

management. Mayo County Council will examine the feasibility of introducing a points based system as

an indication of priority for allocations, having regard to experience gained in other local

authority areas. The same tenancy agreement does apply to all tenants, as do the provisions for anti-social behaviour. (3.3) Given the limited nature of resources, the scale of the accommodation problem, and the number of families requiring accommodation, two offers of accommodation would appear to be reasonable. A reasonable offer is an offer of accommodation which would, in the judgement of the local authority, meet the accommodation requirements of the family in question.

(3.4) The transient halting sites will be delivered during the course of the four year programme when


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Travellers.Accepting a bay in the halting site as a condition for gaining a higher priority on the housing list is unfair.

(3.6) Assessment of Need An approach that involves a process is required.Families should be informed of accommodation options in a non-prejudicial way.The Council should initiate a process of informed assessment of preference and need.

(3.7)Anti-Social BehaviourNeed for definition of what constitutes anti-social behaviour.A sub-group is required to address issues of anti-social behaviour.Before extinguishing their eligibility for housing, anti-social offenders situation should be considered.

(3.8)Review and EvaluationAn ongoing review and evaluation of policies is necessary.

(3.9)Respecting and Resourcing Traveller Culture The programme should give detail on how it plans to resource and facilitate nomadism and Traveller Culture.

(3.10)Emergency AccommodationThe Local Authority should have an emergency accommodation stock.The Programme should detail how services will be provided to Travellers on the roadside while awaiting permanent accommodation. All avenues for the provision of emergency services should be explored.

(3.11)Privately RentingPrivate rented accommodation is only a viable short-term option for Travellers.

(3.12)Powers of EvictionUse of powers to evict should not be invoked until alternatives are provided. When considering carrying out an eviction the Council should consider the effects on the family.

(3.13)Operation of Local Traveller Accommodation Consultative Committee (LTACC)

locations will be chosen following examination of all feasible options. Mayo County Council will be consulting widely on the location for transient sites and any suggestion on locations from the Mayo Traveller Support Group will be positively considered. The County Council is required to control access to public spaces. This function would be greatly improved by an agreement from the Traveller community that unauthorised camping in inappropriate locations would not be condoned. Mayo County Council will be happy to support the study of nomadic needs in due course.

(3.5) The Castlebar halting site is a top class facility which provides six bays of accommodation to a very high standard. The allocation of bays is made on a case by case basis as vacancies arise having regard to a number of variables including need, family compatibility and good estate management.

(3.6) Mayo County Council does operate a consistent process of needs assessment and will consider a move to a points based system, as an indicator for prioritisation of accommodation offers, based on lessons learned and mixed results of trials of similar systems elsewhere.

(3.7) Anti-social behaviour is defined in Section 1 of the 1997 Housing (Miscellaneous Provisions)

Act. The issue of anti-social behaviour can be considered further by the LTACC and the Housing SPC.

(3.8) The development of the Programme over four years will be reviewed by the LTACC and the

Housing SPC.

(3.9) Considerable resources are being invested by Mayo County Council in facilitating the specific

needs of the Traveller community.


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There should be clear terms of reference for the group.An external facilitator should be appointed to monitor the effectiveness of the LTACC.Training is needed for all members of the LTACC.

(3.14)Management and Maintenance of Traveller Specific AccommodationHow the Council propose to manage and maintain Traveller specific accommodation should be detailed.MTSG encourage a tenant participation approach.

(3.15) Structures for Development of Accommodation ProposalsTraveller Accommodation should be developed family-specific.The LTACC or a sub-group thereof should be given the task of devising a template for this.

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(4.0) RESPOND! HOUSING ASSOCIATION

Submission received and considered in reviewing The Draft Traveller Accommodation Plan 2005 – 2008 from Respond! on 7 th February 2005.

OBSERVATIONS

(4.1)General PolicyMCC should begin to define what ‘reasonable and feasible’ mean in relation to providing Traveller Accommodation.Interpretations of this phrase will determine whether or not M.C.C. will be able to realise its policy. Unless the policy is clear it will not provide the foundation that is required for the implementation of programme.The Indigenous clause seems to counter the Housing Traveller Accommodation Act 1998.

(4.2) Housing PolicyThe ‘distinct cultural identity of Travellers’ needs to be spelled out in more detail in relation to the design and location of group housing. It needs to be shown how the Council can have regard to the specific housing needs of Travellers through the ratio system. Something more specific is required and will need to be included in advanced

(3.10) Mayo County Council will aim to reserve a number of units for dedicated emergency

accommodation. However, this must be balanced with the need to provide accommodation to applicants on the current waiting list. The Council assesses each roadside location on a case by case basis and provides services where it is safe and practicable to do so. The Council would welcome positive suggestions regarding the identification and development of appropriate emergency sites.

(3.11) Private rented accommodation will form an important part of the provision of accommodation for both settled and Traveller communities. (3.12) The Council only use its powers of eviction as a last resort. In cases

involving anti-social behaviour or where unauthorised encampments give rise to serious issues of public health or safety or the common good, the Council will reserve the right to evict without the provision of alternative accommodation.

(3.13) The terms of reference for the Local Traveller Accommodation Consultative Committee are as

laid out in the 1998 Housing Act. Training can be provided for the new members of the LTACC who have not had the benefit of training heretofore and who may wish to avail of it. An external Facilitator is not a recommended option at this time.

(3.14) Mayo County Council has a solid record in managing and maintaining Traveller Specific

accommodation and would welcome the support of the Mayo Traveller Support Group in encouraging a tenant participation approach which will include both members of the Traveller and settled communities.

(3.15) Where possible Traveller accommodation is developed on a family specific basis and the

Council would welcome any input from the Mayo Traveller Support Group or other bodies regarding the design of a suitable template.

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The submission is from Respond! Voluntary Housing Association who have Traveller Accommodation Action Plan 2004 – 2008 February 2005.

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plans for the estate in which they are to be located.

(4.3) Refusal of Housing OffersThe offers of accommodation to families should be ‘reasonable’ within the understanding of their ‘distinct cultural identity’ needs.(4.3.2)There should be a housing needs assessment for each family to define what an unreasonable refusal of accommodation might mean.

(4.4)Transient AccommodationFirm planning guidelines will be required to fix on site locations.If Traveller needs are not foremost, the sites will not be used.

(4.5)Halting SitesThe fact that ‘the preference of Travellers is for standard housing’, needs to be taken account of in the policy.Need for a more thorough investigation into the families who want to settle, and those who want to retain their current status. (4.6) Temporary Serviced Sites It is vital that clear criteria are defined to allow such sites.

(4.7)Implementing AuthoritiesThe exact number of families to be housed in Voluntary Housing needs to be notified to the Associations so that proper regard can be made for this. Respond! Welcomes the idea of a ‘consultation forum’ and suggest a more substantive forum.

(4.8) Programme DeliveryThere is a need to clarify details of the programme to public representatives and win approval for it. The document will be accepted but not implemented once there is any public dissent from the settled community.In relation to reviews of the Programme, they will be difficult to implement if the original

provided some Traveller Accommodation mainly as units in mixed tenure in developments which include both settled and Traveller communities.

RESPONSE

(4.1)The development and allocation of accommodation requires an element of judgement and evaluation on a case by case basis. The prioritisation of the allocation of resources to families who have a connection with a county is a topic which has been tested in the courts and has been found not to run counter to the Housing Traveller Accommodation Act 1998.

(4.2)The Traveller Accommodation Plan is a policy document and the issues of cultural

identity and how these concerns are addressed in specific schemes will be dealt with in the development of those schemes.

(4.3) Offers of accommodation will be made having regard to the specific and particular

Circumstances and needs of families, and to other factors including family compatibility and good estate management.

(4.4)Transient sites will be developed following the provision of accommodation to meet the needs of Traveller families within the county which will be the first and most urgent priority for Mayo County Council.

(4.5)The input of the Educational Resource Centres and the voluntary sector will Traveller Accommodation Action Plan 2004 – 2008 February 2005.

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targets are not defined on an annual basis.

(4.9)Management and MaintenanceThe draft should include what ‘Traveller specific’ accommodation includes. Participation by the community in maintenance and management will require a defined training programme.

(4.10)Anti-social BehaviourNeed for definition of anti-social behaviour.Delivering ‘Traveller specific’ accommodation should also include some community development and integration training.

(4.11)Missing Elements of the ProgrammePublic attitudes need to be challenged in relation to housing Travellers in the community.The requirement of the 1998 Act that local Authorities have regard for the ‘infrastructure and social support requirements’ of the Travelling community is not addressed in the Programme.

The local authority needs to see itself as being charged with delivering the accommodation ingredient while indirectly recruiting, integrating and managing the involvement of others.

The Programme needs to set out clearly defined and measurable targets.

(05) PAVEE POINT TRAVELLERS CENTRE

Submission received and considered in reviewing The Draft Traveller Accommodation Plan 2005 – 2008 from Pavee Point Travellers Centre on 4 th January 2005.

OBSERVATIONS

(5.1)Policy StatementPolicy statement ought to be formulated by the LTACC setting out equality commitments to Travellers.

(5.2)Assessment of Accommodation needs

be essential in this area. Rights/responsibilities will be the subject of ongoing dialogue with the

Traveller community over the course of the Plan.

(4.6) Mayo County Council will aim to reserve a number of units for dedicated emergency

accommodation. However, this must be balanced with the need to provide accommodation to applicants on the current waiting list. The Council assesses each roadside location on a case by case basis and provides services where it is safe and practicable to do so. The Council would welcome positive suggestions regarding the identification and development of appropriate emergency sites.

(4.7) The numbers of families to be accommodated in voluntary housing developments will be notified to the Associations as schemes are developed and resources are allocated. A consultation forum will be set up in due course.

(4.8) Public representatives are part of the discussion forum in developing the Traveller Accommodation Programme and there will be annual reviews.


accommodation and would welcome the support of the Respond! Housing Association in encouraging a tenant participation approach which will include both members of the Traveller and settled communities.

(4.10) Anti-social behaviour is defined in Section 1 of the 1997 Housing (Miscellaneous Provisions)

Act. The issue of anti-social behaviour can be considered further by the LTACC and the Housing SPC.


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The assessment should be carried out in an open, non-directive way.The assessment should be done by MCC in co-operation with MTSG.The assessment should include all members of the Traveller community.

(5.3)Future NeedsFuture accommodation needs should be assessed regularly, taking particular account of the younger members of family units.

(5.4)Provision of AccommodationTraveller accommodation should have the same quality standards as any other form of accommodation. There should be variety in the sizes of accommodation units.Provision should be made in local area development Plans for Travellers to purchase and develop their own land.

(5.5)Transient halting sites/stopping placesThe Council of Europe proposals for guaranteeing freedom of movement and freedom of encampment should be adopted. The Council should meet the needs of transient Travellers through the provision of transient sites and other flexible arrangements.

(5.6)Travellers on the RoadsideNeed for policy regarding the treatment of Travellers on the roadside. There should be procedures to prevent Traveller families losing their place on the accommodation waiting lists in case of eviction.There should be a moratorium on evictions for the duration of the Traveller Accommodation Programme.

(5.7) Temporary sites/sites with limited facilitiesTemporary sites ought to be phased out, no Traveller should have to live in ‘emergency temporary provision’ for longer than 2/3 years.

(5.8) Residential Caravan Sites for Travellers Local authorities have a role to play in supporting Travellers’ access to good quality trailer accommodation through loans and grants.

(5.9)Travellers in Standard local authority housingAll applicants for local authority housing should be put on the same housing list and allocated accommodation on the basis of merit. Local authorities have a responsibility to accommodate people who are unable to provide accommodation for themselves. The Council has a responsibility to address anti-social behaviour.

(4.11)Mayo County Council accepts that public attitudes needs to be challenged in relation to housing

Travellers in the community and would welcome the positive engagement of Respond and other groups representing Travellers in helping to challenge and develop models which demonstrate successes. Mayo County Council do not accept that the need to have regard to infrastructure and social support requirements is not addressed in the Programme. The Council would welcome any positive, creative and responsive input into the accommodation process. The Programme includes clearly defined and measurable targets.

RESPONSE

(5.1) The policy on which the Traveller Accommodation Plan is based is clearly stated.

(5.2) Assessment has been carried out in an open non-directive way, and has included all members of the Traveller community who were individually contacted in preparing the Plan .

(5.3) The Plan, including accommodation provided and ongoing needs, will be reviewed on an annual basis.

(5.4) Traveller accommodation has been developed and is maintained to a Traveller Accommodation Action Plan 2004 – 2008 February 2005.

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(5.10)Voluntary Housing and other optionsThere is a need to explore other ways of ensuring the timely and speedy provision of Traveller Accommodation. Travellers should be informed of all the available options available to them including, for example, affordable housing.

(5.11)Design of AccommodationIn designing Traveller specific accommodation, local authorities ought to have regard to the series of guidelines published by the Department.

(5.12) Allocation of AccommodationTraveller tenants should be made aware of the respective rights and responsibilities of both tenants and the local authority as landlord.

(5.13) Management and MaintenanceGood accommodation management is a key consideration in creating sustainable Traveller accommodation. Local authorities ought to strengthen their efforts to develop estate management strategies through Traveller tenant participation. (5.14) Preventing and combating anti-social behaviour Local authorities ought to take account of the Housing Units Good Practice Guidelines on ‘Preventing and Combating Anti-social Behaviour’. Particular attention ought to be paid to confidentiality and the needs of victims of severe anti-social behaviour and intimidation.

(5.15) ConsultationCulturally appropriate consultation with Travellers is crucial for the success of the T.A.P.’s.With respect to the L.T.A.C.C.’s, local authorities ought to adopt and implement the code of practice on consultation contained in the DOEHLG guidelines concerning the operation of L.T.A.C.C.’s

(5.16) Implementation Mechanisms and procedures for implementation need to be clearly stated in the Traveller accommodation programme. To help with such monitoring, the programmes should include explicitly stated annual targets. The Housing SPC should also hold an annual review meeting on the implementation and monitoring of the TAP’s.

standard at least equal to accommodation provided for the settled community. There are a variety of sizes and types of accommodation units. The Council would welcome and support any initiative for Travellers to purchase and develop their own land.

(5.5)Transient sites will be developed following the provision of accommodation to meet the needs of Traveller families within the county which will be the first and most urgent priority for Mayo County Council.

(5.6) The Council only use its powers of eviction as a last resource. In cases involving anti-social

behaviour or where unauthorised encampments give rise to serious issues of public health or safety or the common good, the Council will reserve the right to evict without the provision of alternative accommodation.

A Moratorium for a four year period is neither practicable nor reasonable.

(5.7) It is a policy of Mayo County Council to provide permanent accommodation for all Traveller

families within its remit over the period of the Plan.

(5.8) Mayo County Council has experienced considerable difficulty in the area of provision of loans

and grants for trailer accommodation.

(5.9) All applicants for local authority housing are on the same waiting list and accommodation offers are made on the basis of assessed need allied to judgements regarding good estate management

and family compatibility. The Council welcomes the recognition of the importance of a firm policy in the area of anti-social behaviour and would welcome further input from Pavee Point in terms of support in dealing with cases of anti-social cases of behaviour throughout the county.


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(5.10)The role of the voluntary sector and the provision of accommodation through Affordable Housing strongly supported and encouraged by the County Council.

(5.11) Mayo County Council in the provision of Traveller Specific accommodation has regard to all relevant Government Guidelines.

(5.12) All tenants are provided with training prior to taking up their tenancy. Mayo County Council would welcome the input of Pavee Point to designing Traveller specific training particularly focussing in the areas of tenant responsibilities.


accommodation and would welcome the support of the Pavee Point in encouraging tenant participation approach which will include both members of the Traveller and settled communities.

(5.14) Mayo County Council will take account of the Housing Units Guidelines on

Anti-social behaviour and would welcome the support of Pavee Point and other groups in dealing firmly with cases of anti-social behaviour and intimidation which frequently and seriously effect the quality of life of all residents.

(5.15)Appropriate consultation and engagement by the Traveller community with local authorities is a crucial element in successful provision of accommodation and other services. Mayo County Council welcomes the support of Pavee Point and other agencies in this regard.

(5.16)The Plan does include stated delivery mechanisms and targets. Annual targets will be included and the Housing SPC is part of the adoption and monitoring mechanism for the Traveller Accommodation Plan.


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