Submission to Carlow County Council Draft County Development Plan
Background to the Irish Traveller Movement
Founded in 1990, the Irish Traveller Movement is the national advocacy and membership platform which brings together Travellers and representative organisations to develop collective solutions on issues faced by the community to achieve greater equality for Travellers. We challenge racism- individual, cultural and structural which Travellers face and promote integration and equality. We are led by our grassroots community membership, deliver expertise in shaping organisations locally and promote community leadership ensuring Travellers’ voices are to the forefront of all discussions at a national and international level. Irish Traveller Movement are one of the three national Traveller organisations who are members of the National Traveller Accommodation Consultative Committee and the Traveller Accommodation Expert Review programme board.
The Traveller Accommodation Crisis
There is a crisis in accommodation nationally for Travellers. Despite statutory requirements Travellers continue to live in poor conditions throughout Ireland on road sides, in temporary halting sites and in overcrowded and substandard conditions in both standard and Traveller specific accommodation, with associated health and safety risks and knock on impacts onto mental health and educational outcomes.
Notable, in this context, is the recent report by the Ombudsman for Children's Office ‘No End in Site’ which highlighted the deplorable conditions in which Traveller children are living in. A further European Social Rights Institute report published in September 2021, ‘Monitoring Adequate Housing in Ireland’, found that 39% of Travellers are living in overcrowded conditions and 5% lack access to basic facilities such as sewage and piped water. Travellers are also significantly overrepresented within official homeless figures nationally, accounting for as high as 50% of the homeless population in some local authority areas according to recent Irish Human Rights and Equality Commission Equality Reviews.
The current Carlow Council Traveller Accommodation Programme (TAP) sets out an ambitious target to accommodate 245 families, while it accommodated just 66 families in the previous TAP period. In order to reach this target, particularly in relation to Traveller specific accommodation, it is essential that the County Development Plan aligns with the Traveller Accommodation Programme and clear targets are indicated within it.
We welcome the objectives on Traveller accommodation already included in the Carlow County Council draft development plan and below are a series of recommendations to enhance it to ensure the accommodation needs, including culturally appropriate Traveller-specific accommodation, of Travellers in your local authority area are met during the lifespan of the Plan. This submission is supported by St. Catherine’s C.S.C, which is a member of the Irish Traveller Movement.
Recommendations for County Council Development Plan
- Traveller specific accommodation developments completed under the last development plan period should be outlined in the Development Plan.
- National-level planning guidelines for Development Plans set out the relationship between the Traveller Accommodation Programme (TAP), the Housing (Traveller Accommodation) Act, 1998 and the statutory Development Plan. They require that the range and type of housing required and the land use aspects of the TAP are incorporated into the Development Plan. The Guidelines also state that this should take the form of ‘... objectives that clearly set out the approach of the Development Plan in addressing the accommodation needs of the Traveller community and an indication of the specific locations of known Traveller accommodation projects. To support the identification of additional locations for such projects, zoning policies should also be drawn up in a flexible manner to reflect the urgent need to secure additional Traveller accommodation over the lifetime of the plan.' ( Section 4.56 of Development Plans: Planning Guidelines for Planning Authorities, 2007).
Therefore, projects committed to under the 2019-2024 Traveller Accommodation Programme should be listed as objectives in the Development Plan with clear timelines as per the Housing (Traveller Accommodation) Act 1998 PART III (27) (10), and
Sites should be identified and zoning of land for Traveller specific accommodation, including transient accommodation, should be mapped and illustrated in the programme, in line with the Planning and Development Act, (2000) as amended, particularly s10(2)(i). The legislation requires that a Development Plan shall include objectives for: ‘The provision of accommodation for Travellers, and the use of particular areas for that purpose.'
Given the high recognised need and targets set for one off rural housing in the Carlow Traveller Accommodation Programme 2019-2024 this should be accounted for and planned for, with corresponding zoning of land within the Carlow County Development Plan. The current Traveller Accommodation Programme suggests a target of 50 one off rural housing for Travellers across the Traveller Accommodation Programme.
Given the lifespan of the development plan, consideration should also be given for how sites will be identified for Traveller Specific Accommodation in the next Traveller Accommodation Programme, including transient sites.
- A system of monitoring and reviewing at regular intervals the provisions outlined in the Development Plans as they relate to Traveller accommodation should be included in the Development Plan. These and the provisions of the current Traveller Accommodation Programme should be reviewed every six months with a presentation on progress to the Local Traveller Accommodation Consultative Committee. The inclusion of an ethnic identifier would improve the quality of data collection and monitoring of provision of accommodation for Travellers.
- Section 94 (2) of the Planning and Development Act, 2000, as amended, sets out that Development Plans should ensure that they counteract undue segregation. With this in mind, sites identified for Traveller specific accommodation should be well located, close to key amenities, and chosen in consultation with the community. Plans should include sufficient green areas and children’s play areas.
- All developments should be carried out with consultation at every stage of the process, with prospective residents, local Traveller organisations and with the Local Traveller Accommodation Consultative Committee.
- The Development Plan should identify Travellers as a priority group in its plans to address homelessness and identify what tangible steps will be taken to reduce the overrepresentation of Travellers in homeless figures. 21% of homeless families in Carlow at present are Travellers, while making up just over 1% of the overall population of Carlow, indicating a significant overrepresentation, according to recent figures provided by the Council. The County Development Plan should also take into account the high level of hidden homelessness, where families are living in chronic overcrowding, or without basic facilities of their own, or security of tenure, with plans to alleviate this clearly outlined.
- Appropriate baseline studies on Traveller accommodation needs should be carried out as part of integrated Housing Need and Demand Assessments for Development Plans, if this has not already occurred.
- Carlow County Council should consider, in this process, how future Development Plans could have their timelines aligned with the timelines of TAPs, for a more integrated approach, in line with the recommendations of the Expert Review on Traveller Accommodation.
- The Development Plan should reference the work being done on a national level to implement the recommendations of the Expert Review on Traveller Accommodation and commit to incorporating the work and decisions of the programme board into its future processes.
- The Development Plan should reference the Council’s strategy to implement the relevant recommendations of the recent Irish Human Rights & Equality Commission Equality Review on the provision of Traveller accommodation in the Carlow area.
- Eliminating Energy Poverty in Traveller Specific Accommodation
Providing clean affordable energy, and energy efficient homes in Traveller specific accommodation.
- A recent study by National Traveller Money Advice and Budgeting Service found that Travellers living in mobile homes and trailers experience high levels of energy poverty. The study found that on average, families spend 26% of their income on energy compared with a 4.6% spend in the general population. This study also found that Travellers use a wide variety of fuels to heat their homes while simultaneously experiencing damp, condensation in their homes which gives rise to numerous related health issues. The problem of energy poverty among Travellers arises out of a combination of factors, including the means by which energy is provided as well as the energy efficiency of both the mobile and the day unit/house provided on site. Household income is also a factor in energy poverty.
- In light of this, the Council should plan to review existing Traveller specific accommodation with a view to bringing it up to the current regulatory standards in terms of energy efficiency of the dwellings and in terms of access to sustainable energy sources. It should be ensured that there is access to the competitive energy provision market for Travellers living in Traveller-specific accommodation and that Travellers in Traveller specific accommodation have access to accurate, individual energy bills in order to monitor and control their own energy costs.
- All planned Traveller specific accommodation should seek to ensure that homes built have the highest level of building airtightness combined with effective ventilation systems. In addition, the Council must meet near zero energy building (NZEB) requirements under current regulatory requirements and demonstrate that energy used by the NZEB must be from renewable sources "to a very significant extent", including energy from renewable sources produced on site or nearby. Under current regulations all planned new residential dwellings are expected to be 70% more energy efficient when compared to 2005 performance requirements.