COMHAIRLE CONTAE ÁTHA CLIATH THEAS
SOUTH DUBLIN COUNTY COUNCIL

south dublin county council crest

MEETING OF SOUTH DUBLIN COUNTY COUNCIL

Monday, January 13, 2014

HEADED ITEM NO. 8

HEADED ITEM: H. Department

TRAVELLER ACCOMMODATION PROGRAMME

Introduction

Under the provisions of the Traveller Accommodation Act 1998, South Dublin County Council is required to prepare, adopt and implement a new Traveller Accommodation Programme to meet the accommodation needs of the county's indigenous Traveller Community, i.e. those families who have been resident in the county for at least three years prior to the adoption of South Dublin County Council's Traveller Accommodation Programme 2014 – 2018.

The existing programme, which took affect on the 1st January 2009, expired on 31st December 2013. The new Traveller Accommodation Programme will cover the period from the 1st January 2014 to the 31st December 2018.

 The Minister for Housing and Planning has issued a number of directions under the Act in relation to the preparation of the new Traveller Accommodation Programme and these are contained in Circular Letter Housing 26/2013, together with a 'Memorandum on the Preparation, Adoption and Implementation of Local Traveller Accommodation Programmes 2014 – 2018'. The Minister has specified that the latest date for the adoption of accommodation programmes is the 30th April, 2014.

 Consultative Process

 The Housing (Traveller Accommodation) Act, 1998 requires that an extensive and thorough consultation process underpin the preparation and implementation of the Accommodation Programme with all interests concerned. Accommodation programmes are required to be prepared and implemented in consultation with other local public authorities, community groups and other bodies, Travellers both directly and via the Local Traveller Accommodation Consultative Committee, Traveller Support Groups and the public in general. The purpose of these consultation provisions is to ensure that the views of all concerned with or affected by proposals for Traveller Accommodation are considered.

 Notice of the intention to carry out the Assessment of Need and to prepare the Draft Accommodation Programme was given to members of the Local Traveller Accommodation Consultative Committee, voluntary housing associations active within the county, the Health Services Executive, and all 5 adjoining Housing Authorities.  It was also advertised in the press and circulated to the Irish Traveller Movement. Local Traveller Development Groups, Gardai, Pavee Point, Exchange House and all agencies in the Interagency Group process. The closing date for receipt of submissions prior to the publication of the draft Traveller Accommodation Programme 2014 – 2018 was the 20th September 2013. Five (5) submissions were received and are included in draft programme in Appendix 2. These submissions were from the Health Service Executive, Respond Housing Association, The Irish Traveller Movement, Tallaght Travellers Community Development Group and Clondalkin Travellers Development Group. These submissions were used to inform the content of the draft programme

 The Draft programme was published on the 3rd October 2013 and notice of its publication was advertised in the national press and on the Council's website. Notification was also provided to members of the Local Traveller Accommodation Consultative Committee, the voluntary housing associations active within the county, the Health Services Executive, and the 5 adjoining Housing Authorities. Following publication, a two month period in which interested parties could make a submission on the draft programme commenced. The closing date for submissions was Tuesday, 3rd December 2013. 5 submissions were received and are addressed below.

 A meeting of the Local Traveller Accommodation Consultative Committee took place on the 21st November, 2013 to discuss the draft programme. Following discussions, it was agreed to make the following amendments to the draft Traveller Accommodation Programme:

 Provide further information on the membership and workings of the Local Traveller Accommodation Consultative Committee

 The draft programme presented to the elected members has been amended to address these points.

 Five (5) submissions in relation to the draft Traveller Accommodation Programme were received before the closing date. The submissions and the Council's response to the issues raised follows:

1.        Submission received on the 12th November 2013 from Mark Bradley, Coordinator, Tallaght Traveller Community Development Programme.

 The issues raised in the submission from Mark Bradley and the Council's response are as follows:

 Issue: That voluntary housing agencies are invited onto the Local Traveller Accommodation Consultative Committee & subcommittees along with County Manager. Concern that specific voluntary housing agencies are not identified in the programme.

 Response:  The Council is committed to actively working with any approved housing body who wish to get involved in the management and provision of Traveller accommodation and to this end will actively engage with them over the period of the programme.  Approved Housing Bodies (AHBs) will be invited to join the LTACC when it is next constituted following the Local Elections later this year

 It should be noted that the County Manager is represented on the current Local Traveller Accommodation Consultative Committee by senior management in the Housing Department and that the issue of Traveller accommodation is a key priority for South Dublin County Council.

 Issue: That new developments are kept to a maximum of 4 units to allow better cohesion among families resident on the sites and to create a better sense of ownership and that all new builds are located within or close to settled housing estates with access to necessary amenities.

 Response: One of the core goals of the draft Traveller Accommodation Programme is to meet the projected future demand for social and Traveller specific housing. While there is recognition that smaller developments sometime operate better, regard must still be had to meeting the demand for accommodation. Over the lifetime of the plan, the Local Traveller Accommodation Consultative Committee will continue to review the demand for Traveller specific accommodation and at the planning and design phase, will look to reduce the size of developments if demand is being met through the allocation of casual vacancies. All new developments will be designed so that they are not marginalised from the wider community and have access to all necessary amenities.

 Issue: That the issue of the provision of a transient site for Travellers be a priority under the new Traveller Accommodation Programme.

 Response: As outlined in the draft Traveller Accommodation Programme, it is an objective of the Council to consider the provision of transient accommodation in the county during the term of the current Traveller Accommodation Programme

 In consultation with the other Dublin Local Authorities it has agreed that in the Greater Dublin Area, transient accommodation would be provided as part of a network of transient sites throughout all of the neighbouring metropolitan Authorities, in a coordinated and comprehensive manner and discussions in this regard is ongoing between all four local authorities.

 However, in light of the existing financial constraints, the main focus of the Council will be to meet the projected need for permanent accommodation for Travellers and that the provision of a transient site should be addressed when that demand for permanent accommodation is realized and in conjunction with the other Dublin local authorities.

The provision of such a facility will also discussed with the AHBs who are interested in working with the Council in the provision of Traveller Accommodation.

 Issue: That the membership of the Meeting of Co-ordinating Services for Travellers Steering Group which forms part of the Interagency Traveller Strategy be re-examined to address the absence of Travellers and Traveller representatives.

 Response: While it is not a function of the Traveller Accommodation Programme to determine the membership of the Interagency Co-ordinating Services for Travellers Steering Group, the concerns of both Traveller Development Groups as well as the Local Traveller Accommodation Consultative Committee will be brought to the attention of the steering group.

 Issue: Concern that Traveller families in crisis and presenting as homeless could be excluded from services if their behaviour is interpreted by staff as abusive, confrontational or violent. Submission requests that staff are trained to operate when dealing with families in crisis.

 Response: It is important to note that not only has the Council a duty of care to provide accommodation to those in need, it also has a duty of care to ensure the health and safety of its staff. Frontline staff, who deliver services to those families in crisis, have already received extensive training, including cultural awareness training, but will continue to examine their training needs and requirements under the Performance Management Development System.

 Work is underway in developing an acceptable behaviour policy for customers which will look at best practice here and in the UK. Within the Housing Department, a pilot restorative practice training programme is being rolled out currently which will look to provide a pathway for clients who have been involved in critical incidents with staff to evaluate the impact of their actions and re-engage with services in a timely manner.

 Issue: Need for initiative to enable and educate those Travellers with literacy or computer skills issues on accessing housing services.

 Response: Included in the draft programme (on page 7) is reference to a pilot programme to commence in 2014 where the Council will work closely with the Traveller Development Groups to educate and advise families on the accommodation waiting lists on their options. It is envisaged that this issue will addressed as part of this programme.

 Issue: Concern that the accommodation needs of single Travellers are not met under the proposed programme.

 Response: It is clearly stated in the draft programme that applications for accommodation for either Traveller specific accommodation or standard housing will be considered on the basis of the Council's current Allocation Scheme for Social Housing.

 There is no barrier to single people applying under this scheme providing they meet all the necessary requirements (in need of housing, income does not exceed stated limits etc). To date, group housing provided under previous Traveller Accommodation Programmes has been 4 bedroom units to meet the need of large Traveller families who required accommodation.

 The Council will examine the information gathered during the annual Traveller census count conducted on the 29th November 2013 to identify the number of single adult travellers and examine how their accommodation needs can be met during the course of the programme.

 Issue: That those Travellers who have been granted medical priority by the Council's Medical Officer be identified and steps taken to address their needs.

 Response: The Council will identify those Travellers who have received medical priority and put together a specific programme to identify what specific works are required.  If the funding streams to finance the works are available the programme will be implemented as part of the Traveller Accommodation Programme. 

 Issue: That all budgets provided to South Dublin County Council by the Department of the Environment, Community and Local Government be presented to the Local Traveller Accommodation Consultative Committee meetings.

 Response: Information in respect of capital funding for new builds are already presented to the Local Traveller Accommodation Consultative Committee.  In recent times the funding from the Department in relation to maintenance and management costs have been provided to the committee with a view to improving the value for money achieved within them.  This will continue during this programme.  It is important to note that these monies are recouped after the expenditure is incurred initially by the local authority.

 Issue: Need for a new initiative to replace the Caravan Loan Scheme. Suggested changes to national rent allowance policy to enable Travellers to secure caravans, mobile homes or trailers. The Household Budget Scheme, run by An Post on behalf of the Minister for Social Protection, to be used to ensure repayment of loans to provide mobile accommodation.

 Response: The suggestions regarding rent allowance and the Household Budget Scheme are national issues.  They are however being examined in conjunction with the Governments policy to move from Rent Allowance to Housing Assistance Payment. 

 Issue: That a DVD be made in tandem with the Tenant's Handbook which is currently being reviewed which would be oral and visual in nature and aid those with literacy issues.

 Response: The Council feels there is a great deal of merit in this suggestion. While it is not mentioned specifically within the draft Traveller Accommodation Programme, the subcommittee of the Local Traveller Accommodation Consultative Committee dealing with maintenance and management issues would be seen as the ideal vehicle to drive this initiative.

 Issue: That consideration be given to integrating the Traveller Accommodation Unit to reduce overheads and standardise the housing lists.

Response: It is the intention and aim of the Council to mainstream the management and maintenance of all Traveller specific accommodation within the relevant sections of the Council and to date some of this has been achieved. Viz. Rent collection, Allocations and Estate Management in Group housing

However, it is accepted that the Council should continue to develop policies and practices in relation to estate management and community development prior to the mainstreaming of all aspects of Traveller accommodation within the relevant sections of the Council in order to address the historical legacy of issues and difficulties that Travellers faced in respect of securing accommodation as well as sustaining tenancies after they had been allocated.

The mainstreaming of the services provided by the Traveller Accommodation Unit would not mean any increase in funding available for Traveller accommodation requirements.

 2.        Submission received from Cena  - Culturally Appropriate Homes Limited ( a Traveller led voluntary accommodation association) dated the 14th November 2013, received via email on the 20th November 2013

 Issue: Background to the establishment of Cena, statement of the aims and functions of Cena and information in respect of Cena's proposed pilot schemes; a rural based halting site pilot project and an urban based group housing pilot project and an invitation for local authorities to express an interest in participating in the pilot projects.

Response: South Dublin County Council welcomes the establishment of Cena as a Traveller led association within the approved voluntary housing sector seeking to develop a Traveller led model for the delivery and management of culturally appropriate Traveller accommodation. As stated previously, as part of the draft Traveller Accommodation Programme, the Council is seeking to actively engage with voluntary housing associations to encourage them to expand their role in the provision and management of Traveller specific accommodation. The Council will make contact with Cena and enter into discussions to determine what role the Council can play in enabling Cena to meet its aims.

 3.        Submission received from Irish Traveller Movement dated 27th November 2013, received 2nd December 2013.

 The issues raised by the Irish Traveller Movement (ITM) and the Council's response to those issues are as follows:

 Issue: No specific information within the draft programme on how Travellers apply for Traveller specific accommodation.

 Response:  The draft programme's brief is to set out background, policy, aims and targets in relation to Traveller accommodation for the period 2014 – 2018. It is not intended to be a manual for Travellers wishing to access services. The Council's Traveller Accommodation Unit is tasked with providing an advisory as well as an administrative service to Travellers in respect of accommodation issues and staff are always willing to help any client to apply for accommodation, whether Traveller specific or standard.

 Included in the draft programme (on page 7) is reference to a pilot programme to commence in 2014 where the Council will work closely with the Traveller Development Groups to educate and advise families on the accommodation waiting lists on their options. It is envisaged that this issue will addressed as part of this programme.

 Issue: Links with the Tallaght Traveller Community Development Group and the Clondalkin Traveller Development Group in identifying an assessment of housing need for Travellers.

 Response: Prior and during the Assessment of Housing Need carried out nationally in 2013, both development groups were briefed at meetings of the Local Traveller Accommodation Consultative Committee and at meetings of the sub-committee of the LTACC dealing with Traveller accommodation issues on the assessment of housing need and the response being received from Travellers. The Council is satisfied that every effort was made to make contact with those Travellers who did not respond during the assessment process.

 Issue: That Travellers be recognised by South Dublin County Council as an ethnic minority and recognition of Traveller's distinct cultural needs.

 Response: South Dublin County Council has been advised that the matter of recognition of Travellers as an ethnic group is being examined by the Department of Justice & Equality and other Government Departments. Therefore it would not be appropriate for the Council to make a determination on the ethnic status of Travellers in advance of this.

 The Council is committed through the school project and the Yellow Flag programme to raising awareness on the culture and history of Travellers. The two specific areas of economic activity referred to in the submission, namely horses and scrap trading, are subject to bye-laws, land zoning, licensing etc and as these issues are much wider than the remit of the Traveller Accommodation programme, they are not referred to in the programme.

 Issue: That the issue of the management of accommodation be prioritised.

 Response: The management and maintenance of existing as well as new Traveller specific developments is a core part of the proposed Traveller Accommodation Programme.

 Issue: That South Dublin County Council would hold training for staff who work with Travellers on cultural awareness.

 Response: Frontline staff who deliver services to Travellers have already received extensive training, including cultural awareness training, but will continue to examine their training needs and requirements under the Performance Management Development System.

 Issue: Clarify the meaning of the 'indigenous clause'

 Response: The introduction to the Draft Traveller Accommodation Programme 2014 - 2018 clearly states that the programme is been drawn up to 'meet the accommodation needs of the county's indigenous Traveller Community, i.e. those families who have been resident in the county for at least three years prior to the adoption of South Dublin County Council's Traveller Accommodation Programme 2014 – 2018.'

 The use of an 'indigenous clause' allows the local authority to plan what numbers of houses/bays will be required throughout the programme. The Department of the Environment, Community and Local Government, have stated in circular letter TAU 4/2009, that the High Court has held that the inclusion of an indigenous clause within a Traveller Accommodation Programme comes within the statutory power of a housing authority, as long as the indigenous policy is not applied so rigidly as to become an effective bar to a member of the Traveller community being considered for accommodation by a housing authority.

 Issue: Following the establishment of the new Local Traveller Accommodation Consultative Committee after the forthcoming local elections, that ITM could facilitate a session with the new committee on the goals and terms of reference of the committee.

 Response: This will be arranged following the establishment of the new Local Traveller Accommodation Consultative Committee.

 Issue: That a monitoring system be put in place to record details of families who are transient within South Dublin to give a clear picture of the need for a transient site.

 Response: The Council will continue to monitor and record details of transient Traveller families in the administrative area of South Dublin County Council.

 Issue: That a homelessness policy for Travellers be drawn up at the Local Traveller Accommodation Consultative Committee that would also link into a metropolitan network of authorities.

 Response: The Dublin Regional Homeless Executive which represents the 4 Dublin LA and in which Dublin City is the lead agency is the body charged with the homeless response in the Greater Dublin Area.  Any specific issues that the Local Traveller Accommodation Consultative Committee wish to make in relation to Travellers can be addressed to this body.

 Issue:  No mention in the Draft Traveller Accommodation Programme of an emergency or temporary site being provided or how the Council will deal with emergency situations.

 Response: as stated within the Draft Traveller Accommodation Programme, 'South Dublin County Council does not agree that the provision of spaces to be used on an emergency basis where families leave accommodation because of violence and intimidation is necessary. The Council is committed to developing best practice in tenant participation and estate management so that issues that arise can be dealt with without families needing to abandon their accommodation and also to build vibrant, inclusive, safe communities for Travellers.'

 Issue: ITM recommends the reinstatement of the Caravan Loan Scheme.

 Response: The Council cannot justify the reinstatement of the Caravan Loan Scheme at this time while it is dealing with the legacy of unsustainable high level of arrears owed on loans granted previously.

 Issue: That all years of the proposed programme are costed.

 Response: It is not possible to accurately account for construction costs and land acquisition costs over the five year duration of the programme. Also it is important to note that although the Draft Traveller Accommodation Programme 2014 – 2018 is a multi-annual programme, capital funding for Traveller accommodation projects is currently allocated on an annual basis.

4.        Submission received via email on the 2nd December 2013 from Councillor Gus O'Connell, Chairperson of the South Dublin Local Traveller Accommodation Consultative Committee.

Issue: That the full texts of the submissions received prior to the publication of the draft Traveller Accommodation Programme be included as an appendix

Response: the full texts of the submissions received from Health Service Executive, Respond Housing Association, Irish Traveller Movement, Tallaght Travellers Community Development Group and Clondalkin Travellers Development Group are included in Appendix 2 of the proposed programme.

Issue: Include in programme a reference to formalising links between the Local Traveller Accommodation Consultative Committee and the Housing and Social Development Strategic Housing Development Committee of the Council.

 Response: This has been included in the proposed programme.

 Issue: That an annual review of the programme with a report to the elected members be included.

 Response: It is agreed that an annual review of the Traveller Accommodation Programme would keep all stakeholders apprised of how the programme is performing. An annual review of the programme will be presented to the Housing and Social Development SPC and will address any issues that may arise that could affect delivery of the programme.

 Issue: That the programme include a request that funding be sought on a rolling basis instead of an annual allocation.

 Response: While funding for the programme is critical to its delivery it is not a factor that can be addressed in the actual programme.  The Council will raise the matter directly with the Department of the Environment, Community and Local Government rather than include it in the programme.

 Issue: Include in the proposed Traveller Accommodation Programme an intention to broaden the membership of the Local Traveller Accommodation Consultative Committee to include representation from agencies such as the HSE, Homeless Agency etc.

 Response: It is agreed that the membership of the Local Traveller Accommodation Consultative Committee will be re-examined following the local elections in 2014. Consideration will be given at this time to expanding the membership of the committee to those agencies as well as voluntary housing bodies.

 Issue: Include a clearer definition of how Travellers can access all housing options.

 Response: As outlined in the proposed programme, the Council in partnership with both the Tallaght Traveller Community Development Group and the Clondalkin Traveller Development Group will commence a pilot programme to allow the Development Groups to advise and educate Traveller families on their options in relation to their accommodation needs. This pilot programme was suggested and agreed through the Local Traveller Accommodation Consultative Committee. The Council's Traveller Accommodation Unit will continue to be available to Travellers to advise them on their accommodation options.

 Issue: Make reference to the specific context through which Travellers with special needs are prioritised (not just medical model but also the social model).

 Response: As outlined in the proposed programme, applications on the basis of medical need supported by a medical consultant's letter and subject to the opinion of the Council's Medical Officer in accordance with the Council's Allocation Scheme will be prioritised. While the Council is committed to pursuing the social model of disability, where it is practicable, regard must also be had to medical advice. The Council will discuss with any Traveller family who has received medical priority what options are available. As stated previously in this report, The Council will identify those Travellers who have received medical priority and put together a specific programme to identify what specific works are required and to identify funding streams to finance the works.

5. Submission received on the 3rd December 2013 from Aisling Flynn, Accommodation Development Worker, Clondalkin Travellers Development Group.

 The issues raised in the submission from the Clondalkin Travellers Development Group (CTDG) and the Council's response is as follows:

 Issue: That the membership of the Meeting of Co-ordinating Services for Travellers Steering Group which forms part of the Interagency Traveller Strategy be re-examined to address the absence of Travellers and Traveller representatives.

 Response: : While it is not a function of the Traveller Accommodation Programme to determine the membership of the Interagency Steering Group on Services for Travellers, the concerns of both Traveller Development Groups as well as the Local Traveller Accommodation Consultative Committee will be brought to the attention of the steering group.

 Issue: That all new proposed developments happen in consultation with the Local Traveller Accommodation Consultative Committee, Traveller Groups and the families concerned and that the overall number of proposed units not be reduced but that the size of developments be reduced to enhance cohesion amongst residents. All proposed construction should take place within the context of larger developments rather than large isolated developments.

 Response: The Council is committed to engaging with all interested parties when developing new sites and the issues around the development of these sites will be discussed and explored by the Local Traveller Accommodation Consultative Committee and with residents

 One of the core goals of the draft Traveller Accommodation Programme is to meet the projected future demand for social and Traveller specific housing. While there is recognition that smaller developments sometime operate better, regard must still be had to meeting the demand for accommodation. Over the lifetime of the plan, the Local Traveller Accommodation Consultative Committee will continue to review the demand for Traveller specific accommodation and at the planning and design phase, will look to reduce the size of developments if demand is being met through the allocation of casual vacancies. All new developments will be designed so that they are not marginalised from the wider community and have access to all necessary amenities.

 Issue: That the programme states a commitment to encouraging the involvement of approved housing bodies and developing strategies in partnership with the voluntary housing sector to progress accommodation provision for Travellers.

 Response: This commitment is outlined in the section of the programme dealing with policy.

 The Council is committed to actively working with any approved housing body who wish to get involved in the management and provision of Traveller accommodation and to this end will actively engage with them over the period of the programme.  AHBs will be invited to join the LTACC when it is next constituted following the Local Elections later this year. 

 Issue: That formal links are created between the Local Traveller Accommodation Consultative Committee and the Housing and Social Development Strategic Policy Committee.

 Response: The strengthening of the link between the Local Traveller Accommodation Consultative Committee and the Housing and Social Development Strategic Policy Committee is contained in the section dealing with the Local Traveller Accommodation Consultative Committee.

 Issue: That it is acknowledged that Travellers face significant difficulties in accessing finance to procure mobile homes, particularly as the caravan loan scheme administered by the Council is suspended.

 Response: While it is acknowledged that some travellers have difficulties seeking loans/finance to procure mobile accommodation the Council can not justify the reinstatement of the Caravan Loan Scheme at this time while it is dealing with the legacy of unsustainable high level of arrears owed on loans granted previously.

 Issue: That Travellers are finding it increasingly difficult to access private rented accommodation. This is due to an increasing shortage of suitably priced private rented accommodation and also to reports that landlords are refusing to accept Travellers as tenants. CTDG wish to put on record that there is a national housing crisis looming and that Travellers will be impacted most of all. CTDG also recommends that the programme contain a commitment to developing strategies to address particular issues that Travellers face when accessing homelessness services.

 Response:  Both Travellers and the settled community are experiencing difficulties in accessing private rented accommodation due to increasing demand and increasing rents.  This is a national issue and is already a feature of discussions between Government Departments.

 The Dublin Regional Homeless Executive which represents the 4 Dublin LA and in which Dublin City is the lead agency is the body charged with the homeless response in the Greater Dublin Area.   Any specific issues that the Local Traveller Accommodation Consultative Committee wish to make in relation to Travellers can be addressed to this body.

 Issue: That an annual review of the Traveller Accommodation Programme be carried out to review progress, challenges and achievements. This review would also address the barriers to delivery, in the event of any part of the proposed programme not being delivered.

 Response: It is agreed that an annual review of the Traveller Accommodation Programme would keep all stakeholders appraised of how the programme is performing. An annual review of the programme will be presented to the Housing and Social Development SPC and will address any issues that may arise that could affect delivery of the programme.

 Issue: CTDG have requested that the section dealing with the Local Traveller Accommodation Consultative Committee be expanded to discuss the make-up of the committee and sub-committees and in particular, the inclusive nature of the sub-committees. Also that a commitment is contained within the programme to continue with the sub-committees dealing with Traveller accommodation provision and the management and maintenance of Traveller sites.

 Response: The section within the proposed Traveller Accommodation Programme has been amended to reflect these comments.

 Issue: CTDG raise a number of queries in relation to policy issues.

 ·        Need for a more detailed policy statement in relation to those Travellers who receive medical priority for accommodation and that South Dublin County Council continue to pursue the social model of disability in supporting Travellers who reside on halting sites and wish to continue to do so.

·        Response: The Council remains committed to pursuing the social model of disability, where it is practicable. However, regard must also be had to medical advice. The Council will discuss with any Traveller family who has received medical priority what options are available. As stated previously in this report, The Council will identify those Travellers who have received medical priority and put together a specific programme to identify what specific works are required and to identify funding streams to finance the works.

 ·        That acknowledgment is made within the programme of the openness of the Local Traveller Accommodation Consultative Committee in addressing some of the more difficult and challenging issues around Travellers and their accommodation needs.

 ·        Response: The section of the proposed programme dealing with the Local Traveller Accommodation Consultative Committee has been amended to reflect the comments submitted.

 ·        The appropriateness of the statement within the proposed programme that it is the policy of the Council to provide accommodation to Travellers who are indigenous to South Dublin.

·        Response:A core aim of the proposed Traveller Accommodation Programme is to provide for the future accommodation needs of Travellers within South Dublin. The use of an 'indigenous clause', i.e. those families who have been resident in the county for at least three years prior to the adoption of South Dublin County Council's Traveller Accommodation Programme 2014 – 2018, allows the local authority to plan what numbers of houses/bays will be required throughout the programme. The Department of the Environment, Community and Local Government, have stated in circular letter TAU 4/2009, that the High Court has held that the inclusion of an indigenous clause within a Traveller Accommodation Programme comes within the statutory power of a housing authority, as long as the indigenous policy is not applied so rigidly as to become an effective bar to a member of the Traveller community being considered for accommodation by a housing authority.

 ·        Expansion on what, other than the provision of residential caravan bays, the Council can provide to Travellers to accommodate them in a culturally appropriate way catering for their social needs in respect of issues such as nomadism, economic activities, horse ownership etc.

-       Response: The Council's method of providing culturally appropriate accommodation to Travellers catering for their social needs to date has been the provision of Traveller specific accommodation schemes, many of which combine group housing with caravan bays. Many of the sites have an identified community centre, which are used to provide services such as breakfast and homework clubs for children, internet access, meeting rooms etc. The Local Traveller Accommodation Consultative Committee is the appropriate forum to discuss what other measures can be taken by South Dublin County Council to provide culturally appropriate accommodation catering for the social needs of Travellers. 

The issue of horse ownership is covered by Legislation including the Control of Horses Act 1996 and the Council's Control of Horses Bye-Laws 1997

 Summary

 The proposed programme seeks to build on the progress and success of previous Traveller Accommodation Programmes adopted by this Council and continue to provide safe, vibrant, inclusive communities. The proposed programme focuses not just on the provision of new units to meet projected future demand, but also the building of communities within existing Traveller specific developments in order to maintain and improve those sites for the residents.

 The proposed Traveller Accommodation Programme 2014 – 2018 is recommended for adoption by the elected members.