In light of the publication of the Department of Housing, Planning and Local Government (DHPLG) submission to the Advisory Group on Direct Provision, Nasc would like to respond to some of the key concerns raised therein. As has been repeatedly stated, both in the Day Report itself, and by Nasc – for the new accommodation system to be successful, the international protection application and appeal system need to function efficiently.
Misunderstanding
The underlying objection in the DHPLG is that “[t]he draft proposals include obtaining accommodation in the private rental market for an existing cohort of 7685 residents of Direct Provision centres as well as 3,500 further new arrivals per annum for the duration of their application processes.”
This predicated on a fundamental misunderstanding of the recommendations contained in the Day Report which stresses the need for the new system to begin without any legacy cases.
Firstly, the Advisory Group structured its housing recommendations based on a decision-making process that is concluded within faster, fixed time limits. It recommends legally binding deadlines of 6 months for a first instance decision on an asylum application and 6 months for an appeal to the IPAT. Secondly, the Advisory Group allowed for a transition time of 2 ½ years to phase in the new permanent system. This transition time would allow the State to ensure that staffing and funding are in place to meet these new deadlines and that would also allow the State to take a one-off approach to clear the current backlog of cases and ensure that the new system takes effect in mid-2023 unencumbered by legacy cases. This transition time would also give local authorities 2 ½ years to find housing solutions.
The DHPLG submission further states that the recommendations in the Day Report would require them to provide “provide own door accommodation for 3,500 households per annum”. This figure is also inaccurate. The Day Report estimates 3,500 new international protection applicants per year however 38% of existing applicants for international protection are family units and 27.4% of the current population in direct provision are minors. This represents significantly fewer than 3,500 households per annum. It is also important to clarify that the accommodation to be provided to protection applicants is temporary in nature and confers no right or access to social housing to international protection applicants.
“International protection applicants have been coming to Ireland for decades and will continue to do so in the future. We must accept this fact and build a permanent system to provide for their reception and other needs. International protection applicants are a predictable and expected part of the Irish State and housing policy should reflect this"
Nasc CEO, Fiona Finn
Local Authority Housing
The submission goes on to criticise the draft Day Report for failing to provide an “explanation to reconcile how housing stock provided through funding voted through appropriation accounts and approved as such by the Oireachtas for the provision of social housing would be transferred to another cohort without prior approval by the Oireachtas.”
The simple answer to this is that the report does not require this. The Day Report specifically recommends that additional and ring-fenced funding be provided to the Department of Housing to precure temporary housing for international protection application:
“Dedicated, ring-fenced funding should be provided to local authorities, on a statutory basis, specifically for housing for protection applicants through the Department of Housing, Local Government and Heritage.”
Local authorities have a very wide discretion as to how they would like to provide accommodation in their area and the report acknowledges the fact that a blend of different options will be required in the short to medium term.
Integration not segregation
“The accommodation model proposed by the DHPLG is not a workable solution. Clustered, high density facilities outside of the community, whether owned by the State or by private practitioners, are a more palatable version of direct provision. The Day Report offers a solution that focuses on integration rather than segregation.”
Nasc CEO Fiona Finn
ENDS