Irish Traveller Movement Submission to Draft Wicklow County Development Plan 2021-2027

Recommendations for Wicklow County Council Development Plan

• Traveller specific accommodation developments completed under the last development plan period should be outlined in the Development Plan.
• It is notable that Wicklow County Council’s draft chapter on housing, Chapter 6, makes no reference to Traveller Accommodation, or to the local authority’s statutory obligations under the Housing (Traveller Accommodation) Act 1998. These should be included in the next iteration of the 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 lifespan of the development plan, consideration should also be given for how sites will be identified for 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.

• 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 all prospective residents, including children and young people, 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. This 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.  
• We support the recommendations made by local Traveller organisations in calling for the establishment of tenancy sustainment services, and the allocation of a permanent space for the Bray Travellers Community Development Group to be included in this plan.
• Wicklow 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.
• 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 MABS 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 living on halting sites is broader than the energy efficiency of the mobile or trailer. It 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.
• Traditionally the provision of energy (electricity and natural gas) to Traveller specific accommodation has been problematic. On some halting sites payments are paid directly to the local authority and not to the energy provider.  Many families report not getting an accurate energy bill, not getting detailed breakdowns of energy usage and not being in control of their energy costs. National policy on the provision of cheaper energy is to rely on the competitive market, encouraging consumers to shop around to get the best value. In instances where the local authority directly provides energy to halting sites, Travellers are excluded from the market and do not have access to cheaper deals consequently paying more for their energy costs. The other thrust of national energy policy is to create access to sustainable and affordable energy and to provide energy efficient homes through various programmes which are overseen by the Sustainable Energy Authority of Ireland.  There is little evidence of Travellers having access to any such programmes despite existing government policy to target the most energy poor.
• The European Union (Energy Performance of Buildings) Regulations came into force on 1 November 2019 and are given effect through amendments to Part L of the Building Regulations. This requires that newly-built homes be close to zero energy buildings (NZEB).

• Such new homes will typically be required to achieve a minimum Building Energy Rating (BER) of A2. Existing accommodation or homes undergoing major renovations, defined as at least 25% of the building surface area, are now required to achieve BER B2 or equivalent.

• Under current regulations all planned new residential dwellings are expected to be 70% more energy efficient when compared to 2005 performance requirements.

• 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.
• Given the high levels of energy poverty amongst Travellers living in Traveller specific accommodation we urge the council 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.
• 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 local authorities’ strategy to implement the relevant recommendations of the Irish Human Rights and Equality Commission’s recent Equality Reviews of local authority provision of Traveller accommodation.

Many thanks for your consideration of these issues.