Advance sharing in housing, while ensuring that objectively assessed housing need is met
Supporting rationale
The Commission restates its view on the value of shared housing and that segregated housing in Northern Ireland is not the way forward for our society. We also recognise that people need to feel safe where they live, and considers that actions are needed to encourage and incentivise integration.
While reiterating the importance of ensuring that housing demand is met on the basis of objectively assessed need, actions which advance sharing in housing could also serve to expand housing markets; increase opportunities to meet objectively assessed housing need; and sharing more generally in Northern Ireland.
We recommend actions designed to incentivise and advance safe, shared housing and communities based on equality, dignity and respect.
The Commission considers that actions to advance sharing should also extend beyond a narrow focus on community background. We reiterate our recommendations that the focus of actions to advance sharing should be across all Section 75 grounds; and across a range of public policy domains. Shared communities should include shared housing, as well as shared education, employment, shopping and places of leisure.
As set out in our 2013 Submission to the Panel of Parties (Haass) we highlight the importance of political leadership and recommend the regulation of the display of flags, based on the principles contained in the Flags (NI) Order. We recommend a range of steps to facilitate expressions of identity in a sensitive and non-divisive manner, while also recommending consideration of the extent to which flags and emblems on private property increase community tensions and discourage the two communities from sharing public spaces.
We recommend that the Government makes clear how progress in this area will be tracked (including for all Section 75 categories). We also continue to recommend that the Programme for Government include an additional indicator to track progress in securing increased sharing in housing.
Implement specific long-term measures to eliminate discrimination and intimidation; tackle prejudicial attitudes; and promote values of acceptance and respect for difference
Supporting rationale
Access to adequate and sustainable housing will be maximised where families and individuals from across the Section 75 grounds are able to feel safe in their homes and communities.
We recommend that the programme of work for Government includes priority actions to challenge prejudicial attitudes, behaviour and hate crime, to ensure that public spaces, communities, workplaces and services are free from intimidation, harassment and / or discrimination across the equality grounds.
We reiterate our recommendations to ensure prompt implementation of existing and awaited equality and good relations strategies through comprehensive, measurable, monitored and evaluated action plans. These include the strategies on Race, Sexual Orientation, Disability, Gender and Age.
The Commission is also of the view that sharing in education provision has a key role to play in advancing cohesion, sharing and integration across all equality grounds. We consider that ‘education has a role in shaping an individual’s views, their conduct, their relationships with others, and it has the potential to counter negative images and views that they can be exposed to outside of a school’.
Further tackle the under-reporting of hate incidents and crimes (against persons and dwellings), and increase outcome rates
Supporting rationale
We welcome the Northern Ireland Policing Board’s thematic reviews in relation to transphobic and homophobic, and racist hate crime and recommend that actions are taken by the PSNI to ensure the full implementation of outstanding recommendations. We recommend detailed follow-up work to track the effectiveness of these actions, including to report on positive progress and/or identify key lessons.
In relation to detection, we repeat our recommendation, as per the 2010 Criminal Justice Inspectorate report, that there should be joined up data to track the progress of hate crimes through the criminal justice system. This would allow for better analysis of how such cases are dealt with and identify areas where remedial action is required.
Address the fear of crime among older people
Supporting rationale
Actions must not only focus on tackling crime but also the perception of the prevalence of crime against older people. While a number of strategies exist to reinforce actual and perceived safety, evidence suggests that delivery is dependent on adequately resourced and targeted actions across Government policy. Delivery of commitments within action plans is therefore essential.
We reiterate our 2017 recommendation that the Programme for Government should include a commitment to take actions to address the fear of crime amongst older people. We further recommend the adoption of specific outcomes and associated measures towards tackling the fear of crime amongst older people.
Ensure application of accessible housing standards to all new builds
Supporting rationale
We consider that more needs to be done to ensure that all new builds in private tenures comply with accessible standards, so as to better facilitate individuals to secure a home and remain in it. We note recognition within proposed government policy of the need to increase the provision of accessible homes. Over time, the universal application of accessible standards would significantly reduce the need for formal care services and costly home adaptations in the future.
The Lifetime Homes Standard uses a set of 16 design criteria to build homes that are inclusive, accessible and adaptable. It is complemented by wheelchair standard housing ‘the designs of which have been evolving to meet the needs of assisted wheelchair users and carers’. The 2013 Interdepartmental Review of Housing Adaptations wheelchair dwellings’.Services states that ‘Lifetime homes standards have limitations when needs become more complex and therefore some people may require the use of purpose designed.
Provide information regarding the availability of accessible accommodation
Supporting rationale
Accessible housing is most likely to be found within social housing. However, NIHE’s 2012 Audit of Inequalities notes ‘anecdotal evidence suggests that demand may be rising [within the private rented sector] as more people find themselves in inaccessible private rented property, either because of the shortage of social housing, or because they cannot afford / get a mortgage to purchase a property’
We note and welcome that an interim accessible housing register for social housing is live and that a rolling programme is planned to increase its coverage including to housing association stock and private accommodation.
Ensure the provision of easy to access and affordable adaptation services across all tenures - including by streamlining existing processes and reducing waiting times
Supporting rationale
A person with disabilities may require adaptations to their existing or prospective home. We note recognition within the draft departmental plans of the need to streamline the adaptations and disabled grants process to reduce waiting times. We consider that ensuring the availability of housing adaptations is essential, not least given the emphasis within government policy - particularly Transforming Your Care - on the delivery of social care within the home.
We recommend that support for adaptations should be available across tenures, and easy to access - in terms of using the service, speed of delivery, and cost. We welcome the NIHE’s 2018 commitment to ‘streamline the adaptations and disabled grants processes to reduce waiting times for housing adaptations…’. We also recommend that action is taken to reduce waiting times for occupational therapy assessments in support of requests for housing adaptations.
Extend the Disability Discrimination Act to include reasonable adjustments to communal areas in residential properties
Supporting rationale
Currently under the disability discrimination legislation, landlords and managers of rented residential premises must make reasonable adjustments to the disabled person’s home. In addition, they cannot unreasonably refuse permission for disability-related alterations to be carried out. Landlords however are not required to make disability-related alterations to the physical features of the common parts of let residential premises, such as stairs and hallways; even if they are reasonable to make and paid for by a disabled tenant.
We recommend that the disability discrimination legislation is extended to require landlords to make disability-related alterations to the physical features of the common parts of residential properties, such as stairs and hallways.
Ensure access to adequate, sustainable and long-term independent living provision for all people with disabilities for whom it is a viable housing option
Supporting rationale
Article 19 (the right to live independently) of the UN Convention on the Rights of Persons with Disabilities makes clear that disabled people have the right to determining how to live their own lives, particularly with respect to personal decisions regarding their living arrangements, including with respect to personal care and support. We welcomed the 2017 draft PfG delivery plan acknowledgement of the need for cross cutting actions, including improving independent living and the provision of suitable homes for people with disabilities
We recognise the importance of the Supporting People programme in supporting individuals to live independently. A 2016 action plan identified 13 recommendations following a review of the programme. We encourage their urgent implementation, particularly as regards how they address the barriers to independent living as set out above.
We note that proposals for changes to the adult social care system are still awaited. We reiterate our recommendation to the 2013 consultation on the future of adult social care, that ‘any new social care model must ensure that disabled people are free to choose the type of assistance they require to support a good quality of life and prevent isolation and social hardship’. We also reiterate the importance of ensuring that any transition to the mixed economy model of private and community / voluntary care providers will not result in a diminution of health and social care services in particular for marginalised and excluded groups such as disabled people, older people and carers.
Further advance energy efficiency and expand oil buying clubs across all tenures.
Supporting rationale
While progress has been made, including improvements in energy efficiency through the Affordable Warmth Scheme and the requirements of an Energy Performance Certificate, addressing fuel poverty should remain a priority for action, as highlighted in the Active Ageing Strategy 2016 – 2021.
In addition to further advancing energy efficiency oil buying clubs, open to all tenures, should be promoted and expanded to allow the group purchase of fuel at more competitive rates than is possible by individual households..
Ensure the availability of suitable accommodation and services for homeless single males; younger and older people; and refugees and unsuccessful asylum seekers
Supporting rationale
We note the multi-faceted nature of homelessness, including for those who are vulnerable and/or with complex needs. In light of the prevalence of complex needs, the provision of support services is a crucial factor.
We welcome the ongoing work by the NIHE and others in this regard, and recommend it focuses on the specific needs of individuals from across the equality categories. This should include with regard to those placed in private sector accommodation, for whom the support services (which social housing and hostel accommodation can provide) may not be available.
Single males
Single male reference person households continue to be more likely than single female reference person households to present as homeless to the Northern Ireland Housing Executive (NIHE).
Due to the pressures on social housing, and a relative lack of one-bedroom properties in Northern Ireland, males, if accepted as homeless, are likely to be housed in temporary hostel accommodation on a longer term basis, which may not be appropriate. We recommend action to ensure the provision of accommodation appropriate to the needs of this group, providing appropriate support as required.
Young people
Young people (aged under 35) entitled to the housing element of Universal Credit have been negatively affected by Welfare Reform measures, as regards their ability to secure and sustain private rented sector accommodation, in the absence of available social housing. We continue to call for a review of the impact of Welfare Reform measures on this age group. This impact is manifested in pressures on meeting the shortfall between benefits and rent.
Older people
Although older people aged 60 and over account for only 10% of homeless presentations, 74% of acceptances within this group are due to current accommodation being unreasonable. This trend is increasing over time. The NIHE attributes this to, among other things, our ageing population and instances of complex needs such as disability. Our consideration of housing grants and adaptation services elsewhere in this paper sets out recommendations as regards physical accessibility. It recommends the provision of easy to access and affordable adaptation services across all tenures.
Refugees and unsuccessful asylum seekers
Particular issues arise for individuals from minority ethnic groups (MEG) who are resident in Northern Ireland as refugees and asylum seekers. While those who have been unsuccessful in their asylum application have no right to any accommodation support, refugees do have entitlement. We recommend the provision of appropriate culturally sensitive accommodation for those groups eligible for services. For those currently ineligible, we recommend the provision of suitable emergency accommodation. We note the scheme being provided by Choice, PPR and others which uses privately held housing stock and services from the other partners to provide accommodation and support services to destitute unsuccessful asylum seekers.
Address the longer waiting-list times for social housing experienced by households with a Catholic religion household reference person
Supporting rationale
We reiterate the importance of ensuring that housing need is met on the basis of objectively assessed need. Where stock availability (supply-side factors) differs from individual housing needs and preferences (demand-side factors), longer waiting lists can ensue. In Northern Ireland, this has a particular impact on households with a Catholic religion household reference person.
Analysis of access to social housing in Northern Ireland should take into account a range of factors which shape supply and demand. For example, generally applicable issues of residential preferences, personal safety, particular housing needs, and the availability of appropriate housing stock and/or development land in specific areas must also be considered in the context of segregated residential patterns in Northern Ireland.
On the supply-side, we recommend action to consider for example, how appropriate stock and land for development can be made available to ensure that objectively assessed housing need is more effectively met in areas of high demand. On the demand-side, steps which might both widen areas of preference for those in housing need and sharing more generally could serve to expand housing markets and increase opportunities to both meet objectively assessed housing need and advance increased sharing. We also recommend joint working, including with those working and living within communities, so as to further build trust and confidence between divided communities.
Ensure that the accommodation needs of Travellers are met, in consultation with the Traveller community
Supporting rationale
While some progress has been made, access to appropriate accommodation to meet the needs of Irish Travellers remains limited. The Commission continues to advocate the need for an adequate programme of accommodation to meet the cultural needs of the Irish Traveller community and remains concerned by the lack of progress in securing planning permission for sites in the areas identified as most in need in the NIHE Traveller Accommodation Needs Assessment. It concluded that ‘net housing need is … a much more complex calculation … and will be undertaken by Strategic Partnerships in consultation with the Traveller community’. We welcome the commitment to ensure the involvement of the Traveller community, and to take specific steps to assess Traveller need.
The Traveller Accommodation Needs Assessment also indicated that around one-fifth to one-third of all Irish Traveller households still travel. It therefore remains important that the provision of accommodation is such that it continues to cater for those who wish to have a nomadic lifestyle. Indeed, as noted in Wallace, for some Irish Travellers, ‘bricks and mortar’ accommodation may be inappropriate where it does not accord with their nomadic lifestyle.
Furthermore, there is a lack of recent research with regard to the general levels of adequacy of specific types of sites - including for those beyond the management of the NIHE. Consideration should therefore be given to the extent to which such factors persist, and if so, any prevalence within certain types of accommodation and/or tenures.
We note that the NIHE is undertaking a further Traveller Accommodation Needs Assessment, and look forward to its implementation and outworking giving effect to our recommendation. We welcome that the assessment will seek respondents’ views on their awareness of the accommodation choices available to them.
Ensure greater awareness of the rights, responsibilities and housing options relevant to minority ethnic groups
Supporting rationale
Research suggests there is potentially limited awareness of rights and/or limited accommodation choices available to migrants and minority ethnic groups. Furthermore, these groups may lack a wider network of family and friends with knowledge of the Northern Ireland housing market, which would enable them to make better informed choices. Our Statement on Key Inequalities in Housing and Communities noted that migrant workers were often at risk of being subject to ‘tied accommodation’ with poor conditions and overcrowding. Greater awareness of rights and the market could act to empower potential tenants to explore the full range of options open to them.
Such information should be provided in methods and formats accessible to the identified audience both in terms of language and dissemination channels. We further recommend that frontline staff (including those from the NIHE, Housing Associations and advice centres) are trained on the entitlements of EU and other migrants to benefits and more broadly on the rights and responsibilities of refugees and asylum seekers. We also reiterate our recommendation that government should take account of the need to provide support and advice to asylum seekers as regards emergency and subsequent accommodation.
Ensure that older people of differing sexual orientations and transgender people have their domiciliary, residential or nursing care needs fully met
Supporting rationale
Older lesbian, gay and bisexual (LGB) and transgender people can have different family support networks to the wider population and thus potentially differing needs for domiciliary, residential or nursing care support when compared to heterosexuals. In addition, older LGB and transgender people’s experience of growing up in Northern Ireland may make them more reluctant than others to disclose their sexual orientation, sex, gender or medical history.
To better meet these needs, healthcare workers providing domiciliary, residential or nursing care, should receive specific training in the provision of intimate care for these groups and in the needs and sensitivities of LGB and transgender people. Further any decisions on care plans and in the sharing of information between medical facilities and/or care providers should include the full involvement of the care recipient.
Trusts should ensure there is sufficient capacity to care for permanent care home residents (where they wish it), and that they provide for all older residents requiring care and support
Supporting rationale
Should the Department of Health’s plans proceed to reduce residential accommodation for older people it will be vital that older residents are assured that they will receive the same level of care and support in alternative accommodation. If the plans proceed, we also recommend the mandatory inclusion of an assessment of the quality and services available in alternative care options. Compliance with the best practice guide ‘The Reconfiguration of Statutory Residential Homes’ on the role of advocacy and the importance of infrastructure is recommended.
Understand the accommodation needs, preferences and expectations of older people
Supporting rationale
The demographic trend of an ageing population is contributing to an increase in demand for support services and specialised housing in old age. However it is also the case that sheltered housing has become less attractive to fit, active older people.
Research into housing needs and preferences, and geographical patterns of need may assist the Northern Ireland Housing Executive; Housing Associations; and the nine councils in assessing the demand and supply needs for future social housing. The NIHE has advised that it is undertaking research to this effect. We welcome this development and look forward to its publication and implementation of findings.
Ensure that the mitigation of negative impacts of Welfare Reform continues on a long-term basis
Supporting rationale
While noting the mitigations package put in place in Northern Ireland to cushion the impact of Welfare Reform implementation, and concessions around payments, the Commission is concerned at the long-term implications of the measures on a number of equality groups. We are concerned that the Welfare Reform mitigation measures are of a temporary nature ranging from one year (e.g. mitigation for those who lose out as a result of the transfer from DLA to PIP) to four years (e.g. spare room subsidy/bedroom tax).
In 2015 the United Nations published findings of its Inquiry which highlighted the disproportionate and adverse impact of Welfare Reforms on disabled people across the UK, including with regard to financial hardship: rent arrears, debts, evictions and cuts to essentials such as housing and food.
The Commission continues to urge implementation of long-term mitigation measures to ensure that vulnerable groups are protected from the adverse impact of Welfare Reform.
Address the needs of single tenants / prospective tenants aged 35 years and under when renting in the private rented sector
Supporting rationale
Single people aged 35 years old and under are entitled only to a shared accommodation rate of the housing element of Universal Credit. This is lower than the full rate. Research to date has been of small scale but found that since the changes came into force around one in ten landlords no longer rent to under 35 year old single people.
Furthermore, over one third of landlords participating in that research stated that they might cease letting to Local Housing Allowance single tenants under the age of 35. The Commission continues to recommend the introduction of comprehensive legislation to make unlawful any unjustified age discrimination in the provision of goods and services - including in the provision of accommodation.
In 2015/16 the Department consulted on a discussion document on a review of the role and regulation of the private rented sector. It subsequently consulted on proposals for change. It included proposals around rent increases permissible, giving housing associations a role in the private rented sector and improving information provision requirements. We welcome the commitment within the draft PfG delivery plan to develop affordable housing solutions to meet the needs of single people aged under 35 on benefits, and look forward to the prompt implementation of related actions.
Tackle the barriers which the ‘digital by default’ and telephone advice system of benefits may present to those within some Section 75 categories
Supporting rationale
With the provision of government services moving increasingly to ‘digital by default’ (whereby information provided and accessed by individuals is online), safeguards are necessary to ensure that those within Section 75 groups receive their full entitlement to benefits.
Particular issues may arise for those who do not have access to the internet, or who may require assistance to provide the range of information required.
Furthermore, the Office for National Statistics (ONS) has reported (2018) that the reliance upon online and telephone contact with government benefits staff rather than face to face contact has been found to be problematic for some claimants.
Improve equality data collection and analysis
Supporting rationale
Address key equality data gaps across a number of areas of public policy. Comprehensive equality data is necessary to shape, refine and evaluate the impact of strategies, programmes and policies. There remained significant data gaps across a number of areas and themes, specifically: gender identity; religion; political opinion; and sexual orientation. We reiterate our recommendation that government should ensure, including via Programme for Government outcomes and indicators, that it tracks outcomes both in aggregate, and across the full range of Section 75 equality categories.
With regards to draft PfG delivery plans (December 2016) we restate our view that the indicator ‘number of households in housing stress’ should collect data and also report progress by Section 75 category. It is our general view that data should be collected across all Section 75 grounds, across all relevant actions. We note that while data is collected by gender, age, marital status and religion, it is not available by disability, sexual orientation, race, and having dependants. The Commission recommends action to fill significant and specific data gaps in relation to a number of equality grounds.
Ensure data is sufficiently disaggregated to allow for meaningful equality analysis, to better inform public policy intervention
Supporting rationale
In housing, there is a lack of data disaggregation in relation to: ethnicity; disability status; marital status; and, dependency status. For example, key housing datasets offer limited detail with regard to data on minority ethnic groups and migrants. Instead, any analysis must often rely on small scale surveys and qualitative data. These shortfalls limit the ability to draw robust conclusions about inequalities, and/or progress in addressing the same, across the full range of equality categories and groups.