CIH NI response to the DfC's equality assessment consultation on Anti-Social Behaviour Housing Proposals

We're pleased to be able to respond to the Department for Communities equality assessment consultation on behalf of our members. You can read our full response the questionnaire below.

Are there any data, needs or issues in relation to any of the Section 75 equality categories that have not been identified in Section 2 of the EQIA consultation document?

Yes

Are there any adverse impacts in relation to any of the Section 75 equality groups that have not been identified in section 3 of the EQIA consultation document?

Yes

Please state what action you think could be taken to reduce or eliminate any adverse impacts in the proposals to amend housing legislation in relation to Anti-Social Behaviour

CIH Northern Ireland welcomes the proposed changes to legislation aimed at tackling anti-social behaviour (ASB) in housing. We believe that ASB can have a significant negative impact on people's lives and local areas, and support measures that aim to address these issues effectively. We also welcome the opportunity to respond to this public consultation on the draft equality impact assessment (EQIA) regarding the changes.

We support the proposed mitigation measures outlined in the consultation document, which demonstrate a commitment to promoting equality and inclusivity while addressing the impacts of ASB on vulnerable groups. The emphasis on updating departmental guidance for housing providers to highlight the importance of signposting individuals to independent support services is vital to ensuring tailored and effective support. Specifically, measures targeting young people will help provide accessible and equitable support for those at risk of engaging in or being affected by ASB.

Updated guidance to assist housing providers in identifying domestic violence and signposting people to appropriate resources is another crucial step. Combined with outreach initiatives, these measures will enhance safety and provide critical pathways for those at risk. Similarly, the proposals to support people with disabilities, including tailored programmes addressing specific needs such as physical or sensory disabilities, substance dependency or learning difficulties, will further strengthen vital safety nets.

In addition to the above, CIH Northern Ireland believes that housing staff should be properly trained in:

• Identifying issues relating to domestic abuse
• Awareness of situations where individuals with mental health or learning disabilities may be perceived as both perpetrators and victims of ASB
• Recognising and addressing potential biases
• Ensuring that support services are accessible to all individuals, including those with disabilities, mental health challenges and those facing language barriers.

We also recommend development and implementation of effective referral routes to ensure timely support for residents from relevant services.

It is important to acknowledge the complexity of equality considerations related to ASB, particularly its disproportionate impact on vulnerable groups protected under Section 75. As highlighted in our original submission, people with disabilities are more likely to experience ASB, exacerbating the challenges they already face. Similarly, minority groups, including those defined by race, sexual orientation and gender identity, often encounter additional barriers to accessing safe housing and community environments. These points underscore the necessity of inclusive and tailored approaches to tackling ASB effectively.

We welcome the EQIA’s findings, which highlight the potential benefits of the proposed policy for several marginalised groups. The EQIA recognises that the policy could positively impact people with disabilities by addressing ASB in ways that reduce barriers to safe and secure housing.

The EQIA also identifies benefits for people experiencing housing-related race incidents, as noted on pages 17 and 52. By acknowledging and addressing the specific vulnerabilities of racial minorities, the proposed measures can help mitigate the disproportionate effects of ASB on these communities and foster equitable access to safe housing.

Furthermore, the document’s acknowledgment of housing-related hate crimes faced by LGBTQ+ individuals, as referenced on page 53, is important. Hate crime incidents in or around the home significantly undermine people’s sense of safety and belonging. It is essential that the proposed measures prioritise inclusive practices, robust protections and effective enforcement to combat such incidents.

We are pleased to see the EQIA’s alignment with our original points regarding the importance of empowering housing providers with the tools and guidance necessary to identify and address ASB inclusively. By doing so, the policy not only reduces the prevalence of ASB but also contributes to creating safer, more cohesive and equitable communities for all.

Concurrently, CIH will continue to promote early intervention and preventative measures to address the root causes of ASB through good housing practice.