ࡱ> eg`abcd5@ bjbj22 XXN4`DDDD,o,o,oo8q} @sx"xxxy<<5        $SR" Dyy DDxx BJDxDx  2&~DD* x4s Л4f@,o0z XJ D r}  X* DDDDD*  U mZ ǭ|C[ UUU  T,o",o Homeless Persons Legal Clinic UN Special Rapporteur on Adequate Housing: Questionnaire on Women and Adequate Housing An Australian Submission Coordinated by Dianne Otto Associate Professor Faculty of Law The University of Melbourne Philip Lynch Coordinator Homeless Persons Legal Clinic Public Interest Law Clearing House UN Special Rapporteur on Adequate Housing: Questionnaire on Women and Adequate Housing An Australian Submission October 2002 Philip Lynch Dianne Otto Homeless Persons Legal Clinic Associate Professor Public Interest Law Clearing House Faculty of Law Level One, 550 Lonsdale Street The University of Melbourne Melbourne 3000 AUSTRALIA Parkville 3010 AUSTRALIA Tel: + 61 3 9225 6684 Tel: + 61 3 8344 4063 Fax: + 61 3 9225 6686 Fax: + 61 3 9349 4287 Email:  HYPERLINK "mailto:projects.pilch@vicbar.com.au" projects.pilch@vicbar.com.au Email: d.otto@unimelb.edu.au Acknowledgements We would like to acknowledge the contributions of the following people from Clayton Utz, Allens Arthur Robinson and Minter Ellison to this submission: Paul Coady - Articled Clerk, Clayton Utz Jacqueline Cole - Solicitor, Clayton Utz Lucy Cole - Articled Clerk, Minter Ellison Amanda Jones - Articled Clerk, Clayton Utz Jacky Mandelbaum - Solicitor, Allens Arthur Robinson Charissa Mitsikas - Solicitor, Allens Arthur Robinson Marc Testart - Articled Clerk, Minter Ellison Sophie Waller - Articled Clerk, Minter Ellison Dana Wintermantel - Solicitor, Allens Arthur Robinson We would also like to thank: Chris Haan - Research Assistant, The University of Melbourne Beth Midgley - Research Assistant, The University of Melbourne CONTENTS  TOC \o "1-3" \h \z  HYPERLINK \l "_Toc23845863" PREFACE  PAGEREF _Toc23845863 \h 4  HYPERLINK \l "_Toc23845864" Summary and Findings  PAGEREF _Toc23845864 \h 5  HYPERLINK \l "_Toc23845865" 1. Introduction: The Right to Adequate Housing in Australia in Context (Question 6)  PAGEREF _Toc23845865 \h 8  HYPERLINK \l "_Toc23845866" 2. The Constitutional, Legislative and Policy Framework for the Right to Adequate Housing in Australia (Questions 1 and 2)  PAGEREF _Toc23845866 \h 10  HYPERLINK \l "_Toc23845867" 2.1 Constitutional and Legislative Implementation of the Right to Adequate Housing  PAGEREF _Toc23845867 \h 10  HYPERLINK \l "_Toc23845868" 2.2 The Human Rights and Equal Opportunity Commission  PAGEREF _Toc23845868 \h 13  HYPERLINK \l "_Toc23845869" 2.3 National Womens Machineries  PAGEREF _Toc23845869 \h 14  HYPERLINK \l "_Toc23845870" 2.4 Legal Aid and Remedies  PAGEREF _Toc23845870 \h 15  HYPERLINK \l "_Toc23845871" 3. Anti-Discrimination Legislation (Question 3)  PAGEREF _Toc23845871 \h 16  HYPERLINK \l "_Toc23845872" 3.1 Sex Discrimination Act 1984 (Cth)  PAGEREF _Toc23845872 \h 16  HYPERLINK \l "_Toc23845873" 3.2 Racial Discrimination Act 1975 (Cth)  PAGEREF _Toc23845873 \h 17  HYPERLINK \l "_Toc23845874" 3.3 Disability Discrimination Act 1992 (Cth)  PAGEREF _Toc23845874 \h 19  HYPERLINK \l "_Toc23845875" 3.4 Remedies and Complaint Mechanisms: Human Rights and Equal Opportunity Commission  PAGEREF _Toc23845875 \h 20  HYPERLINK \l "_Toc23845876" 3.5 Conclusion  PAGEREF _Toc23845876 \h 21  HYPERLINK \l "_Toc23845877" 4. Housing Situation of Women in Particularly Vulnerable Groups (Question 4)  PAGEREF _Toc23845877 \h 21  HYPERLINK \l "_Toc23845878" 4.1 Women Escaping Domestic Violence  PAGEREF _Toc23845878 \h 21  HYPERLINK \l "_Toc23845879" (a) Priority Public Housing  PAGEREF _Toc23845879 \h 22  HYPERLINK \l "_Toc23845880" (b) Limited Emergency Temporary Accommodation  PAGEREF _Toc23845880 \h 23  HYPERLINK \l "_Toc23845881" (c) Some Problems with Womens Refuges/Shelters  PAGEREF _Toc23845881 \h 23  HYPERLINK \l "_Toc23845882" (d) Inadequate Other Emergency, Transitional and Supported Accommodation  PAGEREF _Toc23845882 \h 25  HYPERLINK \l "_Toc23845883" (e) Lack of Longer term Housing Options  PAGEREF _Toc23845883 \h 25  HYPERLINK \l "_Toc23845884" 4.2 Indigenous Women  PAGEREF _Toc23845884 \h 26  HYPERLINK \l "_Toc23845885" (a) Inadequate Housing Provision  PAGEREF _Toc23845885 \h 28  HYPERLINK \l "_Toc23845886" (b) Land Rights  PAGEREF _Toc23845886 \h 28  HYPERLINK \l "_Toc23845887" 4.3 Migrant and Refugee Women  PAGEREF _Toc23845887 \h 29  HYPERLINK \l "_Toc23845888" 4.4 Women in Rural and Regional Australia  PAGEREF _Toc23845888 \h 30  HYPERLINK \l "_Toc23845889" 4.5 Women with Disabilities  PAGEREF _Toc23845889 \h 31  HYPERLINK \l "_Toc23845890" 4.6 Single Mothers  PAGEREF _Toc23845890 \h 32  HYPERLINK \l "_Toc23845891" 4.7 Young Women  PAGEREF _Toc23845891 \h 34  HYPERLINK \l "_Toc23845892" (a) Public Housing  PAGEREF _Toc23845892 \h 34  HYPERLINK \l "_Toc23845893" (b) Private Rental  PAGEREF _Toc23845893 \h 35  HYPERLINK \l "_Toc23845894" (c) Community Housing  PAGEREF _Toc23845894 \h 36  HYPERLINK \l "_Toc23845895" (d) Refuges and Shelters  PAGEREF _Toc23845895 \h 36  HYPERLINK \l "_Toc23845896" 4.8 Older Women  PAGEREF _Toc23845896 \h 36  HYPERLINK \l "_Toc23845897" 5. Women and Security of Tenure (Question 10)  PAGEREF _Toc23845897 \h 37  HYPERLINK \l "_Toc23845898" 5.1 Family Law and Security of Tenure  PAGEREF _Toc23845898 \h 37  HYPERLINK \l "_Toc23845899" 5.2 The Residential Tenancies Legislation  PAGEREF _Toc23845899 \h 39  HYPERLINK \l "_Toc23845900" 6. Affordability of Housing (Question 15)  PAGEREF _Toc23845900 \h 41 PREFACE This submission responds to a questionnaire on Women and Adequate Housing, prepared by the United Nations Special Rapporteur on Adequate Housing. The purpose of the questionnaire is to solicit information on the topic of women and housing, in preparation for a more detailed study. The Special Rapporteur was requested to undertake the study by the UN Commission on Human Rights in April 2002. Pursuant to Resolution 2002/49, entitled Womens equal ownership of, access to and control over land and the equal rights to own property and to adequate housing, the study will be submitted to the Human Rights Commission at its next session in 2003. The preparation of the submission has been jointly coordinated by Philip Lynch, coordinator of the Homeless Persons Legal Clinic of the Public Interest Law Clearing House (PILCH), and Associate Professor Dianne Otto, chief investigator of a larger project examining the implementation of human rights in Australia, which is funded by the Australian Research Council. The initial research was undertaken on a pro bono basis by solicitors and articled clerks at three law firms that generously participate in the work of PILCH: Clayton Utz, Allens Arthur Robinson and Minter Ellison. The researchers were Paul Coady, Jacqueline Cole, Lucy Cole, Amanda Jones, Jacky Mandelbaum, Charissa Mitsikas, Marc Testart, Sophie Waller and Dana Wintermantel. This research was then collated, organised, supplemented and reworked into the final submission by Research Assistants, Chris Haan and Beth Midgley, in conjunction with Dianne Otto, at the Faculty of Law, at the University of Melbourne. The submission does not strictly follow the order of the questions as set out in the Special Rapporteurs questionnaire. Instead, it focuses on answering the general questions at the start of the questionnaire (questions 1, 2, 3, 4 and 6) and makes reference to the more detailed questions (questions 10-28) as issues related to them arise in answering the general questions. The exceptions to this pattern are the sections on security of tenure (question 10) and affordability (question 15). This approach was chosen partly because of time constraints, but primarily because providing the detailed information and analysis required by the questionnaire is not easy, given the complexity of Australias indirect approach to implementing its international human rights obligations. Australia relies on a complex web of legislative and policy measures to implement womens right to adequate housing, which, together with the complications of federalism, makes scrutiny of its compliance with its international obligations extremely difficult. Therefore, the submission does not provide a comprehensive response to the Special Rapporteurs questionnaire, but rather highlights some of the most pressing issues impeding womens full enjoyment of the right to adequate housing in Australia. Summary and Findings General Findings The right to adequate housing is not incorporated into Australian law. It is not entrenched in the Federal or State Constitutions, nor is it protected by legislation; Therefore, the right to adequate housing is not recognised as a human right for the purposes of Australian domestic law; Australia relies on indirect methods of implementing the right to adequate housing through government policies and programs, guided by human rights principles set out in international human rights instruments; Australia has no national housing policy and therefore lacks a primary tool for indirect implementation of the right to adequate housing; The national machineries established to advance the enjoyment of human rights in Australia and provide some forms of (non-judicial) remedies for human rights violations, such as the Human Rights and Equal Opportunity Commission and national womens policy machineries, have suffered serious erosions in recent years; Residential tenancies legislation, which governs the relationship between private residential landlords and tenants, provides only very limited security of tenure. Tenants may be evicted without reason upon 90 days notice and are afforded minimal protection from rental increases; There has been a shift away from public housing toward relying on market forces to regulate the cost of housing, combined with narrowly targeted government assistance for those in greatest need. This policy has had the effect of increasing housing costs for everyone; The decrease in Government funding of social housing has impacted severely on the access of people on low incomes to adequate housing. The demand for low-cost housing has grown at the same time that investment in low cost housing has fallen, which means that most low-income households in Australia are in a situation of housing stress; The increase in households experiencing housing stress has occurred despite Australias strong economic growth over the same period; Taken together, the failure to incorporate the right to adequate housing into Australian law, the erosion of national machineries targeted at advancing rights and reducing discrimination, the diminished access of low income earners to adequate housing, and the increase in households experiencing housing stress, constitute serious steps away from rather than towards the realisation of the right to adequate housing in Australia. Findings Specific to Women Because women make up the majority of low-income earners in Australia, they are disproportionately affected by the lack of availability of affordable housing and, therefore, make up the majority of Australians in housing stress situations; The protections provided in the Sex Discrimination Act 1984 (Cth), in relation to discrimination in the provision of housing and accommodation, are restricted to the public sphere and allow for many exemptions; Australias anti-discrimination legislation does not respond to the unique forms of discrimination that may result from intersectional discrimination, as, for example, where discrimination is based on both sex and race; Anti-discrimination legislation in Australia does not impose any positive obligations on the state or vest any substantive rights in the individual; it merely protects the individual from less favourable treatment in certain areas of public life (such as the provision of accommodation) where such treatment is connected with a protected attribute (such as sex). Anti-discrimination legislation and associated monitoring mechanisms are ill-equipped to identify, or respond to, structural discrimination such as the inability of many women to access adequate housing due to gendered poverty; The Australian approach to anti-discrimination legislation has been incremental rather than comprehensive, therefore there are a number of grounds of prohibited discrimination recognised in international instruments that are not recognised in Australian law. In particular, the failure to recognise social origin or social status discrimination leaves women who are homeless, unemployed or in receipt of social security payments without adequate protection against discrimination. Specific groups of women are particularly vulnerable to homelessness and/or living in inadequate housing. They include: women escaping domestic violence; Aboriginal and Torres Strait Islander women; migrant and refugee women; women in rural and regional areas; women with disabilities; single mothers; young women; and older women. Domestic violence is a key cause of womens homelessness and presents a real threat to womens security of tenure; Women experiencing domestic violence often confront difficulties in obtaining documentary evidence sufficient to access priority public housing; The geographic centralisation of much public housing stock means that some women escaping domestic violence are forced to live in close proximity to their violent ex-partners; There is an inadequate supply of safe, appropriate, short-term housing options for many women escaping domestic violence, and only those in immediate crisis are able to be accommodated; Long term, affordable, appropriate and secure housing options for women who are homeless as a result of domestic violence are insufficient to meet the demand; Indigenous women are severely disadvantaged by racial discrimination in the private rental market and the public housing sector, and discrimination against multi-family households; Public housing policy and stock is often culturally insensitive to the needs of indigenous and migrant women; Many migrant women, particularly refugees, are unable to adduce sufficient identification or documentation to access private accommodation; Asylum-seekers holding a bridging visa or a temporary protection visa are ineligible for public housing; Discrimination against migrant women on the grounds of race is widespread in the provision of private rental accommodation; Women living in rural and remote areas suffer higher levels of poverty and have poor access to housing support and other services; Women with disabilities constitute one of the poorest groups in Australia. Consequently, private accommodation is difficult to access. This is exacerbated by a serious shortage of appropriate or supported public housing options for women with disabilities; Women, particularly poor women, face considerable difficulties in security of tenure after marital breakdown; Women head the majority of single parent families in Australia, the group with the highest poverty rate of any group in Australia; Single mothers are often subject to discriminatory treatment by landlords and real estate agents due to assumptions or unwarranted imputations regarding their reliability or financial capacity; Young women confront many barriers to accessing public housing; Young women are often subject to discriminatory treatment by landlords or real estate agents on the grounds of age, gender, parenting status, marital status and race; The distribution of marital property and assets on marital breakdown under the Family Law Act leaves women considerably more likely than men to experience financial hardship after divorce; The failure of the State and Territory residential tenancies legislation to provide for security of tenure and protect tenants from unforeseen rental increases disproportionately impacts on women; Housing affordability is declining in Australia and government assistance is narrowly targeted and inadequate. This disproportionately impacts upon women, who are more likely than men to be experiencing poverty or housing stress, or to be low-income earners. Introduction: The Right to Adequate Housing in Australia in Context (Question 6) The globalisation of free market economic policies during the 1990s has demanded diminished social spending, privatisation of many public sector functions and the deregulation of labour markets around the world. In Australia, as with other western democracies, the result has been a major reconfiguration of the relationship between the individual and the state. While these changes were initiated by the Labor governments of the 1980s and early 1990s, the election of the conservative Federal Government in March 1996 marked the end of efforts to ameliorate the inequities produced by the supposed efficiencies of the market state. In Australias federal system, much of the responsibility for human services delivery has since been devolved from the Commonwealth to the States, and federal grants towards the provision of services at the state level have been largely untied. Also since 1996 (earlier in some states like Victoria), the shift to a minimalist, regulatory state has relocated much of the responsibility for the provision of social services and economic safety nets away from the public sector to individuals and to profit-driven private sector actors. For example, the provision of essential services and utilities such as electricity, gas, water and telecommunications has been fully or partially privatised across Australia. The dismantling of the redistributive state has created new impediments to the progressive realisation of the right to adequate housing in Australia. There has been a shift from attempting to provide affordable public housing to relying on market forces in the property market, combined with limited governmental benefits to assist the poor to obtain adequate housing. This is despite the fact that the number of people living in poverty continues to grow. Housing affordability is steadily deteriorating and homelessness is an increasing problem, particularly for young people, single mothers, elderly single people, and poor families. Yet housing advocacy groups like the National Youth Coalition for Housing and National Shelter have been de-funded by the Government. Major funding cuts have been made to the public housing sector, while 221 000 Australians remain on public housing waiting lists. Since 1986 the number of low-income households in major capital cities in housing stress across Australia has grown from 90 000 to over 250 000 households (the number is higher when regional figures are included). The number of individuals/families in extreme housing stress, paying more than 50% of their income in rent, is 88 846. Despite recent falls in unemployment and Australias strong economic growth, median household incomes have fallen in the face of rising rents and prices. Low-income households are forced to compete for a diminishing stock of low cost rental housing, while the number of low-income households grows. Overall, in the state capital cities, three out of every four low-income households renting on the private market are in housing stress situations. Women, like elsewhere in the world, are disproportionately poor in Australia and have therefore been disproportionately affected by these changes in governmental policy. Sole parents have the highest poverty rate of any group in Australia and are one of the largest groups in respect of housing assistance. Sole parents constitute up to 43% of new public housing tenants in some States. Sole parent families are overwhelming headed by women and a substantial number of these (46%) are on very low incomes (less than $300 per week in 1996). Most of these sole parent families are living close to the poverty line. In a survey conducted by the Australian Housing and Urban Research Institute in 2002, almost 50% of sole parents surveyed, reported experiencing the practical manifestations of poverty, such as inadequate food and heating, problems in meeting bills, etc. An estimated 28% of low income sole parents with dependent children live in public rental properties. Despite the growing problem of inadequate housing, Australia continues to rely on a complex and inadequate legislative and policy framework to implement, indirectly, the right to adequate housing and other economic, social and cultural rights. The Constitutional, Legislative and Policy Framework for the Right to Adequate Housing in Australia (Questions 1 and 2) Constitutional and Legislative Implementation of the Right to Adequate Housing As treaties are not self-executing in Australia, the Government must incorporate the provisions of international human rights treaties by legislation in order to directly create the rights enumerated and impose substantive obligations on the state to respect, protect, promote and fulfil those rights. Although Australia has directly implemented certain provisions of several human rights treaties, it has not directly implemented the International Covenant on Economic Social and Cultural Rights (ICESCR) in specific legislation. In the absence of direct incorporation, and as Australia has no constitutionally entrenched bill of rights, Australia relies on a complex web of indirect legislative and policy measures in order to fulfil its obligation to take steps to achieve progressively the full realization of the rights in the ICESCR, including the right to adequate housing. Further, when considering implementation in a federated state like Australia, account must also be taken of measures at the local State/Territory levels of government. The complexity of indirect means of implementation, together with the complications of federalism, makes scrutiny of Australias compliance very difficult. It impedes effective monitoring within Australia, as well as by international bodies, and highlights the dearth of direct judicial remedies available to those whose rights have been violated. Neither the Constitution nor any legislation in Australia provides for a judicial review process to ensure the consistency of legislation with relevant provisions of the international human rights treaties, which include the right to adequate housing. However, the courts in Australia do make limited use of international human rights treaties when applying Australian law. Treaties to which Australia is party and international human rights law can be used to assist in interpreting ambiguous legislation and developing the common law, for example. Notably, the Committee on Economic Social and Cultural Rights (CESCR) has been critical of Australias failure to implement the ICESCR by direct incorporation: The Committee strongly recommends that the State party incorporate the Covenant in its legislation, in order to ensure the applicability of the provisions of the Covenant in the domestic courts. All the other human rights treaty committees have made similar recommendations with respect to the implementation of their respective treaties in Australia. With regard to the right to adequate housing, the CESCR has also recommended that the State party, at the federal level, develop a housing strategy in keeping with the Committee's General Comments No. 4 and 7, including provisions to protect tenants from forced eviction without reasons and from arbitrary rent increases. In addition, the committee recommends that the State party ensure that all state and territory governments establish appropriate housing policies in accordance with this strategy. Despite this criticism, Australia has failed to directly implement the right to adequate housing. Two federal acts mention the right to adequate housing but do not directly implement it. For example, the Housing Assistance Act 1996 (Cth) states in its preamble: Australia has acted to protect the rights of all its citizens, including people who have inadequate housing, by recognising international standards for the protection of universal human rights and fundamental freedoms through: the ratification of the International Covenants on Economic, Social and Cultural Rights and on Civil and Political Rights; and the ratification of the Conventions on the Elimination of all Forms of Racial Discrimination, on the Elimination of all Forms of Discrimination against Women and on the Rights of the Child; and the acceptance of the Universal Declaration of Human Rights and of the Declaration on the Elimination of Violence Against Women; and the enactment of legislation such as the Human Rights and Equal Opportunity Commission Act 1986. Accordingly the Parliament considers that the provision, by the Governments of the Commonwealth, the States, the Australian Capital Territory and the Northern Territory, of housing assistance to people requiring access to affordable and appropriate housing is essential to reduce poverty and its effects on individuals and on the community as a whole. Further, the Supported Accommodation Assistance Act 1994 (Cth) states in similar terms in its preamble: Australia has acted to protect the rights of all of its citizens, including people who are homeless or at risk of homelessness, by recognizing international standards for the protection of universal human rights and fundamental freedoms through: the ratification of the International Covenants on Economic, Social and Cultural Rights and on Civil and Political Rights; and the ratification of the Conventions on the Elimination of all Forms of Racial Discrimination, on the Elimination of all Forms of Discrimination against Women and on the Rights of the Child; and the acceptance of the Universal Declaration of Human Rights and of the Declaration on the Elimination of Violence Against Women; and the enactment of legislation such as the Human Rights and Equal Opportunity Commission Act 1986. Statutes relevant to ascertaining the extent of Australias indirect implementation of womens enjoyment of the right to adequate housing include: The Family Law Act 1975 (Cth) which governs the division of marital property and payment of spousal maintenance upon the breakup of marriages; The Supported Accommodation Assistance Act 1994 (Cth) and Housing Assistance Act 1996 (Cth), which govern the provision of Commonwealth grants to the States/Territories for the provision of public and crisis housing; The Commonwealth anti-discrimination legislation the Racial Discrimination Act 1975 (Cth), Sex Discrimination Act 1984 (Cth) and Disability Discrimination Act 1992 (Cth) which address discrimination in the provision of housing to certain disadvantaged groups; The States/Territories anti-discrimination legislation that operates alongside the federal anti-discrimination regime; The Social Security Act 1991 (Cth), which governs the payment of social security benefits, including rent assistance, which play a role in providing people with sufficient funds to acquire adequate housing; and The States/Territories residential tenancies acts (eg, the Residential Tenancies Act 1997 (Vic)), which govern the relations between tenants and landlords. Aspects of these statutes relevant to the right to adequate housing will be considered further under specific topic headings in this report. Despite the lack of direct implementation of economic and social rights in Australia, previous governments established national mechanisms which went some way towards fulfilling Australias obligations to respect, protect and promote human rights domestically: notably the Human Rights and Equal Opportunity Commission (HREOC), and national machineries with respect to womens affairs and matters concerning Aboriginal and Torres Strait Islanders. However, the present Government has systematically dismantled or downgraded these national mechanisms, thereby threatening the progressive realisation of human rights in Australia. National housing advocacy groups have also suffered severe funding cut-backs and enforced restructuring, which has reduced their capacity to influence government policy development. The Human Rights and Equal Opportunity Commission The HREOC is a statutory authority charged with promoting respect for and observance of human rights. Its primary responsibilities relate to administering the Governments anti-discrimination regime. It is also responsible for human rights education, advocacy, research, advice to the Government, and for overseeing Australias obligations under seven international human rights instruments which are scheduled to the HREOC Act 1986 (Cth), but this does not include the ICESCR. While scheduling does not have the effect of incorporating the instruments into Australian law, it does define human rights for the purposes of the Act. The exclusion of the ICESCR means that ICESCR rights (including the right to adequate housing) are not even human rights that are subject to the limited oversighting functions of HREOC. Since 1996, there have been significant changes in HREOCs funding, functions and structure. Funding decreased 36% over the period 19971999, curtailing activities in the area of human rights education, limiting access to telephone contact in some states and forcing a focus on the core function of complaint handling and conciliation. The budget cuts also led to a halving of the capacity of the Sex Discrimination Unit. Further changes to HREOC have seen the removal of HREOCs inquiry/determination powers to the Federal Court, so that if a complaint of discrimination under the Racial Discrimination Act 1975, Sex Discrimination Act 1984 or Disability Discrimination Act 1992 is not resolved through conciliation, it can only be continued by making an application to the Court. While this change is constitutionally necessary, no measures have been taken to improve access to the Federal Court, which has recently significantly increased its fees while legal aid budgets have been substantially reduced. Other complaints under the HREOC Act 1986, with respect to the scheduled instruments, that are not covered by anti-discrimination legislation, do not provide access to a judicial remedy at all. Finally, the Government has suggested that the name of the Commission should be changed to the Human Rights and Responsibilities Commission, reflecting the Governments preference for individual self-sufficiency over a social guarantee that basic needs will be met. The significance of this suggestion is that it reveals the Governments view that primary responsibility for social and economic well-being should rest with the individual. This would have the effect of shifting the Governments responsibility for its international human rights obligations onto individuals, leaving the Government with only a residual role. National Womens Machineries Australian national womens policy machinery, which had earlier led the way internationally, has also been gradually dismantled in the name of mainstreaming and efficiency. The Office of the Status of Women in the Department of Prime Minister and Cabinet, first established in 1975, had its funds cut by 40% in 1996, mandating its withdrawal from coordinating and supporting womens policy work across government departments and diminishing its input to Cabinet. Further, the Annual Womens Budget Statement that has played a crucial role since 1984 in monitoring the gendered effects of government policies and programmes, was discontinued in 1996. While all State/Territory Governments also produced Womens Budget Statements for periods of time, the practice survives today in only two places, the Northern Territory and Tasmania. The National Agenda for Women, which promoted a comprehensive and coordinated approach to policy development, was also discontinued in 1996. These are significant losses for Australian women, especially in the absence of specifically legislated economic and social rights, as budgets are powerful instruments of social and economic policy. The policy of mainstreaming womens issues involves each government department taking responsibility for gender policy development, but measures to ensure accountability are ill-defined, and effective linkages and cooperation across departments are impossible without coordinating and oversighting machinery. In fact, womens policy units in several government departments have now been abolished, as has the Womens Statistics Unit in the Australian Bureau of Statistics. It is a mistake to think that mainstreaming can be a substitute for specific mechanisms, as both are necessary. The loss of national womens monitoring machineries is compounded by the reduced access of national womens non-governmental organisations (NGOs) to consultative arrangements. They have largely been replaced by selected prominent individual women at the now tightly controlled annual Round Table Conferences with the Federal Government. Further, funding for national womens advocacy groups has been substantially reduced. Legal Aid and Remedies Two other changes that reduce the Governments ability to achieve the progressive realisation of economic and social rights, including the right to adequate housing, need mention here. First, drastic cuts to legal aid funds of $120 million over 3 years have so stretched the system that many ordinary people no longer have access to the courts. Of particular concern are indigenous and migrant women, women suffering domestic violence, those seeking criminal injuries compensation, women requiring legal assistance with family law matters, and equal opportunity and discrimination cases. Second, severe budget cuts to the human rights units in the Attorney-Generals and Foreign Affairs Departments undermine their ability to effectively advise the government on human rights matters. Administrative law remedies, and anti-discrimination legislation constitute the predominant form of individual remedy for the violation of economic and social rights in Australia. The federal Administrative Appeals Tribunal, established in 1975, is able to review federal Ministerial and official decision-making in areas that include social security, taxation, and veterans entitlements. Further, judicial review of decisions made under federal legislation is also available. However, these mechanisms are severely limited in that they can only review administrative decision-making to ensure that it complies with the terms of legislation. They do not allow alteration of legislation if it violates, or has the effect of violating, social and economic rights. It is also of concern that Victoria is the only state that has matched the federal scheme of administrative review at the state level, and even this has been seriously eroded by the economic rationalist Victorian Government in recent years (which lost office in November 1999). Apart from administrative and anti-discrimination remedies, the scope for complaining about violations of the obligations assumed under the ICESCR is extremely limited. Because the schedule to the HREOC Act does not include the Covenant, the rights enumerated are not even human rights which attract the limited remedial powers of the HREOC. The various proposals for an Australian Bill of Rights have never included economic, social and cultural rights. Even basic social security entitlements are not justiciable at law as positive rights. Taken together, the changes in implementation that we have outlined chart a substantial backsliding rather than a continuous movement towards the full realisation of the rights in the ICESCR, including the right to adequate housing. While this is consistent with the Governments new emphasis on individualism and the market economy, the changes vastly increase the potential for inequitable economic and social outcomes that the CESCR warned about in its Statement on Globalisation. Anti-Discrimination Legislation (Question 3) Significant anti-discrimination legislation has been enacted in Australia at both a Federal and State level. At the Commonwealth level, anti-discrimination legislation includes the Sex Discrimination Act 1984 (Cth), Racial Discrimination Act 1975 (Cth), the Human Rights and Equal Opportunity Act 1986 (Cth) and the Disability Discrimination Act 1992 (Cth). Legislation has been enacted in the States and Territories which largely mirrors the federal legislation. This submission will focus on the Commonwealth legislation. The following summary examines the extent to which the legislation protects the rights of women to access adequate housing and the complaint mechanisms that exist to remedy the infringement of these rights. Sex Discrimination Act 1984 (Cth) Section 23 of the Sex Discrimination Act deals with discrimination on grounds of gender in relation to accommodation. It makes it unlawful for a principal or agent on the grounds of a personal characteristic protected by law, such as a persons sex, marital status or potential pregnancy, to: refuse an application for accommodation; treat an application to rent a property differently to other applications; change the terms on which accommodation is offered (ie by requiring a higher bond); change the terms on which accommodation has already been provided; discriminate in the conditions on which the accommodation is offered; refuse to extend or renew accommodation; evict tenants; or subject the tenant to any other detriment in relation to the accommodation. The effectiveness of section 23 is limited by several exemptions. Section 23(3) states that the section does not apply: where the principal or agent, or a near relative of the principal or agent, resides at the premises with no more than three other persons; where the accommodation is provided by a religious body; or where the accommodation is provided by a charitable or non-profit body solely for the persons of one sex or a particular marital status. Section 28H provides that it is unlawful for a person to sexually harass another person in the course of providing, or offering to provide, (whether as principal or agent) accommodation to that other person. It is also unlawful for a person to sexually harass another person in the course of dealing with that other person in connection with disposing of an estate or interest in land to the other person, or acquiring or offering to acquire an estate or interest in land from the other person. Once again, this provision is encumbered with an exemption when the sexual harassment is at the hands of a near relative. The exemptions in the Sex Discrimination Act serve to confine its application to specific areas of public activity. Yet, much of the discrimination suffered by women is in the private or domestic sphere. In this way, the Act fails to provide an adequate framework for preventing discrimination on the grounds of gender in the provision of adequate housing. Racial Discrimination Act 1975 (Cth) Racism and racial discrimination are major factors in the lack of access by Aboriginal people, migrants and refugees to adequate housing on the private rental market. Under the Racial Discrimination Act it is unlawful to discriminate on the grounds of race, colour, national or ethnic origin of a person or any relative or associate of that person in relation to access to places and facilities or in relation to land, housing and other accommodation. Section 12 of the Act makes it unlawful for a principal or agent on grounds of race, colour or national or ethnic origin of that person or their relative or associate to: refuse or fail to dispose of any estate or interest in land, or any residential or business accommodation, to a second person; dispose of such an estate or interest or such accommodation to a second person on less favourable terms and conditions than those which are or would otherwise be offered; treat a second person who is seeking to acquire or has acquired such an estate or interest or such accommodation less favourably than other persons in the same circumstances; refuse to permit a second person to occupy any land or any residential or business accommodation; or terminate any estate or interest in land of a second person or the right of a second person to occupy any land or any residential or business accommodation. The Racial Discrimination Act does not apply to acts in relation to accommodation being shared or to be shared with the person who did the act, or a person on whose behalf the act was done. The racial discrimination legislation fails to protect particular cultural needs of women and their families in many situations. This can be attributed to the failure of the anti-discrimination regime to recognise intersectional forms of discrimination, such as when sex and race discrimination act together to produce specific forms of discrimination. The Racial Discrimination Act and the Sex Discrimination Act are discrete legislative instruments, so they do not adequately address discrimination that has its basis in both gender and race. The following case study provides a clear illustration of this failure: In June 1977, Mrs Joan Martin, an Aboriginal woman, and her children and grandchildren, were evicted from their home by the public housing authority in Western Australia, Homeswest. At the time of their eviction, 17 adults and children lived in the house. MrsMartins children and their families had earlier been evicted from other Homeswest properties and had been unable to obtain private rental accommodation elsewhere in Perth. The basis of the eviction was that members of Mrs Martins household had created a nuisance. Mrs Martin challenged the eviction by Homeswest in the Equal Opportunity Commission of Western Australia, claiming she had been the victim of racial discrimination that included both direct discrimination and indirect discrimination. One instance of direct discrimination concerned a neighbour who was involved in the campaign to have the Martins removed from the street. The neighbour stated on national radio that as far as housing goes the answer is definitely NOT to integrate Aborigines into white areas. The indirect discrimination suffered by MrsMartin was an outcome of her cultural obligation as an Aboriginal woman to accommodate her children and grandchildren if they had nowhere else to live. In other words, that creation of the nuisance was an inevitable result of the fact that Mrs Martin was compelled by her culture to house 17 people. Unfortunately, this argument was not accepted by the Full Court of the WA Supreme Court and it was held that there was no discrimination. The Racial Discrimination Act needs to be supplemented by complementary policies and programs to deal more effectively with more complex forms of discrimination. There is a need for mechanisms aimed at increasing awareness among service providers who deal with clients from indigenous, migrant or refugee backgrounds and developing more effective channels of communication and advocacy. Investment in, and development and provision of, culturally appropriate low cost housing, which has regard to extended Aboriginal familial relations and needs, is also essential. Disability Discrimination Act 1992 (Cth) Under the Disability Discrimination Act, a person with a disability has the same rights to obtain accommodation and to buy land as a person without a disability. The Disability Discrimination Act does not address any gender-specific discrimination, so no special or additional rights are available for women. Therefore discrimination that results from the intersection of sex and disability discrimination is inadequately addressed. Under the Disability Discrimination Act, it is unlawful for real estate agents, landlords or other providers of accommodation to discriminate against a person because of a disability. Providers of accommodation cannot refuse an application for accommodation from a person with a disability, provide a person with a disability with accommodation on less favourable terms and conditions, or put the application of a person with a disability at the bottom of a list of applicants. The Disability Discrimination Act also makes it unlawful for a real estate agent, landlord or other provider of accommodation to refuse to permit an applicant for accommodation to make reasonable alterations to the accommodation if the person has undertaken to restore it to its original condition, where this is reasonably practicable, where it does not involve the alteration of the premises of any other occupant, and is undertaken at the persons own expense. There may, however, be a defence to an accommodation provider where the provision of accommodation would impose an unjustifiable hardship on them. Additionally, an agent or landowner cannot refuse to sell land or property to a person with a disability or offer land or property to a person with a disability on less favourable terms and conditions. In spite of the protections that it provides against discrimination in the provision of housing to disabled people, the Disability Discrimination Act does not provide a right to adequate housing. The legislation does not address the fundamental problem of the lack of alternative accommodation available for disabled women, which jeopardises their capacity to access adequate housing. Remedies and Complaint Mechanisms: Human Rights and Equal Opportunity Commission As has already been outlined, the HREOC is responsible for the administration of all complaints under the Sex Discrimination Act, Racial Discrimination Act and the Disability Discrimination Act. The HREOC operates alongside state anti-discrimination agencies. The focus of all Australian discrimination legislation is on conciliation. The major shortfall of Australias anti-discrimination regime is that it relies on the availability of substantive rights. There is no guaranteed right to adequate housing and therefore complainants are unable to seek redress if they are denied full enjoyment of the right. Furthermore, where victims of discrimination are able to seek redress, the lengthy complaint process means that the lodging of a complaint will often do little to assist a person to secure housing in the short to medium term. Therefore, the legislation does not usually assist them to secure adequate housing. As a result, few complaints are made in the area of housing and accommodation. Conclusion Although the anti-discrimination legislation in Australia to some extent implements Australias international human rights obligations, it does not cover all grounds of discrimination set out in the ICESCR. For example, it does not protect the rights of individuals against discrimination on the grounds of social status, including homelessness. This is of particular significance for women from disadvantaged and marginalised backgrounds in their efforts to secure adequate housing. In addition, the following particular aspects of the anti-discrimination regime further limits its effectiveness in protecting womens right to adequate housing: Australia has no legislatively protected right to adequate housing; The anti-discrimination legislation is limited to providing remedies to those individuals who have who have been discriminated against in the provision of adequate housing, but only on limited specified grounds; The legislation does not address intersectional forms of discrimination and nor does it prohibit discrimination on the basis of social origin or social status; The effectiveness of the anti-discrimination legislation is further restricted by the many exemptions allowed and by being limited to the public sphere of activity. Yet it is in the private or domestic sphere that many women suffer discrimination. Housing Situation of Women in Particularly Vulnerable Groups (Question 4) The following section examines issues affecting the housing status of women escaping domestic violence, indigenous women, migrant and refugee women, women in rural and regional Australia, single women, young women and older women. Women Escaping Domestic Violence In the years 1999-2000, the greatest proportion of people escaping domestic violence were females aged between 25 and 44 years. Access to adequate housing is a primary concern for women in this situation. If a woman does not have any family or friends to provide housing, her options include priority public housing, emergency temporary accommodation, or womens refuges or shelters. Programs, run by the Departments of Housing exist in each State and Territory, provide priority and emergency housing to women affected by domestic violence. Further funding is provided through the Supported Accommodation Assistance Program (SAAP) to various non-governmental and local government agencies to provide emergency housing. In this section the location, habitability, and cultural adequacy of the housing, among other factors, will be considered in examining the accommodation options available to women escaping domestic violence. Priority Public Housing Priority housing assistance is provided in most Australian States and Territories to people who are considered to be at risk, which includes women affected by domestic violence. Under the NSW Department of Housing Policy a person who is eligible for priority housing assistance will receive an offer of public housing ahead of others on the waiting list. The NSW Policy also offers alternative public housing accommodation to the perpetrator of domestic violence where the tenancy is in his name and the victim does not wish to relocate. The main shortcoming of the priority public housing programs in Australia is the limited stock of dwellings available in most allocation zones. While there is general recognition that there is a need to allocate a property in an area that is safe for the applicant so that they will not easily be found by the perpetrator of the violence, this is not always possible due to lack of available accommodation. There are also specific concerns with regard to access to priority public housing for women who are victims of domestic violence. Women have reported that there is a heavy burden to provide evidence of proof about domestic violence in order to gain access to priority housing. Although in some cases a letter from a support worker was sufficient, in other situations there was a preference for police reports which discriminates against those who did not involve, or who were unable to involve, police. Where multiple sorts of evidence were required, women felt demeaned and forced to identify as a victim. Women from non-English speaking backgrounds may have greater difficulties in providing documentary evidence as a result of cultural issues and availability of services. Further, in order to be considered eligible for priority housing in some areas, women are required to show at least five written rejections from private rental applications. This may be costly where women do not have transport to visit places and deposits are required to view the properties. Limited Emergency Temporary Accommodation Emergency temporary accommodation in private rental accommodation may be provided to people who are not normally eligible for public housing assistance but require urgent short term temporary accommodation and are unable to resolve the need for accommodation themselves. The accommodation is provided for up to three months, during which time the person is to find a suitable housing alternative. A persons ability to resolve their urgent short term emergency housing need is assessed by looking at any assets or savings that the person could use, the persons housing requirements (such as the number of bedrooms required or the need for disability modifications) the appropriateness of alternative housing options, or the inability of the person to obtain private rental accommodation due to other factors such as discrimination. The NSW Department of Housing Policy fails to state whether, in the case of a woman escaping domestic violence, the assets or savings held jointly by her and her spouse are taken into account as showing an ability to resolve the housing need herself. As with priority housing, applicants for emergency temporary accommodation must provide documentation to support their application. This can be difficult for women who cannot return home to collect papers due to an apprehension of violence, and for women from non-English speaking backgrounds, including refugees and migrants. Some Problems with Womens Refuges/Shelters Womens refuges are intended to provide emergency housing in a secure and supportive setting, often with additional services targeted at women escaping domestic violence. While they are the most well known response to women and childrens accommodation problems following domestic and family violence, the shelters do not operate uniformly across Australia. They vary in accommodation style, organizational philosophy, entry point, length of stay, staffing, services and regulations and rules around the refuge or shelter use. Some refuges and shelters receive no government funding and must instead generate the money to cover their expenses from the women who use their accommodation. A recent report entitled Home Safe Home the link between domestic and family violence and womens homelessness (prepared jointly by the Womens Emergency Services Network (Wesnet), the Commonwealth Department of Family and Community Services, and Partnership Against Domestic Violence) identified several positive aspects to finding accommodation in refuges or shelters, including the fact that they provided a safe place and support for women and children following the experience of domestic or family violence. Further, a key benefit is that the shelters provide useful information and assistance to find accommodation, as well as counselling. However, women reported that there were negative aspects to living in a shelter, primarily due to their communal living style. Some women found that it was not easy living with other women and their children, that they were exposed to women who had a range of complex issues and problems, and that communication was difficult in a communal setting when there were language differences. Indigenous and culturally diverse women could have difficulties in communication, customs, food preparation and cultural isolation in a communal living environment (this relates to questions 20 and 24). Life in a refuge may be quite confined by rules, which was identified in Home Safe Home as a problem for some women. The rules may be difficult for women to abide by and in some cases this leads to women breaching their agreement and being forced to leave the refuge or shelter. Policies of enforced relocation when entering a refuge or shelter were not always appropriate and may be disruptive to education and employment. Maintaining employment is an important concern for many women as it grants them financial independence. Workers in other services are concerned that they may not be able to communicate with either the refuge or shelter worker or their client once she has entered the refuge or shelter. A central telephone service for the accommodation is difficult to access in some areas and others did not have a central telephone service (this relates to question 19). It was also reported by some participants in the Home Safe Home study that women may be unable to access refuges or shelters if the domestic violence is not considered an immediate threat to them because it had occurred some weeks earlier or they had moved interstate away from the perpetrator. As a means of coping with demand, shelters are forced to accommodate only women in immediate danger. As a result, access criteria may be too narrow to accommodate all women escaping domestic violence. Further, as domestic violence is a prerequisite for entry into refuge or shelter style accommodation, the study found that women who needed housing for other reasons were ignored. On the other hand, this encourages women to report domestic violence so that they can gain access to refuges. The study identified that women from different cultural backgrounds, particularly where English is not their first language, and older women, are least likely to know of the potential assistance of refuges. Participants in the study also reported that there is a difficulty created by the variation in referral processes nationally, so they were often forced to tell their story numerous times to different staff in order to apply for accommodation. The fact that refuges and shelters receive limited funding leads to several problems that were identified by the study, including lack of transport for women to arrive at the refuge or shelter, lack of trained staff, lack of support in some refuges for children, lack of 24 hour staff in some refuges and the fact that the refuge may be run down and unappealing to women, forcing them to return to the situation of violence. Furthermore, due to the high demand for places, and the assumption that the communal living model is appropriate for all refuges, women often did not find appropriate refuge or shelter accommodation. Inadequate Other Emergency, Transitional and Supported Accommodation Home Safe Home also showed that there is limited emergency accommodation available for women outside of the high security refuge or shelter model. There are very few beds available in other emergency accommodation and, as a result, motels and boarding houses have recently been used for crisis accommodation. Transitional housing or community housing, providing temporary accommodation and support to victims of domestic violence until they re-established an independent living situation, was identified as an affordable and appropriate option for women and children leaving violent homes. However, this is also in short supply in most areas. Short term leases in private or public housing, desirable for many women escaping domestic violence who may not want to leave their family home permanently, are also difficult to obtain. As with shelters and refuges, there is a lack of effective coordination of this emergency accommodation, causing women to contact large numbers of agencies in order to locate housing. Home Safe Home identified a difficulty in progressing from this type of housing to permanent accommodation. This prevents new entrants, and increases demand and waiting lists for emergency accommodation. The report showed that there is a need for very short term accommodation, for one to two weeks, for women whose Domestic Violence Restraining Orders are being served and who are waiting for the perpetrator to move his belongings. Under the present policies, a refuge or emergency temporary housing would not take a woman in this situation as she is not in crisis compared to other women who cannot return to their previous home. However, if this sort of accommodation is not provided, a real crisis may develop, leading the woman into more permanent homelessness. Lack of Longer term Housing Options The main concern faced by women searching for longer term housing was its lack of affordability and suitability. An overall lack of public housing, as well as lengthy waiting lists, were identified throughout Australia. This impacted on both priority housing and long term public housing. Location of public housing is an important consideration. In smaller cities, women found that in some cases they were relocated to the same street or a close neighbourhood to their previous residence where the perpetrator was still living. In larger cities, public housing offers were often made in areas that were unsafe due to high rates of crime. Women were hesitant to live in these locations due to fear and the impact it may have on their children. Further, moving to an unfamiliar area impacts on employment, childrens schools and childcare. This may lead to women returning home to the violent relationship rather than being relocated to an undesirable area (this relates to question 19). The public housing sector is seen by women as more affordable and secure when compared to the private rental market where they feel that they are discriminated against. Women searching for housing in the private rental market reported many cases of discrimination. For example, government bond assistance is often viewed negatively by some agents. However, some women preferred the private rental market due to the increased choice in location. Women who wished to remain in the home that they owned or rented found that in order to be eligible for some government payments or allowances they were required to leave it. Another problem is that the assets test imposed by the Social Security Act 1991 to access social security payments does not disregard the family home if the woman retains a proprietary interest in that home, notwithstanding that she is unable to return due to domestic violence. An issue identified by some women leaving domestic violence situations in some States, and looking for alternative housing, is that accumulated debt and property damage by their former partner meant that they were unable to find public or private housing rental. For some, this leads to a poverty trap of repaying debts and a constant risk of recurring homelessness as a result. Indigenous Women Aborigines and Torres Strait Islanders still rank as the most disadvantaged group in Australian society in terms of housing, education, unemployment, health, life expectancy, socio-economic status and quality of life. The SAAP data for 1997-98 found that twice as many indigenous females as males sought support. It also showed that indigenous people accounted for 12% of people supported by SAAP while representing only 2.1% of the total Australian population. The SAAP data for 2000-01 suggests that these figures are rising, as indigenous people comprised 15.9% of SAAP clients during this period. Indigenous families are more likely to live in subsidised housing and much less likely to be owners or purchasers; they often experience difficulty accessing private rental accommodation due to discrimination and affordability problems; they are more likely to live in accommodation that is overcrowded and to live in rural areas and remote communities where adequate public housing may not exist. Discrimination limits access to private rental and mainstream services are not necessarily responsive to the needs of indigenous people. The Victorian Indigenous Homelessness Study Final Report stated that discrimination in the private rental market severely disadvantaged indigenous women. In particular, the study found that discrimination against multi-family households has negative consequences for indigenous women and their families. Indigenous households are more likely to be multi-family households than any other. In 1996, 6.2% of indigenous households and only 1.2% of all households nationally contained two or more families. Extended familial relations and sharing households is part of Aboriginal culture. However, this is not catered for adequately by the cramped design of public housing and may be one reason for the high rate of evictions of Aboriginal people from public housing. Aborigines are expected to house and take care of extended family members in need, no matter how distant the relationship. In the case of Joan Martin discussed above, Joan commented that it would bring great shame to her and her community if she were to turn a relative away. This cultural difference highlights problems within government policy at present. For example, from an indigenous perspective, three families living in a household is acceptable, whereas government departments see this as overcrowding, that is, the parties have different values (see question 20). Current policies in relation to housing allocations, rental charges, occupancy norms, design and location do not acknowledge the extended family commitments of indigenous people. In particular, for large family groups, the standard threebedroom dwelling does not meet their needs. Moreover, indigenous people are often forced to re-locate to areas where they lack support from family and other networks, and are also isolated from relevant services (see question 20). Consideration needs to be given to the provision of a range of housing sizes, including houses with large numbers of bedrooms, large central living areas, and provision for clearly segregated spaces. The location of appropriate housing needs to take into account the importance of community linkages, as well as their accessibility to valued landmarks, facilities and employment opportunities. Inadequate Housing Provision The Victorian Indigenous Homelessness Study found that there was a severe shortage of housing for indigenous Australians in both the public and private sectors. It noted that the difficulties faced in addressing homelessness for indigenous women were compounded by the invisibility of homeless women. Women tend to stay with relatives rather than on riverbanks or in parks. When homeless women are in dangerous, visible locations it is more likely that the service system will come to their aid for reasons of safety and health of children, even though the solution may be reactive and band-aid. The housing programs and services that do exist for indigenous people are part of a particularly complex service system. The existence of several systems of housing support for low income and homeless people creates confusion among client groups. Indigenous experience of the system include the perception of rigidity and lack of cultural awareness and sensitivity. A variety of housing services are provided by States and Territories under the Commonwealth/State Bilateral Housing Agreements. In 2002, the Howard Government announced the first real increase in indigenous housing funding in ten years to address serious housing issues in rural and remote areas. Over one third of this additional spending has been specifically allocated to the Aboriginal Rental Housing Program. Housing services available to indigenous Australians include: the Aboriginal Rental Housing Program, ATSICs Community Housing and Infrastructure Program (CHIP), the ATSIC Home Ownership Program, and Aboriginal Hostels. Men and women are formally equally eligible for each of these programs. Land Rights The promise of land rights, that was given life by the High Court in the Mabo decision of 1992, suffered a severe setback with the Governments 1998 amendments to the Native Title Act 1993 (Cth), which further extinguish and impair native title. The Committee on the Elimination of Racial Discrimination issued an early warning in March 1999 after examining these amendments, and has since reaffirmed its concerns on a number of occasions. Moreover, in 1997, the Committee on the Elimination of Discrimination Against Women urged the Government to develop necessary legislative and policy measures to ensure womens equal access to individual ownership of native land. Migrant and Refugee Women Migrant and refugee women, especially those from non-English speaking backgrounds, are confronted by a myriad of issues in their everyday life, including difficulty in accessing services, language difficulties, discriminatory employment practices, insufficient child care, lack of transport (especially in rural communities), domestic and family violence and lack of suitable human and financial resources. Migrant and refugee women face particular challenges in securing adequate housing. Migrant women are subject to stereotyping and tend to be classed together, without respect to differences in history, English proficiency, skills and personality. These stereotypes may extend to women applying for accommodation, where landlord or real estate agents reject applications for accommodation based on preconceived notions of cultural differences. With regard to private rental, migrant and refugee women are negatively impacted on by the requirements of providing documentation such as a drivers license, a passport, or a document for travel to Australia issued by the Australian Government upon application. These documents may be difficult for a recently arrived migrant or refugee to obtain and, as a result, could discourage application for private rental. Asylum seekers holding a temporary protection visa (of three years duration) are considered temporary residents and are ineligible for public housing. Due to recent changes in Government policy, there are an increasing number of people holding temporary protection visas. Many of these people face the prospect of extension of their temporary status through a new regime of successive temporary protection visas, which the Government has imposed on asylum seekers who have arrived in an unauthorised manner. These people are also ineligible for on-arrival accommodation and existing settlement support services, and are reliant on ad hoc assistance from voluntary agencies and the State Government Departments. Holders of Permanent Protection Visas, who have had their refugee status determined off-shore before their arrival, are provided with on-arrival accommodation, however its availability has recently been reduced from thirteen weeks to just four weeks. State Departments of Housing have programs for housing new immigrants, for example, the South Australian Governments On Arrival Accommodation Program. This provides rental accommodation to new migrants for a period of up to 3 months before they find permanent accommodation. However, only skilled migrants are eligible to participate in this program. Many women migrants may be unskilled, or suffer from lack of skill recognition and mainly work in manufacturing industries. They are unable to receive housing through this program and are not covered by any others. Due to language and cultural difficulties, migrant women may be unaware of housing options available. This is a particular concern for women from migrant and refugee backgrounds who are victims of domestic violence. They may be unable to access migrant services and translators because of confidentiality, shame and the threat of further conflict within their community. In recognition of these problems, many policies in relation to housing have been translated in order to be accessible to migrants, but there are many further policies that need to be put in place before the difficulties faced by migrant and refugee women will be alleviated. Women in Rural and Regional Australia More than 2 million women live in regional, rural and remote Australia. The Australian population is concentrated in major cities, outside of which, the population is widely dispersed. On a range of social and economic indicators, rural Australians tend to experience higher levels of disadvantage than their metropolitan counterparts This disadvantage is related to low incomes, high living costs, unemployment, poor housing quality and many inequalities in the provision of goods, services and opportunities. The incidence of poverty in rural and remote areas is considerably higher than in urban areas. In NSW, for example, it is estimated that the number of households in rural and remote areas living in poverty range from 18% in major regional centres to as high as 24% in many rural and remote areas. Women are disproportionately represented in the population of rural people living in poverty, and face increasing problems with accessing services, as public transport, banking, social security, childcare, medical and counselling services are withdrawn or privatised pursuant to economic rationalist policies. Women with Disabilities Disabled women in Australia are confronted with the following challenges: they are less likely to be in paid work than other women, men with disabilities and the population as a whole; they are less likely than their male counterparts to have received senior secondary or tertiary education; they are more likely to have been institutionalised than men with disabilities; they are often forced to live in situations that make them vulnerable to violence; and they report a higher level of unmet need than their male counterparts. The Commonwealth State Disability Agreement (CSDA) allocates responsibility for provision of disability services between the States and Commonwealth. The States and Territories are responsible for providing supported accommodation services and receive funding from the Commonwealth Government, together with their own funding, in order to meet identified needs. The Office of Housing in each State and Territory has a program for providing housing to disabled people. Disabled people, both male and female, in Australia face particular problems in finding suitable housing arrangements. The availability of housing for disabled people is often insufficient in meeting needs and demands. Rental accommodation is often inappropriate due to the lack of modifications to most private rental properties and the discrimination that disabled people meet in the rental market. Public housing offered to disabled people is often inappropriate due to accessibility issues. Emergency housing generally has not been modified to ensure that it is suitable for people with disabilities, so that disabled people cannot find crisis accommodation. This may constitute a contravention of the indirect discrimination provisions of the Disability Discrimination Act in that access to emergency housing may be subject to conditions or requirements which people with disabilities are unable or less likely to be able to comply than people without disabilities. This is a particular concern as a large number of people with physical or sensory disabilities live with relatives, often causing pressure and burden to those involved. Consequently, they have a critical need for time out or crisis accommodation (related to questions 16 and 17). An important feature of housing for disabled people is its location. Many people with disabilities are reliant on transport, support services, generic services and education opportunities. Many areas in Australian states are not close to transport or to the commercial centres where most services are located. Transport planning is very much based on facilitating access to work. Until transport planning and policy is able to cater for the specific needs of people with physical and sensory disabilities, it is critical that public housing is located centrally, with good access to public transport. Although the Offices of Housing state a willingness to match applicants preference for housing type and location, often prospective tenants are forced to refuse offers of accommodation on the grounds of inappropriate location, which results in those people losing their position on the waiting list (related to question 19). Disabled women also face particular challenges in the private housing market. As a group, women with disabilities have low incomes and, as a result, affordability of housing is a primary issue for them. The cost of accessible accommodation may be high due to the need for wheelchair accessibility, extra rooms, equipment or carers. Some women with disabilities may require the installation of ramps, rails and other modifications to their kitchens and bathrooms. To a large degree this type of housing is not available on the private market. The cost of modification, if permitted by a private landlord, can be prohibitive. Discrimination in private rental markets makes it difficult for women with disabilities to find accommodation. This is particularly relevant to women with psychiatric disabilities, intellectual disabilities and acquired brain injuries. Although the Discrimination Disability Act is evidence of an attempt to curb this type of discrimination, the Act does not give disabled people the right to access adequate housing, but it is limited to protection from discrimination. Therefore a successful complainant under the Act will not be provided with adequate housing as a remedy (related to question 27). Single Mothers Single parent families are the poorest in Australia and have the highest poverty rate of any group in Australia. They are one of the largest groups receiving housing assistance. Further, the number of sole parents is growing at a dramatic rate. Most sole parent families are headed by women and 46 % of these are on very low incomes (that is, of less than $300 per week) which explains why this group makes up a disproportionate share of those people requiring housing assistance. These families tend to live in areas where they are concentrated. These areas have lower house prices and rental costs. They have high levels of unemployment, low male incomes and weak labour markets. There is a tendency in these areas for women to leave school early and begin their partnering and child bearing earlier, relative to women in the same area who stayed at school to age17. Further, women tended to begin child bearing outside of marriage more frequently than in other areas and there was a higher tendency for marital breakdown. It is estimated that 28% of low income sole parents with dependent children live in public rental and 34% live in private rental, while 32% are home owners or purchasers. The proportion of sole parent families with dependent children aged 014 living in subsidised housing is rising. In 1998 to 1999, between 23% and 43% (depending on the State or Territory) of new public housing tenants were sole parents. Similarly, sole parents made up an estimated 22% of income units receiving Commonwealth Rent Assistance (CRA) in 2000. Unless escaping domestic violence, single mothers may not be eligible for priority housing or emergency temporary accommodation, shelters and refuges. This creates a risk of homelessness if suitable accommodation cannot be found on the private market, or in public housing, in the necessary time frame. Sole parents receiving CRA, and living in private rental properties, tend to be younger and have smaller families than those in public housing. They are also likely to reach a higher level of education. In contrast, sole parents in public housing are more likely to have been born overseas and to speak a language other than English. Sole parents also have particularly high mobility rates. It is likely that these high mobility rates create relocation expenses for sole parent families, result in disruption to schooling and impact on general wellbeing and connection with the local community. This further isolates them and may compound their poverty. Sole parents find it difficult to afford housing as well as other necessities of life. Substantial numbers of sole parents fall behind with their rent, largely due to the need to pay utility bills. The percentage of sole parents on or below the poverty line increases proportionately to the number of children in the family. This indicates a need for more affordable housing options for sole parents or alternative funding arrangements. Single women with children may face discrimination when applying for accommodation due to assumptions about their capacity to meet financial obligations due to the absence of a male partner. This discrimination constitutes unlawful discrimination on the ground of sex or marital status within under the Sex Discrimination Act and the equivalent state and territory sex discrimination legislation, but these mechanisms are seldom used by women on low incomes. Young Women Young women leave home for a variety of reasons. Frequently it is to escape homes where they are subject to domestic violence, incest, sexual, or emotional and physical abuse. However, many young women leave home as part of a normal transition. Both of these groups of young women may go on to become homeless. Certainly, research has identified a causal link between young womens experience of domestic violence in their own home and homelessness. As a result, there is a need for services that are flexible and adaptable, to provide appropriate support for the different womens experiences. These experiences will also differ as young women are not an homogenous group and their experiences differ according to age, ethnic or cultural background, disability, whether or not they have children and many other factors. Since July1998, young people in a housing crisis must obtain assistance through a single program called the Youth Allowance. This does not contain a special homeless rate, it is generally paid to fulltime students aged 16 to 24, to unemployed people under 21years of age looking for work, and to those studying parttime in conjunction with an approved activity. Different rates are paid according to the young persons circumstances, the highest rates being awayfromhome and independent rates. The eligibility criteria for these rates usually apply to young homeless people. Under SAAP, there are many agencies that assist young homeless people. However, there is a need for programs targeted specifically at young women, as their experience of poverty and housing crisis is often likely to be different to that of young men and older women. This is due to a number of factors, including earlier home leaving patterns and establishment of independent households than young men, higher youth unemployment levels, undertaking secondary or tertiary education while living away from home (often without Government subsidies) poverty related to sole parenting and ineligibility for unemployment benefits when in a relationship with a male who has his own source of income. Young women tend to receive lower wages, have less access to employment opportunities and have greater rates of unemployment. Public Housing Young women face some barriers to public rental housing, including: age-related eligibility criteria (which excludes some young women, for example, single young women aged under 16 years); long waiting lists; mobility of young homeless women (which means they face difficulties maintaining their position on public housing waiting lists); affordability problems for young women on very low incomes who struggle to pay the percentage of their income in rent required to obtain public housing; poorly located public housing; and a lack of flexibility in transfer policies so that women cannot respond to changing life situations, for example, education or training or a desire to live near employment opportunities. In addition, young women may be less likely to be accepted for priority housing than older women as they are perceived able to access shared private rental accommodation and they may be less likely to be granted priority on the grounds of domestic violence. The lack of choice in location or type of public housing offered may act as a deterrent to many young women. Private Rental Private rental may be difficult to access for young women due to discrimination by private landlords and real estate agents on the basis of age, gender, parenting status and race. As such, young single mothers, young indigenous women and young women from nonEnglish speaking backgrounds face additional difficulties in accessing private rental. For young women on low incomes, the rising costs of private rental, as well as the need for a bond rent in advance, furniture and other household items, makes private rental unaffordable. The following testimony provides an example of the discrimination faced by young women in the private housing market. It is this organisations general experience that single women with children whether they be victims of domestic violence or young homeless women who are pregnant or parenting have great difficulty in obtaining private rental regardless of whether it is housing or caravan park accommodation. One particular central caravan park in Bendigo advised a client that they had accommodation available. As soon as the client mentioned that Emergency Accommodation Support Enterprise were working with her, they realised that she was homeless and a victim of domestic violence and advised her that they had made an error and had no vacancies. Community Housing Community housing may be difficult to access by young women on low incomes as many community housing groups no longer receive sufficient funding from the Government so they must charge higher rent to young women. Young women not receiving CRA may be ineligible for many community houses reliant on this income as a subsidy. A lack of knowledge and information about community housing options available, and the lack of a coordinated structure and entry point for community housing, may deter many women from seeking such accommodation. This is of particular concern in light of the fact that young women are at more vulnerable than young men and are at particular risk of violence, often from their male partners. Refuges and Shelters The majority of women entering this type of accommodation are escaping domestic or family violence, which may lead to young women being turned away if they are homeless for other reasons. Further, the high security model of a refuge may be inappropriate to many young homeless women who are not escaping domestic violence. Those young women who are escaping domestic violence, and do require specialist, high security accommodation, are also often turned away inappropriately to youth refuges or other young womens services. Women in this position may feel unsafe living in such housing following a domestic violence experience. Many youth refuges do not accommodate single parents, and those that do often accommodate a limited number of single parents at any one time. As a result, young single mothers may find that they cannot be accommodated in a youth refuge on particular nights. Further, the services provided may fail to take into account the needs of their children, so many young women do not approach youth services to find accommodation and are homeless as a result. Older Women Women comprise the majority of older people living in their own homes in the community. The Australian Government, in the 200203 Budget, committed to building on existing programs to assist older Australians to remain in their homes for as long as possible. This includes funding for carer respite centres, aged care packages and aged care assistance. The introduction of occupational superannuation during the 1980s has dramatically changed the way in which retirement income is organised, moving from a system of universal provision of old age pensions to a new regime of self-funded retirement income. Superannuation savings rely on employer contributions, based on individual income. Women are severely disadvantaged by this scheme because of their unequal position in the workforce: lower pay, partial and interrupted patterns of employment, and less opportunity for promotion and salary increases. As a result, older women have fewer financial resources than older men, and are more likely to be dependent on the, now residual, old age pension. Already in 1993, 68% of aged pensioners were women, and 68% of those were dependent on the full pension, indicating that they had no other significant source of income. This situation threatens the housing situation of many older women, and needs to be addressed by appropriate government assistance. Women and Security of Tenure (Question 10) In Australia, women and men formally enjoy equal tenure and property rights regardless of their civil status. However, women who are economically dependent on their partners face special difficulties if the relationship breaks down, and women surviving on a low income and renting in the private rental market face limited security of tenure. Family Law and Security of Tenure Women, particularly poor women, face considerable difficulties in maintaining security of tenure after marital breakdown. Recent research has found that sole mothers, and women from long term relationships who live alone are still more likely than men to experience financial hardship after divorce, and the hardship they experience is considerable. The Family Law Act 1975 (Cth) provides for the division of property following the breakdown of a marriage. It recognises that property may not have been in both parties names and allows for alteration of property interests in line with direct and indirect financial contributions to acquisition, conservation, and improvement of the property. The Family Law Act states that property owned by the parties to a marriage should be tallied in order to ascertain the parties net asset pool. Following this, the parties contributions, both direct and indirect, to the acquisition, improvement and conservation of the net asset pool is evaluated in order to determine how it should be distributed between the parties, regardless of which party legally owns the property. In considering this issue, the court is given a list of factors to take into account: financial contributions, for example, contributions from income; non-financial contributions, for example, repairs and restoration; contributions to the marriage or the welfare of the family, including any contribution made in the capacity of homemaker or parent, for example, if the party was the primary contributor to the welfare of the family; the effect of any proposed adjustment upon the earning capacity of either party; various factors in relation to each party, for example, their age, state of health, income and resources, any children the party is required to maintain, the standard of living that the party requires, any maintenance payments, the duration of the marriage and the extent to which it has affected earning capacity, and any commitments necessary to support either the party or any children; any other order made affecting either the party to the marriage or the child of the marriage; and any child support that the party to the marriage has provided, will provide, or might be liable in the future to provide for a child of the marriage. Case law has stated that there is no presumption of equality of contribution between parties to a marriage. A homemaker contribution will be given the same weight as a breadwinner contribution so that, in theory, women who have remained at home should be no worse off when it comes to settlement of property between the parties. Further, there will be an adjustment if a party has contributed under difficult circumstances that have had a significant adverse impact upon a party. This allows an adjustment for women who have been subjected to domestic violence. On average the wife receives two-thirds of the couples basic assets and one-fifth of the couples non-basic asset wealth. Basic assets are those closely associated with the marriage such as the family home and contents, cars and bank accounts. Non-basic assets include superannuation, life insurance, investments and businesses or farms. Women from high asset (or well-off) families are more likely to receive a minority of overall assets, but are still likely to maintain security of tenure after marriage dissolution by the simple fact that there are considerable assets to divide, such as the family home(s) and various investments. Where there is a family home and children, then the partner, usually the woman, who will take primary responsibility for caring for the children will usually receive the family home. However, despite usually receiving a majority of basic assets, women from low asset (or poor) marriages often receive little, and where no marital home was owned by either partner, can be left relying on crisis centres and public housing. Indeed for women from low asset marriages, receiving a majority share of the basic assets can even increase their financial hardship, as their share is concentrated in the marital home, which is subject to significant mortgage obligations. The Family Law Act also provides that a party to a marriage can seek an order for maintenance. This is available where the party is unable to adequately support themselves and where the other party is reasonably able to provide maintenance payments. However, recent research has shown that the payment of spousal maintenance is rare, minimal and brief, suggesting that spousal maintenance rarely improves womens economic circumstances after marital separation, particularly women from low asset marriages, who receive little even after marital property has been divided. Thus in Australia, despite the provisions of the Family Law Act, recent research has found that 44% of sole mothers from short-term marriages through to 59% of sole mothers from longer-term marriages (that is, 15 years or more) had household incomes below the poverty line some six years post-separation. The Residential Tenancies Legislation Security of rental tenure is regulated by the residential tenancies legislation in each sState of Australia and the laws apply to women and men equally. There are a number of differences between each of the State or Territory Acts, but for the sake of simplicity only the Residential Tenancies Act 1997 (Vic) will be considered. The Residential Tenancies Act does not provide tenants with security of tenure. While landlords must give a tenant at least 90 days notice to vacate a rental property, landlords are not required to provide the tenant with a reason for wanting them to leave. In order to challenge the notice, the tenant must prove to the Victorian Civil and Administrative Appeals Tribunal (VCAT) that the notice was served in retaliation for the tenant exercising their legal tenancy rights (eg requesting repairs). The tenant faces the extremely difficult task of establishing a link between the exercise of their legal rights and the notice, and in most cases the application is unsuccessful. As a result, many tenants are reluctant to exercise their tenancy rights, such as the right to repairs, for fear of eviction. Moreover, there is evidence that landlords regularly misuse 90-day notices as a way of avoiding establishing the requirements for a shorter notice (eg, a 14-day notice for using the property for illegal purposes) because they know their case against the tenant is weak. Many tenants choose not to challenge such notices because they need the 90 days to find alternative accommodation and cannot risk waiting for the uncertain outcome of a VCAT hearing. Given that so many women, particularly single mothers, survive on a low income, protection from rent increases and mechanisms to delay eviction in the event of failing to pay the rent are crucial to such womens security of tenure. If during a lease a tenant falls more than 14 days in rent arrears, then a landlord has the right to serve a 14 day notice to vacate or be evicted. Tenants may challenge such an eviction at VCAT. The Tribunal may uphold the eviction, or it may order that the tenant pay arrears if it is satisfied that the tenant couldnt have avoided falling into arrears; and the tenant intends to repay the arrears; and the tenant can afford to pay the rent in the future. Additionally, tenants security of tenure is reliant on them being able to continue to afford the rental of the premises. The Residential Tenancies Act offers tenants little protection from unforeseen rental increases. Although a landlord must provide a tenant with 90 days notice of a proposed rental increase, there is no limit on the number of rent increase notices a landlord can serve. Tenants can challenge rent increases by requesting that an inspector from Consumer and Business Affairs Victoria inspect their rental property to determine whether the increase is reasonable. The inspector should produce a report evaluating the condition of the property and any services and facilities provided with the property, and on the basis of these factors comparing the proposed rent with that charged for similar properties in the same area. Once the inspector has produced a report, tenants can apply to VCAT for a determination as to whether the rent increase is excessive. The Tribunal will only find that the rent increase is excessive if it is significantly more than the rent payable for similar rental premises in the same area. If the Tribunal does find the increase excessive, it may order that the rent not be increased or increased by a smaller amount. In practice, it is difficult to satisfy the requirement that a proposed rent increase is unreasonable, where a reasonable rent increase is defined as exceeding the market rent. This is exacerbated by the fact that tenants often fear that by exercising their tenancy rights the landlord may increase the rent in retaliation, or are not even aware of their right to challenge the rent increase. Thus in Australia people living on a low income and renting on the private market, a disproportionate number of whom are women, have limited security of tenure. It remains a further concern that such people are unlikely to be aware of or use the limited mechanisms available through which they can defend their tenure. Affordability of Housing (Question 15) Housing affordability is steadily deteriorating and homelessness is an increasing problem, particularly for young people, single mothers, elderly single people, and poor families. Major funding cuts have been made to the public housing sector, while 221 000 Australians remain on public housing waiting lists. Since 1986 the number of low-income households in major capital cities in housing stress across Australia has grown from 90 000 to over 250 000 households (the number is higher when regional figures are included). 89 000 individuals/families live in extreme housing stress, paying more than 50% of their income in rent. Despite recent falls in unemployment and Australias strong economic growth, median household incomes have fallen in the face of rising rents and prices. Low income households are forced to compete for a diminishing stock of low cost rental housing, while the number of low-income households grows. Overall, in the State capital cities, three out of every four low-income households renting on the private market are in housing stress situations. And, at last count in 1999, the number of people who were homeless on any given night totalled 105 304. While there are no formal legal and political barriers to women accessing affordable housing in Australia, women are disproportionately affected by unaffordable housing by virtue of higher poverty rates among women than men. Sole parents have the highest poverty rate of any group in Australia and, are one of the largest groups in respect of housing assistance. Sole parents make up to 43% of new public housing tenants in some States. Sole parent families are overwhelming headed by women and a substantial number of these (46%) are on very low incomes (less than $300 per week in 1996). Most of these are sole parent families living close to the poverty line. In a survey conducted by the Australian Housing and Urban Research Institute in 2002, almost 50% of those surveyed reported experiencing the practical manifestations of poverty, such as inadequate food and heating, problems in meeting bills, etc. An estimated 28% of low-income sole parents with dependent children live in public rental properties. There has been a shift in governmental policy from endeavouring to provide affordable public housing to relying on market forces in the property market combined with limited governmental benefits to assist the poor to obtain adequate housing. A Victorian government press release stated that the Commonwealth Government had reduced its Victorian contribution under the CSHA by 30% since 1992. At the same time public housing waiting lists had increased in Victoria by 2.6% between December 2001 and March 2002 alone. Applicants for public housing face considerable waiting periods. In place of funding public housing, the Commonwealth Government has provided a benefit named Commonwealth Rent Assistance (CRA) to assist people in paying rent on the private rental market. CRA is an allowance paid under the Social Security Act 1991 (Cth) to qualifying recipients of welfare payments who rent accommodation in the private rental market above minimum threshold levels. Payment of CRA is in accordance with a formula that relates to the cost of rent for the individual involved, up to specific maximum rates of assistance. The Government has not implemented any measures to ensure the affordability of housing specifically for women. The CRA falls far short of ameliorating the lack of housing affordability for low-income earners in Australia. Indeed, for single people and couples without children eligible to receive CRA, there is almost no type of dwelling that is affordable in either Melbourne or Sydney. There are a number of other problems with CRA. First, the amount paid is entirely inadequate to provide a wider range of dwelling or location choices for the majority of recipients in Melbourne or Sydney. This is because it does not take account of price variations between similar rental properties in different Australian cities when calculating how much assistance is available to an individual. For example, rental accommodation in Sydney will generally cost a lot more than the same accommodation in Hobart, but an individual will receive the same amount of rent assistance regardless of which city they are renting in. Currently for single people and couples (without children) who qualify for rent assistance almost no type of dwelling can be defined as affordable in Melbourne or Sydney. Second, singles and couples without children who are on a low wage but do not receive any government benefit do not receive any rent assistance. Thus, even though they have a similar income to welfare recipients, they do not receive any rent assistance. The Federal Government also provides a First Home Owner Grant of $7000 to those who are buying or building their first home. However, it is of little assistance to low income earners who still have no hope of affording to buy a home, and will not close the gap for the larger proportion of households in housing stress. In fact, there is evidence that this grant has helped to drive up the cost of housing, thus increasing the difficulties that people on low incomes have in accessing affordable housing. Thus the Government continues to provide inadequate measures to assist people to obtain affordable housing, despite what could be described as an affordable housing crisis in Australia.  There is no national definition of affordability of housing endorsed by the federal government, but a definition used by the National Housing Strategy (NHS) in the early 1990s has been widely used by both government and non-government institutions. The NHS proposed a definition of affordability to be a maximum of 30% of income that households should spend on their housing.  Australian Council of Social Service, Public & Community Housing: A Rescue Package Needed (14 October 2024) 1.  A person is said to be experiencing housing stress if they fall within the lower 40% of income distribution and spend more than 30% of their income on rent or mortgage repayments.  Affordable Housing National Research Consortium, Affordable Housing in Australia: Pressing Need, Effective Solution (September 2001) 2.  Australian Council of Social Service, Public & Community Housing: A Rescue Package Needed (14 October 2024) 4.  Ibid 12.  Australian Housing and Urban Research Institute, Sole Parents, Social Wellbeing, Housing Location and Housing Assistance (June 2002). Research and Policy Bulletin, p 1.  Ibid 2.  Ibid 3.  Eg, the Racial Discrimination Act 1975 (Cth) implements most of the Convention on the Elimination of All Forms of Racial Discrimination (1965).  Minister of State for Immigration and Ethnic Affairs v Teoh (1995) 128 ALR 353.  Committee on Economic, Social and Cultural Rights, Concluding Observations of the Committee on Economic, Social and Cultural Rights: Australia (1 September 2024) para 24.  Committee on Economic, Social and Cultural Rights, Concluding Observations of the Committee on Economic, Social and Cultural Rights: Australia (1 September 2024) para 34.  HREOC has responsibility for the Human Rights and Equal Opportunity Act 1986 (Cth), Racial Discrimination Act 1975 (Cth), Sex Discrimination Act 1984 (Cth), Disability Discrimination Act 1992 (Cth) and assists the Privacy Commissioner in administering the Privacy Act 1988 (Cth).  The scheduled instruments are the ICCPR, the Declaration of the Rights of the Child, the Declaration on the Rights of Disabled Persons, the Declaration on the Rights of Mentally Retarded Persons, the Convention Concerning Discrimination in Respect of Employment and Occupation 1958 (ILO Convention No.111), the Declaration on the Elimination of All Forms of Intolerance and of Discrimination Based on Religion or Belief, and the Convention on the Rights of the Child.  Brandy v HREOC (1995) 183 CLR 245.  The HREOC Act 1986 grants individuals the right to complain about violations of the scheduled instruments to HREOC. The powers of HREOC are limited to conciliation and if a settlement cannot be conciliated, the only further action that can be taken is by way of a report from HREOC to the Attorney-General.  Marian Sawer, The Watchers Within: Women and the Australian State, in Linda Hancock (ed), Women, Public Policy and the State (1999) 36.  Ibid 46-47, referring to the DEETYA Womens Bureau and the ATSIC Office of Indigenous Women.  Established by the Administrative Appeals Tribunal Act 1975 (Cth), and supported by the Ombudsman Act 1976 (Cth), the Freedom of Information Act 1982 (Cth).  Provided for by the Administrative Decisions (Judicial Review) Act 1977 (Cth).  Green v Daniels (1977) 51 ALJR 463.  CESCR, Statement on Globalisation and Economic, Social and Cultural Rights, May 1998, 01/05/98.  Accommodation is defined to include houses, flats, hotel/motel rooms, boarding houses, hostels, caravans/caravan sites, camping sites, mobile homes and mobile home sites, and offices.  Sex Discrimination Act, s 28J.  Sex Discrimination Act, s 28(H)(2).  Womens Rights Action Network Australia, Retreating from the Full Realization of Economic, Social and Cultural Rights in Australia: A Gendered Analysis (2000) 9.  Racial Discrimination Act, s 11.  Racial Discrimination Act, s 12  Racial Discrimination Act, s 12(3).  State Housing Commission v Martin [1998] WASCA 327.  Mike Berry, David MacKenzie, Linda Briskman and Thami Ngwenya, Victorian Indigenous Homelessness Study Final Report (August 2000) 7.  The definition of disability is wide. It includes physical, intellectual, psychiatric, sensory, neurological, or learning disabilities, physical disfigurement and the presence in the body of disease causing organisms. People are covered by the Disability Discrimination Act if they have, have had in the past, may have in the future, or are believed to have, a disability. Further, people who have some form of personal connection with a person with a disability, for example relatives, friends, carers and co-workers, are also protected from discrimination.  Disability Discrimination Act, ss 25 and 26  Disability Discrimination Act, s 25.  Disability Discrimination Act, s 25(2).  Disability Discrimination Act, s 25(3).  Disability Discrimination Act, s 26.  Anti-Discrimination Board of New South Wales, Australian Capital Territory Human Rights Office, Anti-Discrimination Commission of Queensland, Equal Opportunity Commission of South Australia, Equal Opportunity Commission of Victoria, Equal Opportunity for Women in the Workplace Agency, Northern Territory Anti-Discrimination Commission.  In 2000-2001 35 % of all complaint to HREOC ended in conciliation: HREOC, Annual Report 2001-2002, chapter 2.  Womens Rights Action Network Australia, Retreating from the Full Realization of Economic, Social and Cultural Rights in Australia: A Gendered Analysis (2000), 9.  Chris Ronalds, Discrimination Law and Practice (1998), 101.  In 2000-2001, 18 complaints (4%) were made in the area of housing, land and accommodation under the Racial Discrimination Act, only 4 complaints (1%) were made in regard to accommodation under the Sex Discrimination Act and 31 complaints (4%) were made in relation to accommodation under the Disability Discrimination Act: HREOC, Annual Report, chapter 2.  Public Interest Law Clearing House Homeless Persons Legal Clinic, Promoting Equality: Homeless Persons and Discrimination (2002) 10-12.  Australias Welfare 2001, Australian Institute of Health and Wellbeing (2001).  NSW Department of Housing, Policy AL0040A: Priority Assistance.  Donna Chung, Rosemary Kennedy, Bev OBrien, Sarah Wendt, Home Safe Home - The Link between Domestic and Family Violence and Womens Homelessness (2000) 71.  Donna Chung, Rosemary Kennedy, Bev OBrien, Sarah Wendt, Home Safe Home - the link between domestic and family violence and womens homelessness (2000) (Home Safe Home).  Ibid 66.  Ibid.  Ibid.  Ibid 64.  Ibid 68.  Ibid.  Ibid 68.  Ibid 71-2.  Ibid 72.  Ibid 71-2.  Womens Rights Action Network Australia, Retreating from the Full Realization of Economic, Social and Cultural Rights in Australia: A Gendered Analysis (2000), 22.  Commonwealth Department of Family and Community Services, Supported Accommodation Assistance Program (SAAP III) - National Evaluation (1999), 40.  SAAP National Data Collection, Annual Report 2000-2001 (2001) 22, Table 3.11.  Mike Berry, David MacKenzie, Linda Briskman and Thami Ngwenya, Victorian Indigenous Homelessness Study Final Report (August 2000), 15.  Mike Berry, David MacKenzie, Linda Briskman and Thami Ngwenya, Victorian Indigenous Homelessness Study Final Report (August 2001), 59.  Mike Berry, David MacKenzie, Linda Briskman and Thami Ngwenya, Victorian Indigenous Homelessness Study Final Report (August 2001), 7.  Mike Berry, David MacKenzie, Linda Briskman and Thami Ngwenya, Victorian Indigenous Homelessness Study Final Report (August 2001), 59-60.  Senator Amanda Vanstone, Aboriginal Housing Boost, Press Release (19 April 2024).  Mabo v Commonwealth (No. 2) (1999) 175 CLR 1.  Decision 2(54) on Australia: Australia, 18/03/99. CERD/C/54/Misc.40/Rev.2, 18 March 1999.  Consideration of Reports: Third Periodic Report, Australia, CEDAW/C/1997/II/L.1/Add.8, 22 July 1997, para.41.  Commonwealth Office of the Status of Women, State and Territory Consultation with Migrant and Refugee Women (2001), 4.  Australian Housing and Urban Research Institute, A Comparative Study of Housing Needs and Provisions for Recently Arrived Refugees: Summary (2001).  Ibid.  Donna Chung, Rosemary Kennedy, Bev OBrien, Sarah Wendt, Home Safe Home - The Link between Domestic and Family Violence and Womens Homelessness (2000).  HREOC, The Human Rights of Rural Australians, Occasional Paper, May 1996, 5.  Women with Disabilities Australia, Submission to the Senate Inquiry into Housing Assistance (1997).  Women with Disabilities Australia, Housing Issues for Women with Disabilities in Australia: A Discussion Paper (1996).  Ibid.  Ibid.  Ibid.  Ibid.  Terry Burke and Kath Hulse (Australian Housing and Urban Research Institute and Swinburne-Monash Research Centre), Sole Parents, Social Wellbeing and Housing Assistance (2002) vi.  Bob Birrell and Virginia Rapson, The Location and Housing Needs of Sole Parents: Positioning Paper (2001) 9.  Terry Burke and Kath Hulse (Australian Housing and Urban Research Institute and Swinburne-Monash Research Centre), Sole Parents, Social Wellbeing and Housing Assistance (2002) 13.  It rose from 14.6 % in 1986, to 19.4 % in 1996 and 22 % in 1999.  Terry Burke and Kath Hulse (Australian Housing and Urban Research Institute and Swinburne-Monash Research Centre), Sole Parents, Social Wellbeing and Housing Assistance (2002) vi.  67 % of CRA recipients (ie in private housing tenants) state that they had moved two or three times in the previous three years, compared with 39 % of pubic tenants: Terry Burke and Kath Hulse (Australian Housing and Urban Research Institute and Swinburne-Monash Research Centre), Sole Parents, Social Wellbeing and Housing Assistance (2002).  Ibid.  Ibid, vii.  Calman & Ors v Haloulos (1986) EOC 92-163.  Womens Services Network, Domestic Violence in Regional Australia (June 2000), 10.  Youth Allowance is paid under the Social Security Act 1991 (Cth).  MaggiHughes and KarenCharman, Beyond the Doll House, Developing Inclusive Policy for Young Women in Accommodation and Support Services (1997).  Womens Services Network, Domestic Violence in Regional Australia (June 2000), 11.  Othilas Young Womens Housing and Support Services, Women and Housing: Information about Issues Facing Women in Regards to Housing (2000).  Case Worker, Emergency Accommodation Support Enterprise, Loddon Campaspe Region, cited in Public Interest Law Clearing House Homeless Persons Legal Clinic, Promoting Equality: Homeless Persons and Discrimination (2002).  Womens Services Network, Domestic Violence in Regional Australia (June 2000), 10.  MaggiHughes and KarenCharman, Beyond the Doll House, Developing Inclusive Policy for Young Women in Accommodation and Support Services (1997).  Older Womens Network, Women and Pensions, paper presented to the Senate Standing Committee on Superannuation, 1995, 5.  Grania Sheehan and Jody Hughes, Division of Matrimonial Property in Australia, Research Paper No 25, AIFS, March 2001, at 5 (referring to Ruth Weston and Bruce Smyth, Financial Living Standards after Divorce (2000) 55 Family Matters 10).  Mallett (1984) 156 CLR 605; Ferraro (1992) 111 FLR 124.  Grania Sheehan and Jody Hughes, Division of Matrimonial Property in Australia, Research Paper No 25, AIFS, March 2001, at 5 (referring to Ruth Weston and Bruce Smyth, Financial Living Standards after Divorce (2000) 55 Family Matters 10, 31.  Ibid 35.  Juliet Behrens and Bruce Smyth, Spousal Support in Australia, Working Paper No 16, Australian Institute of Family Studies, 1999, at 7.  R Weston and B Smyth, Financial Living Standards after Divorce (2000) Family Matters No 55, 10-15.  Tenants Union of Victoria, Security of Tenure, Policy Bulletin, 2000 at www.tuv.org.au  Ibid.  There is no national definition of affordability of housing endorsed by the federal government, but a definition used by the National Housing Strategy (NHS) in the early 1990s has been widely used by both government and non-government institutions. The NHS proposed a definition of affordability to be a maximum of 30% of income that households should spend on their housing.  Australian Council of Social Service, Public & Community Housing: A Rescue Package Needed (14 October 2024) 1.  A person is said to be experiencing housing stress if they fall within the lower 40% of income distribution and spend more than 30% of their income on rent or mortgage repayments.  Affordable Housing National Research Consortium, Affordable Housing in Australia: Pressing Need, Effective Solution (September 2001) 2.  Australian Council of Social Service, Public & Community Housing: A Rescue Package Needed (14 October 2024) 4.  Ibid 12.  Australian Bureau of Statistics, Counting the Homeless (1999) ABS Catalogue 2041.0.  Australian Housing and Urban Research Institute, Sole Parents, Social Wellbeing, Housing Location and Housing Assistance (June 2002). Research and Policy Bulletin, p 1.  Ibid 2.  Ibid 3.  Sarah McKinnon, Fairer Public Housing System for Victorians, Victorian State Government Release, 20 May 2002, 2.  Affordable Housing National Research Consortium, Affordable Housing in Australia: Pressing Need, Effective Solution (September 2001), 20.  Affordable Housing National Research Consortium, Affordable Housing in Australia: Pressing Need, Effective Solution (September 2001), 20. 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