Teresa Costello
Agricultural Panel · Fianna Fáil · Ireland
“For example, in Tallaght, Firhouse and Ballyroan, people are telling me that the road and junction narrowing has led to increased congestion, longer journey times and frustration on the part of motorists, while also making it more difficult for buses, delivery vehicles and larger vehicles to navigate safely.”
“Likewise, long-acting reversible contraception such as implants and intrauterine devices will continue to be provided through appropriately trained medical professionals. These safeguards ensure that patient safety remains at the heart of this new service. The legislation represents good use of public resources.”
“I thank the Minister of State for being here today. Over the past few years and during my time as a councillor, there have been many changes to the roads in my area. It led me to ask the Minister to undertake a comprehensive review of the design manual for urban roads and streets, commonly known as DMURS.”
“I am not the first to raise this and I will not be the last but I am constantly receiving reports - one as recently as this morning - about the huge number of dumped nitrous oxide canisters in the community. If there is a car park that does not have a gate on it is left full of these. I have had to clear up car parks with people.”
“While I acknowledge the council's position, many local people's lived experience has been different from what has been said about DMURS. We are seeing queues building up at peak times, greater difficulty accessing side roads and a road network that is becoming less efficient for everyone who depends on it.”
“I looked at one particular junction where cars were constantly overshooting white lines. It was very confusing and difficult for motorists. The proposed removal of village car parking under DMURS creates significant challenges.”
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“When Senator Ryan referenced a lack of funding for certain organisations, maybe they have not gone about getting the funding or applying for funding in the manner it is supposed to be applied for. Sometimes, I get queries from people saying that their organisations are not get any funding, and when I ask if they have applied for it, they might not have. I ask if they have a bank account, and they reply that they do not because theirs is only an informal group. If we were handing out money informally, we would be held to account for that.”
“I commend Senator Boyhan who in his caring nature has been very clear with regard to this Bill and making sure that facilities are properly monitored. I commend the Minister of State because unannounced visits are very important. I have learned something in this discussion. I would have been right behind the idea of unannounced visits. When people do not know when they are going to be inspected, they work to a standard and we cannot let it slip. I did not think through the follow-up where they are working together. That is me not knowing something; every day is a school day. I do not think any of us is under any illusion as to the importance of monitoring and keeping an eye on how things are going. The Minister of State has said she reviews these reports all the time and keeps on top of it.”
“Genomics is the study of the body's complete set of DNA and how genes influence health and disease. Genetic testing allows us to identify specific inherited conditions. I underwent genetic testing following my breast cancer diagnosis, so it is an area I am particularly interested in and I am really glad that this has come forward. It can be very beneficial for patients with cancer, rare diseases and a host of other illnesses. We talk about preventative medicine and early diagnosis. This is really a game-changer and is fascinating.”
“I welcome this debate on genetic and genomic medicine and I commend the proposers for bringing forward a motion on an area of healthcare that is rapidly transforming how we prevent, diagnose and treat disease. I find it fascinating. Fianna Fáil welcomes this discussion and the Government's ongoing continued commitment to improving genetic and genomic medicine services in Ireland. Our vision is clear. We want a patient and family-centred genetics and genomics service aligned with the principles of Sláintecare, particularly equity of access, integration of care and improved patient outcomes. Advancing genetics and genomics is central to the future of our health service. It enables earlier diagnosis, more precise and targeted treatments, better disease prevention and more informed care for patients and their families.”
“I am glad to hear the Minister of State has hit the road and is visiting the various CAMHS teams, because to acknowledge that there is a disparity between certain CAMHS teams is very valid. Today, in the health committee, one thing that struck me was that Jigsaw said that some CAMHS teams do not accept referrals from it, but others do. That is wrong. It is almost a postcode lottery as regards where accepts referrals. I was not aware the Minister of State had hit the road on it, but I am happy she has and I am glad she acknowledged the differences, because it shows we can achieve change.”
“Just speaking on the issue of a child being put into an adult facility, what is age-appropriate? I just want to address that. If they are in an adult facility for a very short time, under the care of nurses 24-7, in a room on their own, is that not appropriate for their age for a short space of time? If for one second they were going to be put into a ward with four people, I would be saying that is not age-appropriate. If they can be shielded from the other adults, let us say, are they not in an age-appropriate setting for that short time? I am just putting it out there as something to think about. If they can be protected as such by being looked after 24-7 by nurses in a private room, which is the only offering that has been made in these emergencies, is that not appropriate to their age?”
“I acknowledge what happened in the past, but we are looking forward now. When we are out the other side of all this, recovery is going to be at the heart of it.”
“We have spoken about the aspirations for this Bill. The bar should be very high, as the Minister of State said. What strikes me is what was said about recovery. We want to see people getting better. We want to see them recovering and returning to their lives. We want them to go back to their communities and families and living their lives again. That is what lies at the core of this matter, and it is what struck me during the debate. I commend those who did so on raising concerns about this. I also think as a parent. However, and I have said this, that if it was my child who was 17 years of age, I would say put them into an adult facility for those 24 or 48 hours, have them monitored, make them better, get them home to me and let them have their life. I know this is not being said to prevent that.”
“I commend Senator Boyhan on emphasising the rights and welfare of children in the context of this matter. I wish to speak about children being put into adult services or wards in emergency circumstances. The picture I am have in my head is of a 12-year-old in a ward with 50-year-olds. I accept that it does not happen like that; it is an emergency reaction. There were two 17-year-olds in a private room on their own.”
“This morning, Ziva will be buried, and in truly Ziva style, she has planned the day with no detail left out. My thoughts are with her mam, dad, sister, all of her family and friends, and her beloved dog, Koa. Ziva, you were too young to experience what you did, but you were not too young to be heard. I heard you and I will continue to advocate and spread your message. Thank you for what you have done for the breast cancer community. May you rest in peace.”
“Its mission is to challenge the myth that breast cancer is an older woman’s illness, to highlight delays in diagnostic scanning for younger women, and to ensure that young women are listened to. Even when dealing with her own illness, Ziva tirelessly advocated for change. In 2025, she became a patient ambassador for Breast Cancer Ireland’s Very Pink Run. She organised fundraisers for Oscar’s Kids Ireland. She made numerous media appearances and raised vital awareness about how, yes, women in their 20s could and did get breast cancer. Ziva lived life to the full. She travelled and attended many events, always looking so stylish. She went to concerts, the most recent being Ed Sheeran. This time last year, Ziva visited New York, a place she had long dreamed of seeing. She cherished making memories with her friends and family.”
“Over the weekend, I received the heartbreaking news that Ziva Cussen had passed away. She was just 24 years old. Ziva visited the Seanad on a number of occasions and was present when we held a debate on breast cancer services. It was her strong belief that the system must do better for young women. Ziva was diagnosed with stage 4 breast cancer at just 21 years of age. I first met her in February and we spoke at length about diagnosis, treatment and the realities of living with breast cancer at such a young age. From our very first conversation, it was clear to me that Ziva was someone truly special - warm, engaging, full of life, strong and determined. Alongside Muireann McColgan and Niamh Noonan, Ziva co-founded the Too Young To Be Heard campaign.”
“I thank the Minister for his response. When he took up this role, I knew that there would be movement in this area because I had spoken to him about it previously. He understood at that time how important it was, and it was something he had worked on prior to taking up his current role. In that context, I am happy with today's response. I am happy that he took the 26 recommendations seriously and that he has made certain moves, particularly as this was a priority for him previously. Prior to his being in this role, I had asked the question and there had not been as much movement. What he listed out today is really positive. Conflict resolution and the avoidance of conflict between parents is important. The Minister is making really good strides in achieving that, so I thank him.”
“It rewards delay, avoidance and non-compliance, while exhausting the parent who is already carrying the financial and emotional load. Child maintenance should not depend on how resilient or legally confident a parent is. It should be enforced consistently, efficiently and automatically. Child maintenance is about dignity, stability and fairness. Our children deserve a better system than one that looks the other way. It is time we fixed it.”
“Even when non-payment is proven, outcomes can include adjournments, variations of the order or further delays, while arrears continue to grow and children continue to go without. Other countries that have centralised child maintenance service agencies that calculate payments collect them and enforce them automatically. These systems reduce conflict, ensure consistency and, most importantly, put children first. We need a system that recognises child maintenance as essential rather than optional, one that enforces responsibility fairly and consistently, and stops forcing parents to fight the same battle repeatedly just to secure what their children are entitled to. This is the heart of the problem. The system relies on persistence rather than protection.”
“Those systems work efficiently, with money tracked, payments enforced and consequences that are real. When it comes to child maintenance, however, which is money that directly affects children's well-being, there is no automatic follow-up and no assumption that a missed payment is urgent. To recover arrears through the District Court, a parent must complete detailed applications, file multiple copies, arrange personal service of documents, swear statutory declarations, meet strict deadlines and attend court hearings, often repeatedly. Any small mistake can delay the case or cause it to be struck out entirely, forcing the parent to start again from the beginning. If the paying parent is employed, an attachment of earnings order may be sought. If that parent is self-employed, unemployed or evasive, enforcement becomes even more difficult.”
“Child maintenance is not a bonus or a luxury used to get your hair done, go on holiday or buy a car. It is not optional. It is a legal and moral responsibility to ensure that children that you have brought into this world have their needs met and are provided for. Anyone raising children knows it costs money to meet their needs. Children do not survive on fresh air. If a parent does not pay maintenance, what happens? The answer is often "very little." The parent who should be receiving the payment must go back to court repeatedly, at their own expense, taking time off work, arranging childcare and reliving conflict, all while the child, who, I repeat, was brought into the world by two parents, continues to go without. Compare this with how we collect taxes, fines or social welfare overpayments.”
“I thank the Minister for being here today. In 2024, the previous Minister published the review of the enforcement of child maintenance orders. There were 26 recommendations grouped under three approaches, a consensus-based approach, a compliance-based approach and a deterrence-based approach. I acknowledge the Minister's work on the matter of child maintenance and efforts on the implementation of these guidelines. Every day, in every room we sit in, chances are we are in the company of a parent raising children or a child without any form of maintenance being paid to them by the other parent. That is a disgrace. It is indefensible for someone not to be willing to step up and own their responsibility by financially providing for a child they have brought into this world is indefensible.”
“I share the Minister of State's concerns in respect this matter. As the previous speaker mentioned, we have all read stories. I have heard conversations when a story hits the headlines about someone being hurt. People ask why nothing was done and say that something could have been prevented. If people are admitted involuntarily, it might divert them from the criminal justice system. It could prevent them being incarcerated on criminal charges. It could help them. It was asked whether it was worded correctly. When I read it, I asked myself why should another person's welfare not come into it. It is too late if someone is killed or badly harmed. The people who are speaking today will say it could have been prevented. If we take this out, we have to sit and think about the impact it will have.”
“I thank the Minister of State for his response. I am concerned about the self-evaluation. An independent evaluation is needed. If we want to do things right, renting a room in a community centre is not the correct standard for the people in question. I have a few questions. What is the current budget for day services? How much was secured in budget 2026? What was last year's day services capital budget allocation? What was secured for 2026? The Minister of State may not have those answers to hand but I would appreciate it if he could forward the questions to the Minister. I would be glad to get that information. I have a concern about community centre rooms being rented. Independent evaluation should be carried out. A primary care setting would be more appropriate for that.”
“We do not yet have clarity on when nationally agreed permanent standards and an independent inspection regime will be in place. Adults with disabilities deserve day services that reflect dignity, quality and consistency, as set out in New Directions. It is time to bring this long-promised reform to completion by setting out a firm timeline for standards that ensure quality, safety and inclusion in every community hub used for day services.”
“These differences highlight the need for reform, quality assurance systems and support for providers to meet common standards. I accidentally walked into a community hub and was surprised at how basic it looked, given that the people using the hub had originally been availing of the day services in Stewarts Care, which was providing a high standard of amenities. I asked the Minister when she would instruct her Department to instruct the HSE to establish and publish clear national standards for community hubs and buildings used for day services for adults with disabilities and when those standards would be subject to independent inspection, for example, by HIQA, rather than self-evaluation? We know the interim standards exist. We know self-evaluation is under way.”
“Interim standards were developed by the HSE to check how well adult day services are following New Directions but providers are not yet being inspected against these interim standards. Instead, the HSE has asked all adult day services to self-evaluate their services against the interim standards, with support and training on how to do so. Managers must now start self-evaluations which must include asking stakeholders to rate how their service is doing. Providers must set actions for areas where stakeholders agree there is room for improvement. This process is intended to promote continuous improvement in service quality. Despite this progress, very few positive comments have been made about the buildings or locations used by day services. Many people benefit from their day services but others describe unhelpful or negative experiences.”
“Providers themselves argued for quality standards grounded in person-centred principles alongside systems for monitoring services and support to provide them. The New Directions framework established that all service providers must work with the HSE to prepare plans for delivering New Directions within a quality assurance framework that the HSE will develop. That commitment to quality is to be expressed in service standards and in the arrangements made for monitoring and evaluating services. Yet, almost 14 years after New Directions was published, we still do not have a permanent national standard for community hubs and service locations used for day services.”
“As part of that review, a census was conducted which highlighted a significant absence of nationally agreed or clear definitions about what constitutes a day service. The report describes services that have developed without the benefit of a coherent national guidance framework or robust quality assurance systems. A consultation engaged more than 1,500 people, including service users, families, service providers and the public, on what is working well and what is not. In regard to what people want to see in future service provision, the consultation highlighted the striking differences in people's experiences of services and underlined the need for quality assurance systems and support for providers to achieve common standards.”
“The purpose was clear: to bring these services into alignment with the principles of person-centredness, quality and accountability, and to ensure that every adult with a disability had access to supports that enabled them to live a life of their choosing. The review culminated in the publication of the New Directions report in 2012, which marked a radical shift from provider-led programmes towards user-led supports. Under New Directions, services are designed so that adults with disabilities can participate as equal citizens in their communities and contribute meaningfully to those communities. Crucially, the report also states that the new approach must be underpinned by nationally agreed standards. However, work remains to be completed.”
“I welcome the Minister of State. Day services for adults with disabilities provide a vital network of support for more than 25,000 people across this State, individuals whose personal circumstances, interests and aspirations are widely diverse. There are people with physical, sensory and learning disabilities. They range from young adults beginning their journey into adult life to older people of retirement age. They live in small communities in isolated rural areas and in towns and cities in every part of our country. In 2007, a comprehensive review of HSE-funded adult day services was initiated to modernise and reconfigure the services we were providing.”
“Regarding those aged under 18 being admitted to adult facilities, I was under the impression that there are only two such facilities. Ambition is being shown, particularly as the numbers have decreased so drastically. I appreciate and completely understand and respect the concerns expressed, which are very valid. The Senators are right to raise them. However, I feel ambition has been shown because the numbers have decreased so drastically. It was my understanding that if a child aged 17 and a half got into difficulty, they could be brought to an adult area but would be in a room on their own. As a result, there is a level of privacy for the patient. We have to acknowledge that also. Perhaps the Minister of State will expand on this matter a little more. That was the impression I was under. I feel that ambition is being shown in this area.”
“I thank the Minister of State and welcome what she said. I had concerns about the changes involved and spoke to the Minister of State openly about them. Being a mother, I nearly think of 18-year-olds as children. I know there is the Gillick competency test. This was something I was looking at in the context of the capacity to consent and in establishing if a child possesses that capacity between the ages of 16 and 18. I would like to flesh this out a bit more. Who is going to have the responsibility for determining if those between the ages of 16 and 18 have capacity? What kind of testing - and I know this is probably down the road - will be undertaken to establish that they have capacity? Again, I welcome the Minister of State's acknowledgement of the safeguarding needed in respect of this matter. I think that is so important.”
“It is really good that we are having such a lengthy debate on it because it really matters. As a mother, as I am listening, I am thinking that if it was my child, I would work with them, as the Minister of State said about those two cases. I am sure that for those parents, it was not a nice situation to be in, but they worked, and they agreed to that because it was in the best interests of their child. To have that option removed would not sit easily with me.”
“I have been listening to the debate and can see where Members are coming from. As a parent, if my child was in an emergency situation, I would want them in any unit that would be able to help them in that emergency moment. I understand where people are coming from. However, could I honestly live with myself if a child did not get emergency care because of something we legislated for here? I do not think so. Would it sit right with us, after this goes through, if a situation arose and a child was not able to be facilitated in an adult unit in an emergency situation? How would we feel about that? That is what I am asking myself when I am sitting here listening to everybody. I know everybody is coming at it from a place where they care, and I feel the empathy around the room from everybody. We want to get it right.”
“I also want to refer to something that Senator Ruane raised yesterday about people who may have had criminal pasts but are helping people now. We have to acknowledge that people can change while also having due diligence. I would hate it if someone who was a really good asset and really understood the struggles of some people was not able to help others. We have to acknowledge that while some people may have a past, they can make a huge contribution in helping other people break the cycle. I just want to acknowledge that.”
“While I welcome today's report and acknowledge the enormous work that was done during the pandemic, I suggest that we need to focus on present challenges, particularly delays in diagnostic scanning. Addressing these delays is essential if we are to ensure that every person, especially younger women, has the best possible chance of early detection, timely treatment and ultimately survival.”
“I spoke publicly, including in an interview with the Irish Independent , to encourage people to visit their GP if they felt unwell during this time. All of this re-enforces the message that early diagnosis is key in the fight against cancer. For that reason, I will continue to highlight my concerns around delays in diagnostic scanning for younger women attending symptomatic breast clinics. On Friday, I attended a fundraising event for Breast Cancer Ireland. We heard powerful lived experiences from women with late-stage cancer. We learned about groundbreaking research and ongoing improvements in treatment. Once again, the message was clear: know your own normal, check yourself regularly and see your GP if something is not right. Early detection saves lives.”
“I welcome the news today that the national cancer registry of Ireland has confirmed that there was no consistent rise in late-stage cancers following the pandemic and that survival rates for 2020 and 2021 remained broadly in line with previous years. I know it will monitor this as the years pass. This is reassuring news and reflects the huge efforts made across our health services during what was a challenging time. However, we know that cancer diagnoses dropped sharply in early 2020 as Covid-19 disrupted GP visits, hospital appointments and screening services. During that period, a huge emphasis was placed on encouraging people to visit their doctor if something did not feel right. I really worried that people would be too afraid to attend their GP and I worried about the consequences of this.”
“I thought it was very clear, and I do not think it is right to be mimicking people's voices in the Chamber. We are dealing with something very important here. This is not fun and games. As somebody very new to the Seanad, I do not think that was acceptable.”
“In a similar way, I thought what the Minister of State said was very human rights-focused. I understand that it takes a certain amount of time for people to come around and be in a better position to avail of care. That is what I heard as well.”
“I do not understand that when they are not getting private care. I would like an answer on that to see why a patient receiving public care would be asked to do that.”
“Any surplus or deficit is carried forward and factored into subsequent years’ calculations. The integrity of this mechanism is vital to the functioning of a fair and accessible health insurance market. This Bill continues the annual work required to protect community rating and uphold equity within private health insurance. By supporting it, we are reaffirming the principle that older people and those with greater health needs must not face prohibitive premiums. The update is technical but its impact is fundamental: a stable system, a fair distribution of risk, and protection for those who depend most on health insurance. I have just one question that I wish to raise. I have observed that patients in a public hospital receiving public care are often offered an option to sign for a private health insurance claim.”
“This mirrors the existing arrangements for ordinary members of the authority. The term of the current chairperson is unaffected. Today, 2.53 million people hold private health insurance, representing 46.3% of the population. When revising credits and stamp duties, the Health Insurance Authority must balance several considerations: protecting community rating; avoiding overcompensation; sustaining the market; supporting fair competition; and avoiding surpluses or deficits from year to year. The legislation before us does not introduce new policy. It simply updates the scheme in line with the authority’s recommendations, based on expected claims costs and market conditions for the 2026 to 2027 period. The risk-equalisation scheme remains Exchequer neutral. Stamp duty levies are set to fully offset the cost of credits.”
“The alternative would be a breakdown in community rating and a shift towards age-based and risk-based pricing, something this Oireachtas has consistently rejected. The Bill also contains an important governance change. It amends the term of appointment for the chairperson of the Health Insurance Authority. Under the code of practice for the governance of State bodies, board members should serve a maximum of eight years. The current legislation only allows a chairperson to be appointed for a five-year term, meaning they cannot be reappointed without breaching the eight-year limit. This Bill will allow appointments of up to five years, giving the Minister flexibility to align the chairperson’s tenure with the code, for example through a five-year term followed by a three-year term.”
“Stamp duty rates will also rise for advanced contracts. The rate for those aged 17 and under will increase from €156 to €172 and for adults, it will rise from €469 to €517. For non-advanced products, the levy will increase from €31 to €34 for those aged 17 and under and from €94 to €103 for adults. These adjustments reflect medical claims inflation in 2014 and a higher projected private hospital inflation rate, revised from 5% to 8%. While insurers may reflect these increased levels in their premiums, stamp duty remains a cornerstone of the risk equalisation scheme. Without these contributions, the credits that allow insurers to cover higher risk individuals without charging them more could not be sustained.”
“Ireland's risk equalisation scheme operates within a community-rated, voluntary, private insurance system and must be periodically approved by the European Commission as a form of state aid. Approval was granted in March 2022 for the scheme to operate until March 2027. Each year, this legislation is required to update the levels of credits and stamp duties, in line with actuarial evidence and the recommendations of the Health Insurance Authority. The key changes to credits and stamp duty in this Bill are as follows. Age-related credits will increase for most people aged 65 and over, particularly those with advanced policies. The hospital day case credit rises from €81 to €100 and the overnight stay credit from €163 to €165. The high-cost claims credit will now reimburse insurers for 50% of claims above €50,000, up from €45,000.”
“It is collected and ring-fenced for the risk equalisation fund, which is redistributed to insurers in the form of credits. Those credits compensate for the higher cost of covering older and less healthy individuals and they keep the market stable and fair. This year's Bill provides for increases to the levy on both non-advanced and advanced policies. These adjustments are essential. If levies and stamp duty do not keep pace with rising claim costs and demographic pressures, the risk equalisation scheme becomes vulnerable. An underfunded scheme risks undermining community rating, distorting the market and placing disproportionate financial pressure on insurers with older or higher risk customers. That would run contrary to the very purpose of the scheme.”
“I welcome the opportunity to speak on the Health Insurance (Amendment) Bill 2025. Fianna Fáil will be supporting this legislation. As with the Finance Bill or the Social Welfare Bill, this measure arrives annually to update the framework that sustains risk equalisation and preserves community rating in our health insurance market. Community rating is a core principle of our system. Everyone pays the same premium for the same policy, regardless of age or health status. The risk equalisation scheme is what makes that possible. It ensures that older citizens and those living with illnesses are not priced out of cover or discriminated against in favour of younger, healthier people. The stamp duty applied to health insurance contracts does not flow to the Exchequer.”
“As we said, it spans beyond the local authority, but I would have thought the Department would have had the figures. That is why the Commencement matter was related to that.”
“I thank the Minister of State very much for that. I commend South Dublin County Council. I know it is the minority, and it spans far wider than the local authority housing. Obviously, the Department would have the figures for the local authority housing and that is why I framed it in that manner. On antisocial behaviour, one of the most common complaints I hear that really distresses people is the illegal dumping and burning of rubbish within estates. I have had situations in apartment complexes where instead of going to the bins, people are repeatedly throwing rubbish in the corridors. I am dealing with residents and tenants who are absolutely distraught. It is an ongoing issue. I would like to see action on that and an end to it because people are really distressed about this.”
“I call on the Department to commit to publishing annual disaggregated data on antisocial behaviour inventions by local authorities and AHBs, and to review whether the strongest powers like excluding orders are being used to protect communities. Every tenant deserves to feel safe in their home. The law provides tools to protect them. What we need now is clarity, consistency and oversight so that these tools are used when tenancy breaches become a pattern that harms others.”
“Tenants are doing everything right yet are living with the consequences of repeated antisocial behaviour from others. They are reporting it and engaging with the process. What they see in return is a system that is slow, inconsistent and often unclear. For many, the process feels endless while their day-to-day quality of life deteriorates. I ask the Minister of State to outline the mechanisms that are available to local authorities and AHBs and crucially, how the Department monitors the use of those mechanisms. What guidance or direction is issued to AHBs to ensure that their approaches are aligned with local authorities and the expectations of the Department? It is not enough to have legal powers on paper; we need data. How many tenancy warnings are issued? How many lead to excluding orders? How many lead to full repossession?”
“In the past three years, South Dublin County Council has received almost 2,000 complaints related to council-owned properties. While some cases progress to warnings and termination, the reality on the ground is that many tenants live beside persistent antisocial behaviour for prolonged periods. Approved housing bodies now house thousands of families across the country and are subject to the AHB regulatory authority. They also have the power to seek excluding orders and to enforce tenancy conditions. However, there is little transparency around how often these powers are used, how complaints are handled and what level of consistency exists between AHBs. Tenants housed through an AHB should not have weaker protections, nor should AHBs be operating without proper scrutiny when dealing with recurring breaches.”