The Residential Tenancies Act establishes an independent complaints mechanism in the form of Tenancy Services and the Tenancy Tribunal. Alongside the Act, Healthy Homes Standards establish minimum standards for heating, insulation, ventilation, moisture, and draught stopping. These standards are intended to ensure the quality of rental properties and keep them warm and dry. The Residential Tenancies Act exempts transient and short-term housing, i.e., accommodation provided for less than 28 and 90 days respectively. When emergency and transitional housing initiatives were originally developed, the intention was that both forms of accommodation would be provided for periods shorter than these timeframes: At the time that the Government’s current transitional housing and emergency housing programmes were introduced, it was not envisaged that clients would remain in the services for extended periods of time.61 52 Human Rights Commission However, legal advice was provided to Cabinet in 2020 that the increasing average length of stay in emergency accommodation and transitional housing meant this accommodation was now likely to be subject to the Act. Following that advice, Cabinet made the decision to exempt emergency housing system accommodation (both emergency accommodation and transitional housing) entirely from the Act, rather than amend the legislation to create new provisions specifically for these types of accommodation. Since that legislative change in 2020, residents living in the emergency housing system are not entitled to the protection contained in the Act, including access to Tenancy Services and the independent Tenancy Tribunal. While transitional housing providers have their own internal dispute resolution procedures that residents can follow, these are not independent, there are no review or appeal processes, and disputes cannot be escalated to independent bodies such as Tenancy Services and the Tenancy Tribunal.