becoming less distinct in the whole emergency housing system, these differences stand out because clients in emergency accommodation will end up receiving significantly less support than those in transitional housing. We observe that the emergency accommodation initiative: • is much less likely to meet the minimum standards necessary for delivering this human rights obligation, and • has the potential to negatively affect the operation and effectiveness of the transitional housing initiative, and the overall emergency housing system. In our view, the continuing operation of these two initiatives is hindering, rather than supporting, the government’s ability to meet its human rights obligation to deliver emergency housing that meets standards of decency and other key features, as outlined in chapter 4. Immediate obligation 1: Provide emergency housing that meets minimum decency standards and other key features of the right to a decent home a) Emergency housing must meet minimum decency standards As we have outlined, emergency housing (whether emergency accommodation or transitional housing) must be clean, dry, safe and secure, and in good repair. A major theme emerging from feedback is that emergency accommodation is in many cases not providing basic habitability or essential facilities, i.e., the residents’ basic needs. If emergency accommodation was operating according to its original policy intention, where residents stay for a week before moving into more adequate long-term housing, some of the reported issues, such as unacceptable physical conditions, would be less pressing. However, when people are living in emergency housing for months at a time, motel-style accommodation becomes fundamentally inadequate, particularly where it lacks essential facilities or is significantly too small for the number of inhabitants. Compared with emergency accommodation, transitional housing is more complex. This housing is delivered through a range of different types of accommodation, and some types are more likely to meet minimum decency requirements. We acknowledge that not all transitional housing is provided through motel units; for example, apartment-style transitional housing is much more likely to adequately meets a client’s basic needs regarding decency and essential facilities, even if they remain in that housing for a longer period than 12 weeks. The fact that transitional housing is provided on a contractual basis also offers government more control over the type, quality, and adequacy of transitional housing; government can ensure minimum quality standards are outlined in each service agreement. The proposed Code of Practice for Transitional Housing aims to further clarify the expected standards of transitional housing.The draft Code requires transitional housing to comply with the Healthy Homes Standards, unless the transitional housing is a motel facility. This requirement is an improvement on the current standards for transitional housing.47 However, we note the ongoing use of contracted motel facilities for transitional housing (and COVID-19 contracted emergency housing). We are concerned that exemption of these motels from Healthy Homes Standards will result in an ongoing proportion of the government’s supply of 45