VI. Housing and Standard Living 1. Insufficient Securing of the Rights to Housing (218-225) 57. According to the Population and Housing Census 2005, 2.06 million households (13% of the households surveyed) were living below minimum housing standards. The Government, in No. 218 of its Replies, outlining the meaning and elements of the minimum housing standards, mentions that such housing standards can be considered a significant reflection of ‘the availability of services, materials, facilities and infrastructure’, ‘habitability’, ‘location’ and ‘cultural adequacy’, among the elements mentioned in General Comment No.4 (on ‘adequate housing’) of the Committee. However, the number of the substandard households would be much larger if some of the facility criteria and the housing structure, performance and environment criteria, which were excluded from application in the Census on the ground that they were difficult to measure in an objective manner, are included. 58. The Housing Act in force provides that the Government may give preferential benefits to substandard households, for example, by providing houses or offering loans from the National Housing Fund. However, the ongoing Comprehensive Housing Plan (2003~2010) does not contain specific measures to minimize substandard households, as it was drawn up before the Government's obligation to set up minimum housing standards and work to reduce substandard households was written in law. 59. Almost all of the residentially disadvantaged households living in underground (semi-underground) houses, vinyl houses or single room occupancy hotels are below minimum housing standards. They suffer from: a substandard number of rooms in proportion to the number of household members; a substandard space available; poor requisite facilities including a separated stand-up kitchen, a flushing toilet and a bathing facility; and substandard conditions of housing structure, performance and environment, including susceptibility to disasters such as fires and floods and poor sound-resistance, ventilation and lighting. What is worse, those living in vinyl houses are usually denied an official address by their local governments and, accordingly, their right to basic livelihood and their children's right to education are not properly protected. 60. The fact that, as of 2005, approximately 2.06 million households were living in a residence which fails to meet the space criteria and the facility criteria included in the 17