<p>Observations of Ireland on the draft General Comment on children in street situations.</p><p>Committee on the Rights of the Child</p><p>1. Ireland would like to offer the following observations on the draft General Comment of the Committee on the Rights of the Child on children in street situations:</p><p>2. Generally, the Irish Government has adopted a whole-of-government approach to tackling child poverty which includes: child and family income supports; prevention and early intervention services in disadvantaged areas; access to employment for jobless households with children; national programme to tackle educational disadvantage; physical activity plans and the provision of school meals. </p><p>3. In relation to Article 27 (paragraph 42) of the Draft General Comment, Ireland suggests that the Committee clarify the relevance to “direct material assistance to children”, and if this extends to financial supports. In Ireland, income support is provided to families with children through a combination of universal and targeted child income supports, including child benefit, qualified child increases for welfare recipients, family income supplement and the back to school clothing and footwear allowance. This support, while paid in respect of a child, is not provided directly to children. The focus is on providing support through services rather than direct social welfare payments made directly to them. A similar point arises in paragraph 46 where it is stated that “children in street situations should be included in universal health coverage and social protection schemes.”</p><p>4. Regarding Article 7 on birth registration and Article 8 on identity (paragraph 34), in Ireland, persons may request a Public Service Card (PSC) from the Department of Social Protection, which is available to assist people accessing a range of Government services to verify their identity. The PSC is not usually supplied to persons under 16 years of age. </p><p>5. Many of the situations described by the Committee are not typical in Ireland. Some of the recommendations on developing strategies in Part IV B (pages 5-7) would appear not to be of relevance in all States. However, the definition of a child in a street situation is sufficiently broad that it may encompass some situations relevant to Ireland, for example, children in a homeless family. It seems preferable that the recommendation be modified so that in States where the situations described are atypical, children in street situations are included in other more general strategies, whether on children or on homelessness. </p><p>6. On a separate point, consideration might be given to reviewing the layout of the draft General Comment. While it is understandable that the document has been themed under various headings and the paragraph numbering is logical, the Articles referred to within the headings do not flow sequentially. Take for example, section B, which starts at Article 15, then Articles 7 and 8, then Article 13, then Article 16. </p>