A/HRC/28/62 challenge for local residents is to claim their rights within a complex web of regulatory schemes and decisions applied by an array of governmental actors. 23 24. Homeless people have faced similar struggles. An increasing number of cities, particularly in affluent countries, have responded to homelessness by criminalizing such acts as sitting, lying down, or sleeping in public, or by criminalizing those who help feed homeless persons.24 Challenging that discrimination in the United States, for example, has meant addressing an array of laws and policies at multiple levels of government ranging from constitutional law and housing legislation to local bylaws and ordinances.25 25. The absence of human rights obligations in the priorities promoted by donor and international development agencies in the context of decentralization is also a challenge for the implementation of the right to adequate housing. For instance, in Indonesia, the International Monetary Fund, the World Bank, the Asian Development Bank, the United Nations Development Programme and other donor agencies,26 at the turn of the millennium, actively promoted decentralization without sufficient attention to human rights. 26. As noted by the former Special Rapporteur on adequate housing in the report on her mission to Indonesia (A/HRC/25/54/Add.1), as a result of decentralization, significant powers have been partially devolved to the provinces, districts and municipalities. However, the decentralization of planning and land administration did not appear supported by institutional capacity, resources or organizational tools (paras. 10–11). During her mission she identified many of the obstacles to the implementation of the right to adequate housing associated with decentralization when it is not properly informed by human rights, such as “the fragmentation of programmes between various agencies and the inefficiencies of existing coordinating mechanisms” (para. 25) and the limited capacity of local governments to provide alternative housing to people who had been evicted from their homes (para. 51). V. International accountability 27. The primary dialogue between international human rights mechanisms and procedures is with the national Government. With some exceptions, noted below, that has generally resulted in less attention paid to the critical responsibilities of local and subnational governments in relation to housing. In the Special Rapporteur’s view, within the existing framework of dialogue between States parties and treaty body monitoring mechanism, there is room for considerably more engagement with the responsibilities of subnational governments in relation to the right to adequate housing. 23 24 25 26 Jane Weru et al, “Confronting Complexity: Using Action Research to Build Voice, Accountability and Justice in Nairobi’s Mukuru Settlement”, World Bank Legal Review (forthcoming). National Law Center on Homelessness & Poverty, No Safe Place: The Criminalization of Homelessness in U.S. Cities (2014), p. 8. Available from https://stateinnovation.org/uploads/asset/asset_file/2261/2014_No_Safe_Place_The_Criminalization_ of_Homelessness_in_US_Cities.pdf. Joint response to questionnaire from NHLCP, Columbia University and NCCP (see note 2 above), p. 4. Christopher Silver, “Do the donors have it right? Decentralization and changing local governance in Indonesia”, in Globalization and Urban Development, Harry W. Richardson and Chang-Hee Christine Bae, eds. (Berlin, Springer, 2005). 9