country of former habitual residence.114 The travel document section will examine any evidence regarding their attempts to obtain a passport, including official refusal responses from any Embassies. This is echoed in the travel document application form which requires individuals to “enclose with this application a letter from your Embassy/ High Commission showing that they have formally and unreasonably refused your application for a passport or travel document”.115 If the Embassy or national authorities of an individual’s former country of origin/habitual residence provide no official response, then the travel document section will examine evidence of a person’s genuine attempts to apply for a passport including formal correspondence and copies of completed application forms.116 This approach by the Irish authorities, while understandable in the absence of a formal statelessness determination procedure, is problematic as it fails to acknowledge that the individual concerned is stateless and, therefore, may have no ties to any Embassies of countries they formerly resided in. It appears to be an ad hoc measure in response to the Irish authorities’ failure to formally recognise persons as stateless. Such processes are inefficient and may last for a protracted period before individuals can access travel documents.117 An experienced legal representative in this area has noted that it is rare for Embassies and/or Consulates to issue a letter confirming that it is not possible for them to assist and it is necessary to write at least 3 or 4 times to the Embassy and evidence no response before the ISD will accept that the person has made efforts to obtain a passport. Correspondence with the travel document section shared with UNHCR Ireland’s office indicates that even if a person is granted a travel document once for exceptional reasons, they may face similar challenges during the renewal of their travel document regarding the requirement to have a letter from an Embassy showing that they refused an application for a passport for the individual concerned.118 5.2 Access to Citizenship Article 32 of the 1954 Convention provides ‘The Contracting States shall as far as possible facilitate the assimilation and naturalization of stateless persons. They shall in particular make every effort to expedite naturalization proceedings and to reduce as far as possible the charges and costs of such proceedings.’ Article 34 of the 1951 Refugee Convention similarly obliges state parties to facilitate the naturalisation of refugees, including those who are stateless stating that ‘in particular, costs should be reduced, and the naturalization procedures expedited.’ In Ireland provisions on the acquisition and loss of nationality are found in the Irish Nationality and Citizenship Act 1956 (as amended). As indicated above in chapter 3.1.1., Section 16 of the 1956 Act states that the Minister may, “in his absolute discretion,” grant an application for a certificate of naturalisation, although not all of the conditions for naturalisation are complied with, in the case of refugees and of stateless persons within the meaning of the 1954 Convention. In practice this section generally operates as a waiver in relation to the length of reckonable residence required (normally 5 years) so that stateless persons can apply, like refugees, within 3 years. This is more straightforward if the individual concerned is a stateless refugee. The Department of Justice confirmed that the determination as to the relevant residency criterion to be applied for an application for citizenship is done when the application is received. If the individual is formally recognised by the Minister for Justice as stateless then the 3-year residency criterion will apply. However, for other stateless persons without a formal recognition of their status as stateless by the Irish authorities it is difficult to show how they can benefit from this residence waiver in practice. Legal 114 Correspondence with Principal Officer, Repatriation Division, ISD Department of Justice, November 2019. 115 Department of Justice, Travel Document Application Form, available at: https://bit.ly/3VNQDnZ 116 Correspondence with Principal Officer, Repatriation Division, ISD Department of Justice, November 2019. 117 The processing times for travel documents have been increased during the Covid-19 pandemic to 27 weeks as indicated in this response to a parliamentary question 183/184 October 2021 by Minister of State at the Department of Justice Deputy James Browne, available at: https://www.justice.ie/en/JELR/Pages/PQ-13-10-2021-183 118 Correspondence shared by Immigrant Council of Ireland, November 2019. UNHCR 31