Scottish Social Housing Charter – SCSH Comments
Introduction and General Comments
The Scottish Council for Single Homeless (SCSH) is the national membership body in Scotland for
organisations and individuals tackling homelessness. Our members include voluntary sector
providers, housing associations, local authorities, academics and other professionals involved in
homelessness prevention and alleviation.
SCSH is grateful for the opportunity to comment on the Scottish Social Housing Charter as set
down in the Housing (Scotland) Bill1. The comments outlined in this paper have been formulated
from discussions we have had with our stakeholders and at two specific events.
SCSH recognises that the Charter includes important powers to modernise the regulation of
social housing, and with it, create an independent Scottish Housing Regulator to look after the
interests of homeless people, tenants and others who use the services that social landlords
provide. The Charter will also set a number of outcomes that social landlords should achieve.
While we appreciate that the outcomes must broadly cover all people who reside in social
housing, SCSH feels that the Charter lacks focus on outcomes for people affected by
homelessness. At a SCSH members consultation event our members acknowledged that the
Government planned and coordinated roadshows on the Charter were less than successful in
capturing both the views of homeless people2 and services working with homeless households.
SCSH believes this is unfortunate, as social landlords have a crucial role to play in preventing
homelessness as well as meeting the needs of those who may become homeless. Ultimately, it
provides a chance to embed Scotland's progressive approach to homelessness in the outcomes
we expect from social landlords.
We believe the Charter offers a great opportunity to define what we expect social landlords to
do and answer the fundamental questions about the role, purpose and use of the Social Rented
Sector (SRS) in Scotland. In particular, there needs to be further thought on what the state
subsidy for housing is intended to deliver and for whom. Consideration needs to be made
whether it is for providing housing for those in greatest need, or providing low cost tenure of
choice, or providing affordable housing or whether it more for creating balanced communities
with social mix, or a combination of these.
SCSH believes that in the context of changes to the role of social housing south of the border it
is extremely important for the Charter to be clear how Scotland views the role of its social
housing.
1
The Housing (Scotland) Bill passed Stage 3 on the 3 November 2010
http://www.scottish.parliament.uk/s3/bills/36-Housing/index.htm
2
Whether they are single people, families, younger people, or those living in hostels or other emergency
accommodation or those tenants previously affected by homelessness
Scottish Council for Single Homeless - Scottish Charity SC002734
1
Specific Comments
SCSH at its 11th National Homelessness Conference on the 4 November 2010 ran a workshop on
the Charter to establish member’s views on matters around outcomes for homeless people and
broader issues such as the role of the social rented sector and assessment of landlords
performance.
A. ‘Big’ or Fundamental Questions – Role of the Social Rented Sector, Social Mix, Outcomes
Our members believed that due to the overall shortage of social housing, the SRS should exist
for primarily housing those in ‘greatest need’ and that it should not simply exist as a stepping
stone to living in the private rented sector and/or owner occupation. The decision to live in
social housing should be a positive one but there was acknowledgment that for the SRS to
become a tenure option for all then it is essential that its current stigma is addressed. It was felt
that the high standard of accommodation that predominately features in the sector and the
cohesive communities which exist should be highlighted wherever possible.
Housing professionals expressed some concern about tensions that can exist in the sector where
a balance is required to be found between meeting housing need (in SCSH’s view – the main
aim) and taking into account ‘social mix’. In view of social landlords accounting for social mix,
questions were raised on whether it was required as a stated objective and what exactly
constitutes a balanced community.
Taking a broader view, members feel unguided on how the outcomes contained within the
Charter will be weighted and who decides (or has most influence) on how the outcomes are set
in terms of their significance. Although explained in more detail in the next section, SCSH
believes it is paramount that the outcomes are developed around the perspectives of tenants
and homeless people and that evidence exists to show that all views have been taken into
consideration.
Our members felt strongly that the outcomes must also relate to the Housing Options approach
adopted by some local authorities in Scotland (and championed by the Scottish Government
Housing Access and Support Team). The housing options approach refocuses existing services
and resources and can reduce the number of homeless applicants requiring re-housing. It
empowers people by giving them information and advice about accommodation options and
services available and enables them to make informed decisions.
Adoption of a housing options approach can also help prevent homelessness. Our research on
the cost of tenancy failure revealed that a typical example of homelessness can cost £15,000
to the public purse, with a more complex case costing much more. In view of this, SCSH believes
the Scottish Government and its partners should identify what outcomes could be set that could
ultimately provide incentives for organisations and local authorities to further shift the balance
towards preventative support.
Scottish Council for Single Homeless - Scottish Charity SC002734
2
B. Outcomes for Homeless People and Specific Issues that could Affect Development of Charter
Outcomes for Homeless People
Consultation with our members has identified a number of issues that could affect development
of outcomes for homeless people in the Charter. Any outcomes proposed must be able to be
evidenced at both a local and at a national level. For example, ways for providing housing
support in a rural area can vary widely to those that would be successfully adopted in a major
urban area – so outcomes set at a National level may not necessarily cater for local situations.
Even where local outcomes exist there still may be situations where one area within a council
area may find it easier than another to evidence certain outcomes. Where outcomes can be
measured locally there must be clear parameters or guidance for how this can be achieved.
Outcomes need to be realistic and measurable. For example, outcomes relating to
homelessness prevention may be very difficult to measure and ‘performance’ based assessment
in relation to this would have to take this into account. In addition, assessment must also be
able to consider the difficulties that housing providers can have in recording outcomes for some
individuals who have complex needs and/or a challenging housing situation.
SCSH’s members also identified a range of outcomes that could relate to homeless people.
Many related specifically to temporary accommodation (for example, duration in temporary
accommodation linked to length of time on the LA waiting list and for quality of temporary
accommodation), while others were more diverse and centred around provision of affordable
housing, service user involvement, Section 5 homelessness referrals (and nomination
agreements) and cross sector information sharing on homelessness prevention.
Our members also believed there should be outcomes on tenancy sustainment levels, furnished
tenancies and housing support.
C. Taking account of Homeless People’s Interests - Awareness Raising and Involving Homeless
People
SCSH and our members believe that general awareness raising on homelessness (at a local and
national level) and involvement of service users in influencing local and national housing policy
is essential for the development of robust Charter outcomes. Members believed that this had
not been fully achieved locally despite organised debates and events involving a wide range of
stakeholders.
D. Assessing Landlords Performance
SCSH welcomes an independent regulator created to drive up standards across the social rented
sector – particularly as it will also have responsibilities for regulation of homelessness services.
However, we have some concerns relating to the extent to which the Scottish Housing Regulator
(SHR) will rely on self–assessment by social landlords to achieve this function3. SCSH’s
experience in other fields (for example, when analysing take-up of the health and homelessness
standards), is that the results of analysis of self-regulation did not always accurately reflect
3
SCSH in its evidence to the Scottish Parliament at Stage 1 of the Housing (Scotland) Bill stated that regulation of
social landlords housing and homelessness functions should be risk based and centred around thematic (and
cyclical) inspections.
Scottish Council for Single Homeless - Scottish Charity SC002734
3
reality. Self–assessment can, therefore, provide an over optimistic view of one’s own
performance. In view of this, SCSH and our members strongly believe that measures are put in
place which can verify the ‘quality’ of the self assessment taking place. The SHR and social
landlords must also be aware that the effectiveness of self–assessment will be dependent on
the skills and abilities of people doing it.
Finally, it is vital that stakeholders, tenants and homeless people are given the opportunity to
feed into the self–assessment process. The SHR should ensure that clear and transparent
information on ‘performance standards’ be made available in an understandable format for all
social housing tenants (including those affected by homelessness).
SCSH is happy to elaborate on any of the points raised and are happy for the contents of this
response to be made publicly available.
Daniel Coote
Policy Officer
SCSH
30/11/2010
Scottish Council for Single Homeless - Scottish Charity SC002734
4