The Bevan Foundation is pleased to see proposals to strengthen the homelessness system but is concerned about its timing and the resources needed to make the aims a reality.
The Senedd’s Local Government and Housing Committee is scrutinising the Homelessness and Social Housing Allocation (Wales) Bill which seeks to:
- Expand access to homelessness services and provide additional support to those who need it most.
- Widen responsibility to certain specified public authorities to identify individuals who are homeless or at risk of homelessness and respond effectively.
- Prioritise allocation of social housing to those most in need.
The Bevan Foundation agrees with the statement in the Bill that the current approach to homelessness services is not sustainable in terms of monetary cost, but most importantly the human cost of a life living in the limbo of temporary accommodation. However, making the aims a reality will take significant resources and the timing of implementation is crucial to avoid unintended consequences.
The Bill seeks to reform the statutory homelessness framework, expand services and widen responsibility, but does not address the wider structural factors within the housing market and with the cost of living which are the cause of service pressures.
The Bevan Foundation’s response also says that:
- Proposals to expand the prevention duty to 6 months to reflect changes in notice periods should be welcomed giving local authorities a longer and arguably more realistic chance of working with a household to retain their current accommodation or secure somewhere else to live. We have however heard concerns about how meaningful this will be in practice and the discord this will create with the notice period’s refugee receive for leave Home Office accommodation.
- Concern around move to a more universal homelessness safety net – removing the key tests of priority need and intentionality – highlight the serious inadequacies in the supply of social housing and in particular one bedroom homes.
- The Bill talks about reviewing these temporary accommodation regulations in “due course” and “incrementally with the availability of increased supply”. Despite firmer proposals to improve temporary accommodation standards in the White Paper, the Bill only commits to a report on its use and conditions every 5 years with the first being in 2030. We are disappointed to see that there is no commitment to review this more immediately as much is already known about the negative impacts.
- The Bevan Foundation welcomes the ask and act duties which rightly acknowledge the role of the wider public sector in preventing homelessness. However, their success is also dependent upon adequate resources and training. There are also some key gaps in terms of services listed, including education and primary care services.
- The Bill highlights the current variation in the number of social housing allocations made to homeless households by housing associations and rightly seeks to address this.
- It is concerning that whilst we are seeking to provide a universal homelessness system focused on early prevention in one part of the Bill, we are proposing to close off access to social housing in another. It is proposed that local authorities will have the discretion to decide what classes of person are eligible for social housing. Restricting access to waiting lists means losing a very early prevention opportunity. We should not forget that waiting list data is also a key evidence base to inform the number of social homes which need to be developed.
The extent of the powers to make subordinate legislation given to Welsh Ministers in the Bill is extensive. Whilst we understand why the Bill gives these powers to Welsh Ministers we are concerned about the potential uncertainty this creates. We appreciate that timescales for implementation are being left flexible for the “right time” but it is important to acknowledge that this creates uncertainty for service providers and users. The extent of the powers that the Bill gives to Welsh Ministers also highlights the importance of ongoing Senedd scrutiny.