Housing System Policy Circle: Final Report for the Social Renewal Advisory Board (November 2020)

Policy Circle members:

Organisation

Representative

Crisis

Jon Sparkes (Joint Chair)

Scottish Federation of Housing Associations

Sally Thomas (Joint Chair)

ALACHO/Fife Council

John Mills

ALACHO

Tony Cain

COSLA – Political

Cllr Elena Whitham

COSLA – Official

Laura Caven (from September 2020 – previously Katey Tabner)

Citizens Advice Scotland

Nina Ballantyne

Commonweal

Craig Dalzell

Glasgow West of Scotland Forum

David Bookbinder

JHPDG /Wheatley Group

Tom Barclay

Queen Cross Housing Association (Member of Poverty and Inequality Commission)

Shona Stephen

Regional Networks RTO Representative

Hugh McClung

Regional Networks RTO Representative

Shona Gorman

Royal Incorporation of Architects in Scotland

Karen Stevenson

Rural and Islands Housing Forum (Orkney Housing Association)

Craig Spence

Rural and Island Housing Forum (Eildon Housing Association)

Nile Istephan

Scottish Association of Landlords

John Blackwood

Scottish Women’s Aid

Marsha Scott (from September 2020 - previously Jo Ozga)

Scottish Federation of Housing Associations

Cassandra Dove

University of Glasgow

Mark Stephens

Scottish Government supporting officials

Organisation

Representative

Better Homes Division Deputy Director

Catriona MacKean

Better Homes Division Circle Lead

Naeem Bhatti

Better Homes Division Secretariat

Margaret Irving

Better Homes Division Secretariat

Angela O’Brien

Better Homes Division PRS Unit Head

Amanda Callaghan

Better Homes Division Homelessness Unit

Janine Kellett

Better Homes Division Homelessness Unit

Marion Gibbs

More Homes Division Housing to 2040 lead

Laura Dougan

Planning and Architecture Division

Kuan Loh

More Homes Division Housing to 2040

Liz Geddes

More Homes Division Housing to 2040

Elaine Bell

Better Homes Division Secretariat

Mandy Brown

Interim Director Housing and Social Justice Directorate

Shirley Laing

Report Structure

Summary of proposals

Introduction

Meeting housing need through affordable homes

· Big Challenges, Big Choices

· Proposals

Addressing, preventing and ending homelessness

· Big Challenges, Big Choices

· Proposals

Growing successful communities with great homes

· Big Challenges, Big Choices

· Proposals

Issues to address

Appendix

· Appendix A: Alignment with Housing to 2040

· Appendix B: Reflections on priority Housing to 2040 principles

· Appendix C: HSPC Process Outline

Summary of proposals:

Meeting housing need through affordable homes

Recommendation 1: The Scottish Government should commit to fully using the existing and planned housing stock to increase availability and provide homes for the most people as possible.

· Action 1: Mapping the existing stock

· Action 2: Targeted acquisitions and conversions

· Action 3: Mortgage-to-rent schemes

· Action 4: Council Tax reform

· Action 5: Land Value Tax

Recommendation 2: The Scottish Government seek to ensure that housing costs are affordable and that appropriate social security provisions and financial support mechanisms are in place to meet those housing costs.

· Action 1: Defining affordability

· Action 2: Addressing gaps in financial housing support

· Action 3: Addressing gaps in housing advice services

· Action 4: Improved PRS data collection

Recommendation 3: The Scottish Government should commit to a new National Housing Strategy which delivers both the supply of housing and the broader vision of a well-functioning housing system for Housing to 2040

· Action 1: Overarching housing strategy

· Action 2: New Affordable Housing Supply Programme

· Action 3: Alternative models for housing delivery

· Action 4: Review wider policies

Addressing, preventing and ending homelessness

Recommendation 4: The Scottish Government should make preventing and ending homelessness a national priority

· Action 1: Integrated government strategies

· Action 2: Housing First framework

· Action 3: System-wide prevention

· Action 4: Supporting domestic abuse victim-survivors

Growing successful communities with great homes

Recommendation 5: The Scottish Government should support existing social housing providers in developing cross-sector partnership working and providing some wider support services (e.g. welfare advice, tenancy sustainment, wellbeing programmes, care and support) with communities

· Action 1: Cross-sector delivery

· Action 2: Re-framing social housing

Recommendation 6: The Scottish Government should review existing design standards and guidance to drive improvement and innovation across all tenures.

· Action 1: Cross tenure standards

· Action 2: Accessibility and inclusive design

· Action 3: Reducing VAT on existing homes

· Action 4: Assessing the impact of regulatory requirements

Recommendation 7: The Scottish Government should strengthen the role of placemaking in policy-making decisions in order to encourage collaborative working and support community-led regeneration.

· Action 1: Planning resources

Action 2: Improving private sector developments

Introduction

A home has never been more important. If we didn’t know it before, we do now – homes save lives. Our home forms the basis for our wider health and wellbeing – while growing up, when facing other challenges and opportunities and throughout every stage of our lives. Good housing and inadequate housing are wholly connected to the widest range of social and health outcomes. Housing can provide safety, security and the platform from which to thrive in personal and family life. Inadequate housing puts us in danger, damages our health and prevents us from moving forward. Homelessness is the lack of a proper place to live, and is both an injustice and a hugely damaging experience. Our housing system needs to be a crucial foundation for an inclusive, equal and fair society.

This report has been developed by the Housing System Policy Circle (HSPC) following a series of weekly meetings which began in July 2020. The Policy Circle scope of work was to set out the short, medium and long-term direction for housing policy to feedback to the Social Renewal Advisory Board. Phase 1 of this work included preparing initial recommendations for the Programme for Government while the aim of Phase 2 was to focus on broader and deeper systemic work, including reflections on the ongoing Housing to 2040 work.

Phase 1

The Phase 1 recommendations were developed based on the group’s early discussions and the key themes emerging from these conversations. Following analysis of the central topics raised within the meetings, it was proposed that the recommendations could be framed around three broad but mutually reinforcing themes: meeting housing need through affordable homes; addressing, preventing and ending homelessness; and growing successful communities with great homes. Members of the group also shared various resources and existing publications which were collated and used as reference points for the group throughout the discussions. The Policy Circle submitted 9 high-level recommendations to the SRAB in August. These were based on the key themes identified with a focus on proposals which would help to address some of the urgent issues which have emerged, or been exacerbated, during the COVID-19 pandemic. This also included some suggested actions, which were again developed from the group discussions or existing resources. There were some immediate actions for inclusion in the Programme for Government however it was acknowledged that these would require further development.

Phase 2

The updated proposals seek to build on the Phase 1 recommendations following further interrogation of the specific actions required. This includes some short to medium term actions which have not been addressed in the Programme for Government (PfG) or draft Infrastructure Investment Plan (IIP) and should be considered within the first half of the next parliament. It also considers some medium to long term proposals which will continue to aid the recovery process while also laying the foundations for broader social renewal objectives and the ambition to create a fairer, more equal and resilient Scotland. The medium to long term proposals therefore look beyond the next parliamentary term and offer more strategic level recommendations in line with the Housing to 2040 vision and principles.

Housing to 2040

The Policy Circle discussions have therefore been framed around the ongoing development of Housing to 2040 and the associated draft principles and vision. While some of the proposals put forward to the SRAB offer some first steps to making the 2040 vision a reality (see Appendix A), the group has also discussed the need for a clear route map for delivering on the principles. It has not been possible for the Policy Circle to discuss every principle in detail within the timeframe however the group identified the following principles as the key priorities in working towards a fairer housing system, with further reflections on these provided in Appendix B:

· Principle 15: Everyone has a right to an adequate home

· Principle 9: Decisions around the quality, location and utilisation of existing stock and new build should be ambitious in enhancing biodiversity, promoting Scotland’s energy security, and be consistent with the target for Scotland’s emissions to be net zero carbon by 2045. 

· Principle 1: Local communities should be empowered to respond to housing need in their area, as part of a coherent regional economic approach (creating and maintaining jobs) and supported by provision of the right infrastructure.

· Principle 4: Housing provision should be informed by whole life economic costs and benefits in the round and help to address inequalities in health, wealth and education.

Developing the final proposals

The final proposals have been developed in parallel with the group’s further work on obtaining lived experience evidence, either from existing research or following responses to the Policy Circle’s request for information via members of the Policy Circle and other stakeholders (see Process Outline in Appendix C). While this was not a comprehensive research exercise and is consequently limited in terms of representation, the issues raised have been used to inform the development of the Phase 2 proposals. The proposals will also be reviewed against the final proposals from the other SRAB policy circles (as part of the SRAB reporting) as well as other emerging Scottish Government strategies or policy proposals. Reference has been made to recent commitments in the Programme for Government and the Ending Homelessness Together Action Plan (EHTAP) and some of the initial Phase 1 recommendations have been removed on this basis. The proposals also focus on system level recommendations and actions which will provide support for the most disadvantaged groups. The examples given are therefore not exhaustive but they provide suggested actions for the SRAB to consider in their final report.

There are also some general points which apply to all of the proposals:

· Many of the recommendations are interlinked and while separated into different themes, the actions presented in one area may offer broader benefits or indeed be dependent on actions presented within another theme. The recommendations should therefore be read as a collective strategy.

· The recommendations have been developed in line with lived experience evidence gathered either from existing material or examples submitted to the policy circle however it is acknowledged that further work is needed to ensure wider representation and for any proposed actions to be adequately tested.

· While the proposals have been prioritised based on their impact on the most disadvantaged groups, all recommendations and actions should be viewed from an equalities perspective to ensure the housing system no longer creates or perpetuates inequality in society. This will require robust Equalities Impact Assessments and considerations of intersectionality as part of any further development.

· Although the proposed recommendations are specific to the housing system, they offer alignment with the work of the other SRAB policy circles and will require a cross-sector approach to delivery.

· While some of the proposed actions have estimated costs attached, as sourced from existing research, others have yet to be fully costed and will require further work to identify the budget requirements.

· It is also acknowledged that some of the recommendations relate to reserved matters, the HSPC is proposing that the Scottish Government seeks decisions from the UK Government and examines and maximises all current flexibilities in the meantime.

Meeting Housing Need through Affordable Homes:

Big Challenges, Big Choices

Three of the key challenges raised in the group discussions, and supported by the lived experience evidence, include the availability of homes, affordability and the need for long term planning and investment. These are discussed in more detail below highlighting the current context, the available lived experience evidence, equalities considerations, opportunities and concerns, alignment with existing or developing Scottish Government strategy and potential alignment with the recommendations of the other policy circles.

Availability of homes

The need to provide a sufficient number of homes has been consistently raised in the group discussions. With an estimated 14,000 households currently living in temporary accommodation[footnoteRef:2], 10,000 of which were in temporary accommodation prior to the pandemic, there is an immediate demand for additional homes which can provide settled accommodation for those in need. Those with experience of the homeless system have identified the lack of access to suitable settled accommodation as one of the most important barriers to addressing the homelessness crisis[footnoteRef:3]. This is echoed in the recommendations the reconvened HARSAG group[footnoteRef:4], the recent work of the Everyone Home collective and the actions outlined in the updated Ending Homelessness Together Action Plan (EHTAP). [2: Scottish Housing Regulator (2020) Monthly COVID-19 Dashboards ] [3: Glasgow Homelessness Network (2018) Can we fix Homelessness in Scotland? Aye we can ] [4: HARSAG (2020) Tackling homelessness in Scotland following the coronavirus pandemic - Recommendations from Homelessness and Rough Sleeping Action Group ]

Existing studies have also shown the negative impact of living in unsuitable temporary accommodation, particularly for women and children[footnoteRef:5]. This is supported by the lived experience examples submitted to the Policy Circle which highlight further examples of domestic abuse victim-survivors either being housed in refuges which don’t meet their needs or being allocated unsuitable properties. There were also reports of limited temporary accommodation options for wheelchair users. While these are only a few examples, they highlight the need for those in need to be able to access safe and affordable accommodation which meets their needs and for this accommodation to be provided as quickly as possible. This can only be achieved by ensuring that there are a sufficient number of homes available. The building of new homes will help to increase housing supply over the longer term but the Policy Circle recognised that this cannot be done overnight and there is a more immediate need to utilise the existing stock more efficiently. [5: Scottish Women’s Aid (2017) Change, Justice, Fairness]

Evidence from previous studies also suggests that many people in Scotland are living in existing homes which do not meet their needs. For example, there are reports of disabled people struggling to find suitable wheelchair accessible housing or access adaptations which would enable them to live independently in their homes for longer or return after hospitalisation[footnoteRef:6]. In the context of an ageing population, it is vital that our homes accommodate our needs over an entire lifetime and promote inclusive living. The Policy Circle recognises the commitment within the PfG to review and improve the current housing adaptations system following the group’s initial recommendation to the SRAB. It is also welcomed that this is supported by £58 million of funding to support RSLs in delivering adaptations however other actions around accessibility standards are also discussed in the section of ‘Growing successful communities with great homes’. The lived experience examples also highlighted cases where older people were needing support to downsize from large properties which had now become unsuitable. [6: Equality and Human Rights Commission (2018) Housing and disabled people: Scotland’s Hidden Crisis]

The need to address under-occupation in the owner occupier sector more generally was also raised in the group discussions, acknowledging the need for further development of suitable mechanisms for discouraging the under-occupation of housing. Land and property tax reforms, including Council Tax reforms, were discussed as a possible solution. This would require progressive changes to the band multipliers until Council Tax becomes a proportional tax, based on a uniform percentage of the property value. It was also noted that Council Tax valuations are still based on 1991 values. One effect of not revaluing the tax base is to disadvantage local authorities which have experienced low house price inflation compared to those where prices have risen the most. A combination of the banding changes and revaluation would help create a fairer system of taxation. However, it was also proposed that further longer-term changes, where Council Tax is ultimately replaced with a new national Land Value Tax, could be phased in over perhaps 20 years and offer further benefits. Proposals around land reform were also raised in the group discussions noting that it is often developers, landowners and existing homeowners – rather than communities – who benefit from the uplift in land values generated by development and infrastructure. A Land Value Tax would be one way of exploiting Land Value Capture (LVC) and could be used to address this as well as increasing the rates of new affordable housebuilding. Other suggestions on planning-led mechanisms for LVC (e.g. Section 75 agreements) are discussed in the section on ‘Growing successful communities with great homes’.

Responses to the lived experience exercise also reinforce the need for greater choice in housing, with factors such as property size, location and access to greenspace all highlighted within the responses. Research conducted prior to the pandemic describes the lack of available options for families with children, resulting in them being placed in isolated locations or homes which do not meet their needs[footnoteRef:7]. This has become even more apparent during the national lockdown. Recent research highlighting the negative impacts on family wellbeing resulting from the lack of private outdoor spaces and safe play areas for children[footnoteRef:8], including concerns about play areas for children in the gypsy/traveller community[footnoteRef:9]. There is also limited information on the specific housing needs of women with regard to caring roles and lower incomes and how this may impact needs in terms of the location of properties, building design and tenure options alongside housing costs and support[footnoteRef:10]. [7: Galloway (2020) Challenges from the Frontline – Revisited] [8: Children’s Neighbourhoods Scotland (2020) The impact of COVID-19 on families, children and young people in Glasgow] [9: Scottish Housing Regulator (2019) National Panel of Tenants and Service Users 2018/19 - Thematic Report:Gypsy/Traveller sites ] [10: Scottish Health and Inequalities Impact Assessment Network (2013) Health Impact Assessment of Housing Improvements SHIIAN; Gabe et al (1993) ‘Women, crowding and mental health’ in Burridge R, Ormandy, D. (eds) Unhealthy housing: research, remedies and reform Taylor & Francis. ]

The lack of affordable housing options in rural areas was also noted, particularly in areas with a high proportion of second homes where there are increased pressures on local housing systems. It is therefore welcomed that the PfG includes provisions for new secondary legislation to give local authorities powers to license short-term lets and introduce control areas. However, in addition to holiday homes, the issue of long-term vacant homes has also been raised in the group discussions, with latest figures suggesting that there are currently 34,000[footnoteRef:11] empty properties in Scotland. Scottish Government efforts to address empty homes in the private sector as part of More Homes Scotland and the Scottish Empty Homes Partnership have also been welcomed however this work needs to be continued and accelerated. The EHTAP also encourages the housing sector to prioritise the process of bringing empty homes back into use however there need to be adequate resources in place to support this action and ensure that the existing stock is used effectively to house as many people as possible. Resourcing will need to be available not just to bring empty homes into use, but also to map and understand where and in what state empty homes are to start with. [11: Common Weal (2020) Housing 2040 Consultation Response]

Existing studies also provide evidence of overcrowding in some homes, particularly for families with children[footnoteRef:12] and some ethnic and cultural minority groups[footnoteRef:13]. The policy circle welcomes the recent review of the accommodation needs for gypsy/travellers in Scotland[footnoteRef:14] and the actions outlined in the housing section of the Race equality action plan[footnoteRef:15] while recognising the need for further representation from these communities. Other research on gender inequality in housing also shows that women are disadvantaged in their capacity to secure adequate housing due their more limited access to resources and higher levels of unpaid care work[footnoteRef:16]. It also reported that when compared to households which are headed by men, households which headed by women are more likely to be overcrowded and of a poorer quality standard. General gaps in understanding around the housing needs and experiences of women have also been identified[footnoteRef:17]. The commitment in the PfG to carry out a further evidence review on the needs of minority ethnic communities to inform Local Housing Strategies is acknowledged however it is important that this considers other protected characteristics, including a gendered analysis of housing need, and other disadvantaged groups (e.g. socio-economic factors, rural/island communities). This should embed an intersectional approach to equalities considerations along with a clear strategy to address cases where housing needs are not being met. [12: Galloway (2020) Challenges from the Frontline – Revisited] [13: BEMIS (2016) Agenda and Policy Development in Scotland— Lived experience of Ethnic and Cultural Minority Communities] [14: Scottish Government (2020) Gypsy/Travellers - accommodation needs: evidence review ] [15: Scottish Government (2017) A fairer Scotland for all: race equality action plan and highlight report 2017-2021] [16: Engender (2020) A Woman’s Place: Gender, housing and homelessness in Scotland ] [17: Engender (2020) Gender, housing and homelessness – A literature review]

Affordability

In addition to increasing the availability of housing, and providing access to suitable homes, affordability improvements are needed to help people sustain their homes and prevent homelessness. While the need for genuinely affordable homes has been a longstanding issue, driven by a combination of income stagnation and rising house prices, it has become even more critical in the wake of the pandemic as greater numbers of people face financial difficulties and job insecurity. Although the temporary measures put in place by the UK Government have been welcomed, there are serious concerns around what happens when emergency provisions come to an end. Recent research by the IPPR[footnoteRef:18] highlight the particular financial risks for low-income families, parents and carers, young people, disabled people, black and minority ethnic workers, renters and the self-employed. It has also been highlighted that the pandemic is likely to have a particularly negative impact on those working hospitality, retail and care roles which are typically dominated by female and Black and minority ethnic workers[footnoteRef:19]. Emerging evidence also indicates that many of the pre-existing economic inequalities in Scotland have been exacerbated by the pandemic, highlighting the potential for economic scarring amongst young people, widening gaps in employment participation for disabled people and people of minority ethnicities, impacts on gender equality in the labour market and the disproportionate impacts on lone parents, the majority of who are women and were likely to have been struggling financially prior to COVID-19[footnoteRef:20]. [18: IPPR (2020) Weathering the winter storm: Strengthening financial security in Scotland through the ongoing Covid-19 crisis] [19: Engender & Close the Gap (2020) Gender & economic recovery ] [20: Scottish Government (2020) The Impacts of Covid-19 on Equality in Scotland]

The lived experience examples gathered by the Policy Circle also revealed concerns around growing rent arrears and increasing levels of other debts due to reductions in income and increased costs. The evidence gathered by the Poverty Truth Commission (PTC) included a suggested action around rent caps as well as highlighting the increased cost of living during the pandemic with food, fuel and IT costs being a particular concern for those living in rural areas, BAME communities, households with disabled adults or children and Gypsy/traveller communities. The negative impacts of housing insecurity on children have also been highlighted[footnoteRef:21]. While the increases to Discretionary Housing Payments (DHP) and the Scottish Welfare Fund (SWF) may help to mitigate some financial impacts of the pandemic in Scotland to some degree, take-up of DHPs have not increases as much as anticipated, and the Policy Circle has highlighted the need for further top-up mechanisms and consistent advice on eligibility. [21: Galloway (2020) Challenges from the Frontline – Revisited]

While further details of the new Tenant Hardship Loan Fund outlined in the PfG are still awaited, it is clear that this may not be a suitable option for many and will offer a stop gap rather than a long term solution to improving affordability for tenants. The increasing numbers of households applying for Universal Credit, while a consequence of the pandemic, has also drawn attention to the wider problems of this system including delays in payments and the resulting budgeting difficulties and rent arrears. The PTC work also highlights the issues arising from delays to Universal Credit payments and social security payments being insufficient to cover living costs. Frontline support staff have also reported the increased level of support required for those who have not had to claimed benefits before[footnoteRef:22]. [22: SFHA (2020) SFHA report highlights the impact on arrears of Universal credit]

The lived experience examples also raise some of the difficulties experienced by already disadvantaged groups in relation to accessing housing related information and support, particularly during lockdown where face to face advice has been limited and those with limited digital skills and equipment have struggled with online applications. This has been particularly apparent for older people who are less likely to be online and those who may struggle with language barriers or literacy levels. CAS has reported increases in tenants across all sectors seeking advice on complaints against landlords, particularly in the months following the pandemic. There have also been reports of complex applications procedures in relation to accessing financial and housing support and a generally low awareness of the advice and support available.

There are also reported inconsistencies in the quality of advice services provided across the housing system, particularly for those with complex needs where tailored solutions or multi-agency working is required. A report on the experiences of disabled people[footnoteRef:23] for example highlighted difficulties in the social housing allocations processes due to these being complex, difficult to navigate and seemingly unfair. This resulted in a call for local authorities to provide increased specialist disability advice and advocacy services for housing options. In the case of domestic abuse victims there were reports of a lack of skills, knowledge, confidence and consistent protocol across service providers while there were also calls for more tailored support for those with additional needs in relation to their age, ethnicity, disability, sexual orientation or religion[footnoteRef:24]. A report on the lived experience of homelessness also identified the need for flexible, trauma informed support highlighting the need for staff knowledge, values and awareness[footnoteRef:25]. [23: Equality and Human Rights Commission (2018) Housing and disabled people: Scotland’s Hidden Crisis] [24: Scottish Women’s Aid (2017) Change, Justice, Fairness] [25: Glasgow Homelessness Network (2018) Can we fix Homelessness in Scotland? Aye we can]

While the affordability debate has clear overlaps with the work of the financial security circle, from a housing perspective the issue of ‘affordability’ can be linked with lack of a clear definition of the term. Members of the Policy Circle have highlighted the various problems associated with ‘affordability’ being calculated based on local market rates which can be artificially inflated rather than being genuinely affordable for those on low incomes. While rents in the PRS have continued to rise, the Local Housing Allowance Rate was reduced from the 50th percentile of the local rate to the 30th percentile in 2012 and then frozen from 2016-2020. This limited the amount of support available to households in the PRS through Housing Benefit, Local Housing Allowance and the housing element of Universal Credit.

The welcome changes to LHA rates, introduced in response to the coronavirus outbreak, mean that support from the benefits system will again cover rents up to the 30th percentile in a broad rental market area. This change essentially lifts support to pay for private housing costs back to April 2016 levels but does not reinstate the connection between LHA rates and median market rents that was previously in place from 2008 to 2012. Those in areas where rents have increased dramatically since April 2016 will see the biggest uplift in their rates, but in some parts of the UK people will see barely any increase in support towards housing costs, even if they personally live in a high-rent property.

It is also worth noting that the national LHA cap will mean that there are some areas of the country where rents are higher than the cap, meaning tenants will not benefit from the increased LHA rates[footnoteRef:26]. To give a sense of what the shortfall could look like in different localities, Crisis analysis shows that, for example, in Edinburgh, under the previous LHA rate, just 20 – 30 private lettings were advertised within LHA rates prior to March 2020. This has now increased to around 400 lettings under the new rates, demonstrating the significance of this increase, for those who are able to receive the full allowance. Members of the circle have also noted the difficulties in delivering Mid-market Rent (MMR) properties due to the limitations of the Broad Market Areas approach. In some areas MMR properties are not viable option even where it is expected that they would make a positive impact in the community. The definition is again an issue with a ‘mid-market’ rental amount being based on a percentage of the wider market costs despite MMR properties also being classed as ‘affordable’. [26: Innes, D. (2020) MPs’ Coronavirus Briefing: We Need a Lifeline to Help People Keep Their Heads Above Water. York: JRF. https://www.jrf.org.uk/report/coronavirus-we-need-lifeline-help-people-keep-their-heads-above-water]

One of the possible solutions is a shift from assessing the affordability of rents by comparing them to prevailing market rents, and instead relate affordability to the adequacy of income after housing costs have been met. An acceptable residual income could be based on the Joseph Rowntree Foundation’s Minimum Income Standard which incorporates other household costs (e.g. fuel, council tax, household goods and services) alongside wider living costs required to achieved a decent standard of living and participate in society, recognising that expenditure on some items may include an element of choice. This approach could also allow the higher costs of fuel and transport in rural areas to factored in through adoption of a MIS for Remote Rural Scotland[footnoteRef:27]. [27: Hirsch et al (2013) A minimum income standard for remote and rural Scotland ]

The circle has also discussed the current limitations of Rent Pressure Zones (RPZ). So far, the data required to implement such zones does not exist and the legislation makes it too difficult for local authorities to propose RPZs. This issue is further complicated by the general lack of transparency and reliable local data on rents in the PRS alongside the issue of unregistered landlords and the general lack of enforcement. Improvements in data collection through the landlord registration system would offer some improvements in this area and may offer opportunities to provide a more reliable evidence with which to assess affordability and inform any system of rent regulation. However, the issue of rents levels and rent increases in the PRS also needs to be looked at in the context of the wider pressures on the housing system and previous discussions on the availability of homes.

Even in the social housing sector which offers the most affordable housing options[footnoteRef:28], rents have been increasing can still be unaffordable for those on low incomes. Recent data from CAS indicates disproportionately high level of arrears of advice being sought by local authority and RSL tenants when compared to mortgage holders and PRS tenants. It was also noted that social landlords and local authorities are also facing mounting financial pressures due to the cumulative impact of regulatory, legislative and compliance requirements. In some areas, the impact of the reduction or withdrawal of local authority environmental and related services is reportedly having an impact. Improving tenant safety and the quality of homes and communities comes at a cost, as does building new stock to meet the outstanding need for affordable and social homes. [28: Latest figures from UKHR 2020 show average weekly rents of £74.30 (LA), £86.93 (HA) and £159.01 (PRS) based on 018 figures (https://www.ukhousingreview.org.uk/ukhr20/tables-figures/pdf/20-085.pdf)]

It is important to consider the full impact of this on rents and the value for money offered to tenants in this sector. The suggestion of national rent policy was proposed by one of the circle members, highlighting the recent work in Wales as an example[footnoteRef:29]. SFHA has also already produced rent setting guidance for the social sector and an affordability tool, produced in partnership with HouseMark Scotland, which allows rents to be tested against different affordability measures, income types and household sizes. This provides a flexible approach which allows rents to be sense checked against different household circumstances. For the affordability measures, SFHA typically advocates the moderate incomes approach, based on the Annual Survey of Hours and Earnings (ASHE)[footnoteRef:30] data. [29: Littlewood et al (2019) Rent policy review: final report https://gov.wales/rent-policy-review-final-report] [30: ONS (2020) Annual Survey of Hours and Earnings (ASHE) ]

As with the private rented sector, market pressures and rental costs in the social sector are also location specific meaning affordability considerations may require different approaches across Scotland. However pressures on rents are even more acute in the current context with tenants facing reductions in income and job insecurity which is in turn leading to accumulation of rent arrears in the social housing sector with latest figures from the Scottish Housing Regulator showing total arrears of over £163 million[footnoteRef:31]. Arrears and the accumulation of debt are a clear source of stress for tenants and families who are struggling, and adequate safety nets will be required to ensure these households are protected. With the extended notice periods for arrears-related evictions now in place until the spring of 2021, Scottish Government engagement with social landlords and financial support for tenants will be needed to minimise the longer-term impact on individuals and communities. [31: Scottish Housing Regulator (2020) Monthly COVID-19 Dashboards]

Although owner-occupiers are at much less risk of homelessness than other tenure types, during this period unprecedented numbers of mortgage-holders are making new claims for Universal Credit, including those who probably never expected to seek help from the benefits system. Although forbearance is expected from mortgage lenders, there is little support to manage mortgage costs from the benefits system with the exception of Support for Mortgage Interest (SMI) which is a loan from DWP to help pay the interest on a mortgage (but not the mortgage capital). Someone claiming Universal Credit usually must wait a period of 9 months before being receiving SMI, and the SMI is a loan with interest charged, although this tends to be cheaper than other sources of credit. Some, including JRF, have called on the Government to remove the waiting period for SMI so that mortgage-holders can access support directly after their mortgage holiday[footnoteRef:32] . [32: JRF (2020) Coronavirus: it’s unthinkable anyone should be made homeless now ]

The policy circle has also discussed other options for struggling homeowners to prevent owner occupiers from losing their home. Mortgage to Public Rent or Mortgage to Shared Equity schemes, such as those delivered through the Homeowners’ Support Fund[footnoteRef:33] for example, would allow owner occupiers or landlords who are in danger of foreclosure to convert the property to the social sector and therefore allow the occupiers to remain in their home. This would also address some of the security of tenure concerns noted in the lived experience examples amongst PRS tenants who were worried about their landlord selling their home. CAS did however report that the current procedures for existing schemes were burdensome for the applicants and causing delays in the overall process. [33: https://www.mygov.scot/home-owners-support-fund/]

The group has also highlighted the need to consider the impact of other policies such as the lift in LBTT and the extension of help-to-buy. While these support jobs in the housing market and construction industry they may also inflate prices artificially and so contribute to the overall problem of affordability. Recent research into Help to Buy for example demonstrated that in tight markets this scheme can inflate prices and does not increase supply[footnoteRef:34]. These policies may also entrench existing inequalities and prioritises those able to buy now, which are a small minority of those in housing need. The need for a gendered analysis of such policies has also been raised with recent research highlighting the ‘gender property gap’ and the disadvantages faced by women, particularly in relation to homeownership[footnoteRef:35]. [34: Stephen and Blenkinsopp (2020) “Help with housing costs”, UK Housing Review 2020, Coventry: CIH] [35: Engender (2020) A Woman’s Place: Gender, housing and homelessness in Scotland]

While the commitments in the PfG to increase incomes and create employment opportunities will help to reduce some financial pressures, housing affordability needs to be looked at in the round. Although the increase in DHPs in Scotland could be used to mitigate the impacts to some degree, financial safety nets also need to be sufficient to cover the full costs of living in a home, reflecting for example geographical differences in energy costs. DHPs are also only available to those receiving Universal Credit or Housing Benefit, meaning most students and those with No Recourse to Public Funds will be excluded. It is welcomed that the EHTAP also includes a new commitment to look further at affordability in the PRS however the pressures on the broader housing system, which is in part driven by the previous discussions on the availability of homes, also needs to be addressed.

Long-term planning and investment

The need for a strategic vision for housing has been highlighted as an integral part of laying the foundations for long term recovery and creating a better functioning housing system. The Policy Circle has repeatedly discussed the need for cross-party planning and strategic investment linked to the Housing to 2040 vision and principles. Critical to this will be the supply of affordable housing as outlined in recent research by SFHA, Shelter and CIH[footnoteRef:36] which estimates that 53,000 affordable homes need to be built between 2021–2026, including 37,100 homes for social rent, with an estimated capital cost of £3.4 billion. Alternative housing models, such as community housing initiatives will also require investment. Building on the previous discussions around the lack of available housing options, the lived experience examples also call for more affordable homes to be built in the right places. This supported by recent polling by Shelter Scotland and YouGov which demonstrates high levels of support for building new homes in the social sector and that this should be a priority for political parties[footnoteRef:37]. This work also highlights that an estimated 70,000 children in Scotland (equivalent to 20 children in every school) are currently on social housing waiting lists. The PTC research also mentioned the need for additional high-quality housing with minimum standards and effective enforcement. [36: Dunning et al (2020) Affordable Housing Need in Scotland Post-2021 ] [37: Shelter Scotland (2020) 70,000 children on housing waiting lists]

While the policy circle recognises the current financial constraints and the capital costs associated with reaching these targets, policy commitments need to address new housing supply on a continual basis. This will require a combination of new build supply and more efficient use of the existing stock with further investment for both the acquisition of properties and sufficient funding to carry out the repair and refurbishment work necessary to turn these into suitable homes. It is welcomed that the Scottish Government has committed to invest £2.8 billion in delivering affordable and social homes over the next five years however there is a need for longer term certainty around grant funding and investment beyond Parliamentary cycles. RSLs for example have mentioned the need for a 30 year planning cycle to ensure effective delivery and, as raised in the previous discussion on affordability, the increasing costs associated with building good quality homes will also impact existing and future rent levels unless adequate subsidies are provided. Delivering on policies around placemaking (NPF4) and heat (New Build Heat Standard from 2024) will mean that the costs will only continue to increase. It is critical that affordable housing provides high-quality homes while also offering value for money for the occupants.

It will also be necessary to explore alternatives to subsidies over the longer term (e.g. Section 75 agreements). It was noted that S106 agreements (English counterpart to Section 75) currently support almost half of affordable housing provision in England while at present the Scottish Government does not collect statistics on these agreements. This would be a necessary first step in improving the current system and is discussed further as part of Recommendation 7. It is also crucial that the supply-side of the housing system works better. If the market fails to supply enough housing then general affordability problems build up over time. The current speculative housebuilding model is unable to provide enough housing overall, despite the numbers of units of planning permission consistently exceeding the numbers of units built[footnoteRef:38] and the financial assistance (amounting to around £500 million up to the end of 2019[footnoteRef:39]) provided to purchasers of new properties through Help to Buy. The Scottish Land Commission has also found that housebuilders do not find it viable to building in some post-industrial and rural areas. Alternative models of housing delivery have been proposed to address this including a variant on the New Town Development Corporation model whereby the public sector led on land acquisition and assembly and then sold it on to housebuilders. Further discussions land reform are also discussed in the ‘Issues to address’ section. [38: Stephens (2018) “Planning frameworks and housing delivery”, UK Housing Review 2020, Coventry: CIH, p. 24] [39: Stephen and Blenkinsopp (2020) “Help with housing costs”, UK Housing Review 2020, Coventry: CIH]

Alongside increasing the quantity of new homes, the Policy Circle has continually raised the importance of looking beyond numerical targets and ensuring that new supply also considers housing quality, diversity, accessibility and future aspirations and demands. In the context of COVID-19, the lived experience examples and PTC work has for example, revealed inequalities in who has access to outdoor space and this had now been reflected in the PfG commitment to ensure that all new social housing will offer access to private or communal outdoor areas and well as adequate space for study and homeworking. Housing Need and Demand Assessments and Local Housing Strategies need to effectively address these factors and ensure communities are engaged in the design and planning process.

Investment in housing should also recognise the broader economic and social benefits, including impacts on health and wellbeing and the potential preventative spending which may producing savings in other budgets. The current Affordable Housing Supply Programme for example has sustained 10,000 to 12,000 jobs and contributed to an annual economic output of £1.4 billion[footnoteRef:40]. Recent research[footnoteRef:41] has also demonstrated that social and affordable housing can promote inclusive economic growth by creating jobs, increasing GVA and providing large multiplier effects as well as helping to tackle inequalities by reducing child poverty and homelessness and by providing inclusive, sustainable housing options. The report also highlights how the delivery of affordable and good quality homes can improve health and wellbeing, contribute to successful placemaking and strengthen community resilience, including rural community resilience. However the Policy Circle group discussions on new housing supply have also reiterated the need to link ‘affordability’ with income in order to ensure that the More Homes programme adequately addresses economic inequalities as well as the broader aspects of inequality. [40: Scottish Government https://economicactionplan.mygov.scot/investment/housing/ ] [41: CaCHE and HACT (2020) The Impact of Social Housing: Economic, Social, Health and Wellbeing ]

Meeting Housing Need through Affordable Homes: Proposals

Recommendation 1: The Scottish Government should commit to fully using the existing and planned housing stock to increase availability and provide homes for the most people as possible.

Action 1: Mapping the existing stock

Provide additional resources to local authorities to help centrally map all empty properties, long and short-term, including second/holiday homes, short-term holiday lets, and student accommodation (purpose-built and HMOs in student-dense areas). This should build on the work of the Scottish Empty Homes Partnership and identify barriers to occupation that could be overcome while also providing tools and powers for local authorities to maximise use of the existing stock.

Action 2: Targeted acquisitions and conversions

Provide additional funding for a substantial and accelerated programme of targeted acquisitions in the second-hand market (in line with Action 1) which will allow more properties to be transferred from private ownership to the social housing sector. Targeting should be based on specific local needs and address the current gaps in available housing options for vulnerable groups and those living in temporary accommodation, with a specific focus on addressing the needs of women and children, victims of domestic abuse, disabled people, minority ethnic groups and those with complex needs.

Action 3: Mortgage-to-rent schemes

Expand the existing Homeowner Support Fund and explore other mortgage-to-rent schemes which will transfer privately owned properties to the social sector. This should protect homeowners who are struggling financially as well as allowing private landlords to disinvest while ensuring sitting tenants are not evicted. The administrative processes for existing schemes should also be reviewed with the aim of improving efficiency, reducing timescales and reducing excessive demands on applicants.

Action 4: Council Tax reform

The Council Tax should be reformed to discourage the under-occupation of housing by gradually changing band multipliers until the tax is based on the same proportion of property value for all housing. This should include a revaluation for Council Tax purposes as the tax is still based on 1991 values although it may well be necessary to phase in the impacts of a revaluation.

Action 5: Land Value Tax

Explore options for longer term tax reforms with the aim of moving to a national Land Value Tax

(LVT) to be phased in a period of perhaps20 years. The LVT could replace the existing Council Tax system and the Land and Buildings Transactions Tax (LBTT) but would likely require a new tax base for local government.

Recommendation 2: The Scottish Government seek to ensure that housing costs are affordable and that appropriate social security provisions and financial support mechanisms are in place to meet those housing costs.

Action 1: Defining affordability

Provide a clear framework for assessing housing affordability. This should consider the residual household income after the full cost of living in a home have been taken into account rather than basing affordable rents on a percentage of the prevailing market rent rates. An acceptable residual income could be based on the JRF’s Minimum Income Standard and recognise the higher costs of fuel and transport in rural areas (i.e. MIS for Remote Rural Scotland). An explicit link should be made between this framework and the supply of affordable housing to ensure that these provide a genuinely affordable option for those on low/modest incomes.

Action 2: Addressing gaps in financial housing support

Identify gaps in financial housing support and provide adequate resources to address these gaps. This should identify the groups who are most disadvantaged by the current system or likely to face the most severe financial impacts of the pandemic. This may include those who are in or at risk of rent arrears, PRS tenants in high cost areas, fuel poor households, victims-survivors of domestic abuse, low income families, students, young people, disabled people, black and minority ethnic worker, the self-employed, gypsy/travellers and those with No Recourse to Public Funds. This will require a combination of:

· working with the UK Government to consider further flexibilities for social security in Scotland (e.g. review of LHA rates and options to split UC payments)

· maximising existing social security flexibilities in Scotland (e.g. DHPs, SWF)

· developing new financial support mechanisms to support vulnerable groups (e.g. funds for ‘move in ready’ homes, tenant hardship grant, bundle packages for utilities)

Action 3: Addressing gaps in housing advice services

Identify gaps in housing advice services and provide adequate resources to address these gaps. This should embed a multi-agency ‘no wrong door’ approach and identify the groups with complex needs who need accessible information and tailored, trauma informed support. This should include provisions to address gaps in knowledge and resources amongst housing service providers in order to improve the service provided to vulnerable groups by frontline staff. This may include improved services for older people, disabled people, those with learning difficulties, minority ethnic groups and victims-survivors of domestic abuse.

Action 4: Improved PRS data collection

Improve the understanding of rent levels in the PRS through the collection of more comprehensive data on rent levels both when new tenancies are created and subsequent increases. Options should be considered including using the registration system to collect such data in order to facilitate the creation of RPZs where they are needed in order to tackle excessive increases in localised areas.

Recommendation 3: The Scottish Government should commit to a new National Housing Strategy which delivers both the supply of housing and the broader vision of a well-functioning housing system for Housing to 2040

Action 1: Overarching housing strategy

Ensure continued cross-party planning and investment by establishing a National Housing Strategy and explore options for this to be supported by a new National Housing Agency. This overarching strategy should be linked to the Housing to 2040 vision and principles and seek to co-ordinate existing and proposed strategies and standards for both new and existing/empty homes.

Action 2: New Affordable Housing Supply Programme

Commit to a new AHSP for 2021–2026 which will provide 53,000 affordable homes, including 37,100 homes for social rent, aligned with the affordability framework proposed in Recommendation 2. The programme should be driven by need in terms of locations, property types, population and demographic trends and provision to convert empty homes in all sectors back into use as affordable homes. A review of the current level of grant subsidy should also be included with continued flexibility for local circumstances and a commitment to increase overall subsidy levels in line with CPI as a minimum over the course of the next Parliament. The review should consider the impact of building new homes on rents for existing tenants, and consider how other mechanisms, such as Section 75 agreements, could be better used to provide affordable housing.

Action 3: Alternative models for housing delivery

Explore possibilities for alternative models of housing delivery which move away from the current speculative housebuilding model. This might include adopting a variant of the New Town Development Corporation model whereby the public sector leads on land acquisition and assembly and then sells it on to housebuilders. A new body could be created to acquire land and offer plots with planning permission to facilitate further affordable housing developments. Testing delivery and finance models for community led initiatives such as co-housing, mutual home ownership co-operatives and collective self-build could also be included. There should be a focus on delivering new homes outside urban areas including support for self-managed processes (e.g. Rural Home Ownership Grants), rural housing enablers, small communities trusts as well as working more closely with rural RSLs to provide other local solutions.

Action 4: Review wider policies

Conduct a detailed evidence review to identify existing inequalities across the housing system. This should include a review of all existing policies and programmes (e.g. More Homes and fiscal policies like LBTT rates and lifts) to identify who benefits and who is disadvantaged by these systems while also considering efficiency, equity and value for money. A gendered analysis of the housing system alongside a review of other protected characteristics and disadvantaged groups, including rural and island communities, is also needed to support the development of robust impact assessments (e.g. EQIA, ICIA). A review of the wider social, economic, health and wellbeing and equality impacts of existing policies would also help to identify the cross-sector benefits of investment in the housing sector and inform future policy decisions.

Addressing, preventing and ending homelessness:

Big Challenges, Big Choices

The key challenges raised in the group discussions and supported by the lived experience evidence are centred around addressing and preventing homelessness with the aim of ending homelessness in Scotland. The group has discussed the importance of focussing on prevention and tackling the root causes of homelessness as well as approaches to tackling the symptoms of existing systems failures. The circle has then discussed the importance of making the ending of homelessness a national priority. A summary of the current challenges, the available lived experience evidence, equalities considerations, alignment with existing or developing Scottish Government strategy, including the HARSAG recommendations and Ending Homelessness Together Action Plan (EHTAP) is provided below.

Ending homelessness as a national priority

Whilst Scotland has made some progress in recent years, having seen a fall in the number of households becoming homeless, the most recent figures show that this reduction has plateaued. As the economic impacts of the pandemic begin to be felt, we now risk seeing the numbers rise again unless we take decisive action, making the prevention of homelessness a national priority.

As already noted in the discussions on the availability of homes, in Scotland, there have been persistently high numbers of households in temporary accommodation compared to other UK nations and the pandemic has put this number at an all-time high. Official statistics show that the average time spent in temporary accommodation last year was 184 days. Engagement with those with lived experience has highlighted delays in temporary accommodation and unsuitable accommodation as priorities for change, and the Policy Circle has discussed the need to move towards a model which reduces the overall time spent homeless and reduces long stays in temporary accommodation. This has included suggestions of ‘flipping’ temporary accommodation to settled accommodation where this is deemed appropriate. The pandemic has left us with an unparalleled opportunity to support everyone who has been given somewhere to stay during the lockdown to engage with services and rebuild their lives so that they can move on to a permanent, settled home. Rapid Rehousing Transition Plans (RRTPs) are an essential part of the answer, but for RRTPs to be as effective as possible and work as intended, there must be an increase in the range of settled, suitable and affordable housing options available.

As already noted, the relationship between domestic abuse and women’s homelessness has also been raised in the policy circle discussions. The recent research on the impacts during COVID-19, along with previous research by Scottish Women’s Aid[footnoteRef:42], highlight domestic abuse as a key driver of women’s homelessness, and repeat homelessness, and that homelessness is often the only option available. It also highlights challenges across the system and the various disadvantages faced by woman and children including the emotional and financial costs of domestic abuse, the negative impacts of having to move multiple times, difficulties in accessing suitable accommodation and barriers to support and information. The lack of skills, knowledge and differing protocols across service providers is also reported and although there has now been specific guidance produced for social housing providers[footnoteRef:43], and most of the organisations who submitted responses to the circle indicated that their staff had some level of training, there are also reports of this not been yet being widely implemented. The updated EHTAP does now include a new commitment to respond to the recommendations of the domestic abuse pathway group and to develop and implement human rights-based accommodation pathways for women and children with no recourse to public funds who are experiencing domestic abuse. It has also been announced in the PfG that the Domestic Abuse Bill will be progressed this year allowing further protections for those at risk by ordering perpetrators to leave the home. [42: Scottish Women’s Aid (2017) Change, Justice, Fairness] [43: Scottish Women’s Aid (2019) Domestic Abuse Guidance for Social Landlords]

Aligning with many of the circle’s Phase 1 recommendations, the updated EHTAP has reaffirmed the Scottish Government’s commitment to making ending homelessness a national priority. This is reflected in the commitment to ensure the next National Performance Framework review includes explicit consideration of homelessness; in the commitment to explore how a right to adequate housing can be embedded in Scottish law; and in its theme to “join up planning and resources to tackle homelessness.” However, in order to eradicate homelessness, a longer-term strategy and joint approach across local government and other public sector agencies will be necessary. To ensure that preventing homelessness becomes a national priority across all government departments, these outcomes must be integrated into wider government strategies, including on health, social care, safer communities and employability and skills. This reiterates the circle’s earlier comments on cross-sector collaboration and has clear alignment with recommendations from other Policy Circles. It should be noted that the further upstream prevention activity occurs, the less likely it will be referred to as ‘homelessness prevention’ and may instead be phrased in relation to other objectives, such as reducing health inequalities, but ultimately will lead to the same ends, of supporting people to maintain their homes, security and independence.

Although there has been attention paid to migrant homelessness in both the PfG and the updated EHTAP – including the development of an anti-destitution strategy – preventing migrant homelessness will become an increasingly important priority, as the implications of the UK’s exit from the EU begin to impact people’s lives. Local Authorities should also be provided with guidance to assess the risk of legal challenge and ensure migrant homelessness is addressed in all RRTPs.

Avoiding evictions

Just three weeks after lockdown began, results of an Opinium survey published in the Guardian suggested that a fifth of renters were needing to choose between paying for food and bills or paying rent. Similar research by Shelter found that a fifth of private renters believed they were likely to lose their jobs within three months of the lockdown beginning, leaving many struggling to pay rent. Recent polling by CAS also shows that a quarter of renters and 26% of owner-occupiers were worried about rent/mortgage payments[footnoteRef:44]. The lived experience examples submitted to the policy circle and the previous discussions on affordability also demonstrate financial insecurity as one of the key issues to address. [44: Citizen’s Advice Scotland (2020) https://www.cas.org.uk/news/almost-2-5-people-worried-about-income-concerns-about-bills-rise ]

Following the initial shock in March this year, the pandemic is likely to have a long-lasting effect on many people’s finances. Those at risk of homelessness due to a loss of income will also need access to appropriate advice and support. While the emergency provisions put in place during the national lockdown, including the extended notice period for some evictions and mortgage payment holidays, have provided an important safety net for households, the policy circle has discussed the need for further financial support with early intervention going forward to prevent increases in rent or mortgage arrears. It will be essential to put safeguards in place as the policy responses to the pandemic begin to be rolled-back, providing a safe transition which does not put households at risk of losing their homes.

Three groups are particularly at risk of eviction due to struggling to keep up with rent payments: migrants, young people and large families (particularly single parent families). IPPR analysis of Labour Force Survey suggests that migrants are significantly less likely to own their own homes and are much more likely to be renting – 54 per cent of migrants rent their property (61 per cent of EU migrants and 50 per cent of non-EU migrants), compared to 29 per cent of the UK born.[footnoteRef:45] [45: Morris (2020) Migrant Workers and Coronavirus: Risks and Responses ]

Young people are at particularly high risk of struggling to maintain tenancies for three main reasons. Firstly, low earners are more likely to work in a sector that has been shut down. Secondly, young people receive less support from the benefits system because of their age; single people under 35 are only entitled to the Shared Accommodation Rate to cover housing costs, even if they live by themselves. Thirdly, we know that young people are one of the groups at higher risk of homelessness in normal times, not least because they are disproportionately represented in the PRS (40% of households with a highest earner aged between 16 and 34 live in the PRS in Scotland[footnoteRef:46]), a sector with less security of tenure and the highest costs. Finally, in addition to the higher outgoings that households with children may have faced during the lockdown, putting a strain on household budgets, those with children are more likely to be affected by the benefit cap – especially large families and/or single parents – because despite the uplift in the standard rate of Universal Credit, the benefit cap has not been altered, and the two-child limit still applies. [46: Scottish Government (2020) Scottish household survey 2019: key findings ]

A number of commitments in the Programme for Government and the EHTAP will put in place important protections for tenants, for example committing to develop a cross-sector project to establish mechanisms for avoiding evictions into homelessness, which was one of the Housing Policy Circle’s Phase 1 recommendations. We also welcome the introduction of pre-action protocol for tenants in the Private Rented Sector.

The Policy Circle suggests the focus in the short to medium term should be on sustaining tenancies. Early interventions that support people to stay in their homes are ultimately going to be more powerful in preventing homelessness than changes to the law on eviction although both approaches will be needed.

Preventing rough sleeping

There have been impressive efforts to end rough sleeping during COVID-19 and it has shown that rough sleeping is not inevitable. Actions taken by the Scottish Government, Local Government and third sector partners has shown that what we previously thought was unachievable is within our reach – ending rough sleeping in Scotland. There is an opportunity to build on this momentum and tackle inequalities in our society by taking action to end rough sleeping, and homelessness, in Scotland. 

However, the numbers of those rough sleeping in Scotland’s cities are beginning to increase again, especially amongst EEA nationals. This is particularly concerning given recent Home Office announcements that EEA nationals sleeping rough will – as of the beginning of December when the Brexit transition period ends – be treated as unwilling to engage with services and will be at risk of deportation.[footnoteRef:47] [47: Grierson (2020) Foreign rough sleepers face deportation from UK post-Brexit ]

There has been welcome ambition from Ministers to treat the current situation as an opportunity to end the use of night shelters. The updated Ending Homelessness Together Action Plan included the commitment to modify night shelter provision this winter and end the use of night shelter and dormitory style provision in future, including replacing night shelters in the short term with rapid rehousing welcome centres, which opened in October.

Rough sleeping is almost always a symptom of wider system failures further upstream, either targeted activity specifically aimed at preventing homelessness, or more universal provisions, such as welfare or antipoverty measures. Much of the Circle’s discussions focussed on the need to take an early prevention approach, for example using rent arrears as an indicator of those at risk of homelessness and prevention pathways for young people, particularly those at risk of homelessness due to family breakdown or abuse, which has increased as a result of the pandemic. Research conducted this year highlights increases in referrals to VAWG services following the initial lockdown period alongside significant increases in crisis work with victims[footnoteRef:48]. Updates to this work show a more varied picture across Scotland but that some services were still reporting significant increases in referrals, ongoing negative impacts on the affected victims’ and children’s mental health and difficulties in accessing support[footnoteRef:49]. The policy circle has discussed the importance of preventing these crisis situations and to this end, the recommendations of the Prevention Review Group are likely to inform a longer-term approach to preventing rough sleeping. [48: Scottish Government (2020) Coronavirus (COVID-19): domestic abuse and other forms of violence against women and girls during Phases 1, 2 and 3 of Scotland's route map (22 May to 11 August 2020)] [49: Scottish Government (2020) Coronavirus (COVID-19): domestic abuse and other forms of violence against women and girls during Phase 3 of Scotland's route map (11 August – 11 October) ]

Fundamentally, we need the high-level commitment to prevent a return to rough sleeping upheld by Scottish Ministers and all political leaders, and adequate resourcing and support provided to local authorities to meet this challenge. Rough sleeping, however, is only the tip of the iceberg, and a much greater proportion of homeless households are staying with friends or relatives, staying in temporary accommodation or living in non-residential buildings.[footnoteRef:50] Rough sleeping tends to attract attention because it is more visible and a particularly acute form of homelessness, but Scotland needs a long-term vision and strategy for ending all forms of homelessness. [50: Fitzpatrick et al (2019) The Homelessness Monitor: Scotland 2019, London: Crisis.]

Addressing, preventing and ending homelessness:

Proposals

Given that many of the policy circle’s Phase 1 recommendations have been reflected in commitments in the Programme for Government and the updated Ending Homelessness Together Action Plan, the actions prioritised below are ones where the circle has identified gaps in existing strategies, or believes more decisive action is required. Actions from what were previously recommendations 4, 5 and 6 have been combined here under one overarching recommendation.

Recommendation 4: The Scottish Government should make preventing and ending homelessness a national priority

Action 1: Integrated government strategies

Make both the prevention of homelessness and the right to an adequate home national public health priorities and continue to strengthen the national plan for ending homelessness by extending current work planning beyond 2023 (e.g. a further five years). This work should be built into comprehensive plans to address health inequalities and integrated with other relevant national plans and work, including the Child Poverty Action Plan, Equally Safe: Scotland's strategy for preventing and eradicating violence against women and girls , the Mental Health Strategy, the national Drug Deaths Taskforce, Health and Homelessness and work to address the Hard Edges research.

Action 2: Housing First framework 

Ensure the national rollout of Housing First includes a national Housing First framework to support the rapid procurement of additional lets for Housing First tenants from social and private landlords and to stabilise funding, ensuring adequate resources are in place to provide specialist support services to those with complex needs, including a specific focus on women with complex needs and experience of domestic abuse.  

  

Action 3: System-wide prevention 

Explore options for developing a collaborative, system-wide early warning system for people in rent and mortgage arrears which includes robust information sharing protocols which flag, for example, missed rent or utility payments alongside intel from health or education settings. This should focus on triggering offers of support or signposting for those who are at risk while also considering security and privacy issues. This will require a multidisciplinary approach and should include immediate access to high quality housing advice and sensitive tenancy support. In line with the intent of HARSAG and the EHTAP, this should fully consider the recommendations of the Prevention Review Group, including extension and clarification of the Local Authority duty to provide assistance to prevent homelessness, widening the housing options that can be used to discharge prevention and homelessness duties, and placing specific duties on different public bodies and landlords to “ask” about housing circumstances and to “act” where there is a risk of homelessness.”

Action 4: Supporting domestic abuse victim-survivors 

Ensure housing providers are adequately equipped to support domestic abuse victim-survivors. This should include implementation of the Domestic Abuse: Good Practice Guide for Social Landlords and the availability of a similar resource for PRS landlords to address the critical contribution of domestic abuse to children’s and women’s homelessness. 

Growing successful communities with great homes:

Big Challenges, Big Choices

The key challenges raised in the group discussions and supported by the lived experience evidence include supporting delivering community support, improving standards and guidance and the role of placemaking. These are discussed in more detail below highlighting the current context, deliverability challenges and opportunities and alignment with existing or developing Scottish Government strategies. It is also recognised that this theme will offer potential alignment with the recommendations of the Community-led Place based Renewal Circle.

Delivering community support

The Policy Circle has repeatedly discussed the critical role of social housing providers during the pandemic including their active role in the Supporting Communities Fund and collaborative working with other local organisations to distribute the funding to those in need[footnoteRef:51]. Social landlords have also provided frontline support to tenants and those in extreme need. Recent research[footnoteRef:52] outlines the important social and economic benefits they offer to local communities, recommending that they should be placed at the heart of any proposals for recovery and social renewal. This is supported by the work of the PTC which included a suggested action on supporting housing associations, not only to deliver ‘good houses’ but also in providing community activities which improve wellbeing. There is however a tension between delivering high-quality services and keeping rents affordable for tenants. The Policy Circle had identified the need for a longer-term fund to support vulnerable communities and community anchor organisations and this was proposed in our initial recommendations. The PfG now includes a commitment to a £25 million Community and Third Sector Recovery Programme as well as a commitment to strengthen the role of community anchors as part of the Empowering Communities Programme. [51: SVCO (2020) https://scvo.org.uk/support/coronavirus/funding/scottish-government/supporting-communities-fund] [52: CaCHE and HACT (2020) The Impact of Social Housing: Economic, Social, Health and Wellbeing]

The Policy Circle has discussed the importance of ‘joining the dots’ between housing and other policy areas and budgets such as health, education and the economy highlighting that social housing providers are particularly well-placed to deliver cross-cutting strategies and outcomes, most especially in terms of public health priorities and future care and support models. The Audit Scotland report on Affordable Housing also calls for improved collaboration with health and social care partners[footnoteRef:53] while a more recent paper[footnoteRef:54] explores ‘Models of housing with care and support’ calling for housing to be further integrated into health and social care. There is the potential for a wide spectrum of interventions to developed further, ranging from community based befriending and handyperson services through to complex and specialist accommodation and care packages for a wide range of conditions – not least related to the significant numbers of people living with dementia. There are also overlaps with and between housing and Scotland’s digital strategy with schemes like the Technology Enabled Care in Housing programme. It also welcomed that the Programme for Government includes ambitions to improve digital enablement in new social housing and that the EHTAP includes ambitions to co-ordinate health, social care, housing and homelessness planning. However, further actions may be needed to make sure this is implemented effectively. [53: Audit Scotland (2020) Report: Affordable housing https://www.audit-scotland.gov.uk/report/affordable-housing ] [54: SFHA (2020) Housing Scotland: Models of housing with care and support ]

Improving standards and guidance

A commitment to raise the accessibility, energy and design standards of housing will be key to developing and maintaining successful communities and it is welcome that the Scottish Government has already committed to improving cross tenure standards in housing. Progress on these commitments is now needed, recognising that delivery will require a permanent and substantive government investment alongside market-based mechanisms to drive up standards in the wider housing sector. The lived experience examples included reports of poor standards in the private rented sector and the importance of improving standards in existing owner-occupied homes has been emphasised in the group discussions. CAS have highlighted that social housing tenants also commonly seek advice on repairs and that the proportion of advice on those issues is higher now than it was before the pandemic.

One of the potential barriers identified in improving older homes across all tenures is the current disparity in VAT which is applicable in the case of work to the existing stock but not on new builds. It has been suggested that levelling VAT would stimulate further repair and maintenance work to improve the quality of the existing stock[footnoteRef:55]. This would ensure that sustainable repair is not penalised while also providing opportunities to convert long term empty properties or commercial buildings into housing. This would in turn help to increase the number of available homes and address homelessness while also improving living conditions and comfort levels for the occupiers, increasing their satisfaction with their home and quality of life. This is even more important in the context of the pandemic where people have been spending more time indoors at home. [55: Hurst (2020) RICS urges new chancellor to slash VAT on refurbishment work ]

The recommendations of the Working Group on Maintenance of Tenement Scheme Property[footnoteRef:56] have been referenced in the discussions and it is welcomed that these proposals are now being taken forward by the Scottish Government. The need for improved accessibility standards has also been raised and research on the experiences of disabled people in Scotland has recommended a review of the current guidance on Housing for Varying Needs to ensure inclusive design standards are applied across all tenure types[footnoteRef:57]. These are again changes which can improve quality of life for the most vulnerable householders including older people, people with disabilities and those in fuel poverty. [56: Working Group on Maintenance of Tenement Scheme Property (2019) Working Group on Maintenance of Tenement Scheme Property: Final Recommendations Report] [57: Equality and Human Rights Commission (2018) Housing and disabled people: Scotland’s Hidden Crisis]

The Policy Circle has also discussed the potential for the social sector to move beyond its perceived ‘safety net’ role and lead the way in raising quality standards and improving rent affordability. The social housing sector is already subject to a higher level of regulation than other sectors with statutory targets such as the SHQS and EESSH2 along with the commitments of the Scottish Social Housing Charter. Social housing providers also undertake a wide variety of activities to support their tenants, keep rents affordable and tackle poverty. There are therefore opportunities for this sector to demonstrate good practice and shared learning to drive improvements in the private sector, and the public sector, and deliver high-quality homes and services which will benefit individuals and communities.

One of the key discussions has been the role of the housing system in addressing climate change. The role of housing in the broader context of improving whole cities, towns and communities as part of an ecosystem was also noted. However, there are clear challenges in delivering more energy-efficient homes while also ensuring that the costs of refurbishing the existing stock, decarbonising heat supply and delivering zero carbon targets are not borne by those who are least able to afford it. Rising fuel costs and fuel poverty have been a key concern in the lived experience examples, particularly in rural communities or where households have limited options on fuel types and tariffs. JRF have for example highlighted the limited options for low income households with pre-payment meters[footnoteRef:58]. Recent research involving fuel poor households in Scotland has also highlighted particular concerns around the negative impacts of poorly heated homes on health and wellbeing[footnoteRef:59]. There were also reports of low levels of awareness around the advice and support available. [58: JRF (2020) Poverty in Scotland 2020 https://www.jrf.org.uk/report/poverty-scotland-2020 ] [59: Scottish Government (2020) Lived experience of fuel poverty: research ]

While the Programme for Government commits to a £1.6 billion investment in decarbonisation and addressing fuel poverty, work to update the Climate Change Plan, the Energy Efficient Scotland Routemap and the Fuel Poverty Strategy is still ongoing and further policy statements on heat and hydrogen are also expected. The Existing Homes Alliance has also made proposals on delivering zero carbon homes by 2045[footnoteRef:60] and expressed concerns about the further investment needed to tackle fuel poverty and ensure existing homes are warm and affordable[footnoteRef:61]. There have been calls for further investment in energy-efficiency programmes over the next parliamentary term along with proposals for an Energy Efficient Scotland Bill and Zero Carbon Homes Strategy[footnoteRef:62]. [60: Existing Homes Alliance (2019) Pathway to zero carbon homes ] [61: Existing Homes Alliance (2020) Existing Homes Alliance Scotland gives cautious welcome toinfrastructure investment ] [62: Existing Homes Alliance (2020) Energy efficiency to be at the heart of recovery in 2021 election manifesto ]

With the ambitious energy-efficiency targets already in place for the social sector through EESSH and now EESSH2, the Policy Circle has raised concerns about addressing fuel poverty in the private sector. For example, CAS report that over half of privately rented properties fall below EPC band C[footnoteRef:63]. The implementation of the Scottish Energy Efficiency PRS Regulations had been temporarily paused during the pandemic and the results of the consultation on improving energy efficiency in owner occupied homes are yet to be published. The group has discussed the importance of progressing standards in these tenures while also ensuring there is co-ordination and alignment of policy agendas. For example, there are some concerns around the impact which the increasing costs associated with energy performance will have on rents, particularly where the improvements have a limited impact on fuel bill savings. This was raised as an important concern in rural and remote areas, including island communities, where there may be additional costs associated with building new homes and retrofitting the existing stock. The need for effective delivery of energy-efficiency schemes was also raised, highlighting the need for a fabric first approach and preventing poorly installed measures which can lead to detrimental impacts for the occupants. [63: Citizens Advice Scotland (2020) Poor Energy Efficiency and Consumer Detriment]

The role of placemaking

Well-designed housing and neighbourhoods are essential to health and wellbeing. A practical and comprehensive strategy for place-making is vital for building successful places and this approach has been repeatedly raised in the Policy Circle discussions. As outlined in the Place Principle, this requires a more joined up approach to services, assets and placemaking[footnoteRef:64]. It has also been proposed that embedding the Place Principle will allow impact to be measured through the National Performance Framework to better understand what has been achieved and what still needs to be done. The planning system and new National Planning Framework (NPF4) also need to support the development of good quality homes and communities. The current review of NPF4 therefore provides a good opportunity to ensure planning processes support the national recovery and social renewal. [64: https://www.placestandard.scot/docs/Place_Standard_Strategic_Plan.pdf]

It was suggested in one of the group discussions that housing should be about place, people and property and while there is a clear demand to increase the volume of homes, this needs to be combined with an increased focus on placemaking and meeting peoples’ needs. While placemaking and the use of the Place Standard tool have been noted as useful approaches, the group have also noted the huge amount of resources required to support this. It was also noted that place-based models tend to be gender-blind and there were more general concerns about representation in community engagement activities and ensuring that this does not reinforce existing inequalities. The invisibility of children in local decision making was also raised although it was noted that plans to develop a Place Standard tool for children and young people is currently in development.

Although there have been significant developments in community partic