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STEWARDSHIP AND RESPONSIBILITY: A Policy Framework for Private Housing in Scotland

CHAPTER FIVE: PUBLIC SECTOR INTERVENTION AND SUPPORT AT THE LOCAL LEVEL

INTRODUCTION

314. We have already emphasised our view that the primary responsibility for maintaining and improving the condition of private sector housing rests with the owners. However, the potential impact of poor housing on individuals and households and the consequences of neglect of maintenance and repair for neighbouring owners and communities can be substantial. We are clear that where poor housing conditions impact on other owners or the wider community there is a case for public intervention. For such intervention to be justified it is important that it is proportional to the seriousness of the problem being addressed and provides a proper balance between the objectives of public policy and the rights and responsibilities of individual owners.

315. Public sector activity in this area will generally take one of three broad forms: direct intervention, using powers to compel owners to undertake works; assistance to owners in undertaking those works; and, strategic planning of interventions to achieve policy objectives.

316. The use of powers of direct intervention has been a feature of local government activity since the 19th century. This approach developed from concerns over the public health consequences of slum housing and it is an approach that still underpins much of the legislation in this area. Although the need for such powers remains, the range of issues to be addressed and consequently the objectives of intervention, have changed. The health agenda remains important, poor housing has a direct impact on the well-being of its occupants and effective mechanisms to remove such conditions where they exist are still important. There are, however, a broader range of circumstances that warrant intervention, for example to secure repairs where failure to do so would have an impact on other property owners and to ensure good stewardship of the housing stock overall.

317. The context in which these powers are to be used has also changed. Whereas, in the past, local authorities might have expected to deal largely with private landlords and their tenants, most privately-owned housing is now owner-occupied.

318. Whilst most owners have the resources to maintain their homes, there is no doubt that some genuinely need help for a variety of reasons in order to carry out their maintenance and improvement responsibilities, and that there is a role for the public authorities in providing them with suitable assistance. In the past this assistance has been directed at specific condition problems, such as mandatory grants for improvement works to BTS houses. The growth of owner-occupation has brought into the sector a much wider variety of households. As well as a substantial number of low-income households (Scottish Executive Central Research Unit, 2002) other groups including those with disabilities, older owners and other households with particular needs also make up a significant proportion of owner-occupiers. Public policy should recognise the legitimate needs of these households.

319. The use of both the powers of intervention and of support and assistance has, in the past, been largely driven by the need to address a limited range of specific and clearly defined problems. During the 1970s and 1980s, the need to eradicate up to 250,000 slum houses presented a clear set of priorities that required relatively little by way of a strategic overview or appraisal of options. With the eradication of most of these slums, the process of prioritisation must of necessity become more sophisticated. Closer monitoring of conditions is required to identify new problems as they arise and a more strategic and enabling approach is required to planning interventions to improve conditions and quality.

BACKGROUND

Strategic planning

320. The Housing (Scotland) Act 2001 (the 2001 Act) introduced wide-ranging changes to the system of housing planning that has been in place since the mid 1970s. In particular the Act creates a duty on local authorities to prepare "Local Housing Strategies" for submission to Scottish Ministers.

321. In addition, Section 85 of the Housing (Scotland) Act 1987 (the 1987 Act) places a duty on local authorities to secure that:

'...all houses in their district that do not meet the Tolerable Standard are closed, demolished or brought up to the Standard within such a period as is reasonable in all the circumstances'

and requires that local authorities should survey their area from time to time to identify those houses that do not meet the Standard in order that appropriate action can be taken.

322. The provisions of the 2001 Act are intended to ensure the development of a comprehensive approach to local housing planning. To achieve this the Act specifies (in section 89(2)(a)) a wide range of factors that must be assessed in the preparation of such a strategy including 'the nature and condition of the housing stock'. Section 89 (5) of the 2001 Act sets out the "purpose" to which Local Housing Strategies should be addressed. In particular it defines the purpose as:

'... the provision ... of housing and related services in a manner which - is economic, efficient and effective, and ensures, so far as reasonably practicable, that persons do not live in fuel poverty.'

323. The Scottish Executive has also published detailed guidance for local authorities on how they should go about assessing the needs of their area, carrying out option appraisals on identified strategies for meeting those needs and engaging with interest groups and stakeholders in preparing the strategy.

Assistance to owners

324. The current framework for financial assistance was set out in the Housing (Scotland) Act 1974. This focused on improvement and repair grants, in parallel with compulsory powers to deal with individual houses and housing areas. The provisions were consolidated and revised without fundamental change by the 1987 Act and were amended by the 2001 Act.

Grants

325. Most grants are awarded at the discretion of the local authority, which also decides, within the resources available to it, how much to spend on improvement and repairs grants as a whole in its area. In some cases the local authority must make grant available, e.g. for provision of the standard amenities; or where it has made an improvement order, served a repairs notice or declared a Housing Action Area. Grants may be used to help particular households, for example those requiring disability adaptations. However, overall grant expenditure accounts for only approximately 4% of total investment in private sector housing repair and maintenance (Scottish Homes, 1997).

326. Part 6 of the 2001 Act (which has not yet been commenced) broadens the scope of works eligible for grant, increases the limit on the cost of works and effectively removes the distinction between improvement and repair grants. More fundamentally, it introduces a test that links the amount of grant to the applicant's circumstances. Previously grant was in most cases determined only by the works involved. For owner-occupiers, the proposed new test is based on their resources and may result in 100% grant for applicants on the lowest incomes and no grant for those above a certain income level. For other owners who are not occupiers, different factors affect their decision to invest in their property, and the proposed test is therefore differently based. It is also proposed that for certain priority categories of works, for example, works linked to various forms of statutory notices, any grant made will be at least at a defined minimum level whatever the owner's circumstances.

Other forms of assistance

327. Although grant has been the predominant form of assistance, local authorities have other powers to provide assistance. They can make loans subject to criteria laid down in the 1987 Act, but given those criteria and the nature of the modern financial market, these powers are not widely used. Some local authorities find ways, within general powers or through local legislation, to provide tailored assistance to suit their circumstances.

328. Part 5 of the 2001 Act also permits local authorities to assist an individual in connection with the acquisition, construction, improvement, repair or maintenance of housing. Amongst other things, such assistance may take the form of granting or guaranteeing loans, making available the services of the staff of the local authority and providing or arranging for the provision of information. These new powers are, we understand, to be the subject of guidance and regulation in due course and although they are as yet untested, they provide considerable scope for broadening the range of assistance within the existing statutory framework. This scope will be further increased at the local level by the "power to advance well-being" introduced through the Local Government in Scotland Act 2003.

329. Practitioners on the ground have long recognised that many home owners, especially those with particular needs, may require additional support to assist them to remain in their homes. Care and Repair projects have been developed in most local authority areas to meet these needs. Facilitating access to housing grants is a standard feature of Care and Repair schemes but they may also include small repairs schemes and advise on entitlement to benefits. In addition, the self-contained Central Heating Initiative and Warm Deal programmes provide central heating and insulation for vulnerable and low-income households.

330. Also in this area of service delivery, the "Joint Future" approach is driving efforts to co-ordinate the contribution of local authorities (social work and housing) and health bodies in community care and seeking to improve joint planning, resourcing and management of community care services. It includes a single shared assessment of the individual's needs and, more generally, a "person centred" approach.

Funding

331. The arrangements for funding public investment in private sector housing are also undergoing significant change. We welcome the announcement by Scottish Ministers that expenditure by local authorities will be funded by a Private Sector Housing Grant linked to outcome agreements between local authorities and Communities Scotland. This will allow local authorities to plan more effectively for investment in the private housing stock without direct competition for resources from other areas of their activity. We expect the Grant to be applied primarily to the capital costs of providing assistance and possibly also to some revenue costs such as the initial establishment of the new scheme in the authority's area.

Local authority powers

332. At present the use of statutory notices or enforcement action is only likely to occur on a reactive basis where a problem has become so serious that a clear risk exists to the public or it is unlikely that the owners will be in a position to deal with the problem themselves. Some authorities (notably Edinburgh) have adopted a more pro-active approach to the use of notices in response to contact from owners having problems in carrying out repairs, but this approach is not widespread.

333. Available evidence suggests that one of the main reasons for the decline in the use of statutory powers has been the reduction in the resources allocated to tackling private sector housing problems. This is linked to the fact that statutory notices and orders served in respect of BTS houses and those in disrepair carry with them a mandatory entitlement to grant on the part of the property owner.

334. In addition, the success of the slum clearance and improvement programmes up to the mid 1980s has removed most of the concentrations of BTS properties that the Housing Action Area procedures, in particular, were designed to address. As a result the number of action areas being declared has fallen significantly over the past 15 years.

STRATEGIC PLANNING

Developing the Local Housing Strategy system

335. In paragraphs 320 to 323 above we have set out the main features of the present housing planning system. We consider that the system requires to be strengthened to provide a more effective framework for promoting housing quality. In framing our recommendations to address this issue we took the view that strategic planning should:

• be comprehensive in scope
• be clear as to its purpose and objectives
• set and monitor appropriate targets both locally and nationally
• be responsive to local needs, conditions and priorities
• be linked to effective delivery mechanisms.

336. The revised Tolerable Standard and the proposed Scottish Housing Quality Standard need to be set in the context of a strategic planning framework that gives explicit recognition to the importance of promoting improvements in housing quality in the private sector and provides appropriate guidance to local authorities. This should include targets for improvements in housing quality at both national and local levels.

337. We considered the various duties imposed by the 1987 Act and came to the view that the existing duty in respect of BTS properties set out in Section 85 should be retained. However, the requirement to act in relation to BTS properties only extends to ensuring that action is taken 'within such period that is reasonable in all the circumstances'. In the light of the conclusion from the Task Force's first report that current rates of activity mean it could take 20 years to eradicate the number of homes that fail the Standard as it is currently defined, we are of the view that it would be appropriate that time-scales and targets should be set for the implementation of measures to remove and improve BTS houses.

338. We therefore consider that the relevant section of the 1987 Act should be amended to require that local authorities publish targets for the reduction in the number of BTS houses in their area. In addition Scottish Ministers should set national targets for the reduction in the number of homes failing the Tolerable Standard. These targets should be reflected in, and supported by, plans for the implementation of Local Housing Strategies and the private sector housing grant local outcome agreements.

339. Local Housing Strategies will be key documents in identifying the extent of housing quality problems in local authorities' areas and in the process of developing effective strategies to address such problems. In the light of this we also considered the wording of Section 89 (5) of the 2001 Act in setting out the "purpose" to which Local Housing Strategies should be addressed. We are of the view that promoting improvements in housing quality should be a specified objective of Local Housing Strategies and that this section of the Act should be amended to reflect this.

340. To support the proposals we make in this report it will be necessary to ensure that early changes are made to the guidance on the preparation and implementation of Local Housing Strategies to give local authorities a clear steer as to how these new duties should be approached. In particular local authorities will need new guidance on:

• developing and setting targets and developing strategies for the eradication of BTS housing
• the application and interpretation of the Scottish Housing Quality Standard
• approaches to engaging with owner-occupiers, private landlords and other professionals (including surveyors, architects and solicitors involved in house buying and selling)
• developing information strategies and other interventions to encourage owners to improve and maintain their homes
• developing and assessing strategies tailored to the needs of minority ethnic communities and other equalities groups
• planning for the use of revised statutory powers
• developing and implementing the scheme of assistance
• linking local strategies to other relevant strategies such as the Fuel Poverty Strategy.

341. In addition, the design of both the Scottish House Condition Survey and local house condition survey package provided and supported by Communities Scotland should be developed to allow the stock to be assessed against the revised Tolerable Standard and the Scottish Housing Quality Standard.

PROVIDING ASSISTANCE TO OWNERS

342. Our proposals for assistance to owners to repair and improve their houses are based on the principle that the form of assistance should be appropriate to the difficulty that the owner faces in carrying out works. Lack of financial means is an obvious difficulty for many. However, for others the difficulty may be in organising finance, in organising works, in obtaining co-operation from others affected by or having a responsibility for the works, or indeed in simply knowing how to go about these things. We consider that it should be made clear to individuals what range of possible assistance is available and that the local authority will aim to provide the individual with those forms of assistance that are the most cost-effective in the circumstances.

343. We consider that the local authority should remain the primary channel for assistance. This will allow judgements on the appropriate assistance to be made locally according to circumstances, and will provide the local authority with a tool for the implementation of its Local Housing Strategy. Indeed, our view is that the local authority's scope and flexibility in the use of assistance should be increased in line with their enhanced strategic role created by the 2001 Act. However, we consider that this should happen within a clear national framework to ensure that national priorities are addressed and that there is an appropriate level of consistency across Scotland.

344. We propose that the various forms of assistance that are, and should be, available for the repair, improvement and adaptation of houses are brought together in a single scheme which includes a national framework for their delivery.

Scheme of assistance

345. Paragraphs 346 to 376 contain a set of proposals that in our view link existing strands of policy and build on them to form a scheme that promotes a culture of individual responsibility and increases local discretion within a national framework.

Standards and priorities

346. Works should normally only be eligible for public assistance if they will bring the house to a defined standard. In the light of the recommendations on standards that we make in Chapter Two of this report, we recommend that assistance should normally be directed at achieving either the Tolerable Standard or the Scottish Housing Quality Standard. However, there will need to be some flexibility to allow for:

• locally determined higher standards in Housing Renewal Areas where this is necessary to meet the aims of the designation
• assistance for adaptations to meet the particular needs of those with disabilities.

347. The priorities for directing public resources to the achievement of these standards will differ between areas and classes of housing according to local needs and circumstances. The strategic decisions on the standards to apply and the prioritising of resources should be taken by local authorities in the context of their Local Housing Strategies. They should take into account the national framework of strategic housing priorities, which should be part of the outcome agreements between local authorities and Communities Scotland that will govern the allocation of Private Sector Housing Grant.

348. We propose that, as part of the national framework, the improvement of houses that are below the Tolerable Standard and the adaptation of houses for those with particular needs should be identified as national priorities for assistance.

Forms of assistance

349. We propose that each local authority should consider how to make each of the following forms of assistance available in its area, and in what circumstances, subject to the national framework, applicants will be eligible for each type of assistance.

General advice and guidance

350. The most basic assistance for improvements is general advice and guidance, usually in the form of leaflets, websites and general advice given by advice centres. This should be available to everyone as part of the housing advice services provided by local authorities and by a range of local advice agencies, retailers and others, and those services should be underpinned by suitably resourced training. We note that Communities Scotland's HomePoint service co-ordinates and seeks to improve housing advice, by providing a range of information, developing and supporting a network of housing advice providers with training materials and by promoting an accreditation system built on its national standards and good practice guidance (Scottish Homes, 2000).

351. We suggest that HomePoint should ensure that its services promote and support the proposals of the Task Force, and that it should consider, at an appropriate time, the provision of information and education through a national publicity campaign. The design of any such campaign should pay particular attention to the needs of equalities groups.

Practical assistance

352. Some people are able to afford improvement works but find it difficult to arrange the work or the finance. Each local authority should ensure, as part of the outcome agreement referred to in paragraph 347, that there is the capacity in its area to provide those with particular needs with the equivalent of at least the current core services of Care and Repair schemes together with: services to carry out small repairs ancillary to improvement works; "handyman" services for tasks like changing tap washers; and advice on loans with access to grants for arrangement fees. In our view no particular model for this type of assistance should be imposed across the country, as it is important to retain sensitivity to local circumstances and the local availability of skills in the provision of this small-scale and personal assistance. However, we believe that delivery of these services by an organisation which is seen as independent from the local authority will maximise take-up by the client group. These services should also be extended to those other vulnerable people who need them.

353. We also consider that a small repair service available to those with particular needs who need it to help with pre-emptive repairs would lead to an increase in the general quality of the housing stock. We do not wish to discourage people in these groups who are able to manage their own maintenance responsibilities, and so consider that preventive small repairs services should be available to those assessed as needing them, primarily through their inability to manage the works. It would be reasonable to charge for all or part of the service where the individual has the means.

354. Practical assistance may also help individuals overcome problems in dealing with neighbours on joint and shared responsibilities. We recommend in Chapter Four of this report that local authorities encourage the establishment of owners' associations, property management arrangements and sinking funds and have the power to make modest grants to this end. We also encourage the use of community mediation schemes, subject to a review of the scope for doing so. These forms of practical assistance should be regarded as part of the range of options for assistance available under the scheme.

Loans

355. The normal commercial market provides a wide range of loans but in some cases it is not practical for an owner to obtain a loan. Local authorities should be encouraged to make loans available where this is a significant problem, either direct or through an intermediary and for all or part of the work. In particular, the administrative costs of small loans can be disproportionately high and they can, as a result, be difficult to obtain at reasonable cost on the commercial market. Assistance with small loans could facilitate smaller-scale works and more substantial works where the applicant has difficulty in funding the balance of cost after grant.

356. Loans could be either:

• conventional loans with regular repayment of capital and interest where these are not available from reputable financial providers (for example small loans)
• equity loans where the capital is repaid when the property is sold - again where such a loan is not available from reputable financial providers. Such a loan could involve deferred or interest only payments made at regular intervals, interest "rolled up" into the capital sum and recovered when the property is sold, or the lender taking a share in the equity and recovering the same proportion of the value of the property when it is sold.

357. Where any loan-based assistance is offered, a local authority should also ensure that the client is aware of, and has access to, suitable financial advice before accepting such a loan.

Subsidised loans

358. Local authorities should be able to subsidise conventional loans by reducing interest payments and to subsidise equity loans by reducing the amount of interest, whether it is paid regularly or "rolled up" into the capital sum, or abating the capital sum recovered on sale. In addition, they should be able to make small grants to assist people with access to commercial loans, for example with survey, arrangement or legal fees. A small grant would only be made where the local authority was satisfied that the applicant needed it in order to be able to carry out works.

359. In making proposals for an increased use of loan-based assistance and equity-based loans we are aware that some members of the Muslim community may face problems with this approach. In the light of this we also recommend that the powers available to local authorities should include the options to use loan-based mechanisms that comply with the religious needs of the Muslim community. The details of how such mechanisms could be structured should be the subject of specific consultation with the Muslim community.

Subsidy through grant

360. Where necessary, grant for building works should be available, calculated as a percentage of the approved cost of the improvement works and depending on the house and the owner's circumstances. We expect that grant will, in practice, remain a significant form of assistance used in a substantial number of cases. The nature of grant assistance has been refined over the years and in particular was the subject of extensive consultation in connection with the 2001 Act. We do not propose to depart radically from the basic nature of grant assistance although we do make proposals below on the targeting and calculation of grant.

Change of tenure

361. In some circumstances the works needed may be such that the best course of action is for the owner to sell and move into the rented sector. This may result in significant disruption for the household and in such circumstances the local authority should be able to offer a change of tenure as an option under the scheme of assistance. Change of tenure involves sale of the property to an RSL or the local authority, with the owner becoming the tenant. The landlord would carry out necessary improvements and charge an affordable rent.

362. We expect that the arrangements should follow those for the Mortgage-to-Rent Scheme recently introduced by Communities Scotland, subject to experience from the initial operation of that Scheme. Because this approach subsidises both the cost of bringing the property up to a lettable standard and the setting of an affordable rent, we consider that change of tenure should be available under the scheme of assistance only as a last resort and if the level of subsidy involved is justified in the light of the following criteria:

• other forms of assistance under the scheme will not enable the applicant to bring the house to an acceptable standard and sustain owner-occupation and the maintenance responsibilities that go with it
• without change of tenure the applicant will need to be re-housed in the social rented sector
• it is desirable for the household to remain in the house
• the necessary work will not proceed otherwise.

363. Our view is that change of tenure to achieve improvements or repairs should be managed by the local authority as an integral part of the local administration of the scheme of assistance. We do, however, recognise that a nationally-run and funded scheme (perhaps as part of the existing Mortgage-to-Rent scheme) might offer benefits, particularly as local authorities may find it difficult to develop the necessary expertise in this area. We suggest that this matter be kept under review in the light of demand for tenure change and of experience with Mortgage to Rent.

364. In some cases, the former landlord - local authority or RSL - may wish to buy back properties purchased under the Right To Buy, in order to facilitate a scheme of repairs or improvements on its own properties. If the owner does not meet the criteria we propose above, our view is that the buy-back should be justified and funded as part of the landlord's scheme for its own stock and not be dealt with as a change of tenure funded from Private Sector Housing Grant under this scheme of assistance.

365. Shared ownership as a half-way house to change of tenure could in theory be used to release funds for repair and maintenance, with the local authority/RSL buying a share in the property and carrying out the necessary works, rather than taking full ownership in the manner described above. The price paid would be the value of the share minus the cost of the works. However, the resulting arrangement can be very complex legally. In our view there is not a case for the local authority to become involved in part ownership of the property simply to release funds for works when the same purpose could be achieved with less difficulty by use of an equity loan or other options in this scheme.

National criteria for deciding on the type and amount of assistance

366. Applications for assistance should be made to the appropriate local authority. The local authority should decide applications on the basis of its Local Housing Strategy priorities and its policies within the national framework of criteria contained in the following paragraphs.

367. Local authorities should have substantial discretion in their use of the tools available for providing assistance, subject to the principle that the primary responsibility for the improvement of a privately-owned house lies with the owner. They should use the most cost-effective combination for achieving their objectives. In general this means that subsidised financial assistance should normally come into play only where facilitation and access to finance is not sufficient to ensure that necessary works are carried out. Where a traditional loan is not an acceptable form of assistance on religious grounds it should not be considered as an option by the local authority.

368. The following criteria should apply to assistance for works to individual houses:

• If the house is below the Tolerable Standard, the local authority has a duty to ensure that it is closed or improved within a reasonable time. This may not be until the house next changes hands. It should be required to provide assistance to the owner but the type and combination of assistance necessary in order to help it fulfil its duty should be for the local authority to determine. We recommend also in paragraph 387 that there should no longer be a mandatory requirement on the local authority to make grant available.
• If the house is above the Tolerable Standard, the local authority should deal with the application in accordance with its strategic decisions on standards in terms of paragraph 366 aboves.
• Where a loan or grant is made, the amount should be limited to the reasonable cost of the works (including ancillary costs such as professional fees) necessary to bring the house to the appropriate standard. The local authority should judge reasonable cost, which could allow, for example, for requirements for buildings of historical or architectural significance.
• Where a grant or subsidised loan is made to an owner-occupier the amount of subsidy should reflect the financial circumstances of the owner (or the disabled person where the subsidy is for disabled adaptations) and their spouse or partner. There should be a nationally defined test for deciding the owner's contribution, but the local authority should be able to adjust the test for a defined area (whether that is the whole of the local authority's area or part of it) on the basis of evidence that the distribution of income levels in that area is significantly different from the national distribution of incomes. We expect that the nationally defined test will, at least initially, be that which will apply under the 2001 Act, but recommend that the impact of the test be assessed and it be reviewed on a regular basis.
• Where the works are in a priority category, there should be a nationally defined minimum percentage for the amount of subsidy. The priority categories should be: works to houses that are below the Tolerable Standard or the subject of a statutory repairs notice; works to adapt a house to the needs of a disabled person; works to common and shared parts of buildings; and works to meet fire safety requirements. The local authority should be able to vary the minimum levels upwards or downwards for different classes of application and in designated Housing Renewal Areas where there are explicit grounds for requiring different minimum percentages to address the local authority's strategic priorities.
• Loan, subsidised loan or grant should be provided to private tenants only where the tenant has a contractual responsibility for repairs and maintenance. Where the applicant is a landlord, a developer or the owner of a non-housing property sharing in necessary communal works that benefit houses in that property, the local authority should have discretion to decide the amount of any subsidy.
• Where the house is a second or holiday home that will not be kept available for letting, no assistance other than general advice and guidance should be given. Houses in these categories do not provide for the basic housing needs of the owner or tenant or for the expansion of the available stock and so should not be the subject of public assistance.
• The local authority should ensure that practical assistance in terms of paragraphs 352 to 354 is available for older and disabled households and those other vulnerable people assessed as needing assistance.

369. For common and shared works, in addition to the provisions for minimum grants and for non-housing properties in paragraph 368, the local authority should also be able to provide assistance for improvements for the common benefit to land attached to the building. It will be for the local authority to decide, in the light of any action it may take as provided for in Chapter Four of this report, the amount of any grant to be made towards the establishment of owners' associations, property management arrangements, sinking funds and community mediation schemes as indicated in paragraph 354.

370. We consider that the statutory administrative processes involved in providing assistance should be simplified and streamlined including appeals mechanisms as appropriate, both to benefit the processing of individual applications and to facilitate a co-ordinated and consultative approach when action is taken on an area basis.

Delivering assistance for people with particular needs

371. The scheme we propose here makes special provision to meet the particular needs of older and vulnerable people and those with disabilities in a number of ways, including practical assistance, minimum percentage grants for adaptations and defining adaptations as a national priority for assistance. As noted in paragraph 330, assistance with housing works for this group of people is closely related to community care services. We consider that such assistance should be an integral part of the present scheme to ensure that it remains consistent with other forms of assistance under the scheme and because an individual may well seek to carry out works that are related to the general standard of the house as well as to his or her particular needs. However, we consider that the delivery of assistance should as far as possible be integrated with related community care services in a "person centred" approach that includes a single shared assessment and considers the full range of options for enhancing the availability and quality of housing to meet the assessed needs. In addition we are of the view that, in making an assessment of the needs of an applicant for assistance to carry out works of adaptation to their home, it should be possible to take into account the likely future needs of the applicant and ensure that any additional works that may be needed to meet them are carried out at the same time.

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