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EXECUTIVE SUMMARY

1. On the 18th of August, the Scottish Executive launched a consultation exercise to inform the Ministerial Statement on the abolition of priority need. The Minister for Communities is required, by section 3 of the Homelessness (Scotland) Act 2003, to provide a statement by the end of this year. The Statement will cover the current situation and future action needed to meet the target that, by 2012, all people who are unintentionally homeless will be entitled to a permanent home.

2. Respondents were asked to answer 13 specific questions covering 3 areas: the evidence base; coverage of the Ministerial Statement; and monitoring and interim objectives. This report presents an analysis of the responses to the consultation.

The consultation process

3. The consultation pack was distributed to 332 organisations and individuals. The intended audience of the consultation included all those with responsibility for strategic planning, delivery of and input to Homelessness Strategies in each local authority area, and local partners working with them.

4. In addition to the written consultation exercise, the Scottish Executive hosted 3 seminars in Edinburgh, Aberdeen and Glasgow, providing an opportunity for local elected members to engage directly with the Ministers. Notes of the proceedings were taken and have been combined with analysis of the written responses. In addition to these exercises, there has also been consideration of the issues by the Homelessness Monitoring Group and its 2012 planning subgroup; a Parliamentary debate on homelessness; and various individual meetings between Executive officials and stakeholders.

5. Responses to the consultation demonstrated much evidence of carefully considered comments. In total 50 responses to the consultation were received, the majority (30) from Local Government. Responses from the voluntary sector (13) and NHS (6) accounted for all but four of the other responses received. While there was a relatively low response rate, the specialised nature of the consultation meant that a wide response was unlikely. Many of the submissions were detailed and included significant discussion of the issues raised.

OVERVIEW

Support for abolition of priority need

6. Twenty-two respondents specifically noted their support for the legislative proposals or the commitment to abolish priority need. The Executive was commended for the 'progressive nature' of its homelessness legislation and for its 'innovative and farsighted approach'. The target was seen to be in line with Executive commitments to reduce health inequalities and achieve social justice targets.

7. Sixteen of these supportive statements were qualified with concerns over the ability of local authorities or other housing providers to meet the target in practice, and/ or raised the need for additional investment in social housing and for other financial assistance in order to meet the target.

8. In total, 12 Local Authorities had serious concerns about their ability to meet, or evidence to show that they will be unable to meet the 2012 target. In addition, one respondent felt that Supporting People grant issues reduced the likelihood of achieving the target. Several requests were made for the Ministerial Statement to acknowledge the pressures facing Local Authorities, and the difficulties some would face in meeting the 2012 target.

Balancing need

9. A major concern for several respondents to the written consultation and also expressed at regional seminars was that the target would have a significant impact on allocations policy, increasing the time spent on general waiting lists, and in some cases making a homelessness application the only viable route to social housing. There was also a concern that it could result in homeless households with greatest need waiting longer for permanent accommodation than at present.

10. There was also a view that discussions of 'balanced communities' and possible impacts on waiting lists may mask prejudicial attitudes towards homeless people, who should be understood as coming from within communities.

11. There was a general consensus on the need to have better information about the likely impact of 2012 on general waiting lists. An analysis of waiting list applications and allocations was seen as potentially useful in this context, including an identification of the extent and nature of need on the general waiting list.

Resources

12. It was a widely held view amongst respondents to the written consultation, and amongst those attending regional seminars, that the target was not achievable without significant resourcing in the form of additional affordable housing, temporary accommodation provision and financial resources (often for support work). There were requests for the Ministerial Statement to clearly set out what funding and additional resources would be made available to ensure that the target would be met.

13. Many specific comments were made regarding Supporting People funding. Respondents were highly concerned about decreases in Supporting People funding, and were predicting increases in the level and extent of support needs. While existing funding was welcomed, serious concern was expressed about ability to create new services. A focus on crisis provision was predicted, with detrimental impacts on prevention and sustainability.

Other key issues

Local Sensitivity:

• There were frequent requests for the Minister to recognise the unique concerns facing different types of authority and different geographical areas. The importance of sensitivity to local issues was repeatedly raised in specific comments on evidence base, measuring capacity, and the possibility of setting benchmarks and interim objectives as well as at regional seminars.

Right to Buy

• Several respondents felt that Right to Buy policy had negatively impacted on Councils' abilities to meet demand. There were requests for a re-consideration of the policy generally, and specifically of the potential extension of Right to Buy in 2012.

Tenancy options

• Several respondents raised concerns about restrictions on how Local Authorities could discharge their duties to homeless applicants. Some were concerned that a focus on permanent housing may not result in the most suitable housing outcomes for all, and felt a variety of housing tenures suited to individual needs, including the use of long-term supported accommodation and shared housing, would be highly important. Others raised the difficulty of obtaining secure tenancies in the private sector and recommended either allowing the use of Short Assured Tenancies in some circumstances, or findings ways to increase security in this sector.

Joint working

• Several respondents thought there was a need to improve joint working around homelessness, both for service providers and within the Executive and other bodies. Requests were made for the Minister to clarify the roles and responsibilities of different bodies and sectors and to encourage a corporate approach to homelessness. Comments were also made during regional seminars regarding the need to ensure coordination between different policy areas, for example around regeneration and homelessness, anti-social behaviour legislation and the removal of local connection.

CHAPTER SUMMARIES

The evidence base ( Chapter 2)

14. Key areas highlighted in responses to this section were the need to improve the accuracy of data, for better data on housing need, stock availability, support needs and the impact of other legislative changes.

• Respondents identified a need to improve the usefulness and consistency of data collected by tightening definitions used in collection and producing stricter guidance on methodology. Several emphasised the importance of recording local level data.
• Respondents commented on the difficulty of establishing total housing and the need to improve data on hidden homelessness and levels of rough sleeping.
• Several respondents commented on the importance of identifying 'latent need' for housing and support, and some suggested an analysis of waiting lists.
• Frequent comments were made about the lack of information on the private rented sector, including the size, quality and lettings information.
• Respondents frequently emphasised the importance of addressing the 'mismatch' between available stock and housing need when considering capacity, rather than simply the total amount of stock available.
• A review of existing levels and provision of support services was suggested to map what support was currently being provided, to whom, at what level.
• Respondents requested information on the nature and extent of support needs, both current and projected. Several respondents commented on the importance of considering health support needs.
• Suggestions were made for processes to improve joint working between the different agencies involved in providing support, for example, shared assessments and shared databases of support needs.
• The majority of those who commented (87%), were in favour of a re-run of the pro forma exercise, two thirds favouring either an annual or regular re-run. There was also a commonly held view that the pro forma exercise should be refined to tighten definitions and methodology and to include additional information.

Coverage of the Ministerial Statement ( Chapter 3)

• There was much common ground regarding the policy areas identified. Most commonly cited areas were Supporting People, Right to Buy, Anti-social Behaviour, Housing Benefit, and Health.
• Respondents also raised issues about the private rented sector, discharge their duty restrictions, funding, planning policy, allocations, children's policy, social work, education and prevention.
• A range of specific actions were identified, with many respondents focusing on areas of supply, support, stigma and prevention.
• There was also much consensus over barriers to diverse housing outcomes for homeless households. Key areas raised were stock issues, stigma, private sector, Housing Benefit and support needs. Again, various solutions were identified.
• There was a common view that additional funding would be required, though some respondents also believed existing funding streams could be used more effectively. There was a recurring view that the short-term nature of current funding streams was unhelpful, and that greater coordination between different funding streams within homelessness, health and social work, would be beneficial.

Monitoring and Interim Objectives ( Chapter 4)

• There was support for using the proportion of lets to homeless households and the length of time spent in temporary accommodation as measures of capacity, though also recognition of the shortfalls of these measures. It was commonly believed that the suitability of available stock to housing need should also be considered.
• There was some confusion between benchmarks and measures of capacity, however, about a third of those who commented believed benchmarks could be set. Wide local variations, gaps in the evidence base and the impact of any target on wider housing need were given as reasons why setting benchmarks would be difficult or undesirable.
• Most of those who commented appeared to support the idea that Local Authorities should be required to report against a broader set of targets, though concerns were expressed about increasing the report burden on Local Authorities and about the need to ensure local level sensitivity in any targets set.
• There was less support for a full resubmission of homelessness strategies following publication of the Ministerial Statement, with a commonly held view being that revision of strategies, possibly combined with a requirement to submit a short addendum or annual update, should be sufficient. Some of those in favour of resubmission, however, felt very strongly about this.
• Roughly half the respondents felt an interim objective should be included in the Ministerial Statement. The two main reasons for not including a target were lack of capacity and a preference for locally set targets.
• There was support for phasing to be based on withdrawing the vulnerability test, and /or on age. Other suggestions included that new priority need groups could be identified following a review of homelessness strategies. Several respondents emphasised the importance of sensitivity to local issues and capacity.
• With respect to the timing of any phasing, there was support for a variety of options including a three stage approach and one stage in 2007 or 2008/2009.
• Concerns were raised about the possible interaction of a locally based gradual phasing approach and a suspension of Local Connection.
• Twenty-four responses made suggestions for other possible interim objectives to be included in the statement. Areas suggested indicated targets both for local authorities and for the Executive. Some respondents also requested that targets be set for RSLS, particularly in relation to prevention work and tenancy sustainment.

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