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CHAPTER TWO: SUPPLY

This section has been broken down further under the following sub themes:

1 Supply of New Social and Affordable Housing.

2 Temporary Accommodation Issues.

3 Allocations to Homeless Households.

1 Supply of New Social and Affordable Housing.

The majority of councils mentioned the shortage of suitable housing for rent as being the major barrier in their ability to achieve the 2012 target. This is being compounded by house price inflation forcing more people to look to the rented sector to meet their housing needs.

However supply is about more than just crude numbers. Various factors affect the supply of new housing and if these aren't addressed then local housing needs will not be met. The major issues affecting the supply of and access to new affordable and social housing are reported as follows.

High house prices, low incomes & the impact of the tourist industry on house price inflation.

Increasing house prices throughout Scotland over the last few years have contributed to increasing demand on the social and private sector rented markets. Previously those on lower incomes who would have been able to buy have been forced out of this market as prices have risen. In remote/rural areas these rises can have a magnifying effect due to sparse supply. In addition those working in rural localities tend to have lower than average household incomes making it even more difficult to afford to buy. In some rural locations house price inflation is higher than that of the national level due to the purchase of property as second homes or holiday lets.

In other areas there are concerns that house prices are now so high that even government shared equity schemes, may not be as effective as intended.

With the introduction of new shared equity schemes some rural/island councils feared that these would replace existing successful schemes, such as Rural Home Ownership Grants and Gro-Grants which had proved to be effective in these locations.

Available/Suitable Land.

A number of councils stated that they had very limited land available for housing held on their Housing Revenue Account ( HRA) - or that land available was unsuitable because of contamination or other reasons (flooding etc).

This means that in those areas land for house building is generally only available from private owners at current market values.

In other cases while there is a significant proportion of land zoned for housing the majority may be privately owned, or in the hands of Trusts, with owners expressing a reluctance to sell or develop the land.

Impact of increasing land prices/speculative land banking by developers, appropriate location of available land for development.

Some councils have raised concerns over their difficulties in influencing developers to bring on sites for housing. There is also frustration at developers who, rather than building on a site, hold on to it for a number of years then sell it on for a profit as land prices have increased.

A number of councils noted that the increasing price of land was making it more difficult, particularly for RSLs, to successfully bid for land. In one council land prices had risen by 100% in the past 2 to 3 years.

There are concerns that funding for new developments provided by Communities Scotland no longer reflects increasing land prices. Where RSLs are successful in securing land, they may have to build to a higher density to make developments financially viable.

In some areas the high price of land coupled with the cost of development makes it increasingly difficult to build social housing as the rental income would not be sufficient to service the debt. Higher land costs also puts pressure on the developer's ability to meet the 'affordable' proportion of the project. In some cases the developer will transfer the element of proposed affordable housing from one site to another further down the development programme. In this respect one council stated that despite planning consent for a large number of affordable homes on private sites very few of these had actually been delivered as yet.

Government Agencies/Departments disposal of land.

It was suggested by a number of councils that it would be particularly beneficial if surplus land held by public agencies, such as the NHS, MOD, and by councils for housing themselves, e.g. Education Departments is made available first of all to councils or RSLs at below market prices. In certain areas this would make a huge difference to the supply of affordable housing if land were to be released at affordable prices.

One council has been successful in agreeing disposal of land from the Health Board at less than market rates. They have also been successful in acquiring surplus Ministry Of Defence ( MOD) property at below market value. However, the condition of the housing varies with some properties requiring considerable expenditure to bring them up to the Scottish Housing Quality Standard ( SHQS).

Higher construction costs in rural/island authorities/building capacity/too few developers.

In island councils in particular, construction costs are generally higher than that on the mainland. There are also issues with having limited numbers of local builders who can only complete a set number of properties per year depending on what other work they have. In cases where local builders are engaged in large projects e.g. schools, hospitals or wind farms it is almost impossible for them to take on other work such as house building. In these situations it is also particularly difficult to bring in workers from other areas as there is nowhere to house them during the course of the construction work.

The lack of developers is an issue particularly in rural areas. This can create a problem particularly if one or more of the key developers are resistant to the recommended 25% quota of affordable housing on sites.

Financial burdens on developers in achieving affordable housing targets/ completions.

Homeless teams have commented that developers can be hampered in their ability to deliver the affordable housing element as a result of the financial burden placed upon them. This is not only in terms of the increasing cost of land, but also the cost of providing broader community services as part of the development, e.g. schools provision. If this burden was reduced in some way by providing alternative funding streams for the provision of community services it may be possible to increase the percentage of affordable housing delivered within developments.

Infrastructure issues particularly problematic in rural/island councils.

A number of councils, in particular rural & island councils, commented on the capacity issues Scottish Water is encountering in meeting the demands placed on water and sewerage systems by new developments. In some areas Scottish Water had apparently placed a moratorium for new housing developments because of a lack of capacity leading to delays in programmes being started.

Planning constraints.

Planning constraints are regularly raised as an issue in progressing new build affordable & social housing. Some councils have extensive green belt areas within their locality and developers find it difficult to get planning consent to develop on these sites. Councils are looking for greater flexibility in how to tackle these and other planning issues, requiring a review or relaxation of current planning regulations. One council mentioned that despite the need for more houses the limit of land zoned for house building had already been exceeded.

Negative local attitudes in relation to affordable/social housing.

Councils have commented that when proposing the development of a new site for affordable housing they can face considerable objections from members of the public.

These relate for example to possible increased traffic in the area and NIMBY concerns about the potential lifestyles of the occupants of the new development, particularly in the "affordable" and social housing parts of the development.

This attitude is sometimes reflected by some private developers themselves who fear that affordable housing within a development will "lower the tone" and make it less attractive to potential buyers of the higher cost accommodation.

For councils which have traditionally low density housing, objections are often common if developers plan to build to a higher density in order to make the site financially viable.

Some councils also face community opposition to developing housing in certain areas because of concern with the possible environmental and social impact, and councils often come up against public opposition to development on green belt land.

Yearly loss through Right To Buy outstripping new build social housing developments.

Prior to recent announcements by the new Government on the Right To Buy ( RTB), many councils commented that the completion of new build RSL housing for rent is not matching the numbers being lost by the council via RTB. If supply is to catch up with demand spurred further by increased rights to permanent accommodation, as per the homelessness legislation, this situation needs to be reversed. On a positive note two councils are planning to build housing for social rent with construction currently on site in one of these.

Effectiveness of Pressured Area Status ( PAS).

A number of councils are still year on year losing significant amounts of their remaining stock, in some cases despite being granted Pressured Area Status. Councils generally felt that PAS had a limited impact in preserving rented stock.

The time consuming process of applying for PAS was questioned by a number of councils. Applications have to be made on a lettings area basis rather than on a council wide basis. This process is particularly time consuming for smaller councils who have less staff but may still have numerous lettings areas based on many small communities. Other councils didn't feel that the savings in house sales warranted the effort given that some tenants retain a protected right to buy. Others were concerned that if the council stated it would be applying for PAS this would create a rush of applications prior to PAS being granted.

Councils with identified net housing surplus.

For some councils, Bramley's modelling had identified that they had in fact a net surplus of housing. However in many instances the surplus was as a result of the need to carry out major regeneration or demolition or was in areas where applicants didn't want to live. In cases of regeneration there were concerns that new housing provision would be sufficient to meet increasing demand or long-term need.

What are councils looking for?

• House prices: Councils recognise that the Government can do little with regard to the increase in house prices. However councils would ask that shared equity schemes and the mortgage to rent scheme continue to be sufficiently funded to ensure that they take account of rising house prices and continue to assist as many people as possible.
• Land/Development Issues: Councils would like to see the Government encourage public bodies to dispose of any surplus land or housing to councils or RSLs at preferential rates. This will be of great assistance in particular to those councils who have limited land available themselves.
• Councils request the Government to take account of the increase in land prices when allocating development funding to RSLs. If finance does not take account of increased land prices RSLs will either be priced out of the market, will have to build to high densities or will have to charge significantly more than a social rent in order to service the debt incurred.
• Some councils are seeking a review in relation to the current situation where a trade off is often required between developers and themselves to provide the maximum number of affordable units at the potential expense of community facilities for which no alternative funding is currently available.
• Rural/island issues: Councils in rural or island areas require the recognition that they have unique problems in relation to the supply of housing and need to have specific options/solutions tailored to their needs. Account should be taken of higher construction costs, limited numbers of developers and building companies. Issues around second homes and the impact of the tourist industry also have to be considered, with locals being priced out of the property market.
• Infrastructure Issues: Issues with Scottish Water's difficulties in providing water and sewerage services need to be looked at. Councils want discussions with Scottish Water at a national level to look at ways to resolve their capacity issues which have been delaying developments. These capacity issues are regarded as particularly problematic by rural and island councils.
• Planning Constraints: Councils expect that the Housing Supply Task Force will examine the issues mentioned around the supply of land and will also look at planning constraints faced by councils and will take action to ensure more land is made available for housing.
• Negative local attitudes to affordable/social housing: Councils themselves need to find ways of working with the local community to avoid community objections to plans for the development of sites for housing.
• Greater loss via right to buy than completions by RSLs & effectiveness of pressured area status: Councils need RSLs to increase their housing completions to keep up with the numbers of houses councils are selling via right to buy. This will not be easy given the above issues already highlighted.
• Despite being reviewed in 2006 councils would like the pressured area status process to be re visited as the application process is still considered cumbersome and the effect of the status is limited given that some tenants still retain a protected right to buy.
• Councils with net housing surplus: Councils accredited with net surpluses argue that this surplus can be artificial. The surplus tends to be either housing that has been earmarked for demolition, regeneration, in poor condition or generally in areas of very low or no demand. In relation to demolition and regeneration councils would hope that the number of properties built would match that which was lost.

1. Supply of New Social and Affordable Housing

Actions currently underway

Since the Homelessness Support Project began, the Housing Supply Task Force has been established to examine all the barriers to the provision of housing in Scotland. The remit of the Task Force covers many of the issues which have been raised by councils relating to the lack of supply including planning and infrastructure issues. The Task Force is also considering the specific housing supply difficulties faced by rural and island councils. Accordingly, this report does not include suggested actions on supply as the relevant issues are already being taken forward by the Task Force. The Task Force, which includes representatives from COSLA, will continue to engage with councils, and RSLs, developers and other housing interests to ensure that their concerns relating to supply are taken account of in the Task Force process.

The Scottish Government continues to fund shared equity packages and the mortgage to rent scheme, but should ensure that these reflect increasing house prices. Rural and island councils are particularly keen that rural home ownership grants continue to be to be available as a shared equity option.

The Scottish Government should ensure (a) that their funding for new housing and RSL new build schemes continues to take account of supply issues affecting costs; and (b) that this funding is maintained at a level which will provide new housing and represent value for money.

Suggested Actions in recommended order of priority

1. The Scottish Government, along with COSLA, ALACHO, SFHA and RSLs should enter into discussions with other national bodies who may have surplus land or property with a view to negotiating preferential rates for its disposal. These organisations could be NHS, MOD and the Forestry Commission.

In addition councils should ensure that when disposing of any of their own land first priority is given to the consideration of new housing. This is a vital action if the general shortage of land for affordable housing in certain council areas is to be effectively addressed.

2. It is equally important in areas of acute shortage of housing that councils retain current stock levels. In this respect ALACHO, COSLA and the Scottish Government should enter into discussions with a view to further restrictions in the right to buy than that proposed in Firm Foundations. In addition although revised in 2006, the application of the pressured area status should be further assessed in terms of its impact.

3. The Scottish Government should ensure that Scottish Water's investment programme is sufficiently funded and prioritised to take account of all anticipated strategic infrastructure development to ensure the provision of new housing is not delayed.

2 Temporary Accommodation Issues

Since 2001 councils have significantly increased the provision and quality of temporary accommodation offered to homeless clients. This increase has in some cases resulted in a reduction in use of bed and breakfast accommodation. However there are a number of issues with regard to the provision of temporary accommodation as follows.

Length of stay in temporary accommodation as a result of low turnover generally and specifically within particular communities.

Rural, semi-rural and island councils in particular are experiencing increasing lengths of stay in temporary accommodation because of very low turnover in smaller villages and communities. One council highlighted that because of the lack of available permanent accommodation clients could spend up to 3 years in temporary accommodation.

Numbers of social housing have fallen in these communities and this has had a severe impact on councils ability to house people close to family networks. This difficulty also occurs in certain parts of other more urban councils where stock numbers are low. However the consequences for clients in urban areas are not as acute, as transport links are better and distances between communities are less making it possible to house a client in a neighbouring community and enable them to retain family links.

There were also instances where a low percentage of council and RSL allocations to homeless clients created increased lengths of stay in temporary accommodation.

Length of stay in temporary accommodation as a result of the mismatch in sizes of current stock with what is required by those on homeless lists.

The length of time spent in temporary accommodation is also increasing as a result of the mismatch in the size of accommodation which is required compared to that which is available. This mismatch reflects both ends of the scale. In some areas there is particular pressure on smaller properties, with length of time spent in temporary accommodation for a 2 apartment property in one council being 3 years while in others there is a lack of larger and adapted properties for bigger households and those with disabilities.

Impact on temporary accommodation as a result of the Suspension of Local Connection & methods employed to meet the 2009 target.

A number of homelessness teams stated that they would have preferred that a national decision had been made with all councils implementing the same changes to priority need categories to allow equality of assessment. This view was countered by others who felt that the current arrangement allowed councils the flexibility to take local circumstances into account.

There are concerns that councils will vary widely in how they extend priority need. This will result in inconsistencies across the country giving rise to the fear that homeless people will seek out those councils which are more attractive than others, particularly if local connection is suspended. There is general support for inter-council meetings to discuss this issue.

One council expressed the view that the suspension of local connection coupled with the 2009 target would not really make a difference as they are experiencing a significant influx of migrant workers at present which could in the future result in increased homeless applications.

Some expressed the view that the suspension of local connection will not have a significant impact on numbers presenting from outwith their area as they believe applicants generally want to be housed in the area that they are from and where their family and social networks are.

Others are also more relaxed in relation to the suspension from the view that there has always been a natural drift as people migrate to find employment or services and that as long as exporting councils assist with the long term resettlement of their clients they will be able to cope with this. They also believe that tenancies are more likely to be sustained if clients present in the places where they really want to live.

A particular council has the concern that as it has borders with 6 other councils people from adjoining areas will be attracted by the range of services it has to offer. These include services not mirrored in the neighbouring councils such as those addressing addiction and mental health. Should this happen the capacity of these services will be unreasonably stretched to the possible detriment of existing users.

There are strong concerns from some that the suspension of local connection on its own could have a significant impact. These councils are already experiencing in - migration as they are perceived to be attractive places to live because of their natural beauty. There are fears that the suspension of local connection could exacerbate this. These are smaller more pressured councils where even small increases in numbers can have a significant impact on the council's ability to accommodate all applicants housing and wider social needs eg education, health services etc.

There are concerns in relation to the suspension of local connection in circumstances where the council has a major hospital or prison serving a number of council areas within its boundary. In such cases they fear they would then become the council of choice for homeless presentations as this would be easier than using the referral process currently in place for other local councils.

There is also the possible issue of applicants making multiple homeless applications to different councils. How would councils know a client had made multiple applications and who would be principally responsible for assessing the application?

Councils were also seeking greater clarity as to how the local connection provision could be re-introduced, questioning what the process and timescale would be and what percentage increase (or other measurement) of applications would have to be evident when applying for re-introduction.

Approaching 2009.

During the visits a number of councils gave an indication as to how they would move to meet the 2009 target. Some suggested that they would extend definitions of vulnerability, although not all had come to a firm decision on how to do this. The most common approaches were around changing the upper and lower age ranges; access to children; medical factors; addiction issues; including looked after children; separating spouse, discharge from institution, and those linked in with Criminal Justice or Social Work.

Some suggested they would be more flexible in the interpretation of vulnerability allowing greater discretion by case officers.

Many had not come to a definite view at the time of the visit, with one council seeing little scope for increasing priority need as they are already extremely flexible. Others stated that because of circumstances particular to them they would not meet the target or it would be very difficult to achieve.

One council intended to pilot a total abolition of priority need in spring/summer 2007; however they felt that the suspension of local connection should be delayed to nearer 2012.

Two councils made the comment that the 2009 target is artificial and doesn't reflect actual needs of vulnerable people and as a result may in some circumstances make it more difficult to discharge duty to all current applicants including the more vulnerable.

Meeting the 2009 target coupled with the suspension of local connection will require additional units of temporary accommodation to cope with potential increases in presentations. In addition, if there is an increase in presentations, without an increase of permanent lets households will inevitably spend longer periods in temporary accommodation.

Ability to provide temporary accommodation up to 2012.

Councils noted that to meet the 2012 target the length of time spent in temporary accommodation would have to increase if other factors remain unchanged. One council forecast that length of time spent in temporary accommodation would have to increase by a factor of 6. As the length of time spent in temporary accommodation increases additional units of accommodation are required to meet the needs of those presenting. Most councils stated that the supply of temporary accommodation would have to increase significantly, with some indicating supply of temporary accommodation would have to double and in one case quadruple in order to meet 2012.

For some councils this increase in length of time and provision of temporary accommodation would be unsustainable in the longer term unless overall supply is increased.

Other councils stated that despite increasing their numbers of furnished temporary accommodation they still don't have enough to meet current demand and are increasingly having to use B&B accommodation. Some councils have had to revert to using B&B where they had previously managed to stop its use.

Temporary Accommodation provision by RSLs.

There were a number of comments that RSLs should be encouraged to provide greater numbers of temporary accommodation. Others however expressed the view that increasing RSL temporary accommodation would only reduce the availability of RSL stock for permanent housing. In general the provision of temporary accommodation by RSLs across Scotland was variable.

Provision of Temporary Accommodation in appropriate locations.

Councils expressed concern about their ability to provide temporary accommodation in appropriate locations close to a client's family and social networks as recommended by the Code of Guidance. This issue is particularly problematic within small/remote communities because of the lack of available housing and in locations where the majority of the councils own stock has been sold with limited PRS or RSL accommodation available.

Impact of tourist industry on rural/island councils ability to source private sector temporary leased accommodation and B&B accommodation.

Rural and island councils have far greater difficulties in securing leased accommodation from the private sector because of the pressure on supply caused by the tourist industry. As landlords have their own secure market there is little interest in working with the council. In addition rents in this sector tend to be high, in excess of £500 per week making it unaffordable to those on lower incomes. In some cases however lets can be available during the 6 month "winter period" or at best case for up to 1 year. This in turn creates a greater reliance on B&B accommodation because there are no alternatives.

Again because of the impact of the tourist industry in rural/island and some city councils it can also be difficult to source good quality B&B accommodation. B&B providers would rather accommodate tourists than homeless people. In the summer months it becomes almost impossible to source B&B within some council areas.

Difficulties in sourcing Temporary Accommodation/difficulties in complying with the Unsuitable Accommodation Order and effects of potential expansion of the order.

A number of councils have encountered difficulties in complying with the terms of the Unsuitable Accommodation Order as they are now at the stage that if homeless applications continue to rise temporary accommodation options other than B&B are limited.

These councils have expanded available units of temporary accommodation both by looking at the private sector and their own and RSL stock. However they are now at the stage whereby further use of their own or RSL stock would have a significant detrimental effect on the councils ability to permanently house applicants and the availability of Private Rented Sector stock is limited due to a number of factors. One council mentioned that it had to go back to using B&B in the last 18 months as a result of increased demand for temporary accommodation.

Councils have raised concerns about the difficulty in sourcing private rented accommodation as the accommodation is being taken up by migrant and incoming workers or tourism. In addition, in areas with a buoyant but small private rented sector, landlords are largely uninterested in working with councils to provide accommodation for homeless clients further forcing councils to rely on B&B.

It is therefore difficult in some cases to provide accommodation other than B&B. The resulting increasing use of B&B could lead to increased breaches of the order. In some cases the limited availability of B&B within their own area forces councils to place clients in B&B out of area. This will result in a breach if the order is extended to cover out of area placements for all applicants. Smaller councils also indicated that by the nature of their geographic size temporary accommodation options within their own boundaries are limited and they have no choice but to rely on out of area placements.

The point was also made that in some cases out of area placements might be in the better interest of the client. This can be because the standard of accommodation is better or that the accommodation is actually closer to family supports. In some cases transport links are better than that which would have been available from within the council's boundaries.

Concerns were raised by one council in particular on the use of B&B's in its area by other councils. It was stressed that before a placement is made the appropriate risk assessments need to be carried out and the council should be contacted prior to other councils placing clients in B&B accommodation in its area. The council stated that protocols had been agreed for this process but was disappointed that these were not always followed.

In respect of the proposed expansion of the order for shared accommodation for formerly looked after children and the removal of the exception for Women's Aid properties, it was argued that some models of good quality and well managed shared accommodation can be beneficial for these groups as the client can gain support and encouragement from their peers.

In relation to Women's Aid accommodation, a number of councils stated that properties used for this provision currently did not meet the standard. If the current exception is to be removed many councils may require additional time and will have to allocate considerable future funding for the replacement or adaptation of existing accommodation.

Private Sector Leasing Scheme Issues.

As a result of the overall pressure on councils to provide temporary accommodation a number have either started or are considering providing a private sector leasing scheme. However there is the need for further clarity on how such schemes operate and are financed.

One concern is the possible inflationary effect this could have on the PRS market making the market less affordable for all.

There is also the issue of the affordability of such schemes for both the client and the council. Rents and management charges tend to be high and those on low incomes may not be in a position to afford this, particularly in the event of finding, or sustaining, employment. In this respect it is important that rents are affordable and housing benefit caps are realistic to the local rents being charged.

Other questions relate to the financial operation of the scheme by councils. This is either via the Housing Revenue Account ( HRA) or General Fund, and whether the schemes are operated in house or are contracted out.

With regard to private sector leasing schemes used to provide alternative accommodation to unsatisfactory Bed and Breakfasts, the argument is made that these schemes should be classed as social housing rather than general private rented accommodation, for the purpose of housing benefit caps.

General Private Rented Sector benefits barriers.

It has been recognised that greater use must be made of the private sector's role in providing temporary accommodation. However there are a number of additional barriers to achieving this. One is the impact of the Single Room Rate on those under the age of 25. This restriction is particularly harsh on single pregnant women for whom the restriction is only removed after the child is born. Councils stated that they thought that single room rate should not apply to this client group.

There are issues with the current level of housing benefit caps in some councils as current rental charges significantly outstrip the maximum benefit which can be paid.

Councils are keen for PRS accommodation which is used as temporary accommodation to be affordable to both tenant and council which will allow councils to reduce dependency on bed and breakfast accommodation.

There are further concerns with the introduction of the new housing benefit regulations and the new local housing allowance due to be implemented in April 2008. The concerns are that the new flat rate for council areas will not reflect the difference in rents charged throughout a council area. This will in some cases make parts of council areas unaffordable to those on housing benefit.

There are also concerns that the practice of paying Housing Benefit direct to the tenant rather than the landlord could put more vulnerable clients at risk of eviction.

Negative attitudes of local community/elected member to new homeless temporary accommodation or projects.

In some areas councils find that there can be significant difficulties in providing temporary accommodation or supported accommodation projects within communities because of community/member hostility. In some cases this issue has not been helped by the practice in a few councils of concentrating temporary accommodation in certain locations, although this is not always done by choice but by where properties have become available.

One council in particular noted 300 objections to a Houses in Multiple Occupation application which would have provided 12 temporary accommodation places. Because of the objections the project did not go ahead. These objections occur as too often there is a readiness by communities to associate all homeless people as troublesome or threatening and having drug or alcohol issues.

Perceived inflexibilities in the Code of Guidance regarding length of time spent in Temporary Accommodation.

There are calls for greater flexibility in the Code of Guidance regarding the length of time households may have to stay in temporary accommodation and that this be reflected by Communities Scotland inspectors demonstrating greater appreciation of local circumstances. Councils made the point that in some cases longer periods could be better for some clients - such as those with more complex needs. This allows the client time to settle and for support to be provided.

It is also important that clients are only moved on to permanent tenancies at the point where support staff believe they are ready to make that move and not as a result of trying to meet a target timescale.

Comments were also made that too often housing services are driven by the regulation agenda, rather than the needs of service users. Currently there are tensions between certain management and policy targets which cause conflict across different services e.g. anti-social behaviour orders/exclusion orders & homelessness prevention agenda. There is a need to ensure that the priorities match up and the mutual interests of all service users are appropriately addressed.

Where supply is static increases of Temporary Accommodation can only be at the expense of available lets.

A number of councils were in the position of having to use B&B because of an insufficient supply of temporary accommodation. These councils had explored all other options but the only alternative would be to use their own or RSL stock as temporary accommodation. Councils were reluctant to do this as it would mean a reduction in the availability of stock for permanent accommodation. This has obvious implications in their duty to secure permanent accommodation for those assessed as homeless.

Pressure on resources as a result of B&B use, provision of furnished accommodation and staffing & other funding concerns.

A number of councils have raised concerns in respect of the pressure their general fund is under because of the cost of B&B provision. The majority of councils raised the cost of B&B provision as an issue with annual costs ranging from under £62,000 to over £2 million per year. A few councils did however note that as a result of sourcing additional alternative accommodation they had been able to reduce spend on B&B or restrict its use to crisis situations only.

Resources to increase the provision of temporary accommodation are stretched with costs currently drawing heavily on the General Fund, Housing Revenue Account ( HRA) and Homelessness Task Force ( HTF) funding. Furnishing costs can be high with some councils receiving only small amounts from the furnished tenancies grant. Support and management costs have also to be taken into account in the provision of temporary accommodation and as a result many councils are finding it increasingly difficult to provide furnished temporary accommodation at a reasonable cost to tenants both in work, on low incomes or on benefit.

Councils also mentioned the increase in costs as more staff have to be employed in an effort to meet additional duties as the legislation is rolled out. As councils move to 2012 greater numbers of temporary accommodation will be required. Clients will stay longer which will further increase pressure on accommodation budgets. As the provision of temporary accommodation is increased additional staff will be needed to manage properties and provide housing support.

For those councils who no longer have an HRA the funding of temporary accommodation is particularly difficult.

As they have no ring fenced income generation account to offset furnishing costs, all costs for B&B and furnishing temporary accommodation have to be met from the general fund. There is a squeeze on funding which will only become more acute as the legislation is implemented.

A number of Homelessness Teams expressed concern regarding future funding arrangements for homelessness services, particularly if ring fencing was to be removed. There is concern that funding for homelessness services may lose out to other demands on such as community care, services for the elderly etc.

Department of Work and Pensions/Benefits Issues when moving from Temporary to Permanent Accommodation.

A number of councils had raised concerns over the length of time DWP were taking to process Community Care Grant applications. In some cases this was taking up to 8 weeks. Other councils reported that the majority of applications were initially refused then granted if an appeal was submitted. There are also inconsistencies in the evidence required to support the application with some areas requiring more robust evidence e.g. proof of support package in place to evidence that the client had support needs and, in other cases, the tenancy agreement had to be signed before applications were accepted. These requirements and the length of time to process claims impacts on the client's ability to move from temporary to permanent accommodation within as short a time as possible.

Most councils also reported difficulties in obtaining discretionary housing benefit overlaps. Councils benefit teams are only awarding these in particular circumstances and generally not for homeless clients. These overlaps are beneficial to clients who can't move from temporary furnished accommodation to an unfurnished permanent property quickly simply because they have no furniture. In these circumstances benefit is often only paid on one property and as the client is unable to move in incurs rental charges for both their temporary and permanent accommodation. The client is then in arrears in their new property before they have even moved in. Some councils commented on their limited ability to get overlaps as the discretionary housing benefit budget was small.

What are Councils looking for?

• Code of Guidance strictures in relation to location and time spent in temporary accommodation. Councils would like the Code of Guidance to reflect a greater appreciation of local circumstances which may restrict their abilities to site temporary accommodation in certain areas. Also a lack of stock combined with low turnover of vacancies can result in households staying longer in temporary accommodation. It can also be the case that, for some categories of homeless people - requiring greater preparation for independent living - longer periods in temporary accommodation can be beneficial. If the Code was more flexible, Regulation and Inspection would have more discretion in judging councils performance in this area of provision.

At the moment many councils feel that in interpreting the Code as it stands currently, inspectors do not reflect an appreciation of the practical difficulties councils can face in moving people on from temporary accommodation.

• 2009 Priority Need target/suspension of Local Connection. While some Councils stated that discussion and consideration should be given to the possibility of replacing the percentage targets with a national agreement for the extension of priority need, others were more in favour of coming together where possible on a regional basis to agree common extensions to priority need which would allow each to meet their 2009 target. The ability to achieve agreement will depend on differences in percentage distance to travel between councils. If this difference is significant then this may not be possible.
• Recognition that some councils will be more attractive to present to than others given the services which they provide or the nature of the council itself. In this respect councils want clear guidance on the process of applying for local connection to be reinstated and that all circumstances should be looked at, not just housing provision e.g. impact on health or education services.
• Councils are also looking for clear guidance on the approach to be taken when addressing issues of multiple applications to different councils. There is also the question of how councils will know if an applicant has made multiple applications.
• Recognition by Government and Regulation and Inspection that if other factors such as supply and prevention remain unchanged additional units of temporary accommodation will have to be found to meet the 2009 and 2012 targets. In some circumstances the only options available will be increased B&B usage with its associated higher costs.
• Temporary Accommodation provision in rural/remote areas and role of RSLs. Councils are looking for recognition of the difficulties faced in attempting to source temporary accommodation in areas where tourism has a significant impact. Local councils can't compete with the tourist industry in securing private rented accommodation and in some cases B&B. Councils in these situations would wish that the Government look at this issue in conjunction with them and attempt to try to find a solution or alternative options.
• Good practice guidance in engaging with private sector landlords. How to encourage private landlords particularly in pressured areas to assist councils with the provision of housing for use as temporary accommodation.
• Discussions with SFHA and RSLs on the varied provision of RSL tenancies as temporary accommodation. Councils want greater assistance where possible from RSLs in providing accommodation for temporary use.
• Unsuitable Accommodation Order. Councils wish to continue to be allowed the flexibility to place clients in B&B accommodation outside the councils area. The determining factor will generally be ensuring that this is in the best interest of the client. Councils will require additional time and will have to earmark future funding for the re- furbishment or reprovisioning of Women's Aid Hostels if the current exception for this type of accommodation is to be removed.
• Private Leasing Schemes. Councils would like to have legal clarification on whether it is permissible to operate these schemes from within the HRA. If it is not permissible councils would wish to ensure that they have discussions with the DWP on housing benefit regulations for the provision of temporary accommodation. Discussions around levels of housing benefit caps and the level of the cap for their area would also be welcome.
• PRS Barriers. Councils are looking for discussion/lobbying of DWP to ease single Room rate restrictions particularly for single pregnant women under the age of 25.
• Councils homeless teams need to ensure that housing benefit teams are using discretionary housing payments in the most effective way as possible to prevent homelessness and assist clients to settle into permanent accommodation. Councils need their benefit teams to be more receptive in relation to applications for housing benefit overlaps. In councils where the discretionary housing benefit budget is tight the option to lobby for an increase in the budget needs to be looked into.
• Discussion required on the introduction of the Local Housing Allowance and the possibility of paying the allowance to the landlord rather than the tenant in some circumstances.
• Community opposition to Temporary Accommodation projects. A number of Homelessness Teams would welcome greater support, particularly from councillors, MSPs and MPs, when consulting with the local community on the development of new temporary accommodation projects. The need for additional temporary accommodation is great and councils need to be in a position to provide this in the most appropriate locations. Local communities sometimes need to be persuaded that homeless people are not by definition addicts or trouble makers.
• Pressure on council budgets. As councils move towards the 2012 target greater resources will have to be spent on assisting homeless people in providing accommodation and support. Councils would wish that the increase in resources required should be taken into account when future spending review decisions are taken.
• In anticipation that budgets will no longer be ring fenced homelessness teams expressed concerns regarding the implications for this in securing longer term funding for homeless services.

2. Temporary Accommodation Issues

Actions currently underway

The Scottish Government should come to a decision on the extensions to the unsuitable accommodation order and inform councils accordingly.

In coming to its decision, the Government should take account of (a) the views expressed that the flexibility to place out of area should be retained on the basis of agreed arrangements being in place between the councils concerned to do so and (b) councils support for the removal of the exception for Women's Aid refuges. The Government's decision should include a realistic timescale to implement (b).

The Scottish Government will publish the good practice guidance on temporary accommodation which is currently being prepared. The guidance should include practice examples of working with private landlords and information on how to effectively engage with the private sector.

The Scottish Government has initiated discussions with the UK Government regarding the current impact of reserved benefit issues on Scotland's social reform agenda, including bureaucratic barriers to affordable rented housing. ALACHO, COSLA and the Scottish Government should seek clarification from the Department of Work and Pensions on the housing benefit regulations in relation to private leasing schemes for the provision of temporary accommodation and the circumstances (if any) in which benefit thresholds and caps don't apply. Homelessness Monitoring Group ( HMG) and COSLA should continue to feed into the on going DWP consultation on housing benefit for the private sector to ensure that future caps and thresholds and the local housing allowance allow this sector to be affordable to those on low incomes. In addition adequate safeguards are needed to ensure that those who are vulnerable are still able to have housing benefit paid directly to their landlord.

Suggested Actions in recommended order of priority

4. Given the pressure on councils own stock it is extremely important that ALACHO, COSLA and the Scottish Government should discuss with RSLs and the SFHA the varying provision of temporary accommodation throughout Scotland.

5. Problems of supply and access to temporary accommodation are particularly acute in rural and island communities. Therefore ALACHO, COSLA and the Scottish Government should look at ways to assist such councils to compete with the likes of the tourist industry in securing the provision of temporary accommodation from the private sector and bed and breakfast where necessary. This should include consideration of (a) the need for private landlord incentive schemes to attract landlords; and (b) whether a forum should be set up to allow discussion between the councils concerned. The purpose of the forum would be to share innovative approaches in sourcing both temporary and bed and breakfast accommodation and to produce a good practice guide in engaging with private landlords. CRISIS could assist with the good practice guide as they have experience in attracting landlords to rent deposit schemes.

6. Community resistance is another factor which many councils have to deal with. ALACHO and COSLA should continue to work with elected members to ensure that they see the homelessness agenda as a priority for their council. They should consider organising local or national events to get the message across, possibly involving SCSH as they have previously provided induction training for councillors. Some councils themselves may already have developed induction/awareness raising packs for elected members. The Scottish Government should disseminate the results of the Scottish Social Attitudes survey and ALACHO, COSLA and the Scottish Government should discuss how to take forward the awareness raising agenda with the general public.

7. The Scottish Government should adjust the Code of Guidance on Homelessness to make it clearer that in some cases longer stays in temporary accommodation can be in the best interests of some clients. Regulation & Inspection would then be able to take these factors into account during inspections.

8. With regard to the 2009 target and the increase in pressure on temporary accommodation as a result, COSLA should encourage and ALACHO should facilitate regional meetings for councils who may wish to explore common methods of extending priority need categories. As all councils have different distances to travel to meet their 2009 target those facing the greatest challenges need to know what their options are.9. In order for councils to access and use temporary accommodation effectively ALACHO, SCSH and Shelter should separately lobby DWP for an ease in the Single Room Rate regulations particularly where it applies to single pregnant women under the age of 25.

10. It is for councils themselves to determine how best to use discretionary housing payments. ALACHO, Directors of Finance and COSLA should raise the awareness of the availability of discretionary housing payments as an additional resource to prevent homelessness and assist homeless clients when moving from temporary to permanent accommodation.11. ALACHO should consider providing guidance and assistance if required to homeless teams to assist them in the bidding process to secure long term homelessness funding, from their councils allocation of funding from the spending review.

12. The Scottish Government should issue clear guidance on the handling of multiple applications to councils if local connection is suspended. The guidance should clarify which council will have the duty to make the assessment. The Scottish Government should also issue guidance to councils on the grounds for applying for reinstatement of local connection.

3. Allocations to Homeless Households

General:

The main issue around allocations is determining what level of lettings should go to homelessness applicants rather than other categories of need on the council list. There are concerns about interpreting "reasonable preference" as stated in the Housing (Scotland) Act 1987; maintaining "Balanced communities"; responding to community frustration regarding too many houses being perceived to go to homeless people at the expense of those equally, or "more deserving", on the waiting list; political sensitivity and the need to challenge negative attitudes towards homeless people in general.

There is also the expectation that other social landlords take their share of homeless households and whether this is best achieved through established nominations systems or by the use of Section 5 Protocols. In the current context of the shortage of suitable rented accommodation greater use should be made of the private rented sector in meeting the needs of homeless people.

Issues:

• Proportion of lets to homeless applicants.
• Maintaining "balanced Communities".
• Complying with Code of Guidance requirements.
• Addressing negative attitudes to homeless people.
• The role of other housing providers.
• Stock Transfer implications.

Lets to Homeless People.

Over the period of visits councils were allocating from 18 - 80% (average 32%) of their vacancies to homeless people. A number believe that in order to achieve the 2012 target they will eventually be giving upwards of 80% or more of their stock to homeless applicants at the expense of others on their waiting lists. A few expressed the view that the legislation gave homeless people an (unfair) advantage over other applicants in that the former were able to realise their housing aspirations, rather than just their needs, by sitting tight in temporary accommodation until they were offered the housing they wanted in the areas of their choice.

While councils were aware of the guidance on "reasonable preference", the pressure is generally to give more lets to homeless, not only as a consequence of the legislation but by the need to free up temporary accommodation for the increasing numbers of homeless applicants approaching for assistance. Generally it was felt across the country that as more houses are seen to go to homeless people, more people will be tempted to use the homelessness route adding further to the pressure on both temporary and permanent lettings, as well as assessment and support services.

Balanced Communities.

Social landlords, through guidance or by inspection regimes, are exhorted to use their allocation policies to create or maintain "balanced communities". There is a fair degree of scepticism around this concept and it is open to a variety of interpretations, but the majority of providers feel that giving more and more housing to a single category of applicant is not the best way to achieve this objective.

The biggest increase in homeless applications is from single people, whose general behaviour and life style can vary considerably from other households and might, where concentrated in larger numbers, give rise to tensions and conflict with neighbours. A growing proportion of homeless people in this group are also reported to have other issues such as drug and alcohol or mental health problems which need to be taken into consideration on how allocations are made. This does not necessarily imply that homeless people are any more problematic than any other group within the community.

Negative Attitudes.

As reported earlier and despite the lack of substantive evidence, there is generally a negative attitude towards homeless people by the wider population. This can also be represented amongst staff in housing agencies and at the political level of councillors, Housing Association Boards, MPs and MSPs. Councillors in particular can be pressured by constituents frustrated at long waiting times for housing and the perception of queue - jumping by people considered "less deserving".

Many homelessness teams remarked on the unwillingness of some councillors to drive forward the homelessness agenda. This might accompany a tendency to understate the local factors contributing to homelessness and present the problem in terms of outsiders adding pressure on housing waiting lists. In rural or island councils the extent of homelessness can be less visible and where it does manifest itself be more associated with more personal rather than structural causes. This demonstrated, in certain areas, a lack of understanding or resistance to accept the local dimensions of homelessness and therefore the need to take responsibility for dealing with the issue. In at least two stock transfer areas, a number of councillors had assumed that the responsibility for homelessness now lay with the new landlord and was no longer a council concern, resulting in the service being denied the level of resources required to provide an adequate response.

Code of Guidance.

Turnover of properties in all areas is low relative to the demand for housing. The housing which becomes available more regularly tends to be in less popular areas where many people don't want to live. In many localities there are high incidences of refusals, particularly on first offers, and the majority of appeals relate to rejected offers of accommodation. In many cases it can be difficult to comply with Code of Guidance recommendations to house homeless people close to family or social networks if turnover in these areas is low. The alternative is longer periods in temporary accommodation or B&B, blocking spaces for new applicants and prolonging the period people are homeless and in the system as live cases.

In many councils, more particularly rural and island there are areas which have no council housing at all, making it all the more difficult to meet people's needs. If compelled by circumstances to accept housing in areas they don't want then the chances of repeat homelessness occurring are all the greater.

A number of councils still do not grant homeless people the level of choice available to mainstream applicants in terms of the number of offers of accommodation. Their justification for this is the degree of pressure to get people through the system and minimise time in temporary accommodation or B&Bs. This can be counter-productive where people choose to appeal or if further homelessness arises. Councils may be criticised for this if inspected, but they will also be criticised if households spend extended periods in temporary accommodation or the time to close cases is too long.

In areas which operate Choice Based Lettings, homeless applicants are expected to be "realistic" with regard to their bids for housing by concentrating on areas where the levels of competing bids will be lower. In most choice based systems homeless people are likely to be awarded the highest priority along with that of top medical cases. It is important that where Choice Based systems are in place the necessary guidance and support is provided to assist people make the best use of their bids to secure the housing that most closely meets their needs.

Role of other providers.

In a context of short supply and high demand the more providers of affordable rented housing the better. Councils are not expected to meet the needs of their homeless populations on their own and are required within their homelessness strategies to demonstrate effective and genuine partnerships with other agencies in meeting both the support and accommodation needs of homeless households. The other key players are RSLs and, increasingly, the private rented sector.

Registered Social Landlords ( RSLs):RSLs are publicly subsidised social landlords and it is appropriate that they share with councils the responsibility to address homelessness. On the other hand they are independent organisations run by their own management boards with a great deal of discretion in determining their own policies and objectives, albeit within a national framework of regulation subject to inspection by Communities Scotland.

Where stock transfer has occurred RSLs will be the only providers of social housing and in certain areas where only one RSL operates it constitutes the single provider of such housing. In the stock transfer context, councils retain the strategic responsibility for addressing homelessness and in most cases also provide the homelessness service in terms of assessing need, co-ordinating support and access to other related services, but are totally dependent on RSLs to provide the housing, including sufficient temporary accommodation. In terms of allocations, Section 5 of The Housing (Scotland) Act 2001, provides the principal legal mechanism by which councils can request that RSLs provide secure tenancies to unintentionally homeless households, in priority need, the grounds for non compliance being legally defined.

There is a general feeling amongst councils throughout Scotland that RSLs need to be more involved in tackling homelessness, not only in allocating more houses and providing more temporary or supported accommodation but also developing a more strategic/preventative approach to housing management and tenancy sustainment as well as a wider role in housing advice. Even where there are good joint working relations, councils are of the opinion that RSLs should be inspected more robustly on their contribution to tackling homelessness and should have an explicit legislative responsibility for doing so.

Section 5 referrals are used inconsistently across councils and, excluding stock transfer councils, nowhere are they used exclusively when it comes to accessing accommodation for homeless households. Nominations continue to be used in conjunction with section 5 referrals as the means for securing RSL lets to homeless people, with variable results.

In many situations where Section 5s are used they are preceded by informal discussions to test out whether the Association is likely to accept the referral. Most protocols use the "void led" rather than the "person led" model.

This is often regarded as the most practical approach on the basis that there is
little point making a referral for which no accommodation is likely to become available in the 6 weeks time stipulated in the guidance published on good reason for non-compliance.

Many councils feel they have little control over the process, with limited opportunity to effectively monitor the RSLs responses to referrals in terms of what properties are actually available at the time referrals are made. There are administrative issues as well, particularly around whether the council makes multiple referrals of the same individual households to all the RSLs at the same time or one by one.

In general terms there seems to be a reluctance to use Section 5 as the sole mechanism for referring homeless applicants to Associations. This is partly explained by it being seen as a bit heavy handed, carrying as it does an element of compulsion backed up by formal arbitration. For their part, RSLs are commonly perceived by councils to regard it as something which threatens their autonomy to decide who they house in their own accommodation.

As the pressure increases to house greater proportions of homeless applicants, more RSLs are expressing their unease at the numbers that are coming their way in terms of the impact on maintaining balanced communities and the likelihood of evoking a negative response from existing tenants. Boards of management can exhibit the same degree of misunderstanding of homelessness and negative attitudes towards homeless people as can be found in the wider community.

Private Rented Sector: In many areas of the country councils are looking to establish closer ties with the private rented sector. In general there is greater knowledge of the sector as a result of registration or through efforts to find temporary accommodation for homeless families. Many councils have rent deposit guarantee schemes which have facilitated greater contact and awareness and in many areas the private sector is demonstrating an increasing willingness to work with councils in meeting the needs of homeless people.

A few councils have established Private Landlord Forums and voluntary landlord accreditation schemes or even have dedicated teams to provide assistance and advice to landlords in tenancy matters and legislation.

Following on from Edinburgh's apparent success and despite uncertainties about how these should be funded, there is a growing interest in investigating Private Leasing Schemes mainly in regard to temporary accommodation. Households can stay in such schemes for considerable periods of time begging the question of what constitutes "permanent" accommodation. The restraints imposed by current Housing Benefit Regulations, along with higher rents, and expensive management fees, create employability and affordability issues which lock tenants into "poverty trap" situations for the duration of their stay.

Councils would like to see more flexibility generally to use the sector to discharge duty for certain groups of homeless people, those with less support needs or who are not necessarily looking for the security of social renting. Private renting has certain advantages over other sectors in terms of its location as well as the flexibility and choice it can offer.

What are councils are looking for?

• Maintaining "Balanced Communities". There appears to be a degree of confusion around the term 'balanced communities' in terms of what it means. It comes up most in discussions about homeless people in relation to everyone else as if homeless people were a homogenous group whose needs are greatly different from anyone else's or that certain characteristics apply to homeless people that don't apply to anyone else. Homeless people have their share of other "issues", but so do the wider non-homeless groups and there is no substantial evidence to indicate that homeless people are more likely to be problematic tenants than anyone else. If this is a term which is to be used as an expression of policy and practice there is a need for a more rigorous definition and application.
• Reasonable Preference. The allocation of social housing is predominantly about meeting housing "need". It can be argued that people who are homeless are by definition those most in need so, should have highest priority in the allocations policy. In practice however the needs of other households cannot be ignored for fear of creating negative community reactions or more applicants feeling compelled to pursue the homelessness route for themselves. The pressure, because of the legislation or the need to free up temporary accommodation, is to increase lets to homeless people giving rise to the very consequences which councils are seeking to avoid. Councils are therefore seeking greater clarification on the term and how best to implement it.
• Code of Guidance compliance. Several councils expressed the view that more often than not it is difficult to find housing which meets all the needs of homeless people as contained within the Code of Guidance and some saw this as a requirement to meet the aspirations of homeless people rather than their needs. In this view homeless applicants were enjoying greater advantages, or being accorded more "rights", than others on the waiting list. This is not to say they didn't agree with the principles involved and the obvious advantages of being able to provide housing within people's areas of choice, close to social networks, schools etc but that it was difficult to achieve in practice for all applicants. In the case of homelessness applicants, under what circumstances is it reasonable to argue discharge of duty when not all the criteria had been met but the council was doing the best it can in the given situation of supply and turnover? Inspectors were often seen to be inflexible in this area, appearing not to make allowances for the specifically local difficulties faced. The same was said of lobbying and advocacy agencies such as Shelter, who might encourage households to appeal and "hold out" for a better offer. The question was what degree of flexibility could be allowed for in achieving a balance between these competing pressures on the service? Councils are seeking a review of the Code of Guidance as it relates to allocations to homeless households.
• Role of other providers. There is a very strong feeling that councils will not meet the 2012 target on their own, that more needs to be done by other housing providers to assist councils in their aims.
• RSLs. As the only other providers of social housing RSL's have a particularly important role but don't have the same legislative pressure as councils to meet the needs of homeless people. It was suggested that in some areas RSLs are able to resist housing increasing numbers of homeless people as a result of the perceived lack of accountability in the way they allocate their stock. In order to encourage more RSLs to take their responsibility for homelessness more seriously, inspection should concentrate more on how RSLs address homelessness, not only in terms of lettings and the provision of temporary accommodation, but in their endorsement of wider policy objectives such as prevention, resettlement and longer term solutions.

Section 5 needs to be reviewed in terms of how it is used and its effectiveness. In particular councils are looking for greater transparency from RSLs in relation to stock availability and turnover in order to make appropriate referrals rather than the current practice of referring without having any knowledge of whether a property will be available within a reasonable period. The stock transfer context also requires further scrutiny, the feeling being that in most cases the homelessness function was not given the consideration it needed prior to transfer and that it is difficult to remedy this after the event.

• Private Rented Sector. Councils are looking for more flexibility and guidance on establishing closer working relationships. Existing legislation needs to be reviewed to make the sector more accessible while finding ways to protect the interests of more vulnerable groups/people as private sector tenants. The affordability of private rented accommodation is of concern with rents charged in this sector increasing year on year. In order to make best use of this type of accommodation it needs to be affordable to those on low incomes and those on benefits. Councils want to ensure that housing benefit caps and thresholds are sufficient to keep pace with the increasing rents in the private sector to allow this sector to remain affordable for all. There are various models of working with the private sector, as in England and Ireland, which are worth more detailed consideration. There is a need to explore alternative approaches and for information to be disseminated more widely which can be coordinated by the Scottish Government or other appropriate agencies, e.g. CiH in Scotland, COSLA.
• Negative attitudes towards homeless people. Negative attitudes towards homeless people are widespread and exist at all levels within the community, including housing staff ( RSLs and councils), councillors and RSL Boards. These views need to be challenged and demonstrated to be unjustified. It is likely to be the case that a higher proportion of people with problematic issues might be found within the homeless population but this does not translate into them being any more anti-social or troublesome than any other section of society. This distorted picture stems from a stereotypical image of who the homeless are along with a general misunderstanding of what causes people to become homeless in the first place. It is further fuelled by the publics perception that homeless people get unfair, "undeserved" access to social housing. There is also the view in many areas that homelessness is an imported problem - particularly the case in many smaller or rural councils where local homelessness tends to be less visible.

There is a need to spread awareness about the real nature and causes of homelessness within communities as a whole but particularly community leaders and people in a position to better lead public opinion - Councillors, RSL Boards; tenants groups; community councils; local press and media. There is perhaps a case for specific research into the links between ex-homeless people and subsequent tenancy problems or for housing agencies to monitor this situation for themselves.

• Bureaucratic barriers to allocations. While it is understood Benefits Legislation and Regulations are reserved matters there is a serious need to examine the extent to which some of these contribute to homelessness or prevent effective steps to tackle homelessness in some cases. The Single Room Rent applied to young people up to 25 is a case in point. There also needs to be consistency in the way regulations are interpreted and applied - the use of Discretionary Housing Benefit; applications and criteria for Community Care Grants - across the country.

3. Allocations to Homeless Households

Actions currently underway

Firm Foundations sets out the Scottish Government's future housing policy including the role of RSLs and the Private Rented Sector in addressing housing need. The Scottish Government, together with COSLA and SFHA, should take the opportunity provided by Firm Foundations to review past and current practice of these sectors in meeting the needs of all households seeking safe and secure accommodation.

The Scottish Government will take councils concerns around the operation of
section 5 of the Housing (Scotland) Act 2001 into consideration in the review of section 5 recently initiated by the Scottish Government Homelessness Division, particularly regarding accountability and transparency of the process.

Suggested Actions in recommended order of priority

13. In the interests of clarity it is very important that the Scottish Government, SFHA and CiH (Scotland) lead a national debate or discussion on how the terms reasonable preference and balanced communities are interpreted and implemented strategically. This debate requires to consider the findings of recent Scottish Government commissioned research on allocations with particular regard to those terms. They cause particular confusion in that they lack precision and are difficult to implement in practice. Issues include how to balance the needs of different reasonable preference groups - A legal requirement which dates from 1966 and has only been subject to limited amendment since; and the criteria by which balance in balanced communities can be defined.

It would be helpful to have a much clearer understanding of the objectives of public policy on allocations, including what particular terms mean - and whether they apply to all communities.

14. If 2012 is to be achieved SFHA must encourage RSLs to take a greater role in addressing the needs of homeless households in terms of their contribution to the prevention of homelessness; allocations of housing; provision of temporary accommodation; tenancy sustainment (e.g. Glasgow Housing Association's model); and the provision of housing advice and information. The regulator should continue to focus on these issues when inspecting RSLs.

15. Councils welcome the emphasis placed by the regulator on outcomes for homeless people & consultations should take place with key stakeholders on the nature, aims and objectives of the new regulatory service and the criteria which will apply when inspecting housing and homelessness services for both councils and RSLs.

16. In the longer term interest of successfully re settling homeless people into the community the Scottish Government and Local Government must be more pro-active and positive in promoting the homelessness agenda and lead in challenging negative attitudes and prejudice towards homeless people.

See Actions 9 & 10: points which apply to Temporary Accommodation are also relevant to allocations.

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