18th August 2020
Re. Draft Housing Strategy Consultation
Dear Bedford Borough Council,
Please accept the following points for the Draft Housing Strategy
- The Draft Housing Strategy notes on
page 9 that the target in the previous strategy of 2910 completed homes between
2016-19 was surpassed by more than 1000. There is, however, still an obvious
shortage of homes in Bedford Borough so it appears that the previous target was
nowhere near ambitious enough to meet the needs of the Borough. We therefore
feel that this Housing Strategy should be significantly more ambitious than the
- The Draft Housing Strategy relates
specifically to people who are, or who have recently been homeless. People who
have lost their home experience incredibly difficult circumstances which mean
that providing feedback for this consultation is unrealistic in most cases.
More effort should have been spent to make the feedback process more accessible
and it is simply not enough to say that they could provide feedback on the
website like everyone else. To miss this feedback means that their voice and
wisdom is lost - they, rather than professionals working in the sector, are
most certainly the experts when it comes to the reality of homelessness.
- The Draft Strategy notes a number
of factors that are likely to affect the need for more housing in the Borough.
The effect of various legal cases in recent years, however, is not picked up
on, nor is the likely effect of the Domestic Abuse Bill which will hopefully
soon be enacted that will automatically confer priority need on those
experiencing domestic abuse. The figures cited in the debates around the Bill
would suggest a large number of people who were previously found not in
priority need will be now (assuming gatekeeping were to be eliminated). In
addition, the following cases will most probably result in the Council having a
duty to house hundreds more people every year than it currently does, and will
therefore need hundreds more temporary accommodation units available, not to
mention hundreds more homes as well.
- Thomas v Lambeth in effect lowers
further the threshold for someone being in priority need as a result of
vulnerability. In effect, many people who were not in priority need before this
case will be in priority need now, including, by definition, many, if not most
of the people living in homelessness hostels in the Borough and everyone who
sleeps rough. Hostels, which have historically been used to house those
regarded as not in priority need, will be rendered increasingly obsolete,
whilst the Council continues to spend millions of pounds every year on the
- Lomax v Gosport confirmed that if
someone’s disability is made significantly worse by their current housing
circumstances, they will be legally homeless and therefore owed various housing
duties by the Council
- Samuels v Birmingham confirmed
that, roughly speaking, anyone who has to top up their housing costs from their
living costs of UC will be legally homeless. If UC allowances return to their
pre-Covid-19 level thousands of people will become homeless.
It should be
possible to analyse in details the available information to estimate how many
people these changes will affect in the Borough every year so provision can
match the need.
- It seems that there is a severe
shortage of accessible housing in the Borough, meaning that people living with
disabilities have to wait longer on the Housing Register than households of the
same size without any disabilities. The Equality Act places a pre-emptive duty
on councils to ensure that there is enough accessible housing for everyone who
needs it so that no one is worse off because of their disability in terms of
waiting times (and probably choice of different properties). Analysis of the
Housing Register should be undertaken to compare average waiting times of
households of different sizes with disabilities against those without, and the
number of accessible homes that are needed should be built.
- One of the likely effects of
coronavirus is that many offices in the Borough will become empty as companies
downsize and more people work from home. It is likely there will be many
opportunities to create (decent) quality homes from this unused office space
and the planning application process should be streamlined so this can take
place quickly. There may also be opportunities for the Council itself to
purchase such properties for conversion for its own temporary accommodation and
supported accommodation of some kind.
- The changes in Homelessness Law
and overwhelming evidence that the Housing First model is by far the best and
cheapest way to deal with homelessness compared to the existing ‘staircase
model’ hostel system means that a review of the cost-effectiveness of existing
hostels should be considered, particularly in terms of the quality of support
provided. Pursuing evidence-based homelessness provision will require sustained
political will as it will involve significant changes in the sector and some
organisations stand to lose a lot of income.
- Robust action needs to be taken to
respond to the issue of households accepted on the Housing Register being
subject to blanket exclusions by some housing associations in the Borough, e.g.
when rent arrears were accrued by the applicant when they were subject to
domestic abuse and are then used as an automatic reason to reject someone from
obtaining a new home. This follows a wider issue of the Council having given up
control of social housing in 1990. It should look to reverse this process so
that resources do not simply end up going to lucrative private companies like
it has been to providers of temporary accommodation.
- It is likely that the Strategy
cannot accurately predict the various effects of coronavirus and the resultant
downturn of the economy on homelessness over the next 5 years. Nonetheless
there should be contingencies built into the strategy to account for likely
scenarios caused by coronavirus, particularly in regard to people working in
vulnerable sectors who may be threatened with homelessness for the first time.
This will in part require more co-ordinated support of private landlords. We
therefore believe the Council should consider continuing to monitor the effects
of coronavirus and consider amending the strategy right up until it is
published next year.
- We were surprised that the Council
does not believe there are any rogue landlords operating in the Borough.
- More robust action needs to be
taken to respond to people coming from other areas to Bedford because of the
services available here. Reconnecting people appropriately to their home area
should be prioritised, particularly when they come here because they have been
gatekept by their home councils. This is particularly relevant to some
Finally, we would like to emphasise the fact that the primary
driver of homelessness in our Borough is in no way individual fault on the part
of the people who lose their homes, but rather the simple lack of housing in
the Borough and the resultant exorbitant rents.
Please do not hesitate to contact us if you require any further