2020 Housing Strategy Consultation Feedback

18th August 2020

Re. Draft Housing Strategy Consultation

Dear Bedford Borough Council,

Please accept the following points for the Draft Housing Strategy Consultation.

1. 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 previous one.
2. 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.
3. 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.
   1. 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 hostel system.
   1. 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
   1. 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 neighbouring districts.

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 information

Yours faithfully,