Where are the gaps in the homelessness strategy?

The three headline targets for national accountability in A National Plan to End Homelessness are to increase the proportion of people for whom homelessness is prevented, end the unlawful use of bed and breakfasts (B&Bs) for families and halve the number of people sleeping rough long term. All are to be achieved in this parliament.

There are also targets to reduce homelessness after discharge from prisons, care and hospital, even if the commitment to help refugees and migrants seems weaker.

Just as important – and key to implementation – will be local accountability, which will come via a new outcomes framework for setting out the national priorities that central government will work with local authorities to deliver.

Implementation relies on funding and, though the strategy highlights £3.5bn of investment in homelessness and rough sleeping services over the next three years, most of that was already announced in the Spending Review.

The strategy will also be reliant on changes in the wider housing system, and here the government has a good story to tell on the Renters’ Rights Act, the scrapping of the two-child limit, potential application of Awaab’s Law and the Decent Homes Standard to temporary accommodation and the “generational” (if still inadequate) increase in social and affordable housing investment.

“Key to implementation will be local accountability, which will come via a new outcomes framework for setting out the national priorities that central government will work with local authorities to deliver”

So far, so good, but what about those gaps?

The first, and most gaping, is the continuing freeze in Local Housing Allowance (LHA) rates confirmed in the Budget. With rents already 20% higher than LHA rates, this is a guaranteed mechanism for homelessness generation rather than prevention.

The strategy argues weakly that: “We recognise some private renters need support with their rent. That is why we will work across government to keep Local Housing Allowance rates under review in order to deliver on the government’s priorities, including maintaining the long-term fiscal sustainability of the welfare system. In the short term, in 2025-26, those who need additional support with their housing costs can approach their council and apply for Discretionary Housing Payments.”

This paragraph could have been cut and pasted from any of the Conservative justifications of their cuts and freezes over the last 15 years. Labour ministers know the problems they caused, and now are perpetuating those same problems.

There is a recognition of the soaring costs of temporary accommodation to councils including “significant spend through Legacy Housing Benefit, with systems and funding approaches that have not been updated in years”. However, it remains to be seen whether this means lifting the subsidy cap of 90% of LHA rates from 2011.

Other gaps identified in responses from housing and homelessness organisations include lack of commitment to a national expansion of Housing First and lack of a general target to reduce the 380,000 people and 172,000 children stuck in temporary accommodation.

In his introduction, housing secretary Steve Reed said that the last Labour government made a choice: “They were determined to end homelessness and rough sleeping. We saw that, where there was a desire from across government to bring down temporary accommodation numbers and get people off the street and out of shop door fronts, there was a way. Families living in temporary accommodation halved and rough sleeping was cut by two-thirds.”

Maybe, hopefully, this government can achieve the same, but it is starting with more modest targets, applying to families with children in B&Bs for longer than six weeks and ‘long-term’ rough sleepers (those seen recently who have also been seen in at least three separate months over the past year).

“The plans for England are clearly influenced by changes already introduced or about to be introduced in Scotland and Wales”

The strategy does promise more funding for local authorities to procure temporary accommodation and to explore “options for partnering with social impact and institutional investors to use private finance and support from the National Housing Bank”. The government will also consider regulation of the cost of nightly accommodation (15 times higher than in 2010, and also up 30% under Labour).

Which is fine, but does creating a higher-quality, but semi-permanent, temporary sector really amount to a strategy?

The plans for England are clearly influenced by changes already introduced or about to be in Scotland and Wales, such as proposed legal duties on public services to “identify, act and collaborate” to prevent and address homelessness. Ahead of publication, Crisis highlighted the fact that English housing associations allocate only 27% of their lettings to homeless households compared to 54% in Scotland.

The strategy talks about considering “levers to require social housing landlords to rehouse statutory homeless households referred by the council, including legislating if necessary”. This is similar to changes introduced in Scotland as far back as 2001.

In Wales, legislation currently going through the Senedd includes a new duty on associations to house someone referred by a local authority. As part of the rent settlement, Welsh associations have also committed not to evict into homelessness tenants in financial hardship.

The same Welsh legislation would also end priority need and intentionality tests (already abolished and reformed in Scotland), which can shut people out from the support they need.

In the English strategy, priority need seems to be taken as read and the only mention of intentionality is an exemption for care leavers who are in scope of the corporate parenting duty.

Changes to the legislation clearly have to find the right balance between ambition and implementation. Focus too much on the first and you risk not achieving the second, as under-resourced local authorities struggle to cope.

But focus too much on the second and you risk falling short with the first, and clouding that long-term vision.

Jules Birch, columnist, Inside Housing