Ms Karen Lucas

Head of Housing Needs

Housing Aid Centre

257 Upper Street

London

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24 October 2012

Dear Karen

Thank you for taking the time to meet with me earlier this week to discuss the consultation on changes to Islington’s Housing Allocation Scheme. The localism agenda provides an opportunity for Local Authorities to review the way they deal with housing need, and the obvious concern is that many Councils will use this opportunity to further restrict access to suitable affordable housing for those in need.

As you know, my own view has always been that there should be additional investment in increasing the supply of social rented housing in areas of high housing need -; this is a much more cost-effective approach than continuing to spend vast sums on temporary accommodation and on Housing Benefit for private tenants. I am also well aware that since the election of a Labour Council -; Islington Council is in full agreement with me on this.

I am very concerned that Welfare Reform and the redefinition of what is an “affordable” rent will only make things even worse for the poorest families, and the bedroom tax, direct payment of Housing Benefit to tenants and cuts in Council Tax Benefit will only make things worse for Councils which have already been hit by huge cuts.

As I’m sure other consultees have pointed out, the Housing Allocation Scheme Islington adopts will have to take into account these pressures, as well as taking into account existing housing need and projected changes in Islington’s population.

Choice and management

Islington must continue to provide a choice-based lettings system, and access to housing points should be clear and transparent. However, there are a number of situations where it is more effective for the Local Authority to manage allocations directly, and it will be essential that the balance is seen to be fair.

In my view, the Council should take an active role in helping existing tenants to move, both downsizers and those who are seeking mutual exchange. Where downsizers are concerned, I have already stated on a number of occasions that it should be possible to make simultaneous offers of two smaller flats to two adults currently occupying a larger property.

I was pleased to hear that 150 people who potentially face a reduction in Housing Benefit next year because they are underoccupiers attended an event, but I take your point that not all Islington residents understand how benefit reductions will affect them, and more work is needed to ensure that those who do wish to downsize are assisted to do so. I am concerned that many underoccupiers may not have thought through how they will cope with a Housing Benefit cut.

We discussed how many people would be affected -; at present, the reduction only applies to those of working age, so pensioner under-occupiers would need incentives outside of welfare reform to encourage them to move. I am enclosing a briefing from the National Housing Federation which sets out their view of who will be affected by the April 2013 and Universal Credit changes.

It appears that the April 2013 bedroom tax will only apply to those under State Pension Credit age, including mixed-age couples where one is under the State Pension Credit age -; but the rules for Universal Credit will be more restrictive for mixed-age couples.

I hope that it will be possible to work with potential downsizers to ensure that they are able to move to suitable smaller properties -; as you pointed out, freeing up larger properties for overcrowded households to move into provides a chance for other families to move.

Another concern which constituents have raised with me is the difficulties faced by a disabled person and his/her carer who wish to relinquish two smaller properties and move in together. Whilst I appreciate that larger properties are in short supply, it seems to me that there should be some discretion to help people in these circumstances.  

Homelessness, management and choice

The other point you have raised is a proposal to make a direct offer to single homeless people who you have placed in temporary accommodation. The Council’s duty to this group could presumably be discharged by making an offer of private sector accommodation, if you were to accept this power under the Localism Act.

Whilst I am not advocating that you compel vulnerable single homeless people to accept private sector accommodation, the suggestion that this group could all be managed into social rented accommodation needs to be carefully considered to ensure that the policy is fair and affordable.  

Your paper suggests that single homeless people with support needs find it difficult to use the choice-based lettings system, and therefore get stuck for long periods in temporary accommodation. However, so far as I know everyone in temporary accommodation -; single people and families – should be adequately accommodated, and if this is the case they presumably would not have sufficient points to be able to bid for social housing through choice-based lettings. 

It appears that you are not proposing direct offers to families with children or to pregnant women. As we discussed, many families who have been placed in temporary accommodation do not have sufficient housing points to be able to bid for social housing. Their only route out of temporary accommodation would therefore be private leased accommodation. You mentioned “lease-end points” -; I would like it to be clearer how we can be fair to these families.

It is important to reduce expenditure on temporary accommodation where possible, and it may be that the number of one bedroom and bedsit properties which are available to let would indicate that more assistance could be offered to single homeless people than to those requiring larger homes. Ideally, however, I would like to see the needs of homeless families given equal priority to those of single homeless people.

Points and priorities

I think it needs to be clear how overcrowding is assessed. Whilst I welcome the proposal that a parent with a child living in a bedsit should always qualify for points, regardless of the sex of parent or child, it seems to me that points should be awarded where a parent has to share a bedroom with a child over 10, regardless of the sex of the child or parent. Consideration should also be given to awarding points where any adult has to share a bedroom with a child.

We discussed medical and welfare points -; I think there is some room for changing the way we describe points allocated in these categories, to make it clearer that what is being assessed is the suitability of the current accommodation for the individual tenant, rather than that tenant’s general state of health or welfare. It should be possible to devise a system which gives sufficient priority for a move to those tenants who are at serious risk, whilst avoiding pointless repeated medical assessments.

If the term “welfare points” is retained, it would be helpful to have a clearer definition of when these points might be awarded. It should also be clear whether additional points are time limited, so that those with a large number of points are encouraged to take an active part in the bidding process.

The other issue we discussed was encouraging those applicants with disabilities to bid for properties which are suitable for them. Whilst it would be useful to adopt the London accessible housing framework system of assessing properties, disabled applicants will need to have clear guidance on whether they will be prioritised for particular properties.

I have no problem with the proposal to amend the way applicants qualify for residence points to include only current residents who have lived in the borough for three out of the last five years -; although I would once again be concerned about the position of those placed in out-of-borough temporary accommodation. In my view, everyone who qualifies for residence points should remain on the waiting list.

Where the New Generation Scheme is concerned, I support the proposal to widen the scheme to the children of tenants in private rented accommodation, and to give additional points to those with a severe disability -; although this would need to be defined.

Where additional properties are being built on existing estates, I think it is advisable to have a local lettings scheme. Consideration should be given to whether this applies only to the new-build properties, or whether there will be some local priority for properties which become vacant as a result of tenants moving into the new homes. When we discussed one specific estate, where the current proposal is to build 2-bedroom homes, I would hope that overcrowded families on the estate would at least be offered some priority for larger homes vacated by downsizers.

Moving between boroughs and mutual exchange

I have already indicated that I think Islington Council should take an active role in managing mutual exchange, including taking some properties out of choice-based lettings to facilitate a multiple move, and working with tenants to ensure that they downsize or upsize to a suitable home. I would like to have more information about Homeswapper -; does this service actually work for Islington tenants? How many tenants have moved into/out of Islington using this service? What more could be done to help tenants wishing to move?

You have proposed that Islington should become part of the Mayor of London’s Housingmoves scheme -; how would this work? How many Islington properties would be let to tenants from outside Islington through this scheme? How would they be assessed? How can we ensure that this scheme gives Islington tenants who wish to move elsewhere real choices?

Frequently asked questions

Once the scheme has been established, it would be helpful to offer a FAQ link, so applicants can see the answers to questions like “why don’t the children of leaseholders get New Generation points?” or “why don’t I get any points for having diabetes?”

I hope you find these comments helpful, and I look forward to seeing a draft of the new Housing Allocation Scheme. I have raised a number of questions in the course of this rather long letter, and I would be grateful for your response on these points. Thank you for this, and thank you again for making the time to talk to me about this very important issue. I look forward to hearing from you.

Best wishes

 

Emily Thornberry MP

Islington South and Finsbury