We are consulting on changing the housing allocations policy. The allocation policy sets out the rules the council uses to decide if someone can apply for social housing and how high they would be placed on the housing register, depending on their individual needs. This consultation will be open from 7 July 2023 to 9 am on Monday, 4 September.
Who are we consulting
The council would like to hear from housing applicants, residents living in social housing, businesses, voluntary groups and local organisations connected to affordable housing that might be impacted by changes in allocations policy in Rother. We want to know what you think, whether or not the suggested changes are supported and any impacts or consequences we might not know about.
Why are we consulting
We are revising the Housing Allocation Policy to make sure our social housing goes to those in greatest need.
There have been significant changes in housing law since the policy was last reviewed. Changes include the introduction of the Homeless Reduction Act (2017), requiring local authorities to have a greater focus on homelessness prevention.
Our proposed changes are designed to deliver these objectives:
- Reduce the number of clients on the housing register down from 2,072 (July 2023) to 1,200 by March 2024, which is a stated goal of our Housing, Homelessness and Rough Sleeper Strategy adopted in 2019.
- Reduce the use of temporary accommodation by focussing more on homelessness prevention.
- Establish a transparent and clear method of awarding priority that meets the needs of local residents, particularly the most vulnerable.
- Ensure the policy reflects changes in legislation, particularly regarding eligibility and the Homeless Reduction Act (2017).
- Create a better pathway for clients supported under the Rough Sleeper Initiative.
Our Proposed Changes
A full copy of the Draft Housing Allocations Policy is available by clicking the button below. A concise summary of the changes, impact, benefits and guidance has been included on this page.
Additional priority for applicants in highest need
|Change||Introduce an Urgent Need category,. An applicant in this band is allocated through a direct let, rather than Choice based Lettings, if social housing has been deemed as the only viable option. There would be very specific reasons to be placed in this band such as exceptional homeless cases, significant risk, hospital discharge (where an applicant can’t return to their home), for example. All other allocations would be made through Choice Based Lettings in priority groups to be determined.|
|Impact||As allocations would be made through a direct let, there would no impact to households already on the housing register.|
|Benefit||It would provide greater flexibility than Choice Based Lettings, particularly in situations where there is an urgent or immediate need to provide assistance. It would also assist in preventing homelessness, one of the key aims of the Homelessness Reduction Act (2017). In addition, it would reduce the council’s spending on temporary accommodation for Urgent Need cases, where appropriate.|
|Guidance||The legislation requires local authorities to afford certain groups ‘reasonable preference’ on the housing register and this will still be implemented through the Choice Based Lettings System used for bands A to D, that will sit underneath the Urgent Need Band.|
Amendments to prioritise those most in need: family local connection
|Change||To prioritise applicants for rehousing who currently live in the district over those that don’t. This would be achieved by removing the current family local connection criteria. Family local connection would still be required for certain developments with s106 planning requirements attached to them. In these instances, it would ensure that local residents or family members of local residents would be prioritised for new affordable housing schemes. There are a number of local connection exemptions, which include providing care and support (evidenced) to ensure that vulnerable residents are also protected.|
|Impact||There are currently 509 households whose only local connection is through family.|
|Benefit||It would ensure that in most situations allocations would be made to applicants who are resident in the district. In addition, by reducing the overall number of households on the register it would increase the chances of those who remain on it.|
|Guidance||We are required to afford priority for those residents continuously for at least 2 years. No requirement for family local connection other than exemptions: Armed Forces, Hardship, Welfare grounds and Local Letting Plan.|
Amendments to prioritise those most in need: Need for sheltered housing
|Change||To ensure that allocations are made to applicants with an identified housing need by considering removing households from the housing register who are currently in band D that have no other identified need except a need for sheltered housing.|
|Impact||184 households approximately|
|Benefit||It would mean that applicants who are adequately housed and/or had assets or equity to resolve their own housing situation would be removed from the housing register. It would also reduce the overall number of clients on the housing register and therefore increase the chances for those remaining.|
|Guidance||The government guidance states that authorities should avoid allocating properties to people who own their own homes. It should only be in exceptional circumstances where an elderly owner occupier can’t stay in their own home and need to move into Sheltered accommodation. If an elderly client can’t stay in their own home then they would have a housing need and would therefore be eligible.|
Amendments to prioritise those most in need: Resources
|Change||To ensure that allocations are made to applicants who are not in a position to resolve their own housing situation. This could be done be assessing household income to establish whether it is reasonable for them to afford alternative accommodation in the private rented sector rather than just setting fixed household income. As a guide, spending less than 32% of one’s income in rent or mortgage payments would exclude a household from being eligible. The proposed changes also reduce the permitted savings threshold (currently £24,000) in line with capital sums for Universal Credit purposes which is currently £16,000. The Council will disregard disability payments for former members of the armed forces following discharge, Disability Living Allowance (DLA) payments, Personal Independent Payments (PIP) and applicants with significant mobility issues so this does not adversely affect their opportunity to find suitable accommodation|
|Impact||Difficult to determine a specific number until all applications have been re assessed.|
|Benefit||It would ensure that allocations are made to households most in need and who are assessed as not being able to resolve their situation through ownership or rental. Reducing the number of households on the register will in turn increase the chances of those remaining on the register.|
|Guidance||The guidance advises councils to give less priority to households who have the financial resources to meet their own housing need, including homeowners and those with sufficient income or savings, with some exceptions.|
Reducing the use of temporary accommodation
|Change||The current policy offers the highest priority to accepted homeless households, the vast majority of which are provided with costly temporary accommodation. Looking at the information we have from people seeking homeless assistance we are able to determine that between 15% to 20% of homeless approaches have been from friend or family evictions, where it may have been reasonable for the household to continue residing pending an offer of private rented or social housing. Applicants could be encouraged to pursue other housing options such as the private sector if the council reduces the priority it awards for this pathway. The policy could also be amended to give greater priority to applicants making their own temporary arrangements, where it is safe and reasonable to do so. To reduce concerns about moving clients on from TA in a lower band additional criteria could be introduced. For example, if an applicant has been in TA for 6 months or more and they have exhausted all alternative options then they could be awarded the Emergency Priority. This would prevent TA from silting up and providing a pathway for those already in TA.|
|Impact||Difficult to determine a specific number however this could potentially reduce the number of households needing to access temporary accommodation by 20% which is a significant reduction.|
|Benefit||It would reduce the council’s spend on costly temporary accommodation and paying for storage and removals of the household’s belongings while in temporary accommodation. It would also prevent vulnerable households, including those with children, from the detrimental psychological and emotional impact of becoming homeless and being placed into emergency accommodation. It would allow them to remain, where safe to do so, with family and friends providing stability and often the support they require.|
|Guidance||Part VI of the Housing Act requires local authorities to give ‘reasonable preference’ to homeless households. Provided the accepted homeless households were give preference over other groups eg: those making own arrangements in band A and those placed in temporary accommodation in band B for example it would meet the requirement.|
Encourage clients to accept private rented accommodation
|Change||The Department of Levelling Up Housing and Communities having visited the council suggested that the council encourage clients to accept offers of tenancies in the private rented sector. Such offers can also be used to discharge certain homeless duties. To support this, clients could be permitted to remain on the housing register in Band C following their move into private rented accommodation.|
|Impact||The council has assisted 75 clients into the private rented sector so far this year. Although it is not envisaged that all of these would want to join the housing register.|
|Benefit||It would provide an additional incentive for clients who considering an offer of accommodation in the PRS. Otherwise, they wouldn’t be eligible to join the housing register as they would have no housing need.|
|Guidance||There is no statutory guidance on this issue and it is for the local authority to determine.|
Non-co-operation from homeless applicants
|Change||Following the introduction of the Homeless Reduction Act (2017) there is a statutory requirement for applicants to take the necessary, agreed steps, in their Personal Housing Plan to help resolve their housing situation. Where applicants deliberately refuse to co-operate, then their priority on the housing register could be reduced or removed for a period of time.|
|Impact||Clients are provided with a PHP when they are owed the ‘prevention’ or ‘relief’ duty. Ordinarily, if they are owed either of those duties, they would be given reasonable preference, which is currently Band C. By reducing or removing their priority for a period of time it would reduce their chances of being rehoused.|
|Benefit||It will encourage clients to take the reasonable steps as set out in their personal housing plan which could prioritise other types of housing, such as the private rented sector or supported accommodation. It will penalise those who deliberately refuse to engage in the process of resolving their housing situation.|
|Guidance||Authorities are permitted to adopt criteria that would disqualify individuals owed priority under the reasonable preference category.|
Pathway for former rough sleepers
|Change||The Council has secured funding for accommodation through the Next Steps Accommodation Program (NSAP) and Rough Sleeper Accommodation Program (RSAP). The Council now operates a Housing First scheme, providing supported accommodation to former rough sleepers. Under the terms of the funding, clients are only able to reside in the accommodation for a maximum of two years. It is therefore necessary to award a Band A priority on the to clients who have demonstrated they have the independent living skills to move into independent accommodation, so that vacancies can be created within the Housing First scheme.|
|Impact||There are currently 14 units of RSAP or NSAP accommodation, 11 are Rother District Council owned and 3 are accommodation owned by registered housing providers.|
|Benefit||It will enable the council to ensure timely move on from accommodation that can then be used for other clients in need. It will also enable a sustainable and stable housing pathway for an extremely vulnerable client group.|
|Guidance||The guidance requires authorities to give reasonable preference to applicants on Welfare grounds where they otherwise may not be able to secure accommodation.|
What happens next
We will analyse and collate all responses and report them to the councillors at the Scrutiny meeting on 16 October. They will be able to take your views into account when deciding on changes to the policy.
Depending on the outcome of the committee meeting, their recommendations will be made to the next Cabinet. Full council will make a final decision at the meeting before Christmas.
Any changes will be adopted and will start to be implemented early in 2024.
How to Take Part in this Consultation
This consultation closed on Monday 4th September 2023