To consider a briefing note on the Housing Allocation Policy (Pre-Decision Scrutiny).
The Service Manager for Housing Strategy and Policy commented that this was the first full wholesale review of the Allocations Policy since 2007. Minor changes to the policy had been made since 2007 to ensure the Council complied with national legislation. There were some significant changes being proposed to the Allocations Policy. A Steering Group had been established consisting of Housing Strategy Officers, Wolverhampton Homes representatives, Tenant Management Organisations and Legal Officers, who had met regularly to consider how the Allocations Policy should be updated. Officers had also conducted internal consultation within the Council by attending meetings such as Leadership teams. The briefing note contained the revised objectives for the Allocations Policy. She cited the objectives as follows: -
· Ensure people in the greatest housing need have the greatest opportunity to access suitable housing that best meets their needs.
· Make use of a range of housing options and tenures to prevent and relieve homelessness.
· Make best use of the Council’s and partner registered providers’ housing stock.
· Manage applicants’ expectations by being realistic about stock availability, to support them in making informed choices about their housing options, and the extent to which they are able to express reasonable preference.
· Ensure that the Council’s legal duties and corporate responsibilities are met and that they contribute to delivering the Council’s priorities.
The Service Manager for Housing Strategy and Policy remarked that they were proposing that choice-based lettings be retained, allowing people to bid for the properties they had an interest in, rather than operating a waiting list where the first suitable property available would be allocated to the person at the top of the waiting list. They were looking to modernise Band 4, which was the band given to people that were in no housing need and were suitably housed already. They had over 5000 applicants in that band. Only 2% of properties were allocated to Band 4 at the present time, which equated to approximately 100 properties per year. They wanted to better assist the people in Band 4 with more realistic housing options. This could include guiding them into the private rented sector or homeownership options. They wanted to make better use of the 2% of the stock allocated to Band 4.
The Service Manager for Housing Strategy and Policy stated that a revised banding system was proposed for bands Emergency,1- 3. They were considering introducing a new emergency plus band, which would give additional priority to applicants with a full homelessness duty who were also care leavers, members of the armed forces, require a substantially adapted property, were significantly overcrowded or anyone who required immediate rehousing due to a significant threat to life, to ensure those with the highest level of need were given the most priority.
The Service Manager for Housing Strategy and Policy commented that they were proposing a revision of the right sizing criteria to try and make it fairer for people who were under or over occupying. A new banding priority was being proposed for people wishing to have a larger property because they wished to foster or adopt. It was clarified in the full policy document that it could not just be people expressing an interest in fostering or adoption, they had to have reached a certain point in the process. They were also looking to introduce additional priority for care leavers within the City. It was proposed that Wolverhampton care leavers be excluded from any residency requirements (requiring them to have lived in the City for at least up to the age of 25).
The Service Manager for Housing Strategy and Policy remarked that one area they were looking to make fairer was regarding rent arrears. Presently there was a £60 rent arrears limit, where you would be either temporarily downgraded in the banding system or prevented from bidding on properties. It was proposed that the limit would be increased to £400 which was the average monthly rate. They were also proposing some new exclusion criteria, the current policy meant you were either on the register or excluded completely. It was proposed that the new policy would allow you to be excluded for certain parts, such as a specific geographical location or a type of property, i.e. high rise, where they may be a danger to themselves or other people. It was intended that these exclusions could be reviewed at any time.
A Panel Member asked what action against a perpetrator the proposed new policy would allow when an existing tenant had been found guilty of an offence, such as assault against a person who lived locally to the perpetrator. The Director for City Housing and Assets said they would discuss the matter with the Probation Service and the Police. If there was a risk they would use a multi-agency approach to determine the action to be taken.
A Member of the Panel remarked that she could not support recommendation 11 (Appendix A to the report) – “Allow children of the same sex to share a bedroom post the age of 15”. The current situation was that children of the same sex who reached the age of 15 had to have separate bedrooms, in terms of their housing application. She could not support the recommendation because the age group was such an important time for secondary education examinations. Sharing a bedroom could affect the studies of the individuals concerned.
A Panel Member commented that they could not support recommendation 9 (Appendix A to the report) – “Allowing a maximum of two refusals of offers of housing in a 12-month period before suspending a housing application for six months.” She believed that it should stay the same as the current situation which was that applicants (excluding those owed a homeless duty), could refuse three offers of suitable accommodation in a 12-month period before their application was suspended for a period of three months. Her experience working at Badger Court had informed her that some young people were not fully aware of the consequences of refusing applications until the second occasion of refusal. She felt the proposed new rule was too harsh.
A Panel Member asked about the preparing for a tenancy online training modules. She was aware of a lady who had recently undertaken the training but had significant technical issues. She didn’t want the online training to hold up people in need of housing from being allocated. She had found some of the questions very difficult to answer and asked for the test to be reviewed. One of the questions was about the benefits Universal credit had replaced, which she was sure most people would not know the complete correct answer. The Service Manager for Housing Strategy and Policy responded that the online training modules were run by Wolverhampton Homes in conjunction with the Council. The new allocations policy proposed increasing the support that was available to applicants. The Officers took on board her comments about the preparing for tenancy online training needing review.
A Member of the Panel commented that when some of the recommendations were seen together as a collective rather than in isolation, he had a concern for unintended consequences on the matter of community cohesion. He cited recommendation 6 (Appendix A to the report) – “Remove the priority attached to a quarter of all properties that become available to let to someone with a local connection to an area over those with the greatest housing need,” and recommendation 21 (Appendix A to the report) – “Amend the ‘residency rule’ which requires applicants to have lived in the City for 2 or more years before their housing needs can be fully assessed, to exclude refugees and travellers”. He felt seeing these two recommendations together could fuel far right politics. He suggested that rather than removing the local connection part of the policy, as suggested in recommendation 6, it could be revised instead. The Service Manager for Housing Strategy and Policy responded that in connection with the points the Councillor made, they understood the importance of community cohesion and they had tried to strengthen the local connection in relation to another policy. The policy for the allocation of new build Council properties had seen the local connection strengthened. The Councillor commented that to determine local connection areas, rather than using arbitrary lines on maps, could the Council use other methods such as drive time, walk time or GIS radius systems.
A Panel Member remarked that he had some concerns of unintended consequences in relation to recommendation 3 (Appendix A to the report) – Increase the priority given to Wolverhampton Care Leavers and exempt them from any residency requirements up to the age of 25. He was aware that some children and young people were fostered out of the City for safety and wellbeing reasons. If they returned to Wolverhampton when leaving care, a vulnerable person could end up being exploited by people who they had escaped from. So, whilst he wanted to help care leavers, he did not want them to perversely suffer from the new policy due to an unforeseen safeguarding issue. It was therefore important that appropriate safeguards were in place in the policy for care leavers. The Service Manager for Housing Strategy and Policy responded that they had developed the proposal in consultation with the Leaving Care Team. The proposal had also been to the Care Leave Forum during the consultation who had welcomed the proposal. She did however appreciate the comment and said it was something they should build into their consultation to ensure safeguards were in place.
A Member of the Panel asked why recommendation 19 (Appendix A to the report), was proposed - “Ensure the Allocations policy meets current needs by removing those criteria that are not used i.e. “the two tenancies for one rule.” They asked the question, why the fact that a rule was rarely used, was justification for it to be abolished. They asked for this to be reconsidered. The Service Manager for Housing Strategy and Policy responded that they would give this rule some further consideration.
Resolved: That the final proposals for the Housing Allocations Policy be received for pre-decision scrutiny at the Vibrant and Sustainable City Scrutiny Panel, before the final recommendations are put to Cabinet, currently scheduled for January 2020.