Dear Southwark Council,
This is my response to Southwark council’s consultation on changes to the housing waiting list rules. I have used the council’s consultation survey to ensure that I respond to each of the questions in this survey. But the survey misses out some key changes so I have included these in my answers below. There may be other changes in the new housing allocations policy that I am not aware if the council has not included these in the survey.
1) Pushing families in overcrowded housing down the waiting list
The council do not ask questions in the survey about these overcrowding changes.
There are 4 key changes on overcrowding in the council’s proposals.
The council want to increase the overcrowding criteria for band 1/band A to an even stricter overcrowding test. The new band 1/band A criteria is to be statutory overcrowded and be lacking 3 or more bedrooms. Statutory overcrowding is already an extremely strict test. It is unacceptable for the council to be making this test even stricter. Families who are statutory overcrowded but are not lacking 3 bedrooms will be pushed down the housing waiting list. I do not accept this proposal and I propose instead that the council keep the current criteria for band 1/band A of statutory overcrowding (with the removal of the ‘deliberate act’ clause).
The council are proposing to introduce a new band B for overcrowding where a family is lacking 2 bedrooms. I accept this proposal as it will mean that families who do not meet the strict definition for being statutory overcrowded but who are still very overcrowded will be given a band that reflects their high housing need. Under the current scheme these families would be in band 3 so this is an important improvement for families with this level of overcrowding.
The current rule for band 3 overcrowding is simply being ‘overcrowded – but not statutory overcrowded’. The council are proposing to change this to ‘lacking 1 bedroom’. This new definition is a stricter test because previously someone could be overcrowded living in a bedroom with shared facilities (kitchen, living room, bathroom) with other households. However under the new definition they would not qualify for band 3 as they are not lacking a bedroom. I think that the council should keep band 3 for overcrowding for those who are having to share facilities with people not in their household as it is important that these overcrowded living conditions are recognised.
The council want to change the bedroom criteria. This significant change is not mentioned in the council’s consultation survey. Under the current scheme, siblings of the same sex share a room until aged 15. When a child turns 16 years old, they get their own bedroom. In the council’s proposals, 2 siblings of the same sex aged 20 years old and under must share a bedroom. I reject this proposal as it will cause overcrowding. Children, teenagers, and young adults need their personal space. Overcrowding is already a serious housing problem that many Southwark residents are suffering with. The council should not have policies which lead to overcrowding.
In summary, the council should keep the current overcrowding and bedroom criteria rules and add the band B banding for families lacking 2 bedrooms.
2) Annual Lettings Plan for the council to get around the housing waiting list rules
The council do not ask questions in the survey about the Annual Lettings Plan. Also, the council’s explanation of this Annual Lettings Plan is vague but basically reads like the council making additional rules whenever they feel like it.
I am concerned this will make the waiting list more confusing and difficult to use. I am not clear about how any targets/quotas/ applicants would be selected as part of the Annual Lettings Plan. I am worried that if the Annual Letting Plan targets/quotas are introduced, it will be harder for us to understand how housing is allocated if it is not done through the Southwark Homesearch website and the priority bands. Everyone who is on the waiting list can see what properties are advertised on Homesearch, and it is transparent. If properties are not put on Homesearch and are instead allocated through the Annual Lettings Plan, I will be worried who the properties are given to, and how the council decided to allocate that person social housing.
I am also concerned that the Annual Lettings Plan will mean housing is no longer allocated based on the level of housing need. The priority band system orders applicants based on housing need. The current system is that each property is let to the person with the highest priority who bid on it. This is easy to understand and it is fair. The council already have a direct offers policy to allocate housing in exceptional circumstances, so I am not clear why an additional policy is needed and what this additional policy would look like.
I do not agree with the council’s proposal to introduce an Annual Lettings Plan.
3) The council have total control over who gets new build homes
The council do not ask questions in the survey about the Local Lettings Policy.
The council are proposing to have a ‘flexible quota system’ for new build homes to be reserved for local social housing tenants. The current policy allows the council to reserve 50% of new build homes for local social housing tenants. Under the new system, the council could increase this to 100%, and the council will have more powers to decide which households are picked for new build homes. Similarly to the Annual Letting’s Policy, this proposal is designed to give the council more power over the allocation of social housing, but this means that there is less transparency for those on the waiting list.
I disagree with this proposal and with the current policy as well. I think all new build homes should be put on Southwark Homesearch and allocated according to housing need through the housing waiting list policy.
Social housing should be awarded to those most in need, which is decided by the priority bands in the housing allocations policy. This proposed policy allows those living in local social housing to jump the queue for new-build council and housing association homes ahead of other households on the housing waiting list who have a higher housing need. When there are so many Southwark residents with a high housing need, it is not fair to ‘ring fence’ or reserve new-build council homes only for local social tenants. These homes should be put on Southwark Homesearch so that everyone has the opportunity to place their bids and they are allocated according to the priority bands. If only local social housing tenants are allowed to bid for these homes, this gives them an unfair advantage over many other households in greater need who live in the private rented housing or in temporary accommodation, and even social housing in other areas of the borough. Households in private rented housing and temporary accommodation face greater insecurity, higher levels of disrepair and higher rents and therefore it is not fair to give social housing tenants an advantage over these households. Households should be prioritised by need according to their priority band and not any other additional criteria as this causes confusion. Also, everyone on the housing waiting list already has to have a local connection with Southwark to even join the waiting list.
In my view there is no need for any local letting rules, and the current Local Lettings Policies should be removed.
4) Pushing homeless households down the waiting list
In the new policy, there are a number of changes that will impact homeless households by pushing them further down the housing waiting list. Under the current system, homeless households are awarded band 3 and a homeless priority star. The council is proposing to make the following changes:
· People in temporary accommodation with a Main Housing Duty will be in band C with no additional priority within this band (as the homeless priority star is being removed).
· People who were homeless but move to private housing will remain in band C, and those who live in ‘insecure’ housing will be added to band C. This will mean many more people are in band C who do not live in temporary accommodation
· Moderate medical priority (which is currently band 3 with no priority star) will be moved to band B ahead of homeless households living in temporary accommodation.
· Housing officers can pick some single homeless people for band A.
In summary, the above changes will see homeless households in temporary accommodation with a Main Housing Duty pushed down the housing waiting list. This will significantly increase the already long waiting times for people in temporary accommodation. This will mean years more in overcrowded, far away and dilapidated “temporary” accommodation. It is totally unjustifiable that in the biggest homeless crisis in generations the council would implement policies to demote homeless households on the housing waiting list.
By allowing homeless households who take private rented housing to keep their banding, this policy will help the council to push homeless families into private rented housing where they lose their homeless rights and protections. We have seen a similar scheme with Lambeth council which has been disastrous for those who accepted private housing and for homeless applicants as well. This scheme simply creates a cycle of homelessness where people accept private housing and then become homeless again and have to return to the housing office. A scheme which encourages families to give up their homeless duty (and the rights and protections that this involves) undermines important homeless rights. When a family becomes homeless, the Council should provide suitable temporary accommodation and they should be able to move directly from temporary accommodation to permanent social housing – this is how the current process works and this functions reasonably well.
People who are rough sleeping are some of those at the worst end of the housing crisis and need permanent council housing - but we are not convinced that this policy is the correct way to do this. There is not enough information on this policy and it sounds like housing officers will be given discretion over who is selected for this policy. It is also not clear why this policy is needed when there is already the statutory homeless process that is there to help people, and this already works to prioritise the most vulnerable single people for social housing. This policy seems to be creating another scheme when there are already homeless laws to support people that the council can use. The policy will also undermine the statutory homeless process. Having 2 systems will cause confusion. This policy will cause queue jumping over other people in housing need, such as people in temporary accommodation with a Main Housing Duty who were previously sleeping rough.
I disagree with the above proposals by the council that will lead to households in temporary accommodation being pushed down the housing waiting list.
If the homeless priority star is removed, the council should also find another way to give extra priority to homeless households in Band 3/C, for example, by awarding 2 years waiting time to their effective date.
5) Removing priority not related to housing need
The current waiting list rules award extra priority to people based on working, volunteering, and being a ‘good tenant’ (only for council or housing association tenants) which are not based on housing need, or the time that applicants have been waiting and enduring that housing need. I think this is unfair and that people’s positions on the housing waiting list should be according to their housing need and not whether they are in work or not. By removing the priority stars, people will be ordered within a band according to the time they have had a housing need in that band, for example, someone who has been in temporary accommodation for 8 years will be at the top of band 3, whereas under the current system, if they do not have any stars, they are at the bottom of band 3.
By removing the priority stars, the waiting list system will be easier to understand. By ordering people according to their waiting time in a band, people will have a better understanding of their position and should see their position on properties increase with time. Under the current system, when someone is waiting in a band, their position can vary a lot as people who have been waiting less time than you are awarded priority stars and therefore go ahead of you.
The current priority star system is simply not working. Some people are not aware of the priority star system which is unfair and others have struggled to receive their priority stars. It is also a waste of time of everyone’s efforts which could be better spent fighting for the high-quality council homes we need.
The current priority star system discriminates against single parents, people with disabilities, and carers as it is harder for these people to work and volunteer.
6) Making local connection rules stricter
Under the current policy, usually you can only join the housing waiting list if you have lived in the borough for 5 years, if you have a Main Housing Duty, or if you work in the borough for 16 hours a week for 9 of the last 12 months and you have a housing need (such as living in overcrowded housing). The council is proposing to make this local connection criteria even stricter and completely remove the work rule.
I do not think the council should make the local connection rules any stricter, as they are already very hard to meet for Southwark residents who are struggling with high rents, poor quality and overcrowded private housing, and insecure, zero-hours work.
This is just a way for the council to try to reduce the housing waiting list and hide the housing need that is out there. The only way to reduce the housing waiting list is with council housing! The more people on there are on the waiting list, sends a strong message about the need for council housing.
The council should keep the current work definition for local connection criteria. The council should look at reducing the high local connection criteria, not making them even stricter.
7) Administration changes
The council list a number of smaller administrative changes.
My responses to these are:
7a) Council’s proposal to prevent people in band E from bidding.
I disagree. People in band E should be able to bid for housing so they can participate and understand the bidding system. Being able to bid is a skill and people should be able to practice and learn this. Their situation may change in the future and they may move to a higher band, so being able to bid is important. Also, it helps show how many more council homes are needed as hundreds (and sometimes thousands) of people bid on each property
7b) Council’s proposal that people in rent arrears can be removed from the housing waiting list.
I disagree. I do not think people should be removed from the housing register and made to re-apply as this just creates more admin for everyone. People may have got into rent arrears because of benefit problems. The council should work with people not penalise them. Penalising people doesn’t solve anything.
7c) Council’s proposal on limiting the numbers of offers of accommodation.
I agree that there should be a limit on the numbers of offers of accommodation. The current system where applicants who are in private rented housing or social housing have 2 refusals should be kept and this should also apply to homeless households as well. Currently those in temporary accommodation have a 1 offer rule and do not have any refusals, while people in private rented housing and social housing have 2 refusals. The council should have the same rule for everyone to make things fairer and easier to understand.
7d) Council’s proposal that those who refuse 3 suitable offers are removed from the housing waiting list.
I disagree. People should not be removed from the housing register and made to re-apply as this just creates more admin for everyone. Also losing your waiting time (which can be many years) is a very cruel punishment. A 12 month suspension is enough.
7e) Council’s proposal to conduct an Annual Review.
I disagree. The council should not conduct an Annual Review. The council already have a change of circumstances form for people to submit any changes. And when someone is selected for a property, the council makes checks then, so there is already a system in place. It will be a lot of administrative work to check every applicants’ circumstances each year. Also for applicants who do not speak English or have difficulty with online forms, they may not respond to the council’s communication and find themselves wrongly removed from the list.
7f) Council’s proposal to remove people who have not bid for 12 months.
I disagree. People should not be removed for not bidding. There may be good reasons why they have not placed a bit in 12 months. Maybe the applicants needs support with bidding. The council could reach out to offer help with bidding rather than removing someone. Also, someone may not bid because they know they need to wait many more years. The council should be building enough council housing to ensure people are not waiting years for housing, rather than punishing you for not bidding.
