Review of the Common Allocations Policy
Perth and Kinross Council · 22 January 2025
Back to Housing and Social Wellbeing Committee — 22 January 2025 and its agenda
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Housing And Social Wellbeing Committee 22 January 2025 REVIEW OF THE COMMON ALLOCATIONS POLICY Report by the Strategic Lead - Housing and Communities (Report No. 25/10) 1. PURPOSE 1.1 The purpose of this report is to provide members with an overview of the recent review of the Common Allocations Policy and a summary of the proposed changes and their impact. 2. RECOMMENDATIONS 2.1 It is recommended that Committee: (i) Notes the content of this report, the rationale for the review, the methodology used and the stakeholders who have been involved. (ii) Approves the proposed changes to the Common Allocations Policy, including the enhanced ‘downsizing’ offer, and the implementation of the revised Policy from April 2025. (iii) Notes that three Housing Associations are partners in the design and delivery of the Policy and that they will follow their own, internal approval processes prior to implementation of the Policy in April 2025 3. STRUCTURE OF REPORT 3.1 This report is structured over the following sections: • Section 4: Background/Main Issues • Section 5: Proposals • Section 6: Conclusion • Appendices 4. BACKGROUND / MAIN ISSUES 4.1 The existing Common Allocations Policy (CAP) was approved by the Housing and Communities Committee on 20 March 2019 (Report No. 19/79 refers). This report detailed the outcome of a ‘light touch’ review of the Policy following a more significant redesign in 2016 (Report No. 16/27 refers). 4.2 The Common Allocations Policy has been developed by four partner landlords: Perth & Kinross Council, Caledonia Housing Association, Hillcrest Homes and Kingdom Housing Association.
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Collectively, these landlords operate a Common Housing Register (CHR) providing access to around 11,000 affordable homes in Perth and Kinross. 4.3 The Common Allocation Policy underpins the CHR and ensures that partners meet all legal and regulatory requirements for housing allocation. The policy ensures fair and equitable access to housing opportunities based on housing need. As such, the policy must: • Comply with relevant legislation and statutory guidance. • Ensure open and fair access to housing. • Assign priorities and give ‘reasonable preference’ to certain groups, considering legislation and the local context. • Deliver effective and sustainable outcomes for applicants. • Make the best use of the partners’ housing stock. 4.4 Since the significant redesign in 2016, with minor amendments in 2019, the policy has effectively facilitated access to housing for applicants with urgent or acute housing needs. Despite an overall shortage of affordable housing relative to demand, the policy has ensured fair and efficient access to those in greatest need and has made optimal use of available housing. 4.5 A comprehensive evaluation of the current policy has found that it is fully meeting its aims and objectives. The success of the policy is demonstrated through the following key indicators: • Responding quickly to people in housing need Area 2021/22 2022/23 2023/24 Number of applicants on the Common Housing Register 3,327 3,471 3,306 Number of homeless people waiting for permanent housing 115 196 196 Average homelessness case duration 64 days 78 days 88 days • Total number of permanent tenancies created (lets) across the Common Housing Register partnership; Area 2021/22 2022/23 2023/24 Total number of lets 1,373 996 1,104 Note – the number of lets in 2021/22 was unusually high due to a significant number of new-build properties completing. The number of lets shown for 2023/24 is more representative of what we’d expect on an annual basis.
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• Prioritising applicants in the most housing need; Area 2021/22 2022/23 2023/24 Number and percentage of lets to homeless people 447 (33%) 426 (43%) 568 (51%) Number of lets to people with a medical need 286 103 134 Number of lets to people with Strategic Need priority 236 173 140 4.6 Several changes in the housing landscape, both locally and nationally, have occurred since the last review of the Common Allocation Policy. These include: • Implementation and ongoing review of Rapid Rehousing Transition Plans (RRTP) from April 2019. • Significant national increases in homelessness and the number of households in temporary accommodation during the RRTP period (2019 – 2024). • Changes to homelessness legislation/guidance around ‘intentionality’ and ‘local connection’. • Significant increase in people arriving in Perth and Kinross through humanitarian protection schemes, particularly Ukrainian Displaced People. • Increase in people seeking asylum and an associated change to the UK Governments dispersal policy, resulting in the commissioning of two hotels in Perth by the Home Office to accommodate asylum seekers. • Declaration of a ‘Housing Emergency’ by the Scottish Government in May 2024 with 12 individual local authorities also declaring a ‘Housing Emergency’. 4.7 Whilst Perth & Kinross Council has not declared a ‘housing emergency’, the supply and demand pressures are being felt locally. These pressures mean that more people are experiencing homelessness, the proportion of people whose only realistic option is social housing has increased, and less of our existing tenants are moving to alternative properties or tenures. The national housing emergency declaration is effectively a recognition that the gap between supply and demand is growing. 5. PROPOSALS 5.1 A full and comprehensive review of the Common Allocations Policy has been undertaken in conjunction with partner landlords and other key stakeholders. Applicants and tenants have been consulted on the effectiveness of the current policy and the proposed changes. A review of the ‘Access to Housing’ Equalities Impact Assessment’ (EQIA) has been completed and approved by the Corporate Equalities Group.
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Further information is enclosed in the Appendices to this report: Appendix 1 – Summary of proposed changes to the CAP. Appendix 2 – Revised Equalities Impact Assessment. Appendix 3 – Summary of applicant/tenant feedback. 5.2 The primary driver for the review of the Common Allocations Policy is the recommendation in the ‘Social Housing Allocations in Scotland’ Practice Guide to review allocations policies every 3 to 5 years. 5.3 The position of the Common Housing Register partners ahead of the review was that the Policy was compliant with legislation and statutory guidance and was delivering on its stated objectives. The review process confirmed this, and the Common Allocations Policy is considered to fully meet the requirements outlined in section 4.3. It is important to note that while the review has been comprehensive, the proposed changes to the policy, detailed in Appendix 1, are relatively minor. Tenant Downsizing Scheme 5.4 Currently, around 120 Perth & Kinross Council tenants have an active application for rehousing due to overcrowding. A similar number of tenants have an application for rehousing because they live in properties larger than they need. 5.5 A broader analysis of our tenant/property profile suggests that around 2,000 of our tenants live in larger properties than necessary based on their household size, including over 200 tenants who have 2 or more bedrooms than they need. These tenants are considered to be ‘under-occupying’ their homes. 5.6 A common theme from the tenant and applicant feedback, outlined in Appendix 3, was that the Council should ‘force’ tenants who are under- occupying their homes to move to a smaller property. However, this practice is expressly forbidden in legislation. Therefore, so any intervention to free-up larger properties must be based on providing encouragement and incentives to downsize. 5.7 There is already a ‘Tenant Incentive Scheme’ in place, but its criteria and conditions exclude many applicants, making it rarely used. The current scheme is also limited to tenants who apply for rehousing and is not actively promoted to encourage other tenants to downsize.
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5.8 It is proposed that a revised ‘Tenant Downsizing Scheme’ be offered as a ‘test of change’ project during 2025/26 to free up larger housing stock for overcrowded applicants. This aligns with ‘making best use of housing stock’ point at section 4.3. The revised scheme will: • Be initially limited to Perth & Kinross Council tenants (for funding reasons). • Offer cash and/or non-cash incentives up to the value of £2,000 (providing floor coverings in the new property, arranging removals etc.). • Provide tenants with more choice in terms of the type and size of property they can move to. • Be actively promoted to significantly under-occupied tenants who have not applied for alternative housing. 6. CONCLUSION 6.1 The Common Allocations Policy is already compliant with relevant legislation and is delivering on its stated objective. The revisions to the policy, while relatively minor, will clarify areas regularly raised by applicants and strengthen our ability to prevent homelessness for people living in unsustainable and insecure accommodation, reliant on the goodwill of a friend or relative. The review of the Policy, last updated in 2019, also ensures that the review frequency is in line with guidance. 6.2 The enhanced ‘Downsizing Scheme’ will provide opportunities to meet the housing needs and aspirations of multiple households by incentivising tenants to move to smaller properties. If successful, this will reduce the number of families experiencing overcrowding, resulting in a more efficient and effective use of existing housing stock.
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Author Name Designation Contact Details Martin Smith Service Manager 01738 475000 EPLCommitteeReports@pkc.gov.uk Approved Name Designation Date Elaine Ritchie Strategic Lead – Housing and Communities 8 January 2025 APPENDICES - Appendix 1 Summary of Proposed Changes to the Common Allocations Policy - Appendix 2 Revised Equalities Impact Assessment (EQIA) - Appendix 3 Summary of feedback from Tenant/Applicant Consultation
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ANNEX 1. IMPLICATIONS, ASSESSMENTS, CONSULTATION AND COMMUNICATION Strategic Implications Yes / None Community Plan / Single Outcome Agreement Yes Corporate Plan Yes Resource Implications Financial Yes (HRA) Workforce None Asset Management (land, property, IST) Yes Assessments Equality Impact Assessment Yes Strategic Environmental Assessment None Sustainability (community, economic, environmental) None Legal and Governance Yes Risk Yes Consultation Internal Yes External Yes Communication Communications Plan Yes 1. Strategic Implications Community Plan/Single Outcome Agreement 1.1 This report supports the following priorities within the Perth and Kinross Community Plan 2022-27: 1. Reducing Poverty 2. Physical and Mental Wellbeing Corporate Plan 1.2 This report supports the objectives of the Corporate Plan 2022/23 to 2027/28: i. Tackling climate change and supporting sustainable places ii. Developing a resilient, stronger and greener local economy iii. Enabling our children and young people to achieve their full potential iv Supporting and promoting physical and mental wellbeing
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2. Resource Implications Financial 2.1 There are additional financial implications associated with the revised Tenant Downsizing Scheme. As a ‘test of change’, this will be funded from Housing Revenue Account (HRA) reserves initially and then included in the rent-setting options for 2026/27. Workforce 2.2 There are no additional workforce implications arising directly as a result of this report at this time. Ongoing work is managed within existing resources. Asset Management (land, property, IT) 2.3 There are no additional Asset Management implications arising as a result of this report at this time. Any new proposed developments which arise in the future will be subject to the relevant approval process at the time. 3. Assessments 3.1 Under the Equality Act 2010, the Council is required to eliminate discrimination, advance equality of opportunity, and foster good relations between equality groups. Carrying out Equality Impact Assessments for plans and policies allows the Council to demonstrate that it is meeting these duties: (i) Assessed as relevant for the purposes of EqIA (ii) An Equalities Impact Assessment is included as Appendix 2 Strategic Environmental Assessment 3.2 The Environmental Assessment (Scotland) Act 2005 places a duty on the Council to identify and assess the environmental consequences of its proposals. Sustainability 3.3 Under the provisions of the Local Government in Scotland Act 2003 the Council has to discharge its duties in a way which contributes to the achievement of sustainable development. Under the Climate Change (Scotland) Act 2009 the Council also has a duty relating to climate change and, in exercising its functions must act: • in the way best calculated to delivery of the Act’s emissions reduction targets; • in the way best calculated to deliver any statutory adaptation programmes; and • in a way that it considers most sustainable.
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3.4 No steps are required to be considered relating directly to this report. Legal and Governance 3.5 The Strategic Lead - Legal and Governance has been consulted during the development of this report. Risk 3.6 Any risks associated will be mitigated by the monitoring and reporting procedures which are in place for the work concerned. 4. Consultation Internal 4.1 This report has been developed through work across all services within the Council. External 4.2 The work reported here contains reference to the partnership work which goes on with strategic partners in all sectors to ensure appropriate access to housing. 4.3 The Tenant Committee Report Panel was consulted on this report and a meeting was held to allow tenants to question Lead Officers. Overall, the Panel felt that this was a good and informative piece of work. Tenants were especially pleased to see the Summary of Consultation Responses which highlights tenant participation in action. 5. Communication 5.1 The report will be made available internally and externally when approved. 2. BACKGROUND PAPERS 2.1 No other background papers were referred to in the preparation of this report.