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Agenda Document Pack - Housing and Community Safety Committee - 10/09/2024

Moray Council · 10 September 2024
Back to Housing and Community Safety Committee — 10 September 2024 and its agenda

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Housing and Community Safety Committee 
Tuesday, 10 September 2024 
NOTICE IS HEREBY GIVEN that a Meeting of the Housing and Community Safety
Committee is to be held at Council Chambers, Council Office, High Street, Elgin,
IV30 1BX on Tuesday, 10 September 2024 at 09:30. 
BUSINESS 
1 Sederunt 
2 Declaration of Group Decisions and Members Interests * 
3 Resolution
Consider, and if so decide, adopt the following resolution:
"That under Section 50A (4) and (5) of the Local Government
(Scotland) Act 1973, as amended, the public and media
representatives be excluded from the meeting for Item 12 of business
on the grounds that it involves the likely disclosure of exempt
information of the class described in the relevant Paragraphs of Part 1
of Schedule 7A of the Act.”   
4 Minute of meeting dated 25 June 2024 7 - 12
5 Written Questions ** 
6 Housing Investment Plan Update
Report by Depute Chief Executive (Economy, Environment and
Finance)  
13 - 30
7 Moray Affordable Housing Investment Programme
Report by Depute Chief Executive (Economy, Environment and
Finance)  
31 - 38
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8 Scottish Social Housing Charter Compliance
Report by Depute Chief Executive (Economy, Environment and
Finance)  
39 - 46
9 Grass Cutting Scheme Review
Report by Depute Chief Executive (Economy, Environment and
Finance)  
47 - 70
10 Moray Home Energy Efficiency Programme
Report by Depute Chief Executive (Economy, Environment and
Finance)  
71 - 76
11 Housing and Property Services Budget Report - 30 June
2024
Report by Depute Chief Executive (Economy, Environment and
Finance)  
77 - 84 
Item(s) which the Committee may wish to consider with
the Press and Public excluded   
12 Building Services Trading Operation Budget 2024-25 -
Budget Monitoring [Para 9]
• 9. Information on terms proposed or to be proposed by or to the
Authority; 
Information Reports - Not for Discussion at this Meeting
Any member wishing to call in a noting or information report from one
meeting shall give notice to Committee Services at least 48 hours
before the meeting for which the report is published. The Notice shall
be countersigned by one other elected member and shall explain the
reason for call in including any action sought.   
Information Report - Local Housing Strategy Update
Report by Depute Chief Executive (Economy, Environment and
Finance)  
85 - 94
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Summary of the Housing and Community Safety
Committee functions:
To deal with matters relating to Housing/HMOs, Housing Regeneration,
Homelessness, Social Inclusion, Equalities, Community Safety, Anti-
Social Behaviour (including road accidents) and Community Liaison.     
Watching the Meeting
You can watch the webcast live by going to: 
http://www.moray.gov.uk/moray_standard/page_43661.html    
Webcasts are available to view for 1 year following the meeting.  
You can also attend the meeting in person, if you wish to do so,
please come to the High Street entrance door and a member of
staff will be let into the building. 
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GUIDANCE NOTES 
* Declaration of Group Decisions and Members Interests - The Chair of the
meeting shall seek declarations from any individual or political group at the
beginning of a meeting whether any prior decision has been reached on how
the individual or members of the group will vote on any item(s) of business on
the Agenda, and if so on which item(s).  A prior decision shall be one that the
individual or the group deems to be mandatory on the individual or the group
members such that the individual or the group members will be subject to
sanctions should they not vote in accordance with the prior decision.  Any such
prior decisions will be recorded in the Minute of the meeting. 
** Written Questions - Any Member can put one written question about any
relevant and competent business within the specified remits not already on the
agenda, to the Chair provided it is received by the Proper Officer or Committee
Services by 12 noon two working days prior to the day of the meeting.  A copy
of any written answer provided by the Chair will be tabled at the start of the
relevant section of the meeting.  The Member who has put the question may,
after the answer has been given, ask one supplementary question directly
related to the subject matter, but no discussion will be allowed. 
No supplementary question can be put or answered more than 10 minutes after
the Council has started on the relevant item of business, except with the
consent of the Chair. If a Member does not have the opportunity to put a
supplementary question because no time remains, then he or she can submit it
in writing to the Proper Officer who will arrange for a written answer to be
provided within 7 working days. 
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MORAY COUNCIL 
Housing and Community Safety Committee 
SEDERUNT 
Councillor Amber Dunbar  (Chair)
Councillor Donald Gatt  (Depute Chair)  
Councillor James  Allan  (Member)
Councillor Neil Cameron  (Member)
Councillor John Divers  (Member)
Councillor Jérémie Fernandes  (Member)
Councillor David Gordon  (Member)
Councillor Juli Harris  (Member)
Councillor Sandy Keith  (Member)
Councillor Marc Macrae  (Member)
Councillor Paul McBain  (Member)
Councillor Shona Morrison  (Member)
Councillor Derek Ross  (Member)
Councillor John Stuart  (Member)
Councillor Sonya Warren  (Member)  
Ms Alison Angus  (Non-Voting Member)
Ms Jane Bartecki  (Non-Voting Member)
Ms Elizabeth McKnockiter  (Non-Voting Member)
Clerk Name: Lissa Rowan
Clerk Telephone: 07765 741754
Clerk Email: committee.services@moray.gov.uk 
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MORAY COUNCIL 
Minute of Meeting of the Housing and Community Safety Committee 
Tuesday, 25 June 2024 
Council Chambers, Council Office, High Street, Elgin, IV30 1BX 
PRESENT 
Councillor James  Allan, Ms Alison Angus, Councillor Neil Cameron, Councillor
Amber Dunbar, Councillor Donald Gatt, Councillor David Gordon, Councillor Juli
Harris, Councillor Sandy Keith, Councillor Marc Macrae, Councillor Paul McBain,
Ms Elizabeth McKnockiter, Councillor Shona Morrison, Councillor Derek Ross,
Councillor John Stuart, Councillor Sonya Warren 
APOLOGIES 
Ms Jane Bartecki, Councillor John Divers, Councillor Jérémie Fernandes 
IN ATTENDANCE 
Depute Chief Executive (Economy, Environment and Finance), Head of Housing
and Property Services, Environmental Health and Trading Standards Manager,
Building Services Manager, Ms D Murray, Senior Housing Officer, Mrs G
Anderson, Senior Solicitor and Mrs L Rowan, Committee Services Officer as Clerk
to the Committee.   
1         Chair 
Councillor Dunbar, being Chair of the Housing and Community Safety Committee,
chaired the meeting.   
2         Declaration of Group Decisions and Members Interests 
In terms of Standing Order 21 and 23 and the Councillors’ Code of Conduct, there
were no declarations from Group Leaders or Spokespersons in regard to any prior
decisions taken on how Members will vote on any item on the agenda or any
declarations of Member’s interests in respect of any item on the agenda. 
For transparency, Councillor Dunbar stated that at the last meeting of the
Committee she had declared an interest in the Acquisitions Programme and noted
that there was a brief mention of the programme in Item 6 "Moray Affordable
Housing Programme" however having discussed this with the Legal Services
Manager, stated that she would remain in the Chamber for the consideration of this
item.   
3         Pre-election Statement 
The Chair reminded the Committee of the pre-election period and subsequent
restrictions on the Council publishing material showing support for a particular
Item 4
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political party and that, as the meeting was webcast, should the debate become
political, she, as Chair, may need to intervene. This was noted.  
In relation to Item 6 "Moray Affordable Housing Investment Programme",
Councillor Keith reminded the Committee that it had agreed that the Chair write to
the Deputy First Minister outlining the concerns being expressed by the Housing
Sector at the £200 million cuts to the affordable housing budget and the impact
that will have on the Council's ability to meet housing need going forward whilst
acknowledging that its capital allocation has yet to be confirmed and queried
whether this report could be considered as debate may stray into further criticism
of the Scottish Government which would not be appropriate during the pre-election
period.  
The Depute Chief Executive (Economy, Environment and Finance) advised that
the impact of the reduced resource had been fully debated at previous committees
and that the report on the agenda was to discuss how the current allocation could
be applied and suggested that if the debate becomes political then it could be
moved to the confidential section.  
The Chair then called for a short adjournment to discuss this matter with the Legal
Services Manager.  
On resumption of the meeting the Chair stated that there was no grounds to
warrant discussion of the report in the confidential session and, given the potential
for the debate to become political, sought the agreement of the Committee to defer
the report to a future meeting of the Committee. This was agreed. 
4         Resolution 
The Committee resolved that under Section 50A (4) and (5) of the Local
Government (Scotland) Act 1973, as amended, the public and media
representatives be excluded from the meeting for the items of business detailed
below, on the grounds that it involves the likely disclosure of exempt information of
the class described in the relevant Paragraphs of Part 1 of Schedule 7A of the
Act. 
Paragraph Number of
Minute 
Paragraph Number of Schedule 7a and Reason  
13 9 - Information on terms proposed or to be proposed
by or to the Authority. 
5         Minute of meeting dated 7 May 2024 
The Minute of the meeting of the Housing and Community Safety Committee held
on 7 May 2024 was submitted and approved.   
6         Written Questions 
The Committee noted that no written questions had been submitted. 
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7         Moray Affordable Housing Investment Programme 
As previously agreed, this report was deferred to a future meeting of this
Committee given the potential for the debate to become political.   
8         Antisocial Behaviour Policy 
The Committee had before it a report by the Depute Chief Executive (Economy,
Environment, and Finance) regarding the revised Antisocial Behaviour Policy,
Housing Service Neighbour Nuisance and Antisocial Behaviour Policy which
included a request for approval of staffing changes within the teams.  
Following consideration, the Committee unanimously agreed to:  
i. approve the reviewed and updated Antisocial Behaviour Policy as set out in
Appendix 1 of the report; 
ii. note that two Community Wardens are being recruited in line with recent
budget allocation; 
iii. approve the revised Housing Service Neighbour Nuisance and Antisocial
Behaviour Policy for Moray Council tenants as set out in Appendix 2 of the
report; and 
iv. approve the proposed staffing adjustments within housing detailed within
paragraphs 3.6 and 3.7 of the report.   
9         Allocations Policy Annual Performance Report 2023-24 
Under reference to paragraph 8 of the Minute of the meeting of this Committee
dated 1 April 2024, a report by the Depute Chief Executive (Economy,
Environment and Finance) informed the Committee of the performance of the
Council's Allocations Policy during 2023/24.  
Following consideration, the Committee unanimously agreed:  
i. to note the performance identified within the report; and 
ii. the allocations quotas for 2024/25 as set out in paragraph 5.4 of the report.   
10         Performance Report (Housing and Property Services) - Period to
March 2024 
The Committee had before it a report by the Depute Chief Executive (Economy,
Environment and Finance) regarding the performance of the service for the period
to 31 March 2024.  
The Committee joined the Chair in commending the Service for preventing rent
loss due to voids in the Council’s housing stock and thereafter unanimously agreed
to note: 
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i. scrutinises performance in the areas of Service Planning, Service
Performance, and other related data to the end of March 2024; and 
ii. notes the actions being taken to improve performance where required. 
11         Housing and Property and Economic Growth and Development
Services - Service Plans 2024-25 
Under reference to paragraph 5 of the Minute of the meeting of Moray Council
dated 28 February 2024, a report by the Depute Chief Executive (Economy,
Environment and Finance) invited the Committee to consider the Housing and
Property and Economic Growth and Development Service Plans for 2024-25 whilst
noting that these Service Plans were also considered at the Economic,
Development and Infrastructure Committee on 18 June 2024 and the Economic
Growth and Development plan would be considered at the upcoming meeting of
the Planning and Regulatory Services Committee on 13 August 2024, with each
Committee scrutinising in terms of their respective remits.  
Following consideration, the Committee, as per its remit, unanimously agreed to
approve the Service Plans for Housing and Property Services and the priority area
relating to Community Safety only included with the Economic Growth and
Development Service Plan.   
12         Housing and Property Services - Unaudited Outturn as at 31 March
2024 
Under reference to paragraph 7 of the Minute of the meeting of Moray Council
dated 1 March 2023, a report by the Depute Chief Executive (Economy,
Environment and Finance) presented the Committee with the unaudited outturn
position for the Housing Revenue Account (HRA) and General Services Other
Housing Budget for the period up to 31 March 2024.  
Following consideration, the Committee unanimously agreed to note the unaudited
outturn for 2023/24 for the period to 31 March 2024, consisting of a surplus
balance of £1,586k for the HRA and an underspend of £559k for General Services
Housing & Property, reducing to £133,000 following transfer of funds for refugee
resettlement to ear-marked reserves.    
13         Building Services Trading Operation Budget 2023-24 - Budget
Monitoring [Para 9] 
Under reference to paragraph 9 of the Minute of the meeting of this Committee
dated 9 May 2023, a report by the Depute Chief Executive (Economy, Environment
and Finance) presented the Committee with the unaudited budget monitoring
information for the period to 31 March 2024 for the Building Services Trading
Operation.  
Following consideration, the Committee unanimously agreed to note: 
i. the unaudited financial information for the period to 31 March 2024, as detailed
in Section 5 and Appendix I of the report; and 
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ii. Building Services operating performance for the period to 31 March 2024, as
set out in Section 6 of the report.   
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REPORT TO:   HOUSING AND COMMUNITY SAFETY COMMITTEE ON 10
SEPTEMBER 2024  
SUBJECT: HOUSING INVESTMENT PLAN UPDATE   
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 This report informs the Committee of the actual outturn to 31 March 2024 for
the Housing Investment Plan along with an update on progress of the
Investment Plan for 2024/25. 
1.2 This report is submitted to Committee in terms of Section III G (3) of the
Council's Scheme of Administration relating to the maintenance of the
Council’s housing stock. 
2. RECOMMENDATION 
2.1 It is recommended that the Committee consider and notes:- 
(i) the Housing Investment Programme outturn to 31 March 2024, as
detailed in Section 3 and Appendices I to VI; and 
(ii) the progress that has been made on the Investment Plan in the
first quarter of financial year 2024/25. 
3. BACKGROUND 
3.1 The Council meeting of 1 March 2023 approved the Housing Revenue
Account Annual Budget for 2023-24 (paragraph 7 of the minute refers). This
report outlines the outturn for the Investment Programme to 31 March 2024. 
3.2 The Investment Plan is made of 6 main headings, Response Repairs, Void
Repairs, Estate Works, Cyclical Maintenance, Planned Maintenance and
Other Investment. The detailed spend in each area is included in Appendices
I – VI and the below outline of performance in each area is provided. 
3.3  APPENDIX I shows income and expenditure for 2023/24. The figures show
that an overall year-end expenditure of £14,523k was achieved, which
represents a spend of 68% against the £21,338K annual budget, and a
shortfall £6,815k. The shortfall in investment is attributable to internal staff
Item 6
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resourcing delays in progressing a number of work activities along with
procurement delays in a number of outsourced key investment areas such as
window replacements and electrical testing. The level of expenditure within
the individual budget headings that make up the programme are shown in
paragraphs 3.4 to 3.12 below. The expenditure figure represents all payments
which have progressed through the finance system to 31 March 2024. 
3.4  APPENDIX II shows expenditure on Response and Void Repairs. Spend was
£5,911k to 31 March 2024, works delivered, included 14,744 housing repairs
and 406 void properties repaired. An overspend of £1,292k occurred within
this heading due to increased material and labour costs. 
3.5  APPENDIX III shows the expenditure on Estate Works. Spend was £918k to
31 March 2024 which equated to an overspend of £204K. Significant areas of
overspend were Estate/Forum Upgrades which is partly due to the re
commencement of Estate Walkabouts and various areas of backlog works
which these identified. It is hoped that with these returning to an annual event
that any increased demand on this budget can be budgeted for in future
years. The next round of Estate Audits are due during the next few months
with Walkabouts to be scheduled thereafter. As with a number of areas, we
have seen an increase in costs not least in relation to landscaping. During
2023 a tender was issued for a contractor to undertake grass cutting in our
new build estates, however the process was unsuccessful resulting in ad hoc
agreements to maintain the open spaces. It is intended that this will be
retendered later this year to allow a contract to be in place for financial year
2025/26. A heading within this appendix is Miscellaneous with a total spend of
£283K with no specific budget allocated here. Within this heading large items
of spend included Energy Performance Certificates and EESSH Stock
analysis which was part of our programme to help identify what works are
required to meet the regulatory standard, damp and mould surveys to
understand what works were required to properties where issues were raised
by tenants and works to bring the properties at Pinegrove, Elgin back into use.
Moving forward these items will be allocated to existing budgets or as
appropriate revised budget lines prepared. 
3.6 APPENDIX IV shows the expenditure on Cyclical maintenance. Spend was
£707K to 31 March 2024 which equated to an underspend of £628K. The
majority of this underspend was on PPR & External Painter work. This was
due to a contractor not being able to be secured to take this programme
forward and the weather. The DLO are currently working to resolve this and a
rolling programme for works across the entire Moray area is now in place. 
3.7  APPENDIX V shows the planned maintenance and other investments split
between revenue and capital spend. Overall, the spend was £6,987K to 31
March 2024 which is a significant underspend of £7,683K. The majority of this
underspend has been on the capital upgrades with issues around internal
resource, procurement and external resource all effecting the ability for
delivery. An area where spend was focused was on the replacement of
heating systems where an overspend of £704k was permitted to increase the
delivery, however it is acknowledged that this increased delivery is in part due
to the aging profile of the heating systems within the stock. 
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3.8 APPENDIX VI shows the income and expenditure for Private Sector Housing
position with regard to grant expenditure for Private Sector Housing Grant to
31 March 2024.   
The legally committed figure in Category C of 113k represents 100% of the
allocated budget. Spend to 31 March 2024 was £62k which represents 54.8%
of the allocated budget. 
HOUSING INVESTMENT PLAN  2024/25 UPDATE
3.9 This Committee on 7 May 2024 approved a report titled Housing Investment
2024/25 (paragraph 9 of the Minute refers) which highlighted the level of
performance in relation to Scottish Housing Quality Standards (SHQS) and
Energy Efficiency Standard for Social Housing (EESSH), as well as the
intended improvement actions to speed up improvement in compliance with
these standards. 
3.10 The SHQS Compliance Improvement Plan outlined the actions that were to be
undertaken over the coming 12 months to reach a target of 90% compliance.
Since the report presented on 7 May 2024, significant work has been
undertaken to progress the improvement plan. Specifically, programmes of
remedial/improvement works across all housing management areas have
been developed. Works have commenced in areas through various
contractors including the Council’s ‘in house ‘Building Services (DLO). The
works being undertaken to ensure compliance with SHQS include insulation
(internal and external wall and also loft top up), heating upgrades including
installation of no carbon burning heat sources with solar photovoltac panels,
kitchen and bathroom upgrades and some window replacements. The focus
for the programme is to ensure compliance with SHQS however information
gathered during this process will also help focus programmes of works for
future years. 
3.11 On top of the energy efficiency measures, the other significant compliance
matter is the full compliance with electrical certification (EICRs). Work is
continuing to undertake the checks across the portfolio with work being
undertaken by the DLO and supported by a number of external contractors.
As at the end of June SHQS compliance is at 23% and increase of 8% from
the year end position. With a target of 90% compliance by 31 March 2024. 
4. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
The maintenance of the Council’s housing stock and dealing with
homelessness are priorities identified within the Corporate Plan, the
Council’s Local Housing Strategy, the Strategic Housing Investment Plan
(SHIP) and the Housing and Property Service Plan. 
(b) Policy and Legal
Maintenance and improvement works are carried out in order to meet
statutory legal requirements and in accordance with current relevant
policies. 
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(c) Financial implications
The financial implications associated within this report are dealt with in
paragraphs 3.1 to 3.11 above, with details of the Council house new
build programme now being the subject of a separate monitoring report. 
(d) Risk implications
Failure to expend agreed budgets may affect the Council’s ability to
maintain stock at the SHQS, replace life expired elements and attain the
EESSH.  Budget Managers are aware of responsibilities for managing
budget allocations and approval for variance will be sought from
Committee in line with the Financial Regulations. 
(e) Staffing implications
There are no staffing implications within this report. 
(f) Property
The improvement and maintenance of the housing stock will ensure that
it remains sustainable in the longer term both physically and
environmentally. 
(g) Equalities/Socio Economic Impact
There are no equalities issues associated with this report, as it is to
inform the Committee on budget monitoring. 
(h)   Climate Change and Biodiversity Impacts
The continued investment in the Council Owned Housing Stock identified
in this report will assist the Council to achieve its climate change targets
by utilising a range of energy saving measures that incorporate zero or
low carbon into design, construction materials and systems that support
the Council in achieving The Energy Efficiency Standard for Social
Housing (EESSH). It is anticipated that by 31 March 2025 over 90% of
the Council’s housing stock will have an EPC rating of C or higher. 
(i) Consultations
Consultations have taken place with the Head of Housing and Property
Services, Building Services Manager, Legal Services Manager,
Accountant (Alistair Milne), Committee Services Officer (Lissa Rowan),
and Home Improvement Services Manager, who all agree with the
sections of the report relating to their areas of responsibility.   
5. CONCLUSION 
5.1 The report provides details of the financial outturn for 2023/24 for the
Housing Investment Plan, highlighting the Councils progress in respect
of Housing investment for both the Council’s housing stock and the
private sector. The report also highlights the significant challenges
ahead to ensure that the Council’s housing stock meets and sustains
the tolerable standards required to comply with Scottish Government
and Scottish Housing Regulator (SHR) requirements. 
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Author of Report: Neil Strachan, Property Asset Manager 
Background Papers:   Held on file/sharepoint
Ref:    SPMAN-1285234812-1632
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Item 6
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(all amounts in £'000)
RESPONSE AND VOIDS REPAIRS
Annual Budget
2023/24
Expenditure plus
commitments to date
%
expendituere plus
committed to date
Budget balance
West Area 1,428 1,289 90% 139
East Area 1,114 1,171 105% -57
Central Area 0 828 0% -828
Void House Repairs 1,459 2,137 146% -678
Gas Heating Repairs 618 486 79% 132
4,619 5,911 128% -1,292
31 March 2024
INVESTMENT PROGRAMME EXPENDITURE 2023/24
Item 6
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APPENDIX III
(all amounts in £'000)
ESTATE WORKS
Annual Budget
2023/24
Expenditure plus
commitments to date
%
Budget spent to
date
Budget balance
Garage Upgrades 26 2 8% 24
Asbestos 371 146 39% 225
Landscape Maintenance 87 159 183% -72
Estates/Forum Upgrades 230 328 143% -98
Miscellaneous 0 283 0% -283
714 918 129% -204
31 March 2024
INVESTMENT PROGRAMME EXPENDITURE 2023/24
Item 6
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Item 6
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Item 6
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Item 6
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REPORT TO: HOUSING AND COMMUNITY SAFETY COMMITTEE ON 10
SPETEMBER 2024 
SUBJECT: MORAY AFFORDABLE HOUSING INVESTMENT PROGRAMME 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 To inform the Committee of progress on the Affordable Housing Investment
Programme in Moray.   
1.2 This report is submitted to Committee in terms of Section III G (10) of the
Council's Scheme of Administration relating to the preparation and
implementation of strategic housing plans. 
2. RECOMMENDATION 
2.1 It is recommended that the Committee:- 
i) notes the resource planning assumption received from the
Scottish Government; 
ii) notes the outcomes from the engagement with partners and
stakeholders in the Investment Programme; and 
iii) approves the prioritisation detailed at Appendix I. 
3. BACKGROUND 
3.1 The Council receives an annual resource planning assumption (RPA) from
the Scottish Government’s More Homes Division to fund the supply of new
affordable housing in Moray. The Council’s Strategic Housing Investment
Plan (SHIP) determines how this funding will be used to plan and deliver the
affordable housing priorities of the Local Housing Strategy. The investment
and project priorities set out in the SHIP form the basis of an annual
Strategic Local Programme Agreement (SLP) between the Council and the
Scottish Government. The SLP details the projects that will be funded during
the year, the affordable housing developers who will deliver them, the targets
for grant expenditure and the milestones by which progress on delivery will
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be measured. The Council and Registered Social Landlords (RSLs) are the
principal developers of affordable housing in Moray. 
3.2 On 21 November 2023, this Committee approved the Council’s SHIP (para 9
of the Minute refers). 
3.3 On 13 February 2024, this Committee was advised of the likelihood that the
previously advised RPA would be reduced for 2024/25 (para 9 of the Minute
refers) and agreed a rationale for reprioritisation and reprofiling of projects
anticipated to start during 2024/25/26. The agreed priorities are: 
• corporate and strategically important projects, i.e. Bilbohall; Speyview,
Aberlour;
• supported housing for people with learning disabilities i.e. Woodview2,
Lhanbryde; Western Village, Elgin South;
• Growth Deal and Levelling Up Fund Housing Mix Project developments
i.e. South Street/High Street, Elgin; Dallas Dhu, Forres;
• NHS key worker housing, to be agreed following the publication of NHS
Housing Need Assessment currently in development; and
• Open market acquisition of long-term empty homes. 
3.4 On 7 May 2024, this Committee was advised that, as anticipated, the RPA
for 2024/25 had been substantially reduced to £6.556m (para 10 of the draft
Minute refers). 
4. MORAY STRATEGIC LOCAL PROGRAMME (SLP) 
Resource Planning Assumption 2024/25 (RPA)
4.1 On 28 March 2024, Moray Council received notification of the RPA for
2024/25, i.e. £6.556m. This RPA is reduced from that expected and detailed
in Para 3.2 above but is consistent with reductions in RPA across Scotland
following the Scottish Government budget announcement on 19 December
2023.   
4.2 On 22 May 2024 the Scottish Government advised that the RPA had been
increased slightly to £6.758m for 2024/25. There is no indication of RPA for
2025/26 or beyond.   
4.3 At the time of writing, the distribution of the funds announced by the First
Minister on 26 April 2024, i.e. additional £80m over two years, had not been
announced.  It is understood that these additional funds are to be used for
open market purchases only, not new build development.  
4.4 The following tables illustrate the affordable housing programme where
construction has already commenced, or where the project fits with the
prioritisation previously agreed, and where the 2024/25 RPA has not been
exceeded: 
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Currently under construction 
Site Town No of
units Landlord Completion
date (est)
Banff Road Phase 2 Keith 26 Moray Council Feb 2025
Kineddar Meadows Lossiemouth 10 Osprey Housing Sep 2025
Speyview Phase 1 Aberlour 39 Moray Council Jun 2025
Findrassie Ph2b Elgin 16 Grampian HA Jan 2026
Western Village, Elgin
South Elgin 44 Grampian HA Jan 2026
Total 135   
Site start expected during 2024/25 
Site Town No of
units Landlord Site start
(est)
High St/ South St
redevelopment Elgin 38 Places for
People Nov 2024
Bilbohall Phase 1 (R2) Elgin TBC Moray Council TBC
Total TBC   
4.5 Officers completed programme of engagement with partners and
stakeholders key to the delivery of the affordable housing programme, to
discuss the implications for them of the reduced RPA and uncertainty
regarding future years.   
4.6 In summary, through this engagement programme, it has become clear that
there are some conflicting priorities competing for a finite amount of funding,
but where potential solutions could be a combination of: 
• determining organisations’ capacity to front fund development, i.e.
consider the increased borrowing costs until Scottish Government grant
can be accessed;
• phasing/rephasing of development; and 
• considering alternative sources of funding. 
4.7 The detail of how each development previously planned to start during
2024/25 and 2025/26 are potentially impacted along with the outcomes from
those engagement discussions are set out in APPENDIX I.   
4.8 Officers will continue to maintain a substantial shadow programme of
developments. Should additional grant funding become available, officers will
be able to bring a project(s) forward from the shadow programme, in
accordance with the priorities agreed by this Committee in May 2024 (para
10 of the draft Minute refers) and set out in Para 3.3 above.   
4.9 Progress on programme delivery will be reported to this Committee on a
biannual basis. 
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5. BILBOHALL 
5.1 The R7 site which forms part of the Bilbohall Masterplan (formerly The Firs),
is not part of the planning application currently under consideration. 
However, the existing buildings at The Firs continue to attract antisocial
behaviour and vandalism. The site has been secured with Heras fencing, but
occasional antisocial behaviour has caused nuisance to the neighbouring
homeowners at Fairfield Avenue. 
5.2 Officers have instructed the Bilbohall design team to develop a feasibility
study providing options for development. This feasibility study has provided 5
options which include a combination of retention/demolition of some/all of the
existing buildings, and retention of the existing road/development of the
consented new road through the site. 
5.3 In December 2023, officers included redevelopment of The Firs in options
presented to NHS Grampian to meet their key worker housing need.   
5.4 Officers intend to survey the existing buildings in more detail, complete a
value for money assessment of these options by the end of 2024. 
6. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP) 
Addressing the shortage of affordable housing in Moray is a key priority
of the Corporate Plan and 10 Year Plan, the Council’s Local Housing
Strategy and Strategic Housing Investment Plan (SHIP) and the
Housing and Property Service Plan. The Strategic Local Programme
reflects priorities for investment in the provision of new affordable
housing to meet need identified in the Local Housing Strategy. 
The affordable housing programme supports the aims of the 10 Year
Plan by providing new affordable housing for an increasing population
and a growing and diversifying economy. The target of 50 Council
house completions per annum will be delivered within the investment
planning and funding framework provided by the programme. 
(b) Policy and Legal 
The affordable housing supply programme contributes to meeting the
Council’s statutory duties to address homelessness and meet housing
need in Moray. 
(c) Financial implications 
The report provides details of the resources being made available by
the Scottish Government to part-fund affordable housing in Moray. The
Council has agreed that 50 new council houses will be built per annum.
The current HRA Business Plan has made provision for the level of
borrowing required to part-fund the Council’s housebuilding
programme. The Housing Service intends to complete a further review
of the HRA Business Plan by Dec 2024. 
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(d) Risk Implications
The lack of RPA beyond 2024/25 is a significant risk to larger
developments where construction costs may extend beyond one
financial year. Moray Council and RSL Boards may be unable to
commit to a project if the Scottish Government funding commitment is
unconfirmed. 
There is a risk that slippage or reduction in the programme will result in
loss of Scottish Government More Homes Division grant funding to
Moray, with the funds diverted to other LAs.   
The programme may be impacted by economic and market conditions
and site-specific issues as developments proceed. In particular, interest
rates and potential front funding will impact on the cost of development. 
There are processes in place to manage these risks and mitigations
considered. 
(e) Staffing Implications 
There are no staffing implications arising from this report. 
(f) Property
The report details the ongoing programme for development of additional
affordable housing in Moray in response to strategic needs and
specifically the Council new build programme to increase the Council’s
own supply of affordable housing. 
(g) Equalities/Socio Economic Impact 
The housing needs of equalities groups are identified in the Local
Housing Strategy (LHS). The Moray Affordable Housing Programme
seeks to deliver the housing priorities identified in the LHS. 
(h) Climate Change and Biodiversity Impacts
The aims of the affordable housing programme are closely aligned to
the Council’s Climate Change Strategy, and Local Heat and Energy
Efficiency Strategy (LHEES). 
(i) Consultations 
This report has been subject to consultation with the Depute Chief
Executive (Economy, Environment and Finance), the Head of Housing
and Property Services, Legal Services Senior Solicitor (Georgina
Anderson), the Property Asset Manager, the Head of Economic Growth
and Development, the Strategic Planning and Development Manager,
the Chief Financial Officer and Committee Services Officer (Lissa
Rowan,). 
7. CONCLUSIONS 
7.1 The report provides details of an update on the current and future
affordable housing investment programme, including the recently
revised Resource Planning Assumption for 2024/25.  The report
provides a summary of a series of stakeholder engagement
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discussions with details of the implications for individual
developments presented in APPENDIX I. 
Author of Report: Fiona Geddes, Housing Strategy and Development
Manager
Background Papers: with author
Ref: SPMAN-1285234812-1597
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Page 1
Moray Affordable Housing Programme APPENDIX I
Revised Delivery programme 2024/25–2025/26
Development Priority
category
No of
units
Social
Landlord
Existing
SHIP
site
start
Revised
funding
availability
Issues
Banff Road,
Keith Phase 2
On site  26 Moray
Council
2023/24 On site Construction underway therefore SG funding is
committed.  Completion anticipated February 2025.
Kinneddar
Meadows,
Lossiemouth
On site 10 Osprey
Housing
2024/25 2024/25 Construction underway therefore SG funding is
committed.  
Speyview
Phase 1
Growth Deal/
Location/
Deliverability
39/
31
Moray
Council
2024/25 2024/25 SG funding already formalised prior to amended RPA
notification.  SG funding commitment will extend across
2024/25 and 2025/26.  SG funding has already been
formalised for Phase 2 land acquisition.  Economies could
be achieved through construction of both phases running
consecutively, but this may require HRA front funding if
SG funding is not available in 2025/26.
Western Village,
Elgin South
LD supported
housing/
Deliverability
44 Grampian
HA
2024/25 2024/25 SG funding commitment given via agreed Strategic Local
Programme dated July 2023. Planning application
determination pending.  Site start anticipated in June
2024.  SG funding commitment will extend across
2024/25 and 2025/26.  GHA will provide some front
funding during 2024/25 until 2025/26 SG grant allocation
becomes available.
High Street/
South Street,
Elgin
redevelopment
Growth
Deal/Levelling
Up Fund/
deliverability
38 Places
for
People
2024/25 2026/27 The Levelling Up Fund must be spent by March 2026. 
Potential for site start during 2024/25 remains as GD
funds can be accessed initially, with an element of RSL
front funding thereafter, until SG grant becomes available
in 2026/27.  This development was one option presented
Item 7
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Page 2
Development Priority
category
No of
units
Social
Landlord
Existing
SHIP
site
start
Revised
funding
availability
Issues
to NHS Grampian in December 2023 to meet their key
worker need.
Bilbohall, Elgin Corporate
priority
106 Moray
Council
2024/25 2025/26 Planning application determination pending.  Forthcoming
HRA Business Plan review due by November 2024 will
assess the potential for HRA to front fund construction,
pending draw down of grant, possibly over 4+ years.  To
draw down grant over a shorter term could compromise
ability to fund other projects, i.e. High Street/South Street,
Elgin.
Garmouth Rd,
Lhanbryde
(Woodview2)
LD supported
housing
30 Grampian
HA
2024/25 2026/27 at
the earliest
Provision for LD Supported Housing is a key action in the
LHS and SHIP.  LD housing has recently been
reassessed through the HNDA 2023.  GHA have recently
completed a tender exercise to procure a contractor.  To
provide grant funding sooner than 2026/27 could
compromise funding available other projects i.e. High
Street/South Street, Elgin and Bilbohall.  Phasing delivery
options and alternative means of providing subsidy to
GHA could be explored to allow earlier site start.  
Speyview
Phase 2
Growth Deal/
Location/
Deliverability
31 Moray
Council
2025/26 2027/28 Economies could be achieved through construction of
both phases running consecutively.  Potential to bring site
start forward to 2025/26, but this may require HRA front
funding if SG funding is not available.  Committing SG
funding to this project could compromise ability to fund
other projects. 
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REPORT TO: HOUSING AND COMMUNITY SAFETY COMMITTEE ON 10
SEPTEMBER 2024 
SUBJECT: SCOTTISH SOCIAL HOUSING CHARTER COMPLIANCE 
BY:  DEPUTE CHIEF EXECUTIVE 
(ECONOMY, ENVIRONMENT AND FINANCE) 
1. REASON FOR REPORT 
1.1 To inform the Committee of compliance with the Scottish Social Housing
Charter and the Scottish Housing Regulator’s Regulatory Framework. 
1.2 This report is submitted to Committee in terms of Section III (G) (13) of the
Council's Scheme of Administration relating to the Council’s performance
management framework. 
2. RECOMMENDATION 
2.1 It is recommended that the Housing and Community Safety Committee: 
(i) Considers and approves the draft assurance statement in
APPENDIX I; and 
(ii) Notes that a summary of performance on the key Annual Return
on the Charter (ARC) indicators against national/benchmarking
results will be presented to the Committee on 19 November 2024. 
3. BACKGROUND 
3.1 The Scottish Social Housing Charter came into force on 1 April 2012.  The
aim of the Charter is to improve the quality and value of the services provided
by social landlords.  The Charter sets out the minimum standards and
outcomes that tenants can expect from their landlord. 
3.2 Each year, social landlords must submit an Annual Return on the Charter
(ARC) to the Scottish Housing Regulator (SHR).  Using a range of
performance indicators, the SHR monitors, and assesses landlords’
performance against the Charter.  To meet regulatory requirements, social
landlords must submit an assurance statement to the SHR and publish a
performance report for tenants and service users by 31 October each year. 
Item 8
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4. SCOTTISH SOCIAL HOUSING CHARTER COMPLIANCE 
Annual Return on the Charter
4.1 The Scottish Housing Regulator (SHR) requires landlords to monitor progress
against the outcomes and standards of the Scottish Social Housing Charter.
The Council’s Annual Return on the Charter (ARC) was submitted in May
2024. 
Assurance Statement
4.2 The SHR requires social housing landlords to submit an assurance statement
between April and October each year.  This assures the SHR and
tenants/service users that the Housing Service complies with regulatory and
statutory obligations.  Landlords must notify the SHR of any material changes
in their level of assurance during the year. 
4.3 The statement must be made by the landlord’s governing body or relevant
committee and be available to tenants and other service users.  The
statement forms the basis of the SHR’s risk assessment and level of
engagement with the landlord.  The statement must: 
• confirm the landlord meets all of the relevant requirements set out in its
regulatory framework which can be found online at
www.housingregulator.gov.scot/for-landlords/regulatory-framework;
• set out any areas of material non-compliance and describe
improvement actions and timeframes for these;
• confirm that appropriate evidence has been considered to support the
level of assurance given by the governing body or Committee; and
• confirm the date of the meeting of the governing body or Committee. 
4.4 In reaching a decision about non-compliance, the Committee must decide
whether the issue is material.  The Committee should consider whether an
issue:
• seriously affects the interests and safety of tenants or other service
users;
• threatens the stability, efficient running or viability of service delivery
arrangements; or
• brings the landlord into disrepute or raises public or stakeholder
concern about the organisation or the social housing sector. 
4.5 On 26 March 2024, the SHR wrote to landlords to provide advice on the
preparation of the Assurance Statement, in 2024.  The SHR have requested
that landlords confirm whether they meet all duties in relation to specific areas
of tenant and resident safety and that they have obtained appropriate
assurance about compliance with all relevant safety requirements.  A draft
Assurance Statement (APPENDIX I) has been prepared for the Committee to
consider and approve.   
4.6 The SHR will consider both the ARC results and the assurance statement as
part of their risk assessment process to decide whether they need further
information or assurance.  They will then publish an engagement plan for
each social landlord by 31 March 2025.   
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Annual Performance Report
4.7 Social landlords must also produce an annual report on their performance for
tenants and other service users by 31 October each year.  The report sets out
how they are achieving or progressing towards the outcomes and standards
of the Charter.   
4.8 The SHR expects the report to be developed in partnership with tenants and
service users, rather than exclusively by the Council.  Information about the
development of the report was included within the Summer Tenants’ Voice
newsletter and was included on the agenda of the Moray Tenants’ Forum
meeting on 27th August 2024.   
4.9 The SHR will publish the national results for all social landlords on 31 August
2024.  The availability of the national data forms an essential part of the
development of the annual performance report for 2023/24.  The timing of this
did not fit with the deadlines for today’s meeting.  However, a summary of the
Council’s performance on key ARC indicators will be presented to this
Committee on 19 November 2024, along with a copy of the finalised annual
performance report.   
5. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
The monitoring and management of performance assists the Council to
continue to improve its housing services and manage assets effectively
to provide the best outcomes for tenants and other service users.  This
contributes towards meeting the actions, outcomes and priorities within
the Corporate Plan and the Housing and Property Service Plan. 
(b) Policy and Legal
Reporting on Scottish Social Housing Charter performance indicators is
a legal requirement under the Housing (Scotland) Act 2010.   
(c) Financial implications
There are no financial implications arising directly from this report.  Any
costs associated with implementing improvements will be met from
within existing budgets. 
(d) Risk Implications
The annual assurance statement and annual performance report are
requirements under the Scottish Housing Regulator’s Regulatory
Framework.  In addition, tenants and service users must be provided
with meaningful opportunities to participate in the management of their
homes and decision-making processes.  Failure to meet these
requirements presents a regulatory risk. 
(e) Staffing Implications
There are no staffing implications arising directly from this report.   
(f) Property
There are no property implications arising directly from this report.  
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(g) Equalities/Socio Economic Impact
There are no equalities implications directly arising from this report. The
Housing Service is working towards compliance on recently published guidance
from the Scottish Federation of Housing Associations relating to equalities. 
(h) Climate Change and Biodiversity Impacts
The service delivery aims of the Housing Service are closely aligned to
the Council’s Climate Change Strategy, and Local Heat and Energy
Efficiency Strategy (LHEES). 
(i) Consultations
Consultation on this report has been carried out with the Head of
Housing and Property, senior managers within the Housing and
Property Service, Legal Services Senior Solicitor (Georgina Anderson) ,
Research and Information Officer (Christopher Dewhurst), Customer
Engagement Officer and Committee Services Officer (Lissa Rowan). 
Their comments, where relevant to their areas of responsibility, have
been incorporated in this report. 
6. CONCLUSION 
6.1 This report provides the Committee with an update on the Council’s
compliance with the Scottish Social Housing Charter and Regulatory
Framework and asks the Committee to consider and approve the draft
assurance statement for submission to the Scottish Housing Regulator.   
Author of Report:  Martin Gray, Senior Housing Officer (Information) 
Background Papers: With author
Ref: SPMAN-1285234812-1629 
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Moray Council Housing and Property Service
Assurance Statement 
We comply with the regulatory requirements set out in Section 3 of the Scottish Housing Regulator’s
Regulatory Framework, with the exception of the areas set out below.
We achieve all but the following outcomes and standards in the Scottish Social Housing Charter:
QUALITY OF HOUSING
Moray Council generally performs well as a landlord across the range of benchmarked performance
indicators, there is an identified need for improvement in relation to Scottish Housing Quality
Standard (SHQS) and Energy Efficiency Standard for Social Housing (EESSH).
At the Housing and Community Safety Committee on 7 May 2024, an ambitious improvement action
plan was approved.  It illustrated the route to increasing investment delivery to ensure improved
compliance.  The Improvement Plan includes a target of 90% SHQS compliance by the end of the
reporting year.  This is inclusive of an approved £19m Planned Maintenance and Investment
Programs budget.
SHQS Compliance
Of the 6,380 Moray Council residential properties, 1,444 fully complied (22.6%) with the SHQS.  The
main areas of non-compliance were:
• Electrical Safety
• Energy Efficiency 
Following the 2021/22 ARC submission, the SHR invited landlords in late July 2022 to reassess their
SHQS compliance regarding electrical inspections. After reviewing the Council's position, we
informed the SHR that most of our properties fell below the required electrical testing standard. This
significantly impacted our SHQS compliance, resulting in only 6.3% of properties meeting the SHQS
as of 31 March 2022. We took immediate action to address this by allocating additional investment.
As of 31 March 2024, 1,444 out of 6,380 properties (22.3%) meet the Scottish Housing Quality
Standard (SHQS).  Of the 4,936 that are non-compliant, a large proportion fail for electrical safety
only (2,994 properties), with the next largest group failing for energy efficiency related issues.
EESSH 
The second key component of SHQS which requires improvement is energy efficiency. As at 31
March 2024, 4,150 properties (65%) of our stock met EESSH.  An improvement plan has been
developed to accelerate delivery of energy efficiency programs, which will significantly improve this
position.
Damp and Mould
The Moray Council Housing and Community Safety Committee addressed the rise in dampness and
mould in council houses. Measures include external and internal wall insulation, ventilation systems,
and monitoring devices. A 2023 working group has revised procedures to prioritise inspections and
remedial actions, focusing on vulnerable tenants. Over 250 properties received remedial works in
Item 8
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2023, and future measures will target at-risk properties. Continuous improvements aim to meet the
SHQS and enhance living conditions for tenants. 
Tenant and Resident Safety 
Electrical Safety 
By 31 March 2024, we had conducted 2,277 Electrical Installation Condition Reports (EICR) and
brought 35.7% of properties up to a satisfactory standard.  Additionally, 601 properties have
undergone an EICR and scheduled for remedial works.  All identified C1 faults (most critical) were
rectified immediately, with none remaining unresolved.
As of 1 February 2024, two additional contractors were appointed to support Moray Council’s
electrical safety testing program.  This followed a lengthy procurement process that required
retendering because the local market lacked sufficient capacity to undertake the task.  A monthly
update is provided to the Regulator to advise on the progress on this matter.
Landlord Gas Safety
Two gas service failures regrettably occurred in 2023/24 out of 5,996 annual gas safety checks
carried out.  Both were the result of human errors in recording, with lessons learned on both
occasions and procedures/training updated.
Furthermore, assessment is underway for an alternative servicing management and record keeping
software solution with more rigorous control measures to further reduce the possibility of future
errors.
Fire and Carbon Monoxide Detection
At 31 March 2024, 99.4% of our properties are compliant with the updated Fire Safety Regulations.
Of the 35 properties that are not compliant, 7 are long term voids. Where there are issues gaining
access, we will use our legal right to force entry to the property as a last resort under our No Access
Policy to carry out works associated with our statutory safety requirements.
All our properties (where required) are adequately equipped with CO detection devices and comply
with the Housing (Scotland) Act 1987 (Tolerable Standard) (Extension of Criteria) Amendment Order
2021.  
Lift Safety 
We only have one sheltered housing complex with a lift which is included on a cyclical maintenance
contract to ensure that it complies with relevant legislation.
Asbestos 
We continue to maintain an asbestos register and carry out a risk assessment before work
commences in properties.  Progression has been made to phase out cloned asbestos surveys so that
we have full surveys available for all of our properties.  We are reviewing our asbestos procedure
and are implementing an Asbestos module that will provide staff with electronic access to
information on Asbestos Containing Materials (ACM) within properties. 
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Reinforced Autoclaved Aerated Concrete (RAAC)
After conducting a thorough desktop review and a limited physical inspection of our housing stock
on those properties identified as fitting the profile, we have determined that there is no presence of
RAAC within any of our residential properties. This conclusion is based on the available data and the
results of the inspections carried out, ensuring that our housing stock does not include this material,
which is known for its structural weaknesses. 
Legionella Risk Assessment
We routinely conduct legionella risk assessments on our vacant properties, actively working to
reduce risks by removing dead legs in the plumbing systems. The exception to this practice is with
newly installed mandatory wet sprinkler systems, where the risk of legionella has been assessed as
low and the benefits of these systems outweigh the potential risk.
Health and Safety Executive Reportable Events
Unfortunately, there were four notifiable events reported to the Health and Safety Executive (HSE)
under the Reporting of Injuries, Diseases, and Dangerous Occurrences Regulations (RIDDOR). Three
involved tradesperson-related injuries with no danger posed to tenants, while the fourth concerned
a gas boiler installation fitted by an external contractor.  The property was capped and made safe as
soon as the issue was discovered, and the contractor asked to undertake the necessary remedial
work.
Housing and Homelessness
The total number of homeless households to whom the local authority has a statutory duty to
secure permanent accommodation remained at the same level as last year with 415 households. 
Local RSL’s remained taking a low percentage of the burden at only 15.18% (15.66% - 2022/23). 
New nomination agreements have almost all been agreed and local RSLs are submitting quarterly
returns to Moray Council to monitor their direct homeless lets and applications.
Unsuitable Accommodation Order
During 2023/24 there were 25 households breaching the Unsuitable Accommodations Order.  This
was a direct result of a further increase in homeless presentations from 562 in 2022/23 into 584 in
2023/24.  This was further exacerbated by the lack of new supply of council housing.
Temporary Accommodation Standards Framework
We are working towards compliance with the new guidance/framework.  Most of our properties
satisfy each of the criteria apart from digital inclusion.  However, tenants have access to Moray
Council information hubs and our main reception which all provide free internet access.
Equality and Human Rights
We continue to work towards compliance on the guidance on equalities published by the SFHA in
2023.  We have been unable to fully implement system changes due to conflicting definitions on
some of the protected characteristics which would affect the Scottish Government’s homeless data
collections.  The Government has indicated that they will not review this until at least 2025.   
Integrated Impact Assessments are conducted during the development of all new policies and
strategies. By systematically analysing these impacts and monitoring these protected characteristics,
we ensure that our policies and strategies promote positive outcomes, mitigate any negative
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consequences, and align with our Local Outcome Improvement Plan and Corporate Plan, and their
Equality Outcomes. 
Gypsy/Travellers 
Moray Council does not currently operate any official gypsy/traveller sites. However, we have
established a local protocol for managing unauthorised encampments, which ensures that the needs
of both the encampment residents and the broader community are met. This protocol is supported
by our dedicated unauthorised encampments officer, who oversees the process and provides
necessary assistance and support.
We approved our Assurance Statement on __________________ and sign this statement on behalf
of the Housing and Community Safety Committee. 
Councillor Amber Dunbar     Councillor Donald Gatt
Chair of Housing and Community Safety  Depute Chair of Housing and Community Safety
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REPORT TO: HOUSING AND COMMUNITY SAFETY COMMITTEE ON 10
SEPTEMBER 2024 
SUBJECT: GRASS CUTTING SCHEME REVIEW 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 This report advises the Housing and Community Safety Committee of the
need to review and revise the Grass Cutting Scheme and seeks permission to
consult with key stakeholders. 
1.2 This report is submitted to Committee in terms of Section III (G) (3) of the
Council's Scheme of Administration relating to  carrying out the management
and maintenance of the Council's housing stock. 
2. RECOMMENDATION 
2.1 It is recommended that the Housing and Community Safety Committee:- 
(i) notes the requirement to review the Grass Cutting Scheme; 
(ii) considers and approves the revised draft Grass Cutting Scheme,
as set out in APPENDIX I and Section 5, for consultation; and 
(iii) agrees that a consultation on the revised draft Grass Cutting
Scheme is undertaken with key stakeholders, as set out in Section
6. 
3. BACKGROUND 
3.1 Council tenants are required under the terms and conditions set out in the
Scottish secure tenancy (SST) agreement to take reasonable care to keep
their garden from becoming overgrown, untidy or causing a nuisance unless
the Service has agreed to take care of it.  The Housing Service has a
responsibility for monitoring the condition of tenants’ gardens and has
procedures in place with enforcement action for use where deemed
necessary.  This can include undertaking the work and recharging the tenant. 
Item 9
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3.2 In recognition that some Council tenants are considered medically unfit to cut
their grass, a Council Grass Cutting Scheme was established and agreed by
the Community Services Committee on 7 April 2004 (Paragraph 9 of the
Minute refers).   
3.3 The eligibility criteria for the Grass Cutting Scheme was set as follows, which
is broadly similar to other local authorities.  Tenants must be:
• aged 65 or over with no physically able adults aged 18-64 in the
household;
• under 65 and in receipt of any physical or mental health related benefit
such as Personal Independence Payment (PIP), Disability Living
Allowance (DLA), Adult Disability Payment (ADP), Attendance Allowance,
Employment and Support Allowance (ESA); 
• registered blind; or
• any age who, due to ‘vulnerability’, would not be capable of cutting grass. 
3.4 The Scheme is currently:
• funded by the Housing Revenue Account (HRA) and is provided free of
charge to qualifying applicants who are in receipt of any amount of
Housing Benefit (HB) or the housing element of Universal Credit (UC). 
Those not in receipt of HB / UC are liable for full payment, which is
currently approximately £65 per year.
• delivered by Open Spaces who provide 15 cuts per year, during April and
October. It does not include grass lifting, sweeping or other gardening
work which would increase the requires costs and resources significantly. 
3.5 Following analysis of budgets and consultation with Open Spaces, it has been
identified that the amount Open Spaces charge the Housing Service is not
equivalent to the actual cost of providing the grass cutting service.  Effectively,
Open Spaces have been significantly subsidising the service. 
• 2023/24 - the cost of the service to the HRA was £88,617, which equated
to £10.46 per cut. The actual cost of delivering the service is equivalent to
£24.88 per cut. 
• 2024/25 - An interim agreement is in place where the Housing Service will
charge £17.30 per cut, totalling £181,650 and Open Spaces will only
charge for time attended to cut the grass.  This allows time to review and
streamline the Scheme and implement necessary improvements while still
providing a cost-effective service to tenants which remains below the
market rate and minimising the pressure on the HRA. 
3.6 From 1 April 2025, Open Spaces have advised the Housing Service will be
charged the full cost associated with the delivery of the grass cutting service.
Based on the number of tenants currently receiving the service, the cost to the
HRA is expected to be a minimum of £244,819, excluding any inflationary
increase, which is currently unbudgeted projected spend. A summary is
provided below for ease of reference:
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Year  Cost per cut Annual cost
to tenant –
full cost
recovery
Annual cost to MC *
based on no. of current tenants
on list
2023/24 £10.46 £65 £109,830
2024/25 £17.30 £65 £181,650
2025/26 £24.88 +
inflationary
increase 
£373.20+
inflationary
increase
£244,819 + inflationary
increase and on-costs 
4.      SUMMARY OF REVIEW 
4.1 Officers have carried out a thorough review of the Grass Cutting Scheme,
identifying some key issues which, once resolved provide the potential to
improve the scheme and alleviate any pressure on the HRA. 
Data & monitoring for the current Scheme 
4.2 The limited data available evidences that at the time of review there were 656 
people (9% of all tenants) on the grass cutting list.  Of these:
• 283 (43.14%) were over 65.
• 372 (56.71%) were below 65.
• 68 are recorded as having a disability. 
• Approximately 403 tenants (61.43% of those on the Scheme) were in
receipt of HB / UC benefit payments (this figure fluctuates due to the
nature of benefit payments) and currently receive a free service.
• Due to the current eligibility criteria at 3.3 above, only around
approximately 87 tenants (14%) were eligible to be charged for the
service. It should be noted there can be circumstances when a charge is
not made, e.g. due to an executry. This reduced the number of tenants
who actually received an invoice for re-charge to approximately 47
tenants, 8% of those on the list.
• Limited data is held on the eligibility criteria due to concerns by staff
regarding data protection and GDPR.
• Limited or no monitoring /review of tenants on the scheme to assess if
service still required or meet criteria.
• Problematic cross-referencing and invoicing process between Open
Spaces and Housing. 
Open Spaces Consultation:
4.3 The following issues were raised in consultation with the Council’s in-house 
contractor, Open Spaces:
• Any reduction in the number of cuts per year will cause other operational
issues for Open Spaces around overgrown grass, longer timings needed,
higher risk to machinery when cutting, more tenant dissatisfaction issues
which minimises any efficiency savings.
• Changes to the Scheme and the number of households receiving the
service will have cost and resourcing issues for Open Spaces.  The 
extent of this will be dependent on the changes implemented.
• There is no scope to increase numbers on list due to current Open
Spaces resources. 
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5. PROPOSED REVISIONS TO SCHEME 
5.1 Following a detailed options appraisal, internal consultation with relevant
stakeholders and in line with the associated Integrated Impact Assessment
(IIA) APPENDIX II, Officers propose the following revisions to the eligibility
criteria:
• Removing age from the eligibility criteria and focus on capability, as age
does not accurately represent tenants’ physical or mental ability to carry
out the task.
• Apply criteria where the tenant must have a recognised long-term illness or
disability in line with the legal definition of disability under the Equality Act
2010 - ‘if you have a physical or mental impairment that has a ‘substantial’
and ‘long-term’ negative effect on your ability to do normal daily activities.’ 
Substantial’ is more than minor or trivial and ‘long-term’ means 12 months
or more.
• Remove caveat of not having any other able-bodied person in household
who is able to help to not having any other tenant (who has legal
responsibility for the SST where the household member does not).
• Removal of free service for anyone on HB / UC as it does not necessarily
evidence affordability issues. While there is no specific state benefit that
can be accessed for support with garden costs, the Housing Service does
offer support to tenants to maximise their benefit entitlement. 
• Re-charge all eligible tenants who want to receive the service in line with
the revised terms and conditions for the full cost of the service with no
applicable discounts. 
5.2 Further revisions proposed in terms of the overall scheme are set out below:
• Enhanced data and evidence collection for applicants and tenants
accepted onto the scheme, in line with data protection and GDPR. This will
include a review of the invoicing process and ensure more robust
monitoring to assist with future modelling of the scheme.
• An annual review of those on list to check they are still eligible.
• Introduce a cap on the number of tenants on the list in line with resources
provided by Open Spaces, which is currently a maximum of 700 gardens,
along with introduction of a waiting list.
• Non-payment will result in action taken to recover the amount owed and
refusal of reregistration for the following season. 
5.3 Officers anticipate that the revised Scheme will utilise available financial
resources to their best advantage by targeting those in the greatest need.  It
will:
• ensure value for money by minimising the administration resource
required to implement the Scheme; 
• assist to maintain the appearance of council estates; and 
• enable staff to focus on core responsibilities. 
5.4 It is expected that this will lead to a reduction in eligible households
participating in the scheme, where the majority of the cost would be met by
tenants from 1 April 2025 (with the exception of any reasonable adjustment as
identified in the Integrated Impact Assessment (IIA)), alleviating any pressure
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on the HRA.   Any such change will be factored into revised costs of providing
the Scheme. 
6. TENANT CONSULTATION 
6.1 The Council is legally required to consult with its customers and other key
stakeholders on the revised Grass Cutting Scheme. If the Committee agrees
the revised Scheme, it is proposed to have a period of consultation during
September and October. The consultation will use web-based survey to seek
feedback which will be available on the Council’s website and promoted via
social media platforms. Feedback will be requested from:
• all of tenants currently on the Grass Cutting List;
• a random sample of tenants;
• the Moray Tenants’ Forum; 
• the register of interested tenants; and 
• key stakeholders. 
6.2 The survey will ask five key questions relating to the revised Grass Cutting
Scheme. These are: 
i)  Do you support the review of the draft Grass Cutting Scheme? 
ii) Did you find the draft Grass Cutting Scheme easy to read and
understand? 
ii)  Is there a section of the Grass Cutting Scheme that you would like to
see reworded? 
iii)  Is there something in the Grass Cutting Scheme that we’ve missed that
you think should be included? 
iv)  Is there anything you think should be removed? 
6.3 The consultation feedback will inform the review of the scheme.  Following
analysis and consideration of comments received, any necessary
amendments to the Grass Cutting Scheme will be made.   
7.       FUTURE ACTIONS 
7.1 A further progress report with the outcome of the consultation process, along
with a final Grass Cutting Scheme, will be presented to this Committee on 19
November 2024. 
7.2 Subject to the consultation feedback and Committee’s future approval in
November, an implementation plan will be developed to support a “go live”
date of 1 April 2025.  This will include development of procedures on the
Grass Cutting Scheme, training of staff, enhanced recording and monitoring
mechanisms and a review of all relevant information resources. 
8.      SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
The Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP) identify the need to address the shortage of affordable
housing and tackle homelessness. The Grass Cutting Scheme assists to
make the best use of the Council’s housing stock and promote healthier
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citizens and adults living healthier, sustainable independent lives
safeguarded from harm. 
(b) Policy and Legal
There are no legal implications arising from this report. 
(c) Financial implications 
The Housing Revenue Account (HRA) deals with expenditure and
income for the Council’s housing stock.  This includes the costs
associated with the grass cutting scheme which is offered only to eligible
council tenants.  The revisions to the scheme, including removal of any
subsidy and full cost recovery from tenants in receipt of the service, is
intended to negate the identified financial pressure on the HRA for the
financial year 2025/26 onwards. If it is identified that the service is
required to be provided as a reasonable adjustment in terms of the
Equality Act 2010, consideration would need to be given the financial
implications of this and factored into revised costs of providing the
Scheme. 
(d) Risk Implications
There are no risk implications arising from this report. 
(e) Staffing Implications
There are no staffing implications arising from this report. 
(f) Property
There are no property implications arising from this report. 
(g) Equalities/Socio Economic Impact
An Integrated Impact Assessment was completed as part of the Grass
Cutting Scheme review. The IIA will be updated following the
consultation process. 
(h) Climate Change and Biodiversity Impacts
There are no climate change or biodiversity arising from this report. 
(i) Consultations
Consultation on this report has taken place with the Head of Housing
and Property, Housing Services Manager, Housing Strategy and
Development Manager, Officers within the Housing and Property
Service, Georgina Anderson (Legal Services Senior Solicitor) and Lissa
Rowan (Committee Services Officer) and any comments have been
incorporated into the report. 
9. CONCLUSION 
9.1 This report advises Committee of the need to review the Grass Cutting
Scheme. It presents a revised Grass Cutting Scheme for consideration
and seeks agreement to consult with key stakeholders. 
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Author of Report:  Gillian Henly / Emma Armit, Senior Housing Officer
(Policy) 
Eddie Johnston, Homeless Projects Officer (Rapid Re-
housing) 
Background Papers:   With authors
Ref: SPMAN-1285234812-1627 
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APPENDIX I
1
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Housing & Property Service
Grass Cutting Scheme 
1. Scope of the Scheme
1.1 The scope of Moray Council’s Grass Cutting Scheme is to provide a clear and
transparent framework and criteria for delivering a grass cutting service to
tenants based on their capability to maintain their garden to a reasonable
condition.    It allows those who are unable to maintain their gardens to an
acceptable standard due to a substantial and / or long term physical or mental
health problem an option to purchase an in-house service at a pre-determined
cost. 
1.2 Tenants who require a service are not obliged to use Moray Council’s service
and can source alternative independent private service providers if they prefer
to do so. 
2. Principles of the Scheme
2.1 The principles underpinning the Council’s Grass Cutting Scheme are:
Legality – the Council seeks to ensure that its Grass Cutting Scheme reflects
the legal provisions of the Scottish standard secure tenancy agreement and
good practice.
Mutuality – the scheme is in place for the mutual benefit of both tenants and
Moray Council, as the social landlord.
Consistency – the Council will apply the Scheme in a consistent manner to
ensure that applicants with similar circumstances are assessed equally to
achieve similar outcomes.
Equality – the Council will make sure that it does not act in a discriminatory
manner when administering the Scheme.   
3. Objectives
3.1 The specific objectives of the Grass Cutting Scheme are to:
• provide a grass cutting service for tenants who meet the eligibility criteria
as set out at Section 7, where they are unable to do so themselves; 
Item 9
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APPENDIX I
2
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• assess applications in an objective, consistent and fair manner in line
with individual circumstances; and
• promote and sustain well-kept housing estates and neighbourhoods. 
4. Legal Provisions
4.1  The primary legislation governing the Scottish secure tenancy agreement
(SST) is the Housing (Scotland) Act 2001, as amended by the Housing
(Scotland) Act 2014.  Paragraph 2.11 of the tenant’s SST sets out the
requirements for looking after any garden attached to the property - ‘If you
have exclusive use of a garden attached to the house, you must take
reasonable care to keep it from becoming overgrown, untidy or causing a
nuisance (unless we have agreed to take care of it). If you fail to do this, we
are entitled to decide exactly what work requires to be done so as to comply
with this duty’. 
5.  Equality and diversity 
5.1   The Council is committed to preventing discrimination and promoting equality
of opportunity for every person who seeks assistance with their tenancy.  In
accordance with the Equality Act 2010:
• the Council seeks to ensure that the Grass Cutting Scheme does not
discriminate between individuals with one or more of the following
protected characteristics: age, disability, gender reassignment, marital
status/civil partnership, pregnancy and maternity, race, religion or belief
and sexual orientation. 
• Staff will apply the legal definition of disability when assessing applications
for the service - ‘if you have a physical or mental impairment that has a
‘substantial’ and ‘long-term’ negative effect on your ability to do normal
daily activities.’ Substantial’ is more than minor or trivial and ‘long-term’
means 12 months or more.   
5.2  In providing the grass cutting service, full consideration will be given to the
Council’s Public Sector Equality Duty (PSED). This requires public authorities
to: eliminate discrimination, harassment and victimisation; advance equality of
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APPENDIX I
3
V1 – 05/08/24
opportunity; and to foster good relations between persons who share a
relevant protected characteristic and those who do not. 
6. Service Provision
6.1 The grass cutting service is provided by fully trained and insured staff from
Moray Council’s Open Spaces Management and Cemetries team (OSMC),
who will use appropriate equipment for the task. OSMC staff will, where
appropriate, also provide advice and information regarding areas of health
and safety which are identified during the garden visits where they deem
necessary.  The service will incorporate:
• Limitations – the service includes cutting grass within the boundaries of
the tenant’s garden. Grass cuttings will not be lifted and no other garden
work will be undertaken. If further work is identified as being required, this
will be subject to available resources at the time, a separate quote from
OSMC, and fully payable by the tenant.
• Frequency – Grass will be cut 15 times per year between the months of
April and October.  This could increase or decrease slightly, depending
on if the growth is greater or less than normal.
• Annual Cost – A charge will be made to the tenant, which will be equal to
the full cost of Moray Council providing the service.  Tenants will be
informed of the cost of the service, plus on costs, in advance of the grass
cutting season. Costs will be published and updated on the website.  
6.2 Operational procedures are available for Housing Staff to follow to ensure
relevant training, consistency of assessment, application and ease of service
delivery. 
7. Eligibility Criteria
7.1 The grass cutting service is available to Moray Council tenants where they
meet the following eligibility criteria:
• Are unable to cut their grass due to a recognised substantial and long-
term illness, physical or mental health disability as defined by the Equality
Act 2010 (Section 5.1 above) where there is no other able tenant (please
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APPENDIX I
4
V1 – 05/08/24
note this does not relate to another household member) living with
them who is also responsible for meeting the terms and conditions as set
out in the SST; and
• Are in receipt of any physical or mental health related benefit.  Evidence
of entitlement must be provided.  Examples include Personal
Independence Payment (PIP), Adult Disability Payment (ADP), Pension
Age Disability Payment (PADP) and Attendance Allowance. 
7.2 Where no passport benefit is available, evidence from a relevant health
professional confirming the medical condition will need to be provided and will
be stored in accordance with Moray Council’s data protection and GDPR
requirements and retention schedule. 
8. Monitoring 
8.1 Moray Council Housing Service will:
• monitor the applications and confirm the evidence provided for the
scheme annually;
• maintain the list of current tenants receiving the service, with a cap of 700
gardens, as well as a waiting list where required;
• carry out an annual tenant satisfaction survey and monitor any issues of
concern, reporting back to OSMC for improvement actions where
necessary; and
• continue to monitor the cost of the service from OSMC and review as
required in line with inflation and pressure on the Housing Revenue
Account. 
9. Complaints
9.1 Any tenant who is not satisfied with the outcome of their Grass Cutting
Scheme application can request a review in writing by the Area Housing
Manager in the first instance.  If the tenant is not completely satisfied with the
outcome of the case, it will be referred to the Housing Services Manager for
their consideration. 
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APPENDIX I
5
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9.2 If the tenant is still not satisfied with any aspect of the Grass Cutting Scheme
they can escalate the case through the Moray Council Corporate Complaints
Process. 
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APPENDIX II
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INTEGRATED IMPACT ASSESSMENT (IIA) COVERING 
• EQUALITIES & SOCIO ECONOMIC DUTIES
• HUMAN RIGHTS AND RIGHTS OF THE CHILD 
DATE UPDATES/EXECUTIVE SUMMARY VERSION DETAILS
Insert Date
(e.g.
03/10/2023)
Add brief notes/highlight which section amended (e.g.
first draft of IIA completed and submitted to SFC
25/10/2023 for consideration; noting that further work
on Stage 2 will be required). 
Insert (ShP) Version Info
(when details have been
agreed) (e.g. 5.0
03/10/2023 11:21 AMcL)
05/08/24 First draft IIA submitted for H&CS Committee deadline
05/08/2024 for consideration. 
STAGE 1 - DO I NEED AN INTEGRATED IMPACT ASSESSMENT?  
Name of policy or proposal: MC Housing Tenants – Grass Cutting Scheme 
Is this a  Mark X below
New activity, programme or policy? 
Change to an existing activity, programme or policy? X
Budget proposal? 
Duties: tick the boxes you think apply No Maybe                                                                                                                                             Yes
Equalities: Will your proposal have an impact on groups with
protected characteristics? 
Consider the impact of your proposal on people and how they
access your services and information without barriers.  
X
Socio-economic 
Not every person/family has access to regular income or
savings. Will your proposal have an adverse impact on them  
X
Does your proposal impact on the human rights of people?  X  
Does your proposal impact on the rights of children and
young people 
X  
Reasoning
Item 9
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Briefly describe your reasoning for the responses given above: 
The Moray Council Grass Cutting Scheme currently support tenants who are in receipt of
any amount of Housing Benefit (HB) or the housing element of Universal Credit (UC) and
are unable to maintain their garden.  Those not in receipt of HB / UC are liable for full
payment - £65 per year (for 2024/25). The current criteria for the scheme is the tenant
must be:  
• aged 65 or over with no physically able adults aged 18-64 in the household;
• under 65 and in receipt of any physical or mental health related benefit such as
Personal Independence Payment (PIP), Disability Living Allowance (DLA), Adult
Disability Payment (ADP), Attendance Allowance, Employment and Support
Allowance (ESA;) 
• registered blind; or
• any age who, due to ‘vulnerability’, would not be capable of cutting grass. 
The cost of the scheme to date is funded by the Housing Revenue Account (HRA) and
free to HB /UC recipients.  Following recent analysis of budgets and consultation with
Open Spaces, it has become apparent that Open Spaces have been under charging
Housing and significantly subsidising the service in recent years. As a result, Officers
have carried out a thorough review of the Grass Cutting Scheme which has identified
some key issues which, once resolved will provide the potential to improve the scheme,
review the eligibility criteria and alleviate any pressure on the HRA.  It is proposed this is
done by:
• removing age from the eligibility criteria and focus on capability, as age does not
accurately represent tenants’ physical or mental ability to carry out the task.
• apply criteria where the tenant must have a recognised disability in line with the
legal definition of disability under the Equality Act 2010 - ‘if you have a physical or
mental impairment that has a ‘substantial’ and ‘long-term’ negative effect on your
ability to do normal daily activities.’  Substantial’ is more than minor or trivial and
‘long-term’ means 12 months or more.  
• remove caveat of not having any other able-bodied person in household who is
able to help, to not having any other tenant (who has legal responsibility for the
SST.  The household member does not have this responsibility).
• removal of free service for anyone on HB/UC as it does not necessarily evidence
affordability issues.
• re-charge all eligible tenants for full cost of receiving the service with no applicable
discounts to minimise pressure on the HRA. 
Due to current financial pressures on Moray Council, Open Spaces and the HRA, any
subsidy for the service will be fully removed, with the cost of the service passed onto the
tenant.   
If you have answered “maybe” or “yes” to any of the Stage 1 questions above
then proceed to complete the Stage 2 Integrated Impact Assessment questions
below. 
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APPENDIX II
SPFINANCE-565096732-34   03/09/2024 11:51
If you have answered “no” to the Stage 1 questions above then provide the details
below and submit to [email] 
Lead Officer for developing the contract  N/A
Other people involved in the screening
(this may be council staff, partners 
or others i.e. contractor or community) 
N/A
Date N/A 
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APPENDIX II
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STAGE 2: INTEGRATED IMPACT ASSESSMENT 
Brief description of the affected service
1. Describe what the service does: 
Moray Council Grass Cutting Scheme provides a grass cutting service to tenants (between
April and October) where they meet specific criteria (as set out above in Stage 1). 
2. Who are your main stakeholders? 
Open Spaces who carry out the service on Housing’s behalf and eligible Council tenants
who need assistance in maintaining their gardens in accordance with their Scottish secure
tenancy (SST).   
3. What changes as a result of the proposals? Is the service reduced or removed?
The activities of the service will remain the same, but the eligibility criteria is under review.
The proposed new criteria will:
• change / limit who will be eligible meaning some, who currently or previously
received the service, will no longer receive the service at all under the revised
criteria;
• the legal definition of disability under the Equalities Act 2010 will be considered
when assessing tenants eligibility to access the scheme.
• tenants will no longer receive a subsidised or discounted service meaning full cost
recovery for the service will be passed onto the tenants requiring the service.   
4. How will this affect your customers?
Tenants currently on the grass cutting list will need to re-apply and, depending on
whether they meet the new proposed criteria, may be removed from the current list
meaning they will no longer be eligible for the service from 1 April 2025.  
Tenants who have previously been or are currently receiving the service for free will need
to pay an annual fee for the service from 1 April 2025 onwards.   
5. Impact on staff providing the service
There is the potential for more complaints to be received and addressed by Housing Staff
/ Managers. 
Removing requirement to consider HB / UC entitlement, will reduce the Housing Admin
resource required to continually monitor accounts for payments and fluctuations but this
resource would need to be re-diverted to confirm validation of eligibility and annual re-
registration for scheme.
Potential impact on Open Spaces staffing requirements to deliver the service.  This will be
dependent on whether the number of eligible tenants on the list increase or decrease.   
6. Please indicate if these apply to any of the protected characteristics
Protected groups Potential impacts and considerations
Race  No
Disability  Yes – positive impact for those with disability to
receive service but potential for tenants to pay for
the service.
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APPENDIX II
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Carers (for elderly, disabled or
minors)
No
Sex No
Pregnancy and maternity (including
breastfeeding)
No
Sexual orientation No
Age (include children, young
people, midlife and older people)
Yes – age removed from eligibility criteria and focus
on capability
Religion, and or belief No
Gender reassignment No
Inequalities arising from socio-
economic differences
Yes – tenants who may have previously or currently
received a free service may need to pay in future if
they meet the revised criteria.   
Human rights
List of convention rights Describe, where applicable, if and how
specific rights are engaged
Article 5: Right to liberty and
security
No
Article 6: Right to a fair trial No
Article 8: Right to respect for private
and family life, correspondence and
the home
No
Article 10: Freedom of expression No
Article 11: Freedom of assembly
and association
No
Article 12: Right to marry No
Article 14: Prohibition of
discrimination (in relation to the
convention rights)
No
Article 1 of Protocol 1: Protection of
property
No
Article 2 of Protocol 1: Right to
education
No
Article 3 of Protocol 1: Right to free
elections by secret ballot
No 
Children’s Rights and Wellbeing 
Relevant articles – UNCRC 
Article 2 – Non discrimination No
Article 12 – Respect of the views of the
child 
No
Article 3.1 – Best interest of the child No
Article 6.2 – Right to survival and
development
No
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7. Evidence. What information have you used to make your assessment? 
Performance data Housing Service Grass Cutting List tenant data was used which
was matched to tenant data-set held in NEC to identify age,
disability and whether the tenant receives UC or HB.  While this
allowed some modelling the data was not as robust as it could
have been due to some recording issues in the NEC Housing
system.      
Internal
consultation
Consultation with Open Spaces, Accountancy, Equal
Opportunities Officer, Legal, Housing Services Manager,
Housing Strategy & Development Manager, Housing Admin,
Head of Service. 
Consultation with
affected groups
Subject to Housing and Community Safety Committee approval
on 10 September 2024, a tenant consultation period will run
during September / October 2024 to ensure Housing meet legal
duty to consult with tenants on issues affecting them “in relation
to housing management, repairs or maintenance, where the
proposal, if implemented, is likely significantly to affect the
tenant” – S.54 Housing (Scotland) Act 2001.
Local statistics Due to the data issues for current tenants, further disability data
based on applications received in 2023-24 was sought to give
some indicative data for going forward, taking into account the
potential change in criteria in relation to disability.  
• Approximately 502 (29%) of all applications received
(23/24) contain someone who has declared a disability. 
These include autoimmune, mental health, neuro-diverse
and sensory conditions / impairments that are not all are
physical or obvious.  
• Approximately 441 (26%) applications last year had a
main applicant only and a further 61 (3.5%) have a main
and joint applicant both with a disability of some sort.
National
statistics
Benchmarking against other local authority schemes.
Other Cost analysis has been carried for 2023/24, 2024/25 and
projected spend for 2025/26 to ensure a position of full cost
recovery. 
8. Evidence gaps 
Do you need additional information in order to complete the information in the
previous questions? 
No 
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9. Mitigating action 
Can the impact of the proposed policy/activity be mitigated?  Please explain 
Restricting the eligibility criteria, will effectively mean that only those with a disability,
which is evidenced via passport benefit payment, will be eligible for receipt of the service. 
Consideration would need to be given as to whether the service is a reasonable
adjustment in terms of the Equality Act 2010, reasonable adjustments should be free of
charge.  Not providing them due to costs would be for managers to determine and
evidence. 
Discounts could be offered to those who are accepted onto the list due to a disability. 
While projected information based on the proposed revised eligibility criteria shows higher
rates of those that meet the definition of a disability as defined by the Equalities Act 2010,
many may not wish to take up the service based on their own individual capability.  If all
those who meet the definition were accepted onto the scheme and discounts were
applied, this would have a significant impact on the HRA. 
10. Justification
If nothing can be done to reduce the negative impact(s) but the proposed
policy/activity must go ahead, what justification is there to continue with the
change?   
Due to current budget constraints across the Council, Open Spaces are no longer in a
position to subsidise the grass cutting service to Housing, while the HRA also faces
significant pressures given its commitment to deliver ambitious upgrade programmes as
outlined in the Business Plan to improve the standard of housing stock to meet regulatory
requirements set by the Scottish Housing Regulator (SHR).  The Housing Service needs
to move away from the previously subsidised service and towards full cost recovery from
the tenants to help minimise additional pressure on the HRA.   
The revised criteria and annual monitoring should assist with ensuring the service is
reserved for those who have a real need for the assistance.      
Removal of the free service and replacing it with full cost recovery service will create an
increased financial charge to tenants that are eligible.   While there is currently no specific
state benefit that can be accessed for support with garden costs, the Housing Service
does offer support to tenants to maximise their overall benefit entitlement.  
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SECTION 3 CONCLUDING THE IIA 
Concluding the IIA 
1. No potential negative impacts on any of the protected groups were
found. 
2. Some potential negative impacts have been identified.
The impacts relate to:
√
Reducing discrimination, harassment, victimisation or other conduct
prohibited under the Equality Act 2010
√
Promoting equality of opportunity 
Fostering good relations 
3. The proposals interfere with human rights and/or the rights of the
child
N/A
4. Negative impacts can be mitigated the proposals as outlined in
question 9. 
5. The negative impacts cannot be fully mitigated but are justified as
outlined in question 10. 
√
6. Further consultation with affected groups is needed. √
7. It is advised not to go ahead with the proposals. 
Decision
Set out the rationale for deciding whether or not to proceed with the proposed actions: 
As per Q10 above. 
Date of Decision: 05/08/24 
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APPENDIX II
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Sign off and authorisation: 
Service Housing & Property
Department Housing
Policy/activity subject to IIA Grass Cutting Scheme
We have completed the integrated impact
assessment for this policy/activity. 
Name: Emma Armit
Position: Senior Housing Officer (Policy)
Date: 05/08/24
Authorisation by head of service  Name: 
Position: 
Date:
Permission to publish on website - 
Please return this form to the Equal Opportunities Officer, Chief Executive’s Office. 
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REPORT TO:   HOUSING AND COMMUNITY SAFETY COMMITTEE ON 10
SEPTEMBER 2024 
SUBJECT: MORAY HOME ENERGY EFFICIENCY PROGRAMME 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 This report provides the Housing and Community Safety Committee with
details of progress on the Moray Home Energy Efficiency Programme. 
1.2 This report is submitted to Committee in terms of Section III G (2) of the
Council's Scheme of Administration relating to the exercise of all the functions
of the Council as a housing authority.  
2. RECOMMENDATION 
2.1 It is recommended that the Housing and Community Safety Committee; 
(i) scrutinises and notes the progress made on the delivery of the
Moray Home Energy Efficiency Programme; and 
(ii) Agrees the approaches to delivery of the 2024/25 programme
detailed in Section 5. 
3. BACKGROUND 
3.1 The Energy Efficient Scotland (EES) is a Scottish Government initiative to
tackle fuel poverty by improving the energy efficiency of existing private sector
homes.  The programme offers grant funded works to private sector
households who are at risk of fuel poverty.   
3.2 Energy Company Obligation (ECO) funding is provided by energy companies
at the direction of OFGEM. 
3.3 Since 2013/14, the Scottish Government has provided the Council with an
annual funding allocation from the Home Energy Efficiency Programme
Scotland: Area-Based Schemes (EES:ABS) for energy efficiency
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improvements to homes in Moray.  Details of the last 5 years allocations are
provided below: 
2019/20 £1.436m
2020/21 £2.128m
2021/22 £1.914m
2022/23 £1.842m
2023/24 £2.069m 
3.4 This Committee is provided with an update on the EES ABS programme
annually, most recently on 6 June 2023. 
3.5 The primary focus of the programme is on insulation measures and “fabric
first”, with a secondary focus on “zero carbon first” through heating measures
and microgeneration where feasible, and where it will result in reduced fuel
poverty.  EES:ABS funding should secure an EPC rating of C. 
3.6 During 2013/14 to 2023/24, the Moray programme has delivered measures to
over 1,000 properties as shown in the table below.  With the exception of
2021/22, the Moray EES ABS programme has generally spent all or almost
all, of its budget allocation. 
Year Private sector properties in
receipt of completed measures
2013/14 275
2014/15 151
2015/16 135
2016/17 128
2017/18 96
2018/19 196
2019/20 70
2020/21 100
2021/22 0
2022/23 254
2023/24 358
Total 1,763 
4. MORAY EES:ABS PROGRAMME 2023/24 OUTTURN 
4.1 The Scottish Government’s EES ABS guidance required councils to apply a
“fabric first” approach with measures to be targeted to fuel poor households,
specifically those living in Council Tax bands A-C properties.  Properties may
be suitable for more than one measure.   
4.2 On 3 November 2021 the Council appointed Changeworks as managing
agent to deliver the HEEPS ABS programme for 2 years with an option of an
extension for a 3rd year.  This service is funded from within the Scottish
Government grant.  The agent is required to provide an end-to-end service
from identifying and engaging with targeted householders; procurement of
contractors; to quality assurance, monitoring, evaluation and reporting.  The
agent will provide the resource and expertise required to deliver a multi-
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measure programme involving specialist contractors and provide specialist
advice and support to householders.   
4.3 The full 2023/24 grant allocation of £2.069m was spent by May 2024.  In
addition, In August 2023, the Council was awarded additional funding
(£2.137m) for a “special project” to provide solar PV and battery storage to
properties in specific areas (Forres and Keith), which had received external
wall insulation as part of a previous scheme.  The special project funding was
also spent by May 2024. 
4.4 The Scottish Government guidance provides facility for up to 20% of the
funding allocation to be spent on “enabling”.  Enabling funding can be used to
cover the costs of the following: 
• Scheme marketing, promotion and publicity;
• Scheme development costs, including planning/design and householder
engagement, sample physical surveys etc.;
• Transport costs (for remote and rural areas);
• Scaffolding costs;
• Any ground clearance work for health & safety requirements
• Scheme management and staffing costs, including applications for
building warrants and quality control (clerk of works etc.); 
• Engagement with private rented sector and registered social landlords;
• Complaints procedures; and
• Monitoring and evaluation. 
4.5 During 2023/24, 13% of funding was spent on enabling, predominantly
property surveys; Building Warrant fees; scaffolding; marketing and publicity
costs; and staffing costs which includes Clerk of Works costs. 
4.6 The outturn for 2023/24 is presented in the table below: 
Measure
2023/24
Total main
programme
Special
Project
Solar PV/battery storage 106 202 308
Loft insulation 26   26
Internal wall insulation 26   26
Cavity insulation extraction and refill 15   15
Air source heat pump     0
Room in Roof insulation 4   4
Underfloor insulation 2   2
Total 179 202 381 
* Properties may receive more than one measure 
5. MORAY EES:ABS PROGRAMME 2024/25 
5.1 The Council’s 2024/25 EES:ABS proposals, submitted to the Government on
4 June 2024, set out details of an insulation programme to properties of solid
wall construction across Moray.  
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5.2 The planned outputs for the 2024/25 programme are as follows: 
Measure No of measures 
(private sector) *
Internal wall insulation 71
Cavity wall insulation 27
Air Source heat pump 19
Total 117 
* Properties may receive more than one measure 
Qualifying Criteria and Customer Contributions
5.3 The measures in the 2024/25 programme will continue to be targeted to fuel
poor households living in properties within Council Tax bands A-C.  The
qualifying criteria are available on the Council’s website at
http://www.moray.gov.uk/moray_standard/page_41080.html. 
5.4 Homeowners will be expected to accept installation of all the measures
required to bring their property up to the required EPC rating of C or as close
to it as technically possible.  Where the value of the grant applicable does not
cover the full cost, households will be required to make up the difference from
their own resources.  Partial measures will not qualify for the scheme. 
5.5 Owners seeking to raise funding for their contribution will be directed to the
Scottish Government’s EES Loan Scheme.  This Scheme offers homeowners
interest-free loans to help them meet the cost of measures. 
6. SCARF - ECO4 FUNDED WORKS 
6.1 Home Energy Scotland (HES) provide advice and support on energy supplier
switching, energy saving and fuel debt advice, access to emergency/hardship
grants, as well as signposting to provision of insulation measures, on a
tenure-neutral basis. SCARF administer the HES function in northeast
Scotland. 
6.2 In early 2024, SCARF offered Moray Council the opportunity to join its
recently established Energy Company Obligation (ECO) referral scheme. 
Existing members are Aberdeen City, Aberdeenshire and Angus Councils. 
On 1 May 2024, Moray Council joined the scheme which will provide private
sector owners and renters with access to ECO funded insulation and carbon
reduction measures.  SCARF will source an energy company willing to
provide the ECO funding and will procure contractors from their established
framework.  This scheme is provided at no cost to Moray Council.  Full details
are published on the Council’s website at
http://www.moray.gov.uk/moray_standard/page_154848.html. 
7. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP)
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Addressing poverty and promoting healthy communities is a key priority
of the Corporate Plan and the 10 Year Plan.  Delivery of the EES:ABS
programme will contribute to the achievement of this priority, as well as
contributing towards corporate carbon reduction targets by helping
reduce energy consumption from domestic buildings. 
(b) Policy and Legal
Part 4 of the Climate Change (Scotland) Act 2009 places duties on
public bodies relating to climate change.  Moray Council has declared a
Climate Change Emergency.  Delivery of the EES:ABS programme will
contribute to the achievements of these aims and requirements. 
(c) Financial implications 
The report provides details of progress in delivering energy efficiency
measures to housing stock in Moray, funded from external sources,
mainly the Scottish Government’s Energy Efficient Scotland Area
Based Scheme (EES:ABS), and Energy Company Obligation (ECO)
funding.  No Moray Council funding is required to deliver the schemes
detailed within this report. 
(d) Risk Implications 
There are no risk implications arising from this report. 
(e) Staffing Implications
There are no staffing implications arising from this report. 
(f) Property
This report provides details of improvements carried out to Council
houses to meet statutory standards of energy efficiency. 
(g)  Equalities/Socio Economic Impact
The energy efficiency proposals set out in this report will be targeted to
the homes of fuel poor households. 
(h)  Climate Change and Biodiversity Impacts
The aims of the EES:ABS programme are closely aligned to the aims of
the Local Housing Strategy, the Council’s Climate Change Strategy,
and Local Heat and Energy Efficiency Strategy (LHEES). 
(i) Consultations 
This report has been subject to wider consultation with the Head of
Housing and Property Services, the Chief Finance Officer, the Housing
Asset Manager, Georgina Anderson,  (Legal Services Senior Solicitor) ,
the Home Improvement Services Manager, the Principal Climate
Change Strategy Officer and Lissa Rowan (Committee Services
Officer). 
8. CONCLUSION 
8.1 This report provides details of delivery of fuel poverty measures to private
sector properties in Moray.
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Author of Report: Fiona Geddes, Housing Strategy and Development
Manager
Background Papers:  Held by author
Ref:    SPMAN-1285234812-1619
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REPORT TO:   HOUSING AND COMMUNITY SAFETY COMMITTEE ON 12
SEPTEMBER 2024 
SUBJECT: HOUSING AND PROPERTY SERVICES BUDGET MONITORING –
30 JUNE 2024 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 This report presents the budget position for the Housing Revenue Account
(HRA) and General Services Other Housing Budget for the period up to 30
June 2024. 
1.2 This report is submitted to Committee in terms of Section III G (1) of the
Council's Scheme of Administration relating to the management of budgets. 
2. RECOMMENDATION 
2.1 It is recommended that the Committee scrutinises the budget monitoring
report for the period to 30 June 2024, noting an underspend of £187k for
the Housing Revenue Account and an overspend of £33k for General
Services Housing & Property. 
3. BACKGROUND 
3.1 The Council agreed the HRA Budget for 2023/24 at a Moray Council meeting
on 28 February 2024 (paragraph 7 of the Minute refers). Housing and
Property budget monitoring reports are presented quarterly. 
4. HOUSING REVENUE ACCOUNT TO 30 JUNE 2024 
4.1 APPENDIX I details the HRA budget position to 30 June 2024. 
4.2 The main expenditure variances relate to:– 
4.2.1 Supervision and management – there are a range of variations within this
budget resulting in a net underspend of £123k. This includes underspends in
staffing (£143k) arising from vacancies and the budget provision for pay
award, noting that the provision will be insufficient and that the HRA will not
receive funding for the proposed uplift. There were also underspends of £29k
for software due to invoice timing, £2k for voids and other minor cumulative
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underspends of £5k. This was partially offset by an overspend in relation to
voids (£32k) and Council Tax (£22k). 
4.2.2 Sheltered Housing – there was an underspend of £8k in the sheltered
housing budget, which is mostly attributable to lower than budgeted energy
costs (£7k) and other minor cumulative spend of £1k. 
4.2.3 Repairs and maintenance – there was an overspend of £28k in the repairs
and maintenance budget, which arises from higher than budgeted expenditure
on voids (£72k) and above average response repairs (£54k). These were
partially offset by lower than anticipated planned/cyclical maintenance (£98k);
this was comprised of underspends in electrical upgrades, arising from
slippage in the programme, external decoration and fabric, asbestos works,
rainwater goods and moss clearance, partially offset by roof repairs, enabling
works and other miscellaneous overspends. 
4.2.4 Bad and doubtful debts – there was an underspend of £19k against
provision for bad and doubtful debts, noting that Q1 write-offs of £21,504.72
have still to be processed. 
4.2.5 Downsizing Incentive Scheme – there was a £3k overspend in Q1 and this
is expected to increase in future months due to a higher level of activity
arising from the enhanced priority in the revised allocations policy.
Consideration will be given to reviewing this provision in the course of the
year. 
4.2.6 Service Developments – there is an underspend of £49k, with provision
retained for tenant and service priorities over the winter months. 
4.2.7 The income at 30 June 2024 was £19k higher than expected. This arises from
£27k higher than budgeted rental income and £1k additional income for non-
residential properties, partially offset by £9k lower than budgeted tenant
recharges in the period. 
5. OTHER HOUSING & PROPERTY BUDGET 
5.1 APPENDIX II provides details of the budget position to 30 June 2024. 
5.2 Planning and Development - consists of Improvement Grants and
Affordable Housing budgets, including disabled adaptations. The position at
30 June 2024 shows an underspend of £37k, arising from the timing of grant
income. This budget is administered by Moray Integration Joint Board.  
5.3 Housing Management - relates to the Gypsy/Traveller budget. There is no
budget variance for the period to 30 June 2024. 
5.4 Homelessness/Allocations - comprises of Homelessness and Housing
Support services. There was an underspend of £29k in this budget, comprised
of an underspend in Temporary Accommodation (£49k), partially offset by
overspends in Housing Support (£13k) and general Homelessness (£7k). The
underspend is attributable to additional rental income.  
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5.5 Miscellaneous General Services Housing – there was an underspend of £7k
in relation to repairs and rent for a supported accommodation project
(Urquhart Place, partially offset by a £2k overspend for open space
maintenance at another facility (Pinefield). 
5.6 The Building Services Budget - is reported in detail separately on this
Committee’s agenda and any surplus achieved or deficit will return to the
HRA. 
5.7 The Property Services Budget - includes the budgets for the Design Team
and Property Resources. There is an overall overspend of £106k to date.
Within the Design Team there was an overspend of £15k in specialist
software (£8k), partially offset by an underspend in architectural consultancy
(£3k). Within Property Asset Management there was an overspend of £94k.
This arose from overspends in central repairs and maintenance (£119k)
following a cost increase under a new heating maintenance contract, schools’
repairs and maintenance (£93k), largely attributable to the same contract and
several smaller overspends totalling £13k. These were partially offset by
higher income from the industrial portfolio (£120k) and £11k in other
cumulative underspends. The increased cost of heating and school
maintenance has been raised as a budget pressure. 
5.8 As at 30 June 2024, the Other Housing budget shows a net overspend of
£33k.   
6. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
The provision of new affordable housing, the maintenance of the
Council’s housing stock and dealing with homelessness are priorities
identified within the Corporate Plan, the Council’s Local Housing
Strategy, the Strategic Housing Investment Plan (SHIP) and the Housing
and Property Service Plan. 
(b) Policy and Legal
There are no policy or legal implications arising from this report. 
(c) Financial Implications
The financial implications of this report are considered in Sections 4 to 5
of this report and detailed in APPENDICES I and II. 
(d) Risk Implications
Budget Managers are aware of their responsibilities for managing budget
allocations and approval for variance will be sought from the Committee
in line with Financial Regulations. 
(e) Staffing implications
There are no staffing implications arising from this report.  
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(f) Property
None. 
(g) Equalities/Socio Economic Impact
There are no equalities/socio economic impacts arising from this report. 
(h) Climate Change and Biodiversity Impacts
There are no climate change/biodiversity impacts arising from this report. 
(i) Consultations 
This report has been prepared in close consultation with Finance staff.
Consultation on this report has been carried out with the Chief Financial
Officer, Georgina Anderson (Legal Services Senior Solicitor), Senior
Managers within Housing and Property Services and Lissa Rowan
(Committee Services Officer) who all agree the content of the report
where it relates to their area of responsibility. 
7. CONCLUSION 
7.1 This report sets out the budget position for the HRA and General
Services Housing budgets to 30 June 2024 and also comments on the
variances on these budgets. 
Author of Report: Edward Thomas, Head of Housing and Property
Background Papers:   Held by author
Ref:    SPMAN-1285234812-1624
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Housing Revenue Account         Appendix I
Budget Monitoring to 30 June 2024   
Service Description Annual Budget
2024-25
Budget to 
30 June 2024
Actual to 
30 June 2024
Variance to 
30 June 2024
Expenditure £,000 £,000 £,000 £,000
Supervision & Management 6,081 1,308 1,185 123
Sheltered Housing 64 15 7 8
Repairs and Maintenance 9,694 1,637 1,665 (28)
Financing Costs 7,188 0 0 0
Bad & Doubtful Debts 250 25 6 19
CFCR  2,641 0 0 0
Downsizing Incentive
Scheme 72 18 21 (3)
Service Development 200 50 1 49
Total Gross Expenditure 26,190 3,053 2,885 168          
Income £,000 £,000 £,000 £,000
Non-dwelling rents 260 84 85 1
House rents 25,126 6,668 6,695 27
IORB 437 0 0 0
Other income 152 37 28 (9)
Total Income 25,975 6,789 6,808 19          
Surplus / (Deficit) for the
year 215 (3,736) (3,923) 187          
Accumulated Surplus
Balance brought forward     1,587            
Estimated Surplus
Balance at 31st March     2,250   
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Appendix II    
General Services Housing & Property 
Monitoring to 30th June 2024           
Annual Budget 
Actual &
committed Variance
Service Description Budget to to at 
2024-25 30 June 2024 30 June 2024 30 June 2024    
£'000 £'000 £'000 £'000
Planning & Development 295 43 6 37            
Housing Management 14 10 10 0            
Homelessness / Allocations 1814 427 398 29            
Miscellaneous General Services
Housing 250 68 61 7            
Building Services 0 (49) (49) 0            
Property Services 2202 473 579 (106)            
General Services Housing & Property
Savings (206) 0 0 0            
General Services Housing & Property
Allocations (161) 0 0 0            
General Services Housing &
Property Total  4208 972 1005 (33)     
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REPORT TO: HOUSING AND COMMUNITY SAFETY COMMITTEE ON 10
SEPTEMBER 2024 
SUBJECT: INFORMATION REPORT: LOCAL HOUSING STRATEGY
UPDATE 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 To inform the Committee of the requirement to review the Local Housing
Strategy (LHS), progress made in achieving the outcomes of the LHS 2019-
2024 and that a consultative draft of the revised LHS will be presented to
Committee in Spring 2025. 
1.2 This report is submitted to Committee in terms of Section III (G) (11) of the
Council's Scheme of Administration relating to the preparation and
implementation of strategic housing plans. 
2. BACKGROUND 
2.1 The Housing (Scotland) Act 2001 requires local authorities to produce a Local
Housing Strategy (LHS) supported by an assessment of housing need and
demand.   
2.2 The LHS was approved by Communities Committee on 2 April 2019 (para 8 of
the Minute refers) and is available on the Council’s website at
www.moray.gov.uk/housingstrategy.  The priorities the LHS set out to achieve
are: 
Priority 1: To improve access to housing across all tenures and address
housing need.
Priority 2:  To prevent and alleviate homelessness.
Priority 3: To assist people requiring specialist housing.
Priority 4: To improve the condition and energy efficiency of housing, and
minimise fuel poverty. 
2.3 Local authorities are required to keep their LHS under review.  A mid-term
review was presented to this Committee on 21 June 2022, which detailed
progress made in achieving the outcomes of the LHS 2019-2024 (Paragraph
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7 of the Minute refers).  This report provides a further update on progress over
the past two years. 
2.4 The Housing Need and Demand Assessment (HNDA) is a statistical reference
document which provides a key evidence base for both Local Housing
Strategies (LHS) and Local Development Plans (LDP).  On 13 February 2024,
this Committee were presented with the 2023 HNDA findings and advised of
the forthcoming review of the LHS (Paragraph 6 of the Minute refers).   
3. PROGRESS ON LHS ACTIONS 
3.1 A progress update on the LHS Action Plan is set out below and summarised
in APPENDIX I.  While most actions have now been completed, any
outstanding items will be incorporated into the next action plan. 
LHS PRIORITY 1: TO IMPROVE ACCESS TO HOUSING ACROSS ALL
TENURES AND ADDRESS HOUSING NEED 
Supply of Affordable Housing
3.2 Since April 2019, 555 new affordable homes have been completed and
occupied, with a further 42 expected during 2024/25, illustrated in the table
below: 
Compl
Year
Landlord Buckie
HMA
Elgin
HMA
Forres
HMA
Keith
HMA
Speyside
HMA
Total
2019/20 Moray Council 28     28
Hanover HA  45    45
2020/21 Moray Council  102    102
2021/22 Moray Council  46    46
Cairn HA  16    16
Hanover HA 31 44    75
Osprey Housing  10    10
2022/23 Moray Council  9    9
Cairn HA  28    28
Grampian HA   37   37
Hanover HA  25    25
Osprey Housing  24    24
2023/24 Moray Council  8  33  41
Cairn HA  28    28
Grampian HA   41   41
2024/25 Moray Council    26  26
Grampian HA  16    16
Total 59 401 78 59 0 597
9.9% 67.2% 13.1% 9.9% 0% 100% 
3.3 In terms of the acquisition programme, a further 37 properties have been
added to the Council’s housing stock.  This includes 36 properties in Elgin
acquired in 2022/23 and 1 property in Dufftown in 2023/24. 
3.4 Progress on the Moray Affordable Housing Programme is reported to
Committee twice a year, most recently in May 2024 (Paragraph 10 of the
Minute refers). 
Allocation of Affordable Housing
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3.5 The operation of the Council’s Allocations Policy is reported to Committee
annually, with Housing List quotas reviewed and agreed each time.  The last
report was considered by this Committee on 25 June 2024 (Paragraph 9 of
the draft Minute refers). 
3.6 In 2023/24 relets reduced by 17.5% in comparison to the previous year.  
This was the outcome of a slight reduction in Council tenancy terminations
(6%) and reduced tenancy turnover arising from tenants moving out of the
Moray area or taking up a new tenancy with a Registered Social 
Landlord (RSL).  Despite these challenges, there has been success in
increasing tenancy turnover within Moray Council’s housing stock, achieving a
16% increase in the past financial year, as intended by the Allocations Policy.
The availability of permanent housing options places an important role in
assisting the Council to deliver its Rapid Rehousing Transition Plan (RRTP)
(see paragraph 4.9 below). 
3.7 Following public consultation, the revised Allocations Policy, which aims to
make best use of the Council’s housing stock, was approved by this
Committee on 13 February 2024 for implementation on 1 April 2024
(paragraph 8 of the Minute refers).   
3.8 The majority of nomination agreements with RSL partners have been
reviewed and finalised. 
Downsizing Incentive Scheme
3.9 The scheme was disrupted during the pandemic by the cessation of house
moves and the reluctance of some households to consider moving, especially
those in shielding groups.  The numbers of tenancies created under the
Downsizing Scheme have now returned to previous levels: 
2019/20 2020/21 2021/22 2022/23 2023/24 Total
No. of tenancies 22 14 19 9 19 84 
LHS PRIORITY 2: TO PREVENT AND ALLEVIATE HOMELESSNESS 
Temporary Accommodation
3.10 The Rapid Rehousing Transition Plan (RRTP) has been updated to better
reflect current circumstances and cover the period 2022/23 to 2026/27.  At 31
March 2024, 112 units of temporary accommodation were in occupation with 1
household in unsuitable accommodation (B&B).  There was a reduction of 14
temporary accommodation units during 2023/24.  However, pressure from
increasing homelessness and reduced turnover/supply of new build housing
has resulted in 25 breaches of the Unsuitable Accommodation Order in
2023/24. 
3.11 Following public consultation, the revised Temporary Accommodation
Charging policy was approved by this Committee on 12/09/2023 (Paragraph 8
of the Minute refers). 
Development of Housing First
3.12 The Housing First project commenced in June 2022 with one housing support
officer and one housing support assistant.  Due to the increasing workload, an
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additional housing support worker was seconded to the project in June 2023. 
The project has received 27 referrals to date, with 24 individuals accepting
support.  Of these, 19 have been offered secure tenancies, 2 had tenancies in
crisis which were at risk, 2 are currently in prison and 1 is in homeless
accommodation.   
3.13 The project has established a strong partnership with the Scottish Prison
Service and has the support from other services including housing
management, social work and health services.  Four clients have successfully
"stepped down" from the program and two tenancies were terminated due to
imprisonment and relocation.   
LHS PRIORITY 3: TO ASSIST PEOPLE REQUIRING SPECIALIST
HOUSING 
3.14 During the LHS term, the aim to provide 30-40% of new build affordable
housing as specialist/amenity housing through the Strategic Housing
Investment Plan has been achieved, as shown in the table below: 
Compl
Year Landlord
1
Bed
Ame
-nity
1 
Bed
Gen
Needs
2
Bed
Ame
-nity
2 Bed
Gen
Needs
2
Bed
WC
3 Bed
Ame
-nity
3 Bed
Gen
Needs
4+
Bed
Ame
-ntity
4+
Bed
Gen
Needs
4
Bed
WC
Extra
Care
/ LD
Total
2019/
20
Moray Council   8     2 1 6   11     28
Hanover HA     14           1   30 45
2020/
21 Moray Council   32 32   2 2 18   15 1   102
2021/
22
Moray Council   12 8 6     18   2     46
Cairn HA   14         2         16
Hanover HA   17 10   1 4 19   11   13  75
Osprey Housing   4         6         10
2022/
23
Moray Council   8 1                 9
Cairn HA   8 12       4   4     28
Grampian HA   16 13   2 1 2   3     37
Hanover HA  4 6  2  8  5   25
Osprey Housing 4 4       1 8   7     24
2023/
24
Moray Council   16 16     2 4 1 2     41
Cairn HA   12 8       6   2     28
Grampian HA   16 11       6   8     41
2024/
25
Moray Council   8 9   1   6   2     26
Grampian HA   16                   16
Total No. 4 195 140 6 10 11 113 1 73 1 43 597  
% 0.7 32.7 23.5 1.0 1.7 1.8 18.9 0.2 12.2 0.2 7.2 100
Housing for people with learning disabilities
3.15 Officers continue to work proactively in partnership with Health and Social 
Care Moray and NHS Grampian in the delivery of additional specialist housing
with support for people with learning disabilities.  Provision has already been
made at Highland Yard, Buckie and Spynie, Elgin.  Further provision is
planned at Elgin South and Garmouth Road, Lhanbryde.  The planning
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consent at Bilbohall, Elgin granted in March 2021 includes a “care village”
which will make provision for this group in Phase 2 of development. 
LHS PRIORITY 4: TO IMPROVE THE CONDITION AND ENERGY
EFFICIENCY OF HOUSING, AND MINIMISE FUEL POVERTY 
Energy Efficiency Standard for Social Housing (EESSH/EESSH2)
3.16 A key component of the Scottish Housing Quality Standard (SHQS) is
compliance with the Energy Efficiency Standard for Social Housing (EESSH). 
On 7 May 2024, this Committee approved an improvement plan to accelerate
the delivery of energy efficiency measures to improve compliance (Paragraph
9 of the Minute refers). 
3.17 A new Social Housing Net Zero Standard (SHNZS), the proposed
replacement for EESSH2, is expected to be introduced by 2025 at the earliest. 
Energy Efficient Scotland Area Based Scheme (EES:ABS)
3.18 The Council has been administering the Scottish Government’s EES:ABS 
(formerly HEEPS:ABS) funding since the fund’s inception 9 years ago. The     
Council receives an annual allocation of funding from the Scottish 
Government for provision of “grant in kind” via EES:ABS to private owners, 
with a focus on the alleviation of fuel poverty.   
3.19 A new scheme, ECO 4 Flex, was launched in Moray on 1 May 2024.  The
main objective of this scheme is to reduce fuel poverty by improving the
energy efficiency in private housing that is occupied by low income, vulnerable
and fuel poor households. 
3.20 A separate report on this Committee’s agenda provides an update on both the
EES:ABS programme and Eco 4 Flex schemes. 
4. LOCAL HOUSING STRATEGY 2025-2030 
4.1 Housing consultants Arneil Johnston have been commissioned to carry out
the review of the Local Housing Strategy (LHS).   
4.2 Their approach will be to gather primary research from an early engagement
survey.  This will include an online survey with offline options available on
request.  The survey will be promoted widely, to gather views from the
community on what housing issues need to be considered as part of the
development of the next strategy. 
4.3 Additionally, there will be a digital conference for key stakeholders in October
2024.  This will provide an opportunity to discuss and validate the main
issues, including those identified from the survey.   
4.4 Subject matter expert groups will then be established to scrutinise the key
issues arising from the conference.  This will inform strategic priorities for the
next LHS, with a consultative draft to include an action plan, expected to be
presented to this Committee in Spring 2025. 
5. SUMMARY OF IMPLICATIONS
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(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
All of the LHS outcomes are closely aligned with the objectives of the
Corporate Plan and the 10 Year Plan. 
(b) Policy and Legal
It is a legal requirement of the Housing (Scotland) Act 2001 that local
authorities have a Local Housing Strategy.  Detailed guidance has been
produced by the Scottish Government. 
(c) Financial implications
There are no financial implications arising directly from this report. 
(d) Risk Implications
Failure to implement and review the local housing strategy may present
a regulatory risk.
.
(e) Staffing Implications
There are no staffing implications arising from this report. 
(f) Property
There are no property implications arising from this report. 
(g) Equalities/Socio Economic Impact
It is a statutory requirement that equality issues should be addressed in
the LHS.  Data and evidence about the particular housing and support
needs of equality groups is gathered as part of the Council’s Housing
Need and Demand Assessment.  The LHS sets out how the Council
intends to address these needs.  The LHS includes an Equality Impact
Assessment.  Equality groups were consulted as part of the preparation
of the LHS. 
(h) Climate Change and Biodiversity Impacts
The LHS Outcomes and Actions on fuel poverty and energy efficiency
are closely aligned to the Council’s Climate Change Strategy, and Local 
Heat and Energy Efficiency Strategy (LHEES). 
(i) Consultations
Consultation on this report has taken place with the Depute Chief 
Executive (Economy, Environment and Finance), Head of Housing and 
Property, Acting Head of Economic Growth and Development Services,
Head of Environmental Services, the Strategic Planning and
Development Manager, the Head of Health & Social Care Moray, the
Chief Officer Health and Social Care Moray, the Chief Financial Officer,
Legal Services Senior Solicitor (Georgina Anderson) , Equal
Opportunities Officer, Committee Services Officer (Lissa Rowan), and
senior managers within Housing and Property Services. 
6. CONCLUSION 
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6.1 This report provides the Committee with details of the achievements of
the Local Housing Strategy 2019-2024 to date.  The report provides
details of the forthcoming review of the Local Housing Strategy 2025-30.   
Author of Report: Daska Murray, Senior Housing Officer (Strategy) 
Background Papers: With author
Ref: SPMAN-1285234812-1630 
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Moray Local Housing Strategy 2019-2024 Action Plan 2022/23/24 Appendix 1
Responsibility Timescale Status
Moray Council/
RSLs Annual SHIP published annually. 
Moray Council 2022-24 HNDA 2023 presented to Committee on
13/03/2023.
Moray Council 2023-24 Revised policy implemented from 01/04/2024.
Moray Council/
RSLs Annual Allocations quotas for 2024/25 set by Committee
on 25/06/2024. 
Moray Council 2022/23
Moray Council/
RSLs
Annual
(ARC)
Average time to relet reduced to 35 calendar days
for 2023/24.
Moray Council 2023-24 Majority of RSLs nomination agreements have
been reviewed and finalised. 
Moray Council 2023-24
Moray Council 2019-24 Ongoing
Moray Council ongoing
Moray Council/
RSLs ongoing
Moray Council ongoing
Moray Council 2022-23 Revised policy approved by Committee on
12/09/2023.
Action
Priority 1:  Improve access to housing in all tenures and alleviate housing need
Review RSL Nominations Agreements
Revise the Temporary Accommodation Charging Policy
Increase the supply of affordable rented housing
Regularly review allocations quotas
Implement Moray Council’s Downsizing Incentive Scheme
Priority 2:  Prevent and alleviate homelessness
Minimise the time taken to relet vacant social housing
Complete Moray Council Sheltered Housing review
Ensure provision of high quality Housing Support
Make the best use of
existing social
housing
Deliver updated Housing Need and Demand Assessment (2022/23 based)
Complete RSL Nominations Agreement review
Revise the Council's Allocations Policy
Provide a high quality Housing Options Service
Implement the Rapid Rehousing Transition Plan incl Housing First
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Moray Local Housing Strategy 2019-2024 Action Plan 2022/23/24 Appendix 1
Responsibility Timescale StatusAction
Moray Council 2019-24
See Housing Supply Target.  30-40% of funding is
allocated to development of amenity housing,
although this varies from site to site.
SHIP 2019-24 Progress led by Health and Social Care Moray
Increase tenure choice for older
people
Support implementation of the LDP 2020
Accessible Housing Policy (DP2 (f)) Moray Council 2019-24
People with learning
disabilities
Health and Social
Care Moray 2019-24 Contribute to aims of the LD Accommodation
Review, led by Health and Social Care Moray
Gypsy/ Travellers Moray Council Ongoing
Moray Council Ongoing
Moray Council Ongoing
Moray Council Ongoing Support available, including interest-free loans.
Moray Council 2019-24
Moray Council Ongoing
Increase supply of extra care housing
Stock condition -
Private sector
Increase the supply of ambulant disabled housing for affordable rent
People with physical
disabilities
Implement the Protocol and Guidelines for the Response to Unauthorised
Camping in Moray
Priority 4:  Improve the condition and energy efficiency of housing, and minimise fuel poverty
Develop a Corporate approach to the use of available enforcement powers,
including Compulsory Purchase Orders (CPOs), and designation of Housing
Renewal Areas.
Implement the Private Landlord Registration Scheme Repairing Standard
Implement the Scheme of Assistance
Target support under the Scheme of Assistance to owners of BTS stock or those
who cannot afford the cost of essential repairs
Minimise empty homes in the private sector
Increase supply of appropriate housing with care for people with learning
disabilities
Priority 3:  Assist people requiring specialist housing
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