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Agenda Document Pack - Housing and Community Safety Committee - 27/06/2023

Moray Council · 27 June 2023
Back to Housing and Community Safety Committee — 27 June 2023 and its agenda

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Housing and Community Safety Committee 
Tuesday, 27 June 2023 
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, 27 June 2023 at 14:00. 
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 15 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 the meeting held 9 May 2023 7 - 10
5. Written Questions ** 
6. Performance Report (Housing and Property Services)
Period to March 2023
Report by Depute Chief Executive (Economy, Environment and
Finance)
11 - 16
7. Moray Affordable Housing Investment Programme
Report by Depute Chief Executive (Economy, Environment and
Finance)
17 - 24
8. Allocations Policy Annual Performance Report 2022-23
Report by Depute Chief Executive (Economy, Environment and
Finance)
25 - 34
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9. Decoration Allowance Policy
Report by Depute Chief Executive (Economy, Environment and
Finance)
35 - 50
10. Temporary Accommodation Charging Policy Review
Report by Depute Chief Executive (Economy, Environment and
Finance)
51 - 70
11. Housing and Property Services - Unaudited Outturn as
at 31 March 2023
Report by Depute Chief Executive (Economy, Environment and
Finance)
71 - 80
12. Housing Investment Report 2022-23
Report by Depute Chief Executive (Economy, Environment and
Finance)
81 - 94
13. Information Reports - if called in 
14. Question Time ***
Consider any oral question on matters delegated to the Committee in
terms of the Council's Scheme of Administration. 
Item(s) which the Committee may wish to consider with
the Press and Public excluded   
15. Building Services Trading Operation Budget 2022-23 -
Budget Monitoring
• 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 - Moray Home Energy Efficiency
Programme
Report by Depute Chief Executive (Economy, Environment and
Finance)
95 -
100
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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.     
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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. 
*** Question Time - At each ordinary meeting of the Committee ten minutes will be
allowed for Members questions when any Member of the Committee can put a
question to the Chair on any business within the remit of that Section of the
Committee.  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 ten minutes
after the Committee 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/she can submit it in
writing to the proper officer who will arrange for a written answer to be provided
within seven working days. 
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MORAY COUNCIL 
Housing and Community Safety Committee 
SEDERUNT 
Councillor Amber Dunbar  (Chair)
Councillor Donald Gatt  (Depute Chair)  
Councillor Neil Cameron  (Member)
Councillor John Divers  (Member)
Councillor Jérémie Fernandes  (Member)
Councillor David Gordon  (Member)
Councillor Sandy Keith  (Member)
Councillor Scott Lawrence  (Member)
Councillor Marc Macrae  (Member)
Councillor Paul McBain  (Member)
Councillor Shona Morrison  (Member)
Councillor Derek Ross  (Member)
Councillor John Stuart  (Member)
Councillor Draeyk Van Der Horn  (Member)  
Ms Anna Bamforth  (Non-Voting Member)
Ms Jane Bartecki  (Non-Voting Member)
Mr Ronald Tolmie  (Non-Voting Member)
Clerk Name: Lindsey Robinson
Clerk Telephone: 07966 120593
Clerk Email: committee.services@moray.gov.uk 
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MORAY COUNCIL 
Minute of Meeting of the Housing and Community Safety Committee 
Tuesday, 09 May 2023 
Council Chambers, Council Office, High Street, Elgin, IV30 1BX 
PRESENT 
Ms Jane Bartecki, Councillor Theresa Coull, Councillor John Divers, Councillor
Amber Dunbar, Councillor Jérémie Fernandes, Councillor Donald Gatt, Councillor
David Gordon, Councillor Sandy Keith, Councillor Scott Lawrence, Councillor Marc
Macrae, Councillor Paul McBain, Councillor Shona Morrison, Councillor Derek Ross,
Councillor John Stuart, Councillor Draeyk Van Der Horn 
APOLOGIES 
Ms Anna Bamforth, Mr Ronald Tolmie 
IN ATTENDANCE 
Also in attendance at the above meeting were the Depute Chief Executive
(Economy, Environment and Finance), Head of Housing and Property Services,
Property Asset Manager, Building Services Manger, Georgina Anderson, Senior
Solicitor and Lindsey Robinson, Committee Services Officer as Clerk to the
meeting. 
1.         Chair 
Councillor Amber Dunbar, as 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 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. 
3.         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 Item 9 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. 
Paragraph
Number of Minute Paragraph Number of Schedule 7a and Reason 
9  9 - Information on terms proposed or to be proposed by or to
the Authority. 
Item 4.
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4.         Minute of the meeting of the Housing and Community Safety
Committee of 14 February 2023 
The minute of the meeting of the Housing and Community Safety Committee
dated 14 February 2023 was submitted and approved. 
5.         Written Questions ** 
The Committee noted that no written questions had been submitted. 
6.         Housing and Property Services Service Plan 2023-24 
A report by the Depute Chief Executive (Economy, Environment and Finance)
invited the Committee to consider the Housing and Property Services Service Plan
for 2023-24. 
Following consideration the Committee agreed to approve the Service Plan for
Housing and Property Services at Appendix I. 
7.         Housing Investment 2023-24 
A report by the Depute Chief Executive (Economy, Environment and Finance)
informed the Committee of the planned investment work included within the Housing
Investment Plan for 2023/24 that was approved at Council on 1 March 2023
(paragraph 7 of the minute refers) 
Following consideration, the Committee agreed to note the planned works which will
improve the Council's Housing stock. 
8.         Question Time *** 
Under reference to paragraph 7 of the minute of this Committee dated 14 February
2023, Councillor Gatt sought clarification on the action response he had
received.  He was of the opinion that it should contain information on who had
asked for the information. 
In response the Clerk advised that she would check to see if any changes could be
made to the form used. 
Under reference to paragraph 7 of the minute of this Committee dated 14 February
2023, Councillor Keith sought an update on the extended programme of moss
removal. 
In response the Property Asset Manager advised that he would email Councillor
Keith an up to date list of the properties. 
Councillor Fernandes sought clarification on whether the Council’s Domestic Abuse
policy met the updated standards. 
In response, the Head of Housing and Property Services advised that the policy
meets all standards set by the CIHA and their “Make A Stand” campaign was seen
as best practice across the sector.  The policy will be reviewed periodically and any
changes needed will be considered. 
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9.         Building Services Trading Operation Budget 2023-24 - Annual Budget
[Para 9] 
A report by the Depute Chief Executive (Economy, Environment and Finance)
presented the Building Services Trading Operation Budget for 2023/24. 
Following consideration the Committee agreed to: 
i. approve the proposed Building Services Trading Operation Budget for 2023/24,
as detailed in section 5 and Appendix I of the report; 
ii. approve the service development proposals at a cost of £165k as detailed in
section 6 of the report; 
iii. note the 2023/24 Building Services business priorities highlighted in section 7 of
the report; and 
iv. note Building Services anticipated key performance outputs for 2023/24, as set
out in section 8 of this report. 
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REPORT TO: HOUSING AND COMMUNITY SAFETY COMMITTEE ON 27 JUNE
2023                                                                                                       
SUBJECT: PERFORMANCE REPORT (HOUSING AND PROPERTY
SERVICES) – PERIOD TO MARCH 2023 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 To inform the Committee of the performance of the service for the period to 31
March 2023. 
1.2 This report is submitted to Council in terms of Section III (A) (4) of the
Council's Scheme of Administration to monitor performance of the services
within the Committee’s remit in accordance with the Council’s performance
management framework. 
2. RECOMMENDATION 
2.1 It is recommended that Committee: 
(i) Scrutinises performance in the areas of Service Planning, Service
Performance and other related data to the end of March 2023; and 
(ii) Notes the actions being taken to improve performance where
required. 
3. BACKGROUND 
3.1 On 7 August 2019, the Moray Council, approved a revised Performance
Management Framework for services (para 5 of the minute refers).   
4. SERVICE PLANNING 
4.1 Each service plan sets out the planned strategic and service level priorities
and outcomes it intends to deliver in the coming year aligning closely with
financial planning, corporate and community planning partnership strategic
priorities. This report provides an interim update on progress on the service
plan, key outcomes and performance indicators. The Committee is invited to
review progress to secure assurance that it is satisfactory and to provide
scrutiny and further direction where performance requires attention.
Item 6.
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4.2 The narrative included is by exception, links to Service Plan Actions and
Performance Indicators can be accessed within the Backing Papers of this
report. 
4.3 Initial publication of 2021-22 Local Government Benchmarking Framework
Indicators in February 2023 will be refreshed in June.  The full suite can be
viewed using the My Local Council tool.  Published indicators for this service
have been incorporated within the relevant section of this report depending on
whether results are used to evidence progress against strategic, service plan
or service performance priorities.   
SERVICE PLAN PRIORITIES RAG  
STRATEGIC
LEVEL
Implementation of Property Asset
Management Appraisal (PAMA) 86% 
Purchase land in Forres and
Speyside 37%
Enhance Tenant Participation 42%  
SERVICE
LEVEL
Systemic Review of Voids  94%
Rent Setting Policy Review  26%
Review of Rapid Rehousing
Transition Plan 100%
Annual reviews of asset valuations for
financial reporting  82%
Improvements to ICT within Asset
Team 26%
Effective Delivery of Housing
Management Service  91%    
OVERALL PLAN PROGRESS 62%       
Strategic Outcomes - successes 
4.4 Nothing to report 
Strategic Outcomes – challenges and actions to support 
4.5 Progress with actions contributing to the implementation of the Property Asset
Management Appraisal will continue outwith original due dates.  The depot
review outline business case will be revised to include elements relating to the
vehicle refuelling strategy, reporting is anticipated in autumn 2023.  The Best
Value review of the Housing Maintenance Partnership has made limited
progress, resourcing issues within the Housing Asset Management Team
have been resolved therefore progress is expected over the next six months.
(ACTIONS: HP23-4.1aii, 4.1aiii) 
4.6 With initial land purchases in Forres and Speyside for industrial development
no longer viable, the Commercial Asset Management Team will continue to
liaise with Planning to identify potential sites as part of early work on the next
Moray Local Development Plan.  Capital funding for this will be moved to later
7
3
7
17
7
SERVICE PLAN PI'S
Above Target
Within
Target
Below Target
Data Only
Data not
available
41
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years in the Capital Plan and future opportunities will be progressed through
normal channels.  (ACTIONS: HP23-4.2a-d) 
4.7 As at March 2023, the review and enhancement of tenant participation is 42%
complete.  Following appointment of the Customer Engagement Officer in
April and dedicated time committed by an Area Housing Manager, the pace of
progress is anticipated to increase through establishing baseline participation,
aligning the Tenant Participation Strategy to corporate participatory budgeting
targets and undertaking the tenant survey, due in 2024.  An interim measure
of tenant satisfaction is gathered routinely in the percentage satisfied with the
standard of homes when moving in, which decreased from 83% to 72% in the
year ended March 2023, remaining below target (90%).  Actions to address
will be carried forward through the ongoing review work stream.  (ACTIONS:
HP23-4.3a-d INDICATOR: H2.3) 
Service Level Outcomes – successes 
4.8 A systemic review of voids is nearing completion with over half the
improvement actions identified by the Void Working Group complete.  Regular
review by the Group will ensure ongoing service improvements are
progressed.   Albeit whilst remaining above targets, there are early signs of
the improvements in indicator results as at March 2023, the annual
percentage of rent loss due to voids dropped to 1.01% and average time
taken to re-let empty properties fell to 52 days. (ACTION: HP23-5.1
INDICATORS: H5.4, H5.6) 
4.9 Contributing to delivery of the Rapid Rehousing Transition Plan, targets to
reduce temporary accommodation unit numbers by 5% and the homeless
journey by 1 week were achieved.  Stock levels fell from 134 to 125 and the
average journey time for homeless applicants reduced from 125 days to 104
days in the year to March 2023.  Throughout the 2022/23 period, B&B
accommodation has been required due to increases in homeless demand, to
avoid this in future, stock will need to increase by around 6 units.  Further
improvement on journey time will be challenging unless homeless approaches
reduce or turnover of available lets increases. (ACTIONS: HP23-5.3b-c) 
Service Level Outcomes – challenges and actions to support 
4.10 Rent setting policy review is progressing outwith original due dates with work 
paused due to year end activities.  Consultants have presented modelled 
scenarios of options for officer review and anticipate engaging with  tenants 
on proposals and finalising the approach to a multi-year rent strategy 
and revised rental structure by autumn 2023. (ACTIONS: HP23-5.2b-d 
INDICATORS: H2.1, H5.3, H5.5) 
4.11 Annual reviews of asset valuations are nearing completion, the valuation
review paper has been drafted and submitted to Finance for consideration,
initial meeting held with External Auditor who have scheduled scrutiny in July. 
(ACTION: HP23-5.4) 
4.12 Improvements to ICT systems within the Asset Team have slipped by around
a year.  The licence has been purchased, Iworld consultancy engaged and
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implementation plan agreed from May to August 2023 with process mapping
to follow solution and design phase by March 2024. (ACTION: HP23-5.5) 
4.13 Final stages of implementing the revised Housing Management structure will
complete this work stream, with an additional Area Housing Manager and
Area Housing Officers in post, allocation to area housing teams is being
finalised. (ACTION: HP23-5.6c) 
5. SERVICE PERFORMANCE 
5.1  In line with the Performance Management Framework, operational
performance is reviewed quarterly by departmental management.  Areas
performing well and/or areas subject to a decreasing trend or where
benchmarking results show performance significantly below comparators will
be reported to this committee for member scrutiny.   
5.2 The narrative included in this report is by exception, links to Service
Performance Indicators can be accessed within the Background Papers at the
end of this report. 
Operational Indicators - successes 
5.4 In the year ended March 2023, 90.2% of repairs were completed right first
time, an improvement on performance last year (85.5%) and meeting target
(90%).  (INDICATORS: H2.11) 
Operational Indicators - challenges and actions to support 
5.5 As at March 2023, 88% of emergency reactive repairs and 18% of void
reactive repairs were completed within timescales, falling below the target
levels expected, 99.9% and 98% respectively.  All other reactive repair
categories achieved accepted levels of performance.  Void repairs often
involve coordination of multiple trades that impact on timescales, a factor the
Void Working Group will give further consideration to.  (INDICATORS:
H2.10a, H2.10e). 
6. OTHER PERFORMANCE RELATED DATA 
Complaints & MP/MSP Enquiries
9
4
2
20
1
SERVICE PERFORMANCE PI'S
Above Target
Within Target
Below Target
Data Only
Data not
available
36
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6.1  In line with the Performance Management Framework, complaints are
reviewed quarterly by departmental management in terms of time taken to
respond, outcome and learning points. Links to complaints tables can be
accessed within the Backing Papers of this report. 
6.2 A total of 104 complaints were closed in the half year to March 2023 of which
91 (87.5%) were frontline stage, 9 (8.7%) were investigative stage, and 4
(3.8%) were escalated.  As a comparison, in the same period last year, 78
complaints were closed.   
6.3 In the same period 72 (79%) of frontline complaints, 8 (89%) of investigative
and 4 (100%) escalated complaints were upheld or part upheld, a consistent
trend that the service is further reviewing. 
6.4 The majority of upheld or partially upheld complaints (63) related to Repairs,
Capital and Planned maintenance. 
6.5 A total of 72 MP/MSP enquiries were received during the second half of
2022/23, 32% of the total number received, all were resolved. 
Other Performance (not included within Service Plan) 
6.6 The service completed the acquisition of properties 35 large family homes in
Elgin through open market and Ministry of Defence immediately prior to the
end of the reporting year. These will make a considerable contribution to
alleviating unmet housing need both for those households being directly
rehoused and by freeing up other accommodation in the area.   
Case Studies 
6.7 The service has continued to support the national response to the crisis in
Ukraine, ensuring housing needs are met after initial host arrangements
ended. The acquisition of properties detailed in 6.6 has also enabled the
Council to support the national programme to assist Afghan nationals
displaced following the evacuation from Kabul.   
6.8 Nothing to report. 
7. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
Performance measurement is used to ensure the efficient and
sustainable delivery of services to meet the Council’s priorities in both
the Corporate Plan and the LOIP. 
(b) Policy and Legal
The Council has a statutory requirement to publish a range of
information that will demonstrate that it is securing best value and assist
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in comparing performance both over time and between authorities where
appropriate. 
(c) Financial implications
None. 
(d) Risk Implications
None. 
(e) Staffing Implications
None. 
(f) Property
None. 
(g) Equalities/Socio Economic Impact
An Equality Impact Assessment is not required as this report is to inform
the Committee on performance. 
(h) Climate Change and Biodiversity Impacts
No direct implications 
(i) Consultations
The Head of Housing and Property Services, Depute Chief Executive
(Economy, Environment & Finance) and Service Managers, have been
consulted with any comments received incorporated into this report. 
8. CONCLUSION 
8.1 As at 31 March 2023, the plan overall is 61% complete. Four actions or
sub actions having been completed.  Work to address slippage is
detailed within relevant sections of this report. 
Author of Report: Christopher Dewhurst, Research & Information Officer
Background Papers: Service Plan Actions 
Service Plan Performance Indicators 
Service Performance Indicators 
Service Complaints
Ref: SPMAN-1285234812-1347
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REPORT TO: HOUSING AND COMMUNITY SAFETY COMMITTEE ON 27
JUNE 2023 
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) scrutinises and notes progress on the Moray Affordable Housing
Investment Programme; 
ii) scrutinises and notes progress on the delivery of the Council’s
new build and acquisition programme; 
iii) agrees the amended strategic approach to the Council’s
acquisition programme; 
iv) scrutinises and notes progress on delivery of housing at Bilbohall,
Elgin; and 
v) notes the Council’s response to the Additional Dwelling
Supplement Consultation. 
3. BACKGROUND 
3.1 The Council receives an annual resource allocation from the Scottish
Government to fund the supply of new affordable housing in Moray.  The
Council’s Strategic Housing Investment Plans (SHIP) determines how this
funding will be used to plan and deliver the affordable housing priorities of
Item 7.
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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 be measured.  The Council and
Registered Social Landlords (RSLs) are the principal developers of
affordable housing in Moray. 
3.2 On 15 July 2021, the Scottish Government provided the Council with a
Resource Planning Assumption (RPA) of £46.2m for 2021/22 to 2025/26.   
Year 2021/22 2022/23 2023/24 2024/25 2025/26 Total
Moray £10.357m £8.927m £8.902m £8.933m £9.981m £46.200m 
3.3 On 15 November 2022, this Committee approved the Council’s SHIP
(paragraph 10 of the Minute refers). 
3.4 The last update on the Affordable Housing programme was presented to this
Committee on 14 February 2023 (paragraph 6 of the Minute refers). 
4. MORAY STRATEGIC LOCAL PROGRAMME (SLP) 
Outturn 2022/23
4.1 The spend achieved in 2022/23 exceeded RPA by 27%.  £11.332m was
spent on provision of affordable housing against RPA of £8.927m.  This
positive outcome was due to Moray’s ability to bring projects forward and so
take advantage of project slippage and underspend within the wider
Highlands and Islands administrative region. 
4.2 New build completions during 2022/23 
Site Town No of
units Landlord Completion
date 
Ferrylea R3 Phase 1 Forres 37 Grampian HA Aug 2022
Village Garden, Elgin South Elgin 25 Hanover HA Sep 2022
Findrassie Phase 1 Elgin 28 Cairn HA Sep 2022
Hamilton Drive Elgin 4 Osprey Nov 2022
Total 94   
4.3 Open market acquisitions completed during 2022/23 
Location Town No of
units Vendor completion
(est)
Pinegrove Elgin 33 MOD Mar 2023
Springfield Drive Elgin 2 MOD Mar 2023
Pinegrove Elgin 1 Private seller Mar 2023
Total 36   
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2023/24
4.4 The Scottish Government and the Council have agreed a SLP for 2023/24
based on the resource allocation of £8.902m.   
4.5 As in previous years, the Moray programme will be delivered by a
combination of the Council and the RSLs, Grampian Housing Association,
Cairn Housing Association, Osprey Housing. 
4.6 Currently under construction 
Site Town No of
units Landlord Completion
date (est)
Fyvie Green, Elgin South Elgin 17 Moray Council May 2023
Banff Road Phase 1 Keith 33 Moray Council Jul 2023
Knockomie (R1) Forres 28 Cairn HA Oct 2023
Ferrylea R3 Phase 2 Forres 43 Grampian HA May 2024
Total 121   
4.7 Site start expected during 2023/24 
Site Town No of
units Landlord Site start
(est)
Banff Road, Keith Ph2a Keith 26 Moray Council Oct 2023
Speyview Phase 1 Aberlour 30 Moray Council Mar 2024
Village Green/Bain Ave Elgin 24 Grampian HA Mar 2024
Findrassie Ph2b Elgin 18 Grampian HA tbc
Muirton, Buckie Ph1 Buckie 16 Osprey Housing tbc
Total 98   
4.8 Site start expected during 2024/25 
Site Town No of
units Landlord Site start
(est)
Kineddar Meadows Ph2 Lossiemouth 24 Osprey Housing Jun 2024
Western Village, Elgin South Elgin 47 Grampian HA Jun 2024
Bilbohall Phase 1 (R2) Elgin 105 Moray Council Jul 2024
Lesmurdie Field, Elgin Elgin 18 Places for People Nov 2024
Total 194   
4.9 The amount of More Homes Division grant required has been over-
committed against RPA, but this has the support of the Scottish Government
as an opportunity to take advantage of programme slippage in other local
authority areas and to contribute to the aims of Housing to 2040. 
4.10 Officers and local development partners will continue to take steps to ensure
that a sufficient pipeline of alternative development opportunities is available,
as a contingency against slippage.  These will be mainly sites already in the
approved SHIP. 
4.11 Progress on programme delivery will be reported to this Committee on a
biannual basis. 
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5. HRA BUSINESS PLAN AND WIDER ECONOMIC CONDITIONS 
5.1 The timing of the delivery of new Council housing must be within the capacity
for prudential borrowing, taking cognisance of the HRA Business Plan
assumptions. Following review of the Housing Business Plan in March 2023,
the Council agreed that provision for 50 council houses to be built per annum
would continue to be made, noting that this is a multi-year outlook and actual
output year to year will vary according to development programmes. 
5.2 The current economic conditions are adversely affecting progress and
affordability.  Supply chain shortages are easing, but labour shortages
persist.  Financial issues relating to increased development costs, interest
rates and inflation combined with limited levels of Scottish Government
subsidy continue to make achieving financial viability very challenging.   
5.3 In this context, Moray Council projects have been delayed i.e. Bilbohall, Elgin
in common with a Grampian HA project at Garmouth Road, Lhanbryde.  It
may be necessary to landbank sites and/or delay site starts based on the
HRA prudential borrowing position e.g. Banff Road, Keith (Phases 2/3). 
5.4 The forward programme illustrated above at Paras 4.7 and 48 will be
informed by the ongoing rent restructuring project which is expected to
complete during summer/autumn 2023. 
6. COUNCIL NEW BUILD AND ACQUISITION PROGRAMME PROGRESS 
Bilbohall, Elgin 
6.1 Planning consent was granted for 194 units and associated shared
infrastructure on 23 March 2021.  The consented site is owned by Moray
Council and Grampian Housing Association.  In December 2021, the Council
published a tender for 84 units on the Council owned site, and all the
associated shared infrastructure, for the second time, with the support of
HUB North Scotland Ltd acting as employers agent.  Detailed costs have
been considered but the tender received was not financially viable.  Officers
are pursuing an alternative site design with a density comparable to
commercial housebuilders (105 units), which is more likely achieve financial
viability.  Officers are currently seeking an appropriate procurement route to
appointment of a multi-disciplinary design team to prepare further planning
application(s), before a further tender can be issued.  It is unlikely that this
development will achieve site start within 2023/24. 
Speyview, Aberlour Phase 1
6.2 Moray Council acquired the land for 30 units, with the support of Scottish
Government funding, from Springfield Properties in March 2022.  The
purchase was subject to a 1 year buy back agreement.  This project features
in the Growth Deal Housing Mix full business case.  There have been
significant delays in agreeing infrastructure provision on the site, particularly
with Scottish Water, but these are approaching resolution.  The Scottish
Government More Homes Division are prepared to front fund some of the
cost of infrastructure required for future phases of affordable housing, due to
the strategic importance of this development.   
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Banff Road, Keith Phases 1 and 2
6.3 Handover and occupation of the vast majority of Phase 1 development was
achieved during Apr/May 2023.  Radon testing processes and building
control approvals are proceeding on the remaining 2 properties.  The Council
has taken advice from an independent Radon consultant regarding risk and
ongoing testing and maintenance, and has a legal agreement with
Springfield Properties which seeks to protect the Council from any ongoing
liability arising from the presence of radon gas in the properties, and the
mitigation measures which have been fitted. 
6.4 There is an opportunity to bring forward part of Phase 2 (26 units) into the
2023/24 development programme.  This has the support of the Scottish
Government as it will minimise the potential loss of grant funding to Moray
the 2023/24 programme.  Phase 2 development was included in the SHIP
approved in November 2022, and in the HRA Business Plan reviewed in
February 2023.  Proposals will be presented to this Committee for approval
once the outputs from the Rent Restructure project are clearer, during
summer/autumn 2023. 
7. LAND AND BUILDINGS TRANSACTION TAX CONSULTATION 
7.1 On 8 February 2023, the Scottish Government issued a consultation on the
Additional Dwelling Supplement (ADS) which included a variety of proposed
amendments to Land and Buildings Transaction Tax (LBTT) and ADS.  Most
of the questions related to private sector conveyancing and were not directly
relevant to the Council’s acquisition of properties or development sites. 
However, the consultation proposed that Councils cease to be liable for
LBTT, providing parity with RSLs. 
7.2 Therefore, in answer to the question “Local Authorities, Do you think that the
proposed amendments provide for the Scottish Government’s intended
change?”, where only a yes/no response was required, the Council’s
response of “yes” was submitted within the deadline, on 5 April 2023. 
7.3 In answer to a question relating to the impact on equal opportunities and
human rights the following response was submitted; 
“The relief from LBTT and ADS … will have a positive impact on local
authority budgets, particularly on the resources available to increase
provision of affordable housing.  Given the priority assigned in Moray’s Local
Housing Strategy to increasing provision of affordable housing for older and
disabled people, the resulting increase in resources will have a positive
impact on those needs groups”. 
8. MORAY COUNCIL ACQUISITIONS PROGRAMME 
8.1 On 15 November 2022, this committee approved the Strategic Housing
Investment Plan 2023/24-2027/28 (SHIP) (paragraph 10 of the Minute
refers).  The SHIP provides grant funding facility for the Council to purchase
properties from the open market for provision of affordable housing, where
strategic and value for money criteria have been met. 
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8.2 Officers recommend an expansion of those criteria to facilitate acquisitions
which will meet housing need in areas where housing construction is
constrained.  It is envisaged that this change would increase affordable
housing stock in rural areas in particular e.g. Speyside.  The criteria would be
amended to: 
Open market purchases will be prioritised as follows: 
1. Where the purchase will assist the Council with delivery of SHQS/
EESSH/ capital improvements
2. Where the purchase will assist the Council to meet housing need in
pressured areas and/or where new affordable housing development is
constrained.
3. Where the purchase will assist the Council to meet specialist housing
need
4. Where the purchase will bring an empty property back into occupation 
9. 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 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 fund the Council’s housebuilding programme. The
increasing cost of the programme may lead to a higher level of
borrowing than anticipated in the business plan and therefore reach
thresholds earlier than anticipated.  Dialogue has taken place with
Finance regarding the approach to managing this and modelling of
implications and consideration of mitigations will take place to inform
any decision to bring forward developments. 
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(d) Risk Implications
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, the
increase in interest rates will impact on the cost of borrowing.  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 contained 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 Lindsey Robinson, Committee Services
Officer. 
10. CONCLUSIONS 
10.1 The report provides details of an update on the current and future
affordable housing investment programme.  The report also provides
an update on the Council’s own new build and acquisition programme,
including an update on procurement of housing at Bilbohall, Elgin. 
Author of Report: Fiona Geddes, Housing Strategy and Development
Manager
Background Papers: with author
Ref: SPMAN-1285234812-1339
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REPORT TO: HOUSING AND COMMUNITY SAFETY COMMITTEE ON 27 JUNE
2023 
SUBJECT: ALLOCATIONS POLICY ANNUAL PERFORMANCE REPORT
2022/23 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 To inform the Committee of the performance of the Council’s Allocations
Policy during 2022/23. 
1.2 This report is submitted to the 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. RECOMMENDATION 
2.1 It is recommended that the Committee: 
i. considers and notes the performance identified within the report;
and 
ii. agrees the allocations quotas for 2023/24 detailed at Paragraph 5.5
of this report. 
3. BACKGROUND 
3.1 The Communities Committee approved a revised Allocations Policy on 5
February 2019 (Paragraph 9 of the Minute refers) for implementation on 1
May 2019. 
3.2 The Communities Committee approved Moray’s Local Housing Strategy
(LHS) 2019-2024 on 2 April 2019 (Paragraph 6 of the Minute refers).  The
LHS sets out the Council’s approach to addressing housing need and
homelessness, property condition and fuel poverty.  The operation of the
Allocations Policy is a key factor in the delivery of LHS outcomes. 
Item 8.
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3.3 The Communities Committee has considered performance monitoring
information on the operation of its Housing Allocations Policy annually since
2005.  The most recent report was presented to this Committee on 21 June
2022 (Paragraph 9 of the Minute refers). 
4. ANALYSIS OF HOUSING LIST ALLOCATION AND DEMAND TRENDS 
4.1 Statistical information on the operation of the policy is presented in
APPENDIX I.  The statistics for 2020/21 and 2021/22 should be viewed in the
context of the national response to the COVID-19 pandemic and associated
restrictions in activity: 
4.2 Table 1 provides details of the housing list for the last 5 years. This shows
that the Transfer List remains relatively stable, the Waiting list has been
reducing slightly over 5 years, but that the Homeless list has increased by
17% between March 2022 and March 2023. 
4.3 Housing List trends are being considered in depth as part of the development
of Housing Needs and Demand Assessment (HNDA) and forthcoming Local
Housing Strategy (LHS) 2024-2029, and will be reflected in the revised
Allocations Policy currently in development. 
4.4 Table 2 details the size and type of housing required by applicants on the
housing list. Over the past 5 years, there have been significant increases in
demand for larger 4+bed family sized housing and in amenity/accessible
housing, with corresponding reductions in demand for 2 and 3 bed general
needs housing. 
4.5 The increased demand for accessible housing is consistent with the projected
demographic changes in Moray and the ageing population.  Demand for
sheltered housing has remained almost unchanged despite demographic
changes. 
4.6 Approaches to increasing supply of affordable housing detailed in the Local
Housing Strategy and Strategic Housing Investment Plan are aligned to these
changes in demand. 
4.7 Table 3 provides summarised information on the 1st area preferences of
current housing list applicants. It shows that area preferences are broadly in
proportion to the number of dwellings (all tenures) in each Housing Market
Area. 
4.8 Applicants who apply for housing are able to state where they want to live.
This allows them the choice of any, or all, of the 62 lettings areas across
Moray. These choices can be driven by urgency and availability, rather than a
desire to live in a particular area. To support strategic planning for affordable
housing, applicants are asked separately to state their 1st, 2nd and 3rd areas
of preference (i.e. where they would ideally choose to live). This second,
strategic question is the source used to inform the Council’s approach to
delivery of new affordable housing across geographical areas, and is reflected
in the Strategic Housing Investment Plan (SHIP). 
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4.9 Table 4 provides details of the number of re-lets from Council stock in
2022/23.  When this is compared to the housing list as at 31 March 2023, it
shows that there were 6.5 applicants on the list per re-let (6:1) during 2022/23. 
However this pressure varies greatly across house types and sizes: 
• 1 bed general needs (63:1);
• 2 bed general needs (5:1); 
• 3 bed general needs (8:1); and 
• 4 bed (32:1). 
4.10 The table also shows that there is no evidence of significant migration
between Housing Market Areas (HMA). 
4.11 Table 5 shows that, there is an increasing trend in re-let rates, as intended,
with the introduction of the revised Allocations Policy in May 2019.  Increasing
the numbers of vacancies from existing stock will assist the Council to
successfully deliver the Rapid Rehousing Transition Plan.  Although the
number of relets had reduced in 2020/21, this can be attributed to the
COVID19 restrictions on house-moves in all tenures for part of 2020. 
5. ALLOCATIONS QUOTAS FOR THE HOUSING LIST 
5.1 The housing list consists of three separate lists (waiting, transfer and
homelessness).  The Homeless List includes those who have been assessed
as statutorily homeless, the Waiting List consists of applicants who are waiting
for a council house, and includes current RSL tenants; and the Transfer List of
those who are current Council tenants and who need or want to move.  The
proportion of allocations to be made to each list is determined annually by
Committee. 
5.2 Following the cessation of the Grampian wide common housing register
Apply4Homes, the Council’s online housing application form was implemented
on 29 April 2021.  The implementation process required all housing list
applicants to reregister on the new system.  This process has resulted in a
reduction in the number of applications from households with no connection to
Moray.  Although the totals presented in Table 1 have reduced, there is no
significant change in the number of households who do have a local
connection to Moray, i.e. those who would be most likely to receive an offer of
housing. 
5.3 Table 6 shows the proportion of allocations made to applicants from the 3
housing lists, over the last 5 years.   
5.4 The Rapid Rehousing Transition Plan aims to minimise the use of temporary
accommodation and provide permanent housing options to homeless
households as quickly as possible.  The Homeless List quota proposed below
is intended to strike an appropriate balance between the need to implement
the Rapid Rehousing Transition Plan, and the need to minimise any
unintended consequences of increased quota i.e. that the Homeless List
would be seen by applicants as the quickest route into permanent housing,
and would significantly increase as a result.  
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5.5 Historically this Committee has taken a pragmatic view and agreed quotas
intended to strike an acceptable balance between all lists. The quotas
proposed for 2023/24 have been modified slightly to reflect the reduction in
the Waiting List and increase in the Transfer list (see APPENDIX I, Table 1). 
An increase in the Transfer List quota will generate more availability of
housing and so assist the Council to deliver the Rapid Rehousing Transition
Plan.  The quotas are illustrated in the table below: 
List Target
(existing)
Target
(alternative) Tolerance
Homeless List 50% 50% +/-5%
Waiting List 32% 30% +/-5%
Transfer List 18% 20% +/-5% 
6. NEW BUILD LETTINGS PLAN 
6.1 The new build lettings plan was introduced in 2015.  The Plan sets out how
the Council will deviate from the Allocations Policy in identifying the first tenant
in new build properties, with the aim of establishing successful, sustainable
new communities, and this includes deviation from Housing List quotas. 
6.2 Table 7 shows there were 8 Council new lets during 2022/23.  Acquisitions
completed shortly before year end were not let by 31 March 2023. 
6.3 Table 8 shows the proportions of allocations from each List, and that 47% of
new lets were allocated to Transfer List applicants. 
7. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
Moray 2027 and the Service Plan identify the need to address the
shortage of affordable housing and tackle homelessness.  The
Allocations Policy seeks to make the best use of the Council’s housing
stock and promote healthier citizens and more people living well in their
communities. 
(b) Policy and Legal
The primary legislation governing allocations of Council housing is
contained within the Housing (Scotland) Act 1987 as amended by the
Housing (Scotland) Act 2001, the Homelessness etc. (Scotland) Act
2003 and the Housing (Scotland) Act 2014. This legislation provides the
Council with the discretion to develop allocation and local letting policies
in line with local priorities. 
The Scottish Social Housing Charter sets out standards against which
the Scottish Housing Regulator will assess local authorities as part of its
inspection regime. 
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(c) Financial implications
There are no financial implications arising from 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
There are no property implications arising from this report. 
(g) Equalities/Socio Economic Impact
There are no impacts in relation to equal opportunities or the socio-
economic duty as the purpose of the report is to inform Committee on
performance. 
(h) Climate change and Biodiversity Impacts
There are no climate change and biodiversity implications arising from
this report. 
(i) Consultations
Consultation on this report has taken place with the Depute Chief
Executive (Economy, Environment and Finance), Head of Housing and
Property, Housing Needs Manager, Housing Services Manager, Chief
Financial Officer, Equal Opportunities Officer, Georgina Anderson (Legal
Services Senior Solicitor), and Lindsey Robinson (Committee Services
Officer).   
8. SUMMARY OF IMPLICATIONS 
8.1 This report presents the annual review of the operation of the Council’s
Housing Allocations Policy.  It also presents proposed allocations
quotas for 2023/24.  The quotas proposed are intended to complement
implementation of the Rapid Rehousing Transition Plan. 
Author of Report: Fiona Geddes, Housing Strategy and Development
Manager
Background Papers: with author
Ref: SPMAN-1285234812-1340 
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Moray Council Allocations Policy Performance Report 2022/23 APPENDIX I
Table 1:  No of applicants on the Housing List at year end
List 2018/19 2019/20 2020/21 2021/22 2022/23
Change
since
2018/19
(No)
Change
since
2018/19
(%)
Homeless List 121 92 101 97 114 -7 -5.8%
Housing Waiting List 2,474 2,989 2,425 2,754 2,278 -196 -7.9%
Transfer List 552 628 533 621 559 7 1.3%
Total 3,147 3,709 3,059 3,472 2,951 -196 -6.2% 
Table 2:  Size and type of property sought by applicants at year end
Property size and type 2018/19 2019/20 2020/21 2021/22 2022/23
Change
since
2018/19
(No)
Change
since
2018/19
(%)
1 bed general needs 1,210 1,427 1,180 1,347 1,132 -78 -6.4%
1 bed amenity/ wheelchair accessible 325 526 418 487 409 84 25.8%
2 bed general needs 701 713 590 682 597 -104 -14.8%
2 bed amenity/ wheelchair accessible 108 152 123 138 133 25 23.1%
3 bed general needs 437 518 442 466 367 -70 -16.0%
3 bed amenity/ wheelchair accessible 27 34 31 37 36 9 33.3%
4 bed general needs 146 201 168 195 153 7 4.8%
4 bed amenity/ wheelchair accessible 13 7 7 11 8 -5 -38.5%
5+ bed all types 42 58 48 68 64 22 52.4%
sheltered 58 73 52 41 52 -6 -10.3%
Total 3,067 3,709 3,059 3,472 2,951 -116   
Item 8.
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Moray Council Allocations Policy Performance Report 2022/23 APPENDIX I
Table 3:  Where applicants wish to live – 1st Area Preference as at 31 March 2023
List Buckie
HMA
Elgin
HMA
Forres
HMA
Keith
HMA
Speyside
HMA
CNP
HMA Total
Homeless List 10 90 11 2 1   114
Transfer List 101 309 68 50 28 3 559
Housing Waiting List 306 1,298 382 148 122 22 2,278
Total 417 1,697 461 200 151 25 2,951
14.1% 57.5% 15.6% 6.8% 5.1% 0.8% 100.0%
% dwellings (Source: HNDA Appendix 2) 16.8% 47.6% 18.0% 8.3% 8.0% 1.2% 100.0% 
Table 4:  Re-lets by property size and type 2022/23 (secure tenancies only)
Property size and type Buckie
HMA
Elgin
HMA
Forres
HMA
Keith
HMA
Speyside
HMA
CNP
HMA Total
ratio/ relative
pressure (lets
vs demand)
Bedsit 6 0 5 0 0 0 11 
1 bed general needs 4 8 2 2 2 0 18 62.9
1 bed amenity/ wheelchair accessible 23 66 14 17 10 1 131 3.1
2 bed general needs 29 54 20 12 17 0 132 4.5
2 bed amenity/ wheelchair accessible 19 35 8 1 4 0 67 2.0
3 bed general needs 16 13 6 7 4 1 47 7.8
3 bed amenity/ wheelchair accessible 3 7 1 5 2 2 20 1.8
4 bed all types 2 2 1 0 0 0 5 32.2
5+ bed all types 0 0 0 0 1 0 1 64.0
sheltered 8 11 6 0 0 0 25 2.1
Total 110 196 63 44 40 4 457 6.5
24.1% 42.9% 13.8% 9.6% 8.8% 0.9% 100.0% 
% dwellings (Source: HNDA Appendix 2) 16.8% 47.6% 18.0% 8.3% 8.0% 1.2% 100.0% 
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Moray Council Allocations Policy Performance Report 2022/23 APPENDIX I 
Table 5:  Rate of relets to Council stock (turnover) (new lets excluded)
Council stock 2018/19 2019/20 2020/21 2021/22 2022/23
Change
since
2018/19
(No)
Change
since
2018/19
(%)
Council stock 6,122 6,149 6,251 6,297 6,342 220 3.6%
No of relets 377 470 340 445 457 80 21.2%
Rate of relets 6.2% 7.6% 5.4% 7.1% 7.2%   
Table 6:  Allocations by Housing list (secure tenancies)(relets and new lets)
List 2018/19 2019/20 2020/21 2021/22 2022/23
Homeless List 187 42.0% 256 51.4% 187 42.0% 256 51.4% 236 50.8%
Housing Waiting List 149 33.5% 143 28.7% 149 33.5% 143 28.7% 151 32.5%
Transfer List 109 24.5% 99 19.9% 109 24.5% 99 19.9% 78 16.8%
Total 445 100.0% 498 100.0% 445 100.0% 498 100.0% 465 100.0% 
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Moray Council Allocations Policy Performance Report 2022/23 APPENDIX I 
Table 7:  Moray Council new build completions 2022/23 (new lets)
House type  Buckie
HMA
Elgin
HMA
Forres
HMA
Keith
HMA
Speyside
HMA
CNP
HMA Total
1 bed general needs   8         8 17.8%
2 bed general needs            0 0.0%
2 bed amenity/wheelchair accessible   1         1 2.2%
3 bed general needs   32         32 71.1%
3 bed amenity/wheelchair accessible            0 0.0%
4+ bed all types   4         4 8.9%
Total  0 57 0 0 0 0 45 100.0% 
Table 8:  Moray Council new lets at 31 March 2023 
List 2019/20 2020/21 2021/22 2022/23
Homeless List 5 17.9% 11 5 17.9% 12.1% 5 62.5%
Housing Waiting List 6 21.4% 37 6 21.4% 40.7% 1 12.5%
Transfer List 17 60.7% 43 17 60.7% 47.3% 2 25.0%
Total 28 100.0% 91 28 100.0% 100.0% 8 100.0% 
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REPORT TO: HOUSING AND COMMUNITY SAFETY COMMITTEE ON 27 JUNE
2023 
SUBJECT: DECORATION ALLOWANCE POLICY 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 This report provides an update on the requirement to review the Decoration
Allowance Policy, and presents the Committee with an amended Policy for
approval. 
1.2 This report is submitted to Committee in terms of Section III (G) 3 and 4 of the
Council's Scheme of Administration relating to the management and
maintenance of the Council’s housing stock, and dealing with the allocation
and letting of houses. 
2. RECOMMENDATION 
2.1 It is recommended that the Housing and Community Safety Committee: 
(i) notes the need to review the Decoration Allowance Policy to reflect
changes in operational practice and process as set in Section 3;
and 
(ii) considers and approves the amended Decoration Allowance Policy
as set out in Section 4 and APPENDIX I. 
3. BACKGROUND 
3.1 The Decoration Allowance Policy was approved by Communities Committee
on 19 March 2008 for implementation from 1 April 2008 (Paragraph 6 of the
Minute refers).  The policy outlined the circumstances under which the Council
would help tenants to make good the decoration of their homes following a re-
let or major works, by providing decoration vouchers, or by undertaking
decoration where a tenant is unable to do so. 
3.2 On 23 April 2013, the Communities Committee considered a further review of
the original Decoration Voucher Scheme (Paragraph 7 of the Minute refers)
and agreed to a pilot which aimed to:
Item 9.
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• address procurement concerns; 
• achieve better value for money for the Council; 
• reduce administration in comparison to the previous voucher scheme; and 
• provide tenants with an improved level of service. 
3.3 Following an appraisal of this pilot, which concluded that it was successful and
highlighted the positive customer feedback achieved, the Communities
Committee approved the Decoration Voucher Scheme on 17 December 2013
and it was adopted on a permanent basis from 1 April 2014 (Paragraph 8 of
the Minute refers). 
3.4 A pilot of the void management process was undertaken in 2019 which aimed
to improve void re-let time, reduce void rent loss and allow properties to be
allocated quicker and more efficiently. As part of this pilot, decoration to void
properties was no longer carried out.  These properties were left in a clean
condition with basic preparatory work undertaken, and a decoration pack was
provided to the incoming tenant to carry out their own decoration.  The area
housing officer would specify if the tenant had vulnerabilities which would
require that the property be decorated for them, before sign up. 
3.5 The success of this pilot resulted in changes to the Void Management Policy,
which was updated, after agreement with the Head of Service, in August 2020
to take into account the changes implemented. 
3.6  These operational changes mean that the Decoration Allowance Policy
requires updating.   
4. DECORATION ALLOWANCE POLICY 
4.1 The revised Decoration Allowance Policy (APPENDIX I) sets out the
framework required for addressing appropriate standards of decoration within
Moray Council housing stock at various stages of a tenancy, to ensure
compliance with the Lettings Standard and housing legislation.   
4.2 The Housing (Scotland) Act 2001, (Section 27 and Schedule 4) states that
landlords must carry out any necessary work within a reasonable timescale,
and make good any damage caused by them in carrying out the work. 
4.3 The Letting Standard sets out the minimum standard a property should meet
upon re-let. It states that the internal decoration will be of an acceptable
standard.  No decoration is carried out to void properties unless the tenant
requires the service due to any specific needs or vulnerabilities or the internal
decoration is below that defined in the Letting Standard, for example is either:
• badly marked or smoke stained;
• painted a dark or strong colour which would be difficult to cover; or
• in poor condition, for example if the wallpaper is torn.  
The majority of voids will have basic preparation work done and paint packs
will be awarded, on a room by room basis.  
4.4 The Decoration Allowance Policy details the circumstances when decoration
packs and compensatory payments will be issued and notes that they are
intended:
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• as a contribution towards the cost of materials and equipment needed to
carry out internal decoration work, but may not always meet the full costs
involved in decoration due to tenant choice of aesthetics, etc.
• to offer the tenant more choice and flexibility when decorating their home.
The policy specifies the eligibility criteria to be met in order for the Council to
provide a decoration service and what it will entail. 
4.5 Decoration packs are issued in the form of a decoration voucher. The voucher
is valid for six months and can only be used with the nominated approved
retailer, Johnstone’s Trade Decorating Centre.   
4.6 Compensation payments may be awarded as a result of damage to
decoration following repair work, or as a payment towards remedial works
following a planned improvement or upgrade.  Compensation payments will
be based on average trade prices and will increase annually in line with
inflation.   Compensation allowances for 2023 – 2024 are set out below. 
Decoration Allowance Flooring Allowance
Kitchen upgrade No allowance – kitchen
will be painted after an
upgrade
£100
Heating upgrade £200 No flooring allowance
required
Blinds payment (due
to windows upgrade)
£100 No flooring allowance
required 
4.7   The changes to the Decoration Allowance Policy are required in order to
reflect current operational practices and internal processes already in place.
There is no requirement to consult with tenants or other stakeholders as there
are no proposals which would significantly affect the tenant (Housing
(Scotland) Act 2001, Section 54). 
5. FUTURE ACTIONS 
5.1 Subject to this Committee’s approval of the amended Decoration Allowance
Policy, an implementation plan will be developed.  This plan will propose a “go
live” date of 31 July 2023, and will involve updating supporting procedures
and reviewing all information resources to reflect the agreed changes. 
5.2 The compensation payments will be updated annually in line with inflation. 
Operational procedures will detail these costs to support staff in their delivery
of the policy. 
6. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP)
The Corporate Plan and the Moray 10 Year Plan (LOIP) identify the need
to provide high quality affordable housing, and priority 4 of the Local
Housing Strategy aims to improve the condition and energy efficiency of
social housing stock. 
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(b) Policy and Legal
There are no policy and legal implications arising from this report. 
(c) Financial implications
The overall increased spend, arising from the higher compensation
payments, will be absorbed from the current decoration budget held by
the Housing Asset Team.   
(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
There are no equalities/socio economic impacts arising from this report. 
(h) Climate Change and Biodiversity Impacts
There are no climate change or Biodiversity impacts 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, Building Services Manager, Officers within the
Housing Service, Chief Financial Officer, Georgina Anderson (Legal
Services Senior Solicitor) and Lindsey Robinson (Committee Services
Officer) have been consulted and any comments have been incorporated
into the report. 
7. CONCLUSION 
7.1  This report updates the Housing and Community Safety Committee on
the requirement to review the Decoration Allowance Policy, which
reflects changes in operational processes and practice, and seeks
Committee approval of the Decoration Policy.   
Author of Report: Janice Heron (Housing Policy and Compliance Officer)  
Background Papers: Held by author
Ref: SPMAN-1285234812-1331 
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APPENDIX I   
Page 1 of 10
Moray Council
Housing & Property Services
Decoration Allowance Policy 
1. Scope of policy
1.1 This policy sets out the framework for addressing appropriate standards of
decoration within Moray Council housing stock at various stages throughout the
tenancy.   This policy applies to all tenants who have a Scottish Secure Tenancy
(SST) or a Short Scottish Secure Tenancy (SSST) with the Moray Council. 
1.2 Managers and Officers within Moray Council’s Housing Service will have the
discretion to authorise and issue decoration packs and compensatory
allowances to new and existing tenants in certain circumstances, to ensure the
standard of decoration is acceptable and meets Moray Council’s Letting
Standard.
2. Strategic Context
2.1 The Decoration Allowance Policy will assist the Council to meet the aims and
priorities of its Local Housing Strategy 2019 – 2024, to improve the stock
condition and energy efficiency of housing in the social sector, as well as the
Moray 2027 - Corporate Plan. 
3. Objectives and principles of the Policy
3.1 The overall aim of Moray Council’s Decoration Allowance Policy is to ensure
tenants receive assistance towards the cost of decorating their home while
Moray Council, as a social landlord, ensure the efficient and effective
maintenance of the Council's housing stock. 
3.2 The specific objectives of the Decoration Allowance Policy are to:
• provide clear guidance regarding the use and authorisation of decoration
packs and compensatory payment allowances;
• ensure the council fulfils its legal duties as a landlord;
Item 9.
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• ensure any disrepair or decoration work required following repairs or
upgrade works, are remedied to meet the Moray Letting Standard;
• publicise the terms of the policy to enable a wider understanding by
tenants, staff and the public; and
• give clear guidance on how disputes will be dealt with. 
3.3 The principles underpinning the policy are:
• the Council will provide internal supporting operational procedures for
staff, incorporating agreed good practice to ensure consistency;
• staff training will be provided to ensure that staff are equipped to carry
out the roles expected of them;
• communication with tenants and service users will be in ‘plain language’;
and
• performance will be monitored to ensure the policy is being adhered to. 
3.4 Decoration packs and payments are intended:
• as a contribution towards the cost of materials and equipment needed to
carry out internal decoration work, but may not always meet the full costs
involved in decoration due to tenant choice of aesthetics, etc.
• to offer the tenant more choice and flexibility when decorating their home. 
3.5 The award of a decoration pack or compensatory payment does not remove the
need for tenants to adequately insure the contents of their homes from damage.   
3.6 The award of a decoration pack or compensatory payment does not remove the
need for staff, carrying out work on behalf of the Council, to take adequate care
to ensure that damage does not occur. 
4. Legal Provisions, Regulations and Standards
4.1 Moray Council will ensure that the Decoration Allowance Policy complies with
current legislation, regulatory requirements and promotes good practice. 
Landlord responsibility to “make good”
4.2 The Housing (Scotland) Act 2001 sets out the main requirements of the policy:  
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• Section 27 and Schedule 4 states that landlords must carry out any
necessary work within a reasonable timescale and make good any damage
caused by them in carrying out the work.
• Section 30 explains the right to compensation for improvements when a
tenancy comes to an end.  Compensation costs will be assessed in line with
regulations from the Secure Tenants (Compensation for improvements)
(Scotland) Regulations 1994. 
4.3 The Council require any contractor to 'make good' any damage that they may
have caused e.g. repair and prepare surfaces for redecoration, but not to
redecorate. 
Tenant responsibility for internal decoration
4.4 Paragraphs 2.3 and 5.17 of Moray Council’s Scottish Secure Tenancy
Agreement (SST) and Short Scottish Secure Tenancy Agreement (SSST) state
that the tenant must take reasonable care:
• to prevent damage to the decoration of the property (this includes the
tenant’s household and any visitors to the property); and 
• of the house, which includes carrying out minor repairs and internal
decoration.  
Tenants are advised of these responsibilities when signing their tenancy
agreement and during their tenancy.   
4.5 Other relevant legal provisions and guidance include, but are not restricted to,
the following:
• General Data Protection Regulations (GDPR) and the Data Protection
Act 2018 - The Council will ensure that any information obtained will be
processed and used accordingly.
• Equality Act 2010 – The Council will aim to ensure that it does not
discriminate against someone because of their protected characteristics.
• Human Rights Act 1998 – The “right to respect for private life”, (article 8
of part I, rights and freedoms) and “protection of property”, (article 1 of
part II, the first protocol) apply, however the safety of tenant’s would
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Page 4 of 10
provide an objective justification with these rights, due to it being a
proportionate means to a legitimate aim.
• The Scottish Social Housing Charter identifies various outcomes that are
relevant.  Outcome 4, “Quality of Housing” ensures that tenants’ homes are
clean, tidy and in a good state of repair when they are allocated.  The
“Repairs, maintenance and improvements” outcome (outcome 5) sets out
that tenant’s homes should be well maintained, and landlords must provide
repairs and improvement services that safeguard the value of their assets. 
The ‘‘Value for Money’ outcome (outcome 13) covers the management of
housing services and makes sure that tenants receive services that provide
value for rent and any other charges they pay. 
5. Decoration allowances
5.1 Decoration allowances will take the form of either:
• a voucher for a decoration pack towards paint and decoration materials; or 
• a compensation payment towards decoration or remedial works following a
planned improvement or upgrade. 
5.2 The size of decoration pack a tenant is eligible for will depend on the number 
and size of the rooms that need decorated and will be calculated on a room by
room basis. 
5.3 Decoration allowances may be allocated in the following circumstances and will
be issued at the discretion of the area housing officer who will assess the
property for damage:
• in cases where a tenant moves into a newly allocated Council property and
the standard of decoration is below that defined within the Moray Letting
Standard;
• where repairs have been carried out by the Council, or by a contractor
working on behalf of the Council, and this has caused excessive damage to
the interior decoration of the property; and
• following any planned maintenance or improvement work carried out by the
Council, or by a contractor working on behalf of the Council, where it is
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Page 5 of 10
deemed necessary for a decoration allowance to be issued, for example,
following the installation of a new heating system. 
5.4 For the purpose of awarding any allowance, extensive damage may mean
partially stripped rooms, badly torn wallpaper that would prove unacceptable to
live with, walls poorly painted where extensive work is required to correct, and
so on. 
5.5 A decoration allowance will not be awarded:
• where the existing tenant has caused damage or neglected the interior
decoration of the property.  Moray Council’s Rechargeable Repairs Policy
will apply in these circumstances;
• to change the interior decoration of a property because it is not the incoming
tenant’s personal taste (unless the decoration is a dark or strong colour that
would prove costly to change, for example black); 
• to act as payment after an incident a tenant should have been insured for;
• where a new tenancy is beginning as a result of a mutual exchange; or
• for a room where the Council, or its contractor, has completed decoration. 
6. Decoration allowance for a new tenancy 
6.1 The Void Management Policy (Section 7), refers to the letting standards and
states that, with regard to decoration purposes:
• the property will be in a clean condition;
• paint packs will be assigned to all voids with the exception of those that have
already been decorated; and
• internal doors, walls, skirtings and facings will be in an acceptable condition
for decorating.  
6.2 Section 8 of the Void Management Policy states that a post termination
inspection will be completed on all voids.  This inspection will assess the
decorative standard of the property and review the level of paint pack to be
granted to the new tenant. 
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6.3 Section 12 of the Void Management Policy confirms that only basic preparation
work, and no decoration, will be carried out on void properties with paint packs
being issued on a room by room basis. 
6.4 Tenants being awarded decoration allowances will be sent their vouchers by
email or post following their sign up, if it is a new tenancy.  They will also be
given a Johnstones decoration booklet with information on how to order their
decoration packs and the conditions attached to their use. 
7. Assistance to decorate
7.1 Where a tenant indicates that they will have difficulty carrying out decoration
works themselves because of any particular needs, age, mobility or
vulnerabilities, the Moray Council will provide a decoration service. Tenants who
qualify for, and would like to use the service, can request it through their Area
Housing Officer. This is usually identified during the viewing process. All
sheltered housing properties where decoration is required will be decorated
before the tenant moves in. 
7.2 The Council’s decoration service will:
• be available as an alternative to any decoration pack, 
• only be available for the rooms which have been previously identified as
requiring a decoration allowance during a void inspection (Void
Management Policy, Section 12);
• take the form of the application of emulsion paint from a limited choice of
colours to walls, and white gloss paint to skirtings, fascias, doors and so on. 
The Council will not apply tenant’s own wallcoverings and will not lay floor
coverings. 
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Page 7 of 10
7.3 To qualify for the decoration service the tenant(s) must:
• have difficulty carrying out decoration work themselves due to any particular
need, age, mobility or vulnerability; and
• be in receipt of benefits such as Disability Living Allowance (DLA), Personal
Independence Payment (PIP), Adult Disability Payment (ADP),
Employment and Support Allowance, or Attendance Allowance; or
• be in receipt of other similar benefits paid to persons with physical
impairments. Tenants will be required to verify receipt of benefits by
showing their Award Letter, payment book and so on; or
• have special, social or medical reasons to have the decoration work
undertaken by the Council.  Moray Council will use its discretion to establish
eligibility based on individual circumstances.  Further information sharing
may be required with NHS staff, Social Work and/or the Housing Support
Team or any other appropriate professional.  This may not be required
where evidence is clearly visible; and
• have no adult member of the household, or other family members, who
could reasonably be expected to carry out the work on the tenant’s behalf.         
The Council will use its discretion to establish eligibility on this ground. 
7.4 Tenants who qualify for the decoration service will be required to:
• agree that their tenancy will begin on the same date as it would have if they
were receiving the decoration pack;  
• give the Council, and/or their approved contractor, access to the property to
carry out the decoration works;  
• move personal possessions, as far as possible, especially ornaments, and
other fragile or valuable items in preparation for the decoration works. 
8. Decoration allowances following repair work
8.1 Moray Council may award a decoration allowance following response repair
work carried out by the Council where the interior decoration has been
damaged. 
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Page 8 of 10
8.2 Where the damage is as a result of the neglect of a employee of the Council, or
its contractor, then this matter will be dealt with on an individual basis through
the Complaints Procedure. 
8.3 Once the repair work has been completed and the area housing officer has been
informed of any damage to the decoration, an area housing officer will carry out
an inspection to assess the property for a decoration allowance entitlement. 
9. Compensation payments following planned maintenance or improvement
works
9.1 Compensation payments will be based on average trade prices and index linked
to increase annually in line with inflation.  Full details of decoration allowance
rates are detailed in the internal operational Decoration Allowance Procedures
for staff and will be updated annually. 
9.2 Following a kitchen upgrade:
• the kitchen will be painted by the Council, or approved contractor, with
emulsion paint from a limited choice of colours, with white gloss paint to
skirtings, fascias, doors and so on.
• a flooring allowance will be given. Rates will be detailed in the internal
operational Decoration Allowance Procedures for staff and will be updated
annually. 
9.3 Following heating upgrades tenants will be provided with a compensation
payment to compensate for any remedial work/decoration required. 
9.4 Allowances for compensating tenants following planned maintenance or
improvement works will be paid following the completion of the work by an
automated payment into the tenant’s bank account. 
10. Use of decoration vouchers
10.1 Decoration vouchers for decoration packs will be valid for six months.  The area
housing manager has discretion to extend this time period, or re-issue another
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voucher to replace the original voucher where the situation warrants it. 
Examples would include a family bereavement or prolonged illness.   
10.2 Decoration vouchers can only be used with the nominated approved retailer,
Johnstone’s Trade Decorating Centre, and cannot be exchanged for cash or
any other products.  Tenants will be given a Johnstone’s decoration booklet with
information on how to order their decoration packs and the conditions attached
to their use. 
10.3 The Council will only reimburse retailers when their invoice is accompanied by
‘spent’ vouchers. 
10.4 If, during a property inspection, the decoration of the property is unchanged or
the tenant is unable to demonstrate that they have purchased decoration
materials, either through the presence of the materials themselves or the
receipts for the materials, the area housing officer may, with the authority of their
area housing manager, recharge the tenant for some or all of the value of the
decoration and flooring allowance. 
11. Lost or stolen vouchers
11.1 Any lost, damaged or expired vouchers issued to the tenant for a decoration
pack, will only be replaced at the discretion of the area housing manager
following appropriate enquiries. 
12. Review of decoration allowances
12.1 An annual update of all decoration/allowance rates will be carried out each year
in line with inflation.  
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Page 10 of 10
13. Review of decision and complaints
13.1 Any tenant who is not satisfied with the manner in which the Council, its
contractor(s) or the approved retailer, has dealt with any aspect of the service
they have received regarding decoration and / or flooring allowances  has the
right to have their case investigated. 
13.2 In the first instance the tenant will write to the area housing manager stating
their grievance.  The area housing manager will investigate and respond in
writing within 14 days of receipt of the request for the review. 
13.3 If the tenant is not satisfied with the area housing manager’s response, the area
housing manager will refer the tenant to the Council’s corporate complaints
procedure. 
14. Performance Monitoring
14.1 In order to comply with its service commitments, the Council will monitor the
following:
• the number of tenants who received a paint pack when their tenancy began; 
• the costs involved in the issue of paint packs;
• complaints or comments made around decoration / decoration packs during
tenancy settling in visits.  The comments and complaints are not reported
and are few in number. 
14.2 The supplier, (Johnstones), informs the Council when deliveries of paint packs
are not made, with packs delivered to Council offices after two unsuccessful
delivery attempts to the tenant(s). 
14.3 Paint pack statements are received which show if paint packs have not been
redeemed.  This allows for monitoring of the service. 
14.4 This policy will be reviewed in 2026. 
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APPENDIX II 
Compensation costs for 2023 – 2024 
Decoration Allowance Flooring Allowance
Kitchen upgrade No allowance – kitchen
will be painted after an
upgrade
£100
Heating upgrade £200 No flooring allowance
required
Blinds payment (due
to windows upgrade)
£100 No flooring allowance
required 
Item 9.
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REPORT TO: HOUSING AND COMMUNITY SAFETY COMMITTEE ON 27 JUNE
2023 
SUBJECT: TEMPORARY ACCOMMODATION CHARGING POLICY 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 revise the methodology used when charging homeless households for
temporary accommodation and presents a revised Temporary
Accommodation Charging Policy. 
1.2 This report is submitted to Committee in terms of Section III (G) (4) of the
Council's Scheme of Administration relating to the allocation and letting of
houses and homelessness. 
2. RECOMMENDATION 
2.1 It is recommended that the Housing and Community Safety Committee:- 
i) notes the current practice and the requirement to review the
Temporary Accommodation Charging Policy, as detailed in Section
3; 
ii) considers and approves the revised Temporary Accommodation
Charging Policy, as set out in Section 5 and APPENDIX I for
consultation; 
iii) agrees that a consultation exercise on the revised Temporary
Accommodation Charging Policy is undertaken with key
stakeholders, as set out in Section 6; and 
iv) agrees that an update report setting out the outcome of the
consultation will be presented to this Committee in September
2023. 
Item 10.
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3. BACKGROUND 
3.1 The Council has a statutory duty to assist applicants who are homeless or
threatened with homelessness as defined in the Housing (Scotland) Act 1987,
as amended.  These duties include the provision of temporary
accommodation until such time as the Council has determined the outcome of
their homeless application. 
3.2 On 3 February 2015, the Communities Committee agreed to implement a
revised charging policy for temporary homeless accommodation (paragraph 10
of the Minute refers).   
3.3 Implemented on the 6 April 2015, the overall aim of the Temporary
Accommodation Charging Policy was to maximise income where possible by
setting rent levels at the Local Housing Allowance (LHA) rates with an
additional service charge and making the provision of temporary
accommodation fairer for all. 
3.4 The LHA sets Housing Benefit entitlement for tenants in the private rented
sector, which is typically higher than social housing rents.  The LHA rate
people receive when housed in temporary accommodation depends on the
area they live in, the size and composition of the household and the type of
accommodation used.  The LHA rate was frozen from 2015 until April 2020
when an increase was applied as a part of a package of measures to support
workers during the COVID-19 pandemic.  The LHA rate was frozen again the
following year and remains so. 
3.5 The charging regime which applied in the Temporary Accommodation
Charging Policy had been in place since April 2015 with no subsequent
annual increase.  The special meeting of Moray Council were advised on 1
March 2023 that the effect of this was that income generated remained static
while costs have increased, particularly in light of the coronavirus pandemic
and the cost of living crisis.  This meant the temporary accommodation
service had been increasingly operating at a deficit (Paragraph 7 of the Minute
refers). 
3.6 The special meeting of Moray Council on 1 March 2023 agreed an interim
measure of increasing the rent and service charges by 27% (effective from 6
April 2023) which is the equivalent of the inflationary increase between April
2015 and April 2023 based on the Consumer Price Index (Paragraph 7 of the
Minute refers).   
3.7 In order to mitigate the temporary accommodation budgetary deficit, the
special meeting were informed that it would be necessary to review the extent
to which costs are recovered by rent and service charges with a
comprehensive review of the Temporary Accommodation Charging Policy
(Paragraph 7 of the Minute refers).   
4. LEGISLATIVE CONSIDERATIONS 
4.1 In accordance with the Housing (Scotland) Act 1987 Section 35(2) the local
authority can require a homeless person to pay a reasonable charge for the
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provision of temporary accommodation, as determined by the local authority. 
There is no definition of “reasonable” in the legislation or guidance.  Methods
for calculating charges, as well as the cost of temporary accommodation itself,
varies greatly across Scotland. 
4.2 When calculating temporary accommodation charges, local authorities should
also have due regard to the Code of Guidance on Homelessness.  Section
8.84 of the Code states that in deciding what is reasonable, account should be
taken of what the applicant can pay in the longer term.  In addition, the
applicant should be informed in advance of the cost of the accommodation
and should also be assisted when applying for benefit to cover the cost of
such accommodation. The local authority should take account of, and advise
of, the likely level of benefit when considering charges. 
4.3 The Scottish Government updated the Temporary Accommodation Standards
Framework in April 2023 which recommends that households are provided
with: 
• An assessment to consider whether temporary accommodation offered is
affordable by the household.
• A rent statement of charges, including any additional costs that are
associated with temporary accommodation and how they are paid. 
5. REVISED TEMORARY ACCOMODATION CHARGING POLICY 
5.1 To address the issues outlined in Section 3, the Temporary Accommodation
Charging Policy has been revised and is provided at APPENDIX I for
consideration.  The main policy changes are:
• rent levels are no longer set using the Local Housing Allowance rate and
a management fee;
• the service will operate on the basis of full cost recovery in order to
mitigate against risk to the temporary accommodation budget;
• the temporary accommodation charge is determined by a baseline rent,
equivalent to the average council house rent for the size of property, plus
a homeless service charge; and
• determining what a reasonable sum to recover from those who may have
affordability issues has been revised (as detailed in 5.5 below and Section
7 of the policy). 
5.2 The baseline weekly rent charged will be set at the average council rent by
property size.  The baseline rent will be reviewed and updated annually.  The
Council’s rents remain the lowest amongst local authority landlords in
Scotland and amongst social landlords in Moray and offer tenants an
affordable rent across the range of property types and sizes.  In 2023-24, the
average weekly council rents are as follows: 
Property size 1 bedroom  2 bedrooms 3 bedrooms
Average rent  £61.70 £72.70 £84.15 
5.3 The weekly homeless service charge will be determined by the cost of
operating the service.  A comprehensive review of the cost of operating the
service has been undertaken by Officers.  Originally the review encompassed
all costs associated with providing temporary accommodation, including those
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which are recovered against the general services budget.  This would have
required the homeless service charge to be set at £297 per week which
Officers consider to be unreasonable.  In developing what Officers consider to
be a reasonable charge, costs offset against the general services budget
have been discounted.  The homeless charge will be based on costs
attributed to the management and operation of temporary accommodation,
maintenance and repairs and void periods.  This figure has been divided by
the number of temporary accommodation units to define the annual cost per
property and thereafter the weekly amount of the homeless service charge
established.  For 2023-24, the homeless service charge will be £179.04 which
Officers consider to be reasonable.  This will be reviewed annually as part of
the annual budget setting process. 
5.4 The temporary accommodation charge for 2023-24 will be as follows:  
Property size 1 bedroom  2 bedrooms 3 bedrooms
Temporary
accommodation
charge per week
£240.74  £251.74  £263.19 
5.5 The Council will comply with legislative and statutory guidance as detailed
above and in Section 4 of the policy and will strive to ensure that the
temporary accommodation provided corresponds with the financial means of
homeless households.  A key aim of the revised policy for temporary
accommodation is that it seeks to ensure that temporary accommodation is
affordable to all.  The Council will ensure that it:
• considers the ability of the household to pay the temporary
accommodation charge;
• considers if the temporary accommodation charge is affordable for the
household; and 
• will assist the household to maximise their income via entitlement to
benefits. 
5.6  The Council will charge every household the same temporary accommodation
charge, regardless of income.  However in recognition of affordability for
households, such as those who are working and not in receipt of benefits, the
Council will continue to only recover an amount which it deems it can
reasonably be expected to collect.  When determining what a reasonable sum
for recovery is, the size of property and the financial circumstances of the
individual household will be considered.  In setting a reasonable recovery
amount, it is proposed that the baseline rent, plus 25% of the homeless
service charge, will be a reasonable and affordable amount: 
Property size 1 bedroom  2 bedrooms 3 bedroom
Restricted
temporary
accommodation
charge per week
£106.46  £117.46  £128.91 
5.7 It is proposed that the following transitional arrangements are applied in order
to mitigate against any financial impact for current tenants living in temporary
accommodation:
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• if an existing tenant advises of an adverse financial impact due to the
change, they will be provided with financial assistance.  It is anticipated
that this will have limited budgetary implications given the tenancy
turnover rate in temporary accommodation (<6 months); 
• when a property becomes void, it will be relet in line with the temporary
accommodation charge, as set out in the policy.  From implementation of
the policy, all new tenants will commence on the updated charging
arrangements. 
5.8 Financial analysis projects that, following relevant deductions for void periods
and debt provision, the policy changes will enable the service to make savings
of £135k in the year ahead, which will help achieve the £230k savings
identified in the Housing Revenue Account annual budget report to the special
meeting of Moray Council on 1 March 2023 (Paragraph 7 of the Minute
refers).  It should be noted that the additional income will be dependent on
tenants paying the temporary accommodation charge in full and where this
does not happen, arrears recovery action undertaken to achieve maximum
recovery. 
6. CONSULTATION 
6.1 It is proposed that a consultation exercise on the revised Temporary
Accommodation Charging Policy is undertaken, providing homeless
households and other relevant stakeholders with the opportunity to provide
feedback. 
6.2 The consultation process will involve:
• publication of the revised Temporary Accommodation Charging Policy,
along with an easy to read policy, on the Council website;
• developing an online survey available on the Council’s website and
publicising it across the Council’s social media platforms;
• contacting relevant stakeholders and requesting feedback, including:
• tenants living in Moray Council temporary accommodation;
• Register of Interested Tenants;
• Moray Tenant’s Forum; and
• other relevant stakeholders 
6.3  The consultation feedback will inform the policy development
process.  Following analysis and consideration of comments received, a
further progress report with the outcome of the consultation process, along
with a final Temporary Accommodation Charging Policy, will be presented to
this Committee on 12 September 2023. 
7. TEMPORARY ACCOMMODATION PROVISION 
7.1 The Rapid Rehousing Transition Plan (RRTP) was presented to the Housing
and Community Safety Committee on 6 September 2022 (Paragraph 8 of the
Minute refers).  The Council, along with its partners, are delivering a range of
actions to deliver a preventative approach to reduce the number of people
presenting as homeless while continually reconfiguring temporary
accommodation provision.  Central to this is the ongoing requirement to
reduce reliance on temporary accommodation by supporting people to keep
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the home they have or finding suitable permanent homes more quickly and
reduce the time that homeless applicants occupy temporary accommodation. 
7.2 The Service continues to review and reconfigure the supply of temporary
accommodation in order to address the peaks and troughs in demand whilst
meeting the needs of homeless households and ensuring that length of stay in
temporary accommodation is minimised.  Any increase in homelessness will
directly impact on temporary accommodation, not only an increased pressure
for accommodation provision but also the temporary accommodation budget. 
7.3 As at 30 April 2023, there were 107 units of temporary accommodation, as
follows: 
Landlord 1 bed 2 beds 3 beds Total 
Council  21 59 14 94
RSL 8 5 0 13 
29 64 14 107 
The total number of households accommodated in temporary accommodation
shows a greater reliance on Council properties however this option continues
to offer the Council best value both in terms of cost and flexibility.   
8. FUTURE CONSIDERATIONS 
8.1 As part of its approach to homeless prevention, the Scottish Government,
aims to ensure that all homeless households spend the shortest possible time
in temporary accommodation before moving to settled accommodation.
8.2 The Scottish Government has committed that it will work with its partners to
identify ways to reduce the number of people living in temporary
accommodation, including taking account of the recommendations and report
by its Temporary Accommodation Task and Finish Group, published on 31
March 2023. This included a recommendation that further work on the cost
and financing of temporary accommodation is required.  Particularly that the
Scottish Government should review the guidance to local authorities on
setting charges for temporary accommodation by clearly defining the terms
“reasonable charge” and “affordable”.
8.3 Following an extensive consultation exercise in 2021-2022, is anticipated that
the Scottish Government will introduce legislation to strengthen homelessness
prevention in the forthcoming year.  The anticipated proposals include:
• introducing new duties on public bodies and landlords to prevent
homelessness, particularly by asking and acting on a risk of
homelessness;
• extending the duty to take reasonable steps to prevent homelessness up
to six months before it occurs; and 
• maximising the housing options available to people and prescribing what
actions and reasonable steps may include, including steps to meet the
needs of specific groups.   
8.4 During the consultation, concerns were expressed that the proposals may
result in an increase in the number of homeless referrals, which in turn would
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mean an increase in demand for temporary accommodation and an increase
in the associated costs, placing the budget under greater pressure. 
8.5 Officers will continue to monitor the situation and respond accordingly and will
update Committee on any implications that these proposals may have for the
Temporary Accommodation Charging Policy. 
9. 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 Homelessness Policy will assist
the Council to meet its strategic priority within the Local Housing
Strategy which is “to prevent and alleviate homelessness.” 
(b) Policy and Legal
The Temporary Accommodation Charging Policy will be subject to
detailed consultation and further reporting to this committee in the course
of the year. There are no legal implications arising from this report. 
(c) Financial implications
The temporary accommodation budget continues to operate under
pressure.  Although the Temporary Accommodation Charging Policy is
intended to minimise any risk and deliver savings identified at Section
5.8, Officers will ensure that budgets continue to be closely monitored
and reviewed in future years. 
(d) Risk Implications
Any increase in homelessness will directly impact on temporary
accommodation, not only an increased pressure for accommodation but
also the potential to increase the level of arrears. 
There is a continued need to reconfigure the Council’s supply of
temporary accommodation and ensure that the length of stay in the
accommodation is minimised. The Housing Needs Manger will be
responsible for ensuring that the Council has the correct level and type
of accommodation, alleviating the need for bed and breakfast
accommodation, where possible, and that income from the for
Temporary Accommodation Charging Policy is maximised. 
(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 Equalities Impact Assessment on the revised Temporary
Accommodation Charging Policy will be completed following consultation
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with service users and key stakeholders and any issues will be
presented to this Committee in September 2023. 
(h) Climate Change and Biodiversity Impacts
There are no climate change/biodiversity impacts arising from this report. 
(i) Consultations
Consultation on this report has taken place with the Head of Housing
and Property, Housing Needs Manager, Supported Accommodation
Manager, Housing Strategy and Development Manager and Officers
within the Housing Service and with the Chief Financial Officer, Alistair
Milne (Accountant), Norma Matheson (Benefits Manager) Georgina
Anderson (Legal Services Senior Solicitor) and Lindsey Robinson
(Committee Services Officer) have been consulted and any comments
have been incorporated into the report. 
10. CONCLUSION 
10.1 This report presents a revised Temporary Accommodation Charging
Policy for consideration and seeks approval to consult with
stakeholders. 
Author of Report: Gillian Henly, Senior Housing Officer (Policy)
Background Papers: Held by author
Ref:    SPMAN-1285234812-1343   
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APPENDIX I 
MORAY COUNCIL
HOUSING AND PROPERTY SERVICES
TEMPORARY ACCOMMODATION CHARGING POLICY 
1. Scope of the policy
2. Strategic context
3. Objective and principles of the policy
4. Legislative and regulatory framework and guidance 
5. Affordability 
6. Charging for temporary accommodation 
7. Recovery of the temporary accommodation charge 
8. Recovery of arrears 
9. Review of decisions and complaints
10. Performance monitoring
11. Policy review 
Item 10.
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1
1.  Scope of the policy
1.1 This policy details the framework used by the Council in the charging of rent
and service charges to homeless households for the provision of temporary
accommodation. 
2. Strategic context
2.1 The Temporary Accommodation Charging Policy will assist the Council to
tackle homelessness, which meets the aims of Moray 2027, the Local
Housing Strategy and the Rapid Rehousing Transition Plan. 
3. Objectives and principles of the policy 
3.1 The overall aim of the policy is to ensure that rent and service charges for
temporary accommodation are set at an affordable level, provide financial
sustainability and meet the cost of delivering temporary accommodation
provision. 
3.2 The specific objectives are:
• to use a cost effective and fair rent and service charge setting process; 
• to ensure temporary accommodation is an affordable option to all and
does not act as a disincentive to work; 
• to ensure that sufficient income is generated to cover the cost of operating
and managing temporary accommodation; 
• to ensure that rent and service charges are recovered to their maximum
potential; and 
• to use recovery practices which take into account a household’s income,
whilst ensuring that those with the means to pay do pay. 
3.3 The principles of the policy are to:
• comply with legislation and guidance and promote best practice;
• ensure consistency in the provision of services and agreed practices
uniformly across the service;
• deliver good quality services which are efficient and effective; and
• provide services that adhere to the principles of equal opportunities.
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2
4. Legislative and regulatory framework and guidance 
4.1 The Council will ensure that the Policy complies with current legislation and
guidance and promotes good practice.   
4.2 Councils have a statutory obligation to offer temporary accommodation when
they assess a person or household as unintentionally homeless. The Housing
(Scotland) Act 1987 Section 35(2) states that where this obligation exists, the
applicant should pay a reasonable charge, as determined by the local
authority in respect of the accommodation provided by the local authority, or
that provided by another landlord but which is paid for by the local authority. 
4.3 When carrying out functions under the Housing (Scotland) Act 1987 with
respect to a homeless person and / or persons threatened with
homelessness, local authorities are required to have regard to the Code of
Guidance on Homelessness.  Paragraph 8.84 of the Code states: 
“In deciding what is reasonable, the local authority should take account of
what the applicant can pay in the longer term.  If an applicant is being asked
to pay for accommodation provided by or paid for by the local authority then
the applicant should be informed in advance of the cost of the
accommodation. They should also be assisted when applying for benefit to
cover the cost of such accommodation. The local authority should take
account of, and advise of, the likely level of benefit when considering
charges”. 
4.4 The Temporary Accommodation Standards Framework April 2023 sets out
advisory standards in relation to temporary accommodation and it
recommends that the following actions are undertaken: 
• A household assessment to consider whether temporary accommodation
offered is affordable by the household.
• Providing households with a rent statement of charges, including any
additional costs that are associated with temporary accommodation and
how they are paid. 
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3
4.5 The Scottish Social Housing Charter sets out standards including those which
tenants and homeless people can expect from social landlords.  Outcome 14
states:
”Social landlords set rents and service charges in consultation with their
tenants and other customers so that:
• a balance is struck between the level of services provided, the cost of the
services and how far current and prospective tenants and service users
can afford them.
• tenants get clear information on how rents and other money is spent,
including details of individual items of expenditure above thresholds
agreed between landlords and tenants.” 
4.6 These outcomes reflect a landlord’s legal duty to consult tenants about rent
setting, the importance of landlords taking account of what their current and
prospective tenants and other customers are likely to be able to afford, and
the importance that many tenants place on being able to find out how their
money is spent.  What is crucial is that discussions take place and the
decisions made reflect the views of tenants and other customers.   
4.7 The Council will seek to ensure that it complies with its duties under the
Equalities Act 2010.  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 opportunity;
and to foster good relations between persons who share a relevant protected
characteristic and those who do not. 
5. Affordability
5.1 The Council recognises that the cost of temporary accommodation is higher
than for council housing.  This can result in temporary accommodation being
unaffordable for some households, for example those who are in employment
or are not entitled to Housing Benefit.   
5.2 In accordance with the Code of Guidance on Homelessness, the Council will:
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4
• carry out a household assessment to consider whether accommodation is
affordable for a household; 
• consider the ability of any individual to pay charges in the longer term; 
• give advance notice to an individual of any charges; 
• assist an individual to apply for benefits to pay any charges; and
• take account of the likely level of benefit when considering charges. 
5.3 The Council will seek to ensure that all tenants placed in temporary
accommodation are given relevant information about entitlement to welfare
benefits/income maximisation services in order to encourage optimum take up
from tenants.  It will encourage all those tenants who may be eligible for
assistance to apply for appropriate benefits, for example Housing Benefit. 
This will assist to offset the effects of low income on the tenant’s ability to pay. 
Where requested, the Council will provide assistance with the completion of
application forms and progress claims. 
6. Charging for temporary accommodation 
6.1 The income generated from the charging regime for temporary
accommodation will be equivalent to full cost of operating the service.  It must
be sufficient to cover the costs of the provision of temporary accommodation
in relation to management, service delivery, maintenance and repairs and
void periods of the accommodation. 
6.2 The charging regime for temporary accommodation is the baseline rent and a
homeless service charge: 
Rent setting mechanism 
6.3 Rent charges will be set in accordance with average council house rents,
based on the size of property.
The average council house rental figures will be reviewed and updated
annually. 
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5
Homeless service charge
6.4 The homeless service charge is reflective of the cost of providing temporary
accommodation to homeless households.  
• Housing management costs associated with the provision of temporary
accommodation;
• Maintenance costs, including the provision of furnishings, equipment and
utilities;
• Void rent loss; 
• Staff costs; and 
• Repair and renewal costs.
The homelessness service charge will be reviewed annually in conjunction
with the annual budget setting process and will endeavour to ensure that the
income generated meets the full cost of service provision.  Tenants will be
provided with a breakdown of the service charges. 
6.5 When setting the charge for temporary accommodation, the Council will
charge every household the same level, regardless of income.  However, in
order to ensure that temporary accommodation is an affordable option to all,
the Council will only seek to recover those costs that it can reasonably be
expected to collect. 
6.6 Tenants have an obligation under the terms and conditions of their occupancy
agreement to pay the temporary accommodation charge timeously.  In
addition, it is a tenant’s responsibility to notify the Council of any change in
their circumstances that may affect their ability to pay their temporary
accommodation charge.  Tenants will be reminded of their responsibilities
when they sign their occupancy agreement and during their tenancy. 
6.7 Tenants will be provided with information about the temporary accommodation
charge at the start of their stay in temporary homeless accommodation
including:
• the amount they must pay (rent and the homeless service charge); 
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6
• the importance of making regular payments and / or claiming Housing
Benefit if appropriate; 
• the methods they can use to pay their temporary accommodation charge;
and
• advice on what they should do if they fall into arrears. 
6.8 The service will endeavour to ensure that:
• homeless households remain aware of their responsibility to pay the
temporary accommodation charge on time and the potential
consequences of non-payment; 
• it actively promotes the maximisation of tenants’ income through benefits
take up and money / debt advice; and 
• homeless households receive information, advice and support on
maximising their income by claiming appropriate benefits, improving
personal budgeting skills and dealing with debt. 
6.9 The Housing Needs Manager will be responsible for ensuring that charges for
temporary accommodation continue to reflect good practice and fairness for
all. 
6.10 As part of the review process for the temporary accommodation charge,
tenants will be consulted on any proposed temporary accommodation charge
increase. 
6.11 Tenants will be provided with at least 28 days’ written notice in the event of
any increase in the temporary accommodation charge. 
7. Recovery of the temporary accommodation charge 
7.1 The Council recognises that some people may be unable to pay the amount
of the temporary accommodation charge due for a variety of reasons. This
may include poverty, or other reasons for financial exclusion, which the
Council will endeavour to balance against its duty to recover the amount due. 
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7
7.2 It is a tenant’s responsibility to pay, in full, the amount of the temporary
accommodation charge that the Council seeks to recover. 
7.3 Some tenants may be eligible to get assistance to pay the temporary
accommodation charge through Housing Benefit.  Tenants are responsible for
applying for assistance and for pursuing any claims for assistance.  The
Council will provide advice and support to tenants upon request. 
7.4 In situations, where a tenant may be eligible for assistance but chooses not to
apply for assistance, or to pursue their claim, they will be expected to pay the
full amount of the temporary accommodation charge that the Council seeks to
recover.   
Housing Benefit
7.5 Where a tenant in temporary accommodation is eligible for the full award of
Housing Benefit, the Council will seek to recover 100% of the temporary
accommodation charge. 
7.6 Where a tenant is only eligible for partial payment of Housing Benefit, the
Council will seek to recover a reasonable amount (i.e. the average Council
house rent plus 25% towards the homeless service charge).  
• If the amount of Housing Benefit the tenant receives is more than the
reasonable amount, the Council will recover all of the Housing Benefit
awarded.  
• If the amount of Housing Benefit the tenant receives is less than the
reasonable amount, the tenant will have to pay the difference.   
7.7 Where a tenant in temporary accommodation is working and/or is not eligible
for Housing Benefit, the Council will only seek to recover a reasonable
amount (i.e. the average Council house rent plus 25% towards the homeless
service charge).   
7.8 Discretionary Housing Payments (DHP) are payments that the Council can
make to people who require further financial assistance to meet their housing
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8
costs.  The Housing Service will provide tenants with information and advice
about DHP, including the application process. 
Overpayment of benefits
7.9 Any overpayment of benefits to the tenant such as Housing Benefit will be
recovered.   
8. Recovery of arrears
8.1 The Council will aim to minimise the level of arrears in a sensitive but effective
manner, to enable an affordable solution to be agreed as quickly as possible,
ensuring that there is early intervention in all cases before a debt becomes
unmanageable. 
8.2 The Council will use all appropriate methods of communication open to it
when contacting homeless households in arrears.  Face to face visits will be
the preferred default communication method, however letters, phone calls,
virtual appointments (such as Near Me), e-mail and text messages may be
used if appropriate. 
8.3 Arrears recovery will be based on a staged escalation process, up to and
including repossession for non-payment of the temporary accommodation
charge. 
8.4 The process will be based on a preventative approach that seeks to maximise
tenants' entitlement to benefits and secure regular payments. 
8.5 Once arrears have arisen, prompt action will be taken to ensure that the
arrears do not increase.  The Council will endeavour to make sure that current
temporary accommodation charge is paid, and then ensure that the arrears
are recovered. 
8.6 In cases where the tenant cannot clear the arrears in a single payment, the
Council will agree an affordable payment to reduce the arrears in realistic and
sustained instalments over a specific period of time.  Any repayment
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9
agreement will be based upon a detailed assessment of the tenant's finances
and ability to pay. 
8.7 The Council will maintain a comprehensive record of all action taken and all
contact with tenants in arrears. 
8.8 Legal action is the last stage in the arrears process.  The Council will use all
legal options open to us it the recovery of arrears where the homeless
household is wilfully and knowingly refusing to pay their temporary
accommodation charge, up to and including eviction or the ending of
accommodation. 
8.9 Tenants will be kept informed of, and fully involved in, the legal process at all
stages of legal action. Legal action may include issuing a Notice to Quit,
giving the tenant 40 days’ notice to leave the property, and thereafter seeking
recovery of possession and seeking a payment decree.  In all cases, the
Council will seek recovery of expenses.  Expenses may be awarded where
the arrears have been repaid. The Council will refer the tenant to suitable
agencies who provide advice or assist in representation at court hearings. 
8.10 The decision to request legal action to recover possession of the property and
payment of arrears will only be taken when all other means of arrears
recovery have been exhausted. 
9. Review of decisions and complaints
9.1 A review process exists for tenants who dispute the amount of temporary
accommodation charge to be recovered, the level of arrears or any repayment
plan.  In the first instance, tenants can ask for an explanation from the
Supported Accommodation Officer.  If the tenant is not satisfied with the
explanation provided, they can ask for an appointment with the Supported
Accommodation Manager.  The Supported Accommodation Manager will
review the case and in the event of any dispute, will refer the case to the
Housing Needs Manager. 
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10
9.2 The Council operates a Complaints Procedure that is available to any tenant
who is not satisfied with the way in which their case has been dealt with.
Details of the Complaints Procedure can be obtained on the Council’s website
and from the reception and information hubs. 
10. Performance monitoring
10.1 The Council will monitor performance relating to the temporary
accommodation charge as follows:
• the total amount of temporary accommodation income due;
• the total amount of the temporary accommodation charge collected;
• the amount of arrears, by band showing number of accounts and total
arrears due for each band; and 
• the number of tenants evicted as a result of arrears. 
10.2 The information detailed above will be reported annually to the Housing and
Community Safety Committee.  The reports will be public documents but the
confidentiality of individual customers’ circumstances will be maintained. 
10.3 Other statistics will be collected from time to time for management and
planning purposes. 
11. Policy review
11.1 The Council will review the Temporary Accommodation Charging Policy in
2027 or earlier if required by legislative changes.
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REPORT TO:  HOUSING AND COMMUNITY SAFETY COMMITTEE ON 27 JUNE
2023 
SUBJECT: HOUSING AND PROPERTY SERVICES – UNAUDITED OUTTURN
AS AT 31 MARCH 2023 
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 This report presents the unaudited outturn position for the Housing Revenue
Account (HRA) and General Services Other Housing Budget for the period up
to 31 March 2023. 
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 considers and notes the
unaudited outturn for 2022/23 for the period to 31 March 2023,
consisting of a surplus balance of £2,465k for the HRA and an
underspend of £188k for General Services Housing & Property. 
3. BACKGROUND 
3.1 The Council agreed the HRA Budget for 2022/23 at a Moray Council meeting
on 1 March 2023 (paragraph 7 of the Minute refers). Housing and Property
budget monitoring reports are presented quarterly. 
4. HOUSING REVENUE ACCOUNT TO 31 MARCH 2023 
4.1 APPENDIX I details the provisional and unaudited HRA budget position to 31
March 2023. 
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 overspend of £298k. The main overspends were a
write-off for abortive costs for a potential housing development (£268k),
staffing costs mainly due to the higher than budgeted pay award (£50k), voids
Item 11.
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(£19k), Council Tax (£14k) and other cumulative overspends of £17k,
primarily due to recharges for use of pool cars. These were partly offset by
underspends in software (£66k) and training (£15k). 
4.2.2 Sheltered Housing – there was an overspend of £48k arising from increased
energy costs and additional repairs & maintenance expenditure on fire
protection and other improvements. 
4.2.3 Repairs and maintenance – there was an overspend of £546k net in the
repairs and maintenance budgets, which comprised of £330k in additional
void spend due to volumes and cost per property exceeding projections,
£122k in response repairs and £72k in planned/cyclical works. Whereas there
were planned/cyclical overspends in electrical upgrades (£554k), which arose
from the enhanced certification requirements, £153k in property fee
allocations, £125k in fire risk works, arising from the latter phase of smoke
alarm upgrades, and £127k in other miscellaneous works due to higher costs,
these were partially offset by underspends in external decoration and fabric
repair (£325k), asbestos (£256k), £199k in moss clearing and £180k in
rainwater goods.   
4.2.4 Financing Costs – there was an overspend of £457k due to the higher than
anticipated cost of borrowing following interest rate increases. 
4.2.5 Bad and doubtful debts – there was an underspend of £21k, arising from
lower than anticipated write-offs. 
4.2.6 Capital from Current Revenue (CFCR) – There was an underspend of
£889k based on the estimated balancing figure to maintain level of HRA
reserves. CFCR provision is used as a balancing figure for the overall budget
and limits the requirement for borrowing to fund property improvements. 
4.2.7 Downsizing Incentive Scheme – there was an underspend of £44k with
fewer transfers than expected completed during the year. 
4.2.8 Service Developments – there was an underspend of £294k arising from
recruitment delays and changes to telephony at the Mosstodloch depot; these
were partly offset by consultancy spend, including an additional refresh of the
HRA business plan in response to inflation and interest rates moving
significantly from baseline assumptions.  
4.3 The income at 31 March 2023 was £91k higher than expected.  This is due
mainly to higher interest rates received for balances held (£106k) and
additional tenant recharges (£63k), which were partially offset by delayed
handover of new build housing in Keith (£73k) and lower income from garage
rents (£5k). 
4.4 The estimated HRA surplus balance at 31 March 2023 was £2,465K, which is
in line with the projection. 
5. OTHER HOUSING BUDGET 
5.1 APPENDIX II provides details of the provisional and unaudited budget
position to 31 March 2023.
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5.2 Planning and Development consists of Improvement Grants and Affordable
Housing budgets.  There was an underspend of £19k arising from an
underspend in discretionary grants of £12k and £7k in other minor budgets.
Discretionary grants are given to homeowners for disabled adaptations with
this budget managed by the Moray Integration Joint Board.   
5.3 Housing Management relates to the Gypsy/Traveller budget. This shows an
underspend of £8k due to reduced staffing expenditure (£4k) and reduced
expenditure on supplies and services (£4k) owing to lower seasonal activity. 
5.4 Homelessness/Allocations comprises of Homelessness and Housing
Support services. There were variations across a range of budgets within this
heading resulting in an underspend of £52k in this budget. This is comprised
of an underspend of £339k in grant to be carried forward for future years and
£26k in housing support following the closure of a commissioned service.
These underspends were partially offset against by a £313k overspend in
homeless persons, primarily temporary accommodation. This followed an
increase in service demand in the final quarter of the year but also reflected
increased costs against which service charges had not been uprated.
Approval of a 27% uprating of service charges was approved in March and is
expected to alleviate the potential for future overspends in this service. 
5.5 Miscellaneous General Services Housing comprises of House Loans and
the complex needs development at Urquhart Place, Lhanbryde.  There was
an underspend of £25k across these three budgets.  The main reason for this
was lower than anticipated repairs and maintenance costs relating to Urquhart
Place (£32k), supplemented by an underspend in mortgage repayments
(£1k); these underspends were partially offset by an overspend in grounds
maintenance (£8k), which had been funded by a now exhausted maintenance
bond with an RSL. 
5.6 The Building Services Budget is reported in detail separately on this
Committee’s agenda. Whilst not finalised a modest £2k underspend is
anticipated at this point. 
5.7 The Property Services Budget includes the budgets for the Design Team
and Property Resources. There was an underspend of £230k at year end,
arising from increased rental income/lower costs in industrial estates (£120k),
lower costs for central repairs and maintenance (£93k) due to planned and
cyclical programmes being less than budgeted, £40k in management of held
for sale assets, shared building costs (£17k) and other miscellany (£3k). This
cumulative underspend was partially offset by overspends in Design &
Construction (£14k), schools repair and maintenance (£37k) due to the level
of reactive repairs and £8k in miscellaneous other budgets. 
5.8 Housing and Property Savings – Staffing savings (£132k) below target were
achieved by year end. This arose mainly to due to the filling of previously
vacant posts. 
5.9 Housing and Property Allocations – there was an overspend (£17k)
primarily due to less income than budgeted for shared building service
recharges. 
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5.10 COVID-19 – there was a service underspend of £1k attributable to the Tenant
Hardship Fund balance being carried forward.   
5.11 As at 31 March 2023, the Other Housing Budget shows an unaudited net
underspend of £188k.   
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 and
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
None. 
(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, the Legal Services Manager, Senior Managers within Housing
and Property Services and Lindsey Robinson (Committee Services
Officer) who all agree the content of the report where it relates to their
area of responsibility. 
7 CONCLUSION 
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7.1 This report sets out the provisional and unaudited budget position for
the HRA and General Services Housing budgets to 31 March 2023 and
also comments on the variances on these budgets. 
Author of Report: Edward Thomas, Head of Housing and Property Services
Background Papers:   Held by author
Ref:    SPMAN-1285234812-1327
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APPENDIX I
Housing Revenue Account        
Budget Monitoring to 31st March 2023   
Service Description Annual Budget
2022-23
Actual to 31st
Mar 2023
Variance to
31st Mar
2023
Expenditure £,000 £,000 £,000
Supervision & Management 4,533 4,831 (298)
Sheltered Housing 25 73 (48)
Repairs and Maintenance 7,956 8,502 (546)
Financing Costs 4,096 4,553 (457)
Bad & Doubtful Debts 225 204 21
CFCR 4,303 3,404 899
Downsizing Incentive Scheme 72 28 44
Service Development 456 162 294
Total Gross Expenditure 21,666 21,757 (91)        
Income £,000 £,000 £,000
Non-dwelling rents 242 237 (5)
House rents 21,335 21,262 (73)
IORB 2 108 106
Other income 87 150 63
Total Income 21,666 21,757 91        
Surplus / (Deficit) for the year 0 0 0        
Accumulated Surplus Balance brought
forward   2,465          
Estimated Surplus Balance at 31st March   2,465   
Item 11.
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General Services Housing & Property    APPENDIX II     
Monitoring to 31 March 2023   
Annual Actual Variance
Service Description Budget to at 
2022-23 31 March 2023 31 March 2023    
£'000 £'000 £'000
Planning & Development 255 236 19          
Housing Management 20 12 8          
Homelessness / Allocations 2572 2520 52          
Miscellaneous General Services Housing (20) (45) 25          
Building Services 0 (2) 2          
Property Services 2411 2181 230          
General Services Housing & Property Savings (132) 0 (132)          
General Services Housing & Property
Allocations (161) (144) (17)       
Covid 19 - GS Housing & Property  
39 38 1          
General Services Housing & Property Total  4984 4796 188 
Item 11.
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REPORT TO:   HOUSING AND COMMUNITY SAFETY COMMITTEE ON 27 JUNE
2023  
SUBJECT: HOUSING INVESTMENT 2022/23   
BY:  DEPUTE CHIEF EXECUTIVE (ECONOMY, ENVIRONMENT AND
FINANCE) 
1. REASON FOR REPORT 
1.1 This report informs the Committee of the actual audited outturn to 31 March
2023 for the Housing Investment Programme for 2022/23. 
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 the Housing
Investment Programme audited outturn to 31 March 2023, as detailed in
Section 3 and Appendices I to VI. 
3. BACKGROUND 
Investment Programme
3.1    APPENDIX I shows income and expenditure for 2022/23.  The figures show
that an overall year-end expenditure of £16,292k was achieved, which
represents a spend of 88% against the £18,539 annual budget, and a shortfall
of £2,247k.  The shortfall in investment is attributable to internal staff
resourcing delays 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. 
3.2    The level of expenditure within the individual budget headings that make up
the programme are shown in paragraphs 3.3 to 3.12 below.  The expenditure
figure represents all payments which have progressed through the finance
system to 31 March 2023.   
3.3    APPENDIX II shows expenditure on Response and Void Repairs.  Spend was
£4,898k to 31 March 2023, works delivered, included 21,429 housing repairs
and 482 void properties relet.  An overspend of £411k occurred within this
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budget due to increases in labour  and materials costs, accompanied by an
increased use of sub-contractors to support peak workload periods.. 
3.4    APPENDIX III shows expenditure on Estate Works.  Spend of £496k was
achieved to 31 March 2023 and represents an underspend of £169k which
can be attributed to the Estate audits and walkabouts being suspended
initially due to Covid 19 restrictions and then due to lack of staff resource. 
The Housing Asset Management Team have now began a programme of
Estate Audits and are aiming for 100% complete by 31 August 2023.  Works
identified during Estate Audit and subsequent walkabout will identify the next
financial year works to ensure budget spend.   
3.5    APPENDIX IV shows expenditure on Cyclic Maintenance.  Spend of £444k
was achieved to 31 March 2023.   The shortfall in investment is attributable to
underspends in the cyclical servicing and external painter work programmes
that occurred due to internal staff resource shortage to develop programmes
and a lack of available contractors. 
3.6    APPENDIX V shows expenditure on Planned Maintenance and Other
Investments.  Spend of £10,834k was achieved to 31 March 2023 and
represents 86% of the agreed programme level. An underspend of £1,696k
occurred as a result of a lack of availability of external contractors, and
internal staff resourcing issues that led to delays in the development of  some
key investment programmes. 
Within the planned maintenance programme very limited spend was
undertaken against the EESSH – Insulation heading.  This was due to 
no programme being developed in sufficient time to allow a contractor to be
appointed to undertake the work.  On this basis, a decision was made to focus
spend on deliverable programmes that led to over spends on the Kitchens
and Bathroom and Central Heating budgets.  The over spend in central
heating and the completion of the EESSH - Warm Homes R4 and EESSH –
Lcitp programmes delivered 522 replacement heating systems within the
portfolio. 
General Programme Updates 
3.7    The programme to upgrade smoke alarms in all Council properties in
accordance with statutory legislation saw 99% of properties completed as at
31 March 2023.  The budget was slightly overspent to deliver this programme
due to the reliance on sub-contractors. 
3.8   The kitchen and shower contract budgets were both slightly overspent,
however this delivered 143 replacement kitchens and 37 shower installations. 
3.9   The budget for Disabled Adaptations was £360k and the spend at 31 March
2023 was £380k, resulting in 106% budget spend.  This was an approved
overspend to address the backlog of adaptation instructions which were
accumulated during Covid 19 restrictions. 
3.10 The Committee has been advised previously of the requirement for each
property to have a valid Electrical Inspection Condition Report (EICR).  The
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budget was overspent by £554k, as a result of carrying out 957 EICR’s along
with subsequent remedial works.  The remaining EICR work is planned to be
completed by March 2024 subject to the availability of contractors to support
the in house delivery programme. 
Income and Expenditure for Private Sector Housing 
3.11 APPENDIX VI shows the position with regard to grant expenditure for Private 
Sector Housing Grant to 31 March 2023.   
3.12 The legally committed figure in Category C of £137k represents 121% of the 
allocated budget.  Spend to 31 March 2023 was £101k which represents 
89.4% of the allocated budget.   
4. 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
Maintenance and improvement works are carried out in order to meet
statutory legal requirements and in accordance with current relevant
policies. 
(c) Financial implications
The financial implications associated within this report are dealt with in
paragraphs 3.1 to 3.12 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 associated with 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. 
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(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). 
(i) Consultations
Consultations have taken place with the Head of Housing and Property
Services, Building Services Manager, Georgina Anderson (Legal
Services Senior Solicitor), Chief Financial Officer, Lindsey Robinson
(Committee Services Officer), 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 shows that the Council’s progress in respect of Housing
investment for both the Council’s housing stock and the private sector
continues to recover following the Coronavirus pandemic.   Increases in
building sector labour, materials and plant costs has resulted an
increase in individual budget spend.  Delays to a number of key planned
investment programmes has also led to a £2,247k shortfall in overall
investment. 
Recovery of programmes is essential to enable the Council to address
the identified priorities to improve the quality of housing stock in Moray. 
More specifically, the ongoing investment in the Council’s housing
stock enables it to  achieve the Scottish Housing Quality Standard,
allows for replacement of life expired elements and makes progress
towards the attainment of both the Moray Standard and the Energy
Efficiency Standard for Social Housing. 
Author of Report: Neil Strachan, Property Asset Manager 
Background Papers:   
Ref:    SPMAN-1285234812-1348 
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APPENDIX I
(all amounts in £'000)
HOUSING INVESTMENT PROGRAMME
Annual Budget
2022/23
Expenditure plus
commitments to
date
%
expendituere plus
committed to date
Expenditure to date
%
Budget spent to
date
Budget balance
Expenditure
Response, Gas & Void Repairs 4,487 4,898 109% 4,898 109% -411
Estate Works 665 496 75% 496 75% 169
Cyclic Maintenance 857 443 52% 444 52% 413
Planned Maintenance (Revenue) 1,550 2,016 130% 2,016 130% -466
Planned Maintenance (Capital) 10,610 8,438 80% 8,438 80% 2,172
Other Investment 370 380 103% 0 0% 370
Sub Total 18,539 16,671 90% 16,292 88% 2,247
Other Capital Expenditure
New Build - Capital Costs 14,099 1,362
Total 32,638 17,654
Funded by
HRA Revenue 7,929 7,854 99%
Government Grant 11,200 1,011 9%
Use of Council Tax Discount 600 0 0%
Prudential Borrowing 6,866 8,789 128%
Other Grants 1,740 0 0%
Capital Receipts 0 0 0%
C.F.C.R 4,303 0 0%
Total 32,638 17,654 54%
INVESTMENT PROGRAMME INCOME AND EXPENDITURE 2022/23
31 March 2023
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APPENDIX II
(all amounts in £'000)
RESPONSE AND VOIDS REPAIRS
Annual Budget
2022/23
Expenditure plus
commitments to date
%
expendituere plus
committed to date
Expenditure to date
%
Budget spent to
date
Budget balance
West Area Office 1,386 1,592      115% 1,592 115% -206
East Area Office 1,074 1,015 95% 1,015 95% 59
Void House Repairs 1,427 1,731 121% 1,731 121% -304
Gas Heating Repairs 600 560 93% 560 93% 40
4,487 4,898 109% 4,898 109% -411
31 March 2023
INVESTMENT PROGRAMME EXPENDITURE 2022/23
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APPENDIX III
(all amounts in £'000)
ESTATE WORKS
Annual Budget
2022/23
Expenditure plus
commitments to date
%
expendituere plus
committed to date
Expenditure to date
%
Budget spent to
date
Budget balance
Garage Upgrades 25 1 4% 1 4% 24
Asbestos 360 104 29% 104 29% 256
Landscape Maintenance 50 9 18% 9 18% 41
Estates/Forum Upgrades 230 254 110% 254 110% -24
Miscellaneous 0 128 0% 128 0% -128
665 496 75% 496 75% 169
31 March 2023
INVESTMENT PROGRAMME EXPENDITURE 2022/23
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APPENDIX IV
(all amounts in £'000)
CYCLIC MAINTENANCE
Projected Outturn
Annual Budget
2022/23
Expenditure plus
commitments to date
%
expendituere plus
committed to date
Expenditure to date
%
Budget spent to
date
Budget balance
Gas Servicing 360 319 89% 319 89% 41
Solid Fuel Servicing 15 14 93% 15 100% 0
Air Source Heat Pump Servicing 59 42 71% 42 71% 17
Smoke Detector Servicing 15 4 27% 4 27% 11
PPR & External Painterwork 358 33 9% 33 9% 325
General Servicing 50 30 60% 30 60% 20
Inspections/House Surveys 0 1 0% 1 0% -1
857 443 52% 444 52% 413
INVESTMENT PROGRAMME EXPENDITURE 2022/23
31 March 2023
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APPENDIX V
(all amounts in £'000)
PLANNED MAINTENANCE & OTHER INVESTMENTS
Projected Outurn
Annual Budget
2022/23
Expenditure plus
commitments to date
%
expendituere plus
committed to date
Expenditure to date
%
Budget spent to
date
Budget balance
Kitchens and Bathrooms 1,000 1,049 105% 1,049 105% -49
Bathroom Replacements 175 17 10% 17 10% 158
Central Heating 1,500 2,096 140% 2,096 140% -596
Doors and Windows 1,100 704 64% 704 64% 396
Smoke Alarms/Co Upgrades 375 406 108% 406 108% -31
EESSH - Insulation 1,000 5 1% 5 1% 995
EESSH - Warm Homes R4 c/f 1,860 1,362 73% 1,362 73% 498
EESSH - Lcitp c/f 2,600 2,489 96% 2,489 96% 111
EESSH/EESSH 2 1,000 310 31% 310 31% 690
Sub Total (Capital) 10,610 8,438 80% 8,438 80% 2,172
Rainwatergoods 250 70 28% 70 28% 180
Rainwatergoods - Roof Moss Cleaning
200 1 1% 1 1% 199
Fire risk assesments 0 125 0% 125 0% -125
Roof and Fabric Repairs 500 568 0% 568 114% -68
Plumbing Upgrades 51 7 14% 7 14% 44
Electrical Upgrades 396 950 240% 950 240% -554
Safety & Security 21 63 300% 63 300% -42
Common Stairs 0 35 0% 35 0% -35
Energy Performance Certs (EPC) 0 7 0% 7 0% -7
Sheltered Housing 10 59 590% 59 590% -49
Decoration Vouchers 72 58 81% 58 81% 14
Shower Installations 50 73 146% 73 146% -23
Sub Total (Revenue) 1,550 2,016 14 2,016 15 -466
Disabled Adaptations 360 380 106% 380 106% -20
Enabling Projects 10 25 250% 25 250% -15
Sub Total (Other Investment) 370 380 103% 380 103% -10
Total 12,530 10,834 86% 10,834 86% 1,696
INVESTMENT PROGRAMME EXPENDITURE 2022/23
31 March 2023
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REPORT TO:   HOUSING AND COMMUNITY SAFETY COMMITTEE ON 27 JUNE
2023 
SUBJECT: INFORMATION REPORT ON 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. BACKGROUND 
2.1 The Energy Efficient Scotland programme (EES:ABS formerly known as
HEEPS:ABS) is a Scottish Government initiative to tackle fuel poverty by
improving the energy efficiency of existing private sector homes.  The
programme offers grant-in-kind with a focus on alleviating fuel poverty.  The
cost of the measures to households is discounted by a combination of
Scottish Government grant and Energy Company Obligation (ECO) funding
provided by utility companies.  Only private sector households are eligible for
HEEPS funding but ECO is available to all tenures, including council housing. 
2.2 Since 2013/14, the Scottish Government has provided the Council with an
annual funding allocation for the EES:ABS for energy efficiency and carbon
reduction measures to homes in Moray.  Details of the last 5 years allocations
are provided below: 
2018/19 £1.453m
2019/20 £1.436m
2020/21 £2.128m
2021/22 £1.914m
2022/23 £1.842m 
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Over the years, the Moray HEEPS programme has generally spent all, or
almost all, of its budget allocation. 
2.3 On 7 December 2021, Committee was provided with details of the HEEPS
ABS programme for during 2019/20/21 (Para 8 of the Minute refers). 
2.4 The Scottish Government’s guidance on the scheme expects that
programmes will take a “fabric first” approach and will focus mainly on
insulation measures.  During 2013/14 to 2021/22, the Moray programme has
delivered measures to over 1,700 properties as shown below: 
Year Private
sector Council Grampian
Housing Assoc Total
2013/14 293 43 0 336
2014/15 152 53 0 205
2015/16 135 0 0 135
2016/17 128 33 0 161
2017/18 96 11 10 117
2018/19 222 331 0 553
2019/20 70 48 0 118
2020/21 100 10 0 110
2021/22 0 0 0 0
Total 1,196 529 10 1,735 
The UK Government’s Flexible Eligibility Scheme allows councils to secure
higher levels of ECO funding for energy efficiency improvements to
households at the highest risk of fuel poverty and “vulnerability to cold”.  The
Council has produced a Statement of Intent (SoI) which provides details of the
households in Moray, which are eligible for “LA-flex”.  The key criteria are a
combination of household income/qualifying welfare benefits and the type of
construction of the property.  The Council’s SoI is published on its website at
www.moray.gov.uk/StatementofIntent. 
3. MORAY HEEPS:ABS PROGRAMME 2019/20 – 2020/21 OUTTURN 
3.1 The Scottish Government’s EES:ABS guidance requires councils to target
their delivery programmes to households most likely to experience fuel
poverty, specifically those living in Council Tax bands A-C properties. 
3.2 Changeworks were appointed as managing agent to the EES:ABS
programme on 3 November 2021.  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 provides the resource and expertise required to procure
and deliver a multi-measure programme involving specialist contractors, and
provide specialist advice and support to householders.  The agent will
continue to use the Energy Saving Trust’s Home Analytics database as the
primary source of data to target properties at greatest risk of fuel poverty. 
There is an opportunity to identify Council owned properties of similar
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construction where HRA funded works might be delivered in conjunction with
EES:ABS works in a tenure-neutral manner. 
3.3 There is an opportunity for households to self-refer and those who do not
qualify are signposted to Home Energy Scotland’s helpline for advice. 
3.4 The Council’s proposals for the 2021/22/23 programme sought to continue
delivery of IWI to properties of stone construction, but for the first time,
introduced cavity wall insulation, including extraction of degraded cavity wall
insulation and refill, installation of airsource heat pumps and/or photo voltaic
solar panels (PV) with battery storage.   
3.5 IWI involves adding a layer of insulation boarding to the inside of the external
walls.  The IWI programme focusses on pre-1930 and period properties with a
stone facing external appearance, which, for planning and heritage reasons,
are not considered suitable for EWI.  Due to the cost, time and disturbance
involved in removing fixtures and fittings, kitchen and bathroom areas are
excluded from the scope of works.  Similarly, period details such as cornicing
and fireplaces are excluded from the scope of works.    Routine decanting is
not required and, in general, works can be completed within 4 days.   
3.6 There was a significant underspend on the 2021/22 grant allocation due to
COVID and subsequent supply chain issues. Only 3% of the 2021/22 grant
allocation was been spent.  However a great deal of preparatory work was
completed allowing significant delivery to being using 2022/23 grant
allocation.   
3.7 The following measures were delivered over the 2 year programme.  There is
potential for multiple measures per property. 
Measure 2021/22 2022/23* Total Council Private Council Private
IWI 0 0 0 17 17
EWI 0 0 0 0 0
Cavity 0 0 11 15 26
PV/Battery 0 0 120 142 262
ASHP 0 0 120 12 132 
*projected 
4. MORAY EES:ABS PROGRAMME 2023/24 
4.1 On 22 March 2021, the Scottish Government advised that the Council’s
EES:ABS offer of grant would be £1.769m.  The Government have issued
revised guidance associated with this funding, and advise that the target
group for measures should continue to be fuel poor households in greatest
need of assistance.   
4.2 The Council’s 2023/4 EES:ABS proposals for use of this funding allocation,
submitted to the Government on 5 June 2023, set out a programme of works
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to properties across Moray.  The primary focus of the programme will be on
insulation measures and a “fabric first” approach, 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 help secure an EPC rating of C or better by 2030 for all eligible homes. 
4.3 The planned outputs for the 2023/24 programme are as follows: 
Measure Private
sector Council Total
IWI plus ASHP/Solar PV/Battery storage 50 0 50
CWI plus ASHP/Solar PV/Battery storage 67 0 67
Total 117 0 117 
IWI =  internal wall insulation
CWI =  cavity wall insulation
ASHP =  air source heat pump
PV =  Solar photovoltaic panels 
Qualifying Criteria and Customer Contributions
4.4 The measures in the 2023/24 programme will continue to be targeted to
households most likely to be experiencing fuel poverty, living in properties
within Council Tax bands A-C.  The qualifying criteria are available on the
Council’s website at www.moray.gov.uk/EESABSQualifyingCriteria. 
4.5 Home owners 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 EES:ABS grant 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. 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. 
5. ENERGY ADVICE SERVICES 
5.1 The EES:ABS funding allocation makes provision for a small proportion of
funds to be used for enabling activities.  Some of this activity is delivered in
the form of local energy advice services.  Since 2018/19 officers have
provided funding to the Keith-based Rural Environmental Action Project
(REAP) to provide energy advice services to householders to include home
visits.  This activity will complement the services available via Home Energy
Scotland (HES), which does not include home visits.  REAP and HES have a
well-established cross-referral arrangement providing 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.  Funding to REAP will continue up to
November 2023. 
6. SUMMARY OF IMPLICATIONS 
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(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP)
Addressing poverty and promoting healthy communities is a key priority
of the Corporate Plan and the 10 Year Plan.  Delivery of the
HEEPS: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 and has published as Local Heat and
Energy Efficiency Strategy (LHEES).  Delivery of the EES:ABS
programme will contribute to the achievements of these aims. 
(c) Financial implications 
The report provides details of progress in delivering energy efficiency
measures to housing stock in Moray, including Council houses, funded
from external sources, mainly the Scottish Government’s Energy
Efficient Scotland programme (EES:ABS formerly known as
HEEPS:ABS).  Any ECO funding secured for Council properties will
help reduce expenditure on energy efficiency measures from Housing
Revenue Account.
(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 and older person households. 
(h)  Climate Change and Biodiversity Impacts
The aims of the EES:ABS programme are closely aligned to the
Council’s Local Housing Strategy, Climate Change Strategy, and Local
Heat and Energy Efficiency Strategy (LHEES). 
(i) Consultations
None.   
8. CONCLUSION 
8.1 This information report provides details of progress on the delivery of the
Moray Home Energy Efficiency Programme. 
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Author of Report: Fiona Geddes, Housing Strategy and Development
Manager
Background Papers:  Held by author
Ref:    SPMAN-1285234812-1341
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