HSHAWB 39 Cyngor Sir Ynys Mon | Isle of Anglesey County Council  

Senedd Cymru | Welsh Parliament

Ymateb gan: Cyngor Sir Ynys Mon  | Evidence from: Isle of Anglesey County Council  

The general principles of the Bill are welcomed and broadly align with the policy direction Welsh Government has pursued in recent years – focusing on prevention, person-centred support, and system reform. Given the scale and persistence of homelessness, legislation is necessary to provide the framework and accountability needed to drive change. However, the legislation must be underpinned by sufficient resourcing and flexibility to adapt to local contexts i.e. rural island context like Anglesey.

The is concern on the impact of the legislation on LAs, there will be an increase in demand on services. This legislation must form part of a package of interventions including changes to LHA rates.

The prevention and early identification approach is positive and necessary. Following repurposing structure, Anglesey provides a resource that directly tackles prevention and early intervention.

The definition of ‘threatened with homelessness’ being extended allows earlier and more meaningful interventions, aligning with RHA. The requirement to take ‘reasonable steps’ must be clearly defined within the code of guidance.

The need for more person-centred approaches to explaining notifications letters are welcomed and could form part of WG communications, similar to that prepared for RHW resources.

The PSAP is welcomed as a requirement by the LA, this is already in place on Anglesey, we also welcome the 8-week review point.

Concerns must be voiced on the removal of priority need and intentionality tests. We appreciate the overall purpose of the Act to help prevent homelessness the removal of these will increase workload for LAs.

Clarity on s75 and those in custody is welcomed as part of this Bill.

The duty to ask and act is welcomed, this signals the start of a continuous dialogue with other public authority, although noted that education has not been included. Anglesey already has several pathways developed with key partners such as Health, Probation and Social Services. It encompasses that “homelessness isn’t just a housing problem” phrase.

We welcome the inclusion of people with lived experience as part of the strategy and consultation and is an aspect we promote on Anglesey.

We note our concern on accepting a s68 to those with no local connection and that accommodation will be available for a ‘sufficient period’. This could mean that interim accommodation is available indefinitely and on an inconsistent basis.

We welcome that a local connection remains in place.

The duty to continue to work with those who are vulnerable of risk of losing their accommodation is welcomed and will strengthen the opportunity to work with our HSG partners to provide this support.

We welcome the provisions to place new duties on the LA in relation to certain categories of young people. Anglesey operates a joint-protocol and LAC transitional panel which looks at cases at risk of homelessness jointly between Housing and Social Services colleagues.

Duty to provide information, advice and assistance to detained persons is welcome, this utilises a preventative approach and allows for forward planning. This will place additional resource pressures on the 5 Counties which have a prison within their LA.

The amendment to the definition of domestic abuse is welcomed and aligns with national frameworks.

Case level data collection is welcomed, this will support both LAs and Welsh Government to make data-driven and evidence-based strategic and policy decisions. However, individual LAs interpretation of data causes a mismatch in what data WG will receive. A Wales-wide system would eliminate any confusion and allow for all LAs to monitor, record and track cases, data and outcomes via the same system. 

The ability to request social landlords to make an offer of suitable accommodation on an applicant owed the final duty is welcomed. The ability to request information is also welcomed and will enable LAs to match homelessness persons to suitable accommodation not only within their own stock (if a stock holding authority) but within the stock of RSL providers too. An additional benefit to this is that it is also useful for acquiring information in order to maintain a register of adapted/accessible properties, a requirement on the LA following this Bill.

Amendments for the requirement for an applicant to view accommodation prior to ending duties will require resources to ensure that reasonable steps have been taken to achieve this.

Aligning housing allocation policies with the wider homelessness prevention framework is essential. Consideration of the current housing context and changes since the legislation RHW was enacted, especially the need to reserve social housing for the most vulnerable and at risk of repeat homelessness, is welcomed and aligns with RRH principles.

Reducing the need for Housing staff to operate larger waiting lists that include persons with no housing need welcomed.

Provisions to increase fairness, transparency and consistency across allocation schemes via CHR is welcomed.

Giving local authorities discretion to prioritise based on vulnerability and local need is appropriate but must be carefully monitored to prevent inequity whilst maintaining cultural and local context i.e. Welsh language, parish connections, maintaining communities.

Reasonable preference to care leavers is a welcomed. This will support Homelessness Services in their efforts to cooperate regarding care leavers.

The Bill introduces a requirement for a CHR – this is welcomed. The Bill will ensure consistency across all LAs in Wales. Anglesey already utilise a CHR.

Accessible Housing Registers is welcomed. This will support quicker identification of suitable accommodation for persons in need.

The Bill needs to support clear pathways between homelessness services and housing allocation teams (in both stock holding and RSL partners) to prevent duplication, bottlenecks and bureaucracy. Code of Guidance to accompany the Bill should make clear guidelines for both LAs and RSL partners.

Agree with the interpretation.

Minor and consequential provisions with a phased implementation for certain aspects is welcomed – further consultation needed on the phases and which amendments can be immediate and which are med/long term. This may differ between LAs given specific nuances of each region, sub-region and locality.

The power to make consequential and transitional provision will allow for Welsh Ministers to make amendments as and when needed dependent on the changing landscape of homelessness in Wales. This is welcomed, however, consultation must begin at the earliest stage between WG and LAs to ensure the resource is there to implement any consequential and transitional provision introduced further down the line and that the provisions are achievable, allowing for LAs to consult and advise on any unintended consequences.

Reasonable preference to care leavers is welcomed

Lack of affordable housing supply, particularly in rural areas. Requirement to deliver volumes of 1-bedroom properties which is not attractive to developers and/or RSL partners given the lower profit margins, planning considerations and perceived housing management demand of 1-bedroom properties and their households.

Workforce shortages in housing support and homelessness prevention roles. Particularly exacerbated by the cost of living crisis and the low wages of homelessness/support workforce in comparison with other sectors and inflation. This creates an environment which is not easy to attract, develop and sustain an experienced workforce of good quality which is needed to deliver on the Bill’s proposals.

Digital and data-sharing infrastructure is still underdeveloped in many local authorities, this will not lend itself well to the co-operation duty as well as many other aspects of the Bill and what will be required to report on. Integrated systems that support all LAs across Wales would be hugely beneficial. The Bill appears to take some account of this with cooperation being emphasised greatly, however, how this transpires in practice is yet to be seen. Strong Code of Guidance and a framework that does not allow for partners to fail in cooperating is required.

The powers proposed are broadly appropriate, allowing for flexibility and responsiveness. However, such powers must be exercised transparently and in partnership with local authorities to ensure that guidance and regulation reflect on-the-ground realities.

Without the appropriate allocation of funding to implement, there is a risk of ‘gatekeeping’ to manage limited resources.

Increasing pressures on temporary accommodation which may see local authorities turning to poorer quality accommodation and/or increasing costs further which could have crippling implications on local authorities.

Rigid compliance with national duties might overlook rural/remote challenges with a potential loss of local discretion. In particular, the ‘local connection to Wales’ test as opposed to local connection to the authority.

S79 does not include violent or threatening behaviours towards others nor is it clear how a duty can be ended for nuisance / anti social behaviour.

S66 does not require a local connection to be applied

Preventing homelessness is welcomed by placing this as a requirement on LAs, it will not be possible to achieve this without HSG funding. Currently, this is an optional funding for WG without security that this is available to LAs delivering on the Bill will be challenging.

The Welsh Government’s financial impact assessment appears optimistic, particularly regarding workforce expansion and systems implementation. Local authorities are already operating under significant financial pressures, and without realistic funding models, implementation risks being inconsistent and under-resourced. Local authorities are still affected by the COVID fallout with staff burnout, staff turnover, inexperienced staff etc. The financial impact assessment does not appear to account for this sufficiently.

Housing;Local Government