HB 29

National Assembly for Wales

Communities, Equality and Local Government Committee

Housing (Wales) Bill: Stage 1

Response from: Tai Ceredigion Monitoring Group 




17th January 2014


For the:

Committee Clerk,

Communities, Equality and Local Government Committee,

National Assembly for Wales.      


Dear Sir/Madam,


Thank you for allowing us the opportunity to respond to the current version of the Housing (Wales) Bill.  We, in the Tai Ceredigion Monitoring Group, made a submission during last year's consultations on this matter.


For your recollection, the group was set up to monitor the Tai Ceredigion residential social landlord's implementation of the transferred stock from the Ceredigion County Council up to the Welsh Housing Quality Standard (WHQS).  This is ongoing, although we have moved on to a more scrutinizing role.


Regarding the Bill itself, we welcome much of that included, although, as representatives of tenants, we feel the emphasis has been more on property than on protections of tenants' rights.  An example of this is in the improvement and maintenance of properties, particularly in the private sector.  Although there is some scope to do this through the process in the renewing of licences, there is also scope, especially under the pressures to find suitable accommodation for those who are homeless or feel forced to move because of the welfare reforms, for these improvements to lapse.  Too many tenants in the private sector are being forced through circumstances to live in substandard properties.  Furthermore, the Bill only specifies quality of accommodation standards for social housing.  Therefore, we would prefer a statutory obligation written in the Bill for all landlords to bring their properties up to a recognized standard (currently WHQS) within an acceptable time-frame and to maintain that standard to fulfil the requirements of any renewing of a licence.  In this way it is hoped all properties for rent will be of a recognized standard.


Regarding standards, although Part 4, pp54-9, considers the interventionist powers the Minister has regarding local authorities failing to meet standards, we feel this is not clarified fully as to which sanctions could be used.


Although there is provision within the Bill for private landlords to offer assured tenures, we would prefer a greater of protection of tenure for tenants written into the Bill, culminating with full security of tenure.  The exceptions to this provision, both assured and later secure, would be if tenants had histories of antisocial behaviour, repeated non-payment of rent without negotiation with their landlord, or damage to property without restitution.


With a shortage of suitable tenures, those desperate will look for ways to jump any queues to gain access to available properties.  We have heard of cases of such queue jumping for which the current version of the Bill does not prevent; if fact, actively encourages, and therefore the potential loophole needs closing.  This is where people have joined the armed forces for only the period of basic training in order to claim they are homeless after leaving the force.  We feel the Bill needs to be amended to stipulate only those who have served the regulatory minimum of three years or have been wounded on active service and discharged before their full term.


Although sections 60 and 61 on page 35 give a definition to what is meant by “intentionally homeless”, we feel this is not a easily understandable to tenants who might be considered as such.  Furthermore, we are concerned about cases where the named tenant leaves a property in which their partner and children are living but are not named tenants, thereby making them homeless.  We would therefore request clarification within the Bill of such dwellers in such circumstances.


Although Part 2 of Schedule 1 allows access to the register of licensed landlords within individual local housing authorities, we feel it worthwhile these individual registers to be compiled into comprehensive register for all Wales.  Similarly, we would request a survey of long-term empty properties and unused land previously allocated for residential properties, so the Welsh Government would have some idea of the current rental situation in the Country and of its future development.



Yours faithfully,

Jim Scanlan,

Chair, on behalf of the,

Tai Ceredigion Monitoring Group.