Written evidence submitted by London Borough of Enfield and its Homelessness Prevention Board [IOC 194]

Introduction

Enfield has severe housing pressures.  With a large proportion of low-income residents occupying the private rented sector, the highest eviction rate in the country and a relatively low level of social/affordable housing, homelessness is a challenge that has resulted in Enfield being the second highest user of temporary accommodation in the Country.  With ambitious plans to turn this situation around the Council had agreed a strategy based on measures to increase the provision of secure, affordable private rented accommodation and to work further upstream to prevent homelessness.  The Covid-19 situation has interrupted the delivery of this plan, but it has not dented our ambition and determination to tackle homelessness in the Borough.  Our interest in submitting our evidence is to inform a response so that we are able to address the issues arising and create better housing outcomes for residents as a result.

We are in support of the submissions made by the North London Housing Partnership and London Councils but want to specifically highlight the issues for Enfield.

Generally, the call to action across the police and health sector has instigated very welcome enhanced joint working arrangements. 

In the private rented sector

• The pause on eviction action has provided households with reassurance during this difficult time, but this has postponed action rather than stopping it.  However, we now expect that the lifting of restrictions will result in a wave of evictions.  The current restrictions have suppressed demand rather than removed it.
• The LHA increase has been welcome and in Enfield this has reduced the number of households having less income than their housing costs from 16% to 9%.  However, job losses and other income shocks experienced by households may work against this progress.
• The LHA change has seen more interest from landlords in wanting to rent their homes through prs rather than to the Council through temporary accommodation.
• Because the LHA change has a limited lifespan, with no commitment beyond this financial year, it is difficult to procure properties as there is not guarantee that these will remain affordable for residents.

Rough sleepers

• The development of the third sector in supporting homelessness prevention is vital and the end of funding for this group via winter shelters at the end of March resulted in lost capacity and a greater call on the Borough at a time when this was much needed.
• The “everyone in scheme” created significant challenge for councils to procure accommodation.    Enfield responded through its own initiatives as we were unable to access the wider support measures.
• We have welcomed the multi-agency drive that has arisen due to this measure to work closer with individuals who may have previously been difficult to engage with to address their housing situation.
• However, there remain entrenched rough sleepers with complex needs and it has been difficult to apply multi-agency processes to secure their housing quickly.  More guidance on this situation would have and would still be useful.
• Cost pressures are significant for Enfield and there are multiple calls on the funding allocated by Government.  We have received some £266k MHCLG funding for addressing the costs arising to support rough sleepers but we estimate the cost of this additional emergency accommodation is more like £1,090k for 6 months which is the time we will need to secure rehousing. 

For those at risk of homelessness

• The measures referred to above have assisted short term.  However, the economic impact including job losses and the social implications of the lockdown are likely to drive increased homelessness for which we are preparing.
• We have already seen a large increase in the numbers of non-priority households approaching us for help.
• The voluntary sector requires funding to provide a stable basis to contribute.

In the private rented sector

• Access to Universal Credit is a significant concern in Enfield. These households may have suffered wage cuts or job losses and may have increased personal debt.
• Increased measures to support households that have lost a family member – especially in the light of Covid-19 and whose benefits will be affected needed to be treated with due support – a one size fits all response is not appropriate in these circumstances.
• The increases in LHA levels have been extremely helpful.  However, this has also led to an increase in the number of households affected by the benefit cap.  This limits the impact of the LHA rise so the benefit cap needs to be raised to the same level as the LHA.

Rough sleepers

• There is insufficient supported housing provision to move people on to and a strategy to address these needs to be pursued as a matter of urgency.
• GP registration is essential to ensure access to secondary care services is possible – support to achieve this with hard to engage rough sleepers would be welcome.
• We have received short term funding to support EU migrants under the suspension of derogation arrangements, but these measures should be extended and support to ensure re-housing is provided.
• We continue to see a steady stream of rough sleepers approaching us for assistance.  This is a mixture of ‘new’ rough sleepers and those who are more entrenched.  We are also targeting encampments, and this will result in a fresh cohort of rough sleepers.  The pressure to secure emergency accommodation for this group is continuing to grow.

Homeless

• Most estate agencies and landlords have effectively closed during the emergency, so residents find it difficult to source accommodation
• Households financial resilience will be lower due to job losses and while benefit claims are processed
• There will be an increase in host ejections, especially people who are ‘sofa surfing’ as well as homelessness need and increase in domestic violence
• Expectation that there will be an increase in demand for homelessness services once the restriction on landlord evictions has been lifted.
• The capacity of the third sector to respond has been affected and they provide services and contact that are often trusted by some vulnerable groups.

For those in the private rented sector

• Increased risk of eviction and general disputes with landlords
• Financial hardship as a result of income shocks and reduced financial resilience with all the economic and social consequences that this brings to individuals and communities.

For Rough sleepers

• Without sufficient support (focusing on health and wellbeing, employment/ training/ education, life skills, housing and benefits) they will go back to rough sleeping even if accommodated and will become desensitised to the risk of Covid-19.

For those at risk of homelessness

• A new group of residents requiring housing advice and support all presenting to the Council in a very short space of time
• Increased pressure to find privately rented accommodation for those housed under the emergency provisions
• Increase pressure to find privately rented accommodation for those households receiving a negative decision in relation to their homelessness status. 

For those in the private rented sector

• Control the rate of possession orders and bailiff warrants – incentivise Councils to secure tenancy sustainment’s with a range of levers.
• Continue the ban on s21 evictions beyond the end of the lockdown to reduce the number of households losing their home
• Restrict the use of incentive payments to landlords to stop price/rent inflation. Place greater emphasis on deposit and rent in advance schemes which puts investment in the hands of residents and not landlords.

For Rough sleepers

• Additional resources needed to establish and fund new supported and housing first services and enable LAs to claim intensive HM in the same way as RPs.
• Resources to support establishment of support packages designed to rehabilitate.
• Look to extend the ability to fund supported housing through housing benefit to councils.  This would speed our ability to set up new move on provision.

For those at risk of homelessness

• Phased approach to closing down Everyone In.  Just ending the scheme instantly will have a major impact on public health.  Look to remove priority need criteria until a vaccine is widely available as sofa surfing will not be safe for the foreseeable future
• It is essential to lift the benefit cap during this time
• Ensure Boroughs do not outbid each other for accommodation pricing out the market

For those in the private rented sector

• Supported to return to the PRS with use of procured PRS stock, SHPs Information, Advice and Guidance Scheme, Supported Housing providers

For Rough sleepers

• Supported housing schemes working with partners in the third sector
• PRS/TA where suitable

For those at risk of homelessness

• Supported to remain or move into the PRS

Of the rough sleepers we have housed so far, nearly 50% have no recourse to public funds.  We welcome the funding extended to migrants but would like to see this extended over a longer period.  Equally this still leaves a significant cohort with no recourse to public funds and it is essential that we are able to identify solutions for these residents, both for their own safety and in the wider interest of public health.

For those in the private rented sector

• Widescale evictions – legal and illegal
• Financial difficulties experienced by landlords
• Increased dependency on DHP to cover rent including generating further strain on local authority benefit teams with the need to ensure increased UC applications are processed quickly.

For those at risk of homelessness

• Significant increased demand on homeless services impacting ability to undertaken prevention and increasing the use of Temporary accommodation and council costs
• Higher eviction rates
• Increased number of relationships breaking down as a result of the pressures of the lockdown.  This will see an increased number of households presenting as homeless.
• We anticipate rise in mental health needs (which may impact on employment/ earnings) and substance misuse – both of which can push people into homelessness.

An ambitious strategy to eradicate homelessness

The Charity, Crisis has provided a blueprint for the eradication of homelessness.  This needs to be updated in the light of the issues created from the pandemic and a revitalised government ambition agreed to address the underlying issues for the long term.

A three year funding programme for homelessness

Adequate and longer term investment in homelessness services and interventions is required to support Councils to adopt strategic programmes that will deliver step change in homelessness outcomes.  This is essential in the light of the financial pressures Councils are under as a result of Covid-19.

A national supported housing strategy

There is a real need for a national supported housing strategy to meet the needs of vulnerable residents.  This is a vital way in which people with complex needs including Rough Sleepers can be supported to turn their lives around and also to reduce homelessness.  In the short term, a programme of funding should be established for councils to bid to provide adequate provision to meet the needs arising from the move on of residents out of emergency accommodation.

Incentivise and reward effective multi-agency working

The collaborative multi-agency efforts triggered as a result of the pandemic must be sustained to address the increased risk of homelessness that arises.     Local authority Homelessness Prevention Boards must be supported and incentivised to work collaboratively to deliver real results to reduce homelessness together.

Restrict the use of incentive payments

Enfield is in a very different position from many London boroughs.  We have a relatively large private rented sector that is more affordable than many other London boroughs.  This means that Enfield has been a net importer of homeless households for several years with many other boroughs placing households in both the private rented sector and temporary accommodation.  60% of the temporary accommodation in Enfield is used by other boroughs.  We anticipate that as councils seek move on accommodation for people accommodated under the emergency measures, there will be intense competition between boroughs for private rented tenancies and temporary accommodation.  This is likely to mean that the use and level of incentive payments to landlords and agents will rise and that the overall cost of securing a tenancy will escalate, driven by the competition between boroughs.  There is an urgent need to reach common agreement on stopping the use of incentive payments to prevent a large escalation in costs to both councils and residents.  In line with the rise in the LHA, we would also welcome incentivisation of Boroughs to house residents in Borough where ever possible.

Full support for Councils to deliver new affordable homes

Boroughs are well placed to be further empowered to create balanced housing markets that meets the needs of all of its residents.  At Enfield we are taking all opportunities to secure housing growth including affordable homes.  We have commented separately on the government’s proposals for First Homes – initiatives like this need to be considered in the light of the impact they will make on addressing the housing needs of local communities with a view to preventing homelessness.  Our view is that First Homes will not deliver the right housing solution for our residents and it will substantially reduce the level of much needed affordable housing in the Borough.

In addition, our Housing Revenue account is likely to be affected by income reductions arising from Covid-19 and the consequences to the economy and to jobs as a result.  However, under normal circumstances and over a 30-year period there is capacity.   We urge Government to review how the long-term capacity in business plans can be used to address priorities for new homes in the current climate.

May 2020