Written evidence submitted by the Royal Borough of Kensington and Chelsea [IOC 244]
Summary
The Royal Borough of Kensington and Chelsea (RBKC) welcomed the measures put swiftly in place to support residents in the private rented sector, rough sleepers and the homeless. This includes help targeting directly targeted to residents, support to local authorities and partners delivering services, and efforts to coordinate responses across London.
However, the costs of meeting the homelessness challenge have far outweighed COVID-19 rough sleeping and homelessness funding from Government. This is on top of existing underfunding of costs to local authorities, including RBKC, of administering the wide range of services for residents who are homeless or at risk of it.
There is an opportunity to take huge strides forward in assisting and accommodating London’s rough sleepers. However, the exit and recovery strategy from the emergency response phase needs to be fully funded and sustainable over the long term. Local authorities and partners need the resources to deliver move-on accommodation and support. Fundamental structural factors that directly affect residents such as the lack of access to truly affordable accommodation (a key cause of homelessness and a barrier to preventing it) must be addressed. And residents and families who are experiencing homelessness for reasons other than COVID-19 must not lose out as a result of a focus on those directly affected by it.
The Royal Borough of Kensington and Chelsea invites the Select Committee to consider the evidence below, and the evidence submitted by London Councils which this Authority endorses.
Funding
1.1 Government funding to support the Royal Borough of Kensington and Chelsea (RBKC) cover additional costs resulting from COVID-19 has been welcomed. The Council received £5.9m across all services, and £14,250 of the MHCLG Coronavirus (COVID-19) Rough Sleeping Contingency Fund (which had a £3.2 million commitment nationally). However, this funding has not been sufficient to cover costs: see question 2.
1.2 Changes to Universal Credit and uplifting of Local Housing Allowance rates have also been beneficial.
GLA rough sleeper accommodation programme
1.3 Government funding and support of the GLA hotel programme has been welcome. However, the programme has not delivered significant results for existing and new rough sleepers in RBKC. See question 2.
1.4 The measures taken to prevent the eviction of private rented sector and social housing tenants has contributed to a fall in homelessness approaches to the Council at the present time. Similar, the assistance provided to homeowners may also have contributed, though the Council has, historically, experienced very low numbers of homeless approaches from home owners with financial difficulties (for example, little or no residents assisted through the Mortgage Rescue Scheme).
1.5 Similarly, the Government’s commitment to immediate assistance for every person found on the street has helped to ensure unprecedented offers to rough sleepers, including the availability of hotel accommodation for homeless persons where that supply would otherwise be closed.
1.6 The recent Government guidance on the allocation of social housing is welcome.
Exit strategy
1.7 The Government’s commitment to support the Strategic Coordinating Group’s forthcoming Rough Sleeper Exit Strategy is welcomed, as this will need to be a very considerable, far-sighted and well-funded exercise to achieve its objectives in the long-term.
Funding
2.1 As of the date of submission, the Council had committed approaching £750,000 to specific COVID-19 rough sleeping and homelessness services, demonstrating that the funding, thus far, is insufficient. The Council’s commitment does not take into account forthcoming financial commitments to the COVID-19 exit strategy. At the same time, COVID-19 has resulted in a loss of income for the Council (for example, business rates, council tax, parking charges, commercial and residential rental income) as it seeks to support its local communities and businesses.
GLA rough sleeper accommodation programme
2.2 The pan-London COVID Protect and COVID Support schemes are welcomed but RBKC has found it very challenging to place and support our rough sleepers through these schemes. Therefore, the Council has not been able to place any trust in them and has had to block book and / or procure large numbers of commercial hotel rooms to ensure entrenched and new rough sleepers and single homeless residents are accommodated and supported appropriately.
2.3 The pan-London programme did not provide support for vulnerable residents in supported accommodation unable to self-isolate due to the need to share facilities.
Government guidance
2.4 While the Government’s stance on the prevention of evictions was welcome, the initial presentation of this stance was inaccurate and misleading. Rather than being a `ban on evictions’, evictions could still go ahead where possession had already been obtained. This raised expectations and resulted in confusion amongst tenants and landlords.
2.5 There has been a rise in attempted illegal evictions leaving people homeless during the lockdown. As a result, there has been a greater demand on Tenancy Relations services (with no additional funding) as people deal with new policies.
2.6 There is a significant concern that the prevention of evictions during the outbreak will not reduce homelessness, but increase it leading to a future spike and acute pressure on resources. See question 3 for `post-lockdown’ impact.
2.7 The Government’s (understandable) expectation that no one should be left on the streets has not been complemented by an appreciation for the need to comply with duties under the 1996 Housing Act and 2017 Homelessness Reduction Act. RBKC is now providing hotel accommodation to residents who may not be eligible for assistance, may not be homeless (the decanting of winter shelters in RBKC uncovered residents who not only had no local connection with the Borough but were found to have accommodation available to them elsewhere), and who may not be in priority need. In other words, the Council is currently providing accommodation to many residents towards whom it does not or will not owe a full homelessness duty, and towards whom it may be expected to offer a relief of homelessness in a very challenging accommodation market.
2.8 The Government’s guidance on assistance to persons without recourse to public funds has not been clear and has not fostered partnership working between homelessness services, childrens services and adult services with regard to who is responsible for immediate and longer term support. Over 30% of rough sleepers assisted by RBKC has no recourse. In addition, many residents with the right to rent but no recourse to public funds have experienced the loss of income meaning they are relatively helpless against (eventual) eviction.
2.9 Government advice for hostels and day centre providers of services for rough sleepers was removed from their website and has still not been replaced. This has created confusion on what steps to take where resident with underlying medical conditions or Covid-19 symptoms are sharing kitchens and bathrooms.
2.10 A number of rough sleepers (well known to RBKC outreach services) continue to decline offers of accommodation. There is a challenge marrying ongoing support and engagement with the unclear question of using enforcement to meet the requirement to support residents off the streets, especially as the pan-London accommodation and support offer cannot be relied upon.
2.11 Early in the lockdown, RBKC contacted its main Private Registered Partners to explore the possibility of continuing with allocations of social housing in exceptional circumstances (while observing guidance on social distancing). The response from our RP partners was overwhelming positive. The Government may have issued the recent guidance on the allocation of housing at a much earlier point in time, reflecting the actions already being taken by local authorities and RPs.
3.1 There is severe shortage of affordable accommodation in Kensington and Chelsea; being both a key cause of, and barrier to the relief of, homelessness. The challenge of finding suitable and affordable accommodation in or close to the Borough is likely to become more acute post-lockdown given the greater competition for it. This is a fundamental barrier to assisting residents made homeless during or after the COVID-19 lockdown.
Post-lockdown impacts
Support for rough sleepers and other vulnerable residents
3.2 Having closed winter shelters and other dormitory-style accommodation for rough sleepers in order to offer accommodation in `self-contained’ accommodation, there are significant concerns for future emergency accommodation options, such as No Second Night Out and Severe Weather Emergency Protocol accommodation, especially if key aspects behind social distancing are retained over the longer term. What will replace this provision?
3.3 While RBKC is providing temporary accommodation to single homeless residents who would not usually meet the threshold for placement, it has also identified vulnerable residents made homeless directly or indirectly by COVID-19 who previously were not known to services. These residents will require carefully planned move-on options, alongside the complex rough sleeping cases.
3.4 Block bookings of hotels will need to end or be phased out, as hotels will want to open to commercial business and the cost of continuing to accommodate rough sleepers and single homeless will not be sustainable for GLA and the boroughs.
3.5 There is a strong likelihood that Councils will need to provide suitable temporary and settled accommodation for an increase in the number of residents fleeing domestic abuse.
Homelessness from private rented sector, families and friends
3.6 Actions taken to prevent evictions during the lockdown will not reduce homelessness after it. Instead, the actions take thus far are likely to result in a spike in homelessness increasing further the pressure on resources. For example:
- While many private sector tenants will be experiencing financial difficulties (reduced income, increase in utility bills etc) they are still required to pay rent. Benefit support will be insufficient to cover this financial gap in high value areas such as RBKC, in spite of uplifts to the Local Housing Allowance cap. Private sector tenants will be accruing arrears at the present time that they will not be able to repay. This is likely to result in a significant wave of evictions from the private sector placing great strain on Council homelessness services.
- COVID-19 restrictions on mobility (and fears associated with the COVID risk) are likely to have contributed to a fall in homelessness approaches as a result of families or friends evicting. It is also recognised that the current restrictions are placing great strains on households. It is not unreasonable to expect an increase in this cause of homelessness alongside approaches from the private rented sector.
- Residents who have suffered a fall in income, or a loss of job, during the current outbreak will be far less equipped to secure their own accommodation in the months ahead, especially in high value areas resulting in a greater reliance upon assistance from the Council.
- It is feasible to expect that private sector landlords might seek to cover lost rental revenue during the height of the COVID-19 crisis by raising rents in the near future. This may be fuelled by an increased competition for available properties, both from a pent up private market but also from local authorities seeking to accommodate an increase in homeless residents and families.
Long-term strategies
Funding for local authorities
3.7 A fully-funded, feasible exist strategy for rough sleepers assisted during lockdown (coordinated in London by the London Strategic Coordinating Group) is vital to delivering on long-term objectives.
3.8 The need for boroughs to deliver on the exit strategy will have a real impact on local authorities including RBKC. Local funding will be a huge issue as will the practical challenge of accessing appropriate accommodation for all homeless households. While the brief for the London Strategic Coordinating Group exit strategy states the impact upon other forms of homelessness will not be considered within that particular piece of work, on a practical level for local authorities they cannot be de-coupled.
3.9 The pan-London exit strategy is unlikely to deliver move-on options for all currently accommodated rough sleepers within six months. Therefore, funding will be required to continue to accommodate and support rough sleepers with complex needs in the meantime. RBKC has already committed £357,504 to accommodating and supporting vulnerable residents for the next six months. This cost is likely to rise for a subsequent six months especially if the provider has the option of returning to commercial business.
3.10 There is real opportunity to make enormous strides in accommodating and supporting rough sleepers, and meeting the MHCLG’s goal to end rough sleeping by 2024. Homeless charities such as Crisis and Shelter will expect no less. Therefore, additional funding should be provided for well regarded and much lauded Housing First Schemes.
3.11 Additional funding should be provided to support move-on for low / no need single homeless residents currently accommodated by local authorities but who are unlikely to be owed any homelessness duty beyond the relief of homelessness. The average pre-COVID cost of rehousing a single person to settled private rented accommodation approached £3,400 to address landlord incentives, rent in advance, deposits, bonds, and insurance.
RBKC already has the second highest number of households placed in temporary accommodation per head of borough population. On average, single residents wait over two years in temporary accommodation before moving on to settled accommodation. The Council requests additional funding and a more facilitatory rehousing environment to ensure residents at the core of the COVID-19 crisis can be supported into appropriate accommodation without impacting on the opportunities for other homeless residents and households.
3.12 It is important to recognise that the existing costs to local authorities of administering the Homelessness Reduction Act (the purpose of which the Council supports) far exceeds current funding from Government. RBKC staffing costs alone are almost triple what they were in 2017/18. The Select Committee may wish to consider responses to the MHCLG’s consultation ‘Homelessness Reduction Act 2017: Call for Evidence Summer 2019’ to understand the pressure local authority homelessness services were under before the COVID-19 crisis.
3.13 New models of accommodation and support for rough sleepers will need to be developed to replace existing services that are no longer considered appropriate. Funding may be needed to replace local shared sleeping space services with self-contained facilities.
3.14 A review of revenue & capital funding for supported housing should be undertaken to ensure better staff and skill recruitment and retention, and the delivery of in-house and floating support services in appropriate post-COVID accommodation.
3.15 A funded strategy is required to support residents who have no recourse to public funds at present. Local authorities may not have the legal powers or the resources to continue to support these residents post lockdown, and derogation funding will not be sufficient based as it is on a pre-CV19 position.
Supply of affordable accommodation
3.16 Consideration should be given to mechanisms that increase the supply of truly affordable housing both for the relief and prevention of homelessness, especially in the private rented sector.
3.17 There needs to be a greater focus immediately on increasing the supply of affordable accommodation, both in the social housing sector and private rented sector for residents requiring support post lockdown, bearing in mind the historical under-supply of affordable housing especially in higher value areas. RBKC is already directly delivering new social housing while seeking to increase the supply of genuinely affordable housing through Planning mechanisms. Government should consider:
- Further investment in social housing to stimulate the economy and maintain overall housing supply, given the likely slowing down of the private housing development market.
- the expectation that Private Registered Providers (RPs) will do more to accommodate residents with high support needs
- funding RPs and the voluntary sector to explore intensively managed and supported houses of multiple occupation for single homeless residents aged under 35.
Government guidance
3.18 The Government must issue clear long term guidance on the support that can be provided to residents without recourse to public funds to inform a prudent exit strategy.
3.19 The Government should provide clarity and support on the application of duties under the Homelessness Reduction Act in light of local authorities’ response to supporting single residents off the streets. In such unprecedented circumstances, local authorities should be given the funding, time and powers to support single low / no need residents into settled accommodation without being tripped up by the administration of the Homelessness Reduction Act. There is an opportunity to make great strides to supporting many residents into suitable accommodation.