Response: Homelessness (suitability) consultation

By: Deborah Garvie  Published: August 2012


Shelter strongly welcomes the draft Homelessness (Suitability of Accommodation) Regulations. However, there are a number of areas where we believe the regulations should be significantly strengthened if they are to provide adequate protection to the most vulnerable homeless households.

Summary

We strongly agree that the five broad areas listed (physical condition; health & safety; licensing of houses in multiple occupation; landlord behaviour and elements of good management) should be important in determining suitability. 

However, there are two further areas where we believe better regulation is required: affordability and location of accommodation.  These are almost invariably the most important factors in any offer of accommodation.  For example, the interim findings of longitudinal research  by Shelter and Crisis exploring the use of the private rented sector to house homeless people found that 'most people said that they felt that the area was the most important factor for them, and one that they had based a decision on, alongside the cost of the tenancy'.

We urge the Government to strengthen the affordability regulations  to ensure that accommodation cannot be considered affordable if, as a result of the rent level or any shortfall between the actual rent and the tenant’s housing benefit, the tenant’s income would fall below a basic subsistence level. 

Location is such a vital aspect of suitability that it requires provision to be made in regulations, and not merely in the Homelessness Code of Guidance .  We therefore strongly welcome the Government's preferred approach to strengthening the location aspects of the legislation by specifying them in regulations.

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