Overly strict enforcement of regulations can lead to homelessness

This is the text of a letter I had published in today’s Brighton Argus (14th April 2017) in response to, and in support of, a letter from Mike Stimpson from the Southern Landlords Association who warned that the uncritical enforcement of regulations would result in an increase in rough sleeping

When someone speaks who has as much housing experience as Mike Stimpson from the Southern Landlords Association, we would be wise to listen. Few individuals have such in-depth knowledge, and he is one of the few landlords who will still accommodate people on the lowest incomes.

In his letter of 13th April 2017 he warns that a consequence of the enforcement of regulations relating to houses in multiple occupation will lead to more people becoming street homeless. We should all sit up and listen.

Regardless of what one might think of housing being provided through private landlords, the reality is that almost four times as many homes are let in this way compared to those provided by the City Council and housing associations. With spiralling house prices, fewer local people will be able to buy in the years ahead. We must work with private landlords to make sure housing need in the city is being met.

At the same time, Cllr Tracey Hill is attempting to ensure that family homes for rent are not lost. She rightly wants to avoid whole areas becoming blighted by studentification with small family homes being turned into accommodation for six or seven students.

Her efforts in this regard are to be applauded and should be seen as a challenge to our two universities where not enough accommodation is provided to houses the ever-increasing student population in the city. Whether we can reverse what already has happened is unlikely.

If there is an issue of a lack of basic amenities, fire risks and overcrowding, then enforcement action should be taken. Enforcement is right in some cases, but not in cases where there is cooperation by the landlords and where standards are marginally below what we would ideally like.

This week I heard of enforcement action being against a property that has been let as four bedsits since the early 1960s. I don’t know the property myself, but the provision of such accommodation is essential for someone’s housing journey. I myself once rented a property which falls beneath current minimum space requirements, but small though it was, it was my home and I was happy there.

The simplest way to avoid council houses for families being lost and becoming houses in multiple occupation is by ending the Right to Buy, and not extending it even further to housing association homes. One in four, and some studies suggest one in three, former council homes are now in the private rented sector charging rents four times greater than the previous council rents. How many of these homes in Brighton and Hove, are now let to students?

Shared housing is all that is affordable for many, and the only form of accommodation for which those under 35 can claim housing benefit. I am a harsh critic of government housing policy, but while it remains as it is, we need to ensure that there is a balanced provision of homes.

We need to get this right, and the City Council could do worse that having a very early meeting with Mike Stimpson to find a way forward.

Is the announcement of £1.25 to combat homelessness in Brighton more than ‘soundbite funding’?

img_4006The news that Brighton and Hove City Council has been awarded £1.25 million to tackle the homelessness crisis in the City is great news.  The City Council, under the leadership of Cllr Clare Moonan has done very well to get such a large proportion of the £50 million being allocated nationwide.  It is a further testament to the work being done behind the scenes and the strength of the partnerships in place to tackle rough sleeping.

Of course it will make a difference for many individuals, and the funding will allow for innovation and the development of different services, but the problem of rough sleeping in our City will persist.  The causes of homelessness, especially rough sleeping, are complex and deep routed, and will not be solved by what someone once described as ‘soundbite funding’. (Governments of all colours engage in such funding – high profile announcements with comparatively modest amounts, giving the illusion of making a fundamental impact on a problem that has attracted public interest).

The Prime Minister, Theresa May, said in announcing the funding: “In the run up to Christmas, images of soup kitchens and hostels remind us of the vital lifeline provided by charities and local services to those facing a night on the streets.”

She is right that there are such images in the run up to Christmas, and I have been around long enough to know that the timing of this announcement is aimed as much at responding to heightened concern about rough sleeping as it is about a genuine concern about rough sleeping.

Rough sleeping is not an issue just at Christmas.  At Easter, mid summer and throughout the year the City Council, BHT, the Clock Tower Sanctuary, Off the Fence, St Mungo’s and our other partners will be working to combat rough sleeping.

Communities Secretary Sajid Javid said: “We’re making this £50 million funding available across the country this Christmas for ambitious programmes to prevent homelessness in the first place, so that by next year many more people will have been helped to get their lives back on track.”

The funding will help prevent some homelessness and will help some to “get their lives back on track”. But the reality is that the impact of other government policies will do little to alleviate the housing and homelessness crisis and will cost hundreds of millions, dwarfing the £50 million announced this week.

The proof of the pudding is well known.  By this time next year will there be a reduction in the number of street homeless people in Brighton and Hove and in other cities? By this time next year will there be fewer than the 1,800 children in temporary and emergency accommodation in the the City? By this time next year will there be fewer than the 24,000 on the City Council’s housing waiting list? By this time next year will this announcement be seen as little more than soundbite funding?

Has there been a 100% increase in rough sleeping in Brighton and Hove in the last year?

In the Brighton Argus today (16 December 2016) it is reported that the number of rough sleepers in Brighton and Hove has doubled over the last year.

144 people were counted as sleeping rough on the night of Tuesday, November 8. Last year, the count was 71.

Does this mean that there has been more than a 100% increase? The answer is no. It is my view that there was a great underestimate last year and in previous years, and that rough sleeping numbers have held quite steady for the last three years or so. What has changed is the greater visibility of people sleeping in doorways and elsewhere  throughout the city.

I agree with Councillor Clare Moonan who is quoted in today’s Argus as saying: “At first glance, the number seems to show a large increase on last year’s estimate. The reality is that we now have a more accurate reflection of the situation in the city. This year’s estimate is the most involved and detailed we’ve ever done. We feel that as far as possible we have included all of the rough sleepers on the cities boundaries who are currently not engaging with our mainstream services.

“Understanding the needs of rough sleepers in the city helps us to make sure the right services are in place. Key to this is knowing how many people are in need and where to find them.”

The fact that the number of rough sleepers has remained relatively constant, while not anything to celebrate, it is a recognition of the work that is being done in the city, led by Clare Moonan and the City Council, in partnership with a number of organisations including the Clock Tower Sanctuary, Brighton Housing Trust, Downslink YMCA, Equinox, St Mungo’s, Off the Fence, Sussex Police and others.

If it was not for the efforts of these organisations, the numbers on the street would be much, much higher.

For example, last year BHT’s First Base Day Centre, arguably the main hub for working with rough sleepers in the city, in partnership with other organisations, helped 306 people to move off the streets, that is more than one person for every day that we were open.

The London-based charity, St Mungo’s was awarded a contract last year which included the target of reducing rough sleeping by 20% year on year. While that has not been achieved in the first year of the contract, I am hopeful that the service that they promised will be effective in helping to achieve our shared objectives of ending rough sleeping in the City.

But whether there is one rough sleeper or 144, just one is too many. We need to do everything we can to reduce the number. I still remain hopeful that we can eradicate rough sleeping in one of the richest cities in one of the richest countries in the world.

To support the BHT Christmas Appeal for First Base:

  • Donate through our website
  • Text BHTF50 £(amount) to 70070
  • Send a cheque payable to ‘Brighton Housing Trust’ to 144 London Road, Brighton, BN1 4PH.

Brighton and Hove City Council Budget: My Reaction

brighton-hove-council-logoBrighton and Hove City Council published its budget at 3pm yesterday (30th November). I have reviewed it from BHT’s perspective and have a few observations.

But first, I want to recognise the huge challenges facing councillors. They are trying to cope with unprecedented reductions in funding from central government. I would start by paying tribute to the work of councillors. They will get a lot of criticism, personally and collectively, as well as some personal abuse for making tough decisions caused by circumstances for which they are not responsible. That is unfair.

Of course I am most concerned about homeless people and other vulnerable groups, be they people with mental health and/or substance misuse problems, those escaping domestic violence, and so on.

There are other things that will impact of council budgets, again over which councillors have no control. Welfare reform, not least the benefit cap of £20,000 on households, will see more families losing their homes in high cost areas like Brighton and Hove. There will be greater demands on homelessness services, and the City Council will have statutory responsibility to house many of these households.

All this means that homeless prevention services, like those BHT provides through our advice centres in Brighton, Eastbourne and Hastings, become ever more important. Last year we prevented 2,055 households from becoming homeless.

Can you imagine what would happen if we were not there?

The Council has produced a detailed 98 page summary of its budget proposals. It details cuts, the risk arising from funding reductions, and an assessment of the impact and outcomes of doing so.

There are things I welcome:

  • There are no further cuts proposed in hostel accommodation for homeless people on top of the cuts already announced.
  • There are no reductions in homelessness prevention.
  • There is no reduction proposed in the excellent Mental Health Team for Homeless People.
  • And there is no further reductions proposed in funding for specialist support services given the considerable cuts made in recent years.

There is recognition that recommissioned services are supporting the delivery of the City Council’s Rough Sleeping Strategy to which BHT is an enthusiastic signatory.

Savings of £356,000 proposed from the cost of providing temporary accommodation for homeless households out of Brighton and Hove is ambitious and not without risk and not without its problems such as loss of support structures, disruption to schooling, and so on, but I am reassured that the Council is looking at positive inducements for people to agree to these placements.

A further saving of £550,000 is proposed by prioritising households in temporary accommodation for social housing. If this can be achieved, then it will be good news for families, especially those of the 1,800 children in temporary and emergency accommodation. Inevitably, though, if one group gets greater access to social housing, others will lose out, but from a social and financial perspective, this is a proposal I support.

I do have some big concerns.

There is a proposed £470,000 reduction in funding to the third/charity sector through the new Third Sector Investment Programme. Many small community groups might struggle to survive without this funding. These cuts might also be a false economy. For example, cuts to BHT’s Brighton Advice Centre might see a reduction in the prevention of homelessness resulting in much more costly interventions that the City Council will, by law, have to provide.

First Base Day Centre currently receives a modest £20,000 from this source.  It is essential funding that allows us to continue to provide the services we do to those sleeping rough of our streets.

I was encouraged that the Council is looking at ways of reducing these savings.

I have a mixed reaction to proposals to save £600,000 from community substance misuse services.

The main provider of the Pavilions Partnership, Cranston, has negotiated a reduction in its funding in return for a longer contract. This is commendable.

The proposed £138,000 cut in funding for residential rehab services could be a decision the City might come to regret. If it is to reduce out of area placements I would be quite relaxed about that given that these are rarely effective and a lot of money has been wasted in the past. (People achieving abstinence out of area have limited prospects of remaining abstinent if they return to the City without support structures that are provided in abundance and voluntarily for those who achieve abstinence through a Brighton/Hove based service).

If there is a reduction in funding to the two local residential rehab services provided by the St Thomas Fund and through BHT’s Addiction Services, then I would be very, very worried.

BHT’s Addiction Services are amongst the most effective anywhere in Britain. It is no exaggeration to say that if this service was to be compromised, there will be an increase in drug-related deaths.

I hope that councillors are being well advised regarding this.

Rent Smart Brighton and Hove

Last night (Tuesday 22nd November) I attended the launch of Rent Smart Brighton and Hove.  This initiative seeks to ensure that those seeking to rent are provided with useful information about renting in Brighton and Hove.


Launch of Rent Smart Brighton and Hove with BHT’s Alex Brining, Cllr Tracey Hill and Cllr Warren Morgan

BHT is really pleased to be a partner in this initiative and at the launch my colleague Alex Brining paid tribute to Councillor Tracey Hill who has brought together a diverse group of partners including the City Council, the Southern Landlords Association, University of Sussex Students’ Union, Sussex Student Lettings, CAB Brighton and Hove, the two universities, and Brighton Housing Trust.

Please have a look at the new website and please promote it on your social media.

BHT Submission to the Brighton & Hove City Plan Part Two Scoping Paper

(This is a submission I made to Brighton and Hove City Council in response to its consultation on the last phase of the development of its City Plan)

Brighton Housing Trust is pleased to respond to Brighton & Hove City Council’s consultation on the City Plan Part Two Scoping Paper

Brighton Housing Trust (BHT) is at the very heart of initiatives in Brighton and Hove – and elsewhere – to address both the causes and effects of homelessness in the city.

BHT offers services, advice and support for those forced to live on the streets through its First Base day centre in Montpelier Place with 14,708 visits to our early morning session by 955 different clients in 2015/16. We provide housing advice to those with housing problems including those threatened with losing their homes and for those seeking access to the private rented sector.  In 2015 through the advice centre we prevented homelessness in 436 cases.  We provide skills training both at First Base and at the Whitehawk Inn and run an intern placement programme.  Through our Addiction Services, we provide addiction treatment with some 74 per cent of our clients still abstinent 18 months after their treatment was completed.  We provide community housing in the city including Phase One, a 52 bed high support hostel for single homeless men and women; Route One which provides support and accommodation for 60 adults with mental health needs and Richardson’s Yard, an award winning scheme for housing those in need.

The housing crisis in Brighton and Hove is acknowledged in Part One of the City Plan itself as well as through:

It is hoped, the position does not need restating in this submission.

BHT recognises the important role played by strategic planning, planning policies and individual planning decisions in aiding the provision of much needed housing in the city and, in particular, the provision of housing for those most in need.

In recognising this, BHT is fully aware of the burgeoning constraints placed on the planning system that increasingly restrict its ability to require truly affordable housing to be delivered through the development process. We have seen with dismay, for example, the change in the definition of affordable to one that means that housing delivered through planning within this category is not affordable to those in need and those on low and average incomes in the city.

This requires that the City Plan looks for innovative solutions. BHT has already called for Brighton & Hove to be designated as a ‘Housing Crisis Zone’ (https://andywinterbht.wordpress.com/2015/08/08/brighton-and-hove-should-be-declared-a-housing-crisis-zone-requiring-all-housing-development-to-be-for-social-renting-only/). This designation and some of the necessary actions that could follow are matters for central government working with the City Council but BHT urges the City Council to use the City Plan to spell out clearly the extent of the housing crisis and to use that evidence base to support and justify the introduction of strong policies and the unswerving implementation of those that exist.

For example, we acknowledge the strength of the existing policy CP20 setting the affordable housing requirement. However, first, the City Council cannot be seen to be wavering in enforcing its own requirements.  Second, BHT believes that the nature and depth of the housing crisis in the city – coupled with the lack of available larger sites – means that the Council should resist revising this policy to raise the threshold in line with the result of R (West Berkshire District Council and Reading Borough Council) v. Secretary of State for Communities and Local Government [2016] EWCA Civ 441.

Further, BHT asks that consideration should be given to an even more joined-up approach to affordable housing provision through s.106. This may include using receipts from commuted affordable housing payments to support initiatives such as the Council’s own empty homes strategy or in supporting bodies in the city, such as housing co-operatives, which provide housing for those most in need.

As part of this strategic approach, we believe that there needs to be greater co-ordination and mutual reinforcement between the City Plan and the Council’s housing strategy. We note that the diagram of ‘The Housing Strategy Family’ on page 4 of the Housing Strategy does not include the City Plan.

One of the – if not the – most import roles of Part Two of the City Plan is to find means of providing housing to meet the objectively assessed housing need for new housing. As paragraph 37 of the Inspector’s report () points out clearly:

The City Plan Part One, as proposed to be modified, seeks to meet only 44% of the objectively assessed need for new housing. This is a very significant shortfall which has important implications for the social dimension of sustainable development. However, as noted above, the City is subject to significant constraints in finding land for new development. The target of 13,200 new homes is expressed as a minimum, which offers scope for that number to be increased when more detailed consideration of individual sites is undertaken for the preparation of the City Plan Part Two.

To meet the other 56 per cent of previously assessed need – let alone any additional need that may be identified as part of the Part Two preparation process – is an extremely challenging task. BHT urges the City Council to make full use both of identified sites and of windfall sites by maximising densities in line with good practice in sustainable development.  It also urges the Council to examine the scope for encouraging the densification of housing within existing developments – including through the call for sites exercise to be undertaken as part of the Strategic Housing Land Availability Assessment update process.

The Part Two Scoping Paper poses a number of consultation questions. In this submission to the consultation, BHT wants to focus on three of these.

Question H4 asks whether proposed housing site allocations in City Plan Part 2 should seek to specify a range of dwelling types and sizes or should this be left to a more general criteria-based type of planning policy?

The scoping Paper has already identified that:

For affordable housing, the analysis suggests that a greater proportion of one and two bedroom affordable properties will be required. However, the study notes that this does not reflect any specific priorities for family households in need or that smaller homes typically offer more limited flexibility in accommodating changing requirements of households.

BHT believes that, given the constraints put on local authorities in delivering truly affordable housing, the City Plan should use all possible approaches to try to ensure that the supply of housing matches the needs of those in need as evidenced through, for example, data on homeless acceptances. This would require that the City Plan – as the statutory document – does specify a range of dwelling types and sizes.

Question H11 asks whether policies in City Plan Part 2 should resist the loss of housing from within the existing housing stock. Given the existence of a housing crisis in Brighton & Hove, BHT’s answer is an unequivocal ‘yes’.

Finally, Question H18 asks whether the City Plan Part 2 should include a policy that seeks to protect existing HMOs?

BHT recognises that HMO’s can give rise to problems such as noise but we believe that such is the depth of the housing problems in the city that any accommodation that potential serves those who are excluded by purchase or rental cost from other types of accommodation is protected.

This response to Brighton & Hove City Council’s consultation on the City Plan Part Two Scoping Paper is designed both to demonstrates BHT’s willingness to contribute its expertise and informed viewpoint to the development of Part Two of the City Plan and to put forward a number of key issues related to the focus of our work.

BHT would be pleased to discuss any of these matters covered above further and looks forward to being engaged as the process of drafting Part Two develops.

Brighton and Hove has a new strategy to tackle rough sleeping

Brighton and Hove City Council today (Tuesday 19th July) launched its new rough sleeping strategy. You can read the strategy here. The launch took place at First Base Day Centre and I was asked to make a few opening comments. This is what I said:


With the Sussex Police and Crime a Commissioner, Katy Bourne, and the Divisional Commander of Sussex Police, Nev Kemp, at the launch of the rough sleeping strategy

I am delighted that First Base has been chosen to host the launch of this incredibly important strategy. Could I start by thanking Cllr Moonan and her officers for producing such a challenging and urgent strategy.

This year marks the 250th anniversary of this building – once the ball room for the Prince Regent and a chapel for Queen Victoria, it was moved brick by brick in 1850 from the Old Steine to its current location, becoming a church, St Stephens, then. centre for deaf people and, from 1984, BHT’s day centre for homeless people.

In spite of perceptions, the numbers on the streets of Brighton and Hove have held quite steady over the last three years.

For the week ending on or around 10th June each year, the numbers recorded through CAIRES (the system that First Base, St Mungo’s, Antifreeze, Clocktower Sanctuary, the YMCAs and others use) were:

2014    177
2015    166
2016    163

This has been achieved by great joint working over recent years between most agencies. The fact that we have held numbers steady is to the credit to the organisations and their staff who have led on this work in recent years.
What has changed is the perception of the number of people on the streets.

My colleague Simon Hughes, the manager here at First Base, tells me that this is due to:

  • High profile ‘hotspots’ where people are making ‘homes’ for themselves on the streets
  • Sitting on the streets, often begging, although many may not be homeless
  • Protest groups who do not differentiate between rough sleepers and the wider street community. I guess I may be partly responsible for this too because of my genuine concerns about the impact of current housing policy and of welfare reform.

Collectively we have been moderately successful in helping people to end their rough sleeping. For the months January to May, we have seen a small increase in the numbers helped off the streets:

2014 399
2015 407
2016 419

Notwithstanding the successes we have had to date, we have made little in roads in the 160/170 who remain on the streets.

No one organisation has the answer, no one organisation can end rough sleeping on its own. That is why I warmly and enthusiastically welcome this strategy. We need all services to be on the same page, working as equal partners, be they third sector organisations, the City Council, mental health and substance misuse services, and the police.

We need help from central government, and I hope that under our new Prime Minister, who spoke of her commitment to social justice on the steps of Downing Street, housing will become once again where people live, not an investment opportunity, and where social housing with social rents , is encouraged and funded in order to tackle the housing crisis facing our country.

Together, in partnership, we can help people move away from street life, making sure no-one has the need to sleep rough in Brighton and Hove by 2020.