A national consultation on improving Temporary Accommodation Standards was undertaken between 22 May and 14 August 2019. It reflects the Scottish Government's (SG) ambition to progress the commitments made in the Ending Homelessness Together High Level Action Plan, published in November 2018. The recommendations aim to eradicate rough sleeping, transform temporary accommodation and end homelessness in Scotland.
The consultation contained forty-two questions that covered two key issues:
Firstly, the proposal that the use of unsuitable temporary accommodation should be limited to a maximum of seven days for all homeless households. Currently, this is the case for homeless families with children and pregnant women; the Scottish Government wished to understand the positive and negative implications of extending the Order to all homeless people. Suggestions were also sought on timeframes and exemptions.
Secondly, the creation of a set of Scottish Government advisory standards based on the adopted and updated Guidance on Standards for Temporary Accommodation published by the Chartered Institute of Housing (CIH) Scotland and Shelter Scotland and including additional standards suggested by key stakeholders and those with lived experience that responded to the consultation. Respondents were also to consider how the new advisory standards produced could be introduced as a legally enforceable temporary accommodation standards framework. Several questions explored whether existing CIH Scotland / Shelter Scotland standards could be used as the basis for an advisory framework, and whether legislation (or amendments to existing legislation and regulation) would be required to produce an enforceable standards framework.
In addition to exploring these issues, the consultation included a number of questions on the lived experience of temporary accommodation. These will provide further understanding to inform the process of making the changes outlined above.
Profile of respondents
The consultation received 65 responses (62 via Citizen Space and 3 in non-standard format). A further 351 responses to subsets of questions were received from individuals via an organisation, and are referred to as alternative format responses in this report
Of the 65 full responses, 10 were submitted by individuals and 55 responses came from organisations. The profile of organisations that took part in the consultation is as follows:
- 31 responses from the housing or health sector including local authorities; henceforth referred to as 'housing stakeholders'.
- 24 responses from advocacy, representative, legal and regional stakeholders including organisations that provide specialist housing provision such as refuges; henceforth referred to as 'advocacy stakeholders'.
Respondent categories within the 351 responses submitted by an organisation are shown below:
- 95 individuals with lived experience. These were people who described their experience as 'personal', 'relative' or 'friend'.
- 94 individuals categorised as being without lived experience. These were people who described their experience as 'professional', or 'none'.
- 162 individuals did not provide details of their homelessness status or experience.
Approach to analysis and reporting
This report presents the range of views expressed and trends amongst responses. The analyst team applied a qualitative coding framework based on a review of the consultation questions and sample of responses.
There was significant repetition of views within and across responses to the 42 questions. To improve readability and avoid duplication, the report is structured around themes, aligning questions or common themes in comments.
While qualitative analysis of open-ended questions does not permit the quantification of results, we signify the weight of a particular view, using the following framework. Where there are several themes, we have indicated which are the most common or prevalent across responses:
- Dominant or 'the most common' - the most frequently identified theme within responses to a question.
- Many/Several/Prevalent/Common - a reoccurring theme, not mentioned by all.
- Some/a few - a minor theme.
- A small number - infrequent mention by more than one respondent, not common.
- One - issue raised by one respondent.
Where appropriate, quotes have been included to illustrate key points. Quotes provide useful examples, insights and contextual information, but may not always represent the views of entire groups. If respondents gave permission for their responses to be published, we have quoted directly, however minor spelling or grammatical errors have been corrected to improve readability.
Respondents' responses to the consultation, where permission for publication was granted, can be found on the Scottish Government's website.
The Lines Between was commissioned to provide an independent and robust analysis of the responses to the consultation. This report is set out as follows:
- This first chapter closes with a quantitative summary of responses; number of responses to each question and any breakdown of quantitative questions, for example yes/no responses.
- The Executive Summary and Introduction sections provide background and an overview of the report contents.
- Chapter 1 presents analysis of responses to questions around the Unsuitable Accommodation Order.
- Chapter 2 presents analysis of responses to questions around standards. Relevant parts of responses from people with lived experience are included in this section to provide background and context.
- Chapter 3 presents analysis of responses to questions around monitoring and regulation. Relevant parts of responses from people with lived experience are included in this section to provide background and context.
- Chapter 4 presents analysis of responses to questions around enforcement and sanctions. Relevant parts of responses from people with lived experience are included in this section to provide background and context.
- Conclusions are set out in Chapter 5.
Wherever relevant, responses from people with lived experience are included in with each chapter to provide insight, background and context.
The following tables present the results of the quantitative questions included in the consultation. Please see Appendix 1 to reference the questions in full.
Responses from Section 2 Question 1 are shown below.
|Do you think we should:||Total|
|Option A: Extend the restriction to all homeless people from an agreed date.||27|
|Option B: Extend the restriction to all homeless people but introduced incrementally over a period of time.||22|
|Option C: Not extend the restriction to all homeless people||9|
The table below gives a quantitative summary to the questions that prompted a yes/no response.
|S2 Q4||In your opinion is option A or B the best way to avoid an increase in the number of breaches of the Order?||26||9||30|
|S2 Q8||In extending the Order do you think the same definition should apply to all homeless households as it currently does to families with children and pregnant women?||44||12||9|
|S2 Q9||With the extension of the Order to all homeless households, should these exemptions still apply?||45||9||11|
|S2 Q10||Would sanctions provide an appropriate mechanism to encourage compliance?||19||36||10|
|S2 Q11||Would you like to see the SHR gain any enhanced responsibilities in order to effectively monitor and assess the implementation of the extended Order?||26||27||12|
|S3 Q1||Please confirm whether you agree that the existing CIH Scotland/Shelter Scotland standards provide an appropriate basis for a Scottish Government advisory standards framework.||53||1||11|
|S3 Q2||Do you think these standards are still relevant and fit for purpose?||51||3||11|
|S3 Q4a||Please tell us if you agree that it would be appropriate to include new standards for temporary accommodation within the refreshed Code of Guidance.||49||4||12|
|S3 Q4b||Do you think that the new standards should also be published elsewhere?||36||9||20|
|S3 Q6||Do you agree that a reference to these other legislative and regulatory mechanisms is made within the new set of accommodation standards?||51||0||14|
|S4 Q1||Do you agree with this approach?||43||5||17|
|S4 Q3||Do you think that there should be sanctions, such as penalties or fines applied to those local authorities failing to meet the new standards?||17||34||14|
|S4 Q5||Do you agree that it would be appropriate for SHR to take on this role utilising their current powers or by extending their current powers?||39||6||20|