Housing Rights responds to Programme for Government consultation
Housing Rights has responded to the consultation on the draft Programme for Government (PfG), and the Delivery Plan for PfG indicators 8 and 48. In our response, we highlighted the following key points:
Programme for Government
Housing specific outcome needed
It is disappointing that at the stage of the draft PfG Framework key concerns of Housing Rights, as well as others in the sector, were not addressed. In our response to the earlier PfG Framework, Housing Rights expressed concern that the Framework contained only slight reference to housing, and construed housing in the narrowest of terms. We made a joint call along with the Council for the Homeless, NIFHA and CIH, for a housing-specific outcome in the PfG: “We have good quality, affordable homes for everyone.” We also recommended that the PfG include additional indicators to capture the complexity of housing, and tying these indicators to more PfG outcomes to demonstrate the way in which housing enables the achievement of other outcomes.
In the draft PfG, despite the addition of a second housing-related indicator, the PfG’s emphasis on housing has been reduced significantly, with housing now linked to just 2 of the 14 PfG outcomes.
Homelessness work could be undermined
Without appropriate recognition of the importance of housing in the PfG, the commitment of resources for important work, particularly homelessness, may be found lacking. Housing Rights notes ongoing work to develop a cross-Departmental Action Plan to support the new NIHE Homelessness Strategy. However, without recognition of the links between housing and preventing homelessness and the achievement of many other PfG outcomes, there is a danger that resources for this joint working could be found lacking, which could undermine the momentum of ongoing work on homelessness.
Use “after housing costs” in measuring poverty
Housing Rights would prefer the use of an “after housing costs” measure in measuring absolute and relative poverty. Affordability is now Housing Rights’ fastest-growing advice issue; as an agency working across all housing tenures, we advise clients struggling to make ends meet in private rentals, social housing or owner-occupied homes. These can range from Housing Benefit entitlement and deposit protection, to rent and mortgage arrears and repossessions.
Housing costs are a priority commitment for all households; money available after housing costs is therefore a more accurate representation of living costs and poverty. An “after housing costs” measure would also more accurately capture increasing pressures on housing affordability.
Delivery Plan
More emphasis needed on private rented sector
The activities and narrative of the Delivery Plan, as with the relevant sections of the PfG, are heavily weighted towards the owner-occupier and social sectors, at the expense of the private rented sector. The private rented sector is increasingly important in addressing housing need; the Delivery Plan could be strengthened if it committed to examine the role of institutional investment and housing associations in the PRS, and gave more emphasis to the PRS in actions to help people access affordable housing. Housing Rights strongly recommends that the Department review the content of the Delivery Plan to rectify significant omissions and misunderstandings. Having the correct point of departure for the important work the Department will be undertaking within this Plan will ensure that the efforts which flow from this can be maximised.
Commit to adopting Housing Health and Safety Rating System
Action 3 of the Delivery Plan could be strengthened with a commitment to adopting the Housing Health and Safety System (HHSRS). The HHSRS is under consideration in the current Fitness Review, and integrates health and housing to align with the cross-departmental focus of the PfG.
“Pay to stay” unsuitable for Northern Ireland
The evidence base and rationale for several key activities in the Delivery Plan is unclear – particularly the proposal to explore introducing “pay to stay” in Northern Ireland. There appears to be no recognition that the tenant profile in Northern Ireland is significantly different than in England, and it is almost unheard of for a social household here to have an income of £60,000.
More consideration for equality
The Delivery Plan generally, and particularly in relation to Action 4, should give more consideration to equality, and give consideration to how to promote equality for groups experiencing inequality as recently highlighted by the Equality Commission.
Use financial institutions to sustain home ownership
Housing Rights encourages the Department to balance activities with promoting access to home ownership, with activities to sustain home ownership. We note the Department’s desire to ensure access for under-represented groups such as older people or those with disabilities; it is critical that these and other groups are supported to sustain accommodation, as well as access it. In this light, Housing Rights notes the absence a role for financial institutions (and indeed the government) in preventing home repossession from the Delivery Plan.
Further reading
Read our full response to the Programme for Government, and Delivery Plan.
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