The White Paper explores the reform of core homelessness legislation, including the role of Welsh public services, targeted proposals for prevention, access to housing and implementation.
Extended at risk of homelessness period
We strongly support the principle of increasing the time during which a person facing homelessness should be supported by the local housing authority from 56 days to six months. This would allow for effective early interventions if services are adequately resourced.
Where the threat of homelessness is due to a Section 173 notice, authorities must acknowledge that in most cases, landlords have a reasonable and legitimate reason for seeking possession - such as to sell the property or that they or their family can live in it. In these instances, housing teams should focus on supporting tenants to find alternative rented accommodation rather than disputing the possession.
Scrap priority needs and intentionality
Propertymark supports the proposal to end the priority need test when there is sufficient supply of housing to accommodate all people in need. Whilst we do not want to see anyone excluded from homelessness support, we are concerned there is not enough appropriate accommodation to protect those with the most complex needs, people with disabilities and families with young children. Therefore, we welcome the acknowledgement that ending priority need will require a lead in time to ensure adequate supply levels and minimise extended stays in temporary accommodation.
We also agree with the scrapping of the intentionality test. However, where tenants have made themselves intentionally homeless through acts of serious rent arrears and repeat cases of anti-social behaviour within the PRS, the Welsh Government must support local housing authorities find safe routes into social housing where they can receive greater support for their needs.
Under-18 contract holders
The Welsh Government poses the question of whether the Renting Homes (Wales) Act 2016 should be amended to allow 16 and 17-year-olds to be occupation contract-holders, to broaden the accommodation options available to this group.
The consultation acknowledges this proposal may lead to unintended consequences, and more young people entering the homelessness system. Therefore, they are gathering evidence before deciding whether an amendment should go ahead.
Propertymark agrees in principle that 16 and 17-year-olds experiencing or at risk of homelessness should be able to become contract holders, but property agents and landlords would need sufficient time to create appropriate processes and contracts.
Improve support and access in the PRS
The proposed statutory duty on housing authorities to draw up Personal Housing Plans (PHPs) will struggle to be effective without improved engagement with agents and landlords. The serious lack of social housing means that the private rented sector (PRS) is a vital housing provider. Local authorities should consider keeping databases of PRS homes, particularly those that are adaptable to health or mobility needs.
To support vulnerable tenants to have greater access to the PRS, local authorities should also consider schemes to reduce barriers to obtaining bonds for accommodation, improved training to sustain tenancies and advice lines for those tenants with the greatest and most complex needs to ensure they can be signposted to appropriate support.
The Welsh Government has taken a positive step by not placing the responsibility of referring tenants at risk of homelessness onto landlords and lettings agents.
Propertymark has cautioned against the lack of clarity on responsibilities for lettings agents where landlords have discharged their duty onto an agent, because property agents may not have the day-to-day contact with tenants to effectively assess their risk of homelessness.
