North Yorkshire Council

 

Executive

 

23 January 2024

 

Allocations Scheme for the Provision of Social Housing – Approval of the Proposed North Yorkshire Council Allocations Policy for Social Housing Following Public Consultation

 

Report of the Corporate Director Community Development

 

 

1.0       PURPOSE OF REPORT

 

1.1       To present to the Executive the North Yorkshire Housing Allocations Policy and the results of the public consultation on the draft policyundertaken between 4th September and 17th December 2023.

 

1.2       To seek approval from the Executive to adopt the North Yorkshire Housing Allocations Policy. Approval of the policy will allow progress to be made on upgrading the allocations software, completion of which will dictate the policy implementation date.

 

2.0       SUMMARY

 

2.1       The Council is the strategic housing authority for North Yorkshire and is required by law to have a scheme for determining priorities and procedures when allocating social housing, including council housing stock and housing association properties to rent. The Housing Allocations Policy provides the Council with the framework to manage the allocation of social housing across all localities and allows it to meet its legal duties in relation to its housing function.

 

2.2       A common Housing Allocations Policy promotes fairness, consistency and transparency in decisions relating to the allocation of social housing and assists in the management of our social housing stock.

 

2.3       Choice-based lettings (CBL) encourages greater customer choice, more transparency, increased engagement and interaction between housing providers and customers, better management of customers’ expectations, tackling low demand properties/areas, better acceptance rates and more sustainable neighbourhoods.

 

2.4       Permission is sought to adopt the North Yorkshire Housing Allocations Policy (Appendix A) by 1 April 2025 at the latest. The actual commencement date of the policy is affected by the upgrade of CBL software required to deliver the service and will be widely communicated once known.

 

3.0       BACKGROUND        

 

3.1       North Yorkshire Council has a clear commitment in its Corporate Plan 2023-27 “To help meet housing needs, including those of vulnerable households and those with specific needs”. As a stock holding local authority the Council has 8,299 homes to let and manage.

 

3.2       Further to the council’s stock, there potentially are a further 45,623 homes available for social or affordable rent across North Yorkshire, managed by Registered Providers through HomeChoice.

 

3.3       At present The Council (North Yorkshire) operates two allocation schemes, North Yorkshire Home Choice Allocation Scheme which covers all localities except for Harrogate, and a standalone allocation scheme covering the former Harrogate Borough Council area.

 

3.4       The North Yorkshire Home Choice (NYHC) Allocation Scheme is a long-standing and legally constituted partnership with Beyond Housing, Broadacres Housing Association and Yorkshire Housing having first been established in 2011 and is the principal method for allocating social housing across North Yorkshire, through Choice Based Letting (CBL).  A further eight Registered Providers including Home Group, Together Housing and North Star Housing are full, participating landlords and who advertise the majority of their properties through the scheme which reduces the administrative burden on the council. 

 

3.5       NYHC allows applicants greater autonomy and choice over which properties they chose to bid on. The system allows applicants to view details of available properties and to make informed housing choices. For the landlords, CBL has the potential to minimize voids and hard to let properties, saving time and reducing administration costs.

 

3.6       The NYHC system also allows greater monitoring and data analysis of allocations trends, being able to produce live reports including numbers of applicants, their demographic profiles, banding, bidding patterns, numbers of direct lettings and levels of cross boundary movement (in and out of the partnership area).

 

3.7       Local Government (Structural Changes) (General) (Amendment) Regulations 2018 provide a period of two years for the housing allocation schemes inherited from predecessor councils to be revised and harmonised across the new unitary authority.

 

4.0       NORTH YORKSHIRE COMMON ALLOCATIONS POLICY

 

4.1       In acknowledgement of the requirement to harmonise policy, a proposed social housing allocations policy for North Yorkshire was developed as part of the preparations for Local Government Re-Organisation. This proposed policy has been drawn from the two existing allocation policies.

 

4.2       A summary of the policy proposals and their variation from current NYHC policy and the current Harrogate policy are included at Appendix B.

 

4.3       Although the proposed policy itself, which sets out criteria around qualification, eligibility and how applicants will be prioritised, will not be significantly different for either customers of North Yorkshire Home Choice or Harrogate, the use of choice-based lettings will be a significant change for Harrogate tenants and applicants together with partner agencies operating within the Harrogate locality.

 

4.4       Adoption of the policy and the associated move of existing applications in the Harrogate locality from the current system to the NYHC will require the re-registration of over 2,000 waiting list applicants in the Harrogate locality and 6,000 HomeChoice applicants.  Advice and support needs may increase as users adjust to the new way of working.

 

4.5       It is proposed that to manage the workload as efficiently as possible and provide support where it is required, existing HomeChoice applicants are moved across to the new scheme as soon as the upgrade is complete. Subsequently, applicants from the Harrogate locality will be transferred to the scheme and a common allocations scheme will be in place no later than 1 April 2025.

 

5.0       CONSULTATION UNDERTAKEN AND RESPONSES

 

5.1       At the meeting of 9 August 2023 the Executive Member for Culture, Arts and Housing gave permission for officers to undertake a public consultation on the Council’s draft policy for the allocation of social housing.

 

5.2       The public consultation was open from 4th September until 17 December 2023. A communications plan was developed which detailed the key stakeholders to be consulted. Focus was paid to consulting with current housing applicants in the Harrogate locality, through personal communications and with tenants of North Yorkshire Council through the Annual Report 2022/23 which was sent to each one.

 

5.3       A summary of the online consultation responses is attached at Appendix C. Overall the consultation received 479 online responses, 44% (212) responses were from the Harrogate locality and 42% (200) were from current applicants. Several written responses were also received and considered.

 

5.4       The analysis of the responses shows that overall, the majority of respondents agreed or strongly agreed with each of the proposals.

 

5.5       The table below summarises the levels of support for each of the proposed criteria.

 

Criteria

For

Neutral

Against

1.   Income/Savings

70.4%

14.2%

14%

2.   Local Connection – Residency

76.2%

9.2%

13.6%

2a. Local Connection – Employment

60.5%

16.1%

21.5%

3.   Exemptions -Armed Forces

52.4%

31.3%

15%

3a. Exemptions – Care Leavers

60.3%

25.1%

12.7%

3b. Exemptions – Domestic Abuse

73.7%

13.2%

11.7%

4.  Rural Connection

68.3%

16.1%

13.8%

5.  Boundaries

68.7%

13.6%

16.1%

6.  Refusals

51.1%

15.2%

32.4%

7.  Banding

64.1%

23.2%

11.3%

8.  Bedroom Need

67.2%

17.5%

13.6%

9.  Unborn Children

63%

19.8%

15%

 

5.6       Of the criteria with the lowest levels of support:

 

Criteria 6 – Refusals: Many of those who disagreed with the proposal felt that there was little clarity over what constituted a ‘suitable’ offer and voiced concern over the quality of information available on properties on the HomeChoice website. This can be mitigated by increased scrutiny of the property details uploaded, analysis of refusals data and staff guidance being updated regarding suitable offers.

 

Criteria 3 – Exemptions -Armed Forces: This criteria attracted a high level of neutral responses. Many of those who disagreed with the proposal had concerns that it would negatively impact on specific areas, opposition was highest among respondents from Richmondshire and Selby.

 

In June 2020 the Ministry for Housing, Communities and Local Government (MHCLG) published new statutory guidance: Improving access to social housing for members of the Armed Forces: This document provides a single standalone piece of statutory guidance on allocating social housing for the Armed Forces community. The statutory guidance encourages local authorities to exempt from any local connection requirements divorced or separated spouses or civil partners of Service personnel who need to move out of accommodation provided by the Ministry of Defence.

 

6.0       CONTRIBUTION TO COUNCIL PRIORITIES

 

6.1       The scheme contributes principally to the following Council priority:

 

 “Place and Environment: Good quality, affordable and sustainable housing that meets the needs of our communities”

 

7.0       ALTERNATIVE OPTIONS CONSIDERED

 

7.1       It is a legal requirement to adopt a single allocations policy for the Council by 1 April 2025 with a clear expectation from the regulator that we would consult with those parties who may be impacted by any changes to an existing policy including both applicants and tenants. 

 

7.2       Whilst it is a regulatory requirement for housing providers to let their homes in a fair, transparent, and efficient way, the Regulator for Social Housing does not prescribe this any further. It is therefore a matter for council to determine which approach best suits its current circumstances.  

 

7.3       In the current climate, and now that the Social Housing (Regulation) Act has received Royal Assent, it would seem prudent to adopt the North Yorkshire Home Choice model to ensure compliance rather than to adopt the Harrogate locality model as this would also lead to significant disruption to a greater number of tenants and applicants and impact on our key partners. 

 

8.0       IMPACT ON OTHER SERVICES/ORGANISATIONS

 

8.1       Adoption of the policy and the transfer of applicants from the Harrogate locality to the choice-based system could lead to an increased call volume to Customer Services and to residents seeking support and assistance from other front-line staff, particularly in Health and Adult Services however the bulk of the work will be picked up by the Allocations team supported by colleagues within the wider Housing Management & Landlord Services teams. Based on learning from the consultation exercise, prior to the launch of the new system, an internal communications plan will be initiated, and staff fully briefed on the changes.

 

9.0       FINANCIAL IMPLICATIONS

 

9.1       There will be some one-off expenses associated with the implementation of the policy and the adoption of the North Yorkshire Home Choice allocation scheme. Firstly, there is a need to re-register over8,000 current applications using the revised criteria. The expectation is that the proposed housing management structure maintainssufficient capacity to undertake this work. However, an additional staffing budget of £5,000 is requested to fund additional resource to complete this process more quickly or provide additional support for applicants, if required.

 

9.2       Secondly, it would be appropriate to budget for resident communications for the point at which the scheme is ready to launch, in order to ensure that existing applicants, support agencies and partner organisations are aware of the change. We estimate that this will cost in the region of £5,000 based on previous communications exercises.

 

 

Item

Amount Requested

Details

Staffing

£5,000

250hrs Allocations Officer scp13 + pay award.

Communications (promotion, printing, postage etc)

£5,000

Based upon costs of recent consultation exercise

Total

£10,000

Funded form HRA Working Balance

 

9.3       The alternative costs, both to the council and its partners of adopting the Harrogate locality model would however be even greater still. 

 

10.0     LEGAL IMPLICATIONS

 

10.1     Local Government (Structural Changes) (General) (Amendment) Regulations 2018 provide a period of two years for the housing allocation schemes inherited from predecessor councils to be revised and harmonised across the new unitary authority.

 

10.2     In order to comply with the above requirement we have considered the requirements of the Social Housing Regulator and its Consumer Standards, taken best practice from the existing Social Housing Allocations Policies and undertaken public consultation on the draft proposals in accordance with the council’s consultation principles.

 

10.3     In adopting a common allocations policy for North Yorkshire the council will be promoting fairness, consistency and transparency in decisions relating to the allocation of social housing.

 

11.0     EQUALITIES IMPLICATIONS

 

11.1     A full Equalities Impact Assessment has been completed and reviewed internally based upon the knowledge and information we already hold across both allocation schemes.

 

11.2     Completing the EIA has identified a number of data gaps within both the NYHC and Harrogate systems. As part of the planned upgrade to the CBL software these gaps will be addressed and equalities monitoring information collected for those re-registrations and future applications.

 

11.3     In order to mitigate some of the risks identified in the EIA increased monitoring will be put in place, we will re-establish an Equalities Monitoring operational group for a period of up to 12 months post the planned go-live date of 01 April 2025.

 

11.4     An action plan has been drafted which highlights the above commitments and further work to provide additional support to those applicants identified as no longer meeting qualification criteria, undertake Customer Journey Mapping and establish annual rolling reviews of non-engagement, to ensure that there are no unintended consequences of the new policy being adopted.

 

12.0     CLIMATE CHANGE IMPLICATIONS

 

12.1     A climate change impact assessment screening form has been completed acknowledging that there are no significant impacts. 

 

13.0     PERFORMANCE IMPLICATIONS

 

13.1     Moving to a common allocations policy will allow more transparency and consistent monitoring of application and allocations data. TheHome Choice system allows for a suite of data to be produced on an on-going basis to capture and monitor performance key trends and performance, including numbers of applicants, their demographic profiles, banding, bidding patterns, numbers of direct lettings and levels of cross boundary movement (in and out of the partnership area).

 

13.2     Increased monitoring will be undertaken in the first 12 months of operation at least, to ensure that potential risks highlighted in the EIA are mitigated.

 

14.0     POLICY IMPLICATIONS

 

14.1     The draft social housing allocations policy will replace the two existing social housing allocation policies.

 

14.2     All localities would adopt the revised policy from 1 April 2025, unless the CBL software is in place any earlier, in this case the policy commencement date would be widely communicated.

 

15.0     RISK MANAGEMENT IMPLICATIONS

 

15.1     The Council risks not being legally compliant if it has not adopted a single allocations scheme and accompanying policy by 1 April 2025.

 

15.2     There are risks to be monitored during the adoption of the policy for example, having sufficient resources to complete the re-registration exercise and therefore keeping existing applicants in the scheme, increased void rates, preventing digital exclusion and adverse equality implications.

 

16.0     ICT IMPLICATIONS

 

16.1     The project does have ICT implications, and these have been flagged with the Technology team and included in their work programme, a member of the Technology Team is on the Allocations Policy Working Group.

 

17.0     CONCLUSIONS

 

17.1     The Council is required by law to have a scheme for determining priorities and procedures when allocating social housing. An Allocations Policy for North Yorkshire has been drafted, combining elements of the predecessor allocations policies and public consultation on the policy has been undertaken.

 

17.2     Once adoption of the policy has been agreed, the Choice Based Lettings software can be updated to reflect the agreed criteria and once that process has been completed an official launch date can be agreed, to be no later than 1 April 2025.

 

18.0     REASONS FOR RECOMMENDATIONS

 

18.1     The following recommendations are therefore proposed to ensure that the council meets its requirement in law to adopt a scheme for allocations within the given 2-year timescale.

 

19.0

RECOMMENDATION(S)      

 

19.1

The Executive is asked to:

i)     Note the contents of the report, the proposed Allocations Policy, consultation responses and the Equality Impact Assessment.

ii)    Approve the Allocations Policy, to become effective from no later than 1st April 2025

iii)   Approve the contingency funding for additional staffing and communications budget totalling £10,000 from the HRA working balance. 

iv)   Delegate to the Assistant Director Housing authority the making of any minor amendments to the Allocations Policy as needed by changes to regulation or legislation

 

Nic Harne

Corporate Director – Community Development

County Hall

Northallerton

 

5 January 2024

 

Report Authors: Carl Doolan, Head of Housing Management and Landlord Services &     

 Vicky Young, Housing Policy and Strategy Officer

 

Presenter of Report Carl Doolan, Head of Housing Management and Landlord Services  

 

Note: Members are invited to contact the author in advance of the meeting with any detailed queries or questions.

 

APPENDICES:

Appendix A – proposed North Yorkshire Allocations Policy

Appendix B – Policy Proposals - Variation from existing

Appendix C – Public Consultation Summary

Appendix D – Equality Impact Assessment

Appendix E – Climate Change Impact Assessment Screening