Consultation on a Child Poverty Bill for Scotland: Analysis of Responses

3. The income-based targets

3.1. Views on making income targets statutory

Question 2 asked:

What are your views on making income targets statutory? (105 respondents answered this question)

The majority of respondents agreed with the proposal to make the income targets statutory:

"We strongly support the implementation of statutory income targets for child poverty. Child poverty is intrinsically linked with family and parental poverty which means that income is central to the experience of poverty, and any measures of structural determinants of poverty, like low pay, cannot be ignored." (Glasgow Centre for Population Health)

Many of those who agreed highlighted that income is central to the experience of poverty:

"Poverty is, first and foremost, about household income. As such, it is important that income targets are retained in statute and remain the key indicators of poverty." (Local authority council)

The young people consulted also considered income to be the most important priority determining degrees of poverty: "money - it controls so much of what you do - it all comes down to that", and agreed that income is important when measuring poverty (Scottish Youth Parliament). Other respondents noted, in support of the proposal, that statutory targets would be helpful to focus efforts, are crucial in order to measure progress, and are in line with the United Nations Convention on the Rights of the Child ( UNCRC).

Nevertheless, several responses underlined that poverty is not about income alone, mentioning other causes and outcomes of poverty such as: inequality, lack of opportunity, the cost of living, good parenting, access to childcare, education, housing, worklessness, and health and well-being. Many of the young people consulted also agreed that using income alone would not provide a full assessment of poverty, and that the Scottish Government should be "looking at people as individual cases with different incomes who need different support", noting that the costs of healthcare, childcare, education and travel are important to consider (Scottish Youth Parliament). The need to take into account differences between urban/rural poverty, the importance of inclusive growth and economic strategy, and local variations were also mentioned.

Save the Children mention the approach taken in the UK Child Poverty Act 2010, which placed a duty on the State to consider what measures ought to be taken in a range of areas, including employment, financial support, education and housing, in preparing a national strategy to tackle child poverty. They go on to say: "we believe this is a helpful approach and would urge the Scottish Government to consider including this within the proposed Bill; detailing those policy areas within its competence, where Ministers should consider taking action in support of the ambition to eradicate child poverty".

Some local partners felt more clarity was required over who will be responsible for collecting the data and reporting on targets, as well as who the income targets would be statutory for:

"Further information is required regarding governance structures - who will have the responsibility for meeting these targets? What happens if these targets are not achieved?" (Aberdeenshire Council)

A few responses, again mainly from local authority councils, highlighted the need to make sure targets are aligned with existing reporting structures.

3.2. Views on the income-based measures

Question 5 asked:

What are your views on the income-based measures of poverty proposed for Scottish child poverty targets? For example, are there any additional income-based measures you think we should also use (and if so, why)? Are there any alternative approaches to measuring income - for example, as used in other countries - that you think could apply in Scotland? (100 respondents answered this question)

In the consultation document the Scottish Government proposed setting targets based on the same four income-based poverty indicators as in the Child Poverty Act 2020, namely:

• Relative poverty: the percentage of children living in households with equivalised, net incomes of less than 60% UK median household income, in the same year.
• Absolute poverty: the percentage of children living in households with equivalised, net incomes of less than 60% of UK median household income, in the base year (2010/11), adjusted for inflation.
• Combined low income and material deprivation: the percentage of children living in low income households that lack certain basic necessities. Low income here is defined as an equivalised, net household income of less than 70% of the UK median household income.
• Persistent poverty: the percentage of children living in a household in relative poverty for at least three years out of a four-year period.

3.2.1. General support for the proposed measures

The majority of respondents agreed with the proposed measures. Reasons provided for agreement were that using the existing measures meant that they are 'robust', 'well known' and 'widely understood', 'comprehensive and complementary' and allow comparison with past progress as well as international comparison.

" CPAG strongly support use of the four income-based targets described in the consultation. These measures are internationally recognised as robust measures of child poverty and are the product of more than four decades of consultation and development by successive governments at UK and Scotland level. Achieving the four targets described will make a huge and immediate difference to the health, wellbeing and future prospects of tens of thousands of children across Scotland… we believe that retaining a focus on income based targets in this legislation is the correct approach. Only by maximising the financial resources available to families in Scotland can real and lasting progress be made towards reducing wider societal inequalities and improving child wellbeing." (Child Poverty Action Group ( CPAG) in Scotland)

Some respondents wanted to know whether local targets would be set, whether targets could be measured at a local level, and how reporting would be disaggregated to show local variations.

"We would welcome more information on how reporting will be disaggregated to show local variations and where more effort and resources need to be deployed to reach the 2030 targets." (Local Authority council)

A few respondents noted that they did not think that the persistent poverty targets were ambitious enough:

"An ambitious persistence target for families in Scotland would be no more than two years out of three. In addition, there is a strong case to conclude even this is too long for families with children, especially for under-fives. We know that families with children under five have higher poverty rates than other families and that long-term scarring effects result from growing up in poverty which are less evident with shorter spells." (Joseph Rowntree Foundation)

As above, the impact on young children of being in poverty was highlighted as a key reason for this.

3.2.2. Suggestions for additional measures

Additional aspects of poverty that several respondents thought were not sufficiently covered in the suggested measures focused on financial insecurity, depth/severity of poverty and taking into account the cost of living (and regional variations in this and income). The most commonly mentioned aspect suggested for further attention was the cost of living. Several respondents suggested using Joseph Rowntree Foundation's Minimum Income Standard ( MIS) measure to understand adequacy of income relative to essential costs; others mentioned 'poverty after essential costs', or the 'Budget Standard Approach'. Depth or severity of poverty was also highlighted as an important issue to understand. Measuring levels of severe poverty or destitution (drawing on Joseph Rowntree Foundation and Citizen's Advice Scotland's research), and the 'poverty gap' - "the distance between the poverty line and the typical income of a family experiencing poverty" - were suggested. Some respondents thought that it would be helpful to measure being financially insecure and moving in and out of poverty in a year:

"We did observe, however, that the four income-based measures do not reflect inconsistency of income, when people are falling into and out of poverty, making it difficult to budget." (Glasgow Centre for Population Health)

It was also suggested that measuring e.g. the "rate of people falling into and out of poverty more than once in a year, or a measure of the proportion of a year that a family/household spends in poverty" would be useful. Giving consideration to in-work poverty was also mentioned by some respondents (e.g. "the percentage of children living in households where at least one adult works").

Other comments or suggestions made by one or two respondents included:

• Consider equality aspects and disaggregation in relation to measures
• Considering specific vulnerable groups of young people (looked after, teenage parents, young carers, migrants, asylum seekers, travelling populations etc.)
• The measures use UK median figures rather than Scottish figures
• Food and fuel poverty
• Disability i.e. percentage of children living in poverty where at least one person is disabled
• Place - a place based target to ensure that concentrations of child poverty within neighbourhoods in Scotland is also tracked and addressed
• Income inequality measure (20:20 ratio or Gini coefficient)
• Using the Family Affluence Scale from the Health Behaviour in School-aged Children ( HBSC) study as a measure built from a young person's standpoint
• Subjective measures of wellbeing
• A measure of food insecurity
• Time-use surveys to understand women's time poverty
• A measure of poverty of experience/opportunity

3.3. Views on setting the target levels

Question 6 asked:

What are your views on the Scottish Government's proposals for the levels of child poverty that the targets will be set at? (101 respondents answered this question)

In the consultation document, the Scottish Government proposed that the Scottish targets should be set at the following levels:

• Fewer than 10% of children are in relative poverty
• Fewer than 5% of children are in absolute poverty
• Fewer than 5% of children are in combined low income and material deprivation
• Fewer than 5% of children are in persistent poverty

For the most part, there was agreement with the proposed levels for the targets to be set at. In general the proposed levels were seen as ambitious and challenging but realistic. In describing the levels as challenging, some respondents highlighted the background of UK welfare reforms, the Institute for Fiscal Studies ( IFS) projections that poverty will rise by 2020, and the challenging economic climate. A few respondents, based on this context, noted concerns that there is a risk the targets will not be achieved.

"Whilst big improvements were made between 1994/5 and 2004/5, the improvement in the following 10 years have been much more modest. Current economic prospects are not all that encouraging, and progress over the next 14 years may also be modest. We believe that there is a significant risk that these targets might not be achieved." (Local authority council)

"The impact of welfare reform has had a significant and adverse impact on a number of families and has, undoubtedly, compounded the issue of child poverty. It will be important that the Scottish Government ensures that the newly devolved powers in relation to Social Security are reviewed, with an emphasis on funding child poverty." (North Ayrshire Council)

Others underlined that 'significant political and economic effort' or 'more radical actions' would be required to meet these targets:

"…meeting the targets will be extremely challenging. The public sector as a whole (including NHS Health Scotland) will have to be prepared to be more active in supporting this policy goal, if these are the targets adopted. This would mean moving beyond mitigating child poverty at the margins to preventing and undoing child poverty more directly. To do so may require more radical actions at a national level. Increasing child benefit is one option that has been recommended from evidence dating back to the Black Report. Recent modelling commissioned by CPAG Scotland provides illustration of the child benefit top up at various amounts and their impact on child poverty reduction." ( NHS Health Scotland)

However, most thought it was right that the targets were challenging.

"Any serious attempt to tackle this problem requires challenging goals to be set, and the targets proposed by the Scottish Government to be achieved by 2030 would appear to meet this requirement. Having said this, however, although aiming to get child poverty figures below 10% may be a challenging target, successfully achieving this goal should not be the end of the issue, only the beginning. Otherwise we will continue to fail our young people." (Local authority council)

As above, some respondents raised the issue of the acceptability of leaving 5% of children in poverty, questioning whether this met the goal of 'eradication' or underlining that these targets should be seen as the starting point in eradicating child poverty.

"However, we also believe that, even if these targets are achieved, the Scottish Government's ambition to eradicate child poverty should be relentless and continuous, and that through setting and achieving these identified targets it should simply encourage them to set and realise more ambitious targets to ensure that in the future no child in Scotland will ever experience poverty." (Aberlour Child Care Trust)

A few respondents wanted more information on the evidence base used to determine the target levels:

"The Council welcomes these targets and agrees with the Scottish Government that these are ambitious. In order to help put these targets in context, it would be useful to understand what analysis has been carried out to arrive at these levels and whether the level of decline required has been achieved in the past by any international comparator countries." (Local authority council)

Others again mentioned whether/how local targets would be set, and highlighted that local authorities are starting from different points:

"All local authority areas will be starting from different points and therefore local targets would be a better gauge of progress being made." (Local authority council)

"However it is not clear how local areas with higher levels of child poverty… will be resourced to achieve the 2030 targets." (Local authority council)

Several respondents suggested having interrim targets or milestones so progress towards the long-term targets can be assessed.

3.4. Views on setting targets on an After Housing Costs ( AHC) basis

Question 7 asked:

What are your views on the Scottish Government's proposal to set targets on an after housing costs basis? For example, are there any disadvantages to this approach that we have not already considered? (97 respondents answered this question)

Again, most respondents agreed with setting the targets on an After Housing Costs ( AHC) basis, highlighting that "housing costs are a significant factor in poverty" and that measuring poverty AHC provides a better indication of the resources available to households.

"We support this proposal. For most people, housing costs are an unavoidable expense, therefore, after housing costs levels of poverty are therefore a better indicator of levels of poverty in Scotland. We believe that after housing costs more closely reflect children and young people's lived experience and the resources they and their families have available." (Who Cares? Scotland)

"Shelter Scotland welcomes the proposal to set targets on an after housing costs basis. Compared to setting targets on a before housing costs basis, looking at after housing costs more adequately captures those households that pay disproportionately high costs for their housing due to type or location of their place of residence." (Shelter Scotland)

Several respondents underlined the importance of continuing to report on both Before Housing Costs ( BHC) and AHC, noting that gathering information on both allows poverty to be better understood and that the BHC measure allows national and international comparisons, which are important.

"Housing costs are essential costs and we must take them into account. Both figures can be useful to show how much housing can impact on poverty levels and would inform policy to improve levels of affordable housing for those earning the least. If possible it would be useful to keep both measures as both give information which is useful." (Health and Social Care Partnership)

"We support this, and would encourage continued publishing of both BHC and AHC since these highlight the relative contribution of housing costs to poverty: a significant rise for working-age households, a reduction for older households and a smaller gap between BHC and AHC poverty figures than for the UK as a whole." (Joseph Rowntree Foundation)

A few respondents also suggested measuring poverty after other costs:

"While we support the argument for using the figures after housing costs, it would provide a truer figure if the key indicators in assessing poverty could include an indicator based on disposable income available after the deductions, not only for housing costs, but also average energy costs and transport costs which are also relevant factors in the battle against poverty, particularly in rural communities." (Local authority council)

It was also suggested by some that more consideration could be given to the definition of 'housing costs':

"…as this could potentially include a range of elements e.g. rent/mortgage, Council Tax, utilities, heating costs. Housing costs also vary widely across Scotland so it would be important to understand how an average cost could be weighted to account for local circumstances." (Fife Partnership Board)

"It is also crucial that the amount allocated for housing is a true reflection of housing costs and at present the Household Below Average Income ( HBAI) data does not seem to capture all relevant costs. The 'housing' costs only includes the 'interest' element of a mortgage and does not include the 'capital' element. While this may have provided a more accurate picture of expenditure on housing during the 1990s and early 2000s, when interest-only mortgages were common practice and the investment was meant to be covered by an endowment, it is less accurate today where capital and interest mortgage policies are the norm for owner occupiers. There seems to be a wide divergence concerning how housing costs are calculated and the costs allocated to housing do not seem to reflect the real costs." (Shelter Scotland)

Shelter Scotland also highlighted some other aspects that the current definition of housing costs does not take account of: badly insulated housing with a low Energy Efficiency Rating might be cheaper, but pay much higher energy costs; equivalisation does not account for other important household circumstances, such as caring responsibilities and housing costs associated with disabilities and illness; the state of housing, which has an impact on child development and wellbeing.

3.5. Views on the date for achievement of the targets

Question 8 asked:

What are your views on the Scottish Government's proposal to set targets that are expected to be achieved by 2030? (101 respondents answered this question)

The majority of respondents agreed that the 2030 date for the targets to be achieved by was appropriate, suggesting that this date would be realistic, allow for long-term planning, and aligns with other action plans, particularly the Fairer Scotland Action Plan.

"It will take time to demonstrate the impact of this renewed outcomes focus on child poverty and we welcome the 2030 timeframe." (Local authority council)

"This would seem appropriate and fits with the Fairer Scotland ambitions also set for 2030." (South Lanarkshire)

A few respondents noted disappointment that the Race Equality Framework for Scotland 2016-2030 was not mentioned specifically in the consultation document. Several stated that they were disappointed that the UK level 2020 targets had been dropped; however, they accepted that it would be unrealistic for the Scottish Government to meet the income targets laid out by 2020. Others noted that the targets were set at ambitious levels and the AHC proposal in agreeing that the later date would be reasonable.

"Given the ambitious level at which Government is proposing setting targets, and given also that AHC is likely to be the preferred measure, 2030 would seem a reasonable timeframe for achievement." (North Ayrshire Council)

As with the levels for the targets, a few suggested they would like to see evidence of why this date was chosen as appropriate:

"Citizens Advice Scotland would recommend that the Scottish Government undertake analysis and research on the feasibility of eradicating child poverty by particular dates, and what steps would require to be taken to achieve it, before settling on a particular point in time for a legislative target. Whilst it is important that challenging ambitions to eradicate child poverty are set, it is important that they are realistic. The Child Poverty Act 2010 aimed to achieve the targets in the ten years to 2020, which looks extremely unlikely to be achieved." (Citizens Advice Scotland)

A minority of respondents felt that the 2030 date was not ambitious enough and the targets should be achieved in a shorter timeframe. Others drew attention to the children who would growing up in poverty during this timeframe:

"A target of 2030 seems reasonable in view of the size of the task ahead. In saying this, it is important to find methods of alleviating the effects of poverty for those who continue to live in such circumstances in the interim. Third sector agencies are well placed to support the Government in such efforts (for example Children in Scotland's Food, Families, Futures programme in Glasgow in the summer of 2016). These are short-term solutions to support the progress towards longer-term outcomes." (Families Outside)

Many respondents underlined the need to set "interim"/"shorter term" targets or "milestones" to maintain momentum, assess progress towards the 2030 targets and make sure "we are making a difference to families in poverty now".

"We believe there is a need for the legislation to include interim targets to ensure the Scottish Government and other public bodies are on track towards achieving the 2030 target. Interim targets would allow scrutiny and provide a useful way of measuring progress towards the 2030 goals." (One Parent Families Scotland)

"The danger of setting achievement dates for targets so far into the future is that the targets lose "traction", and are more vulnerable to impact from unanticipated major social or geopolitical changes." (Local authority council)