Consultation on a review of the Scottish Social Housing Charter: an analysis of responses

Annex 3: Additional comments

Chapter 6

Specific points on changing outcome 3:

• Insert "add value" between "participate in" and "influence".
• Add at the end of the outcome "and in a way that suits them".
• Replace "other customers" with "other stakeholders" and add "in a value-adding way" following "participate in".
• Consider changing "at a level they feel comfortable with" as this sounds condescending.
• Reword the outcome as follows: The Customer experience shall be that: 1. Social landlords will comply with the legal requirement to include customers in the management of their businesses. 2. Customers are able to participate in and influence their landlord's decisions at a level they feel comfortable with.

Chapter 7

Suggestions made by one or two respondents regarding changing standard 4 on Quality of Housing:

• Standard should refer to the safety of homes.
• "subject to available utilities" should be inserted after SHQS.
• The standard should be broken down into two sentences with the first referring to the SHQS and the second referring to allocated homes being clean, tidy and in a good state of repair.
• Should be re-written from the customer perspective: "The customer experience shall be that……"
• Could be improved if it referred to the landlord's duty to meet the minimum standard rather than focusing on the specific standards.
• Should incorporate minimum standards for temporary accommodation which would be enforced through the Charter and Regulator. Shelter Scotland stated that, "This is especially relevant considering the changes to the funding of temporary accommodation through housing benefit that is facing local authorities and they should be encouraged to explore options around future provision of these services while maintaining good quality properties and services."
• Standards 4 and 5 should be more distinctly separate. One RSL suggested re-naming standard 4 to "Housing Quality and Investment" and transferring improvements from standard 5 to standard 4 as they perceived improvements to be part of investment in properties and not part of repairs and maintenance.

Suggestions made on changes to the supporting narrative for standard 4:

• 3 ^rd sentence: replace "Beyond" with "Apart from".
• 3 ^rd sentence: replace "cost effective" with "value for money".
• 3 ^rd sentence: clarify what is meant by "higher" energy-efficiency standards".
• Refer to evolving technology and appropriate sources of match-funding.
• Re-word to enable tenants to know what to expect from a property upon allocation to them.
• Need some acknowledgement that given the requirements for value for money, most landlords will be unable to continue to seek enhancements to energy-efficiency standards beyond the targets required by EESH.

Chapter 8

Additional comments of those in favour of changing outcome 5 on repairs, maintenance and improvements.

• The wording "reasonable choices" does not reflect the stronger wording in the supporting narrative.
• "Improvements" should be removed from this outcome and placed under outcome 4 to make the two more distinct.
• Add that the expectation is that repairs will be carried out quickly.
• Need to reference health and safety, for example, "Tenants' homes and communal areas are safe and well maintained…"
• Households in temporary accommodation should have the same rights to repair and maintenance as those in social housing.
• Concern that from the landlords' viewpoint, some repairs are for tenants to address and landlords should not be held to account for these.

Chapter 9

Additional suggestions on how the supporting narrative associated with outcome 6 can be improved.

• Include reference to the Community Empowerment (Scotland) Act 2015 and the local outcome improvement plan.
• Include the requirement for landlords to keep tenants informed on progress of actions, as it can take a long time for some of these in this area to come to fruition.
• Be more specific on what is meant by "range of actions".

Chapter 12

Additional suggestions of a few respondents on changing outcome 11.

• Given the different size and financial position of RSLs, is a one-size-fits-all approach appropriate? Does the outcome refer to housing officers and income officers (and equivalent) providing tenancy/financial support, or bespoke and specialist teams/services?
• A few respondents considered that measurement of success should allow for tenancies terminating within one year due to personal choice rather than failure to sustain the tenancy. Indicator 20 was criticised for being too crude a measure in this respect and treating all such terminated tenancies as failures.
• Two respondents (one RSL and an individual) considered that the content of the outcome and the supporting narrative could be switched around to be more appropriate.
• Scotland's Housing Network provided their view that the provision of care and support is a huge aspect of many social landlords' work. They perceived the Charter to be light on the role of support provision by social landlord organisations to their customers and argued that such an important and prevalent function may justify Charter outcome(s) over and above this one relating to tenancy sustainment, important though this is in its own right.
• One TRG recommended that "accurate and current" precedes "information".
• One TRG suggested the following text be added to the outcome:

"This is based on: - organisations "are available locally and nationally to provide information and support as well as the Council's Housing Options Service; - some people do not want or agree to take the support available, however landlords need to highlight the support available and how to access it" (East Ayrshire Tenants' & Residents' Federation).

Suggestions were made for additions to the text of the supporting narrative relating to outcome 11.

• The explicit inclusion of looked-after children, their parents or carers, and care leavers, in the list of inclusions.
• Links with the health and wellbeing agenda including the Scottish Government's aim of supporting independent living.
• Further reflection of the standard set out by Article 19 of the Convention on the Rights of Persons with Disabilities in that "suitable support" should reflect support to live independently in the community with choices equal to others.
• Greater specificity over support services, for example, "…money and debt advice, support with correspondence or other tenancy related issues or advice and support to understand tenancy management and tenants' rights and responsibilities and tenants who may need their home adapted to cope with age, disability, or caring responsibilities".
• Insert "can identify better and thereafter" before "can help tenants…"
• Insert reference to timeliness of provision of support.

Chapter 13

Additional suggestions in favour of changing outcome 12 were:

• Two respondents questioned the term "good-quality", one individual considering this to be subjective; and the other (a voluntary organisation) suggesting that factors such as time spent in temporary accommodation and quality of support during the time spent in temporary accommodation, should also be assessed by the Charter.
• Two respondents specifically raised concerns about the usefulness of the supporting indicators, with one local authority considering that indicator 26 should be changed so that it cannot exceed 100% (it was reported that this could happen due to the same household being offered more than one type of housing during their homeless application).

• Angus Council recommended that the outcome be re-written in plain English along the lines:

  "homeless people get help and advice quickly and easily; get suitable, good-quality temporary or emergency accommodation when they need it; and are offered support to help them get and keep their home."

• Homeless Action Scotland commented that given the universally accepted move towards a housing options approach (linked with the legal duties on homelessness) they believe that this outcome should be rewritten to cover prevention of homelessness, support and advice, tenancy sustainment as a preventative tool and the quality of service.

Chapter 14

Additional suggestions on how to improve the supporting narrative relating to standard 13.

• Should be an emphasis on continuing to achieve standards and overall aims whilst striving for value for money. Concerns were raised that the former may be lost in an effort to give better value for money. One public body commented that there should always be room for flexibility for arising circumstances, such as requiring more time for decisions in sensitive cases.
• The supporting narrative should promote openness and transparency, perhaps with annual reporting on value for money, in order to facilitate meaningful tenant scrutiny.
• The narrative omits recognition of the added value and social and economic impact which social landlords can bring to local communities.
• Begin the supporting narrative with a sentence which states 'Without compromising on quality of maintenance or repairs, and taking into account reasonable timescales for tenants'" ( CELCIS and Who Cares? Scotland).

Chapter 16

Additional comments of those in favour of changing outcome 16.

• Change title of the outcome to "Gypsies'/Travellers' Sites" to reflect the focus of the outcome.
• Change "should manage the sites" to "will manage the sites".
• The Charter should take into account social landlords' responsibilities to their tenants in terms of the wider place context of homes.

Chapter 17 Scrutiny and indicators

Comments relating to scrutiny and indicators are summarised below.

• Several local authorities provided their view that some indicators may not present an accurate picture of performance. Circumstances were cited where social landlords may be unduly penalised by the current indicators, for example, where they had high standard properties which could never meet the SHQS on account of the way they were constructed.

• Some respondents requested that all outcomes have related indicators, for example:

  "We…….believe strongly that there needs to be a crossover between expected outcomes and indicators to ensure there is a consistent approach to accountability of social landlords" (Homeless Action Scotland).

• The importance of social landlords being grouped into peer groups of like-for-like organisations for comparative purposes was emphasised.
• Several respondents recommended a review of the indicators and the definitions underpinning them.