3. Social housing plays an important role in
providing accommodation for a wide range of
households, including some of the most
vulnerable in society. Its contribution to wider
public policy concerns such as the creation of
socially cohesive communities, educational
performance, health improvements and
economic opportunities is well acknowledged.
Using allocation policies more strategically,
through taking account of and responding to
local circumstances, has the potential to
maximise these and other benefits, a point
reiterated in the statutory allocation guidance.
This practice brief complements the recently
published statutory guidance on the allocation
of social housing.1
It aims to:
1. support local authorities in responding to
the new statutory guidance
2. contribute to the increased use of
flexibilities in local allocations policy
and practice
3. help local authorities to effectively
communicate allocation schemes / policies
as well as any changes following a review,
ensuring that applicants and the wider
community receive the correct information,
so as to counter any misconceptions or
prevent them from becoming established in
the first instance
4. support local authorities to effectively
engage and consult with communities when
developing and / or reviewing allocation
schemes / policies
Who should read this practice brief?
The principal audience for this practice brief
is English local authorities who by statute
are required to have an allocation scheme
in place. It will be of particular interest and
relevance to:
• elected members
• staff responsible for allocations and lettings,
particularly those new to this area.
It will also be of interest to:
• tenant and resident groups
• stakeholders with a professional interest in
housing allocations, such as advice agencies
• registered providers of social housing2
–
they will often be the sole supplier of social
housing in an area and have entered into
agreements to allocate a certain proportion
of their stock to local authority nominations.
This means that they will be affected by
changes to the allocation scheme and are
key stakeholders when it comes to
consulting over any changes.
This practice brief is intended to provide
some pointers on how to translate the
statutory allocation guidance in practical
terms.Wherever possible, practice examples
are used to illustrate the main points. It does
not provide step-by-step guidance on how to
develop an allocation scheme.
Allocations – fair and flexible
1
CLG, 2009, Fair and flexible: statutory guidance on social housing allocations for local authorities in England, London, CLG
2
For a full definition see section 80 of the Housing and Regeneration Act 2008
4. 3
[2009] UKHL 14
Statutory guidance on allocations – principles
Fair and flexible: statutory guidance on social
housing allocations for local authorities in
England provides clarification on the
flexibilities local authorities can exercise in the
allocation of social housing.This follows a
recent House of Lords3
judgement which
recognised the flexibility to which local
authorities are entitled to.
Local flexibilities and decision-making
in allocating housing
In consultation with local communities, local
authorities are encouraged to make greater
use of available flexibilities within the current
legislation, such as putting more emphasis
on local connection and waiting time in
determining relative priority between
applicants. In fact, there is nothing to stop
local authorities from operating allocation
schemes which prioritise applicants who do
not fall within the statutory reasonable
preference categories, as long as overall
schemes do not work to the detriment of
those in greatest housing need.The guidance
reaffirms the view that priority for social
housing should go to those in greatest
housing need, as set out in the statutory
reasonable preference categories.Allocation
schemes are further expected to support a
number of government objectives and wider
policy drivers.
Following the House of Lords ruling in Ahmad
v. Newham LBC, local authorities are no longer
required to provide for cumulative preference
within their allocation schemes, that is
prioritising applicants according to the
severity of housing need or on the basis of
falling into more than one of the reasonable
preference categories.
Prioritising applicants on the basis of waiting
time alone was held to be acceptable.
Furthermore, local authorities wishing to set
aside a small percentage of lets to existing
tenants wanting to move but who don’t fall
into any of the reasonable preference
categories can do so.
Whilst the guidance is not prescriptive in terms
of the method used to prioritise applicants, it
encourages local authorities to have simple
and transparent systems. Banding schemes are
seen as less complex, easier to understand and
hence ‘fairer’, compared to points-based ones.
The guidance further encourages the more
widespread use of local lettings policies to deal
with specific issues and concerns.
4
5. Choice-based
lettings schemes
Under a choice-based lettings scheme
(CBL), applicants will be given the
opportunity to bid for vacant properties
which are advertised.Advertisements will
give details of any restrictions (such as
accommodation reserved for older and
disabled households) in place on certain
properties.Accommodation will generally
be allocated to the bidder with the highest
number of points under the scheme.
To enhance transparency and help
applicants to make best use of the
scheme, lettings outcomes are published
at regular intervals as is information on
the likelihood of securing
accommodation of a certain kind / in
a certain location, taking account of
applicants' priority status and other
circumstances.
The government’s five year housing plan
Sustainable Communities: Homes for All
published in 2005 set out the target to
replace conventional allocation schemes
with CBL by 2010. More recently,
government has set out to extend
CBL coverage by including low-cost
home ownership and properties to rent
from private landlords as well as
encouraging CBL on regional and / or
sub-regional basis.
i
6. 6
iTenant Services Authority standards
framework
From 1 April 2010, ‘registered providers’ of
social housing, including local authorities,
will come under the new regulatory
framework set by the Tenant Services
Authority (TSA).The TSA advocates a
co-regulatory approach, which is based on
a balance between direct regulation and
self-regulation by landlords. Registered
providers are required to comply with a
number of nationally set standards
(referred to as national standards) and
these will be complemented by local
standards which reflect local priorities
following consultation with tenants.Two
of the proposed national standards are of
particular relevance to the topic area of
this practice brief, namely:
the tenancy standard (which covers
allocations)
• registered providers must let their
homes in a fair, transparent and efficient
way.They must take into account the
housing needs and aspirations of
tenants and potential tenants and
should demonstrate how their
allocation processes:
• make the best use of
available housing
• contribute to local authorities’
strategic housing function and
sustainable communities.
the tenant involvement and empowerment
standard
• registered providers will offer all tenants
opportunities to be involved in the
management of their housing.This
must include opportunities to:
• influence housing-related policies
and how housing-related services
are delivered
• be involved in scrutinising
performance in delivering
housing-related services.
7. Community engagement
It is important to communicate the way social
housing is allocated with the wider community,
both to offer clarity and to counter any
misconceptions and misinformation. For
instance, a poll conducted by Ipsos Mori in
20094
showed that nearly a third of
respondents don’t think social housing is
allocated fairly, compared to around a quarter
who thought it was, whilst nearly 45 per cent
had either no or only very little knowledge of
the way the allocation system works in their
area. Communication includes making
available information on lettings outcomes
and the wider background / context which
influences allocations decisions. By providing
information in a transparent way, people are
more likely to view allocation policies as fair or
will take at least a more considered
perspective. Similarly, when it comes to
reviewing the allocation scheme (including
alterations to certain aspects of the scheme /
policy), local authorities are encouraged to
consult as wide as possible.
Partnership working with registered
providers of social housing
The guidance is explicit about the importance
of putting in place robust and effective
partnership arrangements between local
authorities and other registered providers of
social housing as part of their housing
function.Whilst this will be important for all
local authorities, it will be even more so for
those who have transferred their stock.
Partnership working with registered providers
covers a number of areas and these are set out
in the guidance as follows:
• joint development of allocation priorities
• consultation on changes to the allocation
scheme at an early stage
• establishment of a nomination agreement
which is subject to reviews at regular
intervals
• development of common approaches to
allocating social housing, such as the
adoption of a common housing register and
allocation policies.
4
CLG, 2009, Attitudes to housing: Findings from Ipsos MORI Public Affairs Monitor Omnibus Survey (England), London, CLG
8. The statutory guidance sets out government’s
expectations with regard to the outcomes
of local authorities’ allocation schemes.
On the one hand there are clear statutory
requirements which an allocation scheme must
take into account, such as giving priority to
those with the greatest housing need and
having regard to its equality impact.
On the other hand, there are a number of
‘aspirational’ outcomes which government
wants local authorities’ allocation schemes
to take into account.
The allocation scheme
Section 167 of the Housing Act 1996 requires
local housing authorities to have a scheme in
place (known as the allocation scheme) for
determining priorities and procedures to be
followed in allocating housing.
The procedure must include all aspects of the
allocation process and should set out the
persons or job titles of people by whom
decisions are to be taken.The scheme must
include a statement of the authority's policy on
allocating accommodation and state whether
applicants are offered:
• a choice of housing accommodation or
• the opportunity to express preferences
about the housing accommodation to be
allocated to them.
A summary of the allocation scheme must
be published.
However there is some discretion for local
authorities, as exemplified in R (on the
application of Boolen) v Barking and
Dagenham London Borough Council [2009]
EWHC 2196. Here, the court held that the
published scheme did not have to contain
every detail as to how a discretion, which
formed a part of such a scheme, was to be
exercised. However, in order to counter / dispel
myth and in the light of general transparency,
local authorities are encouraged to be explicit
and open about all aspects of the allocation
scheme, a point the statutory guidance
explicitly stresses.
Reasonable preference categories
The statutory guidance reiterates the notion
that social housing is principally aimed at
those in greatest housing need.Therefore,
priority for accommodation must be given to
those who fall within the statutory reasonable
preference categories, namely:
• people who are homeless (within the
meaning of Part 7 of the Housing Act 1996)
• people who are owed a duty by a local
housing authority under s.190(2), 193(2), or
195(2) of the Housing Act 1996 (or under s.
65(2) or 68(2) of the Housing Act 1985) or
who are occupying accommodation secured
by any such authority under s. 192(3)
• people occupying insanitary or overcrowded
housing, or otherwise living in
unsatisfactory housing conditions
• people who need to move on medical or
welfare grounds
Aims and objectives of an allocation scheme8
9. • people who need to move to a particular
locality in the district of the authority, where
failure to meet that need would cause
hardship (to themselves or to others) due to
for instance:
• a need to access medical treatment
• to give or receive care
• to take up an employment or training
opportunity.
Additional preference categories
Additional priority may be given to particular
people within the reasonable preference
categories who have urgent housing needs.5
The 2002 statutory allocation guidance
suggests that additional preference could be
given to:
• those owed a homelessness duty as a result
of violence or threats of violence likely to be
carried out and as a result urgent rehousing
is required.This could include:
• victims of domestic violence / racial
harassment involving violence or threats
of violence
• same sex couples who are victims of
harassment involving violence or threats
of violence
• witnesses of crime who would be at risk
of intimidation leading to violence or
threats of violence
• those who need to move because of
urgent medical reasons.
Critically, any scheme should enable the
identification of those with greatest housing
need and determine how individuals will be
prioritised for housing.The allocation scheme
should provide a clear description of how
bands for reasonable preference, and priority
within bands, are determined and assessed.All
schemes for determining priorities for lettings
should be carefully designed, to reflect the
range of needs that exist locally, and take
account of reasonable preference categories as
determined in law.Allocation schemes should
recognise the need to ensure fair and equal
access to social rented housing.
Equality and diversity
Local authorities need to ensure that their
allocation schemes are compliant with the full
range of duties under the equality legislation,
such as elimination of unlawful discrimination,
the promotion of equality of opportunity and
good relations.Thus, any alterations to the
allocation scheme and policies should be
subject to an equality impact assessment.
In order to help housing organisations to
understand how equality, diversity, good
relations and community cohesion impact on
their everyday work, CIH has produced a
practice brief Equality, Diversity and Good
Relations in Housing to support housing
organisations in embedding the principles of
equality and diversity throughout their work.
www.cih.org/publications/pub801.htm
5
ODPM, 2002, Allocation of Accommodation: Code of guidance for local housing authorities, London, ODPM
10. Allocation schemes and procedures should
consider the following to ensure against
possible discriminatory effects:
arules for awarding priority should be
consistently applied to families separated
pending rehousing
alinking priority to retirement age can be
different for men and women
agiving a blanket priority to existing tenant
transfers, over housing register cases, may
discriminate against black and minority
ethnic people if under-represented among
existing tenants
asingle parent families should be treated the
same as two parent families
acouples in civil partnerships should be
treated the same as married couples
ahomeless households should not be given
less choice compared to other access
channels. BME groups and single parent
households are often over-represented
among homeless households
acan differences in the way applications
from disabled people are handled from
those from able-bodied people really
be justified?
aare grounds for the use of discretion clearly
defined, and are all staff members who
make discretionary lettings suitable trained?
ado processes lead to concentrations of
particular groups in areas?
ahave lettings processes been ‘equality
proofed’.Are sufficient monitoring data
collected and evaluated to alter priority
systems to correct any imbalances?
ais sufficient care taken to ensure that
communication of the allocation scheme
is adequate for people who:
• are newcomers to an area and not
familiar with local arrangements
• may experience learning difficulties
or sensory impairment
• do not have English as their first
language.
Adapted from CIH practice online
www.cih.org/practice/online/
Practice checklist:
ensuring fair and equal access
to social rented housing
a
10
Equality Bill for Great Britain
(June 2009)
The Equality Bill for Great Britain which
brings together all the strands of diversity
within one piece of legislation is due to
become law in April 2010 (subject to
Parliamentary approval) and will bring
with it new and challenging expectations
on housing organisations across England,
Wales and Scotland. It will influence a
whole range of areas that are key to
housing, including regulation and
inspection, monitoring and review and
engagement with local communities. It sets
out to combine the nine major pieces of
legislation relating to equality, and around
100 statutory instruments, into a single act
with the aim of making the law more
accessible and easier to understand.
http://www.equalities.gov.uk/equality_bill.aspx
i
11. Additional outcomes which allocation
schemes should achieve
Under the new statutory guidance, local
authorities are encouraged to develop their
allocation schemes with a more strategic
perspective in order to support broader public
policy outcomes.
Promoting greater choice and wider options
for prospective and existing tenants
Giving applicants more choice over where they
would like to live is believed to help build more
stable neighbourhoods.This is because tenants
tend to be more satisfied with their
accommodation where they have been able to
exercise choice and thus will move less
frequently. Government is keen to see choice in
the allocation system becoming the norm and
has set a target to replace conventional
schemes with CBL. In order to exercise choice,
individuals need the right information and
advice about all the available housing options.
The importance of broadening housing advice
so that households are more aware of their
options, seek advice when they are not in
serious need and plan ahead for housing goals
has been highlighted in the CIH report
Modernising Housing Advice.
www.cih.org/policy/ModernisingHousing
Advice.pdf
Creating more mixed and sustainable
communities
In order to support sustainable communities,
allocation schemes need to be aligned with
other strategic drivers, such as those
articulated in the sustainable communities /
housing and homelessness strategy.This is an
essential part of local authorities’ strategic
housing role. In practical terms, local lettings
policies are particularly useful here, as they can
be used to address particular issues (for more
details on their usage see page 23).
Providing for greater mobility
Making provisions in allocation schemes to
support moves within the social housing sector
can play an important role in promoting
greater social and economic mobility.
Subregional CBL schemes can be a way of
achieving this. But even in the absence of such
schemes, cross-boundary moves between local
authorities can be facilitated through local
lettings policies, which for instance could allow
for a certain number of properties to be
allocated to key workers and others to fill a
specific skills gap within an area.
Utilising the existing housing stock to its
full potential
Given that supply of social housing in most
areas outstrips supply, making most effective
use of the existing stock is a clear priority for
many local authorities.Allocation schemes can
for instance make special provisions for those
freeing up under-occupied properties (for more
information on dealing with under-occupation
see page 20) or those with adaptations where
they are no longer needed by the occupants.
12. Having allocation schemes which are fair and
considered to be fair
The perceived ‘unfairness’ of the allocations
system often stems from insufficient
knowledge, based on anecdotal rather than
first-hand information.The ways allocation
policies are phrased also doesn’t help in this
respect.The system used to prioritise
applicants within the allocation scheme
(particularly points-based ones) can seem
impenetrable to new applicants and potentially
reinforce any misconceptions held.Thus,
finding ways to effectively communicate the
workings of an allocation scheme is of crucial
importance, as is seeking views from the wider
community prior to making changes to a
scheme.These points are discussed at great
length in the latter part of this practice brief
(page 27 onwards).
Supporting people in or seeking work
Around one-third of workless households live
in the social sector.6
This is perhaps not
surprising, since the allocation system
prioritises those in greatest need which tends
to be people who are in some way vulnerable,
disadvantaged and / or disconnected from the
labour market.This can undermine
neighbourhood stability and the long-term
sustainability of whole communities, the very
outcomes government is expecting local
authorities to prevent in part through their
allocation schemes as outlined earlier.Thus,
provisions could be made within allocation
schemes to give some priority to those in or
actively seeking work and / or training.There is
also much that housing organisations can do
to tackle worklessness (CIH has published a
worklessness toolkit which provides many
examples and pointers as to the most effective
ways of addressing this issue).
CIH (2008) Tackling worklessness:A toolkit
www.cih.org/publications/pub130.htm
12
6
Cope H, 2008, Tackling worklessness:A toolkit, Coventry, CIH
13. Practice
example
Dudley Metropolitan Borough Council
makes particular use of local flexibilities to
assist disabled people.Their well-established
Housing Occupational Therapy Team make the
best use of adapted properties, promote other
housing options for people whose homes
would be unsuitable or too expensive to adapt,
and ensure that disabled people have the
same opportunities to exercise choice in their
housing as other residents.The allocation
scheme provides for disabled people to bid
under CBL not only for adapted properties but
also for properties that are identified in adverts
as suitable for adaptation. Individual needs are
assessed, and advice given as to what types of
property to bid for.The allocation is then made
by the OT team to achieve the most
appropriate match, and make the best use of
the property. It includes the flexibility to
allocate properties of a size or type the
household may not normally be eligible for,
providing any competing needs have been
considered. Over the course of 2008,
almost 100 households including someone
with a physical disability have been able to
move to a property of their choice that meets
their needs.Around half were properties that
already had adaptations, with the remainder
being standard properties assessed as capable
of adaptation at a reasonable cost.
Home Connections is a not-for-profit
company owned by local authorities and
housing associations. Home Connections
provides CBL directly to a third of London
boroughs, Birmingham City Council and
15 housing associations.
It has been commissioned by the Greater
London Authority to run an innovative project
to develop links between CBL and employment
opportunities or services.The Housing
Employment Connections project (HECs) is
supported by six London boroughs, Peabody
Trust and specialist employment providers
across London.The project will seek to
introduce and integrate employment
information and services to existing and
potential social tenants when they bid (apply)
for properties in London.
The practical developments achieved in this
project may be incorporated into other existing
CBL schemes and any future pan-London
choice-based lettings and mobility scheme.
When an applicant applies for a property they
will complete a questionnaire about their
employment needs. HECs will act as a gateway
submitting their details to Information Advice
and Guidance organisations and learning and
skills providers (with their permission and
within the restrictions of the Data Protection
Act).These agencies will then work with
the individual and / or signpost them to
other agencies.
Practice
example
14. Local authorities need to consider how they
frame their allocation schemes so as to take
account of both what is required by law and
the government's wider policy drivers.
Local decision-making in allocating
housing – the implications of Ahmad v.
London Borough of Newham
As held in the House of Lords judgement
Ahmad v Newham LBC, local authorities have
discretion in terms of how they prioritise
between those in the reasonable preference
categories, as long as the allocation policy
complies with legal requirements and
is rational.
Newham’s allocation scheme uses two
mechanisms of offering properties, reflecting
two types of need, namely a CBL scheme
(through which 75 per cent of properties are
allocated), and direct offers (those with
exceptionally pressing housing need) for the
remaining 25 per cent.Those subject to a
direct offer have priority within Newham’s
allocation scheme, since only properties which
are not wanted by direct offer applicants are
brought into the CBL pool.
Applicants subject to CBL fall into one of the
following categories:
• priority homeseekers, i.e. those whose
households contain at least one person who
is in a priority need category
• tenants seeking a transfer, i.e. existing
Newham tenants who are applying for
a transfer but do not fall into the
previous category
• homeseekers, i.e. those who do not fall into
either of the above categories.
No more than 5 per cent of the CBL properties
are reserved for tenants seeking a transfer,
with the remainder going to priority
homeseeker applicants. Properties attracting
more than one bid are allocated according to
the applicant’s length of time as a priority
homeseeker.
Mr Ahmad argued that regard should be given
to ‘cumulative preference’, i.e. affording
priority to applicants who fall into more than
one reasonable preference category, when
prioritising between applicants.
In its judgment, the House of Lords held that:
• waiting time is sufficient to prioritise
between applicants within the reasonable
preference categories
• there is no requirement to take account
of cumulative preference
• setting aside a small percentage of lets to
existing tenants wanting to move but who
don’t fall into any of the reasonable
preference categories is not unlawful.
Framing the allocation scheme14
15. Removal of the requirement to provide
for cumulative preference
The removal of the requirement to provide for
cumulative preference should however not be
taken as a requirement for local authorities to
abolish points-based allocation systems where
these are regarded as being fair and workable.
Rather, it will allow for the implementation of
more simple and more transparent systems of
prioritising between applicants such as
banding schemes.
Prior to Ahmad, local authorities were required
to pay attention to cumulative preference
within allocation schemes.This required local
authorities to:
• give greater priority to applicants who
met more than one category of reasonable
preference
• distinguish between degrees of housing
need within reasonable preference
categories through a detailed prioritisation
of an applicant based on assessed
housing need.
However, local authorities are no longer
required to distinguish between degrees of
housing need, or to provide applicants who fall
within more than one reasonable preference
category greater priority. Instead, local
authorities are now only required to make a
distinction between applicants who meet the
requirements of the reasonable preference
categories and those who do not.
In practice this means local authorities can
determine between applicants in the
reasonable preference categories using for
instance waiting time alone.
Advantages include:
• simpler system to operate
• clearer and more transparent system of
prioritisation for applicants to understand
• can be easily monitored
• recognised by applicants as being a fairer
means of distinguishing between otherwise
similar applicants.
The removal of the requirement to provide
cumulative preference however brings with it
the question of how a local authority
allocation scheme can determine how an
applicant can be prioritised where a number of
applicants have a similar level of need, or are
assessed to be within the same reasonable
preference categories.
Banding schemes
Banding schemes group together applicants
into a number of broad bands which reflect
both housing need and the priorities set out
within the local authority’s allocation scheme,
including urgent / non-urgent or no
housing need.
Each local authority is free to prioritise how it
bands individuals together, and how it
prioritises within these bands as long as the
scheme meets the legal requirements and has
a clear rationale. Furthermore, the bands must
reflect the principles set within the local
16. authority’s allocation schemes for determining
priorities.The more complex and numerous the
principles are that underpin the allocation
scheme, the more complex the banding
scheme will need to be in order to reflect
these principles.
Hence, local authorities are encouraged to
operate simple banding schemes as they
would offer a number of advantages:
• quick and easy to administer
• clear and transparent
• make it easier for local authorities to work
together around the development of
CBL schemes.
Conversely, more complex schemes can:
• become expensive and time-consuming
to operate
• require a value judgement to be made,
making the process less transparent and
open to argument
• require more frequent monitoring and
review of applicants’ details to ensure they
are correctly banded. For instance, changes
to individual circumstances over time
mean applicants are more likely to move
between different bands if banding has a
narrow criteria.
It is important to note that the guidance does
not require local authorities to replace points
with a banding scheme.There may be good
reasons why local authorities want to continue
using points-based systems. Existing and
prospective tenants may not necessarily
perceive them as lacking in transparency but
may actually value the fact that they allow for
more factors to be taken into account when
making decisions. Regardless of which system
is used, local authorities should ensure that it
is easy to understand and has the support of
both the community and relevant stakeholders.
Determining priorities between
applicants with similar needs
Section 167 (2A) of the Housing Act 1996
allows local authority schemes to take into
account other factors for the purposes of
determining the relative priority of applicants
with similar housing need or who are assessed
to be in the same reasonable preference
category. Used effectively this provides
authorities with a valuable opportunity to use
factors that take account of and reflect local
circumstances, are driven by the needs and
aspirations of local people and support wider
strategic drivers to shape and deliver
sustainable communities.
Examples given in the legislation include:
• the financial resources available to a person
to meet his / her housing costs
• the behaviour of an applicant which might
affect his / her suitability as a tenant
• any local connection (within the meaning
of section 199 of the Housing Act 1996)
which exists between a person and the
authority's district.
16
17. These are not exclusive, and local authorities
may want to base their decisions on other
factors (see page 18 for more information).
Any priority category adopted should reflect
local priorities, be developed in consultation
with the community and other stakeholders.
Local connection
Home-Options (Derbyshire) is a group
of four local authorities and their respective
RSL’s / ALMO who have formed a common
allocations policy and choice-based
lettings system.
Local residents, elected members, board
members and officers expressed views that the
scheme should assist those in housing need
who have a ‘connection’ to their own local
authority area in the first instance. It was
recognised that connection extends beyond
those that currently live in the area and should
consider those that have lived previously in the
area but have had to move away, those who
need to move to give or receive support, those
who work in the area and those accepted
as homeless.
Applicants with no local connection are
eligible to be awarded housing priority and
placed in the appropriate band.
Local connection and new-build
properties in a rural location
Derbyshire Dales DC helps to provide new
affordable homes across two local planning
authority areas which comprise the Peak
District National Park Authority and its own
local plan area outside the national park.
In general terms, any affordable housing
development has to meet the local needs of
the village or parish the homes are built in.
Between 2002 and 2011 Derbyshire Dales
DC working with housing association partners,
is on course to deliver 658 new affordable
homes let to households with a proven
local connection.
Village local lettings in the
Derbyshire Dales
The village local lettings policy will apply
within the Derbyshire Dales area of the Peak
District National Park and to other villages
within the Derbyshire Dales with a population
of less than 3,000. Applicants resident for six
months or more in a Parish with a population
of less than 3,000 will be considered first
within the band.
Practice
example
18. Waiting time
Gateshead Council’s allocation policy
reflects both the requirement to address
housing need and the desire to assist local
residents who have accumulated waiting time
on the housing register. It recognises the
importance of creating sustainable
communities within a local authority made
up of both urban and rural areas.
The policy is flexible enough to utilise local
lettings policies to address issues threatening
sustainability.Additionally, a proportion of
properties are advertised weekly to applicants
in accordance with waiting time.This
proportion is revised regularly.As housing
need within the borough declines this
proportion is increased, thus maximising the
opportunities afforded to the general
community who do not demonstrate high
level need.
Determining local priorities alongside
reasonable preference
Whilst overall, priority for allocating housing
must be given to those in the reasonable
preference categories, the guidance
encourages local authorities to give some
priority to applicants falling outside the
reasonable preference categories, reflecting
particularly local needs and circumstances as
long as these are not dominating allocation
schemes. By doing so, the allocation scheme is
put on a much more strategic footing, since it
has the potential to support a number of
specific objectives and outcomes at the local
level, including:
• strengthening community cohesion,
particularly in areas where tensions are
known to be associated with the way
housing is allocated
• encouraging greater social and economic
mobility of social housing tenants
• broadening choice and widening options for
prospective tenants
• ensuring the most efficient use of the
housing stock
• responding to employment / skills needs
specific to the area
• creating more mixed communities and
addressing the long-term sustainability
of neighbourhoods
18
Practice
example
19. • developing and maintaining balanced and
stable communities
• attracting a broader customer base
• addressing specific issues at the
neighbourhood level, such as anti-social
behaviour and high turnover through
prioritising use of local lettings policies
• countering misconceptions as to the
apparent unfairness of the allocation
process.
The table on page 21 lists some examples of
factors other than those set out in the
reasonable preference categories that local
authorities might want to consider giving
priority to as a response to local circumstances
and in support of specific policy priorities.
Local flexibilities – establishing
an evidence base
Establishing local priorities outside the
statutory reasonable preference categories
requires robust evidence of need. Rather than
starting from scratch, local authorities will
already hold and have access to a wealth of
existing information and data to assist with
this, including:
• analysis of current housing register
• data on lettings over time
• local lettings plans
• census and / or neighbourhood statistics
• housing market assessment
• economic impact assessment
• information and data collated as
part of strategy documents, such as the
sustainable communities strategy
and local area agreements
• data from previous community or
neighbourhood profiling exercises
• views gathered as part of community
engagement exercises / consultations
• information gathered on tenants and
residents via housing applications,
satisfaction surveys, complaints, etc.
Working with other council departments
and stakeholders, such as local businesses and
employers to identify particular skills gaps in
the area, will be able to assist with
establishing an evidence base.Therefore the
importance of joint working cannot be
overstated. Non-stock holding authorities in
20. 20
particular may want to work with local housing
providers to encourage them to streamline and
co-ordinate processes to capture information
on their customers in such a way as to provide
useful ‘insight’ to inform the development of
local priorities.7
Addressing under-occupation
Mechanisms should be provided to encourage
individual households to free up stock by
releasing under-occupied properties for letting
to larger households.
For example, the allocation scheme could be
framed so as to allow for priority to be given
to households who release a property two
bedrooms larger than they need and a lesser
priority given to households who will release a
property one bedroom larger.
Advantages of moving to a smaller property,
such as lower rent levels / council tax and
cheaper fuel and other running costs as well
as details of the under-occupation scheme
should be publicised through a variety of
means (see checklist on distributing
information on page 35).
Whilst addressing under-occupation is an
important part of effective stock management,
it has to be recognised that it is a potentially
sensitive issue. For many older tenants,
downsizing may mean moving to a different
area, severing social ties and leaving personal
memories behind. On a more practical level,
personal belongings accrued over many years
need to be accommodated as they may hold
sentimental value.
Under-occupation incentives can take the
form of:
• assistance with, or payment of,
removal costs
• assistance with other costs such as
redirection of mail and reconnection charges
• help and support with the actual removal,
particularly in the case of older tenants
• providing for external storage space
• cash payments
• help with redecorating the property
into which the tenant is moving or a
decoration allowance
• if extensive refurbishment is being
carried out, allowing tenant input into
the design / finish of the home into which
they are moving.
7
For more information on this area see Gray A Kent-Smith J and Sinn C, 2008, Customer Insight: Knowing Your Customers good practice briefing,
Coventry, CIH
21. Priority factors Rationale
key workers
responding to employment needs
in the local area
economically active
addressing a known-need for housing local
employees
rebalancing communities
being in training or education
encouraging tenants' aspirations
contributing to local economic growth
positive community criteria, i.e. applicants
making a contribution to a particular area
in an economic or voluntary capacity
encouraging involvement in the community
supporting community enterprises
good behaviour
supporting long-term sustainability
of neighbourhoods
rewarding positive behaviour
encouraging downsizing, including two for one
transfers (i.e. families occupying two homes and
wanting to set up home together)
more efficient use of existing stock
applicants with dependent children under the
age of 10, living in accommodation above the
first floor
providing adequate family accommodation
providing children with a safe play
environment, i.e. garden
applicants wanting to be nearer to schools
and / or educational institutions
encouraging tenants' aspirations
contributing to the long-term
economic growth of the local area
people moving on from supported
accommodation or adapted properties
which are no longer needed
more efficient use of existing stock
people leaving hospital / care
providing choice and supporting
re-integration into community
offenders leaving prison supporting re-integration into community
applicants who have been offered
full-time employment in an area but
are unable to commute
contributing to local economic growth
supporting long-term sustainability of
neighbourhoods
rebalancing communities
22. Stoke-on-Trent’s allocation scheme makes
provision for all existing tenants who are
willing to move in order to allow the local
authority to take advantage of a particular
type of property which is scarce and in high
demand (such as a larger or adapted
property) by awarding them priority within
the banding scheme.
A 'Transfer Incentive Scheme' is available to
existing tenants in 4, 5 and 6 bedroom
properties who are under-occupying by at least
two bedrooms.Tenants make an application to
be considered under this scheme and they are
accepted subject to qualifying criteria (i.e.
secure tenancy, no tenancy breaches or court
action, etc.). Once a tenant has been accepted
onto this scheme they are given enhanced
priority under the allocation scheme to enable
them to be able to move more quickly. In
addition successful applicants are given a
financial incentive of £250 per bedroom
released plus a £300 disturbance payment to
assist with removal costs.
22
Practice
example
23. Local lettings policies are an important tool in
response to specific local circumstances and
are one of the main vehicles for local
authorities and their partners to use flexibilities
within the allocation process. Local lettings
must not dominate the scheme at the expense
of the statutory reasonable preference
categories and if used, their nature and scope
must be published alongside the allocation
scheme.
Local lettings policies may be used to address
a wide range of issues, including particular
housing management and wider public
policy concerns.
Examples include:
• creating balanced and mixed communities
• protecting existing stable communities
• meeting housing need in rural areas by
setting aside a proportion of lets to
applicants with a local connection via
section 106 agreements
• restricting where persons who have
committed serious crimes can be rehoused
(e.g. sex offender will not be rehoused near
schools, playgrounds or other places where
children and young people congregate)
• reducing void rates and tenancy turnovers
• improving community stability and cohesion
• tackling low-demand areas and
difficult-to-let estates
• reducing incidences of anti-social behaviour
• preventing future problems occurring on
newly developed estates or in relation to
recently modernised properties.
When developing local lettings policies, it is
important that any equalities implications are
carefully considered. For instance, giving extra
priority to local people may exclude newly
arrived migrants. It is therefore important that
proposed policies are modelled before they are
introduced to identify outcomes. If the
outcomes are acceptable and it is decided to
go ahead with introducing a scheme, robust
and regular monitoring of outcomes is needed.
Local lettings policies are usually put in place
for a limited time period and can differ from
mainstream lettings policies in various ways,
such as:
• giving priority to people who want to live in
the area
• allocating properties to applicants in non-
priority groups
• disregarding household type and / or
property type matching rules, for instance
allowing under-occupation to promote
longer-term tenancies, reduce child density
and account for future family growth (which
reduce the need for transfers).8
Use of local lettings policies
8
For more information see p.80 in Perry J and Blackaby B, 2007, Community Cohesion and Housing:A Good Practice Guide, Coventry, CIH
24. Proposals for local lettings policies should set
out the following:
• a clear definition of the objective(s) to be
achieved, backed up by clear evidence
• a method which is likely to achieve the
objective(s)
• a potential (equality) impact assessment
• how the scheme will be monitored and who
will be involved
• mechanisms of reporting and reviewing
the scheme
• how the views of local communities have
shaped the scheme
• a clear exit strategy.
Local lettings toolkit
Stoke-on-Trent City Council developed
a local lettings toolkit which aids the
development of local lettings policies,
following a five step procedure.
1. Initial assessment
• define the geographical area
• think about what you and stakeholders
perceive as the problem within the area
• consider your objectives – how would things
change as a result of allocating properties in
a different way
• short-term fix? Longer-term intervention?
• who are your stakeholders?
2. Identifying the critical issues
This includes the gathering of key data in
order to identify the critical issues within the
proposed area, including demand and mobility
and socio-economic background within
the area.
3. Defining the scope and objective(s) of the
proposed policy
4. Getting approval on the details of the
proposed policy
5.Approval report
Writing up a report to seek approval for
introducing the policy, based on the
information obtained and agreements on how
to introduce, manage and monitor the scheme
for a defined period.
24
Practice
example
25. Sensitive lettings
In some circumstances it may be beneficial to
adopt a ‘sensitive lettings’ approach as part of
a local lettings schemes.This is generally used
to address / manage specific issues, such as
the make up of a particular block of flats, i.e.
having the flexibility to by-pass people at the
top of the housing register so as to avoid
lifestyle clashes by not housing certain groups
under one roof. It is important that sensitive
lettings are objective and clearly evidence-
based. It is therefore important that the
rationale for using such an approach is clearly
communicated to both housing applicants and
the wider community, as with all other aspects
of the allocation scheme.
aensure that any policies are part of wider
strategic drivers, such as the local
authority’s housing and sustainable
communities strategy, and are not just
used in a purely ad-hoc / reactive way
ahave a robust evidence base in place to
inform the development of a policy
ause community profiling and similar
techniques to identify where policies may
be most beneficial
amonitor the outcomes on an ongoing basis
and undertake regular impact assessments
of the scheme(s)
ainvolve tenants and residents when
developing proposals and
reviewing policies
aensure that information about any policies
and the rationale behind them is published
as part of the allocation scheme or
alongside it, including the length of time
that the initiative will be in place, the
geographical area(s) the scheme applies
to, what monitoring there will be, the
frequency of reviews taking place, and the
proposed exit strategy.
Practice checklist:
local lettings policiesa
26. Lettings plans
Making the allocation scheme more responsive
to local need requires a robust evidence base.
Developing an annual lettings or rehousing
plan helps in establishing the proportion of
stock which can be set aside for non-priority /
additional preference groups and others (e.g.
key workers or those who fill a certain skills /
employment gap in the locality). Local lettings
plans are an important strategic tool which
enable lettings practices to be linked to wider
strategic issues.As stated in the guidance,
targets and quotas should not be too rigid
in order to take account of changing
circumstances.Thus, it is important to keep the
plan under review throughout the year so that
amendments can be made if a particular quota
or target cannot be met or local needs have
changed.
A lettings plan involves estimating the supply
of properties likely to become available over
the next year through, for example:
• local authority relets
• mobility moves out of an area
• relets through nominations and / or referrals
to housing associations
• new build for rent and low-cost home
ownership
• any leasing schemes managed by
registered providers.
The demand for properties is then estimated,
based on past trends from the various access
routes, such as:
• priority homeless
• people needing to move because their
homes are being improved
(decant schemes)
• temporary accommodation in permanent
stock, e.g. for homeless households,
asylum seekers
• lettings for move-on accommodation
• transfers / mobility / downsizing moves
into the area
• lettings from the housing register
• lettings due to overcrowding
• others, such as key workers, those in
employment / training and applicants who
make a positive contribution to the
community (e.g in a volunteering capacity).
The demand from each of these groups can be
calculated as a proportion of the total
demand. Proportions for each group represent
the target proportions of lettings to be made
during the coming year which are then
converted to a number of lettings based on the
supply figures. Lettings plans for local areas
can be calculated by applying the target
proportion of lettings at the district level to the
supply at the local level.
26
27. This section sets out the broad principles of
effective ways of communicating the allocation
scheme, including the mechanisms through
which it is delivered (e.g. CBL).
Social housing is a scarce resource, with
demand clearly outstripping supply.This is
reflected in the growing number of people on
the housing register, which has reached almost
1.76 million households.Although not a
measure of actual need, housing register
figures provide some indication as to the
demand for affordable housing within an area.
This means that issues of perceived fairness,
transparency and equality are particularly
important when it comes to distributing such a
scarce resource. Given the complexity of any
allocations system it is perhaps not surprising
that there are some common misconceptions
and misinformation about who can access
affordable housing. Effective communication is
therefore key in order to raise awareness and
understanding of current allocation policy and
practice. Left unaddressed, misconceptions
about the way housing is allocated can all too
easily become the dominant view, which will
be difficult to alter.
• a study by CLG9
found that the majority of
people perceive the way social housing is
allocated as unfair
• the same poll showed that most people
simply don’t or at best only know very little
about how the allocation system works
• research by the Equality and Human Rights
Commission10
exposed widely-held fears
that the allocations process puts white
British families at a disadvantage.
It is therefore important that good quality and
accessible information about how allocation
schemes and systems work is provided to both
housing applicants and the wider community.
Effective communication will help to:
• raise awareness among local people about
what constitutes affordable housing,
who is eligible and the wider constraints
under which the local authority and its
partners operate
• reduce the opportunities for the circulation
of misunderstandings and myths about the
ways in which social housing is allocated
• elicit positive response and support from
local people for the adopted allocation
scheme and a sense that it is seen as fair
• increase the public's understanding of the
contribution which good quality, affordable
housing can make to wider public policy
concerns, such as the creation of socially
cohesive / mixed income communities,
educational performance, health
improvements and economic opportunities
Communicating the allocation scheme
9
CLG, 2009, Attitudes to Housing: Findings from the Ipsos MORI Public Affairs Monitor Omnibus Survey (England), London, CLG
10
EHRC, 2009, Social housing allocation and immigrant communities, London, EHRC
28. • widen access to social housing, as it will
encourage individuals to apply who
previously might not have been aware that
they would be eligible. Local authorities
need to be mindful how they will manage
the increase in demand, which is likely to
follow from this
• increase awareness of the full range of
housing options available.
Whilst transparency is important, it has to be
recognised that information alone will not
dispel myths and misperceptions about
allocation of social housing.As the statutory
guidance recognises, deeply felt opinions do
not always change in response to the
presentation of facts. In areas where tensions
are associated with housing allocations,
communication of allocations policies and
outcomes will need to be part of a wider
community cohesion strategy.
28
29. Levels of interest about how the allocations
system works will vary amongst individuals.
For instance, home owners might only have
a passing interest, those wishing to access
housing on the other hand will have quite
different information requirements (e.g. how
to apply for housing, likely waiting times and
chances of being re-housed in certain areas,
etc.). It would not be feasible or practical to
provide bespoke communications material
covering all the various scenarios. However,
being able to identify broad categories of
interest as well as the groups to communicate
with, will help with finding the right
communications vehicles and channels.
Knowing your community is fundamental as
local specific circumstances (e.g. a large
migrant or older person population) will have
an impact on the communications /
engagement process. It also has to be
recognised that views and perceptions can
differ on a very local basis on, for example the
importance of local connection.
Communication – who and what?
Wider public, including existing tenants
and residents
Here, a local authority is concerned with
conveying general information of how the
allocation and social housing system works.
Giving people the facts, figures, contextual and
background information in plain and simple
language will both increase levels of
understanding / knowledge and enable them
to draw their own conclusions, which hopefully
rectify any misconceptions previously held.
Provide general information of how the
allocations and social housing system works
in plain and simple language. Placing articles
in council-produced newspapers, newsletters
(or similar communication material) and
utilising the local media is a cost-effective
way to reach a large audience.
In addition, further detailed information can
be used to supplement the above.This could
include a six-monthly or annual digest, which
could cover things like:
• short introduction to social
(affordable) housing
• stock profile information
• information on current levels of supply and
demand, including the hotspots areas
• overview of the allocations process
• frequency of properties becoming available,
broken down by type, size, location
and accessibility
• breakdown of housing register figures by
need, age, ethnicity, etc.
• likely waiting times for lets
• listing the area(s) / neighbourhood(s)
where applicants are more likely to get
their first choice
• information on local lettings policies.
Targeted groups – one size doesn’t fit all
30. Engagement with the local community
Redditch Borough Council secured funding
from the CLG Trailblazer initiative to promote
the Enhanced Housing Options Service within
the local community.The aim was to
encourage more individuals to contact the
Housing Options service for help or advice
regarding accessing and sustaining housing,
employment or education. It was further hoped
that this would encourage individuals
experiencing problems due to redundancy to
contact the department earlier to increase the
likelihood of preventing homelessness.
In order to increase the capacity to deliver, the
housing options team recruited a number of
volunteers from the local community.
All volunteers received training via workshops
facilitated by the housing options team on
housing options available in the area,
temporary accommodation, housing benefit
and the work of partner organisations such as
local colleges, the citizens advice bureau,
Jobcentre Plus and the local credit union.
The contribution from these volunteers proved
valuable by increasing the number of
customers reached at events.A survey of
customers showed that some felt more
comfortable talking to members of their own
community than employees of the council.
Since the introduction of Housing Options
events there has been a rise in the number of
customers approaching the Housing Options
service for assistance and the number
of successful homelessness preventions
has increased.
Housing applicants and potential applicants
Those wishing to register for social housing
should have access to all the relevant
information, including any relevant support
where necessary. Information should be
available in both printed and electronic
formats.
Although the law only requires a summary of
the allocation scheme to be published, in many
instances local authorities make the whole
document available on their websites (in any
case, the document has to be made available
on request).The summary should be
complemented by easy-to-use procedural
step-by-step guidance (for examples of
CBL guidance see www.compasscbl.org.uk
and https://homechoice.northampton.gov.uk).
Communities are diverse; therefore it is
important to ensure that a range of
communications mechanisms are in place.
Staff
All staff need to have a basic knowledge of how
the allocations system works to ensure that
clear and consistent messages can be given out.
This is of particular importance in the case of
frontline staff and those who will have more
‘informal’ contact with people, such as repairs
and maintenance staff and neighbourhood
wardens.Those who work directly in allocations
need to have regular training and updates on
30
Practice
example
31. latest policy and legislative developments.
Information on who is eligible for housing can
be complex, so accessible and up-to-date
information backed by training is key. CIH and
the Housing Association’s Charitable Trust (hact)
with CLG funding have developed a website
which provides guidance on this issue and can
be accessed at www.housing-rights.info
Wakefield Council worked with the Polish
community to try to ensure it understood a new
CBL scheme. In order to overcome the problem
of reaching the geographically dispersed
Polish community most effectively, a Polish
delicatessen was identified, acting as a
community hub.The shop was used to hold
sessions on the CBL scheme and display posters
and leaflets in Polish. Over 100 Polish people
attended pre-launch CBL information sessions.
Given that the Polish community comprised
around 1,000 people, the information campaign
can be deemed a success.
Welwyn Hatfield Borough Council has
developed an interactive community map as
part of the government’s Timely Information for
Citizens Project.This project reflects the
commitment made by government in the
Community Empowerment White Paper to
improve citizens' access to information on local
services and performance data, in order to
empower them to hold local service providers
to account.
The interactive housing map provides
information to enable people on the housing
needs register to make informed decisions
about where to live by showing for example:
bus routes, schools, location of shops, the level
of demand for property types and localities, and
links to CBL property adverts.With such a range
of information available in one place, the map is
intended to be a useful facility for the broader
community too. User feedback capability means
that citizens and community groups will be able
to suggest additional information and facilities
to be included.The map is due to be launched in
March 2010.
A1 Housing, the ALMO managing Bassetlaw
District Council's housing stock, has produced
a DVD, explaining the CBL system.A DVD was
seen as the best medium to ensure young
people and members of the community with
low literacy levels (of which there is a high
number of), can understand this new way of
accessing council housing. It was felt that more
'traditional' means of communication wouldn't
be sufficient.
Practice
example
Practice
example
Practice
example
32. Elected members
With their public-facing role, elected members
more than anyone else need to be well-
informed about the ways the social housing
system works (this includes all elected
members and not only housing portfolio
holders). Inevitably, given scarce resources,
the question of who gets social housing can
be highly political. Elected members may,
consciously or not, reinforce publicly held
misconceptions, particularly during the run-up
to elections.Whilst local authority officers must
be careful not to enter political debate, they
can help to ensure that any comments are
factually correct by making relevant
information available to all parties.As an
example, CIH has produced a two-page
briefing11
on housing allocations and migration
which provides information at national level
(for England) on this issue. It is often difficult
to respond to political debate, but it is
important to have factual information available
and to respond to media inquiries (e.g. about
how quickly households that are newly arrived
in the area are likely to be allocated social
housing).Although care should be taken not to
comment on individual cases in a way which
would breach confidentiality, it is still
important to respond quickly and accurately
with general information that addresses the
issues being raised.
Stakeholders
This includes all those with some kind of
professional interest in allocations, such as
health and social services, third-sector
organisations and support / advocacy agencies.
In order to give adequate client support,
stakeholders need to be equipped with
adequate knowledge which could be
provided through:
• bespoke briefings, taking account
of the specific client group
• presentations / training sessions
to frontline staff
• roundtable discussions (for instance, South
Somerset District Council invites staff from
Shelter to bi-annual strategy days and
forums to discuss their allocation scheme)
• regular updates on developments (as and
when appropriate).
More formal communication arrangements will
usually be in place with housing associations,
not least because of nominations agreements
or common allocation policies / housing
registers. It is vital that all social housing
providers in an area work together to provide
clear and consistent information on how
homes are allocated.
32
11
http://www.cih.org/policy/finalreportLGA-may08.pdf
33. In addition to information about the broad
allocation scheme, it is important to provide
clear information about lettings outcomes.
This is a common feature of CBL schemes,
with information provided on recent lets on
a regular (often weekly) basis and includes:
• area / district where the property is situated
• address
• number of bedrooms
• floor level
• property type
• banding of the successful bidder
• lettings date
• number of bids.
This information will aid potential bidders in
making informed decisions, giving them a
better idea of the popularity of certain property
types and the associated waiting times.
Providing such detailed information will
enhance transparency of the letting process.
Equally, where properties are allocated as
‘direct lets’ (i.e. those outside the general pool
and set aside for priority cases or as part of
local lettings policies), this should be made
clear. It is good practice to publish the number
/ proportion of such lets and the rationale
behind them.
Wirralhomes has produced a leaflet,
detailing vacancies advertised through the
Wirralhomes CBL scheme over a twelve month
period and the range of waiting times by
property type and geographical location.
It assists applicants to make more informed
decisions when bidding as well as informing
them of the realistic chances to access housing
in relation to their own circumstances.
Blackpool Council publishes a fact sheet
with information on the number of council
properties against the number of vacancies in
the previous year by area and property type.
This information is provided for both general
needs and sheltered accommodation.
Communicating lettings outcomes
Practice
example
Practice
example
34. Making use of internal expertise to
effectively communicate
Communication of the allocation scheme
should be part and parcel of a local authority’s
wider corporate communications
strategy.Where appropriate, make use of
the corporate communications or PR team who
can provide:
• advice on how best to communicate
complex information to different audiences
so as to ‘get the message across’
• press statements on particular issues
• advise on the most effective use of the
council’s existing communication vehicles,
such as free newspapers, leaflets, etc.
• help with brokering contacts with the
local media
• internal communication to staff and elected
members so that they are ‘on message’.
Working together potentially means better
value for money as there will be increased
scope for cost and resource efficiencies.
ause Plain English and avoid jargon
amake printed copies available as not
everyone will have internet access and / or
will be computer literate
aconsider the reading age and readability of
your communication material – consider
those with little or no literacy skills as well
as non-native speakers of English
aconsider how presentation and style can
enhance the readability of the text
ahave access to facilities to communicate
in community languages, Braille, signing,
audio and use of large print literature
as appropriate
amake interpreting services available
where appropriate
aidentify opportunities to co-ordinate
information so as not to overload people.
Giving too much information can be as
bad as giving too little.
In addition to providing the above written
information, local authorities need to remain
mindful that some applicants may require
additional help and support, especially
when dealing with the complexities of
CBL schemes.
Readability
The SMOG test (simplified measure of
gobbledygook) is a simple way to assess
the readability of any written material,
giving an indication as to the reading
vocabulary people can expect to acquire
by a certain point in their development.
For more information and an online SMOG
calculator see
www.literacytrust.org.uk
34
Practice checklist:
producing communications
material
a i
35. ause existing tenants and residents groups /
forums and other community groups to
channel information.Ask all relevant
stakeholders, such as registered housing
providers and other local authority
departments to promote and assist with
distributing information
aidentify community leaders / anchors to
help with developing communication
material and distribution
aengage with elected members to ensure
consistent messages are conveyed
amake the most of internal communication
vehicles, such as newspapers and
newsletters. Equally, make use of local
press and media, such as newspapers and
radio stations to get the message across
ause community facilities, such as
community centres, sports facilities,
GP surgeries, advice agencies and local
shops to display information
aconsider how to communicate most
effectively with geographically dispersed
communities, such as in rural areas. Make
the most of established channels and
groups operating in those areas
aparticipate in community events and / or
consider a stall at the local farmers’
market or shopping centre to get your
message across. Road shows can be a
particularly good way to engage with
hard-to-reach groups
ause the Local Strategic Partnership or
similar forums to raise awareness of
allocations issues and ask them to support
your communications campaign
aensure web links to allocations information
is placed on stakeholders’ websites
amake use of mobile libraries
ahold workshops with support providers /
advocacy groups such as homeless,
disability and refugee organisations to
enable them to assist people with
accessing social housing.
Practice checklist:
distributing informationa
36. We are well aware that many local authorities
will only recently have undergone a review in
response to the requirement of establishing a
CBL scheme by 2010.We are not suggesting
here to embark on yet another comprehensive
review and consultation exercise. Local
authorities should however collate feedback
from existing and potential tenants as part of
their ongoing communication activities around
the allocation scheme through for instance
newsletters and housing application forms.This
feedback will then form a good foundation for
consulting on changes to the allocation
scheme in the future.
Policy drivers around community
engagement
The government aims to ensure that all social
housing tenants have the confidence, skills and
power to engage on housing and housing-
related issues and for all social landlords to
understand the needs of their tenants and to
offer them a full range of opportunities to
influence service delivery and policies.This
objective has been reiterated by the TSA’s
tenant-focused approach to cross-sector
regulation and by CLG’s directions to the TSA
on tenant involvement. In addition, there are a
range of recent statutory obligations that
require local authorities to provide
opportunities for citizens to influence the
design, delivery and scrutiny of public services.
Reviewing allocation schemes – engagement
and involvement36
iSummary of recent
government policy
Creating Strong, Safe and
Prosperous Communities:
Statutory Guidance
Since April 2009, all local authorities in
England are under a Duty to Involve
representatives of local persons in the
exercise of any of its functions, where they
consider it appropriate.This means
embedding a culture of engaging and
empowering local people in service
delivery throughout the exercise of any of
their functions.This includes:
• providing information
to those affected by or interested
about services and policies in an
accessible way, which is easy to
understand and indicates how
people can have their say
• consulting
appropriate and genuine
opportunities should be offered
to allow representatives to have
their say, through for instance surveys,
focus groups as well as direct dialogue
• involvement in other ways
authorities should consider providing
representatives of local persons with
opportunities to get involved over and
above being informed and consulted
(the range of ways to do this are
covered on pages 43-45).
37. White Paper “Communities in
Control: real people, real power”
The white paper promotes a range of ways
in which communities and government can
work together to strengthen the democratic
voice of individuals and communities by:
• incentivising active citizenship,
volunteering and involvement in
the community
• providing better access to information
• giving more people a say, increasing
local influence over decisions and
encouraging greater participation
in the democratic process
• enabling local communities to hold
authorities accountable and seek redress
• identifying ways in which people can
own and run their own community
assets.
Sustainable Communities Act 2007
The act promotes the sustainability of local
communities, starting from the premise
that local people know best what needs to
be done to achieve this in their area. It
provides an opportunity for local authorities
to propose to government action which
they believe would promote or improve the
economic, social and environmental
wellbeing of their area. Decisions on which
proposals to submit are to be made after
consultation with local communities.
Connecting Communities
Programme
A programme of work to connect with
and reinvigorate communities that are
feeling the pressure from recession most
acutely and ensure they are well-placed to
share in prosperity and emerge stronger
and more cohesive. Support will take place
in over 100 neighbourhoods, across 75
local authorities. Each area will draw up
specific plans to address challenges,
aimed at:
• strengthening leadership in the
community as community leaders will
be critical to success.Training will be
provided for front line staff and
community activists
• providing local people with the space to
express their worries and engage with
authorities to help build up their
confidence and self-esteem to give them
greater feeling of control over their
communities and lives
• raising awareness about increased
opportunities, for example, through
investment in regeneration, jobs and
skills, childcare and youth services,
tackling anti-social behaviour as well as
giving people a greater sense that
services are provided fairly.
i
38. As well as supporting wider government
objectives there are clear additional benefits
to effective community engagement and
involvement in the development and review
of allocation schemes and policies, namely:
• better reflection of local pressures
and priorities within allocation schemes
and policies
• broadening the public’s understanding
of how the social housing system works,
including the tensions / considerations
in decision-making
• improved transparency which aids in
building trust between the local authority
and community.
Community engagement and involvement can
take place on various levels, with the approach
taken largely depending on the issue under
consideration, as well as the specific outcomes
sought.The levels of participatory activities can
be grouped around the following broad
headings, as expressed in the statutory
guidance on the Duty to Involve:
• influencing or directly participating
in decision-making (e.g. trying to shape
local priorities via citizens panels, service
advisory panels and neighbourhood
management)
• providing feedback on decisions,
services, policies and outcomes
(e.g. have your say section on the authority
website, feedback forms, petitions)
• co-designing or co-producing and
carrying out some aspects of services
(e.g. involvement in the commissioning of
services; tenant management organisations
managing housing)
• working with the local authority
in assessing services (e.g. user-
evaluation committees, overview
and scrutiny committees).
38
39. Community engagement – principles
There are a number of general principles which
apply to any form of community engagement
exercise, including involving communities in
reviewing the allocation scheme.These can be
summarised as follows:
• communicate and raise awareness about
the various engagement opportunities, since
a lack of information and knowledge about
these acts as a significant barrier to
involvement 12
• work together with partners to engage
people in setting priorities
• let people know why their views are
being sought
• strengthen the capacity of the community to
get involved, including vulnerable and
disadvantaged groups
• have long-term community engagement
arrangements in place, co-ordinated across
partnerships in order to maximise the
impact of engagement exercises
• engage with minority, vulnerable and
disadvantaged groups so that all voices are
heard.Try to avoid treating these groups
differently, but offer practical assistance if
needed (e.g. transport, interpreting
services).As far as possible ensure these
groups are included as part of mainstream
engagement activities
• be realistic about cost and resource
implications as well as the overall capacity
prior to embarking on the engagement
exercise.Ask yourself whether resources
are proportionate to the desired outcomes
• recognise the different knowledge levels of
individuals and communities. People need
to have adequate knowledge, to enable
them to get involved in a meaningful and
constructive way (e.g. the law around
allocations).This way you are more likely
to elicit considered views
• know your community, so messages and
engagement methods factor in the needs
of different groups
• be realistic about the time commitments
you put on individuals and communities
• consider a range of methods so that
individuals can choose how they are
consulted.Account should be taken of any
information already held on customers.
As part of the housing registration process,
ask applicants how they would like to be
consulted in the future.Also, use customer
feedback from previous engagement
exercises to inform your approach. Finally,
draw on the expertise of partners and
stakeholders with relevant experience about
what does and doesn’t work
• communicate the results of the engagement
exercise to consultees and how their views
have shaped proposals.
12
TSA and Ipsos MORI, 2009, Understanding Tenant Involvement, London,TSA
40. Community engagement – challenges
Even the most well-planned engagement
exercise gives no guarantee that large
numbers of people will actually respond to it or
take part.There are a variety of reasons why
individuals might not engage. Understanding
why people choose not to engage is important
in order to maximise participation rates and
provide well-designed, transparent and
genuine engagement. It could be that a
reluctance to get involved may stem from
negative experiences in the past i.e. the
perception that involvement and participation
hasn’t made any difference.Therefore, the
importance of informing people about the
outcome of a consultation exercise and how
their views have shaped the allocation scheme
cannot be overstated.
Other challenges for effective
engagement include:
• the allocation of social housing is a complex
and emotive issue and there could be a
danger (particularly when consulting with
housing applicants) of raising expectations
that cannot be met
• there are likely to be competing priorities
when consulting widely, with tensions
between the interest and expectations of
those living in social housing and those on
the housing register. Being explicit about
the aims and objectives of the engagement
exercise is crucial, as is the provision of
background and contextual information to
increase understanding amongst consultees
of what is feasible and desirable
• public ‘NIMBY’ attitudes may result in
people asking for something which the
local authority cannot (and should not)
deliver (e.g. excluding ex-offenders, Gypsies
and Travellers, etc.). It is important to make
it clear from the outset what can and
cannot be delivered
• there is a risk of consulting with the ‘usual
suspects’, such as existing tenants and
residents groups, which are not necessarily
representative or indeed have the mandate
to speak on behalf of communities
• it is important to set ground rules that do
not censor people but give them a voice
within agreed boundaries to curb extreme
or potentially racist views
• there will be a certain amount of resource
implications in terms of time, money and
skills.Any engagement exercise needs to be
in proportion to the desired outcomes
• meaningful community engagement
requires a culture shift within a local
authority, turning the old paradigm of
top-down on its head.Authorities already
strong on customer-focused service
delivery will be at an advantage here.
40
41. Who to engage with?
Community engagement as part of reviewing
the allocation scheme will usually include the
following groups:
• housing applicants
• existing tenants and residents
• representatives from the wider community,
for example using the citizens panel
• people accessing housing options and users
of support and advice agencies more
generally
• community leaders and councillors
• parish council officers and councillors
• tenants / residents and community groups
• stakeholders and those with a professional
interest in the allocation scheme, such as
housing associations, support services (i.e.
social services, health service), third-sector /
voluntary organisations (i.e. citizens advice
bureau, local credit unions) and faith
organisations
• advocacy groups such as Age UK and local
refugee forums
• local community development practitioners
from either the public or voluntary sector.
Skills for community engagement
It is important that those involved in the
engagement exercise understand the principles
of good engagement, know what the effective
processes are and have the right skills to
deliver it.These include:
• personal skills, such as listening skills,
ability to create trust; and to get people
working together
• contextual skills and technical knowledge,
such as understanding of cultural and
diversity issues
• engagement skills, such as presentation /
public speaking skills; ability to choose
between different methods of engagement
and the knowledge of how to use them.
42. autilising existing staff with the
necessary skills
aworking with partner organisations
who have the skills
ausing community representatives as
champions, peer advisors, etc.
ausing consultants, including professional
communication expertise in order to get
the message across
aworking with support and / or care
agencies to ensure that views of people
with special needs are taken into
consideration.
Ways to engage – useful methods
The following table provides an overview of
the range of methods which could potentially
be used when engaging with communities
around reviewing and / or framing the
allocation scheme.The practice examples
which follow illustrate how local authorities
have used a range of methods to consult on
changes to their allocation policies and
schemes.13
42
Practice checklist:
skills audita
13
For more information on practical techniques see www.peopleandparticipation.net; Communities Scotland, 2007, Community Engagement How To Guide, Edinburgh,
Communities Scotland; and Lister S, Perry J and Thornley M, 2007, Community Engagement in Housing-Led Regeneration:A Good Practice Guide, Coventry, CIH
46. Northampton Borough Council developed
an inclusive consultation process as part of the
allocation scheme review. Utilising the support
of community groups within the consultation
process was seen as crucial as a means of
breaking down barriers. Community group
representatives were inducted in the workings
of the allocation scheme as well as the aims
and objectives of the consultation exercise.
Consultation was undertaken with both
housing applicants and the wider community
and included:
• a text messaging service
• stall / display at the local market
• articles in local press
• adverts at the central coach station and
local lettings agencies
• stakeholder consultation meetings.
Rochdale Metropolitan Borough Council
has embarked on a comprehensive community
and stakeholder engagement exercise as part
of reviewing their allocation scheme. Following
the identification of a number of issues with
the current allocation scheme, focus groups
were held to collate views on these and
generate ideas as well as inform and shape the
next steps of the consultation process.
Intermediaries were utilised to get the
message out to various communities, including
hard-to-reach and under-represented groups.
A postal questionnaire, asking for views and
comments on the proposed allocation policy
changes was sent out to both housing
applicants and those recently rehoused.The
questionnaire was developed in partnership
with the University of Salford, who also
undertook the data analysis.The stakeholder
questionnaire was made available online and
differed slightly from the postal one.
To broaden the opportunities for involvement,
a FREETEXT service was also set up.
Stoke-on-Trent City Council has a
dedicated lettings service improvement team in
place which meets on a monthly basis.The
team identifies good practice and service
procedure improvements and inputs into policy
reviews, ensuring that the ethos of best value
is part of all the services provided by the city
council.
The team is made up of at least 50 per cent
customer representatives (maximum number
12) and consists of members from all tenure
types and also includes members who have
previously accessed the service and members
who are currently accessing our service.
Members are recruited in various ways, but
mainly by advertising.Adverts are placed in
weekly property news sheet, tenants and
residents newsletters, at road shows and
resident association meetings and via the city
council’s website.
46
Practice
example
Practice
example
Practice
example
47. Since the team commenced it has been
fundamental in having an input into the
following:
• implementation of CBL in 2004
• transfer incentive scheme
• literature and leaflets
• service standards
• performance targets
• local lettings policies
• procedures
• satisfaction questionnaires
• allocation policy review
• IT system development
• sub-regional working.
Berneslai Homes utilised their customer
panel during their review of the allocation
scheme as well as in monitoring the
effectiveness and performance of lettings
services and policy.
The panel meets every six weeks, looking at
subjects across the housing arena. It consists
of applicants and existing tenants and
residents, with attendance in the region of
50-60 people when allocation issues are
being discussed.
Customer involvement in developing the
CBL scheme was a priority objective for
A1 Housing in order to ensure community
understanding and support from the very
beginning.The initial working group was
made up of interested tenants from the A1
Hundred Club (tenants with a strong
involvement in participation) and the range of
members was widened to involve applicants
who were not current tenants and therefore
more representative of applicants on the
housing register.
The initial aim was to develop an
understanding of CBL. Once this was achieved
the next stage was to develop general
principles of how applicants should be
prioritised. It was only when these were
agreed that the first draft of the policy was
prepared.The timetable was flexible enough to
allow this to develop at a pace determined by
the group.The CBL Steering Group has
continued throughout the process and is
currently involved in reviewing the progress
made and recommending any changes from a
customer perspective.
Practice
example
Practice
example
48. Redditch Borough Council wanted to
engage its customers in considering the real
issues faced by customers trying to access
housing in their local area and the lack of
housing stock available.
They held 13 focus groups, using a case study
scenario approach, consisting of a total of 123
participants including young people, a range of
ethnic minority groups, local residents, disabled
people, older people and elected members.
20 housing applications were randomly
selected which represented varying levels of
housing need. Focus group participants were
advised that they needed to rank the case
studies in the order in which housing should
be allocated and that only five of the 20
households would in fact be rehoused.
The main findings were as follows:
• without any knowledge of legislation,
participants naturally gave preference to
households deemed to be in priority need
under the homelessness legislation
• housing need was considered to be more
important than local connection when
deciding housing allocations
• local connection was considered to be
important when comparing households of
the same level of housing need
• the length of time on the housing register
was considered to be important when
selecting allocations from households with
the same level of housing need.
All focus groups 'allocated' housing to the
same five households.The order in which they
were placed varied only slightly. Local
connection was considered to be more
important by focus groups consisting of
resident representatives and older people.
Findings from this exercise informed the
framing of the allocation scheme.
aunderstand the cost implications of the
consultation exercise and ensure that
these can be met
aensure that the right skills are in place
for delivering the planned consultation
atell people from the outset about how
far they will be able to influence
decisions made
arecognise the emotiveness of the subject
(particularly when consulting with housing
applicants which can be very personal) and
manage expectations carefully if there is a
lack of supply
48
Practice checklist:
consulting with communities
when reviewing the allocation
scheme
a
Practice
example
49. aset out the options available and provide
background and contextual information
so that individuals are in a position to
meaningfully participate in the
engagement process
ause opportunities to ‘piggyback’ with other
consultation events and think about
holding joint consultations with partner
and stakeholder organisations
atry to engage more widely than with those
who usually get involved
amake sure those running the event have
the necessary skills to effectively engage
with communities
aconsider the most appropriate range of
methods that will ensure a robust
consultation process.Also remember any
resource implications to meet the needs of
diverse communities (e.g. translators,
disability needs, etc.)
aremember the importance of face-to-face
contact during the consultation process,
particularly when engaging with
hard-to-reach, under-represented and
specific needs groups.Also, having a
presence in the community and being
seen as proactive helps with building trust
ainform consultees about the results of the
consultation and how their feedback has
shaped outcomes
asince what people want may conflict with
legislative requirements it is important to
be clear what can and cannot be delivered.
Early in 2009, Tower Hamlets embarked on a
major review of its Social Housing Lettings
Policy following a critical report from a Scrutiny
Working Group in 2008 that concluded that
the existing policy was difficult to understand,
lacked transparency, did not command the
trust of the public and did not deliver the
council’s objectives.
An innovative consultation plan was developed
and implemented during the last quarter of
2009.A brochure was produced which, in clear
terms and plain English, laid out the
weaknesses of the present policy, proposed
changes to overcome them, and how these
might affect housing applicants.This brochure
was accompanied by a survey document to
gauge the levels of support for the proposals
and provide the opportunity to comment fully
on them. Service users could also leave
comments on the web page, as well as post in
the partnership’s online forum.
To supplement this, focus groups were
recruited from the borough’s Residents Panel.
Participants generally were from the housing
register, but not exclusively, ensuring that a
wide range of views and opinions were
collected.Working in conjunction with the
Practice
example
50. youth participation team, a workshop with
children and young people – including the
borough’s Young Mayor – was held to gather
the views of those who may be potential
applicants on the housing register and affected
by the proposals in the future.
A number of public participation events were
attended by council staff and staff from
partner bodies of the common housing
register.This provided the opportunity for
residents to discuss the proposals individually
with an officer and be given support in
completing a survey form.
Throughout the period, the consultation
exercise was also promoted in the Tower
Hamlets Partnership director’s weekly
video blog.
The consultation produced a wide variety of
responses with the overall balance indicating
support for the proposals.A final lettings policy
document incorporating the results of the
consultation was circulated to stakeholders
for final comments before a report was
taken to cabinet for a decision on the new
lettings policy.
50
