Briefing – Impact of Bedroom Tax in Scotland o COSLA is firmly opposed to the Bedroom Tax which is ill conceived, unfair and unworkable and should be abolished o We believe that the Bedroom Tax will do little to increase the supply of housing in Scotland and that the UK Government has not done effective impact analysis on how it will impact - particularly in Scotland. o Any saving to the UK Government is, as COSLA predicted, being passed on in increased rent arrears to councils and RSLs and increased distress to tenants. All councillors are aware of this from their own areas. COSLA members feel very strongly on this. o Councils have been placed in a very difficult position by the bedroom tax. They have to operate the administration of Housing benefit in line with regulations and guidance, while at the same time this measure is increasing rent arrears. o Councils are doing what they can through Discretionary Housing Benefits and other supports to assist people. However, while DHPs can help, there were never designed to be used in the way that is now necessary. There were only ever meant to provide short term help and are not the appropriate mechanism to allow for ongoing needs. o Analysis of housing stock availability in Scotland and COSLA’s sampling shows that many tenants have no option to move. There are simply not enough 1 bedroom properties available – councils COSLA have checked with have confirmed this. o There are many ways in which the Bedroom tax is unfair. Hitting people in council owned temporary accommodation (57% Scottish provision) and not in leased or licenced TA (more typical England) when they have no choice is just wrong Summary of estimated costs of Bedroom Tax in Scotland This is a policy which cannot be made to work. Even if councils had all the money they wanted, building enough 1 bedroom properties (and ignoring all other indicators of housing need and demand) wouldn’t happen in under 3 or 4 years! This policy won’t help housing supply – it is just about cuts – which tenants, councils and RSLs are paying for. It is clear that this policy contributes nothing to housing supply. Anecdotal evidence suggest that most people do not want to move from areas where they have connections, family, employment and, in any case, options to do are very limited. Assuming that the policy was intended to save money, how does the balance sheet stack up in Scotland? This policy was estimated by the UK government to save c£500m, around c£50m is Scotland. COSLA estimates total annual implementation costs in Scotland as: o Costs of DHPs £33.5m o Extra administrative costs for councils No clear figure but feedback from councils suggests major new burden of administration, promotion, advice, rent recovery etc. Experience of admin costs of Scottish Welfare Fund would suggest £ 5m o Additional rent arrears for councils (may in part be mitigated by DHPs) COSLA sampling suggests annual figure of £10m-£12m o Additional rent arrears figures for RSLs SHR data suggests will be less than councils. Estimate £5m o Additional advice and support services – social landlords. Scottish Government provided £2.5m to housing association; Councils will probably be spending a similar proportion. £5m o Loss of rental income due to inability to let E.g.2 or 3 bedroomed property, and the additional costs to the Public purse of more expensive private rented accommodation £??m Estimated total cost of implementing policy £58m - £60m Thus, it looks likely that any saving to the UK Government (itself predicated on tenants not taking UK Government advice to move) will be balanced by expenditure of at least as much additional public money. This does not take account of any additional social cost of distress to tenants, many of whom will find themselves in rent arrears for the first time (increase of 31% in COSLA’s sampling). Salient points from some of COSLA’s recent surveys and sampling Discretionary Housing Payments COSLA had feedback from 26 (78%) councils on the position at 30 September. The original DHP allocation in Scotland was c£10m for 13/14. Funds since added – mostly for very rural authorities, take the DWP allocation for DHPs to c£13.5m in Scotland. Councils can add a maximum of 150% and with SG allocation of £20m to help councils do this, total available in Scotland is now over £33m. DHP is not just for bedroom tax but for housing need/hardship for those on HB. However, prior to recent WR changes, Scottish allocation was only about c£2m. Key findings at 30 September from 26 councils are: 58%(15) have spent or committed 50% or more of their DWP DHP allocation 15%(4) have spent or committed 100% or more of their DWP DHP allocation Only 3 councils had spent less than 30% of their DWP DHP allocation. All were rural. At end September these 26 councils had received 42,247 applications and made 27,828 awards (66%). Some may still need to be processed. Total spent or committed by these 26 was £7,431,642 on 30 September. However the picture is changing very quickly and we now expect spend to increase more sharply. Councils are now revisiting earlier awards and changing practice in the light of more available funding. Many are adopting a more targeted pro- active approach e.g. Renfrewshire, Highland. Key points on DHPs: DHPs help but are not the answer. They are designed for short term relief. All the evidence suggest that most people cannot easily get out of their situation (Lack of smaller houses, Jobs etc.) People are also being moved from an entitlement system to the uncertainties of a discretionary system. We don’t know how much DHP will be available from DWP next year and whether same level of help is possible. DHPs are creating an enormous amount of extra work for councils – dealing with applications, promoting, targeting and an extra assessment required. It would be better to take account of circumstances and widen exemptions from the bedroom tax. Rent Arrears The picture is complex and changing but key points are: Arrears are up. At the end of May, all but one council with housing stock reported an increase in arrears due to the bedroom tax. 75% reported that non-payment of rent due to the bedroom tax was directly responsible for the increase in their rent arrears. Of that rent due to be collected from tenants affected, 60% of councils then reported receiving 40% or less and 80% reported receiving 50% or less (based on responses from 20 of 26 councils). The Scottish Housing Regulator survey of the position at the end of June for all social landlords appears to show that arrears rises are not so dramatic, only reporting a change from 3.51% to 3.73% increase in gross arrears for all social landlords. However they also showed a sharper rise for councils – 4.62% (30 June13) vs. 3.73% (30 June 12). Just below 1% gross rent arrears doesn’t sound too bad BUT if no council tenant hit by bedroom tax paid anything at all, this would only increase gross arrears by 2.5% to 3% and they are still showing a 24% gross rise for councils. To increase our understanding COSLA checked the 30 September position with 6 councils – North Lanarkshire, North Ayrshire, Dundee, Highland, Edinburgh and Fife a good geographical and demographic mix. The selected councils have the following coverage:• • • • • They cover 43% of all working age local authority tenants on HB in Scotland. They cover 48% of all local authority tenants affected by under occupation Two had rent arrears over 4% of their gross rent in 2011-12 and 4 had rent arrears under 4% of their gross rent in 2011-12 Four are urban (prop. density over 200 per Sq. Km; Two are rural (Pop. under 200 per square Km) Three had an HRA surplus of more than 10% of their gross rent in 2011-12 and three had surpluses of less than 3 per cent. The following information is based on returns from all of the 6 councils: Highland North Lanarkshire North Ayrshire Fife Edinburgh Dundee At 30 September 2013 what was your total gross rent arrears figure? £1,427,489 £2,534,000 £1,207,574 £5,668,750 £4650000 £2,085,051 £17,572,864 What was the total gross rent arrears figure for the same period last year i.e. at 30 September 2012? £1,136,335 £1,532,000 £849,214 £4,764,542 £2,700,000 £1,468,407 £12,450,498 How many people in your council area have had a HB reduction as a result of the under occupancy (bedroom tax) changes? 1677 5201 2260 5267 3319 2297 20021 Can you provide a figure for the number of those with an under occupancy reduction who had rent arrears at 31 March 2013? 623 2333 779 1882 969 859 7445 Can you provide a figure for the number of those with an under occupancy reduction who have rent arrears at 30 September 2013? 949 3449 1294 3642 2523 1855 13712 TOTAL The 6 councils identified 20,021 council tenants impacted by the bedroom tax 37% (7,445) of these were in arrears on 31 March before bedroom tax came in. On 30 Sep, 68% (13,712) were in arrears, a rise of 31% Arrears at 30 Sep 2013 were 41%(£5,122,366) higher than for the same period last year What are councils doing generally? Feedback suggests that councils continue to put a lot of efforts into publicising what help is available and providing assistance – DHPs, budgeting advice, housing options, home visits etc. With more funding available than at the beginning of this financial year, a lot are now revisiting awards, targeting tenants they know are in arrears and not coming forward and reviewing their practice. However, this is a heavy administrative burden. Councils are also directing councils to other supports like budgeting advice and employability support where tenants are interested e.g. North Lanarkshire Quite a few councils have existing schemes to encourage downsizing based on swaps and mutual exchanges and these are being promoted – but will not help large numbers e.g. Fife, Aberdeen. All councils produce local housing strategies which take account of housing need and investment plans, population change and the needs of the local economy. They work closely with RSL partners. Allocation policies are geared to take account of local circumstances. This planning and delivery process is being undermined by the bedroom tax. What smaller housing stock is available in Scotland? Scotland has about 61% dwellings owner occupied with around 35% rented (June 2011, latest figures). The rented sector is split with roughly one third each for councils, RSLs and private, thus social renting comprises around two thirds all rented properties, a much larger sector than England. In Scotland, COSLA identified in June 82,500 households affected by under occupancy penalties, 68,500 (1 bed reduction) and 14,000 (2 bed reduction). Most of those affected are likely to require one or two bedroom properties. Scottish Government analysis estimates 21,657 1 bedroom properties and 27,791 2 bedroom properties available for rent in 2009/10 in the social sector and it is likely that the current stock availability reflects this. Demand for these properties comes from housing lists and homeless applicants in addition to increased demand generated by under occupancy changes. COSLA sampled 6 councils in July. (Fife, North Ayrshire, Highland, Dundee, North Lanarkshire, Edinburgh) with all except Edinburgh responding. In total these councils estimated availability of 4697 (1 bedroom) and 5337 (2 bedroom) properties. For these local authorities, 18123 tenants are subject to a 1 bedroom reduction and 4229 to a 2 bedroom reduction. To put these figures in context North Lanarkshire identified 12,393 applicants on its Common Housing Register requiring a 1 or 2 bedroom property at April 2013, with a total annual availability of 2811 1 and 2 bedroom properties in the social sector. Most of the 5 councils lacked detailed knowledge of the numbers of 1 and 2 bedroom private rented properties in their areas. Typically, rents are more expensive in the private sector and there is likely to be no saving and likely increased housing benefit expenditure if tenants move into that sector to avoid a reduction. Additionally, the composition of the private sector is very variable with most smaller sized properties only available on a sharing basis, with prospective tenants having already identified a flat sharer. In many areas outside cities, the private sector market is limited, e.g. North Ayrshire, or affected by holiday lets, e.g. Highland. North Lanarkshire estimates 13% of 1 bedroom private sector lets are sheltered housing and in other areas students will comprise a significant component. Possible moves to available properties are also constrained by issues of employment, travel, family responsibilities and community ties. In some rural areas like Highland (the size of Belgium) remoteness and sparsely populated is especially relevant, where 24 communities have no 1 bedroom accommodation. Prof. Gibb looked at this in his research for Scottish Parliament and concluded that looking at all estimates currently available, clearing the backlog of under occupiers is likely to take from 3 to 10 years or more! Therefore, for the majority of tenants affected by under occupancy penalties in Scotland, there are likely to be very limited opportunities to avoid the penalty through moving to a suitability sized property in the near future. Further Information: Michael McClements Policy Manager michael.mcclements@cosla.gov.uk 0131 474 9307 21 November 2013