1.         The Welsh Local Government Association (WLGA) represents the 22 local authorities in Wales, and the three national park authorities, the three fire and rescue authorities, and four police authorities are associate members. 


2.         The WLGA is a politically led cross-party organisation, with the leaders from all local authorities determining policy through the Executive Board and the wider WLGA Council. The WLGA also appoints senior members as Spokespersons and Deputy Spokespersons to provide a national lead on policy matters on behalf of local government.


3.         The WLGA works closely with and is often advised by professional advisors and professional associations from local government, however, the WLGA is the representative body for local government and provides the collective, political voice of local government in Wales. 


4.         This is the WLGA’s submission to the National Assembly for Wales’ Equality, Local Government and Communities Committee’s inquiry into rough sleeping. The submission is framed around the inquiry’s individual terms of reference.


The effectiveness of Part 2 of the Housing (Wales) Act in preventing rough sleeping

5.         Following the introduction of the Housing (Wales) Act 2014 Local Authorities are required to provide help to secure accommodation to anyone presenting to the local authority who is homeless. This means that more people can now access this help and in particular those rough sleepers who may not have previously been entitled to assistance from the local authority due to their lack of a priority need can now be helped to secure accommodation. Local Authorities work hard to assist those who apply to them for help and the Welsh Government data[1] shows that the number of applications to LAs has increased significantly since the introduction of the Act. LAs have successfully assisted almost half of those households applying to them for help during the first 2 years of the Act.


6.         The Housing (Wales) Act 2014 also puts a duty on LAs to accommodate those who they are helping if there is reason to believe that they fall into one of the ten priority need categories. These categories were widened with the introduction of the Act and the threshold for vulnerability significantly lowered as stipulated in the “Code of Guidance for Local Authorities on the Allocation of Accommodation and Homelessness”. The use of “interim accommodation” has fallen but this is probably due to the fact that households are getting helped earlier and spending less time in this type of accommodation.


7.         Many rough sleepers will be classed as priority need and will be offered “interim accommodation” by the Local Authority. However, it is not unknown for former rough sleepers to be unable to maintain this accommodation due to being unable to adhere to the license conditions. The recent LA questionnaire exercise as part of the Rough Sleeper count 2017 highlighted several occasions where people were sleeping rough having been evicted from hostel accommodation. Potentially there is more than can be done by providers to support people by working with them to retain their accommodation and develop their tenancy skills.


The scale of rough sleeping in Wales and the adequacy of data;

8.         Welsh Government has commissioned a consistent one-night count of rough sleepers for the past two years and the latest figures will be released shortly. It is understood that these figures and those from the previous year’s count (2015) show a significant increase in the number of people sleeping rough across the country. There was concern over comparing the 2015 and 2016 figures due to changes in methodology but the common methodology employed in 2016 and 2017 make comparisons between the two most recent counts more reliable and meaningful. It should be borne in mind however that LAs are becoming more proficient at identifying and engaging with people sleeping rough and this will inevitably increase the number of known rough sleepers identified in the area. It is positive progress that LAs are able to identify these individuals in order to provide services and work with people to move them on into settled accommodation.


9.         During the rough sleeper count period LAs also carried out a two-week data gathering exercise where services asked those presenting as having slept rough to complete a short questionnaire regarding their housing history and reasons for sleeping rough etc. Local authorities collate and analyse these questionnaires, can compare the cohorts in 2016 and 2017, and use this information to plan, design and provide services for people.


10.      The Wallich has recently secured Welsh Government funding to develop a Wales wide data collection system to help agencies to record, share and access data on individuals in order to better understand this cohort. This information system will also help in working with individuals as agencies will be aware of previous input, risk and individual needs.


The causes of rough sleeping and of the apparent recent increases in rough sleeping

11.      The causes of rough sleeping are many and varied. From the recent LA questionnaire exercise as part of the Rough Sleeper count 2017 it appears that many people initially become homeless due to losing a tenancy either through relationship breakdown or rent arrears. In these circumstances, it may be the case that the individual affected is a single person with no apparent priority need status, this would mean that the statutory assistance available to them is limited and no temporary accommodation duty would be owed. The individual, who could be a young person or even a care-leaver, may therefore begin sofa surfing and staying with friends and eventually run out of options and end up sleeping rough. The loss of a tenancy can also be caused by, or lead to, mental health and/or substance misuse issues which can remain undiagnosed due to a lack of accesses to relevant services. This can affect a person’s ability to sustain suitable accommodation and rough sleeping becomes more likely.


12.      Welfare reforms including changes to Housing Benefit rates for single people and smaller families, and the roll out of Universal Credit have affected the income of many. Difficulties with financial management have led to an increase in arrears and affecting households’ ability to secure further accommodation due to former tenant arears and adverse credit records.


13.      Among rough sleepers there is a higher proportion of those who have previously been in custody than among the general population. The National Pathway for Homelessness Services to Children, Young People and Adults in the Secure Estate” which was launched by Welsh Government in December 2015 outlines the way criminal justice, probation services, local housing authorities and support providers should work with people who may be homeless in custody. The Welsh Government research into the success of this pathway will be released shortly. It is our view that the changes to probation services, Transforming Rehabilitation and the introduction of CRCs particularly in the prison setting have caused issues with the successful working of this pathway. The lack of resources within custody in order to identify and assist individuals who may be homeless means that individuals are often applying to Local Authorities with very little time in which to assist them prior to release.



The effectiveness and availability of services including emergency accommodation

14.      All Local Authorities have some services available to assist those who may be sleeping rough. These services will be commissioned and provided based on local needs assessments and evidence from the counts and other information gathering exercises. Some LAs will choose to use B&B accommodation, primarily for single people, whereas others may commission purpose built hostel type provision to accommodate people in an emergency. The use of emergency accommodation will depend on the willingness of the individual to accept the offer and there may be many reasons why a person chooses not to do this e.g. the other individuals already in the accommodation, the ability (or not) to use alcohol or other substances within the accommodation, the perceived risks associated with the accommodation and even the location of the accommodation.


15.      The emergency accommodation provided by Local Authorities will sit alongside other offers of support such as assistance with alcohol and/or substance misuse, mental health provision, tenancy and pre-tenancy support services, and finance and debt advice. Many of these services will be commissioned and paid for by the Supporting People Grant Programme. The Flexible Funding Pathfinder pilots recently announced by Welsh Government offer the opportunity to “do things differently” and to reshape services around the needs of some of the most vulnerable people in our communities.


The steps to prevent and tackle rough sleeping in Wales.

16.      The Housing (Wales) Act 2014 has enabled LAs to begin working with individuals prior to them becoming homeless in order to sustain current accommodation, or intervene to secure alternative accommodation as soon as people become homeless. This has meant that many individuals have been prevented from becoming street homeless due to this rapid intervention.


17.      Representatives from the LA Homelessness Network, Supporting People Network, and specific Local Authorities sit on the Welsh Government’s Rough Sleeper Working Group (RSWG).



18.      Several LAs have utilised additional Homelessness Grant Funding from Welsh Government to develop Housing First type services. Many have also used this funding to enhance their services to rough sleepers and provide Rough Sleeper Intervention Teams (sometimes via local providers) to engage with and help those who are sleeping rough in order to mitigate the length of time spent on the streets and assist people back into settled accommodation wherever possible.


19.      There are obviously still many things that can be done in order to prevent and tackle rough sleeping including early education and tenancy skills development, and engagement of other services in identifying triggers which might result in loss of accommodation and rough sleeping. Once an individual begins sleeping rough there needs to be a rapid response in order to get the individual back into accommodation with provision of the relevant services in order to arrest the slide into chronic rough sleeping. Housing First in particular requires health services (particularly mental health) and substance misuse services, in addition to housing services, to be reactive in responding to individuals when they are ready to engage in order to sustain accommodation and achieve positive outcomes.

[1] http://gov.wales/docs/statistics/2017/170727-homelessness-2016-17-en.pdf