Black homelessness

Evidence of prejudice against Black tenants in the private rented sector makes it crucial that support and pathways to challenge illegal behaviour are available and accessible. We welcome the increased rights for tenants delivered by the Renters’ Rights Act, which will help people to remain in their home, including Black households who are more likely to be threatened with eviction, and make it easier for tenants to challenge poor conduct by landlords. (Conclusion, Paragraph 35)

The new Private Rented Sector Ombudsman should support individuals who have been subject to racial discrimination and where appropriate, for example in cases involving multiple complaints about larger housing providers, escalate cases to the Equality and Human Rights Commission. (Recommendation, Paragraph 36)

The Equality and Human Rights Commission saw its budget slashed in 2013 and has experienced year on year reductions in funding in real terms since then, preventing it from pursuing sustained programmes of work in key areas including supporting people to secure justice in cases of discrimination. The Government should provide and sustain a 10% uplift to the EHRC’s budget. (Recommendation, Paragraph 37)

Local Housing Allowance provides vital support for people on lower incomes. The ad hoc approach of freezing and resetting rates creates uncertainty, pushes people into further poverty and increased risks of homelessness. This in turn forces local authorities to increase their use of temporary accommodation, at substantial cost. (Conclusion, Paragraph 44)

The government needs to increase and sustain Local Housing Allowance rates at the 30th percentile of local private rents. Doing so will help to prevent people from being pushed into homelessness due to private rent increases, will immediately unlock more homes to help councils move families and individuals on from temporary accommodation, and help stop people from becoming trapped in the cycle of homelessness. 48 Such an intervention would benefit all groups, but particularly Black households, given they are disproportionately affected by homelessness. We acknowledge that such a measure is not cost free, though some costs will be offset by reductions to the cost of temporary accommodation, but the increasing affordability gap between LHA and private rents and its negative impact on living standards is unsustainable. (Recommendation, Paragraph 45)

The chronic shortage of social housing places enormous pressure on council staff to find appropriate housing for people who are often extremely vulnerable. They do crucial work in trying circumstances. However, official data suggests that decisions in the social housing system result in bias against Black people for a range of reasons and contributors to this inquiry highlighted shocking reports of explicitly racist behaviour by some housing officers. (Conclusion, Paragraph 59)

We welcome the introduction of the new Competence and Conduct Standard for housing management staff but, given long-standing issues of discrimination against Black people, we believe the government should introduce specific steps aimed at tackling racial bias. (Conclusion, Paragraph 60)

The government should work with local authorities to ensure that their staff are fully equipped to provide equal support to all racial and ethnic groups in need. We are sympathetic to calls for anti-racism training and guidance. We call on the government to consider the merits of including a module on ensuring fairness of process in the new Competence and Conduct Standard. However, given the effectiveness of that training may not be guaranteed, the government should put measures in place to improve transparency and accountability over decision making. (Recommendation, Paragraph 61)

The government should develop a national performance management framework for homelessness assessments and allocation policies which specifically includes monitoring of outcomes by race and sex and compliance with the Equality Act 2010. It should collate and publish a summary of findings at least annually and report significant patterns of racial and other biases in local decision-making to the Equality and Human Rights Commission for investigation and enforcement. (Recommendation, Paragraph 62)

Out of area placements can remove vulnerable people from their support networks at a time when they most need them and have a devastating impact on people’s healthcare and education. Reports of the disproportionate use of these placements for Black households is concerning. Failures of local authorities to fulfil their section 208 duties in notifying the new host local authority exacerbate these concerns. (Conclusion, Paragraph 63) 49

We welcome the government’s plans to address poor practice in the use of out of area placements. Those plans should include measures to address the disproportionate use of these placements for Black households, including through the recording and publication of data by ethnicity and gender. (Recommendation, Paragraph 64)

Statutory services should be required to play a stronger role in tackling homelessness. We welcome the focus in the National Plan to End Homelessness on switching from crisis response to prevention of homelessness and the proposed “duty to collaborate” to help achieve that ambition. The lack of an explicit link between the proposed “duty to collaborate” and tackling racial disparities in homelessness risk is, however, a missed opportunity that we urge the government to address. (Conclusion, Paragraph 73)

In bringing forward the “duty to collaborate” the government should set out a clear ambition to tackle the poorer outcomes including increased risks of homelessness that minority ethnic groups experience in leaving the care of public services. The government should ensure that such a proposal is developed with input from Black communities, Black-led organisations, and Black individuals with lived experience of homelessness. (Recommendation, Paragraph 74)

The Home Office and the police should be added to the list of public bodies subject to the statutory ‘duty to refer’ and included in the forthcoming proposals for a ‘duty to collaborate’. (Recommendation, Paragraph 75)

We welcome the government’s programmes to increase access to mental health support for people in the homelessness system. We would like to see improved access to referral pathways between health and housing services in areas with high levels of Black homelessness. In these areas, health, mental health and hospital discharge policies should include clear responsibilities for identifying homelessness risk and notifying local housing teams. Particular attention under the proposed new ‘duty to collaborate’ should be given to patients from over-represented groups such as Black men leaving inpatient mental health care. (Recommendation, Paragraph 79) Variation in homelessness risk across the Black population

Domestic abuse is a key driver of homelessness. The housing workforce must have the training and capacity required to deal with cases effectively and compassionately. The government has increased the funding available to support victims into safe accommodation but it falls far short of what is needed. We are concerned that the significant funding shortfall is putting 50 people’s lives at risk. Tackling violence against women and girls is rightly one of the government’s key missions. We therefore call on it to urgently review the level of funding it is providing to support victims of domestic abuse. (Recommendation, Paragraph 92)

We welcome the measures in the Social Housing Bill to support victims of domestic abuse and to help prevent them becoming homeless. We will follow the scrutiny of the Bill closely. (Conclusion, Paragraph 93)

Government strategies to end rough sleeping must take into account that women are more likely to manage their homelessness by making themselves less visible. Using this as a coping strategy can expose them to further risks. More hidden forms of homelessness, including less visible rough sleeping, merit attention and resources equal to that given to more visible forms of homelessness. (Recommendation, Paragraph 94)

We welcome the focus on young people in the National Plan to End Homelessness, not least given the elevated risks young people can face through abuse, family breakdown and care leaving. Ensuring young people can get the right support at an early stage to prevent them experiencing homelessness will be vital to the success of the government’s homelessness strategy. (Conclusion, Paragraph 100)

The intersections of race with other characteristics, like age, gender, parenthood, sexuality, and disability, shapes both the likelihood of homelessness and the type of homelessness experienced by Black people and others. Recognition of overlapping issues is essential for understanding how and why homelessness occurs and for designing effective intervention strategies that would benefit Black people and other groups, yet significant gaps in data, both at a local and national level, make this more challenging to achieve. (Conclusion, Paragraph 103)

The Ministry of Housing, Communities and Local Government should create a standardised framework for data collection. This should require local authorities to collect and publish data on social housing applications, outcomes, use and duration of temporary accommodation, and exits from statutory homelessness that can be disaggregated at a minimum by ethnicity, gender, age and disability at a national and local level. Local authorities must be held accountable if they fail to comply with this requirement. (Recommendation, Paragraph 104) 51 The government’s National Plan to End Homelessness

Black people face a greater risk of homelessness compared to other ethnic groups. This disparity is not explained by poverty or geography alone. Instead, it reflects a combination of factors: direct and indirect racism in housing and related services, structural inequalities like lower home-ownership rates and poorer employment outcomes, and the legacy and contemporary effects of housing and welfare policy. (Conclusion, Paragraph 110)

The government’s National Plan to End Homelessness and increased investment in social housing are very welcome. However, it is disappointing that there is little recognition in the Plan of the disproportionate impact of homelessness on Black people or any targeted commitments to address it. Policies and programmes that do not consider racial inequalities will continue to leave Black people disproportionately affected and risk delegating the responsibility for addressing racial inequalities onto third sector organisations and Black communities themselves. (Conclusion, Paragraph 111)

The delivery of the government’s National Plan to End Homelessness, including resultant policies and local strategies, should explicitly acknowledge and seek to tackle the excess risks of homelessness faced by Black people, and the disproportionately worse outcomes they experience within the homelessness system. The plan should seek to embed understanding, transparency and accountability in relation to the impact of race in homelessness at national, regional and local levels. (Recommendation, Paragraph 112)

As part of its National Plan the government should engage with smaller, Black-led organisations who have the trust of their communities. This will enable the government to understand the issues Black people face across a range of ethnicities and other characteristics, and then work with these groups to design tailored interventions. It should use its convening powers to facilitate greater join up between smaller grassroots organisations and national bodies who can help them to deliver comprehensive support. (Recommendation, Paragraph 117)

In allocating funding to third sector organisations the government should not lose sight of those bodies who support the ‘hidden homeless’, including women who might be fleeing domestic abuse and who may be particularly vulnerable and in need of support. (Recommendation, Paragraph 118) 52 Criminalisation of rough sleeping

We welcome the government’s commitment to halve rough sleeping and the additional funding to support that objective. We urge the government to allocate some of that funding to frontline organisations working with Black rough sleepers given the particular challenges those individuals face around personal safety and access to support. (Recommendation, Paragraph 125)

While no one should be criminalised for sleeping rough, it is clear that the use of powers under the Vagrancy Act have been disproportionately used against the Black homeless population. We welcome the government’s repeal of the Act and the resulting positive impact this will have for the Black homeless population. (Recommendation, Paragraph 126) 53