Response to Scottish Government Consultation on Local Connection and Intentionality

• Shelter Scotland agrees with the proposals to change the local connection and intentionality tests. However, we do not think they go far enough. Shelter Scotland advocates removing these tests entirely but recognises that this is a longer process and interim steps should be taken.

• Shelter Scotland frequently assists clients with both local connection and intentionality decisions, and most of our frontline advisers state that they get a new case involving an intentionality decision at least once a week, and a local connection case slightly less often.

• Most of the clients we work with are successful in overturning their intentionality or local connection decision and are eventually given a full homelessness duty.

• So, we believe that local connection and intentionality are being used as rationing tools to prevent or delay people from accessing a full homelessness duty and that people are often being given an incorrect decision without full cognisance of the facts surrounding their homelessness. As a result, their time in the homelessness system is unnecessarily prolonged, which can add avoidable distress and uncertainty for people at an already difficult time.

• In terms of local connection, we believe that if people who are homeless leave an area where they have a connection or present as homeless in a different area to where they have been staying, it is usually for a very good reason and that the decision they have made is most often in the best interests of their household.

• In terms of intentionality, we believe that this barrier is particularly overused and intentionality decisions are often made without proper investigation of a person’s circumstances. We find that effort is rarely made on the part of the local authority to understand the situation in its fullness, whether better support and preventative work could have helped to avoid the situation, and what impact an intentionally homeless decision will have on the household’s ability to access a secure and affordable home.

• A strong, sustained programme of affordable housebuilding is central to the success of these policy changes, to address the pressure currently facing the system, and to ensure that any localised variations in demand for temporary and permanent accommodation as a result of these policy changes can be met.

• Both local connection and intentionality hinders people in moving away from homelessness. This is not in line with the driving principles behind the HARSAG recommendations or Ending Homelessness Together plan of collaborative working, a person-centred system and a ‘no wrong door’ approach, and Shelter Scotland strongly supports change in this area.