Shelter Scotland response to the Scottish Government Consultation on Improving Temporary Accommodation Standards

• We believe that people should have greater enforceable rights to better accommodation, and there is an enhanced role for the Scottish Housing Regulator (SHR) in achieving this.

• Shelter Scotland are also submitting a lived experience response on behalf of our Time for Change group. This can be found on our policy library here.

• Shelter Scotland strongly supports the need for reform to protect people at risk of rooflessness who require good quality, safe and appropriate temporary accommodation. We are broadly in agreement that this should be delivered by extending the Unsuitable Accommodation Order and the introduction of minimum standards around temporary accommodation.

• We recognise that there is good quality temporary accommodation used in many parts of Scotland. We commend those providers that are succeeding and call on those who fail in their duties to raise their standards accordingly.

• We believe that Scottish Ministers should consider these proposals within the context of the abject failure of Scotland’s two largest councils to uphold existing duties placed on them. In particular the 3,535 occasions in 2018/19 (95% in Glasgow) that local authorities failed to accommodate someone who had the right to temporary accommodation and the 620 breaches (75% in Edinburgh) of the existing Unsuitable Accommodation Order.

• The evidence shows clearly that extended stays in temporary accommodation pose a risk to the health and wellbeing of individuals. Shelter Scotland supports people every day whose lived experience demonstrates the long-term damage done to their lives, and policy and practice should seek to reduce the harm caused.

• We believe that there is a key role for a well-funded, evidence based and authoritative Housing Regulator to facilitate and support local authorities to phase out the use of unsuitable accommodation. We are concerned however that the existing regulator has not been able to intervene sufficiently to stop the current failures within Edinburgh and Glasgow. Any new responsibilities must be accompanied with additional resources and capacity.

• There is also a role for the Scottish Government in ensuring that local authorities are properly and sustainably resourced to meet these asks and understand that this will be a particularly difficult challenge for a small number of larger authorities, who will require added support.