6 October 2023 - A necessary long but critically important read and why released on a Friday
Commentary on rented housing is a fact free zone (FFZ) as is the
field of homelessness. I specifically
mean in England as I use facts below about these related areas for England and
Northern Ireland, Scotland and Wales has the same problems though with mostly
insignificant nuances.
This is never scrutinised and from 2000 to 2020 the number of private properties for rent in England more than doubled from just over 2 million to 4.3 million – and by contrast the total of social housing properties increased by just 3,000 in that 20 year period when the population of England increased by 7.2 million. These facts as below reveal a very different picture to that which is being portrayed by housing commentators and especially by private landlord lobbies.
Official data and fact takes far too long to be published and data lags are commonplace so whilst there is anecdotal evidence that PRS landlords are 'fleeing the market' (a) it is not provable; and (b) if some private landlords are 'selling up' the same number of PRS properties are there and do not disappear into the ether. The housing property capacity does not change if landlords sell up!
Two other current narratives which purport to be factual are:
- Increase LHA rates to reduce LHA shortfalls (thus reducing homeless pressures)
- Abolish the two child limit to reduce child poverty (and also reduce homeless pressures)
Both of these are oft-repeated narratives are specious claims for benefit households and non sequiturs as Chart 2 below reveals and demolishes these assertions, We see the facts are ignored by, variously, Shelter, Crisis, JRF, IPPR, CPAG and a raft of other lobbies that the media simply parrots as truth because they are asserted by these ‘usual experts!’
The 1 Parent 3 Child household type (1P3C) illustrates
The zero sum nature of the policy called Benefit Cap is illustrated by the above for the household type of a lone parent and three children and this policy which is an overall benefit cap allows the 1P3C benefit household a maximum of £639 per month in whatever form of housing benefit (UC or LHA) for the 3 bed property they need to escape homelessness from temporary accommodation or refuge.
The OBC operates by CAP minus SUBSISTENCE equals MAXIMUM HOUSING BENEFIT and for the 1P3C benefit household in the regions outside of London as £1835 minus £1195.79 is £639.21 as the maximum monthly housing benefit payable (UC housing cost element or LHA)
Next financial year beginning in April 2024 will see this housing benefit maxima reduce to £559 per month if subsistence benefits are uprated by CPI as they have done during the ten year history of the Overall Benefit Cap that in real terms is today in FY2324 a £943 per month cut compared with FY1314 when the policy began.
IF the overall limit or CAP had been uprated with the
previous September's CPI inflation rate as subsistence benefits are then this
real term cut of £943 PER MONTH would not exist. However, the data table
states the factual reality and demonstrates that the OBC benefit cut, and which
targets cuts to housing benefit as its first point of call, is the largest
benefit cut that the 'usual experts' have ignored and the largest benefit cut
that the electorate has never heard about!
Comment
My apologies for the ugliness of the last chart above and data tables. However, they are the facts of the matter, the irrefutable facts, and the factual reality is far uglier for those most in housign need than my presentation of these irrefutable facts. The same irrefutable facts that the ‘usual experts’ and academics and politicians all fail to see in their various assertions and purported ‘solutions’ that cannot work due to the Overall Benefit Cap policy continuing.
Housing, re-housing and homeless solutions proposed (and stated above) are all specious
and cannot work because those ‘experts’ who assert and promote them reside in
the FACT FREE ZONE that typifies rented housing and homelessness. The irrefutable facts are highly inconvenient
and blow apart the solutions they wish to advocate.
Note well that the claims of private landlords fleeing the market and increase LHA rates will reduce LHA shortfalls and abolish the 2CL to reduce child poverty are just the current falsehoods and assertions of the rented housing, homeless and related social policy arenas. I could bore you silly with many similar spurious ‘solutions’ and false ‘premises’ used by purported experts over the last 30 years. Instead I will mention another current example of the Joseph Rowntree Foundation and IPPR demanding – quite correctly – that universal credit standard allowance, the replacement for dole, income support, etc, is enough to cover the cost of ‘essentials’ that all benefit households face.
I use the IPPR source of this week here which breaks down the JRFresearch released in February 2023 and to crudely simplify the £85 per week UC standard allowance for a single person or single parent household needs to increase to £120 per week
Let’s imagine that the single person / parent rate of universal credit standard allowance overnight increases from £85 to £120 per week as JRF demand. It won't of course but bear with me as it explains the typical FACT FREE ZONE in which the 'usual experts' reside.
Now let’s revisit Chart 2 of how this would affect the 1P3C benefit household. The £85 per week is the £368.74 per month figure used there. This would increase to £521.43 per month (£120pw) which is an increase of £152.69 in the monthly subsistence benefit. It means due to the zero-sum nature of the overall benefit cap policy that the current £639 housing benefit maximum payable would fall by this £152.69 figure and the maximum monthly housing benefit becomes £486 per month.
Now imagine and to avoid the usual negative perception of both benefit claimants and single parents that the 1P3C benefit household is the univerally 'deserving' woman and 3 kids wanting to leave a refuge to where they have fled domestic violence and abuse.
We find that no landlord private or social would re-house them as £486pcm in maximum housing benefit means they cannot afford to re-house this family in the 3-bed property.
When lobbies and ‘usual experts’ as well as think tanks and academics all continue to ignore fact and the factual context of the Overall Benefit Cap policy they miss, amongst other critical things that:
- the greatest direct cause of homelessness, which is at record numbers,
- the massive increase in what we still call NO DSS in all forms of rented housing even the cheapest social housing is due directly to the OBC policy
- the OBC policy with its massive cuts to housing benefit means that every homeless resettlement model whether the more generic TA model AND the domestic violence and abuse refuge model have become defunct due to the OBC.
- the narrative repeated ad nauseam of ‘just build more bloody social housing’ as the ‘solution’ to the never fully defined ‘Housing Crisis’ is as specious as it gets.
The reality and fact, the factual reality and context if you will,
is no council or housing association landlord will house or re-house the
benefit household who does not get enough in housing benefit to cover the
cheapest social housing rents. SRS landlords operating NO DSS as the lay person
still calls it, sees social landlords call it LETWA or Limited Entitlement To
Welfare Assistance, which is exactly the same thing as NO DSS – and it is
perfectly 100% lawful as long as the same affordability testing matrix is
applied to all applicants for housing.
Whilst we still choose to believe wrongly that NO DSS is not endemic in the social rented sector and practiced more and more daily by council and housing association landlords - due mostly to the OBC cutting maximum housing benefit year on year - then everyone concerned with any form of homelessness is ignoring the FACTS. When there is no exit route or homeless-escape property from any form of homelessness whether TA or refuge or other (see below) then all homelessness models fail and become defunct and unfit for purpose. It also means as one of many impacts that every local council homeless department is a hoistage to fortune and will need to source more and more temporary (homeless) accommodation each and every year due directly to the OBC and in which every household will be forced to stay longer in these unsuitable and often dangerous accommodations.
I did a presentation at a CIH conference in London in 2013 with the main theme being that the OBC policy would force all social landlords to operate NO DSS. That is what the facts said then and what a further ten years of OBC operation has proved. As you can imagine it went down like a lead balloon and the 'we are social we will always house those most in housing need ' type of response came from the CIH housing audience.
Four years later the CIH (Chartered Institute
of Housing) commissioned Sheffield University to look into this and the
subsequent report contains the graphic above and from 2017 some 6 years
ago. The increase in social landlords
operating NO DSS which they call LETWA has had to increase year on year due
directly to the systemic flaws in the OBC policy which see a year on year
reducing housing benefit maxima payable to benefit households.
Each year the reducing housing benefit maxima is set against yearly rent increases to produce an ever greater housing benefit shortfall position each year. The OBC systemic flaws have directly led to far more renting households falling down the arrears to eviction into homeless path than the freezing of LHA rates.
Let’s go back to the 1P3C benefit household who can receive a maximum of £639 per month in LHA. In Brighton the 3-bed LHA rate is £1200 per month yet the 1P3C benefit or very low-income household only receives the £639 OBC-dictated maximum and not the £1200 LHA ‘rate’ so increasing LHA rates will not reduce the LHA shortfalls and as no additional overall benefit income is received should the 2CL be abolished then this fantastical claim that it would reduce child poverty is entirely false. It would also see many more children made homeless as their parent who would have £270 less per month in LHA or UC housing benefit would be evicted into homelessness due to arrears build-up and very quickly so.
Summary
Housing, homelessness and social policy fields are a FACT FREE ZONE for its claimed ‘experts’ and until they adopt fact as the primary basis for scoping any housing or homeless problem, which means factoring in the OBC policy, then homelessness and housing poverty can only increase.
As long as the overall benefit cap policy remains the proverbial hits the fan more each year for those who by any objective definition are the most in housing need.
That is not opinion reader it is inevitable fact!
Further Detail
Since 2012 and even before the OBC policy began I warned of its impacts and explained how it works by (a) reducing maximum housng benefit year on year, which (b) sees lower housing benefit set against rising rents each year thus creating ever greater shortfalls between how much in housing benefit is received and th rents they are charged. The Benefit Cap policy was designed that way. It is superficial ivory tower behavioural nudge theory nonsense based on the premise that those on benefits will be forced to work to keep a roof over their children's head.
it doesn't affect many say the 'usual experts' as a deflection to the facts. 662,000 households to date which will include more than two million children have had the roof over their heads threatened. As 26,000 were affected in Year 1 but now we see over 100,000 households per year and these are the poorest households, its scope increases by the year. In Year 1 (FY1314) it affected the very large benefit households of 1P5C and 2P4C in social housing whereas today the very much smaller benefit households of 2P2C and 1P2C have their housing benefit cut and the arrears to eviction into homeless road approaches fast.
The average 3 bed SRS property in the English regions is £739 per month and the 1P3C household cohort I use to illustrate here gets a maximum of £639 for a £100 per month shortfall and rent top-up - that can only be found from subsistence level benefit, the same which the JRF correctly say are not enough and note well the JRF 'essentials' calculation does not include these rent top-ups and despite the fact that only 36% of existing SRS tenants get full housing benefit to meet their rent and at the social rent level too.
The 2P2C benefit household today (FY2324) gets a monthly housing benefit maximum of £498 - which compares to the average 2 bed SRS property in the regions with a 'social rent' level of £468. In April, ceteris paribus, the 2P2C benefit household will have a £405 maximum housing benefit per month when the cheapest 2 bed at the social rent level will average £504 per month in the regions. A £99 per month rent shortfall in social housing ... yet the 'usual experts' only ever talk of the "LHA shortfall" as if they only affect the private renter!
The FACT FREE ZONE yet again.
There are 'easily attainable' exemptions to the OBC say many in their usual expert and highly superficial way and done to avoid scrutiny of their claims such as increase LHA, abolish 2CL and so on.
Receipt of incapacity (UCLDW) or disability benefit (PIP) do give exemption from the ravage of the OBC as does weoking 16 hours per week at national minimum wage. Yet lose these benefits and the exemption ends and from the first decision which can take 18 months to be corrected at the First-tier Tribunal appeal yet by that time the benefit claimant will have been evicted for arrears and despite the fact that 70% or more have the decsion overturned in the claimant favout at tribunal. The removal of legal aid for challenging welfare benefit appeals means so many cannot challenge the often outrageous UCLCW / ESA / PIP decisions made and only 5 -6% challenge those appeals despite the 70% chance of winning at tribunal!
When the government introduced PIP as the replacement for adult DLA in 2012 the stated aim of the policy in its impact assessment was to take half a million households off disability benefit by 2015 and this was achieved and surpassed.
The above is an extract from the DLA to PIP impact assessment and available here from May 2012 and, regrettably, the likes of "I, Daniel Blake" barely touched the surface of the charade that incapacity and disanility assessments are in reality. It is not enough to rightly laud Ken Loach for Cathy Come Home and for I, Daniel Blake because despite highlighting homelessness and incpacity / fit for work assessmenst we still see homelessness at record levels almost 60 years after Cathy Come Home. We need and have to abolish the Overall Benefit Cap policy as it is the root of the social policy evils I discuss above. If its stays we will never reduce homelessness or poverty and it really is that simple. Treat the cause not the symptom as is the case in LHA rates or just bloody well build social housing will ya!
How many lose a job and become affected by the OBC cuts? Specifically, how many 'seasonal' or zero hours contract workers lose or have no work and then become subject to the ravages of the OBC policy? Far too many yet we have so many 'apologists' for this policy who want to beleive 'getting around' its regulations is simple. Far worse is the 'usual experts' assertions as detailed above as these actors know full well that the benefit or very low-income households will not get any more income should LHA rates increase or the 2CL is abilished or if universal credit standard allowance increases from £85 to £120 per week.
ALL of these actors and 'usual experts' are throwing the porrest and those most in housing need and most in poverty under the bus with their specious and highly superficial pronouncements.
Even CPAG who are leading on the abilition of the 2CL know as they admit (as afterthought unfortunately) that no more benefit income in total is received if the 3 or more child benefit household types see the 2CL abolition. Yet CPAG are the only one of the 'usual experts' who do see the OBC impact and the only ones who (passively but not actively) campaign for the Benefit Cap policy to go!
Despite all the scaremonger / doommonger labels thrown at me for creating and repeatedly stating the systemic flaw(s) theory in the overall benefit cap the evidence is ten years of solid substantiation that the OBC is the root cause and no scaremongering happened.
I have no other agenda than supporting those most in housing need and most in poverty need. There is no personal or professional ego in this (or other such bollocks!)
For the past 22 years working as a consultant I have worked with many housing and supported housing providers who need to find ways around the OBC policy and which directly causes a fundamental change of operational and strategic policy in such services - as it does in general needs social housing as the question of who the hell will get social housing now that the benefit household is unaffordable to and for council and housing association landlords. It is only a question of time before government oulls the plug on any and all social housing subsidy funding because 'social' landlords and their model is defunct as its landlords refuse to accommodate those most in housing need.
ALL homeless cohorts need a homeless-escape property that is affordable to escape the vicious state of homelessness. Yet the OBC policy takes away the affordability of the critical homeless-escape property and ensures that homeless household numbers can ONLY increase each year whilst the OBC policy remains.
YET we see the usual experts only choosing to see those who are roofless as the ONLY type or cohort of homelessness when as the above ETHOS framework or template from 2007 readily identifies at least 12 separately and redily identifiable homeless cohorts. In England the system doesn't even bother to count the number of homeless households we have in a year FFS! IF we did then we would know how many homeless-escape properties are needed each year and begin to plan for it - but we cannot even be arsed to count homeless households in any meaninful or valid way!
How useful is a one night only rough sleeper count saying England has some 4,000 rough sleepers when the Everyone In public health initiative during Covid-19 lockdown saw 37,000 street dwellers brought in tootherwise unavailable hotels (closed due to lockdown) and in the 8 months of this knee-jerk scheme. That equates to c55,000 rough sleepers per year and who all need a 1-bed homeless-escape property to end just this 1 cohorts homelessness.
Yet despite this we saw the likes of Shelter claiming that Everyone In was (a) a success which (b) proved we could end rough sleeping (and despite the Shelter report on Everyone In saw 77% not housed after this scheme ended!) - And because Shelter asserted this to be true the usual chronies and sycophants reported this was true and valid!
Shelter ignored the critical FACT of the Everyone In scheme - that the hotels, HMOs and bed and breakfasts used to accommodate the 37,000 were ONLY available because Covid regulations denied their use by their normal clienteles! Once lockdown ended this reverted and the 37,000 bedspaces were no longer available to the rough sleeper or any other homeless cohort. The temporary and once in a century increase in supply due to lockdown ended and supply returned to its normal and abysmally low state and number.
By all means applaud the many in every local council who arranged these temporarily available accommodations and got rough sleeper and shelter dwellers off the streets so quickly, yet it also means the same councils beleive it is somehow NOT a public health emergency of problem that rough sleepers ordinarily have no roof and this is somehow acceptable!
Less rant more facts from the FACT FREE ZONE
Every homeless household needs the homeless-escape property to begin the ending of the state of homelessness. It is unavoidable and a necessity. Most of the above focuses on the non-affordability of the homeless-escape properties and because non-affordability is the greatest element of the never-defined ubiquitous term called the Housing Crisis and which alludes to undersupply as being the principal issue. Yet as I have detailed above there is no utility in just building more social housing at its cheapest social rent level as even they will not be allocated to those most in housing need due to non-affordability.
Undersupply is a huge problem and let me take you back to 2017 when Crisis the national homeless lobby published their 'Moving On' research. It said 100% factually that the previous year SRS landlords provided just 13,000 'move-on' or homeless-escape 1 bed properties to all single homeless households. It also saw Crisis estimate (in fact underestimate) that England has 200,000 single homeless household each year.
A basic issue of 200,000 per year DEMAND yet just a yearly SUPPLY of a mere 13,000.
There are many historical reasons why the social rented sector / social housing has not or ever built one bed properties for those of working age. It is also fair to say they never needed to have built then in the post war boom period ... until 2013 when the under occupation charge, aka the Bedroom Tax began. That aside there is no doubt that just 24% of the entire social housing stock is the 1 bed property and this is nowhere near enough to deal with the scourge of single homelessness. The 2017 Crisis Moving On report demontsrated on their own (under) estimate of 200,000 yearly single homeless that the social rented sector only met 6.5% of the demand ... leaving 93.5% of the 1 bed re-housing / homeless-escape proeprty supply to rest with the private rented sector.
How is the welfare state pillar and purported housing safety net allowed to become 6.5% effective at putting a roof over the heads of its populace?
The Crisis take on this was and still is perplexing.Firstly, it chose to emphasise that the SRS used to supply 19,000 1-bed proeprties per year and which on their estimates of 200,000 pa demand would still be just 9.5% effective and Crisis failed to criticise the miserable levels of SRS 1 bed supply. [The latest CORE data that Crisis used now shows just 11,106 or a furtehr reduction from 13k to 11k pa!]
The second, is the Crisis estimate of 200k pa incorporated just 71,400 of these as sofa surfers and when a few years later the English Housing Survey, which are official statistics, said 541,000 yearly homeless sofa surfers was the number and of which 386,000 were single and childless and thus required the same 1-bed homeless-escape property.
Thirdly, even after the EHS homeless sofa surfer number Crisis still asserted that England has only 71,400 single homeless sofa surfers and not the 315,000 more per year that EHS official data said!
Most surprising of all is that Crisis are the prime mover of the Housing First model being used in the UK - a model aimed solely at single persons or couples needing the 1 bed homeless-escape property and to accord with its ivory tower theory needs to be a social housing 1-bed property.
The 2017 Moving On report (see above) says in its third bullet point:
Around two-thirds of single homeless people have support needs that mean their immediate destination should be some form of housing with tailored support such as supported housing or a Housing First solution.
Two thirds of the (under) estimated 200k per year demand is 133,000 or so 1 bed social housing supply for the Housing First model and the HF Demand per year YET Crisis know the 1 Bed total SRS supply was 13k in 2017 and just 11k in 2022. This is Crisis demonstrating their supply and demand FACT FREE ZONE when it comes to 'solutions' for addressing single homelessness in England. It is delusional yet regrettably all too typical of the FACT FREE ZONE and FACT FREE BUBBLE that Crisis as one of the usual experts resides in.
None of the above is the manipulation of numbers or lies, damn lies and statistics. It is merely the correct use of FACT in the correct context and at THE most basic level. YET we allow the 'usual experts' and 'usual suspects' to get awy with such pitiful assertions that we can end homelessness when the irrefutable facts say this is impossible.
I have no problems with being called a scaremonger / doommonger or similar label for reporting these facts yet they are just the usual experts playing the shameful blame the messenger card as the facts as reported prove their pronouncements are ignorant, negligent and delusional.
Am I the only one that gives a flying fig ...








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