Investing in Affordable Housing:
The UNISON Scotland Submission to the Scottish Government consultation,
‘Investing in Affordable Housing’.
- UNISON is Scotland’s largest trade union representing over
162,000 members working in the public sector in Scotland and
is the largest union representing those who work within the
social housing sector.
- UNISON Scotland welcomes the focus on increasing the amount
of affordable housing in Scotland, especially as the economy
continues to decline and more pressure is put on the existing
- UNISON Scotland would prefer to see local authorities able
to bid for housing grant on an equal basis with Registered
Social Landlords (RSL) in order to increase the amount of
affordable housing in Scotland and create a more stable housing
- Local Authorities already carry out assessment on housing
need with their Local Housing Strategies and look at investment
plans via their Strategic Housing Investment Plans. By providing
more funding, on an equal basis to RSLs, UNISON Scotland believes
that local authorities could be important drivers in increasing
the amount and range of affordable housing.
- UNISON Scotland is concerned that the proposals for regional
prospectuses are made, more to reduce the number of regions
rather than to identify and work with recognised housing markets.
Similarly UNISON Scotland has concerns regarding Glasgow and
Edinburgh being excluded from their surrounding housing markets
according to the consultation.
- If this consultation is taken forward, then UNISON Scotland
would like to see local authorities having the choice of not
only competing for funding on an equal basis, but also having
the option of joining and/or leading consortia.
- In order to maintain transparency over the use of public
funding for affordable housing, UNISON Scotland does not believe
that the private sector should be included in any consortia.
- When deciding the funding criteria for Lead Developers,
UNISON Scotland would like to see the inspection grades awarded
by the Scottish Housing Regulator, as well as RSL contributions
to tackling homelessness, taken into account.
- UNISON Scotland believes that core indicators relating to
the number and type of units completed (including specialist
housing), along with overall costs and subsidy levels should
be included. It is also important to capture information about
quality and sustainability and the extent to which local programmes
deliver on the priorities set out in SHIPs.
This paper constitutes UNISON Scotland’s response to the Scottish
Government consultation, ‘Investing in Affordable Housing’.
UNISON is Scotland’s largest trade union representing over 162,000
members working in the public sector in Scotland and is the largest
union representing those who work within the social housing sector.
UNISON Scotland welcomes the opportunity to respond to this consultation
Before answering the specific questions contained within the
consultation document Unison Scotland would like to highlight
a number of general points regarding investing in affordable housing.
UNISON Scotland welcomes the focus on increasing the amount of
affordable housing in Scotland, especially as the economy continues
to decline and more pressure is put on the existing stock. The
report by the Chartered Institute for Housing (CIH) on the economic
crisis, ‘The credit crunch & the Scottish housing system’,
highlights the impact this is having on the whole housing system.
This includes falling house prices and sales as well as increasing
levels of repossessions. This is also reflected in the latest
Housing Statistics for Scotland which indicates a marked decline
in new build starts, particularly in the private sector, but also
UNISON Scotland is also concerned at the reduction in Housing
Association Grant (HAG) levels from June 2008 as highlighted in
the ‘Arrested Development’ report by CIH. The current economic
crisis is impacting on the ability of RSLs to borrow private finance,
while keeping rents affordable, as the HAG reduction – although
partially reversed in February 2009 – will result in RSLs building
fewer affordable houses.
Although the focus of this paper is on Registered Social Landlords
(RSLs), UNISON Scotland believes that there should be a level
playing field with regard to the investment for affordable housing,
to allow local authorities to access funding on an equal basis
A key element in building affordable housing is the issue of
land. Local authorities can provide land for development but are
constrained in having to achieve best value for any land sales.
By providing more equitable access to funding, local authorities
can bring the land into use for their own building programmes
and move more quickly to build affordable housing.
Another key element blocking local authorities from building
new affordable housing is the historic housing debt. In the Firm
Foundations consultation paper the Scottish Government committed
itself to pursue the Westminster Government for debt write-off.
UNISON Scotland would be interested in further information on
this approach as debt write-off would allow local authorities
to build more affordable housing.
UNISON Scotland believes that Scotland needs to develop a housing
policy that promotes efficient and stable choices rather than
specific tenures, and to assess the possibilities for more effective
methods of securing unearned land value gains for affordable housing
purposes. UNISON Scotland believes that both the Scottish and
the Westminster Governments should critically rethink the current
housing policy emphasis given to promoting owner occupation, especially
to groups in society that are vulnerable to, and poorly equipped
to cope with, economic and housing market volatility.
In general, UNISON Scotland believes that there is still some
detail to be added to the policies discussed within this consultation
and would prefer to give a fuller response once this detail is
UNISON Scotland Response
Question 1: To what extent does our assessment of the current
economic situation reflect your assessment?
UNISON Scotland believes that one of the consequences of the
current economic situation is likely to be an increased need for
affordable housing. This makes it important to maximise the number
of new homes that can be provided from the national housing budget.
This reflects our response to the Firm Foundations consultation.
Question 2: Does the economic situation strengthen or weaken
the case for investment reform at this time, and why?
UNISON Scotland believes that the current economic situation
strengthens the case for investment reform in order to maximise
the number of affordable housing from the current housing budget.
However, UNISON Scotland would suggest that local authorities
should have a stronger role in the direct build and provision
of affordable housing. Local authorities have a range of skills
and resources, not least land, which could be brought into service
to increase the supply of affordable housing if they were allowed
the same access to affordable housing funding as RSLs.
Question 3: Do you agree that local authority Strategic Housing
Investment Plans and related strategies should form the basis
for identifying investment priorities for periods of up to five
While agreeing that local authority Strategic Housing Investment
Plans (SHIPs) and related strategies should form the basis for
identifying investment priorities for periods of up to five years,
UNISON Scotland believes that the use of Regional Structures and
Prospectuses may detract from existing work being carried out
on SHIPs. Through their Local Housing Strategies (LHS) local authorities
identify housing needs and plan to address these from investment
planning via their SHIP. The objectives stated in the consultation
paper can already be achieved by the current structures and thus
be more easily and quickly implemented by the use of SHIPs rather
than establishing new regional prospectuses.
Question 4: Do you agree with our proposed principles on which
geographic regions for investment will be based?
If Regional Structures are to be implemented they should be based
upon transparent principles as indicated in the consultation paper.
Question 5: a) Do you agree with our proposed treatment for
Orkney, Shetland and the Western Isles Councils? b) Do you agree
with our proposed approach for Glasgow City and City of Edinburgh
a) UNISON Scotland recognises the unique nature of the Island
authorities and accepts that different treatment may have to be
applied to them.
b) UNISON Scotland has concerns regarding the differential approach
to Glasgow City and City of Edinburgh Councils. If there are to
be opt-outs from the regional structure then, while accepting
the position above of the island authorities, it would be better
to achieve uniformity across the rest of the country and incorporate
Glasgow and Edinburgh within their regional housing markets.
Question 6: Do you agree that Councils, as the strategic planning
and housing authorities, and in collaboration with RSLs, should
advise on the regions to be adopted as the basis for Prospectuses?
UNISON Scotland believes it is essential that local authorities
are involved in identifying the regional groups. The illustrative
map contained within the consultation document seems to be aimed
more at reducing the number of regions rather than identifying
existing linkages between local authorities. For instance, the
seems no logical reason for Group E where councils on either side
of the Clyde are grouped together and almost circle Glasgow, yet
that city is excluded even though it has a major impact on this
regional housing market. Currently eight councils in the Glasgow
and Clyde Valley area are working together to implement new guidance
on assessing housing need and demand within this area. If the
aim of the consultation is to ensure housing investment is based
on regional areas, then it seems at odds to break up existing
regional housing markets. UNISON Scotland would prefer housing
investment to be based upon local authority areas.
Question 7: a) Do you agree the scope of the content proposed
for Prospectuses set out in Table 2? b) How can we ensure that
the housing need of people with specialist requirements or in
more remote or rural areas are fully reflected in Prospectuses?
a) UNISON Scotland is in broad agreement with the scope of the
content proposed for the Prospectuses set out in Table 2. We believe
that they should draw on the information already contained within
the SHIP for each local authority area.
b) Information relating to specialist housing need is already
gathered within each Local Housing Strategy and is fed into the
relevant SHIP. There is no need to duplicate this work.
Question 8: a) Do you agree that there is a need to provide
guidance within Prospectuses on maximum rent levels and is the
proposed framework acceptable?
UNISON Scotland understand the reasons for providing guidance
on maximum affordability thresholds and think this would be helpful.
Question 9: a) Are there other issues which would similarly
benefit from guidance? b) What are these and what is the case
for including them?
UNISON Scotland has no further comment to add here.
Question 10: a) Is the Lead Developer role proposed here sufficient
to deliver a more streamlined and effective approach to investment
in and procurement of new affordable housing? b) Does it adequately
balance and recognise the needs and roles of non-developing RSL
- The proposal will lead to a reduction in the number of developing
RSLs, however without further information on expected outcomes,
UNISON Scotland is uncertain on how effective this approach
- The consultation paper appears to take adequate account of
the roles of non-developing RSL partners.
Question 11: What are your views on the routes we propose
for establishing Lead Developers?
The proposals seem reasonable, based on the policy objectives
contained within the consultation paper.
Question 12: a) Do you agree with the proposed principles
of consortia and responsibilities for consortium heads?
UNISON Scotland is in general agreement with the proposed principles
of consortia and the responsibilities for consortium heads.
Question 13: a) Do you agree with the proposals on formation
of consortia, including the requirement of a formal agreement
to govern relationships within consortia? b) What guidance would
be helpful to support the sector in setting up consortia and Lead
Developer arrangements? c) What guidance would be helpful to ensure
tenant and community engagement in
- UNISON Scotland agree with the general proposals and the requirement
for a formal agreement to govern relationships within consortia.
- UNISON Scotland has no comment to make on this issue.
- Local housing need would already have been assessed via LHS
for each constituent local authority area within any regional
area. RSLs may be able to bring additional local knowledge to
the process but this should not be at the expense of over-ruling
identified housing need. However, this could be reflected in
tenant input on housing design and layout etc.
Question 14: a) Do you consider that there may be circumstances
in which consortium membership should include local authorities
or other non-RSL bodies? b) In what circumstances would you see
this as appropriate?
- If this process goes ahead, UNISON Scotland believes that
local authorities could bring additional knowledge and resources
to consortia, including land, and the potential to pool resources
for greater economies of scale. Due to issues surrounding the
transparency of public funding, UNISON Scotland does not believe
private developers should have a role in this process.
- UNISON Scotland believes it should be up to each local authority
to decide whether to join local consortia.
Question 15: Are there circumstances in which bodies other
than RSLs might be eligible to become heads of consortia and Lead
UNISON Scotland could envisage local authorities becoming lead
developers but this would be dependent on the size and scale of
proposed regional areas. However, UNISON Scotland believes that
local authorities – if given a level playing field on access to
funding for affordable housing – could build affordable housing
more quickly and cheaply than RSLs.
Question 16: Do you agree that a pre-qualification process
should be included in the new arrangements?
UNISON Scotland has no concerns regarding the pre-qualification
Question 17: Are the pre-qualification criteria and information
requirements set out at Annex C a reasonable basis on which to
work with the Regulator, the SFHA and COSLA to refine the pre-qualification
The information provided in Annex C seems reasonable.
Question 18: Do you agree with the proposed funding criteria
for bids for specific projects?
UNISON Scotland would also like to see the inspection grades
awarded by the Scottish Housing Regulator, as well as RSL contributions
to tackling homelessness, taken into account.
Question 19: Do you agree with our proposed approach to development
of an assessment framework?
UNISON Scotland believes it is important that local authorities
are able to contribute to the assessment of the proposals.
Question 20: How might we enhance the involvement of local
authorities, RSLs and other stakeholders in the assessment of
Local Authorities have increased their involvement in existing
investment processes over the past few years with the development
of SHIPs. UNISON Scotland believes their involvement is crucial
to the assessment process but would want more detail on the proposed
Question 21: Do you agree with our proposed approach to the
appointment and management of Lead Developers?
The proposals seem reasonable.
Question 22: a) Do you agree with the overall approach to
grant agreements for Lead Developers as set out here? b) What
do you suggest we could alter to make grant payments more streamlined?
- UNISON Scotland believes that the approach is consistent to
the policy objectives of this consultation.
- UNISON Scotland has no comment to make on this issue.
Question 23: Do you have any comments on the proposed timetable?
UNISON Scotland believes that the timetable is challenging, especially
for local authorities who have to group together in, as yet, unidentified
Question 24: Which indicators and what aspects of the Investment
Programme should be included in a monitoring and evaluation framework?
UNISON Scotland believes that core indicators relating to the
number and type of units completed (including specialist housing),
along with overall costs and subsidy levels should be included.
It is also important to capture information about quality and
sustainability and the extent to which local programmes deliver
on the priorities set out in SHIPs.
For further information please contact:
Matt Smith, Scottish Secretary
14, West Campbell Street,
Glasgow G2 6RX
Tel 0870 7777 006 Fax 0141-331 1203
Submissions index |