This is an article for Welsh Housing Quarterly
The new Welsh Housing Bill is a substantial document that contains many welcome provisions. The reform of the housing revenue account subsidy will release more money for investment, however, there are a number of issues which need further thought.
The proposal to allow local councils to discharge their homelessness duty into private accommodation for example is a welcome flexibility, but the removal of a statutory duty to rehouse ex-prisoners is a serious misstep in my view.
That proposal is being made for purely popularist reasons and belies the evidence in the government's own research, published in 2008, that concluded that housing issues are a major factor in the decision of 75% of ex-prisoners to re-offend. That report suggested that more joined up thinking is needed to prevent re-offending.
As Shelter Cymru pointed out If, as the government's own research states, housing is a necessary, but not sufficient, condition to prevent reoffending, then surely the solution is
not to destabilise the 'necessary' condition but rather to ensure that the supporting conditions are more effectively met.
They argue that the new duty would be more effective if it were underpinned by priority status to guarantee a right to temporary accommodation while prevention work is being carried out. They say that without a right to temporary accommodation, it will be virtually impossible for local authorities to work with homeless prison leavers effectively.
If these individuals end up street homeless on release, it is highly likely that they will fall out of touch with prevention services and back into a cycle of reoffending. This has consequences for community safety, healthcare, social services and, eventually, for homelessness as well.
My concern is similar, that without a statutory duty to rehouse prisoners underpinning rehabilitation work, councils will just not bother to do the work and reoffending rates, which are already higher than those in England will rise even further.
The move to register letting agents is a long overdue and necessary measure but the proposal to force all private landlords to also register may prove to be resource-intensive and over-ambitious. HMO licensing has been in force for about six years but council officers have failed to find thousands of these properties. I cannot see how they will have any more joy in locating other types of property especially when the landlord may just be letting his or her house because s/he cannot sell it as is quite common.
Finally, in relation to the council tax charge for empty properties, my view is that the government needs to consider a staircasing provision, whereby a property that is empty for a longer period might attract a higher council tax: for example, 150% up to five years, 200% up to 10 years and 300% up to 20 years. I think that that would provide an incentive for the owners of those properties to bring them back into use and not to leave them causing a blight on our communities for substantial periods of time.