Local Government and Housing Committee, 26 June 2025 | Open Senedd

Local Government and Housing Committee, 26 June 2025 | Open Senedd

Emily James

Thank you Chair. Yes, from Pembrokeshire's perspective, we do welcome the Bill. I completely agree with what Laura is saying around the unintended consequences of the Bill, but, from our perspective, homelessness is not everybody's issue at the moment, and with the new legislation and the new duties on public bodies, we feel that that is changing the entire view and how we approach the prevention of homelessness. So, that aspect of the Bill is really important for us.

If I could just touch on what my colleagues have said about the private rented sector, we’re still dealing with the unintended consequences of the Renting Homes (Wales) Act 2016 implementation. That was a piece of legislation that was brought in post COVID, but it was actually written prior to COVID. And we are dealing with the ongoing issues there, in terms of the security of tenure in temporary accommodation, and we would still like an outcome around that, because we were advised that that would be considered.

We lost a number of landlords within the private rented sector in Pembrokeshire as a result of that, which has again increased the pressure on the affordability within that part of the sector. We have used Welsh Government funding through the private rented sector leasing scheme to try and fill some of that gap. But we aren’t able to meet that demand, and, as Martin has said, there are lots of other aspects now—people all trying to get into the same type of property. So, the challenges are that supply issue, but the challenges are also around providing appropriate accommodation for people to move on to.

Cheryl touched on the complexities that we have of customers who are in temporary accommodation, or who we’re working with to try and prevent homelessness. And in order to do that, we really do need the level of funding to come with that, to provide appropriate supported accommodation, or wraparound support services to make that a success. Otherwise, there will be repeated homelessness presentations, and it will not be rare, brief and unrecurring, which is the whole ethos and desire of Welsh Government with the legislation.

So, we do welcome the principles of it—absolutely—and that’s where we want to work to. And I would say most local authorities have already adopted many of those principles already, and are working to that six months, for example, rather than the 56-day prevention period. We really welcome that level of prevention input. But those new public body duties are so crucial to making this a success.

09:09Watch #Official Record

Emily James

I don't think it's the draconian element of it; I think it's the ability for us to be able to engage with those customers. So, when you're having those conversations about intentionality, it only comes at the very end stages of the current legislation anyway. We're already not applying it, as Laura has referred to. When you look at the statistics across Wales, they're very low in number, but it is about having that ability to have those conversations with the customer, do that prevention work and engage with them. Because if you have a system that doesn't allow for changing behaviour and buy-in to change that behaviour, then it leaves us in a situation where, as Laura said, the reliance on the social housing sector is going to be there to pick that up.

If I can give you an example: if you're consistently not paying your rent, what will happen is that you will come back into the system, you will continue to not pay rent, and we'll still have to keep accommodating you. I appreciate the deliberate manipulation test is there, but as Laura said, it's the timing of that test and how it refers to the entire housing sector. By only looking at people's circumstances on the social housing register—as they currently are today, not at previous behaviour and previous trauma, as you said, and how we can look to intervene and support in the most appropriate way—you're not going to see a huge change in behaviour. We're not able, as local authorities, to get that level of engagement either, so it's that tool that comes with it. It's not a case of trying to go in with a draconian tool and resource to local authorities—it's a case of that engagement. That's how I would look at it and how we perceive that from a Pembrokeshire perspective.

Social housing is already under massive pressure. We need to be making sure that we're utilising that and making sure that people's homelessness journeys are rare, brief and non-recurring. And if that test isn't there, I think we need to really monitor how that is impacting on the sector in terms of rents, in terms of behaviour, as you said—there are significant anti-social behaviour cases that most local authorities and RSLs would be able to give you examples of—but we need to be able to go in and manage that in a really productive and proactive way.

09:20Watch #Official Record

Emily James

Thank you. Yes, I've written a few things down there, Chair. For me, as my colleagues have already raised, on the housing support grant and the funding that goes into that, from a Pembrokeshire perspective, we've been a bit of a poor relation in terms of the housing support grant. We were advised that the formula would be reviewed yet again, and each time there's been a slight increase to that, which we really welcome, we're already at a detriment because of that current formula, which means that we don't have some of those resources available to us to meet some of the reasonable steps required in the current legislation, let alone in the future legislation. So, for me, the housing support grant, the funding, the implementation and the transitional funding that comes with the Bill are really crucial, as Martin and Cheryl have referred to. But I think it goes a little bit wider than that. You're going to be looking at additional review periods, additional reviews in terms of the PSAPs, but also the ongoing support and that 12 months after, which I completely agree with, but, in the current resources that we have within homelessness services, we're not going to be able to meet that demand.

I know, within the additional document, there were some costings put down there in terms of the impact of the legislation, and I think one of the elements in there was that it takes three and a half hours to do a review. It doesn't take three and a half hours to do a review; I would say that takes at least a whole day, if you're going to do it and do it justice.

On the IT element that Cheryl refers to, we also need to be really making sure that we're capturing the right data coming out of that, particularly around the prevention work. If we're asking public bodies to take on that additional 'ask and act' aspect, we need to be capturing that prevention work on a much wider scale, not just in the homelessness teams or the housing support grant services.

09:39Watch #Official Record

Martin Cooil

Going back to the 56-day notification point, I think this really highlights a significant challenge for us all in terms of implementation. We know what the reference points are, the time frames. When it doesn't happen, what's the consequence? Where's the accountability? All roads lead to homelessness services being the end destination, so if things on that track to get to the homelessness service go slightly out of sync, off track, the challenge sits with the homelessness service. So, I think consistency and accountability within the new legislation, and how is Welsh Government and how is this committee in years to come going to know that what we all intended is actually being delivered? Yes, you can have outcomes. Yes, you can have data. There's loads of great stuff that's happening through sub-groups of the ending homelessness national advisory board that I sit on, so I know there's great stuff. But, actually, how do you know the spirit of the Act is being implemented and interpreted? So, that kind of leads us to training and consistency and monitoring that isn't just numbers; it's qualitative as well as quantitative.

One final point, and it goes back to Emily mentioning APs, approved premises, because my ears picked up then. It's really scary that we have people with significant risks, significant vulnerabilities, who are being refused by APs. They still have homeless duties that are owed to them, but they're too high risk, too dangerous, too complex to go in part of the semi-secure estate. And they just come to the homeless service, so we'll manage that risk. That's really frightening. When we talk about trauma-informed, person-centred ways of working, us as leaders within our organisations have to be person-centred, trauma-informed with our workforce, because they are working under immense challenges and significant strain. They're doing it with a smile on their faces because they're bloody brilliant, but when you hear in the office that we have someone coming out and he's been refused from AP because of his risk, staff just think, 'We're just being dumped on here.' I think that really is a significant risk, a very specific bit, but something that I couldn't not raise. So, thank you, Emily, for pricking my ears up.

09:52Watch #Official Record