In mid 2021 the Department for Communities issued a Call for Evidence to inform a 15-year housing supply strategy. PPR’s submission said that, in line with the UK’s international human rights obligations, those with the most severe need must be the priority.

The DFC issued its draft strategy in late 2021 and the finalised version three years later. In that time the number of FDA homeless households in the north has increased by around a third, to over 30,600 households. Nearly 5,000 of them are living in temporary accommodation in single lets, hostels, B&Bs and hotels -- unthinkable in 2021. Given the circumstances, we would have expected the final strategy to be more focused on those in the greatest need – but this is not the case. 

Instead, while much of the descriptive text from the draft appears verbatim in the final, key actions and commitments have been shifted in ways that risk leaving the most deprived less protected than before.

1. Commitment to consultation on the future of the House Sales Scheme / right to buy deleted

With regard to social housing, the draft’s commitment (on p. 25) to “bring forward a consultation on the future of the Housing Executive House Sales Scheme”, otherwise known as ‘right to buy’ – which over past decades has seen 122,000+ Housing Executive homes sold, hamstringing the housing body’s ability to meet need – has been cut from the final version.  

While a significant change to the strategy itself, this is consistent with Lyons’ statements elsewhere committing to continuing the scheme (for example, his responses to Assembly colleagues’ written questions like AQW 16024/22-27 and AQW 7910/22-27). It appears that the public will not get a chance to make their voices heard on this issue or to influence the Department’s approach to it after all. 

2. Commitment to ring-fenced funding for social homes in areas of need cut

The 2021 draft’s reference to the higher proportion of housing stress households “from the Catholic community, relative to the Protestant community” remains, but the policy response – ring-fencing Housing Association Grant funding for areas of acute housing need (see p. 21 of the draft) – has been cut.

In fact, all references to the wide variations in levels of unmet social housing need across the north – a defining characteristic of our housing landscape, and hardly one to gloss over – have also disappeared. To give a few examples, actions that have been deleted from the final version of the housing strategy include

• “build more social houses, especially where they are most needed” (p. 21 of the draft)

• “seeking the prioritisation of water infrastructure for new housing in areas of most acute housing need” (p. 21 of the draft)

• “consider how existing powers can be used better to achieve housing and regeneration in areas of greatest housing need” (p. 22 of the draft. In the final, ‘in areas of greatest housing need’ has been deleted).

While the final version of the Housing Supply Strategy refers repeatedly to ‘housing needs’, and also to ‘housing-led regeneration’, there is no reference to the existence of areas of acute and concentrated housing deprivation, such as in predominately Catholic areas of North and West Belfast and of Derry. The presence of these areas of high housing demand and high unmet housing need – and the often stark contrast between their levels of homelessness and housing stress and those of neighbouring areas – are swept under the carpet in this Housing Supply Strategy. The average reader would be forgiven for coming away with the impression that housing need must be spread more or less uniformly across the north. This is patently false, as analysis of the Housing Executive’s own evidence has repeatedly demonstrated.

Why does it matter?  PPR’s recent research into census data on deprivation and social housing provision found wide divergences:

South and East [Belfast] were found to have social housing provision largely in line with deprivation levels, and in some areas more housing than would be expected. North and West Belfast had significantly less, and the area around the Mackie’s site, where the Take Back the City coalition has been campaigning for more social homes, has almost the lowest level of housing provision relative to deprivation in the whole of Belfast and indeed the north.

Given its responsibilities for housing, but also around poverty and combating disadvantage, the Department should be leaning into the gaps between acute housing need and social housing provision, rather than acting as though they don’t exist.

Given its responsibilities for housing, but also around poverty and combating disadvantage, the Department should be leaning into the gaps between acute housing need and social housing provision, rather than acting as though they don’t exist. A credible housing strategy should strive to correct imbalances in housing provision so that ALL areas can benefit from a level of social housing provision that is comparably proportionate to need. This requires, at a bare minimum, acknowledging that there are areas of high unmet need currently under-served in terms of social housing provision.

3. Protections for private tenants (such as establishing specific grounds for eviction) cut

For private tenants, facing an average annual rent increase of 10% - again unthinkable in 2021 - and struggling to make up the difference, some protections in the 2021 draft – limits on tenancy deposit amounts  and restrictions on rent increases (p. 27) -- were incorporated into the Private Tenancies (NI) Act 2022, with further work foreseen under the Department’s private rental sector reform initiative (see the Communities Minister’s responses to Assembly colleagues’ written questions like AQW 17383/22-27; AQW 15128/22-27; AQW 18244/22-27; and AQW 18067/22-27).

However, the work on “establishing specific grounds for eviction” foreseen in the 2021 draft (p. 27) does not appear in the final strategy – in fact eviction is not mentioned at all, despite calls for the final strategy to reflect the 2024 Stormont motion for legislation on no fault evictions. (See the Minister’s responses to AQW 19554/22-27 and AQW 16101/22-27 for more on this). His  repeated assertion that extending notice to quit periods is a sufficient protection for private tenants, and that banning no-fault evictions is unnecessary, is surprising, to say the least, given our current  unprecedented levels of homelessness here.

4. New Homes Ombudsman

Additions? An obvious one is the ‘New Homes Ombudsman’ – floated in the draft as an idea for consideration (p. 26) but presented as a definite in the final strategy (p. 30). Will this post prioritise homes for people with the highest level of objective need? It’s a fair question, particularly as the other new post announced in the final strategy -- a new Intermediate Rent Operator (p. 25) – most definitely will not; its task is to provide homes to rent

for tenants who cannot or do not wish to access home ownership and would be unlikely to attain sufficient points to have a realistic chance of accessing social housing in an area of choice.

The proof will obviously be in the pudding – but the choices made internally in the Department about what to cut from the 2021 draft, and what to add, indicate a potential shift in emphasis that could have real ramifications for the ever-growing cohort of people in severe housing need across the north.