Support for housing costs in the reformed welfare system - Work and Pensions Committee Contents


3  The Social Sector Size Criteria (SSSC)

48. The Welfare Reform Act 2012 gave the Government powers to reduce Housing Benefit for social sector tenants of working age deemed to have more bedrooms than required for their family's size. The Government named this policy the "removal of the spare room subsidy". Opponents of the policy call it the "bedroom tax". In the interests of neutrality we refer to the policy as the "social sector size criteria" (SSSC). The policy was implemented from April 2013. Housing Benefit claimants in the private rented sector have been subject to restrictions in Housing Benefit based on the size of their accommodation since 1989.

49. The intentions of the SSSC are: to contain spending on Housing Benefit; to provide motivation for tenants to move into smaller accommodation if they are not using all the space in their current accommodation, thus freeing up larger properties for those who need them; and to provide further work incentives. The Government expected to save around £930 million over two years (in present value) as a result of the reform, and originally estimated that it would affect 660,000 households. The SSSC initially affected a lower number: 547,000 in May 2013, dropping to just under 500,000 by November 2013.

50. The new Regulations allow one bedroom per:

·  single adult or couple;

·  any two children under 15 of the same gender;

·  any two children under 9 of either gender.

51. Exemptions apply to non-resident carers who provide overnight care and parents whose adult son or daughter is serving in the armed forces. Approved foster carers who have been between placements for 52 weeks or less qualify for one spare bedroom.[52] From 4 December 2013, following the outcome of a court case which found against the Government, the exemption was extended to households containing "a severely disabled child who would normally be expected to share a bedroom [but] is not reasonably able to do so due to their disability."[53]

52. Those deemed to have extra bedrooms will have their support for housing costs reduced by a fixed percentage of their eligible rent (the full assessed reasonable rent for their property) regardless of the level of support for housing costs they receive. The reduction rates are:

·  Where "under occupying" by one bedroom—14% of eligible rent

·  Where "under occupying" by two or more bedrooms—25% of eligible rent.[54]

53. The Government has commissioned an independent evaluation of the effect of the policy across Great Britain. The consortium will present initial findings in 2014 and a final report in 2015.[55]

The regional impact of the SSSC

54. The latest estimates show that around half a million households are affected by the SSSC. However, the impact varies significantly across the regions of the UK.

WALES

55. Wales, with its large rural population, is experiencing the largest proportional impact from the SSSC: 46% of working-age social housing tenants in Wales are affected.[56] Rural areas in particular are known to have lower amounts of social housing, and the available stock tends to be larger sized accommodation. Community Housing Cymru reported that, while many of the 40,000 affected Welsh tenants wished to downsize to avoid the SSSC deduction, there are not enough smaller properties available for these tenants. Welsh housing associations were concerned that rural tenants would have no choice but to move to different areas if they wished to downsize in response to the SSSC.[57]

SCOTLAND

56. Scotland, like Wales, has relatively few smaller properties and is therefore experiencing a significant impact from the SSSC with 82,500 households affected. The Convention of Scottish Local Authorities (CoSLA) told us that around 68,500 Scottish households would require a one-bedroom reduction and around 14,000 would require a two-bedroom reduction to avoid losing any Housing Benefit. However, according to the Scottish Government, there are only around 21,657 one-bedroom properties and 27,791 two-bedroom properties in total available for rent in the social sector.[58]

57. The Scottish Government pledged that it would use DHP funds to cover the entire shortfall in Housing Benefit arising from the SSSC in Scotland. Central Government allocated £15 million in DHP funding to Scotland in 2013-14. The Scottish Government added £20 million to DHP from its own budgets, bringing the total DHP fund up to £35 million. In order to fulfil its pledge, it would need to add another £15 million to the DHP fund, bringing it up to £50 million. However, central Government has capped the amount of top-up that local authorities can add to their DHP to 2.5 times the original allocation. This cap will need to be lifted in order to allow the additional £15 million to be added. The Scottish Government has requested that the cap be lifted but DWP has not yet responded to the request.[59] There is ongoing debate in Scotland over using other mechanisms to close the funding gap.

ENGLAND

58. Households in London and the South of England are proportionately less affected by the SSSC than those in the North, as there are fewer households that are deemed to be "under-occupying" (overcrowding of households is a greater issue in the South). The North of England, which has more rural areas and areas with lower concentrations of social housing, contain a greater proportion of households affected by the SSSC. The annual financial loss to households in the three most affected areas in the North of England is £160 million compared to £30 million in the South East of England.[60]

59. The Industrial Communities Alliance provided a table showing the regional impact of the SSSC (based on the initial estimate of the numbers of households affected):

Table 2: Impact of the SSSC by region[61]
  Housing Benefit: Under-occupation
  No of
h'holds affected
Estimated
loss
£m p.a.
No. of h'holds affected
per 10,000
Financial loss per working age adult £ p.a.
North East 50,000 30 44020
North West 110,000 80 37018
Yorkshire/Humber 80,000 50 36016
London 80,000 90 24015
Scotland 80,000 50 34014
Wales 40,000 20 31013
West Midlands 60,000 40 26011
East 50,000 40 21011
East Midlands 40,000 20 2109
South West 30,000 20 1307
South East 40,000 30 1106
 
Great Britain 660,000 490
260
10

The SSSC and housing stock

60. Housing stock differs from area to area depending on when it was built. Carol Matthews of Riverside Housing Group explained that larger properties predominate in some areas where social housing stock was built in the 1930s, 1940s and 1950s when requirements were for "larger family accommodation." Andrew Fraser of NHS Health Scotland cited the case of a family in his area, living in an estate built in the 1950s in which every property has three bedrooms.[62] In some cases, local authorities and providers have deliberately "under-occupied" social housing. Between 1993 and 2009, 40% of registered provider two-bedroom homes outside London were allocated to single people.[63] Affinity Sutton Group explained:

    In some areas, particularly in the north of England, we have historically allowed under-occupation of three and four bedroom houses. This is both because this is the predominant property type and also because we cannot meet the large demand for two bedroom homes. Additionally, we try to actively manage levels of child density, thereby allowing families to grow into a property and help with community stability and cohesion. Most local authority allocation schemes allowed for under occupation by one bedroom for the same reasons.[64]

61. Social housing providers emphasised that it was not straightforward to downsize tenants, mainly because of the lack of smaller properties.[65] The LGA explained that it was difficult to move affected tenants, not just because of the lack of smaller properties but because there was a general lack of housing stock. [66]

62. Newcastle City Council commented that "re-housing people affected by the SSSC presents a huge challenge." 3,233 of its tenants were on the waiting list for a one-bedroom property but only around 800 one-bedroom properties were becoming available each year (including bedsits).[67] The West London Housing Partnership said that, while priority is given to social tenants who are downsizing, only 234 of the 4,000 households impacted by the SSSC had been able to move in the preceding year, indicating that the majority "will be stuck for many years being penalised for something they cannot swiftly change."[68]

63. Professor Steve Wilcox also made the point that social housing tenants do not necessarily choose the size of the property that they live in, rather it is:

    [...] essentially allocated, rather than selected [...] They are not in full control of what they are allocated, but the degree of influence varies from area to area. Equally, the demand for transfers and the pressures on stock will vary from one part of the country to another.[69]

64. We understand the Government's wish to use social housing stock more efficiently and to reduce overcrowding. However, the SSSC so far seems to be a blunt instrument for achieving this. In many areas there is insufficient smaller social housing stock to which affected tenants can move, meaning that they remain in housing deemed to be too large and pay the SSSC. This is likely to be causing financial hardship to a significant number of households. We recommend that the Government carries out a detailed assessment of the available social housing stock in each local authority area. If there is clear evidence that there is insufficient smaller housing stock and that those who are willing to move cannot do so, the Government should consider allowing affected households more time to find ways of adjusting to the SSSC before the reduction in benefit is applied. Where a household is under-occupying but there is no suitable, reasonable alternative available, the SSSC reduction in benefit should not be applied.

65. To support the policy intent of better and more innovative use of social housing stock, and as a further measure to ease the burden on affected tenants and providers, we recommend that the Government allocate funding to a national scheme in which all providers of social housing can share information about their available housing stock; the stock needed by tenants on housing waiting lists; and those households interested in mutual exchange.

SSSC policy design

66. Some witnesses believed there were problems with the Government's assessment of the amount of space families required. Community Housing Cymru and Professor Wilcox both made the point that, within social housing, bedrooms are generally designed as either one-bed-space or two-bed-space rooms, and that many social sector properties contain rooms which have only one-bed-space. These are specifically designed to accommodate only one child. They were concerned that, as a result of the policy, some families are essentially being expected to fit two children into a bedroom designed to contain a single child. Carol Matthews of Riverside told us that bedrooms classified as single by the local authority were being classified as double bedrooms under the SSSC regulations.[70]

67. Professor Wilcox explained that current social housing stock had been built with a particular idea of how much accommodation was suitable for families, in which an extra room for a household was not necessarily considered to be "under-occupying". The number of rooms allowed under the SSSC was similar to that thought suitable according to pre-Second World War environmental health standards, and was no longer applicable to modern health and social standards. Riverside pointed out that the Department for Communities and Local Government (DCLG) bedroom standard more closely resembles the ones used by social housing providers. Moving the SSSC to the DCLG standard would make the application of the policy simpler and free up enough homes to be able to deal with overcrowding.[71]

68. Newcastle City Council questioned whether the SSSC policy was likely to succeed in encouraging better use of social housing stock. It pointed out that in Newcastle overcrowding was not a significant issue with only 1% of households on the housing register in a preferential category because of overcrowding, compared to 4% classified as being in particular need because of welfare reform. It cited research which found that Newcastle's social housing market was typical of the wider region and it suggested that it was therefore unlikely that moving tenants to neighbouring authority areas would constitute a solution.[72] Councillor McCarty made the point that the SSSC had actually led to very few over-crowded families being rehoused.[73]

69. We are concerned that the number of bed-spaces per bedroom is not taken into account when assessing whether people are considered to be "under-occupying" within the regulations governing the SSSC policy and that, therefore, in some cases, two children are being expected to share a room that was designed for one child. We recommend that the Government use the Department for Communities and Local Government standard of bed-spaces rather than the number of bedrooms in order to determine whether a household is under-occupying under the SSSC.

The SSSC and people with disabilities

70. DWP originally estimated that in around 63% of affected households either the claimant or their partner would have a disability (as defined under the Disability Discrimination Act).[74] Witnesses estimated that 60-70% of affected households in England and 80% of affected households in Scotland contain someone with a disability.[75]

71. Witnesses were particularly concerned about the impact on the estimated 100,000 affected households who live in properties which have been adapted or were purpose built to accommodate the tenant's needs arising from their disability. Housing associations argued that moving from an adapted property was not practical or cost-effective for this group of tenants because of the cost incurred in refitting the aids and adaptations in a new property. The National Housing Federation told us that the average grant awarded to provide aids and adaptions was £6,500. Scope pointed out that, for many disabled people, moving home was problematic: people with mental health conditions "find the thought of moving very distressing"; and people with physical disabilities "will find packing and moving house impossible, and hiring someone to help, too expensive." [76]

72. Witnesses pointed out that there was a serious shortage of suitable properties, or ones which could be easily adapted, for those with mobility difficulties. Habinteg housing association told us that people with disabilities whose circumstances meant they were willing and able to move might still be compelled to wait up to 10 years for a suitably accessible property, meaning affected tenants could be forced into a situation where they would need to fund the extra housing costs themselves for up to 10 years.[77]

73. In response to a Court of Appeal judgement in May 2012 in relation to the Local Housing Allowance size criteria, households containing a child with a severe disability which means they are unable to share a bedroom were exempted. The Government issued guidance in March 2013 which made clear that the exemption also applies to the SSSC. It states that:

    When a claimant says that their children are unable to share a bedroom, it will be for LAs to satisfy themselves that this is the case, for example, a claim is likely to be supported by medical evidence and many children are likely to be in receipt of Disability Living Allowance (DLA) for their medical condition. In addition LAs must consider not only the nature and severity of the disability, but also the nature and frequency of care required during the night, and the extent and regularity of the disturbance to the sleep of the child who would normally be required to share the bedroom. In all cases this will come down to a matter of judgement on facts of each individual case.[78]

THE SSSC AND CARERS

74. Under the SSSC policy an extra room is allowed for "a carer (or team of carers) providing overnight care." This does not include part-time carers; nor carers who are also the partner of the person for whom they provide care, who are expected to share a room with the person to whom they provide care. Carers UK believed that it was "inconsistent and inequitable" that an extra room was not permitted for carers who care for their disabled partner. It pointed out that some carers who are also partners may be unable to share a room because of the condition of their partner or because of the equipment required to assist the disabled person, which may be noisy or cumbersome. It stressed that it was important for carers to have a separate bedroom so that they can avoid disturbed sleep and continue to provide care. It also gave the examples of people with disabilities needing an extra room to store oxygen equipment, dialysis machines or for lifts.[79]

75. Professor Wilcox argued that it made more sense to exempt people with disabilities from the SSSC. The Coalition of Care and Support Providers in Scotland (CCPS) specifically recommended that people with adapted homes or couples who cannot share a room because of disability be exempt. Several witnesses believed that people in receipt of Personal Independence Payment (PIP) and Disability Living Allowance (DLA) should be exempted from the SSSC. Surrey Welfare Rights Unit believed that people who needed carers who, even occasionally, required their own room, should be exempt.[80]

76. The Government told us that it had no plans at present to exempt adults with disabilities from the SSSC, and that it was more interested in ensuring that DHPs were structured in a way which provided support to people with disabilities, especially those in "heavily adapted homes".[81] However, as discussed in greater detail in Chapter 7, it can be difficult for some people with disabilities to access DHPs, especially in areas where local authorities are taking disability benefits into account in the means test for DHPs.

77. We note that the SSSC is affecting many people with disabilities who have adapted homes or who need a spare room to hold medical equipment or to accommodate a carer. We are deeply concerned that the policy is causing severe financial hardship and distress to people with disabilities, many of whom will not easily be able to move. We do not believe that Discretionary Housing Payments are able to provide effective support to these households because of their short-term and temporary nature, the variability in award and the distress that having to re-apply can cause to affected households. We recommend that disabled people living in a home that has been significantly adapted for them should be exempt from the SSSC. We also recommend that the Government exempt from the SSSC households which contain a person who is in receipt of the higher level mobility or care component of Disability Living Allowance (DLA) and the equivalent in Personal Independence Payment (PIP).

78. If the Government is unwilling to use DLA and PIP entitlement to establish a right to an exemption from SSSC for disabled people, then we recommend that it extend to adults the exemption already applicable to households containing disabled children who are unable to share a room because of their severe disabilities, as assessed by local authorities. This exemption should include those whose disability means that a room is required for medical equipment, or for a carer, including a partner who is also a carer, and part-time carers.

The impact of the SSSC on affected tenants

79. Witnesses were concerned that households affected by the SSSC were experiencing financial hardship. Surrey Welfare Rights Unit described the SSSC as having had an "unprecedented negative impact on some tenants" who were "forced into rent shortfalls." Steve McIntosh of Carers UK reported that, of the affected families who were paying the shortfall in Housing Benefit, 75% were cutting back on food or heating and that tenants who were not covering the costs were accruing debt or arrears. [82] StepChange Debt Charity made a similar point.[83] Z2K was concerned by the Government's assertion that people could easily make up their SSSC reduction through increasing work by two or three hours. It pointed out that, because of tapers to Housing Benefit and Council Tax Reduction, people may in some cases need to work an extra 12 hours or more in order to make up the shortfall, an option which may not be available to all affected claimants.[84]

Steps by housing associations to mitigate the impact of the SSSC

80. Many housing associations told us that they had been working to mitigate the impact of the SSSC on their tenants and on their own budgets by:

·  investing in "awareness raising" among tenants about the benefit reforms and how they might be affected.

·  working with tenants to improve their job readiness.

·  increasing the number of welfare benefits advisers and the provision of debt and money advice services.

·  offering financial assistance to those wishing to downsize.

·  use of mutual exchange and home swapping services.[85]

81. Some housing associations and local authorities reported getting to know tenants better and building better working relationships with them as a result of the increased focus on engagement. Better relationships increased the likely success of interventions around work, moving or applying for the full range of available benefits.[86]

82. Witnesses agreed, however, that for many affected households there were few options because of lack of availability of alternative housing, inability to find work (or the right kind of work) or disability.[87]

83. Official statistics show that the numbers of affected claimants dropped from 547,000 in May 2013 to just under 500,000 by November 2013. However, the data do not show the reasons for the reduction. Some of the reduction could be related to changes in household structure, moving house, entering work, or increasing hours. Other reductions could be as a result of claimants ceasing to claim because their entitlement was reduced to zero, or to such a low level that they decided to stop claiming, or because they were already in the process of moving. [88]

SAVINGS FROM THE SSSC AND CLAIMANT BEHAVIOUR

84. The Government expected to save around £930 million over two years from the SSSC (in present value), a projection based on multiplying the average penalty by the estimated number of affected households. [89]

85. The Centre for Housing Policy and the Institute for Fiscal Studies made the point that these savings would only be realised if claimants responded to the policy by increasing hours or entering work (and thereby making up the shortfall in their Housing Benefit). If claimants responded to the policy by moving to a smaller property or taking in a lodger the full level of savings expected from the policy may not be realised.[90]

86. Organisations representing housing associations pointed out that, while the welfare reforms may save central Government money, costs are being passed on to local authorities, housing associations and voluntary organisations, who are incurring extra costs through rent arrears, transitional arrangements and supporting affected tenants.[91] Riverside Housing Group set out some of the extra costs to local authorities and other agencies:

·  increases in DHP funding;

·  the costs of fitting aids and adaptions for disabled tenants who move;

·  the cost to housing associations of rent arrears, re-let times, rent collection, tenant support and loss of development capacity; and,

·  costs to public services of helping tenants cope with debt, homelessness and health needs.

87. It believed that, based on this work, there was "a powerful case" for further scrutiny of the DWP's savings estimate".[92] The Chartered Institute of Housing agreed that there was "evidence of 'cost shunting' between national government budgets and from national government to local authorities and voluntary organisations."[93]

88. We recommend that the Government produce, by March 2015, a full cost-effectiveness analysis of the SSSC policy, taking into account the funding for Discretionary Housing Payments and the additional costs incurred by local authorities and social housing providers as a result of the SSSC, to assess the overall impact of the policy on the public purse.

THE IMPACT OF THE SSSC ON INVESTMENT IN SOCIAL SECTOR HOUSING

89. The National Housing Federation predicted that around 17,500 fewer homes across England may be built per year as a result of the diversion of spending by housing associations. It suggested that the Government has also been providing less funding for building social sector homes because of the rise in the Housing Benefit bill (resulting from high unemployment, wage stagnation and rent rises in the private sector). It argued that social housing providers need support from Government to build more affordable homes and that increased home building would ultimately reduce the Housing Benefit bill as more claimants would then be able to rent in the social sector rather than the more expensive private sector.[94]

90. Riverside calculated that the combined impact of the welfare reforms, including Universal Credit, could, in the worst case scenario, lead to a loss for them of £22 million over five years—an annual net loss of around £4.3 million. It calculated that this would reduce its ability to build new homes by around 500 properties.[95]

91. We note that, as a result of the SSSC and other reforms, local authorities and housing providers are having to provide extra support to affected tenants, and are also having to invest additional resources in chasing arrears, dealing with evictions and managing re-allocations. We are concerned that this diversion of resources is having a detrimental effect on local authority and housing provider budgets and the ability of providers to build social housing. We recommend that the Government consider allocating extra funding to social housing providers in areas where the additional costs arising from the SSSC are identified as significant, to mitigate the impact and ensure that their ability to build new social housing is not compromised.


52   DWP, Impact Assessment- Housing Benefit: Under occupation of social housing, June 2012; DWP Press Release, Housing Benefit: data published on reforms to restore fairness, 13 November 2013; DWP, Housing Benefit caseload statistics: December 2013, February 2014 Back

53   Explanatory Memorandum to the Housing Benefit And Universal Credit (Size Criteria) (Miscellaneous Amendments) Regulations 2013 No. 2828 Back

54   DWP, Impact Assessment- Housing Benefit: Under occupation of social housing, June 2012 Back

55   DWP (HCT 08) para 4.5, the consortium is made up of Ipsos MORI, Cambridge Centre for Housing and Planning Research and the Institute for Fiscal Studies Back

56   Welsh Affairs Committee, Second Report of Session 2013-14, The impact of changes to housing benefit in Wales, HC 159, p 3 Back

57   Community Housing Cymru (HCT 46) paras 10 & 11 Back

58   Scottish Federation of Housing Associations (HCT 49) paras 5.3.1-5.3.2; Convention of Scottish Local Authorities (HCT 53) para 14 Back

59   Inside Housing "Freud and IDS stonewalling bedroom tax fund request" 11 March 2014; Inside Housing "Scotland pledges to meet full cost of bedroom tax" 3 February 2014; House of Commons Library Standard Note, Under-occupation of social housing: Housing Benefit entitlement, 24 February 2014, SN/SP/6272 Back

60   DWP, Impact Assessment- Housing Benefit: Under occupation of social housing, June 2012, Pp. 10, 18 Back

61   Industrial Communities Alliance (HCT 21) p 4 Back

62   Oral evidence taken on 15 January 2014, Q330 Back

63   Homes and Communities Agency What, where and for whom have Registered Providers been building between 1989 - 2009 May 2011 Back

64   Affinity Sutton (HCT 23) para 2.8 Back

65   Oral evidence taken on 04 December 2013, Qq99-101 Back

66   Oral evidence taken on 18 December 2014, Q227 Back

67   Newcastle City Council (HCT 48) para 7 Back

68   West London Housing partnership (HCT 38) section 5 Back

69   Oral evidence taken on 06 November 2014, Q54  Back

70   Community Housing Cymru (HCT 46) para 9; Oral evidence taken on 06 November 2014, Q56; Oral evidence taken on 04 December 2013, Q113 Back

71   Oral evidence taken on 06 November 2014, Q54; Oral evidence taken on 04 December 2013, Q137 Back

72   Newcastle City Council (HCT 48) paras 8&9 Back

73   Oral evidence taken on 18 December 2014, Q218 Back

74   HC Deb, 21 November 2013, col 1021w. The numbers affected by the SSSC have since been revised to 547,000. Back

75   Scope (HCT 45) paras 6.2; Citizen's Advice Scotland, Voices from the frontline: The Bedroom Tax and disabled people, November 2013; Oral evidence taken on 29 January 2014, Q418 Back

76   National Housing Federation (HCT 31) para 6.3; Chartered Institute of Housing (HCT 63) para 1.12; Placeshapers (HCT 24) para 4.3; Scope (HCT 45) para 6.4 Back

77   Habinteg (HCT 18) para 3.1 Back

78   DWP Housing Benefit and Council Tax Benefit: Urgent Bulletin (HB/CTB U2/2013) 12 March 2013 Back

79   Carers UK (HCT 76) para 2.1, Oral evidence taken on 15 January 2014, Q319 Back

80   Oral evidence taken on 06 November 2014, Q60; Oral evidence taken on 04 December 2013, 160; Oral evidence taken on 18 December 2014, 222-223; Oral evidence taken on 29 January 2014 420; Coalition of Care and Support Providers in Scotland (HCT 22) paras 3.8-3.9 Back

81   Oral evidence taken on 12 February 2014, Q565 Back

82   Surrey Welfare Rights Unit (HCT 30) para 3; Oral evidence taken on 15 January 2014, Q321 Back

83   Oral evidence taken on 29 January 2014, Qq409, 411 Back

84   Zacchaeus 2000 Trust (HCT 35) paras 25-26 Back

85   Peabody Trust (HCT 01) p. 1; Habinteg (HCT 18) para 4.1.4; Aragon Housing Association (HCT 81) p. 2; Community Housing Cymru (HCT 46) para 14; Home Group (HCT 19), para 7 Back

86   East Kent Housing (HCT 03); Caerphilly County Borough Council (HCT 20) para 2.1 Back

87   Oral evidence taken on 18 December 2014, Q185; Oral evidence taken on 29 January 2014, Q411 Back

88   DWP, Impact Assessment- Housing Benefit: Under occupation of social housing, June 2012; DWP Press Release, Housing Benefit: data published on reforms to restore fairness, 13 November 2013; DWP, Quarterly Statistical Summary, 13 November 2013; DWP, Housing Benefit caseload statistics: December 2013, February 2014,  Back

89   DWP, Impact Assessment- Housing Benefit: Under occupation of social housing, June 2012; University of York, Centre for Housing Policy, Testing DWP's assessment of the impact of the social rented sector size criterion on housing benefit costs and other factors, October 2013, p. 11 Back

90   DWP, Impact Assessment- Housing Benefit: Under occupation of social housing, June 2012, Oral evidence taken on 06 November 2014, Q57; University of York, Centre for Housing Policy, Testing DWP's assessment of the impact of the social rented sector size criterion on housing benefit costs and other factors, October 2013, p. 11 Back

91   Scottish Federation of Housing Associations (HCT 49) paras 5.1.3 and 5.1.7  Back

92   The Riverside Group (HCT 33) paras 3.5 & 3.6 Back

93   CIH, Haringey Council, Experiences and effects of the benefit cap in Haringey, October 2013, page 5 Back

94   National Housing Federation (HCT 31) paras 2.2, 3.2 Back

95   The Riverside Group (HCT 33) para 2.4 Back


 
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