Scottish Social Housing Charter – a Consultation

Housing, Regeneration and Planning An AnalysisOfResponses Charter -AConsultation Scottish SocialHousing

SCOTTISH SOCIAL HOUSING CHARTER – A CONSULTATION

AN ANALYSIS OF RESPONSES

John Scott, Steven Reid and Katy MacMillan ODS Consulting

Scottish Government Social Research 2012

This report is available on the Scottish Government Social Research website (www.scotland.gov.uk/socialresearch) only.

The views expressed in this report are those of the researcher and do not necessarily represent those of the Scottish Government or Scottish Ministers.

© Crown copyright 2012 You may re-use this information (not including logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view this licence, visit http://www.nationalarchives.gov.uk/doc/open-government-licence/ or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or e-mail: [email protected]

CONTENTS

EXECUTIVE SUMMARY

1. INTRODUCTION ...... 1 2. OVERVIEW OF RESPONSES ...... 3 3. GENERALISSUES/COMMENTS ON THE DRAFT CHARTER...... 5 4. RESPONSES TO THE CONSULTATION QUESTIONS ...... 12

LIST OF TABLES Table 2.1: Distribution of Responses to the draft Scottish Social Housing Charter Consultation Table 4.1: Responses to Q.1 by Stakeholder Group Table 4.2: Responses to Q.2a by Stakeholder Group Table 4.3: Responses to Q.2b by Stakeholder Group Table 4.4: Responses to Q.3a by Stakeholder Group Table 4.5: Responses to Q.3b by Stakeholder Group Table 4.6: Responses to Q.4a by Stakeholder Group Table 4.7: Responses to Q.4b by Stakeholder Group Table 4.8: Responses to Q.5a by Stakeholder Group Table 4.9: Responses to Q.5b by Stakeholder Group Table 4.10: Responses to Q.6a by Stakeholder Group Table 4.11: Responses to Q.6b by Stakeholder Group Table 4.12: Responses to Q.7a by Stakeholder Group Table 4.13: Responses to Q.7b by Stakeholder Group Table 4.14: Responses to Q.8a by Stakeholder Group Table 4.15: Responses to Q.8b by Stakeholder Group Table 4.16: Responses to Q.9a by Stakeholder Group Table 4.17: Responses to Q.9b by Stakeholder Group Table 4.18: Responses to Q.10a by Stakeholder Group Table 4.19: Responses to Q.10b by Stakeholder Group Table 4.20: Responses to Q.11a by Stakeholder Group Table 4.21: Responses to Q.11b by Stakeholder Group Table 4.22: Responses to Q.12a by Stakeholder Group Table 4.23: Responses to Q.12b by Stakeholder Group Table 4.24: Responses to Q.13a by Stakeholder Group Table 4.25: Responses to Q.13b by Stakeholder Group Table 4.26: Responses to Q.14a by Stakeholder Group Table 4.27: Responses to Q.14b by Stakeholder Group Table 4.28: Responses to Q.15a by Stakeholder Group Table 4.29: Responses to Q.15b by Stakeholder Group Table 4.30: Responses to Q.16a by Stakeholder Group Table 4.31: Responses to Q.16b by Stakeholder Group Table 4.32: Responses to Q.17 by Stakeholder Group

ANNEXES

Annex One: Consultation Recipients Annex Two: Consultation Respondents

EXECUTIVE SUMMARY

Introduction

The report provides an analysis of responses to the Scottish Government’s consultation on the draft Scottish Social Housing Charter. The Charter is introduced by the Housing (Scotland) Act 2010 and will set the outcomes that social landlords should be achieving for tenants and other customers.

The draft Charter presents outcomes and standards across five key performance areas: the customer/landlord relationship; quality of housing and the environment; access to housing and support; getting good value for rents and service charges; and Gypsies/Travellers and other customers.

Overview of the response

There were 248 responses to the consultation (at the time this analysis was undertaken). The largest group of responses (96 - 39%) came from Registered Social Landlords (RSLs). The next largest grouping was tenant and resident groups (74 – 30%). The other main groups of respondents were local authorities (24 – 10%), private individuals (24 – 10%) and representative/membership/voluntary organisations (16 – 6%). There were also responses from equality and care organisations (9 – 4%), and public/statutory bodies (5 – 2%).

The Scottish Government also set up a dedicated webpage for the consultation. Six responses (and six supplementary comments) were posted on the Charter website.

Summary of responses

• Almost all respondents welcomed the principle of a Scottish Social Housing Charter and felt that it was a positive step forward for social housing in Scotland. • Most respondents felt that the themes covered within the Charter were sensible, and covered the core areas of social landlord service delivery. • Generally, local authorities, tenant and resident groups and private individuals indicated their support to the proposed outcomes and standards. However, in a number of cases their support was qualified. • Respondents – including RSLs, local authorities and tenant and resident groups – raised concerns about the number of outcomes and standards included within the Charter. There was particular concern that the number of outcomes and standards had more than doubled between the first and second consultation on the Charter. • Many respondents felt that it would be possible to cover the principles of the outcomes through considered redrafting – removing duplication and repetition. • A significant theme among respondents was that the Charter outcomes were not clearly drafted, and that there was a mix of outcomes, standards and processes without any clear distinction between these. • Respondents – particularly local authorities, RSLs and representative bodies – had significant concerns about how the Charter outcomes would be

monitored, measured and enforced. Some felt that monitoring requirements were disproportionate and at odds with the aim of creating a regulatory regime that minimises the burden on good landlords. • Tenant and resident groups were broadly supportive of the outcomes and standards covered in the Charter. Some felt that the Charter could be worded more strongly and could provide stronger safeguards in relation to tenant participation, community consultation, and effective management and governance. • RSL and local authority respondents felt that tenant satisfaction featured too prominently as a measure of achievement of the outcomes and standards. Many suggested that greater recognition should be given to the wide range of potential measures or indicators. • Many social landlords felt that it was important that tenant responsibilities, as well as landlord responsibilities, were reflected in the Charter. • Another concern among social landlords was that some Charter outcomes were outwith the remit and sole control of landlords. This was seen as having the potential to create confusion and cause difficulty monitoring and holding landlords to account. • A number of respondents – mainly equalities organisations – felt that the Charter should be more explicit about requirements in relation to equality and diversity. • The Scottish Federation of Housing Associations (SFHA), Glasgow and West of Scotland Forum of Housing Associations (GWSF) and the Chartered Institute of Housing (CIH) Scotland set out alternative proposals for the Scottish Social Housing Charter. Each of these proposed a significant reduction in the content of the Charter. A total of 38 RSLs and local authorities indicated that they agreed with one of these three responses.

1. INTRODUCTION

About this report

1.1 This report provides an analysis of responses to the Scottish Government’s consultation on the draft Scottish Social Housing Charter. It gives a detailed analysis of the responses to the consultation questions and provides an analysis of the views of particular groups, highlighting trends and issues where appropriate.

Background to the consultation

1.2 The Scottish Social Housing Charter is introduced by the Housing (Scotland) Act 2010. The Act requires Ministers to consult on and set the standards and outcomes that social landlords should be achieving for tenants and other customers. The Charter is the document that will set out these standards and outcomes. It forms the basis for the new Scottish Housing Regulator (SHR) to monitor and assess the performance of social landlords in Scotland.

1.3 Following a programme of stakeholder consultations in 2010 and publication of a Charter discussion paper in February 2011, the Scottish Government launched a formal consultation on the draft Scottish Social Housing Charter in August 2011. The consultation document explains the background, purpose and scope of the Charter. The draft Charter presents standards and outcomes across five key performance areas: the customer/landlord relationship; quality of housing and the environment; access to housing and support; getting good value for rents and service charges; and Gypsies/Travellers and other customers.

1.4 The consultation document was published on 1 August 2011 and the consultation period ended on 1 November 2011.

1.5 It was publicised widely. A copy was sent to all local authorities, RSLs, Registered Tenant Organisations, and other stakeholders. The Scottish Government also set up a dedicated webpage for the consultation. This provided information on the draft Charter and gave people the opportunity to post comments. These comments are considered in this report. A full list of consultation recipients is given as Annex One. A total of 248 responses were received. A full list of respondents is given as Annex Two.

1.6 The consultation included 33 questions in relation to the Charter. Respondents were able to provide either an open response or complete the consultation questionnaire offering systematic responses to each of the consultation questions. At the end of the consultation questionnaire respondents had the opportunity to give general or additional comments.

1 1.7 The analysis was undertaken using a response matrix. Respondents were categorised into stakeholder groups and responses were fed into the matrix in accordance with the answer to the consultation question. General and additional points that did not relate to the questions were fed into a separate section of the matrix and treated manually.

1.8 Some respondents chose not to answer the consultation questionnaire. These responses were read thoroughly and where the respondent directly answered any of the questions, the comments were fed into the appropriate place on the matrix. Substantive comments were treated separately as with other responses.

2 2. OVERVIEW OF RESPONSES

Introduction

2.1 This section gives an overview of the responses that were received to the consultation. It considers who the responses came from, who was not represented in the response, and gives general comments on the responses.

Who replied to the consultation?

2.2 The consultation was issued to 874 organisations and individuals including housing organisations, local authorities, tenant and resident groups and voluntary organisations.

2.3 A total of 248 responses have been considered in this analysis of responses. These came from a range of organisations and 24 private individuals. A number of responses were submitted later than the original consultation deadline and have been considered. However, some responses were submitted too late to be included in the formal analysis – these responses have been considered separately by Scottish Government officials.

Table 2.1: Distribution of Responses to the draft Scottish Social Housing Charter Consultation Type Total received % of responses Registered Social Landlords (RSLs) 96 39 Tenant and resident groups 74 30 Local authorities 24 10 Private individuals 24 10 Representative/membership/voluntary 16 6 organisations Equality and care organisations 9 4 Public and statutory bodies 5 2 Total 248 100

2.4 As Table 2.1 shows, the largest group of responses (96 - 39%) came from Registered Social Landlords (RSLs) this accounts for around half of RSLs in Scotland. The next largest grouping was tenant and resident groups (74 – 30%). This group included local Registered Tenant Organisations (RTOs) and tenant and resident associations as well as regional networks/federations. Twenty-four responses (10%) came from local authorities representing 75 per cent of Scotland’s councils. Another significant respondent group were private individuals, making up ten per cent of the response (24 responses). The remaining responses came from representative/membership/voluntary organisations (16 – 6%), equality and care organisations (9 – 4%), and public and statutory bodies (5 – 2%).

2.5 Some responses were submitted on a joint basis. For instance, the submission from Moray Council was based on tenant, landlord staff and elected members views. A joint response was submitted by Scottish Disability Equality Forum, Independent Living in Scotland and Inclusion Scotland; and

3 also by the Association of Local Authority Chief Housing Officers (ALACHO) and the Scottish Housing Best Value Network (SHBVN).

2.6 There was some sharing of responses. This was primarily members of the same representative body agreeing with that organisation’s response rather than pure ‘campaigning’ to influence the outcome of the consultation. Notably, 14 RSLs submitted the same response as the Glasgow and West of Scotland Forum of Housing Associations (GWSF). A further six RSLs submitted similar responses to GWSF, and two more indicated their support. Three RSLs and one tenant and resident group stated their support for the response submitted by the Scottish Federation of Housing Associations (SFHA) and two RSLs said that they supported the submission from the Chartered Institute of Housing (CIH) Scotland.

2.7 There was also some evidence of response sharing among some tenant and resident groups from the same area. Three private individuals submitted responses very similar to those of tenant and resident groups.

2.8 Six responses to the consultation were posted on the Charter website. These came from private individuals including tenants and housing professionals. There were also six comments made in response to the posts.

Who was not represented in the responses?

2.9 Responses came from a wide cross-section of organisations and individuals with an interest in the proposals. The total number of responses was larger than originally anticipated by the Scottish Government.

2.10 However, around half of RSLs and a quarter of local authorities (8) did not respond to the consultation. This may have been as a result of being content with the response made by a representative body.

The interpretation of quantitative and qualitative information

2.11 The background analysis used a quantitative approach to demonstrate how strongly different elements of the draft Charter were supported or opposed. Whilst this is a useful way to see the general opinion among respondents, it has not been relied on as the main method of analysing views and identifying key themes. Generally, we feel that the quantitative information should be treated with caution due to the different way respondents have answered the questionnaire (with, for example, respondents indicating their support or disagreement to a proposed outcome but then making similar comments about it). In addition, a number of respondents chose not to use the consultation questionnaire.

2.12 Because of these issues, a qualitative approach has been the main focus of the analysis, based on what people said and trends in views. This qualitative approach has allowed us to identify the key themes emerging from the consultation and particular areas of agreement and disagreement among respondent grouping.

4 3. GENERAL ISSUES/COMMENTS ON THE DRAFT CHARTER

Introduction

3.1 This section considers a number of general issues and comments in relation to the draft Charter that we have identified throughout the analysis. These were highlighted by a number of key respondents (and frequently referred to by other consultation respondents).

Purpose

3.2 Many respondents welcomed the Scottish Social Housing Charter and felt that it was a positive step forward for social housing in Scotland. Generally most tenant and resident groups, local authorities and private individuals supported the draft outcomes and standards in principle – but often suggested amendments. However, some RSLs questioned what the rationale was for the Charter, feeling that the existing performance standards for social landlords already provide a good framework.

3.3 Although the consultation paper outlines the intended purpose of the Charter, many still felt that the purpose was not clear. The main concern related to whether it was intended to be a statement of what tenants can expect from their landlord, or a wider framework for measuring and assessing the performance of social landlords.

“It does not give a coherent or logical sense of the Charter’s overall purpose or its guiding principles.” (Glasgow West of Scotland Forum of Housing Associations)

“We believe the purpose of the Charter is unclear. On one hand it looks like a list of standards for customers to assess landlords against. On the other it looks like a framework for landlords to self- assess to satisfy customers and the regulator on their performance.” (Castle Rock Edinvar HA)

3.4 A number of respondents indicated that they felt that the draft Charter was not workable as it currently stood, and would welcome considerable effort being put into restructuring and redrafting the Charter.

Number of outcomes and standards

3.5 Overall, most respondents felt that the themes covered within the draft Charter were sensible, and covered the core areas of social landlord service delivery. However, all respondent groupings – including RSLs, local authorities and tenant and resident groups – raised concerns about the number of outcomes and standards included within the draft Charter. There was concern that the number of outcomes and standards had more than doubled between the first and second consultation on the Charter.

3.6 Almost all RSLs and local authorities felt that the number of outcomes and standards was unmanageable, and that the focus should be on a smaller number of key outcomes. Tenant and resident groups had more varied views. While some – such as the Scottish Tenants Organisation – felt that it was important not to reduce the number of outcomes covered, others felt that the draft Charter was too long and needed to be concise.

“It would be possible to condense some of the outcomes yet still retain the quality required for a meaningful charter.” (Glasgow and Western Isles Regional Network)

3.7 Most felt that it would be possible to cover the principles of the outcomes through considered redrafting – removing the duplication or repetition which many felt occurred throughout the draft Charter.

Drafting an outcome

3.8 Many also felt that a clearer focus on outcomes – as distinct from standards or processes – would help to reduce the number of outcomes within the draft Charter. Respondents from across all groups felt that the draft Charter outcomes were not clearly drafted, and that there was a mix of outcomes, standards and processes without any clear distinction between these.

“Many of the things being presented as outcomes within the Charter are actually standards or ways of achieving the outcomes.” (Scottish Borders Tenants Organisation)

“We believe that there is a significant opportunity for the focus of the Charter to be sharpened on outcomes and move away from processes. Doing so could also assist in reducing its overall size.” (Scottish Housing Regulator)

3.9 Representative organisations such as COSLA and the Improvement Service highlighted the extensive work which has been undertaken nationally to develop clear outcomes accompanied by measurable indicators. It was felt that this expertise had not been drawn on in drafting the proposed Charter.

“...any measures should be linked firmly into Best Value 2 and Single Outcome Agreements, as a lot of research has gone into developing robust and realistic outcome indicators, and there is no point in developing a new parallel structure.” (COSLA)

Measuring outcomes and standards

3.10 Many respondents – particularly local authorities, RSLs and representative bodies – had significant concerns about how the Charter outcomes and standards would be monitored, measured and enforced. Most were aware of the simultaneous consultation being undertaken by the SHR, which set out proposals for how the Charter would be used to monitor and compare landlord

performance. However, many felt that having both consultations running at the same time made it very difficult to fully understand and comment on proposals for the Charter content and its monitoring.

3.11 One key concern about monitoring related to the drafting of its outcomes and standards. Many respondents felt that the outcomes and standards were not precise enough to allow their effective monitoring, with many of the outcomes being subjective and open to interpretation. Many highlighted that if the Charter is to be used for monitoring and comparing landlord performance, it needs to have clear, relevant and measurable outcomes and standards.

“To be effective the Charter outcomes require to be meaningful and measurable. Currently many of the outcomes are very broad, ambiguous and too narrowly focused on tenant satisfaction, that assessing compliance would be very difficult for the Scottish Housing Regulator.” (Tenants Information Service)

3.12 The SHR also highlighted that the number of the draft outcomes and standards and the lack of precision over some definitions would make it very challenging to develop a meaningful and manageable regulatory assessment and reporting framework. It suggested reducing the number of outcomes and standards, and sharpening the language used.

“Charter statements need to have a degree of clarity and precision to enable us to assess landlords’ progress consistently.” (Scottish Housing Regulator)

3.13 Many respondents felt that tenant satisfaction featured too prominently as a measure for whether outcomes and standards were being achieved. This was a particular issue for RSLs and local authorities – but was also raised by some tenant and resident groups. Respondents suggested that while tenant satisfaction was an appropriate and useful measure for some outcomes, it was overused and sometimes used inappropriately within the draft Charter. Many suggested that greater recognition should be given to the wide range of potential measures (or indicators) of whether a landlord is achieving an outcome or standard – including both qualitative and quantitative information sources.

“We suggest that the Scottish Government reconsiders how it can make the most appropriate use of tenant satisfaction in the Charter. It will be an important measure for us to use in determining landlords’ achievement of the Charter, as part of a basket of performance indicators and measures rather than an exclusive test. We would not place sole reliance on this to determine landlords’ compliance with any individual Charter outcome.” (Scottish Housing Regulator)

“Too much focus on tenant satisfaction, which is very important, but too difficult to measure.” (Balmoral Tenants and Residents Association)

“Satisfaction can and should be a measure against compliance with the Charter, but not an outcome in its own right.” (CIH Scotland)

3.14 Finally, where the Charter referred to ‘locally agreed standards’ many were unsure of what this meant and felt it needed further clarification. The use of the term ‘standards’ rather than ‘outcomes’ was confusing, and people did not understand if the local agreement was to take place at landlord, neighbourhood or local authority level. There was also some concern that these could not be measured and compared objectively and that they would lead to unequal service standards across Scotland. However, some did feel that there was a place for locally agreed standards, if the term was more clearly defined.

Impact on resources

3.15 Representative bodies such as Glasgow West of Scotland Forum of Housing Associations (GWSF), the Scottish Federation of Housing Associations (SFHA), the Association of Local Authority Chief Housing Officers (ALACHO) and the Scottish Housing Best Value Housing Network (SHBVN) felt that the Charter as drafted would lead to significant additional reporting and monitoring responsibilities being placed on social landlords. These were seen as “completely disproportionate” and at odds with the aim of creating a regulatory regime that minimises the burden on good landlords. Many respondents agreed with the views of their representative bodies on this matter.

“It will lead to significant additional costs for RSLs (and, in turn, tenants) in gathering the views of tenants and other customers.” (GWSF)

“The Charter as drafted contains 71 outcomes. This is too long, and will lead to burdensome, resource intensive and costly reporting requirements.” (SFHA)

3.16 Many felt that the increased regulatory burden contradicted the direction in which public services in Scotland were moving – quoting the principles of the Crerar Review and the Public Services Reform Act 2010. Others highlighted that it contradicted the draft Charter outcome of keeping rents as low as possible for tenants.

“[The] requirements represent a potentially significant additional resource burden on councils, particularly at a time when the national aim is to reduce the burden of regulation (as clearly stated in the Public Services Reform (Scotland) Act 2010).” (ALACHO and SHBVN joint response)

“It is also important that the Charter is shaped in such a way to reduce the regulatory burden on landlords rather than increase it” (The Moray Council)

3.17 A minority of tenant and resident groups, and their representative bodies, also raised concerns about resources.

“We are concerned that there will be an impact on front line services because of the staff time required to implement, monitor and self assess performance against the Charter.” (Eildon Tenants Organisation)

3.18 Tenants Information Service (TIS) also raised concerns about the impact on tenant volunteers, due to the strong focus on tenant participation and tenant satisfaction. It emphasised that often a small number of tenants actively become involved in participation opportunities, and that the Charter as drafted could place additional demands on already stretched tenant resources.

“Tenants are concerned about the additional workload which will be placed on a traditionally small pool of volunteers to become involved in self assessment and performance monitoring of landlord services.” (Tenants Information Service)

Landlord and tenant responsibility

3.19 Respondents raised concerns about the balance between landlord and tenants responsibilities within the draft Charter. Some social landlords felt that the draft Charter focused overly on tenant expectations, with the danger of some outcomes and standards raising tenant expectations beyond what they felt was reasonable.

3.20 The stated purpose of the Charter is to give a clear understanding to tenants and others what they can expect from a social landlord, and to provide the basis for the SHR to monitor and assess the performance of social landlords. However, many landlords felt that tenant responsibilities, as well as landlord responsibilities, should be reflected in the Charter – given that many outcomes would require tenants and landlords to work together for these to be achieved. Some – such as COSLA and the Improvement Service – suggested that some of the outcomes did not reflect moves towards community empowerment as promoted through the Christie Commission report on the future of public services.

“It is our view that social landlords cannot deliver outcomes to tenants and other customers, as they have to want their outcomes and help to deliver them.” (Improvement Service)

3.21 Another concern – again raised largely by RSLs and local authorities – was that some draft Charter outcomes and standards were outwith the remit and sole control of social landlords. Specific issues were raised in relation to the ‘estate management’ and ‘antisocial behaviour, neighbour nuisance and tenancy disputes’ outcomes. This was seen as having the potential to create confusion, and to cause difficulty monitoring and holding landlords to account when outcomes and standards may be outwith their control.

“Some draft outcomes set out expectations that are either entirely outwith an individual landlord’s control or dependent on the performance not only of the landlord but also of other bodies or, in some cases tenants.” (Scottish Housing Regulator)

3.22 Some RSLs and local authorities suggested that it would be useful to clarify within the Charter what is a statutory requirement, a regulatory requirement, a new requirement within the Charter, and an aspirational requirement.

Equality

3.23 The consultation specifically sought views on whether there should be a separate equalities outcome. A number of respondents – mainly equalities organisations – felt that the Charter should be more explicit about requirements in relation to equality and diversity. Many commenting on this issue felt that having a specific outcome or standard on equalities would focus the attention of landlords, tenants and regulators on this issue.

“We contend that there should be a specific outcome or standard for equality within the Scottish Social Housing Charter.” (Equality and Human Rights Commission)

3.24 Others highlighted the need to focus on certain equalities issues within the Charter – including the rights of children and young people; the principles of independent living; housing accessibility; inclusive communication; and hate crime (particularly within the ‘anti-social behaviour’ outcomes and standards).

Alternative models

3.25 The SFHA, CIH Scotland and GWSF set out alternative proposals for the Scottish Social Housing Charter. A total of 38 RSLs and local authorities indicated that they agreed with one of these three responses. Nine agreed with the SFHA response; six agreed with the CIH Scotland response; two agreed with both the SFHA and CIH responses; and 22 agreed with the GWSF response.

3.26 The SFHA response suggested reducing the Charter to a single page – with nine outcome statements covering communication and transparency; participation; allocations; rents and service charges; maintenance and housing quality; tenancy sustainment; estate management; anti-social behaviour and complaints. It also suggested three further outcome

statements, clearly marked as not applicable to all landlords, on homeless people; services for Gypsies/Travellers; and factoring. It also suggested a range of potential performance measures for each outcome.

3.27 CIH Scotland suggested reducing the Charter to have five sections covering – the customer/landlord relationship; quality of housing and the environment; access to housing and support; getting good value from rents and service charges; and owners and other customers. Within each section they proposed a series of outcomes statements. This would reduce the total number of outcomes to 37.

3.28 The GWSF response suggested reducing the Charter to have five overarching outcomes covering – the customer/landlord relationship; quality of housing; neighbourhood and community; access to housing and support; and getting good value from rents and service charges. It provided draft text for each outcome. It then suggested that the remaining ‘outcomes’ within the Charter are clearly described as ‘standards’ – and clear measures of each standard are provided. These measures could include tenant satisfaction, but also other evidence. The principle behind these changes was to reduce the length of the Charter; to be clearer about the distinction between outcomes, standards and measures; and to reduce the reporting burden for social landlords.

3.29 The GWSF also proposed that RSLs would report annually to the SHR on the overarching outcomes and to tenants and other customers on supporting standards (and accompanying indicators) agreed according to local priorities.

Timescales

3.30 A small number of respondents raised issues about the timescales for implementing the Charter. Some social landlords were concerned that the Charter would be implemented from April 2012 onwards, leaving limited time for development and awareness raising of the SHR’s approach to monitoring Charter outcomes and standards. The Council of Mortgage Lenders (CML) was particularly concerned that there would be no testing or early review process following the introduction of the Charter. Many respondents felt that the Charter required to be monitored earlier than five years from its implementation.

“It is our view that five years is too long before the first review of the Charter.” (SFHA)

“There may be some merit in piloting the Charter with a limited number of social landlords.” (Council of Mortgage Lenders)

4. RESPONSES TO THE CONSULTATION QUESTIONS

Introduction

4.1 This section analyses the responses received to each of the consultation questions, in terms of a quantitative overview and summary of the key points made by respondents.

4.2 Where the questions were split into two parts, we have treated the responses to both parts together in this report. This was due to the significant cross-over in the responses to the questions. For example, many respondents stated that they disagreed with an outcome or standard because they felt it was unclear or vague and needed rewording.

4.3 Throughout the responses we found there to be a general pattern among respondent groupings (with the exception of Questions 6, 15 and 17), with a large majority of tenant and resident groups, local authorities and private individuals supporting the draft outcomes and standards, and RSLs and representative bodies disagreeing with them.

4.4 However, as we have highlighted earlier, this should be treated with some caution as we found a number of respondents qualified their responses. Some respondents expressing support or disagreement for a particular outcome shared similar views when their qualifications were taken into account. In some cases qualifications were contained in general comments received, in other cases they were specific to the particular question.

Question 1: Have we missed out any areas that the Charter should cover? If so please tell us.

Table 4.1: Responses to Q.1 by Stakeholder Group Type No Yes Neither/ No (areas Both Response missing) Registered Social Landlords (RSLs) 15 48 18 15 Tenant and resident groups 24 26 7 17 Local authorities 4 11 3 6 Private individuals 11 6 6 1 Representative/membership/voluntary 0 6 5 5 organisations Equality and care organisations 0 6 1 2 Public and statutory bodies 2 0 0 3 Total 56 103 40 49 Percentage 23% 42% 16% 20% Percentage of those responding 28% 52% 20% -

4.5 Of those responding to this question, more than half said that there were areas missing and proposed additions to the draft Charter. Private individuals, public and statutory bodies and tenant and resident groups were less inclined to say that there were areas missing than the other respondent groups.

4.6 There were relatively clear distinctions in the missing issues identified by different respondent groups. RSLs in particular (and some tenant and resident groups), raised the issue of wider role activities and the contribution that RSLs make to community and neighbourhood regeneration.

“Many RSL’s are active in delivering a range of initiatives to contribute towards the social, economic and physical improvements within the communities they serve. We believe there should be an outcome included in the Charter for those RSL’s who are active within this area. This will achieve a greater focus on the additional services that are provided for tenants and other customers and would also encourage RSL’s to consider value for money in this area.” (Queen’s Cross Housing Association)

4.7 The GWSF proposed a specific outcome on Neighbourhood and Community.

“Tenants and other customers live in well-designed and sustainable neighbourhoods, where they feel safe. Communities are strong, resilient and supportive and people take responsibility for their own actions and how they affect others.” (GWSF)

4.8 A number of RSLs felt that the draft Charter should have been more informed by the existing performance standards for social landlords.

“Our major concern was and still is that the development of such a charter was not informed by the existing system of performance standards.” (Pentland Housing Association)

4.9 Another common comment among RSLs was in relation to the tenant and landlord relationship, and particularly tenant responsibilities.

“The Standards as they stand place responsibility completely on the shoulders of landlords. We would contend that individual tenants and communities have a vital role to play in ensuring the maintenance of standards and the quality of environments. The absence of any reference to the responsibilities of tenants in establishing or maintaining the quality of accommodation, services or amenity within their immediate neighbourhood is we feel a major failing of these proposed standards.” (Dunedin Canmore Housing Association)

4.10 Tenant and resident groups felt that there needed to be greater clarity in the draft Charter on tenant participation. In particular they wished to see an outcome on tenant involvement in the self-assessment process for the SHR.

4.11 Across respondent groups (and notably among equality and care organisations) there was a view that equality and diversity was overlooked in

the draft Charter. Capability Scotland felt that the Charter needs to explicitly address independent living and accessibility:

“We would like to see the Scottish Government address these issues by including the following: • An outcome relating to accessibility within the housing quality section • An overarching equalities outcome covering all protected characteristics of the Equality Act 2010 • More detail and a reference to independent living in the outcome on aids and equipment”. (Capability Scotland)

4.12 Prevention of homelessness was also raised as a potential gap in the draft Charter, primarily by local authority respondents. Respondents felt that the Charter only focused on alleviation and did not cover prevention. This issue was also highlighted by a respondent on the Charter website.

“The Charter does not cover homelessness prevention which is currently an important policy area, given the focus on HUBs throughout Scotland.” (East Dunbartonshire Council)

4.13 The Scottish Council for Single Homeless (SCSH) felt that the Charter provided an opportunity to define the main purpose of social housing:

“Given that the Charter’s primary purpose is to ensure homeless people, tenants and other customers receive an improving service from their social landlords, SCSH believes that the Charter needs to clearly define the purpose of the Social Rented Sector and who it’s intended to house. It could be (for example) – • for providing housing for those in greatest need; • providing low cost tenure of choice; • providing affordable housing, or whether it is more for; • creating balanced communities with social mix; • or a combination of the above.” (Scottish Council for Single Homeless)

4.14 Some respondents (RSLs and tenant and resident groups) felt that the Charter should say more about effective management and good governance.

“There are no outcomes in the Charter ensuring that landlords run their business in an efficient and effective manner that ensures that the organisation remains financially viable and fit for purpose. This is an important outcome since the underlying financial security of a landlord is a pre-requisite to ensuring that it provides high quality services to tenants and other service users.” (Yoker Housing Association)

Question 2a: Do you agree with the ‘participation’ outcome? Question 2b: Is the ‘participation’ outcome clear and understandable?

Draft ‘Participation’ Outcome Tenants and other customers: • can participate in their landlord’s decisions • are satisfied that their views and priorities are reflected in landlord services • have opportunities to be involved in developing, monitoring, assessing and reporting on the quality of the housing services the landlord provides • have a range of ways to get involved, including ways suitable for those who are hard to reach or seldom heard • are able to get involved, if and when they want to, at a level they feel comfortable with • get support to build their capacity for more effective involvement • can take part in reviewing opportunities for involvement to ensure they are working well.

Table 4.2: Responses to Q.2a by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 32 48 1 14 Tenant and resident groups 40 33 0 2 Local authorities 16 3 1 4 Private individuals 12 11 0 1 Representative/membership/voluntary 2 8 1 5 organisations Equality and care organisations 4 2 0 3 Public and statutory bodies 1 0 0 4 Total 107 105 3 33 Percentage 43% 42% 1% 13% Percentage of those responding 50% 49% 1%

Table 4.3: Responses to Q.2b by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 11 65 2 17 Tenant and resident groups 46 26 1 2 Local authorities 11 6 2 5 Private individuals 11 12 0 1 Representative/membership/voluntary 1 6 0 9 organisations Equality and care organisations 2 1 0 6 Public and statutory bodies 0 1 0 4 Total 82 117 5 44 Percentage 33% 47% 2% 18% Percentage of those responding 40% 57% 2%

4.15 A significant concern among respondents was a lack of clarity on the scope and level of participation that is being expected in the Charter. A number of RSLs were concerned that the standards as written were open to wide interpretation and may unrealistically raise expectations on the level of influence over decisions. There were recurring concerns about the phrase “can participate in their landlord’s decisions” which was felt to be confusing.

Some respondents suggested that it would be more appropriate for the outcome to focus on “influencing decisions” or “decision making processes”.

4.16 Respondents, particularly from RSLs and local authorities also felt that the draft outcome did not reflect the different levels of participation that take place. For example, wider participation and consultation structures often sit alongside formal governance structures that see tenant membership of decision-making boards and committees.

4.17 Across respondent groups there were concerns about the length of this section of the draft Charter. There was strong support for the number of outcomes and standards to be reduced, and specifically for the GWSF and SFHA proposals for a single overarching outcome for this area.

4.18 Many respondents doubted how measureable the draft outcomes and standards were in their current form. There was particular concern over whether customer satisfaction could be used to measure tenant participation in a robust way.

4.19 A number of equality and care organisations felt that the draft Charter should be specific about accessibility and communication requirements for tenant participation.

“The Charter fails to outline the specific of how people are ‘reached’ and how communication needs will be met. Tenants should be clear on what they can expect from their landlords, and be able to action any failure on their landlord’s part to meet those expectations.” (Scottish Disability Equality Forum/Independent Living in Scotland/Inclusion Scotland)

4.20 In addition to the comments on clarity and measurability, respondents raised other concerns about the language used. Several tenant and resident groups felt that the wording should put greater compulsion on landlords to meet their duties. For example, the West Strathclyde Regional Network and others felt that “words like ‘must’, ‘will’ or ‘shall’ must be used in place of ‘can’ or ‘should’”. In contrast, some RSLs felt that the language used placed too much emphasis on RSLs to involve tenants in decisions, regardless of appropriateness and the level of interest among tenants.

Question 3a: Do you agree with the ‘communication and customer services’ outcome? Question 3b: Is the ‘communication and customer services’ outcome clear and understandable?

Draft ‘Communication and Customer Service’ Outcome Tenants and other customers: • are satisfied that landlords recognise their communication needs, and provide information and deliver services in a way that meets individual needs

• are treated with respect for their individuality and diversity

• receive and can easily get the information they need about their landlord

and the services they provide

• can contact their landlord easily to report problems, get advice and give

views • are satisfied with how the landlord handles their views and enquiries and provides feedback • have access to efficient and effective procedures for dealing with complaints • are satisfied that their landlord uses complaints and experiences of performance failures to improve services, and keeps people informed about this • are satisfied that complaints are dealt with simply, fairly, in a timely manner and as close to the front line as possible.

Table 4.4: Responses to Q.3a by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 30 49 2 14 Tenant and resident groups 45 29 0 1 Local authorities 15 4 2 3 Private individuals 13 10 0 1 Representative/membership/voluntary 2 4 1 9 organisations Equality and care organisations 3 2 1 3 Public and statutory bodies 2 0 0 3 Total 110 98 6 34 Percentage 44% 40% 2% 14% Percentage of those responding 51% 46% 3%

Table 4.5: Responses to Q.3b by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 13 62 2 18 Tenant and resident groups 52 21 0 2 Local authorities 10 7 2 5 Private individuals 12 11 0 1 Representative/membership/voluntary 2 5 1 8 organisations Equality and care organisations 2 1 0 6 Public and statutory bodies 0 2 0 3 Total 91 109 5 43 Percentage 37% 44% 2% 17% Percentage of those responding 44% 53% 2%

4.21 There was a high level of concern about the drafting of this outcome with around half of those expressing a view stating that it was not clear and understandable. Again, the most negative response came from RSLs and representative/membership/voluntary organisations, and public/statutory bodies were also concerned about the clarity of this section.

4.22 A number of respondents noted the work currently being undertaken by the Scottish Public Sector Ombudsman (SPSO) to develop a single model complaints handling procedure (CHP) which social housing providers will be legally required to adopt. They suggested that the outcomes and standards should reflect the conclusions of this work.

4.23 The SPSO strongly supported the inclusion of standards relating to complaints handling but raised some concerns in relation to using customer satisfaction as the main measure for the final outcome. They proposed removing this final outcome on complaints.

4.24 Many respondents repeated concerns about measurability and the use of customer satisfaction as an indicator. This was a particular concern in relation to complaints and some RSLs were concerned about blurring between satisfaction with complaints procedures and the outcome of a complaint.

“It is legitimate to ask us to demonstrate that we have dealt with complaints “simply, fairly, in a timely manner...” but even if we do a complainant might not be “satisfied” of this if, for example, the decision was not to their liking. The measure has to be the action we take not the subjective perception of that action.” (Reidvale Housing Association)

4.25 Respondents generally felt that this section was too long and repetitive. Several consultees supported the calls from the SFHA, CIH Scotland and GWSF to reduce the number of outcomes and standards. In particular, respondents felt that the three outcomes relating to complaints were unnecessary and could be reduced to one outcome. Paragon Housing Association argued that there should be three outcomes in this section relating to three key areas: communication; customer service; and complaints.

4.26 Many respondents, notably tenant and resident groups and private individuals, highlighted the issue of resources for strong communication with tenants.

“We want to see resources specifically mentioned in terms of funding and that landlords must have staff dedicated to tenant participation in the Charter so that resources must be available to all tenant/RTOs to allow them to engage with their landlords and carry out their activates as independent bodies.” (RTO Region 6 – South West Scotland)

4.27 Several tenant and resident groups also highlighted the importance of feedback following consultation and felt that this should be more clearly emphasised in the outcomes and standards.

4.28 Some RSLs were concerned about the cost of monitoring this element and felt that it would take resources away from services.

“…there is a lot of volume and much of it can’t be measured. There are concerns about diverting resources into assessment on these issues, rather than the actual services received or carrying out the work.” (Scottish Borders Housing Association)

4.29 There were a number of concerns about the language used in this section. In addition to comments about the outcomes and standards being vague and ‘subjective’, some respondents felt that there was too much jargon and that phrases such as “experience of performance failures” and “the front line” were more appropriate to housing professionals than tenants (East Lothian Housing Association).

Question 4a: Do you agree with the housing quality outcome? Question 4b: Is the housing quality outcome clear and understandable?

Draft ‘Housing Quality’ Outcome Tenants’ homes: • meet the Scottish Housing Quality Standard, or a locally agreed standard that exceeds this, by April 2015

• meet all legal requirements for health and safety

• are clean and tidy and in a good state of repair when they are allocated, and

meet locally agreed standards.

During the lifetime of this Charter the Scottish Government may consult on higher

energy-efficiency standards for social housing. If adopted, the new requirements

will form part of the next Charter.

Table 4.6: Responses to Q.4a by Stakeholder Group Type Yes No Other No Comments Response Registered Social Landlords (RSLs) 32 46 5 13 Tenant and resident groups 53 18 1 2 Local authorities 17 2 1 4 Private individuals 15 8 0 1 Representative/membership/voluntary 3 5 0 8 organisations Equalities and care organisations 3 2 3 1 Public and statutory bodies 1 0 0 4 Total 124 81 10 33 Percentage 50% 33% 4% 13% Percentage of those responding 58% 38% 5% -

Table 4.7: Responses to Q.4b by Stakeholder Group Type Yes No Other No Comments Response Registered Social Landlords (RSLs) 27 50 3 16 Tenant and resident groups 59 11 0 4 Local authorities 13 3 3 5 Private individuals 15 8 0 1 Representative/membership/voluntary 1 4 1 10 organisations Equalities and care organisations 2 1 0 6 Public and statutory bodies 1 0 0 4 Total 118 77 7 46 Percentage 48% 31% 3% 19% Percentage of those responding 58% 38% 3%

4.30 Support for the housing quality outcomes and standards was relatively high compared with others in the draft Charter. Many generally welcomed the outcomes and standards, and were supportive of them in principle.

4.31 Many social landlords felt it was important that the first outcome in this section, relating to the SHQS, should be clearer that exemptions and abeyances are accepted (which mean that some properties realistically will not meet the SHQS). Many felt that current wording of the outcome was misleading and could raise tenant expectations. Although some agreed that the outcome should be aspirational, others felt that it was important to recognise that landlords’ ability to go beyond the SHQS may be very limited. Some raised issues around the challenges of meeting the SHQS in mixed tenure estates, due to the need to involve and work with owners. Some felt that the issues around working with owners should be acknowledged more explicitly within the Charter – more generally rather than specifically within the housing quality section.

4.32 Although private individuals and tenant and resident groups were also broadly supportive of this first outcome, many felt that it was important that the SHQS was seen as a minimum. They suggested that this should be reflected in the wording of the Charter.

4.33 Many felt that the second outcome, referring to legal health and safety requirements, was unnecessary. They argued that there was no need to restate legal requirements which landlords are already required to operate within.

“Is it necessary to state that our housing should meet legal requirements?” (Reidvale Housing Association)

4.34 Some equalities organisations felt that it was important to make reference to temporary accommodation for homeless people and Gypsies/Travellers sites within this outcome – to mainstream equality within the Charter. Other respondents highlighted the need to consider accessibility as a factor of housing quality. It was felt that this was a good way of making it clear that accessible housing is part and parcel of good quality housing provision.

4.35 Finally, many RSLs highlighted the need to balance the responsibilities of landlords and those of tenants in relation to housing quality.

“The Charter should emphasise that a good community isn’t just built by landlords meeting their obligations, but also on tenants fulfilling their duties too.” (West Whitlawburn Housing Co-operative)

4.36 In relation to the outcomes and standards being clear and understandable, a number of key themes emerged – both from those who supported the principles of the outcomes and standards, and those who did not:

• The SHQS should be described so that tenants understand the housing quality standards referred to. • “Clean and tidy” was seen as a very subjective phrase, with RSLs, tenants and local authorities all suggesting that this should be defined more clearly. • “Good state of repair” was also seen as subjective and imprecise, particularly by tenants and RSLs. • The term “locally agreed standards” was seen as confusing.

“The words ‘clean and tidy’ should be deleted as it is different things to different people.” (Private individual)

4.37 Many respondents proposed alternatives which simplified the wording of the outcomes and standards or reduced their number. Many felt that the outcomes and standards should be combined and “replaced with a shorter single outcome statement” (TPAS Scotland). The SFHA suggested merging this section with the maintenance and repairs section, and many supported this proposal.

Question 5a: Do you agree with the ‘repairs, maintenance and improvements’ outcome? Question 5b: Is the ‘repairs, maintenance and improvements’ outcome clear and understandable?

Draft ‘Repairs, Maintenance and Improvements’ Outcome Tenants: • receive repair, maintenance and improvement services that are responsive to their needs and priorities and meet locally agreed standards

• can report repairs easily and are clear about the timescales, priorities and

procedures for carrying them out

• can choose when work is done, at times convenient for them

• get repairs and improvements done right, on time, first time • are involved in and kept informed about planned improvements to their home • are given choices about improvements • can get involved in monitoring and reviewing the repairs service they receive. 21

Table 4.8: Responses to Q.5a by Stakeholder Group Type Yes No Other No Comments Response Registered Social Landlords (RSLs) 18 66 1 11 Tenant and resident groups 48 22 1 3 Local authorities 12 7 1 4 Private individuals 15 8 0 1 Representative/membership/voluntary 2 6 0 8 organisations Equalities and care organisations 3 1 0 5 Public and statutory bodies 1 0 0 4 Total 99 110 3 36 Percentage 40% 44% 1% 15% Percentage of those responding 47% 52% 1%

Table 4.9: Responses to Q.5b by Stakeholder Group Type Yes No Other No Comments Response Registered Social Landlords (RSLs) 16 63 3 14 Tenant and resident groups 59 7 0 8 Local authorities 9 8 2 5 Private individuals 18 5 0 1 Representative/membership/voluntary 2 4 0 10 organisations Equalities and care organisations 2 1 0 6 Public and statutory bodies 1 0 0 4 Total 107 88 5 48 Percentage 43% 35% 2% 19% Percentage of those responding 54% 44% 3%

4.38 The overarching concern in relation to the ‘repairs, maintenance and improvements’ outcomes and standards was that they focused on landlord responsibilities in meeting tenant needs and priorities, and did not reflect the need for joint working, negotiation and compromise between tenants and landlords.

4.39 This was largely raised by RSLs, many of whom pointed out that decisions about repairs, maintenance and improvement needed to be driven not only by tenant priorities, but also by wider priorities such as property condition and meeting the SHQS; balancing the needs of tenants with different needs; balancing the needs of tenants and owners and financial and business planning. However, some tenant and resident groups also felt that there was too much focus on tenant needs and not enough on the balance between tenant and landlord responsibilities.

“Sometimes the needs and priorities of one tenant cannot be met, as the priorities and needs of the many need to take precedence.” (Private individual)

“Improvements and planned maintenance do not respond directly to tenants’ needs and priorities but are carried out for the benefit of the property”. (Aberdeen City Council)

4.40 Respondents generally supported the principle of tenant choice over when work is done – to some degree. However, many felt that the way the outcome was currently phrased would lead to unrealistic expectations that work could be undertaken any time, day or night. Landlords and tenants pointed to the resource implications of this, if contractors were required to undertake work outwith normal working hours. Landlords also highlighted that this would not always be practical – for example where a group of tenants is receiving work which should be undertaken on the same day for economies of scale and efficiencies.

“[Tenants choosing when work is done] could be impossible for some landlords and would incur a cost”. (Milton Albyn Housing Forum)

4.41 Respondents also felt that it was an admirable aspiration to work to complete all repairs and improvements first time. However, both landlords and tenants recognised that this was not always possible. Landlords pointed to a range of factors which influenced this – including the accuracy of initial information provided by tenants; the need for further visits to diagnose, monitor or resolve problems; the need to order parts; and the process of gaining agreement for common repairs. Many respondents suggested that it may be more appropriate for landlords and tenants to agree local standards in this area.

“This is a dangerously worded outcome – as it raises tenant expectations to a level that landlords cannot reasonably fulfil in all cases.” (SFHA)

4.42 Some local authorities, RSLs, private individuals and tenant and resident groups felt that the outcomes and standards should make reference to tenants’ statutory rights in relation to repairs and compensation.

4.43 A number of equalities and care organisations and local authorities highlighted that this section should cover travellers’ sites and temporary accommodation, with outcomes around repairs, maintenance and improvements applying equally to these types of accommodation.

4.44 Finally, respondents raised a number of issues about how the outcomes and standards were drafted. The main issue was that many felt this section moved away from outcomes standards, and into detailed processes. These respondents felt that the number of outcomes and standards in this section could be reduced, or amalgamated with others – such as those in the section on Housing Quality.

“More than the other sections, this begins to get into what landlords should be doing – rather than the stated purpose of the Charter which is to be clear about what landlords should be achieving”. (GWSF)

Question 6a: Do you agree with the ‘estate management’ outcome? Question 6b: Is the ‘estate management’ outcome clear and understandable?

Draft ‘Estate Management’ Outcome Tenants and residents: • take pride in where they live!

• are satisfied that landlords are working in partnership with other agencies to

ensure that estates meet locally agreed standards for maintenance,

cleanliness and safety

• are satisfied that tenancy conditions are enforced consistently and breaches

dealt with quickly

• can get involved in monitoring and reviewing the estate management

service they receive.

Table 4.10: Responses to Q.6a by Stakeholder Group Type Yes No Other No Comments Response Registered Social Landlords (RSLs) 17 67 0 12 Tenant and resident groups 36 36 1 1 Local authorities 11 9 1 3 Private individuals 8 15 0 1 Representative/membership/voluntary 2 7 0 7 organisations Equalities and care organisations 2 2 0 5 Public and statutory bodies 1 0 0 4 Total 77 136 2 33 Percentage 31% 55% 1% 13% Percentage of those responding 36% 63% 1%

Table 4.11: Responses to Q.6b by Stakeholder Group Type Yes No Other No Comments Response Registered Social Landlords (RSLs) 9 67 4 16 Tenant and resident groups 43 27 0 4 Local authorities 7 12 1 4 Private individuals 12 11 0 1 Representative/membership/voluntary 2 4 0 10 organisations Equalities and care organisations 1 2 0 6 Public and statutory bodies 1 0 0 4 Total 75 123 5 45 Percentage 30% 50% 2% 18% Percentage of those responding 37% 61% 2%

4.45 Many respondents supported the principle of an estate management outcome. However, levels of agreement with the detailed proposed estate management outcomes and standards were low – with significant numbers feeling that they were not clear or understandable. In contrast with other questions, only half of the tenant and resident groups said that they agreed with the draft outcomes and standards.

4.46 The main concern – across all respondent groups – was that the outcomes and standards went beyond what could reasonably be described as a core landlord responsibility.

“….it is important that the Charter focuses upon the areas which are the responsibility of the landlord”. (South Lanarkshire Council)

4.47 This was a particular concern as to how achievement of these outcomes and standards would be measured. As with several other outcomes and standards, many respondents expressed concern about the focus on tenant satisfaction as a measure. Many respondents felt that tenants would need to have access to a wide range of information in order to be able to accurately assess whether they were satisfied or not with a landlord’s performance – and some questioned whether tenants would be keen to invest significant time in doing so.

“How do tenants know if breaches are enforced consistently and quickly?” (East Dunbartonshire and Lanarkshire Regional Network)

4.48 Many landlords, and some tenant and resident groups, were also concerned about the reference to residents, and sought clarity on landlord responsibility in this regard. Many were concerned about whether there would be a requirement to measure resident satisfaction, whether this was appropriate, and the resource implications of this.

“We are concerned about what estate management functions landlords would be responsible for in terms of ‘residents’ as it is tenants who fund this work through their rents.” (West Lothian Joint Housing Networks Response)

4.49 Some RSLs operating across wide geographical areas questioned how landlords with dispersed stock – often a small number of properties within each neighbourhood or community - could be held responsible for estate management outcomes.

4.50 An additional concern was that the outcomes and standards did not focus on what respondents would describe as estate management. Some suggested that some of the outcomes and standards would sit better in other sections – around tenancy management, maintenance and anti-social behaviour.

4.51 There was particular concern about the first outcome relating to tenants and residents taking pride in where they live. Many respondents felt that this was outwith the remit of a landlord, depended on a wide range of other factors and was very difficult to measure. Many suggested deleting this outcome.

“It is impossible to measure and is certainly outside the gift of the landlord function to achieve...” (CIH Scotland)

“Although we would like to see more people taking a pride in where they live, this is undeniably impossible to measure.” (East Fife Federation of Tenants and Residents Associations)

4.52 The second outcome also attracted significant concern. RSLs felt that it was unfair that they would be judged on partnership working, when other local agencies were also responsible. Many felt that this was a process, not an outcome or standard. Several respondents suggested the real focus should be on ensuring neighbourhoods are well maintained, clean and safe. Some tenant and resident groups indicated they would like to see a national ‘estate standard’, which would set out the standards they should expect.

“It is very difficult for tenants and residents to measure how well their landlord is undertaking partnership working.” (Eildon Tenants Organisation)

4.53 Many felt that the third outcome did not recognise the complexities of dealing with breaches of tenancy conditions. RSLs highlighted that successful resolution may be dependent on external agencies or legal processes. Respondents were particularly concerned with the use of the word ‘quickly’, believing that this raised expectations beyond what was realistic.

4.54 Some respondents suggested that the final outcome should be deleted as the spirit of the outcome was already covered in the participation section. Many tenant and resident groups felt that it was important that this section referred to tenant, as well as landlord responsibilities.

4.55 A minority of RSLs suggested that the estate management section should include an outcome relating to void management. Overall, respondents suggested that there was potential for simplifying and rationalising the outcomes; wording the outcomes more clearly; and focusing on changes not processes.

Question 7a: Do you agree with the ‘housing options’ outcome? Question 7b: Is the ‘housing options’ outcome clear and understandable?

Draft ‘Housing Options’ Outcome People looking for housing: • get the information they need on the range of housing options available in their area to help them make informed choices and decisions

• have a say in what type of house they want to live in, and where.

Table 4.12: Responses to Q.7a by Stakeholder Group Type Yes No Other No Comments Response Registered Social Landlords (RSLs) 32 49 2 13 Tenant and resident groups 47 20 4 3 Local authorities 13 6 1 4 Private individuals 11 11 1 1 Representative/membership/voluntary 2 8 0 6 organisations Equalities and care organisations 2 2 0 5 Public and statutory bodies 1 0 0 4 Total 108 96 8 36 Percentage 44% 39% 3% 15% Percentage of those responding 51% 45% 4%

Table 4.13: Responses to Q.7b by Stakeholder Group Type Yes No Other No Comments Response Registered Social Landlords (RSLs) 27 51 3 15 Tenant and resident groups 49 16 0 9 Local authorities 11 7 1 5 Private individuals 16 7 0 1 Representative/membership/voluntary 2 6 0 8 organisations Equalities and care organisations 1 2 0 6 Public and statutory bodies 1 0 0 4 Total 107 89 4 48 Percentage 43% 36% 2% 19% Percentage of those responding 54% 45% 2%

4.56 Respondents generally recognised that it was important for individuals to make informed choices about their housing options, and welcomed the inclusion of a housing options section within the draft Charter. However, many had concerns about the way the outcomes and standards were currently phrased.

4.57 Many respondents said that the first outcome needed to refer to the limitations which can affect individual housing choices. Many felt that this outcome should explicitly refer to advice about likely housing prospects, given that people need to understand the range of options available and how realistic or likely each of these options is in their individual circumstances. They felt that without referring to housing prospects, this outcome was in danger of raising individual expectations beyond what could reasonably be achieved.

4.58 The biggest concern raised by RSLs and representative bodies related to landlord responsibilities around the provision of housing options advice. Many felt that to date the provision of housing options advice had mainly been the responsibility of local authorities, and that the draft Charter appeared to be extending this responsibility to RSLs. Both landlords and representative bodies questioned whether RSLs were now expected to deliver a housing options service in-house – or if it would be adequate to provide advice about their own stock and signpost applicants to other places. Many RSLs expressed concern about the potential cost of providing a housing options service, and whether this was an appropriate use of tenants’ rents.

“It is important to balance the role played in housing information and advice by councils, other landlords, and other advice providers. We believe that housing information and advice should be led and co- ordinated by councils – and that RSLs should play their part in supporting agreed local strategies.” (GWSF)

4.59 Respondents across all groups also raised concerns about the second outcome. Some simply did not understand what this outcome was trying to achieve and were particularly confused by the wording ‘have a say’ which was seen as vague and unclear. Many were unsure whether landlords would be measured on whether applicants could express a preference, or whether this preference was actually met through allocations.

4.60 Many felt that this outcome was repetitive and unnecessary, while others felt that the reference to choice further raised expectations beyond what was possible. Many tenant and resident groups felt that the outcome was unrealistic and created a ‘wish list’ which was not based on reality. Respondents pointed to the mismatch between housing demand and supply, and the fact that in reality many applicants did not have much choice in the housing they are offered. A high proportion of respondents suggested removing this outcome.

“What real choice do people have about house type when there is great demand and little supply.” (Private individual)

“Remove bullet 2 as we feel this raises expectations of people and gives false hope.” (Castlepark and Eglinton Tenants and Residents Group)

4.61 However, a small number of equalities organisations highlighted the importance of choice over house type, location and size - particularly for disabled people and people from ethnic minority communities.

4.62 Many respondents across all respondent groups – including Shelter Scotland - raised significant concerns that the housing options outcomes did not refer to homelessness prevention.

“It is a significant weakness that the draft Charter does not include a specific outcome relating to measurement of activity around prevention of homelessness.” (Glasgow City Council)

4.63 As with other outcomes and standards, many respondents raised concerns about how these would be measured. Many felt they were not precise enough to be measured effectively. Some respondents suggested merging the housing options section with the access to social housing section, and reducing the overall number of outcomes substantially.

Question 8a: Do you agree with the ‘access to social housing’ outcome? Question 8b: Is the ‘access to social housing’ outcome clear and understandable?

Draft ‘Access to Social Housing’ Outcome

People looking for housing:

• can apply easily for the widest choice of social housing that would meet their needs in the area • have easy access to, and can easily understand, a landlord’s allocation policies • get clear information on how the landlord allocates homes and their prospects for being allocated one • are satisfied that landlords are working together to simplify and maximise

access to housing, for example through Common Housing Registers or as

members of an exchange scheme • are satisfied that allocation policies reflect a landlord’s consultation with its tenants and the demand for housing in the area • are satisfied that landlords make the best use of the housing available.

Table 4.14: Responses to Q.8a by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 20 64 0 12 Tenant and resident groups 47 20 2 5 Local authorities 15 6 0 3 Private individuals 17 7 0 0 Representative/membership/voluntary 2 8 0 6 organisations Equality and care organisations 4 2 0 3 Public and statutory bodies 1 0 0 4 Total 106 107 2 33 Percentage 43% 43% 1% 13% Percentage of those responding 49% 50% 1%

Table 4.15: Responses to Q.8b by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 14 63 3 16 Tenant and resident groups 58 8 1 7 Local authorities 10 10 0 4 Private individuals 19 5 0 0 Representative/membership/voluntary 2 4 0 10 organisations Equality and care organisations 1 1 0 7 Public and statutory bodies 1 0 0 4 Total 105 91 4 48 Percentage 42% 37% 2% 19% Percentage of those responding 53% 46% 2%

4.64 Support for the ‘access to social housing’ outcome was most prevalent among local authorities, tenant and resident groups and private individuals. However some respondents and local authorities in particular, qualified their responses.

“In general, this section highlights the difficulty in trying to create a Charter which caters for a diverse range of needs and interests, as they may often compete and what satisfies one customer in terms of the best use of housing will not often satisfy another.” (Glasgow City Council)

4.65 A small number of respondents highlighted the need for the Charter to be clearer when outcomes or standards were informed by legislation. Shelter Scotland felt that the lack of reference to housing need was an omission.

“...it does not overtly address the basic principle that should guide all social housing allocations: need.” (Shelter Scotland)

4.66 A significant number of local authorities highlighted the reliance on measuring satisfaction among housing applicants in the final three outcomes, and felt this could be problematic. For example, some felt it would be difficult for applicants to assess whether landlords were working together to simplify and maximise access to housing or were making best use of the housing stock available to them.

4.67 Many tenant and resident groups did not expand on their support or make suggestions for detailed drafting changes. Of those that made substantive comments, a number highlighted that currently social landlords’ allocation policies do not operate as effectively as tenants would like them to. This is because landlords cannot or do not do not always consider the impact of some allocations on the wider community. Some of these respondents suggested that there should be national guidance on allocations.

4.68 Other tenant and resident groups highlighted the challenge in measuring ‘satisfaction’ in allocations.

“ETF would like to know how the Scottish Housing Regulator would monitor satisfaction that landlords make the best use of the housing available”. (Edinburgh Tenants Federation)

4.69 Similar views came from bodies such as Scottish Women’s Aid.

“There is also a risk that the tenant or customer will confuse their satisfaction with the outcome of the application rather than satisfaction with the process”. (Scottish Women’s Aid)

4.70 RSLs voiced greatest disagreement with the proposals as currently drafted. Some indicated their agreement with the principles but then went on to qualify this in terms of the challenges in measuring satisfaction as currently drafted.

Question 9a: Do you agree with the ‘homeless people’ outcome? Question 9b: Is the ‘homeless people’ outcome clear and understandable?

Draft ‘Homeless People’ Outcome Homeless people: • get the information they need to make informed choices and decisions on the range of housing options available

• can get accommodation and support that meets their needs and legal rights

• get prompt and easy access to help and advice

• are treated fairly and with respect while they are homeless, with

consideration for their individual circumstances • get ongoing support and communication • get good-quality temporary accommodation that meets their needs and locally agreed standards • are satisfied that landlords are working in partnership with other agencies to provide a range of support.

Table 4.16: Responses to Q.9a by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 29 51 3 13 Tenant and resident groups 46 16 4 8 Local authorities 14 7 1 2 Private individuals 16 6 0 2 Representative/membership/voluntary 3 8 0 5 organisations Equality and care organisations 2 2 0 5 Public and statutory bodies 1 0 0 4 Total 111 90 8 39 Percentage 45% 36% 3% 16% Percentage of those responding 53% 43% 4%

Table 4.17: Responses to Q.9b by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 23 52 4 17 Tenant and resident groups 54 7 1 12 Local authorities 11 9 0 4 Private individuals 17 5 1 1 Representative/membership/voluntary 3 5 0 8 organisations Equality and care organisations 2 1 0 6 Public and statutory bodies 0 1 0 4 Total 110 80 6 52 Percentage 44% 32% 2% 21% Percentage of those responding 56% 41% 3%

4.71 Views were broadly split on the ‘homeless people’ outcome. The SFHA, together with a number of social landlords (RSLs and local authorities) highlighted that the majority of homeless outcomes and standards identified apply only to local authorities. They proposed that these should be set out separately, making it clear that they do not apply to RSLs, in a similar way to existing performance standards for social landlords.

4.72 A number of social landlords and others noted that the draft outcome focused on addressing homelessness but does not cover prevention. They felt that this was an important omission.

“There is nothing in the proposed Charter that focuses on homeless prevention...” (The Moray Council)

4.73 Some social landlords also highlighted the use of satisfaction to measure partnership working arrangements. They questioned how homeless people would be able to make this assessment and whether it was the most appropriate way to provide a robust measurement.

4.74 A small number of landlords suggested that the outcome would be more appropriately referred to as ‘Housing Options Advice’ and cover all people looking for housing rather than limiting it to homeless people. Others questioned whether the outcome could be combined with the ‘Access to Social Housing’ outcome.

4.75 Significant numbers of RSLs indicated their support for the approaches being proposed by the GWSF, SFHA or CIH Scotland in terms of reducing the number of outcomes and developing local standards reflecting tenant priorities.

4.76 While offering specific suggestions for strengthening outcomes and standards, Shelter felt that the draft Charter outcomes were “a significant improvement on previous drafts of the Charter”. Glasgow Homelessness Network felt the outcomes were positive and “would contribute to improvements in the delivery of homelessness services” but thought they may be difficult for people using homelessness services to understand. However, the SCSH suggested they were “far too limited”. For instance, they proposed the inclusion of outcomes relating to permanent housing options.

4.77 Many respondents raised concerns about the reference to homeless people being ‘treated fairly and with respect’. They argued that this should apply to all customers and should be “an inherent and underlying principle” at the outset of the Charter.

4.78 While the vast majority of tenant and resident groups supported the draft outcomes and standards, a number queried how they would be measured.

“We are unclear how this would be monitored and evidenced.” (East Lothian Tenants and Residents Panel)

4.79 Other tenant and resident groups made specific proposals for rewording or including additional outcomes and standards.

Question 10a: Do you agree with the ‘tenancy sustainment’ outcome? Question 10b: Is the ‘tenancy sustainment’ outcome clear and understandable?

Draft ‘Tenancy Sustainment’ Outcome Tenants: • are satisfied that landlords, in partnership with other organisations, provide a range of support to enable them to remain in their home • can get support to help them remain in their home if their tenancy is at risk • can get the adaptations and equipment they need to help them stay in their home, where this is appropriate • are satisfied that tenancy conditions are enforced fairly and quickly.

Table 4.18: Responses to Q.10a by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 17 67 1 11 T enant and resident groups 43 23 2 6 Local authorities 12 8 1 3 Private individuals 15 8 0 1 Representative/membership/voluntary 3 6 0 7 organisations Equality and care organisations 2 2 2 3 Public and statutory bodies 1 0 0 4 Total 93 114 6 35 Percentage 38% 46% 2% 14% Percentage of those responding 44% 54% 3%

Table 4.19: Responses to Q.10b by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 14 64 2 16 Tenant and resident groups 50 19 0 5 Local authorities 12 7 1 4 Private individuals 12 9 1 2 Representative/membership/voluntary 2 4 1 9 organisations Equality and care organisations 2 1 0 6 Public and statutory bodies 1 0 0 4 Total 93 104 5 46 Percentage 38% 42% 2% 19% Percentage of those responding 46% 51% 2%

4.80 Local authorities were broadly supportive of the tenancy sustainability outcome. However, a number identified a repeat of statements made in the ‘Estate Management’ and ‘Anti-Social Behaviour’ outcomes. A number also questioned the appropriateness of tenant satisfaction as a robust method of measurement.

“The people who are at greatest risk of not sustaining their tenancy are probably least likely to participate in satisfaction returns and this undermines the purpose of this measure”. (Renfrewshire Council)

4.81 Glasgow City Council suggested that tenants should be offered support to help them sustain their tenancies at all times and not just at a crisis point when their tenancy was at risk. They highlighted that this is a guiding principle of the Housing Options approach being promoted by the Scottish Government and felt that the outcome should reflect this. This view was endorsed by Shelter Scotland and others.

4.82 Some social landlords drew attention to the fact that providing adaptations relied on the availability of resources. As drafted, the outcome may not be achievable. They suggested awaiting the outcome of the current consultation on adaptations.

4.83 The issue of adaptations was raised by others. Action on Hearing Loss Scotland expressed their “delight” that tenants will be able to get the adaptations and equipment they need to help them stay in their home. They highlighted that people with hearing loss may need a wide range of equipment to facilitate their independence and live safely.

4.84 But the SFHA and a number of RSLs drew attention to the fact that there is not a statutory duty on RSLs to provide adaptations, and that the link to the availability of resources cannot be ignored. They proposed removing this outcome altogether.

4.85 The commitment to landlords undertaking adaptations was generally welcomed. But a number of organisations questioned how this would be funded and raised concerns that tenants would be expected to pay for adaptations through their rents.

4.86 A number of RSLs (that indicated both their support and disagreement with this outcome) expressed concern with imprecise language and the reliance on ‘satisfaction’ to measure outcomes and standards.

4.87 Some RSLs also highlighted that the provision of support to a tenant may be dependent on others. They questioned it being used as an outcome to measure the performance of a landlord.

“The implication of this section of the Charter is that RSLs must ensure that their tenants get support. Yet the provision of support is under the control and decision making of others whom the RSL has no control over.” (Lister Housing Co-operative)

4.88 Rural Stirling Housing Association felt that, as worded, the outcome could lead to tenants’ expectations being unrealistically raised in what they can expect from a small landlord in terms of support.

4.89 Other RSLs highlighted the requirement to follow due process when enforcing tenancy conditions ‘fairly and quickly’. They suggested that tenants may be unaware of the actions and constraints for a landlord in dealing with these issues.

“The Board were extremely concerned that the landlord was going to be assessed by its performance in enforcing tenancy conditions “fairly and quickly” as the process for doing so is often outwith the control of the landlord...” (Wishaw and District Housing Association)

4.90 As with other outcomes and standards, many RSLs supported the alternative proposals being put forward by their representative and membership organisations.

4.91 While an overwhelming majority of tenant and resident groups supported the outcomes and standards in principle, a number drew attention to issues of drafting and measurement.

“Using words like “quickly” in outcomes is poor as this is open to interpretation and does not set a defined timetable that people can expect landlords to operate within”. (East Ayrshire Tenants and Residents Association)

4.92 Some tenant and resident groups suggested that the outcomes placed greater emphasis on supporting tenants to remain in their homes than supporting wider community needs.

“We have concerns that significant effort may be put into helping anti- social tenants remain in their homes to the detriment of other tenants and the wider community”. (Central Alexandria Tenants and Residents Association)

Question 11a: Do you agree with the ‘anti-social behaviour’ outcome? Question 11b: Is the ‘anti-social behaviour’ outcome clear and understandable?

Draft ‘Anti-Social Behaviour, Neighbour Nuisance and Tenancy Disputes’ Outcome Tenants and residents: • are able to easily report tenancy disputes, neighbour nuisance and anti-social behaviour • get clear information on how tenancy disputes, neighbour nuisance and anti- social behaviour are dealt with • are satisfied that disputes are dealt with quickly and effectively and tenancy conditions are promptly and fairly enforced • are kept informed on progress with complaints, and understand the outcome • if affected by anti-social behaviour, get the support they need to help them deal with the situation • if causing nuisance or anti-social behaviour, get support to help them stop this and to keep to their tenancy agreement • are satisfied that landlords are working in partnership with other agencies and the local community to prevent and tackle anti-social behaviour • can get involved in reviewing and monitoring the tenancy disputes, neighbour nuisance and anti-social behaviour service they receive.

Table 4.20: Responses to Q.11a by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 23 57 2 14 Tenant and resident groups 42 28 1 3 Local authorities 12 8 1 3 Private individuals 11 11 1 1 Representative/membership/voluntary 2 6 0 8 organisations Equality and care organisations 1 1 2 5 Public and statutory bodies 1 0 0 4 Total 92 111 7 38 Percentage 37% 45% 3% 15% Percentage of those responding 44% 53% 3%

Table 4.21: Responses to Q.11b by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 16 62 2 16 Tenant and resident groups 46 22 1 5 Local authorities 10 9 1 4 Private individuals 15 8 0 1 Representative/membership/voluntary 2 3 0 11 organisations Equality and care organisations 2 1 0 6 Public and statutory bodies 1 0 0 4 Total 92 105 4 47 Percentage 37% 42% 2% 19% Percentage of those responding 46% 52% 2%

4.93 Social landlords (local authorities and RSLs) generally agreed with the need for an outcome on dealing with anti-social behaviour. But many of those expressing both agreement and disagreement with the draft outcomes and standards suggested changes. A key concern raised by some social landlords was that dealing with anti-social behaviour was often complex, involving issues for which a landlord is not solely responsible, and requiring a multi-agency approach. These consultees suggested that outcomes and standards as drafted did not reflect this.

“This outcome should focus clearly on partnership working, and on providing clear and understandable information to those involved about what can be done and when.” (Rural Stirling Housing Association)

4.94 A number of social landlords suggested that, as drafted, some of the outcomes and standards would be difficult to measure. In particular, these landlords drew attention to the outcomes focusing on tenant and resident satisfaction. They suggested that tenant and resident expectations in dealing with anti-social behaviour problems might be unrealistic and difficult to measure performance objectively.

“ABS cases are often complex and cannot be resolved within set timescales. Where a dispute is resolved by the quickest and most appropriate methods, tenants and residents may not agree that this has been the case, and such unrealistic expectations can contribute to a lack of satisfaction....” (Anti-Social Behaviour Officers’ Forum)

4.95 Others suggested that that there were too many outcomes and standards, some of which duplicated those contained within the ‘Estate Management’ and ‘Tenancy Sustainment’ outcome. Some social landlords put forward specific proposals for rewording and condensing the number of outcomes and standards. Others indicated their support for the outcomes proposed by the GWSF, SFHA or CIH Scotland.

4.96 A number of social landlords and others drew attention to issues of confidentiality if tenants and residents were involved in monitoring anti-social behaviour services, as suggested by the final outcome. Some social landlords highlighted that there needed to be a better distinction between monitoring strategic and policy issues, and individual cases, and this should be better reflected in the drafting of the outcome.

4.97 A substantive proportion of tenant and resident groups indicated their support for this outcome. However, many (indicating both their support and disagreement) made substantive comments, perhaps indicating the importance attached to this issue.

4.98 A number of themes emerged in the comments. Many tenant and resident groups noted the often lengthy timescales for dealing with anti-social behaviour issues. They suggested the term ‘quickly’ was misleading to

describe a process that may require legal action. North Lanarkshire Federation suggested the need for “fast track systems” to speed up the process for dealing with anti-social behaviour.

“Tenants are frustrated about their landlords’ ability to deal with anti- social behaviour...” (Eildon Tenants Organisation)

4.99 Some tenants and residents groups identified that dealing with anti-social behaviour is not always a housing issue. They suggested that the draft Charter did not acknowledge this and that it might be difficult for landlords to meet the outcomes and standards as drafted for this reason.

4.100 Other tenant and resident groups suggested that measuring satisfaction may not be the appropriate way of assessing how effective a landlord is at dealing with cases of anti-social behaviour.

4.101 The need for good communications between landlords and victims was identified by many tenant and resident groups. Some highlighted the importance of ensuring that landlords had processes in place to give tenants the confidence to report incidences of anti-social behaviour and support them while investigations were ongoing.

4.102 A number of tenant and resident groups suggested that the outcome should link to ‘access to social housing’. They argued that tenants engaged in anti- social behaviour should be restricted from being allocated housing by another social landlord.

Question 12a: Do you agree with the ‘value for money’ outcome? Question 12b: Is the ‘value for money’ outcome clear and understandable?

Draft ‘Value for Money’ Outcome Tenants and other customers: • benefit from continually improving services while rents and service charges are kept as low as possible

• can get involved in monitoring and reviewing how landlords deliver value for

money.

Table 4.22: Responses to Q.12a by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 26 55 0 15 Tenant and resident groups 49 18 2 5 Local authorities 15 5 0 4 Private individuals 15 8 0 1 Representative/membership/voluntary 3 4 0 9 organisations Equality and care organisations 3 0 0 6 Public and statutory bodies 1 0 0 4 Total 112 90 2 44 Percentage 45% 36% 1% 18% Percentage of those responding 55% 44% 1%

Table 4.23: Responses to Q.12b by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 15 58 3 20 Tenant and resident groups 56 10 0 8 Local authorities 12 7 0 5 Private individuals 17 6 0 1 Representative/membership/voluntary 3 2 0 11 organisations Equality and care organisations 2 0 0 7 Public and statutory bodies 1 0 0 4 Total 106 83 3 56 Percentage 43% 33% 1% 23% Percentage of those responding 55% 43% 2%

4.103 Just over half of respondents to this question indicated their support to the draft outcomes and standards. As with other questions, the lowest level of support was among RSLs.

4.104 The perceived contradiction between improving service standards and containing rent levels was identified by a range of respondents. A significant number of local authorities suggested the outcome should be redrafted to remove the reference to rents and service charges ‘being kept as low as possible’. Some local authorities suggested rent levels should be measured against ‘customer aspirations’, others against their ‘affordability’.

“Tenants may choose not to keep rents low in order to achieve a higher standard.” (Private individual) “Low rents do not always equate to value for money.” (The Moray Council)

4.105 Some RSLs expressed concern that continually improving standards must ultimately have an impact on rents. A number drew attention to the impact that reducing subsidy to build new homes had on rent levels.

“RSLs cannot continually improve services while ensuring rents and service charges are kept as low as possible”. (Dunedin Canmore Housing Association)

4.106 Local authorities generally expressed their commitment to continuous improvement, and agreed with the principles of the outcome.

“Glasgow City Council welcomes the emphasis on transparency and tenant and customer involvement in this area” (Glasgow City Council)

4.107 But a number of local authorities highlighted the challenge in measuring value for money. Some referred to the lack of any industry standards and queried how value for money would be measured. They felt that this could pose challenges for tenants involved in any monitoring or review process.

4.108 Falkirk Council suggested that guidance on how this outcome would be measured would be helpful. Angus Council suggested that work being undertaken by the Scottish Housing Best Value Network on a value for money model could be shared.

4.109 A number of private individuals also highlighted the lack of definition of ‘value for money’ and the potential for different interpretations by landlords and tenants.

4.110 On a similar theme the SFHA and a number of RSLs questioned how ‘low rents’ and ‘value for money’ would be objectively measured, and how tenants would be involved in monitoring and reviewing how landlords deliver value for money. SCSH was unsure how the Scottish Government anticipated homeless people becoming involved in such reviews.

4.111 The vast majority of tenants and residents groups supported the principle of being able to become involved in monitoring and reviewing that best value was achieved from their rents. A number suggested strengthening or including an additional outcome to allow tenants to get involved in making decisions about how their rent was spent.

4.112 However, a number raised similar points to landlords in terms of the measurement of value for money, and the challenge between maintaining rents ‘as low as possible’ and continually improving services.

4.113 Some tenant and resident groups highlighted the need for information to be provided in an understandable format for tenants to be able to make an informed judgement as to whether value for money was being achieved. Others suggested that an outcome should be included to give tenants confidence that rental income was being solely used to support housing investment and services.

4.114 Some respondents suggested that the outcome was partly duplicated elsewhere and could be combined with the ‘participation’ and’ rents and service charge’ outcomes.

Question 13a: Do you agree with the ‘rents and service charges’ outcome? Question 13b: Is the ‘rents and service charges’ outcome clear and understandable?

Draft ‘Rents and Service Charges’ Outcome Tenants: • are satisfied that, after consultation, landlords have taken their views on rents and service charges into consideration and that they strike a balance between the levels of service, their cost, and how far current and prospective tenants can afford them • can get involved in reviewing rent and service charge increases and how these are spent

• are satisfied that rent and service charges are collected efficiently, rent

arrears are managed effectively, and rent loss from empty homes is

minimised

• can get clear, easy-to-understand information on how rents are set

• are satisfied that rent levels clearly reflect the size and other key features of the properties

Table 4.24: Responses to Q.13a by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 27 53 2 14 Tenant and resident groups 37 27 4 6 Local authorities 16 4 1 3 Private individuals 9 14 0 1 Representative/membership/voluntary 3 4 1 8 organisations Equality and care organisations 4 1 0 4 Public and statutory bodies 1 0 0 4 Total 97 103 8 40 Percentage 39% 42% 3% 16% Percentage of those responding 47% 50% 4%

Table 4.25: Responses to Q.13b by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 17 57 2 20 Tenant and resident groups 44 24 0 6 Local authorities 13 5 1 5 Private individuals 11 12 0 1 Representative/membership/voluntary 3 2 0 11 organisations Equality and care organisations 2 1 0 6 Public and statutory bodies 1 0 0 4 Total 91 101 3 53 Percentage 37% 41% 1% 21% Percentage of those responding 47% 52% 2%

4.115 A number of respondents across respondent groups suggested that there was overlap between the ‘rents and service charges’ and the ‘value for money’ sections. They felt this led to repetition and there was an opportunity to reduce the number of outcomes and standards.

4.116 In addition to overlap between outcome areas, some local authorities suggested the number of outcomes and standards in this section could be simplified and condensed. They proposed that a differentiation be made between those outcomes and standards that tenants can get involved in reviewing, such as rent increases, and those that are about the efficient delivery of services which can be measured in other ways.

4.117 A number of local authorities suggested that measuring satisfaction to compare landlords’ performance in rent collection, arrears and void management was not appropriate. They argued that there were performance measurements that could be used to measure outcomes more effectively.

“As currently drafted three of the five [outcomes and standards] relate to measures of tenant satisfaction in relation to what are in some instances quite complex issues...” (South Lanarkshire Council)

4.118 Some private individuals suggested that the outcomes and standards needed to be more focused and measurable. As with the previous question on ‘value for money’, a number suggested that there should be an outcome specifying the use to which rental income can be put.

4.119 SCSH questioned why the outcomes only applied to tenants and did not include housing applicants and homeless people. Likewise Falkirk Council suggested that owners who pay service charges or rent lock-ups should also be included.

4.120 A small number of respondents felt that recognition needed to be given to the ability of landlords to meet their ongoing financial obligations when setting rents.

4.121 Many RSLs also felt the outcomes and standards could be simplified and made capable of objective measurement. As with a number of other questions, some RSLs endorsed the condensed outcomes proposed by GWSF, SFHA or CIH Scotland.

“Clear simple outcomes....are required that are measurable and achievable.” (Scottish Borders Housing Association)

4.122 Some RSLs highlighted that responsibility for rent setting was ultimately the responsibility of their Boards and the outcomes and standards did not recognise this.

“At the end of the day it is a business decision for the Association what level of rent needs to be charged and this needs to be recognised in the statement.” (Port of Leith Housing Association)

4.123 However, a number of tenant and resident groups suggested the outcomes and standards should be strengthened to ensure that landlords take tenants’ views into account when setting rents and deciding priorities for expenditure.

“The outcomes must be clearer to stipulate that tenants will be able to influence what the rental income is spent on....” (West Strathclyde Regional Network)

4.124 Some tenant and resident groups highlighted the importance of receiving good quality information and being provided with appropriate support to allow them to make informed decisions about how their rents are spent.

“In order to influence rent setting, tenants need to be able to access information about housing finance and this should be made available in all formats and easy to understand.” (Edinburgh Tenants Federation)

Question 14a: Do you agree with the ‘transparency’ outcome? Question 14b: Is the ‘transparency’ outcome clear and understandable?

Draft ‘Transparency’ Outcome Tenants and other customers can easily get information about: • the organisation, governance and administration of their landlord

• how their landlord makes and implements its decisions

• how the landlord spends their rents and other money, including information

about individual items of expenditure above agreed thresholds.

Table 4.26: Responses to Q.14a by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 27 58 2 9 Tenant and resident groups 47 22 1 4 Local authorities 12 7 2 3 Private individuals 14 9 0 1 Representative/membership/voluntary 2 5 0 9 organisations Equality and care organisations 3 1 0 5 Public and statutory bodies 1 0 0 4 Total 106 102 5 35 Percentage 43% 41% 2% 14% Percentage of those responding 50% 48% 2%

Table 4.27: Responses to Q.14b by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 19 55 3 19 Tenant and resident groups 51 15 2 6 Local authorities 12 7 0 5 Private individuals 14 9 0 1 Representative/membership/voluntary 3 2 0 11 organisations Equality and care organisations 1 2 0 6 Public and statutory bodies 1 0 0 4 Total 101 90 5 52 Percentage 41% 36% 2% 21% Percentage of those responding 52% 46% 3%

4.125 Many responses to this question focused on the third outcome relating to the provision of individual items of expenditure above agreed thresholds. Many RSLs and local authorities (who indicated both their support and disagreement with this outcome) were concerned about the difficulty and cost associated with providing information on individual items of expenditure. They felt that the draft Charter was not clear on how threshold limits would be set and there was particular concern at the suggestion of a £500 limit. This was viewed as disproportionate and potentially costly and time consuming for social landlords.

“The threshold the paper hints at is £500. The problem here is there is no protection against vexatious requests for information as there is with Freedom of Information legislation. Any request must not lead to a disproportionate level of staff time and resources being invested in order to meet.” (SFHA)

4.126 Some respondents, including tenant and resident groups and private individuals, felt that thresholds should be set locally and that this should be stated explicitly in the outcomes.

4.127 Several respondents felt that the outcome would not increase transparency due to the existing management structures of social landlords and the regulatory system for the sector.

“...it is unclear how this outcome will achieve transparency by providing information on an arbitrary level of spending...Landlords are already accountable to committee members, elected members and regulators and we consider that this is sufficient and proportionate. Again, though, we believe there is an important principle here which should be retained, and our suggested wording is ‘tenants get clear information on how rents are set and how rental income is spent’.” (CIH Scotland)

“This will be too bureaucratic and needs very careful consideration, given the already robust and accountable financial reporting processes RSLs operate.” (Cunninghame Housing Association)

4.128 Some RSLs were concerned that the term ‘easily’ in relation to accessing information was subjective and would be difficult to monitor and demonstrate. Several RSLs argued that the outcome must stipulate that information provided on spending must be ‘clearly detailed’ and ‘easily understood’.

4.129 There were also comments in relation to the landlord’s need to comply with obligations under the Data Protection Act and issues of confidentiality. For example, Dunedin Canmore Housing Association noted that since rents contribute to staff salaries, this could be seen as an individual item of expenditure to be disclosed. However, they considered this to be confidential information.

4.130 Support for the third outcome was greater among tenant and resident groups. However, many felt that expenditure thresholds should be set locally and that this should be stated explicitly in the outcomes.

4.131 Some tenant and resident groups highlighted the need for information on expenditure to be made available in accessible and transparent ways.

4.132 A small number of tenant and resident groups raised concerns that the cost of monitoring and reporting on expenditure above agreed thresholds might have an adverse affect on rent levels.

Question 15a: Do you agree with the ‘services for Gypsies/Travellers’ outcome? Question 15b: Is the ‘services for Gypsies/Travellers’ outcome clear and understandable?

Draft ‘Services for Gypsies/Travellers’ Outcome Gypsies and travellers: • when using sites provided by social landlords, benefit from good-quality, well-managed accommodation.

Table 4.28: Responses to Q.15a by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 29 32 4 31 Tenant and resident groups 44 14 6 10 Local authorities 16 3 1 4 Private individuals 18 2 1 3 Representative/membership/voluntary 3 4 0 9 organisations Equality and care organisations 0 1 0 8 Public and statutory bodies 1 0 0 4 Total 111 56 12 69 Percentage 45% 23% 5% 28% Percentage of those responding 62% 31% 7%

Table 4.29: Responses to Q.15b by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 27 30 7 32 Tenant and resident groups 59 5 1 9 Local authorities 13 3 2 6 Private individuals 17 4 0 3 Representative/membership/voluntary 3 3 0 10 organisations Equality and care organisations 1 1 0 7 Public and statutory bodies 1 0 0 4 Total 121 46 10 71 Percentage 49% 19% 4% 29% Percentage of those responding 68% 26% 6%

4.133 There was comparatively strong support for the outcome relating to ‘services for Gypsies/Travellers’ and a majority of those responding to the question felt that the outcome was clear and understandable.

4.134 A number of consultees from across respondent groups felt that the outcome should say more on the provision of information, advice and support to Gypsies/Travellers. Some respondents also felt that the section should take account of the needs of those not using official sites and particularly the management of unauthorised encampments.

“Outcome should also include a bullet in relation to provision of advice and assistance to Gypsies/Travellers. Consideration should be given to procedure/provision of information in relation to Council’s management of unauthorised encampments and how this is monitored as well as what can be expected in terms of service for all service users.” (North Lanarkshire Council)

4.135 Several respondents, particularly among tenant and resident groups, argued that the Charter should explicitly state that Gypsies/Travellers should be consulted in relation to site provision and use, and other housing related services.

4.136 Some respondents felt that it was unnecessary to include a separate standard for Gypsies/Travellers but believed that the principle of supporting this group

should be incorporated in the rest of the Charter. GWSF suggested that the content of this section should be presented as supporting standards (to be reported on at a local level) and argued that services for Gypsies/Travellers should be covered in the standards relating to the customer/landlord relationship and the quality of housing.

4.137 Clyde Valley Housing Association were uncertain whether the Charter is the appropriate place for an outcome on services for Gypsies/Travellers but felt that the content should be covered elsewhere.

“This outcome should be combined with the earlier outcome on ‘access to social housing’, which should be retitled ‘access to housing’. The key issue here is that housing customers should be treated equitably and considered in terms of how their housing needs are met, rather than having certain groups defined or differentiated separately.” (Clyde Valley Housing Association)

4.138 Some respondents felt that it was inappropriate to use the term ‘accommodation’ and several tenant and resident groups felt that this should be changed to ‘amenities’ in relation to authorised sites.

Question 16a: Do you agree with the ‘other customers’ outcome? Question 16b: Is the ‘other customers’ outcome clear and understandable?

Draft ‘Other Customers’ Outcome Owners and residents receiving factoring and other services from a social landlord: • are satisfied that their landlord delivers locally agreed standards and services

• can get the information they need on factoring services

• can participate where improvements are being carried out

• can get involved in monitoring and reviewing the factoring and other services

they receive.

Table 4.30: Responses to Q.16a by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 30 48 2 16 Tenant and resident groups 53 8 0 13 Local authorities 13 9 0 2 Private individuals 17 5 1 1 Representative/membership/voluntary 2 4 0 10 organisations Equality and care organisations 1 2 0 6 Public and statutory bodies 1 0 0 4 Total 117 76 3 52 Percentage 47% 31% 1% 21% Percentage of those responding 60% 39% 2%

Table 4.31: Responses to Q.16b by Stakeholder Group Type Yes No Other No comments Response Registered Social Landlords (RSLs) 23 53 3 17 Tenant and resident groups 60 3 0 11 Local authorities 10 9 0 5 Private individuals 17 6 0 1 Representative/membership/voluntary 2 5 0 9 organisations Equality and care organisations 1 1 0 7 Public and statutory bodies 1 0 0 4 Total 114 77 3 54 Percentage 46% 31% 1% 22% Percentage of those responding 59% 40% 2%

4.139 There was a relatively positive response to the ‘Other Customers’ outcome, with a majority of those responding indicating their agreement. However, a number of respondents felt there needed to be greater clarity as to who ‘other customers’ referred to.

4.140 Local authority and RSL respondents also felt that terms such as ‘need’ and ‘participate’ were unclear. There was particular concern about the third outcome relating to improvements. Local authorities were concerned that this would be impractical and may imply to owners that they could undertake work themselves.

4.141 A number of respondents noted that, if the first standard related to factoring, then the use of the term ‘landlord’ was inaccurate. In addition, several RSLs stated that if the standard related to a factoring arrangement, any ‘locally agreed standards’ would be superseded by the terms of the title deed or factoring agreement.

4.142 Respondents were concerned that the outcomes and standards in this section do not take account of the legal framework in which factoring takes place, and implied a level of flexibility that doesn’t exist.

“Standards on maintenance and improvements need to reflect the legal framework for buildings in multiple ownership, in particular the voting rights of owners in determining whether or not work goes ahead. Factoring service providers do not have the level of control that is implied by the wording in the draft Charter.” (GWSF)

4.143 Several respondents noted the implications of the Property Factors (Scotland) Act 2011. Grampian Housing Association argued that since factoring will be regulated through the Act, monitoring through the Scottish Social Housing Charter would be “double regulation”. Bridgewater and Clyde Valley Housing Associations both argued that standards in relation to factoring should not be contained within the Charter.

“These should be completely removed from the Charter. They have no place in a Social Housing Charter. The services being provided to

owners are provided on a commercial basis and the standards which must be achieved are located in other legislation and Codes of Guidance.” (Bridgewater Housing Association)

4.144 However, some tenant and resident groups felt that this section should be strengthened and should set out more clearly defined standards specifically for factoring. Several argued that there should be a requirement for those providing factoring services to offer greater clarity on their services and charges.

Question 17: Do you think that a good landlord should be able to achieve these outcomes?

Table 4.32: Responses to Q.17 by Stakeholder Group Type Yes No Other No Comments Response Registered Social Landlords (RSLs) 29 19 31 17 Tenant and resident groups 64 4 0 6 Local authorities 16 3 0 5 Private individuals 19 2 2 1 Representative/membership/voluntary 4 2 1 9 organisations Equalities and care organisations 2 1 0 6 Public and statutory bodies 2 0 0 3 Total 136 31 34 47 Percentage 55% 13% 14% 19% Percentage of those responding 68% 15% 17%

4.145 Most of those responding to this question felt that a good landlord should be able to achieve the outcomes and standards within the draft Charter. Many felt that landlords would already be meeting many of the outcomes and standards. In particular, tenant and resident groups felt that good landlords should achieve these outcomes and standards, and many highlighted landlords’ existing legal responsibilities in terms of tenant participation.

“We believe that a good landlord will find these outcomes easy to achieve if they stick to involving tenants and listen to their views.” (Maxwellton Court Tenant Association)

4.146 However, the vast majority of those answering ‘yes’ qualified their response. Many reiterated their overarching concerns with the draft Charter (outlined in Chapter Three). A number of key concerns were raised, both by those who agreed and disagreed with this question.

4.147 For many, it was the way in which the outcomes and standards were expressed which created a problem. Respondents felt that the draft ‘outcomes’ were actually a mix of outcomes, standards, measures and other statements. The drafting of the outcomes made it difficult to assess whether a landlord could achieve these outcomes, due to a lack of clarity and objectivity.

4.148 Many respondents reiterated their concerns about how the outcomes and standards were to be evidenced and measured. In part, this was due to concerns about drafting; in part this was because respondents were unsure how the SHR would monitor outcomes and standards, and what the requirements would be of landlords (and tenants, through tenant satisfaction surveys). Many emphasised the importance of using other measures beyond tenant satisfaction – including performance outcomes.

4.149 Many highlighted that there would be resource implications for landlords in demonstrating that they were achieving these outcomes and standards – and that this may impact on quality of service or tenants’ rents.

“The requirement to prove that the Charter is being complied with through customer satisfaction surveys may prove onerous and expensive for RSLs.” (River Clyde Homes)

4.150 Some respondents highlighted that landlords will have different levels of responsibility for these outcomes – including homelessness, housing options and Gypsies/Travellers sites. They felt that greater clarity on expectations for different landlords would help. Some also stressed that some draft outcomes and standards went beyond the direct control of landlords – requiring joint working with others, or working within a legal framework.

4.151 Some stressed that it would take time and resources for landlords to achieve these outcomes and standards – particularly any new requirements. For example, GWSF highlighted that the draft Charter introduced new requirements such as repairs by appointment, information on landlord expenditure and housing options advice.

4.152 External factors such as the housing market, economic climate, funding for social housing and welfare benefit reform were all identified as factors that would impact on a landlord’s ability to meet the proposed outcomes.

4.153 Some of the draft outcomes and standards were seen as aspirational and unrealistic for landlords to achieve.

4.154 Many respondents to the question did not answer ‘yes’ or ‘no’, and indicated that they couldn’t fully answer this question. This was generally because they felt the draft Charter needed significant development before it could be seen as a clear and measurable performance framework. A number of respondents stated that they supported the alternative Charters proposed by GWSF, SFHA and CIH Scotland, which were seen as simpler and more measurable.

Question 18: Do you wish to add anything that is not covered by the questions above?

4.155 The key issues raised in response to Question 18 have been outlined in our summary at Chapter Three.

ANNEX ONE – CONSULTATION RECIPIENTS

List of Consultation Recipients

The following organisations were specifically invited to respond to the consultation:

Local Authorities Aberdeen City Council Aberdeenshire Council Angus Council Argyll and Bute Council City of Edinburgh Council Clackmannanshire Council Comhairle nan Eilean Siar Dumfries and Galloway Council Dundee City Council East Ayrshire Council East Dunbartonshire Council East Lothian Council East Renfrewshire Council Falkirk Council Fife Council Glasgow City Council Highland Council Inverclyde Council Midlothian Council Moray Council North Ayrshire Council North Lanarkshire Council Orkney Islands Council Perth and Kinross Council Renfrewshire Council Scottish Borders Council Shetland Islands Council South Ayrshire Council South Lanarkshire Council Stirling Council West Dunbartonshire Council West Lothian Council

Registered Tenants Organisations (RTOs) Abbey Court Tenants Association Abbeyhill Tenants Organisation ABC Residents and Tenants Association Abertay Residents Organisation Academy and St Meddans Court Residents Association Adamsons/Elders Tenants Association Alcath Tenants and Residents Association Alexandra Court Tenants Organisation

Allandale Residents Association Altonhill Residents Association Alyth Area Tenants and Residents Association Anderson Terrace Area Tenants and Residents Association Angus Housing Association Residents Association Annan East Tenants and Residents Association Annandale TARA Annbank Tenants and Residents Association Anniesland Court Residents Association Apsley Street Tenants' Organisation Archerhill Mini-Multis Residents Association Arcon Court Tenants Committee Arden Tenants Association Ardfin Tenants Social Club Ardochrig Tenants and Residents Association Ardrossan (CHA LTD) Tenant's Association Argyll Tenants Panel Arkleston and Newmains TRA Arthurlie Tenants and Residents Association Ashcroft House Social Fund Ashgill Residents Association Association of Clydebank Residents Groups Association of Residents of Cliffburn and Hayshead (ARCH) Auchenback Tenants and Residents Association Auchinairn and Crowhill Tenants and Residents Association Auchmuty Tenants and Residents Association Auchterarder Tenants and Residents Associaton Auldhouse Tenant and Residents Association Avonbridges Tenants and Residents Association Bagatelle Court/Tenants Association Baillieston Tenants and Residents Association Balmoral Tenants and Residents Association Balmore Housing Residents and Social Club Balornock (East) Swedish Timber Tenants and Residents Association Balornock East Residents Association Bank Farm Sheltered Housing Complex Tenants Association Banner Residents Association Bannerfield Residents Association Bantaskine Tenants and Residents Association Bardrainney Tenants and Residents Association Barrie Terrace and Hunters Ave Tenants and Residents Association Batson Street Block-Tenants and Residents Organisation Bellsbank Tenants and Residents Association Bellsmyre Neighbourhood Forum Belville Community Association Benmore Social Club Bingham Neighbourhood Association Birnies Court Tenants Association Blackness Area Residents Association Blackwood Court RTO

Blair Residents Association Blairdardie (South) MSF Residents Association Blairgowrie and Rattray Tenants and Residents Association Blalowan Park and Maitland Drive Tenants and Residents Association Blythswood, Kirklandneuk and Meadowside TRA Boghall Tenants and Residents Group Bongate View Tenants and Residents Association Borrowfield, Charleton and Seacater Community Group Bottom of the Hill Tenants Association Braehead Residents' Group Braes and Banchory Residents Association Braesview Tenants and Residents Association Branchton Tenants and Residents Association Brandfield Residents Association Bressay Brae Centre Residents Association Breton and Corentin Court Residents Association Bridge of Weir TRA Bridgend Tenants and Residents Association Broomhill Tenants and Residents Association Broomhouse Tenants and Residents Association Broomlands and Queen Street Residents Association Broomlee Court Residents' Organisation Bruce Road Flat and Community Residents Association Burgh Hall Village RA Burnblea Tenants and Residents Association Burnside Court Residents Association Cables Wynd House Residents Association Cadder Community Council Café de la Tour Cairn Brock Housing Network Cairn Housing Association Townhead Tenants and Residents Group (CHATTAR) Cairns Tenants and Residents Association Calder High Rise Neighbourhood Council Calder Tower Residents Association Caledonia Court Residents Association Caledonia, Glen Street/Corner TRA Callendar Park Tenants and Residents Association Calside TRA Calvay Social Action Group Cambusbarron Forth Tenants Campbell Area Tenants and Residents Association Cardenden Tenants and Residents Association Cardenden Tenants and Residents Association Cardross Tenants and Residents Association Carlile Place Tenants and Residents Association Carmunnock Tenants Association Carronvale Tenants and Residents Association Cartsdyke Tenants and Residents Association Castings House Tenants Organisation Castlebay Tenants Association

Castlecroft Tenants and Residents Association Castlehill and Westcliff Housing Regeneration Group Castlehill and Westcliffe Housing and Regeneration Group Castlepark and Eglinton Tenants and Residents Group Cathcart, Orchard and Bellscroft Residents Association Cathkin Braes Tenant Management Co-op Cathkin Residents Association CATRA - Crimond Area Tenants / Residents Association Catrine Residents Association Catrine Tenants and Residents Association Cearns Community Association Central Alexandria Tenants and Residents Association Central Cambuslang Tenant and Residents Association Chapelhall Tenants and Residents Association Chapelhill Mount Tenants and Residents Association Chapelle Crescent Residents Association Chapelton Residents Association Charleston Tenants and Residents Association Charleston TRA Charleton and Condor Tenant and Residents Association CHP Tenants Forum Clachan (Strachur) Tenants and Residents Association Clackmannanshire Tenants and Residents Federation Claddens Place Resident Social Club Cliftonville and Coatdyke Tenants and Residents Association Cloch HA Tenant and Resident Forum Clovenstone Neighbourhood Council Clune Park Tenants and Residents Association Clyde Tower Tenants and Residents Association Coatbridge Central Tenants and Residents Association Coatbridge Federation of Tenants and Residents Association Coatfield Lane and Giles Street Residents Association Coatshill and Thornhill Tenants Association Cochrane Castle TRA Coillesdene Complex Neighbourhood Association Coillesdene House Association of Residents and Tenants Colinsheil Court Tenants Association Community Learning and Resident Centre Cornmill Court Tenants' Organisation Cornton Castle Rock Edinvar Residents Association Corsehill Tenants and Residents Association Cowan Crescent Development Group Cowdenknowes Residents Association Cowgate Tenants and Residents Association Cowlairs Area Association Coxfield Lane Tenants and Residents Association Craigendoran Tenants and Residents Association Craigie Residents Association Craigmillar Castle Regeneration Group Craigmillar Neighbourhood Alliance

Craigmillar/Peffermill Courts Tenants Group Craigour Drive and Green Residents and Owners Association Cranhill Area Association Creighton Court Social Club Cresswell TARA Cultenhove Opportunities Partnership (COP) Cumbernauld Citizens Dalbeattie Tenants and Residents Association Dalintober and Millknowe Tenants and Residents Association Dalmeny Tenants and Residents Association Dalmuir Multi Storey Flats Tenants and Residents Association Dalvait and Carrochan Tenants and Residents Association Darg Road Tenants and Residents Association De Moray Association Denburn Court Tenants Association Derby Street Multis Residents Association Dicks Hill Community Reference Group Dougall Court Tenants Association Dougrie View Tenants and Residents Association Dowanhill Tenants' Organisation Drongan Tenants and Residents Association Drumchapel Community and Events Registered Tenants Organisation Dryburgh Gardens Residents Group Dual Tenant and Residents Association Dubton and Hillside Community Group Dudhope Park Tenants Association Dumbarton and Vale of Leven District Housing Federation Dumbiedykes Environmental Group Dumbryden Neighbourhood Council Dumfries and Galloway Federation of Tenants and Residents Dunblane Tenant's Association Dundee Federation of Tenants Associations Dundee Hillcrest Tenants Forum Dundee West Communities Association Dundonald Sheltered Housing Unit Dunlop Tower Residents Association Dunrobin Gardens Social Club Duntocher Tenants and Residents Association Easdale Residents Association East Ayrshire Tenants and Residents Federation East Fife Federation of Tenants and Residents Association East Knightsridge Tenants and Residents Association East Lothian Tenants and Residents Panel East Renfrewshire Tenants and Residents Federation Easter Drylaw Residents Association Eastern View Residents Association Eastpark Residents Association Eastwood Residents Association EATRA - Ellon Area Tenants and Residents Association Edinburgh Tenants Federation

Eildon Tenants Organisation Eskview Tenants and Residents Association Fairplay Tenants and Residents Association Farrier Court Sheltered Complex Fauldhouse Central Tenants' and Residents' Group Federation of Inverclyde Tenants and Residents Associations (FITRA) Ferguslie North Tenants and Residents Association Ferguslie Park North TRA Fernhill Community Association Fife Federation of Tenants and Residents Association Fintry North Residents Group Five Sisters Housing Network Fleming Place Residents Association Foamslags Tenants and Residents Organisation Forgewood Housing Co-op Registered Tenant Organisation Forres Area Tenants Forum Forrester Court Tenants and Residents Association Forrestfield Gardens Social Club Forthill Tenants Association Fortrose House Residents Group Foxbar West TRA FRANRA - Fraserburgh North Residents Association Fraser River Tower Tenant and Residents Association Friends of Archibald Kelly Court Association Fullarton Tenants Association Gaberston Residents Association Gallatown East Tenants and Residents Association Gallatown West Residents Association Gardens Residents Association Gateside Area Residents Association Gateside Tenant Resident Association Gauchalland East Tenants and Residents Group Gemmell Court Tenants Association Gibshill Residents Association Gilfoot and Girvan Crescent Tenants and Residents Association Glebe Court Residents Association Glen Lyon Court Sheltered Housing Residents Association Glenashton Community Association Glenburn TRA Glencruitten Tenants and Residents Association Glenrothes Area Residents Federation Glenrothes Sheltered Housing Residents Association Glenwood Tenant and Residents Association Globe Court Tenant and Residents Association Goose Green TandRA Gordon Street and Manderson Street Residents Association Govan C Festival Court Residents Association Gracemount Action Residents Association Grampian and Morven Courts Residents Association Grangemouth Paragon Residents Association

Granton Royston and Wardieburn Residents Association Greenbank Court Tenants Organisation Greenbank Residents Association and Social Club Greendykes Neighbourhood Association Greenock Central Residents Action Group Greig Court Residents Association Gretna Tenants and Residents Association Grieveship Residents Association Grive Road and Fancy Farm Tenants and Residents Hailesland Park Neighbourhood Council Hailesland/Walkers Neighbourhood Council Hallglen and Glen Village Residents Association Hanovarians Tenants' Organisation Hanover 65 Club Tenants Organisation Hanover Court Residents' Association Hanover Court Tenants' Association Hanover Court, Banchory Resident's Association Hanover Gardens (New Scone) Residents Organisation Hanover Residents (Wilson Street, Paisley) Tenants Organisation Happyhillock Tenants and Residents Association HARA - Hatton Area Residents Association Hareleeshill Residents Association Harestanes Tenants and Residents Association Harley Court Tenants' Organisation Harrow Court Social Club Harthill and Eastfield Tenants and Residents Association Hays Neighbourhood Association Herriet Court Residents Committee Hill Court Residents Association Hillside Tenants and Residents Association Hindmarsh Tenants and Residents Association Hooper Place Residents Association Houldsworth Court Tenants Organisation Househillwood Tenants and Residents Association Hunterhill TRA Hurlford Tenants and Residents Association Hutchesontown Area Association Hutton Park Residents Group Hyvot and Moredun Residents Association Inch Community Association Inchmyre Tenants and Residents Association Jamestown Community Group JLSH Tenants Association John Knox Street Area Tenants and Residents Association John Smith Court Tenants Association Johnstone Castle Tenants and Residents Action Group Johnstone Centre TRA JTA Tenants Association Jubilee Court Residents Association Keal Residents Association

Keir Hardie Court Residents Association Keir Hardie Hill Tenants and Residents Association Kelburn Community Group Kilbowie Tenants and Residents Association Kincaidston Action Group Kirkhill Residents Forum Kirkmichael Tenants and Residents Association Kirkshaws Housing Initiative Group Kirkshaws Tenants and Residents Association Kirkstyle Tenants and Residents Association Kirkton Court, Fleming Court and Mill Road (KFM) Tenants Group Kirkview Social Committee Knightswood East Tenants and Residents Association Ladywell and High Street Tenants and Residents Association Laichfield Community Association Lambhill Action Group Langlands Residents Association Langloan Tenants and Residents Association Largs Tenants and Residents Association Larkhall Area Tenants and Residents Association LATRA - Longate Area Tenant and Residents Association Laurieston Tenants and Residents Association Letham Community Tenants and Residents Association Lichtenfels Gardens Tenants Association Lightburn Tenants and Residents Association Lister Tower Residents Association LOBS Tenants' and Residents' Association Locharbriggs Tenants and Residents Association Lochgelly Central Area Tenants and Residents Association Lochmaben TARA Longpark and Gladstone (CHA LTD) Tenants Association Lossiemouth Tenants Forum Lumphinnans Tenants and Residents Association M.E.R.G. -Minority Ethnic Residents' Group Macedonia Tenants and Residents Association MACKAN Tenants and Residents Association Magdalene Neighbourhood Association Maidencraig Court Residents Association Marchwood and Bathgate East Tenant's and Residents Association Margaret Blackwood Lychgate Lane Tenants Association Martin Crescent Area Residents Association Maukinhill Residents Group Maxwelton Court TRA Mayview Tenants Association McDuff Tenants and Residents Association Meadowfoot Tenants and Residents Association Meadowhill Tenant and Residents Association Mearns Village Community Association Menzieshill North Tenants and Residents Association Mid Lothian Tenants Forum

Mill Court Social Club Mill Friars Tenants and Residents Association Mill of Haldane Community Association Mill O'Mains Tenants and Residents Association Millar Park Tenants Association and Social Club Milton Estate and Loan Tenants and Residents Association Milton Tenants and Residents Association Mission Place Social Club Moira Park Sheltered Housing Tenants Association Montgomerie Park Tenants and Residents Association Montgomerie Street Tenants and Residents Association Moorpark TRA Moray Tenants Core Group Morefield Residents Association Mount Pleasant and Putyan (CHA Ltd) Tenants Association Muirhouse High Rise Action Group Muirpark Tenants and Residents Association Muirton Park Residents Association Murray Drive Residents Association Myrtleshaw Residents Association Netherburn Tenant and Residents Association New Bonhill Regeneration Group New Govan Tenants and Residents Association New Gowkthrapple Action Group New Kincardine High Flats Tenants and Residents Association New Lairdship Place Tenants Group New Lanark Village Group New Lochside Tenants and Residents Association New Petersburn Partnership New Pleasance Residents Association Newbridge Residents Association Newmains Federation of Tenants and Residents Associations Newton Green Tenants and Residents Association Newton Park Court Tenants Association Newton Tenants and Residents Association Nichollfield Tenants and Residents Association Nicol Street Tenants and Residents Association Niddrie Marischal Neighbourhood Association Niddrie Mill Tenants and Residents Association Nithsdale Mills Tenants Activities Club North Bughtlin Tenants Association North Cardonald Tenants and Residents Association North Drumry Multi-Storey Flats Tenants and Residents North Lanarkshire Federation of Tenants and Residents Association North Mountblow Tenants and Residents Association North Muirton Residents Association North Sighthill Residents Association Northpark Residents Association Nungate Tenants and Residents Association Oatlands Residents Association

Ochils Tenants' Organisation Old Pollok Tenants and Residents Association Oliphant Court Tenants Association Onthank Residents Assoc Ormiston and Salton Tenants Association Osborne and Winton Court Tenants Group Overton Tenants and Residents Association Oxford Street Residents Association Oxgangs Central Residents Association Oxgangs Lochan Tenants and Residents Association Park Farm Tenants and Residents Association Parkfoot Court Tenants and Residents Association Parkhall and District Tenants and Residents Association Parkhill Residents Association Parklife Tenants and Residents Association Partick United Residents Group (PURG) Penilee Tenants and Residents Association Pennyburn Tenants and Residents Association Pennycook and Sinderins Courts Residents Associations Pentlands Edge Tenants Residents Association (PETRA) Perth and Kinross Tenants and Residents Federation Perth City Tenants and Residents Association Peterson Park Residents Association Phoenix Court Residents Association Pinkston Tenants Association Pipe Street Garden Tenants Association Plantation Community Association Pollokshaws Social Committee Port Bannatyne Pentanque Association Port Glasgow Town Centre Tenants and Residents Association Portobello Court Neighbourhood Association Prestonfield Tenants and Residents Association Provost Hogg Court PRSH (Milngavie) Tenants and Residents Association Quarrelton TRA Quarrye Residents Association Quarryhill Court Tenants Association Quigleys Tenant and Residents Association Radnor Park Multis Tenants and Residents Association Rainbow Tenants Association Rankin Court Residents Association Ratho Station Residents Association Ravens Court Social Club Ravenscraig Residents Association Ravensheugh Tenants and Residents Association Rawyards Tenant and Residents Association Residents Panel Restalrig House and Lochend House Residents Association Riccarton West Tenants and Residents Group Riddochhill Drive Tenants' and Residents' Association

Riddrie Tenants and Residents Association Rigside and Douglas Water Residents' and Tenants' Association Rimblelon and South Parks Residents Association River Ayr Tenants Association Riverside Gardens Tenants Association Riverside Tenants and Owner Occupiers Association Robroyston Residents Association Rosewell Drive Tenants and Residents Association Rosewell Gardens Residents' Association Tenants Organisation Rosshead Tenants and Residents Association Royal Court Residents Association Rutherglen and Bankhead Residents Association Ruthrieston Residents Association Saddlers Wells Court Residents Association Saltcoats High Flats Tenants and Residents Association Sandwood Tenants and Residents Association Sandyflats Tenants and Residents Association Sandyhills High Flats Tenants Association Sandyhills Residents Association Sanquhar Tenants and Residents Association SATRA - South Aberdeenshire Tenants and Residents Association Sauchie Community Group Saughton Mains Residents Association Saunders Street Tenants and Residents Association Scottish Borders Tenants Organisation Sea Road Area (South) Tenants and Residents Association Seaforth House Residents and Ex-Residents Association SHER (Sheltered Housing East Renfrewshire) Shetland Tenants Forum Shortlees TARA Shortlees Tenants and Residents Association Skelmorlie Tenants and Residents Association Slaemuir Tenants and Residents Association Slateford Green Residents Association Smyllum Tenants and Residents Association (STAR) Soroba Community Association South Ayrshire Tenants Group (SATG) South Garden Tenants Organisation South Kessock Residents Association South Maunkinhill Tenants Association South Toryglen Tenants Association Southhouse/Burdiehouse Residents Organisation (SABRO) Southpark Residents Association Spateston Tenants and Residents Association Spey Coast Forum Springboig Tenants and Residents Association Springhall Tenant and Residents Association St. Mary's Association of Residents and Tenants St.Andrews Residents Association (Hillcrest) Stakeford Tenants and Residents Association

Stanley Tenants and Residents Association STAR Stirling Tenants Assembly Stonedyke Residents Association Strathfillan Housing Group Strutherhill Tenants Association Summerlee Gartsherrie Sunnyside Court Tenants' Organisation Tamfourhill Tenants and Residents Association Taransay Court Tenants Association Tarbolton Tenants and Residents Association TAWRA - Thistle and Windmill Residents Association Tenant Service Review Group Tenants and Residents of Ardler -T.A.R.A. Tenants and Residents in Pilton The Barns Neighbourhood Council The Bilbohall Estate Forum (incorporating Rothes) The Charrier Residents Association The Glens United Action Group The Lordburn, Restenneth and Pitreuchie Action Group The Rowans Tenants Group (Sheltered Housing) The Terrace Residents Association The Tryst Tenants and Residents Association Thistle Residents Association Thornliebank Tenants and Residents Association Thornwood Tenants and Residents Association Timmergreens Action Group (TAG) Tollpark Tenants and Residents Association Top Blocks Residents Association Town of Lanark Tenants Forum Townhead Tenants Association TPPT - Tenant Participation Promotion Team Tranent East Tenants and Residents Association Treetops Tenants and Residents Association Troon Harbour Tenants and Residents Association Trust Housing (Ashgrove Court) Tenants Organisation Trust Housing (Lindsayfield) Tenants Association Tullichewan Tenants and Residents Association Tulloch Tenants and Residents Association Twechar Tenants and Residents Association Tweedbridge Court Tenants Association Uplawmoor Tenants Association Upper Greenhill Residents and Tenants Association Viewpoint Tenants Representative Group Wallacetoun Tenants and Residents Association Waterside Tenants and Residents Association Waulkmill Residents Association Waverley Tenants Organisation Weir Street Residents Groups Wellpark Community Association

West Drive Tenants Association West Dunbartonshire Tenants and Residents Organisation West End Tenants and Residents Association West End White Flats West Lodge Tenant Group Westbridgend Tenants and Residents Association Westburn Village Neighbourhood Council Western Isles Tenants and Residents Forum Westfield Court Residents Association Wheatfield Community Backgreen Association White Cart Tower Tenants and Residents Association Whitegates Residents Association Whitehaugh TRA Whitfield Area Forum for Tenants Whitfield Avenue Semi's Tenants Association Whitfield Rise Action Group Williamsburgh Court TRA Windsor Park Tenants and Residents Association Wingate Park Village Tenants and Residents Association Wingate Tenants and Residents Association Wishart Place Tenants Forum Woodhall Community Association Woodside Court Residents' Association Wyler Tower Tenants and Residents Association Wyndford Residents Association

Regional Networks Regional Network Committee Members (89 individuals)

Public Agencies / Government Bodies Accounts Commission Audit Scotland Benefit Fraud Inspectorate Equalities and Human Rights Commission Office of the Scottish Charity Regulator Scottish Commission for the Regulation of Care Scottish Housing Regulator Scottish Information Commissioner Scottish Public Services Ombudsman Scottish Youth Parliament Social Work Inspection Agency Young Scot Enterprise

Representative / Professional Bodies Association of Local Authority Chief Housing Officers (ALACHO) Chartered Institute of Housing (CIH) England Chartered Institute of Housing (CIH) Scotland Convention of Scottish Local Authorities (COSLA) Council of Mortgage Lenders (CML) Employers in Voluntary Housing (EVH)

Glasgow and West of Scotland Forum of Housing Associations (GWSF) Homes for Scotland (HfS) Housing Quality Network Joint Services Housing Advice Office (Scotland) Scottish Churches Housing Action (SCHA) Scottish Federation of Housing Associations (SFHA) Scottish Housing Best Value Network (SHBVN) Scottish Rural Property and Business Association (SRPBA) Tenants Information Service (TIS) Tenant Participation Advisory Service (TPAS) Scotland

Voluntary, charity and equality organisations Action for Children Action on Dementia Age Scotland Alzheimer Scotland BEMIS Bethany Christian Trust Capability Scotland Catholic Parliamentary Office CEMVO Scotland Central Scotland Racial Equality Council Citzens Advice Scotland Cyrenians Deaf Action Deafblind Scotland Dumfries and Galloway Council Dunfermline Business Centre Edinburgh and Lothians Racial Equality Council Enable Glasgow Centre for Inclusive Living Glasgow Homelessness Network Grampian Racial Equality Council Haig Homes Inclusion Scotland Leonard Cheshire Scotland Lily Walker Centre Mobility and Access Committee for Scotland Ownership Options Ownership Options in Scotland PATH Scotland Positive Action in Housing Positive Steps Poverty Alliance Quarriers RNIB Scotland RNID Scotland Rural Housing Service Save the Children Scottish Association for Mental Health

Scottish Churches Parliamentary Office Scottish Consortium for Learning Disability Scottish Council for Single Homeless Scottish Council for Voluntary Organisations (SCVO) Scottish Council of Jewish Communities Scottish Council on Deafness Scottish Deaf Association Scottish Disability Equality Forum Scottish Older Peoples Advisory Group Scottish Refugee Council Scottish Transgender Alliance Scottish Women's Aid Scottish Women's Convention Sense Scotland Shelter Scotland Stonewall Scotland The Big Issue Transform Community Development Volunteer Development Scotland West of Scotland Regional Equality Council West of Scotland Seniors Forum

Academic Glasgow Caledonian University Glasgow University Heriot Watt University University of Aberdeen University of Edinburgh University of Highlands and Islands University of St Andrews University of Stirling University of Strathclyde University of York

Other Anderson Strathern Solicitors Biggart Baillie LLP Solicitors Brechin Tindal Oates Solicitors Burness LLP Solicitors Harper Macleod LLP Solicitors HBJ Gateley Wareing Solicitors HouseMark Ltd Macleod and MacCallum Solicitors McClure Naismith Solicitors Orchard and Shipman plc SHARE TC Young Solicitors

ANNEX TWO – CONSULTATION RESPONDENTS

List of Respondents

The following organisations and individuals responded to the consultation:

Registered Social Landlords (RSLs) Abbeyfield Crieff and Muthill Society Aberdeen Housing Partnership Aberdeen Soroptimist Housing Society Albyn Housing Society Almond Housing Association Ardenglen Housing Association Argyll Community Housing Association Atrium Homes Ayrshire Housing Barrhead Housing Association Bield Housing Association Blairtummock Housing Association Bridgewater Housing Association Cairn Housing Association Caledonia Housing Association Calvay Housing Association Cassiltoun Housing Association Castle Rock Edinvar Housing Association Cathcart and District Housing Association Cernach Housing Association Cloch Housing Association Clyde Valley Housing Association Clydesdale Housing Association Copperworks Housing Co-operative Cunninghame Housing Association Drumchapel Housing Cooperative Limited Dumfries and Galloway Housing Partnership Dunbritton Housing Association Dundedin Canmore Housing Association East Kilbride and District Housing Association East Lothian Housing Association Easthall Park Housing Co-operative Eildon Housing Association Fairfield Housing Co-operative Fife Housing Association Forth Housing Association Gardeen Housing Association Glasgow Housing Association Glen Oaks Housing Association Govanhill Housing Association Grampian Housing Association Hanover (Scotland) Housing Association

Hawthorn Housing Co-operative Hebridean Housing Partnership Home Scotland Homes for Life Housing Partnership Horizon Housing Association Irvine Housing Association Kendoon Housing Association Kingdom Housing Association Knowes Housing Association Lanarkshire Housing Association Larkfield Housing Association Link Group Linstone Housing Association Lister Housing Cooperative Loreburn Housing Association Loretto Housing Association Manor Estates Housing Association Maryhill Housing Association Milnbank Housing Association Moray Housing Partnership New Gorbals Housing Association Northview Housing Association Orkney Housing Association Paragon Housing Association Parkhead Housing Association Partick Housing Association Pentland Housing Association Port of Leith Housing Association Prospect Community Housing Provanhall Housing Association Queens Cross Housing Association Riedvale Housing Association River Clyde Homes Rosehill Housing Co-operative Rural Stirling Housing Association Rutherglen and Cambuslang Housing Association Scottish Borders Housing Association Shettleston Housing Association Shire Housing Association Southside Housing Association Spire View Housing Association Thenue Housing Association Tollcross Housing Association Trafalgar Housing Association Trust Housing Association Viewpoint Housing Association Waverley Housing Weslo Housing Management West Granton Housing Co-operative West Highland Housing Association

West of Scotland Housing Association West Whitlawburn Housing Co-operative Wishaw and District Housing Association Yoker Housing Association

Tenant and resident groups Aberdeen City Council Tenant and Resident Forum Aberdeenshire Housing Partnership Tenants Association Archerhill Mini Multis Residents Association Auchenback Tenants and Residents Association Balmoral Tenants and Residents Association Banner Residents Association BEEM Regional Network (Region 5) Blackness Area Residents Association Bottom of the Hill Tenants Association Breton and Corentin Court Residents Association Bridge of Weir Tenants and Residents Association Cairns Tenants Association Caledonia Court Residents Association Campbell Area Tenants and Residents Association Cardenden Tenants and Residents Association Castlepark and Eglinton Tenants and Residents Group Central Alexandria Tenants and Residents Association Central Region Network of Registered Tenants Organisations Charleston Tenants and Residents Association Clydesdale Housing Association Tenants and Residents Group Cumbernauld Housing Partnership Tenants Forum Dalmeny Tenants Association Drongan Tenants and Residents Association Dumbarton and Vale of Leven Housing Federation Dundee Federation of Tenants Associations Dunterlie Tenants Action Group Duntocher Tenants and Residents Association East Ayrshire Tenants and Residents Association East Dunbartonshire and Lanarkshire Regional Network East Fife Federation of Tenants and Residents Associations East Lothian Tenants and Residents Panel East Renfrewshire Tenants Residents Federation Edinburgh Tenants Federation Eildon Tenants Organisation Eskview Tenants and Residents Association Fife Federation of Tenants and Residents Associations Fife Residents (Collated by Fife Council) Forth Housing Association Tenants Glasgow and Western Isles Regional Network Govan "C" Tenants and Residents Association Hailesland Neighbourhood Council Herriet Court Residents Committee. Highland and Argyll and Bute Regional Network – Region 1 Invergordon Albyn Residents Association

Link Housing Association Tenants Panel LOBS Tenants and Residents Association Locharbriggs Tenants and Residents Association Lochmaben and District Tenants and Residents Association Longpark and Gladstone Tenants and Residents Association Maxwellton Court Tenant Association Mearns Village Community Association Milton Albyn Housing Forum North Ayrshire Tenants and Residents Network North Lanarkshire Federation Partick United Residents Group Pentlands Edge Tenants and Residents Association Quallelton Area Tenants and Residents Association RTO Region 6 - South West Scotland Saltcoats High Flats Tenants and Residents Association Scottish Borders Tenants Organisation Scottish Regional Network 2 Scottish Tenants Organisation Shortlees Tenants and Residents Association SHR Tenant Assessors Panel Skelmorlie Tenants and Residents Association Strathfillan Housing Group Sunnyside Court Tenants' Organisation Tayforth Regional Network The Federation of Inverclyde Tenants and Residents Associations West End White Flats Tenants and Residents Association West Lothian Housing Networks West of Scotland Tenant Participation Network Group West Strathclyde Regional Network (Region 7) Western Isles Forum of Tenants and Residents' Associations (WIFTRA)

Local authorities Aberdeen City Council Aberdeenshire Council Angus Council Argyll and Bute Council City of Edinburgh Council Clackmannanshire Council Dundee City Council East Ayrshire Council East Dunbartonshire Council East Lothian Council Falkirk Council Glasgow City Council Highland Council Inverclyde Council The Moray Council North Ayrshire Council North Lanarkshire Council Orkney Islands Council

Renfrewshire Council Shetland Islands Council South Lanarkshire Council Stirling Council West Dunbartonshire Council West Lothian Council

Representative / membership / voluntary organisations Anti Social Behaviour Officers’ Forum Association of Local Authority Chief Housing Officers (ALACHO) Built Environment Forum Scotland (BEFS) Chartered Institute of Housing (CIH) Scotland Convention of Scottish Local Authorities (COSLA) Council of Mortgage Lenders (CML) Scotland Glasgow Homelessness Network (GHN) Glasgow West of Scotland Forum of Housing Associations (GWSF) Improvement Service Royal Town Planning Institute (RTPI) in Scotland Scottish Council for Single Homeless (SCSH) Scottish Federation of housing Associations (SFHousing Association) Scottish Housing Best Value Network (SHBVN) Scottish Women's Aid (SWA) Shelter Scotland Tenants Information Service (TIS) Tenant Participation Advisory Service (TPAS) Scotland

Equality and care organisations Action on Hearing Loss Scotland Black and Ethnic Minority Infrastructure in Scotland (BEMIS) Capability Scotland Inclusion Scotland Independent Living in Scotland (ILiS) Quarriers VIP Group Scottish Council on Deafness Scottish Disability Equality Forum (SDEF) Scottish Refugee Council (SRC) Scottish Women's Convention (SWC) Scottish Youth Parliament (SYP)

Public and statutory bodies Care Inspectorate Equality and Human Rights Commission (EHRC) Scotland's Commissioner for Children and Young People (SCCYP) The Scottish Housing Regulator (SHR) Scottish Public Services Ombudsman (SPSO)

Private individuals 24 private individuals

Social Research series ISSN 2045-6964 ISBN 978-1-78045-610-2 web only publication www.scotland.gov.uk/socialresearch

APS Group Scotland DPPAS12426 (01/12)