Written evidence from Cymorth Cymru (H&LG LCO 3)

Cymorth Cymru is the representative body for providers of housing-related support, homelessness and supported living services in Wales and as such has three overarching objectives:

· To ensure that providers maximise their contribution to the lives of the people using their services and the communities in which they operate.

· To improve services by strengthening the links between policy and practice and ensuring those working in frontline service delivery understand and operate effectively within the wider policy context, and those working in policy development understand and learn from the experiences and knowledge of those working on the ground.

· To increase public understanding and support for services that help people build the lives they aspire to within their community.

1 Background

Cymorth Cymru has around 100 organisations as members from across third, statutory and private sectors all of whom work to help people overcome a range of barriers to building the life they want and contributing positively to their community.

We wholeheartedly support the proposal for a Legislative Competence Order relating to housing and local government.

2 Key points

· We believe that the LCO request is in the spirit and scope of the devolution settlement and the LCO mechanism is in accordance with the Government of Wales Act 2006.

· There is considerable support and demand for the LCO amongst providers of housing, housing-related support and homelessness services in Wales.

· We are unaware of any cross-border issues that could prove problematic in relation to the LCO.

· The Memorandum from the Welsh Assembly Government relating to the LCO clearly sets out the purpose, rationale and scope.

· The LCO in and of itself would not necessarily increase the regulatory burden on private, public or third sector organisations but is likely to lead to improvements in this area.

· The LCO doesn't necessitate the formation or abolition of any Welsh institutions or structures to our knowledge.

· We believe the LCO is more appropriate than the use of framework powers or other mechanisms for policy development as the proposal will provide policy makers in Wales with the ability to be more responsive, flexible and inclusive in their development of policy.

3 Further details

Our submission will naturally focus on the proposals most pertinent to our members but it is important to also state that the key issue for us is that the LCO enables decisions to be made at the local level on a range of housing, support and homelessness issues.

The areas of most interest to our members are the proposals around:

· Housing-related support

· Homelessness

· Tenure

Housing-related support

The proposals rightly state that policy development in this area is being led by the production of a national strategy and action plan. Since the Welsh Assembly government memorandum explaining the scope and rationale was drafted however, an independent review into housing-related support has been announced by the Deputy Minister. The review will be making recommendations on the future of services in September 2010 and it would be useful for the Assembly to have as much freedom in this area as possible to take forward any proposals from the review it accepts.

As housing-related support links housing with other policy areas such as social care, it is also relevant that there is a review being carried out into social services in Wales. Again, the LCO would provide the opportunity for recommendations from both reviews to be taken forward in a co-ordinated fashion.

There are also policy developments in relation to specific client groups that could be facilitated by the LCO. In particular, housing, support and care for older vulnerable people.

Homelessness

There are significant links between homelessness and housing-related support as many support services provide the route out of homelessness and to independence. The Assembly have produced a national homelessness plan and there are a number of actions that could be taken forward if the LCO went ahead.

Tenure

We fully support the Law Commission's proposals on the introduction of a single tenure. Current tenure law was developed historically and without consideration of the needs of tenants or providers of supported accommodation. Consequently, current options are confusing and not as appropriate for either parties as they could be. The LCO would enable Wales to take these proposals forward. We believe that this would be hugely beneficial for both vulnerable people and providers of support services.

4 Recommendation

We fully support the proposals for the Legislative competence Order relating to housing and local government and recommend that it is taken forward.

January 2010