Enterprise and communities (EqIA)

What is the policy/strategy/function/trying to achieve/do?  

To carry out a CPO of privately owned flats at Blocks (C,D,E) of Millcroft Road and implement a Rehousing Strategy for existing owner occupiers and tenants, demolish the existing properties and then re-develop the site to build modern and energy efficient housing for social rent to meet local needs.

If this policy is subject to the FSD what does it suggest about the impact or potential impact on socio-economic disadvantage? 

Low Income

The provision of new affordable social rented housing seeks to increase opportunity of access to a safe, warm and affordable home with lower energy costs via energy efficiency within the modern construction. Residents who are affected by the CPO will be entitled (where applicable) to home loss and disturbance payments to compensate and assist with their future rehousing options. Additional housing points (due to intended demolition) will be provided to tenants upon confirmation of the CPO, who wish to be rehoused in a social rented property through the Common Housing Register.

Low Wealth

Increased provision of high-quality, affordable, energy efficient homes will help reduce cost of living and so help enable people to build wealth. Residents and owners who are affected by the CPO will be entitled (where applicable) to home loss and disturbance payments to compensate and assist with their future rehousing options. This will assist with those that are experiencing financial difficulties.

It is anticipated that some owners will be in a Negative Equity situation, where the current value of their flats will have decreased below the level of their outstanding mortgage. The Council are aware of this very sensitive situation and will assist each individual owner to address their own specific circumstances when considering rehousing options. The Council can provide direct support from its Tackling Poverty Team, who are able to assist residents further in regard to any concerns they may have in relation to their benefits and how the compulsory purchase may affect any benefits they receive or may wish to apply for in future.

In addition, the Citizens Advice Bureau have provided a named local contact for the residents of Millcroft Road. CAB are able to advise on a variety of issues from mediation to general money advice, in addition to further housing advice including lease agreements and private rented enquiries.  They are furthermore able to signpost to Independent Financial Advice.

Material Deprivation

The majority of the properties are owned by private landlords. Tenants living in the properties may be disproportionately impacted by the lack of amenity, and due to financial hardship residing in a situation to which they have no means of resolution or economic escape.

New homes will assist in combating increasingly higher costs of living due to their energy friendly design. Material deprivation commonly associated with the inability to afford basic resources such as food, heating and paying for unexpected bills can be tackled since overall monthly bills should not be unaffordable. New homes with provision to enable access to internet and other media services will support the education of the new residents and their access to training and personal development, in turn increasing the likelihood of material deprivation being less prevalent.

Prior to the CPO strategy and in an attempt to assist with prevention of further deterioration of Blocks D & E the Council started enforcement works which were carried out in April 2012 and comprised of essential repairs only. The owners were offered the opportunity of applying for a £500 grant towards the cost of work with any outstanding debt secured against the title of the property.

The Council has put in place a package of assistance in order to mitigate the impact of the Scheme on residents.  This is set out in the Council’s Rehousing Strategy.  As part of the Rehousing Strategy and, given the Council’s commitment to help owners with any potential financial hardship, a decision was made by the Housing Committee on 31st August 2022, to write off the outstanding Maintenance Order debt. This further limits the risk of material deprivation by removing the burden of debt from the owners.

Area Deprivation

New homes designed to be warm, safe and secure will aim to replace homes that continue to decline in condition whist supporting the health and well-being of the local community. Other issues such as fly tipping, vandalism, anti-social behaviour and crime will be mitigated via  regeneration of the area and removal of the existing homes no longer fit for purpose.

Give details of the impact it has on groups and individuals

Disabled people and people with long term health conditions

Some residents in this group might be impacted more severely by their displacement than other groups as suitable replacement housing will could require extra care. Appropriate, support will be available and directed to those that are disabled or have health concerns. Eligible residents will be  entitled to claim compensation under the relevant statutory provisions.

People defined by their race, colour and nationality, ethnic or national origins.

International residents have been identified who have Student Visas. In the case of the CPO being confirmed, it has been possible to foster an agreement with local RSLs to rehouse residents with Student Visas and therefore avoid the risk of homelessness within this group of residents (given they do not have Rights to Public Assistance and would not be able to be rehoused via the Council).

A long-term lack of maintenance of the blocks has resulted in extremely poor living conditions for the residents in general.  Continuous fly-tipping and vandalism results in the blocks having a negative impact on the whole surrounding area.  There have also been serious concerns raised by Strathclyde Fire and Rescue about fire safety due to the dumping of rubbish and household items within the closes, which resulted in the council sealing off bin chutes and undertaking more frequent waste uplifts from the blocks.  There are also ongoing problems of anti-social behaviour and crime. 

Officers from the Council’s Environmental Health section carried out external inspections of the properties during 2011 to establish the condition of the blocks against a ‘Reasonable Standard Assessment’ set out by the council. The results of the survey showed that the blocks were not being maintained to a reasonable standard with individual closes showing evidence of failing The Tolerable Standard as defined in the Housing (Scotland) Act 1987.

The Council’s private sector team have worked with owners of the flats, and the Greenrigg and Millcroft Flats Residents Association, over many years to try and improve the condition of the blocks and put in place effective maintenance arrangements.  However, this has not resulted in satisfactory solutions and the blocks have continued to deteriorate, despite the use of maintenance orders being instructed on the blocks of by the council in 2014 under the Housing (Scotland) Act 2006.  A recent condition survey of the blocks carried out in 2019 on behalf of the council found high concentration of defects on the properties, especially in relation to roof condition, brickwork, stair wells and entrance security, further demonstrating a continued decline in conditions.

The provision of housing which meets the needs of older people and people with disabilities and / or long-term health conditions will promote equality of opportunity between the groups identified in 2.3 and the general population through providing higher quality, energy efficient and safe housing. Research has shown that disabled people face particular adverse housing challenges.  Provision of affordable, accessible, high quality housing assists disabled people in overcoming these challenges.

The CPO at the Millcroft Road will improve the living conditions through a combination of mainstream housing and bespoke housing for disabled and/or older people within an integrated environment to promote social inclusion and improve health and well-being. Similarly mixed developments provide integration of people with differing socio-economic backgrounds and circumstances; all developments whether mixed or for a particular client group or group with particular needs provides access to safe, warm affordable homes with opportunities to link to media services that promote accessibility to facilities that may reduce both area and material deprivation.

There is a robust Rehousing Strategy in place for all people living in the Millcroft Road flats. The Rehousing Strategy will aim to protect the human rights of all residents by assisting to provide access to high quality housing, security of tenure, adequate conditions and access to affordable housing.

After many attempts to resolve the issues in order to improve the living standards and environment of Millcroft residents and the Carbrain area. Given the number of ownership interests within the blocks, it would be impossible or impracticable for the Council to acquire all of the interests on a voluntary basis. A Compulsory Purchase order is therefore necessary in order to deliver the Scheme.

The Council has carefully considered the balance to be struck between individual rights and the wider public interest. The Council considers that there is a compelling case in the public interest for confirmation of the Order. The compulsory purchase of the blocks is considered necessary and proportionate in the circumstances having due regard to the interest of the affected parties and is therefore justified. Owner occupiers, landlords and tenants will be contacted by the Council to discuss their individual circumstances, including potential compensation entitlement and re-housing assistance.

Only owner occupiers (those that have lived in their Millcroft home for over 12 months) will be given the option of a new build flat (shared equity or rent) in Burns Road, while tenants of private landlords will be given advice regarding re-housing through the Common Housing Register depending on each individual’s points allocation for rehousing – including additional points for demolition.

The Coronavirus pandemic meant that it was it was deemed unsafe and unhelpful to carry out a refresh of the door to door Resident and Owners Survey. Following Committee Approval and the decision to carry out the CPO and new build homes at Millcroft Road, the Council have recruited extra personnel to form a dedicated Millcroft team. This team has been able to liaise with owners and residents directly in order to provide support though individual engagement, which has allowed for their circumstances to be fully understood and for the matching support to be allocated or provided. Information will continue to be gathered about Millcroft residents and housing options interviews carried out on a rolling basis where required.

Additional research will help us provide an appropriate supply and mix of new build housing, meeting a wide range of housing needs, to help support people to live well in their community.  In particular, additional data/research on the need for specialist provision will help us articulate the requirements in the Millcroft/Carbrain area and help improve the health and housing outcomes for residents.

Through this additional engagement with residents, a large number of international residents have been identified who have Student Visas. In the case of the CPO being confirmed, it has been possible to foster an agreement with local RSLs to rehouse residents with Student Visas and therefore avoid the risk of homelessness within this group of residents (given they do not have Rights to Public Assistance and would not be able to be rehoused via the Council).This is one such example of how continuing engagement with residents and local stakeholders can assist with managing some of the negative effects of the CPO. This will continue and knowledge of residents will improve right up to the point of when the CPO is determined.

What actions/measures will be put in place or are planned to mitigate any adverse impact or promote equality?

Continue to gather further evidence to identify the housing needs of residents and those with different protected characteristic groups that might be affected to help inform the Rehousing Strategy and improve resident and owner engagement.

What is the result/ recommendations of the EqIA

If the strategy to implement the CPO and construct new affordable homes is approved at committee and Scottish Government then engagement with residents will allow support for their rehousing needs.