Consultation Response

Consultation Response – ‘Proposed changes to guidance on evaluating the extent of rough sleeping’

About the Simon Community

The Simon Community has been in operation since 1963 living and working with homeless people in London.  It currently runs services almost every day of the year making contact with over 180 people on an almost daily basis.  We are intimately connected to the lives of people sleeping rough and homeless in the capital through regular outreach work, our house of hospitality and our residential house.  The Simon Community model has inspired innovation in others since its inception and we continue to pride ourselves on our independent and pioneering way of working.  We have carried out regular counts of people rough sleeping in central London as an independent verification of the issue.

As we approach our 47th anniversary we continue to see a need for our services and voice which meets a need where no other provision exists.

Summary Comment

This is a welcome chance to discuss the issue of recording the numbers of rough sleepers, particularly in London.  The system has been flawed for many years and this is a timely attempt to re-look at the issue.  There is a helpful refining of the definition of a ‘rough sleeper’ and a move towards independent voluntary sector verification of the counts.  However we are extremely concerned that allowing local authorities to estimate numbers will lead to under – counting of the figures as happened in 2009.  We are also concerned that the guidance omits any explicit reference to the role of police and other agencies in the preparation and carrying out of counts.  This is the time to explicitly rule out the use of tactics of moving on in preparation for a count.  Given its record in speaking out on these issues in opposition the government should act on them when in power.  If the issue of homelessness is to be tackled a true picture of the situation must be built up and acted upon. 

This paper sets out detailed responses and recommendations informed by this position in response to the paper Proposed changes to guidance on evaluating the extent of rough sleeping (DCLG, 2010):

Main changes proposed

1.   Conducting street counts to be a choice for individual local authorities.

This is a major cause for concern and is the main problem with the proposed changes.  We are worried that local authorities opting out of counting may lead to an under-counting or misunderstanding of the problem.  It has been reported that in 2009 total national figures were wrong to the tune of some 807 people.  We also know that, particularly in London, rough sleepers often move from one local authority to another.  We would be extremely disappointed to see any local authority opt out of its obligation to count.


2.   Local authorities should submit an estimate of the number of people rough sleeping on a typical night.

Estimates are a further way for inaccuracies to creep into the system.  One local authority estimating 25 when the total is 35 may not be a major issue for that local authority.  However for the whole country of 433 Local Authorities to make estimates the scope for mistakes is unacceptably high.

3.   The definition of rough sleeper to be expanded.

This is a welcome change and the changed definition takes a more common sense approach.

4.   To encourage neighbouring local authorities to count on the same night.

This is a sensible step but the guidance should go further and demand (particularly for central London boroughs) that this instruction be followed.  We are concerned that people in one borough can be moved on (or indeed move themselves) from one borough to another in advance of a count.  To carry out one count across all of central London would eliminate the chances of this happening.  One local authority’s ‘success’ in reducing numbers could become the next borough’s ‘failure’ to deal with the problem. 

5.   To move the recommended starting time to 2am.

This is a sensible approach as it will give a truer picture of rough sleeping.  It may make the job of recruiting volunteers harder but will be worth the effort.  It is critical that local knowledge be used to understand where people will be at this time as it may be that previously unknown locations are being used.

6.   Responsibility for independent verification of counts will shift from CLG to Homeless Link members.

We welcome the move towards verification by a body outside of government.  We would expect to see that independence respected and reports by the verifiers to made publicly available.  These reports should include sections on the role of the police and the treatment of rough sleepers (see comments below at point 2).  We would also like to see the opportunity expanded to those agencies who choose not to be homeless link members but can demonstrate capability and experience to do this important task.  Finally, we would expect that voluntary organisations are properly paid for this work rather than outsourcing a government responsibility with no budget.

Notes on draft guidance

In addition to the comments above about those points highlighted by the consultation we would like to make the following observations:

1.   Numbers are not enough. 

As the guidance states that this information will be used to help commission local services, it is essential that qualitative data are collected.  Feedback on current services (by those who use them and those who do not) offered, focus group work and, above all, the CHAIN datasets need to be part of the commissioning decision.  The voice of people experiencing homelessness should be central to an intelligent commissioning decision.

2.   The role of the police must be clarified.

In the past police and other local authority agencies have been involved in moving people on in advance of a head count.  There must be really clear guidance on this to stop it happening.  It is a gross misuse of public funds and a clear line on it in these instructions should eliminate the practice once and for all.  Independent verification should include some oversight of this issue.

3.   The rights of rough sleepers.

There are references to waking people who are rough sleeping in ‘order to get information from them that may be helpful’.  This must be removed.  It is not acceptable to wake somebody to gather information from them.  Any information about where people are sleeping should be gathered from voluntary agencies and outreach workers prior to the count.  If there is a major cause for concern about an individual a trained outreach worker or emergency services should be called as with any member of the public.

4.   Use of information.

There needs to be an understanding that the data collected should be used to gather an overview of the situation.  In conjunction with other information it can be used to make general decisions about the use of resources.  It should not be used to record information about individuals.

5.   Timing of counts and the link to the ‘zero target’.

It should be understood that counting at one time during autumn will only give a limited view of the situation.  Some of the more complex issues around the seasonal differences in rough sleeping will not be revealed by this approach.  The problems associated with seasonal labour in summer and extreme cold in winter should not be overlooked.  For example, a count earlier this year revealed that even with cold weather shelters open revealed large numbers rough sleeping in Westminster. This is an issue for us all to deal with and we cannot afford to get caught up in celebrating fluctuations in a general upward trend.  The emphasis should be on an honest appraisal of what people need and what works in the long term.  We cannot afford to see the issue become a political football in the run up to the 2012 target and the Olympic games.

Simon Community, August 2010.


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