Housing for a Multiracial Society – Review Response – November 1999

1 November 1999

Housing for a Multiracial Society

 A Response to Scottish Homes’ Review 

Of the Ethnic Minority Housing Strategy 

For Glasgow 1995-1998 and the Consultative

Report on Key Findings and Draft Action 

Plan for 1999-2002


November 1999






1. Positive Action in Housing (PAiH) is a black & minority ethnic housing organisation, working to combat racial harassment and black homelessness in Scotland. Throughout its work, PAiH draws its perspective from those at the margins of society. This has meant supporting issues that affect their daily lives – homelessness, racial harassment and attacks, enduring unmet housing needs and restricted employment and training opportunities.


2. We welcome the opportunity to comment on Scottish Homes’ Ethnic Minority Housing Strategy for Glasgow, particularly as we submitted a widely circulated response to the draft Race Equality Policy in 1994. We also welcome the progress made by Scottish Homes and the Housing Association movement since the Commission for Racial Equality’s formal investigation in 1993, but remain conscious of the persistence of racial disadvantage, discrimination and harassment within the housing sector.


The Consultation Exercise


1. The Consultative Report is jargon-heavy and presents a barrier to genuine partnership.


2. We are concerned that Positive Action in Housing was not involved at the review stage of the Strategy. Given that responses are needed by November 99 and the Action Plan will be published in December 99, what real scope is there for our views to be taken into account?


3. This paper details Positive Action in Housing’s concerns about the Consultation Paper. We comment on the overall Strategy and answer the questions posed on the Draft Action Plan. This paper should be read in conjunction with Scottish Homes’ Consultation Paper.


The Corporate Strategy


1 In 1994, Scottish Homes set out to ‘become the leader of racial equality in Scotland’. At the same time, the Commission for Racial Equality warned that unless Scottish Homes demonstrated leadership within three years this would ‘lead to doubts over Scottish Homes’ commitment to racial equality’.


2 According to the recently published review[1] of the Strategy, Scottish Homes ‘has fallen short of its aspiration to be a leader in racial equality’. In light of this, we are forced to question Scottish Homes’ commitment to racial equality. In our view, the Strategy failed to perform well in key areas because of several factors:


2.1 Midway through the Strategy, Scottish Homes did not replace its Race Equality Officer who played a crucial role in disseminating information and building links and confidence with grassroots black & minority ethnic organisations.


Scottish Homes ignored pressure

2.2 from the Commission for Racial Equality, the Housing Equality Action Unit, the SFHA and black & minority ethnic groups to develop a specific and costed strategy to support black & minority ethnic led housing associations. The complementary approach of specialist and mainstream housing provision offers:


An unrivalled specialism in black and minority ethnic needs;

Genuine self-determination to black and minority ethnic communities

The impetus to the mainstream housing movement to follow best practice in black and minority ethnic housing provision.


2.3 Scottish Homes has failed to sufficiently involve black & minority ethnic organisations in several areas of its work. We should be able to expect this level of accountability and co-working from a publicly funded housing agency.


Investment Programme (Page 3)


1. We are pleased that there was an overspend of the £5.0 million targeted at Glasgow for the period 1995-98. This was a step in the right direction towards addressing historical discrimination and exclusion of black and minority ethnic communities since the 1950s within the public and then the voluntary housing sectors.


2. We are very disappointed that Scottish Homes is u turning on ring-fenced funding. Ring fencing made Scottish Homes accountable to black and minority ethnic communities and encouraged the development of schemes or housing for black & minority ethnic needs.


3. Despite the commendable efforts of a small number of housing associations, Scottish Homes failed to allocate sufficient ring-fenced money to address the pressing need for larger housing and other types of housing in safe areas. The lack of larger housing in safe areas can also be attributed to Scottish Homes’ development funding regime, which militates against the building of larger housing.


4. We recommend that Scottish Homes:


Continues ring-fenced funding;

Increase this ring-fenced money to £75 million over the period 1999-2002;

Define the unmet housing needs to be addressed in partnership with Positive Action in Housing and black and minority ethnic housing agencies.


Black and minority ethnic-led housing associations


1 The Commission for Racial Equality in its 1993 investigation of housing providers called on Scottish Homes to support black and minority ethnic led housing associations. Positive Action in Housing supports it, the government, the Housing Corporation, the SFHA and the Commission for Racial Equality – so why not Scottish Homes?


2 Positive Action in Housing has supported local groups in their attempts to set up black and minority ethnic housing associations. But, without the close involvement and resources from Scottish Homes, this approach is unlikely to reach fruition. We would like to see development funding targeted towards black and minority ethnic housing associations. Such an approach would complement mainstream housing provision in the same way as disability or older peoples’ housing has been developed by a combination of specialist and mainstream.


Allocations (Page 3/4)


1 Tenant Representation


2 We are pleased to note that black and minority ethnic tenants represent 19.2% of core-area housing associations. But the document does not state the percentage of black and minority ethnic lets across Glasgow. We would expect the target to be at least 5%.


3 We are pleased to see an increase (of 38%) in the number of black and minority ethnic tenants of the core area housing associations, but remain conscious of the steady decreasefrom 95-98 in the number of lets to black and minority ethnic tenants in Glasgow and Scotland as a whole.


4 This must be seen against the sharp increase in housing referrals to Positive Action in Housing. During 1998/99 we received 743 enquiries, 92% from Glasgow[2].


5 The latest SCORE Statistics (SFHA) shows that for 1998/99 only 1.5% of lets went to black and minority ethnic households. SCORE’s explanation for this decrease is ‘the decline in the inner city building programme in favour of the outer estates’[3]. We disagree with this view, particularly as ring fencing for black and minority ethnic housing was only just kicking in against the grain of the national development strategy[4].


6 Shared Ownership


7 In 1998/99 both shared ownership and GRO grants proved beyond the reach of black and minority ethnic communities[5]. Additionally, there is no reference in the Scottish Homes document to the poor take up of shared ownership.


8 We are aware of the strong preference amongst our service-users for a route to home ownership, not least to establish a sense of security. Historically[6], and today, black and minority ethnic people are unlikely to get a foot on the ladder to home ownership in the public and voluntary sectors because of exclusion and poverty[7].


9 The three main problems facing black and minority ethnic tenants during 1998/99 are:



Racial harassment and,



10 The problem of severe overcrowding in our communities has existed – and been researched exhaustively – for decades. The problems have multiplied several times over because of the failure to build sufficient 3,4 and 5 apartments in safe, multiracial areas.[8]


11 Research carried out by the University of Stirling[9] found that the scale of overcrowding in Glasgow’s black and minority ethnic communities is FIFTEEN times greater than it was[10] ten years ago. Specifically, Pakistani households are ELEVEN times more likely to suffer overcrowding than the general population.


12 We are concerned that housing providers have sometimes suggested that overcrowded families should separate into smaller units. This flawed approach places an expectation on black and minority ethnic families to fit into a housing system traditionally geared to the needs of a white – rather than a multiracial – society.


13 Our success rate with helping families to be rehoused is severely hindered by the lack of suitable housing in safe areas. Only 47% of cases were resolved in less than 6 months. 14.3% were resolved in 6-12 months. 38.8% were resolved in more than a year. 8% of our cases are unlikely to ever be resolved because of lack of suitable housing in multiracial areas.


Raising Awareness & Promoting Involvement (Page 5)


1 We fully support Scottish Homes’ commitment to work with any group dedicated to the housing interests of black and minority ethnic communities.


2 Scottish Homes has a duty to consult all key partners concerned with black and minority ethnic housing interests. This includes partners funded/influenced by Scottish Homes, e.g. WOSREHF. It also includes black and minority ethnic organisations not funded/influenced/controlled by Scottish Homes. Consulting widely and openly helps to ensure accountability and inform public policy. It is pointless being selective or exclusive about which partners are to be involved in the review of the Ethnic Minority Housing Strategy. (See also 2.1 – 2.3).


3 Outreach Work and Supported Ethnic Minority Community Groups


4 Without performance indicators it is difficult to ascertain progress. How successful have outreach projects been in qualitative and quantitative terms? For example,


How did Scottish Homes measure the ‘significant impact’, which led to a raised profile of housing associations amongst black and minority ethnic communities?


How did Scottish Homes assess the ‘improved cultural and racial awareness among Association staff and committee members’?


What has changed in the associations’ mainstream practices or services to black and minority ethnic communities as a result of outreach work?


We should like to see performance indicators for outreach work in order to be clear about the level of success or otherwise.


5 Promoting Involvement in Housing Associations (pp5-6)


6 We welcome the progress made to promote black and minority ethnic shareholder membership.


7 However, the figures on committee representation are most disappointing. In a three-year period, Scottish Homes has managed to recruit only SIX black and minority ethnic committee members. We are also conscious of the reality of tokenism on mainstream committees.


8 In 1996, Scottish Homes concluded that[11] “Although there have been some successes in participation, fundamentally community based housing associations as a group cannot be said to effectively represent in membership or management the local communities they aim to serve, and the community participation ethos has to date failed to embrace effectively ethnic minority groups.” How successful has the Strategy been to promote empowerment of black and minority ethnic communities in Scottish Housing?


9 What difference does the presence of one or two black committee members make to black and minority ethnic housing issues in mainstream housing associations? We fully support Scottish Homes comments on this issue: “There is no evidence to show that the presence of one or two black and minority ethnic committee members have any measurable effect in steering Associations towards improved targeting of Ethnic Minority housing needs. Only in those Associations with substantial representation (e.g. Charing Cross Housing Association) is there a clear link between membership and improved provision.”[12]


10 Positive Action in Housing believes that the empowerment and genuine involvement of black and minority ethnic communities (in order for black and minority ethnic issues to be considered in the mainstream) will only happen once:


There is a level playing field

Scottish Homes supports black and minority ethnic housing associations[13].


11 We recommend that Scottish Homes gets to grips with its own findings from 1996 about the reality of black and minority ethnic involvement on mainstream committees (rather than point to disparate numbers on a handful of committees as a measure of black and minority ethnic empowerment and influencing of black and minority ethnic issues).


12 It would be wrong to assume that black and minority ethnic members are/should be interested in the race equality aspects of the committees’ agenda, or that the responsibility for race equality lies with black and minority ethnic members. The responsibility, of course, lies with the entire management committee.


8 Taking the Strategy Forward – Page 7 


1 Potential for Improvement (p7)


2 The targets for the Social & Environmental Grant programme and the GRO grant would have been met had there been a properly targeted and widely circulated information campaign for black and minority ethnic organisations. Both these grant possibilities could benefit many black and minority ethnic people in housing need. What measures will be taken to use GRO grants to address black and minority ethnic needs with private developers? How do we know that black and minority ethnic people in housing need are not facing indirect discrimination?


3 What was the ‘degree of variance among core area housing associations with regard to the nature of their approach to improving performance in meeting ethnic minority needs?’ This is unclear.


4 Withdrawing ring fenced funding


5 In March 1997, Scottish Homes stated[14] that ring-fenced funding would be discontinued after 1998, ‘as appropriate structures and procedures will by then be in place to ensure balanced Housing Association provision through mainstream housing allocation and development programmes’.


6 We are disappointed that Scottish Homes is withdrawing ring-fenced funding despite the fact that its own review proves that the agency has failed to adopt ‘appropriate structures and procedures’ to ensure proper attention is paid to black & minority ethnic housing needs[15].


7 For several years, the Housing Corporation has been dedicated to ring-fenced funding to meet black and minority ethnic housing needs. So why, in the light of its own poor Review, does Scottish Homes still insist that it doesn’t need ring-fenced funding?


8 We strongly recommend that Scottish Homes continue ring-fenced funding, instead of disbanding it in favour of structures that are simply not working for black & minority ethnic communities.


9 Target Setting (pp7-8)


10 Scottish Homes Registration & Supervision should be sensitive to which part of the ethnic minority strategy they emphasise to core area and non-core area housing associations. For example, target setting for black and minority ethnic committee members by non-core housing associations may be unrealistic or result in tokenism.


11 We estimate the figure for Glasgow’s black and minority ethnic population to be around 5%[16]. Scottish Homes should set a 5% target for the black and minority ethnic representation in Glasgow housing associations.


12 Housing Associations in multiracial areas should set targets (for black and minority ethnic tenant representation) that are higher than their area of operation to take account of historical disadvantage and the disproportionately higher level of housing deprivation found in black communities. These housing associations should set targets for committee and shareholder membership that reflect the ethnic composition of their areas of operation.


13 What measures will Scottish Homes Registration and Supervision take to support and lead housing associations towards fulfilling their targets? What punitive measures will Scottish Homes take against housing associations that fail to comply with the Strategy?


14 Racial Harassment Policies


15 In non-core areas, the implementation and monitoring of effective racial harassment policies and procedures requires specific attention[17]. The best support mechanism to enable ethnic minority households to sustain their tenancies (especially in non-core areas) is to see a demonstrable record of the housing association or co-op to get rid of racist tenants – fast – and put a stop to racial harassment in and around the neighbourhood – fast. Otherwise it is unlikely that black and minority ethnic tenants will wish to move or remain there – particularly in non-core areas.


9.                Partnership Working (p8)


1 We welcome Scottish Homes’ commitment to work with ‘all key partners’ during 1999 – 2002. We welcome Scottish Homes’ invitation to respond to consultation documents such as this. However, we would appreciate earlier involvement in the development of the race equality strategy.


2 We are concerned that Scottish Homes appears to expect black and minority ethnic organisations to become members of other organisations in order to gain access to the consultation/partnership process. This is wholly unacceptable.[18] Scottish Homes must consult openly with all black and minority ethnic organisations with a housing interest.


Direct Action by Scottish Homes (p9-10)


1 Given the past failure to develop Strategy & Development Funding Plans and Programme Agreements why is Scottish Homes favouring this route over ring-fenced funding? This approach lacks clarity, accountability and hard targets in monetary terms. It is a step in the wrong direction for the Ethnic Minority Housing Strategy. (See 8.4-8.8).


2 Geographical areas


3 Various reports show that ‘area’ is the most crucial and sensitive factor in the right move for black and minority ethnic communities, yet Scottish Homes seems to be making a decision about which areas are right for our communities.


4 Outreach


5 We are unclear as to the quantifiable benefits of outreach work. What happened to the workers on these temporary projects? Were they taken on by the housing associations after the project’s ended? Was the project work integrated into the mainstream housing associations work after the project money ran out? Where is the monitoring framework to assess these factors?


6 Funding for Best Practice


7 Will external grant funding during 1999–2002 to develop best practice guidance and training/awareness sessions for housing association staff and committee members be accessible to black and minority ethnic organisations?


8 Awareness Training


9 What are the performance indicators for assessing the impact of training/awareness of ethnic minority housing issues for Scottish Homes’ staff?


Questions for Consultation (pp10-11)

1 The consultation document asks specific questions about the Action Plan. We would add the following to support the previous points.


2 How can Scottish Homes and its housing association partners work more effectively together to meet the future housing needs of ethnic minority communities in Glasgow?


By consulting openly with black and minority ethnic organisations with a housing interest. By involving black and minority ethnic organisations at the start of the consultation process – not the end. Not ignoring black and minority ethnic organisations as key partners. By calling on Scottish Homes Board to support the setting up of black and minority ethnic led housing associations.


3 How can ethnic minority households in Glasgow be further encouraged to apply for social rented housing out with traditional core settlement areas?


Racial harassment and the fear of racial harassment determine black and minority ethnic households’ choice for housing.   It is disappointing that Scottish Homes proposes that minority ethnic households in Glasgow should seek social housing out with core settlement areas, having not sufficiently addressed these communities needs in their areas of preference. (Minority ethnic applicants have risen by 15% on the ‘core area’ housing association waiting lists since 1994/95.)   In the absence of a track record of anti-racist work in non-core areas, black and minority ethnic communities are vulnerable and likely to suffer from racial violence, racial abuse and isolation[19]. Furthermore they will have no infrastructure of community support and people will be living in fear of their lives. This question smacks of social engineering and dispersal of black and minority ethnic communities so that numbers aren’t a problem. Whatever happened to self-determination and the individual’s right to live where he/she chooses? Do black and minority ethnic communities not have the right to choose? Why should black & minority ethnic households be coerced into moving anywhere they don’t want to? Their reluctance should speak for itself.


4 How can housing associations and other public sector landlords support ethnic minority tenants who take up rented housing in areas out with traditional core settlement areas? 


By having well implemented racial harassment policies with a demonstrable track record of stopping racial harassment in its tracks and protecting black & minority ethnic tenants without quibbling or playing down the problem.


5 How can housing associations across Glasgow improve access to their existing housing for ethnic minorities and what role can Scottish Homes and key partners play in this process?


By supporting a black & minority ethnic housing association and learning from its expertise and experience.


6 Are our proposals on target setting reasonable?


No. See Section 8.8-8.13.


Black & Minority Ethnic Tenant Representation 


We expect the target for black & minority ethnic tenant representation for core area housing associations to be at least 30%, given the high ethnic minority populations and the level of housing deprivation caused by:


Past exclusion

Failure to address unmet needs, and

Institutionalised racism


Representation of black & minority ethnic workers


How many black & minority ethnic workers were recruited during 1995-98? What is the representation of black and minority ethnic workers in Glasgow housing associations? Why was this issue not covered in the Glasgow Strategy? There is no reference to targets being set for the recruitment of black and minority ethnic workers and trainees. We suggest that Scottish Homes sets a target of 5% black and minority ethnic workers across Glasgow, much higher in multiracial areas. Representation should be monitored across all levels of seniority in the workforce. The figures should be made available publicly.


Are our proposals on SDFPs and Programme Agreement reasonable and what might the timescale be for their phased implementation from core areas to the outer city and the wider region? 



No. See 8.4–8.8. Scottish Homes should revert to the ring-fenced approach and more vigorously and appropriately target ring-fenced money to specific/unmet black & minority ethnic housing needs in open consultation with black & minority ethnic organisations including Positive Action In Housing.




Given the findings from our review, what should our key measurable objectives be, and how can they best be monitored?


As stated earlier, t

he report makes no reference to the numbers of black & minority ethnic workers recruited during the period 1995-98. This is surprising as the recruitment of black & minority ethnic workers is an important issue for Scottish Homes to be promoting. What was the experience of PATH trainees taken on in Glasgow? What support is to be given to PATH Scotland?


We recommend that PATH Scotland receives core funding of at least £75,000 per annum from 2000-2003. We are also disappointed that, give Scottish Homes poor track record of recruiting black and minority ethnic workers, Scottish Homes has only taken up one or two PATH trainee. We recommend that Scottish Homes takes up ten PATH trainees in Glasgow over the period 1999-2002 and persuades those housing associations in multiracial areas with under-representative workforces to recruit PATH trainees in appropriate numbers.


We have serious reservations about the proposal for Strategy & Development Funding Plans in the absence of ring-fenced funds. As Scottish Homes own review demonstrates, housing associations may not have the relevant knowledge and specialist skills required in assessing the unmet housing needs and aspirations amongst the minority ethnic communities.


The failure to strategically plan and provide for the specific/unmet needs of black and minority ethnic communities is a significant factor of the low number of lets. It is time that a race equality strategy combined with strong policy enforcement addresses the needs of black and minority ethnic communities living in multiracial areas. We strongly feel that such a strategy would be best carried out by a programme of ring fenced funding of at least £75 million over the next three years.   This strategy should be focused on:


Building housing


Supporting black and minority ethnic organisations to take up partnership with housing providers, and


Supporting black and minority ethnic groups to manage/own houses as housing associations in their own right.


This would lead to empowerment of black communities as committee members, shareholders and employees within the Scottish housing movement.


We recommend that the main development priorities for black and minority ethnic communities over 1999-2002 is:


Suitably designed sheltered housing for Indian/Pakistani elders in safe, multiracial areas [20].


A vigorous development programme to build three, four and five apartment housing in safe, multiracial areas.


Positive Action in Housing[21]

November 1999







Scottish Homes Glasgow & North Clyde Region

Review of the Ethnic Minority Housing Strategy for Glasgow 1995-1998 – Consultative Report on Key Findings and Draft Action Plan (1999)


SFHA SCORE Housing Association Lettings In Scotland

The Score Annual Digest 98-99 (October 99)


Scottish Homes Glasgow District Office

Ethnic Minority Housing in Glasgow – Development Funding Strategy (1996)


Positive Action in Housing

4th Annual Report (1999)


Housing Equality Action Unit

Ethnic Minority Housing Response to the Consultation Paper (1994)


Positive Action in Housing

Investing in Modernisation – Response to the Government Green Paper (June 1999)


Positive Action in Housing

Position Paper: Ethnic Minority Led Housing Associations (November 1995)


Scottish Homes

Action for Racial Equality (October 1994)


Housing Equality Action Unit

Black & minority ethnic housing associations – Myths and Realities (1992)


Housing Equality Action Unit

Ethnic Minority Housing – Testing Good Intentions (June 1995)

[1] Organisational Development Support 1999

[2] Our statistics[2] show a clear link between poor housing, poor health and poverty.

[3] SCORE Statistics

[4] There was a steady increase in money from 95/96 (£1.258m) to 98/99 (£3.287m) for black and minority ethnic housing needs.

[5] We note from SCORE statistics that in 1998/99, only one sale to a ‘non-white’ household was recorded out of the 388 sales (0.003%).

[6] In the eighties and nineties, black and minority ethnic people lost out on right to buy because of exclusion and racial harassment from the council housing sector.

[7] To qualify for shared ownership, you must have a minimum level of income.

[8] We are aware of several cases where families with two or three children have been waiting years, even a decade or more for suitable sized housing.

[9] “Too white, Too Rough, Too Many Problems…”

[10] Experience of Ethnic Minority Housing Applicants Glasgow 1989 Glasgow City Council

[11] Ethnic Minority Housing in Glasgow – Scottish Homes Glasgow District Office – Development Funding strategy (1996)

[12] Ethnic Minority Housing in Glasgow – Scottish Homes Glasgow District Office – Development Funding strategy (1996)

[13] As we have always stated, such associations have an excellent track record of involving black and minority ethnic people as shareholders, committee members and give them the experience and skills to work effectively in mainstream housing associations.


[14] Scottish Homes Ethnic Minority Housing in Glasgow – Development Funding Strategy (March 1997)

[15] We also note that most ‘housing association Strategy & Development funding Plans and Programme Agreements have not provided sufficient analysis of the local housing needs of ethnic minorities or developed targets for anticipated future demand’.

[16] Although the 1991 census says Glasgow’s black and minority ethnic population is 3.2% these figures are almost ten years out of date. They are also under-representative of the black and minority ethnic community because of under-reporting.

[17] Racial harassment (actual or potential) and community support are two issues consistently highlighted as the reason why black and minority ethnic communities prefer to remain in multiracial areas.

[18] Otherwise this raises questions as to why Scottish Homes is not helping Positive Action in Housing to increase its membership.

[19] From research undertaken by Scottish Homes (The Experience of Households from Minority Ethnic Groups in the Scottish Housing System. 1994) the findings clearly state that ‘racial harassment and attack was a key issue for many minority ethnic households and there was a dominant concern to live in safe neighbourhoods’.

[20] Research carried out by Positive Action in Housing (1999) for Bield, Hanover and Kirk Care Housing Associations shows a high projected need over the next 20 years. These groups appear to be overlooked.

[21] Thanks go to Akhtar Khan for help in preparing this response.


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