Engagement plan from 19 December 2024 to 31 March 2025

Landlord name

City of Edinburgh Council

Publication date

19 December 2024

Why we are engaging with City of Edinburgh Council (City of Edinburgh) 

We are engaging with City of Edinburgh about its services for people who are homeless, service quality, stock quality and tenant and resident safety.  

The context in which local authorities are delivering services to people who are experiencing homelessness has become increasingly challenging in the last few years.  In our December 2023 update to our thematic report on homelessness services in Scotland we set out that there is systemic failure in the delivery of some local authorities’ services to people experiencing homelessness.  By this we mean that the demands on some local authorities now exceed their capacity to respond.  This is the case at City of Edinburgh.  We will continue to monitor, assess and report on City of Edinburgh’s performance in discharging its duties to people who are homeless, and we will engage with the local authority to promote improvement where this is possible. 

We are ready to work with the Scottish Government, City of Edinburgh itself and other stakeholders to identify and implement actions that will address the systemic issues affecting the delivery of homelessness services at City of Edinburgh. 

During 2023/24, we reviewed and compared the data for all local authorities from the Scottish Government’s national homelessness statistics.  We also spoke to all local authorities to gather further information and assurance about their homelessness services.  To assess the risks to people who are threatened with or experiencing homelessness we will engage with all local authorities during 2024/25 with a focus on the provision of appropriate temporary accommodation. 

We will engage with City of Edinburgh in particular about the following areas:  

  • how people access the homelessness services provided by City of Edinburgh;  

  • the provision of temporary accommodation by City of Edinburgh to people who are homeless; and  

  • outcomes for people who are homeless.   

In November 2024, City of Edinburgh decided to stop using unlicensed HMOs (Houses in Multiple Occupation) as temporary accommodation for people who are homeless. This meant it had to move households living in these HMOs into other forms of temporary accommodation at short notice. In order to do this, City of Edinburgh suspended non-emergency repairs and allocations, except for households with a disability and households being discharged from hospital, until early January 2025.  

We will engage with City of Edinburgh about how it is managing any risks to the homeless households affected, and about the impact these decisions will have on City of Edinburgh’s ability to comply with its statutory duties - particularly to provide suitable temporary accommodation – and its ability to achieve the Scottish Social Housing Charter outcomes and standards. We will engage with City of Edinburgh about the plans it will put in place to ensure that it can return to delivering a full repairs and allocations service to its tenants and service users as quickly as possible.  

To assess the risk to social landlords we reviewed and compared the 2022/23 service quality performance of all social landlords to identify the weakest performing landlords.  We have therefore already been engaging with City of Edinburgh about non-emergency repairs and the time taken to re-let homes. City of Edinburgh has made positive progress with a plan to bring empty homes back into use.  We have also been engaging with City of Edinburgh about complaints, rent arrears and inaccuracies in its reporting for repairs performance.   

City of Edinburgh has identified reinforced autoclaved aerated concrete (RAAC) in some of its homes. It has told us it has a plan in place to manage any associated risks. 

In July 2022, we contacted City of Edinburgh following media reports of dampness and mould in some of its high-rise blocks. City of Edinburgh shared an improvement plan that it had developed following a recent review of its approach to managing reports of dampness and mould across the city.  

Since then, City of Edinburgh has refined its improvement plan to align with good practice guidance and has completed most of the actions within it. This has included developing a new process for investigating and addressing reports of dampness and mould and recruiting additional resources to deliver this. 

We will continue to engage with City of Edinburgh to seek assurance that cases of dampness and mould are resolved timeously and effectively.  

City of Edinburgh has told us that a significant number of its tenants’ homes do not fully comply with electrical safety and fire detection requirements which came into force in early 2022 and form part of the Scottish Housing Quality Standard. City of Edinburgh is currently progressing inspections to provide Electrical Installation Condition Reports and to install integrated smoke and heat alarms in all of its tenants’ homes.   

City of Edinburgh has told us about challenges it has faced, including accessing tenants’ homes and the availability of contractors, which has delayed its progress to complete the outstanding works. We expect City of Edinburgh to have appropriate plans in place to mitigate the delays in progressing these works. 

City of Edinburgh is regularly non-compliant with its gas safety duties across a small number of tenants’ homes. City of Edinburgh has told us that its process for gas safety can lead to checks not being completed until after the required twelve-month period. 

 

What City of Edinburgh must do 

City of Edinburgh must:  

  • send us the information we require in relation to its homelessness service;   

  • continue best efforts to meet its statutory duty to provide temporary accommodation when it should and to comply with the Unsuitable Accommodation Order; 

  • keep us updated on its capacity to meet its statutory duty to provide temporary accommodation when it should and to comply with the Unsuitable Accommodation Order; 

  • by 7 January 2025 provide us with details of its plans to return to the delivery of a full repairs and allocations service to tenants and service users and provide us with monthly updates on its progress with these plans;  

  • send us the information we require about the actions it is taking to improve its performance on complaints, non-emergency repairs, re-let times and rent arrears and to address inaccuracies in its data collection and recording; 

  • tell us if there are any material adverse issues which might affect its capacity to manage the risks associated with RAAC; 

  • provide us with assurance that it is resolving any reported cases of dampness and mould timeously and effectively; 

  • send us monthly updates on progress on achieving compliance with electrical safety and fire detection requirements; and 

  • comply with its statutory gas safety duties, provide us with a plan by 31 January 2025 which sets out how it will ensure compliance with these duties, and provide us with monthly updates on its progress with this plan.  

 

What we will do 

We will: 

  • review the information City of Edinburgh provides about its homelessness service and engage as necessary;  

  • meet with City of Edinburgh on a monthly basis to discuss its homelessness service and engage as necessary;  

  • meet with City of Edinburgh to seek assurance about its best efforts to provide suitable temporary accommodation; 

  • review City of Edinburgh’s plans to return to the delivery of a full repairs and allocations service, monitor its progress with these plans and engage as necessary; 

  • review the information that City of Edinburgh provides about its work to improve its service quality performance and address the inaccuracies in its data collection and recording and engage as necessary;  

  • review any information City of Edinburgh provides about RAAC in its homes and engage as necessary; 

  • meet with City of Edinburgh on a monthly basis to seek assurance it is dealing effectively with dampness and mould in its homes; 

  • review City of Edinburgh’s progress on achieving compliance with electrical safety and fire detection requirements and engage as necessary; 

  • review City of Edinburgh’s plan to comply with its gas safety duties, monitor its progress with this plan and engage as necessary; and 

  • update our published engagement plan in the light of any material change to our planned engagement with City of Edinburgh.   

 

Regulatory returns  

City of Edinburgh must provide us with the following annual regulatory returns: 

  • Annual Assurance Statement; and  

  • Annual Return on the Charter. 

It should also notify us of any material changes to its Annual Assurance Statement, and any tenant and resident safety matter which has been reported to or is being investigated by the Health and Safety Executive or reports from regulatory or statutory authorities or insurance providers, relating to safety concerns. 

 

 

Our lead officer for City of Edinburgh Council is:

Stephen Lalley

Regulation Manager