The sub-committee received updates on the council's Homelessness and Rough Sleeping Strategy 2023–2027 and considered the implications of the expiry of the current Rough Sleeping Initiative funding in March 2025. Members were informed of the increasing costs of temporary accommodation and the City of London Police’s three-stage method of tackling begging and rough sleeping, known as Operation Luscombe. Members also heard a presentation on work that has been undertaken to make the provision of services for rough sleepers more collaborative.

Tackling rough sleeping and tented encampments

Chief Inspector Nikki Gander from the City of London Police informed Members of the three-stage ‘traffic light’ method used by the City of London Police to tackle begging, and to ensure people sleeping rough in the City of London are offered support.

The first stage involves issuing a green warning card, which asks the individual to refrain from begging in the City for 12 months. Individuals are also provided with an invitation to a fortnightly support and intervention hub held at St Botolph's Church, where the individual can receive help from a range of specialist organisations. If caught begging again, the individual is issued with an amber card, which is equivalent to a Community Protection Warning. A red card, which is equivalent to a Community Protection Notice, is issued for a third offence. Continued begging after a red card can lead to the City of London Police applying for a Criminal Behaviour Order against the individual.

Chief Inspector Gander provided an update on the number of cards issued since April 2024:

20 green tickets (Invitation to the hub)

9 amber tickets (Equivalent of a Community Protection Warning)

3 red tickets (Equivalent of a Community Protection Notice)

1 blue tickets (Reported for begging offence)

She also provided an update on the progress of Criminal Behaviour Order applications:

Currently only one CBO has been issued by the court and the individual has not been seen in the City since. We are currently processing a further CBO application for continued begging despite all warnings/referrals being given.

Members were informed that attendance at the Hub has been mixed recently, with many attendees being repeat visitors who go to the Hub primarily to receive food and drink. However, Chief Inspector Gander stressed that:

This is still essential to ensuring a welfare and diversion approach to begging prior to any enforcement activity.

Chief Inspector Gander also confirmed that the City of London Police are currently looking at alternative offers of support to Operation Luscombe.

Chief Inspector Gander updated Members on rough sleeping “hotspots” in the City. She informed Members that the Community Multi-Agency Risk Assessment Conference (MARAC) has made referrals relating to two rough sleeping encampments. The first of these encampments is located at Peninsular House on Monument Street. The second is located at Castle Baynard Street.

These referrals led to a partnership approach between the Corporation, outreach teams, and the City of London Police. Chief Inspector Gander said that this partnership approach has “identified a need for a joint policy/approach to tackling the negative impacts of rough-sleeping” which is currently being led by Simon Cribbens, Assistant Director of Commissioning and Partnerships at the City of London Corporation.

Chief Inspector Gander added that after an incident at the Castle Baynard Street encampment in September:

CoL and CoLP reviewed the risk of leaving empty/abandoned tents in situ and agreed a low-level joint operation to remove abandoned tents and provide a cleanse in the area. This also provided a further opportunity for all those present to engage with outreach services and receive support. Positive feedback from all parties. There has been a slight increase in new tents since.

Chief Inspector Gander finished her update by informing Members that:

Due to the ongoing and challenging nature of the issues around rough-sleeping and tented encampments it has been agreed within the CCM to create a specific partnership team, using the SARA model to focus on identifying appropriate solutions, engagements, processes to ensure a balanced, risk assessed approach.

Homelessness and Rough Sleeping Strategy 2023-2027

Will Norman, Head of Homelessness Prevention and Rough Sleeping at the City of London Corporation, provided Members with an update on the council’s Homelessness and Rough Sleeping Strategy 2023–2027, including a summary of progress against the aims set out in the strategy, and a commentary on the strategy’s Performance Scorecard and accompanying Dashboard charts.

Mr Norman explained that:

38 actions have commenced – four more than the last period

25 actions are currently live (underway with/without issues) – one more than the previous period

13 actions are now completed – three more than the last period

Mr Norman highlighted several key points about rough sleeping in the Square Mile, including:

The number of rough sleepers recorded in the period...has decreased by 15% to 256. While this figure is still high, this is the lowest quarterly total since Q2 2023/24.

The number of rough sleepers occupying high-impact rough sleeping sites...has increased sharply in the period due to work carried out by commissioned services at Castle Baynard Street.

The rate at which the service is making accommodation placements for rough sleepers is significantly higher at the mid-point in the year than it was at the same point in 2023/24.

However, Mr Norman also noted that despite the successes, challenges remain:

Referrals to specialist substance misuse services...decreased for the second consecutive quarter – from 35 in Q1 to 25 in Q2. Officers are currently analysing data to measure our understanding of assessed need against the rate of referral to explore the source of the trend.

City of London’s response to the Ministerial letter on Rough Sleeping

Members received a report from Ian Tweedie, the Head of Service for Adult Social Care at the City of London Corporation, about the council’s response to the ‘Recommendations for Safeguarding Adults Boards Regarding Individuals Rough Sleeping’ Ministerial letter, which was sent to all Directors of Housing and Directors of Adult Social Services in England, and all Safeguarding Adults Board Chairs in May 2024.

The letter identified the importance of Safeguarding Adults Boards in the multi-agency response to rough sleeping, and made recommendations in four areas:

• Governance structure, accountability, and system-wide change
• Named board member for rough sleeping
• Strategic plans, annual reports, and procedures
• Safeguarding Adult Reviews

Mr Tweedie reported that the City of London Corporation’s response to the Ministerial letter identified that the City of London “has a mature system in place in relations to rough sleeping” and provided assurance to the City and Hackney Safeguarding Adults Board that the council is able to meet the recommendations made in the Ministerial letter.

Mr Tweedie added that Dr Ade Cooper, the independent Chair of the City and Hackney Safeguarding Adults Board, has formally noted that the board is happy with the council’s response to the Ministerial letter.

Rough Sleeping Initiative Funding

Members heard a report from Will Norman, Head of Homelessness Prevention and Rough Sleeping at the City of London Corporation, about the implications for the council’s Homelessness and Rough Sleeping service following the expiry of the current tranche of Rough Sleeping Initiative (RSI) funding in March 2025.

The report explained that while “an extension of funding (or an entirely new grant programme) is expected”, the government is yet to confirm its spending commitment. This means that there is currently a great deal of uncertainty around how much funding the council will receive to tackle rough sleeping from April 2025, when the funding is due to be renewed. This uncertainty presents the council with a number of challenges:

At a local level, the amount of funding is unknown. If the funding amount is less than the current award, we will need to consider ending or amending current work funded through the RSI, or fund the work from the City Fund.

The timing of any grant determination has a bearing on decision-making. Some contracts are set to expire during 2024/25. Without notification of further funding, all contracts will need to end by 31 March 2025.

Any grant award for 2025/26 is expected to be limited to 12 months in duration.

Mr Norman added that while no formal announcement has been made, the council expects to hear from the government about the renewal of the RSI funding in December 2024.

Mr Norman reassured Members that the council is already making plans to ensure that services for rough sleepers can continue in the event of a reduction in the amount of RSI funding the council receives:

The City and Tower Hamlets Navigator contract is set to expire, with no possibility of extension. Officers are currently designing a solution that sustains service delivery to the client group, but also returns a saving. This and other adaptations will ensure that the cost of the 2025/26 RSI programme falls within the value of the grant awarded by MHCLG.

Costs of temporary accommodation

Sinead Collins, Senior Housing Officer at the City of London Corporation, informed Members about the increasing cost to the council of providing temporary accommodation to households deemed to be statutorily homeless.

Ms Collins explained that since 2019/20 the council has experienced a significant increase in demand for homelessness assistance. This increase is due in part to the commencement of the Homelessness Reduction Act 2017, which expanded the council's legal duty to house homeless people, and in part to the increasing cost of renting in London.

This increase in demand for assistance has, in turn, resulted in an increase in the amount the council is spending on temporary accommodation:

In 2023/24, the City of London spent £1,029,756 securing temporary accommodation. This is almost double what was spent in 2021/22 (£562,409).

Ms Collins also explained why the council does not lease properties to be used as temporary accommodation, but instead uses more expensive nightly-paid temporary accommodation:

Due to the unique nature of the City of London and the smaller number of approaches in comparison to other London local authorities, it is not cost effective for the City of London to lease properties for the use of temporary accommodation. This is because it is likely that rooms would remain empty while we continue to be subject to their rent costs. To maintain flexibility, we use temporary accommodation which is let at the more expensive nightly paid rate.

Homelessness Rough Sleeping Coproduction Programme

Kirsty Lowe, Rough Sleeping Services Manager at the City of London Corporation, provided Members with an update on the Homelessness Rough Sleeping Coproduction Programme, which the council has been developing over the past five years.

Ms Lowe explained that:

Coproduction is a way of working together to create positive change. Coproduction seeks to maximise the involvement of people who have experienced a problem or challenge in identifying and solving that problem.

She then outlined the three main elements of the programme, which is currently being delivered by Mayday Trust and Groundswell:

• An Advisory Group made up of people with lived experience of rough sleeping
• A Champions group made up of professionals working in the sector, who meet monthly to discuss how they can make their services more collaborative
• Workshops for leaders and decision-makers in the council and commissioned organisations, designed to encourage collaboration and identify best practice

Ms Lowe finished her presentation by informing Members that funding for the Homelessness Rough Sleeping Coproduction Programme is currently due to end on 31 March 2025. However, she stated that she hoped to extend the programme for another year, funding permitting.

Tackling the detrimental impacts of rough sleeping

Members heard a report from Simon Cribbens, Assistant Director of Commissioning and Partnerships at the City of London Corporation, and Chief Inspector Nikki Gander from the City of London Police, about how the council should respond to the detrimental impacts of rough sleeping.

The report was prompted by the appearance of rough sleeping encampments in the Square Mile and by “requests for action to be taken” from Members, businesses and officers. The report explained that:

Interventions to respond to encampments in the City have been reactive in relation to escalating issues and risk. They have not been planned as part of a wider and longer term approach. This is because the City Corporation does not have a clear policy position to guide and empower officers. Neither is there the necessary resource required for more co-ordinated and sustained interventions were that approach to be pursued.

The report set out a draft policy position statement, which proposes a more proactive, planned approach to tackling the detrimental impacts of rough sleeping, combining support and outreach work with the use of enforcement powers to tackle anti-social behaviour where necessary. The draft policy statement stresses that:

We will always take a welfare first approach. Identification and consideration of a person’s specific circumstances, including their safeguarding and support needs, are an integral part of the City Corporation’s approach. However, where detrimental issues persist or are likely to persist, we will consider the use of legal powers and tools to intervene.

The policy statement includes proposals for:

• Removing abandoned belongings.
• Storing abandoned belongings for 28 days before they are disposed of.
• Removing tents in specific circumstances, for example where they are no longer being used as sleeping sites and are instead being used for illegal purposes, or where they are causing a statutory nuisance¹.

The draft policy statement is accompanied by an operational protocol, which outlines the process for deciding to take enforcement action, including the authorisation process, requirements for an evidential base, and follow-up reporting requirements. The draft protocol stresses that any enforcement action should be a last resort, and should only be used where offers of support have not been accepted by the individuals concerned.

The report identifies several risks associated with taking enforcement action against rough sleepers:

• Displacement of rough sleepers to other areas, where they may be less safe, and may lose access to services and support
• People returning to the area after enforcement action has been taken
• Negative perceptions of the council and the City of London Police
• Criminalisation of rough sleeping

Members discussed the report and were asked to consider several questions about the draft policy and protocol:

• Are Members supportive of the policy position in principle?
• What level of negative impact would need to be evidenced in order to justify taking enforcement action?
• Are Members willing to accept the risks inherent in taking enforcement action?
• What safeguards could be introduced to mitigate those risks?
• Would Members support publishing a policy statement on the council’s website?

Members also asked officers to clarify the data on private rented sector outcomes, and requested that residents associations be consulted on the development of a new policy.