I set out below this Associations response to your consultation initiative, following my attendance at the event you organised last week. Thank you for inviting Hanover (Scotland) to take part.

 

The timescale for response is regrettably too short for meaningful discussions to have taken place under our existing service user consultation arrangements. Hanover Scotlands experience however is that there is a settled expectation amongst residents to whom it provides a service that their developments are essentially, if not exclusively, for those of normal retirement age and above.

 

Local authorities are the main commissioners of our services. As such their views are essential to full and effective consultation.

 

Viewed from Hanover Scotlands own perspective, the age profile of our residents generally is rising and the 60 years cutoff, which we broadly apply across our rented sector and at nearly all owner occupied developments we manage, is in practice less of an active criterion than it may have been in the past. The age criterion for rented developments, and at some owner occupied developments depending on their title conditions, is in any case subject to exception for suitable younger applicants in need of support although in practice this has led to very few occupancies being granted to date to younger applicants. A reluctance amongst younger people to live in a development occupied almost exclusively by much older residents has perhaps tended to keep down the numbers of such instances.

 

Age related occupancy restrictions are generally set out or referred to in the title deeds of owner occupied sheltered and retirement developments. You asked about Scottish statutory provisions with a potential bearing, and may wish to take advice on the impact of the Title Conditions (Scotland) Act 2003 in this regard.

 

Hanover (Scotland) endorses your remarks about the importance of regulatory impact assessment as part of the legislative planning process. We hope that, as well as more effective implementation of the principles underlying equalities legislation, any streamlining of compliance processes resulting from your review will impact beneficially on costs to the consequent benefit of service users. To this end a shared approach by regulatory bodies towards any information requirements would be most desirable.

 

David Reid

Housing Services Manager

Housing and Care Services Department

Hanover (Scotland) Housing Association Limited