Commenting on the Government's Discussion Paper on the Charter, CIH says that although the original expectations were that the Charter outcomes would be quite broad and high level, this would mean the Scottish Housing Regulator effectively having to identify more detailed outcomes when setting out how it will measure compliance with the Charter. But, says CIH, the Act is clear that it's for the Scottish Government to set outcomes and standards and for the Regulator to assess compliance with them.

David Bookbinder, Head of Policy and Public Affairs at CIH Scotland, said:

"We've been critical of the long timescales involved in developing the Charter, especially given that we can't see it being much different from the Performance Standards which were in place until recently. We still have reservations, but the Discussion Paper does at least move things on by giving real examples of possible outcomes, and by being clear and jargon-free.

"What these examples highlight, however, is that if outcomes are too broad or woolly, it'll present the Regulator with a headache in coming up with criteria for assessing compliance. For example, if an outcome is "Temporary accommodation meets the needs of those receiving it", it would surely be difficult for the Regulator to check compliance without some more specific standards. None of us wants to see an overly prescriptive Charter, but it will need a reasonable level of detail for it to be meaningful and for performance against it to be measurable.

"In the end, we think tenants will be less interested in what the outcomes are and rather more interested in what their landlord's doing to achieve them. And for both landlords and tenants, a big practical issue will be developing good systems for self-assessing performance and finding realistic ways of involving in this process those tenants who want to contribute."

CIH Scotland's short response to the Charter Discussion Paper can be found HERE

Contact: David Bookbinder, tel: 07950 684153