Comments on the Welsh Government’s Rough Sleeping Action Plan

Where feedback is available, comments have been added following each relevant point of the Action Plan.


2. Conduct research to understand the causes of the recent increase in rough sleeping and identify opportunities to improve its prevention, including the role and suitability of emergency and temporary accommodation. (By July 2018)

Comment: It is unclear whether this has happened and whether any research was published.


3. Promote the prevention of rough sleeping through emergency housing arrangements and maximising the effectiveness of homelessness prevention under s66 of the Housing (Wales) Act 2014, and, where rough sleeping cannot be prevented, support a no second night out approach.

Comment: The numbers of people still sleeping rough in some Authorities whilst ‘emergency housing units’ are left vacant, suggests that what’s on offer is not always suitable to those in need. No initiative such as no second night out has been introduced as of yet.


4. Promote and engage with the work being undertaken to reduce the impact of Adverse Childhood Experiences (ACEs), to help address contributory factors to rough sleeping in later life. This will include training for workers in trauma informed practice and related skills to help them to support rough sleepers with an appropriately sensitive and empathetic approach. (By December 2018)

Comment: It is positive that much work has taken place with supporting the 3rd sector to embrace this crucial area of our work, but it isn’t clear how much work has been done to embed this into statutory services. Implementing PIEs is currently not an eligible activity, it really needs to be in the new HSG.



5. Foster, through guidance and advice, the application of Supporting People resources to support rough sleepers into accommodation and to help them sustain that accommodation in order to help them avoid further rough sleeping. (From  April 2018)

Comment: We positively welcome the shift towards more SP contracts being tenure neutral, subsequently allowing services to work with rough sleepers. We welcome any move that frees providers up to spend funding in ways that can be demonstrated as having most impact.


6. Promote services which help build the skills and confidence of rough sleepers and help them to access training and employment, including day services. This will include a report on effective practice. (By December 2018)

Comment: With regards to the report on effective practice of rough sleepers accessing training and employment – it’s not clear whether such a report was issued.

Widening the eligible activity scope of SP contracts would enable providers to offer more of this type of support. 


7. Encourage the development of peer support to help rough sleepers move away from the streets, including training for peer mentors. (From April 2018)

Comment: We have not noticed any particular drive in encouraging this type of crucial support across LAs in Wales.


8. Promoting a positive message to the public about the best way to help a rough sleeper, and raise awareness of the difference between street based activity and those who are actually homeless. (From October 2018)

Comment: It’d be good to get some examples of, or clarity around, how this has been done at a systemic level.

Little to no evidence exists that suggests diverted giving schemes have any significant impact on the public’s response to begging, and inappropriate messaging can be detrimental to the homeless community, yet some LAs have been hasty in their attempts to set such schemes up without thorough planning and preparation.

Messaging from within LAs into the public domain has been insensitive and has ultimately exacerbated the negative stereotypes and stigmas held against homeless people.



9. Promote assertive outreach services and a case management approach to help each individual rough sleeper to secure accommodation, supported by an appropriate IT system. (From March 2019)

Comment: We encourage the development of assertive outreach through mobile provision and openness to innovation from the third sector, for example; Safe Space.


Emergency Accommodation

11. Ensure access to safe emergency accommodation with support is available throughout the year, by widening the range of provision and improving move-on to release bed spaces. This should be evidenced in statutory homelessness reviews and strategies. (From January 2019)

Comment: Some of the systems and referral processes set up to facilitate access to residential provision can at times cause delays in allocating people to beds resulting in unacceptable and unnecessary void levels.


12. Review severe weather plans and ensure they all offer appropriate protection and support for rough sleepers, and proactively help them to access more suitable housing and support. (By March 2018 and November 2018)

Comment: Some LAs’ SWP only become active upon there being 2 nights of adverse weather/temperatures. SWP provision should be initiated so that people are prevented from having to sleep rough in any severe weather.

Housing First


13. Encourage the application of Housing First principles (and review experiences of implementation) to enable rough sleepers to find settled accommodation, including the use of individual budgets to aid resettlement and incentives to improve access to the private rented sector. (By October 2018)

Comment: We welcome the roll out of trailblazer funding and the commitment to HF. However, there remains disputes between RSLs and support providers on the legalities surrounding flexible substance misuse policies.  The could potentially undermine the national roll out of HF.


Legislation and statutory guidance

14. Require local authorities to review the needs of rough sleepers in their area and plan to meet their needs within their local homelessness strategies to meet duties under ss50-52 of the Housing (Wales) Act 2014. Planning should include addressing the needs of women, couples, and people with pets. (By December 2018)

Comment: Local Authorities are encouraged to embrace the agility of the third sector.  The Wallich acknowledges the magnitude of this challenge.  The third sector wants to support more through co-production.


15. Provide stronger statutory guidance on rough sleeping, to ensure effective application of homelessness legislation to improve outcomes for rough sleepers. This will include clearer guidance on assisting those with no local connection, to ensure they receive personalised assistance to secure accommodation. (By July 2018)

Comment: We are not aware of any such guidance being provided, but we feel strongly that it is required.


16. Consider the case for amending secondary legislation to modify priority need groups, including rough sleepers. (By January 2020)

Comment: We are unaware of any progress with this, but we very much welcome its consideration going forward.


Measuring and Monitoring  

18. Review the annual national two week data gathering exercise to ensure appropriate details are collected of people claiming to be sleeping rough to assist policy development. By July 2018

Comment: It is unclear whether such a review has taken place, and if so, what impact the review had.



19. Provide funding to drive a reduction in rough sleeping, encouraging innovative approaches to tackle the problem, including incentives for private landlords. (From February 2018)

Comment: With regard to incentives for private landlords, it is unclear whether work on this has taken place.  More information on this would be useful.

The new money that has been made available is welcomed, but the unknown/short term nature of it does impact on how effectively it can be used.  We urge a shift towards all funding being awarded on longer term arrangements.


20. Invest in accommodation solutions and services specific to the needs of young people as alternatives to sleeping rough, working with the End Youth Homelessness Partnership. (From February 2018)

Comment: Innovation has been stifled due to a lack of appropriate land being made available.


Joint working  

21. Improve access to health and substance misuse services for rough sleepers, through improved implementation of the Welsh Government’s Health Standards for Homeless and Vulnerable Groups. This will include development of model joint working protocols for engaging mental health and substance misuse services with rough sleepers. (From April 2018)

Comment: We are unaware of any significant shift in such services becoming more accessible.


22. Strengthen pathways between services across local authorities, voluntary agencies, health and housing sectors, to ensure that staff have sufficient awareness and training to appropriately signpost and enable individuals to navigate through the system to access the help they need. (From April 2018)

Comment: Prisoner Pathway still appears to be ineffective.  

Promoting Good Practice

24. Convene a national conference on rough sleeping to explore best practice across the UK and internationally. (By November 2018)

Comment: We are unaware of any progress on this point.

Inquiry into rough sleeping – numbers and demographics

Data comes from The Wallich’s recently published South Wales Street Based Lifestyle Monitor, available online here:



The number of people seen by the Rough Sleeper Intervention Teams in South Wales increased by 9% from 2016-17 to 2017-18.

The number of contacts recorded between 2016-17 and 2017-18 rose by 74%. ‘Contacts’ refer to any engagement made between the team and a person, and as such, the same people can be counted several times. The table below clearly demonstrates that the extent of rough sleeping has increased significantly.



As standard, we publish data about the age and gender of our clients.




Perceived demographics of NRPF clients

We recently carried out some internal research about NRPF clients – not just people sleeping rough, it should be noted, though they all would have a vulnerable housing situation.


Mostly males (as high as 90%) with quite a wide age range of 20-60 from Eastern Europe; countries include Poland, the Czech Republic, and Lithuania.


One service mentioned predominantly males over 35, from a variety of countries. Another said: demographics seem to include Polish people, some middle aged and some younger – around twenty.


Mostly Eastern Europeans