What can the European Affordable Housing Plan deliver on homelessness
FEANTSA's reaction to the European Affordable Housing Plan
“At this time of year, across Europe, we go home. We go home to our friends and family. We welcome people into our homes to share food, warmth and shelter. Most of us, but not all of us. Not all of us, unfortunately, because over 40 million people last year were not able to adequately heat their homes because of the high energy prices. Not all of us, because not everybody has enough room to welcome people in. And because some people in Europe have no home at all – over 1 million of our citizens are homeless.
Is this who we are in Europe? Is this who we want to be?”
Dan Jørgensen at the presentation of the European Affordable Housing Plan
FEANTSA applauds the launch of the first ever European Affordable Housing Plan. It is the result of much collaborative work in the past year with a wide diversity of stakeholders, including the homeless sector. The Plan is structured around four pillars and proposes ten concrete actions the Commission commits to in order to help alleviate housing unaffordability across the European Union.
Since homelessness is often invoked to justify housing policy decisions that rarely actually help combat it, this document sets out FEANTSA's homelessness check on the Plan. It proposes key points for mainstreaming a homelessness focus across all the components of the Affordable Housing Plan. We touch on the work that lies ahead, to which FEANTSA is open and ready to contribute.
Supporting the most affected
We congratulate the Commission on including homeless people as a priority target group. This has been our main demand since the Plan was announced. We welcome the focus on the financing aspect of the fight against homelessness within the Plan, which is essential for strengthening the housing approach to homelessness. This includes the dedicated workstream within the Pan-European Investment Platform to mobilise new investment in social housing and housing-led solutions for homeless people, as well as stepping up support to homeless people in the next EU budget. We look forward to better understanding what these commitments will look like in practice.
We also welcome the announcement of a Council Recommendation under this Pillar. We are, however, puzzled by the lack of alignment between policy actions. The Plan includes a Council recommendation on fighting housing exclusion, in misalignment with the Danish Presidency conclusions on the future European Affordable Housing Plan, which invites the Commission to consider a Council Recommendation on ending homelessness, in order to promote stronger cooperation at EU level.
Why does the terminology matter and why do we need a Council Recommendation explicitly focused on homelessness? There are at least 1.2 million homeless people in Europe, an estimation that includes people sleeping rough and people in emergency and temporary accommodation. People whose experience of homelessness has become or is becoming chronic due to a lack of proper public policy and, in particular, an inadequate articulation between housing and social policies, are among the most affected. As much as this social emergency requires a broader understanding, it also requires a targeted response. This would contribute to aligning the actions outlined in the Plan with the human rights approach to housing, as it claims in its introduction. As a tool of policy coordination between Member States, a Council recommendation on homelessness would help set clear obligations, as well as more formal governance and monitoring structures in the fight against homelessness as the most extreme form of social exclusion.
We also welcome the Housing First and housing-led approaches assumed by the Plan. We think it is an unmissable opportunity to promote concrete actions to scale up Housing First, for example, through support for essential training for frontline staff. To that end, we offer our partnership to the Commission.
Ending homelessness is always about housing, but not only about housing. Homelessness needs to be mainstreamed across all the EU policies that affect it (housing, social and anti-poverty, migration, health, equality, etc.). This is one of the workstreams of the European Platform on Combatting Homelessness. Therefore, we are encouraged by the acknowledgement, in Commissioner Jorgensen’s speech, that “homeless people in many countries are actually citizens of other countries”. We encourage the Commission and the European Labour Authority to take measures to understand and address the links between free movement and homelessness. Addressing labour mobility in the context of the skills shortage must indeed take into account also the European dimension of homelessness and the increased precarity and vulnerability of mobile workers, which we would expect from the announced “Fair Labour Mobility Package”.
Boosting supply
Measures to boost supply rightfully cover both new construction and more efficient use of the existing housing stock through renovation and repurposing of vacant spaces. However, when talking about boosting supply, crucial questions from a homelessness perspective are: what type, at what price, and for whom? A credible sufficiency approach requires that renovated and repurposed properties respond to urgent unmet housing needs.
These are questions to be considered both in the “housing simplification package” and the New European Bauhaus, as tools proposed to catalyse more housing investment.
We also welcome the initiatives to reduce energy costs, especially the Partnerships for Better Homes. At the same time, we stress that targeted measures must be prioritised over universal price reduction, along with removal of structural barriers to renovation faced by low-income households, such as up-front costs, degraded housing, debt, and insecure work and tenure. Neighbourhood regeneration should be carried out with social safeguards to prevent displacement.
Mobilising investment
The Plan details a number of actions that fall within the EU’s competencies, such as improving access to financing opportunities, new opportunities for housing investments in the current and next MFF, technical assistance and the change to state aid rules.
Regarding the next MFF, it is important to note that programming responsibility for the National and Regional Partnership Plans (NRRPs) lies with the Member States. If it is serious about stepping up support for people experiencing homelessness in the next EU budget, the Commission will need to 1) activate centrally managed programmes and 2) support the mobilisation of NRRPs resources on homelessness. Just stating that the possibility to programme on homelessness exists will not suffice. The ringfencing of funds would be the obvious mechanism to ensure money reaches people experiencing homelessness. However, there is little political appetite for this inside the Commission in the context of the simplification agenda. Additional options include capacity building and technical assistance to promote programming on homelessness, guidance on funding reforms in homeless policy, including in the context of the European Semester, ensuring that a proportion of all homes funded by the EU are made available to address homelessness.
To help increase private investment in affordable housing, the Plan proposes the development of EU level guidance for assessing the social outcome of housing investments. We think such an assessment framework must be grounded in a human rights approach to housing and must include the extent to which the housing delivered actually helps re-house people experiencing homelessness.
FEANTSA remains wary of the changes to state aid rules to include the distinct category of affordable housing as a service of general economic interest in addition to social housing. We maintain that this decision carries significant risk to divert precious resources away from genuinely affordable state-subsidised housing, which is essential to deliver a housing response to homelessness.
Enabling immediate support while driving reforms
We applaud the central place given to non-profit and limited-profit housing, especially as a stabilising pillar and an essential counterforce to the volatility of housing markets. FEANTSA has long advocated for the crucial importance of public and non-profit social housing in preventing homelessness, and providing an affordable and sustainable solution to people experiencing homelessness.
Among the Plan’s unexpected proposals is the new initiative titled the “Affordable Housing Act”, which would introduce a framework for helping public authorities identify stressed housing areas. We argue that data related to homelessness, housing deprivation, and overcrowding should be considered in the definition of stressed housing areas.
The work that lies ahead
With a new governance structure announced, the Affordable Housing Alliance, FEANTSA remains ready to contribute to integrating the fight against homelessness as a guiding objective against which we will measure the success of the Plan, as well as to contribute to advancing the Plan’s complementarity with the upcoming Anti-Poverty Strategy and the existing European Platform on Combatting Homelessness.