Placement Policy - Emergency and Temporary Accommodation
December 2025
1. Introduction
1.1This policy sets out Spelthorne Borough Council’s (‘the Council’) approach for the placement of households in emergency and temporary accommodation, both inside and outside of the borough. It covers both interim placements made under s188 Housing Act 1996, while homelessness enquiries are undertaken, and longer term temporary accommodation (TA) placements for households accepted as homeless under s193 Housing Act 1996.
1.2Due to the lack of supply of affordable, suitable emergency and temporary accommodation in Spelthorne, it may be necessary to procure some properties outside of the borough. Where possible, this accommodation will be in the periphery of Spelthorne, for example Hounslow or Runnymede. However, at time of high demand and limited supply, it may be necessary to secure accommodation further away from Spelthorne. Such placements will only be procured when all other reasonable options have been exhausted. Prior to placing a household into such accommodation, an assessment will be undertaken to determine the suitability of the accommodation offered.
1.3This policy details how applicants will be prioritised for emergency and temporary accommodation in Spelthorne, and out of the borough.
2. Offers and Refusals
2.1Homeless applicants who are housed under the Council’s interim duty to accommodate pursuant to s188 of the Housing Act 1996 may initially be placed into emergency accommodation, including bed and breakfast (B&B) with shared facilities or short-term self-contained accommodation, while enquiries are carried out. This accommodation may be outside of the borough. If the Council decides it has a duty to house the household, they may be moved to longer-term TA, owned by the Council, Knowle Green Estates or a Registered Provider as soon as a suitable property becomes available.
2.2Wherever possible, the Council will avoid placing families with dependent children or pregnant women into B&B accommodation. Where no other suitable accommodation exists and such placements are necessary, the Council will move these households to more suitable self-contained accommodation within six weeks to comply with legislation.
2.3Where the Council decides that applicants housed under s188 are not owed the main homelessness duty, they will be asked to leave following reasonable notice after being notified of the decision. Each case will be assessed on its own circumstances as reasonable notice will differ between households. As a guide:
2.3.1 A single person or couple with a non-priority decision will usually be given 7 days’ notice.
2.3.2 A single person or couple without children who have a priority need, who have been found intentionally homeless, will usually be given 14 days’ notice, to allow handover to other services.
2.3.3 The Council will give regard to the safeguarding of any children in a family, the cessation of emergency or temporary accommodation will always be notified to Social Services in cases where there are dependent children. In the event of a negative decision, families with dependent children will usually be given 28 days’ notice, this is to give Children’s Services adequate time to contact the family and arrange accommodation.
2.3.4 In all cases, if there has been a serious breach of licence (violence, criminal damage, arson), the Council will usually end a s188 duty within 24 hours.
2.3.5 If the Council is satisfied that the property has been abandoned, the Council will aim to take back occupation of the property as soon as possible, without mind to the above notice periods.
2.3.6 In all cases, the Council may use discretion to give a longer notice period to increase opportunities for partnership working with other agencies.
2.4Applicants will be given one offer of suitable interim or longer term temporary accommodation; they will be advised to accept this offer straight away. There is no obligation upon the Council to enable applicants to view the accommodation prior to acceptance. In making the offer, the households’ individual circumstances will be considered, taking into account the factors set out in section 3 of this policy and the Council’s criteria on in and out of borough placements detailed in section 4.
2.5If an applicant refuses an offer, they will be asked to provide their reasons for refusal. This applies to new applicants to whom the Council has an interim duty to accommodate under s188, as well as those being transferred to alternative TA. The Council will consider the reasons given and undertake further enquires as necessary. If the Council accepts the reasons for refusal as valid, the offer will be withdrawn and a further offer will be made.
2.6Where applicants refuse suitable emergency accommodation (which may include out of borough placements) and the Council does not accept their reasons for refusal, and considers that the offer is suitable, applicants will not be offered further accommodation and will be required to make their own arrangements. There is no right of appeal against the suitability of accommodation offered to applicants under s188 (although they can apply for judicial review through the courts). For applicants where the Council has accepted a s193 rehousing duty, there is a right to request an internal review of the suitability decision, pursuant to s202.
2.7In cases where the applicant still refuses a suitable offer of accommodation, the homelessness duty will be discharged. If the applicant is resident in emergency accommodation, they will usually be asked to vacate the property and advised that no further assistance will be provided. If they are already in longer-term TA, the current housing provider would be advised that the duty has been discharged so that they can start possession action.
2.8Where applicants, whom the Council has accepted a s193 duty, refuse a suitable offer and submit a review request, they will only continue to be accommodated during the review period in exceptional circumstances. Each case will be considered on an individual basis, taking into account the overall merits of the review request, any new information or evidence that may affect the original decision, and the personal circumstances of the applicant and the potential impact of the loss of accommodation.
3. Suitability of accommodation – factors to consider
3.1Location – if suitable and affordable accommodation is available within the borough, applicants will be housed in Spelthorne, allowing them to maintain any established links with services and social/support networks. However, when there is a lack of suitable accommodation or there are higher priority households awaiting accommodation in the borough, out of borough placements will be used to meet the Council’s housing duty (see section 4 on priority for local accommodation). If no suitable accommodation is available in Spelthorne, attempts will be made to source accommodation on the periphery of the borough or further afield.
3.2Affordability – in order to be suitable, a property must be affordable for the household. This may have a greater impact on larger households who require bigger properties to meet their housing need. In such circumstances, the Council will initially look for a property in-borough and if unsuccessful, will gradually increase the radius in which it searches for a suitable property.
3.3Size, condition and facilities– accommodation must provide adequate space and room standards for the household and be fit to inhabit. Households in temporary accommodation will often be placed into properties with fewer bedrooms then they would otherwise be entitled to in settled accommodation, with the expectation that the living room provides dual purpose as a living and sleeping area. In deciding on the fitness of the property, consideration should be given to the length of time needed to complete any necessary repairs and whether it is reasonable to complete these while the property is occupied. The quality of the decoration/furniture, the layout/type of accommodation, provision of parking and lack of access to a garden are unlikely to be acceptable reasons for a refusal.
3.4Health factors – the Council will consider health factors, such as mobility, care and support provided by other statutory agencies. If the applicant or a member of the resident household is citing medical grounds that were not identified during the initial assessment, the applicant must submit supporting medical evidence within 48 hours. The key test in determining the impact of medical issues is whether the condition itself makes the housing offered unsuitable. Many health services are universal and are provided across the country. Spelthorne has no unique or specialist health providers which would necessitate staying in the borough.
3.5Education - attendance at local schools will not be considered a reason to refuse accommodation, though some priority will be given to special educational needs and students who are close to taking public examinations in determining priority for in-borough placements (see Section 4).
3.6Employment –the Council will consider the needs of applicants who are in paid employment to reach their normal workplace from the accommodation that is secured (see Section 4).
3.7Proximity to schools and Services - The council will consider the proximity to schools, public transport, primary care services, and local services in the area in which the accommodation is located.
3.8Any special circumstance - The Council will consider any other reasons for refusal put forward by the applicant and come to an overall view about whether the offer is suitable.
4. Criteria for prioritising placements inside/outside of Spelthorne
4.1As the borough faces pressure to house applicants, it will increasingly be necessary to make decisions about the suitability of out of borough placements for individual households and balance these against the type and location of emergency and temporary accommodation that can be offered.
4.2 Wherever possible, the Council will seek to make placements within the borough of Spelthorne. However, in times where demand for emergency accommodation is significantly high, the Council may choose to retain a small number of self-contained emergency or temporary accommodation units in the borough. This is to ensure the availability of accommodation for households that may approach with one of the priority needs outlined below. If a household does meet one of the priority needs specified, they may be offered accommodation out of the borough in the first instance. This is to ensure that there is sufficient availability of self-contained accommodation for those who may require to be in-borough more urgently.
4.3 Priority for accommodation in the borough will be given to:
4.3.1 Applicants with a severe and enduring health condition requiring intensive and specialist medical treatment, where a move out of the borough would disrupt that treatment and continuity of care.
4.3.2 Applicants who are in receipt of a significant package and range of health care options that cannot be easily transferred.
4.3.3 Applicants with a severe and enduring mental health problem who are receiving psychiatric treatment and aftercare provided by community mental health services and have an established support network where a transfer of care would severely impact on their wellbeing.
4.3.4 Households with children registered on the Child Protection register in Spelthorne, who are linked into local services and where it is confirmed that a transfer to another area would adversely impact on their welfare.
4.3.5 Households containing a child with special educational needs who is receiving education support in Spelthorne, where change would be detrimental to their wellbeing.
4.3.6 Applicants who have a longstanding arrangement to provide care and support to another family member in Spelthorne who is not part of the resident household and would be likely to require statutory health and social support if the care ceased. This must be evidenced by a Carers Assessment and/or receipt of Carers Allowance and confirmed by Social Services that there are no suitable arrangements available to replace the existing care arrangement.
4.3.7 Any other special circumstance will also be taken into account.
4.4. Priority for accommodation within neighbouring boroughs will be given to:
4.4.1 Applicants who have as part of their household, a child or children who are enrolled in GCSE, AS or A-Level courses in Spelthorne, with exams to be taken within the next six months. Wherever practicable, the Council will seek to place such households within 60 minutes travelling distance by public transport, of their school or college.
4.4.2 Wherever practicable, any applicant who works for 18 or more hours per week and has been employed continuously for more than 12 months will not be placed more than 90 minutes travelling distance by public transport, from their place of employment.
4.5 Accommodation out of the borough:
4.5.1 When no suitable property is available, applicants who meet none of the above criteria are likely to be offered properties outside of Spelthorne.
4.5.2 Applicants who are victims of domestic abuse would be placed outside of Spelthorne in an area where the risk of abuse does not exist having considered all other factors within this policy.
4.5.3 Applicants who are at risk of violence being perpetrated against them would be placed outside of Spelthorne in an area where the risk of violence does not exist having considered all other factors within this policy.
4.5.4 Applicants who indicate a desire to be housed in a particular area outside of Spelthorne will be housed in those area(s) so far as reasonably practicable.
5. Other considerations
5.1 Discretionary placements or placements that are made under the Rough Sleeper Initiative (RSI), that are not made under the functions of the Housing Act 1996, may be dealt with differently. RSI is currently funded by the Ministry of Housing, Communities and Local Government and is due to be reviewed in 2025. Any placements made under RSI must be verified by the Council’s RSI coordinator.
5.2 When making decisions, due regard will be given to the most updated version of the Homelessness Code of Guidance and any other UK statutory instruments introduced by the Government.
6. Review
6.1 This policy will be reviewed every 5 years and will be monitored by the Council’s Strategic Housing Group.