Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Fifth Report

2 The definition of a Decent Home

12. Much of the evidence submitted to this inquiry was concerned with the way in which a Decent Home has been defined. The ODPM has stressed throughout that the Decent Homes standard should be understood as a minimum level below which action is triggered,[9] rather than as an end in itself. However, many witnesses argued that in reality, some homes were improved so as just to meet the standard. Furthermore, the standard omitted important issues which are often given high priority by tenants and homeowners.

13. In this chapter, we will consider the four dimensions of the Decent Homes definition in the light of evidence given to the Committee, and we will subsequently consider aspects which are excluded from the definition, and the relationship between the Decent Homes policy and the Sustainable Communities Agenda.

14. Figure 2 below shows the proportion of all properties failing the Decent Homes standard on each of the four criteria, and also the proportions of stock in different types of tenure which fail the standard on each criterion. Figure 2: Dwellings failing each of the four Decent Homes criteria by tenure, 2001

SOURCE: The English House Condition Survey 2001, Table A4.28

Criterion 1: Meeting the current minimum standard for housing

15. The first criterion for a Decent Home is that it meets the minimum standard for housing in force at any given point in time.

16. The current minimum standard for housing is the "fitness standard", as enshrined in the 1985 Housing Act. The fitness standard sets out a list of nine criteria with which a dwelling must comply, such as structural stability, sanitation, basic heating etc.

17. The Housing Bill currently before Parliament will, in due course, replace the Fitness standard by the Housing Health and Safety Ratings System (HHSRS). The HHSRS system will be based on assessments of the potential hazards of dwellings for the health and safety of its actual or potential occupants. In other words, the hazard assessment of a dwelling will depend not only on the characteristics of the dwelling, but also on the characteristics of the people who live there, or who are likely to live there.[10] The ODPM assesses that the HHSRS may be brought in with effect from 2005, or later.[11]

18. Some 900,000 homes (13% of all non-Decent homes) fail the Standard because of unfitness, with three quarters of these failing on at least one more of the four Decent Homes criteria.[12] Four out of five unfit homes are found in the private sector. About 11% of all privately rented dwellings fail the basic standard for housing, as compared to less than 3.5% of dwellings that are owner-occupied or owned by Registered Social Landlords (RSLs), and less than 5% of dwellings owned by Local Authorities (see Figure 2 above). [13]

19. In the latest set of guidelines issued in February 2004, the ODPM estimates that the change from the Fitness standard to the HHSRS is likely to result in an increase in the number of dwellings failing the Decent Homes standard of approximately 450,000. Only about 20,000 of these will be in the social housing sector, while the remainder is in the private sector, only partially covered by the Decent Homes target.[14]

20. The change from the Fitness Standard to a fundamentally different way of conceiving of and assessing a minimum standard for housing will inevitably impact on efforts to achieve the Decent Homes standard, not least the way in which Decent Homes compliance and progress is measured. A number of witnesses expressed concerns on the potential impact of this change on the Decent Homes processes.

21. The criticism broadly fell into two categories. Firstly, some witnesses pointed to the disruptive effect of changing the parameters halfway through the lifespan of the Decent Homes Target. For example, both the Chartered Institute of Environmental Health (CIEH) and the Places for People Group argued that the change is likely to render the measurement of compliance and progress problematic.[15]

22. The second area of concern relates to the nature of the new system. Several witnesses were concerned that the new system might be more dependent on subjective judgement than the Fitness Standard. Property Consultant Richard Hand wrote:

"…the new HHSRS appears much less well suited, less easy to capture and record on site […] and open to wide variance through the non-specific interpretive nature of the system."[16]

23. Whilst the National Housing Federation was similarly concerned with the level of subjectivity inherent in the HHSRS,[17] the Atlantic Housing Group went further, pointing in particular to the problems associated with the fact that under the HHSRS, the action required to tackle the hazards of a dwelling will depend not only on features of the dwelling itself, but also on the characteristics of its inhabitants at any given time. Atlantic told the Committee that:

"… there are far greater implications than some people realise. There is a huge amount of interpretation. […] We provide a lot of housing for people with dementia, for people with learning disabilities, for people recently discharged from mental institutions and people with recurring mental illnesses. A lot of those people live in supported housing which is shared and the Health and Safety Rating standard will, I think, prove difficult to implement there and I think there is going to be a huge amount of training for people involved here. […] With the people we house, it is going to go like that: Mr A moves in, it is a Category 1 hazard; Mr A moves out, it is not a Category 1 hazard. I think there are a number of implications for this and I think there is a lot of thinking to be done about this standard."[18]

24. Even if the impact in terms of increasing the number of non-Decent Homes in the social sector were minor, Bethnal Green and Victoria Park Housing Association told the Committee that it will be Local Authorities that will bear the brunt of the change. This is because it is Local Authority stock rather than Housing Association stock which is most likely to move from decent to non-decent with the change. Furthermore, Local Authorities will be charged with the monitoring and enforcement on private market properties.[19] ODPM's own figures broadly confirm this view:

"the net increase in the proportion of non-decent homes in local authority stock due to the change from fitness to HHSRS is 1.6%. The increase in the RSL sector is 0.5%. In the owner occupied sector the increase is 8.8% and 3.5% in the private rented sector."[20]

25. When conducting pre-legislative scrutiny on the draft Housing Bill in 2003, we expressed our concern about sufficient funding being made available for Local Authorities to handle the significant extra workload and training requirements following the introduction of the HHSRS. The Government accepted this recommendation, stating that:

"The Government will address this. The Government is committed to fully funding any new burdens that it places on local government."[21]

26. However, when questioned on this topic, the Minister, Keith Hill, indicated that no extra money would be forthcoming to deal with increasing numbers of non-decent homes as a result of the change to the HHSRS.[22] We reiterate and extend our earlier recommendation that the Government should ensure the allocation of sufficient funding to deal with the consequences of introducing the Housing Health and Safety Ratings System (HHSRS). With an estimated increase in the number of non-Decent Homes of some 450,000, funding will be required not only for training Environmental Health Officers to enforce the new system, but also for dealing with an overall increase in the number of non-Decent Homes.

Criterion 2: A reasonable state of repair

27. A dwelling satisfies this criterion unless:[23]

a.  one or more key building components are old and, because of their condition need replacing or major repair; or

b.   two or more other building components are old and, because of their condition need replacing or major repair.

A building component can only fail to satisfy this criterion by being old and requiring replacing or repair. A component cannot fail this criterion based on age alone.

28. More than 1.8 million homes failed the Decent Homes standard on this criterion in 2001, the worst offender in relative terms once again being the privately rented sector where 17% of all homes fail the Decent Homes standard due to serious disrepair. 9% of Local Authority dwellings and 5% of RSL stock fail on this criterion (see Figure 2 on page 8).[24]

29. Witnesses to the Committee did not voice any serious concerns with regard to this criterion.

Criterion 3: Reasonably modern facilities and services

30. A dwelling fails the Decent Homes standard if it lacks three or more of the following six characteristics:[25]

a.  a kitchen which is 20 years old or less;

b.  a kitchen with adequate space and layout;

c.  a bathroom which is 30 years old or less;

d.  an appropriately located bathroom and WC;

e.  adequate noise insulation [external noise only]; and

f.  adequate size and layout of common entrance areas for blocks of flats.

31. As shown in Figure 2, only 2% of all dwellings in England fail the modern facilities and services criterion. The problem is greatest in Local Authority owned stock where 6% of stock fails on this criterion. About 90% of dwellings which fail the Decent Homes standard on the modern facilities criterion do so partly because of the age of the bathroom and kitchen facilities (see Figure 3). These two components are failed more often than any other components.Figure 3: Stock failing on individual components as a percentage of all stock failing the 'modern facilities & services' criterion

SOURCE: The English House Condition Survey 2001, Table A3.6

32. In relation to the 'modern facilities and services' criterion, issues of flexibility and tenant choice caused the most concerns. The National Housing Federation, representing the majority of Social Landlords, summarised the concerns of their members into two categories:

1.  "The degree of flexibility allowed in the criteria, and

2.  The lack of a clear definition for one particular measure: the need for a kitchen with adequate space and layout." [26]

33. Defend Council Housing elaborated on the issue of flexibility, explaining that in its current form, the guidelines do not allow tenants sufficient influence on the way money is spent. Defend Council Housing told us that this criterion:

"…has sometimes been used to force people to have new bathrooms when they are perfectly happy with the ones they have."[27]

Given that the vast majority of dwellings failing the modern facilities criterion does so partly because of the age rather than the state of facilities such as kitchens and bathrooms (see Figure 3), this point is particularly important. It makes little sense to replace facilities in perfectly good order, especially if it is against the wishes of the tenant.

34. The Chartered Institute of Housing (CIH) recognised the need for flexibility in order to accommodate tenants' wishes, and suggested that:

"The approach we would like to take is guidance rather than being over prescriptive because there is overlaid with all of this, […] the issue of what tenant preferences are. Tenants, for example, might be quite happy to live with a 30 year old bathroom and prefer some other work being done to reduce their fear of crime or whatever and we need some flexibility to allow landlords to respond to that."[28]

35. The issue of flexibility was also of concern to many other witnesses, but not always for the same reasons. The Chartered Institute of Environmental Health (CIEH) were effectively concerned that this criterion was too flexible pointing to the randomness inherent in the fact that dwellings simply have to live up to any three out of six characteristics:

"There is a lot of concern with unmodern kitchens, unmodern bathrooms and noise [insulation] as to exactly what we are trying to achieve under the Decent Homes Standard with that sort of criteria where you can pick and mix to see if the house meets the standard and we would like to see some sort of a priority rating on those criteria and that particular element of the standard."[29]

36. These very different views might be a reflection of the diverging realities of the private and the social housing sectors. Defend Council Housing, seeks to represent tenants on estates where the Council landlord are likely to apply estate-wide policies on what is to be done, and how investments are to be allocated. In this scenario it is primarily a question of how (often scarce) resources are to be spent. In the private sector, it is often more a case of if the owner of a non-decent property can afford to, let alone be persuaded to, spend any money at all on improvements. Consequently, it might make good sense for tenants in social housing to call for greater flexibility of the modern facilities criterion, whilst conversely it might be more sensible for private sector tenants to ask for clear and unambiguous requirements and less flexibility.

37. The Committee recognises the need to safeguard the rights of all occupants to the level of facilities and services covered by criterion three. However, we also believe that the Decent Homes standard is too inflexible in stipulating that kitchens and bathrooms of a certain age must be replaced. This means that in some cases facilities in good order, and with which occupants are perfectly happy, are replaced. In other cases, poor facilities which are not old enough to be replaced under the standard are left in place.

38. The challenge, therefore, is to create a criterion for 'reasonably modern facilities' which allows sufficient room for tenant choice whilst simultaneously preventing dwellings with facilities that are clearly unacceptable, such as outside toilets, from meeting the modern facilities criterion.[30] A possible solution to the latter is found in a proposal from the Chartered Institute of Environmental Health (CIEH), namely that the six dimensions of criterion three should be prioritised in some way,[31] thereby preventing a 'pick and mix' approach to the provision of modern facilities. This could easily be combined with a proposal from Mr Cairns, an independent Environmental Health Consultant, that rather than stipulating particular life-spans as being acceptable for kitchens and bathrooms, the definition should stipulate that these facilities should be 'serviceable' or something of that nature,[32] leaving room for a degree of judgement and tenant preferences.

39. We believe that the requirements for modern facilities should be weighted according to tenant preferences. A greater degree of flexibility and tenant choice should be applied in determining which facilities are to be replaced, with assessment based on quality and functionality as well as the views of occupiers, rather than exclusively on age.

Criterion 4: A reasonable degree of thermal comfort

40. This criterion was originally measured in terms of fuel poverty. A household was seen as being 'fuel poor' when it spent more than 10% of its disposable income on fuel. Consequently, dwellings would pass or fail this criterion on the basis of the relationship between the characteristics of the dwelling and the income of the household living there. This obviously meant that dwellings might move between decency and non-decency without any changes to the dwelling.

41. As of 2002, and following lobbying by social Landlords,[33] the thermal comfort criterion was changed in favour of one requiring a dwelling to have simply:

a)  Efficient heating, defined as "any gas or oil programmable central heating or electric storage heaters or programmable LPG/solid fuel central heating or similarly efficient heating systems which are developed in the future."[34]

b)  Effective insulation, where the level of insulation deemed to be effective varies depending on the heating system in the dwelling:

i.  "For dwellings with gas / oil programmable heating: cavity wall insulation (if there are cavity walls that can be insulated effectively) or at least 50mm loft insulation (if there is loft space) is an effective package of insulation.

ii.  For dwellings heated by electric storage heaters / LPG / programmable solid fuel central heating a higher specification of insulation is required: at least 200mm of loft insulation (if there is a loft) and cavity wall insulation (if there are cavity walls that can be insulated effectively):" [35]

42. Far more homes fail on the thermal comfort criterion than any of the other three criteria (see Figure 2 on page 8). In 2001, 5.6 million dwellings in England failed on the thermal comfort criterion[36] - more than one in every four homes in the country. Importantly, of these, more than three quarters fail only on the thermal comfort criterion, which in turn means that any change in the definition of this criterion might have a very significant impact on the achievement of the Decent Homes PSA target.

43. Thermal comfort appears to be a particular problem in local authority and privately rented stock where 34% and 40% respectively of all stock fail on this criterion as compared to owner-occupied stock (23%), or stock owned by Registered Social Landlords (22%) (see Figure 2).

44. Evidence presented to the Committee indicates that there are three key areas of concern with regard to the thermal comfort criterion. Firstly, is the level required high enough? Secondly, but linked to the first area of concern, is the policy adequately integrated with the Government's own Fuel Poverty Strategy and its Energy White Paper?[37] And thirdly, is the way in which thermal comfort is defined and measured the most appropriate?

Is thermal 'comfort' comfortable?

45. Many of our witnesses argued that the thermal comfort criterion was set at far too basic a level.[38] Several pointed to the fact that the requirements under the Decent Homes standard are very much lower than under current building regulations.[39]

46. The Chartered Institute of Environmental Health (CIEH) called the insulation requirements "rather retrograde"[40] and pointed to the fact that where building regulations will soon require all new homes to have a minimum of 300mm of loft insulation, the Decent Homes standard requires just 50mm in properties with gas or oil programmable heating, and 200mm in dwellings with certain other types of heating. They argued that:

"Allowing such a major trade-off might make the difference in whether or not an occupying family is living in fuel poverty." [41]

47. This point is important partly because the Government is committed to the eradication of fuel poverty through another target.

48. Some witnesses, for example from the Energy Saving Trust,[42] suggested that it would be feasible, and indeed desirable, to change the levels required by the thermal comfort criterion at this late stage, However, the Committee does not consider that it would be helpful, or indeed fair towards housing providers, to change the goalposts for the thermal comfort criterion for the 2010 target at this stage.

49. However, the Committee does believe that the thermal comfort criterion provided for in the Decent Homes standard is far too low. We recommend that in the new 'Decent Homes Plus' target which we propose paragraph 90 below, the required levels of thermal comfort should be in line with the building standards in force at the time when such a target were to be set.

50. This course of action would not eradicate the problem of dwellings having to undergo improvements in several rounds, because homes only just brought into compliance with the 2010 target would invariably have to be to be revisited after 2010 in order to comply with a 'Decent Homes plus' target. However, this is the best option available, in the sense that, it would not force landlords to change planning and finance arrangements already in place for the 2010 target, or indeed to re-visit, before 2010, properties already made decent under current guidelines. Instead, some housing providers may decide to continue with their current plans, whilst others may decide to alter their plans to incorporate a 'Decent Homes plus' target at this early stage.

Eradicating fuel poverty and lowering carbon emissions - coordinated policy-making?

51. The thermal comfort criterion of the Decent Homes target overlaps with two other key Government policies, the UK Fuel Poverty Strategy and the Energy White Paper. Some of our evidence indicated that there is little cross-departmental joined-up thinking, leaving disparate policies in need of alignment and integration in order to maximise the benefit of resources spent.

52. The UK Fuel Poverty Strategy springs from the Warm Homes and Energy Conservation Act 2000, and is a joint project of the Department of Trade and Industry (DTI) and the Department of the Environment, Food, and Rural Affairs (DEFRA) aimed at eliminating fuel poverty in Britain by 2016. There is an interim target of eliminating fuel poverty among vulnerable households in England by 2010[43] - the same time-span as the Decent Homes target. The key policy instrument employed to achieve the target is the Warm Front scheme, which provides grants for energy efficiency measures for vulnerable households, primarily in private sector housing.[44]

53. In other words, where the thermal comfort criterion of the Decent Homes policy deals with the whole of the social housing sector, and the Warm Front scheme relates to the whole of the private housing sector, the 2.7 million vulnerable households living in the private sector[45] are effectively covered by both targets. The fact that the two targets are conceived and measured in fundamentally different ways, means partly that the standards aimed at (and hopefully achieved) in the private and public housing sectors are different. Where the targets overlap, for vulnerable households in the private sector, measures to achieve compliance with one target might not lead to compliance with the other. The All Party Parliamentary Warm Homes Group told us that:

"NEA has estimated that up to 1 million social homes that already comply with the current [Decent Homes] standard are still in fuel poverty.[46] Thus, to apply that same standard to homes that do not currently comply with it will not ensure:

  • Either that the Government's target to end fuel poverty in social housing by 2010 is met or
  • Given that many people in social housing are in the vulnerable sectors, that the government's target to end all fuel poverty in those sectors by 2010 is met."[47]

54. Another Government policy which overlaps with the thermal comfort aspect of the Decent Homes target is the commitment to reduce CO2 emissions by 60% by 2050,[48] with an interim goal of reducing emissions by 20% below 1990 levels by 2010.[49] The Energy White Paper states that households are expected to deliver savings of 5MtC (Million tons of Carbon) by 2010, and more than half of those savings (2.8MtC) are expected to come from improvements in home insulation and the installation of 5 million new boilers of the most energy efficient type.[50] One of the vehicles created to help deliver these savings is the Energy Efficiency Commitment (EEC) for domestic energy suppliers whereby each supplier has to meet energy savings targets by encouraging households to install energy-saving appliances and insulation. "At least half the target must be met in households whose occupants are either on a low income or disabled."[51]

55. The Energy Saving Trust stressed the importance of social housing making its contribution to this goal, and stressed the importance of integrating these different policy initiatives.[52] The Sustainable Energy Partnership pointed out that:

"…if the current [Decent Homes] standard is retained, the only way to achieve fuel poverty objectives will be to bring homes up to that standard and then at a later date upgrade them once again. This is wasteful and, some of our members have commented, absurd. From a CO2 reduction point of view this current standard is similarly wasteful. It will mean that home brought up to that standard will continue to generate too much CO2 which again will mean that if long term objectives are to be met they will have to be re-upgraded at some later date."[53]

56. No less important is the inefficient use of resources resulting from the lack of coordination of the different programmes in the areas of Decent Homes, fuel poverty, and energy efficiency. The National Consumer Council pointed to the importance of integrating the policies at all levels, right down to the guidance issued to stakeholders:

"The energy efficiency commitment is basically the biggest pot of money available that could help to achieve the Decent Homes standard and the integration of these more formally in terms of guidance for local authorities to seek out funding from suppliers would be very welcome.[54]

57. The Committee received some evidence suggesting that it would be feasible, even at this advanced stage, to change the definition of the thermal comfort criterion so as to align it with the UK Fuel Poverty Strategy and the Energy White Paper.[55] The Committee does not believe that this would be helpful. The criterion has clearly been set at far too low a level. The 'Decent Homes Plus' target, recommended below, should not only include a much more ambitious thermal comfort criterion, but it must also work in tandem with other key policies such as the Fuel Poverty Strategy and energy efficiency targets. Funding for the different programmes must be closely coordinated.[56]

Measurement Methodology

58. The problem of integration of different energy efficiency policies could, at least to some extent, be eradicated by the use of a universal measurement scale. The UK Fuel Poverty Strategy and the Decent Homes target are not only out of out of alignment, but it would also be virtually impossible to achieve alignment without changing the ways in which they are quantified and measured. The National Consumer Council recommended to the Committee that:

"A decision should be taken across these schemes about what particular measure works best in this regard since alternatives do exist such as SAP ratings."[57]

59. The National Consumer Council was not alone in proposing that the SAP rating would be the optimal method for setting the minimum level of thermal comfort in the Decent Homes standard.[58] The Department of Trade and Industry has defined the SAP rating as follows:

"The Standard Assessment Procedure (SAP) is the Government's standard for home energy rating. SAP ratings provide a simple but reliable indicator of the efficiency of energy use for space and water heating in new and existing dwellings. SAP ratings are expressed on a scale of 1 (poor) to 100 (excellent). The SAP is a fuel cost based rating system, but the calculation methodology can be used to calculate CO2 emissions and units of energy used. The SAP takes into account only those aspects of a dwelling which are fixed, such as the heating system, controls, insulation levels, double glazing, etc. It is therefore not affected by occupancy patterns, the use of domestic appliances, individual heating patterns, or regional weather variations."[59]

60. A second benefit of using the SAP ratings would be to bring the Decent Homes Standard and the UK Fuel Poverty Strategy into line with new developments on the private housing market. Clause 133 of the Housing Bill currently before Parliament will in future require sellers of domestic property to provide an energy efficiency certificate to prospective buyers as part of a Home Information Pack.[60] It was indicated in the Government's consultation on the Draft Housing Bill that the measurement to be used in the Homes Information Packs would be the SAP rating.[61]

61. Finally, but not least, some evidence indicated that SAP ratings are easier and more reliable in use than the current method for assessing thermal comfort. Richard Hand, a chartered surveyor explained that:

"…there is a much more simple and widely understood method of assessment available (i.e. SAP ratings). More accurate and meaningful projections could be provided if SAP were utilised to make the assessment under this criterion. This method would require no more work than clients are currently expected to produce for other forms of reporting (e.g. Home Energy Conservation Act)."[62]

The National Energy Action Group added that:

"We are supportive of the idea of a SAP rating. SAP ratings will be part of the Welsh housing quality standard. An NHER rating will be used in Scotland. I am afraid to say that England is a wee bit out of step in this respect. It is a good, substantial and objective measurement of the energy efficiency of the property and we would recommend SAP rating."[63]

The Chartered Institute of Environmental Health argued that:

"…if there is to be intervention to improve energy efficiency, the way that should be dealt with is with a SAP value for intervention and a target SAP value for any improvement to be made."[64]

62. We recommend that when defining the thermal comfort criterion for the 'Decent Homes Plus' standard, a widely used and recognised industry measure such as SAP ratings should be used. We regard it as vital that the measure chosen is used across all the targets and policies in the energy efficiency area, irrespective of the sponsoring Government Department.

Aspects excluded from the definition

Accessibility for the elderly and disabled

63. A number of witnesses providing evidence to this inquiry expressed deep regret at the failure to incorporate accessibility requirements into the Decent Homes standard. In their joint memorandum to the Committee, the Disability Rights Commission, the Joseph Rowntree Foundation and the Habinteg Housing Association argued that accessibility issues are anything but a minority issue, not least with an ageing population.[65] Marie Pye of the Disability Rights Commission explained to the Committee that:

"We have a situation where we have at least 8.5 million disabled people in this country. That is one in five of the adult population, so this is not a minority issue. Over 40 per cent of social housing tenants have a disability but four out of ten disabled people in recent research said their housing situation was making them more dependent on others. That is not a situation that we think it is acceptable to continue in the long term. Added to this, we have a rapidly aging population who are increasingly finding their housing inaccessible. Simply building new homes for all those people is not an economic way forward."[66]

64. The three organisations argued that an opportunity was being lost, especially because it would have been feasible to incorporate accessibility criteria into the standard without incurring prohibitive costs.[67] They pointed out that several well-established standards of accessibility already exist, and that one of these could be incorporated into the Decent Homes standard. Examples of such standards are the Lifetime Homes criteria, the Housing Corporation Scheme Development Standards, as well as Part M of the current Building regulations. The three organisations concluded that the Lifetime Homes criteria would be the most appropriate for incorporation into the Decent Homes Standard because this would allow for some flexibility of approach, and an incremental approach would be possible.[68]

"We feel we have a tool kit of well developed standards that are tried and tested that we hope very much could enhance Decent Homes Standard and bring about some improvements in accessibility."[69]

65. The Committee is convinced that accessibility standards for elderly and disabled people should have been incorporated into the original Decent Homes Standard, and we therefore recommend that nationally recognised accessibility criteria should be incorporated into a 'Decent Homes Plus' standard.

66. Both Care & Repair England and the Disability Rights Commission suggested that a pragmatic approach could be taken to incorporating accessibility into the Decent Homes Standard, whereby accessibility would only be addressed where work was being carried out for other reasons. In other words, a property would not be able to fail the Standard purely on accessibility issues:

"We are suggesting you take a pragmatic approach, which in some ways is slightly different to the Decent Homes Standard. You would not necessarily say every home is a "decent home" if it meets a certain access standard. We would say that when through the Decent Homes Refurbishment Programme you are addressing a particular feature within a property, you ensure that that feature becomes accessible. Therefore, if you are undertaking a programme to replace all the windows in a block, you buy in the kind of window openings that meet the British standard in terms of accessibility so that when an old or disabled person is living in that home, maybe today, maybe next month, maybe next year, they can actually open the windows, and then when that person is living there you do not suddenly have to spend another £1,000 replacing all the windows just because the windows that were replaced under Decent Homes did not have the right fasteners on them. It is those relatively simple measures that would achieve an incremental improvement in access."[70]

67. Care & Repair England provided specific examples of how renovations such as the fitting of PVC windows may worsen accessibility for elderly and disabled people. They suggested that:

"…all specifications for programmes of improvement to properties as part of compliance with Decent Homes Standard should be vetted by an occupational therapist in order to ensure that minimal standards are adhered to with regard to improving accessibility and livability standards"[71]

68. The Committee finds it unacceptable that work carried out to achieve the Decent Homes standard may in fact lead to a worsening of accessibility for elderly and disabled people. We recommend that the ODPM take immediate steps to ensure that accessibility standards are met in all work carried out on dwellings in order to meet the Decent Homes Standard.

Internal noise insulation

69. The UK Noise Association pointed to another issue, namely internal noise insulation, which is not currently covered by the standard, but which they believe to be a vital component of a Decent Home. As it currently stands, the Decent Homes Standard includes provision on noise from external source such as aircraft or road noise. The new Housing Health and Safety Ratings System (HHSRS) will also include noise as one of 29 hazards to be considered when assessing the fitness of a dwelling. However, the UK Noise Association told us that:

"…there is nothing whatsoever in the standards to require local authorities or others to improve the internal insulation; that is, the sound insulation between properties."[72]

70. The UK Noise Association told us that a significant proportion of the tenants in social housing suffer as a result of poor sound insulation between properties,[73] and they made an important point when arguing that the lack of noise insulation causes a considerable deterioration in the health and quality of life for some residents. This, they said, should be taken into account when making any attempt to calculate the extra cost of including internal sound insulation in the Decent Homes Standard.[74]

71. The Committee believes that noise transfer between homes is a frequent problem which greatly reduces the quality of life of those affected. We recommend that internal noise insulation between and within dwellings be included in the 'Decent Homes Plus' standard which we recommend below.

Too basic to be decent?

72. In the discussions of the criteria which make up the Decent Homes Standard as well as the areas which are not included in the standard, we have repeatedly come to the view that the Decent Homes standard is too basic. We are clearly not the only ones to reach this conclusion. The Chief Inspector of Housing at the Audit Commission told us that:

"…in terms of a market position, in terms of what people would aspire to, it might be seen as acceptable just about in 2003 but by 2010 it will be seen as old hat."[75] (emphasis added)

73. The ODPM counters such criticisms by arguing that:

"If a property is beneath that standard we expect them to take action. We do not expect them just to improve up to the standard. For example, if the property is built below the standard required for insulation, we do not expect them just to raise the level of insulation up to the minimum required. It would often be cost-effective for them to put in a higher level of insulation, but that is something that we leave to the landlord and government does not prescribe."[76]

74. This view was endorsed by the regulator for Registered Social Landlords (RSLs), the Housing Corporation. Norman Perry, the Corporation's Chief Executive, told the Committee that:

"When housing associations are investing in the Decent Homes Standard, by and large they are improving their homes to a higher standard than the Decent Homes Standard requires."[77]

75. In its memorandum to our inquiry, the National Housing Federation appeared to agree that the Decent Homes standard is simply a welcome benchmark for the minimum acceptable standards, and that there is a general expectation in the RSL sector that a higher standard should normally be achieved.[78]

76. However, when giving oral evidence, the Chief Executive of the National Housing Federation, Mr Coulter, elaborated on this by saying that the Decent Homes standard:

"…will be tolerable […] but […] will not meet aspirations. They certainly do not reflect what you would expect from private sector or Housing Association housing, from new-build for example and the investment plans which associations pursue when the resources are available to them."[79]

77. Finally, the National Consumer Council made a point with regard to the very low thermal comfort criterion, but their point is also valid more broadly with regard to the Decent Homes standard, particularly in areas of high demand:

"We tend to think that the ODPM has overestimated the extent to which the market is likely to raise above these standards. In most situations the demand for housing exceeds supply. There are not pressures there."[80]

78. The Committee is concerned about the fact that, already in 2004, there seems to be a considerable discrepancy between what tenants aspire to as being Decent, and what the Decent Homes Standard guarantees. This discrepancy can only grow over time, and the Chief Inspector of Housing at the Audit Commission is likely to be right in his assessment that the standard will be seen as "old hat" by 2010. It is regrettable that the ODPM has pegged the standard at such a basic level, only to tell social housing providers that they are actually expected to improve homes to a higher standard. Problems arise in two interconnected ways. Firstly, funding arrangements are geared towards providing the level of funding needed to bring homes up to the Decent Homes standard as currently defined, so it is unclear how further investments are meant to be funded, particularly for ALMOs, PFI schemes, and Local Authority retained stock. Secondly, if social landlords are unable to bring their stock to standards higher than the Decent Homes standard, it is likely that by 2010, social housing will still be seen as the poor relation with a degree of stigma attached.

Decent Homes in relation to the Sustainable Communities agenda

79. Virtually all the stakeholders from the social housing sector who gave evidence to our enquiry were concerned that the Decent Homes standard should include standards for communal areas and the neighbourhood environment more generally, and that the Decent Homes policy and the Sustainable Communities agenda were insufficiently coordinated and integrated at present.

80. Several of our witnesses had carried out survey work among tenants showing that neighbourhood and community issues come top of the list of priorities among tenants. The Local Government Association told us that in their biannual surveys of tenants, neighbourhood management issues such as crime and security consistently come out in the top.[81] The National Housing Federation has reached much the same conclusion:

"…the tenants' survey work that we have done and also the work we commissioned separately by Professor Richard Skates showed that number one in terms of tenant aspirations and desires were things like a safe neighbourhood, a friendly environment, security and crime and things like the condition came further down the list. Certainly in the tenant satisfaction surveys that we carry out generally speaking I am afraid it is the old traditionals that come up top such as litter and dogs, they are predominantly the things that tenants get most concerned about which is looking outwards beyond the front door. To answer your question, there is statistical evidence which shows tenants do have a broader view of what they consider to be a decent environment."[82]

81. The Hammersmith and Fulham Housing Commission[83] and Citywest Homes both told us that their experience of tenant priorities 'on the ground' confirmed the findings of such surveys. The Hammersmith and Fulham Housing Commission said that although their tenants welcome the Standard,

"the main criticism from tenants was the lack of any estate wide aspect to the standard, especially things like entry door systems, estate improvements, lift standards, that kind of thing, that should be added to the standard because tenants care about what happens outside their front doors as well as what happens inside."

Citywest Homes added that their tenants:

"took the view that good kitchens, good bathroom and good thermal insulation are very important things but if the money is only spent on that and not spent on improving lifts and the estate environment, play areas, and all of the things that make living there decent then it will not achieve an improvement in the quality of life, so people will have better kitchens but will not feel better about the place they live."[84]

82. The ODPM does recognise that Decent Homes and Sustainable Communities are closely intertwined:

"…two thirds of non-decent social rented housing is in the 112 most deprived local authorities identified for housing resource allocation purposes. Poor housing conditions are also linked to low demand. The 20 local authorities that make up the market renewal pathfinders own 18% of the non-decent social housing. Delivery of the decent homes agenda is therefore essential to the success of neighbourhood renewal and housing market renewal polices."[85]

83. However, our witnesses, particularly ALMOs and Local Authorities, were virtually unanimous in arguing that the two policies need a great deal more integration, and that the Decent Homes policy in itself needs to be more flexible in allowing some Decent Homes funding to be spent on broader environmental issues important to tenants. The Sunderland Housing Group put the point about policy integration succinctly:

"…meeting the criteria for sustainable communities is a bigger agenda than Decent Homes. As such, Decent Homes should sit within the wider agenda of sustainable communities rather than being the sole driver for strategy and investment."[86]

According to the Chartered Institute of Housing (CIH), however, under current arrangements:

"…the PSA target on decent homes is in danger of undermining other elements of the government's housing policy - in particular those related to the sustainability of communities. […] Pressure to achieve the DHT may force social housing providers to spend scarce funds on work that delivers the DHT but that does not create sustainable communities. A practical example here would be window replacement programmes in low demand tower blocks where demolition and renewal may create a more sustainable community. Recognition should be given to the additional costs and time needed to deliver 'sustainable decent homes' - particularly in areas where a neighbourhood renewal or community regeneration approach is needed."[87]

84. Nottingham City Council is known for having turned around estates with low demand problems by investing in the general fabric of the communities. However, the investment in neighbourhoods has meant less investment in the stock itself, and the current funding arrangements do not stretch to both reaching the Decent Homes target and at the same time keeping up the level of neighbourhood investment.[88] In their evidence to the Committee, Nottingham City Council concurred with the Chartered Institute of Housing in pointing to the link between lack of investment in the general fabric of communities and low demand which in turn can send whole communities into a downward spiral of unsustainability:

Not only is the imbalance between the internal and the external expenditure wrong per se, it is also misguided in that people choose houses primarily because of the characteristics of the area they are in. The internal appointment of the house is always a secondary factor and if we are to stop depopulation in some of the towns and cities in the English regions then we should be placing emphasis on the environment far more as a means of attracting people to live in currently less popular areas. By pursuing the current policy we could create well appointed homes with no one to live in them."[89]

85. The fact that the inspectorate for the sector, the Audit Commission, cautiously agreed that in some cases, environmental improvements are at least as important as internal work to carry out the Decent Homes standard only serves to strengthen the point. The Audit Commission also admitted that:

"…more funding might be needed if 'decent neighbourhoods' are to [be] achieved alongside DHS [the Decent Homes Standard]."[90]

86. As for the Registered Social Landlord (RSL) sector, the National Housing Federation told us that they are already encouraging their members to invest in neighbourhoods:

"Our new sector change initiative, 'iN Business for Neighbourhoods' is the largest project ever undertaken by the National Housing Federation; it encourages our members to continue to improve their performance and to provide improved neighbourhood services."[91]

87. We have heard evidence from many stakeholders that the Decent Homes target and Sustainable Communities policy need to be much better integrated. As things stand, there is a tension between the two aims, not least in funding terms. It makes no sense to make internal improvements to homes situated in dilapidated neighbourhoods with unsustainable communities, without also addressing the wider environmental problems. We recommend that the Sustainable Communities and Decent Homes policies be properly integrated, and the funding coordinated so that a home can only be seen as decent if the external environment and neighbourhood are also decent and sustainable.

Decent Homes Plus?

88. The current definition of a Decent Home is not only very narrow, but also very basic. Some witnesses have argued that the Standard should be, and indeed could be, changed at this stage others have cautioned against doing so. The Committee has concluded that desirable though it would be to raise the level as well as increasing the breadth of the standard at this stage, it would be neither feasible nor fair on housing providers to do so. Furthermore, as pointed out by Norman Perry from the Housing Corporation, changing the standard now would entail significant consequences in terms of the monitoring of progress:

"In terms of being able to monitor the performance against the standard, you are talking about several hundred local authorities and a couple of thousand housing associations, and it has taken quite a big effort to get them all pointing in the same direction in terms of collecting data and submitting that on a regular basis. To change now, I think, would have a time lag for the quality of data."[92]

89. In the course of our inquiry, a couple of witnesses touched on a very different idea, namely the notion of having a 'Decent Homes Plus' standard. The Hammersmith & Fulham Housing Commission recognised the need for creating a standard which goes beyond the Decent Homes standard, and they have therefore defined their own local Decent Homes Plus standard. The Commission explains the background thus in their memorandum to us:

"The Commission viewed the Decent Homes Standard as a minimum that applied mostly to the condition of individual homes and buildings. It does not take account of local conditions, the shared environment relevant to estate life, or the need for regular planned maintenance to keep common parts in good decorative order.

The Commission felt it was important to set a Decent Homes Plus Standard as a way of addressing the local needs that arise from the inner city location of our borough, our own aspiration to improve residents quality of life, and new demands that are placed on estate facilities by changes in the wider society, government regulations and new technologies."[93]

90. Interestingly, the Housing Corporation seems to endorse the idea of having a 'Decent Homes Plus' standard with a target date some years beyond 2010:

"If a government were to set another higher standard, say, for 2015, then there would be the lead time necessary to make the necessary changes."[94]

91. The Committee would like to see a more ambitious definition of Decent Homes, whilst at the same time recognising that it would be unhelpful to move the goalposts for the 2010 target at this stage. The Committee recommends that a more aspirational 'Decent Homes Plus' PSA target be set now for achievement at a later date, in which a higher and broader standard is aimed for. Depending on the exact level and breadth of this new 'Decent Homes Plus' Standard, the target date should be set in the 2015-2020 range.

92. The new 'Decent Homes Plus' should be better aligned to the wishes and expectations of occupants, and it should include:

a)  A much more ambitious thermal comfort criterion which is in line with building regulations in force at the time when the new Standard is set. Policy development, evaluation and funding for this criterion must be closely integrated with other key policies such as the Fuel Poverty Strategy.

b)  Accessibility standards for elderly and disabled people

c)  Internal noise insulation within and between dwellings

d)  Standards for the external environment such as communal areas should be included in the standard. This may be done through an integration and coordination of the Sustainable Communities policy with the Decent Homes policy.

We would not expect Local Authorities and Registered Social Landlords (RSLs) to formally start recording or monitoring progress against the 'Decent Homes Plus' standard until a later date. However, we would hope that most choose to incorporate it into their planning as soon as possible.

9   DEC01, para. 2.1. Office of the Deputy Prime Minister (ODPM) Back

10   The Housing Bill: Explanatory Notes; December 2004; Para 46. Back

11   DEC01, para. 2.6. Office of the Deputy Prime Minister (ODPM) Back

12   ODPM: English House Condition Survey 2001: Building the Picture; July 2003; para. 3.7. Back

13   ODPM: English House Condition Survey 2001: Supporting Tables: Table A3.8. Back

14   ODPM: A Decent Home: The Definition and Guidance for Implementation: February 2004. Annex A: para 11. Back

15   DEC37 para 1.1.1, Chartered Institute of Environmental Health; DEC59, Section 1. The Places for People Group.  Back

16   DEC26, para. 2.6. Richard Hand. Back

17   DEC21, para. 3.2.1. National Housing Federation. Back

18   Q347, Dr Smith, Atlantic Housing Group.  Back

19   Q314, Mr Greenwood, Bethnal Green & Victoria Park Housing Association. Back

20   DEC01(c), p2. Office of the Deputy Prime Minister (ODPM). Back

21   The Government's Response to the ODPM: Housing, Planning, Local Government and Regions Committee's Report on the Draft Housing Bill; CM6000, November 2003, para 10. Back

22   ODPM Select Committee 2003; Draft Housing Bill, CMHC751-III: Q640, Keith Hill.  Back

23   ODPM: A Decent Home: The Definition and Guidance for Implementation: February 2004. Annex A: paras 3.6 Back

24  ODPM:EnglishHouseConditionSurvey2001:SupportingTables:TableA3.8. Back

25  ODPM:ADecentHome:TheDefinitionandGuidanceforImplementation:February2004.AnnexA:paras3.17-3.19. Back

26  DEC21,para.3.2.2.NationalHousingFederation. Back

27   Q221, Eileen Short, Defend Council Housing. Back

28   Q13, Sarah Webb, Chartered Institute of Housing. Back

29   Q13, Peter Brown, Chartered Institute of Environmental Health. Back

30   A dwelling with an outside toilet would not be seen as having "an appropriately located bathroom and WC", but as long as it was seen as having three other among the six characteristics, the dwelling might pass the Decent Homes Standard. Back

31   Q13, Peter Brown, Chartered Institute of Environmental Health. Back

32   Q411, Mel Cairns, Environmental Health Officer. Back

33   DEC01, para 2.3. Office of the Deputy Prime Minister (ODPM). Back

34   ODPM: A Decent Home: The Definition and Guidance for Implementation: February 2004. Annex A: para. 3.22. Back

35   ODPM: A Decent Home: The Definition and Guidance for Implementation: February 2004. Annex A: para. 3.23. Back

36   ODPM: English House Condition Survey 2001: Building the Picture; July 2003; paras 3.4 - 3.5. Back

37   For details on the Fuel Poverty Strategy, see:  Back

38   See for example DEC09, National Energy Action; DEC11, All Party Parliamentary Warm Homes Group; DEC30, The Sustainable Energy Partnership. Back

39   See for example Q3, Sarah Webb, Chartered Institute of Housing and Andrew Griffiths, Chartered Institute of Environmental Health Back

40   Q4, Peter Brown, Chartered Institute of Environmental Health. Back

41   DEC37, para 1.1. Chartered Institute of Environmental Health. Back

42   DEC29, p2, The Energy Saving Trust. Back

43   DTI: The UK Fuel Poverty Strategy, November 2001;  Back

44   NAO: Warm Front: Helping to combat fuel poverty; HC769, June 2003; paras 1.10 - 1.11 Back

45   ODPM: English House Condition Survey 2001: Building the Picture; July 2003; Supporting tables: Decent Homes; Table A4.28 Back

46   E.g. in written evidence to the inquiry into fuel poverty by the Trade and Industry Committee Back

47   DEC11, para. 2.5. Back

48   DTI: Energy White Paper: Our Energy Future - Creating a Low Carbon Economy; February 2003; Foreword  Back

49   Energy White Paper: Our Energy Future - Creating a Low Carbon Economy; February 2003; para 2.14 Back

50   Energy White Paper: Our Energy Future - Creating a Low Carbon Economy; February 2003; para 3.5. Back

51   Energy White Paper: Our Energy Future - Creating a Low Carbon Economy; February 2003; para 3.32. Back

52   DEC29, The Energy Saving Trust, p2. Back

53   DEC30, The Sustainable Energy Partnership, paras 4-5. Back

54   Q54, Georgia Klein, National Consumer Council. Back

55   Cf. DEC29, p2., The Energy Saving Trust; DEC09a, National Energy Action. Back

56   See also paragraphs 48 and 49 above. Back

57   DEC45, p7. National Consumer Council. Back

58   See for example comments by the Chartered Institute of Environmental Health (Q3), as well as DEC45 p7, The National Consumer Council; DEC26, para 3.11, Richard Hand. Back

59   DTI: The UK Fuel Poverty Strategy: Annex A: Energy Efficiency Measures; November 2001, para 2.  Back

60   ODPM: Housing Bill Explanatory Notes; para 248;  Back

61   ODPM 2003: Contents of the Home Information Pack: A Consultation Paper; p18. Back

62   DEC26, para. 3.11, Richard Hand. Back

63   Q57, Ronald Campbell, National Energy Action. Back

64   Q3, Andrew Griffiths, Chartered Institute of Environmental Health. Back

65   DEC31, paras 4-6, The Disability Rights Commission, The Habinteg Housing Association, and The Joseph Rowntree Foundation. Back

66   Q65, Marie Pye, Disability Rights Commission. Back

67   DEC31, Executive Summary , The Disability Rights Commission, The Habinteg Housing Association, and The Joseph Rowntree Foundation. Back

68   DEC31, paras 12-14. , The Disability Rights Commission, The Habinteg Housing Association, and The Joseph Rowntree Foundation. Back

69   Q64, Marie Pye, Disability Rights Commission. Back

70   Q70, Marie Pye, Disability Rights Commission. Back

71   DEC63, para. 5.2, Care & Repair England. Back

72   Q67, John Stewart, UK Noise Association. Back

73   DEC02, p1. UK Noise Associaiton. Back

74   Q69, John Stewart, UK Noise Association. Back

75   Q171, Roy Irwin, Audit Commission. Back

76   Q88, Neil McDonald, Director of Housing, ODPM. Back

77   Q169, Dr Norman Perry, Housing Corporation. Back

78   DEC21, para. 3.1. The National Housing Federation. Back

79   Q445, Jim Coulter, National Housing Federation. Back

80   Q56, Jill Johnstone, National Consumer Council. Back

81   Q250, Mr Atherton, the Local Government Association. Back

82   Q458, The National Housing Federation Back

83   Q281, Steve Hilditch, Hammersmith & Fulham Housing Commission. Back

84   Q284, Nigel Brooke, CityWest Homes. Back

85 Back

86   DEC49, para. 3.2. Sunderland Housing Group. Back

87   DEC58, para. 7.2. Chartered Institute of Housing. Back

88   David Blackman: Two Sides to the Story in Inside Housing, 28 February 2003. Back

89   DEC14, para. 13. Nottingham City Council. Back

90   DEC61, para. 38. The Greater London Authority (GLA). Back

91   DEC21, para 8.1. The National Housing Federation. Back

92   Q174, Dr Norman Perry, Housing Corporation. Back

93   DEC28, p 2. Hammersmith & Fulham Housing Commission. Back

94   Q176, Dr Norman Perry, Housing Corporation. Back

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