Conclusions and recommendations
A Decent Home for all?
1. The
Committee welcomes the policy of setting a minimum standard for
a Decent Home. (Paragraph 6)
Criterion 1: Meeting the current minimum standard
for housing
2. 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. (Paragraph 26)
Criterion 3: Reasonably modern facilities and
services
3. 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.
(Paragraph 37)
4. 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. (Paragraph 39)
Criterion 4: A reasonable degree of thermal comfort
5. 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. 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
91 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. (Paragraphs 48 and 49)
6. 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. (Paragraph 57)
7. 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. (Paragraph 62)
Aspects excluded from the definition
8. 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. (Paragraph 65)
9. 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.
(Paragraph 68)
10. 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. (Paragraph 71)
Too basic to be decent?
11. 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. (Paragraph 78)
Decent Homes in relation to the Sustainable Communities
agenda
12. 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. (Paragraph 87)
Decent Homes Plus?
13. 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. (Paragraph 91)
14. 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. (Paragraph 92)
The rate of progress
15. The
Committee is disturbed by the large unacknowledged and unexplained
discrepancies found in the data provided by the ODPM on progress
towards the Decent Homes target. The discrepancies effectively
make it impossible to assess whether the Department is on course
to delivering one of its key PSA targets. We recommend that the
ODPM investigate this matter very carefully, and that it make
public its findings and a full explanation along with the most
accurate set of figures and projections.(Paragraph 101)
16. The Committee
is concerned that a lack of funding as well as the delays caused
by lengthy options appraisals procedures and tenant ballots may
result in Local Authorities being unable to meet the 2010 target.
(Paragraph 107)
17. We are not persuaded
that the ODPM is doing everything possible to ensure the target
is met in full across the different sectors. In particular, we
are concerned that the year on year rate of improvement is not
rising fast enough to meet the target. We recommend that the ODPM
take immediate action to ensure that the rate of improvement be
increased and sustained at the level required. (Paragraph 111)
The cost of reaching the target
18. The
discrepancies in the ODPM data makes it virtually impossible to
assess whether the currently projected funding provisions are
likely to be adequate for keeping the social housing sector on
track to meeting the Decent Homes target. The Committee is concerned
that sufficient funding may not be being planned for, especially
given the ODPM's own admission that the cost of bringing each
home up to the Decent Homes target is likely to increase in real
terms over time, as Social Landlords come to deal with the more
difficult stock. We recommend that the Government address this
issue with urgency. (Paragraph 116)
19. The Committee
is concerned that, having set a very limited target for Decent
Homes in the private sector, the Government should now address
seriously how this target is to be achieved. (Paragraph 119)
Local Authority housing
20. The
Committee recommends that the Government revisit its dogmatic
pursuit of the separation of stock management and strategic management
of housing. A flexible policy and a level playing field is needed
so that tenants and Councillors can tailor solutions to suit local
circumstances. In some cases, the optimal solution, as well as
the one preferred by tenants, may well be that the Local Authority
retain full ownership and management responsibilities. (Paragraph
128)
21. We have not heard
evidence that creating an ALMO per se enhances the achievement
of Decent Homes, or indeed of tenant satisfaction. The option
of creating an ALMO should continue to be available to Local Authorities,
but there should be no financial incentive for Councils to do
so. (Paragraph 139)
22. In the Committee's
view, PFI schemes are not well suited as a key instrument for
achieving Decent Homes. The schemes are highly complex, and unsuitable
as whole-stock options. Furthermore, they do not guarantee increasing
levels of tenant participation and choice, one of the key aims
of the Government. (Paragraph 141)
23. The prudential
borrowing rights introduced through the Local Government Act are
not sufficient to create a level playing field. The Committee
recommends that Local Authorities be granted wider rights to borrow
prudentially against rental income streams for the purpose of
improvements to the stock and to help create sustainable communities.
We recommend that the Government reconsider adopting the principle
of investment allowances to Local Authorities. (Paragraph 152)
24. The Committee
agrees with those stakeholders who argue that Local Authorities
hold the potential to manage housing stock just as effectively
as RSLs, ALMOs or PFI schemes. Consequently, Government financial
support available for investment in Decent Homes under those schemes
should be available on an equal footing to Local Authorities managing
their own stock. (Paragraph 154)
25. The Committee
has been deeply concerned to learn of the catch-22 position in
which some local authorities now find themselves. The Committee
recommends that, as a matter of urgency, the Government provide
constructive alternative options for Local Authorities in this
situation. (Paragraph 160)
26. The Committee
fully supports the Government's commitment to tenant choice and
involvement in determining how Local Authority housing should
be owned and managed. However, the commitment to tenant choice
is a charade unless Local Authorities are able to act in accordance
with the wishes of their tenants. We recommend that the Government
take immediate steps to ensure that where a majority of tenants
wish for their homes to remain under Council management, they
are not penalised when it comes to access to funding for investment
in Decent Homes or any other policy initiatives. (Paragraph 163)
27. The Committee
is not convinced that ALMOs and stock transfer RSLs necessarily
lead to better tenant participation and satisfaction. There is
no reason to suggest that the same results and management innovations
could not be achieved under Council management, given equal resources.
The Hammersmith and Fulham Housing Commission is an example of
Local Authority innovation and best practice development in this
area. (Paragraph 166)
28. The Committee
believes that there should be a level playing field between local
authorities with retained stock, ALMOs, and stock transfer companies
in terms of the mechanisms and volumes of funding available to
them. The current situation unfairly steers tenants towards the
stock transfer option because the funding available is unlimited
whereas the funding potentially released under the ALMO scheme
is finite, and funding for Local Authority managed stock is even
more restricted. (Paragraph 169)
29. We recommend that
a level playing field between the different ownership and management
options should encompass not only funding mechanisms directly
related to the Decent Homes target, but also funding for wider
investment purposes. Based on local circumstances, managers and
tenants should themselves be able to determine how to balance
investment in Decent Homes, as currently defined, with investment
in making the community sustainable and decent. (Paragraph 172)
30. We believe the
requirement for tenant consultation and approval should be identical
regardless of whether a Local Authority intends to go down a PFI,
ALMO, or stock transfer route. (Paragraph 174)
Registered Social Landlords
31. We
recommend that, whilst the Government should maintain the policy
of rent restructuring, its effects should be reviewed to ensure
that the levels of stock investment can be maintained across the
social housing sector. (Paragraph 182)
32. The Committee
is concerned that the absence of a scheme to replace the Estates
Renewal Challenge Fund programme will result in Local Authorities
being unable to transfer their worst stock, having transferred
the remainder to RSLs. In that scenario, Local Authorities could
end up owning and managing the stock most in need of large amounts
of investment, but with no resources to invest in it at all. We
therefore recommend that the Government replace the Estates Renewal
Challenge Fund with a similar system of dowry funding. (Paragraph
187)
33. The Committee
fully recognises that there are circumstances where demolition
of social housing stock is the best available option. However,
the Committee is concerned that some social housing providers
may see the demolition, or in high-value areas such as London,
the sale of properties as the easiest and most cost-effective
way of achieving the Decent Homes standard. We recommend that
the Government puts guidelines in place preventing the social
housing stock from being unnecessarily eroded through sale or
demolition. (Paragraph 191)
The applicability of the target in the private
sector
34. The
Committee believes that every household has a right to a Decent
Home. The Government should set a longer term target for bringing
all homes up to the Decent Homes standard, say by 2015. The Government
should consider carefully how to provide both funding incentives
and statutory enforcement vehicles in order to achieve such a
target in the private sector. (Paragraph 197)
35. The Committee
sees little sense in limiting the target only to a proportion
of dwellings inhabited by vulnerable households. Making such distinctions
is likely to waste resources in monitoring, and also to render
monitoring and enforcement inaccurate and ineffective. Instead,
the Decent Homes target should be applied to all dwellings in
the private sector as well as the social sector. (Paragraph 199)
The private rented sector
36. Consequently,
we consider that the limitation of the target to vulnerable households
is likely to disadvantage such families even further, especially
in areas of high demand. (Paragraph 202)
The owner-occupied sector
37. The
Government should ensure that equity release mechanisms and /
or financial assistance be made available to owner-occupiers whose
homes do not meet the Decent Homes standard, helping them to finance
the undertaking of vital repairs and improvements in order to
bring their home up to the Decent Homes standard. Financial assistance
and advice should be targeted particularly at areas where low
property values make it difficult or impossible for owners to
take out a mortgage in order to make repairs. (Paragraph 205)
Enforcement
38. The
Committee recommends that Local Authorities be granted powers
of enforcement vis-à-vis private landlords, as well as
funding sufficient to carry out such enforcement. (Paragraph
207)
39. We urge the Government
to implement, as soon as possible, and within a timeframe to facilitate
our recommendation in paragraph 196 above, the Law Commission's
recommendation, made seven years ago, for the creation of a statutory
right for tenants to a home complying with specified minimum standards.
Given that the fitness standard is soon to be replaced by the
Housing Health and Safety Ratings System (HHSRS), we believe the
Government should opt for making the full Decent Homes Standard
a statutory right for tenants, enforceable by them through the
courts. (Paragraph 211)
Funding
40. The
Committee agrees with the Chartered Institute of Environmental
Health that there is an urgent need to re-evaluate the priority
given to Decent Homes in the private sector. We urge the Government
to make both statutory changes to tenancy legislation, and to
the enforceability of the target in the private sector, and to
provide sufficient and targeted funding for the standard to be
effectively enforced in the private sector. (Paragraph 214)
Conclusion
41. Our
final, but vital recommendation is that the treasury commit additional
funding to the Decent Homes policy sufficient to ensure that the
current Decent Homes 2010 target be met, and that a subsequent
'Decent Homes Plus' target can also be met. (Paragraph
220)
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