Memorandum by the London Borough of Greenwich
(DEC 51)
This paper summarises Greenwich Council's views
on the issues under review concerning the Government's Decent
Homes Standard.
DECENT HOMES
DEFINITION
LBG welcomed the introduction of the Decent
Homes standard and has significantly increased capital investment
in order to achieve it. However, LBG believes that the current
definition should be expanded to encompass wider issues of concern
to tenants such as security and community safety, streetscene
and estate environment, communal areas and neighbourhood regeneration.
The current focus on achieving the Decent Homes target risks limiting
the amount available to invest in addressing these wider community
concerns.
SCALE OF
THE PROBLEM
LBG is concerned about apparent inconsistencies
in the methodologies used by different authorities and the lack
of good data on RSL stock at a local authority level. The wide
range of Decent Homes figures being reported across London, for
example, is hard to equate with the spread of housing capital
investment over the last decade. Whilst the variation could reflect
different programme and maintenance strategies and performance,
there appears to be underlying uncertainty between boroughs as
to the consistency and accuracy of the overall figures for London.
This partly reflects the nature of stock condition surveys, which
given the expense involved are often reliant on extrapolating
data from small samples. It also remains the case that many authorities
are currently using data from surveys specified and carried out
before the Decent Homes standard and guidance was published.
FUNDING OPTIONS
LBG believes that additional investment should
not be restricted to the three options (PFI/ LSVT/ ALMO) and that
it is wrong to tie stock improvement funds (which should be principally
needs-based) too closely to service delivery (performance-based).
Whilst there are clearly some merits in the focus on housing management
delivery which an ALMO offers, there might be dangers of an associated
reduction in joined-up working in areas such as support to vulnerable
tenants, environmental quality and community safety which closer
integration to a council's corporate organisation may deliver
more effectively.
IMPLICATIONS OF
PSA+ AND NAO REVIEWS
LBG supports the enhanced stock options appraisal
process set out in guidance this June. The PSA+ review rightly
criticised earlier option decisions by some authorities who chose
stock transfer or ALMO options without consulting tenants in sufficent
detail on other options.
However, LBG urges further caution about stock
transfer as a cost effective option, given NAO findings and wider
experience of the financial risks involved. Given the restrictive
Government view of investment options, there remains a danger
that some authorities will effectively be forced to conclude that
stock transfer is the only realistic option to meet investment
needs (eg if ALMO is ruled out by performance issues), despite
concerns they may rightly have about cost effectiveness over the
long term. LBG is also concerned that the knock-on impact on an
authority's General Fund position is not always fully factored
in to options appraisals.
TENANT CHOICE
Consultation with LBG tenants indicates strongly
that tenants want more than just decent homes—wider environmental,
security and safety concerns (perhaps best summed up as Decent
Neighbourhoods) are equally if not more important. As a result,
there is a danger that targeting investment on DH means reduced
tenant choice over investment through the capital programme. The
current LBG programme was agreed at a local level by each of our
13 neighbourhood housing panels as a flagship element of our Tenant
Compact. The five-year programme was agreed before the DH standard
was announced. Subsequently the programme has been uplifted to
include additional DH elements, but without additional resources
(in fact, with HIP due to be reduced by up to 30%) the planned
completion timescale of the programme has been delayed. This has
undermined the council's credibility at the critical point when
the stock options appraisal process is about to commence.
In summary, there is an inherent conflict between
setting a national target and empowering tenants to make real
choices over stock investment priorities. Under current policy
and guidance, the Government risks giving the impression that
it places a higher priority on delivering the Decent Homes target
than on maximising tenant empowerment.
LINKS BETWEEN
DH AND WIDER
SUSTAINABLE COMMUNITIES
AGENDA
LBG recognises the important links between delivering
Decent Homes and supporting the wider objectives of the sustainable
communities plan. The Council is concerned that there is a need
for community cohesion in the Thames Gateway development areas
in relation to integrating new populations with existing local
communities and particularly options to improve mobility for LA
tenants and meet local housing needs. We have concerns about an
over-emphasis on meeting London-wide needs and those of key workers
in particular at the expense of homeless families and overcrowded
Council tenants.
We are pleased that the Government has recognised
that stock options are not always limited to finding ways to make
homes decent—in some cases, such as the Ferrier estate in
Greenwich, demolition and re-provision is the most sustainable
option. LBG will be looking carefully at whether this approach
would also be a preferred option for other estates, particularly
linked to the wider regeneration agenda in the Woolwich area,
an important part of the Thames Gateway growth area.
LBG welcomes this Select Committee review and
would be happy to provide any further background detail and comment
if requested.
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