Memorandum by the Tenant Participation
Advisory Service (TPAS) (DEC 54)
This response has been prepared using views
and comments previously publicly expressed regarding stock options
appraisal and the Decent Homes Standard. While the paper represents
TPAS' view it is subject to formal approval by TPAS' Executive
Committee.
TPAS is a membership organisation of over 300
social landlords and 1,000 tenant groups that exists to promote
tenant empowerment. It is a market leader in Tenant Participation
providing training, information services, conferences and consultancy
work. It is presently an ITA for a number of stock options appraisals
and transfer negotiations.
THE DEFINITION
OF "DECENT"
AND THE
SCALE OF
THE PROBLEM
TPAS welcomes the Governments' floor target
of decency. While the scope of the target is limited it represents
a useful minimum standard. As far as practicable housing providers
should be encouraged to exceed the standard.
TPAS notes that the Decent Homes Standards prescribes
no level for noise insulation. Although it accepts the Governments'
view that noise nuisance is difficult to assess it believes that
domestic noise disturbance has a significant impact on the quality
of life for tenants. Government should consider providing minimum
standards for noise insulation in the DHS. TPAS would suggest
that the present levels prescribed for new build in Scotland would
be appropriate.
Tenants should be involved in decision making
around the relative priority given to Decent Homes Standard works,
and any potential works over and above the minimum standard. Housing
providers should provide sufficient support and training to tenants
to make sure that this negotiation can be meaningful.
There is no doubt that a large number of social
housing does not reach the Decent Homes Standard.
FUNDING MECHANISMS
TPAS holds no particular view on the most appropriate
mechanism for funding and delivering the Decent Homes Standard.
It welcomes the development of the ALMO option
and has noted the rapid improvement in services delivered by many
of the early ALMO authorities.
For PFI to be a viable option the funding process
should be simplified to allow schemes to deliver more quickly
and at lower cost.
It is absolutely crucial that tenants are involved
at an early stage in the strategic decision making process. While
TPAS notes government guidance to this effect, there is little
evidence that many Local Authorities have made efforts to involve
either experienced activists or the broader community in early
discussions about the available options; the key option choice
seems to be made in advance of tenant involvement. Effective dissemination
and discussion of information at an early stage should make any
future ballot more likely to succeed.
Ballots should be held no matter what the chosen
funding vehicle.
TENANT CHOICE
The scope for tenant choice in delivering the
Decent Homes Standard is limited. In particular, TPAS has concerns
about a number of elements of the ITA process:
— As Aldbourne Associates have noted
in their review of the National Compact Framework, Tenant Compacts
are rarely used as the bedrock for tenant involvement in strategic
decision making. Effective support for the meaningful engagement
of tenants in stock options could be better achieved if the importance
of compacts were to be re-stated. Clearly, this would also provide
new impetus to the compact initiative.
NB: TPAS has recently produced guidance, in
partnership with the Community Housing Task Force, on "Tenant
Compacts and achieving the Decent Homes Standard" www.tpas.org.uk/pdf/TPCNetwork/achievingdhstandardbriefing.pdf
— There is a clear lack of suitably
qualified ITAs in the market place. Local Authorities should be
further encouraged to delay their option appraisals until tenants
can be sure that they have selected the right ITA. This may involve
stretching the 2005 deadline for completion of option appraisals.
Similarly, the timescales for completion of the option appraisal
too rarely take account of government guidance to go at "the
tenants' pace".
— There is very mixed practice in the
recruitment of ITAs. TPAS is pleased to be a partner (with PEP)
in the Community Housing Task Force Roadshows around Good Practice
in stock options. However a clearer message that tenants should
lead in the recruitment of their ITA and receive sufficient training
to do this effectively would be welcome.
— The provision of a central budget
to allow tenants to control their ITA was agreed in principle
by Lord Rooker and would greatly assist tenant empowerment. TPAS
is however, aware of the practical problems with such a scheme
(such as complying with treasury guidelines) in a relatively short
time. A beneficial approach might be to encourage Local Authorities
to devolve ITA budgets to tenant control.
NB: TPAS has recently produced a paper for CHTF
outlining specific examples of Good Practice in delivering a tenant
inclusive ITA process.
THE LINK
BETWEEN THE
DECENT HOMES
TARGET AND
OTHER PARTS
OF SUSTAINABLE
COMMUNITIES AGENDA
The Decent Homes Target seems to be well integrated
with other parts of the sustainable communities agenda. However,
it is important that housing providers and other partners take
the time to make sure that their plans accurately reflect neighbourhood
aspirations and needs.
In low demand areas it is to be hoped that Market
Renewal Pathfinders do not repeat top-down mistakes of the past.
Difficult decisions will have to be made around demolition in
particular, and it is important that these choices are made with
full community involvement.
Similarly, in the Southern growth areas there
is widespread concern within the membership that unit cost, through-put
and higher density levels will be prioritised above consultation.
"But all too often—in the interest
of quick results—change has been imposed from above without
proper understanding of what the problems are, or there has been
no support from communities to get involved." A New Commitment
to Neighbourhood Renewal—National Strategy Action Plan page
19.
In order for the broader sustainable communities
agenda to be successful it is crucial that Decent Homes are seen
in the context of neighbourhood needs.
TPAS has maintained for some time that the biggest
single problem facing social housing providers and their tenants
are related to Anti-Social Behaviour and Crime. Recent government
activity in this area has been beneficial. The clear link with
physical renewal should be, if possible, strengthened. At ground
level housing providers should be pushed to improve their ASB
management and criminal justice agencies clearly need to improve
their responsiveness to the needs of housing providers and tenants.
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