Memorandum by the Chartered Institute
of Housing (CIH) (DEC 58)
1. INTRODUCTION
1.1 The Chartered Institute of Housing (CIH)
welcomes the opportunity to contribute to the Select Committee's
inquiry into how the PSA target relating to "decent homes"
is to be achieved.
1.2 CIH is fully supportive of the introduction
of the decent homes standard (DHS) and of the concept of a target
by which all homes should achieve this standard (DHT). We do,
however, have a number of concerns surrounding its implementation
and its links with other elements of current government policy
and these are outlined below.
1.3 The response provided below represents
an outline position only.
2. DEFINITION
OF "DECENT"
2.1 CIH is aware of the debate concerning
a possible expansion of the DHS definitions but were broadly supportive
of the PSA+Review recommendation to leave it unchanged. Our primary
concern in relation to the current definition of decency is that
it does not incorporate broader "liveability" issues
that many landlords and residents see as being crucial to the
maintenance of sustainable communities. We therefore prefer the
term "sustainable decent homes" and/or "decent
communities"; would suggest a degree of flexibility be built
into the implementation of the DHS to enable expenditure on environmental
factors and would support the development of a "decent neighbourhoods
indicators".
3. THE SCALE
OF THE
PROBLEM
3.1 The English House Condition Survey provides
the best indication of the scale of the problem but CIH our concerns
relating to this issue include:
— ODPM figures may under-estimate the
true scale of the problem;
— it is extremely difficult to adequately
assess the scale of the non-decency problem in the private sector;
and
— although the largest number of non-decent
houses fail the standard because of thermal inefficiency the most
serious problems are with sub-standard and unfit homes and more
work may be needed to target resources at this sub-group.
4. MECHANISMS
FOR DELIVERY
4.1 CIH welcomes government attempts to
provide local authorities with alternative mechanisms for meeting
the DHT but would raise the following issues of concern.
4.2 Options
Our primary concern relates to local authorities
for whom none of the current options are realistic or meaningful
choices. An example in this context is provided by local authorities
whose stock transfer proposals have been rejected by their tenants
but whose performance is not good enough to enable them to take
advantage of an ALMO. CIH would wish to see resources being allocated
to an "Improvement Programme" which would help poor
performing landlords improve to the point where all options were
available to them.
4.3 Transfers
CIH notes the valuable contribution that transfers
can make to the delivery of decent homes where this is what tenants
support. Specific comments on transfers include the following:
— we would support ODPM gap funding
for negative value transfers;
— we would support funding (through
transfer valuations/business plans) for master-planning work and
demonstration schemes that allow tenants to take part in and visualise
restructuring and renewal schemes;
— we would encourage ODPM to further
support transfers that build a regeneration approach in to the
proposal from the start; and
— we would support moves to enable
regeneration bodies to initiate transfer proposals.
4.4 ALMOs
We would strongly support efforts to expand
the autonomy/business freedoms of ALMOs as discussed in the 2002
"blue skies" debates.
4.5 Private Sector
CIH welcomes the extension of the DHS and DHT
to vulnerable households in the private sector but is concerned
that insufficient resources and policy tools are available to
local authorities to deliver improvements in this sector.
5. IMPLICATIONS
OF RECENT
STUDIES
5.1 PSA+ Review of Decent Homes
CIH welcomed the work undertaken by ODPM as
part of the PSA+Review on decent homes and participated in both
the Steering Group and the Project Group for this exercise.
5.2 In addition to the points raised in
section 4 above we would be keen to see the recommendations contained
in the final report implemented in full.
5.3 AC and NAO evaluations
CIH supports efforts to strengthen the strategic
enabling role of local authorities in relation to the delivery
of the DHT and would welcome moves to improve the monitoring of
the promises made to tenants as part of transfer/ALMO/PFI/retention
proposals.
6. THE ROLE
OF TENANT
CHOICE
6.1 CIH is wholly supportive of government
policies aimed at providing tenants with meaningful housing choices
but we would outline some concerns in this area in relation to
the DHS/DHT.
6.2 Empowering tenants not to chose a decent
home
There is a clear tension between empowering
tenants on the one hand and dictating what work should be done
to their homes on the other. Many social landlords will confirm
that where tenants are invited to prioritise the improvement work
that should be carried out in their home/neighbourhood they often
choose items that do not fall within the DHS (such as environmental
work aimed at increasing community safety). In other cases tenants
(particularly older households) may prefer to avoid the disruption
of improvement programmes altogether.
6.3 There is therefore a genuine tension
between meeting the needs of current tenants (either to prioritise
work that does not contribute to the DHS or not to have any work
done at all) and meeting the needs of future tenants (for decent
homes). Whilst CIH recognises that there is no straightforward
solution to this tension we would argue that it needs to be recognised
and addressed both by central government and by local social landlords.
6.4 The Community Gateway Model
CIH has worked with others to produce the "Community
Gateway Model"—a model originally developed to enshrine
tenant empowerment within the transfer process but since expanded
to cover ALMOs and the wider option appraisal process. This model
is now being used by a number of local authorities and CIH is
undertaking some action learning research to evaluate its success.
We were disappointed that greater prominence was not given to
the wider use of this model in local authority option appraisals
(through the ODPM guidance) and would argue for a strengthening
of the guidance in this area.
7. THE LINK
WITH OTHER
ELEMENTS OF
THE GOVERNMENT'S
AGENDA
7.1 CIH is concerned that 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.
7.2 Sustainability
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.
7.3 Regeneration
Although the PSA+Review process went some way
to emphasising the need to link transfers in particular with regeneration
CIH would argue that more could be done in this area. Specific
points include:
— supporting the idea that regeneration
bodies (such as LSPs) could initiate transfer proposals;
— encouraging non-housing budgets to
support housing-led regeneration programmes;
— ensuring the DHS is built into the
work of regeneration programmes (such as NDCs); and
— supporting ALMOs to take a regeneration
approach to investment programmes.
7.4 Environmental sustainability
At present the use of "green" technologies
and non-traditional methods of construction is often prohibitively
expensive and does not feature in work to achieve decent homes.
8. GENERAL POINTS
8.1 CIH considers that, although there may
be sufficient funding in total to tackle disrepair and poor housing
conditions in the social sector by 2010 there remain concerns
about implementation of the DHS/DHT at the local level.
8.2 Almost half of the councils who still
own housing stock have not yet prepared adequate plans for achieving
the DHT and this includes a number of large urban authorities
whose potential impact on the overall achievement of the target
is very significant because of the size of their stocks and the
high proportion of non-decent homes which they contain.
8.3 Our assessment of the risks is as follows:
— Many authorities are having difficulties
making viable political decisions because stock transfer remains
very controversial, despite the PSA Plus Review's helpful clarification
of the options. Some may be opting for stock retention without
sufficient certainty of the necessary resources; others may be
opting unrealistically for the ALMO route.
— Compounding this problem are the
demands of tenant involvement—very important though it is.
Smaller LAs may have insufficient experience of involving tenants
in strategic decisions. Larger LAs may simply face a very big
task in coordinating tenant involvement at neighbourhood level,
given the size of their stocks and their prior histories of tenant
involvement.
— Larger authorities such as Birmingham
and Sheffield are embarking on mixed strategies, but now have
a tight timetable in which to deliver a potentially complex mix
of transfer, ALMOs and stock retention. ODPM delivery mechanisms
tend to assume a single approach for each LA, they are not yet
geared up to mixed approaches with different timetables and financial
and inspection requirements.
— Many LAs which have opted for stock
retention have a tight timetable/budget for delivery of DHS which
can easily be thrown out by adverse decisions. For example, most
LAs can now count on only 70% of previous HIP resources, and this
only for the next two years, because of the change towards regional
allocation processes. Others will have been reliant on expected
levels of management and maintenance allowances which might now
fall (in the case of many London boroughs) by 10-20%, or even
more, as a result of the recently announced changes.
— On the options available to LAs,
there is now greater clarity about and ease of access to transfer
for large urban authorities, but there remain problems about both
ALMOs and PFI. ALMO resources are largely geared to achieving
DHS, but tenants' priorities may well be wider than DHS, and this
will affect attitudes towards a potential ALMO. Even with recent
changes in PFI, there remain widespread concerns about its complexity
and the ability to deliver improvements in the required timescale.
We therefore remained concerned about whether
the highly important target of ensuring decent homes in the council
sector will be achieved in practice. The deadline of July 2005
for LAs to produce viable options appraisals is especially important:
ODPM will have to work carefully and in detail with authorities
in the run up to this date, responding to changing requirements
at local level, but at the same time firm in its resolution to
intervene if implementation plans in individual authorities are
inadequate.
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