Memorandum by The Guinness Trust (DEC
60)
SUMMARY
The following comments are submitted to the
ODPM Committee, which is reviewing issues connected with Decent
Homes for their consideration.
In general terms, the following concerns are
highlighted:
— the definitions used in the standard
make the task of assessing compliance quite difficult;
— the definitions used in the standard
make the task of comparing performance between RSLs difficult;
— the assessment of noise nuisance
is not properly dealt with;
— general conditions of the environment
within which individual properties exist are not assessed and
yet this is of importance to the sense of safety and well being
experienced by residents;
— the acquisition of stock which is
in poor condition will force RSLs to report failure of the standard
for large numbers of their properties in 2010 if acquired in the
next few years;
— programmes will be skewed in order
to meet the decency standard and this will reduce tenants choice,
reduce our efficiency in procurement and project management and
may reduce quality;
— it is difficult to keep track of
those properties which currently meet the standard but which will
fail it in 2010; and
— a focus on meeting the decency standard
may cut across our long term asset management plans.
1. THE DEFINITION
OF DECENT
1.1 It is always difficult when words such
as "appropriate" , "reasonable", "suitable"
etc are used to set standards. This broadly leaves RSLs to define
for themselves how this can be interpreted. There are some advantages
because this allows RSLs the flexibility to work with their staff
and residents to define standards, which suit their stock, local
needs and client groups. However when the standard is used by
the regulator or the ODPM to compare the performance of RSLs with
each other, it can be difficult to be certain that the standards
chosen are of a comparable nature.
1.2 As part of designing a stock condition
database, the Guinness Trust Group is incorporating a software
mechanism to calculate the level of decency for us. Obviously,
we are taking decisions about how this software works and how
best to interpret condition on-site as we gather the data for
input to the database.
1.3 Presumably many other RSLs are doing
a similar exercise and again there are bound to be differences
in the way their software is designed and the way data is gathered.
This process can be compared with the Standard Assessment Procedure
(SAP) for rating the energy efficiency of dwellings which was
introduced some years ago. That gave very clear and detailed guidance
about how the calculation should be done whether by software or
by an individual person. That resulted in some certainty that
whatever accredited software supplier was used, the rating of
a property would be the same within a very small margin of error.
That is not the case with assesing decency and it might be worth
considering whether a similar approach could be adopted.
1.4 Another difficulty is introduced by
the way that some factors in assessing decency are considered
more than once. One example of this is the heating system as heating
is considered under criterion a (the fitness standard), criterion
b (as a key building component) and also as criterion d (providing
a reasonable degree of thermal comfort).
This can make assessment complicated in order
to accurately assess the factors whilst trying to avoid double
counting where that is inappropriate.
1.5 Criterion C refers to the need for adequate
noise insulation, which is a good thing as our experience has
shown that it is of great significance to residents. However,
the standard exclusively refers to external noise generated by
traffic or factories rather than say external noise in general
(eg. from play areas, community centres, other commercial uses
or other buildings or dwellings nearby). It then details that
the single solution to this is to provide double glazing when
in fact the solution to external noise may require a number of
construction changes.
For many residents noise transfer between dwellings
and even within dwellings can have a far worse effect on their
sense of well being than external traffic noise and yet this is
not mentioned in the standard.
1.6 In general terms, Housing Associations
provide housing which is of good quality. We strive through our
programmes of investment, planned or cyclical maintenance and
improvement projects to maintain high standards and meet rising
resident aspirations and so in many cases the standard is quite
a low one. An example of this would be setting the standard for
kitchens at under 20 years old whereas our programmes include
planned replacement to a more frequent cycle.
1.7 However the standard makes little reference
to the environment of estates other than to briefly mention the
common entrance areas of blocks of flats which should have "adequate
size and layout". Our residents place great importance on
living in estates which have well managed and maintained common
parts such as play areas, paths, parking areas, unadopted roads,
garage courts and green space. They also value the provision of
adequate lighting on estates to add to their feeling of safety
and security.
2. THE SCALE
OF THE
PROBLEM
2.1 When the Guinness Trust Group first
reported the number of dwellings failing the decency standard
in March 2002, it did so by using an evaluation method designed
in-house. Local teams of staff were briefed on the process and
using their local knowledge assessed each group of properties
they managed against the guidance provided by the DTLR. The results
were collated to give an overall figure for the Group. This process
was repeated in March of 2003.
2.2 For the report in 2004 we will be adopting
a different mechanism using new software and based upon the results
of a new stock condition survey completed by external consultants.
2.3 We have an asset management strategy
in place that is supported by, among other things, a detailed
programme of planned maintenance. Our asset management strategy
will identify groups of properties which for a variety of reasons,
we may not choose to invest in whilst in their current form. Those
groups of properties may have exit strategies or remodelling plans
in place or we may be in consultation with other RSLs about them
as part of considering better managing arrangements.
2.4 The requirement for all the homes we
manage to meet the standard in 2010 may force us to invest in
properties and that would cut across our considered asset management
approach. Clearly that is not desirable.
3. FUNDING AND
DELIVERY
3.1. The number of properties managed by
the Guinness Trust Group is growing by a process of traditional
development, merger and acquisition. Where stock transfers take
place as part of the process of recognition that the current RSL
cannot adequately resource the investment required, it is likely
that many properties within the transfer will fail the decency
standard.
3.2 The RSLs that consider taking such stock
on, particularly as 2010 approaches, will either be forced to
alter their investment programmes artificially to meet the standard
rather than invest in a considered, appropriate way or to report
large numbers of failures of the standard and risk their reputation
when performance figures are published.
3.3 There should be a way of recognising
the existence of plans to deal with such properties without affecting
overall performance in meeting the decency standard for existing
stock.
3.4 Funding of the work needed to meet the
decency standard in general terms will be met from the business
plans of well-managed RSLs. The main sources of failing the standard
for the Guinness Trust Group are those elements that our residents
have asked us to prioritise in any event. Our planned maintenance
and improvement programmes therefore are designed to meet their
aspirations and priorities whilst also addressing the needs of
the buildings.
3.5 However the requirement for all homes
to meet the standard by 2010 will require us to skew our programmes
in ways which do not meet our standards of best practice for procurement,
project management or minimising disruption to residents. That
alteration to our usual practice will introduce inefficiencies
and costs will increase as a result, putting more pressure on
our ability to carry out the work.
3.6 The potential for the requirement to
meet the decency standard, to divert our attention away from our
asset management strategy, is of great concern.
4. TENANT CHOICE
4.1 The requirement for all of our properties
to meet the standard by 2010 will reduce tenant choice. Our programmes
will have to be artificially skewed as described above and so
this will place a constraint on the ability of residents to help
us make plans and set priorities for future investment.
If for example we had planned to carry out work
in 10 years time but now must do that work in seven years time
in order to meet the decency standard, we obviously have to rearrange
other work to free up the resources needed.
4.2 If resources are under pressure we may
be forced to consider reducing the quality of the work we do rather
than carry on our usual practice of trying to drive the standard
of quality up to meet resident aspirations. The ability of tenants
to influence quality will diminish in such circumstances.
5. OTHER CONSIDERATIONS
5.1 It is relatively straightforward to
assess current condition and put plans in place to ensure that
the needs of any non-decent properties have been met by 2010.
It will however be quite difficult for some RSLs to have systems
in place which keep track of those properties which are currently
decent but which will fail the standard in 2010 in order to make
sure that their needs are also dealt with.
5.2 As focus on achieving the standard will
divert resources from considered programmes and plans, this may
have an adverse effect on our ability to innovate, to create programmes
of work which suit long-term partnering arrangements and to think
about the long-term future of some parts of our asset base.
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