Memorandum from Gentoo Group (BDH
11)
Beyond Decent Homes: decent
housing standards post 2010
SUMMARY OF RESPONSE
· The Decent Homes
Standard has achieved a degree of success in acting as a lever for major
investment into the nation's affordable housing stock.
· There needs to be
further differentiation between providers over the degree of quality of
improvements to the stock - 2 landlords can both achieve Decent Homes (which is
a minimum standard) but have markedly different quality standards in their delivery.
· The affordable rented
sector is heavily regulated in terms of improvement standards and rent control,
neither of which apply to the same degree to the private sector. The Group
would like to see a combination of relaxation of rent control and more punitive
measures on the private sector to ensure decency is sustainable in the long
term.
· LSVTs provide a long
term sustainable solution to Decent Homes but also bring a range of wider
benefits. As such we would advocate the LSVT model as a preferred management
solution to Decent Homes and neighbourhood regeneration.
· A range of new
initiatives are underway that will improve environmental impacts and fuel
poverty such as retrofit and Passivhaus. The Group would like to see further
development in these areas which would be of direct benefit to achieving
decency in the housing sector.
Beyond
Decent Homes: decent housing standards post 2010
Response
by Gentoo Group
1.0 PURPOSE
1.1 The purpose of this response is to present Gentoo
Group's comments to the Communities and Local Government Committee inquiry and
call for evidence into Decent Homes post 2010.
2.0 BACKGROUND
2.1 Gentoo Group (the Group) was formed in April
2001 following the transfer of Sunderland City Council's housing stock. With
36,000 units involved this remains the largest English stock transfer to date.
This response represents the views of Gentoo Group which comprises:
· Gentoo Group
· Gentoo Sunderland
· Gentoo Homes
· Gentoo Construction
· Gentoo Ventures
This response will be in 2 parts:
Section 3 will cover general comments
on Decent Homes and its progress over the last 10 years
Section 4 will cover specific comments
on the discussion questions set out in the call for evidence document.
3.0 GENERAL COMMENT
3.1 The Decent Homes standard set out a minimum
property standard designed to meet the national back-log of repair in
affordable housing. The Group reached the Decent Homes target in 2005 and has
since maintained its stock at or above this level. As such the Decent Homes
standard has achieved a degree of success in acting as a lever for major
investment into the nation's affordable housing stock.
3.2 The Group has maintained that this is a
minimum standard and that often landlords have gone significantly beyond the
Decent Homes standard in terms of promises to residents and the delivery of
maintenance and improvement programmes.
3.3 The Group would also state that often it has
been hard to differentiate between the performance of landlords in terms of the
quality of improvement that has been made and the extent to which the Decent
Homes standard has been exceeded. There have been considerable differences in
the average levels of spend per unit on modernisations for example between for
example the first round ALMOs and LSVTs although both would claim to have met
the Decent Homes standard.
3.4 There is a much bigger issue however.
Through regulation, the affordable rented sector has been brought almost up to
the Decent Homes standard. The wider private sector, particularly the lower end
of the private sector continues to suffer from poor stock condition and under
investment. The affordable rented sector continues to have to meet standards on
existing stock and more stringent standards on new stock. These have to be met within a regime of rent
control that is not applied to the private sector. The Group feels that more
could be done either to bring relaxations to rent control within the affordable
rented sector or to place heavier sanction on the private rented sector to
ensure that if they are to be eligible for housing benefit, then properties
should be at or near the Decent Homes standard.
4.0 SPECIFIC
COMMENTS
4.1 What lessons can be learned from the Decent
Homes programme and equivalents in Scotland,
Wales and Northern Ireland?
The overall policy
driver to bring affordable housing up to the Decent Homes standard has been
largely successful. The ability to connect the policy driver with the securing
of significant funding levels have been key to the programmes delivery. In particular
the ability to unlock revenue through the LSVT route has mean that not only can
the 2010 target be largely achieved, it can then be maintained in perpetuity.
What has been disappointing is that the standard has been applied within
housing that is regulated but has been much more sparsely applied to the
private sector. There should surely be some scope for linking the receipt of
housing benefit as a public subsidy with the achievement of Decent Homes. In
terms of owner occupation, this is more difficult. The Group would like to see
further exploration of ethically administered home improvement grant or equity
release programmes in order to be able to raise standards in owner occupied
housing.
4.2 Where targeted housing fails to reach the
Decent Homes criteria by 2010, how should this backlog be addressed?
The whole sector has
had the same length of time within which to conduct option appraisals and then
implement investment programmes and to have a situation where some tenants are
still living in substandard accommodation should not be acceptable. Where
housing does not reach the standard there has to be some form of remedial
measure in order to ensure that customers can at least live in housing that
meets the statutory minimum requirement. Where there is persistent failure to
deliver then maybe a solution is enforced full or partial transfer of stock to
a social landlord who will deliver this for the customer's benefit.
4.3 Should minimum acceptable social housing
standards be amended to take account of environmental standards, fuel poverty
and the estate?
Yes - Decent
Homes moves us someway to CO2 reductions but it will never on its
own move us to an 80% reduction by 2050.
There need to be some standards, measures or targets that landlords need
to hit. An example of a standard could
be that all homes must meet a % reduction in CO2 or alternatively an
improvement in the standards required e.g. heating, air tightness or appliances.
A further example could be the SAP target e.g. all properties have to have a
SAP rating above a certain level. In the Group's experience we have also looked
at the potential impact on fuel savings that can be attributable to
environmental improvements. Provisional estimates show that these are in the
order of 50% savings on retrofit properties and up to 90% on Passivhaus - both
of which would bring significant benefits in terms of fuel poverty.
4.4 Do the management organisations - councils,
including via ALMOs, and housing associations - need to change? Will they have
sufficient funds?
There may need to be change within
some organisations in order to arrive at a management and funding model that is
serviceable in the long term. Recent research by the Joseph Rowntree Foundation
evidenced that LSVTs for example have brought significant additional benefits
on the back of their creation. These included investment over and above the
Decent Homes standard, significant additional renewal and regeneration
programmes and the adoption of more inclusive and customer focussed cultures.
When compared to the alternative models of stock retention or ALMO it is
difficult to see how some organisations can continue if any kind of parity
between providers can be maintained.
Often the decision to go for ALMO or
retention has been seen as the politically acceptable route. The Group has
argued consistently however that the need for a ballot for a transfer to
proceed has often been a sticking point
- something that is not imposed in the same way as for instance in
health or education. The LSVT route provides so many benefits - including
removal of housing from the PSBR - that it would seem sensible to push this
route as vigorously as possible as the best value solution for the long term
management of the sector.
Failing
this, to ensure the long term retention of decent standards in the sector,
together with the additional expense of higher environmental standards - a much
increased level of public investment would be needed.
4.5 What are the implications for decent housing
standards of the Government's proposal, currently out for consultation, to move
to a devolved system of council housing finance?
The devolved system of council housing
finance to enable local authorities to retain capital receipts and income from
new build housing is supported by the Group. In terms of implications this may
release some additional resource into the sector for investment purposes but it
is unlikely to have a major impact as the following table illustrates.
Table 1 :
RTB Sales in England
over last 5 years
|
2004/05
|
2005/06
|
2006/07
|
2007/08
|
2008/09
|
|
49,980
|
26,650
|
16,900
|
11,960
|
2,860
|
There is
also little prospect of sales levels rising to anywhere near their previous
levels due to the comparative reduction in discount compared to valuation. It
is difficult to see therefore how either capital receipt retention or the
release of income from new development will have a major impact for Decent
Homes.
4.6 How should the Decent Homes target for
private sector homes occupied by vulnerable people be taken forward?
The overall management and monitoring
of the Decent Homes target with regard to vulnerable people should be part of
the remit of Local Authorities. This should cover both an assessment of
vulnerability and then setting of targets to ensure that Decent Homes standards
are met. The Group would be particularly concerned that that the thermal
comfort and fuel poverty aspects of the standard are met. As we have stated
earlier in this response there should be some sanction applied through housing
benefit eligibility for landlords if they do not comply with Decent Homes
targets.
The further use of selective licensing
schemes could be applied as a way of ensuring that landlords are encouraged to
meet Decent Homes criteria. The further use of Home Improvement Agencies could
also be of assistance to vulnerable households who may be equity rich but cash
poor within the owner occupied sector.
4.7 Are adequate arrangements in place for the
future regulation of minimum acceptable housing standards?
The broader remit of the TSA to cover
both local authority and housing associations will go some way to ensuring that
affordable rented housing is captured in terms of regulation. As far as the
private sector is concerned the main regulatory mechanisms should be operated
through the Local Authority with some wider accountability within Local
Strategic Partnerships and particularly within Local Area Agreements. National
Indicator 158 - % Decent Council Homes goes some way to ensuring this is
monitored, but a wider remit on this indicator is probably needed to ensure
that regulation is effective and consistent across sectors.
Specifically in regard to
environmental factors, the further monitoring of indicators such as SAP
ratings, EPC data and/or carbon reduction data (such as stock footprints),
across the whole stock would enhance the regulators understanding of 'decency'
and therefore the ability to monitor it.
4.8 Are there local examples of innovative best
practice with wider post 2010 applicability?
The Group has taken a holistic
approach to its achievement of decency within the housing stock. The Group's
Amenity A standard contains elements that take it beyond the Decent Homes
standard in terms of inclusion of external boundaries, and security measures.
The compliance position is set out in table 2 overleaf:
Table 2:
Gentoo compliance against Decent Homes Standard
|
Gentoo Amenity A standard
|
DHS Compliant
|
Exceeds DHS Compliance
|
|
New
bathroom
|
ü
|
|
|
New
kitchen
|
ü
|
|
|
New
external door
|
ü
|
ü
|
|
Double
glazed PVCu windows
|
ü
|
ü
|
|
Rewire/additional
sockets
|
ü
|
ü
|
|
Thermal
insulation
|
ü
|
|
|
Environmental
improvements
|
|
ü
|
|
Upgraded
heating if required
|
ü
|
|
|
Fencing
|
|
ü
|
A further learning point from the
Group's experience of modernising over 20,000 properties is that residents
preferred to have the full modernisation works completed within a single time
frame such that there was only one major intrusion into the property. A number
of landlords continue with modernisation of single elements which causes
multiple disruption to households which can be traumatic for vulnerable people.
More
recently the Group has been looking at the impacts on household income in terms
of fuel consumption and fuel poverty. Initiatives such as retrofit and new
build technical standards such as Passivhaus will ensure that fuel costs are
greatly reduced. There is also a need for education and information sharing
however so that residents can get the best out of environmental initiatives
that are available.
September
2009
| 