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Memorandum from Sandwell Metropolitan Borough Council (BDH 16)
1.0 Summary
1.1 This response is limited to bullet points 6 and 7 of the CLG Call for evidence dated 22nd July 2009, namely those relating Decent Homes in the private sector and regulation of minimum standards.
1.2 The key points are:- · Private sector housing represents the overwhelming tenure type in the country yet there are no significant targets set in terms of attaining decency in this sector; · Funding for decent homes in the private sector has declined rapidly in recent years and is set to decline further with the emphasis shifting further to building new homes; · The recent credit crunch has meant many existing home owners are unable to access funding to undertake essential repairs and are excluded from other tenure options due to lack of choice or affordability; · Non decent private homes have a significant impact on the health service, the economy, education and social inclusion and neglecting this sector is storing up problems for the future; · Specific problems exist in the private rented sector, which has seen a rapid expansion in recent years, and the recent messages from Government about delays in implementing proposals from the Rugg review are disappointing in that respect; · The Thermal Comfort element of the Decent Homes standard is low and should be reviewed.
2.0 Details
2.1 Approximately
80% of the homes in
2.2 Of these, 35.8% (6.5 million homes), are estimated to be non decent compared to 29.2%, just over 1 million homes in the social sector[2]. Significantly over 45% of homes in the private rented sector were estimated to be non decent even though this only accounts for 12% of the stock nationally.
2.3 In 2007, 39% of vulnerable households in private sector housing were living in non decent homes rising to almost 52% in the private rented sector compared to 28% in social housing.
2.4 Despite this no national indicator exists in respect of decent homes in the private sector.
2.5 National Indicator 158 requires Local Authorities to set targets in reducing the number of non decent Council homes and include these within its Local Area Agreement but this indicator makes no reference to the private sector.
2.6 This authority has seen funding specifically for private sector decent homes within the Regional Housing Pot reduce from £6.7M in 2006/07 to £1.2M (through the regional Kick Start partnership) in 2009/10. It has also been advised that private sector renewal is likely to be reduced further in future years to fund the Government's commitment to new homes.
2.7 Whilst we have made significant progress in tackling non decent homes locally, achieving the PSA7 target of 70% of vulnerable households in decent homes, there are still significant challenges in the private sector housing market.
2.8 Our most recent stock condition survey suggests that over £236m is required to ensure that all privately owned homes in the Borough meet the Decent Homes standard[3].
2.9 Whilst we agree with the Government's position, in fact it is a fundamental principle underpinning our private sector housing strategy, "that it is primarily the responsibility of private sector owners to maintain their own property"[4], in a borough where nearly 40% of private properties are occupied by a vulnerable household[5] this will be a significant challenge for many home owners.
2.10 The recent financial crisis has exacerbated this position, not only restricting access to borrowing for people seeking to buy new homes but also to those looking to improve their existing home through a combination of more reluctant lenders, reduced market values (and hence free equity to borrow against) and lower incomes.
2.11 The Council is able to assist many of those who are "equity rich but cash poor" through the West Midlands Kick Start scheme, there is a significant and growing number that have insufficient equity to access such loans but require urgent works to protect their health and safety.
2.11 Older housing, with greater maintenance requirements, is concentrated in the private sector, so failure to invest now will inevitably lead to a storing up of problems that will require larger scale investment to remedy in the future. Our survey revealed nearly 25% of homes failed the repair element of the decent homes standard, with a further 5% of homes having category 2 hazards under the Housing Health and Safety Rating System (HHSRS) both indicators of under investment.
2.12 Furthermore, our survey suggested that only 14% of homeowners currently living in a non decent home would have sufficient income to carry out the repairs required, meaning financial assistance, be it in the form of grants or supported loans, is required for the remainder.
2.13 Whilst it could be argued that supporting such owners is not sustainable it must be recognised that access to other forms of tenure is not a realistic option. Demand for social housing has increased considerably over the last 2 years with on average over 200 applicants for every property that becomes available.
2.14 In this environment the Council has had to become ever more creative in how it accesses finance for private sector renewal. Significant lobbying has resulted in NI187 (fuel poverty) being accepted as one of the 35 key indicators in our Local Area Agreement and a wide variety of partners provided funding for our services including the Primary Care Trust, Working Neighbourhoods Fund, The Housing Market Renewal Area, Kick Start and the New Deal for Communities.
2.15 This reflects the high priority placed on supporting vulnerable home owners regionally and locally that is not reflected in a national indicator for such work.
2.16 The HHSRS specifically links housing defects to the health and safety of the most vulnerable occupier. Using this system it is quite clear to see the impact poor housing has on occupier's health. This is clearly demonstrated by the most common category 1 hazards; cold homes and trips and falls, the cost to other services of which can also be shown using tools such as the Chartered Institute of Environmental/ Building Research establishment cost calculator[6].
2.17 Private Sector renewal also benefits the local economy, primarily through employment and training opportunities for local contractors but also by providing increased confidence in run down areas, raising market values and providing more disposable income to occupiers. The latter is particularly true of energy efficiency measures.
2.18 The private rented sector continues to grow, and whilst the vast majority of such properties offer decent accommodation there are considerable issues at the bottom end of the market.
2.19 The 2007 EHCS indicates that almost 52% of vulnerable households in the private rented sector lived in a non decent home. The private rented sector also had double the proportion of properties with the lowest energy efficiency assessments and almost a third of privately rented homes have a category one hazard under the HHSRS compared to one fifth of owner occupied homes and a tenth of social homes.
2.20 In this context it is disappointing to read recent announcements from CLG that there are no plans to publish a Housing Green Paper taken forward the recommendations of the Rugg Review at this moment in time[7].
2.21 A SAP rating of less than 35 has been set as a proxy for the likely presence of a category one hazard under the HHSRS for excess cold and this is also relevant to the assessment of the thermal comfort element of the decent homes standard.
2.22 However, there is considerable scope to extend the requirements of this part of the standard. Currently a dwelling could pass this element if it has programmable gas heating to only 2 rooms and either cavity wall insulation or 50mm loft insulation[8].
2.23 This level of provision will do little to help the Government meet its own targets around eradicating fuel poverty and reducing CO2 emissions.
2.24 The National Indicator relating to fuel poverty has 2 elements - a reduction in the number of vulnerable households living in properties with a SAP of less than 35 and an increase in the number where SAP exceeds 65.
2.25 Whilst a SAP of above 65 may not be achievable in all circumstances it would seem logical to amend the Decent Homes guidance to make this a target of refurbishment wherever possible. In some cases this might mean the provision of renewable sources of energy such as solar water heating something which is completely absent from the current standard.
3.0
3.1 National Indicator 158 should be amended to make specific reference to non decent homes in the private sector analogous to the targets set in the former Public Service Agreement (PSA) 7.
3.2 A Housing Green Paper should be brought forward as soon as possible to implement the recommendations of the Rugg Review into the private rented sector.
3.3 The Thermal Comfort element of the Decent Homes standard should be reviewed to bring it more into line with the Governments targets for eradicating fuel poverty and reducing CO2 emissions.
September 2009
[1] English House Condition Survey 2006 Annual Report, Communities and Local Government [2] English House Condition Survey 2007 Headline Report, Communities and Local Government [3] Sandwell MBC Private Sector Housing Stock Condition Survey 2009 [4] ODPM Circular 05/2003 Housing Renewal [5] Defined as being in receipt of at least one of the principle means tested or disability related benefits [6] Good Housing Leads To Good Health: A toolkit for environmental health practitioners, BRE 2008 [7] Environmental Health News 24th August 2009 [8] A Decent Home: Definition and guidance for implementation June 2006 update, CLG |