Memorandum from The Hyde Group (BDH 24)

 

 

 

1.0 Introduction and Summary

 

1.1 The Hyde Group (Hyde) is one of the largest housing associations in the county. We own or manage more than 40,000 properties, allowing more than 120,000 people to make their home with Hyde.

 

1.2 The following is a summary of Hyde's response:

 

· Any new decent homes standard should focus on the energy efficiency of homes. This should be measured through the SAP ratings of the property.

 

· Any new standard will need to be sufficiently funded by Government with a realistic timescale for completion. It is unlikely that all the funding streams used to complete Decent Homes works will be available to a new standard.

 

· A new standard should not be too onerous on landlords, and be able to be easily included into existing asset management strategies.

 

· A new standard should consider the estates and common areas surrounding homes. However, defining a specific standard for this may prove difficult, and opinions of local residents should always be taken into account. Redevelopment should be available as an option alongside further investment.

 

· The behaviour of society must be taken into consideration when trying to become more energy efficient and reduce carbon emissions. Any energy efficiency target must take this into consideration, with funding made available to educate residents on how any new technologies can be used most effectively.

 

 

2.0 What lessons can be learned from the Decent Homes Programme?

 

2.1 The Decent Homes Programme was successful in improving the standards of social homes. The Programme had clear, achievable targets on a realistic timescale. It was well backed by financial resources, giving landlords means from which to deliver the aims of the Programme. However, responsible social landlords would have undertaken much of this work anyway and that requiring them to accelerate often substantial repairs/improvements to meet the imposed deadline may not always have resulted in the most cost effective approach.

 

2.2 A whole supply chain developed capacity to deliver the Programme, providing employment for thousands of people. A number of maintenance contractors transformed their businesses on the back of the Programme, forming a mini-economy with suppliers of new kitchens, bathrooms and windows.

 

2.3 Hyde, like many social landlords, ensured that a local labour clause was included in delivery contracts. This provided much needed employment to some of the most deprived areas of the country, helping to improve the economic and social well being of areas alongside the physical elements.

 

2.4 One of the great successes of the Decent Homes Programme has been the variety of ways in which the aims have been achieved. A variety of delivery options have seen the public, private and voluntary sectors working together to achieve the stated goals. Of particular success has been the ability of housing associations to use private investment to improve social homes.

 

2.5 Conversely, the application of a Decent Home Standard to the private sector has been less successful. A shortage of available funding and weak legislative powers meant that there was a lack of imperative to make the necessary improvements. If new minimum standard were to be introduced to the private sector, greater incentives would be needed to ensure the homes were improved.

 

2.6 The Decent Homes Standard focussed on the internal aspect of homes, paying little regard to the design, construction or materials used in their development. In some instances, Decent Homes works were completed in homes that were no longer fit for purpose, ahead of alternative strategies such as demolition and rebuild. Any new decent standard should ensure that long term investments are not made into homes where other options for their future may be more appropriate.

 

2.7 A new minimum standard should be based on a more straight-forward scoring system that recognises different stock has different potential for improvement. Assessment criterion should be less subjective (reasonable) and perhaps not allow landlords to trade off one facility/component against the other, as with criterion B and C of the current Decent Homes programme.  With this in mind it is very likely there are numerous discrepancies in landlord reporting with many adopting a pragmatic interpretation of the guidance, particularly with regard to tenant refusals, void dwellings and those marked for demolition.

 

3.0 How should the back log of Decent Homes works be addressed?

 

3.1 Hyde does not have a backlog and we are confident that all of our homes will meet the standard by the end of 2010. However for those Local Authorities and ALMOs who will miss the target, the backlog could be addressed in a number of ways. The review of council housing finance through the Housing Revenue Account system may go some way to ensuring that local authorities can meet their decent homes targets. However, it may take some time to achieve the targets, and a new timescale would need to be agreed with each local authority.

 

3.2 Indeed, given that the council housing finance review may take some time, other options may need to be pursued. One option could be to transfer non-decent local authority or ALMO homes to a housing association with a proven track record of delivery. The association would then be able to raise the private finance to complete the works in a shorter timescale.

 

 

4.0 Should a new minimum standard include environmental standards, fuel poverty and the estate?

 

4.1 "Environmental standards" could mean a very wide range of measures. There is no widely used and accepted means of measuring environmental performance, with the BRE's EcoHomes XB being one of the only schemes available, although it has some deficiencies and is not in widespread use.

 

4.2 The concept of "fuel poverty" would present a number of practical difficulties if it were to be turned into a target. The amount of information required not just on buildings but also on resident's incomes could make this extremely complex.

 

4.3 We propose that any new standard should be focussed on energy efficiency, using SAP ratings. Following the introduction in October 2008 of mandatory Energy Performance Certificates, supply chains have been developed and an increasing amount of data accumulated.

 

4.4 In order to achieve greater energy efficiency and reduce carbon emissions, society must change behaviours and attitudes towards the consumption of fuel and energy. As a landlord, Hyde are in a unique position to help our residents change behaviours towards energy use, and urge the Government to investigate how funding could be targeted to achieve this aim.

 

4.5 Please note our comment at 2.6 above, based on our thoughts that some Decent Homes works were made to homes where redevelopment may have been a more appropriate option. However we do not believe that it is practical to attempt to define in a mandatory Standard what constitutes an acceptable place to live. Ultimately, only residents themselves can judge this. What is important is that mechanisms are put in place through which residents are able to propose demolition and redevelopment as options and for there to be funding mechanisms to achieve this if this is their choice.

 

4.6 The standard of the estate / common areas has a co-relationship with the level of an area's socio-economic sustainability. It can affect long and short term demand and reputation of an area, making it less attractive as a place to live, resulting in people moving out or being trapped in their homes, and an increase in the fear of crime, actual crime and general sense of well being. It is therefore very important that common areas are secure and maintained to a high standard at all times, and that measures are in place to act quickly to return an area to a high standard should it become victim of vandalism. This approach has been proven to work in many areas, and though it can prove expensive initially, as an investment, it contributes significantly to longer term sustainability, reducing overall costs over time

 

4.7 When developing a standard for energy efficiency, the age of the properties needs to be considered. The structures of many Victorian and Edwardian homes, with solid walls and suspended timber floors, make it difficult to achieve a high energy efficiency rating without incurring excessive costs. Owner occupiers of such homes are generally willing and able to pay higher heating costs in order to have such period homes that they value in terms of location, size and character. However social housing residents are less able to pay these costs and social housing landlords have insufficient income to undertake the major works required. Sale of these homes into the private sector may be a better use of limited funding.

 

 

5.0 Do the management organisations need to change? Will they have sufficient funds?

 

5.1 The Decent Homes standard was achieved by providing access to a variety of funding streams. One option was to transfer Council stock over to a Registered Social Landlord (RSL) who could then raise the necessary private finance to complete the works. Much of this stock will now be geared to such an extent that raising further finance to complete new works may be problematic. Therefore, extra funding will need to be given to any new standard to ensure that it is achieved in a timely fashion.

 

5.2 Hyde, along with all RSLs, has a robust strategic approach in place to ensure that all its properties are maintained to an acceptable standard. Incorporating a new minimum standard into this strategy would be relatively simple, so long as the standard is not too onerous.

 

6.0 What are the implications for decent housing standards of the Government's proposal to move to a devolved system of council housing finance?

 

6.1 The review of the Housing Revenue Account will allow local authorities to greatly improve their asset management. Councils will have more ability to invest in their stock for the long term, and may improve the longevity of any new decent homes standard.

 

 

7.0 How should the Decent Homes target for private sector homes occupied by vulnerable people be taken forward?

 

7.1 If private sector landlords or homeowners are having difficulties in bringing their properties up to Decent Homes standard, there may be an opportunity to transfer these properties to an RSL or local authority to complete the works.

 

 

8.0 Are adequate arrangements in place for the future regulation of minimum acceptable housing standards?

 

8.1 There is a sufficient regulatory regime in place for any future minimum housing standard in the social housing sector. The Tenants Services Authority (TSA), and its predecessor the Housing Corporation, have been successful in monitoring the number of homes still awaiting Decent Homes works.

 

8.2 Further consideration is needed as to how a new minimum standard would be regulated in the private sector.

 

 

9.0 Are there local examples of innovative best practice with wider post-2010 applicability?

 

9.1 Hyde has a number of innovative projects under development which may have post-2010 applicability. We would be happy to share

 

9.2 Our Retrofit and Replicate 2 project on the Progress estate in Greenwich has just secured Government funding to develop its designs. Our designs are for 2 properties, built c.1915, at the tail end of Garden City movement. The properties are in a Conservation Area since 1970s and also have further Article 4 directive restrictions. One property will be void, and one tenanted, to highlight differences in what can be achieved between the two types of properties.

 

9.3 Our Beyond Decent Homes pilot project is still in an early planning stage. The project's main aim is to achieve a reduction of carbon emissions across a housing estate through improvements to the building fabric and working with residents to improve behaviours. We intend to focus improvement works on a small block of flats (15-20 units) which has had Decent Homes works. The intention is to consider the practicalities of how to upgrade properties without removing the Decent Homes improvements. We plan to have a resident engagement strategy for the whole estate, ensuring that tenants have as much information as possible on how to reduce their carbon emissions. We will work with residents to encourage lifestyle changes, and hope that not only will they see a reduction in carbon emissions, but also a reduction in their fuel bills.

 

September 2009