UNCORRECTED TRANSCRIPT OF ORAL EVIDENCE To be published as HC 1054-iiiHouse of COMMONSMINUTES OF EVIDENCETAKEN BEFORECOMMUNITIES AND LOCAL GOVERNMENT COMMITTEE
Beyond Decent Homes
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Transcribed by the Official Shorthand Writers to the Houses of Parliament: W B Gurney & Sons LLP, Hope House, Telephone Number: 020 7233 1935
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Oral Evidence
Taken before the Communities and Local Government Committee
on
Members present
Dr Phyllis Starkey, in the Chair
Sir Paul Beresford
John Cummings
Anne Main
Alison Seabeck
Mr Andy Slaughter
________________
Witnesses: Ms Sue Adams, Director, Care and Repair, Mr Joe Oldman, Senior Policy Adviser for Housing, Age Concern/Help the Aged, and Mr Steve Malone, Director, Foundations, gave evidence.
Q167 Chair: Good morning. Can I start the questioning off? If you agree with whatever the first witness has said, do not feel obliged to say it again; that way we will obviously cover the greatest amount of ground. Can I start off by asking you how successful you think the Decent Homes programme has been overall and then, specifically, how successful you think it has been in relation to the private sector?
Mr Malone: We think that the Decent Homes programme has been hugely successful in the social rented sector predominantly around the fact that there are targets focused on the priority and level of funding. We have to say, however, that we feel it has had limited impact in the private sector; there has been no noticeable change in stock conditions shown, by CLG statistics - there are still considered to be around 1.23 million vulnerable people in owner-occupied and private rented, which is about 39% of properties. We feel that there is a likelihood of this figure increasing with deteriorating economic conditions and the increasing levels of extreme vulnerability (so issues around pensions, savings equity values in homes, unemployment and demographic implications), and we feel that the primary reasons for the lack of impact include the lack of dedicated funding - some examples are around private sector renewal funding shift of £75 million - the lack of targets in a non-mandatory regime, a lack of prioritisation driven by a lack of targets, and consideration of the broader implications around health and social care costs.
Q168 Chair: In expanding on that, can you address whether you think it is down to specific difficulties of the private sector that are to do with non-delivery?
Mr Oldman: I think there is a specific issue around the private rented sector. Obviously, in terms of standards, that is the most problematic sector, but there have been particular difficulties (and I think it was raised in relation to Supporting People) that older, private tenants have had particular difficulty in terms of accessing grants for repairs and adaptations. I think we are hoping that the current review of the private rented sector, through the Rugg Review, will actually look at conditions within the sector and their impact on older people.
Q169 Chair: Can you expand on the difficulty? Mr Oldman, you alluded to the difficulties for older private sector tenants in gaining access to grants. Can you briefly explain why?
Mr Oldman: I think there has always been an issue with regulating private tenants and the whole difficulty about having improvements carried out, and the fear of landlords trying to gain vacant possession. That has always been a fear, particularly for vulnerable, older people. So there has always been that kind of barrier in terms of the legal framework which has made it difficult, but, also, in terms of older people, because it is such a diverse sector, the whole problem of identifying older people and then actually making contact with the relevant services.
Ms Adams: Just to add. We have looked at the data in a great deal of detail from the introduction of the Decent Homes standard in 1996, and it started out with pretty large-scale investment, so social rented housing was a very coherent programme of mass investment, and a huge impetus and a very high profile target as well. So it got off to a very strong start. Actually, even back in 1996, for the private sector it did have a target, at that point, which was originally given equal weight to the 2010 in the non-decent social rented. At that stage, again, there was a grant system that was relatively accessible to people, and quite a lot of local support. Then we have seen that, gradually, that has tailed off. When you read the various aspirational documents of the Department, there is quite a lot of wishful thinking that you can reduce any investment in private sector housing and equity release and the private market will step in and fill the gap, and I do not think we have seen much evidence that that wishful thinking has actually happened in reality, particularly amongst the older old. So I think that is possibly one of the reasons for the tailing off.
Q170 Chair: I am sorry - particularly amongst the ----?
Ms Adams: Older old. The over-75s.
Q171 Anne Main: On the older old, I would be grateful if you could qualify what you mean by "older old" when we are talking about this. Should any priority be given to improve the decency of old people's housing over and above other groups? I do not know if you are going to split it down into "old" and "older old" or just "older". If you could be specific.
Ms Adams: I think there is a case to be made for prioritising action in older people's homes.
Q172 Anne Main: Can you give a category of old?
Ms Adams: Okay. Just looking straightforwardly at the evidence, older people over retirement age in private sector housing are more likely to be living in non-decent homes, but then that really starts to escalate when you hit over-75 and then over-85 - each of those deciles - which is all we have to go on, in terms of social policy. There is a step change at each level. I look at why should Decent Homes be addressing the older old - the over-75s, the over-85s? My strongest argument is that we have a health and social care policy and a policy around ageing and older people that says: "Enable independence for longer; enable older people to live in their own homes for longer, have preventative activities in the home that reduce accidents, reduce falls and make people healthier", but we do not seem to have a private sector housing driver that targets resources at the people in the worst housing at that end. So the argument, for me, that any social interventions are on private sector housing, targeted at those who have preventative health and social care needs or reduced health and social care needs, to me, is a strong enough argument. On top of that argument, when you analyse people's incomes and savings, and who is in the worst housing, it is single older women who see a big drop in income; for people over-75 and over-85 you get a massive drop off in their savings and, of course, they are less able to actually do the things in the house themselves.
Q173 Anne Main: Are you arguing, then, just doing the various deciles that you have just described, and even whether you are male or female, for prioritisation within a priority category?
Ms Adams: I am arguing for prioritisation on basic health and social care benefit, and I think there are models where locally people are - local authorities ----
Q174 Anne Main: You can have a fantastically fit 82-year old, like my father-in-law, and a more fragile 65-year-old. How are you going to do it? You are not going to do it just on age then?
Ms Adams: No, you can do it on health. I am saying that when you look at where people live, on statistical averages, then you can make statements that they are more likely to be in poor housing over a certain age group. If you refine that further and say: "How would you implement that locally?" it seems to me the good examples we have come across are where there are good health and social care needs.
Q175 Anne Main: You have just argued against yourself about prioritising for the older old and then actually saying that you should be looking at it as a package. I am trying to get from you, do you really believe it should be prioritised on age (because you specifically did say that) or actually, no, not age?
Ms Adams: If you want a very simplistic system which has age cut-offs, there are benefits to being over that. If you want to have a subtler system that is locally managed, then you would tag it to joint health and social care assessment. I think I am giving you two options: a very simplistic system which has age levels, and age bars, and a more sophisticated system which will tackle health inequalities and age inequalities, which would have a more targeted, local focus, where it is linked to health and social care. There are models where people are doing that.
Q176 Chair: Just briefly, would you go along with that, or do you think there ought to be a different strategy?
Mr Malone: I think I would agree with what Sue said there, the emphasis not being a homogenous group.
Q177 Chair: The same with you, Mr Oldman?
Mr Oldman: Yes, I agree with that and, obviously, the health and safety rating system is an assessment looking at the individual context of the conditions.
Chair: Indeed, we are just coming to that, I think.
Q178 John Cummings: Why do you think it is that local authorities are not using their statutory powers to improve private housing? Do you have any examples of local authorities which are working effectively in that area?
Mr Malone: I think there are a variety of reasons why local authorities are not using their statutory powers. Where it is not working well it is issues around effective targeting, as we have just discussed there; it is issues around joined up working and the pooling of funds between adult social care and health and housing, and there seems to be, because of the lack of a mandatory nature to the scheme, a lack of emphasis around enforcement in that respect, and, quite often, capacity within local authorities to achieve those levels of enforcement.
Q179 John Cummings: Are you saying it is ineptitude rather than any decision?
Mr Malone: No, I do not think I am, to be honest with you; I think sometimes there are challenges within the local authority in terms of structure and the way local authorities are working, and the priorities are different within local areas. So I do not think it is ineptitude; I think it is around the fact that there are no national targets.
Q180 John Cummings: A lack of political will?
Mr Malone: I think there is a lack of
focus on that area, yes. Where it works
well there is clarity and uniformity of the issue and, as I say, health care
and housing are all actively involved in private sector renewal. I think the funding that is available for a
variety of schemes, from small, emergency repairs, works well and are not a
burden in the process with high administration costs; I think there is the ability
to bring in other schemes as well, such as Warm Front, DFGs and what-have-you,
to enable larger repairs. Some good
examples are the likes of
Q181 Chair: In Rochdale, do they have a lot of private sector housing which is of poor quality?
Mr Malone: Yes.
Q182 Chair: They have. Including private rented?
Mr Malone: Yes, they have private rented as well, and also it is quite a good case study area because they have got quite a mixture of rural versus urban as well.
Q183 John Cummings: Do you have a specific template for identifying non-decent private homes occupied by vulnerable people?
Mr Malone: I do not know whether my colleagues can help out here, I think the HHSRS is the core template for identifying ----
Q184 John Cummings: Is it a national template or is it one which you have devised yourselves?
Mr Malone: The overall HHSRS is a national template.
Q185 Chair: I think the problem that we have had from other witnesses is that HHSRS is a very low standard, even lower than the Decent Homes standard, but it has been said to us that many local authorities are not using the undoubted power they have under HHSRS to enforce standards. Do you have examples of that? Any of you?
Ms Adams: Where they are not?
Q186 Chair: Yes.
Ms Adams: I would say most are not. There are not many who are systematically going out there and looking for homes that fail; where they are looking for category one hazards, because it is only category one hazards where the authority is supposed to do something. The flaw in the system is that what they are meant to do is not very clearly defined. They are not legally obliged to remedy the situation. In informing the householder that they have got a category one hazard, in law, you can probably legally argue, they have acted. Why are they not doing it, is really very complicated. I see it is a combination of political priority and political will, local funding priorities and national funding priorities, and there has been quite a strong steer from Communities and Local Government that authorities really should be moving towards the equity release model and a very strong steer that the priority for expenditure on housing is new-build housing with very specific targets for the numbers of new units. Since you have not got a target of equal strength for addressing disrepair in the private sector as you have with building new homes or addressing disrepair in the social rented sector, it is almost inevitable that those will take priority when finances are squeezed.
Q187 Chair: Can I just take you up on this steer about new build? Most councils will be delivering most new build through agreements with developers, not direct council funding. I do not see how that is diverting their funding from dealing with Decent Homes. It may be diverting their attention but I do not see how it is diverting funding from Decent Homes.
Ms Adams: We have looked at the distribution of funding from the Regional Housing Pot, and there has been a growing shift of Regional Housing Pot money out of private sector renewal and into new-build subsidy, because the money from the Regional Housing Pot is sliced up and given out to developers in the social rented sector as well. Last year we actually saw a 25% slicing-off of the notional budget from CLG to the Regional Housing Pot to achieve the Government's higher targets on new build.
Q188 Sir Paul Beresford: So it is not the local authority's fault?
Ms Adams: It is not just the local authority's fault; it is a combination of factors. If you are told you have to do something you will do the thing you absolutely have to do rather than the thing that has been indicated as a lower priority. So, for example, with Local Area Agreements, you have a national indicator around an improvement of the social rented stock. There is no national indicator that can be even selected from the Local Area Agreements which would drive private sector housing stock improvement. We sit there trying to weave it into other categories, but there is not an NI related to private rented improvement.
Q189 Chair: I think we are getting into the question which was going to be asked next, which is about what action needs to be taken at a national level to ensure improvement on the non-decent private housing? Maybe one of the others can suggest what you think the key things are that can be done at a national level to ensure more of an emphasis on non-decent private housing.
Mr Malone: I can kick that off, I think, and perhaps pass over to my colleagues. I think there is absolutely a requirement for targets in this area, in the same way that they are set in social housing. I think that the standards should be raised to enable the level of decency to be appropriate. I think there should be, as Sue said a moment ago, that linked in with the national indicators so that the authorities are bound to try and achieve certain targets within the local area.
Mr Oldman: I think that much more investment needs to go into services for older, private owners in terms of home improvement agencies, in terms of handy-person services, but, also, much greater co-ordination of the range of different services from those that are dealing with things like minor repairs, to fire safety, to home security. At the moment, I think there is a kind of lack of co-ordination and linkage between the different services that are available, but, also, I think, in terms of people who actually use our handy-person service, for people I have spoken to there is also an issue about the basis on which people engage with services. A lot of people who use our services say they are unwilling to engage with statutory services because they have a concern about means testing and about financial intrusion. So there is an issue about how you actually engage with older people in the first place.
Q190 Chair: Can I ask a fundamental question? Do you think that, going forward, the best way is to have a very clear Decent Homes standard for the private sector and then national targets, or do you think there needs to be a bit more of a re-think about all the other sources of funding that are going into related matters, such as fuel poverty and fuel efficiency, and building a kind of target that incorporates all of that lot and encourages all the different funding streams to be brought together?
Mr Malone: I think that is an "and" rather than an "or". Yes, there should be national targets, but there should be far more co-ordination and responsibility for the shared funding pots as well.
Q191 Chair: What are the extra things that need to be brought into the target that will then drive that?
Mr Oldman: I think one of the additional things that needs to be looked at is how this is operating in relation to initiatives like Lifetime Homes standards, like the Code for Sustainable Homes, like Part M of the Building Regulations - all these things that relate to new build. There do not seem to be parallel standards in relation to the Decent Homes initiative and so I think there needs to be some kind of balance between the existing stock and the excellent initiatives that are seen around new build.
Q192 Alison Seabeck: Have you done any assessment of exactly how much this would cost the taxpayer, if we were to meet the sort of targets that, ideally, you would like to see hit across the private sector stock?
Mr Oldman: I know that both the Audit Commission and Capgemini, in terms of looking at the kind of services that have been supported under Supporting People, have actually saved a lot of money, so I think part of the argument is around prevention; that by doing very basic, simple things you can actually prevent people ending up in hospital or needing help.
Q193 Alison Seabeck: So with interests over all parties across Parliament in ensuring people will stay for longer in their own homes, if that is what they desire, there is no logic in keeping them in their own homes if their own home is damp and cold (despite the fact that it is, obviously, their home), and there will ultimately be knock-on costs to health, I guess, is what you are saying. However, there is that evidence from the Audit Commission?
Mr Oldman: Yes, the issues around things like people having falls and accidents because there is not adequate lighting or because a piece of carpet has not been - very basic, simple things. There are clear savings from some of these actions.
Ms Adams: Can I come back on that? I think you can come up with some amazingly scary figures. If you said tomorrow: "How much would it cost to make every home in the country decent?" then no one is going to do that. The English House Condition Survey data from the Department really has a lot of very detailed data in there, and you could cost out a phased programme of targeted interventions at particular age groups for particular aspects of the standard, if you really wanted to. What we have to remember is we are currently spending about an eighth of what we were spending back in 1983 on private sector housing. In the same time we have seen a complete revolution. So in terms of your Committee brief and looking at the future Decent Homes standard, I think you are right that there has to be a more holistic look because you have to look at a target for this in connection with other targets. If there are no targets and it is a free-for-all for everybody then this might stand or fall, but if other areas are targeted and they are quite hard targets that authorities have to meet, and this is not, then anything that is not loses out. I think there is a combination of what is the political view about what we do for low-income homeowners, when we have seen a total social revolution in 30 years away from social rented housing and into low-income owner-occupation; we have gone from half the people renting to three-quarters of older people who are homeowners now, and we have got more low income people in home ownership than we have low-income tenants. Yet any structure for supporting that has not really caught up. So there is the big picture, which I think any of us would be very happy to work with any government on, of how do we then target what resources there are, or you make a very sweeping political decision and say: "We don't do anything for low-income homeowners"? Or we just completely throw it out to localities. I think, perhaps, a lot of us would argue, for coherency sake, we would like to see national targets that are linked to health and social care policy, and we would like to see this whole area a high priority for Communities and Local Government.
Q194 Anne Main: I think you have, at the end, just about caught what I was going to ask you. You say you want to see national targets for it. I was going to ask the flip of that. You said you were looking to find ways of weaving into the rules that you already have ways of accessing funding or ways of doing this. Would the opposite of national targets be greater discretion and flexibility to use money how best it will fit or to direct funding to how best it will fit?
Ms Adams: Then you would have to do it completely across the board, because as long as you have got any other mandatory functions and targets that authorities absolutely have to do ----
Q195 Anne Main: That is what I am saying. Since you have already got a target for the 30% (I think you just said yourself was the number of people now as opposed to how it used to be - the greater proportion are in the private sector), would you like to have the targets scrapped, since the targets are only aimed at a small number of people, and be allowed to just get on with it yourself? Politically, do you say that would be a better way of going forward?
Ms Adams: I suppose I am concerned that local authorities would not take on board health and social care impacts; they might take the social care because they pay for it, but would they take the health impact is what I would like to know.
Q196 Anne Main: I do not know: I am asking your views - and the rest of the panel. You suggested everyone having a target. Of course, an opposite could be true - nobody has a target. I would quite like to hear the panel's views on that.
Mr Malone: In terms of the funding element and whether people would take responsibility for social care and health, I think where it is evidenced (where that works well in local authorities) it clearly does work well, and where there is an integrated pooling of that revenue and services are very much directed towards the local community it works exceptionally well. When those funding pots are silo-ed and isolated is where the grey areas occur.
Q197 Anne Main: So are we getting rid of the silos or creating more silos?
Mr Malone: With a national target?
Q198 Anne Main: Yes.
Mr Malone: I think the national target is around providing the emphasis and focus for authorities to work towards.
Q199 Chair: I think we still have not quite got to what this national target would be. Would it be the percentage of elderly people in non-decent private homes - that is reducing that percentage? Is that what it would be, say? Is that the sort of target you would want?
Mr Malone: Vulnerable groups - probably broader than just elderly.
Q200 Chair: Okay, but is that the sort of target you would be thinking of - just that broad target?
Mr Malone: I think so.
Mr Oldman: Yes.
Ms Adams: The numbers could be locally negotiated. If you take the picture, we have PSA targets, do we not? We have big, global PSA targets which give us a strong indication of government's intention and vision. So there has to be that political steer and that political leadership. How that is then interpreted and translated locally and how the money is spent, as long as it contributes to that, should be locally determined. So if you have a national vision that is actually saying politically: "We think there is some role for the state because of either ideals ----
Q201 Chair: That is not a target. Targets are much more specific.
Ms Adams: Then you say that we want to see the national government target, PSA target, (as it used to be but it was dropped) that we will reduce the number of vulnerable groups in private rented housing to 70%.
Q202 Chair: You would like that target to be reinstated, essentially, as a national target, because otherwise you do not think the majority of councils are going to give it much emphasis?
Ms Adams: No. From experience. It is what has happened - based on what has actually happened.
Q203 Chair: Can we move on to this funding bit, then, and let us try and be specific. I am not quite clear whether you are suggesting that if you reinstated the target for vulnerable people in non-decent homes (that is reducing the numbers, obviously) then the Disabled Facilities Grant could go, and just be tipped into the pot, say.
Ms Adams: Are you saying we should just merge it?
Q204 Chair: I am asking; I am not saying. I am trying to test what you are actually suggesting. If you want local authorities to have freedom to do it, then an obvious thing to do would be to say they could just tip the DFG money into a generalised pot; some of it might be used for Disabled Facilities Grant for elderly people and some of it might not; it might just be rolled into a Decent Homes programme.
Ms Adams: There is an element there of mixing up two functions. The Disabled Facilities Grant is very specific for adaptations, and that adaptation might not contribute anything to that house achieving the Decent Homes standard.
Mr Malone: I think what there is an argument for is the co-ordination of services there, so that any duplication or inefficiency is driven out of the system. So, for example, if you are assessing a home for an adaptation under DFG then that home should be assessed for its decency and the wellbeing of the individual.
Q205 Sir Paul Beresford: Local authorities complain that there are too many targets, there are too many people looking over their shoulder from central government and too many pots. Could they be reduced?
Ms Adams: They have been reduced massively.
Q206 Sir Paul Beresford: Could they be reduced more, and still achieve some of the things we want?
Ms Adams: The local authorities can choose; they have only got to choose 35 targets for national indicators.
Q207 Sir Paul Beresford: That is a horrific figure.
Ms Adams: It was reduced to that from 180.
Q208 Sir Paul Beresford: I know, but 180 was outrageous, and 35 is horrific. Could it be reduced more?
Ms Adams: That 35 is everything, across the whole area, so there might be no housing ones chosen at all.
Q209 Sir Paul Beresford: What about the various pots? The Chairman is asking if some of the pots could be put together.
Ms Adams: They have, in effect, because the Disabled Facilities Grant was not going into the Regional Housing Pot anyway, so the boundaries have been taken off the Disabled Facilities Grant - with, actually, pretty dire consequences in some places. If it was bad before, in some places it has got even worse now because you keep taking away that impetus. It is not always as simplistic as targets; the Disabled Facilities Grant is an interesting example where a local authority is obliged to match-fund, and once that has been taken away we are seeing authorities not putting anything into that pot at all because they do not have to. So the expenditure goes where it has to.
Q210 Sir Paul Beresford: Or they do not have the money.
Ms Adams: So we are seeing DFG budgets reduced by 60%, because the only thing that is going into the pot is the national allocation. I suppose I get slightly alarmed when I see any controls or any labels taken off at all.
Q211 Chair: I am feeling there is a huge tension between what you are saying. On the one hand you seem to be saying that local authorities should be given flexibility. On the other hand ----
Ms Adams: On how to deliver.
Q212 Chair: But when they are given flexibility you are not very happy with the decisions they take.
Ms Adams: Because the flexibilities are limited. Whilst they still have to do something - what I am trying to explain is: if you have to do some things you do the things that you absolutely have to do, where the money is tight.
Q213 Chair: I understand that, but there is no reason for a council to decide that DFG is such a low priority that they reduce the funding on it.
Ms Adams: There is if there are other areas of expenditure, such as child protection, where they have to deliver.
Q214 Chair: If there was an electorate (?), it, presumably, would be a bit displeased about the fact that people die before they get DFG.
Ms Adams: It is not a very political high priority in most places, compared to, say, child protection. Nobody is going to be hauled over the coals and sacked for non-delivery of a DFG, whereas they will be in the headlines if there is a child protection case.
Q215 Chair: Okay. Can we just go backwards to the issue about what is currently in the Decent Homes standard and what might be in the Decent Homes standard beyond 2010? Do you have any views about what should be added to the Decent Homes standard?
Mr Oldman: I found it quite interesting looking at a previous Committee report in 2004 that was actually looking at the missed opportunity to include accessible housing within the definition, not so much as a definition within Decent Homes but actually saying that in any renovation that is carried out we should ensure that materials - for example, doors, windows and taps and fittings - comply with basic accessibility standards. I am surprised that that has not been incorporated or considered further.
Q216 Chair: So you would want that to be incorporated?
Mr Oldman: It just seems to me that it is not something that would be costly but it is the logical thing of saying: "If we are going to renovate housing we need to make sure it complies with accessibility standards", in the same way as we have with new build and Lifetime Homes standards.
Chair: Anne, did you want to ask about the money and where it is coming from?
Q217 Anne Main: Yes, I certainly do because, Ms Adams, you actually referred to this, about the amount of state expenditure on private sector stock falling from, I have figures of, £1,040 million in 1983/84 to £266 million in 2006/07, and I am sure that is the figure you were referring to, so, given that you felt that was not satisfactory, what is your understanding of the likely levels of future public funding for the improvement of non-decent private sector housing? What would you think was reasonable?
Ms Adams: Well, that is two questions of the amount which I think was reasonable versus what is likely to be. I think what is likely to be is an incredible squeeze on every area of public expenditure, as we know, but the reality is that the country was not awash with money in the late 1970s and early 1980s, but a political decision was taken that that was a higher area of priority for spending, so in future there is a straightforward argument to be made by the different departments about what is the priority for expenditure. What it probably means, if we drop all monies for any work on private sector housing, is there will be a knock-on effect on an ageing population which becomes increasingly ill.
Q218 Anne Main: So you can actually point out that it is not just the funding, but it is the shift in priority between things?
Ms Adams: It is a combination of the two things.
Q219 Anne Main: So you believe that, even if it is not just more money, we are talking about redistribution here really, are we not, so, if you put it into one pot, you take it from another pot because none of us believes there is masses of money sitting unused, so are you saying then that the priority has got to be set with a different emphasis back to what it was or similar to what it was?
Ms Adams: Well, we are not going to go back to what it was, but I would certainly like to see a small increase in the recovery from last year's 25 per cent reduction, just as a minimum.
Q220 Chair: And, if it does not come from Government, what alternative sources are there?
Mr Malone: I think you have a silver bullet that has been used in past, which is the equity models for that, although that marketplace has not been taken up in its entirety and I think some of the groups that we are talking about are probably the least likely to access that model, so we have kind of lender solutions diverging to the borrower's resistance towards that, so there is a policy gap there. I still think that, although equity is a model, it requires public support and investment.
Q221 Anne Main: If I can just come back to you on the equity, in 1997 there were these SAM mortgages, which you are probably aware of, shared appreciation mortgages, where people did release equity, exactly as you are describing, and it has had a very poor press. Indeed, these SAMs victims are going to the European Court because the equity has disappeared in their homes, so is it because the equity model is not right, the equity model release is not right, rather than just that people do not want to use it because there have been some horrific cases in the late 1990s?
Mr Malone: Yes, and I think that is what we need to avoid. Is the equity model right? I do not think it is at the moment. I think that the reliance on private sector involvement in the equity model fundamentally flaws that approach. I think there is a requirement for that initial investment through public sources, and I think there are some cultural and economic issues that are involved in the equity model as well, and the complexity of the products, so around the whole equity model and particularly for the cohort of people we are talking about, there needs to be that abundance of advice, guidance and support to manage an individual through that process because it is incredibly complex.
Q222 Chair: I was thinking of an equity release model that involved the public sector effectively, so councils taking the property in return for funding the improvements.
Mr Malone: That is one model in terms of an appreciation-style model. There is a variety of models, but again an individual authority probably has not got the volume or the capacity to enable that to happen on a large enough scale to support the gap that there is, so it is about authorities combining their resources in that respect to create volume. I think what we have got at the moment is actually that the target groups, which equity models were directed at originally, are not being hit, and there is some anecdotal evidence from people like West Midlands Keystart that the individuals that the equity is being released to, although in a vulnerable capacity, are not probably the most vulnerable and are not the elderly.
Q223 Chair: Who are they then?
Mr Malone: They tend to be those at the lower income end of a working age.
Q224 Chair: So it is still individuals who would not be able to bring their houses up to standard?
Mr Malone: It is still appropriate individuals, but what I was meaning is that it is missing those hard-to-reach, vulnerable groups.
Q225 Chair: What about the private rented sector though because that model presumably does not work for that?
Mr Oldman: I think one of the things that the Rugg Review is looking at is how more older people can be supported and encouraged to move into the private rented sector, and I suppose one of the things that we are looking at is whether there could be a better relationship between landlords and older tenants by setting up perhaps specialist accommodation registers which then give landlords advice on things like grants and DFG. I think there are different ways of approaching it, but I suppose there is a debate around how appropriate the private rented sector is for older people at the moment, given that most forms of tenure tend to be insecure.
Chair: Thank you very much indeed.
Memoranda submitted by National Energy Action
and the Sustainable Housing Action Partnership
Examination of Witnesses
Witnesses: Mr Ron Campbell, Head of Policy and Information, National Energy Action; Professor Anne Power, former Commissioner, Sustainable Development Commission; and Mr John Sharpe, Director, Sustainable Housing Action Partnership, gave evidence.
Q226 Chair: Good morning. The same as before, obviously do not feel obliged to repeat things if the other witnesses have said it because we have got a fair number of questions to try and get through. Can I just start off then with the opening one as to why you think energy efficiency standards are so important to the Decent Homes Programme?
Mr Sharpe: I think that Decent Homes so far has created a very good framework on which to build and we must not throw it away. I think we saw yesterday, and you will see some of the case studies in our report, that social landlords are already seeking to enhance the Decent Homes Standard, so I think that it provides an excellent framework. It also shows, and again our report shows this, that it can help be instrumental in meeting government climate change targets, especially the low carbon transition plan targets, the reductions by 2030 and 2050, and then it actually mops up behind it things like health and well-being and fuel poverty. Listening to the previous witnesses, if that structure is then used, it can then start pulling together things like accessibility, so it can become an all-encompassing standard. Our key members are ALMOs, RSLs and stock-holding councils and the Government has actually created successful structures, so you have actually got in place structures which will work and we should enhance those, and the standard could be the structure and the framework within which all that happens.
Q227 Chair: Can you explain how that would also work within the private sector with both owner-occupiers and private landlords?
Mr Sharpe: The private sector is very
difficult to get at. There are various
things like landlord accreditation and so on, and trying to share best practice
is what we try and do. One specific
example, and again we have got some examples in the report, is where you can
take a complete housing area which has mixed ownership in it, and Family in
Somerfield, Birmingham have done this, Gould in East Riding have done it, and
you then use the social landlord to provide the structure, the economies of
scale, the specification for the work and then you build into that soft loans
and an ability for the private sector, and we have actually got some examples
in here that actually work. The snag is,
as we found when we listened to Gould when they came to our conference last
month and when you talk to Family in
Q228 Chair: In those examples, what was the proportion of housing in those areas that was under the direct control of those housing associations?
Mr Sharpe: In Somerfield there were 400
houses. I can get the figures, but I
have not got them with me. I could get
those from Family in
Q229 Chair: That would be extremely helpful.
Mr Sharpe: The other thing I should say is that Urban Living are involved in that, who are a pathfinder who are due to be out of existence in two years' time, and they have been an excellent catalyst as well, so those sorts of catalysts are quite helpful. I can get those figures for you.
Q230 Sir Paul Beresford: Much the same was done by many London councils in the 1980s, the housing action areas, doing whole streets and so forth, so it is not new and it worked then.
Mr Sharpe: Yes, and I think that there needs to be a cohesive joined-up approach to this stuff, so that is not the total answer, but it is one example that we have got.
Mr Campbell: NEA takes the view that energy efficiency is central to the Decent Homes Standard because the thermal comfort element of the Decent Homes Standard is the means by which the Government proposed to address fuel poverty and social housing. Consequently, I think it was argued at the time or certainly the position was put fairly forcefully that we did not think that the standard, as proposed, would actually achieve that objective, but we learned a little bit and we hoped to build on it, and I think our hope is that this is one of the things that can emerge from this kind of session, the need for an improved Decent Homes Standard. The Government's annual fuel poverty progress report was published last week and, on the Government's data, there are 4.6 million fuel-poor households in this country, so, far from progressing, we have regressed to the situation as it was in around 1996.
Q231 Chair: Is that a regression largely because of the increase in fuel prices rather than a deterioration in the housing stock?
Mr Campbell: Yes, in fairness, it is almost entirely a consequence of movements in energy prices, but there has not been a corresponding level of remedial intervention in the standard of the housing. There is a very strong correlation between poor energy efficiency standards and fuel poverty. The average SAP reading in a property occupied by a fuel-poor household is about 36 and the average across the whole country is some 50.
Q232 Chair: Can you just remind us what the SAP rating is that is part of the current Decent Homes Standard?
Mr Campbell: It is a means of quantifying -----
Q233 Chair: No, what the level is.
Professor Power: A SAP rating of 57 is the average for social housing.
Q234 Chair: No, that is not what the question was. What is the SAP level that is specified in the thermal efficiency standard for Decent Homes?
Mr Campbell: There is none.
Mr Sharpe: I do not think there is one. Well, my colleague thinks it is 35.
Mr Campbell: If I could explain that, SAP
35 is used by DCLG as a proxy for a category one hazard under the cold
conditions. There is not actually a SAP
standard set. Unlike
Q235 Chair: So there is a SAP rating in the Decent Homes Programme in Scotland and Northern Ireland?
Mr Campbell: Both the Scottish housing quality standard and the Welsh housing quality standard feature aspirational SAPs at the very least.
Q236 Chair: So what SAP level would you like there to be in a revamped and expanded Decent Homes Standard in order to start to deliver the sorts of benefits that Mr Sharpe was outlining?
Mr Campbell: The problem is the difference related to tenure here. If we are talking about social housing, then I think we can be more ambitious and more rigorous in terms of the demand for heating and insulation standards. The current debate centres on the approximate SAP reading that would be needed to fuel poverty-proof a property, and the technocrats tell me that that is approximately SAP 81 now. Not so many years ago the Government estimated that SAP 65 would achieve that objective of fuel poverty-proofing a property. As with so many other fuel poverty-related targets, movements in energy prices have completely undermined that.
Q237 Chair: You said that that would be realistic in social housing, but not the private sector. Is that because the private sector is so far away from it that it would be ----
Mr Campbell: It is a combination of things. It is because the social rented sector is of a rather higher standard. I think it is also easier for probably municipal landlords, or whatever the structure of the landlord is in the social rented sector, to carry out the kind of remedial works that would achieve that objective. I think it is much, much more difficult to do that across the whole of the private sector housing.
Professor Power: I would just like to add a little bit about the benefits of adding energy efficiency to social housing. The first is that you need ongoing investment, and the £10,000 average from the Decent Homes Programme was a fantastic start, but it did leave out an awful lot, including major energy efficiency measures, so, given that there will have to be follow-through investment, it makes perfect sense to add on energy efficiency, and for lots of the social housing stock that would actually be relatively easy. Although the SAP rating for social housing is much higher than the average, it is much higher than the 35 that was mentioned as the fuel poor average, it is a long way below 80 and it could reach 80 with an ambitious target. Also, the urgency is greater because of the huge concentration of low-income households and benefit-dependent households in the social rented sector. Finally, social housing can actually lead the way both in area renewal with big energy efficiency targets, but also in a kind of beacon approach to raising the profile of energy efficiency. For example, Radian Housing Association, in a couple of weeks' time, is holding a very big event down in Hampshire to showcase what they are doing in raising the energy efficiency of their social rented stock on a group basis, and we have already had a couple of other models, so I think the potential of social landlords both to maximise the individual fuel poverty value, the value of their actual stock and the neighbourhood and wider social impacts is pretty huge. I would also like to pick up on Paul Beresford's point about housing action areas. We do have a model for area action, targeting mixed tenure fuel-poor areas which will often include low-income owner-occupiers and very, very poor-quality private renting, and the social landlords there are probably already something of a beacon and it is these other sectors that are not doing so well, but that would require the levering of significant capital investments. You mentioned the different programmes, but I do not know whether the programmes, as currently constructed, would actually do that or whether it would be something more like the community energy-saving approach.
Chair: Can we leave the funding bit to one side for the minute.
Q238 John Cummings: Mr Sharpe, what has SHAP's research project actually shown about the feasibility of incorporating improved energy efficiency standards into future Decent Homes standards?
Mr Sharpe: What we did, and this is very relevant to the last discussion, is we set a minimum 42 per cent reduction from 1990 levels by 2016 which gave us a SAP rating of 75 by 2016 and an energy performance certificate of C. We then looked at an 80 per cent reduction, which is the low carbon transition absolute by 2050, and we thought we could get to that by 2025 which gives a SAP of 85, and that ties in very well with the NEA's evidence which was looking for 81, so they are the figures. We then costed out nine property archetypes and we come to figures, and the £10,000 is interesting, of between £15,000 and £32,000 and that includes terraces, hard-to-treat, semi-detached, high-rise and medium-rise and they are all in the report which I think you have seen. It is interesting that in actual fact we have divided it up into three five-year work packages, so there are some easy wins in the first work package, but also, very importantly, taking account of work that has already been done which is really important. Otherwise, if we try and impose a standard on top of Decent Homes, we are going to be duplicating work, so it has got to be a very flexible standard to take account of previous improvements, so that is what the work has been based on, SAP 75 by 2016 and SAP 85 by 2025, but flexible to property archetypes and previous work that has been done, so that is the structure of the report that we put together.
Q239 John Cummings: To Mr Campbell and Professor Power, what specific measures do you wish to see in the Decent Homes Standard, and do you think it is realistic to think that such standards can be achieved in the current funding climate?
Mr Campbell: I think that, from our point of view, the crucial first stage is that an actual standard be adopted because, as the thermal comfort element of the Decent Homes Standard is currently constituted, it is a measures-based approach, so it is either/or for mean insulation measures and there is a prescription about the minimum standard of the heating device. We do not think that that represents a proper standard. We think a proper standard should be some kind of objective and definitive statement of the quality that is required, in which case it should be a SAP rating. There is an argument clearly about how we go from the minimal and inadequate Decent Homes Standard to the gold standard, SAP 81/SAP 85 level, and what stages we pass through in order to get there. We would have been considerably happier had the Decent Homes Standard in the first instance simply constituted rigorous, conventional energy efficiency measures, so that would have been whatever insulation measures were technically feasible and whole-house heating using the most technically efficient heating system. In the short term, we would be happy to see these kinds of measures. We understand that this is only a short-term measure and that we will have to be much more ambitious and much more rigorous in the future in terms of the kind of kit that goes into these dwellings.
Professor Power: We have thought a lot about
this and it does seem that there are kind of two categories of measure, so hard
measures are the obvious ones, but they should be at maximum levels. For example, it was accepted in the last
Decent Homes that normal roofs were generally insulated, but they were not
insulated to a sufficient standard and they should go to the maximum
standard. Flat roofs often were not
insulated at all under the last programme because it was so expensive, so, if
the roofs were okay, they were left alone, and I do know of several cases where
that has happened. On wall insulation,
there is a huge controversy over it and I personally think that we should be
pushing much, much harder for external wall insulation. Where it has been done to council housing,
including houses, it has generally had a massively beneficial effect, not just
on the thermal warmth, but on the environmental aspect. There is an estate in
Q240 Chair: Were they solid walls?
Professor Power: They were concrete, not very well built and terribly poorly insulated, so they were not brick.
Q241 Chair: So no cavity wall then?
Professor Power: No. Where there is a cavity wall, obviously it is
pretty straightforward, but I think a lot of homes, particularly if they are
modern concrete, but also if they are older terraced, you have got a problem,
so
Q242 Chair: Too much of a fetish of not ----
Professor Power: Of not covering external walls, and I think personally that that is a mistake, but I know that other people definitely disagree. On the under floor issue, the vast, vast majority of people like carpets and other kinds of floor coverings, even sort of board-laid, so you do not actually have to dig up the whole floor in order to do under-floor insulation, so that is another thing which can be done much more easily if there were a ready introduction of under-carpet insulation instead of under-floor insulation, and then finally porches made a very big difference.
Q243 Mr Slaughter: Are you sure you are not making a fetish of cladding everything to the exclusion of build quality? We are coming on later to looking at going beyond the building itself, which I think the SDC has talked about, and looking at neighbourhoods rather than just the building itself. If you start by taking away the design features of a building, and a lot of people use this as an example, a lot of the build quality of the earlier social housing is to far higher standards ----
Professor Power: Sorry, but I personally would not press that point.
Q244 Chair: Sorry, which point?
Professor Power: I would not press clustered
external cladding over historic buildings, no way, but I would say that,
because of the historic building problem, we are actually applying that logic
to many properties that actually would be enhanced by cladding. Perhaps I could offer the German model, which
hits an 80 per cent energy saving on the properties it deals with, which has a
tea-cosy idea of buildings, so you keep tea warm by putting on a tea cosy, you
keep it very warm by putting on a very thick tea cosy and you keep it at a
completely even temperature by putting on a cladded tea cosy. There are posters all over
Q245 Mr Slaughter: How expensive is that?
Professor Power: Well, external cladding in
Q246 Mr Slaughter: My experience is that it is vastly expensive. I am not saying that is a reason for not doing it, but you may be right, there will be economies of scale if it happens more frequently, but I do not think it is quite as easy as that.
Professor Power: I am not suggesting it is
easy, but it is not as difficult as it is cracked up to be. The Liverpool Mutual Housing Association
could actually provide you with evidence of what they did on the Daneville
Estate which they funded, which the tenants are delighted with and which they
are managing to save large amounts of energy on the back of, so it has been
done. I actually worked in the
Q247 Chair: Perhaps we can just move on to the funding aspect, and I would remind people that we have obviously got your written evidence as well and that will be drawn on in our report, so you do not need to rehearse things necessarily which are in there, but, as I understand it, the existing Homes Allowance is £2 billion a year necessary to achieve the carbon emission targets. How do you think we can actually raise these sorts of levels of funding, given the likely squeeze on public expenditure in the future?
Mr Sharpe: I think that certainly our members welcome the basic tenets of the review in June for giving more flexibility. We think it is unrealistic to expect that all of this is going to be grant-funded, but we do think that the grant funding should underpin other means.
Q248 Chair: Are you talking about the grant funding in the social sector?
Mr Sharpe: From Decent Homes.
Q249 Chair: In the social sector?
Mr Sharpe: Yes. That could also be transferred for grants into the private sector. We have set out in here financing through engagement with utilities, which is already starting to happen of course with their obligations under CERT, we have looked at ESCOs and the energy service companies and the way in which that can actually become profit-making, and energy trading. One of the key things though is the flexibility about securing benefit from rent, and that is a topic that came up yesterday and it is a very thorny topic about sharing the benefit with the tenant. Then, there is the ability of taking the increase in land value without having to sell the land by putting it into some form of land trust. What we then think would happen is that the grant funding would underpin a succession which would almost be matched funding probably by a variety of these, and in the private sector that could then possibly be equity release, so it becomes a sandwich which builds itself up with the grant funding underpinning it. However, we then think that the really important thing is to have a standard, a key standard, which will hit targets. The problem we have at the moment is that most funding is predicated towards new technologies and what our research shows, which backs up exactly what Anne said, is to do the passive house, do the fabric first, concentrate on the fabric, concentrate on doing the easy bits first, and everyone can understand that and that is easy and that also has benefits to worklessness and so on, so, if we take that and we then put the funding into those simple, straightforward measures, it then becomes applicable, so the grant funding works within that and the standard that the people have to meet, we think, should be linked to the low carbon transition plan, so within that the standard then becomes the driver to be funded in these sequential ways.
Mr Campbell: There are two issues, I suppose, the current levels of funding and the future required levels of funding. There are actually considerable amounts of money being invested in energy efficiency at the moment. In the private sector, the Warm Front Programme spent nearly £1 billion over its three-year spending programme. I understand, although I do not actually recognise the number, that £2 billion will be spent on heating and insulation improvements in the social sector. Also, we have the carbon emissions reduction target which will invest something like £3.2 billion over a three-year programme, so there is a considerable amount of money that is currently being invested in domestic energy efficiency. Unfortunately, from both a carbon reduction perspective and a fuel poverty perspective, these levels of investment are not nearly enough, so this is your £64 billion question: where is the money coming from? If we are realistic, there is only one source of funding and it is me and you and everybody else really and it is whether we achieve this funding in the most progressive manner or whether we do as we currently practise, which is to achieve it in a fairly regressive manner. Most of the investment for energy efficiency currently comes through domestic consumers' bills. We, NEA, think that that is not the most equitable means of raising funding for energy efficiency and, unfortunately, then the conclusion that we are left with is that the necessary resources to promote government social policy objectives should be raised through direct taxation.
Sir Paul Beresford: Again, I am showing my age, but, if we go back to the 1980s, a lot of local authorities used their capital receipts for mortgages and second mortgages, housing action areas, et cetera, and built up a portfolio and then sold the portfolio to building societies, banks and so forth so that the money was recycled and came back to the public sector. Is there an opening for that?
Q250 Chair: Professor Power, would you like to answer that question?
Professor Power: I would love to answer that question! There is a whole sort of web of factors that would help answer that question and your question. The first is that the net cost of all insulation measures is negative over time. In other words, you gain more than you spend over time, but, for example, for wall insulation it is 17 to 20 years, so it is quite a long time. If you are a social landlord, you have two advantages. Obviously, if you are a council, you are still restricted, in spite of the Government attempting to even the playing field, but I think more and more councils are finding ways of creating arm's-length structures that can actually borrow and social landlords can borrow cheaply and over the long term. I know that there are restrictions on borrowing, but, given the asset and given the long-term stability of social renting, generally it is still considered a very good bet for investors, so one is its net negative costs over time and, two, social landlords can borrow. Two lenders, from my understanding, having sat in several big meetings with big investors on exactly this problem, are willing to do it and there is the potential. Obviously, they do need some kind of government backing for the system, but the Government does effectively back the system through rent, which is the third problem. Rents for non-local authorities are tied to a rent convergence policy that is a huge handicap to any non-local authority social landlord borrowing to invest because they cannot put up their rents to pay for that investment, so there would have to be some complicated agreement whereby rents rise to cover the additional cost of paying for the investment in energy efficiency as a trade-off for rents getting their energy through some kind of ESCO structure with the social landlord, as a result of which the tenants would pay net less rent than their combined rent and fuel bill would have otherwise been as energy prices rise, so there is a package and actually the National Housing Federation - I do not know if they are giving evidence.
Q251 Chair: We have had evidence from them.
Professor Power: Well, they have given a lot of thought to this, but there are private funders, the Council for Mortgage Lenders and particularly some of the investment banks, who are actually looking at the viability of those schemes and looking for ways of actually investing their money, so it needs somebody very clever to break through. There is a key point, that the Government has to take VAT off this kind of investment because at the moment it is property repair and property upgrading is still liable to VAT, and that obviously is a killer.
Q252 Mr Slaughter: Professor Power, the SDC said that we need to look further than the building level and we need to look to improvements to the local environment and community-level infrastructure, ie, going beyond Decent Homes at the moment, but what do you mean exactly by that? How far should that go? Are we talking about common parts, are we talking about estates, are we talking about whole neighbourhoods?
Professor Power: I think that is a really,
really good question. When the last
Decent Homes Programme was announced, I did have many meetings in Government
over exactly that issue because at the beginning the Decent Homes Programme was
very narrowly tied to buildings only. I
knew from my work, particularly in
Q253 Mr Slaughter: So we are talking about physical improvements and we are not talking about policing or other sort of revenue spending schemes or things of that nature? Even if you are just talking about physical improvements, then the more you expand it, and yes, okay, I am with you when you are talking about common parts and possibly even some estate design and things of that nature, but, as soon as you then start saying, "Right, we are going to do the roads, the buildings and the shops", then the money becomes so diluted and diffuse.
Professor Power: Well, you do not need to use Decent Homes money to do that.
Q254 Chair: But you would do if it were a Decent Homes part. It is a slightly different question, saying, "Should all those things also be done?" from "Should they be part of an expanded Decent Homes Programme?"
Professor Power: I agree, that it is two different programmes, so my answer would be that the Decent Homes Two should go to the curtilage of properties and not just to the front door of properties, so it should include the immediate controlling areas of the social, but, if the Decent Homes Programme, mark two, were driven for the environmental benefit and the social benefit of the areas, and, after all, social housing is incredibly concentrated still, in spite of best efforts to break it up and disperse it, then the wider area benefits and some of the budget streams that I am talking about would be brought in. On the policing, one thing we do know is that more street activity and more human contact within neighbourhoods creates a lot of informal policing, and we also know that more upgrading activity creates an informal form of policing, so there are actually indirect supervisory benefits in having more activity on the ground, and then you need to maintain it, so you have to have caretakers, neighbourhood wardens and neighbourhood management, which I have argued very strongly for.
Q255 Mr Slaughter: Do you not think you are being just too ambitious here in terms of the aims of Decent Homes? You are moving from the necessary capital improvements, whether they are for energy efficiency, and trying to take over people's lives, and is there not too much regarding social housing, whether it is individual units or estates, as something that has to be treated? These are ordinary people and yes, of course, if it is a high crime area, you will have more police, but why does it have to be some part of a great government and nationally directed scheme?
Professor Power: Well, you did ask me about it. We are the only country in Europe that does not have an actual legal structure for the supervision of common areas within neighbourhoods and it is partly because we build houses and it is partly because we have a high level of owner-occupation and a very low level of private renting, it is for all sorts of historic reasons, but we have more vandalism in this country than any other European country, we have more graffiti, we have more youth disorder and we have a whole range of social consequences.
Q256 Chair: I think we are going way beyond the bounds of this inquiry. Can we just get back very briefly to an expanded Decent Homes, not whether these things are desirable, but whether they should be within an expanded Decent Homes.
Mr Sharpe: Sandwell Homes and Accord Housing have taken the trouble now to get ISO 14001, the environmental management system, and they have then actually gone on to get EMAS, which is the European standard, a very high standard with lots of continuous improvement. I think there is a lesson there because that has provided a framework within which they are putting their policy for decent homes, but enhanced decent homes and a lot of other continuous improvement. My thought is that the Decent Homes Standard could become something that looks like an ISO 14001, in other words, to provide a framework and then you could latch other things on to it where you wanted to because you could almost take the modules and put them into it, so you already have a model, and I know that Wolverhampton Homes are the same, they are heading off towards 14001, so it demonstrates that there is a wish to have a framework within which to work and it would start to pick up lots of this stuff, but you could then decide which bit. What you will need to strengthen in that, and EMAS is very strong on continuous improvement, but 14001 is not, so what you would need to do is to ensure that the continuous improvement element included the standards that you wanted to have reached, so I think the Decent Homes Standard could become something that looked like an ISO 14001 standard which would then give flexibility, but set some key targets. Now, you could decide whether it is going to go from curtilage and whether it is going to include other areas because of course what Sandwell and Accord do is bring all of their tenant groups into it and they bring their green infrastructure into it, they are doing that already, so that provides a nice structure, and you could then almost pick and choose which bits you put into that structure.
Q257 Chair: I think we must draw this to a close, but very, very briefly, does that only apply to the social sector, or could it conceivably be applied to the private sector?
Mr Sharpe: The problem is the structure. The problem is finding the structure for it to work with. Landlords' accreditation would be one way and combining it with the social sector would be the other, so I think they are two ways of doing it.
Chair: Thank you very much indeed.