Beyond Decent Homes - Communities and Local Government Committee Contents

 
 

 
3  Our findings: social sector

The size of the problem

29.  The decent homes target was measured, in its first six years of existence, against the English House Condition Survey. In 2001, according to the English House Condition Survey (EHCS), there were 4,236,000 homes in the social sector, of which local authorities managed 2,811,000 and registered social landlords (RSLs) 1,424,000. The percentage of the total judged non-decent was 38.9% (1,647,000 homes). By 2007, the most recent year for which EHCS figures are available, the total stock had fallen to 3,891,000 homes, of which local authorities managed 1,987,000 and RSLs 1,904,000. The percentage of homes considered non-decent was 29.2% (1,138,000 homes).[44] Since 2007, however, CLG has measured its progress against the target by reference to data provided by landlord returns, through the Business Plan Statistical Index by which local authorities report to CLG their use of the Housing Revenue Account each year. These figures recorded 47.5% non-decency in 2001. The most recent figures showed this to have to declined to 14.5% in 2009.[45]

30.  In its written evidence to our inquiry, CLG indicated that the target of 100% decency was unlikely to be met, stating:

We have previously said that we expected around 95% of social homes to be decent by 2010 […] It is estimated that the local authority sector will have a backlog of over 255,000 non-decent dwellings at the end of 2010.[46]

In oral evidence several months later, the Minister told us that "We estimate that by [the end of 2010] around 92 per cent will be decent".[47] However, he also announced during the evidence session that he was launching a "full-scale assessment" of the programme as, notwithstanding the progress made, some authorities appeared to be regressing. He told us:

I am concerned, for instance, that 27 local authorities have seen their levels of Decent Homes drop backwards in the last year. I am concerned that ten authorities had more than a third of their stock at the end of 2008/2009, in other words April this year, non-decent. I am particularly concerned that 14 authorities had an increase in their non-decent stock over the last couple of years of 10 per cent or more of the total homes for which they are responsible.[48]

MEASUREMENT OF THE TARGET

31.  As described above, the decent homes target for social sector homes is now measured through the returns which local authorities and registered providers make to the Government and the Tenant Services Authority on an annual basis. Some witnesses cast doubt on the reliability of landlords' data. The Chartered Institute of Environmental Health (CIEH) told us in evidence that "it is likely that many social landlords and some consultants employed to carry out stock condition surveys do not understand the system adequately so that their assessment of 'non-decency' must be questionable".[49] Ridge and Partners told us that, in their work in 2004 reviewing stock condition survey results, databases and survey designs, they had discovered that "the methods of data collection, interpretation and reporting vary considerably". Ridge told us that in some instances "organisations were (not unreasonably) putting faith in the findings of third parties and software that (in our opinion) was simply incorrect in their assessments of [decent homes standard] results". It said that the "absence of clear condition survey guidance and a national calculation model means that this 'risk' still remains".[50] In oral evidence, Richard Hand of Ridge repeated these concerns, concluding that "the only way of appraising [the quality of data] is for that to be scrutinised more closely during Audit Commission inspection, for example, or that type of opportunity", and calling for "clear guidance about the modelling process for the data that exists, getting rid of a lot of the inconsistency".[51]

32.  We conclude that consistency of the data on decency can and should be improved. We recommend that the Government establish national guidance on the collation of stock condition data, to reduce inconsistencies in the assessment of decency by landlords. Adherence to the national guidance should form part of the Audit Commission's assessment of local authorities.

33.  We mentioned above that properties where the tenant has been offered, and has turned down, decent homes improvements may be counted as decent for the purpose of collating statistics by landlords. Hyde Group told us:

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.[52]

34.  We consider that where a tenant has refused decent homes work to a property and the property remains non-decent, that property should be recorded as a refusal and not as a decent home. We recommend that the decent homes guidance is amended accordingly. Further, we consider that when the tenant has moved on, the decent homes work should be offered to the new tenant, as soon as feasible.

Implementation in the social sector

35.  In order to meet the target, the Government provided significant funding. In addition, it laid down principles about how the improvement of homes was to be managed. The 2000 White Paper stated that the ownership and day-to-day management of social housing stock was an important lever by which to affect quality, and indicated that the Government's preference was to move day-to-day management out of the hands of local authorities. It said that "those who are elected to serve their local communities should be concerned with the full range of strategic issues surrounding the housing needs of their communities, rather than focusing more narrowly on the day-to-day management of social housing".[53] The White Paper pledged to engineer "a progressive shift in ownership so that the stock is more widely owned by a range of different organisations, including housing associations, local housing companies and tenant-led organisations, with tenants benefiting from a greater choice of housing providers and local authorities focusing more on their strategic housing".[54] The Government offered local authorities several models of management in order to reach the decent homes target, each with different conditions attached. All local authorities were required to conduct a Stock Survey and prepare an Options Appraisal comparing the different choices available in the context of local circumstances, and consulting tenants in order to agree the route to be taken.

36.  In the first instance, local authorities could transfer their stock to the housing association sector. Ownership of the stock was thereby moved to a non-profit-making body, which had the advantage over a local authority of being able to borrow against the future rental stream, thus attracting private finance in to fund improvements. The White Paper recognised that some councils carried more debt than would be redeemed by the sale of the stock; and committed funding to pay off this overhanging debt to allow sales to take place. Transfers could only take place after a ballot of tenants indicated their consent. By December 2008, 170 authorities had transferred all their stock to an RSL, six more were planning to do so, and an additional 15 had made partial transfers.[55]

37.  The second option for councils for managing homes while retaining ownership of the stock was to create an Arms Length Management Organisation (ALMO). Councils had to demonstrate that tenants supported this choice of operation; and ALMOs were required to attain a two-star rating by the Audit Commission in order to be granted funding by the Government. By 2008, 66 authorities had established an ALMO.[56]

38.  Councils could, alternatively, use a Private Finance Initiative to fund and manage their housing improvements. Councils could draw up long term contracts with private sector providers, which would take responsibility for raising the necessary capital finance, and be freed from public sector expenditure controls, in return for an annual, performance-related service fee. By December 2008, 14 authorities were using, or planning to use, this approach.[57]

39.  Finally, some councils retained the ownership and management of their stock. The achievement of the standard was supported in the retained sector by the introduction of the major repairs allowance (MRA) and the requirement to develop 30 year business plans for the first time (a requirement which also applied to those local authorities which established ALMOs to manage their stock). The Prudential Code was introduced through the Local Government Act 2003, which gave greater flexibility for authorities to reinvest housing receipts and borrow to secure improvements. By December 2008, the number of retention authorities was 112.[58]

The standard

CRITERION (A): THE STATUTORY MINIMUM STANDARD FOR HOUSING

Dwellings which fail to meet this criterion are those containing one or more hazards assessed as serious ('Category 1') under the HHSRS.[59]

40.  When the decent homes criteria were drawn up, the statutory minimum standard for housing was known as the 'fitness test' under the Housing Act 1985. The Housing Act 2004 created the Housing Health and Safety Rating System (HHSRS), which replaced the fitness test in decent homes guidance as a new tool for assessing minimum housing standards. The HHSRS requires an appraisal of the potential risks to an occupant of the home in 29 areas, including physiological and psychological risks and protection against infection and accidents. The seriousness of a hazard is judged according to four categories ('Category 1: Extreme' to 'Category 4: Moderate') and decent homes must be free of Category 1 hazards. The Housing Health and Safety Rating System Operating Guidance published by the Office of the Deputy Prime Minister in 2006 explained:

The underlying principle of the HHSRS is that - Any residential premises should provide a safe and healthy environment for any potential occupier or visitor.

To satisfy this principle, a dwelling should be designed, constructed and maintained with non-hazardous materials and should be free from both unnecessary and avoidable hazards.[60]

As noted above, the introduction of the HHSRS had the effect of increasing the number of non-decent homes by widening the range of requirements for a decent home.

41.  The evidence we received made various observations and comments on the introduction of the HHSRS as part of the decent homes standard. The Chartered Institute for Environmental Health described the system as "less subjective"[61] than the fitness standard and Sandwell Metropolitan Borough Council said that:

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.[62]

42.  More than one witness, however, expressed concern that the system was not being used properly. The College of Occupational Therapists told us that local authorities "report confusion over whether the person they are to have in mind in administering the tool is simply an imaginary subject or the actual occupant".[63] The Residential Landlords' Association told us that the system is "too complex", and "not understood always by all Environmental Health Officers".[64] The Chartered Institute for Environmental Health told us that RSLs, in particular, were not taking up training in how to use the HHSRS. It said:

Anecdotal evidence abounds of RSLs having inadequate plans and procedures for the use of the system in monitoring performance and standards. However, only a few employees of RSLs have benefited from such training and there is no coherent programme of training, which has been a matter for individual social landlords and local housing authorities.[65]

In oral evidence the CIEH told us that the training "is available to all, but it is just not being taken up by RSLs".[66]

43.  On a separate point, the CIEH raised the question of whether the inclusion of the HHSRS in the decent homes criteria obviated the need for the other criteria. It said the incorporation of the Housing Health and Safety Rating System "raises the question as to whether it alone should form the basis" of the standard.[67] We discuss below the fact that even should the thermal comfort criterion be met, a house may still have a Category 1 hazard for cold, which raises the question of whether the thermal comfort criterion serves a useful purpose which could not be covered by HHSRS. The Institute also suggested that a future decent homes standard could increase the stringency of decency levels by requiring that a decent home is free not only of Category 1 hazards but of some Category 2 hazards as well.[68]

44.  Although, on the whole, the Housing Health and Safety Rating System has been embedded successfully in the Decent Homes Standard, there is evidence of lack of understanding of the system by some landlords. We recommend that the Government, in partnership with the TSA, take steps to improve the availability and take-up of training in use of the HHSRS.

CRITERION (B): A REASONABLE STATE OF REPAIR

Dwellings which fail to meet this criterion are those where either: one or more of the key building components are old and, because of their condition, need replacing or major repair; or two or more of the other building components are old and, because of their condition, need replacing or major repair.[69]

45.  We received little evidence concerning this criterion and therefore conclude that it is broadly operating as intended.

CRITERION (C): REASONABLY MODERN FACILITIES AND SERVICES

Dwellings which fail to meet this criterion are those which lack three or more of the following: a reasonably modern kitchen (20 years old or less); a kitchen with adequate space and layout; a reasonably modern bathroom (30 years old or less); an appropriately located bathroom and WC; adequate insulation against external noise (where external noise is a problem); and adequate size and layout of common areas for blocks of flats. A home lacking two or fewer of the above is still classed as decent, therefore it is not necessary to modernise kitchens and bathrooms if a home meets the remaining criteria.[70]

46.  Criterion (c) covers perhaps the most visible element of the decent homes standard and requires potentially significant works to update the amenities of a property. However, the guidance makes clear that "a dwelling would not fail… where it is impossible to make the required improvements to components for physical or planning purposes". Moreover, local authorities are urged to integrate decent homes work with other regeneration strategies and take into account other ways of dealing with stock: the guidance states "it may not be necessary to make homes decent when demolition and new build may be more appropriate".[71]

47.  There was disagreement amongst witnesses about the wisdom of the age-related requirements of criterion (c). Stoke-on-Trent Council praised it for being understandable to tenants. It said that age "is the most accessible criterion for tenants to understand as the key to trigger" replacements and that an assessment "based on condition alone will reflect usage and may work to the detriment of those tenants who properly maintain their property […] an assessment based on condition alone may act as a perverse incentive for tenants to take appropriate care of components including kitchens and bathrooms".[72] The Council therefore advocated maintaining the link to age and condition of key amenities. On the other hand, West Kent Housing Association told us that modernity is "a matter of opinion and fashion as such is best determined by customer choice rather than regulation standards", and that "timed replacements of kitchens, bathrooms etc specified in criterion (c) (provision of modern facilities) should not form part of minimum Decent Homes Standards".[73] CIEH queried the inflexibility of the age component, saying "age in itself is not necessarily a reflection of condition". It said that it "is not necessary to replace satisfactory facilities which are older than the prescribed limit (and with which occupiers are happy) nor is it acceptable for inadequate facilities which are newer to remain in place".[74] Finally, Mr Michael Gelling OBE, Chair of the Tenants' and Residents' Organisations of England, told us that tenants did not consider the criterion to be 'decent'. He said:

if you ask anybody, what would you class as a decent home, they would not say, well, if I had a modern kitchen at least 20 years old, that would be a decent home…They would not say a reasonable modern bathroom, 30 years old or less, would be a decent home. Ordinary tenants are quite surprised when they see what a decent home standard is, because it is a very low bar.[75]

48.  The logic of criterion (c) is unclear and may allow some landlords to classify homes as decent by virtue of some of the criterion's specifications being irrelevant to the property type. A dwelling meets criterion (c) if it lacks two or fewer of the listed characteristics. According to this logic, if there are no common areas and external noise is not a problem, it appears that the home is classed as decent, even if the other characteristics are not present. As we discuss later, however, the TSA plans to iron out variability of application of the standard by requiring landlords to publish how they apply the standard to their properties. We conclude that criterion (c) is expressed in a way that allows homes with quite different standards of amenities to be classified as decent. A landlord may avoid installing new kitchens and bathrooms if he judges the other elements to be "adequate" and "appropriate". We recommend that the TSA collate and disseminate best practice on compliance with this criterion to assist landlords and tenants in discussions of how the standard is applied at a local level.

CRITERION (D): A REASONABLE DEGREE OF THERMAL COMFORT

This criterion requires dwellings to have both effective insulation and efficient heating. It should be noted that, whilst dwellings meeting criteria b, c and d are likely also to meet criterion a, some Category 1 hazards may remain to be addressed. For example, a dwelling meeting criterion d may still contain a Category 1 damp or cold hazard.[76]

49.  The thermal comfort criterion has generated the most criticism in the evidence we have received. Those criticisms have focused on whether the specifications provided in the guidance do, in fact, provide a comfortable degree of warmth in a home; and how best to measure compliance with the standard. The thermal comfort criterion is also seen by some as a lever by which to bring into the decent homes standard measures to reduce the carbon dioxide emissions from housing, as we discuss below.

50.  The thermal comfort criterion is primarily related to health. Care and Repair England spelled out in its evidence the direct effect of cold housing upon the mortality of the elderly:

One of the most widely recognised health inequalit[ies] linked to housing conditions is that of excess winter deaths amongst older people. Between December 2007 and March 2008, there were an estimated 25,300 deaths in England and Wales, an increase of 1,000 from the previous winter.[77]

The evidence went on to explain that cold homes and fuel poverty have a direct effect on these numbers:

There is a close correlation between winter temperature and death rate, combined with fuel poverty and incidence of cold homes. The level of excess winter deaths in the UK is higher than in colder countries, such as the Scandinavian countries, which have better housing, so it is often argued that the thermal standard of properties in the UK is a significant causal factor.[78]

51.  The degree of thermal comfort of a home depends upon several factors: the level of warmth required by its inhabitants to remain well; the physical infrastructure of the house which determines its energy efficiency; and the affordability of energy for its inhabitants, which is also affected by the income of the inhabitants and the price of energy. The guidance on the thermal comfort criterion covers the first two of these factors. It specifies energy efficiency inputs (what heating systems should be installed in a home, what thickness of cavity wall and loft insulation must be used) and also falls within the purview of criterion (a) in specifying risk-based outputs for the inhabitant. That is to say, under criterion (a) the home must be compliant with the HHSRS, which means that there must be no Category 1 hazards, including from excess cold. As the guidance comments, simply meeting the required insulation and heating systems inputs will not necessarily be sufficient to prevent a Category 1 hazard. The guidance seeks to link an energy efficiency measurement to warmth by specifying that a Standard Assessment Procedure (SAP) rating (the Government's measure of energy efficiency) of less than 35 "has been established as a proxy for the likely presence of a Category 1 hazard from excess cold".[79] Guidance on the application of the HHSRS, rather than the decent homes standard per se, states that:

A healthy indoor temperature is around 21°C. There is small risk of health effects below 19°C. Below 16°C, there are serious health risks for the elderly, including greatly increased risks of respiratory and cardiovascular conditions. Below 10°C a great risk of hypothermia, especially for the elderly.[80]

52.  The criterion has been criticised from several angles: that the criterion's requirements are too low and poorly expressed; that guidance is needed on how to evaluate the risk of excess cold under the HHSRS; and that the Government's fuel poverty policies, which cover bring into the mix the affordability of energy, are inadequately linked in to the criterion.

53.  The evidence was almost universally negative about the level at which the thermal comfort criterion is set. The Chartered Institute of Environmental Health told us the level was too low;[81] the Association for the Conservation of Energy called it "woefully inadequate to provide affordable warmth";[82] Sandwell Metropolitan Borough Council stated that the criterion at its current level would "do little to help the Government meet its own targets around eradicating fuel poverty".[83] National Energy Action described the criterion as "not fit for purpose" and stated that the "adoption of SAP 35 as a proxy for a Category 1 hazard under the Housing Health and Safety Rating System, with the implication that any higher SAP does not pose a major risk to health and well-being, is unacceptable".[84] Several witnesses told us that most landlords had already brought their properties up to a higher level of energy efficiency.

54.  Other evidence we received criticised the terms in which the criterion is quantified. West Kent Housing Association criticised the guidance for being "too prescriptive and concentrate[d] on inputs rather than specifying outcomes";[85] the Construction Industry Council noted that the guidance focussed on improvements to the interiors of individual homes, hence excluding exterior insulation and neighbourhood-wide measures.[86] The Energy Saving Trust stated that "there is a lack of guidance about what is a Category 1 hazard for cold", describing "confusion among local authorities"; the Association for the Conservation of Energy concurred, citing research by the Chartered Institute of Environmental Health showing that "the energy assessment required by the HHSRS is quite subjective, leaving council officers unsure whether the premises in question are in fact suffering from 'excess cold'".[87]

55.  The decent homes standard requires the absence of Category 1 hazards under the HHSRS in criterion (a) and it is not, therefore, necessary to repeat this requirement specifically in relation to thermal comfort in criterion (d). However, there is evidence of confusion around how to use the HHSRS in this area. We recommend that the Government formulate and disseminate practical guidance on what constitutes a risk of excess cold under the HHSRS, building on the extant guidance for landlords and property related professionals on the HHSRS.

56.  While the decent homes guidance refers to SAP 35 as a "proxy" for the absence of Category 1 thermal comfort hazards, we consider that the thermal comfort criterion should be redrafted explicitly as a minimum energy efficiency rating. We discuss below (in relation to reducing carbon dioxide emissions) what that rating should be. The standard should not mandate the specific inputs (such as type of heating system, thickness of insulation) needed to reach that energy rating, as there will be various ways to reach the desired outcome. Rather, accompanying guidance should indicate the inputs likely to be necessary for warmth and energy efficiency, while recognising that different solutions may be necessary for different properties.

57.  The final key criticism centres on linking the thermal comfort criterion to policies on fuel poverty, which takes into consideration the link between energy efficiency, energy costs and income. The fuel poverty strategy defines fuel poverty as follows:

A household is said to be in fuel poverty if it needs to spend more than 10% of its income on fuel to maintain a satisfactory heating regime (usually 21 degrees for the main living area, and 18 degrees for other occupied rooms). The "Fuel poverty ratio" is therefore defined as: Fuel poverty ratio = fuel costs (usage x price) ÷ income.[88]

Stoke-on-Trent Council told us that there "is a clear need to improve the links between Decent Homes Standards and fuel poverty targets" and that in its current form the Decent Homes Standard "makes little contribution to these targets". It concluded that there "is potential however to achieve significant efficiencies by appropriately linking these two programmes".[89] Circle Anglia suggested solving this problem by requiring social landlords to get involved in the setting of energy prices, saying that the "new standard could include a duty to take action to supply affordable energy in partnership with energy suppliers".[90] Mr Ron Campbell, Head of Policy and Information at National Energy Action, told us that "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".

58.  However, the evidence also referred to the difficulty of addressing fuel poverty through this mechanism. Mr Campbell said:

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.[91]

Others argued that for these reasons the thermal comfort criterion alone would not be an adequate instrument to tackle fuel poverty. The TSA stated:

eliminating [fuel poverty] requires not only the work necessary to make homes energy efficient, and adapting them for the wider effects of climate change. It also requires effective interventions to deal with fuel costs and the level of household income.

The Housing Group of the Building Research Establishment (BRE Housing) argued that for these reasons fuel poverty should be left out of the standard, stating in evidence: "fuel poverty is often suggested as an additional item [to include in a future decent homes standard] but social landlords have no control over two of the most important determinants - household income and fuel prices".[92] Hyde Group agreed, saying:

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 residents' incomes could make this extremely complex.[93]

Westminster City Council stated "the fuel poverty standard may be difficult to implement as it is out of the control of the Council and is dependent on fuel prices and residents' incomes".[94]

59.  In evidence to us, CLG conflated the issues of thermal comfort, energy efficiency, carbon dioxide emissions and fuel poverty, citing positive results as follows:

The decent homes programme has already made great improvements to the energy efficiency of Social Sector homes…By 2010 the Decent Homes programme will have reduced emissions by 8% from 2006 levels, helping to tackle climate change. The decent homes programme also helps to reduce fuel poverty.[95]

60.  Thermal comfort and fuel poverty are inextricably linked: a comfortably warm home will not be achieved through energy efficiency alone, should the inhabitant be unable to afford energy costs.. Whilst, as the Department points out, the decent homes programme helps to reduce fuel poverty, we consider that it would be asking too much of the standard specifically to use it to meet fuel poverty targets because it does not depend just on the property but also the income of the occupant.

61.  We conclude that, while the decent homes standard should not be linked directly to fuel poverty programmes, its recasting as we recommend to tackle energy efficiency more explicitly, would have knock-on effects on fuel poverty. As we discuss below, this would also make a direct contribution to reducing carbon dioxide emissions from housing. We discuss the detail of this energy efficiency outcome measure in the section on additional criteria: reducing carbon dioxide emissions.

62.  The Government's Strategy for Household Energy Management proposes a new "Warm Homes" standard for social housing, "to supplement the Decent Homes standard". The Strategy states that this "would cover both insulation and connection where feasible to low carbon district heating or renewable heating". The document states that the Government intends "to develop the detailed standard working with others during this year, and to work with the Tenant Services Authority (TSA) to ensure that landlords plan how they would achieve it by 2020 contingent on the necessary support and funding".

63.  We applaud the Government's focus in its Household Energy Management Strategy on warmth and energy efficiency of homes. It is not clear from the Strategy how a new "Warm Homes" standard would complement the decent homes strategy and its thermal comfort criterion. We urge the Government to avoid a proliferation of standards.

VARIABILITY

64.  We have received a number of representations about how the standard is interpreted and implemented by landlords at a local level, many of which described inconsistencies in the way in which the standard has been applied. The g15 group of housing associations stated in evidence that "there have been differences in interpretation which has led to inconsistencies in what constitutes a decent home";[96] another housing association, Gentoo, told us that "two landlords can both achieve Decent Homes (which is a minimum standard) but have markedly different quality standards in their delivery" and have spent different amounts on improvement per unit.[97] Consultancy Ridge and Partners told us that the terms in which the decent homes criteria are expressed leave room for ambiguity: for example, criterion (c) refers to "adequate" space and layout of a kitchen.[98] However, another consultancy, Savills, told us that standards "are always subject to interpretation, however prescriptive they are".[99]

65.  Some suggested that interpretability, combined with the imperative of meeting the target, had led some providers to aim for the minimum possible level of improvement, especially where funding was limited. Southwark Council suggested that a "target-driven culture could create a perverse incentive for authorities to meet the bare minimum and be rewarded for doing so".[100] Savills stated that "people can use standards to suit their own purposes unless there is very tight control". In particular, in the case of local authorities with retained stock, "a minimalist approach has been taken to the achievement of the standard", whereas ALMOs, which "have a vested interest in increasing the quantum of work required to meet Decent Homes, have taken a different approach".[101] Mr Sparrow of Savills advised us that the way round this issue was by re-writing the standard in clearer terms:

one key way of avoiding that or helping to avoid that is to cut out as far as possible the interpretation issues within the standard itself and streamline it and make it simple, so instead of the examples where a property has to fail on two components to fail overall or three components to fail overall—anything like that that can be taken out, where it is a straight failure, yes or no, would help the whole interpretation and consistency.[102]

66.  CLG told us that the decent homes standard "is a minimum standard that triggers action below which no social housing should fall; it does not represent the standard to which all work should be carried out" and recognised that the "majority of landlords are completing work in excess of the standard". [103] Peter Marsh, Chief Executive of the Tenant Services Authority, told us that the baseline standard "absolutely is clear" but that "a number of providers have gone beyond the baseline and said that they will do more than is required by the standard itself". He told us that the new regulatory framework would require each provider "to set out clearly how it intends to meet each standard". He stated that the TSA would "be asking the councils and the housing associations to say what their interpretation of decency is and what meeting the Decent Homes standard by 2010 or beyond that means for them and their tenants", which would improve transparency.

ADDITIONAL CRITERIA

67.  Our terms of reference for this inquiry included the question: "Should minimum acceptable social housing standards be amended to take account of environmental standards, fuel poverty and the estate?". In the evidence we received, witnesses raised a long list of other possible additions to a future standard. These suggested additions fell into three categories: the fabric of the home; energy; and the physical and social conditions of the neighbourhood or estate.

68.  The fabric of the home has been the focus of the decent homes standard since its inception. Witnesses suggested that to the existing criteria could be added minimum space standards, sound insulation, accessibility, security features and fire safety. Suggestions to add criteria relating to energy consumption ranged from energy efficiency, fuel poverty, carbon dioxide emissions and overheating to water consumption. On the estate or neighbourhood, witnesses advocated, among other things, standards for access to green space, anti-social behaviour, maintenance of pavements and footpaths, provision of drying areas, parking, lifts and other common parts.

69.  In our deliberations we have chosen to focus on energy efficiency and the estate or neighbourhood. However, the range of suggestions we have received for additional criteria for a new decent homes standard demonstrates the necessity of having a clear view about what the decent home standard is for. The current definition is fairly narrowly focused, but a significant number of landlords have attached higher standards and a wide range of additional improvements. As mentioned above, the TSA's proposed approach is to mandate national minimum standards accompanied by locally-negotiated supplementary standards.

70.  We asked witnesses about how far the decent homes standard could or should be used as a vehicle to drive improvements outside the home and seek to ameliorate social conditions as well as physical ones. Sarah Webb, Chief Executive of the Chartered Institute of Housing, told us that "the relatively narrow focus that it has had on bringing all properties up to a minimum standard has actually been very important" and that "retaining a focus on properties and the space in which properties are is, we think, valuable". She stated that CIH "would not […] think that the Decent Homes programme carried forward is the panacea for everything that is wrong with housing and communities". [104] On the other hand, others felt that the decent homes standard should be used to influence areas outside the home. Professor Power, former Commissioner at the Sustainable Development Commission, told us that "if you [do] not upgrade the environment at least to some minimal standard alongside your upgrading of homes, then you would lose a lot of the benefit of the upgrading of the homes".[105] She went on to tell us that by improving estates, it was possible to encourage people to occupy homes continually, reduce demand to leave an area, improve youth behaviour, create jobs, improve children's play and the use of social spaces, increase levels of informal policing and reduce vandalism.[106] Property management company and housing association Places for People advocated a "sustainable communities framework" which included indicators for housing and community, the environment, infrastructure and access to opportunities, employment and opportunity, health, crime and education.[107]

71.  The Government acknowledges the effects of the decent homes work on wider issues outside the home, and accepts the need to consider setting national standards on additional issues. The written memorandum we received from CLG and the HCA stated that "the social sector Decent Homes programme has delivered much more than the obvious improvements to the housing stock".[108] The additional benefits listed included improving asset management by landlords, making efficiency savings through procurement consortia, empowering tenants and increasing social inclusiveness, improving the environment and security of estates and contributing to tackling worklessness by creating employment and training opportunities. As mentioned above, the draft standards proposed by the Tenant Services Authority span six areas, of which quality of accommodation and the decent homes standard is one part.

72.  We conclude that setting national standards is only one way of improving housing and is not appropriate for all types of improvement, and that the decent homes standard should remain narrowly focussed. We further conclude that, while some issues are best dealt with through national standards, others are more appropriately set in local standards or agreements. This is the approach which the Tenant Services Authority's statutory regulatory framework proposes for the setting of standards in the social housing sector. As we note elsewhere, many housing management organisations have agreed and set, in conjunction with their tenants, local standards which go beyond the nationally-set standard and which reflect the priorities and resources of local communities. We commend those organisations which have done so and encourage others to follow suit. Meanwhile, we welcome the TSA's approach to this issue, under which it will have an important role in regulating the process by which such standards are reached and ensuring that all parties—including tenants—have had a proper input into agreeing appropriate local standards.

The environment

73.  Our questions about additional criteria produced many responses which focused on reducing carbon dioxide emissions through energy efficiency measures. Witnesses also referred to a wide range of other "environmental" considerations. Waterwise told us that the standard should include provisions on saving water, most simply by installing showers instead of baths, but also setting standards for taps, toilets, showers and white goods "to reflect the 2009 introduction of water efficiency into Building Regulations".[109] Circle Anglia recommended the inclusion of waste disposal and recycling;[110] Westminster Council told us that its tenants had expressed interest in recycling and organic waste disposal;[111] and the Sustainable Development Commission said that it "would […] like to see an enhanced Decent Homes standard cover areas such as water, materials and construction/demolition waste, household waste and summer overheating".[112]

74.  Whilst many—indeed all—of these suggestions may be desirable, to include them all in a national standard would make it unwieldy and inflexible. We conclude that 'environmental' standards other than energy efficiency should not be set nationally in the decent homes standard, but may be agreed locally in accordance with the principle we note above.

Carbon dioxide emissions and energy efficiency

75.  In our discussion above of the thermal comfort criterion we referred to the debate about using that criterion as a lever for reducing the carbon dioxide emissions from housing stock. Thermal comfort is about the warmth and indirectly the health of the inhabitant of a home, whereas reducing carbon dioxide emissions is related to a broader policy for combating climate change. Both outcomes—a warm home and housing which emits less carbon dioxide—may be achieved through energy efficiency measures.

76.  The reasons for taking steps to reduce the carbon dioxide emissions from housing scarcely need rehearsing here. We stated in our Report on Existing Housing and Climate Change in 2008 that there "is clear scientific and political consensus that climate change is the greatest long-term challenge facing the world".[113] The Government stated in the UK Low Carbon Transition Plan that action on climate change "is urgently needed to prevent widespread human suffering, ecological catastrophes, and political and economic instability".[114] The UK is committed to reducing its carbon dioxide emissions by 80% by 2050. 27% of total emissions are from housing, and 80% of existing housing will still be in use in 2050.[115] A target has been set to reduce emissions from housing to nearly zero by 2050. While regulating emissions produced by new buildings is important, most reductions will have to come from adapting existing housing. The recently published Strategy for Household Energy Management proposes a range of measures to improve energy efficiency across tenures.[116]

77.  CLG already has a policy on the energy efficiency of housing outside the decent homes policy. In 2007 the Department's Strategic Objectives included a measure on energy efficiency of existing housing. DSO 2.6 is as follows:

Average energy ratings for all homes

Measure of success: to increase the average energy efficiency (SAP) rating for all homes over the spending period, from the 2006 baseline of 48.7 SAP points.[117]

CLG's 2009 Autumn Performance Report recorded that the latest available data indicated that in 2007 the average SAP rating of homes had risen to 49.8. The average ratings for local authority-owned and registered social landlord-owned social housing were 56.2 and 59.5 respectively.[118]

78.  The evidence we have received has endorsed the importance of reducing carbon dioxide emissions in the social sector. The Chartered Institute of Housing told us its members saw the issue as "crucial",[119] Circle Anglia said that "social policy and environmental concerns demand" it,[120] and the Sustainable Development Commission told us that social landlords were keen to play their part, citing "significant interest from social housing providers to deliver significant energy efficient improvements to their stock".[121] Over and above reducing social sector emissions, action in the social sector is seen as leading the way in a revolution which needs to sweep the much larger private sector along with it. CLG stated in evidence that the Government "has committed that the social housing sector will show leadership in improving the environmental performance of the existing housing stock".[122] We consider in this section the steps that can be taken to reduce emissions; the barriers to action; and whether the decent homes standard has a part to play in this equation. We discuss the possible cost implications of work to improve energy efficiency in the section on future funding, below.

Steps to improve energy efficiency

79.  Our witnesses described some of the options that could be used to reduce emissions in housing. These fall into what might be termed old and new technology. The Sustainable Housing Action Partnership (SHAP) stated that meeting the carbon reduction targets "could require a major retro-fitting of low carbon technologies such as solar water heating, photo-voltaic electricity generation and heat pumps";[123] Places for People stated that "there needs to be more investment in practical technology for retro-fitting existing homes (insulation, ground-source heat pumps, solar panels, etc.)".[124] Other witnesses were keen to emphasise the importance of fairly basic and straightforward adaptations such as external and under-floor insulation. Mr John Sharpe, Director of SHAP, told us the Partnership's research suggested that the primary focus should be on the fabric of the house and "doing the easy bits first".[125] Savills endorsed this approach, saying "the areas to focus on will be to improve the existing energy performance of the properties by conventional means, e.g., more efficient heating systems, more insulation etc., the provision of renewable energy initiatives where applicable".[126] In part the reason for this approach is cost-effectiveness: Mr Andy Doylend, Executive Director (Operations) of Circle Anglia told us that an experiment Circle Anglia was conducting in Norfolk to assess the carbon reductions that can be achieved through conventional and new technologies had found that "the shocking fact when you look at the price of the two is that the one where you have used modern technology is three or four times the price in terms of retrofit".[127] Mr Sharpe, however, told us that "the problem we have at the moment is that that most funding is predicated towards new technologies".[128]

80.  These latter comments correspond very closely with the findings of our 2008 report Existing Housing and Climate Change, in which we noted that:

[in] the clamour surrounding an urgent response to climate change, it is tempting to concentrate, as the Government has to some extent done, on how the homes of the future can be made as carbon-free as possible, or to focus on Eco-Towns and microgeneration, on Combined Heat and Power systems and personal wind farms. It is equally easy to forget that far more apparently mundane means of achieving rapid reductions in the UK's carbon emissions are much more easily available to improve quickly and simply the housing stock already standing. As one witness to our inquiry said, cavity wall insulation is not a 'sexy' subject. It is, however, part of the range of long-existing, familiar, comparatively cheap and comparatively easy-to-install technologies already freely available.[129]

81.  Witnesses were also keen to emphasise the importance of changing behaviour through education. Hyde Group stated that the "behaviour of society must be taken into consideration when trying to become more energy efficient and reduce carbon emissions",[130] Mr Doylend told us that education was a key strand of Circle Anglia's efforts to improve energy efficiency[131] as did Gentoo and Fusion 21 of their respective strategies,[132] and Savills told us such measures "could have a significant impact".[133]

82.  We note that the unit cost of new technologies will decline with the development of the market and recognise that new technology will have an important role to play in reducing emissions from housing in the medium to long term. Meanwhile, there is much that can be done at much lower cost while the evidence base is built up to justify large-scale spending on new technologies. We conclude that future funding should prioritise 'old technology' to improve the energy efficiency of housing: insulation and efficient heating systems, and education. We commend the Government's Strategy for Household Energy Management for prioritising basic works such as loft and cavity wall insulation.

83.  It was clear from the evidence that enhancing a dwelling's energy efficiency is not always straightforward. The variation in age and design of housing stock presents several problems. Mr Doylend of Circle Anglia told us that works must be tailored differently to each property as "one size just does not fit all". He said:

you have to look at every property in isolation to see what is the construction, is it an area where it cannot have gas it has to be on electric or oil heating, what is the standard of the property generally? You have to pick up a package of repairs and refurbishment that meets that property's needs.[134]

Moreover, substantial volumes of older stock present particular problems. Hyde Group told us that 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". [135] Many post-war social housing blocks are also constructed in such a way as to make energy efficiency very difficult or costly to improve. It is also necessary to consider the impact of adaptations to older stock on its aesthetic value.[136]

84.  We were advised that in some cases, the cost of retro-fitting a property may be so high as to be prohibitive. Hyde Group suggested that one solution would be to minimise the stock of this type which is held by social landlords. It said:

Owner occupiers of [period] 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.[137]

CLG recognised the problem of intransigent stock, the fabric of which would make retro-fitting prohibitively expensive. The Department told us some research had been commissioned through BRE to consider the issue of hard-to-treat dwellings. CLG's comment to us was that it "may not be appropriate to spend significant sums of money to ensure an individual property achieves a particular SAP rating when the same resource could deliver a bigger benefit for a wider number of people if used differently".[138]

A role for standards

85.  There was also a debate in the evidence we received about whether, accepting the need to raise energy efficiency standards and to determine how costs would be met, the decent homes standard is an appropriate policy lever through which to influence this area of policy. As cited above, CLG has set a target outside the decent homes policy for raising the average SAP rating of housing. However, witnesses argued that more needed to be done. In the first instance, witnesses were clear that some form of regulation would be needed to incentivise landlords to act on the scale necessary. The Energy Saving Trust stated that without this, little would change. It said:

Across the rented sector, increases in energy efficiency do not tend to be reflected in property capital value or rentability. Tenants are also unlikely to prioritise action on energy efficiency over more visible home improvements, such as a new kitchen. With no "pull" for higher energy efficiency standards for financial or tenant demand reasons, regulation needs to be used to ensure landlords act.[139]

Similarly, Mr Hand of Ridge and Partners told us that "the key reason for including [energy efficiency measures] within Decent Homes is that at the moment, apart from the goodwill of the landlord, there is no financial benefit to the landlord in making that investment".[140] Other witnesses, such as g15, argued that local variability of circumstances and the range of conflicting funding priorities meant that it would not support "a regulated requirement to enhance the standard" over the freedom to set enhanced standards tailored to local conditions.[141] Fusion 21 said that landlords "should be encouraged but not forced to improve energy efficiency and environmental standards".[142]

86.  Those who supported a regulated standard were divided on whether this should be a new policy instrument or whether the decent homes standard could accommodate energy efficiency measures. Some witnesses reasoned that the decent homes standard was the best place for higher requirements to be set simply because it was a familiar mechanism. Professor Power told us that "it makes perfect sense to add on energy efficiency"[143] and Mr Sharpe cited the benefit of using a structure that already exists, telling us: "Decent Homes so far has created a very good framework on which to build and we must not throw it away".[144] The Sustainable Development Commission reiterated the value of the standard in the absence of a more appropriate structure. It said:

The Decent Homes standard is the Government's primary mechanism to improve standards in the social rented sector and over vulnerable private sector tenants. In the absence of a Code for Existing Homes the Decent Homes standard must be expanded to include tougher energy efficiency standards.[145]

On the other hand, the TSA said of its draft standards that "the use of a quality of accommodation standard to secure wider objectives for environmental sustainability and carbon emission reduction is not the only, or necessarily the primary lever by which the objectives might be secured" and warned "setting new higher standards to succeed [the decent homes standard] is likely to be necessary to meet the goals in [the Low Carbon Transition] plan, but they will not be sufficient on their own".[146]

87.  As we describe above, we consider that standards should be set for the energy efficiency of social housing stock and that such a standard should be part of an updated decent homes standard regulated by the Tenant Services Authority. As we recommended above, this energy efficiency standard should be formulated as the replacement of the thermal comfort criterion. Setting a standard is unlikely of itself to achieve the desired results, but it is a necessary component of doing so. We note the proposal by the Government of an additional "Warm Homes" standard and commend to it our suggestion of amending the thermal comfort criterion.

Setting a standard

88.  As noted above, while setting a standard for energy efficiency would have an impact on thermal comfort and fuel poverty, an energy efficiency target would need to be divorced from the income-energy price matrix of fuel poverty, simply because it would be impractical for the parameters of large-scale physical works to be determined by an indicator which is so sensitive to economic fluctuation and the income of the occupant. Mr Doylend, Executive Director (Operations), Circle Anglia told us that Circle Anglia used a minimum SAP rating of 61 for its stock.[147] The suggestions we received on how high the level should be set ranged from SAP 65[148] to SAP 81.[149] As mentioned above, CLG already has a target to increase the average SAP rating across all homes. A more rigorous standard would set a minimum rating; however, setting a minimum standard is complicated by the limitations of some property archetypes. CLG stated in evidence:

The Government will consider whether any future standards that could contain a specific minimum, or average, Standard Assessment Procedure (SAP) target. However, there are practical issues regarding the feasibility of achieving a given level of thermal performance across all homes.[150]

89.  This comment from CLG, regrettably, takes us no further forward than when we published our 2008 report Existing Housing and Climate Change. In that report, we recommended:

that the Government include specific energy performance improvement standards in any social housing improvement programme that follows Decent Homes in 2010. In particular, we recommend that any future programme contain a specific minimum, rather than average, Standard Assessment Procedure target for all social housing.

We sought the Government's view on the suggestion that that minimum SAP rating should be 65.[151] In its response, the Government said that it would consider whether any future Decent Homes programme could contain a specific minimum SAP target of 65 (or a different figure) as part of a review of relevant standards carried out as part of the review of the financing of council housing which we consider elsewhere in this Report. That work is still going on but, as we agree this Report, has yet to produce an answer.

90.  Witnesses have agreed that the best-understood and most effective energy efficiency standard would be a SAP rating. The SAP rating of 35, currently referred to in the decent homes guidance, is unacceptably low. We accept that raising the bar for all property types to a minimum level which is unachievable for many properties is not the answer but do not consider that this should be used as an excuse for not setting any standards. We recommend that the Government urgently develop a range of minimum SAP ratings for different property types. We further recommend that these minimum SAP ratings be established on a sliding scale over several years to require landlords to meet progressively more rigorous requirements over the next few decades.

The estate

91.  The evidence we received was consistent in its appraisal of the importance of maintaining the areas outside the dwelling, from common parts on estates to communal spaces to whole neighbourhoods and communities. Savills told us that "there are significant pockets of social housing stock throughout the country where the need for environmental improvements/works is arguably more important than the work to the fabric of the properties".[152] The reasons espoused for this were several. We were told by many witnesses that tenants placed a high value on the quality of the external environment. Stoke-on-Trent City Council stated that tenants "would prefer to see significant investment into their local environment" and that "feedback from tenants highlights the importance they place on environmental issues, including external areas, paths and fencing".[153] Mr Peter Morton, Chief Executive of Sheffield Homes, told us that "tenants come out of their homes in Sheffield having had them made decent and they are satisfied, they go outside their front door and they go into an environment which is not decent and that needs fixing".[154]

92.  In addition to fulfilling tenant expectation, witnesses expressed the view that the potential rewards of upgrading external areas were substantial. The Hyde Group stated:

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.[155]

The London Borough of Newham reiterated that "external features often have a role in determining whether housing is perceived as safe and as an attractive place to live; and consequently have an impact on quality of life in an area"[156] and Bolton at Home told us that "the decline of public sector housing caused by under-investment may be checked by improving dwellings up to the presently prescribed decency standards, but can only be permanently reversed if those key socio-economic and environmental areas are also addressed as part of a 'decent communities' approach".[157] It is also clear that some landlords have already incorporated external features into the work that they consider part of their decent homes standard.

93.  There were counter-arguments about whether, notwithstanding the importance of upgrading estates and external areas, the decent homes standard was the correct policy lever by which to get this work done. In the first instance, witnesses were sceptical about whether a useful definition could be produced to create a national minimum standard for areas outside the home. Ridge and Partners stated that while desirable, "this is likely to be almost impossible to define (usefully) in generic terms". This was a function of the wide variety of social housing models: "What works in an inner city estate is probably irrelevant to the country village infill development".[158] Birmingham City Council said "the immediate difficulty to overcome is what to define as the standard, how you would measure such a standard and how would you compare".[159] BRE Housing doubted whether it was possible to set a single standard in this area[160] and in oral evidence Mr Simon Nicol, Director of BRE Housing Group, said that "We would probably spend the first few years defining what a neighbourhood was before we started setting out to measure something".[161]

94.  Some witnesses suggested that improving estates would be better done through measures other than the Decent Homes standard. The Scottish Executive, giving evidence on the equivalent Scottish standard, summed up these arguments when it stated:

The 'need' for minimum housing standards to cover the wider estate as such a standard could be very difficult to draw up, implement, monitor, maintain and finance from rents. That is not to say that the wider environment is not important—it is. However, whether a housing standard is the correct vehicle to do this requires a significant amount of cross-departmental work.[162]

As well as the definitional problems discussed above, witnesses argued that landlords were not always able to influence issues outside the dwelling. SHAL Housing stated that 'the estate' is not within the control of the social landlord"[163] and Fusion 21 warned that:

not all social housing is estate-based and government needs to be aware that, whilst the quality of neighbourhoods is important, few social landlords can have a significant impact on their own. Great care must be taken not to hold social landlords to account for wider neighbourhood/environmental standards which they cannot always influence.[164]

These arguments led Ridge to comment that, rather than include the estate in the standard, it would be preferable to "to encourage a more joined-up approach to estate regeneration and environmental improvement by forcing collaborative working systems (with all social housing providers and local stakeholders contributing)".[165] Mr Nicol concurred, saying "we should be working with tenants in individual situations to determine their priorities and pump money into management, maintenance and those issues that concern tenants, rather than imposing a standard from on high that may not be applicable or particularly useful to tenants on particular estates".[166]

95.  CLG's evidence to our current inquiry demonstrated its awareness of the importance of improving external environments when it told us that tenants "can sometimes ascribe higher importance to the improvements outside their home rather than within".[167] The TSA's draft regulatory framework proposes a standard to cover the quality of the home and to require registered providers to have a repairs and maintenance policy which covers communal areas as well as homes.[168] The framework also proposes a "Neighbourhood and Community" standard requiring housing providers to keep common areas clean and safe, "co-operate with relevant partners to help promote social, environmental and economic well being in the areas where their properties are" and work with other agencies to "prevent and tackle anti-social behaviour in the neighbourhoods where they own homes".[169] The TSA's proposal would require landlords to publish both a neighbourhood policy and an anti-social behaviour policy, agreed with their tenants, and, if tenants so wish, to set local standards in both areas.

96.  Our predecessor ODPM Committee heard many of the arguments about standards for external areas in the course of its inquiry into Decent Homes in 2003-04. The Committee came to the conclusion that it "makes no sense to make internal improvements to homes situated in dilapidated neighbourhoods with unsustainable communities, without also addressing the wider environmental problems".[170] The Report concluded that the funding and policy of creating sustainable communities should be aligned and integrated with the decent homes policy, "so that a home can only be seen as decent if the external environment and neighbourhood are also decent and sustainable" and recommended that a new decent homes standard should include standards for the external environment and communal areas.[171] The Government's response to that Report was non-committal, considering it then "too early" to start establishing a new decent homes standard.[172]

97.  The maintenance of cleanliness, safety and good repair of common parts of estates and communities is of great importance to tenants and makes a substantial contribution to social integration and well-being. We applaud the TSA's recognition of these aspects in its proposed approach to standards and the flexibility it aims to build in to its Neighbourhood and Community standard. We particularly welcome the role which the TSA sees for tenants and other community stakeholders in the process of setting standards locally.

Management of the programme

98.  A ten year policy programme with the budget and reach of the decent homes programme brings with it inevitable challenges of implementation. We discuss some of those challenges here, with the intention of identifying lessons for the future.

THE BACKLOG

99.  CLG has stated clearly that the goal of making all social sector homes decent by 2010 will not be reached. The most recent assessment from the Minister is that 92% of homes will be decent by the end of 2010.[173] The evidence we received from CLG at the beginning of the inquiry attributed this to several factors. 69% of the backlog, we were told, was properties managed by ALMOs. The sequencing of ALMO funding meant that Round 3-5 ALMOs, responsible for 106,700 "backlog" properties, would not complete spending until 2016 and Round 6 ALMOs, responsible for 11,250 properties in the backlog, had had funding deferred, as discussed above.[174] The remaining 31% of the backlogged properties, we were told, were retained by local authorities. The reasons for these authorities not meeting the deadline, CLG said, were "a shortfall in capital receipts as a result of the current economic downturn" and the rejection by some tenants of the local authorities' plans to implement the decent homes programme through stock transfer or creation of an ALMO.

100.  Some of our witnesses disagreed about the likely size of the backlog at the end of 2010. In contrast to CLG's estimate of 8% non-decency, Mr Hand of Ridge and Partners, Mr Sparrow of Savills and Mr Nicol of BRE Housing Group all agreed that the percentage of non-decent social sector homes was likely to be 20-30%.[175] Mr Sparrow told us that this estimate included properties where work had been refused by the tenant, which are not included in CLG's calculation. Mr Nicol said that the rate of improvement had slowed as the properties that were easiest to improve had been dealt with first. He also said that "a lot" of landlords had not taken into account the properties that would move from decent to non-decent during the duration of the programme.[176] He said:

as the Decent Homes work has progressed, other homes have fallen into non-decency, and these have largely not been quantified by a lot of local authorities and social landlords; they have assumed that the work they are doing is fixing the stock whereas in fact there is stuff coming in at the other end, if you like.[177]

101.  Ridge and Partners characterised this issue as a failure throughout the programme to confront the total non-decency levels, which comprise current non-decency levels plus potential non-decency. Ridge explained that the numbers of decent and non-decent properties are in continual flux as non-decent properties are made decent and formerly decent properties become non-decent through age. Ridge stated that the available data had "consistently failed to ask the most important question (in our opinion)—'what is the total non-decency up to 2010?' [total non-decency being the sum of current non-decency + potential non-decency, less any duplicated addresses]". The focus on results or progress in any one given year "is misleading" and that "an organisation may achieve 0% 'currently non-decent' in a year, only to see the database rolled-on at the year end and then all of the next year's 'potentially non-decent' dwellings become currently non-decent one day later".

102.  Ridge and Partners suggested that some providers may have "chosen to manipulate their data in order to produce more pleasing short term results" and that there might be a mounting "time-bomb" of works which will only be evident after 2010. Ridge said that because reporting "is currently constrained to a 2010 deadline the picture of works required beyond this date are unknown". They told us:

Whilst of course not ethical, it is entirely possible that some organisations have chosen to defer work predictions (mostly of 'poor condition') to 2011 or thereafter. In some instances organisations may now be facing a high workload up to 2015, or 2020.[178]

103.  When we took oral evidence from the Minister in December, he used the opportunity to announce a "full-scale assessment" of the programme, telling us that he was "concerned that some local authorities, the poorest performing local authorities, are going backwards".[179] Social landlords are being invited to submit evidence on:

  • how their local standard reflects or exceeds the decent homes standard and where they chose to reprovide homes rather than improve;
  • how they have ensured that their programme offers value for money;
  • details of any 'bolt-on' schemes to their investment programme, e.g. job creation/apprenticeships, community programmes; and
  • any local issues or lessons learnt. [180]

104.  We conclude that the measurement of non-decency should comprise both a snapshot of the current position plus a forecast of potential future non-decency in the next few years, in order to predict future work and spending required. We recommend that the assessment that the Department has been conducting identify the true scale of the backlog of work to achieve the decent homes standard across the social housing stock and provide an accurate picture of what remains to be done. As we recommended above, homes where the tenant has refused decent homes work should not be counted as decent.

ACCESS TO PUBLIC FUNDING FOR DECENT HOMES

105.  The most obvious expected explanation for shortfalls in decency numbers is financial: the argument that there has not been enough money available in time to complete the programme. We consider funding issues in more detail below, including the impact of economic trends over which CLG has had no control. Where CLG has played a key role, however, is in determining what funding has been distributed to whom, and when. This section considers CLG's policy on the means of funding the Decent Homes programme, and its implementation of that policy in respect of arm's-length management organisations (ALMOs) and authorities which chose to retain both the ownership and the management of their housing stock.

106.  We note that some of these issues are discussed in the National Audit Office's recent report,[181] and are considered further in the Public Accounts Committee's follow-up to that report. We concentrate here on the evidence submitted to our own inquiry.

ALMOs

107.  We heard that the treatment of ALMOs by CLG changed as the programme progressed, causing disquiet amongst providers. Sheffield City Council told us that:

Later ALMOs had more flexibility with funding and developed local standards in consultation with tenants. The different treatment between ALMOs across bidding rounds 1-6 started to become divisive in later years. Rounds 3-5 had higher funding through supported borrowing, and greater certainty about completion.[182]

108.  The National Federation of ALMOs (NFA) expressed dissatisfaction about how CLG managed the contribution of ALMOs to the decent homes programme. In particular, the NFA felt that CLG had set short deadlines for providers, missed its own deadlines and changed the timing of the release of funding on several occasions. For example, Gwyneth Taylor, Policy Director of the NFA, told us that local authorities were given a month's notice to apply for Round 6 ALMO funding in June 2006. Authorities were told that CLG would make its approvals of applications by September, but in fact did not do so until March 2008. In addition, the HCA brought forward £100 million of ALMO funding in January 2009; in July CLG deferred £150 million under the Housing Pledge (see above); and in August CLG announced £87 million funding for cavity wall insulation. Meanwhile, as we noted ourselves in an earlier report, a total of £29m over 2006-07 and 2007-08 was transferred out of the Decent Homes ALMO programme and into the budget for the Olympics.[183] The NFA's conclusion was that, while additional funding was welcome, unpredictability of funding made it difficult to plan and spend effectively.[184]

109.  CLG recognised in evidence that the deferral of funding for Round 6 ALMOs had contributed to the backlog of works.[185] When we put the NFA's points to the Minister, he said that "the profile of the Decent Homes Programme investment around the edges has been a bit lumpy". However, he defended the deferral of Round 6 funding as "part of a response to the recession" and said that the decision meant "more money for affordable house-building, and the opportunity for each and every one of these areas to gain a great deal more than they feel they may lose in the short term".[186]

110.  We took oral evidence from one of those ALMOs whose funding had been deferred in Round 6, East Durham Homes. Paul Tanney, its Chief Executive, spoke for all the ALMOs which remained to receive funding when he told us:

[...] what [the Government] needs to do is guarantee Decent Homes funding over the next four to five years, not just for East Durham Homes but for all those ALMOs that have not achieved decent standards. Even with the new proposals for self-financing of the housing revenue account we will not be able to achieve decency in the modelling work we have done without there being separate Decent Homes grant funding.[187]

Later, the Minister repeated the current Government's commitment to funding fully the completion of the Decent Homes programme; but added that "the detail of the commitment and the period will be for the next spending review".[188]

111.  We regret the Government's inability to give a firm commitment now, just a few months from the originally planned end of the Decent Homes programme, on how the funding will be provided to enable the remaining ALMOs that have yet to receive funding to improve decency in their stock. The lack of clarity prevents effective planning by the ALMOs concerned but, more importantly, affects thousands of tenants who continue to have to live indefinitely in non-decent housing. We call on the Government to make clear as soon as possible when the funding will be delivered to achieve the completion of the Decent Homes programme in the ALMO sector.

Retained stock

112.  In some local authority areas lack of tenant support has made it impossible for the council to proceed with the option either of establishing an ALMO or of transferring stock. For example, tenants rejected the councils' proposals in Birmingham and Southwark. Councillor Nick Stanton, Leader of Southwark Borough Council, told us that the Council had "wanted to go for an ALMO or a stock transfer with tenant support" but that "there is no tenant support at all for ALMOs or stock transfer; tenants want to remain council tenants". He said that "whatever consultation exercise we have undertaken it has always resoundingly shown that".[189] Similarly, Birmingham told us that its efforts to persuade tenants of the merits of its options appraisal had been unsuccessful. Councillor John Lines, Cabinet Member for Housing, told us:

In 2001 Birmingham City Council spent £12 million in trying to convince the tenants that they would be better off with an ALMO or any other way than being under the council. The tenants—74,000 of them—said "No thank you".[190]

113.  Witnesses have indicated dissatisfaction first with the policy requirement that in order to be granted significant additional funding, local authorities had to surrender a day-to-day stock management role; and second, that where tenants did not approve a change of management despite the best efforts of the local authority, funding continued to be unavailable. BRE housing group described this as "using the Decent Homes targets as a way of forcing Local Authorities to carry out stock transfers and/or set up ALMOs" and that it had been "deeply unpopular with tenants and staff within these organisations".[191] Ridge described those authorities which had been unable to win tenant support for change as "caught in an impossible situation".[192] In 2004, our predecessor ODPM Committee described the pursuit of this policy as a "dogmatic quest to minimise the proportion of housing stock managed by Local Authorities".[193]

114.  This is not a new issue, and we do not intend to rehearse here the arguments about the Government's commitment to recasting the housing role of local authorities as strategic rather than day-to-day management. There was consensus in the evidence we received, however, that the policy has resulted in some authorities being inadequately funded to meet the decent homes target. CLG said of this group that:

The Department, and latterly the HCA, has been working with the two largest authorities to find innovative funding solutions. The Department, Government Offices for the Regions and the HCA are also actively engaged in discussions with another 10 of these local authorities about how they will deliver the standard in their housing stock.[194]

115.  The Minister stated that "those local authorities that retain their own stock can fund their Decent Homes work through a combination of major repairs allowance, in some cases supported borrowing, in some local authorities capital receipts".[195] Questioned about whether stock transfer would be necessary to enable authorities to meet the Decent Homes standard, he went on to link future funding for this work to reform of the Housing Revenue Account:

Stock transfer is clearly an option and will remain an option for local authorities, but if you look at my written Ministerial Statement on 30 June, I made clear that any future stock transfers will be on terms that are equitable to the basis for local authorities, and their financing under a dismantled and reformed HRA subsidy system. [...] The reform and dismantling of the HRA subsidy system will build into it more money for council housing, more money for maintenance and management, more money for major repairs, and will allow each of the 202 local authorities in the system at present to have the resources over the long term to be able to maintain their homes at a Decent Homes level.[196]

116.  We discuss reform of the Housing Revenue Account elsewhere in this report. Here, we welcome the Minister's suggestion that reform of the HRA will enable all local housing authorities to fund the maintenance of their homes at a decent level. We note, however, that the Minister's replies were significantly weaker on the question of how retention authorities can bring their stock up to that level in the first place. HRA reform will not solve that problem. We call on the Government urgently to set out how, post-HRA reform, authorities which have retained management of their stock will be funded to eliminate the backlog of non-decent housing.

IMPLEMENTATION BY MANAGEMENT ORGANISATIONS

117.  We have heard many positive things about the way in which landlords have implemented the decent homes programme, and the beneficial effects of the Government's pursuit of variety in housing provision through endorsement of stock transfer and creation of ALMOs. The Audit Commission provided us with a comparison of the outcomes of 362 inspections it carried out across all providers between 2006 and 2009, 203 of which included an assessment of social landlords' asset management capabilities. Of the 203 inspections, 113 were of housing associations, 56 were of ALMOs and 34 were of local authority landlords with retained stock. The data are not strictly comparable, as the selection criteria for inspection were different: whereas the local authorities and housing associations were selected for inspection on the basis of risk and so might be expected to have problematic outcomes, all ALMOs are inspected to ensure they reach a two-star rating before funding was released. However, some observations may be made. The Audit Commission advised us that, of the services inspected;

ALMOs deliver major works well and better than other sectors, but slightly worse than their services overall. Housing associations deliver major works better than they do their overall services. Local authority retained services perform considerably worse than ALMOs and housing associations for both major works and overall services.[197]
ALMO inspections  
Overall service rating
 
 
Major works rating
 
 
Good/excellent 
42
 
75.0%
 
39
 
69.6%
 
Poor/fair 
14
 
25.0%
 
17
 
30.4%
 
Total 
56
 
 
56
 
 
Local authority retained inspections       
Good/excellent 
3
 
8.8%
 
7
 
20.6%
 
Poor/fair 
31
 
91.2%
 
27
 
79.4%
 
Total 
34
 
 
34
 
 
Housing Association inspections       
Good/excellent 
39
 
34.5%
 
59
 
52.2%
 
Poor/fair 
74
 
65.5%
 
54
 
47.8%
 
Total 
113
 
 
113
 
 

Source: Audit Commission (BDH 52)

ALMOs

118.  ALMOs have been credited with increasing the quality of housing services, improving the engagement of tenants, improving asset management, achieving efficiencies, bringing in an entrepreneurial attitude and improving value for money. We heard that separation from the local authority enabled decisions to be made more quickly.[198] The funding mechanism, which allocated funds to those ALMOs that attained two stars from the Audit Commission rather than requiring ALMOs to compete against each other, meant that ALMOs had helped each other by sharing experiences.[199] The requirement to attain a two-star status from the Audit Commission in order to access funding was described as "a very, very strong driver".[200] Ridge told us that ALMOs "have increased quality of service in the non-RSL sector and apparently benefit from the segregation from the other duties that local authorities have".[201]

119.  The Audit Commission told us in evidence that the inspection regime had played a significant role in maintaining standards. Not only were ALMOs required to meet a two-star standard before gaining funding, they were also re-inspected within three years to ensure standards were maintained. The attainment of two stars was not "an easy option" and many ALMOs had needed two attempts to succeed.[202] The National Federation of ALMOs told us that ALMOs were required to perform at a two-star level of service but "with the same level of funding and mainly the same staff as the previous local authority housing department" before additional funding was allocated and that, therefore, "it is not just an increase in funding or new staff that makes the fundamental difference to performance" but instead the ALMO structure, "with the focus on performance, delivery and customer service together with a new closer relationship with residents".[203] However, some ALMOs have not yet been able to meet the two stars required to access the funding.[204]

120.  This leads us to consider the future role for ALMOs. The Government has confirmed that it sees a role for ALMOs in the future management of housing stock. CLG stated:

We see a strong future role for ALMOs which are valued by their tenants. We would expect ALMOs to continue to develop their housing management capacity and to look for opportunities to extend the range of services they offer, including to other landlords, where this would improve efficiency and effectiveness.[205]

The National Federation of ALMOs told us, however, that local authorities are reconsidering the future of their ALMOs as decent homes funding comes to an end.[206] The London Borough of Hillingdon has recently decided to close down its ALMO and take the management of its housing stock back in-house.[207]

121.  We conclude that the ten-year experience of ALMOs has generated improvements in asset management of social sector stock that are not simply attributable to additional funding. We further conclude that these improvements should not be lost because of a lack of clear statements by the Government on the future of ALMOs after completion of the decent homes funding already allocated. We recommend that the Government make arrangements for the continued management of housing stock by ALMOs, including by providing for access to funding under the new self-financing system. We consider that local authorities should not take their ALMOs back in-house until they have conducted a ballot of tenants and received an endorsement by tenants of that plan.

Authorities with retained stock

122.  As we have discussed, the Government's policy on decent homes has indicated a lack of conviction in the ability of local authorities to manage stock and implement major repairs. Witnesses to our inquiry have also queried the ability of local authorities to manage their stock with a holistic and long-term view. For example, East Durham ALMO sourced its 90% non-decency rate to the fact that "historically the council was wedded to charging low rents, which meant that there were not sufficient funds to invest in the stock".[208] Savills told us that "there are two areas of weakness that we see within many local authorities, both at a senior level": strategic financing and strategic asset management skills.[209] The Audit Commission told us in evidence that almost half of the councils it inspected between 2003 and 2006 had "poor" services. This meant that:

Most did not have an asset management strategy. Resident involvement was limited, including at a strategic level.[210]

123.  On the other hand, as we have seen, local authorities have not had access to the resources available to other management organisations, and it is difficult to separate out with confidence the reasons for the problems experienced by authorities with retained stock. Southwark Borough Council told us that the decent homes funding it had received was "simply insufficient to do the job for all our investment requirements" and that it had to balance resource needs across a range of housing goals:

We make investment decisions that balance a range of needs and priorities against large but limited resources. These include balancing investment in our stock to meet the Decent Homes standard, our other landlord obligations, and our regeneration commitments […] Decent Homes is therefore not the only call on our limited resources.[211]

124.  We conclude that local authorities with retained stock are capable of effective day-to-day management, but that lessons learned from ALMOs should be applied to improve their results. We further conclude that unless local authorities with and without ALMOs receive the same funding for housing improvements, the results will always be skewed in favour of ALMOs.

Housing association sector

125.  The Audit Commission explained in evidence to us that housing associations fell into two categories. Those which had "had stock for many decades, or which have grown through the acquisition of existing stock" were finding the decent homes standard "more of a challenge" than those which "have grown through building new homes with Housing Corporation, now the HCA, support". However, in general, "across the housing association sector the scale of the challenge, given the access to private finance and average age of stock that is younger, is proportionately less than in the council sector".[212]

126.  Housing associations have been praised for their housing management in our evidence. Witnesses have told us that stock transfer has led to additional monies spent on housing, the creation by RSLs of "more inclusive and customer-focussed cultures",[213] and that housing associations "have an established track record of adapting positively and delivering change resulting from market and regulation needs".[214] Again, the Government has stated clearly that the option of transferring more housing to RSLs remains open in the future. CLG stated:

Transferring to a housing association should also remain an option that council tenants can choose. There are potential benefits from bringing in a not-for-profit body with access to private finance to own and manage the homes.[215]

FUTURE MANAGEMENT OF SOCIAL HOUSING IMPROVEMENT

127.  It may be argued that the particular status of the management organisation does not matter, and that each vehicle for implementing the programme has different strengths and weaknesses. Mr Capie, of the Chartered Institute of Housing, told us that it "does not matter if you have retained stock, it does not matter if you have an ALMO, it does not matter if you have transferred [stock], the debates and arguments should be about how we make sure that all local authorities are delivering that service as well as they should do".[216] Hyde Group told us that the variety of providers was in fact a strength, and that a "variety of delivery options have seen the public, private and voluntary sectors working together to achieve the stated goals".[217] The CIEH and CIH agreed that the key to this was through "a firm commitment on core services, and involving tenants and shaping those core services".[218] BRE Housing Group emphasised the importance of good staff. It said "it is the drive, calibre and vision of the staff (particularly those at the top) that is important in delivering improvements and a quality of service rather than the type of organisation that they work for".[219]

128.  The evidence has argued strongly that the prerequisites for good housing management are: adequate funding; good asset management information, long-term planning and strategy; involvement of tenants and residents in setting priorities; and a clear structure of guidance and expectation. The Tenant Services Authority has proposed a regulatory framework which includes indicators in some of these areas. Its draft standards include Governance and Financial Viability, Value for Money and Tenant Involvement and Empowerment. The draft Tenant Involvement and Empowerment standard requires providers to include tenants and residents in decision-making processes about the management of their homes and the setting and scrutiny of local performance standards, and to publish information about how they are going about this. The Value for Money standard will require providers to publish information about how funds have been allocated to different priorities and why, how value for money has been achieved and tested, and plans for future savings. The Governance and Financial Viability standard, which is expected only to apply to RSLs, will require providers to have "a robust and prudent business planning and control framework" and adopt a code of governance.[220] In addition, the Audit Commission inspects housing providers, working in collaboration with the TSA as its powers come into full force in April 2010. The Audit Commission uses Key Lines of Enquiry (KLOE) to inspect various aspects of housing landlords, one of which is the "Stock investment" KLOE, covering management, repair and improvement of stock.

129.  The question is whether this regulatory framework will be enough, of itself, to raise the game of underperforming organisations, particularly some retention authorities. Regulation and inspection can identify problems: remedying them—or, better, preventing them from happening at all—is another matter. James Sparrow of consultancy Savills, questioned further on Savills' written submission on this point, told us:

I think the point we were saying is that it is getting to the source of the problem rather than simply saying that there is a lack of asset management skills and financial skills in some of these organisations. It is a question of why; and the reason why, particularly in the local authority context, is that there has been no incentive for them to do so. There has been no incentive for local authorities to take a long-term view on retaining their assets. [...] Our view is that only by building in the long-term incentives for organisations to make true asset management decisions [...] will the asset management skill base and the financial skills follow through.[221]

130.  The establishment of ALMOs has significantly improved the performance of council landlords and the requirement to reach a two-star rating of service in order to be granted funding has been a very successful driver of standards of housing management. Some local authorities that have retained day-to-day management responsibilities do not have adequate asset management skills and strategies in place, notwithstanding the existing regulatory framework and inspection regime. Nevertheless we recognise that, for a number of reasons, it is not appropriate for all local authorities which retain ownership of their stock to establish an arm's length body to manage it. We recommend that, rather than take day-to-day management of housing out of the hands of those councils, the Government establish a mechanism to incentivise housing departments of councils to improve their performance in order to receive additional funding. This will put retention authorities on a level footing, in funding terms, with authorities which have established ALMOs, and will help to ensure that those authorities can make the sort of progress to eliminating non-decency in their housing stock which has been achieved by local authorities with ALMOs.

Funding

131.  In our terms of reference for this inquiry, we asked whether management organisations will have sufficient funds to maintain the decent homes standard after 2010. The evidence we have received has also responded to an unasked question: whether the funds provided to date have been sufficient to meet the target in 2010. As we have already mentioned, our focus in this inquiry was firmly on the future of the Decent Homes programme, and we have not therefore looked in detail at past funding. A recent report from the National Audit Office looked at the financing of the programme up to this point; our colleagues on the Public Accounts Committee have recently published a follow-up report.

132.  The Department has clearly stated that it is committed to funding the completion of the decent homes programme beyond 2010 in order to bring all social housing up to the standard, as promised in the target. The Minister told us:

I have said before this Committee, I have said in the House and I have said publicly: we will finish and we will fully fund the completion of the Decent Homes Programme. We will fully fund it. We will complete it, and we are totally committed to it. I said also that the detail of the commitment and the period will be for the next spending review.[222]

The Government has also said that it will provide funding for the maintenance of the standard in the future. It has, furthermore, said that funding will be provided for some areas which might be considered additional to the standard, ie. the maintenance of estates and common areas. It has said that it will consider the application of higher minimum standards, which would have further cost implications.

133.  We have already discussed the issue of the remaining backlog in retention authorities and in ALMOs which have not yet received Decent Homes funding. In this section we look beyond the elimination of the backlog at how decency can be maintained in the long term. The problems that the Government faces in ensuring that its commitment to maintaining the standard can be met vary across housing providers, although the economic downturn has implications across the sector. Below we consider, first, the position in respect of housing associations, and then the rather more complex issues surrounding local authority housing finance. We then go on to consider how the costs of the additional criteria which we have considered might be met.

HOUSING ASSOCIATIONS

134.  The key issues affecting housing associations have centred on the tightening of business plans given the increasing costs of borrowing brought on by the credit crunch. It is not expected that borrowing costs will reduce to their previous low points in the medium term. The reduction in the retail price index, to which rent increases are tied, has also affected short term planning as rent increases are lower than previously expected (as discussed below). Many housing associations have therefore had challenges in looking at the refinancing of their loan books and in taking out new facilities for investment. This affects both new supply and improvement of the existing stock, as the Council of Mortgage Lenders pointed out in their evidence to us:

The reduction in rental income for housing associations will potentially impact on their ability to service existing debt and/or raise additional borrowing to continue to meet the decent homes standard as well as deliver new social housing at this critical time in the recession and future recovery.[223]

135.  However, the primary issue facing housing associations continues to be the balance of spending between those two objectives, building new homes and improving the existing stock. National grant funding via the Homes and Communities Agency for new development has been a key part of the stimulus package within the Government's response to the recession, so up until now funding has continued to flow. However, the future of grant funding in the next comprehensive spending review period and beyond is much less certain. This matters for the achievement and maintenance of the decent homes standard because reducing grants for new build could result in housing associations having to reduce investment in the existing stock as they continue to have to squeeze margins to develop new homes which continue to be badly needed. As surveyor Richard Hand, of Ridge & Partners, told us:

it is about striking the balance between availability of resources and the requirements of the existing assets. It is all good and well investing in new-build property; however, if we cannot maintain the existing assets we will simply create a large catch-up or backlog programme that will have to be dealt with through programmes such as Decent Homes again in the future.[224]

136.  We recognise the pressures facing the Government and the housing association sector in continuing to deliver both new homes and the maintenance and improvement of existing stock. We have previously expressed our continued support for the Government's house-building targets and recognised the need for new homes. Here, we emphasise that the provision of new homes should not be at the expense of the maintenance of existing ones. We support the Government's policy objective of not just a home, but a decent home, for all. As grant and rent policy for the housing association sector evolves and future spending decisions are made, the maintenance and improvement of the existing stock must be given equal priority to the building of new homes.

LOCAL AUTHORITIES

137.  Future funding for the maintenance of standards of decency in the local authority housing sector depend crucially on reform of the Housing Revenue Account (HRA) subsidy system. As we have explained above, the Government has proposed the dismantling of the current revenue subsidy system for the HRA affecting local authorities and their arm's-length management organisations (ALMOs) and its replacement with a system of 'self financing' in which rents and right-to-buy receipts are retained by authorities locally, and no longer pooled nationally. The prerequisite for this reform will be a one-off adjustment to the debt held by each authority, that adjustment to be made on the basis of the redistribution of the total amount of historic debt held by local authorities across England.

138.  The main drivers for reform have been the increasing challenges faced by authorities in planning locally under a system in which government applies very detailed formulae about what allowances are distributed where; and the widespread acknowledgement that the expenditure allowance, particularly the major repairs allowance, is not sufficient to maintain the decent homes standard (once properties have been brought up to the standard). Gwyneth Taylor, Policy Director for the National Federation of ALMOs, told us:

Longer term there is the issue about sustainment of Decent Homes funding post-2010 for those ALMOs and local authorities that have achieved it and that is very much dependent upon the outcome of the finance review and what resources might be made available to enable that to happen. Certainly the current major repairs allowance will not achieve sustainment of Decent Homes, even once backlogs have been met, and some of the early round ALMOs are already in danger of falling back out of decency again, having achieved Decent Homes once already.[225]

139.  Witnesses to our inquiry were generally positive about the potential for HRA reform to improve the ability of local authorities at least to maintain decency standards once achieved. Westminster Council argued that "giving councils control over their own HRA [...] would give certainty [and] the ability to plan and deliver an efficient forward capital programme."[226] Hyde Group said:

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 [reform] may improve the longevity of any new decent homes standard.[227]

The Chartered Institute of Housing suggested that "if local authorities gain financial freedom through the planned HRA reforms, this will help considerably in finding the resources to maintain the local authority stock in the future", pointing out that "Scottish authorities already do this to some extent because of their greater freedom".[228]

140.  However, all such comments were subject to the proviso that there was sufficient money within the reformed system. The Tenant Service Authority's memorandum gave a realistic view of the situation:

The ability of LA landlords to comply with [the Decent Homes] standard depends on their funding position; the proposals for reform of council housing finance offer the prospect of local authorities being in a better position to manage the quality of their housing stock on a more stable and predictable basis, but realising this will depend on the specific outcome of the review.[229]

As CLG's memorandum points out, "In practice, meeting and maintaining the standard depends on funding availability from government or other sources (e.g. rental income or private finance)".[230] Below we consider the two main sources of income for local authorities raised in evidence to us: government subsidy in the form of the Major Repairs Allowance; and rents.

Rents

141.  Rents are subject to a "convergence policy" under which rises are strictly controlled by the Government to ensure, first, continued affordability, and, second, to work towards the alignment of rents in the local authority sector and those charged by housing associations, which are generally higher. Some have argued that there should be a relaxation of rent policy to allow higher rents to be charged in return for higher standards of accommodation. Sarah Webb, Chief Executive of the Chartered Institute of Housing, referring to rent policy across the social housing sector, told us:

It is our firm belief that the time has come for a major rethink on rents generally. We think that there was a strong case for arguing for the rent convergence policy that we have had over the last ten years, but as with all ten year policies, we are getting to the point of having done that, we have reached that point, and we now need to rethink rents. [...] we need a fundamentally new way of looking at rents which allows local authorities, ALMOs and housing associations to reflect local variations and local differences and local offers with tenants in a more [...] adult way than is currently the case.[231]

142.  However, when we questioned him on this possibility, the Minister ruled it out, telling us:

Generally, we have a system for both housing associations and council tenants, which makes sure that the rents continue to be affordable, that the rental stream is capable of supporting the development and improvement in the housing services they required; but essentially it is equal and equivalent for the tenants. I do not see the immediate case for moving away from that presumption of equality within the system, or indeed the imperative to make sure that they remain affordable, and that there is that important gap between the public housing rents and the private sector rents.[232]

He was supported by Peter Marsh, Chief Executive of the TSA, who replied

If the basic premise is that for a set level of rent it is possible to provide a service that includes decency of homes, then the argument for increasing those rents where that cannot be done is questionable [...] There are a number of housing associations and ALMOs and local authorities that have managed to achieve decency within the current rental convergence criteria. There are a number of associations and authorities where rents will be going up, and over the last four years have gone up RPI plus and in some cases RPI plus, plus £2. That rental stream has been sufficient to fund Decent Homes.[233]

Mr Marsh also alluded to another reason why the Government would be reluctant to relax rent controls:

When we are talking about future standards, we also have to bear in mind the cost on the public purse of an increase in rents, bearing in mind HMT foots the bill for a good proportion, something like two-thirds of the cost of rents; so that has to be paid for out of the fiscal envelope.[234]

Major Repairs Allowance

143.  If rent increases are not to fund future achievement and maintenance of decency standards, then what remains is government subsidy, specifically the major repairs allowance (MRA) and management and maintenance allowance, which form part of the HRA subsidy system. The National Federation of ALMOs summed up the general view of witnesses about current levels of these allowances:

The major repairs allowance is nowhere near keeping pace with the requirement to cater for properties that fall outside the decent homes standard post 2010 while management and maintenance allowances are considerably below that which is needed to maintain current levels of service and day to day repairs.[235]

Gwyneth Taylor, the Federation's Policy Director, amplified this in oral evidence:

The original aim of the Decent Homes programme was to fund the backlog and then future properties would not fall out of decency because the major repairs allowance would achieve that. The Government's own review has proved conclusively that the major repairs allowance would need to be dramatically increased, by at least 43 per cent overall but in individual circumstances probably by a significant amount more, in order to sustain Decent Homes longer term.[236]

144.  The Government's proposals for HRA reform recognise that current levels of major repairs allowance are insufficient for decency standards to be maintained in the long term, and include an increase in MRA of 24%. However, the National Federation of ALMOs was not the only witness to our inquiry to express scepticism about whether even that increase would be sufficient. Westminster City Council claimed that "nationally it is now recognised that the Major Repairs Allowance is 40-60% less than required".[237] A 24% increase represents around £825 per property per year. Property consultants Savills said that, based on "over a million surveys in the social housing sector across the country in the last five years", around £1000 per unit per annum would be needed over a 30-year period.[238]

145.  When we put this scepticism to the Minister, he replied:

In the proposals set out at the end of July we are building in an increase of 24 per cent for major repairs into the way we are looking to base the new system and new settlement. That seems to me an adequate provision, one that recognises the ambition to see more money in the system in future; but if these witnesses have made the case that that is insufficient, we will clearly look at that as part of assessing the responses we have had to the consultation.[239]

This response falls short of an absolute assurance that the reformed HRA subsidy system will deliver enough money to ensure that decency standards can be maintained; but we welcome the work the Government has done on reform of the HRA subsidy system and its intention, in principle, to ensure that there is sufficient money within the reformed system to maintain properties at a decent standard. Combined with the improved potential for effective asset management and forward financial planning which witnesses have indicated that properly implemented HRA reform should also bring, this should enable local authority landlords to maintain standards of decency over the long term and prevent any reoccurrence of the backlog which existed at the start of the Decent Homes programme. However, in the absence of detail about the funding that HRA reform will in fact supply for the maintenance of stock, we consider that the convergence policy applied to social rents should be relaxed. The restriction of rent rises has a negative effect on the ability of landlords to set their rents and related standards of service after consultation with tenants.

146.  An additional challenge faced by ALMOs is the inability to plan effectively for future funding. We recommend that the Government give ALMOs the capacity to raise private finance against future rental streams in the context of a 30 year agreement with their local authority.

ADDITIONAL COSTS OF ADDITIONAL CRITERIA

147.  We discussed above the ways in which we believe the decent homes standard should be amended. There are cost implications of those recommendations, which we discuss below.

Carbon dioxide reductions and thermal comfort

148.  Witnesses concurred in describing the cost of meeting the carbon reduction targets nationally through physical adaptations to stock as daunting. West Kent Housing Association stated that "the environmental standards of achieving 80% reduction in carbon emissions by 2050 will require the doubling of expenditure on our existing homes".[240] Circle Anglia described the sums required as "enormous".[241] As for what the cost of this work is likely to be, we received various estimates. The National Housing Federation quoted estimates from their members of £25,000 per property in order to meet 80% carbon reductions targets, "with higher costs in difficult to treat properties such as high rise flats".[242] SHAP's research suggested a cost of between £15,000 and £35,000 per property to achieve an 80% reduction in emissions.[243] The Tenant Services Authority stated that more work needed to be done on the detail of how these costs would be built up.[244] However, the point was also made by some witnesses that energy efficiency measures, while presenting a challenging upfront cost, would themselves generate savings. Professor Power, former Commissioner of the Sustainable Development Commission, told us 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.[245]

The Construction Industry Council referred us to a more optimistic estimate from the Audit Commission, which judged in its report Lofty Ambitions that reducing emissions by 29% could cost nearly £50 billion but "the resulting savings in household fuel bills would equal the investment in eight years".[246] Gentoo told us that fuel savings of 50%-90% could be made, depending on the level of adaptation.[247]

149.  Landlords stated clearly in evidence that they would not be able to bear the costs of a national programme of comprehensive energy efficiency upgrades themselves. Mr John Clayton, Investment Director of Sandwell Homes, told us that "there is precious little funding available for large scale improvements for thermal efficiency in properties".[248] West Kent Housing Association told us that the "substantial increase in the investment [required] cannot be funded through the existing regime of social housing rents and grants without a radical change in government policy".[249] Circle Anglia told us it was "not now able to resource the improvements required to energy efficiency, installation of new technologies and micro-generation equipment to meet a very substantial increase in SAP standards or the carbon emissions reductions currently anticipated without grant funding or a mechanism that allows us to share the costs of improving homes with residents".[250]

150.  There was disagreement about how the necessary funding might be generated. Some considered that the proper source of funding for this work was government grant and direct taxation.[251] Mr Ron Campbell, Head of Policy and Information for National Energy Action, for example, argued:

If we are realistic, there is only one source of funding and it is me and you and everybody else…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.[252]

Others noted the role which energy suppliers were playing, particularly through Carbon Emissions Reduction Target (CERT) programmes.[253] The g15 group of housing associations suggested that the Government should go further and "incentivise energy suppliers to develop schemes that fund enhanced environmental standards, for example the installation of more fuel-efficient boilers with recovery of costs through a combination of tax incentives to the supplier and through an increased standing charge to the customer".[254] Few would suggest that both of these sources of funding—general taxation and contributions from energy suppliers—should not be used. Where disagreement arose was on the question of the extent to which costs might be shared with tenants and residents of homes.

151.  Energy efficiency measures might be expected to reduce an inhabitant's outgoings by reducing energy requirements. Indeed, CLG told us that decent homes work under the thermal comfort criterion had already reduced tenants' fuel bills by an average £173 a year between 1996 and 2007.[255] David Orr of the National Housing Federation told us "all the costs [of energy efficiency adaptations] at present fall on the landlord although all of the benefits rest with the tenant" but that discussions with tenants had generated "evidence that tenants accept the logic of saying that if you have a £5 a week energy saving it is worth paying £3 a week to get that".[256] The Energy Saving Trust referred to the Pay As You Save scheme piloted for owner-occupiers and stated that an equivalent scheme could be constructed to serve those renting homes. It said:

Schemes to pay for energy efficiency improvements in the rented sector could work in a similar way: landlords would make energy efficiency improvements and then charge part or all of the costs back to non-vulnerable tenants as increased rent or service charge. Critically, the aim would be that the tenant should never pay more in increased service charge than they save on their fuel bill.[257]

g15 and Fusion 21 voiced similar sentiments.[258]

152.  On the other hand, National Energy Action—reflecting the view of its head of policy Mr Campbell, noted above—stated that it "[did] not share the view that capital works for improvements in thermal efficiency should be funded through an additional element to rent, services charges, or energy bills" and that "Pay as You Save is not an appropriate approach to delivering higher energy efficiency standards in this segment of the housing stock".[259]

153.  In our Report on the Communities and Local Government Departmental Annual Report 2008, we drew attention to the apparent inequity whereby private tenants could apply for a Warm Front grant to replace an old heating system, whereas a social sector tenant whose heating had not yet been replaced under the decent homes programme would have to wait until the system broke down. We encouraged the Department to consider ways to allow vulnerable people in the social sector access to the same level of assistance as in the private sector.

154.  The Government's Strategy for Household Energy Management proposes a new obligation on energy companies, from 2013, to help householders to save energy, from which it expects "social landlords will benefit".[260] The strategy states that in order to fulfil the obligation, "energy companies will invest in energy saving, including loft and cavity wall insulation and eco-upgrades" and that because "particularly in the early days of the solid wall insulation industry, this funding will be used most cost effectively in large blocks of housing, we expect it to be particularly focused on social housing though it will also be available to provide support more widely". However, it is not clear, even following this new obligation on energy companies, that the inequity to which we drew attention in our earlier Report will be eliminated. We recommend that the Government address this inequity by allowing vulnerable people in the social sector access to the same level of assistance as others.

155.  We conclude that further work is required to calculate the costs of comprehensive work to adapt social housing stock to higher standards of energy efficiency. Whatever the final figure may be, however, it seems clear that it will be well beyond the ability of landlords, householders or energy suppliers alone to fund. A range of funding solutions will be necessary, including—but not limited to—'Pay As You Save'-type schemes.

Improving estates

156.  We discussed above the arguments for including the condition of estates in the decent homes standard, and recommended that standards for estates be agreed locally. Witnesses expressed concerns about how improvements to estates would be funded. Stoke-on-Trent City Council stated that adding the estate to a minimum standard would "have a considerable impact on affordability of future programmes";[261] the Construction Products Association said that "resources will be spread too thinly if minimum acceptable standards are amended to take into account issues such as the estate".[262] The Scottish Executive raised the question of how additional monies should be raised for such purposes, in view of "the tenants' perspective that they should not be expected to pay more than their fair share of broader environmental works though rent". It said:

This issue is difficult because it is the responsibility of local government in general (funded by central government grant and council tax) to maintain the upkeep of the local area for the benefit of all residents, whether tenants or owner occupiers. Right-to-buy has also complicated these issues as all former areas of social housing are to a lesser or greater degree populated by owner-occupiers who stand to gain as much as tenants from improvements to the wider estate.[263]

BRE Housing Group queried whether tenants and leaseholders were "willing and able" to pay extra service charges for such work.[264] Mr Nigel Long, Head of Policy at the Tenant Participation Advisory Service, stated "one of the big debates that is taking place now around the reform of council housing finance is what should be charged to the tenants and what should be charged to the general taxpayer". He said that "most of the problems on the ground require a range of players to be involved, the landlords, the police, health and so on and so forth, probation and what have you" and that "the taxpayer should pick up the bill for all things such as police, rather than things which are direct landlord responsibility".[265]

157.  The Review of Council Housing Finance stated: "We propose funding the ongoing maintenance of lifts and common parts in addition to the decent homes standard". CLG also made a clear commitment in its written evidence to fund necessary works: "We will also improve the common areas of estates and will ensure that there is sufficient funding in the new system to do so",[266] a commitment repeated by the Minister in oral evidence.[267]

158.  We welcome the Government's commitment to the improvement of the common areas of estates, and to ensuring that there is sufficient funding in the new system to do so. The key to this, as to so much else concerning funding of ongoing maintenance of social homes, is reform of the Housing Revenue Account system. We look forward to seeing a reformed HRA which ensures that sufficient funding is available for the necessary work without placing too great a burden—in the form of increased rents or service charges—on individual residents of social housing. The 30-year business plans prepared by individual local authorities under a reformed HRA system will need to assess the potential contributions from all sources to the maintenance of common areas, and build in sufficient resources to maintain them to a decent standard.

159.  The ALMO sector faces another difficulty in making improvements to estates: ALMO budgets allow only 5% of funding to be spent on measures other than on the fabric of the home. We consider the restriction of ALMO spending on estates or communal areas to 5% of their budgets to be unreasonable, and recommend that the Government introduce greater flexibility to allow ALMOs to spend a greater proportion of funds on these measures as necessary.


44   CLG, Live tables on stock, Table 119, Stock of non-decent homes1 in the Social Rented Sector, England, available at www.clg.gov.uk. Back

45   IbidBack

46   Ev 165 Back

47   Q355; "Minister launches full assessment of the decent homes programme", CLG Press Notice,8 December 2009. Back

48   Q 395 Back

49   Ev 97 Back

50   Ev 118 Back

51   Q 332 Back

52   Ev 129 Back

53   Department of the Environment, Transport and the Regions, Department of Social Security, Quality and Choice: A Decent Home for All, April 2000, p. 60. Back

54   Quality and Choice: A Decent Home for All, p. 17. Back

55   NAO, The Decent Homes Programme, Session 2009-10, 21 January 2010, HC 212, p. 14. Back

56   Ibid.  Back

57   IbidBack

58   IbidBack

59   CLG, A Decent Home: Definition and guidance for implementation, June 2006 - Update, June 2006, p. 11. Back

60   Office of the Deputy Prime Minister, Housing Health and Safety Rating System Operating Guidance, Housing Act 2004 Guidance about inspections andassessment of hazards given under Section 9, February 2006, p. 8. Back

61   Ev 97 Back

62   Ev 100 Back

63   Ev 71 Back

64   Ev 114 Back

65   Ev 97 Back

66   Q 6 Back

67   Ev 97 Back

68   IbidBack

69   CLG, A Decent Home: Definition and guidance for implementation, June 2006 - Update, June 2006, p. 11. Back

70   CLG, A Decent Home: Definition and guidance for implementation, June 2006 - Update, June 2006, pp. 11-12. Back

71   Ibid. p. 17. Back

72   Ev 80 Back

73   Ev 94 Back

74   Ev 97 Back

75   Q 41 Back

76   CLG, A Decent Home: Definition and guidance for implementation, June 2006 - Update, June 2006, p. 12. Back

77   Ev 73 Back

78   Ev 73 Back

79   CLG, A Decent Home: Definition and guidance for implementation, June 2006 - Update, June 2006, p. 18. Back

80   CLG, Housing Health and Safety System Guidance for Landlords and Property Related Professionals, May 2006, p. 23. Back

81   Ev 97 Back

82   Ev 277 Back

83   Ev 100 Back

84   National Energy Action, Submission to Department of Communities and Local Government Consultation: Reform of council housing finance. Back

85   Ev 94 Back

86   Ev 294 Back

87   Ev 277 Back

88   Department of Energy and Climate Change, Annual Report on Fuel Poverty Statistics 2009, p. 2, available at www.decc.gov.uk. Back

89   Ev 78 Back

90   Ev 86 Back

91   Q 236 Back

92   Ev 263  Back

93   Ev 129 Back

94   Ev 137 Back

95   Ev 331 Back

96   Ev 89 Back

97   Ev 91 Back

98   Ev 118 Back

99   Ev 285 Back

100   Ev 134 Back

101   Ev 285 Back

102   Q 333 Back

103   Ev 331 Back

104   Q 3 Back

105   Q 252 Back

106   Qq. 252-255 Back

107   Ev 102 Back

108   Ev 165 Back

109   Ev 76 Back

110   Ev 86 Back

111   Ev 137 Back

112   Ev 161 Back

113   Communities and Local Government Committee, Seventh Report of Session 2007-08, Existing Housing and Climate Change, HC 432-I, para 2. Back

114   Department of Energy and Climate Change, The UK Low Carbon Transition Plan: National strategy for climate and energy, 15 July 2009, p. 22. Back

115   Ev 161 [Sustainable Development Commission]. Back

116   Communities and Local Government and Department for Energy and Climate Change, Warm Homes, Greener Homes: A Strategy for Household Energy Management, 2 March 2010. Back

117   CLG, Community, opportunity, prosperity: Annual Report 2009, Cm 7598, July 2009, p. 81. Back

118   CLG, Community, opportunity, prosperity: Annual Report 2009, Cm 7598, July 2009, p. 14. Back

119   Ev 145 Back

120   Ev 86 Back

121   Ev 161 Back

122   Ev 331 Back

123   Ev 70 Back

124   Ev 102 Back

125   Q 249 Back

126   Ev 285 Back

127   Q 159 Back

128   Q 249 Back

129   Communities and Local Government Committee, Existing Housing and Climate Change, para 71. Back

130   Ev 129 Back

131   Q 161 Back

132   Ev 91, Ev 111. Back

133   Ev 285 Back

134   Q 160 Back

135   Ev 129 Back

136   Q 244 Back

137   Ev 129 Back

138   Ev 331 Back

139   Ev 151 Back

140   Q 330 Back

141   Ev 89 Back

142   Ev 111 Back

143   Q 237  Back

144   Q 226 Back

145   Ev 161 Back

146   Ev 265 Back

147   Q 160 Back

148   Q 326 [Mr Nicol] Back

149   Ev 277 [Association for the Conservation of Energy] Back

150   Ev 331 Back

151   Communities and Local Government Committee, Existing Housing and Climate Change, para 26. Back

152   Ev 285 Back

153   Ev 78 Back

154   Q 114 Back

155   Ev 129 Back

156   Ev 131 Back

157   Ev 271 Back

158   Ev 118 Back

159   Ev 260 Back

160   Ev 263 Back

161   Q 325 Back

162   Ev 328 Back

163   Ev 70 Back

164   Ev 111 Back

165   Ev 118 Back

166   Q 325 Back

167   Ev 165 Back

168   TSA, A new regulatory framework for social housing in England: Summary, November 2009, p. 12. Back

169   TSA, A new regulatory framework for social housing in England: Summary, November 2009, p. 17. Back

170   ODPM: Housing, Planning, Local Government and the Regions Committee, Decent Homes, para 87. Back

171   Ibid., paras 87, 92. Back

172   Office of the Deputy Prime Minister, Government Response to the ODPM: Housing, Planning, Local Government and the Regions Committee's Report on Decent Homes, Cm 6266, July 2004, p. 7. Back

173   "Minister launches full assessment of the decent homes programme", CLG Press Notice, 8 December 2009. Back

174   Ev 165 Back

175   Qq 323-4 Back

176   Q 324 Back

177   Q 324 Back

178   Ev 111 Back

179   Q 395 Back

180   "Minister launches full assessment of the Decent Homes programme", CLG press notice, 8 December 2009. Back

181   NAO, The Decent Homes Programme, Session 2009-10, 21 January 2010, HC 212, paras 2.8-10. Back

182   Ev 275 Back

183   Communities and Local Government Committee, Second Report of 2008-09, Communities and Local Government's Departmental Annual Report 2008, HC 238, paras 44-46. Back

184   Q 281 Back

185   Ev 165 Back

186   Qq 365-6 Back

187   Q 277 Back

188   Q 360 Back

189   Q 93 Back

190   Q 96  Back

191   Ev 263 Back

192   Ev 118  Back

193   ODPM: Housing, Planning, Local Government and the Regions Committee, Decent Homes, Summary. Back

194   Ev 165 Back

195   Q 367 Back

196   Qq 368, 370. Back

197   Ev 297 Back

198   Q 266 [Ms Taylor] Back

199   Q 282 [Ms Taylor] Back

200   Q 14 [Mr Capie] Back

201   Ev 118 Back

202   Ev 297 Back

203   Ev 281 Back

204   Ev 145 [CIH] Back

205   Ev 165 Back

206   Ev 281 Back

207   "Hillingdon reclaims homes from Almo", Local Government Chronicle, 19 February 2010. Back

208   Q 261 [Mr Tanney] Back

209   Ev 285 Back

210   Ev 297 Back

211   Ev 134 Back

212   Ev 297 Back

213   Ev 91 [Gentoo] Back

214   Ev 94 [West Kent Housing Association] Back

215   Ev 165 Back

216   Q 14 Back

217   Ev 129 Back

218   Q 14 Back

219   Ev 263 Back

220   TSA, A new regulatory framework for social housing in England: Summary, November 2009. Back

221   Q 336 Back

222   Q 360 Back

223   Ev 144  Back

224   Q 341 Back

225   Q 258 Back

226   Ev 137 Back

227   Ev 129 Back

228   Ev 145 Back

229   Ev 265 Back

230   Ev 165 Back

231   Q 20 Back

232   Q 375 Back

233   Qq 376-7 Back

234   Q 377 Back

235   Ev 281 Back

236   Q 259 Back

237   Ev 134 Back

238   Qq 344-5 Back

239   Q 378 Back

240   Ev 94 Back

241   Ev 86 Back

242   Ev 155 Back

243   SHAP, Moving Beyond Decent Homes Standard 2009: Creating the low carbon standard for social housing, 1 October 2009, p. 17.  Back

244   Ev 265 Back

245   Q 250 Back

246   Ev 294 Back

247   Ev 91 Back

248   Q117 Back

249   Ev 94 Back

250   Ev 86  Back

251   Ev 70 [SHAL Housing], Q159 [Mr Orr] Back

252   Q 249 Back

253   Mr Sharpe Q 249, BDH 33 [Energy Saving Trust]. The Carbon Emissions Reduction Target, which came into effect in April 2008, obliges energy companies to take steps to ensure that the amount of carbon dioxide emissions from homes is reduced. Under CERT, energy suppliers provide grants and offers to help pay for energy efficiency measures and renewable energy technologies for the home. CERT will be in effect for three years, with the target of making an annual net saving of 4.2 million tonnes of carbon dioxide by the end of the programme. For further details, see www.energysavingtrust.org.uk.  Back

254   Ev 89 Back

255   Ev 331 Back

256   Qq157-8 Back

257   Ev 151 Back

258   Ev 97, Ev 111. Back

259   National Energy Action, Submission to Department of Communities and Local Government Consultation: Reform of council housing finance. Back

260   Department of Energy and Climate Change, Communities and Local Government, Warmer Homes, Greener Homes, p. 7-8. Back

261   Ev 78 Back

262   Ev 122 Back

263   Ev 328 Back

264   Ev 263 Back

265   Q 50 Back

266   Ev 165 Back

267   Q 370 Back


 

 
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