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
Ibid. Back
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
Ibid. Back
58
Ibid. Back
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
Ibid. Back
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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