Memorandum from West Kent Housing Association
(BDH 13)
DECENT HOMES
1.0 Summary
1.1 This is West Kent Housing Association's
response to Communities and Local Government Committee's inquiry
on Beyond Decent Homes: Decent homes standards post 2010
1.2 The summary of key issues raised in
this paper is:
— A holistic approach to decent homes over
a longer period of 20 years would have achieved better value for
money.
— Decent homes standards should be outcomes
focused.
— Decent homes standards should not include
provision of modern facilities which are defined by age rather
than condition.
— The minimum acceptable housing standards
across all tenures should be considered for amendment to take
account of environmental standards, fuel poverty and the estate.
Social housing should not be singled out. Raising minimum housing
standards should be considered and balanced in the wider context
of social policy and its adverse impact on rent affordability,
worklessness and poverty trap.
— Higher environmental standards cannot
be funded out of existing income streams and asset values of housing
associations without a change in government policy on rents, service
charges and grants.
2.0 What lessons can be learned from the decent
homes programme and equivalents in Scotland, Wales and Northern
Ireland?
2.1 The 2010 target was too short (10 years)
compared with the life cycles of most of the key components in
buildings. A holistic approach over a longer time period (20 years)
identifying the improvements and replacements necessary to achieve
the decent homes standard would have resulted in fewer premature
renewals and replacements and therefore better value for money.
The just in time strategies for replacements enable more effective
use of resources and reduce the costs associated with achieving
and sustaining decent homes.
2.2 The decent homes standards in some cases
are too prescriptive and concentrate on inputs rather than specifying
outcomes. For example, criteria D (providing a reasonable degree
of thermal comfort) specifies the different thicknesses of loft
insulation for gas and electrical heated properties.
2.3 I believe that timed replacements of
kitchens, bathrooms etc specified in Criteria C (provision of
modern facilities) should not form part of minimum Decent Homes
Standards. Modernity is a matter of opinion and fashion as such
is best determined by customer choice rather than regulation standards.
2.4 Beyond 2010 all landlords should be
required to maintain all their homes to the decent homes standards.
A tolerance margin needs to be considered to allow a reasonable
period (say maximum of a year) for replacing components as they
fail.
3.0 Should minimum acceptable social housing
standards be amended to take account of environmental standards,
fuel poverty and the estate?
3.1 The minimum acceptable housing standards
across all tenures should be considered for amendment to take
account of environmental standards, fuel poverty and the estate.
Raising minimum housing standards should be considered in the
wider context of social policy. The impact of higher housing standards
and therefore its costs needs to be considered and balanced particularly
in respect of:
— Social housing rent affordability.
3.2 For example the environmental standards
of achieving 80% reduction in carbon emissions by 2050 will require
the doubling of expenditure on our existing homes. This substantial
increase in the investment cannot be funded through the existing
regime of social housing rents and grants without a radical change
in government policy. Even if the government policy was changed
to allow for recovery of such investment through rents and service
charges, the increase in housing costs will have an adverse impact
on the poverty trap and worklessness.
4.0 Are adequate arrangements in place for
the future regulations of minimum acceptable housing standards?
4.1 Yes. We favour a move towards less regulation
and a move towards more outcomes focused regulation
5.0 Do the management organisations—councils
including via ALMO's and housing associations—need to change,
will they have sufficient funds?
5.1 The housing associations have an established
track record of adapting positively and delivering change resulting
from market and regulation needs. The increased financial pressures
resulting from 80% carbon reductions will require a reshaping
of the government policy on funding the management organisations
as such changes cannot be funded from existing income streams
and asset values. Carbon reduction grants may need to be increased
to ensure that social housing rents remain affordable and do not
adversely impact the worklessness and the poverty trap.
6.0 Are there local examples of innovative
best practice with wider post-2010 applicability?
6.1 West Kent Housing Association have developed
and implemented the following strategies, policies and arrangements
to deliver services which have very high resident's satisfaction,
high quality and reducing real costs:
— Lean Just in Time asset management strategy
which has reduced our costs by about 12.5%.
— West Kent's unique partnering arrangements
with our contractors which have enabled a flexible and prompt
response on all works whilst substantially reducing cost in real
terms over the last four years.
6.2 We believe that our Lean Just in Time
asset management strategy and our open book cost reimbursable
partnering arrangements are replicable and would offer efficiencies
to most management organisations.
September 2009
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