Memorandum from Sandwell Metropolitan
Borough Council (BDH 16)
1.0 SUMMARY
1.1 This response is limited to bullet points
6 and 7 of the CLG Call for evidence dated 22 July 2009,
namely those relating Decent Homes in the private sector and regulation
of minimum standards.
1.2 The key points are:
— Private sector housing represents the
overwhelming tenure type in the country yet there are no significant
targets set in terms of attaining decency in this sector;
— Funding for decent homes in the private
sector has declined rapidly in recent years and is set to decline
further with the emphasis shifting further to building new homes;
— The recent credit crunch has meant many
existing home owners are unable to access funding to undertake
essential repairs and are excluded from other tenure options due
to lack of choice or affordability;
— Non decent private homes have a significant
impact on the health service, the economy, education and social
inclusion and neglecting this sector is storing up problems for
the future;
— Specific problems exist in the private
rented sector, which has seen a rapid expansion in recent years,
and the recent messages from Government about delays in implementing
proposals from the Rugg review are disappointing in that respect;
— The Thermal Comfort element of the Decent
Homes standard is low and should be reviewed.
2.0 DETAILS
2.1 Approximately 80% of the homes in England
are privately owned, representing some 17.6 million homes.[13]
2.2 Of these, 35.8% (6.5 million homes),
are estimated to be non decent compared to 29.2%, just over 1 million
homes in the social sector.[14]
Significantly over 45% of homes in the private rented sector were
estimated to be non decent even though this only accounts for
12% of the stock nationally.
2.3 In 2007, 39% of vulnerable households
in private sector housing were living in non decent homes rising
to almost 52% in the private rented sector compared to 28% in
social housing.
2.4 Despite this no national indicator exists
in respect of decent homes in the private sector.
2.5 National Indicator 158 requires
Local Authorities to set targets in reducing the number of non
decent Council homes and include these within its Local Area Agreement
but this indicator makes no reference to the private sector.
2.6 This authority has seen funding specifically
for private sector decent homes within the Regional Housing Pot
reduce from £6.7 million in 2006-07 to £1.2 million
(through the regional Kick Start partnership) in 2009-10. It has
also been advised that private sector renewal is likely to be
reduced further in future years to fund the Government's commitment
to new homes.
2.7 Whilst we have made significant progress
in tackling non decent homes locally, achieving the PSA7 target
of 70% of vulnerable households in decent homes, there are still
significant challenges in the private sector housing market.
2.8 Our most recent stock condition survey
suggests that over £236 million is required to ensure that
all privately owned homes in the Borough meet the Decent Homes
standard.[15]
2.9 Whilst we agree with the Government's
position, in fact it is a fundamental principle underpinning our
private sector housing strategy, "that it is primarily the
responsibility of private sector owners to maintain their own
property",[16]
in a borough where nearly 40% of private properties are occupied
by a vulnerable household[17]
this will be a significant challenge for many home owners.
2.10 The recent financial crisis has exacerbated
this position, not only restricting access to borrowing for people
seeking to buy new homes but also to those looking to improve
their existing home through a combination of more reluctant lenders,
reduced market values (and hence free equity to borrow against)
and lower incomes.
2.11 The Council is able to assist many
of those who are "equity rich but cash poor" through
the West Midlands Kick Start scheme, there is a significant and
growing number that have insufficient equity to access such loans
but require urgent works to protect their health and safety.
2.12 Older housing, with greater maintenance
requirements, is concentrated in the private sector, so failure
to invest now will inevitably lead to a storing up of problems
that will require larger scale investment to remedy in the future.
Our survey revealed nearly 25% of homes failed the repair element
of the decent homes standard, with a further 5% of homes having
category 2 hazards under the Housing Health and Safety Rating
System (HHSRS) both indicators of under investment.
2.13 Furthermore, our survey suggested that
only 14% of homeowners currently living in a non decent home would
have sufficient income to carry out the repairs required, meaning
financial assistance, be it in the form of grants or supported
loans, is required for the remainder.
2.14 Whilst it could be argued that supporting
such owners is not sustainable it must be recognised that access
to other forms of tenure is not a realistic option. Demand for
social housing has increased considerably over the last two years
with on average over 200 applicants for every property that
becomes available.
2.15 In this environment the Council has
had to become ever more creative in how it accesses finance for
private sector renewal. Significant lobbying has resulted in NI187 (fuel
poverty) being accepted as one of the 35 key indicators in
our Local Area Agreement and a wide variety of partners provided
funding for our services including the Primary Care Trust, Working
Neighbourhoods Fund, The Housing Market Renewal Area, Kick Start
and the New Deal for Communities.
2.16 This reflects the high priority placed
on supporting vulnerable home owners regionally and locally that
is not reflected in a national indicator for such work.
2.17 The HHSRS specifically links housing
defects to the health and safety of the most vulnerable occupier.
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,
the cost to other services of which can also be shown using tools
such as the Chartered Institute of Environmental/Building Research
establishment cost calculator.[18]
2.18 Private Sector renewal also benefits
the local economy, primarily through employment and training opportunities
for local contractors but also by providing increased confidence
in run down areas, raising market values and providing more disposable
income to occupiers. The latter is particularly true of energy
efficiency measures.
2.19 The private rented sector continues
to grow, and whilst the vast majority of such properties offer
decent accommodation there are considerable issues at the bottom
end of the market.
2.20 The 2007 EHCS indicates that almost
52% of vulnerable households in the private rented sector lived
in a non decent home. The private rented sector also had double
the proportion of properties with the lowest energy efficiency
assessments and almost a third of privately rented homes have
a category 1 hazard under the HHSRS compared to one fifth of owner
occupied homes and a tenth of social homes.
2.21 In this context it is disappointing
to read recent announcements from CLG that there are no plans
to publish a Housing Green Paper taken forward the recommendations
of the Rugg Review at this moment in time.[19]
2.22 A SAP rating of less than 35 has
been set as a proxy for the likely presence of a category 1 hazard
under the HHSRS for excess cold and this is also relevant to the
assessment of the thermal comfort element of the decent homes
standard.
2.23 However, there is considerable scope
to extend the requirements of this part of the standard. Currently
a dwelling could pass this element if it has programmable gas
heating to only two rooms and either cavity wall insulation
or 50mm loft insulation.[20]
2.24 This level of provision will do little
to help the Government meet its own targets around eradicating
fuel poverty and reducing CO2 emissions.
2.25 The National Indicator relating to
fuel poverty has two elements—a reduction in the number
of vulnerable households living in properties with a SAP of less
than 35 and an increase in the number where SAP exceeds 65.
2.26 Whilst a SAP of above 65 may not
be achievable in all circumstances it would seem logical to amend
the Decent Homes guidance to make this a target of refurbishment
wherever possible. In some cases this might mean the provision
of renewable sources of energy such as solar water heating something
which is completely absent from the current standard.
3.0 CONCLUSIONS
AND RECOMMENDATIONS
3.1 National Indicator 158 should be
amended to make specific reference to non decent homes in the
private sector analogous to the targets set in the former Public
Service Agreement (PSA) 7.
3.2 A Housing Green Paper should be brought
forward as soon as possible to implement the recommendations of
the Rugg Review into the private rented sector.
3.3 The Thermal Comfort element of the Decent
Homes standard should be reviewed to bring it more into line with
the Governments targets for eradicating fuel poverty and reducing
CO2 emissions.
September 2009
13 English House Condition Survey 2006 Annual
Report, Communities and Local Government Back
14
English House Condition Survey 2007 Headline Report, Communities
and Local Government Back
15
Sandwell MBC Private Sector Housing Stock Condition Survey 2009 Back
16
ODPM Circular 05/2003 Housing Renewal Back
17
Defined as being in receipt of at least one of the principle means
tested or disability related benefits Back
18
Good Housing Leads To Good Health: A toolkit for environmental
health practitioners, BRE 2008 Back
19
Environmental Health News 24 August 2009 Back
20
A Decent Home: Definition and guidance for implementation June
2006 update, CLG Back
| 
