Memorandum from The Hyde Group (BDH 24)
1. INTRODUCTION
AND SUMMARY
1.1 The Hyde Group (Hyde) is one of the largest
housing associations in the county. We own or manage more than
40,000 properties, allowing more than 120,000 people to make their
home with Hyde.
1.2 The following is a summary of Hyde's response:
— Any new decent homes standard should
focus on the energy efficiency of homes. This should be measured
through the SAP ratings of the property.
— Any new standard will need to be sufficiently
funded by Government with a realistic timescale for completion.
It is unlikely that all the funding streams used to complete Decent
Homes works will be available to a new standard.
— A new standard should not be too onerous
on landlords, and be able to be easily included into existing
asset management strategies.
— A new standard should consider the estates
and common areas surrounding homes. However, defining a specific
standard for this may prove difficult, and opinions of local residents
should always be taken into account. Redevelopment should be available
as an option alongside further investment.
— The behaviour of society must be taken
into consideration when trying to become more energy efficient
and reduce carbon emissions. Any energy efficiency target must
take this into consideration, with funding made available to educate
residents on how any new technologies can be used most effectively.
2. What lessons can be learned from the Decent
Homes Programme?
2.1 The Decent Homes Programme was successful
in improving the standards of social homes. The Programme had
clear, achievable targets on a realistic timescale. It was well
backed by financial resources, giving landlords means from which
to deliver the aims of the Programme. However, responsible social
landlords would have undertaken much of this work anyway and that
requiring them to accelerate often substantial repairs/improvements
to meet the imposed deadline may not always have resulted in the
most cost effective approach.
2.2 A whole supply chain developed capacity
to deliver the Programme, providing employment for thousands of
people. A number of maintenance contractors transformed their
businesses on the back of the Programme, forming a mini-economy
with suppliers of new kitchens, bathrooms and windows.
2.3 Hyde, like many social landlords, ensured
that a local labour clause was included in delivery contracts.
This provided much needed employment to some of the most deprived
areas of the country, helping to improve the economic and social
well being of areas alongside the physical elements.
2.4 One of the great successes of the Decent
Homes Programme has been the variety of ways in which the aims
have been achieved. A variety of delivery options have seen the
public, private and voluntary sectors working together to achieve
the stated goals. Of particular success has been the ability of
housing associations to use private investment to improve social
homes.
2.5 Conversely, the application of a Decent
Home Standard to the private sector has been less successful.
A shortage of available funding and weak legislative powers meant
that there was a lack of imperative to make the necessary improvements.
If new minimum standard were to be introduced to the private sector,
greater incentives would be needed to ensure the homes were improved.
2.6 The Decent Homes Standard focussed on the
internal aspect of homes, paying little regard to the design,
construction or materials used in their development. In some instances,
Decent Homes works were completed in homes that were no longer
fit for purpose, ahead of alternative strategies such as demolition
and rebuild. Any new decent standard should ensure that long term
investments are not made into homes where other options for their
future may be more appropriate.
2.7 A new minimum standard should be based on
a more straight-forward scoring system that recognises different
stock has different potential for improvement. Assessment criterion
should be less subjective (reasonable) and perhaps not allow landlords
to trade off one facility/component against the other, as with
criterion B and C of the current Decent Homes programme. 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.
3. How should the back log of Decent Homes
works be addressed?
3.1 Hyde does not have a backlog and we are
confident that all of our homes will meet the standard by the
end of 2010. However for those Local Authorities and ALMOs who
will miss the target, the backlog could be addressed in a number
of ways. The review of council housing finance through the Housing
Revenue Account system may go some way to ensuring that local
authorities can meet their decent homes targets. However, it may
take some time to achieve the targets, and a new timescale would
need to be agreed with each local authority.
3.2 Indeed, given that the council housing finance
review may take some time, other options may need to be pursued.
One option could be to transfer non-decent local authority or
ALMO homes to a housing association with a proven track record
of delivery. The association would then be able to raise the private
finance to complete the works in a shorter timescale.
4. Should a new minimum standard include
environmental standards, fuel poverty and the estate?
4.1 "Environmental standards"
could mean a very wide range of measures. There is no widely used
and accepted means of measuring environmental performance, with
the BRE's EcoHomes XB being one of the only schemes available,
although it has some deficiencies and is not in widespread use.
4.2 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 resident's incomes could make this extremely
complex.
4.3 We propose that any new standard should
be focussed on energy efficiency, using SAP ratings. Following
the introduction in October 2008 of mandatory Energy Performance
Certificates, supply chains have been developed and an increasing
amount of data accumulated.
4.4 In order to achieve greater energy efficiency
and reduce carbon emissions, society must change behaviours and
attitudes towards the consumption of fuel and energy. As a landlord,
Hyde are in a unique position to help our residents change behaviours
towards energy use, and urge the Government to investigate how
funding could be targeted to achieve this aim.
4.5 Please note our comment at 2.6 above, based
on our thoughts that some Decent Homes works were made to homes
where redevelopment may have been a more appropriate option. However
we do not believe that it is practical to attempt to define in
a mandatory Standard what constitutes an acceptable place to live.
Ultimately, only residents themselves can judge this. What is
important is that mechanisms are put in place through which residents
are able to propose demolition and redevelopment as options and
for there to be funding mechanisms to achieve this if this is
their choice.
4.6 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.
It is therefore very important that common areas are secure and
maintained to a high standard at all times, and that measures
are in place to act quickly to return an area to a high standard
should it become victim of vandalism. This approach has been proven
to work in many areas, and though it can prove expensive initially,
as an investment, it contributes significantly to longer term
sustainability, reducing overall costs over time.
4.7 When developing a standard for energy efficiency,
the age of the properties needs to be considered. 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. Owner occupiers of such
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.
5. Do the management organisations need to change?
Will they have sufficient funds?
5.1 The Decent Homes standard was achieved by
providing access to a variety of funding streams. One option was
to transfer Council stock over to a Registered Social Landlord
(RSL) who could then raise the necessary private finance to complete
the works. Much of this stock will now be geared to such an extent
that raising further finance to complete new works may be problematic.
Therefore, extra funding will need to be given to any new standard
to ensure that it is achieved in a timely fashion.
5.2 Hyde, along with all RSLs, has a robust strategic
approach in place to ensure that all its properties are maintained
to an acceptable standard. Incorporating a new minimum standard
into this strategy would be relatively simple, so long as the
standard is not too onerous.
6. What are the implications for decent housing
standards of the Government's proposal to move to a devolved system
of council housing finance?
6.1 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 may improve the longevity of any new decent homes
standard.
7. How should the Decent Homes target for private
sector homes occupied by vulnerable people be taken forward?
7.1 If private sector landlords or homeowners are
having difficulties in bringing their properties up to Decent
Homes standard, there may be an opportunity to transfer these
properties to an RSL or local authority to complete the works.
8. Are adequate arrangements in place for the
future regulation of minimum acceptable housing standards?
8.1 There is a sufficient regulatory regime
in place for any future minimum housing standard in the social
housing sector. The Tenants Services Authority (TSA), and its
predecessor the Housing Corporation, have been successful in monitoring
the number of homes still awaiting Decent Homes works.
8.2 Further consideration is needed as to how a new
minimum standard would be regulated in the private sector.
9. Are there local examples of innovative best
practice with wider post-2010 applicability?
9.1 Hyde has a number of innovative projects
under development which may have post-2010 applicability. We would
be happy to share
9.2 Our Retrofit and Replicate 2 project on
the Progress estate in Greenwich has just secured Government funding
to develop its designs. Our designs are for two properties, built
c 1915, at the tail end of Garden City movement. The properties
are in a Conservation Area since 1970s and also have further Article
4 directive restrictions. One property will be void, and one tenanted,
to highlight differences in what can be achieved between the two
types of properties.
9.3 Our Beyond Decent Homes pilot project is
still in an early planning stage. The project's main aim is to
achieve a reduction of carbon emissions across a housing estate
through improvements to the building fabric and working with residents
to improve behaviours. We intend to focus improvement works on
a small block of flats (15-20 units) which has had Decent Homes
works. The intention is to consider the practicalities of how
to upgrade properties without removing the Decent Homes improvements.
We plan to have a resident engagement strategy for the whole estate,
ensuring that tenants have as much information as possible on
how to reduce their carbon emissions. We will work with residents
to encourage lifestyle changes, and hope that not only will they
see a reduction in carbon emissions, but also a reduction in their
fuel bills.
September 2009
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