Memorandum from the Local Government Association
(LGA) (BDH 42)
The Local Government Association (LGA) Group
welcomes the opportunity to respond to the consultation "Beyond
Decent Homes: decent housing standards post 2010" issued
by the CLG Select Committee.
The LGA group is made up of six organisations:
the LGA, Improvement and Development Agency, Local Government
Employers, Local Authorities Co-ordinators of Regulatory Services,
Local Partnerships, and Leadership Centre for Local Government.
The LGA is the single voice for local government.
As a voluntary membership body, funded almost entirely by the
subscriptions of our 424 member authorities in England and Wales,
we lobby and campaign for changes in policy and legislation on
behalf of our member councils and the people and communities they
serve. We work with and on behalf of our membership to deliver
our shared vision of an independent and confident local government
sector, where local priorities drive public service improvement
in every city, town and village and every councillor acts as a
champion for their ward and for the people they represent.
SUMMARY
— Even once the current decent homes standard
is achieved for social housing, there remain further considerable
challenges—maintaining stock which has been improved in
good condition, responding to legitimate tenant aspirations for
improvement, improving energy efficiency and carbon emissions,
and improving standards in the private sector.
— Tackling these challenges will be all
the more difficult in a climate of very constrained public spending.
However, the LGA Group believes that our proposals for reform
of council house finance and funding for energy efficiency have
potential to deliver improvements without massive additional demands
on the taxpayer.
— We are not convinced that the current
Decent Homes standard should be replaced by something covering
the same range of aspects of condition. Rather, subject to minimum
standards for the health and safety of tenants, social landlords—individually
or together, should be free to develop local standards responding
to the views of their tenants, subject only to the regulatory
oversight of the Tenant Services Authority.
How should the Decent Homes target for private
sector homes occupied by vulnerable people be taken forward?
1. The social sector has been subject to
a target that all homes should meet the Decent Homes standard
by 2010, and this looks set to be achieved for the overwhelming
majority of homes. Whilst addressing non-decent private sector
homes occupied by vulnerable people remains a government priority,
the national Decent Homes target was abolished in 2008 and the
Decent Homes standard cannot be enforced in the private sector.
2. The 2007 English House Condition Survey
notes that approx 7.7 million non-decent homes—1.1 million
in social housing, 1.2 million private rented and 5.3 million
owner-occupied. We suggest it would not be realistic to upgrade
the Decent Homes standard whilst so many non-decent homes remain
under the existing definition, with no realistic programme in
place to get them upgraded. The current standards for the private
sector as set out in the Housing Act 2004 ensure that properties
meet appropriate health and safety. We believe that these do not
need reviewing at this time, having only recently been introduced.
3. Indeed, achieving even the Decent Homes
standard in the private rented sector is likely to be very challenging
in an environment of very constrained public spending, unless
government were prepared to mandate landlords to bear the cost
themselves. HHSRS already enables councils to deal with the health
impacts of poor housing and is an enforceable standard. Upgrading
old kitchens and bathrooms that are still serviceable, present
no risk to the occupiers, and cannot be enforced could be seen
as less of a priority. As such, category 1 hazards under the HHSRS
could be the standard against which housing standards are monitored
focusing on "Safe and Healthy" housing.
4. We agree with the emphasis the Government
is now placing on tackling the energy efficiency and carbon emissions
of the existing housing stock. It is especially important that
this includes the private rented sector. The proposals in our
recent policy document Kyoto to Kettering[68]
would enable, we argue, more effective area based schemes for
bringing properties up to a good standard, indeed better than
Decent Homes, which, for example only requires 50mm of loft insulation.
Do the management organisations—councils,
including via ALMOs, and housing associations—need to change?
Will they have sufficient funds?
5. On 29 June, the Government announced
a £1.5 billion package to support increased supply of housing
as part of Building Britain's Future. On 17 July, further
details of the package were announced, including funding for ten
local authorities to build new homes under the housing private
finance initiative (PFI). In a letter to the LGA, the Housing
Minister said that this would be funded through efficiency savings
by the Homes and Communities Agency (HCA) and efficient and flexible
management of its housing and regeneration programmes.
6. On the same day, the HCA wrote to Arms
Length Management Organisations (ALMOs) announcing that funding
under the ALMO capital programme would be deferred for those ALMOs
that have not yet achieved two star status. This effectively means
that ALMOs that have not yet achieved two star rating will not
receive planned funding for their decent Decent Homes programmes.
In addition, there can be no commitment to continued funding for
Decent Homes in the post 2011 financial period.
7. The decision affects eleven councils
in total, six of whom are in London. The total funding deficit
over the next five years is in the region of £970 million[69].
This includes those most recently launched ALMOs who are investing
heavily in preparing for their forthcoming Audit Commission inspections
in the next six-nine months. A number of ALMOs that had been promised
funding this financial year have already drawn up programmes of
work and communicated these to tenants. Withdrawing funding at
short notice significantly damages ALMOs' and councils' ability
to plan and deliver vital services, and will amount to real and
immediate cuts to services for tenants.
8. The LGA is calling for government to:
a. immediately reinstate or replace funding for
those ALMOs who are on course to achieve two stars and have planned
programmes of work in 2009-10 and 2010-11.
b. commit to continued investment for improving
the condition of council owned housing in the post 2011 period
and to work with local government to agree a mechanism for delivering
this investment. This will need to be considered alongside the
reform of the Housing Revenue Account and the development of a
new system of council housing finance.
Are adequate arrangements in place for the future
regulation of minimum acceptable housing standards?
9. Subject to the Government proceeding
with secondary legislation under the 2008 Act, there will be a
new regime for the regulation of all social landlords on a consistent
basis from April 2010. The LGA and partner organisations lobbied
energetically and successfully for the Government to amend its
legislation so the new regime was not limited to housing associations.
We believe these new arrangements offer the potential for a new
approach to the setting of standards for the condition of the
local stock. In line with the principles underlying those new
arrangements, there should be less emphasis on government or regulators
setting national standards which apply across the whole stock,
and more emphasis on landlords—individually or working together
in a locality, to set their own standards reflecting what tenants
want in particular places.
10. The new Tenant Services Authority (TSA)
should, of course, ensure that all social tenants live in properties
which are not a threat to their basic health and safety. But,
far more than currently, other aspects of condition should be
for individual landlords to determine, reflecting what their tenants
tell them about their priorities. The proposals on local standards
set out in the TSA's recent discussion document[70]
offers a framework for doing this.
What are the implications for decent housing standards
of the Government's proposal, currently out for consultation,
to move to a devolved system of council housing finance?
11. The announcement to consult on a devolved
system of council housing finance was a substantial victory for
councils working together through the LGA's housing campaign Places
You Want To Live. This is a significant step in the right
direction to allow councils to maintain and improve the standards
for their housing without massive additional demands on the Exchequer.
However, there are a number of issues which need to be addressed
to enable councils to fulfill their potential to improve their
stock.
12. The consultation paper proposes a one
off payment for councils to leave the Housing Revenue Account.
This will mean a redistribution of debt between councils, with
lower debt councils taking on additional debt.
13. The most important issue for the sector's
response to the consultation will be what debt, if any, should
be redistributed in this way—taking account of the proposals
in the LGA's policy document[71]
that the Government should write off councils' current housing
debt entirely. The consultation paper offers a notional debt figure
of £18 billion. The LGA's calculations put current (real)
debt at £15.5 billion. Currently around £1.1 billion
of the £6 billion of income raised annually in the subsidy
system services this debt. The LGA believes that future investment
in our homes, improvement to stock and the delivery of new lower
carbon homes will be hindered if councils are loaded with excessive
debt. Councils need sufficient headroom in their business plans
for them to be able to contribute effectively to their communities.
14. Ensuring that councils are not burdened
by excessive debt will enable them to provide 80,000-90,000 new
affordable homes over the next five years delivering approximately
£35 billion additional investment to the English economy.
With nearly two million people on council housing waiting lists
this new housing would help to reduce housing benefit bills and
the public cost of homelessness, and would allow councils to house
homeless families more quickly.
15. Ahead of comprehensive reform of the
current system, we believe there should be a remission in 2010-11
and 2011-12 of the "negative subsidy" which many councils
are paying. The LGA will show how this would generate activity
in the construction economy as well as securing improvements for
tenants.
Should minimum acceptable social housing standards
be amended to take account of environmental standards, fuel poverty
and the estate?
16. We agree that carbon reduction and improved
energy efficiency are extremely important for the next stage of
housing policy. The issue, however, is at least as much how the
necessary huge programmes of work can be funded and delivered
as the setting of standards.
17. At the national level there are a range
of different initiatives and funding streams to improve the UK's
housing stock. These include £2,800 million from the Carbon
Emissions Reduction Target (CERT) and £350 million from the
Community Energy Saving Programme (CESP), which are funded and
administered by energy suppliers and generators, £874 million
from Warm Front, £2,200 million from Decent Homes and £84
million from the Social Housing Energy Saving Programme.
18. The LGA believes that energy efficiency
needs to be at the heart of council and other housing providers'
considerations and future plans for their stock. Higher energy
efficiency and carbon reduction initiatives will enable landlords'
to improve stock condition, reduce fuel poverty, improve health
and reduce the environmental impact that housing creates. The
LGA publication From Kyoto to Kettering: local government's
manifesto for low carbon communities illustrates how these
initiatives can be paid for without having a burdensome impact
on public expenditure.
19. The same publication sets out how local
government could better coordinate and use funding to deliver
local insulation schemes. For example, in Kirklees 40,000 households
will benefit from a free insulation offer—saving each one
£300 each and every year on their fuel bill. Energy suppliers
have chosen the cheapest route to deliver their carbon obligation,
for example giving away over 150 million low energy light bulbs
instead of tackling the lack of insulation in homes.
20. There are around 1.2 million social
homes that need insulating. Adding to the range of funding initiatives
is the Social Housing Energy Saving Programme (SHESP) administered
through the Homes and Communities Agency. The aim of this programme
is to help social landlords insulate hard to treat cavity walls
that would not otherwise be filled under the Decent Homes programme.
The budget for 2009-10 was £54.5 million, but local authorities
were given only a month to formulate and submit a bid to improve
their "harder to insulate" cavity wall dwellings. This
was an incredibly short space of time in which to announce and
expect local authorities to pull together a serious funding bid.
London successfully secured 75% of this funding.
21. The LGA is calling for a single National
Community Energy action Fund to distribute funds to local areas
to be coordinated by councils. This would ensure cost effective,
comprehensive and systematic delivery, moving away from the current
scatter-gun approach to delivery.
22. The LGA recognises that zero-carbon
new homes provide the potential to fund local projects to provide
insulation for existing homes. This could be through a local community
energy fund to pool developer funding. The London Borough of Barking
and Dagenham have adopted this approach through a local energy
services company.
September 2009
68 From Kyoto to Kettering, Copenhagen to Croydon:
local government's manifesto for building low-carbon communities,
July 2009 http://www.lga.gov.uk/lga/aio/2400550 Back
69
This estimate is based on information provided by affected councils
to the LGA. Back
70
Building a new regulatory framework-a discussion paper, June 2009. Back
71
Local Housing-Local Solutions: the case for self-determination,
June 2009 http://www.lga.gov.uk/lga/aio/2001508 Back
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