Written evidence submitted by the Chartered
Institute of Environmental Health
1. SUMMARY
— The
Government's decision to cut entirely the private sector renewal
budget will seriously impair the ability of local authority environmental
health practitioners (EHPs) in local authority private sector
housing teams to bring empty homes back into occupation and ensure
properties meet the requirements of the Housing Health and Safety
Rating System.
— This
will similarly have a knock-on effect on the capacity of EH teams
at the local level to improve owner-occupied homes.
— The
Chartered Institute of Environmental Health (CIEH) has produced
a toolkit that provides a method of measuring and showing the
value of private sector housing intervention to health, society
and quality of life; it includes a cost calculator. (paragraphs
3.3-3.4)
— The
CIEH has commissioned research that estimates the costs to the
NHS of excess cold hazards and states these costs by region. (paragraphs
6.1-6.2)
— The
CIEH has carried out a survey of our members working in local
authority private rented sector housing teams which illustrates
the impact of the cuts in the renewal budget. (see paragraphs
2.5-2.6)
— Homes
that stand empty are a wasted resource and have a detrimental
effect on neighbourhoods. Bringing them back into occupation is
vital to regeneration and environmental health practitioners are
key to this objective.
— Housing
is a key part of urban renewal, and is often the driving issue
behind the establishment of renewal areas by local authorities.
— The
CIEH would welcome the opportunity to present oral evidence to
the Select Committee.
2. RESOURCES
The impact of the cuts in the private sector renewal
budget
2.1 Reliance on the private rented sector (PRS)
is growing because of limitations in social housing supply and
because first time buyers cannot afford owner occupation until
much later now. The PRS has grown by over one million households
between 2005 and 2009 and is integral to community regeneration
strategies.
2.2 But 40% of PRS homes are over 90 years old,
and nearly 30% have serious health and safety hazards compared
to 13% in the social rented sector. Forty five percent of PRS
homes also fail the Decent Homes Standard. There are 1.4 million
families, many of these elderly owner-occupiers, living in homes
that fail to meet the decency standard. Housing renewal policies
need to be carefully integrated with the wider regeneration agenda.
Renewal will not prove cost-effective without a clearly identified
economic future.
2.3 The demise of the Housing Market Renewal
programme, eight years into what was originally envisaged as a
10-15 year programme, is particularly damaging in this regard.
The aim of the programme was to deliver change and regeneration
on a large scale, working through partnership across areas with
weak housing markets, irrespective of local authority boundaries.
2.4 The Audit Commission in their recent review
of the HMR[137]
commented:
— "Cumulatively,
HMR achievements have been significant and, in a difficult year,
pathfinders have continued to make progress. The HMR programme
is making a difference to the communities it serves, with fewer
empty houses, reduced crime, and more jobs and training opportunities,
especially in those neighbourhoods that are more advanced in their
programmes.
— By
March 2011, pathfinders will have:
— — Refurbished
more than 108,000 existing homes;
— — Attracted
private investment to complete over 15,000 new homes;
— — Readied
substantial sites for future development through selective acquisition
and clearance of up to 30,000 properties;
— — Generated
some £5.8 billion of economic activity across the economy;
— — Created
some 19,000 jobs in construction and related industries;
— — Helped
maintain over 2,600 jobs in the construction industry each year."
CIEH survey on the impact of the cuts in the private
sector renewal budget
2.5 In January 2011 the CIEH conducted a survey
of its members in local authorities to gather information and
feedback on how the loss of this funding would affect their housing
renewal activity in 2011-12 and beyond (see box at 2.6).
2.6 Eighty percent stated that the number of
properties to be renovated with assistance from the local authority
would reduce, with 27 of these (57% of all responses) saying they
would reduce substantially or there would be no renewal assistance
provided. Just ten responses (5%) stated that the number of properties
renovated would stay the same or increase only slightly. None
stated that the number would increase substantially.
| Which of the following reflects the local authority's situation best:
|
| Number will increase substantially | 0
|
| Number might increase slightly | 4
|
| Number will stay the same | 6
|
| Number will reduce slightly | 2
|
| Number will reduce substantially | 17
|
| Number will decrease from an already small number
| 7 |
| There will be no renewal assistance provided
| 15 |
| Other | 1 |
| Total | 52 |
2.7 Many local authorities stated that they expected provision
for both housing renewal and DFGs to substantially contract in
2012-13. The following comments are taken from the responses and
provide a further snapshot of the situation at local level:
"The recent Comprehensive Spending Review and local government
grant settlement has had a double impact on this Authority. The
total cut of the national private sector housing renewal budget
has led to the necessary but unfortunate decision to withdraw
all forms of private sector housing assistance to vulnerable households
within this district. All available council resources will be
targeted at ensuring our statutory duties will be met in respect
of mandatory DFG's. In addition the reduction in public sector
funds and the need to streamline the Authority has led to a reduction
in numbers of the housing renewal team via compulsory redundancy".
"No decision has yet been made regarding our Housing Assistance
Policy for 2010-11 but the feeling is that we may have to abandon
our funding for discretionary grants for the next financial year.
If it remains, it is likely to be substantially reduced".
"We are hoping to keep a small sum for HRA for dire emergencies,
in the form of loans. We will also be having discussions with
a local credit union about potential roles for them".
"We have been heavily reliant on the Targeted Funding Stream
and so all we will have to spend next year is the residual funding
from that programme which ended in 2010-11, most of which is for
empty homes and in fairness there is still quite a lot of that
funding uncommitted. Where we are facing problems is in ordinary
renovations for elderly people and will have to rely entirely
on the equity release programme which, from past experience, doesn't
deliver that many cases. I'm very worried about fuel poverty given
that Warm Front is being cut and our own TFS funding is winding
down".
"Housing Renewal Assistance—there will be no renewal
assistance provided. We have a budget of £60,000 for 2010-11.
This will be cut completely in 2011-12".
2.8 In the context of the cuts, alternative investment sources
and creative funding packages to support housing growth and regeneration
will need to be explored by local authorities and their partners.
As uncertainty over departmental budgets is set to prevail, local
authorities will need to be proactive in securing funding from
alternative sources including the EU, reforms of the Housing Revenue
Account and the government's New Homes Bonus.
2.9 As the public sector shrinks, housing and regeneration
will be increasingly reliant on the private sector. New approaches
to investment and risk management from the private sector will
need to emerge. Public bodies can invest land and property assets
to build portfolios of projects that can recycle investment, cross
subsidise and spread risk.
3. EMPTY HOMES
3.1 Homes that stand empty are a wasted resource and have
a detrimental effect on neighbourhoods. Bringing them back into
occupation is vital to regeneration.
3.2 Most empty homes are privately owned. Measures available
to authorities to bring them back into use range from informal
advice and encouragement through practical measures such as private
sector leasing schemes to the use of enforcement powers. If only
5% of long term empty homes in England could be brought back into
use, councils would cut annual homelessness costs by £500
million.[138]
3.3 Environmental health practitioners play a key role in
restoring empty homes to occupation and in promoting Decent Homes
in the private sector. To assist its members and local housing
managers in achieving a better understanding of the links between
housing and health, the CIEH commissioned the Building Research
Establishment (BRE) Housing Centre to produce a toolkit.[139]
The aim of the toolkit is to show how links between homes and
health can be made, including where possible, the cost benefit
of some specifically linked housing and health issues. Providing
evidence of cost benefit is important where resources for improvement
or enforcement are lacking.
3.4 The toolkit provides a method of measuring and showing
the value of private sector housing intervention to health, society
and quality of life. One of the tools available is a cost calculator
based on the Housing Health and Safety Rating System (HHSRS.)
which demonstrates the value interventions by producing a baseline
of likely numbers of incidences within local authority areas,
together with the health costs and costs of mitigating the hazard.
This figure can be used as evidence of the cost and subsequently
compared to the costs of improvement works.
4. REGENERATION
4.1 The housing, regeneration and planning landscape in the
UK is changing fast. Public funding for affordable housing and
regeneration has decreased dramatically and shall continue to
do so, with the imminent closure of the Tenants Services Authority
and the Audit Commission and with bodies such as the Homes and
Communities Agency (HCA) expected to play a "leaner"
enabling role.
4.2 Of course there are major challenges for delivery and
local authorities will have to explore innovative solutions, for
example through working collaboratively with partners, embracing
new funding mechanisms and income sources and using public sector
assets more creatively to leverage investment.
4.3 Local authorities and their partners should drive regeneration
and housing growth in response to community needs. As the public
sector shrinks and the need to attract private sector investment
becomes more important, tough decisions will be necessary to prioritise
schemes with the best chance of success and where there is scope
for making better use of the public estate.
4.4 Research carried out by the Audit Commission[140]
showed that while local authorities acknowledge that housing can
contribute to wider objectives, including regeneration, councils
themselves do not see these as a priority. In concluding that
local authorities needed to take a broader approach and integrate
their planning, housing and regeneration strategies, it noted
in contrast that the strategic housing function was often dispersed
across the council structure. Any disconnection between private
sector renewal and regulation and some strategic housing functions
represents a missed opportunity.
4.5 Furthermore, the Audit Commission has asserted that few
local authorities focus on the potential of their regulatory powers
to help achieve their strategic housing and regeneration objectives.[141]
Only 14% of local area agreements had objectives relating to making
better use of their existing stock and only 6% have a specific
objective to bring empty homes back into use: both critical components
of community regeneration strategies. This also indicates the
low priority that councils generally give to regulating the private
sector. The CIEH found in a 2008 survey that many local authorities
are reluctant, or are not sufficiently resourced to use the regulatory
and enforcement powers they have at their disposal to improve
the housing stock.[142]
4.6 Regeneration programmes are most often area-based, looking
to address physical, economic, and social problems. Aligning the
resources and work of private rented sector teams with these areas
can help maximise their impact.
4.7 Bristol City Council's[143]
decent homes funding has been targeted at areas with both poor
housing and poor educational attainment, in an attempt to support
improved educational performance through improved housing standards.
Poor management and maintenance of rented properties and management
of tenants' anti-social behaviour can contribute to neighbourhood
problems that lead to a poor reputation and concentration of deprivation.
4.8 B.A.R.L.O. Housing Ltd[144]
(Bolton's forum for private rented sector housing) has area-based
information on property and tenancy management standards including
complaints, nuisance, anti-social behaviour and empty properties.
This information is used to target grants, enforcement, landlord
and tenant support, and referencing, training and housing management
advice in order to achieve coherent and effective area based regeneration.
5. ENERGY EFFICIENCY
5.1 Innovative financing and energy efficiency represents
a further opportunity to integrate the strategic housing function
firmly within the regeneration imperative. Innovative funding
models combining funding and investment from a range of sources
are required by local authorities and their partners in retrofitting
existing homes and exploring opportunities to improve energy efficiency
when addressing non-decent housing stock.
5.2 There are opportunities for community empowerment based
on capturing revenues from alternative sources such as renewable
energy. Funding models can reinvest profits from renewable energy
generation in further community projects and lead to community
ownership of assets.
5.3 Only 5% of private homes are top rated for energy performance
compared with 21% of social rented homes and 2.1 million private
sector homes are a health hazard because of excess cold. Poor
energy efficiency is a major contributory factor in causing fuel
poverty and two thirds of all households in fuel poverty are owner
occupiers or private tenants. Older people are more likely to
experience fuel poverty than other age groups with those over
75 most likely.
5.4 Substantial resources are available nationally to improve
energy efficiency. Local authorities have an important part to
play in raising awareness and facilitating access to energy efficiency
grants, offers and advice from external agencies.
5.5 The CIEH is supporting Friends of the Earth and the Association
for the Conservation of Energy in their campaign for a minimum
energy efficiency standard for private rented homes.
5.6 Private rented homes are the worst maintained part of
the housing stock and contain large numbers of vulnerable households
and those living in fuel poverty.
— People
living in private rented homes are over four times more likely
to be living in a cold home than people living in social rented
homes.
— The
private rented sector has a greater proportion of the most energy
inefficient homes—those in Energy Performance Certificate
Band G. They are twice as common in the private rented sector
as in other sectors.
— Half
the properties in the private rented sector are not considered
to be of a "decent" standard by the Government.
6. EXCESS COLD
6.1 The CIEH has commissioned, on behalf of Friends
of the Earth research into the costs to the NHS of cold dwellings
across England and in particular to private rented dwellings.[145]
The methodology used two different techniques for measuring and
explained the relationship between Category 1 Excess cold (under
the Housing Health and Safety Rating System) and Energy Efficiency
Rating (EER) bands. This additional report more clearly defines
the estimated costs to the NHS of Excess cold hazards and states
these costs by Region.
6.2 The research estimates the likely costs to
the NHS of private rented dwellings with F and G EER bands. This
is associated, as far as possible, with dwellings with Category
1 Excess cold hazards. The cost to the NHS of Excess cold in the
private rented sector, using the BRE Category 1 calculator, puts
this figure as somewhere between £50 million and £270
million dependent on the combination of risk likelihoods used.
It is reasonable to assume that the cost to the NHS for not improving
these dwellings will be at least £145 million per
annum. The table[146]
below illustrates the potential regional and national impact:
| Region | Number of Dwellings
estimates to be Associated
with Excess cold
| Cost to the NHS of
NOT improving these
dwellings
|
| North East | 17,000 | £5,497,000
|
| Yorkshire and Humber | 66,000
| £13,968,000 |
| North West | 66,000 | £10,493,000
|
| East Midlands | 67,000 |
£12,073,000 |
| West Midlands | 65,000 |
£12,823,000 |
| South West | 97,000 | £24,717,000
|
| East of England | 68,000 |
£14,690,000 |
| South East | 128,000 | £32,197,000
|
| London | 82,000 | £18,878,000
|
| All privately rented dwellings | 656,000
| £145,335,000 |
Excess seasonal deaths
6.3 Environmental health practitioners (EHPs) are at the forefront
of efforts to combat excess cold and damp in the owner occupier
and private rented sector and are important in addressing the
wider impacts of climate change on health. In the UK, deaths are
likely to fall because of milder winters, although in the last
five years‚ more than 130‚000 people over 65 have died
from cold related illnesses during the winter months in Britain.[147]
6.4 For EHPs who work in housing there are clear opportunities
for input. EHPs can provide advice and assistance for occupants
on issues such as improved insulation. They can also engage specific
proactive interventions designed to identify and assist particular
individuals or types of property. Improving our housing stock
is a key component of reducing carbon emissions and has clear
health benefits.
6.5 It is equally important to ensure that our communities
and dwellings are able to cope with abnormally high temperatures
and heat waves, such as those in 2003. Advance planning is at
the core of all early warning systems, together with identification
of these high-risk groups so they can be protected.
7. SUSTAINABLE COMMUNITY
STRATEGIES
7.1 An effective sustainable community strategy expresses
the overarching vision for a local area and its people. It should
address the social, economic and environmental elements needed
to build and maintain sustainable communities. The local housing
strategy must be incorporated in the sustainable community strategy.
7.2 Local authority structures should ensure that portfolio
holders, as well as housing strategists, are feeding into the
local strategic partnership (LSP). Local authorities also need
to have clear structures and processes that help to develop, within
the LSP, an understanding of all housing in its area and how actions
to influence, support or address problems across tenures can play
a part in delivering more sustainable communities.
8. THE ROLE
OF THE
PRIVATE RENTED
HOUSING SECTOR
IN REGENERATION
8.1 12% of all homes are in the private rented sector. It
also has the highest percentage of housing still to reach decent
homes standard (around 40%), having therefore a major impact on
local housing markets, and on many people's housing experiences.
8.2 Local authorities have an important place-shaping role
and there is a renewed emphasis on the importance of the strategic
housing function in contributing to the delivery of place shaping.
The strategic housing role involves local authorities taking a
considered approach to housing and making detailed plans which
use all resources and powers at their disposal to help achieve
specific outcomes across the whole housing market.
8.3 The nature of the private rented sector at local level
and the way it operates (as a sector and as individual properties)
can have a significant impact on households, communities, and
service providers.
Selective licensing and regeneration
8.4 Selective licensing of private rented sector properties
can be used to consolidate aspects of the regeneration programmes,
where local authorities have done as much as possible to tackle
decline using voluntary methods.
8.5 Salford and Gateshead[148]
councils are both using selective licensing to support regeneration.
In Salford, the selective licensing scheme requires landlords
to either use the Salford Private Landlords Tenancy Agreement
or insert a clause into their own agreement that allows the landlord
to take reasonable steps to deal with anti-social behaviour.
8.6 In Gateshead, selective licensing has contributed to regeneration
because problems remained in the private rented sector despite
use of an accreditation scheme and support provided to landlords
and tenants. The area suffered from low demand, there were large
numbers of empty properties, low value housing with low rental
values and a lot of complaints about housing relating to standards
and anti-social behaviour. The selective licensing scheme was
designed to tackle low demand by acting as a lever to improve
housing standards as well as reducing anti-social behaviour.
8.7 The accreditation scheme has driven up standards. Accredited
landlords have been able to access match funding for work to update
properties. The selective licensing scheme is therefore indirectly
helping bring properties in the private rented sector up to the
decent homes standard.
9. THE STRATEGIC
ROLE OF
THE LOCAL
HOUSING AUTHORITY
9.1 The CIEH has recently contacted key decision makers in
local government to highlight the value of private sector housing
services.[149] They
make an important contribution across a broad range of policy
areas, delivering real benefits for vulnerable people and local
communities, including:
— Preventing
homelessness.
— Tackling
fuel poverty.
— Older
people's social care.
— Health
protection and improvement.
— Carbon
reduction.
— Sustainable
neighbourhoods.
— Increasing
housing supply and widening choice.
— Regeneration
strategies.
9.2 Managing the private rented sector strategically
within the aim of balancing housing markets can maximise housing's
contribution to economic wellbeing and regeneration.
9.3 Delivery of these strategies relies on the
contribution of a range of partners, including landlords. Local
housing authorities have worked to move their focus from management
of social housing to oversight of the whole housing market, and
new structures have been developed to support this approach. For
many areas priority is on increased supply of market housing.
10. THE CHARTERED
INSTITUTE OF
ENVIRONMENTAL HEALTH
10.1 The CIEH is a professional body;
we set standards and accredit courses and qualifications for the
education of our professional members and other environmental
health practitioners. As a knowledge centre, we provide
information, evidence and policy advice to local and national
government, environmental and public health practitioners, industry
and other stakeholders. We publish books and magazines; run educational
events and commission research.
10.2 As an awarding body, we provide qualifications,
events, and trainer and candidate support materials on topics
relevant to health, wellbeing and safety to develop workplace
skills and best practice in volunteers, employees, business managers
and business owners.
10.3 We are also a campaigning organisation,
working to push environmental health further up the public
agenda and to promote improvements in environmental and public
health policy. We are a registered charity with over 10,500
members across England, Wales and Northern Ireland.
10.4 In support of this submission, the CIEH
offer to provide expert witness to the inquiry so that we might
give further evidence on the importance for the regeneration of
communities of safe and healthy housing. EHPs play a key role
in ensuring that properties in this sector meet the standards
in the housing health and safety rating system.
March 2011
137 "Housing Market Renewal" (Audit Commission,
March 2011) Back
138
"Building Better Lives" (Audit Commission, 2009) Back
139
"Good Housing Leads to Good Health: A Toolkit" (Chartered
Institute of Environmental Health and Building Research Establishment,
September 2008) Back
140
"Building Better Lives: Getting the Best from Strategic Housing"
(Audit Commission, 2009) Back
141
ibid Back
142
"Survey of local authority regulatory activity under the
Housing Act 2004" (CIEH, February 2008) Back
143
Taken from "Cinderella Strikes Back: Strategic Housing and
the Private Rented Sector" (Chartered Institute of Housing,
2005) Back
144
ibid Back
145
"The Health Costs of Cold Dwellings" (Friends of the
Earth, Chartered Institute of Environmental Health and the Building
Research Establishment, to be published April 2011) Back
146
ibid Back
147
"Climate Change, Public Health and Health Inequalities: A
Resource for Environmental Health Practitioners" (November
2008) Back
148
"Cinderella Strikes Back", ibid Back
149
"Local Authority Private Sector Housing Services" (CIEH,
2011) Back
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