Levelling Up, Housing and Communities Committee
Oral evidence: Disabled people in the housing sector, HC 63
Monday 5 February 2024
Ordered by the House of Commons to be published on 5 February 2024.
Members present: Mr Clive Betts (Chair); Bob Blackman; Ian Byrne; Mrs Natalie Elphicke; Kate Hollern; Tom Hunt; Andrew Lewer; Mary Robinson; Nadia Whittome; Mohammad Yasin.
Questions 1 - 59
Witnesses
I: Mikey Erhardt, Policy and Campaigns Officer, Disability Rights UK; Christina McGill, Co-Chair, Housing Made for Everyone (HoME) Coalition, and Director of Social Impact and External Affairs, Habinteg Housing Association; Jacquel Runnalls, Co-opted Lead in Accessibility and Inclusive Design, Royal College of Occupational Therapists (RCOT) Specialist section in Housing.
II: Cllr Victor Chamberlain, Member of the Local Infrastructure and Net Zero Board, Local Government Association, and Leader of the Opposition (Liberal Democrats), Southwark Council; Adrian Dobson, Executive Director Professional Knowledge and Standards, Royal Institute of British Architects (RIBA); Timothy Douglas, Head of Policy and Campaigns, Propertymark; Sam Stafford, Planning Director, Home Builders Federation.
Witnesses: Mikey Erhardt, Christina McGill and Jacquel Runnalls.
Chair: Welcome, everyone, to this afternoon’s session of the Levelling Up, Housing and Communities Select Committee. This afternoon we are starting an inquiry into a really important subject, disabled people in the housing sector. We will be looking at the availability of suitable housing, the challenges that many people face in getting suitable housing, the variety of tenures and the differences between them.
Before I go over to the first of our two panels today, I will begin by asking Committee members to put on record any particular interests they have that may be relevant to this inquiry. I am a vice-president of the Local Government Association.
Mohammad Yasin: I am a member of Bedford town deal board and I employ a councillor in my constituency office.
Kate Hollern: I also employ a councillor in my constituency office.
Mrs Elphicke: I am a vice-president of the Local Government Association and I employ a councillor in my office.
Q1 Chair: Thank you, colleagues, for that. Before I come to our first panel, I will just say that, as well as the very important witnesses we are going to have giving evidence to us today, we have also launched a survey to get a wider view of people’s attitudes towards the provision of suitable housing for people with disabilities, what problems people may be having that they want to tell us about and, indeed, what is going right for them.
The best way to do our survey is to click on to the Levelling Up, Housing and Communities Select Committee website, have a look at our survey, complete it and let us have your views and comments through that process. It helps us get a wider number of views than we can possibly get by having people before us giving evidence, important though that is.
Coming over to our important witnesses today, perhaps you would just like to go down the table and say who you are and the organisation that you are representing.
Mikey Erhardt: I am Mikey Erhardt. I am a disabled renter and a housing campaigner at Disability Rights UK. We are one of the UK’s leading disabled people’s organisations, which means we are run by and for disabled people.
Christina McGill: I am Christina McGill from Habinteg Housing Association, which specialises in accessible and adaptable housing, and has done for about 50 years. At Habinteg, I am the director of social impact and external affairs. I am also co-chair of the Housing Made for Everyone Coalition, which is made up of 10 organisations that all have an interest in this area.
Jacquel Runnalls: I am Jacquel Runnalls. I am a specialist housing occupational therapist and have been for over 20 years now. I am here representing the Royal College of Occupational Therapists’ specialist section in housing as its co-opted lead on accessibility and inclusive design.
Chair: With regard to Habinteg, we paid a visit to one of your developments when we did our previous inquiry into housing for older people.
Christina McGill: That is right.
Q2 Chair: Let us move on to the issue of housing for people with disabilities or the lack of housing in some cases. Could we begin by asking a general question? What impact does having a properly accessible home have on the health and wellbeing of disabled people? It is not just about accommodation; it is the wider effect that it has on people and their lives.
Mikey Erhardt: It is a really important question to ask. To introduce this, it is important for members of the Committee to remember that there are about 14 million disabled people in the UK. We are one in five people. We are not a homogenous group. We live different lives and we have different impairments, genders, sexual orientations, class backgrounds and faiths. In particular, a lot of us have very different housing needs.
In general, we have been consistently failed. There is very little provision for accessible housing in this country, even less provision for accessible and affordable housing, and even less provision for accessible and affordable housing in your local area, where you might have grown up or you live.
Access to that housing is getting worse and the impacts are really telling. One in five disabled people in social housing and one in three in the private rented sector have an unmet housing need. That is a house that is unsafe or perhaps inaccessible. It might have a category 1 hazard. It might have damp, cold or mould. All of these exacerbate long-term health conditions and impairments. I have spoken to paediatricians. Every day, they are getting younger and younger children in with lung conditions, asthma or heart problems because of the housing that they live in. As those children grow up, housing provision is not getting better for them.
In general, we are at a bit of a breaking point. It is now a crisis point for us, really. No matter who we are as disabled people, the right that everyone in this room and everyone outside this room has to affordable, accessible and warm housing is just not being met. I have spoken to people who have lived in inaccessible temporary accommodation for decades. They cannot even get basic changes made. They are trapped in housing circumstances that mean they do not feel like they can get out and get a job or be part of the local community. They feel trapped. That is the prevailing feeling as a disabled person in this country when it comes to our housing.
Christina McGill: One of the privileges of working for an organisation like Habinteg is that we get to hear about the vast difference that can be made to somebody’s life when they are able to access a home that meets their needs.
When I talk to Habinteg tenants, I routinely hear about the positive impact on people’s overall life chances, their attitudes to themselves, and their actual confidence level about what they are able to do and what they are able to aspire to do, whether that is in the world of volunteering or paid work or whether it is about maintaining family relationships and being able to tuck their children into bed at night rather than saying goodnight to them at the bottom of the stairs.
It is also about having personal independence in and around the home. Last year, I met a new tenant of ours who spoke about the incredible difference that it made to him to be able to use the bathroom by himself instead of having to have somebody to help him. He talked about the enormous positive impact that had had on his own wellbeing and mental health.
Social engagement is also really well supported by having an accessible home in the place that you need it. One of the people with whom I spoke last year had to move house from Dorset all the way to Durham to get their needs met. In so doing, he had stretched out and broken ties with a lot of his family and friends. Having those homes available in the place where you need them is really critical. Those are the points that I would like to make in response to that question.
Jacquel Runnalls: I will just add to what everybody else has said, certainly in terms of quality of life and cost savings. As the Building Research Establishment has identified, producing accessible and adaptable homes can also have significant savings to NHS and social care budgets. The BRE has said it could mean £1.4 billion in NHS savings. It is fundamental.
As Mikey said, people tend to think of disabled people as a homogenous group, but they are not. As occupational therapists, we see people in their own homes, and we really see the difference that accessible and adaptable housing can make. We also see, critically, the barriers that are created through poor and inaccessible housing, like not being able to put your kids to bed, read them a story or get out to work. We know that people who are inaccessibly housed are four times less likely to be able to work. There are other things like having friends and family over. You might have disabled friends as well. It is not just you as a person.
It is great if you can have an accessible home, but, if your local neighbourhood or the transport facilities are not accessible, that can have a massive impact too. It is more than just the home. We need to consider the wider environment. You can have the most accessible home, but what if your neighbourhood is not accessible?
Q3 Chair: Do you have any idea or are there figures to show how many disabled people are currently living in unsuitable housing? What are the main barriers to them getting access to suitable housing?
Christina McGill: The English Housing Survey is a really good source of information on this. When it last released information on accessible homes by using household data in combination with housing data, we were able to see that, when it came to wheelchair users, for example, there are around 400,000 wheelchair users living in a property that is not either specifically designed or subsequently adapted to meet their needs. Those are people who could be making do in quite extreme situations.
The barriers fall into three main areas. The first is supply. Do we have enough accessible housing in this country? We have the oldest housing stock in Europe. Around 9% of homes offer the minimum combination of accessibility features. We need to improve the quality of new homes to help resolve that situation.
The second thing would be findability. Suppliers need to have better systems to enable people to access what they need, to find out about it and, if they are a social housing tenant, to bid for the tenancy. If you are a private tenant, it is really important to know where the accessible housing is. The actual job of work of searching for an accessible home is extremely long and painstaking for most people who need one.
The third point would probably be around affordability. Being disabled costs a lot more than being non-disabled. The affordability factor is really vital there as well.
Jacquel Runnalls: Apparently there are 1.8 million disabled people who need accessible housing. Another critical thing is that 15% of disabled people are living in non-decent homes. Only 9% of new-build housing meets visitable standards, which means that the other percentage does not.
Generally, to add to what Christina has said, there is a complete lack of general advice, advocacy and support in finding homes. It is a minefield. As a disabled person, you probably have enough on your plate without trying to scrabble around. Anecdotally, there have been many times when I have had to try to help people and to point them in the right direction.
As a result, disabled people are quite often pushed towards a local authority in terms of looking for social housing. Yes, there is the affordability, but not everybody wants social housing. They might want to purchase. In terms of going to your local authority, there are online applications; it is quite a medicalised assessment process. Housing occupational therapists can help with housing advocacy and advice. They can hopefully do a non-medicalised assessment of need and help look at properties.
There is also a big mismatch in terms of finding properties and finding information about the accessibility of properties, whatever tenure that is. In terms of general marketability and property databases, it is just—
Chair: We are going to come on to advice and databases in a few further questions.
Mikey Erhardt: This question about barriers is really important. I would like everyone to take away from today that the majority of the barriers that disabled people face to accessing the housing that we have a right to are self-imposed by policy failure.
There has been a failure to build enough social homes and a failure to implement consultation recommendations. We were chatting about this outside. The first consultation on M4(2), which is the baseline for accessibility standards, came out in 2020. There was a commitment to introduce those two years ago and nothing has happened. I believe we may hear more today in the disability action plan around the same sort of stuff. We are waiting years and years and years for no movement on raising standards on new builds.
Chair: Yes, we are going to follow that up in the next question as well.
Mikey Erhardt: There have been a vast number of other failures. New build is not the only answer for disabled people. New build is not the only answer for getting accessible homes. We do not have accessibility standards in the private rented sector. In general, we do not have enforcement of standards in the private rented sector.
We do not have any legislation or proposals to tackle spiralling rents at a time when, as my colleagues have noted, it costs around £975 a month more to be a disabled person than a non-disabled person. That is the Scope disability price tag figure.
Q4 Chair: Where did you get that figure from?
Mikey Erhardt: That is from Scope. That is an estimation of how much it costs as a disabled person. On a variety of factors, including transport, home bills, food and energy, that is how much more it costs simply to live the life of a disabled person. That is not factoring in anything else. It is around £975 a month.
Housing costs are a huge problem for disabled people. We are less likely as disabled people to be in work. The employment gap is still high. The TUC estimates that the disability pay gap for those of us who are in employment is around 17%. Have we seen any policies or proposals to tackle spiralling rents and costs? No. It is another failure.
The last one that is really pertinent to disabled people up and down the country is that, despite the first recommendations from the Grenfell inquiry around PEEPs coming out in 2019, we have still not introduced these safety measures. It is estimated by ARMA, the Association of Residential Managing Agents, that 500,000 people are affected by the cladding crisis. As some members know, personal emergency evacuation plans, or PEEPs, were recommended in 2019.
Across the board, the barriers are self-imposed. We have made decisions in this House and in other areas that have led to this crisis.
Q5 Mary Robinson: Mikey, you have led straight into my first question, which is around that commitment. In July 2022, the Government indicated that they would make the M4(2) standard on adaptable and accessible dwellings the national baseline standard for new homes. You have expressed your concern about it. What is the impact of that not coming into regulation?
Mikey Erhardt: Fundamentally, we are not building enough homes as it is, but without a regulatory baseline there is nothing that holds developers accountable to build more accessible houses. M4(2) is the bare minimum. If we had more time, we could discuss the limitations. I am sure Christina and Jacquel will talk a bit more about M4(2) and planning categories.
The impact is that we are simply not building anywhere near the number of accessible homes that we need. Developers have an outsized hand and role in shaping provision across the country.
According to the EHRC, 68% of local authorities reported that developers do not adhere to accessibility standards or provisions, be that in the viability assessment or in other areas. Despite knowing that this is a problem—no local authority will tell you it is not a problem—the number of local authorities that felt able or were able to take any sort of action was 3%.
Until we have a regulatory minimum, a baseline that everyone is working off, every developer up and down the country, we are just not going to build any accessible homes.
Q6 Mary Robinson: Christina, Mike has set out the position. Should local planning authorities be doing more? What should they be doing?
Christina McGill: I think so. The M4(2) baseline will make a big difference. The last time we did a review of all local plans, we found that around 23% of homes in England as a whole were planned to be built to the M4(2) standard. Bringing in that as the baseline will increase the supply of M4(2) homes dramatically. As an impact of that, those homes will be much more inclusive and much more flexible.
They are great family homes. They are not homes designed just for disabled people in any shape or form. It is an inclusive housing standard that will adapt and change as the needs of that household grow. They will be much easier to adapt. That means the DFG budget will go further. There is a connection between these two things. They are much more efficient to adapt.
We also have a concern that very few wheelchair-accessible properties are being specified in local plans. When we did that forecast exercise in 2020, only 76 local plans specified any new homes to be built to the M4(3) standard, which indicates that there is an enormous postcode lottery across the country. I really do not believe that disabled people’s needs are very different from one local planning authority to another. A lot more attention needs to be paid to that.
Q7 Mary Robinson: Should there be a percentage imposed in terms of getting that right?
Christina McGill: We would really like to see two things. The first is a very clear direction within the NPPF that local plans must designate a proportion of M4(3) homes. We would like to see that proportion start at 10% because we are in a catch-up situation, much as London has been. London has been working on that policy principle for a long time. We would like to see that rolled out across the country. If an individual local authority area has reason to believe that it does not need that many, maybe it should have to provide proof of that, rather than the other way round.
Q8 Mary Robinson: There has been a lot of discussion about homes being homes for life. Of course, not every disabled person is disabled from early years. As they get older, people have different needs. Should that be specifically part of the requirements?
Christina McGill: That is really what the M4(2) standard is designed to resolve. As somebody’s needs change, whether that be on a temporary or permanent basis, their home is able to adapt with them. If their needs become even greater, there is an alternative for an M4(3) style home. The M4(2) standard is designed to adapt as people’s needs change.
Q9 Mary Robinson: Is this currently being set out with section 106 agreements rather than through legislation or regulation?
Christina McGill: I am not an expert on section 106 policies, but it is my understanding that they tend to be used in a general way to bring forward affordable housing. One would hope that, in most local planning authorities, those affordable homes would be designed to an accessible and adaptable standard.
Jacquel Runnalls: Just to add to what Christina is saying, M4(2) has still not been mandated. Anecdotally, local authorities are saying that they do not need to include it in their local plans because it is going to be coming in. We have not even had the consultation yet. It is still a few years down the line. Unfortunately, the NPPF is quite vague about accessible housing.
You touched on homes for life. Interestingly, the NPPF also refers to what used to be called building for life. It is now building for healthy homes. That used to include lifetime homes. It now has no specific reference to accessible and adaptable housing. The same goes for the national design codes. There is a section that refers to healthy homes, but it includes accessible housing and space standards. Again, there are different tick boxes and different levels. Access and space are not seen as complete requirements in the design codes, if you are setting a local plan.
We need to move on. There has been research since the 1980s evidencing the significant benefits of designing not just for older and disabled people but for families, with easy access for pushchairs and prams.
There is a bit of a missed opportunity in terms of looking at the marketability. It is the same for M4(3). You could have an access rating that was almost like an energy rating. There was research done a long time ago in Northern Ireland. They had been building lifetime homes. When they asked the residents, a lot of them said, “I like living here”, but they were not entirely sure what it was that they liked about it. There is some positive marketing that could be done.
In terms of M4(3), as Christina touched on, since 2004 the London plan has asked for 10% of housing to be wheelchair accessible. It has independent viability testing. In fact, the London plan 2021 says “at least 10%”. That is 20 years down the line.
One other thing that we have not really touched on is evidencing local need. Christina and I worked on an Equality and Human Rights Commission toolkit for local authorities. Again, national planning policy is quite vague about evidencing local need. The NPPF does refer to consulting local disabled people, but there is a whole raft of other local evidence-based tools that you can use.
I despair when developers or people say, “I could not sell my M4(3) property”. That is possibly because they did not advertise it like that. It is a bit of a missed opportunity. There are 400,000 wheelchair users unsuitably housed in England.
There are other policies. I know Liverpool is also applying the 10%. We need to play catch-up. It is almost like it should be the other way round. If you do not want to provide the 10%, you should have to evidence why.
Q10 Mary Robinson: Should accessible neighbourhoods be included in local plans?
Jacquel Runnalls: Yes, absolutely. That is part of the national design codes. There is much more understanding about the need. In fact, some of the guidance that I referred to talks a lot more about neighbourhoods. In years long ago, it was lifetime homes and lifetime neighbourhoods. It talks about sustainability and good neighbourhoods, but what is that if it is not accessible and inclusive for everybody?
Chair: We will now move on to the issue of advice and support, which we have touched on a little bit.
Q11 Mrs Elphicke: We have touched on it a little. I would like to start with Jacquel, please. You described it as a minefield in terms of people being able to go for advice and support. Could you expand more on people going to local authorities? Particularly, is the support provided by local authorities adequate? Is the support provided by occupational therapists and specialists adequate in terms of assessing what can be done to adapt homes?
Jacquel Runnalls: Like I said, it is a bit of a minefield when people are pushed to local authorities. Staff should have equalities training and should have that information and advice. That is where having specialist expertise, such as a specialist housing occupational therapist who advocates for the disabled person, can certainly help.
If you are specifically talking about local authorities—I have touched on this—there are online application systems and choice-based lettings. It is a bit of a minefield. You have to jump through hoops as a disabled person. It might be a very medicalised assessment.
Going back to what we were talking about in terms of evidencing need, that is where having somebody like a housing OT can really help. We work with housing teams. We go and view empty properties in terms of accessibility and using accessible housing registers. We can understand the big picture of who is out there; we can evidence need in terms of what we build; and we can check who is on the waiting list for what. There is also the whole thing about identifying whether there are empty properties.
Q12 Mrs Elphicke: In relation to new-build properties, I understand the point about the assessment and how that is tracked in the planning system. In terms of existing properties, how could it be made better and easier to identify the particular suitability of a property? What kind of register would that be? We have touched on a few. Is it the Land Registry? Is it the new private rented landlords registry that is coming through? Is it with the local authority? How could this be improved?
Jacquel Runnalls: At the moment, it is very piecemeal. Local authorities, where you might have a housing occupational therapist, may operate an accessible housing register. The term “register” is sometimes a bit of a misnomer. It is probably more about categorising the accessibility of the property. For example, if an empty property becomes available, a housing OT might go out, assess its accessibility and then potentially match it to somebody who is on the waiting list.
Some local authorities see the benefits of that and even have grants for adaptation. As an example, I know of one gentleman who had a family. Because there was no accessible property, he had to be housed in residential care at a cost of £54,000 a year. It cost £26,000 to adapt a property, and he was able to move in with his family.
In terms of local authorities, if there is the will, they will have an accessible housing register. In terms of private landlords, there are pockets of good practice. I know National Trading Standards has recently brought in a process where people have to identify material information in relation to accessibility. It is quite basic, but it is a start. There are some really good pockets of practice, but that is it: they are pockets.
There is an organisation called AccessiblePRS, which has started working with some of the larger estate agents.
Q13 Mrs Elphicke: I am sorry to cut in there. In terms of the new approach, there is going to be a national register of landlords. I see a couple of nods, so I am going to bring in Christina and Mikey. Do you want to add to that? What is the best place to manage this information?
Christina McGill: That sounds like a really great opportunity. The portal is intended to give information about a property directly to prospective tenants. That is an ideal place to put key information about accessibility.
Similarly, on the social housing side, there is an opportunity being presented in the new consumer standard from the Regulator of Social Housing, which is asking social providers to know their properties and their tenants better. That provides the opportunity for the linkage that Jacquel was just describing to be more meaningful, better informed and more accurate.
If those two things could happen, and even better if they could speak the same language and use the same ways to describe the accessibility features of a given property, somebody who is setting out in a year’s time to search for a new home would have a much better experience.
Q14 Mrs Elphicke: Mikey, would you agree? Does that sound like the best way to deal with it?
Mikey Erhardt: I think so. Alongside colleagues at Inclusion London, which is another disabled people’s organisation, Advice for Renters, and Branch Properties, which is an accessible rented property specialist, we have proposed to the Department to use the new property portal to map and understand accessibility in the private rented sector. There is a massive opportunity there, which coincides with the retrofit opportunities to have higher EPC levels and finally insulate those cold and drafty homes that Christina was talking about.
If a landlord has to get a surveyor’s report in order to access the property portal, there is no reason why that surveyor’s report could not also map the property out, so that we can understand the variety of private rented properties. Perhaps they will not meet M4(3), but there are loads of disabled people out there who are trapped in homes that do not require huge changes.
Let me give you a good example. I have spoken to someone who has lived for about eight or nine years in a property where all they need is a grabrail in their shower so that they can shower independently. You asked at the start about what difference it makes. They just need a grabrail. That can cost as little as £15 or £20. The landlord does not want to make that change. Over time, their condition has worsened. They are not able to shower independently. They now require a much higher care package. They could have used that to live independently in their community; they could have used it on anything else, but it is now being used to have a shower. They are not able to find anywhere else to go.
Q15 Mrs Elphicke: On the grabrail, I understand the situation in relation to the landlord’s responsibility. It sounds as if a centralised housing support function would work well there.
Just expanding that slightly as well, what about the Land Registry? Where there are significant structural or construction changes, do you see a role for the Land Registry? Christina, I am conscious that you mentioned owning as well as renting. Is that equally important?
Christina McGill: I think so. As Jacquel mentioned earlier, somebody could be living in a property and not know about or understand its adaptability features, once you have gone from the first owner to the second. We need the history or the brand of that property to follow in the central information. That would be useful.
Jacquel Runnalls: The biggest thing is about how information is presented. There are different portals, such as Homes for Londoners, but they all use slightly different things. If you speak to a disabled person, what is important to them? It can be basic information, but it needs to be the same. It is not just about the property. It is about how you get up from the street. People are using things like photos, video tours and floor plans, but we need to have a common language.
There is a general lack of understanding. There is also a slight myth that an adapted property is accessible. That is not necessarily the case either. It would be really helpful to have categories or simplified key words and language, if you are talking about bringing something together.
Mrs Elphicke: That is really helpful.
Q16 Kate Hollern: The current maximum for a disabled facilities grant stands at £30,000. I believe it has been there since 2008. I am going to ask the question, but I know the answer. Is that enough to meet most house adaptations?
Jacquel Runnalls: About 50% of disabled facilities grant—DFG—adaptations are between £5,000 and £15,000. Some of the things that we have touched on are smaller adaptations. The most common are level-access showers and stairlifts.
As you say, it has been £30,000 since 2008. Even just with inflation, we worked out that it would be about £47,000. There are also additional building costs. I know OTs who are frustrated by the system. They are dealing with ever more complex cases. Trusted assessors hopefully deal with the less complex cases.
Having spoken to colleagues across the country who deal with people with much more complex needs, particularly children, some of those adaptations, such as extensions, are coming in between £100,000 and £190,000. Even though they might be a smaller percentage, they still need the adaptation.
It has not moved with the times. The disability strategy said that the Government were going to review the DFG means test. The Government commissioned an independent review of DFGs in 2018. That was one of the clear recommendations that came out. It was not just the amount but also the means test and the allocations grant.
Just to go back to the £30,000, what is happening now is that, under the regulatory reform order, local housing authorities can set up home assistance grants. That is using the discretionary part of the disabled facilities grant. They are topping up. A lot of councils are topping up that money through the better care fund. It is not really evidencing the need that is out there. It is a complete postcode lottery. One local authority may top up to a certain amount; others may not. All of us said we were keen for the upper limit to be reviewed.
Q17 Kate Hollern: As an occupational therapist, when you do an assessment, does that upper figure constrain what you would recommend?
Jacquel Runnalls: Probably not, no, because of the discretionary grants. As an OT, you are there to assess need. Under the legislation, it is about what is necessary and appropriate. That is something that OTs definitely advocate for. I would like to think we are there for the disabled person. It is not about budgets.
If you go down that route, you are then not evidencing the need. If somebody needs something and the money is not there to fund it, you are not reflecting the real need. That is why there are waiting lists and people are waiting for adaptations.
Q18 Kate Hollern: How long is the assessment period, generally?
Jacquel Runnalls: There are limits in the legislation. Once a person has been assessed, the local authority has six months to give them a decision on whether the grant is going to be made available and 12 months to do the work. It fluctuates. Again, it is a bit of a postcode lottery.
Some local authorities will have home improvement agencies. There is some good practice out there. Foundations, the home improvement agency, has examples of that. Again, it is a complete mixed bag. There is a shortage of technical officers and OTs; there are longer waiting lists. The picture is very patchy. It is not just about the money, but also about resourcing.
Q19 Kate Hollern: You spoke about the grants. I have tried to get my head around the means tested element. It is fairly complicated, is it not? Can you tell me simply how it works?
Jacquel Runnalls: I am not an expert on the means test either, but one thing that I do know is that it does not really take outgoings into account, even given the cost of living. Apparently quite a high number of younger working-age couples drop out because they are asked to give a financial contribution and feel they are not able to do so. Along with the upper limit, we have been calling for a review of the means test. It really needs updating.
Christina McGill: At the HoME Coalition meeting that we had last week, we were talking about the DFG. One of our member groups has just been doing some research for an upcoming report. From the data it was able to gather, 75% of DFGs are not being delivered within the recommended timeframe.
I thought that was a very shocking figure when you consider that most people apply for an adaptation because they need it. It is not something people come to in an anticipatory way. It is like, “I need it now”. Some people have more fast-moving conditions. I am thinking about conditions such as motor neurone disease, which moves very quickly. This is not fit for purpose for people who need an adaptation here and now.
It leads to situations where people are potentially spending longer times in hospitals or other forms of care. A tenant who recently came to Habinteg was in a dementia unit as a 30-year-old person seeking an appropriately adaptable home. Another young man of 16 was using a commode in the kitchen of his house while he waited some two years or so for the adaptation of his family home. That just puts a bit of colour behind the data. These are the kinds of situations that people are facing.
Mikey Erhardt: One thing that is really important to remember here is that the DFG is meant to be a floor that raises the standard of housing in this country. It is completely failing to do that. The area where it is perhaps most acutely felt is in the private rented sector. About 19% of disabled people live in the private rented sector.
Like I said earlier, in general, disabled people are way less likely to own our own homes. As council waiting lists grow and we fail to build accessible and affordable houses, we are going to the private rented sector more and more.
When I first started doing this job as a housing campaigner, I spoke to a disabled people’s organisation that had done this work for 20 years. It said to me, “The thing you need to remember is that for disabled people private rented and social rented is treated in the same way that non-disabled people treat buying a home”. Quite often, you are looking for something for life. As a disabled person, because of your income and because of the conditions in this country, you know you are much less likely to own your own home. That is more acutely felt depending on your impairment. There are people with specific learning disabilities where the home ownership level is less than 10%.
Private rented and social rented homes are crucial for disabled people. DFG does not work in that area: 8% of DFG grants go to the private rented sector. To be honest, I wish I could sit here and give you really good, detailed statistics of the barriers in that area, but, because landlord refusal in the private rented sector in particular is such an issue, it is impossible to chart.
For most processes, as a disabled renter, you go to your landlord informally and you say, “Hey, I would like to do X, Y and Z. I need whatever”. That is not going to get recorded in the data when the landlord turns around and says no or, as I have often been told, the landlord then issues a section 21. There is no structural incentive through the DFG process or in general for a landlord to provide you an adaptation other than on their goodwill.
DFG does not work for private renters. There needs to be some sort of change. Through the Renters (Reform) Bill, we have seen how other elements of legislation could work. It feels really horrible as a disabled person to be making a correlation between the disabled facilities grant and having a pet, but in the Renters (Reform) Bill we have decided that a landlord cannot unreasonably refuse you to have a pet. Why can a landlord unreasonably refuse you an adaptation?
There needs to be a change. That needs to be taken a lot more seriously so that I do not have to sit here again and talk about pet ownership, as great and as important as that is for a lot of people, in the same sentence as a house adaptation that keeps you safe.
Q20 Kate Hollern: I was going to ask you why it is only 8%, but you have commented on that. It is a very complicated funding system, is it not? There is a discretionary top-up grant. How does that work?
Jacquel Runnalls: That is what I was referring to before. Under the regulatory reform order, as long as a local authority has a housing assistance policy in place, it can use discretionary funding as part of the DFG. Because of the upper limit, this is what people are doing. The majority of local authorities now have housing assistance policies. They are looking to top up grants particularly and at more innovative things like fast-track adaptations for people who have rapidly deteriorating conditions.
Although usually as an OT you can try to do an assessment, the DFG has quite a physical focus. Some people living with dementia are using these grants for quite simple things and delaying discharge. They are having to look to the discretionary top-up to top up the grants and use them in more innovative fast-track ways. I know Government’s response to not reviewing the DFG means test was to say that people also had access to that. I do not know whether it is necessarily the right vehicle. It could be used in other creative ways. The grant itself needs to be fundamentally addressed and updated.
To touch on what Mikey was saying about landlords, we worked with the National Residential Landlords Association to try to dispel the myths. It undertook research on this. Landlords thought that a person would have to move out to have an adaptation. They thought they would have to fund it and that it had to look clinical, which it does not. There is then the marketability.
It is also about changing attitudes. If a disabled person is happily renting an accessible property, they may stay there longer. It is guaranteed rent. Sometimes it is about dispelling those myths and working together to try to get landlords to come on board in terms of their duty under the Equality Act.
Christina McGill: The piece of work with the NRLA was really helpful in helping to flag to private sector landlords that somebody asking for an adaptation does not necessarily have to be an impingement on them and their property. It can be a very positive thing for them. That was a really strong piece of work. It deserves to get a bit more oxygen.
Mikey Erhardt: That research found that a third of landlords were currently unwilling to rent to a disabled person who had access needs.
Something to make clear is that changes in this area, particularly in the private rented sector, cannot just come from goodwill. They do need to be legislated in. We cannot just hope that so-called good landlords—if I had more time, I would love to dispute that term with you all—will introduce them out of goodwill. We need legislation in this area.
Kate Hollern: Yes, they should not be discriminating.
Q21 Mary Robinson: I am conscious of time so I will make this quick. Mikey, you made good points about the importance of grabrails and landlord refusal in the private sector, which is a hindrance.
I was wondering about the flexibility of the grant. It could well be that landlords do not want to make the adaptations because they are worried about dilapidations when a person moves on. Is there any flexibility in the grant to pay for a property to be put right again afterwards and be restored to its existing condition?
Jacquel Runnalls: Yes, sometimes people are spending the discretionary grant on making good[1]. There is also provision within the DFG. The myth about making good was one of those that we tried to dispel.
Q22 Chair: When I asked about increasing the £30,000 limit, the response I got from the Department was, “If you give more in some grants, there will be less for others. Is the money allocated by Government totally spent each year?
Jacquel Runnalls: In what respect?
Chair: There is a budget for DFG, which the Government provide.
Jacquel Runnalls: It pretty much is. This goes back to my third point about the allocation of the grant. The allocation levels were set in 2011. Some of the areas now have a much higher level of need. Some areas may have enough grants, whereas others do not.
You still have the £30,000 limit. The cost of an extension to a property is now way over £30,000. It is three times that. It is just not reflective. Even though it might suit a lot of people, there are people with higher needs. There is also not enough accessible housing.
There may be local authorities where it is not fully spent, but, again, that goes back to the allocation, which was one of the points that I wanted to review.
Q23 Tom Hunt: I have a series of questions about differences in tenure. We have received a lot of written submissions, which have highlighted a particular problem with disabled people accessing suitable housing in the private rented sector. It is linked to some of the points that have already been made.
Landlords and managing agents currently have legal duties to support disabled tenants. How could these be strengthened or better enforced? I will pick up on the comment just made by Mikey about how it needs more teeth and cannot all be through gentle encouragement.
In principle, I agree. There is a concern, rightly or wrongly, that the changes to being a landlord that have been made in the last few years might have meant there are fewer landlords. Is there a danger that, if we go too hard, a lot of people who are landlords will cease to be landlords and we will have fewer properties? Is there a balancing act to strike here?
Mikey Erhardt: In my personal opinion, no. We have not seen landlords leaving the market as a result of the proposed introduction of the Renters (Reform) Bill. The NRLA had to admit that that was not happening despite having briefed otherwise. It had to admit that that assessment was inaccurate.
It is important to remember that there are lots of tools in terms of legislation that we could use and give more teeth to. In the private rented sector, for instance, the decent homes standard is a great one. At the same time as we are thinking about cold, damp and unsafe homes, why are we not thinking about which of them could be more accessible?
There could and should be an anticipatory duty to elements of housing accessibility so that, as we spoke about, it is not just on a disabled person to figure out what could be done or changed. If they are operating within the law, the landlord should be anticipating Equality Act questions for the property they are leasing out. In some instances, they are making a lot of money from leasing out properties to disabled people. Why is it only the disabled person who needs to be empowered and feel comfortable in that position?
It is a very fraught position, given, as we have already discussed, how few accessible homes there are and how expensive it is in the private rented sector. Some 45% of disabled renters are reporting that they cannot heat their homes to comfortable temperatures because of how expensive everything in this area is. In that fraught scenario, could a landlord not do more to anticipate people’s needs? I think so.
Jacquel Runnalls: I know that an organisation called AccessiblePRS is working with Chestertons, Knight Frank and online portals such as Zoopla and OnTheMarket to promote the letting of accessible properties, to train staff and to look at providing accessible information on the portals. People are starting to sign up. They are seeing the benefits.
That is not to take away at all from what Mikey is saying about the dire situation generally, but people are starting to realise the benefits in terms of letting properties that have accessible features.
Q24 Tom Hunt: It was interesting to hear the points you made about some of the practical advantages of renting to those who are disabled. Other than it just being morally a good thing, there are some practical benefits. A lot can be achieved just through better communication.
Practically, how can central Government and local authorities work more effectively with landlords and managing agents to support disabled tenants and perhaps make progress in the private sector?
Jacquel Runnalls: You were saying about the portal. That sounds like a really good opportunity. I know part C—it is a bit odd: it goes with flooding—of National Trading Standards’ guidance on material information disclosure now covers accessibility and adaptation. It is talking about step-free access, whether there is a wet room and essential living on the ground floor.
A landlord may not necessarily realise that their property is beneficial or accessible, if it is ground floor or all on one level. It is about education as well, but we probably have to put that information out there. It is about understanding what that means.
This does not necessarily mean huge structural changes. It can be done inclusively. You could have a beautiful wet room. There is this thing about adaptations looking clinical as well. They do not have to. That is where we need a bit of education about the benefits.
Christina McGill: I agree with all of that. Zooming back out from that to talk about how important this is, there are more and more people of middle and older years receiving their housing through the private rented sector. These moves are going to become more and more important as time goes on and that market grows. All reasonable steps such as a portal would be really advantageous. At the end of the day, this is about having inclusivity for our homes in this country, is it not? We want to have the best we can for everybody.
Q25 Tom Hunt: I have some specific questions here about neurodiversity. A lot of what we have talked about here has related to physical disabilities, but there are a lot of people with more hidden disabilities that may be just as challenging. Is that part of the debate? Is it a source of concern? I am thinking about individuals who have extreme autism, ADHD, bipolar or even dyspraxia or something like that. To what extent is that an issue?
Mikey Erhardt: It is going to become an increasingly big issue. We talked about the NPPF at length. There is not a lot in the NPPF or in building standards to help people who have the impairments that you have listed.
If that baseline had been introduced back 10 to 20 years ago, when it was first talked about under a different name, we would be able to have this conversation in a much more thorough way. That includes in-house adaptations. The adaptations that you might need if you are visually impaired are very different from those that you might need if you have a mobility impairment.
The one real key worry for me, for Disability Rights UK and colleagues across the DPO sector is the Renters (Reform) Bill and the new provisions around antisocial behaviour. We know that disabled people, people with the impairments that you have listed out, are more likely to be seen as antisocial and perceived by society and our institutions as antisocial. That makes it easier to evict people for antisocial behaviour. It is a huge concern. We have not seen that borne out yet. The legislation has not been brought in.
Being very frank, landlords have not had to use that legislation before because they have always had section 21. We do not know the damage that that legislation will cause, but it is a huge concern.
Q26 Tom Hunt: I want to ask about any potential registers where disabled people would get information about appropriate properties. I am dyslexic and dyspraxic myself. The way I process information is perhaps different from the way that other people process information. I can really struggle with the way things are presented, particularly when it comes to online systems and processes. There are many others who might struggle a lot more than I do.
If we have this non-centralised variability between different areas’ systems, it concerns me that it will not be set up and framed in a way that is appropriate for individuals who may have a range of neurodivergent needs. Would it be an added attraction, therefore, to have a more standardised national system? If there is one, you can ensure it is done in that way.
Christina McGill: Yes, as long as it is well informed. The important thing there is that it is meeting people’s needs from the point of view of people who are really well informed and well consulted.
Jacquel Runnalls: Yes, with disabled people, but the thing that is also often missing is that support, advocacy and advice. It is all very well to have systems, but what if you do not have the support to navigate it? I know just from working as a housing OT with an accessible housing register that the London accessible housing register was set up to give disabled people an informed choice and to follow the social model of disability, but because choice-based letting systems are so difficult to navigate, what has ended up happening is that, where housing OTs are employed, it is much more about hand holding or getting to know who is on the waiting list.
Whatever system you have, people will always need support, so it is about training, information, support and advocacy, but particularly working with disabled people to find out what works for them.
Q27 Tom Hunt: Finally, it seems to me that, clearly, we are identifying here a series of problems that need to be addressed, and a system that is not working for disabled people. For physical disabilities, clearly it is not working as it ought to, but when it comes to neurodiversity, or more hidden disabilities, do you think there is a particular problem there of lack of awareness that is perhaps even greater than physical, or do you think they are both about as bad as each other when it comes to how far we have to go?
Christina McGill: To the point that you made about the provision of information, that might be one area that is particularly challenging at the moment, because the understanding about practices and information policies that can be supportive or not is still emerging at this time, so we should see more on that.
In the social housing sphere, another thing that has come through the new consumer standard is providing information in a range of formats that is suitable to people’s individual needs. There is a way to go to bring everybody up to an understanding that that is not just about visual impairment. There is more to it, so upskilling everybody who is responsible for providing this information in that wider, diverse range of needs is really important, yes.
Q28 Mrs Elphicke: Following up on some of the aspects of complexity and categorisation, I am just wondering if there has been any experience or concern regarding legal liability for the categorisation of property. If the sort of approach that we have explored today were to be implemented, do you think that an external validation, for example, like that which applies with EPC certificates, could aid the adoption of landlords, conveyancers and others being more engaged with the process?
Jacquel Runnalls: Yes, that would be a great idea. Certainly, working on the London accessible housing register way back in 2004, we developed a whole toolkit, but it was alongside disabled people. The categories are dated now; they need updating, but it is about having something that is well recognised.
The other thing is about understanding and expertise, though. You still need to have that expertise about what you are assessing and what you are looking at in a property, but anything that gives it validity would be great. Again, it is just about having the same categories, and then people also get to know what it means. There will always be nuances, and that is where you need a bit of support and advocacy, but I do not see how it would be a negative thing.
Christina McGill: I would agree with that. Having something that is similar to and even done at the same time as EPC inspections would be a real step forward. The key thing that we see at the moment, though, is that even people in roles where you would imagine there is a good understanding of the current building regulations standards as they are maybe have misunderstandings about the standards, why they are the way they are, what they mean, how to read a plan, and how to understand if that plan meets the standard or not. There is a big job of training to be done to bring all the experts up to scratch with that kind of thing, but it would be a good idea.
Mikey Erhardt: Yes, I would agree with that assessment. It speaks to the need for local authority funding. You want skilled practitioners in this area to pick up on the nuances that have been pointed out by members of the Committee. You cannot do that without funding and capacity at local authority level.
Mrs Elphicke: The who is a different question from the what, but thank you. That is incredibly helpful.
Chair: Thank you all very much for coming. There has been a lot of very helpful, detailed information for the Committee to consider about the challenges that people with disabilities are facing. I am sure we will reflect on and take account of that when we come to do our final report. Thank you very much indeed.
Examination of witnesses
Witnesses: Victor Chamberlain, Adrian Dobson, Timothy Douglas and Sam Stafford.
Q29 Chair: Thank you all very much for coming. I will just ask you to begin by going down the table and saying who you are and which organisation you are here on behalf of.
Victor Chamberlain: Good afternoon. I am Victor Chamberlain. I am representing the local infrastructure and net zero board of the Local Government Association, and I am also the leader of the opposition in Southwark.
Adrian Dobson: Hello, I am Adrian Dobson. I am the executive director for knowledge and standards at the Royal Institute of British Architects.
Timothy Douglas: Good afternoon and thank you for the invitation today. I am Timothy Douglas. I am head of policy and campaigns at Propertymark. Propertymark is the UK’s largest professional membership body for property agents, with 18,000 members working across the UK in sales, lettings, commercial, valuers, auctioneers and inventory service providers.
Sam Stafford: Hi, I am Sam Stafford. I am planning director at the Home Builders Federation. Over 300 or so HBF members are responsible for building about 80% of the houses in this country.
Chair: Thank you all very much for coming. Before we go to the first question, I will just say that there are four of you on the panel today. If you hear something you agree with, you do not have to say it again. You can always say that you agree. That is almost an invitation to try to make sure that we get through all the questions that we need to address to you today.
Q30 Kate Hollern: As we heard from the previous panel, there is a clear demand for more adaptable and accessible properties. Why is there such a limited supply?
Adrian Dobson: As you have heard in the previous session, while this M4(1) category from the building regulations is the baseline standard, we are unlikely to see a big increase in the supply of buildings that meet the M4(2) category. There is some good practice. The London plan asks for 90% M4(2). I believe that Leeds is currently consulting on 30%. Hull has a requirement for 25%, but it is unlikely that we will see a big uplift without an implementation. The Government have already indicated an intent to raise that baseline standard, but we have not had the consultation on the implementation yet, so I think that is what we really need to get some momentum on.
Timothy Douglas: From Propertymark’s perspective and speaking to our members, particularly the sales and letting agents, we have failed to build enough homes, as was outlined in the first session, but we have also failed to build the right type of homes that people want.
One of the challenges that people with disabilities have faced when securing a new home, based on feedback from our members, is that the accessible homes they need vary greatly. Again, it was alluded to in the first session that there is a significantly different type of property that is required. We are not building bungalows anymore; that comes up often. Agents ask for those requests. Flats, including retirement apartments, do not have proper access or charging points for electric wheelchairs.
There is a whole range of things, but, certainly from our letting agent members, there is a lack of suitable property choice for applicants. There is one agent here who works in Bath, so in the city. They have a large amount of Georgian listed buildings, and it is often very challenging for renters to access those buildings or to get adaptations. Of course, people think that those people renting with a disability should have more contemporary properties, but they are only a small percentage of the stock that is available in that city.
Sam Stafford: The obvious big point is that we are not building enough homes per se. Looking at the percentage of homes delivered by way of section 106 agreements, if RPs are relying on section 106 for their stock rather than development itself, and if private completions are falling, then section 106 completions will fall.
I was quite struck in the first session by the references to local plan policies. Again, last year the number of local plans that were published in draft, submitted and adopted was the lowest, even lower than the year before, which was the lowest for a decade. When I was here last, we were talking about housing targets. For every delayed local plan because of housing targets, that is a local plan that is not doing everything else that a local plan should be doing, like putting local policies in place.
Now, we could talk about national development management policies, which would be a way of levelling that policy framework in this area across the country, outwith legislation and moving that baseline up through building regs. Some authorities have gone closer to M4(2) through supplementary planning documents, local policies and such. The industry is wary of having different approaches in different local authority areas, which makes the case for national development management policies, but ultimately the development industry builds to the policies and regulation in place at the time, and could go more quickly in that regard.
In fact, it is quite striking that, of 400-odd responses to the 2020 consultation that was referred to earlier, 98% of respondents were supportive of the principle of making homes more accessible. This should not be contentious.
Q31 Kate Hollern: No, it absolutely should not. Do you think it is simply the case that fewer accessible homes are built because they are seen by developers as less profitable?
Victor Chamberlain: From the local government’s perspective, we feel that we are best placed to provide the housing that meets the needs of disabled people. If you look at affordability, for a lot of disabled people social housing is the only viable option. It is the only one that remains affordable when you take into account local housing allowances, and we are seeing that the private sector is not responding to local need in quite the same way that we do in local government.
We also need rapid and large-scale support from Government to go out and build a whole new generation of council housing that will be adaptable to individual disabled people’s needs.
Q32 Kate Hollern: Can I just come back to Sam? Is it because they are seen as less profitable?
Sam Stafford: I will pull you up on the profitability point. Let us say a national builder that is operating nationwide is looking at two sites. One is a greenfield in the south and one is a brownfield in the north. In the south, the local authority does have a policy that requires, say, 10% M4(3) on the private stock, as well as section 106 agreements and such. Maybe the authority in the north has not. Into the appraisal of those two development opportunities, the developer making land bids is putting the same number for profitability into that spreadsheet. Those two schemes, on paper, will be as profitable as each other.
The issue in this space, and other areas of built fabric and built standard, is viability, not profitability, because if you were to apply the same standard from the greenfield site in the south on an M4(3) property, which is significantly more expensive to build, in the north you would not be bidding for that land because you would not be getting to a land value that would be acceptable for the landowner to sell it to you, if that makes sense.
Q33 Kate Hollern: It does, but there are huge profits for developers, are there not?
Sam Stafford: They are doing alright.
Kate Hollern: They are doing a bit more than alright.
Sam Stafford: But, on an individual site-by-site basis, the site has to stack up, in the parlance.
Q34 Kate Hollern: You spoke about the north and south. Are there any examples of regions doing it better than others?
Sam Stafford: Generally speaking, there are some issues with sanitary provision in M4(2), I believe. M4(3) is very expensive to be making wheelchair-accessible homes beyond a detached or a bungalow. Bungalows rub up against the drive for density, so we have conflicting policy objectives already.
Generally speaking, the development industry is relatively relaxed about M4(2) becoming a baseline. The key thing for industry is stability, certainty and a regulatory framework that can be planned for with certainty. I have not read the reports fully, but I hear, for example, today that there might be some rowing back on the commitment to heat pumps and the phasing out of gas boilers. Now, there will be a technical director at one of our members somewhere who has been pulling their hair out because they were trying to work out through their supply chains how to find enough heat pumps a little bit further on down the line, and now they are not. That is the regulatory challenge that anything in this space causes our members, not necessarily the principle.
Adrian Dobson: In terms of the higher baseline standard that we are arguing for, the M4(2), it is probably important to say that it is about accessible and adaptable dwellings. We are talking about dwellings that have level access, living space on the entrance level, and slightly more generous circulation areas; then they can be adapted if somebody becomes disabled or elderly, or even if they have small children. It has a slightly higher spatial requirement, so inevitably the cost is slightly higher, but it is only by imposing that baseline that you will get the levelling up across the geographical base. That is why it is probably necessary.
As has also been said, the M4(3) category, which is completely wheelchair accessible, is going to take more space. Again, you are going to have to ask for certain percentages. In the previous panel, 10% was suggested as the London percentage. Perhaps 10% to 15% is where we are going to have to get to, bearing in mind that these are only standards for new build, and we have a very old housing stock. It all takes place in the context that we have the smallest houses in Europe on average, so we are not talking about incredibly generous space here; we are talking about bringing it up to an adaptable standard.
Timothy Douglas: From Propertymark’s point of view, it is slightly out of the remit of our members building homes. However, the feedback we get is that there should be more encouragement for developers to build disability-friendly property. Greater use of the section 106 agreements or discounts on the community infrastructure levy should all be looked at and made use of by local authorities where they can.
A lot of our members would say that you have to look at the evidence locally, and that goes back to local plans. It was said in the first session that disability is only referenced as a definition in the national planning policy framework, and nothing further, so there is definitely more we could do.
Borough councils and county councils need to integrate the powers that they have in terms of transport, infrastructure and social care provision. Integration across councils is important, but it is about making the distinction between new homes and existing homes. An accessible housing register would certainly help across social, private, rented and owner-occupied in each local area.
Victor Chamberlain: I very much agree with you on that point, Tim. Wheelchair-accessible homes are only provided where there is a local demonstrated need, so where the local need is demonstrated through the planning policy. That means that you get this patchwork quilt of policy. You have areas like London where 10% is being provided for all new housing to be wheelchair accessible or easily adapted, but that is not the case everywhere across the country. It is a postcode lottery, and that should not be right. We need a more universal approach to this.
Q35 Kate Hollern: Just on that point, there is also financial support, but what other support could the Government give to make houses more accessible and more affordable? We are always talking about wheelchairs, but of course there are other disabilities.
Victor Chamberlain: Absolutely, and we should always be mindful of that when we are talking about this. You need to think about disability in the round. I was here for your discussion earlier about the disabled facilities grant and the fact that that is just so inadequate to meet the needs. That is one aspect.
Chair: We are going to come on to that with the further questions.
Victor Chamberlain: From a local government perspective as well, one of the key ways that we are able to support disabled people is through adult social care and the support and services that we provide that way. Everyone in this room will be well aware that we must address the billions of pounds in shortfall for adult social care if we are going to continue to be able to provide those essential services and the support that we need for disabled people in the housing sector.
Q36 Ian Byrne: The national planning policy framework makes little reference to disabled people; it mentions bats more. How could the NPPF and, by extension, local plans be revised to put greater emphasis on the housing needs of disabled people?
Adrian Dobson: Yes, I did check this just to make sure that I was not saying the wrong thing. At the moment, accessible and adaptable housing only features as a footnote in the NPPF. There are some other references to meeting housing need, but it is just a footnote.
It has to be recognised, though, that we are in a world where we seem to be putting quite a lot of things that used to sit in building regulations within planning, such as sustainability. In actual fact, some elements of fire safety have now moved that way. It is about not just the NPPF itself having more meat on this issue, but also recognising that you need capability and skills within the planning authorities and the funding that goes with it. Yes, the NPPF could be strengthened in this respect, but there are other aspects to loading more and more expectation upon the planning system.
Q37 Ian Byrne: Would that be a recommendation?
Adrian Dobson: Yes, I think so.
Ian Byrne: Does anyone else want to come in on that question?
Sam Stafford: I do not want to keep banging on about the standard method, but a lot does seem to head us back in that direction. The standard method is the starting point in the NPPF, but too often, because of the contentiousness of housing issues and because so much is being dealt with locally and not at a greater than local level, the standard method is a starting point and an end point.
By the time you get to an examination, it is eight months down the line. Everyone is so sick of talking about housing needs that they say, “We will just take that figure, thank you very much”. Nobody is paying any attention to the paragraph that says that, within the context of the standard method, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies. That is just not given the attention because of the contentiousness of the target, as well as green belt and everything else. It is already there.
If you dealt with the contentiousness of that, maybe we could then have a conversation about policies, because there is a lot of crossover in this space with housing for older people as well. That is very much not given the attention that is needed in local plan policies. In my personal opinion, that is because of the contentiousness of just getting there in the first place.
Victor Chamberlain: Most councils will also take into account their equalities duties through an equality impact assessment when they are setting out their local plan, and that will look at the positive and negative impacts that could be incurred by different groups and those with protected characteristics.
It is notable that, in the recent consultation on the NPPF, there was no mention of the Equality Act. That is something that perhaps the Committee would like to look at.
Q38 Ian Byrne: It is a glaring omission, absolutely. I will just go back to Adrian. What is stopping developers from making M4(2) adaptable housing the baseline standard ahead of the regulation?
Adrian Dobson: I am sure cost must come into it, but our impression is that there is not huge resistance to making M4(2) the baseline standard.
Ian Byrne: They have done that before.
Adrian Dobson: Yes, that came through the consultation. It is probably more difficult when it comes to M4(3). We are then back to positioning this with planning. The weakness of it is that we all know that it is quite difficult for local planning authorities to keep their local plans up to date. When we looked into it, less than half of local planning authorities have any requirement for M4(3). That is the bit where I suspect the development community will need the bigger push.
Q39 Ian Byrne: Sam, can I just touch on a question that came from Disability Rights? Why are accessible homes regularly removed from plans at the viability stage, and what arguments do developers use?
Sam Stafford: I made a note of that. I would like to explore that further. That is not something that I recognise.
Ian Byrne: It would be good if you can make a note. If you write to the Committee, that would be really good.
Sam Stafford: Applicants will be making applications that are consistent with policy, and authorities can turn those applications down if they are not. Then, post-planning, building regulations submissions will be going consistent with building regulations.
Q40 Ian Byrne: You do not think that is a culture within the industry.
Sam Stafford: That is very much not something that I recognise at all.
Q41 Ian Byrne: Victor, in 2008, the EHRC found that 68% of local authorities reported that developers did not comply with accessibility requirements. Do you think anything has changed in the five years since?
Victor Chamberlain: The answer is probably not enough. We have to work with all partners in local government, and we need to work very closely with developers to help them to understand how important this area is. That is an ongoing process.
We need a lot more homes of every type and tenure, so we have to work with the private sector to be able to get homes that are suitable for disabled people, but that are also suitable for lifetime homes and that can be suitable for adaption. I would not be able to quantify how much it has improved, but we have not seen enough progress, or certainly not at a quick enough speed.
Q42 Bob Blackman: I will probably start with you, Adrian. Obviously, there is an amount of money that has to be spent on making a home accessible, and that means that that home is then presumably permanently made in that position, so how do you market and marry up those disabled people with the property that they need?
Adrian Dobson: You did touch on this in your first session. There has already been talk of this national accessible housing register as being one particular method. There is the notion that you might make this information available through the property and selling websites, such as Rightmove and Zoopla. You could have some kind of rating basis. If we were going to go down that way, at the moment the classifications within the building regulations are a bit arcane. They are perhaps discussed in certain circles, but, if we could use those classifications as the basis, that would be quite helpful.
The key point here is that we have a very old housing stock. About 10% of our existing housing stock would meet what there is fairly general agreement is quite a low standard, the M4(1) standard, so there is huge scope to get on record what is happening with those buildings. That is where, in a sense, the real work is. The plea we are making to raise the baseline standard for new dwellings is because that seems to be the only way that you can really accelerate progress, but it is the existing stock where the attention is really needed.
Timothy Douglas: From the property agents’ point of view, the requirement on the portals has come up. Certainly, we know agents who, over the years, have consistently used accessible property websites, such as accessible-property.org and AccessiblePRS, which I know was mentioned in the first session, to advertise specific properties. Certainly, they need to be more widely published and more promoted.
In terms of the portals and specialist features, yes, there is a project by the National Trading Standards estate and letting agency team to improve upfront information. This is not about new regulations or legislation; it is the consumer protection regulations, but it is a new framework in order to present that information. I spoke to the legal counsel at the largest portal last week about this issue, and they said that they are building the filters and the capacity for dropdowns to be included on adaptations and what the property has.
It is a positive step across the board in terms of upfront information, not just helping people know what they are purchasing and reducing fall-throughs, but, certainly in this space, the information about adaptation should be added.
Q43 Bob Blackman: Do you have any recommendations? We are talking about a future private sector portal, which should operate on a national basis. Are there any recommendations that you would make that should be included within that, and have you put those in to those who are creating it?
Timothy Douglas: We recognised what was said about utilising the new portal and the database, and we would encourage that, definitely. That seems to be the direction of travel through the legislation, so we need to utilise it. You need to make a distinction between who is managing the property and the property building, so there is individual and property that will be included in the portal.
The wider point around the private rented sector is that, ultimately, a landlord register and a register of properties will help, but fundamentally we still do not have any regulation of property agents. We do not have any register of landlords, so ultimately we are still not quantifying or regulating the people behind that information. That certainly would help, and further education, training and qualification, where modules could include accessibility and equality, could be included on that syllabus through the qualification and statutory code of practices. All of that needs to be taken into consideration with this new PRS database as well, definitely.
Sam Stafford: All I would say in relation to new build property, in particular with regard to M4(3), is just about the need for those homes to be available for that use in perpetuity. On that basis, the section 106 RP model is the framework to do that, rather than a percentage of open market by way of planning policy. It is anecdotal, but I am aware of six homes on a 254-home scheme in Hertfordshire that were marketed for that purpose, and within a very short period of time those adaptations have been taken out by purchasers down the line. That, as a mechanism, is much more effective than a percentage of open market sales.
Victor Chamberlain: I would just add that information on accessibility is often particularly poor in the private sector, but that can also be true in the public sector too. Tenants bidding for properties can sometimes find that they come up against the—
Q44 Bob Blackman: You will get people bidding or coming in with disabilities who are homeless or threatened with being homeless. How do you marry them up then to a property that they will need, given their needs will often be quite specific?
Victor Chamberlain: Too often, we as local government do not do enough or a good enough job on that, but, bluntly, that is because we just do not have enough social housing in the country. If we were able to build the 100,000 homes a year that we need in local government, we would have the capacity to be able to match people up better to the diverse needs that they have.
I am aware that, in my borough, there was a lady who was waiting 22 years to find an accessible home that met her needs. She lives on crutches. She cannot get up. Her lift is frequently broken. She cannot get in and out of her bath. There simply are not enough homes in our borough that are suitable for her needs, so we need to build a lot more.
Going back to your question, there is a lack of information in the sector. Councils should be supported to provide independent sources of information and advice for people on housing support and care services. That is one area that we could certainly be supporting local government further on.
Q45 Bob Blackman: Can I just come back to you on this one issue? We are going to talk about the disabled facilities grant in a minute. In terms of funding for local authorities to do this sort of work, do you have a scale of what would be required?
Victor Chamberlain: I do not off the top of my head, but I am happy to go away and consult some colleagues, and I will write back to the Committee with some more information if that is okay.
Bob Blackman: That would be very helpful.
Timothy Douglas: While a national centralised database will help, you cannot underestimate that local authorities will still need local registers, and they need to know their local areas. Of course, local authorities are under pressure with resources, but we want to get away from the fact of people bidding. If they continue to work with agents and landlords, then you are placing people in property. You are not just doing adaptations on an ad hoc basis. They are building up a database of information.
Propertymark and our regional executives engage with local authorities as best possible, but before Christmas we did an FOI request and, of the 112 local authorities in England that came back to us, around half indicated that they have not held a single landlord forum since 2021. There is no civic engagement for property agents. It was concerning that only a small number of local authorities were preparing forums for 2024.
I know we have had Covid and the pandemic, and resource is tight, but there is more that can be done to engage that partnership working between agents, landlords and other local agencies in order to place people, so that it is proactive and not reactive.
Q46 Bob Blackman: The one issue, of course, that is important here is that the range of disabilities we are talking about can be quite wide, or the needs can be very different. Therefore, matching those up is going to be key.
I certainly take in what Sam has said about people buying properties and then taking out the disabled facilities, which is a concern straight away. Otherwise, people might either buy them and then rent them out for disabled people, or disabled people might choose to buy them. It is clearly a mismatch that we have to deal with.
Q47 Andrew Lewer: I always found during my time as a councillor and particularly as a local authority leader that disabled facilities grants were some of the more complex procedures that we had to deal with, let alone the people with the disabilities trying to cope with it.
That built on work with the Motor Neurone Disease Association and its “Act to Adapt” campaign, which argued that there was so much red tape around some DFGs that it would be better just to pay them out. That would cost less money than the bureaucracy of all the checking and layers of procedure involved.
However you go about it, there is a finite amount of money. In that context, does the panel have a view on the Government uprating the £30,000 limit, which is the current limit for any individual disabled facilities grant?
Victor Chamberlain: I suppose it is not shocking to hear that I think that the current DFG is insufficient to meet demand. We know from DLUHC’s own information that there are around 2 million households with people who have health conditions requiring adaptations. The additional £50 million of funding that has come through is very welcome, but it still does not allow us to get to a level where we can meet demand. As was discussed in the previous evidence panel, with bill cost inflation and the cost of doing serious major works and adaptions, it just does not touch the sides, really. We need a significant increase in support for DFGs from Government.
The risk as well is that we have local authorities picking up the bill and filling in the gaps. Where we do not have the support from DFG, local authorities are acting using their own adult social care budgets. That means that we are increasing pressure even further on adult social care, which, as we know, is an area that needs a lot more attention.
Q48 Andrew Lewer: Yes, absolutely. Within those huge pressures you describe, would you regard being able to do larger numbers of disabled facilities grants as a priority, or upgrading the £30,000 limit for large-scale adaptations?
Victor Chamberlain: Can I say both? We probably do need a bit of both. The reality is that £30,000 is just insufficient. It has not been increased in 15-odd years. We know the cost of living has gone up. So has the cost of doing major works, so we need to take it up in line with the current cost of inflation, but the pot itself probably needs to be larger too so that we can go further and support more people.
Adrian Dobson: I do not have much to add on the grants, other than that, at a time of high inflation, thresholds rise. The construction industry has seen a lot of inflation. Other than that, I just want to reinforce the more general point that having more accessible and adaptable housing must, in the long term, relieve some pressure on the capacity of health and social services, so there is a long-term investment argument, however you are spending money in any of these arenas.
Timothy Douglas: We at Propertymark would certainly agree that the amount needs to rise. It has not even risen with inflation. It is surprising that it is even lower than Wales as well, based on the size of the population and housing.
Before we get to the grant itself, awareness among agents and maybe wider property agencies and landlords is really important. We did a small focus group of 50 agents before I came to the evidence session today. We asked a couple of questions. “How supportive are landlords to requests for property adaptations?” and 47% of agents said that landlords are supportive, but when we asked, “Are you familiar with the disabled facilities grant?”, 65% said no. “Have you ever signposted the availability of the grant to your customers?”, and 92% said no.
From a professional body point of view, there is a lot more that we can do and are continuing to do, but there is that lack of awareness. We need to improve the signposting, and ultimately that, as we said at the start, can feed into that strategic planning from local authorities.
Sam Stafford: This is not something that I am really qualified to speak on.
Q49 Andrew Lewer: Victor, why do you think the disabled facilities grant process takes so long, and how could it be accelerated? This is not so much a funding point, hugely important though that is. This is really a process point.
I wondered about your view of cutting down on checking. This basis that MNDA and others have made is that, yes, every now and then you will make a grant that is not strictly necessary or might not have been absolutely ideal, but to find all that out for every single application ends up costing more than the benefits of just getting on with it and letting the odd one slip through the cracks.
Victor Chamberlain: I have to confess that I am not an expert in this area, so I would have to come back to you with some evidence having spoken to colleagues about that. I know that the system is extremely bureaucratic, and perhaps that is one area where we could improve it to make sure that we are dealing with what the DFGs are there to do.
Q50 Andrew Lewer: If you do, I would be grateful if the LGA could look into whether two-tier local authorities are particularly bureaucracy-ridden with this, because I have a slight suspicion, having served on both and now being an MP for a unitary, that they are.
Victor Chamberlain: I will take that away.
Andrew Lewer: Thank you. That would be appreciated. Does anyone else have any views on process improvements with DFG?
Timothy Douglas: Yes, I have two examples from a landlord I have spoken to and a letting agent. One landlord I spoke to fairly recently has a large number of properties, and he was keen to adapt a property but has no sitting tenant. He wants to adapt and create a specialist property for the future and put that on to the property start in his area, but he has not been able to access any funding because, ultimately, he does not have a tenant or an intended tenant to be in that property.
We either need to relax the criteria around the grant or allow a separate pot of funding that landlords can access if they want to specifically develop a property. He had some frustration there that he could not access it without having a tenant, essentially.
The other example I have is a letting agent who had a tenant in situ. Unfortunately the tenant had a road traffic accident and had to make adaptations, but while the application process was going on, before the funding was approved and the adaptations were made, sadly the tenant passed away. Are there standard timeframes that a local authority has to respond to for this specific type of funding? If not, it should potentially be looked at whether there needs to be a fast-track process through planning in that local authority if planning adaptations are needed and it does not get clogged up in the planning processes there. Hopefully, those are some suggestions.
Q51 Andrew Lewer: That is helpful. Thank you. I had a case of someone with motor neurone disease and it took so long to put a ramp in that the only time it ever got used was to take him to the ambulance to take him to the hospice, so he only used it once. Of course, local authorities have a challenge in terms of assessing spend that someone will use and benefit from for years versus spend that either may be too late or only has a very limited usage, particularly if it is a very specific disability.
You have touched upon this obliquely already, Timothy—19% of disabled people live in the private rented sector. Only 8% of disabled facilities grants are spent on adaptations to private rented homes, so there is a significant discrepancy there. I wondered if anyone on the panel had any views about why that discrepancy existed and how it might be rectified.
Timothy Douglas: From Propertymark’s point of view, it comes down to more awareness of the grants and more co-ordination locally with landlords and letting agents. Then it becomes a case of recording and creating a register of properties that have been adapted.
Another key element that we need to concentrate on is retaining that property once it has been adapted. Normally, from speaking to agents, it tends to be arrangements between the landlord and the tenant, and perhaps an agreement that, once the tenant has moved on, then the adaptations are reversed. We need to try to look at whether there are, dare I say it, incentives for landlords. In the market we have at the moment, where there is high demand, they are potentially more likely to reverse the adaptations to get the property back on the market. Is there an incentive, perhaps through council tax, to reduce the worry about a void period in order to get another tenant with a disability in that property and utilise it as best possible?
Victor Chamberlain: I broadly agree with Timothy there. There is a need for an information drive to increase awareness about the DFG, particularly in the private rental sector. A lot of private landlords, anecdotally, are reluctant to adapt homes that would suit a tenant. If they knew that there was a grant available to address that particular issue, they perhaps would not be. If we can improve the information among the PRS, we could do a good amount of work there.
Adrian Dobson: Let me just go to the point that was raised earlier. There is a slight trap in raising the numbers of, say, wheelchair-accessible dwellings that are built. There is this trap that, because, inevitably, the space standard is slightly more generous, it is not just at letting or second sale that it might not be used with that purpose in mind, but even before it gets to that market. We have this curious thing that we tend to sell properties on numbers of bedrooms and this kind of thing, so you can see how it could be subdivided. There is a risk there that we need to think about.
Andrew Lewer: Yes, it is the usual onion with all these grants. The more you look into it, the more complicated it seems than it would at first look.
Q52 Mary Robinson: This is just a quick follow-up, and it was partly answered. We heard earlier from Mikey, who is a disability rights campaigner, about a case that he had. Somebody just wanted a grabrail in a shower and the landlord refused. He said quite clearly that some of the barriers are landlords’ refusals in the private sector.
Awareness is one thing, but what are the reasons why they are refusing? Is it because of the dilapidations when a person moves on, or is it that they cannot be bothered to make the adaptations that are needed? It is easier not to.
Timothy Douglas: It is disappointing to hear that. Certainly, you would think that the smaller adaptations could happen with a conversation, and I am pretty sure they do in the majority of cases.
It is very difficult to justify that, and I am not going to defend it, but I would say that ultimately, if you are a landlord and agent renting out a property, there are now over 150 laws. There are over 300 regulations. There is a whole wide range of things that they need to consider. Yes, being a landlord comes with, as has been said, profits, but that is huge responsibility. Again, we have varying degrees of management practices, varying degrees of people and landlords, and different types in the sector. You would like to think that, on that occasion, perhaps it is a combination of those factors. We definitely encourage our agents to engage with tenants on that basis.
Q53 Mary Robinson: There is no regulator, as you pointed out, for estate agents as such. Should there be one? That would be a question, but what message would you send to your clients about what they should be doing now in terms of adaptations?
Timothy Douglas: From the regulation point of view, Propertymark advocates for the regulation of property agents. All our members are qualified, and we audit them, do compliance visits and look at their accounts. With the Building Safety Bill, the Renters (Reform) Bill, and the Leasehold and Freehold Reform Bill, it is absolutely wrong that managing agents, estate agents, letting agents or anyone on a new build development is not qualified and working to a code of practice or a regulator to manage or sell that property. The Secretary of State has said that all property managers in the social rented sector should be qualified, so we should be doing that across all tenures and extending it.
We advocate for that regulation. We are developing guidance at the moment for agents, both in their own offices, to ensure that their offices are accessible for clients, and when they are managing a property. We have done a lot of work on the upfront information with the National Trading Standards team and the portals to ensure that all that information is going to be correct for consumers.
Q54 Tom Hunt: In terms of this discussion about the discrepancy between 19% of disabled people being in the private rented sector and only 8% of the disability funding grants going to that sector, and the discussion about perhaps more enforcement and the reasons why different landlords do not make adaptions to properties, were there to be a movement in the direction of more enforcement, more legal obligation and more teeth, do you think there would be a risk that, if it was not handled in the right way and the communication was not good enough, some landlords might say, “This is all too much trouble. I am going to leave the sector”? Just playing the devil’s advocate, is that something you would be concerned about?
Timothy Douglas: You will always get landlords who will leave the sector, but you will always get people who come into the sector. There is not one type of landlord or property agent. There are different models out there. There is a whole range of things. We have talked about legislation, but there are tax changes and energy efficiency. There is a whole range of burdens that come with renting out a property.
The suggestion by Mikey in the first panel was that we should be moving towards adaptations not being unreasonably refused. He made a good point that we are focusing a lot on pets and perhaps not on this issue. The Renters (Reform) Bill is an opportunity to level the playing field in this area.
Q55 Mohammad Yasin: Recently, I met some of my constituents who came to my drop-in surgery. They were finding it very difficult to live in the property they have because of the lack of facilities. The toilets are downstairs and they sleep upstairs. The gentleman was in a wheelchair. They are living in a privately rented property, and are waiting for the council to provide them with a suitable property, but there are hardly any. They were very upset and in tears. In your view, Tim, are some landlords and letting agents currently failing in their duties towards their disabled tenants?
Timothy Douglas: As I said earlier, there are property agents who are using those specific websites and those portals to advertise property that has been adapted, but there is more that we can do in order to promote them. Where property has been adapted, that needs to be more widely advertised. We need to create more choice for people, definitely.
Victor Chamberlain: Some elements of the private sector are delivering good-quality homes for people who have disabilities. Things like build to rent are built to a really high standard and built to be accessible way into the future. That is a model that we could look to adopt more, although I am sad to say that the example you gave is one that is all too common up and down the country.
A lot of the time, there is a shortage of genuinely affordable homes that are suitable for a lot of disabled people. Until we start building significantly more social housing, we are going to continue to see disabled people being poorly served by the housing market.
Q56 Mohammad Yasin: Should there be a duty to offer accessible homes on the rental market to disabled people first, rather than to the highest bidders? It is very likely that the higher bidders will get there first, and disabled people who may not have a lot of money will lose out.
Victor Chamberlain: There is certainly an issue, when disabled people are looking for private rental homes, that they are facing discrimination. 45% of landlords have said that they would not be willing to rent to someone if it required adaptations, so we need to do something to support disabled people when they are engaging with the private rental sector. I would have to go away and look at your idea, but I am happy to provide some thinking from colleagues across local government on that.
Adrian Dobson: We have issues with our housing stock more generally. We have a lot of people in fuel poverty because we have poor insulation and this kind of thing. I am back to my point that there needs to be the capacity in the planning system to properly assess housing need. As a number of people have said, inevitably it requires a greater social housing provision. That is absolutely clear on a whole series of issues, and accessible homes is only one example of that.
The market demand should be there as well, because we are ageing as a population. Just as we are beginning to see, if we are talking more generally about accessible environments, the city environment and the town environment, and being able to get to public transport, there are advantages for a whole swathe of society that come from this.
Q57 Mohammad Yasin: How can central Government and local authorities work effectively with landlords and letting agents to support disabled people?
Timothy Douglas: I touched on this earlier.
Mohammad Yasin: You did, yes.
Timothy Douglas: We certainly feel that there is more that agents, landlords and local authorities could do to engage. As I said, almost half of the local authorities that came back to us on the FOI do not have a landlord forum in place, so there is no informal or even formal mechanism for engaging with the sector. That is something we would like to see happen.
We would like to work with local authorities in order to create a register of adapted properties in local areas. They could do that through a forum, because landlords and agents would be able to tell them where that stock is.
The wider issue is that, yes, we are not building enough homes, but Propertymark has long said that we need to move away from housing targets and concentrate on tenure. What is needed in each local authority? How many homes do we need for people to rent? How many do we need for people to buy? It is about adaptations to social housing as well. Moving away from targets and focusing on tenure is really important.
Q58 Mohammad Yasin: NRLA research shows that a third of landlords would be unwilling to let to a disabled renter with access needs in the future. Why is this happening and what can be done about it?
Timothy Douglas: Obviously, I do not speak for the NRLA, but there is a whole range of adaptations that might be needed for different property types. You would like to think that some of the smaller adaptations could be done in pretty much all properties, but there may be restrictions on the property that they own. In flats, you have superior landlords as well. Then different properties have different restrictions on leases. You would like to think that there are legitimate reasons, based on the building type, that may prevent that. Therefore, we need to engage and have wider conversations around why adaptations are not happening in those specific areas.
Q59 Chair: In terms of section 21 being abolished, do you think that will cause a slight change of attitude for landlords? Now, if a tenant comes along and says, “I need some adaptations”, the landlord can say, “Thanks very much. Go and find another property”. It will not be quite as easy to do that if section 21 does not exist.
Timothy Douglas: It is a very good point. There might be unintended consequences. The removal of the fixed term and going to periodic and open-ended tenancies may be more of the issue, because, ultimately, at the moment the agent, landlord or tenant would arrange to be in a property for a set amount of time. That potentially would allow for the grants and funding to be arranged.
Once we have moved to the new world, after the first six months the landlord will be able to use one of the grounds if they need to remove the tenant. A tenant will be able to give two months’ notice on day two, so there is an unintended consequence there that we are moving to a less secure system and more ambiguity. Some wider thinking needs to be done around the long-term linking between the grants, changing the property, landlord security and tenant security going forward.
We have said that, through the Renters (Reform) Bill, if we could retain periodic or fixed term as an option, based on the tenant’s needs, we could retain some extra flexibility and allow landlords to know that, for a year, two years or three years, they are going to have a tenant in that property. That might help with some of the adaptations, whereas in the new world it could be an unintended consequence.
Chair: Thank you all very much for coming and giving us, again, a lot of very helpful, detailed information. We are going to reflect on that and hopefully make some suggestions to deal with the problems and difficulties that you clearly identified for us. Thank you very much indeed for coming this afternoon.