Written evidence submitted by South Yorkshire Housing Association [RSH 038]
About South Yorkshire Housing Association
South Yorkshire Housing Association is a medium sized, locally focused association that provides a diverse range of Housing, care and wellbeing services in the Sheffield City Region. We provide charitable and commercial services for around 20 thousand local people. We employ 650 people and turn over £50 million annually. We are active members of the PlaceShapers group of associations and are committed to their values.
SYHA has strong views on the issues being reviewed by the Select Committee. We are committed to good governance and effective regulation of the sector and we believe improvements could be made for the benefit of tenants and the reputation of the sector.
How widespread and serious are the concerns about the quality of social housing?
Recent publicity about the stock condition of some housing associations has raised serious concerns both about asset management standards and the way in which some social landlords respond to complaints. These particularly relate to dampness and condensation, but other factors have been highlighted. In our view, this affects a minority of social housing landlords, but has dragged down the reputation and status of social housing as a whole. The last thing our tenants need is to feel they have been further stigmatised. Standards of decency in the social housing sector are far better than in the Private Rented Sector and for owner occupation. Nevertheless, a minority of predominantly large social landlords do appear to have fallen short in their service standards and their culture. This appears to be particularly the case for some organisations that are over-spread and/or over-large. Some large housing associations work in dozens of local authority areas and some work in well over 100. It is difficult to see how over-spread organisations can provide effective services locally.
South Yorkshire Housing Association is a strong supporter of the PlaceShapers’ ethos. One of the principles of PlaceShapers’ associations is to build close, constructive relationships with local authority partners. Our experience in South Yorkshire is that over-spread landlords who may manage homes in the Sheffield City Region do not have a strong presence – particularly at a senior level. Their Boards and executive teams are inevitably remote. I have worked in the Sheffield City Region for 25 years and I have never seen the Chief Executives of the largest associations that have stock here actually physically present in our local area.
The trend towards mega-mergers should now be reviewed. There must be a serious question about the quality and value for money of services of over-spread, over-large social housing providers. Perhaps it is time to consider whether some of these associations should be broken up into more compact regional organisations. The Regulatory Code currently says providers should consider whether to merge, it does not say anything about considering whether to break up organisations that have become unwieldy and lost direction.
We suggest that a requirement to work effectively locally with local councils and Mayoral Combined Authorities (where applicable) should be built into the Regulatory Code, and that the Regulator of Social Housing should monitor this. Under previous regulatory frameworks the regulators routinely contacted the local authorities in the areas associations operated and invited their views on the quality of this relationship. Restoring this accountability would be a progressive step.
The need to ensure strong links between providers at the local level, including the local authorities, chimes with current government thinking on place-centred responses to levelling up, rather than purely organisation-centred responses. Regulation should therefore reflect that.
This type of qualitative assessment could be applied to other measures. We do feel there has been a drift towards numerical, quantitative measures in social housing regulation.
What is the impact on social housing providers resources, and therefore their ability to maintain and improve their housing stock, of the need to remediate building safety risks and retrofit their homes to make them more energy efficient?
In recent evidence to the Select Committee, Michael Gove described this very question as the “Sophie’s Choice” facing social housing providers. He is absolutely right. This is the biggest financial and strategic challenge we all face.
At SYHA we have surveyed our stock and assessed the costs of bringing homes up to net zero carbon by 2050. The total is £150 million. This sum, if inserted into our business plan, would break our financial viability tests and loan covenants within the next 20 years. The Chief Executive of PlaceShapers, Matthew Walker, recently spoke individually to all the Chief Executives of the PlaceShapers’ 104 members. He reported back that only one of his members would continue to be financially sustainable if these costs were incorporated in their financial plans.
SYHA, in common with most associations, want to build more social homes to contribute to tackling homelessness. Our ability to do this, and respond to residents’ preferences for stock improvement, are being severely hampered by the increasing costs of meeting regulatory requirements in respect to building safety risks and new regulatory standards.
Is the current regime for regulating social housing fit for purpose?
The principles of co-regulation, mature scrutiny by the RSH and contents of the Regulatory Codes are broadly fit for purpose. We have noticed a significant improvement in the quality of regulation provided by the RSH in recent years. We have found the culture of the organisation and the quality of the officers we deal with have been proportionate and level-headed. There is mutual respect in our transactions. We do believe, however, that the role of the RSH should be strengthened by:
i) Requiring the RSH to monitor social landlords’ performance in tackling homelessness. We note the comments of the Kerslake Commission that:
“Housing associations are not public bodies, and therefore do not have a legal duty to address homelessness. However, housing associations do have social responsibility, and an important role to play in the provision of secure and safe accommodation, and support for people who are homeless or at risk of homelessness. The Commission is calling on the housing sector to drive forward a commitment to collaborate with Local Authorities and other public agencies, to prevent and relieve homelessness, and help develop solutions and strategies. To incentivise housing associations to prevent and contribute to homelessness solutions, the Regulator of Social Housing should monitor performance in this area.”
An extract of a note sent from Homes for Cathy earlier this year to MLUHC officers can be found below as a footnote.[i] This gives more detail of our suggested approach.
How clearly defined are the roles of the Regulator of Social Housing and the Housing Ombudsman?
In recent months the Housing Ombudsman appears to have strayed over into territory that is the responsibility of the Regulator of Social Housing. The more proactive approach that the Housing Ombudsman is taking is welcome in many respects, but the roles and responsibilities of the two organisations should be clarified to clear up the current confusion.
Does the current regime allow tenants to effectively resolve issues?
Please see the response above relating to the position at Clarion.
Do the Regulator and Ombudsman have sufficient powers to take action against providers?
We believe that the extent of the sanctions open to both organisations are sufficiently strong, but that the remit of the RSH should be extended as outlined above.
Will the reforms proposed in the Social Housing White Paper improve the regime and what progress has been made on implementing these reforms?
It is disappointing that legislative time has not been provided by the Government to enable the provisions of the White Paper to be enacted. Nevertheless, the housing association sector has broadly responded effectively to the challenges thrown up by the White Paper and by the Grenfell tragedy. In particular, the National Housing Federation-led campaign, Together with Tenants, has provided a useful framework for housing associations to make cultural change to address concerns of poor tenant engagement. Some associations have also made particular efforts to develop principles of co:design and place this at the heart of their tenant engagement. For example, at SYHA we have co-designed our new Customer Promises with a diverse group of tenants, have refreshed our tenant co-scrutiny and co-governance groups using the principles of co-design, and will be using tenant-led co-evaluation to monitor our progress on improving our tenants’ experience with us. If SYHA is called to give evidence at the Inquiry, we would be happy to expand on our work in this regard.
Locally, we have led the establishment of a collaborative group of social landlords. Local Authorities and ALMOs have joined local housing associations to develop best practice in responding to the agenda set out in the White Paper on tenant engagement. We have now met with Ed Miliband MP, one of the commissioners of the Shelter Inquiry into the Future of Social Housing, on three occasions and reported back to him on our work. He has responded extremely positively, describing the work of the group as “inspiring”.
One of the reasons that the group has been so successful is that housing officers have been joined by tenants from all the organisations. Many of the tenants have joined the Housing Ombudsman Sounding Board, ensuring good links with policy development in this area. The group has also been supported by policy officers from the National Housing Federation.
The proposed Tenant Satisfaction Measures [TSMs], currently out for consultation, are robust but purely capture surveyed quantitative data (mainly satisfaction scores), rather than the breadth and depth of rich insight that could be gathered from more qualitative or participatory evaluation. As in the Clarion case referenced above, a reliance on quantitative data as a performance indicator can miss the reality, or at the very least a sense-check, of the actual experience of tenants.
There is a strong possibility that many housing organisations will outsource the survey collection for the TSMs, for example, to ensure that the statistical accuracy requirements are met. Whilst this will result in TSM data that is compliant and statistically representative, it may inadvertently further lessen the opportunities for those in housing organisations to genuinely talk and listen to their tenants, and to hear their views on their experience in a wider or deeper way. There is a danger that the TSMs as proposed create an industry around data collection, rather than a meaningful focus on improving the quality of the tenant experience.
What changes, if any, should Government make to the Decent Homes Standard?
SYHA has been involved in developing thinking on this issue. We have nothing specific to add to the consensus that is emerging that the DHS should be refreshed.
Should the Decent Homes Standard be amended to include energy efficiency and other means of mitigating climate change, and if so, how?
See the answer to the previous question.
Should all providers of social housing, not just councils, be required to register with the Regulator?
Absolutely, there is absolutely no reason why the regulation of all social housing should not be brought under one regime.
What challenges does the diversification of social housing providers pose for the regulatory system?
SYHA is a particularly diverse organisation. The last time we received an IDA (In Depth Assessment) the Regulator suggested we should become a case study for the RSH due to the extent of our diversification. Some of our service areas fall under the regulation provided by the Care Quality Commission and other regulatory regimes. This has not been a problem for us, or the regulators concerned. When the RSH has considered issues relating to some of our more diverse services (e.g. Social Prescribing, employment support for people with mental health issues and the reduction of loneliness and isolation for older people) we have found them to be proportionate in their response. The respective regulators we have engaged with have all been clear about their roles; there has been no unnecessary duplication, nor has anything fallen between the different stools.
[i] We support this and would suggest that something even firmer, especially around preventing evictions into homelessness and ensuring allocations policies do not discriminate against homeless people should be incorporated. SYHA is a strong supporter of the Homes for Cathy Group which has been arguing this for several years. We would like to see associations required to publish their performance on these issues in their annual accounts and on their websites.
ii) The role of the RSH should be extended to ensure they are able to talk to tenants. Their inability to do so currently was highlighted in the recent investigation into the problems at Clarion Housing Group.
iii) We believe the Regulatory Code should be extended to highlight the issues of over-spread, over-large associations and the importance of their Board considering de-mergers or reducing the size of the organisation by disposing of stock.