Written evidence submitted on behalf of YMCA England & Wales [RSH 045]
a) YMCA is the largest voluntary sector provider of supported accommodation for young people in England & Wales, providing over 8,800 beds a night and providing specialist supported housing both as commissioned and noncommissioned services. Quality providers such as YMCA provide a vital lifeline to vulnerable young people, connecting them with councillors, advice and support, budgeting and life skill sessions, and helping them reach a place where they are able to move out and live independently.
b) Housing Stock quality at present is extremely varied and remedial work is often rarely undertaken in acceptable time frames; particularly when private head landlords let property to a managing agent or de facto mesne tenant to deliver a service. The legislative intent of the Government to improve transparency in the social housing sector is welcome and we believe that it will force compliance.
c) Labour shortages, lack of supplies, and limited ability to raise upfront funds are the main obstacles that we face as a social landlord when seeking to undertake remedial work and retrofitting at present. These pressures however promise to only be temporary as they are caused by domestic and geo-political circumstances that we are optimistic will be resolved.
d) The Decent Homes Standard is not the correct vehicle to provide stipulations on energy efficiency, as it is a set of standards that relate to the suitability of the property based on the safety and welfare to the tenant.
e) Older properties are often not suitable for retrofitting or have upper ceilings that can be met with regards to energy efficiency. For smaller providers, it is not possible to access carbon reduction funds for energy efficiency work and the funds require restructure to ensure that all providers can effectively and fairly access them. Expecting minimum EPC performance would in addition not account for a variety of housing stock and older properties.
f) We are pleased with the role of the Regulator of Social Housing and the Housing Ombudsman in principle. We would be pleased to see the capacity of the regulator and the Ombudsman increased in order to effectively deal with arising issues and have capacity to have a free flow of exchange between the regulator and the provider. The Government’s intent to increase the powers of the regulator and the ombudsman are welcome, provided they have the capacity to enforce. The regulator must be mandated to make contact with the resident and managing agent in order to ensure that it is able to effectively regulate.
g) We would encourage all providers to register with the regulator, regardless of size.
h) Increased overheads on providers must not be allowed to be displaced onto tenants, as this will make social housing unaffordable and not allow tenants to move on from social housing.
i) We recommend that the Government adopt a joined up approach to housing, and work to minimise duplication and ensure data is captured in the same way across regulatory frameworks. It is our hope that the Government's work on social housing will be the first step forward in this regard.
1.0 About YMCA
1.1 YMCA is the largest voluntary sector provider of safe, supported accommodation for young people in England and Wales, offering more than 8,800 beds a night and covering services ranging from emergency accommodation to longer-term social housing for young people. YMCA provides accommodation predominantly for young people aged between 16 and 25, providing them with access to a wide range of services, including youth workers, case workers, councillors, and support services. YMCA England & Wales represents a federation of 101 YMCAs, many of whom provide commissioned services at Local Authority level.
1.2 YMCA welcomes the opportunity to submit evidence to the Housing, Communities, and Local Government Select Committee Inquiry on the regulation of social housing. As a commissioned service, YMCAs operate mixed models dependent on local area, acting in some instances as the social landlord directly, as well as leasing housing stock from large providers.
2.0 The quality of social housing
2.1 YMCA believes that providers should aspire to exceed standards of the regulator for social housing whenever possible, and welcomes the legislative intent established in the Government’s social housing white paper.
2.2 At present, we have concerns relating to the quality of social housing stock provided by very large housing providers, and let to organisations such as our own for service delivery. In this relationship, the large housing provider acts as the head landlord, with YMCA acting as the intermediate landlord “managing agent” or de facto mesne tenant. Contractually, it is often the responsibility in this situation for the head landlord to undertake necessary remedial works and ensure that the building provided is in compliance with regulations, but anecdotally our managing agents report that this remedial work is rarely undertaken in acceptable time frames by the head landlord, leaving us with little recourse other than to repeatedly press for works to be undertaken and threaten legal action against the head landlord in order to ensure that the housing stock is maintained to an acceptable quality for our tenants.
2.3 It is our belief that the Government’s Social Housing white paper, in providing transparency, will effectively name and shame bad social landlords and push standards up, ensuring that remedial work is taken effectively and to a suitable time frame.
3.0 Maintenance of housing stock
3.0.1 YMCA welcomes the commitment to high standards and the intent of the Government to ensure that housing stock is maintained and provided at a decent standard. However, we are aware of a number of pressures, both financial and otherwise, that can cause restrictions on ourselves as a provider to undertake work on our housing stock.
3.1 Remedial work
3.1.1 At present, undertaking remedial work can be constrained and unreliable due to delays in obtaining necessary supplies and materials. Supply line disruption, coupled with the lack of availability of tradesmen to undertake remedial work places direct pressure on our smaller providers as their projects are not seen as of suitably large enough scale to receive priority attention. Our providers have also reported frequently that the costs associated with general maintenance have risen sharply which in turn increases our overheads as a provider seeking to maintain our properties to a high standard. This issue is further impacted by recruitment issues- our providers report general difficulties recruiting for positions, likely related to the economic impact of the coronavirus on the job market, which can in turn lead to delays on maintenance and repairs. It is our belief that these obstructions are temporary, and linked to external factors such as the COVID-19 pandemic and disruptions to the imports and labour market domestically- resolving themselves in due time.
3.1.2 While YMCA welcomes the Government’s commitment in the Social Housing white paper to place tenant feedback centrally to reporting against social housing providers, pipeline disruption and availability of workforce can mean that tenant feedback could be impacted if repairs are not perceived to be undertaken in a timely manner. Similarly, in situations where YMCA is a social landlord and provides or contracts in other services to provide support to residents, tenant feedback on housing expectations could be impacted on feedback regarding experience of services. It is important that the Government differentiates these two and ensures tenant satisfaction relates to housing, and can not be misconstrued to also include services.
3.2.1 Over the course of the Coronavirus, and the Government’s “Everybody in” strategy to tackle rough sleeping, many YMCAs undertook retrofitting work to bring units in compliance with Good Homes standards, such as the installation of ensuite pods in rooms in our accommodation provision.
3.2.2 YMCA believes that ensuring a high standard of accommodation is vital to ensuring tenant satisfaction and creating an environment where tenants are given the support that they need. YMCA strives to ensure that when work is undertaken in our properties, we are psychologically informed as to the environment created for our residents, and create an environment in which they feel comfortable- such as renovations and repairs to communal areas that create welcoming spaces. However, retrofitting places financial pressures upon providers that shoulder high upfront costs that although we as a provider may wish to install, we do not have the capital upfront in order to secure.
3.2.3 In addition to capital constraints, retrofitting and remodelling is often constrained by the nature of the building in which we are providing the social housing. While purpose-built buildings are often easy to remodel and repurpose to meet standards, older buildings often present more severe challenges and can cause reductions in housing stock as a result. One of the primary obstacles that we face with retrofitting in older properties is room size, and remodels may require us to take rooms out of housing stock in order to accommodate larger rooms with bathrooms etc. This presents an issue for us as a provider as the feasibility of our accommodation hinges on being able to provide a certain number of rooms, at a certain rate (exempt rate) in order to sustain the associated costs of providing our services. As such, older properties are much less suitable to retrofitting than purpose-built properties; and while our ambition is to provide homes to the highest possible standards, the availability of land for new builds is often extremely limited geographically- many of our providers operating in areas with higher house prices or more densely urban environments may not have the capital accessible to them to acquire land for new builds in the area, or there may be physically no space in a suitable location for a new build to be situated, meaning that expanding our provision to meet the demand for social housing relies on retrofitting older buildings so that they are suitable. We are pleased that Homes England shows at present good appreciation of geographical and land value pressures, and can make allowances accordingly.
3.2.4 Presently, YMCA providers benefit from Local Housing Allowance exemptions. The additional capital that we are able to raise through this is crucial to our providers in order to make improvements to the property. It is our concern that increased scrutiny over provision of the exempt rate, or if it were to be removed entirely from non-commissioned services, we would face concerning financial pressures due to specialist supported housing, by nature, being a high cost and low margin business. As such, any adjustment to the exempt rate for non-commissioned services could force closure of provision and severely affect the viability of sector providers.
3.3 Energy efficiency
3.3.1 YMCA considers energy efficiency to be a long term investment for our social housing. However, improving energy efficiency, such as by installing heat pumps or insulation faces limitations at present for us as providers. Heat Pumps, in smaller, or shared living schemes may not be practical to install, particularly in older buildings, or financially viable due to the levels that we are able to insulate properties.
3.3.2 Similarly, improving energy efficiency by investing in green options often will entail large up front costs that we as a provider, similarly to retrofitting, are not able to raise to undertake the work in the immediate future. While some large providers will hold the necessary surplus to undertake these works, YMCA’s provision does not hold surplus to this extent.
3.3.3 While YMCA is aware of the decarbonisation fund that is offered in order to promote the introduction of energy efficiency improving measures into housing, this still requires a ⅓ contribution by the provider, which often proves itself difficult to raise. As smaller-scale providers, we find that our provision is often overlooked for the funds and we would welcome work from the Government to improve access to funds such as this for small providers. Further to this, the Government should consider how large providers with high levels of surplus could be expected to utilise their surplus to undertake works to improve energy efficiency, and gear decarbonisation funds to provide smaller providers without high levels of surplus with access to the necessary capital to also undertake these works.
3.4 Funding for supported accommodation
3.4.1 YMCA is aware that the Government has previously expressed intent to review funding for supported accommodation. It is our position that any review of funding in the future must ensure that the exempt rate is maintained for non-commissioned services. As discussed in our comments in sections 3.1-3.3, the maintenance of this rate is integral for providers such as ourselves to raise the necessary capital to undertake works. YMCA strongly encourages the Committee and the Government to consider the impact of all their work in the area of social housing in context with supported accommodation in order to ensure that the sector is given suitable recognition and affordances.
4.0 Role of the Social Housing Regulator and Housing Ombudsman
4.1 At present, YMCA is happy with the theoretical roles of the Social Housing Regulator and the Housing Ombudsman. We welcome the Government’s intention to give more powers to the regulator in order to enforce breaches effectively, and ensure that the regulator can drive compliance with consumer standards.
4.2 At present, we do not believe that the Social Housing Regulator is able to effectively monitor the maintenance of consumer standards and the decent homes standard due to long notice periods for surveys. We would recommend that the Government use its Social Housing Paper to legislate to compel the regulator to make contact with residents and managing agents in order to understand the service being provided and ensure that social landlords are meeting their requirements. In provisions where we act as the managing agent and mesne tenant to a head landlord, we note that often given notice periods for inspection serve as catalysts for issues to be addressed by head landlords which does not satisfactorily reflect reality of the landlord's willingness to conduct remedial work or indeed efficiency in conducting the work. As such, we are encouraged by the Government's intention to reduce the notice period required by the regulator for inspection.
4.3 Regarding our relationship with the Housing Ombudsman and the Regulator, YMCA notes that for many small registered providers, there is often very little contact with the regulator, and that it is only in the event of breach or tenant complaints that our smaller registered provision would be required to engage. At present, this light touch regulatory approach is extremely suitable for us as a provider to offer our services without undue overheads and administrative work.
4.4 However, YMCA would advocate for, subject to capacity, strengthening of the relationship between provider and regulator in order to allow for a better exchange of information- at present, our engagements with the regulator may only be focused on highlighting issues that need address, if any, and not allow the regulator to understand if a head landlord is refusing to take remedial work on the property until a time as when the regulator issues notice to inspect. As such, we would consider strengthening the relationship between the provider as the managing agent and the regulator to be ideal to capture the reality of our provision and effectively hold landlords to account.
4.5 Regarding the Government’s intentions to regard tenant satisfaction as an assessment of the performance of the landlord to the Regulator and Ombudsman, YMCA has concerns that the Government has not considered distinctions in social housing between supported accommodation and general needs. For example, when reflecting on service provided when placed into our supported accommodation, particularly in situations where external services are contracted in by the local authority to provide support and YMCA acts as the social landlord, tenants may reflect on the quality of services that they have received but not make the distinction between this service and the social housing that we provide. Negative reflections regarding contracted services therefore could reflect poorly on tenant satisfaction scores and could trigger intervention by the Ombudsman or regulator unless the measures for tenant satisfaction are distinctly set to measures that are within the remit of the head or mesne landlord and differentiated from feedback on support. Considering this, the Government's intention to require landlords to report how rents are being spent is welcome, as it will highlight situations where the landlord generates a large surplus and does not invest in the maintenance of its housing stock adequately.
4.6 Furthermore, the Government should consider how the ways that a landlord addresses issues with tenants differs between supported accommodation and general needs settings. For example, in situations of anti-social behaviour, supported accommodation provision such as that provided by YMCA will generally address issues through community support networks and addressing the support needs of the individual. Conversely, in general needs provision, providers will tend to appoint anti-social behaviour point workers. It is our sense that proposed regulation of social housing at present has not given suitable consideration to providers of supported accommodation and similar, and how these changes interact with our models. With large scale providers, issues are addressed through task-management in order to improve efficiency. While this mode is efficient, in our experience outcomes are generally better than there is consideration of the residents; for example, who they trust to manage and resolve issues.
5.0 The Decent Homes Standard and Energy Efficiency
5.1 The YMCA movement appreciates the importance of energy efficiency and addressing climate change as a responsibility for providing a future for our young people. As such, YMCA recognises the importance of considering how all aspects of society can be made greener, and we can promote energy efficiency as part of combating climate change.
5.2 YMCA understands that the Decent Homes standard is used as a measurement for determining the suitability and livability of a property in relation to the Health and Safety Rating System (HHSRS). The principles for application of this standard are to ensure that dwellings meet statutory minimum standards and do not contain hazards; are kept in a “reasonable” state of repair, and provide a reasonable degree of thermal comfort.
5.3 YMCA understands the intention for the Decent Homes Standard is to ensure that a tenants safety needs are predominantly being met and that items that are outside of their lifetime are replaced by the landlord as part of maintenance work. As a primary function therefore, the Decent Homes Standard places certain minimum standards on properties in order to ensure the wellbeing of the tenant.
5.4 As such, introducing energy efficiency, which does not relate to the wellbeing of a tenant, would introduce a requirement that while potentially well intentioned, is incongruous with the objectives of the Decent Homes Standard. At present, the provision of a reasonable degree of thermal comfort likely requires the property to provide some degree of thermal insulation, and the presence of a central heating boiler system or similar, that is maintained by the landlord. This requirement therefore already sets some standard of efficiency for the property, rooted in the wellbeing of the tenant. Replacement of items in the property that are “old”, defined in the Decent Homes Standard as outside of their lifespan, already commits the landlord to take remedial work on properties to replace items such as outdated boilers, which, as newer models are installed, improves the standard of the heating systems within properties and likely yields more energy efficiency.
5.5 Introduction of energy efficiency into the Decent Homes Standard would also be challenging when determining by what measure a property is considered energy efficient. If energy efficiency were measured in the Decent Homes Standard via the rating provided by a properties Energy Performance Certificate (EPC), it would likely set an energy rating that all properties would be required to meet, for example “Must receive an EPC certificate of C or above”. This requirement shows no consideration for the age of the property. Older properties present challenges to insulate or retrofit to make them more energy efficient due to their nature, for example, not possessing a cavity wall and therefore it not being possible to install cavity wall insulation. Furthermore, older properties often require specialist insulations in order to maintain the breathability and habitability of the house. Installing spray foam insulation in older properties can cause internal condensation, damp, and black mould as the house is unable to effectively disperse warm air through the roof cavity as per its design. This in turn poses health risks to the resident and could conceivably contravene the Decent Homes Standard.
5.6 YMCA has concerns that energy efficiency requirements in the Decent Homes Standard could create capacity issues as older buildings are no longer deemed suitable as social housing,despite meeting the needs of tenants. In most, if not all cases, energy efficiency requirements would require extensive retrofitting, such as the installation of heat pumps, but, particularly in smaller properties, this would have limited benefit compared to the upfront costs.
5.7 This practical obstacle therefore presents high upfront costs, further compacted by difficulty accessing funds for carbon reduction as we have already discussed in section 3.3. Further to this, older properties may reach a point where it is not possible to improve their energy efficiency to meet EPC standards of C or above. YMCA understands that EPC standard C is the standard that is being widely considered as the benchmark for energy efficiency in social housing, but for older properties, we do not believe that it would be proportionate to require adherence to this level of certification.
6.0 Registration with the regulator
6.1 YMCA would recommend that all providers register with the regulator. At present, smaller registered providers do not tend to interact with the regulator unless a visit is triggered due to a reported breach of standards, and so the regulator does not pose a dramatically increased administrative burden on our provision. The Majority of YMCAs services are registered with the regulator, as this presents financial advantages for our provision as it is able to access enhanced rents as a result.
6.2 Although we do recognise that requiring all providers to register with the regulator could cause some providers to move out of the sector, which in turn presents capacity challenges, we believe that efficient and effective provision would not find a requirement to register with the regulator a disincentive, as their provision would already meet or exceed minimum standards. The main concern that we would have as a provider is that requiring providers to register with the regulator could force smaller providers to take on administrative costs in order to do this. Despite this,we would advocate that all private providers be mandated to register with the regulator.
7.0 Regulatory challenges
7.1 At present, there is a high degree of duplication across departments and regulators that are required to be demonstrated as met by providers- as a provider, we are required to demonstrate to numerous bodies such as Ofsted, the Local Authority, Homes England, and the Regulator for Social housing, that our provision is suitable. In most situations, YMCA is a registered social landlord in addition to this.
7.2 As considered in 6.0, requiring provision to register with the regulator could add an extra level of duplication and administration that providers are required to report against. This however is not necessarily a severe requirement on a provider so long as information required by the standard is required in the same format. Only in situations where the same information is required, but in a different format does duplication become an unnecessary administrative burden to providers. Considering this, we would recommend that the Government adopt a joined up and streamlined approach to the Housing Market and social housing strategy, so that information required by regulatory bodies is captured in the same way and therefore reduce administrative burden.
7.3 While YMCA supports the premise of ensuring that providers are effectively regulated and social housing is provided to a good standard, increased overheads from remedial work, retrofitting, and building new housing stock presents financial challenges alongside staff costs that could force up the cost to providers and reduce income streams. As YMCA does not run our services for profit, our concerns relating to this are the individual cost impact of increased overheads on tenants. As Local Housing Allowance rate has been frozen for the past 5 years, if changes were agreed it is possible that providers would mitigate the increased costs via increasing service charges for their social housing and have the consequence of making social housing unaffordable. We would consider this a failure of social landlords if this were to happen.