Written evidence submitted by Merton Centre for Independent Living [RSH 048]
Merton CIL is a pan-Disability user-led Deaf and Disabled People’s Organisation that has been supporting Deaf and Disabled People in the borough since 2008. We work with people with all types of impairment including physical impairments, sensory impairments, mental health service users, people with learning difficulties and people with chronic illness or long term ill-health. Many of our service users have more than one impairment, and many are also carers and/or parents. Deaf and Disabled People do not have to be members to use our services but we do have an ever-growing membership who shape our direction and focus as an organisation. At the end of 2021 Merton CIL had over 400 members.
In 2020-21 our advice and advocacy service provided casework to 206 people, with 844 hours of advice on a range of issues including social care, benefits, and disability hate crime. Many of the service users we support experience problems with a range of issues that are often interlinked.
While Merton CIL’s main role is to provide advice and advocacy support for individuals, we engage with local consultation and co-production to work with the Council and the voluntary sector in the borough. We also work with London-wide and national organisations and campaigns to improve the lives of Deaf and Disabled people.
The London Borough of Merton has a population of 209,421 people. According to the 2011 census, 25,232 residents felt their day-to-day activities were limited a little or a lot, about 12% of the population.
The Greater London Authority (GLA) estimates that by 2020 Merton’s population had increased by just over 1% to 211,787, which would bring the number of Deaf and Disabled people to approximately 25,484.  The GLA also projects that Merton’s population will increase to 225,157 people by 2031. If the proportion of Deaf and Disabled people remains at 12%, this would mean there will be 27,018 Deaf and Disabled people in Merton in 2031. The likelihood is that the ageing population will mean the proportion of Deaf and Disabled people will increase.
The Council’s disability profile gives the following figures about different types of impairment/disability in 2018: 
Merton Centre for Independent Living is very concerned about the quality of social housing and the impact this has on Deaf and Disabled people. The organisation provided support on housing issues through its advice and advocacy service until April 2019 when funding changes meant this part of the service had to close, although it has recently re-opened.
Analysis of the people Merton CIL supported between 2016 – and 2019 showed many concerns about poor housing and repairs. As a small organisation, it is difficult for us to draw conclusions about how widespread the problems are, but they are certainly serious even if they only affect a small number of households.
Merton CIL would argue that suitable adaptations and accessibility are key determiners of the quality of housing for Deaf and Disabled people. While it is beyond the scope of this call for evidence, we would point to the lack of targets for delivering new housing in much of the country, and the failure to meet targets even where they are set as they are by the Mayor and the boroughs in London, as meaning there will continue to be a lack of quality homes for Deaf and Disabled people. 
This situation is exacerbated by a lack of information about what adapted housing is available. The EHRC noted that some councils have a register of accessible housing, though this is only 22% of councils at present. In Merton CIL's area, our understanding is that neither the London Borough of Merton nor the main social housing provider, Clarion Housing Group, holds information about the accessible housing stock.
The impact of poor quality in terms of inadequate access can be a matter of life and death. Any consideration of social housing would be incomplete without reference to fire and safety issues in the light of the Grenfell Tower tragedy. It raised crucial issues about the safety of housing for Disabled people as a number of those who died in the fire were Disabled people.
The Equality and Human Rights Commission’s submissions to the Grenfell Tower Inquiry said that people with mobility impairments, visual impairments and people with dementia experienced difficulties living in Grenfell Tower and:
‘Some of these vulnerable individuals lost their lives as they could not escape from the building during the fire.
Their experiences before and during the fire tell a story of systemic failure to respond to their specific circumstances. From being housed in unsuitable accommodation to the lack of priority given to them by the emergency services, vulnerable residents of Grenfell Tower were let down. The evidence suggests that the authorities failed, and continue to fail, to take appropriate protective measures that adequately corresponded to the needs of particularly vulnerable groups.’ 
It said that human rights case law should mean that the authorities should address the risk to the life of groups including Disabled people but there is no legal requirement for high-rise buildings to provide for the evacuation of Disabled people or to provide fire refuges.
Locally, Merton CIL has supported Disabled people who live on the upper flaws of tower blocks who experience frequent problems with out-of-order lifts placing severe limits on their freedom of movement.
The Fire Safety Act 2021 will be addressing some of these issues but Merton CIL sees a need for accessibility and usability to form part of the regulation of social housing.
Merton CIL believes the seriousness of concerns about the quality of social housing should include consideration of the impact of disrepair and poor/delayed maintenance.
In looking at this it is worth starting by referring to the Housing Ombudsman 2019 spotlight report on repairs which noted that repairs remain consistently the biggest issue for complaints that it deals with, accounting for about a third of the cases it receives every year.  It said:
'Living in a home in a poor state of repair can have a significant impact on residents; this can cause stress and frustration, and damage the ongoing relationship with their landlord, as residents are faced with the issue every day.'
This reflects Merton CIL's experience of supporting people with problems around getting repairs carried out. Complaints about difficulties with repairs accounted for a small but significant number of the housing cases Merton CIL previously dealt with.
At the point where they came to Merton CIL for assistance, they seem to have been caught in a repeating cycle in which it has become impossible to resolve clear problems. Some of Merton CIL’s members told us it is particularly difficult to deal with people with no local knowledge who have to rely on computer systems for information about the person they are speaking to and any specialist equipment they have. A Merton CIL member told us:
‘You tell them what you need, you tell them what’s broken. They’ve got all the information but they’re up north somewhere and send the wrong person. It’s much easier to speak to someone who knows me and knows my needs.’
Merton CIL would argue Disabled people are particularly impacted when there is a problem with their home. Turning off the water when a pipe has burst or cleaning up after a leak is going to be more difficult for anyone with a mobility or dexterity impairment; dealing with cold and damp conditions will cause health problems for people with impairments such as arthritis or ones that cause respiratory problems; people with equipment including powered wheelchairs and mobility scooters that need charging will be particularly affected by problems with the electricity supply, and just making arrangements for a repair is more difficult for someone with a communication impairment.
Dealing with problems at home is obviously difficult for everyone but we believe there needs to be recognition of their particular impact on Disabled people and can be more difficult for us to resolve.
These situations are recognised as having an impact on people’s physical and mental health, particularly where they go on for an extended period of time, and for people who already have physical or mental health impairments/conditions they are likely to be further exacerbated.
We looked at some of the general information about repairs and maintenance while our housing service was working before April 2019. Overall indicators suggested there should be fewer problems with repairs than in the past. Clarion Housing Group, Merton’s main social housing provider, noted in its 2017 -2018 annual report that 92% of repairs are completed on time and 88.8% of tenants are satisfied with repairs.  Executives from Clarion attended a scrutiny meeting with Merton councillors in January 2018 to discuss issues about repairs and regeneration.  At that meeting, Clarion said there were no long-term repairs that related to problems that had started before September 2017 and that their statistics showed Merton was 'first in London' for fixing repairs on the first attempt.’ They said that other providers were now looking at what they could learn from Clarion's service.
This does not appear to have been accurate. Merton CIL was certainly supporting people with maintenance and repair problems that extended back several years when our service stopped in 2019 and we have been made aware of others since.
These are brief details of some of the issues Merton CIL helped people with between April 2016 and April 2019:
As part of our investigation into this work, we found that in 2018 1.1% of social housing in Merton (approximately 122 homes) did not meet the Decent Homes Standard, which was above the average for London.
Merton CIL has been concerned recently to learn that Clarion was allowed to waive the Decent Homes Standard, with approval from the Council and the Regulator, on 1,000 homes in 2014 that are scheduled for regeneration.  However, this regeneration will not now happen until 2018.
Merton CIL only has a very limited amount of evidence about this issue and has not been engaged with it directly for two-and-a-half years.
This said, looking at our previous experience, the experience of our advice and advocacy service in the last few months of re-starting this area of support and looking at recent press reports about social housing in Merton on the BBC, ITV and reports that the MP for Mitcham and Morden says half the complaints they deal with are about Clarion Housing Group, it is different to see how the current regime is fit for purpose.  Tenants, and Deaf and Disabled tenants in particular, seem to be left in terrible, sometimes unsafe, conditions without any sense that the daily misery they have to endure needs to be rectified and for this to be given a timescale.
Merton CIL argues for the value of co-production with users in all aspects of public services and this seems to be missing in current social housing and its regulation. Social housing seems to have lost the value of local housing associations and developed into distant, monolithic corporations that are, in at least some instances, indistinguishable from the worst private landlords in some of their practices.
While the scope of this call for evidence is focused on the regulatory regime, Merton CIL sees an urgent need for a much broader review.
 See London Plan monitoring reports - https://www.london.gov.uk/what-we-do/planning/implementing-london-plan/monitoring-london-plan
 https://www.bbc.co.uk/news/uk-england-london-57233032 ; https://www.itv.com/news/2021-08-17/residents-anger-as-clarion-cleared-despite-slum-conditions-on-housing-estate; https://www.insidehousing.co.uk/news/news/clarion-housing-issues-take-up-half-of-workload-claims-mp-73414