Written evidence submitted by G15 Housing Association Residents [RSH 055]
We are writing in response to your call for evidence collectively as residents of a number of different housing associations, all of which are members of the G15 largest London housing associations. Whilst the creation of this response has been supported by employees of G15 landlords, the views are ours alone.
To support the collation of responses overall we have placed our comments under each of your questions, including noting where we have no specific response. At the end we also add some additional thoughts which did not fit well under the other questions.
1. How widespread and serious are the concerns about the quality of social housing?
We cannot claim detailed knowledge of all of the homes our landlords own but believe that most housing association residents don’t live in conditions that have been seen on television. We do feel the fact that any do is disgraceful. To some extent it is natural that media attention has been focused on the most extreme cases, which are small in number, of ceilings falling down, building materials in the bath for months, extreme damp and mould etc. We feel that landlords need to have a clear strategy to deal with these instances.
We also have concerns that there are much wider spread issues, affecting many more residents, which if not resolved in time could lead to bigger problems. Whilst some of the problems of quality may be partly due to the challenges other residents face in their lives, an inability to address such issues by landlords has led to some residents losing trust in their landlord and as a result simply giving up on reporting issues.
Avoiding this relies on landlords identifying problems and resolving them in time. Neither of these can necessarily be relied upon to happen. We are concerned that operatives working for housing associations will see these conditions every day but may not report them. Whilst operatives may not all have seen homes in such extremely poor condition, they will have seen conditions which could lead to that if not addressed – e.g. taking too long to respond to repairs and some very obvious and visible conditions. A minor repair could become a major repair if not dealt with in time. Landlords should have in place a set of robust guidelines for reporting repairs by tenants, their employees, third party contractors and regular inspections.
We feel that the scale of the problem of quality in social housing has not yet been fully quantified and there is a need for good data to underpin the understanding of the situation. We believe most landlords have more work to do on this.
We believe that some of the problems that have received media attention are caused by poorly built s106 schemes. We know that some of our landlords have taken a decision to not take any more s106 schemes because of issues around design and service charges.
In order to fundamentally address the situation that has been uncovered we believe it is really important that landlords are completely committed to really hearing the concerns that are raised and acting on them. Landlords need to be serious and listen to residents, as well as ensuring the “eyes and ears” they already have on the ground - both reactively and proactively - pick up and report early signs of potential problems.
We are also concerned that there are some homes which are in such poor condition that they are no longer fit for the purpose they were built for and should now be demolished to make way for new, high quality affordable homes.
This is made very difficult by current funding conditions around estate regeneration, the low levels of grant funding for new affordable homes and the risk that government will divert what little funding for affordable homes there is to ‘red wall’ seats to suit the levelling up agenda.
We also feel that some of the problems of quality can be traced back to government decisions in relation to rent cuts imposed in 2015. This delivered a short-term benefit to government (and some residents) but has had long-term impacts in relation to reduced investment in existing homes – these are being felt now.
Overall we think there is a clear and important role for the Government to proactively influence housing associations to improve trust and transparency amongst communities that already feel excluded. This has particular links to the equality, diversity and inclusion agenda. The Government has not helped this and in fact we believe that government has reinforced stigma in social housing by describing it explicitly and implicitly as a tenure of last resort. We believe that social housing plays many roles in different places and this needs broader recognition.
Finally, we would like to advise the committee to consider quality more broadly. It isn’t just the structure or internal condition of homes, it should cover the quality of management and maintenance of estates, communal areas and neighbourhoods as a whole, as all of these things impact the lived experience of residents and generally show up in the appearance of their homes and estates.
2. 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?
This question is largely one for social landlords to answer but we do have active concerns in relation to this as residents. Only a certain amount of the funding for these costs can come from additional rent and as landlords can only spend the money they have once there will be a negative impact on delivery of new affordable homes. This speaks to a fundamental question on the balance of investing in existing homes against building new affordable homes. We see that there is more tension between these two competing areas than there has been for some time.
We note that the Government is not yet clear on how retrofit activity to make homes more energy efficient will be funded. We would support government making additional funding available for this instead of relying on additional rent increases.
We also have concerns in relation to the very high costs likely to be associated with the remediation of building safety risks and that there is a limit to the costs that can be passed onto residents whose finances are already stretched. We see this as a particular issue for shared owners. We are very conscious of the scale of these costs, the uncertainty faced by people living in blocks where remediation is necessary and the impact this can have on their health and wellbeing, given that government has not yet provided for the real costs of remediation to be covered.
3. Is the current regime for regulating social housing fit for purpose?
Our perception is that the Regulator of Social Housing (RSH) doesn’t have the powers to force landlords to do things – if it does have that power then it doesn’t seem to use it.
We do not know if any of this is due to the fact that the RSH has had a temporary chair for some time. We note that there are no residents on the board of the RSH or indeed anyone with a ‘consumer’ focus. We believe that addressing this would be an important step in the right direction to give the RSH focus. We know that there is a massive resource of committed residents who could be available as a ‘peer support’ to help provide this perspective to the RSH.
We positively welcome public statements made in recent times by the Housing Ombudsman (HO) but more time is needed in order to see whether this has a positive real impact on complaints handling and resolution, as well as ensuring that providers are genuinely learning lessons through complaints.
We all believe that resident engagement is a key part of co-regulation but are concerned that within the social housing white paper there are no new ideas about what engagement really means and how to take it to the next level. Many social landlords are moving on this already, but this is very much work in progress, it’s crucial to maintain momentum and there remains the question whether the actions currently proposed and their scope will make a real and sustainable difference.
4. How clearly defined are the roles of the Regulator of Social Housing and the Housing Ombudsman?
We note that both the RSH and the HO both have lengthy descriptions of their work and there is clearly some overlap between these. However essentially the HO is there to deal with escalated complaints and the RSH deals with everything else. If this is correct then simpler and clearer statements to that effect in resident-facing communications from both would be beneficial.
The fact that a number of dissatisfied residents appear to have skipped the HO entirely and gone straight to ITV or disrepair solicitors suggests that their role is not widely understood and more work is needed in that area.
5. Does the current regime allow tenants to effectively resolve issues?
As noted above we have concerns that a number of residents have lost trust in the system. If something isn’t done once or twice then many people will give up and not bother reporting any more issues. The COVID-19 pandemic has clearly impacted on some services to an extent and some residents are waiting for the ‘return to normal’ but apathy and mistrust existed before then.
We are not convinced that the current system enables issues to be resolved in a timely manner. Historically the HO has taken a very long time to come to conclusions. Such long lead times on unresolved complaints means that there cannot be an effective resolution for the resident. Many people will wonder ‘why bother?’.
6. Do the regulator and ombudsman have sufficient powers to take action against providers?
We believe that the powers of the HO are relatively weak and this – combined with the fact that historically it has taken them a long time to deal with complaints escalated to them means that it is hard to achieve resolution for residents. Residents need to have confidence that appropriate sanctions and redress are available but also – critically - that the underlying issue (e.g. an incomplete repair) will also be resolved.
We would like to see government, presumably through the RSH, set very clear expectations to landlords on embedding the voice of their residents into their governance structure. All of us feel that resident voice in decision making by our landlords is important and merely relying on surveys is not sufficient. Resident board members bring a distinctive voice and can play an important role in ensuring boards maintain focus on improving resident engagement and satisfaction. We believe resident board members should be mandatory to ensure we are able to influence our organisations at the top level.
In respect of compliance with the Decent Homes standards (we deal with the standards themselves later in this response), this is enforced by the RSH, but it appears to us that this is not done proactively. We would encourage the committee to explore what the barriers are to this, what if any changes to it will occur with the proposed changes to consumer regulation and how this change will be put into place.
We have significant concerns in relation to ‘ambulance chasing’ solicitors seeking Decent Homes cases getting in the way of effective repairs – we think that this can have particularly negative consequences upon vulnerable residents. Most of us believe that these firms add additional cost for landlords – much of which goes into their fees, delay the process and raise expectations of residents to get a windfall in compensation and that the RSH or government should have additional powers to stamp down on this. We felt that this could also be supported by clearer expectations around possible compensation for affected residents. There was also a counterview that such firms, when operating within the bounds of professional ethics, can be effective at forcing landlords to take repairs seriously.
7. Will the reforms proposed in the social housing White Paper improve the regime and what progress has been made on implementing those reforms?
We welcome the return of proactive consumer regulation but this is not sufficient in and of itself. We think that it is important to prevent additional processes from becoming a tick-box exercise. A key aspect of this should be involving residents of the housing association being inspected in any new In Depth Assessment. Residents should be interviewed by the inspection team to allow a qualitative view alongside any data analysis.
The RSH at the moment is largely focused on governance and viability – they will need to have sufficient resources and energy to cover the expanded role in relation to consumer standards.
We note that the RSH is now consulting upon proposed Tenant Satisfaction Measures. We are not convinced that these are yet framed appropriately, noting many are based on surveys rather than focusing on outcomes which are tangible. We are also unsure why there is reticence around league tables. Assuming the measures are reported publicly and transparently, which is necessary, then the sector press will produce league tables anyway. We believe the measures need to be focused on the things which really matter to residents – and as far as possible not drive negative behaviours in landlords.
Continuing the theme of transparency we believe that it is important that every inspection report should be published. Residents deserve to be able to see these in the same way that parents can for an OFSTED report of schools.
We believe that transparency is crucial to create trust between residents and landlords. Things mustn’t be hidden on websites where most people can’t find them. Engagement is a much wider question than involving people on committees, boards and local groups – landlords need to be brave enough to share what is happening – not just the shiny positive stories. We believe that broader sharing of the problems and what is being done to overcome them – could be a good driver for encouraging more people to get involved and help landlords to overcome them. Conversely we also felt that good news from the housing association sector doesn’t get as much attention as perhaps it deserves.
We want to see clearer statements from the Government on addressing the root causes of anti-social behaviour and serious crime in and around social homes. Whilst the Social Housing White Paper does address anti-social behaviour and proposes a number of steps we would like to know how government will ensure that these actions are taken and that they deliver the right outcomes.
8. What changes, if any, should the Government make to the Decent Homes Standard?
We believe that the standards need to be stripped down to be clearer and more understandable. Assuming these standards bring additional requirements it will also be very important to be clear about how this will be funded.
We believe that the priority for residents of social housing is to be safe, warm, secure and dry and any changes to the Decent Homes standard should focus on that. We have concerns in the past that Decent Homes works have prioritised new kitchens and bathrooms over ways of keeping residents warm and dry – sometimes based on the erroneous belief that this was what residents wanted.
We think there are also other things which could be considered as part of Decent Homes, including, for instance, a suitable internet connection – which helps increase chances of employment and reduce loneliness and soundproofing to reduce disturbance from adjacent flats.
We also think there should be consideration of decent neighbourhoods and the other services that landlords can provide to support that and the communities in which they are based including providing opportunities for training and employment and reducing crime and anti-social behaviour through CCTV.
9. Should the Decent Homes Standard be amended to include energy efficiency and other means of mitigating climate change, and if so how?
We have mixed views on this question. Firstly, we’d like to make the point that any works to improve the energy efficiency of the home should ensure that the lighting and heating of it is affordable to the resident. This is especially important for residents on low income where arguably the aim should be to make the home cheaper to heat.
If these energy efficiency measures do make it cheaper to heat then a case could be made to incorporate this into the Decent Homes Standard – noting this is most adhered to in the social housing sector. If the works make heating the home more expensive then it is hard to argue they should be applied in the social sector before the private rented or owner occupied sectors.
In applying additional standards to the social sector, we also think it is important that the additional impact on leaseholders and shared owners is recognised, as energy efficiency works have the potential to provide both with significant bills.
10. Should all providers of social housing, not just councils, be required to register with the regulator?
We have chosen not to answer this question but do note the importance of consistency for all social housing residents.
11. What challenges does the diversification of social housing providers pose for the regulatory system?
As residents of housing associations we have relatively little to comment on here, other than reiterating the point above on the need for consistency. We also note that there are challenges in relation to for-profit providers of social housing who lack the social purpose of our landlords.
We feel that in these questions the committee may, to some degree, be overlooking the important, but difficult, issue of stigmatisation. We feel that the White Paper proposals appear quite narrow in this respect and urge you to consider this as part of your work.
We would like to see more consideration of who is social housing ‘for’? We all are acutely aware that there is a massive shortage of social housing and that this closely interacts with the question of how such homes that do become available are currently allocated. If new social housing tenancies are restricted to people in the greatest need then this can reinforce stigma. We note that government has committed to an evidence collection exercise on allocations and this might be something the committee choses to probe in more detail.
We have different views in relation to the impact that large landlords may have in this area. Some of us believe that large landlords have more capacity to address and improve situations where things go wrong (for example by rapidly replacing failing contractors) and others felt that some large landlords have become distant to the core values of housing associations.
Lydia Bocage (Catalyst resident)
Mary Burke (Notting Hill Genesis resident)
Marc Merry (Southern Housing Group resident)
Jerry Piper (Metropolitan Thames Valley resident)
Fayann Simpson (L&Q resident)
Terry Stacey (Clarion resident)