Written evidence submitted by Your Housing Group Limited [RSH 061]
A charitable registered society under the Co-operative and Community Benefit Societies Act 2014 no. 30666R, registered with the Regulator of Social Housing no. L4203.
Your Housing Group is a registered provider of social housing with a large and diverse portfolio of over 28,000 homes across the North West, Yorkshire and the Midlands. These range from general properties for social and affordable rent, through to retirement living developments and innovative private rental offers. Widely regarded for its expertise in regeneration, Your Housing Group prides itself on providing homes which help people to live independently and on enabling people to get on and off the property ladder at different stages of their lives. With a pioneering, creative workforce, we are working efficiently and effectively to build as many quality homes as possible to play our part in solving the national housing crisis.
How widespread and serious are the concerns about the quality of social housing?
The quality of social housing has come under scrutiny over the past year following an ongoing investigation by ITV News into the poor conditions faced by some tenants, as well as a general increase in media coverage highlighting examples of such conditions within social homes. This is a serious concern for registered social housing providers and has been damaging to the reputation of sector, which has been called into question.
The testimonies of the social housing tenants featured within ongoing media coverage on quality of homes should not be dismissed and clearly illustrate negative experiences with individual registered providers, who are rightly being called to account for service failures. However, the wider issue remains as to whether concerns about the quality of the social housing sector as a whole are justified. It is our view that the vast majority of providers are continuing to meet the challenge of delivering quality homes and services to residents, including meeting or exceeding the requirements of the Decent Homes Standard, in the face of testing economic and operating conditions from Covid-19 to the financial pressures of decarbonisation and building safety.
Modernising social housing stock is an ongoing challenge but should be a priority for all registered providers. Your Housing Group are committed to delivering a high-quality, modern and effective repairs service and to providing homes that are comfortable, maintained and safe for people to live in. It is important to note that in general, 50-60% of all social housing stock (including that of Your Housing Group) is over 40 years old and is starting to show signs of requiring improvement, replacement or modernisation. Despite these challenges, YHG are fully committed to ensuring that tenants receive the standard and quality of home they are entitled to, and that in doing so tenants are treated with respect.
A recent example of this in action is YHG’s current damp and mould project. YHG have proactively contacting all tenants asking whether they have issues with damp and mould. YHG have followed up every contact, and will track and monitor required works to completion.
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?
The legal requirements in relation to building safety (Building Safety Bill, Fire Safety Act) and government decarbonisation targets and energy efficiency agenda as set out in the Net Zero Strategy/ Heat and Buildings Strategy mean that these are rightly top priorities for registered providers. However, the increased investment required in staffing and in works being undertaken to satisfy the ongoing requirements of these important aspects of social housing alongside normal day to day business activities is extremely significant and will seriously impact our resources.
With building safety legislation not fully finalised and issued, and decarbonisation programmes at a relatively early stage, the final costs of implementation are still difficult to predict. However, housing associations estimate they will have to spend more than £10bn to make all their buildings safe over the next decade. October 2021 research conducted by Savills for the NHF predicts that decarbonising housing association stock in England by 2050 will cost the sector at least £36bn. The report’s headline spending figures sit on top of housing associations’ existing stock investment programmes, assumed to run to about £70bn between now and 2050. It warns that the sector “will not be able to absorb the costs of decarbonisation without [government] support”.
Potential impacts on registered providers’ resources outside of the ability to meet the costs of maintaining and improving their existing stock on top of building safety and decarbonisation works, is likely to be the ability to carry out planned development projects. Another October 2021 survey of 106 housing associations by the NHF found that more than one in 10 new affordable homes planned by housing associations can no longer be built due to the costs of making buildings safe following the Grenfell Tower fire, with social rent homes taking the biggest hit.
Is the current regime for regulating social housing fit for purpose?
The fact that the Regulator’s consumer standards are currently being reformulated as part of the Social Housing White Paper package of proposals demonstrates that these were in need of a fresh, more proactive approach to reflect the current landscape and renewed focus on tenant voice. However, it is important to acknowledge the key role these have played in maintaining standards within the sector. We await further detail from the Regulator on further proposals, for example of the draft themes of the new consumer standards.
We would not suggest any changes to the current system of self-assessment backed-up by periodic inspection and graded approach to regulatory judgements.
How clearly defined are the roles of the Regulator of Social Housing and the Housing Ombudsman?
The Memorandum of Understanding that was developed between the Regulator and the Social Housing Ombudsman in September 2020 sets out to clearly define the roles of the parties.
From a landlord’s perspective the greater partnership working between the two bodies makes sense and is welcomed. This is also in tune with a more proactive approach to consumer regulation, as set out in the Social Housing White Paper. The diagrams within the Regulator’s recent Consumer Regulation policy paper are helpful in setting out the relationships between the Regulator, Ombudsman and other stakeholders.
However, further work may be needed on the part of the Regulator, Housing Ombudsman and on registered providers, on improving the information available to the general public on the roles of each and the correct pathways to raise concerns and complaints.
Does the current regime allow tenants to effectively resolve issues?
Our view is that YHG as an organisation, and the sector as a whole, has a robust framework of internal practices in place to process, respond to and learn from residents’ complaints and other forms of feedback that adheres to the Housing Ombudsman’s Complaint Handling Code, published in July 2020. As an organisation we value all customer feedback about our services, and positively use this to capture learning and ways to improve. Our complaints process, including timescales for responses, is well publicised and clearly set out in a customer-facing service standard in addition to our Customer Feedback Policy. We aim to investigate and resolve complaints fairly and thoroughly, with an emphasis on clear and timely communication to residents, meaning that the vast majority are successfully resolved before reaching the Housing Ombudsman Service.
YHG welcomes the action taken to speed up access to the Housing Ombudsman by removing (through the Building Safety Bill) the need for residents to either go to a ‘designated person’ or wait eight weeks before approaching the Ombudsman directly, which should lead to a more efficient process for residents.
The fact that the Housing Ombudsman Service has also been expanded and its powers increased should mean it can make decisions more quickly and can take stronger action against landlords where needed.
In our experience, the Ombudsman’s timescales for processing resident complaints is currently around three months. Given the very significant increases in complaints and inquiries the Service has received over the past year, as documented in its recent annual report and regular insight reports, we feel that this is currently a fair timescale.
Will the reforms proposed in the social housing White Paper improve the regime and what progress has been made on implementing those reforms?
The White Paper reforms are generally viewed in a positive light by the sector, and the Paper was welcomed as backing the sector’s own proactive work to improve accountability, quality, and transparent relationships with residents, and acknowledging both the importance of social housing and the good work of many social landlords.
Registered providers including YHG have been quick to respond to the Regulator’s “don’t wait” message in relation to delivery of White Paper proposals, and are already taking proactive steps to move forward with important work around transparency, accountability and tenant satisfaction in the absence of detailed announcements, demonstrating a firm commitment to delivering the White Paper’s reforms and the ethos behind them.
A firm timetable for implementation of many of the proposals is still needed from government. Progress has been made by the Regulator, for example publication of its formal consultation on draft tenant satisfaction measures. However, as set out in the Regulator’s recent Consumer Regulation policy paper, much of the work to be done relies on the correct legislation being put in place by government, and we have no clear timetable for this. It is important that any momentum is not lost by government as ultimately, it will be social housing tenants who are impacted.
What changes, if any, should the Government make to the Decent Homes Standard?
The Decent Homes Standard has been instrumental in ensuring that social housing stock meets a minimum level of decency. However, given that the Standard was most recently updated in 2006, we believe that the case for change is a strong one. Specifically, any revised Standard should reflect current expectations of providers and residents, as well as current government policy – for example a minimum SAP score of band C by 2035 as set out in the government’s Clean Growth and Net Zero strategies; a minimum standard for communal areas, and access to outdoor space and green spaces.
Should the Decent Homes Standard be amended to include energy efficiency and other means of mitigating climate change, and if so how?
It is our view that the Decent Homes Standard must be amended to reflect current government policy and strategy around energy efficiency and decarbonisation. SAP ratings of less than 35 under reasonable degree of thermal comfort are currently within the Decent Homes Standard, however is this sufficient enough when we are striving to achieve an SAP score of at least 69 (band C) by 2035? YHG have an internal working group which is well underway with working to address issues within Chapter 6 of the Social Housing White Paper (To have a good quality home and neighbourhood to live in).
What challenges does the diversification of social housing providers pose for the regulatory system?
Over recent years the sector has faced its most challenging operating environment to date, with financial challenges that have included four years of rent reductions, and other government-driven policy changes such as the current and future financial implications of meeting building/ fire safety compliance and the net zero agenda. As a result of these pressures and in order to generate income, many providers have chosen to diversify into non-core activities (whether in development or service provision) that go beyond providing affordable housing. There are also a growing number of for-profit providers, with over 50 businesses due to register with the Regulator next year. For-profit providers can be useful in bringing private capital into the sector to help deliver on development targets.
However, as a growing number of providers move into these profit-making areas to generate enough income to meet the demands of government-driven policy, this may raise concerns as to whether to Regulator of Social Housing possesses both the powers and the expertise to regulate such activities, and to regulate private organisations. The current regulatory regime for for-profit private registered providers is not currently aligned with that of not-for-profit private registered providers, and this is something that must be addressed.
December 2021