Written evidence submitted by One Manchester [RSH 062]
About One Manchester
One Manchester is a registered provider of social housing with 12,000 homes based in South and East Manchester formed from the merger of two separate stock transfer associations.
Reason for submitting evidence
One Manchester believes it has something to contribute to this discussion as a medium sized landlord in the North which has a significant number of high-rise blocks from which it has removed cladding and has completed the first fully carbon zero social rented home in the country as part of its net-zero carbon journey.
1.0 How widespread and serious are the concerns about the quality of social housing?
1.1 The majority of social housing is decent and providers strive to deliver good quality, however over the last decade social housing organisations have been hit with a myriad of challenges and difficult choices have been made with respect to the quality of our homes, with the four years rent reduction, drive to build new homes and ‘sweating our assets’, lifecycles have been stretched and replacement programmes extended. In addition to this the critical housing shortage in our areas means that many homes are overcrowded adding to wear and tear and the likelihood of condensation and mould issues. Less money has been available for issues considered to be more ‘cosmetic’ such as internal cyclical painting programmes and the replacement of fences and estates in some places are beginning to look tired.
1.2 There has clearly been a significant campaign in the press in relation to social housing, much of which appears to be justified however this goes alongside the campaign of legal firms around the country actively targeting estates for disrepair claims. Registered Providers of social housing (RPs) are paying thousands of pounds to defend cases or paying costs where the legal fees are multiple times any compensation given and this is diverting time, resource and money from ongoing works, however the sector needs to get much better at listening and getting to the root cause of any issues so a resolution can be found.
1.3 One Manchester does recognise that these challenges have led to operating models in some organisations where some providers are not as close to customers as we once were as a sector, increasingly moving towards digital methods of interaction (compounded further by COVID19). This means that we have more questions than answers about the condition of our homes and our customers. One Manchester is addressing this through the development of a new operating model with increased resources on the frontline that will be funded through efficiencies elsewhere in the organisation.
2.0 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?
2.1 The investment into maintaining and improving One Manchester’s stock remains a priority for the organisation. Over recent years this has focussed on building safety and improving the energy efficiency of our stock, including the installation of renewable heating.
2.2 One Manchester has responded strongly to building safety requirements, has remediated all the flammable cladding and received money back from the Government. We are currently installing sprinklers and have a programme of fire stopping work and fire door maintenance all of which has been budgeted through the business plan, at present this isn’t impacting on general maintenance or planned improvement works, however any additional requirements could have an impact.
2.3 Running in tandem with the fire-works we have had a number of renewable heating schemes. We are currently trialling three different forms of retrofit on individual properties before rolling out the works to over a hundred properties in a regeneration scheme we are working on which has received BEIS funding. There is a huge financial impact from carbon zero and providers will need to think carefully about choices and options moving forward, but building safety, compliance and decency must always come first. Working with Savills we have identified that we will need over £300 million to complete the carbon zero works across our stock in line with the Greater Manchester target of 2038 currently only a third of that sum is in our business plan and the Board is looking at a range of alternatives including more borrowing and longer borrowing timescales in order to fund this work. This should not impact our on-going maintenance programme however we are currently finding that having benefitted from undertaking necessary component renewals as part of the original decent homes’ standard, we are now in a position where those components replaced as part of the original programme are reaching end of life and the life cycles predicted are not being achieved across all properties. Programmes of work will be ongoing to replace those components however timeframes do not always align with those for carbon-zero and it will be complex to maintain decency whilst ensuring that heating, doors, windows and roofs are not replaced twice within a few years as we work towards carbon zero.
2.4 These ongoing demands on the finances of providers are included within business plans of some and for others they are not and timing issues could result in wasted money. It is highly likely that as plans for achieving Carbon Zero are firmed up some RP’s may end up thinking about what stock to retain and what not, linked to APE and may become more likely to dispose rather than spend a huge amount of money for some stock that has very low NPV. The question then for those homes and the communities in which they sit is who else will invest in them?
3.0 Is the current regime for regulating social housing fit for purpose?
3.1 We believe the principles themselves are fit for purpose but the application is weak and there is a recognised need for providers to clearly and robustly demonstrate that regulation is deep routed within the organisation. The current system is proportionate and robust from a financial, governance and safety perspective but there needs to be the same importance placed against consumer standards when assessing organisations to truly hold us to account
4.0 How clearly defined are the roles of the Regulator of Social Housing and the Housing Ombudsman?
4.1 For providers themselves the role of both the Ombudsman’s and the Regulator’s roles are clearly defined. The Ombudsman has done a lot of work over the past couple of years to improve communication on their role and remit. The inter-relationship between the two is not clear and there needs to be much better linkages between the experience and decisions of the HOS and those of the regulator.
4.2 From a customer perspective some will be aware of the HOS but the majority will not and its role lacks clarity for customers. Very few or no customers would be aware of the regulator, what it considers, the significance of the G/V ratings and the impact they have on obtaining cheaper finance etc.
5.0 Does the current regime allow tenants to effectively resolve issues?
5.1 Our experience is that we believe it does and that our customers think this too however all parties and particularly our customers would say that it is not easy to navigate and takes too long to achieve an outcome.
6.0 Do the regulator and ombudsman have sufficient powers to take action against providers?
6.1 We believe the Ombudsman has sufficient powers, however we do not believe they have sufficient resource to cope with the demand following the White Paper and the roll out of the Complaint Handling Code, demonstrated by the length of time investigations take, response time to emails etc.
7.0 Will the reforms proposed in the social housing White Paper improve the regime and what progress has been made on implementing those reforms?
7.1 We believe that the wider customer satisfaction score and requirements to publish etc along with the wider customer involvement requirements specifically around health and safety are positive and will improve the regime. They will create a more structured framework for providers to work to and provide clarity around expectations and what good looks like. One Manchester has incorporated most of the requirements into its service and reporting measures already and has an action plan in place to ensure full compliance.
8.0 What changes, if any, should the Government make to the Decent Homes Standard?
8.1 Any new decent homes standard needs to address and endorse a fabric first and clean heat approach, particularly when we consider the net-zero requirements. Insulation levels should be explicit. At the same time we need to review how damp is addressed and eradicated with stipulations made over mechanical ventilation requirements that work in tandem with the building regulations.
8.2 The decent homes standard should set an explicit minimum standard with customers at the heart of the new approach. Lifecycles need to be reviewed in line with what the sector is experiencing and consideration given to adopting an approach where lifecycles are dependent on the use of the buildings e.g. older person’s accommodation longer lifecycles than family housing
8.3 Decent homes was successful in modernising homes, however, it did not consider the external environment, communities, landscaping and place making. Future standards should set the tone around this improving external and communal environments for all of our customers.
9.0 Should the Decent Homes Standard be amended to include energy efficiency and other means of mitigating climate change, and if so how?
9.1 The DHS currently says very little about energy efficiency – just efficient heating and effective insulation. The timing of this will be difficult as many Local Authority areas have different dates to achieve Carbon Zero and there is also the Governments 2050 target and therefore it is not clear what date and what proportion of homes would be expected to be at carbon zero. The DH standard should include a minimum EPC rating graduated to 2050. In the same way the newbuild industry is being forewarned that from 2025, gas will no longer be allowed, and carbon emissions must be 75-80% lower in newbuild – could the DHS be incremental - from 2025 EPCs below D will not meet the definition; from 2030 EPCs below C will not meet the definition?
9.2 There are many other ways to set a minimum threshold on energy efficiency and climate change, but to vary from the already established and recognisable EPC as a threshold as a minimum may be confusing.
9.3 We believe DHS has to include something that sets a minimum threshold in this area.
10.0 Should all providers of social housing, not just councils, be required to register with the regulator?
10.1 Yes, we believe they should.
11.0 What challenges does the diversification of social housing providers pose for the regulatory system?
11.1 It is always going to be difficult to monitor the wider work of RP’s as the amount of diversification will increase over time as RP’s deliver additional services in response to reductions in service from other agencies and look for ways to generate income/returns to fund the widening Decent Homes/Decarb etc choices that are needed to ensure social properties remain fit for purpose and we have a supply of new homes to address demand.