Written evidence submitted by Claire Brown MLPM MIEMA CENV [RSH 069]

PhD Researcher – Tyndall Centre for Climate Change, The University of Manchester.


Claire’s research focuses on addressing issues around heating and cooling demand in social housing in the UK. Looking at how new-build social housing could be a potential way to reduce demand on the power grid through better design and exploring further opportunities for self-generation. Exploring how commercially viable solutions might exist to allow social housing to be built with high energy performance built-in


How widespread and serious are the concerns about the quality of social housing?


  1. Quality of social housing is about a safe and secure place for any tenant to live. This housing is provided by someone else on their behalf. All housing should be a safe place, free from risk and harm. As such the quality of housing seen in the UK does not always meet this standard, when it should. It is important that this issue of healthy homes is addressed and that current levels are improved. The LGA reported that in 2019, £2.5bn in costs were attributed to illnesses related to damp and cold homes. Investment and reforms are needed, things cannot go on a business as usual. The Decent Homes standard is an opportunity to improve the lives of millions and reduce the burden, particularly on the NHS concerning ill-health as a result of poor housing standards.


  1. Overheating, condensation and mould are all systemic issues around poor delivery and maintenance of housing and in some cases, a reluctance of contractors to implement improvements above building regulations during design and build. The UK Building regulations for Parts F, L and O have only recently been released in consultation format (15th December 2021) – as such multiple homes (an estimate of 800,000) have been built to lower standards when they could have been developed and constructed with higher efficiency and performance. This has led to a situation where homes will have to be retrofitted in the future to meet the demands of a changing climate. Inside Housing report that this will be in the region of £104bn in costs to ensure all social housing homes meet the net-zero target.


  1. Historically, cold and damp homes in past governments have been addressed through multiple mechanisms. The Decent Homes Standard is just one. For Social housing, this is a key mechanism that can be applied and supported to reduce poor housing for social housing tenants.


  1. Social housing should be part of the national infrastructure of a sustainable future, as such it should have a higher priority in any national plan for improvements. This was outlined in the Building Utopia report from The University of Manchester, including a discussion on decarbonising heat in Social Housing. Social housing and the provision of suitable, climate-resilient homes will alleviate a range of social and health risk that is currently witnessed in the UK.


  1. Rent for social homes is less than the private sector and supports those most at risk from further poverty through reduced rental payments. However, fuels costs and energy consumption can potentially still be a risk metric as a result of the type of housing provided.


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?


  1. Improving energy efficiency in parallel with improving building safety risks - By having more efficient buildings we can reduce risks such as overheating and condensation and mould growth. However, the current Grenfell Inquiry and associated reports have found many issues surrounding retrofit projects and their management. The public frustration around these fatal issues and subsequent reaction to external cladding has reduced public support and appetite for such renovations.


  1. The Northern Housing Monitor recently published a report which identified a need for 270,000 Northern homes that will need to be retrofitted a year to 2035 – which is equivalent to almost 400 homes a week. A staggering figure.


  1. The ability for social landlords to undertake renovations and necessary improvements for energy efficiency and fire safety updates should not be removed. There should be suitable and adequately funded support for social landlords to act on the necessary changes. As such, the public image of renovations and retrofit projects needs to be addressed. BEIS or Homes England could undertake a series of workshops or campaigns to support social landlords in explaining the improvements and to allow for clear and transparent information to be made available for the tenants and any interested parties.


What changes, if any, should the Government make to the Decent Homes Standard?


9.       This standard is necessary for an update and should be part of any levelling up agenda that supports lower-income families. Especially those who are in social landlord properties. The original target was for all homes to be decent by 2010 -but this is not the case. The Housing Health and Safety Rating System (HHSRS) includes the requirement to be free from hazards. Hazards could potentially include those related to climate change in any revision to the standard. However, this should be a standard that is recognised as a compliance issue and one that should be met, even if the tenant does not want the improvements. This would be a step-change from the original 2006 version.


10.   Environmental and security issues should be included. Climate change adaption and climate resilience should also be a thread that sits within any Decent Home standard. This should be more than meeting compliance with building regulations. This is about pro-active planning that utilises scientific knowledge about the implication for climate change, particularly within the levelling up agenda and risk to the UK population. For example – heatwaves in 2019 saw almost 900 extra deaths in England alone. This is reported by the Committee on Climate Change (CCC) to be in the region of 7,000 by 2040 when temperature increases for the UK are expected to have a significant impact on human mortality. Homes that are designed to provide shelter from the heat and not significantly overheat will be an ever-increasing requirement and will be a necessity to reduce the occurrence of overheating related deaths in the UK.


11.   Cold homes also provide a risk factor and should be part of the conditions to be recognised within the Decent Homes standard and recognised by Social Housing landlords as something of key interest. Whilst the criterion in the Decent Homes Standard calls for a reasonable state of repair – the importance will be around the definition of how this very statement is defined in the regulation.


Should the Decent Homes Standard be amended to include energy efficiency and other means of mitigating climate change, and if so how?


  1. It absolutely should. The Heating and Buildings strategy launched in 0ctober 2021 limited its commentary on a fabric first approach for building heating strategies but instead focussed on the replacement of gas-powered boilers.


  1. A decent home should meet four criteria (a) it meets the current statutory minimum standard for housing (b) it is in a reasonable state of repair (c) it has reasonably modern facilities and services and (d) it provides a reasonable degree of thermal comfort.


  1. This statement needs to ensure that each section is clearly defined and without an ability to merge or water down the requirements. Two-thirds of the North’s homes are below Band C – the minimum target where practical, cost-effective and affordable by 2035. Representing a huge challenge, but one that should not be ignored.


  1. A reasonable degree of thermal comfort is proposed – but this needs to be defined within a context of standards. Those who are vulnerable or who have a specific illness, elderly or children have very different requirements for thermal comfort. Thermal comfort in 2021 and thermal comfort in 2050 will mean very different things considering climate change projections for the UK.


  1. Upgrading fuel poor homes to EPC Band C by 2030 where reasonably practicable and providing additional funding to the Home Upgrade Grant and the Social Housing Decarbonisation Fund is needed. Investing £1.75 billion to also meet the requirements of the Decent Homes Standard will give those organisations within the social housing sector the regulatory support to ensure that works are instigated to meet the requirements of energy and thermal comfort - Whilst addressing concerns over damp and inefficient buildings.


  1. Decent homes should also mean that climate resilience is part of the design or retrofit. Climate change will be one of the biggest impacts on homes in the next 50 years. Projections from the Met Office show that the climate will be wetter and warmer. Whilst the warmer temperatures will see a reduction in heating demand, it is anticipated that this could also lead to an increase in cooling demand. Cooling demand also needs to be included as part of the remit – under the banner of thermal comfort. Cooling might need to be included in 2050/2080 weather scenarios ­and should be about maintaining a level of comfort that does not lead to illness or death.


  1. The list of building elements within the Decent Homes standard must be maintained and include renewable technology that meets the decarbonisation plans for the UK. This should include but is not limited to Solar Panels, PV and ASHPs. ASHPs will become particularly important post-2035.



December 2021