Written evidence submitted by the London Tenants Federation [RSH 097]

London Tenants Federation (LTF) brings together borough, neighbourhood and London-wide federations and organisations of tenants (including leaseholders)[1] of social housing providers (both council and housing association). Our membership also includes the London Federation of Housing Co-operatives and the National Federation of Tenant Management Organisations.

Each of our members have their own membership comprising local tenants and residents’ associations, tenant managed organisations and co-operatives. LTF has been in existence since 2002.

Our main focus is engaging our member organisations and their members, in London-wide strategic housing, regeneration and planning policy


We have engaged in most Examinations in Public of the London Plan. We respond to regional and national consultation relating to housing, planning and regeneration.  At times, we are invited to engage in London Assembly, Housing and Planning Committee meetings.

We have strong links with other London community and voluntary sector organisations that also have an interest in housing, regeneration, planning and community related issues.

Our submission draws on our members’ meetings and conference discussions held at various times, and refers to London Tenants Manifesto for a Positive Future for Social Housing in London (published in January 2021. We have response to most of the questions set by the committee.

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

While clearly not all social housing landlords fail in their duty to properly manage and maintain tenants’ homes, problems relating to the quality of social housing, are sufficiently widespread to cause serious concern

Problems for both council and housing association tenants include poor quality maintenance, failures to deal promptly with individual and communal repair issues, shoddy workmanship, poor tenant consultation, tenants finding it difficult to get their complaints responded to, or adequately dealt with. At times tenants find they are being blamed themselves for issues that landlords are actually responsible for. We feel this is fed by disrespect for, and negative stereotyping of social housing tenants.

Health and safety issues may not always be very obvious, but (according to Inside Housing 21.10.21) a new survey of 106 housing associations by the National Housing Federation has found that 61 landlords have discovered dangerous materials on their blocks since Grenfell.

Numerous changes / major works may have occurred to social rented homes since their construction. Little or no information is held on this in the public domain, few tenants will know the extent to which compartmentalisation may have been breached in these works.

Tenants often struggle to access the information they want about their homes and the decisions that are being made on their behalf. This is much worse for housing association tenants who have no access to freedom of information.

Opportunities for tenants to shape delivery of services is weak and, too often, consultations are little more than tick box exercises, excluding proper debate.

Complaint’s systems are long and arduous, with many tenants being ground down and or giving up before even attempting to access the Ombudsman. In fact, the use of complaints procedures appears to be a control mechanism to wear tenants down, make then give up and go away.

Even where complaints are acknowledged there are often failures to change methods of operation to prevent similar complaints having to be made again.

See here a link to - Six Years to get a bathroom leak fixed.  Housing Association Tenant describes complaints procedures - a video from a special meeting that LTF arranged with the London Assembly Housing Committee members for their enquiry into tenant involvement in decision-making post Grenfell in 2018

Transparency and accountability are also incredibly weak.

From 1998, in the promotion of council stock transfers to housing associations, tenants were told that the quality of management and maintenance of their homes would be far higher if they opted for stock transfer. Tenants were also told that housing association landlords were far more tenant friendly.

While this has been disproved time and again, the worst example we have seen is the Eastfields estate in Merton. Merton homes were stock transferred in 2010 to what is now Clarion Housing Association in 2010. The homes are in an horrendous condition, as has been highlighted in local and national (via ITV’s David Hewitt) media.

However, social landlords’ failures to address serious issues of mould, damp and infestation of mice, rats and cockroaches are not uncommon in housing association or local authority estatesWe have attached a list of 31 articles from local newspapers that highlight similar situations in 2 ½ months of October, November and part of December (on pages 9 to .

Housing associations mergers, with a focus on developing new homes including market and intermediate, often appear to be at the expense of existing social housing tenants. Many feel that their housing associations have moved far from their original social objectives.

Where local authorities are developing new homes, this tends to occur through demolition of existing homes – either whole estates or parts of estates.

In such circumstances, even before potential demolition is mentioned, tenants may suffer years of repairs and maintenance neglect. This would appear to be designed to persuade tenant the only way to address the problems is via demolition. Tenants may then suffer years or even decades of repair and maintenance neglect, neighbours being moved from their homes and communities, increased health problems suffered and once demolition or refurbishments commence, the conditions suffered can be intolerable.

Here is an example from S Lambeth Estate. (NB we have encouraged them to make their own submission as they have lot of information / evidence for the committee.

The following have contributed to the poor conditions that many social housing tenants are suffering:


See video here of a tenant describing her housing association’s ‘secretive’ and ‘tokenistic’ tenant representation. This is also from LTF’s involvement in the London Assembly Housing Committee meeting on tenant involvement in decision-making post Grenfell.

This is another video from our meeting with the London Assembly Housing Committee meeting and its investigation into tenant involvement in decision-making post Grenfell A resident scrutiny board whose members cannot criticise their landlord in public.


  1. 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?

Despite cries of financial hardship from large housing associations, their financial situation is generally financially secure. Inside Housing reported on 17.01.21 that Clarion, for example, had seen its net surplus rise by 29% to £100m despite forking out a further £18.6m in fire safety costs. 

This is supported by tenants’ rent increases of CPI + 1% since 2021. The English Housing Survey’s Household Resilience Survey, Wave 3 (October 21) reported that rents in the social housing sector rose on average from 27% of household wages pre-pandemic to 37% a year later and is still at 34%.

The impact of this likely increased numbers of social housing tenants being forced into greater financial hardship and debt.

The failure by central government to provide sufficient funding to support delivery of new homes means that tenants rents are footing the bill for new homes, at the expense the maintenance of their homes.

The G15 and London Council’s Delivering on London’s Housing Requirement: interim report suggests that they will struggle to meet the cost of required improvements to fire safety and meeting net-zero as well as delivering the new social rented homes desperately needed in London. They argue for more money from central government, which we would support, but also ask that the government make a 30-year commitment to tenant rent increases of CP1+1% which, given the hardship this presents to some of the least well-off households in London, is totally unacceptable.

The boroughs with the G15 have consistently failed to deliver the social rented homes needed in London. Despite London Plan Examinations in Public providing evidence that they could deliver 131,237 social rented homes from 2005-19, only 61,572 were delivered.

London’s social housing tenants should not have support in footing the bill for these failures.

We are also concerned that some housing association landlords are already talking about ‘hard-to-retrofit’ social rented homes and are suggesting they would be prepared to sell some homes to meet the cost of retrofitting others. Inevitably this would increase the need for replacement social rented homes.

  1. Is the current regime for regulating social housing fit for purpose?

The co-regulatory system just doesn’t work. It assumes an equal balance of power and interest between tenants and social landlords, when this is just not the case. This means that when things go wrong, tenants find it very difficult to get issues resolved.

There is a lack of regulatory powers at the local level that might enable local authorities – councillors and officers - to take action against housing associations.

We believe the regime for regulating social housing will remain inadequate without tenants’ rights being integral to all strategic decision-making and housing management structures including on the health as safety.  Tenants should have rights to organise collectively and to take a full and equal role in the decisions (enshrined in legislation) made about their homes from the local to national level.

Individual tenant satisfaction / perception surveys (as announced by the Regulator of Social Housing – Dec 21) are an insufficient and patronising way for tenants to assess how effective their landlords are in dealing with a range of issues and particularly on health and safety. These are no substitute for tenants being able to collectively make assessments through access to information and independent advice, the opportunity to scrutinise and have face to face discussion with landlords.

London Tenants manifesto for a positive future for social housing in London, Chapter 2 – safe, well designed and managed homes, proposes more serious and effective ways of achieving safety in social tenants’ homes.

We suggest that housing association tenants should have same rights as council tenants under an expanded FOI Act, have the Right to Manage and to Transfer (including being able to switch to a local authority or tenant led landlord), secure tenancies, the local Audit and Accountability Act, the Public Sector Equalities Duty and the Gunning or Sedley rules around consultation.

All social housing tenant households should also have the right to a secure, well-maintained social rented homes of a suitable size enshrined in law.

We feel that social landlords should not be allocated grant funding to deliver new social rented homes unless it is proven that they are delivering a good service to existing tenants and are facilitating good quality tenant involvement in decision-making.

LTF proposed this in a list of ‘asks of the London Mayor in our submission to the London Assembly Housing Committee’s investigation into tenant involvement in decision-making, post Grenfell.

We note however that in September 2021 the largest allocation of grant funding for new homes that was allocated by the Mayor of London’s office, was to Clarion Housing Association, shortly after public revelations of their extremely poor management of the Eastfield Estate. Many saw this as rewarding poor management of social rented homes.

  1. How clearly defined are the roles of the Regulator of Social Housing and the Housing Ombudsman?
  2. Does the current regime allow tenants to effectively resolve issues?

No. The suggestions in response to question 3 and others from London Tenants Manifesto for a positive future for social housing would be much more effective.

  1. Do the regulator and ombudsman have sufficient powers to take action against providers?

We are not convinced that the processes are adequate, as highlighted in our response to question 3.

7.               Will the reforms proposed in the social housing White Paper improve the regime and what progress has been made on implementing those reforms?

Despite the proposals in the green paper for addressing issue of fire safety, negative stereotyping of social housing tenants and provision of an effective voice, these are missing or inadequate in the green paper.

Regarding fire safety, the fundamental democratic deficit at the heart of the Building Safety Bill is the absence of social housing tenants and residents voices (via democratic and accountable organisations from the local to national level). The proposals in the draft Bill were overwhelmingly shaped and influenced by the landlord sector, and by extension, building owners and managers, developers, fire risk assessors and enforcement bodies. It was a clear watering down of the government’s promises to implement the Grenfell Inquiry recommendations and residents’ interests are still at risk of being ignored or trampled on.

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

The government should consult thoroughly with tenants /particularly tenants’ organisations at all. Consultation with tenants was absent in the development of the 2004 and 2006 decent homes standards.

It has failed to fully involve tenants in its recent review of the standard.

LTF asked for representation on the review body. We were advised no, since our organisation is London-, not nationally, based. We noted that the G320 and G15 housing association landlords were both London based, but were engaged in the review.

Any new standard must come with guaranteed funding from government to cover costs and with no strings attached (unlike the situation that occurred previously when tenants and or councils had to opt for stock transfers, PFI or ALMOs should they have insufficient funds to meet the standard).

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

See response above.

  1. Should all providers of social housing, not just councils, be required to register with the regulator?
  2. What challenges does the diversification of social housing providers pose for the regulatory system?

We would like to see that all institutions that exert direct influence on tenants homes and neighbourhoods are accountable to tenants through democratic structures that operate in an open and transparent fashion (See section 1.7 of the London Tenant Manifesto – a positive future for social housing in London).


List of links to 31 articles in local press in London focused on the poor conditions in social housing tenants’ homes over a period of 2 ½ months – October, November and part of December 2021.

S London mum with 5-week-old baby and 6-year old in damp (severe mould) throughout her Lambeth council flat with holes in floor, in which her son’s foot has been trapped on multiple occasions. He has skin conditions – insect creep from the gaps in the floor.

Southwark mum left living in mouldy flat with damp up to her waist and broken window screwed shut (Guinness Trust). She lived in a flat for almost 6 years and then was moved to another flat also with damp.

Vulnerable mum and baby forced to live apart from dad stuck in council flat with no heating or hot water for a month (K&C council)

21 Oct 2021

Vulnerable man – fell through floor of his ‘hell hole’ Hackney council flat would rather sleep on part bench.

13 Dec 21

Single mum of 3 with black mould in her (Clarion HA in Merton) 1-bed flat (Sadler Close). Family of 4 share one bedroom – son has asthma caused by the mould.

14 Dec 2021

Mum forced to sleep in living room with disabled daughter after ceiling of her Westminster council flat collapses.

9th Dec 2021

Horror of London (Peabody estate - Southwark) where 7 ceilings have collapsed.

15 Oct 21

Peabody Estate Westminster – where ceiling has collapsed and children rotate bedrooms because there is so much damp.


11 Oct 21 

Autistic man’s Westminster Peabody flat let unable to use his toilet for 6 months as it leaks into neighbour’s home.

2nd Oct 21

Westminster Peabody estate – thick black mould from nearby drainpipes.  Water seeping through brickwork, flooding the estates path. Water flows down the stairs because of poor drainage.


London family stuck in mould infested (Let Sell property managed by Waltham Forest council) where leaks are so bad that they have an umbrella stuck to the ceiling in the bathroom. Tenant and wife both disabled


Mum badly burnt after pipe burst (in Westminster council flat) and flooded daughter’s bedroom with boiling water


Mum living in rodent infested Westminster flat – eating food with cupboards strewn with droppings


Survivors of abuse living in a Housing for Women block of flats in Lewisham - with broken doors fear their safety.  Communal doors have been broken for years. Homeless people occupy the hallways at night – leaving smell of faeces and urine. Residents also suffer smell of rotting food in their flats as bins (below their flats) are always overflowing. There are also issues of anti-social behaviour including eggs being thrown on balconies and fire risks with lighted cigarettes are dropped from balconies onto floors below, lack of fire alarms and damp and mould. Lifts often don’t work.


70-year-old living in mould ridden Wandsworth council flat with serious bed bug problem.

Mum, 27, living in mouldy Lambeth council flat with brown liquid running down the walls. The flat has a number of issues including extensive mould and extensive repairs that have not been resolved despite multiple requests to the council.


Family living in a Hammersmith and Fulham council flat left with no heating or hot water for 3 months (and won’t be fixed for 8-10 weeks).


Mum of A2 Dominion flat in Hammersmith and Fulham have never had enough hot water to wash and bathe children.


Mum, 14-year-old son and baby daughter living in temp Clarion flat since 2018 in East London – other residents have gradually moved as Clarion say the flats are ‘extremely’ dangerous.

Because the mum rejected Clarion's options of living in a "crime ridden" estate nearby and out of borough in Walthamstow, Clarion served her a notice of possession order (known as a court order) last March. She says she was horrified when a senior housing officer reportedly told her in a later meeting: "It's social housing, what do you expect?"

Communal hallways reek of urine and gone-off food. There are faulty fire alarms and mice infestation.


Mum, 22, living with toddler and baby in Clarion home in Croydon says it is so grim she 'catches 3 mice a day'. Suffers condensation and black mould in bathroom.


Family living in mouldy Westminster council flat (83 year old and two grandchildren) with serious insect infestation - in food. 


Vulnerable tenant of a Hackney Wenlock Barn TMO council flat has sought legal advice after complaining for 2 years about the state of his home. Main issues – no heating and sink blocked and leak in kitchen pipe, damp and water (3 inches deep) has spread and all floors are saturated. Electrics remain in use – a serious danger to the tenant. Mould all over kitchen including furniture and cupboards are rotten. The kitchen extractor fan is broken. Bathroom as not working light – mould and damp on walls and basin blocked. Mould and damp also in living room and bedroom.


Bexley mum, 40, says stress of living with leaks, damp and mould for 7 years in L&Q block in Bexley  has caused health problems. Flat has leaks, damp, mould and asbestos


London mum (and three children)  left with no roof for three weeks and forced to pee in bucket (Bexley council owned home).




Streatham tenant living in damp and mould-infested property compensated two years after first complaint

              A Streatham (Lambeth council tenant) has won £3500 damages after taking legal action against the council for a second time for poor living conditions.  The tenant had been complaining since August 2019 about the damp and mould infested property.




Disabled 56-year-old woman ‘drowning in black mould makes a desperate plea to Lambeth council for help. Tenant had been complaining for 2 years, they have sent out workers to fix the issue but the black mould remains and has spread across the ceiling of her bathroom. The tenants is housebound apart from hospital appointments.





Brentford grandmother living in uninhabitable rat a damp infested Hounslow council house with family of 5.


W London disabled tenant who can hardly get down the stairs, feels like a prisoner in her home because of damp, rats and holes in the flooring. She has been witing for 6 years for her house to be made wheelchair accessible. A surveyor who visited her home has labelled the house uninhabitable. The tenant has osteoporosis, arthritis and beathing problems.





Widower’s flat so damp and mould ridden that pictures fall off walls and floors are covered in wet towels.


The 81-year-old has been living in a hotel for 3 months while he waits for Clarion to carry out repairs to his mould infested flat in Merton. Clarion sent a surveyor to see the property three times but took no action.





A family living in mould, damp mic and asbestos in their Hackney council flat for more than 20 years has suffered another devastating blow as their living room ceiling collapsed.





Tenants’ hell in fly-infested Westminster council flat where lights crackle due to leak in the ceiling and mould developing on walls – for 6 weeks as leak not fixed.





Care worker forced to leave home because of rats, damp and mould may not get new property 'until Christmas'


Clarion flat with damp, mould and vermin in Merton.  Tenant says she is one of many Clarion residents who are being moved into hotels while the housing association decants or completes repairs in properties. She said this is not an isolating incident, this is taking place with every other resident that Clarion is taking control over - why are they failing. 


December 2021

[1] When referring to ‘tenants’ we mean both tenants and leaseholders (as set out in our Articles of Association)