Written evidence submitted by Sovereign [RSH 100]


About Sovereign

As one of the country’s largest housing associations, Sovereign manages more than 60,000 homes and aims to build around 2,000 new homes every year. We have deep roots in the south of England, with almost 60,000 homes focused in a core area covering Berkshire, Hampshire, Oxfordshire, Gloucestershire, Dorset, Devon, Wiltshire, the West of England and the Isle of Wight.

As part of a five-year strategy, Sovereign has trebled investment in community work, stepped up its development programme with a greater emphasis on major land-led schemes and focused on providing sustainable, affordable homes for nearly 140,000 customers and residents.


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

Concerns about the quality of social housing are both widespread and serious. High-profile media campaigns, such as the ITV coverage of damp and mould in social housing have brought the issue of quality to a wider audience in the last 12 months. It was widely reported when the Secretary of State for Levelling Up, Housing and Communities described the quality of some social housing as “scandalously poor” at the Conservative Party Conference.

Concerns about the quality of social housing are serious. Covid-19 had a disproportionate impact on people living in overcrowded, damp or cold homes with direct consequences on their health. Even for those who did not get ill with Covid, the impact of lockdowns on mental health and wellbeing was far worse for people in poor quality homes of all types. As we said in our annual report: “The impact of the pandemic should force a rethink in aspects of housing policy in our sector and beyond.”

Poor housing is bad for people’s health in many other ways too. According to research commissioned by the Centre for Ageing Better - Good Homes for Allone in five excess winter deaths are attributed to cold homes.

The regulatory regime in place in the social housing sector means that compared to both the private-rented sector and owner-occupied homes, social housing is on average better quality. However, there is wide variance between and within housing associations.

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?

Any resource we use to remediate building safety risks or to retrofit homes to make them more inefficient reduces our capacity to build new homes, or to make improvements to homes that do not make them more energy efficient.

The cost of decarbonising social housing has been estimated at £104bn, or an average of around £20,000 per social home. While social housing providers are preparing to invest billions in improving stock to be net zero by 2050 it will have an impact on their ability to invest in other things.

In terms of energy efficiency, however, most improvements we would make to a home will have a direct or indirect positive impact on energy efficiency. Replacing doors and windows improves insulation, reducing energy use. Where more substantive improvements are needed, we would use materials that will improve a home’s energy efficiency. Other measures, such as improving ventilation to reduce damp and mould can have an indirect positive effect, making it easier for a resident to keep their home warm.

Our customers’ safety if our number one priority and all our customers should live in a home that is safe and meets all statutory building safety requirements. However, remediating building safety does not always bring an immediate, tangible benefit to residents’ day-to-day lives if they are social housing tenant. For example, replacing an external wall system that does not meet building safety standards may have no impact on the energy efficiency of the homes in a given block. For leaseholders, who may be liable to pay for remediation work and for shared owners, whose property value is affected if a building does not meet safety standards, remediation work is an absolute priority.

Sovereign is committed to ensuring all our customers living in homes which meet the highest standards of building safety as well as meeting all regulatory requirements. We are currently working with Homes England to establish whether we can benefit from the available public funding for remediation work. In some cases, failure to meet standards may rest with developers and, where that is the case, we would like them to fund work to bring developments they built up to standard. If we have to spend money on building safety remediation it will impact on our ability to invest in both new homes, retrofitting existing stock and other customer services.

We are also committed to our homes being net zero and we are ready to invest in this too. It again follows, however, that when we make that investment it will be at the expense of building new homes.

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

The current structures are fit for purpose, but the evolving responsibilities of the Regulator of Social Housing reflect the need to improve consumer standards for our tenants.

The government’s White Paper - The Charter for Social Housing rightly sets out the ambition to raise standards and meet the aspirations of social housing residents. When it was published Sovereign welcomed the fact that the Social Housing Regulator would be taking on new responsibilities as a proactive consumer regulator. This is the right direction of travel and has the potential to improve consumer standards, ensure customers a provided with quality services and that when things go wrong complaints are dealt with effectively.

Many of the proposals in the White Paper and in the RSH’s response to it are already best practice in the sector. At Sovereign our Resident Board Partnership undertook a structured scrutiny of the White Paper and concluded overall it was “not a radical change but a helpful one”. We noted the link between public health and decent homes and the emphasis on safety. We also welcomed the inclusion of Performance Indicators and other measures to improve transparency and accountability.

How clearly defined are the roles of the Regulator of Social Housing and the Housing Ombudsman?

The Regulator has defined responsibilities to enforce statutory obligations and improve standards across the sector. The Ombudsman exists to support individual tenants and to resolve disputes between them and their landlord. Clearly the two are aligned in objectives and the Ombudsman’s responsibilities flow directly from the standards set by the Regulator, the distinction in the roles is clear.

Does the current regime allow tenants to effectively resolve issues?

While the current regime does provide the basis on which tenants can resolve their issues, the proposals in the White Paper strengthen that regime. We welcome the end of the 8-week wait for tenants to access the Ombudsman and the strengthening of the Ombudsman’s powers. An independent reviewer should give tenants confidence in the Housing Ombudsman Service. Our Resident Board Partnership in particular welcome proposed changes to the make the Ombudsman more accountable to tenants.

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

Yes, but they could be strengthened to improve consumer standards.

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

As set out above, we believe that the reforms proposed with improve consumer regulation and formalise tenant engagement that constitutes best practice in the sector.

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

The Decent Homes Standard should be strengthened and broadened. We recommend introducing a new standard that grades homes as well as setting out minimum standards.

Sovereign has this year published our own Homes and Place Standard, setting out the standards we want to see for every home we own. The Standard is built around four key pillars: customers, homes, places and sustainable future. Our homes will be adaptable, digitally connected and cost effective. The places we create will be inclusive and safe. Most importantly, our Standard will empower our customers to have a positive impact on the environment and enable us to achieve net zero by 2050.

We are currently in conversations with officials in BEIS around how the Homes and Place Standard could play a role in decarbonisation of social housing stock. We would welcome the sector wider adoption of a good home standard that incorporates a far broader vision of what makes a good home in a good place to live.

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

Yes.  It is vital that any revised Decent Homes Standard includes energy efficiency and other means of mitigating climate change. For existing homes, a new standard should take into account insulation to minimise heat loss, whole house ventilation systems, energy efficient appliances and lighting. However, as with our Homes and Place Standard, a new Decent Homes Standard should take account of how homes and places impact customers’ carbon footprint in terms of their use of public transport, access to amenities and the biodiversity of their neighbourhoods.

Should all providers of social housing, not just councils, be required to register with the regulator?


What challenges does the diversification of social housing providers pose for the regulatory system?

As the sector has diversified and social housing providers have expanded their activities as developers, in supporting their tenants and in the range of housing products available there is more activity for the regulator to take account of. The types and categories of customers is more diverse and different customers increasingly expect different services. The broader the range of activity undertaken by housing providers the more the regulatory system must reflect that diversity. The biggest challenge is to prioritise: providing clear regulation on building safety, decent homes and accountability.


December 2021