Written evidence submitted by Almshouse Consortium Ltd [RSH 104]

Call for Evidence

The inquiry seeks evidence on the quality of social housing, the effectiveness of the regulatory regime and the proposals in the social housing White Paper.

The inquiry seeks answers to the following questions:

1. How widespread and serious are the concerns about the quality of social housing?
2. 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?
3. Is the current regime for regulating social housing fit for purpose?
4. How clearly defined are the roles of the Regulator of Social Housing and the Housing Ombudsman?
5. Does the current regime allow tenants to effectively resolve issues?
6. Do the regulator and ombudsman have sufficient powers to take action against providers?
7. Will the reforms proposed in the social housing White Paper improve the regime and what progress has been made on implementing those reforms?
8. What changes, if any, should the Government make to the Decent Homes Standard?
9. Should the Decent Homes Standard be amended to include energy efficiency and other means of mitigating climate change, and if so how?
10. Should all providers of social housing, not just councils, be required to register with the regulator?
11. What challenges does the diversification of social housing providers pose for the regulatory system?

Almshouse Consortium Limited
Response to HCLG Committee

Almshouse Consortium Limited (ACL) is a not-for-profit Lead Investment Partner of Homes England and the Greater London Authority. It was conceived, and operates, as a vehicle for almshouses across England and London to access grant funding for the construction of new almshouses and the remodelling of historic stock.  Over its life, ACL has obtained grant funding or around £34m for almshouses.

ACL supports the submission made by the Almshouse Association and seeks to provide further information drawn from its particular experience of dealing with the regulatory regime on behalf of its members.  This is most often encountered when individual members seek registration, with the Regulator for Social Housing, to be able to access grant funding from Homes England for new build developments

Almshouses vary from mainstream affordable housing in a number of ways.

1. Most are many centuries old, with buildings being gifted by local benefactors, often with land, the income from which covered the building maintenance.  Many are Listed Buildings which require more expensive maintenance.

2. The property is held as permanent endowment, which means it cannot be sold without the consent of the Charity Commission.  This consent is generally granted only if the properties can be re-provided.

3. At the time of construction, the availability of land was less of an issue than it is today and many almshouses occupy sites with significant land holdings around them. There are many situations where the land was acquired to allow future developments to meet a further need for low-cost housing over time. This legacy land remains undeveloped due to lack of funding rather than housing need these days.

4. Most almshouses are very small with an average of less than 20 dwellings, managed by Trustees who live locally and are very much a part of the community.  Many are in rural locations where the provision of new affordable housing is difficult to achieve.

5. Any supplementary income from renting out the land does not bring in sufficient revenue to add to the rental income to meet the higher cost of maintaining the historic Almshouses. (Trustees are looking to increase the number of dwellings to make their management and maintenance more efficient and achieve a minimum critical mass with consequent economies of scale. Where possible almshouses often seek to amalgamate or share the services of a Clerk to manage the properties whilst minimising cost.
6. Many Almshouse charities were formed at times were there was a shortage or suitable affordable accommodation for local residents. We are in very similar times were there is an acute shortage of affordable housing. Over 100 Almshouses came forward to the Almshouse Consortium at the start of 2021 to seek advice on accessing the new affordable homes programme. They had a clear desire to once again to have a role in providing new homes to meet the housing needs in their locality.. In terms of Almshouse Consortium Membership over half are looking to provide new accommodation for older persons and some are looking to continue to build housing for more vulnerable members of society such as homeless. Increasingly innovative designs are being considered to meet the new environmental standards adding air source heat pumps on remodelling schemes or using modern methods of construction schemes on newbuild developments

7. As the requirements currently stand, only registered providers can access grant funding from the GLA or Homes England for new build schemes or new supply The new supply can cover many different options such as change of use of an office or garage to residential or reconfiguration of 2 larger homes for example to create 3 homes

The registration process is an onerous one, particularly for an almshouse with only a few houses.  The process is appropriate for large providers where potential risks could impact on a large number of residents, but is disproportionate for small providers especially those where they do not see themselves having a prolonged programme of development. We have an example where an Almshouse will have to become registered to convert a garage to form a new residential dwelling. Planning has been obtained but now they need to become registered to access c£45,000 grant funding. They do not have any further land or assets to develop once this scheme has been completed

8. ACL recognises that a change in legislation to facilitate almshouse development is unlikely at this time and could take the life time of the 2021-26 programme to be introduced delaying the possibility of many new homes for much longer. As a result at ACL suggests the following approach may be a proportionate response to the regulatory framework.

• All almshouses are members of the Almshouse Association, as an overarching body.
• The AA produces a guidebook – Standards for Almshouse Management – which members use to extract standard policies and procedures over a wide range of issues to ensure compliance with legislation as the building owners and managers
• These policies represent good practice across the industry but where there are gaps between what is required to meet the regulatory standards and the current version of SAM, they could be tailored to the requirements of the regulator if necessary.
• Agreement of relevant standards, and their incorporation within SAM would give a template for registration, acceptance of which by the almshouse could be made in the knowledge that it will meet the regulatory standards.
• Working with the Almshouse Association, ACL would promulgate these to all almshouses seeking to register before a new build scheme is initiated.

As background to the above, ACL currently is liaising with over 25 almshouses who have not accessed Homes England funding previously. Together they are seeking to develop around 453 new houses on land already owned.  These are only the ones who are actively taking a development forward but we know others are interested and looking to follow their lead. From the initial approaches received some are already registered, some do not require registration and some are starting the registration process. However as can be seen from the numbers we had over 100 initial responses, there are therefore a significant number who have decided not to continue their development plans. The overriding message given back is they have withdrawn due to the complexities of registration.

At a time when the need for affordable housing is as great as it has been in living memory, a method of facilitating a proportionate approach to registration would release land for development, and the affordable new build dwellings it could provide.

January 2022