Written evidence submitted by an association of residents at St Georges Estate [RSH 106]
This submission concerns residents' well-being, quality of life in social housing, social exclusion, sense of security at St. Georges Estate, Eastend Homes, a registered social landlord in Tower Hamlets.
As an introduction EastEnd Homes inherited St. Georges Estate through stock transfer from Tower Hamlets council in 2006 voted for by residents as a new form of social landlord with a 3 part governance of members:
1.East End Homes Limited,
2.London Borough of Tower Hamlets
3.Residents of the estate.
3. was phased out through a change of constitution with little consultation with residents. We understand that media reportage is not a part of this call for evidence but a link is provided here on its details. It can be excluded from this submission.
Our submission concerns quality of life in social housing after the stock transfer, ability of residents to have a say in the affairs of the estate (as Eastend Homes brands itself as a 'community led housing association') and to provide examples that may be of value to the government White Paper and the policy changes it suggests. In particular we draws out inconsistencies and disparities between one housing provider and another: a level playing field in terms of guidance and good practice is needed from our perspective.
Evidence Subject 1
The Housing Association's fulfilment of its Section 106 obligations
As part of its stock transfer and acquiring the freehold of St.Georges estate in Wapping East End Homes were to provide a new community centre of 510 sq m along with other allocations of Section 106 towards alleviation of social deprivation, community development, levelling up and addressing inequality.
The full details are provided in the Strategic Development meeting files of 2008 approved by LBTH
The key details concerning the community centre were:
8.38 The applicant (Eastend Homes) has advised that the existing community centre (OAP Club) adjacent to
Swedenborg Gardens will be refurbished and integrated into the regeneration estate. In
addition, a new community centre of approximately 510 sq.m will be provided at ground level
on the site’s frontage to The Highway as part of the development of site 10. This aspect of
the proposal supports the Borough’s planning objectives to secure community infrastructure
to respond the additional needs of the local community and help achieve a sustainable
residential development (Policies CP5, CP19, and SCF1 of the IPG). The provision of the
additional community centre will be secured by way of S106 agreement
8.39 It is considered that the community facility for the residents is welcomed and is appropriate to
the proposed density increase. It is recommended that a condition be attached which will
require the applicant to provide a full management plan which sets out the detailed
information regarding the size, access, accessibility, procedures and general operation of the
proposed community facility.
8.45 To mitigate against the demand of the additional population, the applicant will be required to
provide £262,941 towards the provision of health contributions and £296,208 towards the
provision of education facilities. This will be secured by way of a S106 agreement. In
addition, the proposed scheme will retain and refurbish the existing community centre and
children’s play area on site. A new community centre (510 sq m) will be provided which
represents a value of £806,677. This will be secured in the Section 106 agreement This
complies with policy SF1 of the adopted UDP and policy SCF1 of the IPG as it ensures that
all residents will have access to social facilities.
The reality for residents is this. Whilst EastEnd Homes (EEH) were quick to demolish the existing community centre, we are still awaiting our community centre ten years later in 2021.
Several residents wrote to MP Jim Fitzpatrick in July 2019 asking for information on our community hall and consultations but EEH have not consulted the community.
EEH responded to the MP that they had offered a space that was rejected by TRA (Tenants Residents association) in 2013 by its then Chair - however the space was rejected as it had no windows in the main hall. The demolished 1970s facility had windows and access directly from hall onto external landscape.
Few in the community are informed of all this. This process of EEH consultation method has been challenged by residents as EEH communicate with a single person on a personal email of the TRA Chair of their EEH approved TRA. Thereby little of the information trail can be seen by the greater community. EEH's approved TRA also operates without AGMs which we are requesting through enquiries and the EEH website contains little information on their approved TRAs in what is meant to be a community led housing association..
Following 2013, the then allocated community centre, a new-build 'corner unit' in corner of Canon Street Road and The Highway, has stayed closed. As a result community life in the estate has shrunk or been damaged irreparably. To quote one resident as part of the consultation for this submission, “EastEnd Homes has made us voiceless”.
In summer of 2021,the present TRA chair a 77 year largely incapacitated in hospital with whom EEH communicates privately released plans - after much pressure - of the proposed opening of the community centre to concerned residents. It revealed a community hall of less than 60 sq m (not 510sq m) with the bulk of the community hall now allocated for EEH's own office use.
See plan enclosed – Community_Hall_13.7.21.jpg.
However community use is planning classification D, office use is B. Residents are not aware of EEH submitting a planning application for change of use.
Through door to door consultations we are asking that EEH fulfils its Section 106 obligations which were part of the stock transfer and residents are requesting a proper community hall.
Our evidence should address aspects of the White Paper on Social housing covered inadequately in our opinion, namely good practice on how community amenities and Section 106 obligations essential to a healthy community life are covered. That community assets as real estate should be considered as part of an economy for the benefit of residents and their associational life; not to be treated as another part of the real estate for the social landlord.
Evidence Subject 2
This subject of evidence is to highlight disparities in Section 20 charging between housing associations that leave leaseholders in social housing in artificially created insecurity and the need for greater transparency and consistency.
To give examples, the Tower Hamlets Council policy suggests a ten year payment plan for Section 20 Major works charges:
Example of a public declaration of Major work charges - so that families can plan their future would be:
Even Poplar Harca, a Tower Hamlets housing association, whose repayments plans for its leaseholders are considered severe, offers 5 years payment for major works over £10k, 3 years under 10K.
However, East End Homes, as a 'community led' housing association do NOT provide details on their website:
Whilst EEH routinely respond to enquiries to say they offer a 4 year payment plan, this would be for amounts above £20K. The term they offer their residents is effectively a max of 3 years: the image we provide – East_end_Homes_Major_Works_plans.JPG - is what they send to the leaseholder with their invoice so that Section 20 Major Works are classified as Service charges.
We have many times asked why East End Homes payment terms are this way and so poor compared to other social landlords; their reply is that 'it has been approved', along with the repeated use of "fair and reasonable".
The 'it has been approved' refers to approval by the EEH board. However a straw poll of 50 residents showed that no-one knew who the board is, or anyone on it, in particular the resident board member.
Whilst East End Homes allow a resident board member, that person is chosen by them, not elected by residents as raised in a Tower Hamlets council enquiry in December 2011 with a request to the EEH CEO that:
RSLs have a duty to ensure democratically elected representation for tenants, leaseholders and freeholders on estate management boards
and further that,
the election of residents to the board would be an easy process to carry out in comparison to the enormous benefit
The White Paper needs to highlight good practice regarding this both for the benefit of RSLs and resident bodies.
But to return to the subject of Section 20 charges, therefore at East End Homes, a major works charge of £19,500 is payable by a leaseholder in 3 years maximum which is really out of reach for the household incomes in Tower Hamlets – it has no relation to the averages wages for Tower Hamlets residents.
We have asked East End Homes how their FCA (Financial Conduct Agreement) based on its payment plans was approved, when it is due for renewal, how it is consulted upon.
They say it is due for renewal late this year or 2022. How are leaseholders informed/consulted beforehand in this 'community led' housing association?
East End Homes' language says they offer a "tailor made" payment plan for resident leaseholders through their Extended payment plan which means they simply outsource the problem to another organisation, the Bow Welfare office. Referral is discretionary and dependent on EEH and no family can plan their future securely based on such language. Thus we ask, Why not a transparent policy like other RSLs in the same Tower Hamlets ward.
Residents call the Bow office 'a debt management office' for which they must submit all their personal financial details which takes away the planning that a household could do with a sensible payment plan like other social landlords. ie. a person who has no debt problem now has a debt problem because of how East End Homes is charging their residents.
We have Whatsapp messages from residents who have used that service - a form of bondage and extortion using a household's home. Going on a financial hardship list, with loss of their credit rating etc. This situation is created by EEH's 'tailor made' payment policy. What it fails to state is that it is EEH's short payment terms that forces many leaseholders in debt which then requires the use of the Bromley by Bow Centre. But in reality the Bow Centre can not help if a resident can not pay; so some residents facing court action from EEH have to try and get help from organisations like Shelter.
Also we note, East End Homes have taken out voluntary charging options for the unemployed (ie taking a charge against the property even they are now freeholders of ex-council land and property) unlike many other RSLs (registered social landlords). This has huge consequences for residents especially in this pandemic time in this borough who have lost work.
To illustrate situations created by the RSL with little thought on resident welfare, in 2020 at the midst of the Covid lockdowns, EEH brought forward by one year lift works for one block, Hatton House. This has massive implications on EEH leaseholders; neither do EEH give figures on the impacts on leaseholders nor how many they are taking to court because of their payment policy.
Eg if they can not pay £800/month towards overlapping Section 290 charges.
We have asked East End Homes about access to measure the effects of its charging policy, particularly on communities whose 'right to buy' home is the sole asset within extended families.
RSLs are constituted to act in the best interests of their residents. Their payment terms should reflect the average incomes in their constituency. Again good practice guidance is needed on this in the White Paper. Otherwise within the same ward, even the same street, leaseholder residents have a fundamentally different experience and sense of security.
To highlight poor practice, we return to the timing of lift works during Covid which aside from capacity of leaseholders to pay, has effect on the entire community.
The affected residential blocks usually have 2 lifts in operation- odd and even floors. Now they have only one for a period of over 14 months. This makes social distancing impossible through covid but residents must use their lifts to access their homes in a tower block. We ask, who is measuring the effects of this over 14 months? Is it not then surprising that certain ethnicities in Tower Hamlets who live on estates like St Georges are amongst the worst affected by Covid.
Additionally, residents have reported 4 occasions to their councillors over a 6 month period when no lift was in operation at Stockholm House, a 17 story block for period of 2 hours.
We draw attention to the necessity of meaningful consultation of Section 20 Major works that involves the community of residents; and the need for some independent powers to determine whether or not certain Major works can go ahead.
The lift works have overlapped with works on installing new firedoors and other safety measures following Grenfell. The consultations on value for money has been very weak but regarding outcomes, we provide another example. Any visit to St Georges estate will show the new yellow edging to the stairways through these major works now to be black - within 6 months given poor cleaning. If hi-vis yellow is meant to be a safety feature, it has no purpose now because of the standards of cleaning at East End Homes.
Challenging all this diminishes and saps the energy of residents if they try to complain through the internal complaints systems of RSLs.
We also ask if Major works serve any benefit to the residents if maintenance thereafter is poor.
Evidence submission 3
Samples responses to some of the questions laid out in the Call for evidence, Regulation of Social Housing.
How widespread and serious are the concerns about the quality of social
Answer: Requests for comparative performance data and activity to establish best practice norms are not fulfilled; simply put it would be good for there to be mechanisms for interested residents and/ or residents associations to meet one another towards establishing good practice.
As stated here elsewhere currently information is provided via the landlord without any broader reference.
Note: Towards this we recommend that White paper expressly allocates funding towards new resident-led bodies. Having regulatory body or enhanced powers for Ombudsman are not sufficient.
Is the current regime for regulating social housing fit for purpose?
As a resident of Eastend Homes you are entirely isolated within a particular institutional structure; housing information is from a single organisation; alternative information is not readily available; there is no meaningful mechanism for input into significant organisational matters; complaints are made via the landlord’s own process; the system does not seem to easily facilitate a landlord entertaining a complaint against them.
How clearly defined are the roles of the Regulator of Social Housing and the Housing Ombudsman?
The roles are generally unknown to residents
Does the current regime allow tenants to effectively resolve issues?
Not at all; the system is fundamentally flawed; the power imbalance between landlord and resident is total; consultation on estate wide issues is flawed if present at all; on an Eastend Homes estate a community
centre provision was to be maintained as a condition of a planning consent; 10 years later it is still not provided; the planning consent make reference to financial obligations; is this normal?
Do the regulator and ombudsman have sufficient powers to take action
Should all providers of social housing, not just councils, be required to register with the regulator?
In particular the disparity in access to information for residents between what is classified as 'Local authority' housing and what is classified as a 'Housing association' should be done away with.
The levelling applies to all providers of social housing. Housing associations have taken advantage on this so it is difficult for residents to access information they are not obliged to disclose.