The Social Housing White Paper announced a review of the Decent Homes Standard.  The Northern Housing Consortium is pleased to have been invited by the Ministry of Housing, Communities and Local Government to be a core participant in the Review sounding board. 

The first phase of the review is considering the case for criteria within the Decent Homes Standard, and what might be included in a new standard. The second phase will consider refining decency in more detail.

In order that we can be sure we’re representing our members’ views effectively within the review, we’d be grateful if you could complete this short survey. Not all the questions are mandatory.

 
The current statutory minimum

The first part of the current decent homes standard concerns statutory minimums:

Criterion a: It meets the current statutory minimum standard for housing

With the implementation of Part 1 of the Housing Act 2004 on 6 April 2006, the Housing Health and Safety Rating System (HHSRS) replaced the Housing Fitness Standard as the first criterion of the Decent Homes standard. HHSRS is a risk assessment procedure and does not set a standard.

To be decent, a dwelling should be free of category 1 hazards, and the existence of such hazards should be a trigger for remedial action unless practical steps cannot be taken without disproportionate expense or disruption. Landlords should consider the circumstances very carefully in the interests of the occupiers of the dwelling before concluding that a hazard cannot be dealt with effectively, and in such cases should ensure that the occupiers are fully aware of the position.

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* 1. Do you believe this criterion reflects present day expectations and concerns?

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* 2. Are there any unintended and undesirable consequences precipitated by the criterion?

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* 3. Has this criterion been practical and deliverable on the ground?

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* 4. In the new Decent Homes Standard, do you believe this criterion should be:

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* 5. The HHSRS is a risk assessment procedure, and does not set a standard. Please comment on any challenges this presents.

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* 6. Since the introduction of the Decent Homes Standard, the Homes fit for Human Habitation Act has become law. This Act legislates that homes must be ‘safe, healthy and free from things that could cause serious harm.’ We are interested in any views on the interaction between recent legislation, the HHSRS and the Decent Homes Standard.

Reasonable state of repair

The second part of the current decent homes standard concerns dwellings’ state of repair:

Criterion b: It is in a reasonable state of repair

A dwelling satisfies this criterion unless:
  • one or more key building components* are old and, because of their condition need replacing or major repair; or
  • two or more other building components** are old and, because of their condition need replacing or major repair.
A building component can only fail to satisfy this criterion by being old and requiring replacing or repair. A component cannot fail this criterion based on age alone.

*Key building components are those which, if in a poor condition, could have an immediate impact on the integrity of the building and cause further deterioration in other component
** Building components are the structural parts of a dwelling (e.g. wall structure, roof structure), other external elements (e.g. roof covering, chimneys) and internal services and amenities (e.g. kitchens, heating systems).
 A full list of building components is given in Annex A of the current Decent Homes guidance.

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* 7. Do you believe this criterion reflects present day expectations and concerns?

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* 8. Are there any unintended and undesirable consequences precipitated by the criterion?

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* 9. Has this criterion been practical and deliverable on the ground?

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* 10. In the new Decent Homes Standard do you believe the 'Reasonable state of repair’ criterion should be:

Modern facilities and services

The third part of the current decent homes standard concerns facilities and services:

Criterion c: It has reasonably modern facilities and services

A dwelling is considered not to meet this criterion if it lacks three or more of the following facilities:
  • a kitchen which is 20 years old or less;
  • a kitchen with adequate space and layout;
  • a bathroom which is 30 years old or less;
  • an appropriately located bathroom and WC;
  • adequate external noise insulation; and
  • adequate size and layout of common entrance areas for blocks of flats.

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* 11. Do you believe this criterion reflects present day expectations and concerns?

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* 12. Are the ages suggested for kitchens (20 years old or less) and bathrooms (30 years old or less) still appropriate?

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* 13. Are there any unintended and undesirable consequences precipitated by the criterion?

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* 14. Has this criterion been practical and deliverable on the ground?

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* 15. The current guidance makes clear that ‘A dwelling would not fail this criterion, where it is impossible to make the required improvements to components for physical or planning reasons’

Please comment on the current use of this exemption

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* 16. Current guidance makes clear that ‘Local authorities must consider how Decent Homes feeds into wider regeneration strategies…  it may not be necessary to make homes decent when demolition and new build may be more appropriate’

Given the changes to housing markets and availability of funding for renewal since the original guidance was developed in the mid-2000s, we are interested in member views on how the decent homes standard now interacts with regeneration.

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* 17. In the new Decent Homes Standard do you believe the ‘Modern facilities and services’ criterion should be:

Reasonable degree of thermal comfort

The fourth part of the current decent homes standard concerns homes being capable of a reasonable degree of thermal comfort. The Social Housing White Paper notes that the review must consider how the Decent Homes Standard ‘can better support the decarbonisation and energy efficiency of social homes’.  The current criterion (below) is  in need of significant updating to reflect net zero requirements and we are particularly interested in member views on this section:

The revised definition requires a dwelling to have both efficient heating; and effective insulation.

Efficient heating is defined as any gas or oil programmable central heating; or
  • electric storage heaters; or
  • warm air systems; or
  • underfloor systems; or
  • programmable LPG/solid fuel central heating; or
  • similarly efficient heating systems which are developed in the future.
The primary heating system must have a distribution system sufficient to provide heat to two or more rooms of the home. There may be storage heaters in two or more rooms, or other heaters that use the same fuel in two or more rooms. Even if the central heating system covers most of the house making a dwelling decent, under the HHSRS a landlord must be sure that the home is warm enough for the occupant.

Heating sources which provide less energy efficient options fail the Decent Homes standard. Programmable heating is where the timing and the temperature of the heating can be controlled by the occupants. However this is not a requirement in supported housing or housing for older persons where it is necessary for health and safety reasons for landlords to ensure adequate levels of heating are maintained.

Because of the differences in efficiency between gas/oil heating systems and the other heating systems listed, the level of insulation that is appropriate also differs:
  • For dwellings with gas/oil programmable heating, cavity wall insulation (if there are cavity walls that can be insulated effectively) or at least 50mm loft insulation (if there is loft space) is an effective package of insulation; and
  • For dwellings heated by electric storage heaters/LPG/programmable solid fuel central heating a higher specification of insulation is required: at least 200mm of loft insulation (if there is a loft) and cavity wall insulation (if there are cavity walls that can be insulated effectively).
A SAP rating of less than 35 (using the 2001 SAP methodology) has been established as a proxy for the likely presence of a Category 1 hazard from excess cold. From April 2007, local authorities will report energy efficiency using the new 2005 methodology.

Loft insulation thickness of 50mm is a minimum designed to trigger action on the worst housing. Where insulation is being fitted, landlords should take the opportunity to improve the energy efficiency and install insulation to a much greater depth.

The Government is considering the most effective means of improving the energy efficiency of ‘hard to treat’ homes where the construction may preclude the installation of traditional cost-effective insulation measures. This is being considered in the wider context of progress against the UK Fuel Poverty Strategy. More information on dealing with hard to treat properties and best practice guidance is available from the Energy Savings Trust website

Where new heating systems are being installed or existing system replaced, landlords should take the opportunity to increase the energy efficiency of the dwelling if possible. This would be achieved through installing energy efficient boilers where possible. Energy efficient boilers are those with a SEDBUK A-C rating. Where this is not possible

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* 18. Do you believe this criterion reflects present day expectations and concerns?

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* 19. What elements should comprise a modern criteria?

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* 20. Should the Standard still set out acceptable heat sources and minimum levels of insulation, or is an outcome-based measure more appropriate? If so, what might this look like?

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* 21. Are there any unintended and undesirable consequences precipitated by the criterion?

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* 22. Has this criterion has been practical and deliverable on the ground?

Other areas

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* 23. The Social Housing White Paper refers to the role the decent homes standard might play in the improvement of communal areas and green spaces. Do you have any comments on how this might be taken forward?

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* 24. The Social Housing White Paper refers to the role the decent homes standard might play in resident safety. Do you have any comments on how this might be taken forward?

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* 25. The Social Housing White Paper refers to the role the decent homes standard might play in tackling anti-social behaviour. Do you have any comments on how this might be taken forward?

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* 26. Do you have any other comments related to the Review which you’d like to share with us?

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* 27. Please indicate whether you work in a

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* 28. And which region of the North you are based in

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* 29. If you would like the NHC to keep you updated on the progress of the Decent Homes Review, please provide your email address:

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