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A review of the Decent Homes Standard is currently taking place. The Standard is a minimum level below which ‘social housing’ is not supposed to fall. It was introduced in 2002 because of a huge backlog of maintenance on council homes. Government had starved council housing of funding for many years. A Major Repairs Allowance introduced for councils enabled them to implement the DHS. A significant, if belated, improvement in living conditions was made, providing central heating, double glazing and UPVC doors. Having said that, the standard was set “too low” according to a Parliamentary committee. A sort of DHS stage 2 to improve it was expected, but nothing has been done since 2006.
The review was announced in the Social Housing White Paper last November. The government has set up a Review Sounding Board to lead discussion which comprises ‘experts’ from the sector. The minutes of the first Board meeting have been published. Speaking on the terms of reference for the review, a Ministry of Housing official said that “We will examine if there is a case for change and what is the reasoning and evidence to back that claim.” The Board would examine the ‘management case’ for change.
“The aim is for the Board to examine each criterion at each meeting and offer evidence on whether it should be:
a) retained unchanged and why
b) amended in some way and how
c) removed altogether and/or if it should be replaced.”
In the discussion there were a few searching questions. A representative of TAROE (Tenants and Residents Organisations of England) asked
“Why the scope of the Review was restricted given it has been nearly 20 years since last reviewed. Why isn’t work on decarbonisation and impact of CV19, particularly space standards, not in scope?”
There is no reply in the minutes to this rather awkward question.
A representative of ARCH (Association of Retained Council Housing) raised the issue of cost to social housing providers of improvements in the DHS and how they will be funded. He said that costs will need to be considered throughout the Review. The Ministry official “noted it was too early yet but the Review would need to be mindful of costs and that additional expectations on DHS may not be followed by funding and sector may need to fund.”
A question was asked about transparency, to which the reply was that there is a wider group of around sixty non-participants who see the Board papers and will be also asked to contribute their views and comments.1
A question was asked about whether the scope should include the Private Rented Sector. The official explained that in the past the DHS was extended to PRS with vulnerable tenants.
“We will review the scope as we move into Part 2 of the review. We will also be working closely with policy officials who are working on a minimum standard for the PRS as part of the review of the Housing Health and Safety Rating System.”
The current Standards say that for a home to be considered ‘decent’ it should be free of Category 1 hazards as defined by the Housing Health and Safety Rating System, which are a risk to health. The official said there were three questions for the Board to consider in relation to the statutory minimum standards:
Question 1: In your view, how consistently does this criterion fit with other expectations across Government? For example, does the criterion go far enough in tackling priorities such as safety, crime, climate change and health?
Question 2: Looking back at the period 2006 to date, how practicable has it been to
a) identify and
b) remedy individual hazards in housing stock?
For example, how possible has it been to survey and hazards across all your stock?
Question 3: If the criterion needs amending, do you have proposals for options for change? What are they?
The next meeting of the Board will be on April 13th and will consider the DHS criterion “reasonable state of repair”.
It would appear that the review has the option to do nothing, propose changes or ditch it altogether and propose an alternative. We can’t have “change for changes sake” can we?Whilst there are many technical issues associated with the Standard the key issues appear to me to be:
1) The Standard, as two Parliamentary committees said, was set “too low”. A DHS stage 2 was expected 15 years ago. It needs improving. For instance some of the expected lifetimes of the housing components (bathrooms, kitchens, roofs, central heating systems) are too long. But to renew them more often would require extra funding. T
2) If you propose to improve the standard then you have to assess the cost of bringing them up to the new standard. So far as council housing is concerned the DHS cannot be improved without an assessment of the current state of finances of council Housing Revenue Accounts. They are currently under-funded. They have insufficient funds to maintain the current DHS never mind an improved one. The Ministry official, however, warned that there might not be any money on offer.
3) Given the fact that any new homes built from 2025 will have to have a non-carbon heating system councils are currently trialling on a small scale either building homes such as Passivhaus and/or retrofitting existing homes. It is impossible for the government to stick to its commitments on de-carbonisation without retro-fitting. For this to be done for existing council housing stock there will have to be central government funding or it will simply not happen. Assuming an average of £20,000 per property2 that means that retro-fitting the 1.6 million council housing stock in England would cost £32 billion. To amend the standard without including retro-fitting would be an indication that the government is not serious about its environmental commitments in relation to global warming. To amend it and not provide the finance for councils to implement would equally show a lack of seriousness.
The White Paper said that the government would review the DHS to consider, amongst other things, “how it can better support the decarbonisation and energy efficiency of homes”. It can’t do that by leaving the standard unchanged and it can’t support decarbonisation without funding it.
4) To resolve the current under-funding of HRAs, cancellation of the bogus debt3 which they have been saddled with, is necessary if they are to have the funding for an improved DHS. This would provide an extra £1.25 billion a year.
5) Whilst the DHS nominally applies to the PRS, in reality, given the scale of growth of the sector which was promoted by various governments, local authorities have miniscule resources for policing the sector. So Environmental Health Officers tend to concentrate on Houses in Multiple Occupation. For other properties they rely on being given a tip-off by tenants. Clearly any improved DHS would have little impact on the PRS unless councils were able to significantly increase the numbers of these staff.
PS. We will be producing a more detailed briefing on the DHS.
See the 2006 document A Decent Home: Definition and guidance for implementation June 2006 – Update
The minimum standard requires that:
- The property must be free of Category 1 hazards under the Housing Health and Safety Rating System.
- It must be in a reasonable state of repair.
- It must have reasonably modern facilities and services
- It must provide a reasonable degree of thermal comfort
In 2017, 6% (234,000) of social homes had at least one Category 1 hazard. Within the social rented sector, housing association homes (4%) were less likely to have Category 1 hazards than homes owned by local authorities (8%). The most serious risks of harm from living in an excessively cold home or from falls were also less prevalent among social homes.
The most common hazard in the social rented sector in 2018 was falls on stairs, damp and mould hazards. In the social sector, fire hazards were less likely to be present . There was one notable change in the relative prevalence of hazards between 2008 and 2018 in social rented homes. In 2008, damp hazards were equally as common as falls on the level and falls between the level hazards. In 2018, however, damp hazards were more likely to occur than falls on the level and falls between the level.
For information o the HHSRS see Housing Health and Safety Rating System: outcomes of the scoping review – GOV.UK (www.gov.uk)
1I am one of this sadly small number of people, hence I have been sent the minutes.
2From a cursory investigation most councils seem to be talking of £20,000 or there abouts. Installing heat pumps is not much use unless insulation eradicates heat loss.