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Empowering Tenants to Drive Real Change in the Private Rental Sector

The State Of It

The number of households renting from private landlords has doubled since the year 2000 to 4.6m but quality of housing and protection for private tenants has not kept pace.

According to Environmental Consultant Dr Stephen Battersby, there are 4 times more damp homes in the private rented sector (PRS) than in the social rented sector.

Four years after the Tories promised to reform the private rented sector tenants are as vulnerable as ever to bad landlords. ‘No fault’ evictions, known as Section 21 evictions, are in fact soaring – up 76% on last year according to the BBC. While figures are skewed by the ban on evictions during the pandemic, in the first quarter of 2022, claims and orders in private landlords’ possession cases had returned to a similar level to 2019.

This is a miserable situation for private renters in this country – paying steep sums for terrible conditions and insecurity, while the government drags its feet over promised reforms.

When the Renters Reform Bill was finally announced last year in the Queen’s Speech, long-awaited by organisations like Marks Out Of Tenancy and our colleagues at the Renters Reform Coalition, one thing that was notably lacking was details of any extra money or enforcement powers or bodies which will be put in place to back up the new rules.

Herald A Substantial Shift

In the absence of any new enforcement from government, Marks Out Of Tenancy allows renters to take matters into their own hands by providing written feedback and a score for the landlord, property and area. This gives tenants a much needed mechanism to call out sub-standard properties and problem landlords, providing desperately needed transparency and accountability in the PRS. 

“A longstanding characteristic of the sector is poor information and communication,” writes Professor Alex Marsh of the UK Collaborative Centre for Housing Evidence.  

He continues: “Small-scale landlordism coupled with transient tenants compounded, in many areas, by high demand means that there is a market for poor quality and the market does not discipline poor quality providers. The arrival of websites like Marks Out Of Tenancy may eventually herald a substantial shift in this dynamic: they allow the market to develop a form of memory.”

Meanwhile current enforcement falls short. Convictions of rogue landlords under the Prevention of Eviction Act 1977 remain startlingly low; a May 2022 report by Safer Housing shows that of a total of 6,930 reported offences under the act in 2020 only 23 had proceedings brought against them and only 12 resulted in a conviction. 

The PRS has been left to self-regulate for too long and it simply has not worked. Landlord associations and voluntary landlord registration schemes on their own can’t regulate landlords, and overstretched local authorities can’t do any more to challenge bad landlords than they already are doing – but there is space for a regulatory force outside the market and the state.

Introducing ‘Decentred Regulation’

The UK Collaborative Centre for Housing Evidence makes the case for ‘decentred’ regulation in response to the current crisis in the PRS in a 2020 report entitled Improving Compliance with Private Rented Sector Legislation (page 34). 

The report explains: “Much regulatory thinking starts from the state – in the case of the PRS: local authorities, licensing agencies, trading standards and the police – as the core of the regulatory regime. Decentring regulation is an invitation to look more widely at the organisational landscape of a policy sector to understand what else is going on and which other organisations and social actors are acting in a regulatory capacity. Approaching regulation as “decentred” frequently signals a concern with processes of self-regulation.”

This is precisely what Marks Out Of Tenancy exists to do. As the report states, Marks Out Of Tenancy is a platform that seeks to regulate quality in the PRS via tenant feedback and rating completely independently of the state.

In the context of decentred regulation, Ben Yarrow, CEO of Marks Out Of Tenancy says:

“Imagine a scenario where a local authority had imposed restrictions on properties that can be used as Airbnb rentals – and the Airbnb platform reported back to a local authority when a property was being let without a licence. Or imagine a scenario where Checkatrade or Trustatrader reported non-compliant plumbers who were operating without Gas Safe certification. These scenarios are unlikely to occur – these companies would be hurting their own business by reporting their own customers, however Marks Out Of Tenancy differs significantly in that we have no vested financial interest in the rental transaction.”

Marks Out Of Tenancy needs help threading review data with enforcement; while a well-publicised bad landlord may struggle to find a new tenant, all the bad reviews in the world will not force them to make the necessary repairs if they are not minded to. This is where it becomes essential to work closely with existing regulatory and enforcement bodies at the Local Authority level. 

For our local authority partners, we provide legally compliant, timely and accurate data from tenant reviews.

On a basic level it enables licensing and enforcement teams to find out:

  • Which properties are being rented
  • Who was acting as the landlord
  • How many people were living in the property
  • If the property needed a licence
  • If it was licensed at the time it was being rented
  • If the property complied with Minimum Level of Energy Efficiency (MEES) standards

Through the Marks Out Of Tenancy portal, housing officers are also able to open communications with the tenant who left the review.

Using pre-written templates, officers are also able to send letters through the Marks Out Of Tenancy portal, addressed to landlords of flagged properties inviting them to comply with licensing requirements, MEES legislation or even a friendly chat.

The platform continues to grow in scope and ambition, having recently secured a significant grant to fund our work for the next three years. This funding will enable tenants in the London boroughs of Southwark and Lambeth to make better-informed decisions about where they choose to rent. The platform reach will also be expanding nationally at the same time.

The Ask

A single review of a landlord and rental property can make a huge difference to the decision making process of an individual renter – but we’ve built the technology and infrastructure to impact and drive change across the whole industry. If every tenant used the platform they could force a substantial shift in the way landlords treated them.

We want Marks Out Of Tenancy to help bring about a shift in the fundamental relationship between tenants and landlords. But it requires stakeholders like Local Authorities and existing regulatory bodies to allow us in – this platform can be a valuable resource when combined with agencies with enforcement powers against bad landlords.

Marks Out Of Tenancy invites housing professionals at Local Authority level to begin looking outside of the purely enforcement and regulatory systems currently at play, recognise that trade associations or professional landlord bodies do not aid with actively rooting out the poorest quality providers, but rather, that tenants on the frontline can provide an invaluable insight into the service provided by landlords and the products they’re obligated to maintain.

Ben Yarrow is CEO of Marks Out Of Tenancy, a PropTech firm focused on improving housing conditions.

 

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Review: Show me the Bodies – How we let Grenfell happen by Peter Apps

This is an excellent and harrowing account of the events of the night of 14 June 2017 and the relevant policy framework by a leading housing journalist. 72 residents lost their lives in the fire that engulfed Grenfell Tower. We know from Part 1 of the now-published Grenfell Tower Inquiry that this tragic event should never have happened. Part 2 of the inquiry is in the process of being written. Once the final report is published, the police will announce what criminal charges if any will be brought. 

In successive chapters the author takes the reader through what happened on the night of the fire and the historical reasons for the fire. Below are summarised the key staggering conclusions that the author reaches. 

Peter correctly identifies the failure to properly respond to the fire at Lakanal House in South East London with fatal consequences. The inquest exposed major fire safety failures. The coroner wrote to the Government to ask for a review of the official fire safety guidance. She wanted the government to encourage greater use of the fire sprinkler system. The Coalition Government was too concerned with deregulation to take effective action: had they done so this tragedy would not have happened.

The Building Research Establishment were not asked by Government to carry out tests on the paneling at Lakanal House. However, the Metropolitan Police and the Fire Brigade approached the BRE to do so in December 2009.  The result of these tests was that the panels used on the walls burnt fiercely and did not meet the relevant safety standard.

Fire Brigade Commanders struggled with managing the fire on 14 June. Communication systems failed which had been at fault in 2009. A paper system was relied upon to communicate between incident commanders and firefighters. The Brigade had no effective plan to deal with a major fire at this 24-storey block.

There was an over-rigid reliance on the “staying put “policy whereby residents were told to remain in their flats until fire fighters could rescue them. The fire and the smoke were too intense and toxic to allow firefighters to get to all floors in this 24-storey tower block. Nor was there an effective Plan B if the staying put policy failed. 

Part 1 of the inquiry has recommended the introduction of Personal Emergency Evacuation Plans. 37 of the Tower block residents when the fire broke out were disabled: they could not be evacuated unaided. Fifteen of them died in the fire. Despite Ministers saying that they would implement all Inquiry recommendations, the Government will shortly have to defend its refusal to make such plans mandatory in the High Court. 

There were numerous failures by the landlord, Kensington and Chelsea Management Organisation. Warnings from residents were ignored as were various fire safety notices served on the Tenant Management Company by the London Fire Brigade There were major problems with the self-closing mechanisms for the fire safety doors that an independent fire safety consultant failed to spot.

The tower block was fitted with Aluminum Composite Material (ACM) cladding. ACM is effectively two thin sheets of aluminum held together by a plastic core. The plastic bonding the metals together is polyethylene. This is made from petroleum. It is highly flammable. The manufacturers knew from tests carried out in 2004 that this was the case. They concealed these results from their customers and lobbied Government for less regulation.

There was one civil servant, Brian Martin, who was responsible for fire safety policy in residential buildings. He knew all about the dangers of ACM cladding. He had the difficult job of trying to advise Ministers who were committed to deregulation and austerity cuts. Prime Minister David Cameron pledged in a speech in January 2012 to ‘wage war against the excessive health and safety culture that has become an albatross around the neck of British business’.

At the inquiry on 30 March 2022, Brain Martin is quoted as saying there were ‘a number of occasions where I could have potentially prevented this [ the fire] from happening.’ ‘What I will say is that the approach the government-successive governments had to regulation had had an impact on the way we worked, the resources we had available, the mindset that we’d adopted as a team, and myself in particular. I think, as a result of that, I ended up being the single point of failure in the department… For that I’m bitterly sorry.’

But for covid, fire safety would have been the major political issue of the day. The Government has partly improved the fire safety regime via the 2022 Building Safety Act. Remarkably the United Kingdom still appears to be only one of two countries in the world that still allows planning permission to be granted for blocks with only one stairwell. 

All Labour activists should read this book. It shows up the failure of Government policy to have effective fire safety policies due to an ideological commitment to deregulation. It will make you angry.

Dermot Mckibbin is a member of the National Leasehold Campaign, a supporter of the Leasehold Knowledge Partnership, and writes a blog on www.getcommonholddone.co.uk. He is also a member of LHG Executive Committee.  

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Labour must embrace innovation to achieve its housing ambitions

At its conference the Labour Party made bold pledges on housing. Not only will it support a council housing renaissance, but Keir Starmer committed to supporting 1.5m more people onto the housing ladder, boosting home ownership to 70% of households across the country.

In a sector that has been hampered by a revolving door of ministers – we are already on our fourth this year – and initiatives that never quite match up with their promise such as the Starter Homes that never materialised, how can the party ensure that it can truly deliver on its housing ambitions?

The policy pledges will have to be fulfilled against the backdrop of an existing supply deficit of homes of all tenures and funding constraints which will reduce the social housing sector’s ability to build. In September the National Audit Office reported that there is a forecast shortfall of 32,000 in the number of homes to be delivered under the 2016 and 2021 Affordable Homes Programmes (AHP) administered by Homes England, with a further risk that fewer homes are completed because of building cost inflation and other challenges. When asked by Lisa Nandy whether the Autumn Statement would have an impact on the AHP’s budget, the Housing Minister, Lucy Frazer, simply said that the Government remained committed to the Programme. In the context of departments across the board being required to make spending cuts, this will be worth keeping an eye on. 

Whilst the sector has welcomed the Government’s announcement of a social housing rent cap of 7%, higher than the 5% initially proposed, its own modelling nevertheless suggested that this would result in a loss of £4.9bn in rental income for registered providers over 5 years. This is income that would otherwise be invested in delivering new homes as well as in services for residents. The funding black hole adds to previous research outlining the scale of the gap between the need for and delivery of affordable housing. 

To meet housing need in England between 2021 and 2031, Crisis and NHF research found that 145,000 affordable homes must be built each year. Government figures for 2021-22 show that only 59,000 such homes were provided. Of these, just 7,500 (13%) were new homes for social rent. Whilst the total new affordable homes figure is the highest since 2014-15, it is still 86,000 short of what is required. The scale of the challenge is clear. 

The only way to deliver the amount of new affordable homes needed is with a significant injection of private sector investment in addition to government grants and loans. At a time of constrained public finances, more should be done to proactively encourage private funding into decent quality, secure and affordable housing.

As an affordable home ownership provider funded by institutional investment including major pension funds, we know that there is appetite in the market from investors and the potential for a significant funding injection into the sector. It is viewed as an attractive low-risk, long-term investment.

As well as bringing more funding to the sector overall, using private investment to deliver affordable home ownership products would enable local authorities to direct their grant funding to deliver more social housing, helping to meet Labour’s vision for “council housing, council housing, council housing”. It is a win-win. 

Homes England figures have spoken about it being a priority to increase the diversity of capital within the affordable housing sector. Addressing Inside Housing’s development summit last year, its chair, Peter Freeman, said that “Matching public need and private enterprise around a set of principles that can deliver both public and commercial value represents a huge opportunity to positively increase affordable housing delivery in this country.”

In our experience, this position needs to be better communicated to local government to provide them with the certainty that it is ok to accept affordable housing funded through institutional investment rather than government grant. Whilst a number of local authority areas have adopted innovative models and are thinking outside the box when it comes to delivering affordable housing, we have found that often councils choose to seek external legal advice before proceeding, to check that they can do this. As well as prolonging the delivery of new homes, this is costly, at a time when local government finances are constrained. The uncertainty comes from doing something that is not the norm. 

There are billions of pounds waiting to be unlocked if the government did more to encourage local authorities to consider institutional investment. To drive real change, there needs to be clear, written guidance that encourages local authorities to welcome such investment in their affordable housing provision. This would provide the confidence needed by councils that there is national level support to do so. 

The mini-budget in September jeopardised the Conservative Party’s position as the party of homeownership. First-time buyers have seen mortgage offers removed and existing homeowners are fearful of increasing mortgage costs. 

There is a real opportunity for Labour to make headway in this space. But it must be prepared to embrace innovation and institutional investment to find new ways of delivering the homes we desperately need. If the Party wholeheartedly backed this source of funding, it could drive an increase in new affordable homes across the country. Without it, its housing ambitions will be hard, if not impossible, to achieve.
Steve Collins, Chief Executive, Rentplus-UK Ltd

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The urgency of moving beyond coproduction

Coproduction, residents and staff working collaboratively to design, evaluate and deliver public services, has been in vogue for many years. However, there is a new urgency to achieve genuine coproduction that produces a tangible benefit for residents. In their report, Stigma and Social Housing in England, Denedo and Ejiogu argue that having tenants on the board of directors is a way to end stigma, and to focus the organisation on the needs of tenants. However, Kensington and Chelsea, where the Grenfell Fire happened, had tenants on the board and described themselves as a tenant managed organisation. Rochdale Boroughwide Housing Association, where Awaad Ishak tragically died from the effect of mould, describes itself as England’s first tenant and employee owned mutual. 

Those of us working in council housing know how chronically underfunded we are and how risky the current situation is. In common with most experienced housing managers, there is an element of ‘there but for the grace of God go I’ when I read the press reports. Tragedies and appalling services have happened across the social housing sector. Having tenants on the board certainly does not make the housing service riskier, but the question for Kensington and Chelsea and Rochdale is why didn’t it make it safer? Why didn’t having tenants on the board affect the culture of the organisation?

The Building Safety Act requires housing providers to meaningfully engage with our residents about building safety. Tenants need to be able to affect the priorities of the organisation and its everyday practices, but they also need good quality advice from their paid professionals. 

Genuine coproduction that produces a positive impact for residents is tough to achieve. I know, I’ve been manager of Leathermarket JMB for 25 years, which is a tenant managed organisation (TMO), with a board comprising of ten resident directors, elected by fellow residents. We manage 1,550 homes under a Right to Management Agreement with Southwark Council. This partnership with Southwark Council represents that greatest devolution of control and responsibility to council estate residents anywhere in England. The JMB is self- financing in that we keep the rents and service charges our residents pay, we then pay Southwark our proportion of the borough-wide debt and for the services that council continues to provide. We then use the rest of the pay to provide services and deliver major works.

We seek to maintain estates that include blocks that are a hundred years old, with no cavity walls to insulate, and a factory built tower block, which now seems to be part of the late 1950’s experiment to see how cheaply council housing could be built. Unfortunately, democracy does not wash away damp. It needs money to eradicate damp. As I explained in my Red Brick blog, The Secret of Council Housing Self-Financing, council housing across the country is underfunded. Paul Watt in his book Estate Regeneration and its Discontents makes a compelling case that Southwark has the most underfunded housing stock in England. As a TMO with fully devolved financial and repair responsibility we grapple with the consequences of this underfunding every day; but at least we have greater control than any other tenants’ group in England. 

Democracy does not produce the technical expertise required to solve complex cases. However, democracy does clarify priorities. When disrepair cases started to pop up on the regional news, our resident chair phoned me up to demand a list of our complex disrepair cases. As soon as the lockdown restrictions ended the Board told me to get our staff visiting tenants’ homes to find out what had happened to the well-being of our tenants and the condition of their homes during lockdown.  It is our residents who face the greatest challenges who are least likely to be persistent in demanding a response from us if there is damp in their homes.  

Another advantage that the JMB has is that we are a local organisation, rooted in our community. We are very open to our residents, which means that families who have damp in their homes are less likely to get lost in the bureaucracy. Also, even when we have had overspends I’ve never been asked to limit expenditure on damp eradication. Our resident board members would not stand for this. 

As highlighted by the Ombudsman, damp is not a life-style issue; however, if the cause is not penetrating/ rising damp or overcrowding, sometimes the family can work with us to manage the consequence, to argue otherwise takes away agency from residents. A family can’t reduce the size of its household or pay for heating it can’t afford, but it can run a mechanical ventilator or open a window for half an hour after bathing and wipe away minor signs of damp.  I wrote a damp policy that included a contract, which sets out what works we will do and the realistic action that families can take to help. When I distributed it to our directors I got told to re-write it, because I’d trodden too close to the life-style line. Good damp management requires intensive work and good coordination within the office, especially between the repairs, major works and housing management teams. I have the address of every home where we know damp is present written on a whiteboard in my office. We have a student on placement from London Metropolitan University to chase up action on all of our homes affected by damp. We have set up a project team, with a resident director, to ensure that our approach becomes more effective.

Given the current underfunding of council housing and the cost of living crisis faced by residents, coproduction has to move beyond ‘the added value of customer insight’. It arguably has a life and death importance.  Social Housing Regulator please take note.

For more information about Leathermarket JMB:

Home

In the Shadow of the Shard – A film by John Rogers: https://www.youtube.com/watch?v=dPrsDCU2qUc 

The Caring City-Juliet Davis. Bristol University Press. 2022

Coproduction: A paradigm shift. An MA dissertation by Andy Bates: Available London South Bank University Library 

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Labour should commit to ending Right to Buy

From discussion with senior figures we know that the Labour Party leadership is hesitant about committing to ending Right to Buy because they expect the Tories to denounce them as being “opposed to aspiration”. RTB was never about aspiration. It was a means of the Tories weaning away electoral support from Labour on council estates. It was designed to mobilise self-interest; what used to be called getting-on or keeping up with the Joneses.

It is not difficult to challenge the argument on “aspiration”. Whilst RTB is a gift to the person buying (they are getting the property on the cheap) it has dire social consequences for others because it means one less home for the growing numbers on the waiting list. It also means a loss of rental stream to councils, leaving them with less income to pay for work on their depleted housing stock. 

There is nothing superior about a homeowner over a renter. Not wanting to own a home is not an expression of lack of aspiration. Being unable to afford one is not a sign of ‘failure’. The experience of the pandemic led millions of people to reconsider what is important in their lives. Personal acquisitions do not guarantee contentment. Owning a home is not a guarantee of ‘security’. As the current situation shows a mortgage can be an albatross around the neck. With interest rates above 6% more people will struggle, as they have to renew their fixed term mortgages.

Historically council housing can be said to have facilitated home ownership for those who wanted it. The reasonable rents enabled tenants to save up a deposit, buy a home on the market, and hand the keys back to the council for a new tenant from the waiting list.

RTB was one of the main causes of the housing crisis. As a result of its continuation in England there are now less than 1.6 million council homes left. The acute shortage of council housing, in combination with house price inflation (the ratio of prices to earnings for both median and lower quartile new build homes is more than 10 times) has forced millions of people into the insecure, expensive and often poor quality private rented sector. There are 4.8 million households in England in the PRS. 

In the last financial year more than 10,000 council homes were sold under RTB. Add around 2,000 demolished, and councils have to build at least 12,000 just to stop the loss of homes. That number has not been built since 1990. Since the discount on sales was increased, 107,000 homes have been sold and 26,000 demolished. Only 42,000 homes have been built or bought, to replace them.

Some people say that the problem is not selling homes but failing to replace them. But even if councils were able to keep all the receipts for RTB, the fact is that the cost of building new homes is far higher than selling existing homes. The difference between the receipt and the cost of replacement would come from the housing revenue account; that is, from existing tenants’ rent.

In 2019 and 2021 Labour Conference overwhelmingly passed resolutions which called for an end to RTB. At the 2021 conference Lucy Powell (then responsible for housing) said that ending RTB was the right thing to do, and it was what the members wanted. At the 2022 conference, Lisa Nandy told a fringe meeting that the policy was under review. The Labour Campaign for Council Housing has therefore produced a statement (see below) calling on Labour to commit to ending RTB. We want to get across the message to the leadership that ending RTB is a necessary precondition for tackling the housing crisis and it is what the membership wants.

What can you do to help?

  • Sign the statement yourself.
  • Get your branch and/or CLP to support it.
  • If you are a councillor get your Labour council group to support it.
  • Ask your trade union organisation to sign it.

RTB has been ended both in Scotland and Wales. It is a cost-free policy. It will mean that, for the first time since its introduction, new homes built will increase the stock numbers and open up the prospect of reducing the number of households on the waiting lists. Combined with funding for new build programmes it will liberate the rising generation from the PRS.

Martin Wicks

Secretary Labour Campaign for Council Housing 

To sign the statement (below) email [email protected] 

Statement: Labour should commit to ending Right to Buy

“We the undersigned agree with Lisa Nandy that “the idea of a home for life handed on in common ownership to future generations is an idea worth fighting for.” That requires the ending of the disastrous Right to Buy policy. In Scotland and Wales it has already been ended. 

In England there are now less than 1.6 million council homes left. Even if councils were able to keep all receipts for sales they would have to build more than 12,000 council homes a year just to replace homes sold and demolished. That many haven’t been built since 1990. 

RTB not only means the loss of homes but councils losing rental stream, leaving them with less money for the maintenance and renewal of their existing stock. 

Many homes sold under RTB end up in the private rented sector; an estimated 40%. This drives up the housing benefit bill because of the much higher private rents.

Labour conferences in 2019 and 2021 voted overwhelmingly for RTB to be ended. It was incorporated in the 2019 manifesto. At the 2021 conference Lucy Powell said that it is the right thing to do and that is what the members want.

Ending RTB will stop the loss of homes and ensure that for the first time since it was introduced all new council house building will increase the stock and enable the waiting lists to begin to fall. It is also without cost and will stop the loss of rental income to councils.

We therefore call on Labour to commit to ending RTB when in government.”

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Are the Tories really serious about fixing social housing or listening to tenants? 

The tragedy of the death of Awaab Ishak as a direct result of the poor conditions in his social rented home has rightly awakened a storm of protest about the state of rented housing in this country. It is shaming to have to admit that our rented housing is failing so many people, but particularly the public sector stock that many of us are so proud of. 

Michael Gove’s attempt on the Today programme on 24th November to lay the blame for mouldy walls and damp conditions entirely on social housing providers is unfair and just does not hold water. The Tory Government should take some responsibility for where we are now – but it won’t, of course. 

Firstly, the point should be made that the housing sector has had to deal with massive funding pressures since the Tories came into power in 2010. This started with the Spending Review of 2010 which saw investment in building new housing association homes cut by two thirds. Caps on subsidy, followed by rent caps (to save on Housing Benefit expenditure), and the end of funding for Decent Homes improvements meant that the sector stopped putting enough cash into maintenance. We also saw continual extensions of the Right To Buy reducing incomes from rents, and housing providers diverting funds into work to support tenants to cope with shrinking incomes through welfare “reforms”. The plain truth is that the failures in the stock are systemic and were predictable, and Gove’s attack on the sector is totally opportunistic and hypocritical. 

It is really shattering to hear so many tenants still saying that their landlords are not listening to them, but Gove’s claim that the current government is on the side of the tenant does not compute. He said they are bringing forward legislation “to allow us to hear the voice of tenants more clearly”, but he clearly does not remember that it was the Tory-led Coalition Government which, in short order after their election in 2010, as well as abolishing the Tenant Services Authority and the Audit Commission, thereby reducing the regulation of social landlords, also abandoned both National Tenant Voice (NTV) and the National Tenant Council, leaving tenants with no national representation at all. NTV would have had 4 distinct roles: 

  • advocacy
  • research 
  • communication
  • support

By contrast, as Marianne Hood pointed out in LHG’s recent In Conversation session, Robert Jenrick (former Secretary of State) saying he wanted tenants to feel more empowered did not mean, as Marianne comments, that tenants will be more empowered under the Tories’ plans. Indeed, the Social Housing (Regulation) Bill currently going through Parliament contains no mechanism to hear the collective voice of tenants, gives powers to the regulator but none to tenants, and provides tenants with little by way of accountability or redress, despite claims made by the Tories. Tenants – seen as consumers with a range of choices – will have no additional sanctions; only the Social Housing Regulator has these powers.  

Marianne also pointed out that genuine effective participation can lead to better design, better policies, and better use of scarce resources, and indeed to the avoidance of costly mistakes. The diminution of the tenant participation movement by the Tories from 2010 onwards – along with the end of tenants being required to be on Housing Association Boards – is part of the story of the tragic waste of life at Grenfell and elsewhere, as shown in Rochdale and sadly, likely in other places too. 

As I show below, some responsibility has to be taken by architects keen to use the latest but untested ideas of new design and new materials. We can also guess that structural problems, becoming rife in the private house-building in recent years, are likely to affect social housing too, since the problems are largely due to cost-cutting, under-supply of building inspectors, and poor regulation of the construction industry.

It is also shattering to hear that landlords are still alleging that their “lifestyle” is to blame for the damp and mould. 46 years ago, one of my first tasks as a new housing aid worker covering the North East of England was to help families living in a fairly new council estate who were lumbered with electricity bills of £200-300 a quarter, an unthinkable amount in the mid-1970s. The ceiling heating installed there was simply not suitable for the concrete “scissor” blocks, and many of the maisonettes were not only cold but had green and black walls, furniture rotting from the mould, and soaking wet carpets. As happens today, tenants were told they were not managing the heating properly, should stop drying clothes inside the rooms, and to turn up the heating and open the windows. The estate was demolished in the 1990s, with no-one in any doubt that the cheaply-built mass-produced concrete homes, and the ceiling heating, had not met the council’s original vision of the estate as a “bold pioneering showpiece development”. 

Of course the many stories about damp and mouldy homes heard since the inquest have been these problems in the private rented sector too. Michael Gove tries hard to persuade us that they are taking action to make life safer and more secure for private tenants. The abolition of S.21 no-fault evictions, first promised by the Tory Government in April 2019 is still awaited: the Renters’ Reform Bill will not go before the House of Commons until well into 2023, if we are lucky. Legislation to prevent retaliatory evictions will be included: surveys done by Shelter in 2014 led to the conclusion that around 200,000 private tenants had been evicted after asking for repairs to be carried out.

The cut in the numbers of Environmental Health Officers employed by local councils is also a huge contributor to the lack of enforcement on poor housing conditions. In 2019, Unison found that EHO budgets per head of population had more than halved – falling by 52.92% between 2009 and 2018 – and enforcement visits by EHOs had dropped by nearly a half. CIEH (the environmental health professional body) reported in 2021 that 9 out of 10 EH teams had used agency staff in 2020 because of lack of resources or recruitment problems, and 56% of councils had vacancies left empty for 6 months or more. Teams which now cover Covid-19 planning and contact tracing, food hygiene, emergency planning, trading standards, and business advice, in addition to their housing work, are widely said to be struggling to deliver some of their statutory environmental health duties. 

Finally, Gove’s statement on the radio that everyone has the right to a home fit for habitation would be great if it were true. Whilst the Homes (Fitness for Human Habitation) Act 2019 introduced by Karen Buck MP gives landlords a duty to make sure that homes are safe, healthy and free from hazards that could cause the tenant and their household serious harm, there is as yet no right to a home enshrined in UK law. LHG and the Labour Campaign for Human Rights are together doing our level best to ensure that this right is built into English law when we have a Labour Government in place. This would indeed ensure there is effective enforcement, redress for tenants, accountability of all landlords, and a voice for tenants, both individually and collectively. 

As Karen Buck herself points out, “with the Human Rights Act itself once again under attack by this Government, we must remain focused on what can be achieved and must be demanded right now, to end the misery endured by so many people trapped in unfit homes.” 

Sheila Spencer is the Secretary of the Labour Housing Group.

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Awaab Ishak’s death and the failure of democracy within social housing

Image: Family handout

The damning verdict of the Awaab Ishak inquest has thrown a spotlight on the poor housing standards faced by many tenants across Britain. In Rochdale, where I am a Councillor, this tragedy has obviously hit home.  

Widespread media coverage means that most people have read about this awful case and seen the photos of the house where two-year old Awaab died, as a result of mould which the landlord – social housing provider Rochdale Boroughwide Housing (RBH) – failed to deal with. I can’t stop thinking of Awaab and his family.

National and local news outlets have rightly, in my opinion, reflected public sentiment: the buck for RBH’s failures stops with the housing association’s senior bosses including Chief Executive, Gareth Swarbrick. Michael Gove demanded a meeting with him earlier this week, but so far, no one from RBH has stepped down. 

Arguably, this is an exercise in blame avoidance – the Housing Secretary is keen to ensure the Government doesn’t take the rap for this, despite the fact that it’s part of a national problem. Many people living in social housing across the UK are suffering due to inadequate maintenance after over a decade of Tory cuts in the sector. The new cap on social housing rent increases, announced by the Chancellor the Autumn Statement, will make things even worse.  

Mr Gove stepping in ‘from the top down’ is also at odds with what would be happening here, if the social housing provider was adhering to its own mission statement.  

RBH is an independent, separate entity to Rochdale Council. It was previously an arm’s-length management organisation (ALMO) but became fully responsible for the borough’s council housing stock – over 12,000 homes – a decade ago, in 2012. RBH chose to call itself a ‘mutual’ rather than a housing association, and frequently emphasises its claim to be ‘the UK’s first tenant and employee co-owned mutual housing society’ with organisational values such as ‘responsibility’, ‘equity’ and ‘democracy’.

In relation to ‘democracy’ RBH says, on its website: ‘We are democratic. Our democracy is rooted in our mutual status and evidenced in our governance through our Representative Body and Board. Our tenants, employees and communities have a voice and power over what we do, and how we operate.’

This is simply not the case.

RBH does have a ‘Representative Body’ from which the only elected representatives of the community  – two Labour councillors, one of whom is the Council’s portfolio holder for housing – were removed by RBH officials at the start of this year. They publicly disagreed with the housing association’s plan to demolish council flats in Rochdale town centre. RBH is not allowing the Council to put the representatives it has nominated on this panel.    

Labour councillors have also questioned RBH’s credentials as a ‘mutual’. Under a proper mutual system, the tenants and communities RBH purports to empower would have democratic control, and surplus would be re-invested in the housing stock. In Rochdale, RBH executives have been enjoying repeated, substantial pay rises.

Following the coroner’s verdict on RBH this week, Rochdale Council’s housing portfolio holder has intervened by writing to them. It is a strongly worded letter and I agree with its content, but I’m sorry to say: it’s only a letter. This is the opposite of ‘communities having a voice and power’.

One reason this sad case stands out is that a mouldy home making people ill is something one might expect to see from an irresponsible landlord, hellbent on making a profit at any human cost, in the private rented sector. Awaab Ishak didn’t die in private rented housing, though.

Social housing providers need to make a surplus: enough money to invest in, and improve, their stock. Unlike in the private sector, social landlords’ main concern is not profit making – arguably they should not be doling out continued, significant pay rises and quashing scrutiny from elected representatives.

All bodies whose work significantly impacts the community, like RBH does, should have some form of democratic representation on their boards from a local authority. Social housing providers should also refrain from placing directors of other housing associations on their boards as this does not result in adequate scrutiny when it comes to decisions about executives’ pay. 

Political oversight (or at least involvement) should come from the most local level possible. This is a vital element of ensuring that social housing providers listen and respond to people’s needs, at a time when – as this case tragically illustrates – standards appear to be declining. 

Without input from community representatives with confidence and ‘know how’ about how boards and local democracy work, social housing providers like RBH will continue to fail to acknowledge and understand public opinion. Most importantly executive directors should feel that, when they are making decisions about the lives of so many people, ‘the public’ are sitting in the room.

We are in the middle of interrelated cost of living and housing crises. There is much more we need to find out about the state of the social housing stock across the country and questions about standards do need to be asked, because many of the people this affects are the poorest and most vulnerable in our society. 

Councillors across the country have important skills to contribute in these areas. 

Perhaps a future Labour Government could pass legislation to ensure that social housing providers have local authority representation on their boards. This would help to ensure that ordinary, local people have a stronger voice on these critically important issue.  

Elsie Blundell is a councillor, the Chair of Labour Housing Group North West branch and sits on Labour’s National Policy Forum.

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How stigma shapes social housing policy in England

The reality of life for far too many people and families in England is that they are judged negatively and even actively discriminated against because they rent their home from a social landlord. “Sink estates”, “underclass”, “work-shy”, “uneducated”, “lacking in aspiration”, “zones of criminality”, “benefit scroungers”, “drug-infested”, “getting something for nothing ” are just some of the phrases that have commonly been used to describe social housing estates and their tenants.

The Grenfell Tower tragedy in 2017, in which 72 people died brought to the fore of public consciousness, the stigma experienced by social housing tenants as well as the ineffective and discriminatory complaint procedures in social housing. This led on to the Social Housing Green Paper, published by the Government in the summer of 2018, which highlighted stigma in social housing as a significant issue which needed to be addressed. 

While the Grenfell fire and the White Paper cast some light on stigma as an issue, little was known about the nature of social housing stigma. Why should people have to face this type of stigmatisation just because they live in social housing? What is the impact of this type of stigma on the lives of social housing tenants? How is it challenged?

Seeking answers to these questions led us on a journey – meeting with residents, speaking with housing associations and landlords, advocacy agencies and government officials, and reviewing how the media typically treats this issue. This resulted in our report titled “Stigma and Social Housing in England” which we published in July 2021. The report highlighted the complexity of social housing stigma as it intersects with other stigmas such as poverty, mental health, race, drugs and crime stigmas. It also highlighted how stigma is driven by political rhetoric, housing policy which residualises social housing and promotes home ownership while depleting social housing stock through the right to buy and a lack of investment in social housing as well as the absence of a strong tenant voice to advocate for the rights and interests of tenants.

Following the publication of this report, we opened up a sector-wide consultation on a number of issues which we felt were central to addressing stigma. The questions focused on the status of housing as a right, challenging and changing negative rhetoric on social housing from politicians and the media; creating a strong tenant voice and empowering tenants, changing the power imbalance between landlords and tenants and making landlords more accountable to tenants. In September 2022 we published our analysis of the consultation responses in a report titled “Stigma and Social Housing in England: feedback on the consultation responses” as well as a policy briefing, titled “Reducing social housing stigma in England: recommendations for the housing sector”.

In this blog, we highlight a few of the key issues from our report and their implications for housing policy.

Housing should be viewed as a right… 

In “Stigma and Social Housing in England: feedback on the consultation responses”, our respondents specifically noted that there needs to be a radical shift from housing being seen as a symbol of wealth to one in which adequate housing is considered a basic and fundamental human right. Taking seriously the idea of housing as a fundamental human right would entail a complete rethink of the purpose of social housing and more particularly it would mean:

  1. Moving away from policies of residualisation of social housing and the promotion of home ownership as a more superior tenure than renting.
  2. Placing a responsibility on government to provide adequate housing for everyone. This would need significant investment in social housing as well as the halting of policies such as the right to buy which deplete social housing stock.
  3. Social housing should be available to all households including all those squeezed into the private rental sectors. 
  4. Recognise the intersection of social housing stigma with other stigmas and develop policy measures that adopt a holistic approach to challenge the stigma in social housing.

Affordability of housing should be at the core of government housing policies to ensure the provision of social homes that meet the needs of a diverse set of people.

Political rhetoric…

In both “Stigma and Social Housing in England” and “Stigma and Social Housing in England: feedback on the consultation responses”, our responders overwhelmingly pointed out that politicians primarily drove the intensification of stigma in social housing in two ways. First, is that politicians use stigmatising language to justify their housing, particularly to residualise social housing and to project homeownership as a viable tenure to desire. Secondly, our responders argued that politicians stigmatise social housing residents in a bid to justify welfare reforms. They agreed that the stigmatising narrative from politicians and policymakers is a key driver of the negative media narrative on social housing, and this needs to change to build a sustainable and inclusive housing system. To address this, a few things need to happen

  1. Political will and policy need to be directed towards tackling stigma. This implies that policymakers need to be held accountable when found to have directly stigmatised social housing and its occupants.
  2. Politicians need to set the right tone to shape the societal perception of social housing and the media stereotyping narrative of social housing.
  3. To tackle stigma, policymakers need to adopt a collaborative approach to understand who lives in social housing and their everyday realities to inform housing policies. Indeed, given the intersectionality and complexity of stigma, unless there is a joined up approach to tackling stigma which involves tackling other associated stigmas it is unlikely that much progress will be made.

Accountability to Tenants…

The power imbalance between landlords and tenants is not new, and has previously been highlighted in the social housing green paper and in our initial report “Stigma and Social Housing in England”. This imbalance is driven in part by the nature of regulation of social housing. The weak regulation of the consumer standards and the marginalization of tenants in the co-regulatory arrangements in the sector has meant that power is placed in the hands of the landlords and a space is created in which landlords can deliver poor services and stigmatise tenants with impunity. To address this, a few things need to happen:

  1. Refocusing social housing regulation to reflect the interests of the tenants.
  2. Involve tenants in the co-regulation of the sector. Particularly, tenants have to be involved in the setting of service standards and the assessment of performance in relation to those standards.

Stronger tenant voices…

In both “Stigma and Social Housing in England” and “Stigma and Social Housing in England: feedback on the consultation responses”, our responders agreed that there was a distinct lack of tenant voice at a local, regional and national levels. Tenants need to be placed at the centre of policies and practices that affects them and they should be given substantive opportunity to shape those policies and improve the services that affect them. To promote a culture of inclusivity and democratic accountability, effective tenant panels and associations should be encouraged by housing providers, professional and trade bodies, the regulators; and feedback from these groups should be taken seriously to improve services and tenants’ experiences. 

In addition, participants in this consultation noted that the lack of an effective voice means that tenants do not have the power, mechanisms, resources or structure to lobby, challenge or help steer housing policies and regulations at the regional and national levels. 

At the regional and national levels, tenants’ voice should be established for the tenants and with the tenants, with the operations independently managed by the tenants. This will ensure that power and voice are directly placed in the hands of the tenants and not in the hands of any third parties with limited power to advocate for them.

Mission Drift…

Finally, one of the issues which featured strongly in the consultation’s responses was the sense that social landlords had lost sight of their “social mission” and had become more focused on making profits than on challenging politicians and the government to improve the lived experiences of social housing residents. By putting profits before people, tenants felt, that had contributed to poor service delivery and the continued stigmatisation of tenants. There were clear indications that as social landlords became bigger, the mission drift became more pronounced. One thing that can be done here is to limit the size of social landlords to ensure that they remain rooted in the communities which there serve. This would include breaking up larger providers.

Concluding comments…

Building an inclusive and sustainable social housing system devoid of stigma should not be expected overnight because the shift requires needs to happen at both policy level as well as at organisational levels. Stigma in social housing has been perpetuated over decades, and its eradication will require a multifaceted approach with conscious, consistent, deliberate, collective and sustained long-term programmes, policies and partnerships to change people’s perception of social housing and its residents. For this to happen, meaningful actions must be taken by all stakeholders to tackle this deep-rooted problem that affects the everyday realities, the quality of life, and the life chances of social housing and its residents. Some of these actions include:

  1. Adopting a rights based approach to housing
  2. Investment to significantly increase the social housing stock as well as putting an end to the right to buy and other policies which deplete social housing stock
  3. Expanding access to social housing
  4. Stronger regulation focused on interests of tenants
  5. Independent national, regional and local tenant voice organisations
  6. Increased tenant involvement in governance structures of landlords
  7. Placing a limit on the size of landlords to ensure that they remain rooted in the communities which they serve and focused on the interests of tenants and communities

About the authors:

Dr. Mercy Denedo is an Assistant Professor in Accounting at Durham University Business School.

Dr. Amanze Ejiogu is a Senior Lecturer in Accounting at the Newcastle University. 

Contact details:Enquiries can be sent to us via [email protected]

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Plans to destroy the Healthy Housing Assessment System will leave us all worse off

Unhealthy dwellings are not just uncomfortable, they can cause death.  On 15 November 2022, Coroner Joanne Kearsley held that 2 year old Awaab Ishak died as result of prolonged exposure to mould in his home.  This tragic death highlights the need for the application and enforcement of the Housing Health and Safety Rating System to be stepped up. But, here we report on proposals that would weaken the System not strengthen it.

In 2021 the Department for Levelling Up, Housing & Communities (DLUCH) commissioned a revision and update of the Housing Health and Safety Rating System (the Rating System). The draft of the proposed new “revised” Guidance (which has not yet been published but was previously expected to be in place by the end of 2022) ignores the principle underlying the Rating System, hasn’t really been updated, will cause confusion, and will result in legal conflicts. If adopted, it will result in increased suffering for individuals, days off school and off work, and greater demands on the health and care sectors.

After 10 years’ development, the Rating System was adopted in 2006 and is the statutory method for assessing housing conditions in England and Wales. It focuses on identifying threats to health and/or safety arising from deficiencies in a dwelling – Hazards. The principle underlining the System is that “Any residential premises should provide a safe and healthy environment for any potential occupier or visitor.” 

The Rating System has been recognised internationally as a major shift in housing assessment.

The revision commissioned by DLUCH was supposed to achieve several objectives, including: 

  • Reviewing and updating the current Guidance.
  • Providing a simpler means of banding the results of an assessment to make them clearer to understand by landlords and tenants.
  • Developing new standards to be incorporated into an assessment.
  • Amalgamating and/or removing of some Hazards.

We consider that the draft Guidance is badly written, confused and confusing, does not obviously update the existing Guidance, introduces arbitrary unexplained bandings, brings in so-called minimum standards, and mismatches and combines some Hazards. Not only that, it creates conflict with other legislation, and would fail to promote healthier housing if applied and enforced under Part 1 of the 2004 Housing Act.

There is no obvious updating of neither the statistical data behind the Rating System nor the evidence on housing and health. This leaves the important support for the Guidance nearly twenty years out of date.

The Rating System developed a method for putting a number against each identified Hazard (a Hazard Score). The legislation deems Hazard Scores above 1,000 as Category 1, and those less than 1,000 as Category 2, and places a duty on local housing authorities to take action to deal with Category 1 Hazards, and a power to do so for Category 2 Hazards. Local authorities can also deal with all Hazards, Category 2 as well as Category 1, at a dwelling. The proposed guidance creates three categories (with no explanation) dividing Category 2 Hazards into those with Scores of 101-999 and those of 100 or less. This implies Hazards Scoring 100 or less can be ignored (are “tolerable”), and if action is taken to deal with several such Hazards, or such a Hazard is included with a Category 1 Hazard. This adds a new ground for appeal.

As well as the proposed guidance suggesting that some Hazards are “tolerable”, it also introduces the idea of “normal behaviour” – two totally arbitrary concepts. While the current Guidance makes it clear that the Rating System does not include any potential hazard that is solely attributable to occupier behaviour, the revised version seems to imply some dwelling Hazards should be either “tolerated” or are made worse by the occupier, presumably, through “abnormal behaviour”. No guidance is given on what constitutes a “tolerable” Hazard, nor what is “normal behaviour”. These concepts will make it easier for landlords to argue that any Hazard is the fault of the tenant.

The objective to propose minimum standards has been taken to be a licence to introduce minimum standards for every Hazard.  The current Guidance avoids the pass/fail approach of a standard recognising three flaws with any standard. First, the line drawn tends to become the norm – Why should someone exceed the line? Second, it doesn’t give an indication of the severity of failure. Third, minimum standards encourage a check-list/tick-box approach to assessments – if the minimum is reached, then it is OK – it passes.

The minimum standards seem to be linked to a misconception that there are disconnections between the HHSRS and other legislative standards. It is difficult to find a disconnect when the current Guidance manages to avoid them stating that account should be taken of any relevant matter when assessing a Hazard. Meeting a standard does not mean there isn’t a Hazard. For example, the Electrical Safety Regulations set a standard that all electrical installations should be safe, but it does not state how many sockets should be provided to avoid the need for extensions leads (the wires of which could be a trip Hazard). Another example is that relating to smoke and CO alarms. 2015 Regulations (some nine years after the Rating System) requires such alarms to be fitted in rented dwellings and working at the start of the tenancy. The Rating System guidance advises that the lack of such alarms in any dwelling should be taken into account and that they should be working at the time of inspection.

The current Guidance applies to any structure used or intended to be used as a dwelling – the same assessment approach can be used to assess a house, a flat, a caravan, or a park home. This seems to be ignored by the proposed guidance and some so-called minimum standards are only geared toward houses.  (While the current Guidance gives clear definitions to avoid confusion, the proposed guidance does not.)

29 potential housing Hazards are given in the current Guidance, grouped to reflect the four basic health requirements in dwellings (as first set out by the American Public Health Association in the 1930s). The proposed guidance regroups the Hazard, without any rationale, ignoring the fact that the current Hazards are given in other legislation (such as the Homes (Fitness for Human Habitation) Act 2018).

The proposed guidance proposes combining some Hazards. These include a Hazard labelled “Domestic and Personal Hygiene” which brings together three Hazards in the current Guidance – “Domestic Hygiene, Pests and Refuse”, “Food Safety”, with “Personal Hygiene, Sanitation and Drainage”. Another combines “Fire” with Explosions”, and another “Biocides” with “Carbon Monoxide and Fuel Combustion Products”, “Uncombusted Fuel Gas”, and “Volatile Organic Compounds”. Aside from the incompatibility of these, it is difficult to understand why this has been attempted.

Other matters of concern suggest a lack of appreciation of the significance of a review of the HHSRS and a lack of understanding of the relationship between health and housing.

The concern is that the civil servants who commissioned the work will not appreciate the impact of the ill-thought-through proposals, and that the current political pressure could see this guidance adopted without challenge when tabled in both Houses.

What can be done? 

The guidance would have to be issued by the Secretary of State under s9 Housing Act 2004. If you agree with us that this would be against the interests of tenants and put their health at risk, do write to your MP and/or to the Secretary of State as soon as you can to argue for the draft guidance to be rewritten. 


This piece was prepared by David Ormandy, Steve Battersby, and Richard Turkington, members of the Academic-Practitioner Partnership for Healthier Housing. www.healthierhousing.co.uk

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Setting the right housing targets will be critical for Scotland

Unlike in England, where the new Government has denounced housing targets as Stalinist in another sign of an uneasy relationship with its own 2019 manifesto (300,000 a year were pledged), the question of how many homes Scotland needs and where to put them is a live policy debate. The National Planning Framework 4 (NPF4), expected to be laid before Parliament this year, will set out for each local authority a minimum requirement of the number of homes for which land should be made available. 

This important decision has taken on added salience because of the cost of living crisis. High rents and massive mortgages have left us little capacity to absorb economic shocks, whether external such as energy costs or the self-inflicted hike in mortgage rates following the budget announcements. Ensuring sufficient land is available for housing is crucial to bringing housing supply and demand into better balance and thereby improving affordability. It is also critical in ensuring there are enough shovel-ready sites to realise the Scottish Government’s commendably ambitious target of 110,000 new affordable homes between 2022-2032.  

Housing targets are partly a practical necessity (aligning housebuilding with infrastructure) and partly a democratic middle ground which balances competing interests. These attributes may not endear them to those seeking ideological purity, but they chart a course through undesirable alternatives. Targets are a compromise between a libertarian free-for-all, where people can build wherever they choose, and an exclusive, communitarian beggar-thy-neighbour approach, where those fortunate to live near undeveloped land in and around cities and towns are able to exercise an absolute veto over its use. The former fails to recognise people’s desire to shape, debate and influence what happens in their local area. The latter fails to give voice to families seeking a home of their own, which meets their needs and aspirations, and most of the population who consider we are facing a housing crisis.  

The housing crisis, while national in nature, must be solved on individual sites across the country. Without a clear target which local authorities are required to meet there will be a high risk of vocal local objectors successfully lobbying Councillors to prevent housebuilding. While those in need of a home make their voices known at a national level (evidenced by the prominence of housing issues in political debate) they do not, and cannot be expected to, lobby in favour of specific developments. Objectors and those commenting on planning applications play a valuable role in the process but without housing targets representing those in need of a home there would be a clear democratic deficit in planning for housing. 

Because land for housing is rationed in this way, unlike the inputs for the other of life’s essentials, it is critical that targets are as accurate as possible with sufficient tolerance for changes over time. The risks of setting targets which are too low are profound – placing upward pressure on affordability and leaving local authorities chasing scarce land at high prices to deliver their affordable housing. 

The Scottish Government is right to set out targets in NPF4. However, the figures in the 2021 draft are based on a flawed default methodology. The defaults have been changed in response to evidence submitted by some local authorities. However, these changes are haphazard; some local authorities put forward detailed, considered evidence such as households surveys, others submitted limited information probably due to pressures on resources. Remarkably, two of the least affordable local authorities in the country, East Renfrewshire and East Dunbartonshire (where house prices are 10 times average earnings) successfully lobbied for targets below the already low defaults.  

There are two components to the Scottish Government’s methodology. Household projections are added to an estimate of households in existing need to give a target. Uncritical reliance on household projections leads to unsatisfactory housing outcomes being projected forward as Professor Glen Bramley has observed “If household growth has been artificially suppressed by the undersupply of new housing, then basing future need calculations on those lower growth figures will by necessity under-estimate that need”. This is acknowledged by the National Records for Scotland who produce the projections. The past decade or more has seen worsening affordability and housing outcomes we should be planning to improve upon, not perpetuate. No attempt has been made in draft NPF4 to quantify the additional homes needed in areas where houses are less affordable and have become less so over the last decade (below).

Image: Average house price multiples of workplace full-time earnings in 2021 (left) and change since 2011 (right). Using Registers of Scotland Average House Price data and ASHE full-time earnings by workplace location

The definition of existing need only recognises it in its most acute form; those in temporary accommodation and households which are both overcrowded and concealed. Concealed and overcrowded households are where two or more families live in one home without sufficient rooms. This is an exceptionally high bar missing many other forms of urgent need such as overcrowded households, adults and adult couples living with their parents, on waiting lists, in unsuitable or physically unfit homes and those in unaffordable homes. It is not fit for purpose and will underestimate the extent of housing need. Household surveys are needed to better understand existing unmet need.

The Scottish Government has been less bombastic than the UK Government in its growth ambitions, but its Strategy for Economic Transformation is clear and aims “to deliver economic growth that significantly outperforms the last decade, so that the Scottish economy is more prosperous, more productive and more internationally competitive”. Draft NPF4 should be changed to provide targets which are fit for purpose, fully understand existing need and address affordability challenges. These will be essential in providing the homes Scotland needs to deliver housing outcomes which significantly outperform those of the last decade and take pressure off household budgets. 

Joe Larner is an Associate Director at Holder Planning based in Edinburgh, with around 8 years of experience focused on housing projects of all tenures in Scotland and England.