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Modernising Scotland's Social Housing: Consultation Report: Summary of Responses to Consultation Paper

SECTION 2 -THE SCOTTISH SOCIAL HOUSING STANDARD

6. The consultation paper set out an outline Scottish Social Housing Standard; this was based on research on existing standards undertaken by the Housing Improvement Task Force. The outline Standard consisted of 5 key criteria with detailed elements within these. We sought views on whether the criteria definitions/key elements were appropriate or whether others should be included. The paper then went on to discuss whether accessibility and additional features of Secured by Design should be included in the new Standard. Consultees were also asked for their thoughts on what the minimum quality benchmarks might be for the detailed areas and also on an appropriate target date and possible milestones for meeting the Standard. Finally, we asked social landlords to consider their delivery strategies for achieving the Standard.

7. Respondents overwhelmingly welcomed the Minister's proposal to establish a Scottish Social Housing Standard. Several councils confirmed that they had already developed a quality standard for their own stock. Only one council opposed the concept of a national standard on the grounds that any quality standard should be set by councils in consultation with tenants. A number of consultees felt that the scope of paper should have been extended to include an environmental standard.

8. Respondents were invited to comment on any part of the outline quality standard and several took the opportunity to offer their views on various criteria and key elements. We have summarised these multiple comments as far as possible but it has not been possible to report on every individual response. The distribution of responses on the Standard is shown at Table 2 below

9. A common theme of many of the responses was that account should be taken of the design of individual dwellings, in particular the non-traditional construction types, since this could impact on landlords' ability to achieve the new Standard.

Table 2-Distribution of Responses on the Scottish Social Housing Standard

Structure of this section

10. This section summarises responses on the 5 key criteria in the outline Standard:

• Compliant with the Tolerable Standard;
• Free from Serious Disrepair;
• Energy Efficient;
• Modern Facilities and Services;
• Healthy, Safe and Secure.

It then goes on to report on other issues:

• Accessibility
• Secured by Design

Timescale

• Delivery Strategies
• Other Comments

Tolerable Standard

11. The first quality criterion for meeting the proposed Scottish Social Housing Standard was that properties should meet the Tolerable Standard. Of the 5 responses, 2 felt that the Tolerable Standard was outdated and that the associated individual elements should be incorporated under alternative quality criteria. Others suggested the Tolerable Standard definition should include the provision of electricity and water; free from damp; fit for human habitation; radon gas detectors; and serious disrepair.

12. Separately from the consultation on the Scottish Social Housing Standard, the Housing Improvement Task Force was asked by the Minister to review the Tolerable Standard. Its report "Stewardship and Responsibility: A Policy Framework for Private Housing in Scotland" published in March 2003, recommended various changes to the Tolerable Standard. Following consultation on the Task Force report, the Scottish Executive announced in December 2003 that the Tolerable Standard would be modified in line with the HITF recommendations to include additional items (basic provision of thermal insulation and electrical systems which are adequate and safe in use) and improved specifications of the "wholesome water" and "substantially free from dampness" requirements. Any changes made to the Tolerable Standard will read through to the Social Housing Standard.

Free from Serious Disrepair

13. This second quality criterion included reference to primary building elements like walls and structures with chimney stacks, damp proof courses, windows and doors listed as key building elements. Respondents focused their attention on "missing" elements.

14. The inclusion of a quality level for electrical wiring/installations and gas/oil installations attracted a relatively high level of support especially from local authorities and registered social landlords. There was also support for the inclusion of common areas in the new Standard e.g. lifts and foyers; balconies and verandas; and access steps and stairwells. We received a couple of suggestions on "finishes": that harling, rendering and pointing should be included and perhaps should be extended to include internal features e.g. door facings and skirting.

15. There were several comments on our proposals for assessing failure against the Free from Serious Disrepair quality criteria. Overall respondents were concerned that percentage failures would apply, and felt that 20% was too high a margin, and a roof which was 20% defective could result in 100% inconvenience to the resident. A few respondents felt that the proposed quality levels were too subjective for consistent interpretation and expressed a need for clear guidelines if adopted. More than one tenants' group was of the view that properties should fail on a single key element and that there should be tighter control of components likely to become unsafe if in disrepair.

Energy Efficient

16. The outline Standard proposed that the Energy Efficient criterion should be defined under 2 key elements: effective insulation and NHER (National Home Energy Rating). On insulation, 2 respondents felt that thermal insulation standards should be restricted to all new build and improvements during major works where cost effective. We received a couple of responses expressing the view that the proposed 200mm measure for loft insulation was too prescriptive and felt that, if applied, guidance would be required on the definition of "where appropriate." Five respondents felt that the insulation of boilers, tanks and pipes should be included in the new Standard. On other forms of insulation, there was overwhelming support for the inclusion of double glazing in the Scottish Social Housing Standard with a couple of respondents preferring triple glazing. It was the view of a couple of councils that wall and or ground floor insulation should be included as key elements.

17. Our outline Standard included a target NHER rating of 5 or above as a measure for assessing the energy efficiency of homes. An NHER assessment provides a figure between the range of 0-10 representing the cost of energy used per metre square of floor area of the property. In this NHER range, 0 is associated with high fuel costs and 10 with low annual fuel costs, high insulation levels and efficient heating appliances.

18. The majority of respondents supported setting a NHER rating of above 5. A number of respondents thought that the proposed NHER target should be given further consideration, as the ability to meet it will be affected by the house type and participation of owners in flatted accommodation. Groups representing rural communities were concerned that the lack of fuel choice and mains gas supply in their areas would limit the ability to meet NHER targets economically.

19. Several RSLs wished to see the SAP measurement (Standard Assessment Procedure) applied rather than the NHER since a historical database had already been established. A single respondent highlighted that the application of SAP was consistent with building regulations and Communities Scotland requirements. The SAP rating system has been developed specifically to be included in the building regulations. The SAP system produces a rating between 1(very inefficient) and 120 (very efficient). Unlike NHER the location is not taken into account (so similar buildings will have similar ratings even though one is in Thurso and the other in Torquay).

20. On failure triggers on Energy Efficiency, six respondents. including 2 local authorities and 2 RSLs, were of the view that fuel poverty should be adopted as a measure for homes which fail to meet the quality criteria for energy efficiency. But energy efficiency groups recommended that the target NHER rating, for inclusion in the new Standard, should be defined once the report from the Scottish House Condition Survey 2002 was released.

Modern Facilities and Services

21. The outline standard in the Paper included a quality standard for kitchen and bathrooms and facilities generally. Twenty respondents (9 LAs) wanted to see 2 aspects removed on the grounds of practicality: a second WC in houses with three or more bedrooms and prescribed kitchen sizes. They felt that the design of the majority of existing social housing would not allow the necessary level of adaptation and that these elements of the Standard would be impossible to enforce retrospectively. Two respondents from the financial sector suggested that the costs associated with the re-design of existing stock to include second WCs and prescribed kitchen sizes would be disproportionate and that tenants should be consulted since there could be an impact on rents.

22. Several respondents wished to see guidance provided on the pass/failure criteria for kitchens. Their view was that value judgements are open to interpretation and felt that the age and condition of facilities should feature in the Standard, mirroring England and Wales. The view of a couple of respondents was that while storage space is important in kitchens, space for work surfaces is essential for safe working sequences. One council commented that it may not be necessary or desirable to provide these facilities where the property is under occupied and likely to remain so for some time.

23. There was support from several respondents for a separate Standard for new build properties and one respondent wished to see increased basic space specification with an emphasis on greater room space and a greater variety of styles for new builds.

24. Several tenants' groups wanted to see showers feature in the new Standard, either with over-bath fittings or as separate units. On the proposal to add provision for 3 double sockets in kitchens, a number of respondents felt that level of supply was inadequate, while others felt that in modern homes, there should be a prescribed number of sockets in other rooms. One homelessness group recommended the inclusion of laundry and drying facilities. We also received a few suggestions for the inclusion of broadband/digital access (Smart Technology) in the Scottish Social Housing Standard.

Healthy, Safe and Secure

25. In the paper, several key elements were proposed under each of the 3 above headings. Generally, consultees did not frame their responses under the 3 different definitions and the divisions between them, especially between safe and secure, became blurred.

26. Under the definition of healthy, homelessness groups were among those respondents who wished to see "free from dampness and condensation" added to the Scottish Social Housing Standard. In that vein, and linked with health improvements, there was considerable support for the addition of ventilation systems in kitchen and bathrooms. Energy efficiency groups were among the 8 respondents who wished to include some measure of energy efficiency to the proposed full house central heating systems. Local authorities and tenants alike felt that it was important to consider the safety, age and condition of the heating system as well as its efficiency and effectiveness.

27. On safety issues, twenty two respondents supported the inclusion of carbon monoxide detectors and several respondents shared concerns about the control of asbestos and lead in water and pipes. On windows, we received a couple of requests for safety catches on properties above first level. And there was a single response on the need for windows and balconies to be child proof. Several respondents suggested the inclusion of fire precautionary measures; hard wired smoke and fire alarms; sprinkler systems; fire walls and fire breaks in roof spaces and security doors with a permanent visual identifying symbol on the external face. We also received a single suggestion for preventative measures for properties on a flood plain to be included in the Standard.

28. We received a wide range of views on the criteria defining secure homes. These ranged from the strength of doors and types of locks to secure bin rooms and lift areas. The most frequent response, from 11 consultees, was for the provision for callers to be identified securely e.g. by provision of a spy hole, entry phone or door chain. The majority of councils expressed concern about the cost of providing emergency lighting in communal areas and in particular the role of owner-occupiers in flatted accommodation. There were conflicting views on the inclusion of secure window locks, where some tenants' groups supported the measure, others urged caution fearing that internal windows locks could prove hazardous in emergency evacuation situations.

29. We received a significant number of responses from a wide range of groups, including 10 local authorities and 6 tenants' groups, requesting the inclusion of sound insulation in the Standard. Several felt that adequate sound insulation/proofing should be required particularly in respect of flatted accommodation. A couple of respondents referred to adequate sound insulation being a minimum requirement of current building regulations. Two others felt that sound insulation should be included on the grounds that there was a link between noise nuisance and neighbourhood disputes.

30. The Chartered Institute of Housing felt that noise nuisance needed to be addressed but that the Standard may not be the best way to tackle it. Three respondents acknowledged the costs and technical complexities for existing stock and suggested that a core standard should be applied for new builds or during major works where it is seen to be cost effective.

Accessibility

31. The outline Standard was guided by the Housing Improvement Task Force's recommendation that an accessibility measure should not be included. Their view was that particular needs which relate to the changing usage of housing stock over time are impossible to predict and that significant sections of the housing stock will prove incapable of providing barrier free or wheelchair access and will never be required to do so.

32. This section of the paper attracted 72 responses with differing views. The majority of respondents supported the exclusion of an accessibility element in the social housing standard; some felt that the Standard was not the appropriate vehicle to promote accessibility.

Several landlords and RSLs shared the view that an accessibility standard should be set for new build properties or as part of major refurbishment programmes reflecting local need for varying levels of accessibility. A couple of respondents preferred to see the inclusion of the Housing for Varying Needs concept in the new Standard.

33. Several respondents felt that accessibility should be added across all properties. Others agreed that accessibility should be included but that certain house design/construction types should be exempt. One major housing organisation pointed out that mobility is not just about the long-term wheelchair bound individual but that the needs of older and semi-ambulant residents should also be taken into consideration. They wanted all dwellings to have doors with level thresholds with sufficient width for use by disabled people, accessible WC facilities, accessible entry phone systems where applicable and accessible light switches. One special needs RSL expressed the view that improvements in accessibility should be assessed at the changeover of occupancy and where adaptations have already been carried out; any special facilities should be retained to meet local demand.

34. A common theme running through a large proportion of responses was that an accessibility measure is required at local level and that data collection is crucial to inform landlords' strategic planning through the preparation of Local Housing Strategies and resource allocation. A couple of respondents felt that disabled people themselves should be consulted at the planning stage of housing developments. Others felt that there was already sufficient guidance available on planning barrier free housing e.g. Lifetime Homes; and Design for Varying Needs etc.

Secured by Design

35. The consultation paper asked respondents whether they wanted to see any additional features of the Secured by Design (SbD) initiative included in the Standard. Housing projects funded by Communities Scotland are expected to adhere to the principles of the Secured by Design (SbD) initiative unless there are some characteristics of the development which prevent those principles being applied. Ministers want to see this approach applied to all Scottish Executive funded housing projects.

36. Fourteen respondents felt that more of the features should be included in the new Standard and we received recommendations for a wide range of measures: the inclusion of CCTV for multi storeys and underpasses; mortice deadlocks; viewed entry systems in multi-storeys and movement sensor security lighting.

37. The preference of many respondents, including 13 local authorities and 7 RSLs, was for SbD to be restricted to new developments or during major refurbishment work with several raising the need to consult tenants on cost implications. One RSL accepted that it would be difficult to adapt existing properties to SbD but suggested that features such as burglar alarms could be introduced. There was a single suggestion that there was a need to include the requirement for basic household insurance in the Standard.

38. On improving neighbourhood environments, there were conflicting views on SbD. While a couple of respondents expressed the view that the concept of SbD has the potential to produce a fortress mentality, others felt that there should be a risk assessment in low crime areas; or that local residents' concerns should be addressed. One council stressed the need for caution in that security is dependent on behaviour as well as the presence or absence of a facility. Several respondents shared the view that the police authorities should be consulted at the planning stage, although it was accepted that local resources may be stretched.

Timescale for achieving the Standard

39. The consultation paper sought views on setting a target date for meeting the new Standard. Of the 75 responses received, the majority had a preference for a 10 year target.

There were other suggested target dates; ranging between 5 and 13 years. One local authority felt that the Standard should be met in the shortest possible time but that rent affordability and sustainable investment should be the key drivers, a concern shared by several tenants' groups. A few consultees felt that the target for meeting the Standard should link closely with the Scottish Executive's targets for eradicating Fuel Poverty.

40. There was some support for a 10 year target to run once local authorities and registered social landlords had assessed the condition of their stock and delivery strategies were in place.

41. The consultation paper also sought views on the setting of milestones. These were mixed but several landlords supported setting interim targets through consultation with tenants on priorities. We also received a couple of responses suggesting that landlords should focus investment on houses in the greatest need. One RSL felt that individual landlords should set their own targets based on the stock condition surveys. Several respondents felt that there should be year on year improvements with interim percentage targets leading to full compliance. A couple of respondents felt that percentage targets would allow landlords to take the easy repair option in order to boost their figures.

Delivery Strategies

42. Our consultation paper explained that once the new Scottish Social Housing Standard had been defined, the next stage would be for social landlords to prepare their delivery strategies for achieving it. April 2005 was proposed as the date for submission of these strategies, for councils it was proposed that this would take the form of an update to the Local Housing Strategy.

43. The majority of the 29 local authorities submitted comments on delivery strategies. The Local Housing Strategy was seen as the appropriate vehicle for providing the necessary data with inbuilt scope for 5 year reviews. Three councils thought that they would face difficulties through having to allocate staff and budgetary resources to the compilation of delivery strategies. Seven RSLs expressed concern about costs associated with assessment and compliance with the Standard and a few pointed out that any reserves they have are required for maintenance and major repairs. A couple of RSLs felt that they would have difficulty meeting the 2005 target date for the submission of strategies. Several respondents took the view that guidance should be provided by the Scottish Executive to ensure consistency across delivery strategies.

Other Comments

44. Respondents took the opportunity presented by the consultation exercise to air their views on other matters: many landlords expressed concern about the cost of meeting the Standard and the role to be played by owner-occupiers, particularly in flatted accommodation. One council, which had already set its own local standard through consultation with tenants, was concerned about the impact of the new Social Housing Standard on their business plan. Several councils queried why RSLs have been asked to submit their stock profiles to Communities Scotland when local authorities are required to assess housing need/demand in their area across all tenures for inclusion in their Local Housing Strategies. There was a single comment about Value Added Tax and how local authorities and RSLs treat it differently. One RSL was concerned about the impact of the Transfer of Management of Development Funding from Communities Scotland to local authorities. Finally one council asked if compliance with the Standard would become part of Communities Scotland's regulatory duties.

Scottish Executive Response

45. The consultation paper set out proposals for a Scottish Social Housing Standard. Since March 2003 however Scottish Ministers have announced that following the recommendations of the Housing Improvement Task Force, they will bring in a cross-tenure Scottish Housing Quality Standard in line with the Partnership Agreement to introduce a decent homes standard. The details of the Standard and a target date for reaching it in the social housing sector were announced by the Minister for Communities at the same time as the issuing of this consultation report. All recipients of this report will also receive a copy of the Scottish Housing Quality Standard-Detailed Specification, which will also be available on the Scottish Executive website at: www.scotland.gov.uk/consultations/housing/shqs04-00.asp

46. Communities Scotland will be issuing guidance on the preparation of Standard delivery strategies in the Summer of 2004. In the meantime, April 2005 is confirmed as the date for the submission of these strategies by local authorities and registered social landlords. Communities Scotland will also be responsible for assessing the strategies on behalf of Scottish Ministers.

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