The HARA response to the Green Paper consultation ‘A New Deal for Social Housing.’

Part 1: Ensuring homes are safe and decent 

Without directly-elected residents (meaning tenants, shared owners and leaseholders) on committees of governance, there is no hope of improving the safety of housing association homes. 

As far as Housing Association Residents Action (HARA) is aware, the National Housing Federation still continues to promote the position that Fire Risk Assessments should not be disclosed. This is just wrong. 

In addition, the widespread practice of ‘selecting’ residents to sit on committees of governance (including the Boards of housing associations) undermines accountability. In the 21st century the practice is quite simply an insult, not only to democratic principles, but also to residents of housing associations. 

This lack of accountability through fraudulent ‘resident representatives’ seriously damages the attempt to ensure that homes are safe and decent. We suggest, as a start, that:

  1. All Housing Associations must be subject to the Freedom of Information Act. We note that Information Commissioner is on record as saying this is necessary.
  1. All committees of governance in housing associations should have directly elected residents sitting on them. We suggest that at least 50% of committee members be directly elected residents. 
  1. All Fire Risk Assessments be disclosed by housing associations. This to include disclosing what recommendations have been completed and what have not.
  1. Improve repairs and cyclical maintenance by ending outsourcing to contractors through procedures like Qualifying Long Term Agreements which are an invitation to corruption in housing associations and the exploitation of their residents. 
  1. Giving democratic tenants’ and residents’ associations the right to serve improvement notices on housing association landlords.  Such an improvement notice should have a time limit for response by the housing association.
  1. The possibility of residents taking over the management of their homes when housing associations fail to manage.  

Part 2: Effective resolution of complaints

The complaints procedure is quite simply broken. The Ombudsman and the Regulator have failed to control housing associations. We suggest:

  1. Clear and absolute rights and standards to which landlords can be held to account.
  1. Tenants and leaseholders need more powers and checks on housing associations. The language of ‘more choice’ by comparing services, is false.
  1. Regular resident-led inspections, reporting directly to the Board, are essential These should be carried out by directly-elected tenant and leaseholder representatives.  
  1. Directly-elected residents to oversee and scrutinise housing strategy, charges (including service and other charges), rents, and housing association decision-making.
  1. A completely independent complaints procedure is still necessary.  But we suggest that directly-elected resident representatives, properly supported with adequate staff, would be able to respond in many cases to issues which are currently not being dealt with by a failing complaints procedure. 

Part 3: Empowering residents and strengthening the Regulator

We strongly support the strengthening of legislation and regulatory standards to improve the safety of social housing (especially in relation to the reduction of fire risk) and the quality of housing management.  

We are not aware of any large housing association in England which has directly elected resident members sitting on any committee of governance. Residents are ‘selected’ (and paid) to do the bidding of Boards and Executive teams of the large housing associations. Minutes of Board meetings are secret – as are shareholder minutes. Shareholders are often chosen by criteria which are not disclosed and are not recallable or subject to time limits in office. 

The continued pretence of fraudulent ‘tenant involvement’ procedures undermine the integrity of governance, destroys resident confidence in management, and promotes poor, unaccountable, decision-making by those in governance. We suggest:

  1. Increased transparency on fire safety, asset management policies, use of disposals proceeds funds and recycled grant.
  1. The end of support for new housing made through housing benefit – to be replaced by direct grant for construction. The consequences of the policy of funding construction through housing benefit has been the ethical corruption of the housing association movement and the increasing poverty of housing association residents. 
  1. Tenants and residents associations should be funded directly and independently of housing associations. Truly independent, properly funded, tenant and resident organisations are vital for rebuilding effective housing associations. 
  1. Open, independent ballots of residents on any redevelopment scheme, regeneration, merger or other major change in the homes of residents of housing associations. Currently housing associations think it is acceptable to have ‘consultations’, while refusing to disclose the results, as evidenced by recent merger consultations. 
  1. Housing Associations should make public the criteria for their shareholders and ensure that a large proportion of shareholders are directly elected residents. Shareholders should not serve for indefinite periods and should be rooted in the community. 

Part 4: Tackling stigma and celebrating thriving communities

HARA welcomes the recognition of the positive role of housing for the community rather than for profit. We stress the key importance of the right to housing found within the Universal Declaration of Human Rights.

For example the United Nations Special Rapporteur on Adequate Housing explains this human right in her report on the UK in 2013:

“The Special Rapporteur wishes to underscore that the right to adequate housing should not be considered narrowly. It includes guaranteeing various aspects, such as security of tenure, affordability, accessibility, location and cultural adequacy. The Committee on Economic, Social and Cultural Rights has underlined that the right to adequate housing should be ensured to all persons irrespective of income or access to economic resources.”

The Green Paper does not even begin to respond to this important human right to housing.

  1. Ministers should refrain from propagating the fallacy that that housing for the community (‘social housing’) is subsidised. It is not. In addition such investment becomes a public asset. It should be pointed out that home ownership is hugely subsidised for political reasons. Social housing is largely unfunded for the same political reasons. 
  1. Strong rent controls are necessary for thriving communities. Housing associations are building largely unaffordable ‘affordable housing’ which traps ordinary people, particularly pensioners, in the benefit trap destroying communities in the process. 
  1. Of course, the practice of give only short-term tenancies does similar damage to communities. It should stop. 
  1. Shared owners are frequently trapped by rapidly-rising service charges which can destroy their lives if they cannot sell. This further damages the communities in which they live. 
  1. Creating thriving communities requires that large merged ‘mega’ housing associations be broken up into smaller locally-accountable housing organisations. 

Part 5: Expanding supply and supporting home ownership

Housing association have effectively become large volume house builders without ethics or values. Tellingly, National Housing Federation statistics compiled in June 2018 note that only 10% of the homes built by housing associations in the last year were ‘social rent homes.’ In the words the housing association movement has effectively given up its traditional ‘social purpose.’ For example, the Model Rules for Housing Associations produced by the National Housing Federation in 2015 remove ‘social housing’ as the primary object. 

Home ownership should not even be in the Green Paper. As the Highbury Group notes in its response to the Green Paper:

“Home ownership, even if access is increased at the margins, is not a solution to meeting the housing needs of those households who have incomes and assets significantly below the levels at which access to market housing for sale is an option, and for the Government to imply otherwise is misleading. Social housing needs to be seen as a valid tenure in its own right and not just a springboard to home ownership.” 

We suggest, as a start, that:

  1. Right to Buy legislation be reviewed.  

2. Help to Buy is merely an additional subsidy to large housing builders and developers. It should be halted immediately

3. The Affordable Rent Programme should be stopped. The widely respected Joseph Rowntree Trust has repeatedly pointed out that ‘affordable rent’ (80% of market rent) increases poverty amongst housing associations residents. All ‘conversions’ of social rent homes to ‘affordable rent’ should end.

4. Ending the housing association policy of subsiding the construction of out-of-reach homes by selling social rent homes. This policy is obviously absurd if the intention to attempt to end the housing crisis. The sale of existing social rent homes should be stopped. Similarly, housing associations should be prohibited from agreeing regeneration projects which cut the number of social rent homes. 

5. The main outlines of a policy to solve the housing crisis are well known. It includes: ending the privatisation of housing, direct investment in social rent homes, ring-fencing public land to build homes for the community (social rent homes), and maintaining an increasing the supply of ‘social rent’ housing at some 40% of market rent – particularly in London.

6. The model of plundering residents and selling social rent homes in order to increase income stream to pay off debts for construction of out-of-reach housing has no future. It was a failure as a policy and it should end.


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