5 observations about WHQS that need tenant engagement
TPAS Cymru welcomes the new Welsh Housing Quality Standards, and we are fully committed to supporting tenants and landlords with its implementation. However, we have some thoughts regarding the interpretation of achieving the objective.
Risk 1: Are we measuring success correctly?
We want affordable low energy homes, AND we want to decarbonise housing.
So, as a sector we’ve agreed on EPC A as the measure of success, but that is a measure of energy efficiency not carbon emissions. Recently, a landlord’s case study was published where a gas boiler was retained rather than a heat pump installed, and it still achieved EPC A. I know tenants will be delighted at cheaper bills, but if we haven’t decarbonised homes, do we have the right measure? Equally, our most popular case study this year was an innovative retrofit in Cwmbran that really got people excited. Fossil fuels removed, exciting new heating solutions installed, but only achieved EPC B so for some it could be considered a failure under the WHQS target. Are we chasing the right target?
Risk 2: Innovation speed v’s Procurement rules
We attended an event recently where suppliers demonstrated their products, in particular product innovation in solutions that tackled at damp & mould AND/OR energy efficiency (they are interlinked).
The audience of housing procurement, energy experts, damp specialists, technical assessors etc were impressed and liked what they saw. But there seems to be a 4–5 year lag (and lots of expense) before new solutions are recognised for the official points-based systems ‘SAP’. It could be a brilliant solution, but if the buyer doesn’t get the recognised points in their EPC score, they might have to choose something less efficient or cheaper because it has already been approved. This is a UK level issue not Wales specific, and suppliers were claiming many European countries have faster pathways for getting product development accepted into mainstream standards.
Risk 3 – Assessing a home and its EPC standard.
The housing sector need to get all their homes up to EPC A standard. That is a big ambitious, challenge, and most of the time social landlords will self-certify with inhouse experts. But are tenants included in these conversations?
We have already seen cases in the private sector, where a landlord got EPC assessment done and was graded EPC D. The tenants felt it was not reflecting their bills, so they paid approx. £100 to have their own EPC check, which came back as an EPC F , which is not just 2 grades different, but it also meant that if correct was being illegally let as the minimum EPC in the private sector is EPC E!. Could this happen in social housing?
Do Tenant groups need a way of auditing the landlord certifications?
At the moment, the number of Retrofit projects in Wales is small, but we have just over 10 years to retrofit 230,000 homes. That can’t all be done by the people we have in place now. We are going to need lots of recently qualified energy assessors, 3rd part contractors (who will be eager to please the large social landlords) and housing leadership will be challenged to hit these challenging targets. We are concerned energy assessors could come under pressure to grade positively. The example already used in sector is like getting 3 estate agent valuations and picking the highest value. We fully accept EPC is much more scientific and we are not questioning the professionalism of good assessors in social housing, but even the most pro- energy assessor will accept that there is still scope for interpretation in SAP/EPC, as we expand the pool of those qualified to assess.
We know retrofitting all homes to EPC A is going to be a challenge. Some properties are going to be expensive to change and therefore boards need to consider value for money. This creates a dilemma for social housing landlords. Here is why:
They will end up doing the work on certain properties at significant cost because it’s the right thing to do, but knowing the rent on that property will never cover the costs/value of the home.
The landlord applies for an exemption from Welsh Government, and the tenant doesn’t get the benefits. (More on that below)
The landlord sells the property, either as a vacant or with the tenant in it. This is a real option being considered for their challenging properties. This concerns TPAS Cymru greatly.
a) These are tenants’ homes, they are meant to be safe haven.
b) There are thousands of people on Council waiting lists across Wales, in temporary accommodation and sadly homeless. We need more social housing not less.
c) Dumping these homes on the private sector will just mean lower housing standards and higher cost to taxpayers in form of higher rents paid to private landlords often via universal credit payments
d) A social landlord may ‘own’ the properties, but they are just the guardians. These properties were paid for by tenants rent, various grants and subsidies, stock transfer, favourable land deals etc.
We need much stricter controls and tenant scrutiny of any sales.
Risk 5 – Interpretation and tenant rights
Overall, the new WHQS standard is ambitions, positive and an important next step forward in raising standards. TPAS Cymru fully supports them, but it relies on landlord interpretation of each standard.
What happens if it is decided that your home can’t be brought up to EPC A and the landlord applies for an exemption from Welsh Gov? The tenant might still be facing larger energy bills than other tenants and also being asked to contribute to WHQS via above inflation rent rises. Should they get a rent discount? Where does the tenant stand?
What are landlord’s plans for ensuring tenants voice is fully reflected in the interpretation of the standards? We have developed a WHQS tenant engagement framework and are keen to work with the sector in rolling out best practice.
We have already seen where some properties in a development have solar panels installed, others have the same solar panels plus a battery. Does the landlord have a clear policy on why there is a difference?
Take a simple thing like the new requirement for water butts for each property – TPAS Cymru visited a show case retrofit terraced property which didn’t have a water butt added. When we asked why there wasn’t one, it was because the down pipe went down the properties of the neighbouring left and right houses. So, unless the guttering is altered, the tenant won’t have a water butt? Who decides? Maybe the tenant wanted one…can a tenant appeal?
Finally, these changes to homes need embedding and tracking with tenants. Previously a contractor could change a combi boiler for another combi and simply leave. Removing a combi boiler and replacing with a heat pump needs intelligent tracking and regular tenant contact to establish how they are getting on and to see if its meeting the objectives.
Will tenants get a say in the solutions?