Welsh Housing Quality Standards – What’s next for tenants in Wales

Brief background

Welsh Housing Quality Standards (WHQS) were introduced in 2002 to raise the standard and condition of properties in Wales. WHQS applies to Registered Social Landlords (RSLs) and Local Authorities with social rented homes.

For landlords to meet WHQS, their housing must be:

1. In a good state of repair
2. Safe and secure
3. Adequately heated, fuel efficient and well insulated
4. Contain up-to-date kitchens and bathrooms
5. Well managed
6. Located in an attractive and safe environment
7. Where possible, suitable for the specific needs of those living there, such as people with disabilities

In 2011, additional monitoring and data collection began on WHQS as the initial monitoring didn’t provide a clear focus for landlords or enable WG to assess progress realistically.

According to WG, these standards have now been met and WHQS 1 has drawn to a close. It is, however, important to note, that there were a number of ‘acceptable fails’ that enabled landlords to have their housing stock signed off by WG.

Acceptable fail: whereby achieving the standard for one of the elements is not possible. An example of this would be, the cost or timing of the work or residents choosing not to have the work done.

What now?

WG commissioned independent researchers to evaluate WHQS 1 in 2021 and the key findings were as follows:

1. The close working relationship between landlords and WG since 2017 helped to build trust, share best practice and improve the level of data collection.
2. 93% of homes in Wales had achieved WHQS by the end of March 2019, which includes ‘acceptable fails’. The biggest challenge was the energy performance of the properties.
3. Wales is leading the way in a UK context to housing
4. Two out of five tenants had not heard of WHQS but the majority felt that it is important

Key recommendations

Decarbonisation

1. Delivering decarbonisation through the new WHQS would provide a clear framework that can be monitored and in turn, ensure that tenants are no worse off as a result of the decarbonisation work in their homes. The aim should be to improve comfort levels and reduce fuel poverty.
2. WG should work with tenants and landlords to develop good practice
3. There needs to be an approach to measure performance, review progress and make adjustments to targets where necessary

Data collection and direction

1. The new WHQS should be evaluated before, during and after the programme
2. Individual properties should be monitored to improve the way data is checked across other policy areas, such as health
3. The new WHQS should be monitored through the use of a traffic light system when considering acceptable fails. This will show where additional intervention/ funding could improve the status of the property, or whether it will never be able to reach the standard in full
4. There should be two yearly reviews and annual workshops to showcase the data

Communications

The review acknowledged that there were improvements needed in terms of the communication around WHQS, stating that WHQS 2 should be written in plain language and that WG need to ensure that they are communicating effectively with landlords to ensure WHQS 2 is a success.

Flooring

The review recommended that landlords and tenants work together to develop a standard that ensures tenants are not faced with the burden of having to find the finances to purchase flooring for their new homes.

Broadband

Similar to flooring, the review recommended that landlords and tenants work together to develop a standard that is effective in delivering broadband to tenants.

What is next for WHQS?

In spring 2022, WG released a consultation document based on the recommendations made in the review. The analysis of the responses to the consultation is currently taking place, with an aim to launch WHQS 2 in November 2023.

The key elements in the new proposed standards are:

• Heating systems in homes must be affordable, with a minimum of SAP92 – Energy Performance Certificate A

(Overall, social housing stock in Wales is currently at EPC D, and therefore heating bills are higher)

• The overall carbon emissions coming from social homes must be lessened.
•  Landlords must produce a Target Energy Pathway for their homes, following a Whole Stock Assessment
• Unless kitchens are in good condition, they can’t be more than 16 years old
• Unless in good condition, toilets and bathrooms must be less than 26 years old
• When a tenant moves into a new home, all rooms, staircases and landings should have suitable floor coverings.
• Landlords should aim to stop digital exclusion amongst their tenant population
• Storage outside of properties should be made available
• Fire detection and alarm systems should be installed and maintained
• Annual gas safety certification must be undertaken by a qualified professional

Housing associations and local authorities with housing stock will be expected to comply with these new standards by 2033, if the proposals are accepted.

What are TPAS Cymru hearing?

When speaking with landlords, it is clear that they are keen to bring properties up to this higher standard, however, the common consensus is that it is incredibly ambitious for such a short time frame, particularly for landlords who need to retrofit their older, less efficient homes. It is arguable that the supply chain needed to achieve this new standard just isn’t currently set up for that scale and pace. There is also the skills gap to consider; we do not have enough of the skills in the UK to get to where we need to be in the time frame that has been proposed.

It is important to note that every landlord is at a different stage with their homes. I mentioned earlier that the overall housing stock in Wales is at EPC D, but that is the ‘overall’, meaning that some is actually at an E and F.

(EPC is generally driven by fuel costs, which means the closer to A you are, the cheaper your energy costs)

This is why landlords are being asked to complete a whole stock assessment and show the plan with the cost and time frames to take that stock and get it to the standard.

Let me give an example, let’s look at Coastal Housing Association. Coastal have 6000 homes, with their overall stock at a high EPC C rating and could therefore be at the forefront of reaching the 2033 targets. Then we look at Swansea council, who have almost 14,000 older homes, with lower EPC ratings, and it seems impossible to meet that target by 2033. Our understanding, is that the current aim is to provide a realistic plan to WG who will then decide if it is acceptable, taking into account those individual differences in their stock profile.

Another important point to note, is that all local authorities have a target of zero carbon by 2030 and whilst this includes their schools, it does not include their social housing.

When looking at other regions, it is clear that Wales are taking ambitious steps in terms of improving the quality of homes for tenants. TPAS Cymru have been and will continue to working closely with stakeholders, including tenants, landlords and Welsh Government to help shape the new standard.

What are TPAS Cymru’s thoughts?

As an organisation, we have been supportive of the ambitious objectives of WHQS2, particularly around the decarbonisation agenda. Through our various range of contact points, tenants share with us that lowering their energy bills is absolutely key. Then taking into account the climate emergency and the decarbonisation of housing, we believe that WHQS2 is the best way to ensure that tenants needs are being met.

Despite the challenges we have mentioned in this blog, we support the proposed timescales for 2033 and are pleased that they haven’t been extended, despite the challenge in brings. We fully support the commitment to Whole Stock Assessments and a Target Energy Pathway by 2026 and we believe it is essential to enable appropriate planning, resources and engagement with the tenant population.

OBSERVATIONS

Produce an Affordable Warmth and Decarbonisation Plan within 3 years is a positive move that we support. However, TPAS Cymru feels strongly that plans need to show real evidence of tenant engagement and tenant consideration of solutions, and approaches. Tenant lifestyle, demographics and awareness also need to be factored into the decarbonisation plan. In addition, we hope that plans will be made available to tenants to allow scrutiny, tracking and accountability.

[Landlords] Provide ongoing updates for affordable warmth and their current carbon emissions on their whole stock. At TPAS Cymru, we welcome this, but would want to ensure that there is complete transparency for tenants and feel that using WG statistical reporting is essential.

WG’s role to facilitate data and experience sharing – Tenants must be included in transparency of data sharing, not just within a select group of technical staff.

The sector would welcome a forum to share learning – We fully support this, but as above, this must include the shared learning of tenants, not just within a select group of technical staff. TPAS Cymru feel that it is also important that housing officers, regeneration teams, any tenant facing teams should be involved in the sharing of best practice as well as lessons learnt. We can support that. We have a Net Zero Engagement officer who is engaging and listening to tenants on this subject. TPAS Cymru has tools like Tenant Pulse and monthly tenant forums to research, test, and receive quick feedback on ideas.

Acceptable fails- TPAS Cymru have always been uncomfortable with a perceived size of ‘acceptable fails’ under WHQS1. Our concern is even greater for WHQS2. We would like to see stronger scrutiny of this subject with independent reviews of exemptions on economic grounds, as well as greater transparency within regulatory reporting.

Disposals- The same principle applies to disposals. Other social housing providers should be offered the property at a discounted rate. Pushing the problem into the private sector where landlords can charge (often the taxpayer via UC), twice social rent for lower standards is not the solution.

If you have any questions, please email Elizabeth Taylor at [email protected]