LTF Response to the Cave Review of

Social Housing Regulation - Call for Evidence

16.02.07

The London Tenants Federation is an umbrella organisation bringing together borough wide council tenant federations and organisations across London. It is an independent organisation; build on the basis of consensus. It respects the diversity of its membership; does not aim to supersede any of its member organisations but rather to strengthen them though sharing and exchanging information; responding collectively and individually to national and regional government consultation.

During its 4 years existence, with a small grant from London Councils which provides funding for a part time support worker, it has grown in strength and influence. As an example, its September ‘06 conference -Tenants Vision for Housing was arranged, managed and chaired by LTF members with support from its part time worker. It had guest facilitators from a number of the key organisations that LTF members have developed links with through the Housing Forum for London and also had guest attendees and speakers from Europe and further afield including the General Secretary of Habitat International Coalition.

The LTF operates in a democratic and accountable fashion built on formal local authority tenant structures. Its members have an enormous amount of knowledge and experience from the local, neighbourhood and borough level, through to the regional level. Its members are elected through borough wide tenants’ federations and organisations. They have a remit to feed back through their organisations and to bring to the LTF table issues relating to debates held within their organisations. Within its very small budget it aims to be accountable through its member organisations and its newsletter, which is distributed to tenants and residents associations affiliated to borough wide tenants’ federations and organisations and / or borough TP sections.

This response does not respond directly to each question in turn of this consultation – but rather makes some general comments on issues that are of greatest concern to the LTF membership in relation to the issues raised in the consultation papers.

General Comments on the Cave Review

This consultation paper is one a number of recent consultations that appear to be proposing far reaching and fundamental changes to the way in which social housing is delivered and regulated. These consultation papers appear to be driven, not by the needs and demands of those who live in social housing, but by professionals and politicians. That is, in a top down, rather that bottom up fashion.

The LTF has concerns about how these numerous consultations fit together; of what the overall picture is and what the future holds for council and housing association tenants. LTF members fear that rather than enabling change in a bottom up manner as appears to be suggested, that they will result in the continued erosion of tenants’ rights, less choice and less sustainability within communities of social housing tenants.

Certainly it is very clear in London that issues relating particularly to rent restructuring, affordability of rents, increasing land and property prices are impacting detrimentally on social housing tenants. The result is an increasingly marginalised sector. There is fear that low income families – those living in social housing are being forcing to move from their homes and communities as a result of market rather than community led policies.

Despite the inclusion of an ‘Issues paper for residents’, it is difficult to see the paper as being genuinely targeted at tenants. Firstly, the issues are almost exclusively about the RSL sector, making it hard for council tenants to engage with your review. Secondly, with the enormous lack of formal, democratic and accountable tenant structures within the RSL sector, it is hard to see how a genuinely representative view of RSL tenants may be derived from this review.

We would be very grateful for feed back on the number of responses you receive, giving details of the numbers of responses from tenants’ organisations. We would be pleased to work with your review team on an issues paper which was more relevant to the housing needs and concerns of council tenants. We can also assist your review team to engage more with both council and RSL tenants; for example, you might be interested to know that there is a major London conference of RSL tenants on March 26th, about which we can provide more details.

The need for a strong low cost rented sector

The LTF is concerned that social housing is a scare resource as stated in the ‘call for evidence’ and feels that this is a situation that must be addressed through positive investment by central government to support a strong low cost rented sector.

The polarisation of London’s communities has increased as investment in the public housing sector has reduced. There have been huge increases in overcrowding, homelessness and numbers on local authority waiting lists in London.

The LTF questions the Government’s drive to wholesale ownership and feels there must be a right to rent. Renting should be recognised, without stigma as a valid and worthwhile form of tenure for many people and particularly prudent for a large percentage of the working population in London.

The LTF believes that the focus on increasing home ownership has increased the levels of prejudice directed at and stigmatisation of social housing tenants. Creaming off more who will have the potential to part buy will necessarily leave an increasingly economically deprived section of community living in social housing. This works contrary to the notion of creating stable and sustainable communities.

Whilst home ownership is presented as a choice that a majority desire, the fact is that gaining access to low cost rented housing has become increasingly marginalised, so that those who are working have little option but to buy or part buy; despite the economic difficulties this presents for them. Renting in other European countries is a perfectly normal tenure as it was in this country until relatively recently.

The LTF believes that housing is a right for all and not a commodity. Central to housing provision should remain the provision of a stable home base for family life and not become open season for those who see it as a source of profit or who would reduce it to mere collateral against which to increase personal debt.

Evidence of hardship amongst homeowners who are not high income earners is increasing. Leaseholders in every single London borough are suffering from high bills to pay for capital works related to the decent homes standard; forcing more into debt. Recently published figures also show that repossessions across the country have risen significantly.

‘Choice’ and the market

LTF members fear that the emphasis, explicitly expressed in this consultation paper for a greater role for the market, will necessarily result in less democratic and accountable structures and the erosion of tenants’ rights. The main focus of the review relates to the regulation of the RSL sector. The cursory mention of the local authority sector, suggests the intention is further reduction of the role of council housing

The suggestion that the market place is the best way to ‘incentivise landlords to provide improved services’, is not evidenced. On the contrary the outsourcing of services in the local authority sector has neither improved services nor accountability to tenants.

The promotion of ‘choice’ for tenants to change landlord suggested in the ‘call for evidence’ as a proper ‘market’ incentive, demonstrates a complete misunderstanding of the needs and concerns of both council and housing association tenants in relation to their housing. This is evidenced by the fact that so few local authority tenants have any real desire to change landlords or management of their homes. And where this has occurred, it is often as a result of financial incentives being proffered in order to promote a change of landlord rather than this being about genuine choice.

The LTF suggests that rather than ‘greater competitiveness’ in the social housing sector, what is actually required is a greater degree of democratic accountability to those who live in social housing.

The reduction in genuine democracy at the local level has had a detrimental impact on local authority tenants. Particularly of note is the council cabinet structure, where decisions are made in a more enclosed and exclusive environment with little opportunity for community to be involved, and also the increase in the number of quangos or partnerships with have been developed. This has resulted in much reduced levels of democratic accountability and an increased in apathy amongst poorer sections of the community.

The role of tenants

Effective delivery of housing services is dependent on the involvement of tenants at all levels of decision making, as well as the monitoring and regulation of social housing services.

Local authority tenant structures are far more well-developed and sophisticated than those in the RSL sector – enabling engagement not exclusively on housing issues, but those of the wider community at the estate, neighbourhood and borough wide level. In London, the LTF has developed an independent tenant structure built on existing local authority tenant structures that has enabled engagement at the regional level.

Since gaining representation on the Housing Forum for London, (now the Mayors Housing Forum) the LTF has also argued for similar representation for RSL tenants, through the organic development of accountable RSL tenant structures. The LTF’s paper to the Housing Forum for London in September ’05 kick started debate and resulted in the establishment of the Community Engagement Taskforce, now a sub group of the Mayors Housing Forum – dealing with issues of community engagement in the regional housing agenda.

Whilst local authority tenants are not always happy with the services they receive; this relates also to years of insufficient levels of funding for maintenance of local authority homes as well as failures to be heard, when consulted. However, for the majority there is no desire to change landlord. In fact links the LTF has made with independent RSL tenant organisations in London, has found them to have far less; almost minimal engagement in discussion with their landlords around issues outside those relating to day to day management of their homes.

There is a level of transparency relating to formal local authority tenant structures that simply does not exist within the RSL sector where informal consultation structures are the norm. And whilst the LTF is aware of the positive role that informal engagement may have particularly in terms of bringing hard to reach groups into the formal structures, LTF members are keen to see it’s more formal and transparent structures extended into the RSL sector.

The majority of tenants and residents involved in formal local authority tenant structure members are extremely suspicious of focus groups, shopping incentives, sounding boards and other gimmicks that undermine genuine accountable debate and participation in decision making. They find them patronising and unaccountable solutions to problems relating to tenant engagement. They fear that they are used to cherry pick those who will provide the desired responses.

The LTF is of the view that the rights of local authority tenants – in terms of consultation and engagement should be afforded equally to RSL tenants. These should be enshrined in law.

The regulatory system generally must be much more accountable to residents. Many local authority tenants certainly complain that their councils have become much better at the exercise of ticking the right boxes – but not necessarily better at responding to the issues that are important to them.

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