Seòmar agus comataidhean

Evidence submitted by CIH Scotland July 2021

1.  The importance of the housing sector
1.1 Housing plays a fundamental role in the lives of every individual living and working in Scotland andtheCoronavirus pandemic has shone a light onthe importance of access to a safe, warm and affordable home. Housing provides the foundation to support mental health, well-being and help people reach their potential, as well as tackling poverty and climate change. Investing in housing, whether building new homes or improving existing homes, also provides employment and supports the economy. 

1.2 We have identified two areas in which we believe the Committee can play an important role in holding the Government to account,for existing commitments and in helping to develop new priorities. This evidence submission is therefore set out in two sections:

Sector response to developing a right to adequate housing

2.8 The Scottish Government has demonstrated its commitment to realising housing as a human right as part of the Housing to 2040 vision, alongside a specific development of a right to adequate housing.Additionally,the Scottish Government is also carrying out a consultation on the Scottish Social Housing Charter, to help inform and develop a revised version of the Charter from 1 April 2022.  

2.9 We believe that the commitment to embedding equalities and human rights, including the right to adequate housing, alongside the ongoing consultation of the Charter, represents an important opportunity for the Committee to explore how these can be packaged together. In this regard, the Committee can play an active role in setting out its insight and recommendations as to how the Charter can be improved so that equalities and human rights are more determinative and feature more prominently as a priority for landlords and the Regulator.

2.10 This, we hope, would support improved equalities and human rights outcomes for tenants, not only in the context of regulation, but also in terms of resourcing for landlords and the Scottish Housing Regulator to provide appropriate oversight.

2.11 We note that a recent report from ALACHO (Association of Local Authority Chief Housing Officers) has sought to highlight the progress that has been made (or lack thereof) surrounding how the right to adequate housing has been translated into housing police and practice, including resource allocation. Whilst we welcome the recognition by the Scottish Government of equalities and human rights within Housing to 2040, it must act to progressively realise the right. 

2.12 We believe that the Committee can play an important role in building on this report, in gathering further evidence to create more compelling recommendations to the Scottish Government on how housing and human rights can be progressed at the practical level, in line with the Government’s commitment to embedding a right to adequate housing. 

Recommendation: We would encourage the Committee to investigate, gather further evidence and provide recommendations on how the ongoing consultation of the Social Housing Charter could be improved within an equalities and human rights framework, as well as supporting this through adequate resourcing, as well as exploring and considering what new standards the housing sector should be working towards to ensure that the right to adequate housing is realised. 

Our housing workforce and housing as a profession

2.13 There is much to be welcomed from the Scottish Government’s 20-year route map, Housing to 2040. The vision rightly identifies and places much focus on keyissues such as affordability, supply, homelessness, and climate change. Whilst all of this is positive and reflects a number of our priorities, Housing to 2040 places no focus on professional development, succession planning or housing education. If we want to successfully achieve the priorities identified within the strategy, there has to be a corresponding focus on professionalism and supporting housing practitioners to develop the necessary skills and knowledge required to deliver on this ambition. 

2.14 The Scottish Government has already set a precedent surrounding the importance of having a qualified profession, but only in the context of letting agents. If we want to successfully deliver on the ambition in Housing to 2040, we need to have the right workforce, with the right skills, in place. This stands out at a time where we are seeking alignment across the whole rented sector. We are currently looking to carryout an evaluation with the Scottish Association of Landlords to help identify what we can learn from the introduction of mandatory qualifications for letting agency staff and ultimately, how this learning can be entrenched throughout the sector. As part of our work, we will also be launching the professional standards–a voluntary, self-assessment tool to support housing professionals identify what training, qualifications and guidance they need for their professional development.

2.15 Whilst this is all a step in the right direction, it is not enough. Here, we believe that the Committee can play a vital role in auditing whether or not what is in place is sufficient, and whether more steps will have to be taken by the Government.

Recommendation: We would encourage the Committee to consider the appropriate qualifications and standards for housing staff in different roles, in order to meet and deliver on the ambition in Housing to 2040.

Affordable housing supply and subsidy review

2.16 A key part of Housing to 2040 includes the Scottish Government’s plans to deliver 100,000 affordable homes over the next decade, with at least 70% of these forming social rent and against new higher standards with regards to energy efficiency, space and outdoor space. Whilst these ambitious targets and the introduction of a long-term plan for affordable housing are welcome, we have to be mindful of the impact that this may have on tenant’s rents as the cost of housing development in Scotland increases.

2.17 As we seek to deliver more homes, alongside new and improved housing standards, this will inevitably lead to higher costs. Research by the Scottish Federation of Housing Associations this year has found that the average cost of building a new home in Scotland since 2016 has increased by up to 21 percent. Whilst the introduction of higher standards is of paramount importance, it is also vital that the grant benchmarks system is appropriately reviewed so that additional costs are reflected, and we can deliver the safe and affordable homes that the Scottish Government describes in Housing to 2040.

2.18 The Scottish Government must continue to work with the housing sector around reviewing whether any adjustments are necessary for the current subsidy benchmark levels. As we have seen, tenants’ rents are already rising above inflation, and a report from the Scottish Housing Regulator indicates that registered social landlords’ average rents are forecast to increase by around 2.5 percent each year during the period 2021-2025.Thereport from the 2021 affordable housing investment benchmarks working group will soon be published and set benchmarks for the next parliamentary term. Here, the Committee can play a key role in reviewing the work of the subsidy working group, in collating evidence pertaining to what the genuine cost of building is and what impact this will have upon tenants’ rents and equally, poverty over the course of the Parliament.

2.19 In assessing these benchmarks and the projected impact on tenants’ rents, the Committee can play a vital role in auditing the increasing costs of new build as we look to enhance standards and in turn propose recommendations to the Scottish Government surrounding appropriate grant rates that can match these costs. We would also request that the Committee further consider the disparity in grant rates between local authorities and registered social landlords.

Recommendation: We would encourage the Committee to assess the impact of the building programme on tenants’ rents and set out recommendations for grant rates to ensure that rents remain affordable. We would also encourage the Committee to consider the disparity in grant rates between local authorities and registered social landlords. 

3. Supporting priorities and targets in Housing to 2040

Proposed whole rented sector strategy 

3.1 As part of setting out its priorities in Housing to 2040, the Scottish Government has committed to the development of a new cross-tenure rented sector strategy, to drive improvements in the affordability, accessibility and standards of both the social sector and private rented sector. The rented sector strategy forms a vital componentof the Scottish Government’s 20-year route map, representing a long-term housing plan. At CIH Scotland, we believe that this commitment, alongside other priorities, have the potential to transform our housing system. 

3.2 However, we also recognise that central to the success of a whole rented sector strategy is identifying the differential legal and policy basis for standards, where there is scope for further alignment, and how this can be enforced and financed. 

Recommendation: We would encourage the Committee to commit its own enquiry into the viability of a whole rented sector strategy and consider where improvements are needed in both the private rented sector and the social rented sector with regards to standards, services and supply, to inform the Scottish Government’s own strategy and legislation in this area. This may include grounds for recovery of possession, energy efficiency EPC ratings, the provision of white goods and home furnishings, and other relevant services. 

Progressing towards net zero 

3.4 A key focus of our future work will include working towards net zero emissions homes as we tackle the climate emergency. The Scottish Government has committed to reaching net-zero emissions in Scotland by 2045, of which homes account for roughly 16 percent. In order to reach the ambition targets set by the Scottish Government, our homes will have to be energy efficient, with the vast majority switching to low or zero-carbon heating.

3.5 Transitioning to a net-zero nation will necessitate significant investment from Scottish people across all tenures. However, it is not clear that the sector or the public are aware of the magnitude of this investment or what can be expected as we begin transitioning to net-zero.

3.6 Whilst CIH supports the need to tackle the climate crisis and understands the role that housing must play, it is crucial that associated costs with moving to net-zero emissions homes are not passed to low income households, otherwise we may push more people into poverty. As part of its draft Heat in Buildings Strategy, the Scottish Government estimates that the total investment required to decarbonise Scotland’s buildings will be £33 billion+. Whilst the £1.6billion investment pledged by the Government is welcome, this is not enough to prevent the costs being passed onto low income households, increasing the risk of poverty. 

Recommendation: We would encourage the Committee to review how effectively landlords and households can access relevant information, advice and financial support in order to meet climate change targets, and make recommendation for changes in support to support the sector’s transition to net zero.

Who we are:
CIH is the professional body for those working within the housing sector, representing the independent voice for housing and home of professional standards. Our membership across the world is over 17,000, with 13,000 of these members in the UK and 2,000 in Scotland. Spanning all tenures of housing, our overall mission is to support housing professionals to help create a future where everyone has a place to call home.