Seòmar agus comataidhean

Dear Ms Burgess

Many thanks for your letter of 1 July, and please accept GWSF’s best wishes on your appointment as Committee Convener. We very much look forward to working with you and your colleagues on the Committee, as we have done with your predecessors in the past.

Brief background on GWSF

GWSF is a membership body for 64 community based housing associations in Glasgow and ten other local authority areas across the west of Scotland. As well as providing high quality housing and housing services, our members are often seen as community anchor bodies who have an intimate understanding of the local community’s wider needs.

This has manifested itself most obviously during the pandemic, when around two thirds of our member associations have been able to apply for, then distribute, invaluable Scottish Government Covid funding - initially to provide emergency help (e.g. with food and fuel support) in the early days of the pandemic, and more recently to support longer term recovery.

We would be very happy to provide the Committee with further information on our members’ activities in support of Covid recovery if this would be helpful.

Mitigating the impact of Covid on local housing associations

Priding themselves on being closer to tenants than might be the case with larger regional or national housing associations, our members have worked intensively, from the early stages of the pandemic, to contact tenants to see if they are OK and whether they are (or expect to be) having difficulty paying their rent. Whilst this work obviously has not prevented arrears arising, Covid data returns made by all social landlords to the Regulator demonstrate the success of this approach:

Our members’ efforts to work with people to mitigate their arrears (for example by making a Universal Credit claim) mean that the worst arrears tend to come from tenants who are either not engaging at all with their association, or (in a small minority of cases) tenants who refuse to pay rent and believe there are no sanctions which can be used against them. For these households, the longer notice periods (which remain in place) and the evictions ban (which has ended) may have reinforced a perceived message about a lack of sanctions.

Even with the lifting of the evictions ban, our members - and the courts – continue to see eviction as a very last resort, and will always be keen to work with tenants to come to a suitable repayment arrangement and sustain the tenancy.

Our members have also played a highly proactive role in supporting local authorities to meet their homelessness responsibilities during the Covid crisis. In Glasgow this has led to record lets to homeless households during 2020-21, and that success is continuing into the current financial year.

Further priority issues for GWSF

Our 2021 Election Manifesto summarises the issues of greatest importance to GWSF members, but by way of highlighting some key issues for the Committee’s benefit, we would identify the following as being among our top priorities, and would be delighted to support the work of the Committee should it choose to look into any of these in greater detail in its forthcoming work programme.

1 Social housing’s role in reducing carbon emissions

The Committee will doubtless be studying the report of the ZEST (Zero Emissions in Social Housing) Task Force when it is published shortly. GWSF was part of the Task Force and commends the key recommendations

Our member associations have a good track record in proactively contributing to improving energy efficiency standards and addressing fuel poverty among tenants. But the future challenges are even greater, because:

as we seek to further improve energy efficiency, the law of diminishing returns applies – more needs to be invested to make relatively modest improvements and bring relatively small reductions in fuel bills, and

the move to installing renewable heating systems (such as heat pumps, heat networks), which are invariably more expensive than gas-based systems, are likely to increase fuel costs, with no obvious means by which the Scottish Government or other partners in Scotland can prevent low income people in social housing being disproportionately hit because social housing sector is taking the lead in driving forward change.

The poorest energy efficiency levels are in privately owned housing, and there is three times more private than social housing in Scotland. This makes it especially critical that minimum energy efficiency standards for home owners, which have consistently been shelved in recent years, are progressed, despite the obvious political and cultural reluctance to tell home owners how to run their affairs.

2 Improving our tenements

Tenements come in all forms, and traditional pre-1919 tenements are part of our urban heritage. Levels of disrepair in commonly owned tenements are significantly greater than in self-contained owner-occupied property. The future of tenements is of great importance to community based housing associations, who have a good track record of working closely with our local authority partners to try to address disrepair in mixed tenure blocks (and, in some cases, in fully private blocks).

A radical new Scottish Government approach is needed to supporting councils and housing associations to further address chronic disrepair in mixed tenure and privately owned tenements. 

 Alongside medium and longer term legislative change in line with the 2019 recommendations of the Parliamentary Working Group on Tenements, ring fenced funding is needed for local authorities to enhance their capacity to offer the right mix of carrots and sticks to owners who may be unable or unwilling to pay for their share of essential works. 

This issue links directly with that of reducing carbon emissions from housing. Without a radical approach to repairing the structure and fabric of our tenements, widespread improvements in energy efficiency in mixed tenure and privately owned stock are unlikely.

3 Monitoring the true costs of providing high quality new build social housing

Community based housing associations look forward to making a significant contribution to the new five-year programme to provide 50,000 social and affordable homes. We imagine the Committee will be keen to monitor the progress of the programme as councils and housing associations grapple with a new set of challenges:

Homes newly approved this year and beyond will need to meet a range of new standards, including on energy efficiency, internal and external space, the installation of fire suppression systems

As a result of both Brexit and Covid factors, providers are currently facing what we hope are temporary delays to the supply chain, resulting in shortages of components and labour: inevitably this will bring increased costs

Benchmark grant levels for the programme are in the process of being decided. These are not grant ceilings, and serve mainly to determine whether a project is fast-tracked or (if it exceeds benchmark) subject to a more detailed technical appraisal. The Scottish Government believes the proposed new benchmarks will result in a majority of projects not needing a detailed appraisal, but neither GWSF nor any of the other representative bodies on the Benchmarks Working Group believe that this will be the case. This may affect the momentum of the programme, and we think the benchmark grant levels will need to be reviewed sooner rather than later within the five year programme.

GWSF would be very happy to assist the Committee in any way possible, both on the above issues and on the wider range of issues we imagine the Committee will be looking at as part of its work programme.