G15 responds to Decent Homes Standard for private rented sector consultation

The G15 welcomes the opportunity to respond to this important consultation and supports the government proposal to extend the Decent Homes Standard (the Standard) to private rented, temporary, purpose-built student and tied accommodations as well as to lodgers.

The homes we manage, irrespective of type and tenure, already meet the Standard set for social housing and we believe that all residents should be able to expect, as a minimum, the same standards. As such, we call on the government to reduce, as much as possible, exceptions proposed in this consultation for the private rented sector.

The G15 also supports the commitment to review the Housing Health and Safety Rating System (HHSRS) by the end of 2022. As we highlighted in our responses during the Decent Homes Review, we believe that there are ample opportunities to make the rating system simpler for both landlords and residents.

Whilst we support the government proposal, it is important to recognise that the roll out of the proposed reforms will likely result in a reduction of privately rented accommodations and/or an increase in their rent. This is because private landlords, particularly smaller and non-professional ones, will likely pass the costs they incur to achieve compliance onto residents and/or leave the market. For similar reasons, we also believe that the proposed reforms will have an impact on local authorities’ ability to source temporary accommodation and that, where they succeed in sourcing them, their cost will likely increase.

Whilst, as stated above, the homes we manage, irrespective of type and tenure, already meet the standards, we believe that the government should allow an 18-month implementation period as a minimum. This will enable landlords to carry out stock condition surveys, improve homes that are currently not compliant, and it will provide the market the time to adjust to the change.

Whilst we understand the rationale behind asking local authorities to monitor compliance, we believe that they are already under huge resourcing pressures and that, should the government ask them to carry out this additional monitoring function, further resources should be provided to them.

Finally, whilst we understand that this is out of scope for this consultation, we would like to highlight our suggestion, advanced in our response to the Decent Homes Review, to shift away from focusing on single components in favour of looking at components as a system. This would be similar to what the Fire Safety Act and the Building Safety Act aim to achieve. The new Standard should look at key metrics such as safety and security, fitness for living, affordability and energy efficiency.