G15’s response to the consultation on Awaab’s Law

We welcome the government’s commitment to improving standards in the social rented sector following the shocking death of Awaab Ishak, which was a shameful moment in the history of the social housing sector. No one should come to harm because of the condition of their home. We share the desire to make sure that such an appalling incident is never repeated, and we want to work with government to ensure these proposals are effective.

G15 members are investing record sums into the condition of our existing homes to ensure that they are safe, warm, and comfortable for residents. Last year, members invested £1.5bn into repairs and maintenance, equivalent to over £2,000 per home, and it’s likely that this figure will be even higher this year. Many members also have bespoke damp and mould processes, which ensure that this serious issue is dealt with quickly and sensitively.

We believe that members already provide a repairs service that meets the proposed requirements in the vast majority of cases. However, we are concerned that the proposals could significantly increase the demand on repairs services without leading to the speedier resolution of hazards. We are concerned that the government has overestimated the capacity in the wider repairs and maintenance workforce to carry out repairs in the timescales it has outlined. This is a particular concern in high-demand areas like London, where we operate.

This also comes at a time of significant financial stress for the sector, where members can only reallocate spending by sacrificing planned works, which we believe would be counter-productive to the overall aim of improving the condition of the homes we manage.

The key points from our response are as follows:

• While we welcome any legislation designed to improve safety standards for residents, we are concerned that, as currently drafted, this legislation may have unintended consequences.

• Properly assessing whether any one of the 29 hazards may pose a significant risk to a resident, while taking into account any vulnerabilities, is complex. If enacted, we are likely to err on the side of caution and investigate a much wider range of repairs within the 14-day timescale than necessary, which would have a significant resource implication and would likely affect our response times on repairs for damp and mould.

• We are concerned about the specific consequences of including certain hazards in scope. A short-term repair is not always an appropriate solution, for example to the overcrowding and space hazard.

• Residents must have legal routes of redress where landlords have failed to meet their obligations. However, we are sceptical about how helpful the legal disrepair process can be. It is often stressful, time-consuming and expensive, and rarely helps residents get their issue resolved more quickly.

• We are also concerned that implementing a subjective threshold for expedited works will result in a surge in spurious legal disrepair claims that are neither in the resident nor the landlord’s interest. We are already experiencing higher volumes of claims from claims management companies and legal firms (many who used to operate in the PPI/personal injury space), who approach social housing residents indiscriminately. We believe it is wrong that money is diverted to profit-making companies rather than spent on residents’ homes.

• It’s absolutely right that landlords are responsible for ensuring the homes they manage are free from hazards, and we have rigorous processes in place to ensure that this is the case. However, we believe that it would also be beneficial to increase resourcing of local authorities’ Environmental Health departments, who have significant expertise in identifying and advising on the appropriate remediation of hazards. Improving funding for these bodies is likely to result in a more consistent and equitable approach than creating additional routes through the courts system for residents to challenge perceived mismanagement.

• We also believe that government has significantly underestimated the additional cost burden these requirements would create for landlords in its impact assessment.

We do not believe that any of these hurdles are insurmountable and are committed to working with government to make Awaab’s Law work.