Housing to 2040: consultation analysis

Analysis of Question 6. Do you have any proposals that would improve the quality, standards and state of repair of existing and new housing?

Respondents made various suggestions, with the most common themes discussed in response to this question being:

• Repairs and maintenance to existing housing stock
• Adaptations
• Skills development in the construction industry and trades
• Regulation of tradespeople
• Innovative construction models
• Measures to improve the quality of new build housing
• Issues around empty homes.

We discuss each of these themes below.

Existing housing stock: repairs and maintenance

Many respondents referred to the importance of repairs and maintenance in improving the standard of Scotland’s existing housing stock, and some observed that this should be a higher priority than building more new housing.

"Local authorities must invest in older housing stock and not only prioritise new build housing." - Local third/community sector organisation

"We need to think beyond just building new homes as the primary solution to national housing problems." - Architects and design/development organisation and professional/umbrella organisation

Comments related to several aspects associated with repairs and maintenance, including ensuring consistent standards across tenures and between new build and existing stock, as well as suggestions for promoting improved levels of maintenance in Scotland’s existing housing stock. We discuss these issues below.

Consistent standards related to repairs and maintenance across tenures

Many respondents commented on the differences in standards related to repairs and maintenance between social housing and properties that are owned by private landlords or owner occupiers. There was a commonly held view that, while the Scottish Housing Quality Standards ensure high standards in the social housing sector, there were no equivalent standards in the private rented and owner occupier sectors, where standards of repair and maintenance tended to be lower: "Levels of disrepair in the private sector housing stock are stark". The consensus among many respondents was that this was particularly true in the private rented sector, with a view expressed by a minority that "private landlords often focus on maximising revenue income potential rather than longer term asset management which requires capital investment and ongoing maintenance". 

Consequently, there was widespread support for the development of a single set of standards that would apply to all housing, regardless of tenure, to ensure that property owners maintain their housing in a good state of repair. The comments below are illustrative of the responses from many respondents.

"There should be a single set of quality standards across all tenures to ensure standards are of high quality, flexible and adaptable." - Local authority

"Charters [should be] in place for both the social and private rented sectors which set out minimum standards and which continue to be refreshed annually." - National third sector organisation

Some also indicated that these standards should have a legislative foundation so that property owners would have a legal obligation to maintain the housing effectively. 

Some respondents noted that the standards should encompass general repair and maintenance as well as energy efficiency standards. A few referred specifically to the Energy Efficiency Standard for Social Housing (EESSH2) and commented that this should be applicable to private landlords too. One respondent urged the Scottish Government to ensure that the private rented sector is "held to the same high standards as social housing" as "otherwise they will hinder social landlords meeting EESSH2 in mixed tenure common blocks". A few respondents referred to other recent legislative changes that had led to improvements in fire safety in social housing and noted that these should be extended to the private sector too. 

"Private landlords should be held to the same health and safety and energy efficiency standards as social landlords." - Local authority

While most comments related to improvements required among owner occupiers and private landlords, some respondents also noted that investment was needed in social housing stock. 

Consistency in standards for existing housing and new builds

A common view among many respondents was that existing homes should be updated, with repairs and improvements carried out to ensure they meet the same standards as new build properties, particularly in terms of energy efficiency. A few respondents specified that this could involve the installation of new doors, windows, insulation materials and heating systems.

"Support needs to be provided for thermal performance upgrades such as insulation and windows. There needs to be choice and availability of systems for replacing current gas, oil and other carbon-based heating systems." - Architects and design/development organisation and professional/umbrella organisation

A few respondents discussed the specific challenges associated with updating Scotland’s older housing stock from the 20^th century or earlier. 

"A step change is needed to address the challenges with pre-1919 tenements and this requires a more holistic approach to assessing building performance and developing a package of works which includes carrying out essential repairs as well as retrofitting all required elements to decarbonise heat and energy supply and improve thermal efficiency." - Local authority

Financial support for private landlords and owner occupiers to undertake repairs and maintenance

Some respondents noted that owner occupiers and landlords must be encouraged to maintain their properties adequately and some felt that potential resistance from owners and landlords to invest in their properties to bring them up to the required standards is a significant threat to working towards the Housing to 2040 vision.

Suggestions for support that could encourage private landlords and owner occupiers focused on financial assistance including loans and grants, and VAT reform. We discuss these issues below. 

Loans and grants

A common suggestion from many respondents was that the provision of low interest loans and grants could help private landlords and owner occupiers to make repairs. Often, respondents provided little further detail beyond advocating the need for financial support, but a few gave more detailed suggestions such as enabling access to low or zero interest loans, home equity loans and/or grants. Two suggested that the newly formed Scottish National Investment Bank could provide loans for home improvements. 

A few others cited the Scheme of Assistance, which is "critical in maintaining and promoting housing quality in the private sector and should be a key element of any future vision for housing quality, particularly given the scale of private sector stock". One suggested a review of the scheme to evaluate how well it is working locally, and a few others suggested providing more resources for local authorities to deliver the scheme, such as "grants or incentives for private sector repairs". 

VAT reforms

Some respondents noted that charging VAT on repairs to existing properties "is clearly a disincentive" and "actively discourages repair and renovation of existing buildings". There was consensus that VAT on repairs to existing properties should be reduced or removed.

"The Scottish Government needs to address and rectify the inequity of VAT liabilities on existing buildings. We feel that applying VAT on housing repairs, refurbishments, conversions of existing property and not on new build harms retrofitting and refurbishment." - Private landowner

Again, a few respondents commented that the private sector compares poorly to social housing, and the Government could consider how tax incentives or regulations could be used to encourage the private sector to follow the better practice of the social housing sector.

Enforcing the standards

As well as providing financial assistance to support private landlords and owner occupiers to carry out repairs, there was a clear feeling among respondents that more needed to be done to compel owner occupiers and private landlords to maintain their property adequately.

Many respondents called for greater support and/or resources for local authorities to enable them to apply the enforcement powers they have under the Housing (Scotland) Act 2006 where property owners fail to undertake critical repairs. 

Other respondents suggested that local authorities should penalise property owners through, for example, fines, an increase in council tax, or a charge made for compulsory work carried out, where they fail to adequately maintain their housing.

A few felt that local authorities should have compulsory purchase or lease powers where a property is at risk of disrepair to enforce against the neglect and abandonment of our existing buildings. Another suggestion made by a few respondents was to give more power to tenants to compel landlords to carry out necessary repairs, or to carry out the work themselves and deduct the expenses from their landlord.

A few respondents suggested that mortgage providers could play a role in obliging property owners to undertake repairs and maintenance work. One suggestion was made, for example, that mortgage providers should take into account the future repair and maintenance costs of a property when carrying out affordability checks at the approval stage, and another was that conditions related to property maintenance could be built into mortgage agreements. 

In terms of the private rented sector specifically, some respondents suggested that the process for registration of landlords could be strengthened to ensure that they maintain their properties adequately. The view was that the registration process is currently quite light touch, and a stricter system could be implemented. 

"A landlord is not currently required to submit/upload any of the certificates/checks that they are required to undertake when they seek a landlord registration, instead they are only required to confirm that they have done them… this approach allows the less trustworthy landlords to bypass undertaking these checks." - Local authority

"PRS licencing should include a system for enforcing quality standards – the cost of enforcement should be added to the licence cost rather than passed on to the Local Authority." - Local third/community sector organisation

Shared ownership blocks

Shared ownership blocks, with flats owned by different landlords and owner occupiers, were singled out by some respondents as presenting difficulties related to repairs and maintenance. Residents in these properties can encounter difficulties in arranging for repairs to be carried out unless all owners agree and contribute financially, which is not always straightforward. To address this, respondents made various suggestions, including the involvement of factors where appropriate, the introduction of mandatory owners’ or residents’ associations, a local authority-backed missing share scheme, mandatory communal building maintenance funds that owners must contribute to and, where appropriate, the involvement of factors to help facilitate these measures.

Adaptations

Several respondents commented on the importance of ensuring that residents are able to make adaptations over time to their housing in response to their changing needs. This might include creating office space in order to work from home, extending a property to make space for a growing family, and/or adapting a property to react to reduced mobility caused by illness, disability or old age. This is an issue that we discuss in more detail in the analysis of Question 4 of the consultation. 

Skills development in construction and trades

Another theme identified by some respondents relates to skills development in construction and related trades. A few commented on a skills shortage in the sector, particularly as the UK leaves the EU and tighter restrictions on migrant labour are introduced. The importance of Scottish Government investment in education, training and skills in the sector was a theme highlighted by a few respondents. 

"This investment will ensure we have a workforce capable of delivering high-quality buildings and manage and provide high-quality services." - Private landowner

Regulation of tradespeople

Regulation of tradespeople was another issue identified by a few respondents, in terms of:

• legislating for minimum standards of work with penalties for companies that do not meet these standards; 
• providing routes for residents to seek recompense when sub-standard work is completed; and
• ensuring that tradespeople involved in the work have achieved a minimum level of training and obtained recognised qualifications.

Innovative construction models

There was a view among some respondents that making greater use of innovative construction models could help to enhance the quality, standards and state of repair of new housing. Most notably, respondents described off-site construction as a method with the potential to:

• increase quality and standards;
• save time and money; and
• increase productivity and reduce waste.

We also discuss the potential of innovative construction models in the analysis of Question 3.

New build housing

Many respondents made comments specifically related to improving the quality and standards of new build housing in response to this question. 

One suggestion provided was awarding contracts for new build social housing to smaller, local housing builders, rather than relying on a small number of large, national builders. One respondent noted, for example, that small and medium-sized builders might require capacity building support to help them develop bids that can compete with larger builders that employ bid consultants/staff.

A few respondents commented on Housing for Varying Needs, which provides spatial standards for new build social housing. There was a feeling among a few respondents that these standards should be reviewed and refreshed, and extended to the private sector, to ensure that private developers cannot circumvent design standards for reasons of profitability.

A few also commented that there should be more governmental regulation over the quality and energy efficiency of the materials used in new build developments, with a particular focus on reducing the amount of plastic and MDF used in construction.

Some respondents felt that more should be done to ensure that new build developments suit local needs and contribute to the local community. A few noted the importance of ensuring that the views of local communities are taken into account when making planning decisions, and that local authorities are empowered and resourced to enable forms of development which seek to enhance existing places, and to resist poor quality housing that is not sustainable and does not contribute to the quality of our places. 

Some suggested the need for a more formal inspection process for new build homes (in the social and private sectors) to ensure they meet quality standards, along with rights for residents to address snagging issues.

Empty homes

Another theme identified by some respondents was the importance of bringing empty homes back into use which would provide valuable additional housing stock. A few noted that this would reduce the antisocial behaviour and vandalism that empty homes sometimes attracts. A few respondents felt there was a role for central government in supporting local authorities and housing associations to acquire empty homes.

"The Scottish Government must be bolder with enabling legislation such as enforced sale or a quicker, more streamlined version of compulsory purchase once a home has been empty for a period of time." - Local authority

"We recommend an incentive/ enforcement regime to reduce numbers of empty private houses. Support should be enhanced for Local Authorities and Housing Associations to acquire empty private housing." - Health and social care body or professional/umbrella body

A few referred to the Council Tax levy and noted the importance of this in disincentivising owners retaining empty properties.

"The current Council Tax levy on empty homes should be continued and enforced throughout Scotland to deincentivise having these out of the housing system for use." - Local authority

Another suggestion from a few respondents was that local authorities should invest more in empty homes, for example by appointing Empty Homes Officers in every local authority. A few others suggested providing financial assistance to support the re-introduction of empty homes into Scotland’s housing stock.

"We need to provide loans and grants to help bring empty homes back into use. The introduction of the Empty Homes Loan Fund was welcomed but property owners haven’t engaged due to the conditions of the loan." - Local authority