Housing Strategy

Priority 3 - Improve the Overall Quality of Housing in Pembrokeshire

What the evidence says

‘…..the issue of poor housing is of critical importance to national, regional and local health and wellbeing strategic objectives…’

 

‘….estimated 238,000 dwellings with a Category 1 hazard in Wales, representing approximately 18% of the total housing stock.’

 

‘….older profile of housing and the rural distribution of housing in the county…….linked to comparatively poorer housing conditions……’

 

‘….a home built before the First World War is seven times as likely to have a significant health and safety hazard than one built after 1980.’

 

‘….good data and ongoing monitoring of the condition and energy efficiency of social rented stock held by the council.’

 

‘…….achieved the WHQS for our own housing stock in 2013…’

 

‘……little or no contemporary data on private sector housing, which accounts for approaching 87% of the 63,034 dwellings in the county.’

 

‘…..lack of intelligence on housing conditions across the county preventing a more proactive approach to improving housing standards.’

 

‘….government funding towards addressing housing conditions has been significant reduced..’

 

‘….housing within the remainder of the social rented sector in Pembrokeshire, owned and managed by our partner Registered Social Landlords, meets the Welsh Housing Quality Standard.’

Summary analysis

Public Health Wales’s Wider Determinants of Health Unit identifies the quality of housing as recognised as being one of the key determinants of health alongside factors such as education and skills, money and resources and the availability of good, fair work.

'Housing is one of fundamental building blocks for a healthy life and all aspects of our homes and where we live affect our physical and mental health and well-being' by Public Health Wales – Healthy Housing

We know that the effects of poor housing impact all ages but we also know that older people and children can be more vulnerable to respiratory difficulties alongside poor mental wellbeing and increased accidents due to hazards such as cold, dampness and mould. Falls from trip hazards can lead to early mortality in the elderly and cold housing impacts across all ages with additional economic consequences for low income households for whom fuel poverty is a significant economic challenge. Good quality housing is important to ensuring children in Pembrokeshire have a healthy start in life. Where housing is poor it leads to children suffering from health inequalities and generally poorer outcomes in education and social inclusion. The effects of poor quality housing can carry long term and immediate consequences for the health and wellbeing across a number of indicators.

The costs to public services are also significant with figures reported by Public Health Wales suggesting that poor quality housing in Wales cost the NHS more than £95m per year in first year treatment costs alone and the cost to Welsh society is over £1bn.

• It is predicted that the number of people aged over 65 admitted to hospital because of a fall, is set to increase from 15,024 in 2017 
• 30% of over 65s and 50% of over 80s have a fall each year.
• Allergens and dust mites, which grow more rapidly in damp and humid environments, are an important cause of asthma 
• Overcrowding can lead to psychological distress and mental disorders, especially those associated with a lack of privacy and childhood 
• It is estimated that in England and Wales 10% of excess winter deaths can be attributed directly to fuel poverty.
• Deaths from cardiovascular disease are more likely to occur in cold temperatures. (Ruse and Garlick, 2018)

It is clear that there is a wealth of evidence to indicate that poor housing has significant impacts both on the health and wellbeing outcomes of the population but also represents a significant cost to public services including health, social care and education. Accordingly, improving the condition of housing can result in improved health and wellbeing outcomes for our population with associated benefits for wide ranging public services. However, in order to develop strategies to tackle the consequences of poor quality housing in Pembrokeshire we need to understand the condition of housing in the county.

The last Welsh Housing Condition Survey conducted in 2018 did not report at local authority level, however, amongst its key headlines it found that:

• 23% of homes failed to meet the Welsh Housing Quality Standard
• 9% of homes were in a state of disrepair
• 5% of homes had damp problems
• 7% of homes had condensation problems
• 6% of homes had mould problems
• Older homes are more likely to be in a poor condition than newer homes.
• Older homes are more difficult to keep warm
• 34% of homes built before 1919 were found to contain a Category 1 HHSRS hazard.
• Private rented homes represented the poorest housing in Wales

There is useful data within the WHCS to identify particular trends and risks in relation to the age of property and the incidence of poor conditions. For instance, whilst poor housing is not evenly distributed through the housing stock of Wales we know that rural counties, including Pembrokeshire, contain a relatively high proportion of pre-1919 properties by comparison to more urban areas. There is also a weight of evidence to suggest that conditions in the private rented sector, especially within Houses in Multiple Occupation, can be worse than in the owner-occupied sector. We can therefore recognise the likely risk that a high proportion of our residents are experiencing poor housing conditions by virtue of the age of our housing stock, their housing tenure and the type of accommodation in which they are living. In light of the significant weight of evidence-based research available, we can also determine that households occupying the poorer quality housing in Pembrokeshire are likely to be experiencing the health inequalities and poorer wellbeing outcomes associated with that housing.

However, in Pembrokeshire, whilst we have good information on the overall quality of social housing in the county there is little or no information in relation the age profile or condition of housing within the private sector stock to enable the development of a comprehensive strategy to improve housing conditions in the private sector or to understand the potential savings to health and societal costs in Pembrokeshire.

Our approach

Therefore, an important aspect of our approach to improving the quality of housing in Pembrokeshire will be to improve our understanding of the condition of private sector housing across the owner-occupied and private rented sector. We can then determine the options for seeking to address the identified issues ranging from considering direct financial assistance to the use of statutory enforcement actions or the provision of advice and guidance to owner occupiers and landlords.

Due to the significant reduction in capital funding available from Welsh Government in recent years local authorities have found it necessary to reduce the amount of funding available for housing and other grants to address housing conditions. This coincided with legislative changes, including through the Regulatory Reform Order, that addressed the end of mandatory renovation grants by encouraging a move towards encouraging local authorities to use their discretionary powers towards more flexible assistance policies. Pembrokeshire introduced an updated Housing Grants and Loans Financial Assistance Policy in March 2022 setting out our approach to the award of mandatory and discretionary financial assistance. Whilst setting our support for mandatory and discretionary Disabled Facilities Grants under ENABLE, the policy outlines a range of other support available including:-

• Empty Homes Grants to bring empty homes back into use to help regenerate communities and provide affordable housing
• Home Improvements Loans to support a range of improvements contributing towards making a property warm, safe or secure
• Discretionary Lifetime Loans to support addressing significant Category 1 hazards in a property where the occupier cannot meet the means test for a Home Improvement Loan
• Houses into Homes (Empty Properties Loan) to bring long term empty properties back into use for sale or rent.
• Health and Housing Ancillary Assistance which is dependent upon the availability of e.g. Integrated Care Funding and can be used in the form of a repayable loan for use in interventions which independent living

The policy objectives centre on the promotion of independent living, increasing the provision of homes for residential use as well as improving the condition and safety of housing with the primary aim of the health and wellbeing of residents. Funding is provided through a mixture of grant from Welsh Government and council funding including making use of the funding form the council tax levy to support bringing empty homes back into use. In the context of limited financial resources the policy seeks to make the best use of those resources to deliver home improvements to those most in need. The council will therefore continue to focus its resources on enabling independence and addressing the housing conditions of the most vulnerable through the use of grants and loans set out in our Financial Assistance Policy. However, we need to ensure that we use opportunities for identifying the households most in need through our partnership working across health and housing including through the voluntary sector. This is particularly important in terms of securing the best outcome from limited resources. Examples where this has already assisted intervention has been through our identification of vulnerable households eligible for the Eco-Flex energy grant scheme which has enabled energy saving measures to be installed to address fuel poverty and carbon reduction.

Much of the work of our Public Protection Team (comprising of 2 FTE officers for housing standards) is in responding reactively to reports of poor housing conditions or poor housing management with the consequence that we are unable to measure the impact of our interventions on overall housing conditions nor target our work in a more planned and proactive way. Since 2020, the two officers have dealt with 3510 service requests encompass all housing matters from eviction, disrepair, damp and mould or general queries about the property. Inevitably, whilst we have increased staffing levels in Public Protection more recently to include an Empty Homes Officer, capacity is the biggest constraint, however, we can ensure that we are using our capacity to best effect in targeting issues of highest risk, for instance in using our statutory powers to enforce standards in private rented housing including Houses in Multiple Occupation. We will also use our local knowledge together with supporting information, for instance from the Census 2021, to identify areas where we may want to target interventions or vulnerable households on an area basis, specifically focussing our capacity where there are indications of higher levels of deprivation and identifying particular households in need of advice and support to remedy poor housing conditions.  To support this approach we will develop publicity, including on-line, to raise awareness of how tenants in the private rented sector can access help from Public Protection services to address poor living conditions. A further opportunity to improve housing standards is with proactive engagement with regeneration activities and planning services to ensure conversions and other residential developments meet relevant housing standards. This will require the pre-application process to include consultation with Public Protection to ensure issues such as means of escape from common parts or waste storage are considered and addressed at an early stage.

As part of our engagement with private landlords we will continue to use the Landlords Forum as a route through which we can encourage the raising of property standards and  management standards and help landlord compliance with regulatory and legal requirements by providing guidance and advice.

We have potential opportunities for targeted actions alongside regeneration initiatives that emerge from the Placemaking Plans that have been developed in a number of Pembrokeshire’s town centred through the Welsh Government’s Transforming Towns funding programme. The role of Public Protection in ensuring the proper management of HMO’s and other shared dwellings can support the improvement of town centres where residential dwellings are in disrepair or affecting the amenity of the area. We will therefore engage with economic regeneration and investment plans which emerge from Placemaking Plans as part of our targeted approach to improving standards and increasing the supply of new affordable housing.

We recognise the lost opportunity of empty homes but also understand the negative impact that empty homes can have on the local environment and more generally the impact of empty properties, including space above shops in some of our town centres where Placemaking Plans have been developed. In contributing to improving the overall quality of housing and in supporting investment in the regeneration of areas of the county we will continue to implement the actions set out in the Empty Properties Action Plan 2021-25.

In establishing our strategic and operational approach to improving the quality of housing in Pembrokeshire we will develop a Private Sector Housing Delivery Plan informed by the intelligence we gain regarding the condition of our private sector housing stock. The range of actions that could emerge from the Plan include:

• Our approach to reducing the number of Category 1 hazards in our most deprived areas including how we will engage and work with landlords
• The development of advice and assistance appropriate to owner-occupiers, tenants and landlords regarding general maintenance obligations, home improvement loans, information on equity release, legal rights and responsibilities, access to adaptation grants etc.
• How we will regulate landlords and their agents regarding certain types of tenure such as HMO’s including details on Registration and licensing approaches and obligations
• Targeted advice on the prevention of falls and preventing accidents in the home involving children
• Guidance on the initiatives available to support independent living including home improvement loans and ENABLE grants and loans
• Advice and guidance on our approaches to bringing empty homes back into use including details on how landlords can work with RSL’s and the council on creating affordable homes
• Details on the advice and direct assistance available to address energy efficiency and fuel poverty.

The development of a Private Sector Housing Delivery Plan will help ensure that the council fulfils its strategic role in understanding and seeking to address the condition of local housing in Pembrokeshire.

We will continue to improve the quality and management of our own housing stock through our HRA Business Plan which is refreshed annually. The plan sets out our commitments regarding investing in new homes, however, in addressing the quality of housing it identifies our investment approach in regenerating our existing estate and how we are developing our investment approach towards de-carbonising our homes in meeting government-set targets for council homes. The following key maintenance and investment headlines are set out in the strategy:

• Maintaining WHQS by investing £28.1 million over the next 5 years on renewing kitchens, heating, electrics, re-roofing and bathroom replacements
• Preparing for the introduction of the revised WNQS2 which is likely to impose additional requirements on matters such as de-carbonisation.
• Investing in our non-traditional/hard-to-treat stock through an investment programme that includes tackling de-carbonisation through the Optimised Retrofit Programme (ORP).
• Developing a phased plan for ORP following a Whole Stock Assessment.

Whilst we have good intelligence on our own housing stock the development of a detailed programme to include ORP requires the undertaking of the whole stock assessment to ensure the programme is fully costed and risk assessed taking into account the challenging government targets for de-carbonisation. The expenditure and delivery capacity required to deliver a decarbonisation programme is significant and in the absence of additional funding will impact on spending plans including the potential to reduce borrowing capacity available for investment in new homes.

Our HRA Business Plan highlights the future challenge of meeting WHQS2 on our existing housing stock, including meeting de-carbonisation targets which will also apply to our RSL partners operating in Pembrokeshire. Similarly, ensuring new developments continue to meet Welsh Government’s DQR standards and considering opportunities for the use of Modern Methods of Construction (MMC) apply across the affordable housing sector. There will be opportunities to work together in maximising the efficiency and cost effectiveness of our approaches to meeting these challenges including sharing best practice in delivering technical and cost effective solutions as well as identifying opportunities for implementing MMC strategies. We will therefore establish a joint forum with our RSL partners where we can work together to ensure the development and delivery of best practice across the maintenance, management and development of our housing stock.

Key achievements 

• We have funded the recruitment of an additional Housing Standards Officer to support work in Public Protection and especially in support of delivering empty property grants
• We have allocated match funding of £298,554 towards empty properties grant programme
• We have held 2 landlord forums during 2023 providing advice and guidance on a range of matters including regulation and standards in the sector.
• We have established and delivered a letting agent forum in support of improving standards of management and maintenance through advice and guidance
• Between 1^st January 2022 and 31^st December 2022 we responded to 1,396 service requests to Public Protection on housing condition and tenancy matters including in respect of HMO’s, single family dwellings and on the management of tenancies.

Our priority actions

• P3.1     Work to improve our understanding of and the condition of private sector housing across the owner-occupied and private rented sector.
• P3.2     Develop a Private Sector Housing Delivery Plan informed by the intelligence we gain regarding the condition of our private sector housing stock
• P3.3     Use our capacity to best effect in targeting issues of highest risk, for instance in using our statutory powers to enforce standards in private rented housing including Houses in Multiple Occupation.
• P3.4     Engage with economic regeneration and investment plans which emerge from Place-making Plans as part of our targeted approach to improving standards and increasing the supply of new affordable housing.
• P3.5     Improve the overall quality of housing and support investment in the regeneration of areas of the county by implementing the actions set out in the Empty Properties Action Plan 2021-25.
• P3.6     Continue to focus our resources on enabling independence and addressing the housing conditions of the most vulnerable through the use of grants and loans set out in our Financial Assistance Policy.
• P3.7     Continue to improve the quality and management of our own housing stock through the investment approaches outline in our annually refreshed HRA Business Plan
• P3.8     Share best practice with our RSL partners where we can work together to ensure the development and delivery of best practice across the maintenance, management and development of our housing stock.

Challenges to delivery

• Capacity issues within our services to respond to reactive enquiries whilst also working proactively
• Lack of funding from Welsh Government towards addressing poor standards in the private sector
• Risk of additional numbers of private sector landlords choosing to leave the sector due to licensing, registration or other obligations being placed on their properties
• Ensuring place-based actions bring together the necessary partnerships and funding to maximum effect
• Uncertainty regarding the funding/budget implications of de-carbonisation works required to our stock

Detailing the actions

Taking into account the high level nature of data contained within the Welsh Housing Condition Survey 2018 and our strategic role in understanding the condition of housing in our local area we will investigate the cost and funding implications of commissioning a Pembrokeshire-wide House Condition Survey. This would support the development of our strategies for improving the quality of housing in the private sector.

To deliver against this action we identify the scope of funding availability for:

P3.1.1  Undertake an options appraisal for the commissioning of a Pembrokeshire Housing Conditions Survey (year 1-2)

 

Whilst we have developed an Empty Property Action Plan we do not have a comprehensive and evidence based strategy for addressing conditions in the private sector. Based upon the evidence secured through an analysis of the available data held by the local authority, we will: 

To deliver against this action we will:

P3.2.1  Develop a Pembrokeshire Private Sector Housing Plan (year 2-3)

 

The limited capacity within our Public Protection Team means we have to prioritise and target our interventions towards tackling the most problematic stock. This risk-based approach ensures we can address housing conditions and concerns about management and regulatory compliance to best effect including through enforcement or guidance and advice. However, we can use similar strategies in the identification of vulnerable and other households most at risk of living in poor housing by virtue of other indicators including on an area basis utilising deprivation data and receipt of means tested benefits etc... We have successfully issued guidance to our own tenants and private sector tenants on preventing and addressing damp and condensation in the home and these examples can be more widely used to provide advice and support.

To deliver against this action we will:

• P3.3.1  Take a risk-based approach to using our enforcement and regulatory powers including HMO’s or where there are indications of higher levels of deprivation by identifying particular households in need of advice and support to remedy poor housing conditions. (year 1-2)
• P3.3.2 Use opportunities for identifying the households most in need through our partnership working across health and housing including through our HSG services and the voluntary sector. (Year 1-3)
• P3.3.3  Develop publicity, including on-line, to raise awareness of how tenants in the private rented sector can access help from Housing/Public Protection Services to address poor living conditions. (Year 1-2)
• P.3.3.4 Continue to use the Landlords Forum as a route through which we can encourage the raising of property standards and  management standards and help landlord compliance with regulatory and legal requirements by providing guidance and advice. (Year 1-2)
• P.3.3.5 Develop procedures to ensure Public Protection advice is sought at pre-application stage on conversions or other relevant residential development schemes to ensure appropriate standards are met. (Year 1-2)

The Housing Strategy has identified that opportunities exist for area-based interventions for investment in new affordable housing or regeneration. Housing conditions play a significant part in the economic health and wellbeing outcomes for communities and should form the basis for regeneration investment in targeted town centres. We will also continue to promote our private sector leasing scheme (Leasing Scheme Wales) which enables the local authority to take over the management of private rented property but also invest in improvements to property standards.

To deliver against this action we will:

P3.4.1  Ensure that addressing housing conditions, including opportunities for bringing empty properties back into use are incorporated into investment planning emerging from Placemaking or other regeneration plans. (Year 1-3)

Whilst the actions set out in the Empty Properties Action Plan should be reviewed and incorporated into any Private Sector Housing Strategy we will continue to deliver on the action plan 2021-25

The Financial Assistance policy sets out details on eligibility for and access to the full range of grant sand loans schemes operated by the council. We will keep the policy updated to ensure it reflects any changes to the available grants or additions to the schemes available. We will also engage with our partners in health commissioning to investigate opportunities for co-funding of preventative grants and loans which support independence through addressing hazards in the home.

Details of the investment plans including the overall investment programme and associated financing are set out in the HRA Business Plan. Monitoring and evaluation of progress against the investment plans set out in the HRA Business Plan will continue through the HRA Working Group with regular budget and performance monitoring through Cabinet and Full Council.

To deliver against this action we will:

• 3.7.1    Continue to ensure all new affordable housing development is delivered to WDQS in contributing to overall quality of housing in Pembrokeshire.
• 3.7.2    Through the investment plans set out in the HRA Business Plan ensure we maintain our housing stock to meeting WHQS and prepare for the implementation of WHQS2

We are committed to exploring opportunities for partnership working with our co-providers of affordable housing to ensure we make the most use of our shared resources, expertise and experience in raising the quality of housing to the benefit of our tenants. This is particularly important in developing best value approaches to meeting de-carbonisation targets together with developing the best models for delivering new homes through MMC and approaches to meeting quality standards for new and existing homes. These challenges provide a good opportunity for close partnerships between the Council and Pembrokeshire’s RSL’s.

To deliver against this action we will:

3.8.1    Establish a Technical Forum through which Pembrokeshire County Council Housing Services and our RSL partners can develop and share best practice and best value in delivering quality homes for their residents