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ARCH response to Social Housing Green Paper 09/11/2018 Labelled as Development, Consultation, Scrutiny, Legislation

ARCH has submitted its response to the Social Housing Green Paper.


When first announced in September 2017 the then Secretary of State, Sajid Javid, promised that the Social Housing Green Paper "would be the most substantial report of its kind for a generation" based on "a wide-ranging, top-to-bottom review of the issues facing the sector". The Green Paper, when finally published on 14 August contained a mixture of firm decisions, proposals and a series of 48 specific questions for consultation.


Some of the key highlights in the Green Paper include:


  • An announcement that the Government does not intend to implement the Higher Value Assets Levy and forced sale of higher value council housing, proposed under the Housing & Planning Act 2016 and a promise to repeal the relevant legislation when Parliamentary time allows.
  • An announcement that the Government does not propose to implement the mandatory fixed-term tenancies provisions of the Housing and Planning Act 2016 "at this time"; but this wording suggests that they may not be repealed.
  • A strengthening of the role of the Social Housing Regulator and proposals for a set of performance indicators, which would be reported to the Social Housing Regulator, who would publish them in a set of league tables.
  • The canvassing of views on several proposals for reform of arrangements for handling residents' complaints, including statutory requirements on local authority complaints schemes, scrapping or shortening the waiting period before a complaint can be referred to the Housing Ombudsman, training for "designated persons", and raising residents' awareness of how to make and escalate complaints.
  • A commitment to tackling the stigma attached to social housing, with proposals for a "best neighbourhood" competition and steps to improve the customer service and neighbourhood management provided by all social landlords.
  • The potential re-introduction of stock transfer for council housing to "community led" housing associations, reform of the Right to Manage arrangements, or other measures, in giving tenants more choice and control over the services they receive.
  • A question as to whether the Decent Homes Standard needs to be revised or updated in the light of Grenfell and other developments since 2006
  • The potential introduction of debt funding and longer term "strategic partnerships" to help housing associations develop affordable housing.
  • Further promotion of shared ownership by allowing tenants to purchase as little as 1% share in their home.


Conspicuous by its absence in the Green Paper was any proposal for further lifting of Housing Revenue Account debt caps, to allow councils to borrow prudentially against their assets and future rental income streams to fund further investment in the existing stock and the building of new council housing. However, the Prime Minister subsequently announced at the Conservative Party Conference that the Government intended to scrap the HRA borrowing cap.


The scrapping of the HRA borrowing cap was subsequently confirmed in the 2018 Budget and the HRA cap that controls local authority borrowing for house building was abolished, with effect from 29 October 2018.


The Green Paper also proposed the setting up of a pilot with a small group of social landlords, who would innovate and trial options for communicating and engaging with residents on safety issues. ARCH was contacted by officials from MHCLG seeking to facilitate arrangements for site visits to a number of local authorities with high rise blocks and on 26 October, the Government issued a formal invitation for expressions of interest from social housing landlords to participate in a Social Sector (Building Safety) Engagement Best Practice Group.


The Regulator of Social Housing invited the ARCH Chief Executive to a meeting on 31 October to discuss the Green Paper and in particular the elements of the Green Paper regarding future regulation of the sector. We have extended an invitation to the Regulator to attend a future meeting of the ARCH Board and the ARCH Tenant Group to discuss regulation and performance indicators.


We have also continued dialogue with HouseMark, the National Federation of ALMOS (NFA), Councils with ALMOs Group (CWAG) on how the sector might develop a workable set of performance indicators and have involved the Local Government Association (LGA), National Housing Federation (NHF) and the Housing Ombudsman in those discussions.


In preparing our response to the Green Paper, we issued invitations via email to ARCH member councils to submit their views and comments.


The ARCH Tenant Group was also invited to consider the Green Paper and input their views and comments, to help prepare the formal ARCH response and a special meeting of the ARCH Tenant Group was held on 15 October.


A workshop for ARCH Board members was subsequently held on 19 October to consider the response to the 48 questions posed in the Green Paper and the ARCH Tenant Group's views were fed into that workshop.


A final draft response to the questions was circulated to Board members for comment prior to formulating the final ARCH response to the Green Paper.


Read the ARCH response to the Green Paper


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