Almshouse Association seeks Members’ opinions on Government Consultation
The Government has opened a consultation into improving the energy performance of privately rented homes. Whilst almshouse charities are not privately rented homes, the Association is of the opinion that the proposed changes will impact almshouse charities.
The Association believes that there are two questions, numbers 7 and 27, which could potentially impact our members.
We are proposing the following response to each:
7) Do you agree with increasing the cost cap to £10,000 inclusive of VAT as our preferred policy proposal? If not, please explain why not and provide evidence with your answer.
The Almshouse Association would not welcome the agreed increase of the cost cap to £10,000 as this could potentially make energy saving improvements out of the reach for many almshouse charities who would struggle to find those funds independently. The guidance, as it is, requires greater detail on the impact this change would have on almshouse charities who are not private sector landlords. For reference, the official definition of an almshouse is:
The recognised definition of an almshouse is:
A unit of residential accommodation (usually a house or flat) which belongs to a charity, is provided exclusively to meet the charity’s purposes (for example, the relief of financial need or infirmity) and is occupied or is available for occupation under a licence by a qualified beneficiary.
An almshouse charity is typically a charity which is established for purposes which are to be furthered by the provision of one or more almshouses.
An almshouse charity is usually a charity for the relief of financial hardship by the provision of housing and associated services or benefits which must (or is authorised to) provide its primary benefit by the grant of a licence to occupy the accommodation that it owns to its beneficiaries.
In addition, an almshouse charity is likely to have one or more of the following features:
The origin of the charity is a private gift for the relief of poverty;
The beneficiaries are required to pay a weekly maintenance contribution that must not be set at a level that would cause hardship;
The nature of the accommodation is such that the licence requires that beneficiaries must show particular consideration for the needs of other residents;
A significant proportion of the accommodation is permanent endowment;
The beneficial class or the geographical area from which it can be drawn is restricted.
We would suggest that the cap be kept as it is at £3,500 plus VAT.
Alternatively, if the cap is raised then further guarantees of support would need to be introduced to help charitable providers of housing such as almshouses who provide a vital service on the finest of margins. If grants cannot be introduced to cover the full cost of the improvements then there should be no legal requirement for them to make the improvements.
27) Should listed buildings and those in a conservation area be legally required to have an EPC?
The Almshouse Association believes that the current guidance around EPCs and listed buildings needs further clarification. A number of our members provide housing in listed buildings which is a barrier to improving energy standards due to the high cost of carrying out this work within conservation restrictions. The Association does believe that we need to raise energy standards across the sector, but that this must be carried out while respecting each building’s listed status. This process comes with a substantial cost. We believe that unless grants and support can be provided to help make energy improvements, while respecting the history of each building, then listed buildings should not be legally required to have an EPC.
We would welcome the comments of our members on these issues ahead of the consultation’s closing date on 30th December. Members who wish to view the whole consultation can find it here.
Feedback can be sent to Jack Baldan via jackbaldan@almshouses.org
Posted 26 November 20