Almshouse Association Response to the Energy White Paper

The Almshouse Association welcomes all efforts to create a greener, more energy efficient society. To safeguard our future we must take on this task with the strongest will and determination. The Energy White Paper forms an initial part of this effort, but it does not provide enough information to reassure many of our members.

Many of our members are investing in new, green improvements to their properties through schemes such as the Green Homes Grant. This support will be vital in ensuring members can take that first step towards more energy efficient almshouses. However, the size of the task at hand is of such scale that this grant alone will not suffice in the long term.

Due to the historic nature of almshouses, a large proportion of our members across the country oversee listed buildings. Improvements to these buildings requires a high level of skill to maintain the integrity of the building. This skill comes with a high cost, a cost which many charitable providers of housing just cannot afford.

The Almshouse Association is ambitious to see a green revolution across the almshouse movement, not only because it is good for the planet, but because it will improve the lives of almshouses residents. Improved energy efficiency will not only reduce costs but will also improve the comfort and health of residents. However, we cannot achieve these improvements alone and so we need further clarification from the Government on additional unique support which can be provided to almshouses.  

This could include:

• Targeted funding for historic and listed buildings through trusted, registered providers who can bring these buildings into the 21^st Century, whilst respecting the building’s natural heritage
• Longer deadlines to become EPC compliant as many would struggle to bring themselves into line with an EPC C by 2035 without other interventions
• Exemptions to continue for buildings which have proven attempts to improve energy efficiency. Currently, if £3,000 is invested in energy improvements and the EPC is still below requirements, an exemption is granted. If alternative support cannot be provided then some would have no choice but to seek an exemption.

We look forward to working with the Government on these proposals so that almshouse charities can be clear as to their role in our greener future.

Members may wish to view the full White Paper here.

If you have any thoughts on the proposals then please email Jack Baldan at jackbaldan@almshouses.org

Posted 15 December 20

Each month, the Association posts a news summary of the latest Policy and Governance legislation that could impact / requires action from our member charities, with links to further information where applicable. Please find below our November/December 2020 Summary.

Ministry of Housing, Communities and Local Government

• Protection for renters – MHCLG have reiterated the protections for renters, apart from exceptional circumstances, from eviction during national restrictions and over the Christmas period. Evictions cannot be enforced by bailiffs until 11^th January, with the 14 days’ notice required meaning that no action should be taken before January 25^th.

• Spending Review/LHA Freeze – The Chancellor made a number of announcements during the annual Spending Review. This year the review only provides funding to Government departments for one year, rather than the usual three years. The most significant announcement for almshouses is that Local Housing Allowance rates will be frozen from April 2021. This decision will result in as cut in housing benefit when taking inflation into account.

• Immigration and Social Security Co-Ordination (EU Withdrawal) Act 2020 – The Government has passed its reforms to immigration ahead of the end of the Brexit transition period. The new rules:
  • End freedom of movement
  • Make EU, EEA and Swiss citizens subject to UK immigration controls
  • Makes a provision to protect Irish citizens’ immigration rights
  • Provides a power to amend retained EU legislation relation to social security co-ordination
  • Any members who employ EU nationals should look into how the change in law may affect them.

• Universal Credit direct rent payments to social landlords – A change has been made through the Universal Credit Landlord Portal so that social landlords receive direct rent payments on the same cycle as their tenants receive their benefits. Members may wish to make themselves familiar with this system if they feel it would help them more easily collect their WMC. It should be noted that applications to enrol on the system are currently closed.

Coronavirus

Christmas Bubbles

Guidance has been published regarding Christmas bubbles which can be formed between December 23^rd and 27^th. The Government announced that three households can meet during this period to celebrate Christmas. The following points are also worth highlighting:

• You can only be in one Christmas bubble and cannot change your Christmas bubble
• You can travel between tiers and UK nations for the purposes of meeting your Christmas bubble
• You can only meet your Christmas bubble in private homes or in your garden, places of worship, or public outdoor spaces
• You can continue to meet people who are not in your Christmas bubble, outside your home, according to the rules in the tier where you are staying
• You cannot meet someone in a private dwelling who is not part of your household or Christmas bubble
• You must not form a Christmas bubble if you have coronavirus symptoms or are self-isolating.
• Existing support bubbles count as one household towards the three-household limit
• If someone is in your Christmas bubble, you can visit each other’s homes and stay overnight, including in private rented accommodation. You can also go to a place of worship together, or meet in public outdoor spaces. You cannot meet your Christmas bubble in any other indoor setting, such as a pub, hotel, shop, theatre, or restaurant.
• You may form a different Christmas bubble from the people you live with normally. If you and the people you are living with want to be in different Christmas bubbles, you can choose to stay somewhere else with different people for this period and form a Christmas bubble with that household and one other household (this will count as three households) – guidance here
• The guidance notes that “forming a bubble if you are vulnerable or clinically extremely vulnerable carries additional risks – see advice for clinically vulnerable people”

Previous Policy and Governance Updates:

Policy and Governance – October 2020 Summary
Policy and Governance – September 2020 Summary
Policy and Governance – July/August 2020 Summary
Policy and Governance – June 2020 Summary
Policy and Governance – May 2020 Summary
Policy and Governance – Apr 2020 Summary
Policy and Governance – Mar 2020 Summary
Policy and Governance – Feb 2020 Summary
Policy and Governance –Jan 2020 Summary
Policy and Governance – 2019 Summary

Posted 11 December 20

76% of the general public view almshouses as an important form of housing, according to YouGov*

Research carried out by YouGov, on behalf of The Almshouse Association, found that 76% of respondents believe almshouses are an important form of housing, but … 84% of people were not aware of any almshouses in their local area.

The research forms part of The Almshouse Association’s plans to establish a better understanding of almshouses amongst the general public and in Government. The Association is proud to see respondents recognise that almshouses are a vital part of the housing sector. However, the research also highlighted challenges ahead for the almshouse movement. It is clear that many people (84%) are not aware of a local almshouse, and whilst more than half of over 55s had heard of almshouses, overall, 65% of those who undertook the survey, were not very clear on what an almshouse actually is. Members will no doubt be familiar with this challenge.

At The Almshouse Association, as we approach our 75^th anniversary in 2021, we will embrace this challenge.

We will use our anniversary and your community events to push for wider recognition of your work and greater understanding of the vital service that almshouses provide across the country.

*All figures, unless otherwise stated, are from YouGov Plc.  Total sample size was 2001 adults. Fieldwork was undertaken between 18th – 19th November 2020.  The survey was carried out online. The figures have been weighted and are representative of all GB adults (aged 18+).

Posted 30 November 20

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 30^th 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

The new Value for Money (VfM) Standard, which took effect from April 2018, requires registered providers to report against a prescribed set of VfM metrics.

The Almshouse Association recently held a webinar for members entitled Demystifying VfM: Regulatory requirements and what you need to do.

We recorded the webinar and have made the accompanying powerpoint slides available so that all members can have access to the guidance at their convenience. Click in the links below to download:

• Webinar recording
• Powerpoint slides

The webinar was hosted by The Almshouse Association and presented by Steve Smedley, Associate Director at Acuity. Acuity provides resident satisfaction and customer research, performance improvement, learning and development, and consultancy to the social housing sector.

Posted 25 November 20

Following a concerted campaign by The Almshouse Association and with help from individual members, the Government has agreed to include existing almshouse buildings in the Exempt class of the Heat Network (Metering and Billing) Regulations 2014.

The Government agreed with the Association’s argument that it would not be cost-effective to install metering devices and bill based on consumption.

This news is also important for the continued wider almshouse movement as it is the first time that the official definition of almshouses has been referenced in an official government document and noted in legislation. This marks a major milestone in our journey of promoting almshouses in the 21^st Century.

Exempt Class includes:

“An existing building where the building (or part of the building) is supported social housing, almshouse accommodation, or purpose-built student accommodation.”

As a consequence there is

“No requirement to install metering devices for customers (no assessment of technical feasibility and cost-effectiveness is required as the outcome is expected to be negative)”.

In addition the mandatory billing requirements will not apply.

However, if an almshouse charity is building new almshouses they will fall into the Open Class.  Buildings in the Open class must have meters or heat cost allocators installed unless it is assessed not to be technically feasible or cost-effective.

The regulations come into force on 27 November 2020

Note: The other aspects of the regulations still apply and almshouse charities will still need to notify their Heat Networks under Regulation 3 which states that:

“A heat supplier must submit an updated notification within four years of the date of the first notification submitted and within every four year period thereafter from the date of the previous notification.”

Many members will already be aware of and abide by this regulation.

The Government’s response to their consultation, including the recommended amendments, can be found here.

Full guidance on the regulations can be found here.

Posted 16 November 2020. Updated 23 November 20