Mr Tony Cain Secretary Housing Improvement Task Force Housing Division 2 Victoria Quay Edinburgh EH6 6QQ Date: 12 June 02 Dear Mr Cain CONSULTATION FOR THE HITF REPORT AND HOUSING (SCOTLAND) ACT 2001: PART 6 - THE CONSULTATION PAPER ON THE IMPLEMENTATION OF THE IMPROVEMENT AND REPAIRS GRANT PROVISIONS REPORT The Housing Service has recently held a cross-services meeting and looked at the above matter. On behalf of the group, I am pleased to forward the collective comments for your perusal. Please find attached a collective response of Fife Council with regards to the Housing Improvement Task Force Report and the Improvement & Repairs Grants Provisions Consultation Paper. Should you require further information, please kindly get in touch. Yours sincerely Ms Euphene Shek Housing Officer (Private Sector Initiative)
COMMENTS IN RESPECT OF THE HITF REPORT 1) Comments on specific subjects: 1.1 Equity Release It is generally felt there is merit in further investigation of the possibility of adopting a scheme to finance essential housing repairs/improvements using a form of equity release. Such a scheme would benefit especially older owner-occupiers where perhaps there is high equity in their property. A loan could be made available to proprietors to aid repairs/improvements which could be repaid on the future sale of the property. Any such scheme would substantially reduce the funding burden on Local Authorities. 1.2 Means Testing Any introduction of mandatory means testing to determine % grant funding should in the first instance be simple. If the intention is to introduce in certain instances either 100% or high % grants, Councils will require additional finance to be made available to fund such a scheme. If change ~s to be made to the current arrangements this may be premature as further changes may be deemed necessary as a result of the ongoing work being undertaken by the Housing Improvement Task Force. 1.3 Energy Efficiency/Fuel Poverty Local Authorities should encourage upgrading measures for insulation and heating systems when applications are received for repairs/improvement grants. Grant assistance should be made
available and awarded at the same % as the other grant earning works.
2) Housing Improvement Task Force Areas should now be looked at further in detail by the Housing Improvement Task Force are: [a] Look at alternatives to grant aid as a means of providing funding resources to private owners for improvement and repair work to properties. [b] [c] [d] [e] [f] [g] Look at arrangements for allocating finance from Scottish Executive to local authorities for housing improvement and repair grants to ensure that this money is being used for and producing desired improvement and repairs to houses. Look at targeting grants for specific identifiable improvement and repairs within houses. Look at extensions and amendments to the tolerable standard in context of the purpose for which the tolerable standard should be used. Look further at the establishment of an index of housing quality and where this fits in with the tolerable standard in being applied to improving housing standards. Look at where and when notices should be served to require improvement and repairs to property, along with how achieving compliance with the notices can be achieved. Look at how adequate financial resources, from private and public sector, will be available to assist in complying with notices. 3) Local Authority Powers Workshop Comments given by a colleague who attended the workshop: I think that the Workshop held on Local Authority Powers, which I attended, provided a worthwhile opportunity to feed into Stage 2 of
the work of the Housing Improvement Task Force. If the other three Workshops were of a similar format to the one that I attended, then the Housing Improvement Task Force will have been provided with good feedback from those local authorities that attended as to the areas that should now be considered in Stage 2.
I COMMENTS IN RESPECT OF HOUSING (SCOTLAND) ACT 2001: PART 6 THE CONSULTATION PAPER ON THE IMPLEMENTATION OF THE IMPROVEMENT AND REPAIRS GRANT PROVISIONS REPORT 1) Comments on specific subjects: 1.1 Qualifying Works We agree that the minimum standards indicated in paragraph 16 are acceptable in regard to inclusion for the purpose of grant earning works. It should be noted that the reference made in paragraph 16.4 to Technical Standards J3 - J7 is incorrect. It should refer to J3 - J6, as J7 relates to conservatories. 1.2 Means Test See comments made in respect of HITF report. 2) General Comments The comments relate to the various points in the consultation paper on which views are being sought. Paragraphs 15 18 How will the minimum standards for the new categories of improvement work tie-in with the existing minimum standards to be met for grant applications? Will it be a case that all minimum standards must be met for all categories of work, new and -old, or
will applicants be able to choose which category of work they are applying for and, therefore, the minimum standards for the other categories, new and old, will not apply? Paragraphs 15 18 (continued) Reference is made in these paragraphs to the Mandatory Licensing Scheme for Houses in Multiple Occupation under the Civic Government (Scotland) Act 1982. Certain properties may only fall within the HMO Licensing Scheme because of their occupation, e.g. student halls of residence, and these might not normally come within the definition of house within the Housing (Scotland) Act 1987. Further clarification and guidance regarding whether such properties would be eligible for grant assistance would be welcomed. Paragraph 20 The principles proposed for a test of resources appear reasonable. Any test of resources should be based on the same criteria throughout Scotland. Paragraphs 22 24 The reasoning against a test of resources for private landlords, owners of commercial properties or developers is noted. If a test of resources is not to be applied to such applicants, then it should be transparently clear that such applicants would not benefit, by not having a test of resources applied, over any applicant who has a test of resources applied. Paragraphs 25 26 Why should the theory that the applicant would be able to trade down or borrow against an equity on the property to finance essential
improvements or repairs be more applicable to houses above the current Council Tax Valuation Band level for grant, than those that are below this level. It may be equally possible for owners of property with houses in Council Tax Valuation Bands E and below to borrow against any equity in the property. It would appear more appropriate to include property valuation and any outgoings on mortgage payment in any test of resources as an alternative to blanket coverage by application of Council Tax Valuation Band levels.
Paragraphs 27 28 The proposals to use certain benefits as a passport appears appropriate to simplify the test of resources requirement provided the benefits used in such a system are inappropriately means tested benefit. Paragraphs 29 34 Income from joint owners and spouses who are not resident in the property should be taken into account in assessment of income for test of resources. There are cases where families of elderly occupants are joint owners of the property, do not reside in the property but will benefit from improvements carried out. Is state pension included in other income? It would appear that only income is being considered for the test of resources. Is there not a case for including the level of savings and property value in relation to possible equity release as well as income when considering any test of resources? Paragraphs 35 37 As referred to above, the eligible percentage of grant is being set on an income only base test of resources and this will not always reflect the applicants or owners ability to contribute towards the cost of improvement or repairs, as would be the case if savings and possible equity release are also considered. Paragraphs 38 39 Not all applicants will benefit from the setting of a minimum percentage grant as this will still be dependent on local authorities considering certain types of applications -as Discretionary Grants.
I Paragraph 40 40% would appear an appropriate minimum percentage grant. Paragraphs 41 42 No problem with proposed implementation date if this is not considered to be an over ambitious timescale for work still to be carried out. Paragraphs 43 47 The revised advice to applicants is welcomed, provided it is available by the time the new grant arrangements are to be implemented. The provision of a software package could prove advantageous, again if being provided it should be within the timescale outlined for implementation of the scheme. Paragraphs 48 50 Not sure why reference is being made to the grant has not been paid in the two-year period when this two-year period appears to be referring to prior to approval. Paragraphs 51 52 The time periods and arrangements being suggested appear adequate for the circumstances.