GWSF response to consultation from David Stewart MSP: Proposed Bill on Sprinklers in Social Housing
April 2018
1 Introduction
As the membership body for 66 community controlled housing associations in Glasgow and the west of Scotland, GWSF welcomes the opportunity to respond to this consultation on a potential Bill on sprinkler systems in social housing.
GWSF and its members take very seriously the safety of tenants and residents, with fire safety being a critical component of this. Whilst fire safety has always been extremely important, in the wake of Grenfell it was only right that swift action was taken to assess any immediate risk from the type of cladding which is thought to have had such an impact on the spread of the fire and the tragic loss of life.
Some improvements in fire safety were already being considered well before June 2017, such as the recent move to bring smoke alarm standards in social housing and owner occupied housing in line with the private rented sector. But we recognise the fact that Grenfell has led to fresh reviews of fire and building safety standards and to calls for further improvements, with Mr Stewart’s proposed Bill being a key example.
Below we comment separately on the respective proposals relating to (a) all new build social housing and (b) existing high rise social housing. As an overall comment, however, GWSF would ask that the concern we all share to see fire safety standards as robust as possible is considered carefully and in the wider context of the affordability implications for social housing tenants, who are among the poorest households in Scotland.
We would also argue that whilst we recognise links between levels of deprivation and the likelihood of fires, creating a housing landscape where protection in other tenures is inferior to that in social housing is far from ideal.
2 Sprinklers in all new build social housing
It is ultimately for Ministers to decide whether there should be a higher standard applied to social housing than is dictated for all new housing by the Building Regulations. GWSF notes the position in Wales, and can see that in some respectsthere is a ‘cleaner’ argument for this change compared to the much greater challenges of retrofitting existing stock.
But whilst the sector would fully expect grant levels to be raised in recognition of the increased costs, it is a mistake to think that the higher cost would be entirely covered by grant. For housing associations, new build is funded by a combination of grant and private finance, with the latter covered wholly from tenants’ rents.
The cost effectiveness of greater safety standards is something on which both tenants and social landlords should be able to come to an informed view, and to do so in the context of other pressures such as from welfare reform. The potential introduction of higher standards is also coming at a time when the Scottish Housing Regulator has beencalling for rent increases to be minimised, with some pressure groups demanding that rents are frozen.
3 Retrofitting existing high rise blocks
From the Housing Minister’s letter of 28 March 2018 to Holyrood’s Local Government and Communities Committee, we note that the Building Standards Fire Safety Review, chaired by Dr Paul Stollard, is progressing speedily and is expected to make recommendations to Ministers around the end of May. This review is focusing primarily on high rise housing, and so it will be important to await both the outcome of this and the interim findings from Grenfell before any decisions are made to consult on retrofitting existing stock.
The technical complexities of retrofitting are such that, as the consultation recognises, different challenges arise in different blocks. There may be blocks where retrofitting is especially difficult, and some where it is feasible but very expensive.
With retrofitting, the financial implications for social housing tenants are even greater than is the case for new build. Unlike the system of grant for new social housing, there is no similar grant mechanism for major repairs to existing stock, and so unless this changes, the cost will fall wholly to tenants. And owners in mixed tenure blocks will certainly need financial support if they are to pay their share of the cost. GWSF is not comfortable with the notion (hinted at in the consultation) that in mixed blocks it may only be the flats owned by the social landlord that get sprinklers retrofitted.
Finally, there are longer term funding implicationsof installing sprinklers in either existing or new build stock, as any sprinkler system will need ongoing maintenance and eventually replacement.
4 Next steps
GWSF would be very happy to contribute to the ongoing consideration of the measures in this proposed Bill.