Welsh Housing Quality Standard (WHQS)
Social Housing Bill
The existing Standard WHQS has been in place for over two decades. It was felt that it requires updating to reflect changes to how people live, work and feel about their homes. It also needed to factor in decarbonising the Welsh social housing stock at scale.
In May 2022 Welsh Government sent out consultation documents to all Social Landlords in Wales for them to provide feedback by 3rd August 2022.
Welsh Housing Quality Standard 2023 [HTML] | GOV.WALES
Welsh Housing Quality Standard: draft (gov.wales)
In early February they published the findings.
Wavehill were commissioned to analyse the findings and have produced this report.
Welsh Housing Quality Standard Consultation (gov.wales)
Here are some key statistics from the report which have particularly focused on the retrofit element of the report/standard. There were 202 fully completed responses of which 105 tenants and 32 social landlords.
- 91% of social landlords felt that the new proposed Standards fails to strike a good balance between being bold and being achievable. In contrast, 79% of tenants agree that the Standard achieves a good balance.
- Less than half (46%) of all respondents considered the timescale appropriate. Of those who disagreed, almost all of them believed that the target outlined in Part 3 (Homes must be affordable to heat and have minimal environmental impact) of the Standard was too soon. Most social landlords (94%) disagreed, as did technical experts (63%) and representative bodies (60%). On the other hand, tenants were mostly supportive (62%).
- The proposals suggest using Environmental Impact Rating (EIR) as a measurement to assess the carbon emissions of homes. An EIR is based on a calculation of annual carbon emissions from heating the home and water, ventilation and lighting, minus emissions saved by energy generation at the home. Overall, 85% of all respondents agreed with the measure. Whilst most technical experts were in agreement, 38% disagreed.
- Where achieving EIR 92 within an individual home may be too difficult and/or costly, the proposals suggest that social landlords could balance that with more efficient homes that achieve a higher rate, or alternatively, through other defined Community Carbon Benefits. This provides landlords with a flexible approach to achieving net zero across their stock. There was broad support from tenants for this proposal, at 95% and representative bodies at 80%. In contrast, only 25% of social landlords and 38% of technical experts agreed with this target.
- Social landlords sought further clarification on funding that would accompany the proposed Standard. The findings suggested that additional funding would support planning and enable more detailed understanding of feasibility of the proposals in terms of both scope and timescales.
- While respondents recognised that they are not perfect and several solutions were presented as alternative options (such as using a kilowatt hour approach), there was a clear feeling that the EPC and SAP methodologies were considered by respondents the best available tool. This was considered the right approach given the level of standardisation and widespread recognition across the UK. However, technical experts provided notes of caution when using SAP methodology, such as ensuring a degree of flexibility to allow for the possibility in future to include other measures or alternative metrics as they evolve. From these perspectives, the SAP/EPC approach was considered by technical experts to be limited in its ability to guide responses because it models the energy efficiency of a home against a set of benchmarks which may be subjective.
- Some respondents voiced concern that the proposed Standard could lead to some landlords taking a “path of least resistance.” This means that without sufficient incentive, they may assess that it is more cost-effective to simply dispose of older properties which require a lot of work and costs to meet the EPC A rating.
We now await Welsh Government to issue the final version of WHQS 2023, which will no doubt have implications for all social landlords across Wales.
If you would like to know more, please get in touch with Katie Carey, Procurement Manager (Wales) kcarey@chicltd.co.uk
