Apr 20, 2022

Decent Homes Review – SHIFT Environment response

Decent homes

The Department of Levelling Up invited us to comment on their review of the Decent Homes Standard so far and here’s a summary of our response.

As a team of professional environmentalists, we carry out annual environmental assessments for around 60 UK social landlords.  As part of these assessments, we see growing environmental issues affecting the landlords we work with. These include:

  • Increased flood events
  • Increased overheating events
  • Increased fly-tipping
  • Water stress meaning increased engagement with water companies
  • Biodiversity and green spaces are anticipated to have an effect as regulation is introduced

The Decent Homes Standard (DHS) is an ideal way to tackle these issues, especially given its success at improving homes when it was first introduced.  We are firm believers in the adage that “you can only manage what you measure” and we urge the standard to contain reporting metrics that address these environmental issues.

Our responses were limited to environmental issues.  Our full response gave detailed answers to the questions posed, but in summary:

“Ventilation, particularly in the context of damp and mould (ensuring appropriate appliances are installed to facilitate air circulation)”  – As well as tackling damp and mould, ventilation has a key role to play in overheating and being prepared for projected heat waves.  We note this is part of the “thermal comfort” issue and the document states that the interaction of “thermal comfort” with other decarbonisation issues is being explored.  However, there is no specific mention of overheating risk.  Given the overlap of ventilation and overheating risk we believe quantified “overheating risk” should be introduced as part of thermal comfort in any new DHS.  The degree of ventilation will be part of that quantification.

“Home security (ensuring suitably robust doors and windows are fitted)” – We note that home security is a crucial issue, and we urge that flood risk and adaptation be considered as part of any new DHS.  Flood risk is real, and we note the rise of flood incidents amongst our clients.  It causes misery and disruption to residents.  Again, flood risk is a quantifiable metric that we believe should be reported via new DHS.

Refuse management (to improve neighbourhood management and upkeep, and the quality of shared spaces) – Our clients note the rise of fly tipping incidents and national figure indicate stagnation on recycling levels.  Therefore, this is a crucial and quantifiable issue to be included in DHS reporting.

Water efficiency (to improve energy efficiency of water heating) – We welcome this inclusion.  Again, this is a quantifiable metric that should form part of a new DHS.


Thermal comfort – we note that “thermal comfort” is recognised as a crucial element of decarbonisation and climate change.  However, given the importance of the issue we urge that it is included in the new DHS.  The sooner it is regulated, the sooner it will inspire at least “no regrets” works to be initiated.  This will avoid overloading landlords with too much retrofit works at a later date.

Green spaces – this does not seem to be addressed at all, even though it formed a significant part of the Social Housing White Paper.  Specifically, the White Paper rightly identified “COVID-19 is also showing the importance of access to safe, open and green spaces for people’s wellbeing. The importance of access to green spaces for exercise and mental wellbeing is especially important for those without private gardens.”  In addition, we have found that larger and better green spaces contribute to better air quality, more biodiversity, better summer cooling, flood attenuation and increased carbon sequestration.  This is a quantifiable metric that should be included in a new DHS.


We welcome the potential to update the DHS to improve the wellbeing of residents in rented accommodation.  We strongly recommend that updates should be via the regulatory avenue rather than guidance only.  There is a unique opportunity to tackle highly important environmental issues in any update.  Furthermore, we recommend metrics approach to DHS annual reporting so that all the issues can be tackled via a “manage what you measure” approach.  To be effective we also recommend that environmental issues be reviewed by third party appropriately qualified professionals.

If you would like to see our full response or advice on how to take a metrics approach to environmental improvements, please get in touch.


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