«Name» «Address1» «Address2» «Address3» «Post_Code» 15 February 2021 Dear «Name», Re: Communal Heating System Complaint from tenants via PPR I refer to your complaint received on 11 November 2020 regarding the communal heating system at Bleach Green Court. As this complaint was sent via Participation and Practice of Rights (PPR) we have continued to engage your representatives at PPR as well as contacting tenants by telephone to discuss individual concerns. In addition to the complaint, Choice also received an environmental information enquiry on 11 November 2020 via PPR requesting information regarding the environmental impacts of the heating system under the terms of the Environmental Information Regulations (EIR) 2004. Specifically: 1. logs of all use of the telecare alarm system to report lack of heating at the facility 2. logs of all maintenance and repairs carried out to the heating system at the facility by Fusion and other providers 3. logs of reports by the facility coordinator of heating issues raised by residents 4. an itemised breakdown of heating costs at the facility. Choice can advise that in response to the EIR request all required information was provided on 9 December 2020, within the specified 20 working days. I appreciate however that there has been a delay in issuing the final response to this complaint. Nevertheless, the Association has continued to keep residents and their representatives, informed throughout our investigations and we would like to thank you for your patience. We have conducted a thorough comprehensive complaint investigation which included: • • • •
liaison with tenants regarding heating system individual assessments by the heating contractor, checking functionality and operation of individual controls and system overall, and continuous monitoring of heating system over the period liaison with independent energy body to provide feedback on heating costs efforts to organise a video link meeting with tenants and representatives. However it was agreed by all parties in light of Government guidance and restrictions as well as a positive covid case being presented at the scheme, actions that may potentially encourage any residents to gather should be deferred for safety reasons.
Having assessed the complaint the Association has determined that it relates to the following issues, which will be addressed in order: a. Concerns that the heating system does not meet a range of international and domestic standards b. Tenants asking for a “reasonably priced heating system that you can control and keeps us warm during the winter.” c. Tenants have to pay for heating even when not at home e.g. on holiday. d. Tenants do not receive a breakdown of heating costs. e. Heating is turned off at night and comes back on in the morning f. Tenants have no control over settings.
a. Concerns that the heating system does not meet noted international and domestic standards In your letter you have referred to a number of international and domestic standards and it is suggested that the system in Bleach Green does not meet the standards specifically: •
International law - Right to adequate housing - Habitability Component – right to be protected from cold and damp. We can advise that the system provides warmth and there are no damp issues at the scheme and as such we are satisfied that the habitability component standard is met.
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International law - World Health Organisation Principle 2 - protection from injuries and disease, draws attention to the importance of adequate and efficient heating in cold weather. We are satisfied that the heating provision is efficient and sufficient at the scheme throughout the year.
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Domestic standard - Decent Home Standard - requirement to provide reasonable degree of thermal comfort and provision of individual control of the timing and temperature of the heating. We can confirm that heating levels provide thermal comfort and all residents have individual controls to regulate the temperature of the heating. We can advise that the heating system in Bleach Green is not therefore in breach of the Decent Home Standard.
b. Tenants asking for a “reasonably priced heating system that you can control and keeps us warm during the winter.” During our investigations Choice examined the overall costs to tenants over a 3 year period. This information was shared with PPR through the EIR and confirmed that tenants pay varied amounts according to their own usage. It was noted in your letter that tenants pay £10.39 per week. Choice charge each tenant a heating charge of £6.16. This is then reconciled quarterly to reflect the actual heat being used within your flat and to cover the full cost of Natural Gas for Bleach Green Court. The weekly heating charge is reviewed each year.
The Association believes that the heating system at Bleach Green is a reasonably priced heating system and it operates as it should during winter. To clarify, tenants pay a set weekly amount initially, which is in place to help with budgeting throughout the year and heating statements are sent out periodically to reconcile this against usage. Part of the charge is based on actual heating used within each flat from a heat meter and the remainder is a proportion of the actual gas charges for the scheme, to cover hot water use and the cost of generating and distributing heat around the scheme. Further to tenants’ concerns Choice liaised with National Energy Action (NEA) NI, who are the national fuel poverty charity seeking to ensure everyone is warm and safe at home. Choice advised NEA of the average heating costs for residents of Bleach Green and explained how the system was installed and operated. NEA has confirmed that the system is economical and raised no concerns regarding charges or system management.
c. Tenants have to pay for heating even when not at home e.g. on holiday. Tenants are required to pay a proportion of the scheme gas costs which relate to generating and distributing heat and hot water around the scheme. These costs would apply irrespective of whether they are at home or not, which is standard practice with most communal heating systems. Tenants have control over individual heating usage and cost for their own flat and if they are away for a period of time they can reduce their heating times/temperature, or turn it off altogether, and their heating costs will reduce as a result. The reduction in costs will be evident when a heating statement is issued. This process ensures tenants pay for heating costs related to usage in their own flats according to their individual heating control settings.
d. Tenants do not receive a breakdown of heating costs I can advise that Choice has an established system in place whereby tenants periodically receive statements outlining their heating costs and any additional charge or credit which is applied to rent accounts. The most recent heating statements were issued to residents on 21 October 2020 and 28 January 2021 and contained an explanation of individual usage, meter readings and a breakdown of costs. Heating statements summarise how charges are calculated. Costs are split to show the element of charges that are due to: heating use within the flat as per their heat meter reading; and the remaining costs are associated with generating and distributing heat and hot water for the overall scheme, to ensure it is available 24hrs/day, and proportioned costs in relation to hot water. It is worth highlighting that a number of tenants actually received credits to their accounts to reflect lower heating use. In addition, a summary document was provided to tenants previously which explained, in detail, the process around how costs are calculated. The frequency of these statements had been raised in a meeting with residents several years ago and I can advise moving forward that it is agreed the statements will be issued quarterly. I trust this will help reassure tenants that individual usage is accounted for by the Association.
e. Heating is turned off at night and comes back on in the morning Choice acknowledge that there was a short period of time in October 2020 when heating may not have been available during the night. This occurred during a period when the communal heating controls were being updated. Choice apologises for any inconvenience this may have caused and we appreciate this may have contributed to a belief that heating as such was not routinely available at night. Nevertheless, during the period of upgrading we can confirm that any repairs reported were promptly addressed and we are pleased to advise no further reports have been received regarding this specific issue. I can advise that other than the heating upgrade period, heating has historically been available 24hrs/day for tenants during colder weather, based on outside air temperatures. The recent heating control upgrade provides the facility for Choice and Fusion Heating to remotely monitor and check the levels of heating available during the night. In addition, the weather compensation controls primarily impact on the temperature of heating during warmer weather. This ensures a cost efficient heating system for residents. I can confirm that hot water is also available at all times.
f.
Tenants have no control over settings I can confirm that tenants have control over heating within their apartments. As would be the case in any modern efficient heating system, each property has a timeclock, a room thermostat and TRVs on radiators. These allow tenants to decide when they would like heat to be available and also set a specific temperature to meet their needs. The only limitations to these controls are as noted above, when heating flow temperatures are reduced during periods of warmer weather. Choice has previously provided information to tenants at Bleach Green advising how to operate their heating controls. This has recently been reviewed and a copy is attached for your information. As part of this investigation our contractors, Fusion Heating, arranged a time with concerned tenants to individually review controls within apartments. The feedback from Fusion was that all tenants had individual controls that were working satisfactorily. During the inspections a few tenants raised issues with radiator valves sticking which was also quickly resolved.
Additional Clarification Points I would like to take this opportunity to address some additional points which I hope will be helpful to clarify any other outstanding issues ie: • Previous Complaints • PPR - Advice from Heating Professionals • Lack of engagement - Choice Management
Previous Complaints Your letter notes that tenants report problems to the Scheme Coordinator who raised the issue with management but this has not fixed the problem. Please be assured that these reports were addressed in accordance with procedures and each time a heating contractor or Property Services Officer would attend the scheme to quickly address any concerns, as would be the case with any repair request or fault logged. An assessment of the repair history supports this. Whilst Choice advised that no formal complaints had been received via the Association’s formal complaints procedure regarding the heating at Bleach Green Court, this does not detract from repair issues reported via Scheme Coordinator or our Service Centre. The recent EIR information details the repair history for the scheme and an analysis of the EIR information does confirm that some of the reports are interlinked and relate to the same issue. We hope this information provides helpful context as to the degree of the issue at hand. As noted in your complaint Choice previously liaised with Sinn Fein regarding the heating system in 2017, the survey attached to your complaint is from this period in 2017. We acknowledge a further discussion was held with Sinn Fein in 2018 regarding a number of issues. Action was taken to address the matters and I can confirm that Sinn Fein have raised no further issues.
PPR - Advice from Heating Professionals The complaint letter refers to advice that has been sought from heating professionals who have recommended a solution to your concerns. The Association would welcome sight of this information.
Lack of engagement - Choice Management Your letter states that “no representative from Choice management has attended the facility since the Covid-19 pandemic began”. I would like to advise that during the initial lockdown Choice, in response to the Covid-19 outbreak, took a decision to reduce footfall in sheltered living schemes to protect tenants and mitigate the spread of the virus. During this time the Scheme Coordinator worked from home and kept in daily telephone contact with all residents (Mon-Fri). However, arrangements were in place to ensure essential health and safety checks were completed and that contractors were available to respond to any maintenance concerns. Scheme Coordinators returned to schemes in July 2020 and have generally remained on site since. Prior to the pandemic, the Association would have normally convened a tenant meeting and/or met with individual tenants to discuss and resolve such matters. As you are aware a meeting via video link was suggested with residents and representatives from PPR; however as infection issues started to escalate again, Choice and PPR agreed that such a meeting should be deferred until such times as it can safely be undertaken. Nevertheless, please be assured that Choice management and operational staff continue to remain available and are happy to discuss any concerns raised by tenants and their representatives.
Conclusion In light of the information above I hope residents will be assured as to the efficiency and cost effectiveness of the heating system and the provision for individual control. The Association is satisfied that the heating at Bleach Green Court also provides value for money to users. Choice is committed to keeping this matter under close review to ensure sufficient levels of heating are available at the scheme and to ensure that residents are kept fully informed of heating charges. I trust this meets with your approval. However, if you are not content with this response you have the right to request that the matter progresses to the next stage under the Choice Complaints procedure by writing to our Customer Services Officer within 28 working days at this address. Please ensure you inform us as to the reason why you are dissatisfied with the response and how you would like us to resolve it. If this proposal is reasonable and does not simply raise again matters which have already been dealt with, the complaint will be escalated to Stage 2 of our complaints procedure.
Yours sincerely
Michael McDonnell Group CEO
Documents Attached: 1. Heating Guide for tenants 2. Guidance on using the heating system at Bleach Green Court 3. Heating Controls Guide