Window replacement in social housing: the planning factor that’s easy to miss 

The Housing Ombudsman’s latest report on window disrepair is a sobering read. It identifies cases where residents were left in cold, damp and unsafe homes – children among them – with some complaints running for years before windows were repaired. Window-related issues now account for around 9% of the Ombudsman’s severe maladministration findings, well above the usual level of roughly 2%. 

These cases matter, and the human cost is real, but they rarely reflect indifference. Most providers are managing ageing stock on constrained budgets, and the Ombudsman has been candid that replacing windows – particularly in high-rise blocks – is both complex and expensive. Window programmes are typically held up by a combination of factors: funding and competing capital priorities; the interplay between responsive repairs and cyclical major works programmes, where repairs are folded into larger schemes that then slip; procurement and supply chain lead times; access to occupied homes; and, on higher-risk buildings, the building and fire safety requirements introduced since Grenfell. 

One factor sits among these but is consistently underestimated: planning consent. Replacing windows is often not a straightforward maintenance task, and across much of the social housing stock it requires formal consent that, if identified late, can hold a programme up for months. 

The reasons are well established. Permitted development rights that allow like-for-like changes to houses do not extend to flats and maisonettes, so external window works to blocks of flats generally require planning permission. Conservation areas frequently carry Article 4 directions that remove permitted development rights. Listed buildings require listed building consent, as windows are usually character-defining. Even works that appear to be routine maintenance can constitute development requiring consent where the material, frame profile or sightline changes. On higher risk buildings, fire safety obligations and the Building Safety Act regime add a further tier of approvals. 

These considerations are becoming more pressing. As Awaab’s Law is extended to cover further hazards – including damp, mould and excess cold – landlords will be under a duty to act on precisely the conditions the report describes, within fixed timescales. That makes it all the more valuable to understand the consenting position at the start of a programme rather than discovering it once works are already underway. 

This is where bringing the relevant disciplines together can make a practical difference. Frankham approaches window replacement as a coordinated programme rather than a series of separate tasks: 

• Measure – condition surveys and accurate take-offs, establishing the planning and listed building status of each property early. 

• Design – specifications that balance thermal and acoustic performance, appearance, planning acceptability and fire safety. 

• Deliver – planning and listed building applications, procurement strategy, and project and cost management through to completion. 

Where survey, design, consent and delivery sit with a single team, the interdependencies between them are easier to manage and the risk of a programme stalling is reduced. 

Frankham works with housing associations, local authorities and registered providers on window replacement and wider planned works programmes and is happy to discuss how a programme might be approached or to review one that has stalled. 

If you would like to speak to our team, get in touch with Oliver Morse, Director of Frankham Projects – oliver.morse@frankham.com.