Notice

Social Housing Decarbonisation Fund: questions and answers

Updated 21 October 2021

Applies to England

Update: 9 September 2021

We have added questions and answers to the following sections:

• eligible properties (questions 12, 14 and 15)
• mixed tenure (question 25)
• eligible measures (questions 29, 30, 31 and 33)
• modelling at bid stage (questions 42 and 43)
• funding and eligible costs (questions 51 and 52)
• application process (questions 67 and 68)

We have also updated the answer for question 28.

Eligible applicants

1. Does a Local Authority (LA) have to form a consortium with other LAs or Registered Providers (RPs) of Social Housing, including Private and Local Authority providers?

No, a local authority can submit an application using their own housing stock as a single LA.

2. Can an LA submit two applications with different stock?

LAs may submit two applications provided the same stock is not submitted twice. Where a LA is involved in more than one application, it must ensure it has the capacity to deliver the full funding within the stated delivery window should all applications for funding be successful.

3. Can an LA lead on multiple applications from different RPs, or can the lead LA only submit one application with all interested RPs?

An LA can lead multiple applications from multiple RPs or may lead one application from all interested RPs.

4. Can an LA form a consortium with a RP and submit the application as the Lead LA without putting forward any stock?

The lead LA does not have to submit their own stock as part of a consortium application, the application can be entirely made up of stock from other registered providers of social housing.

5. Does an RP with nationwide stock have to submit multiple applications with multiple LAs, or can the application comprise housing stock from across local authority regions, but submitted by a single lead LA?

A single LA can lead an application with a single RP, or a consortium of RPs, across multiple Local Authority regions. Housing stock can only be submitted once and should not be duplicated across multiple LAs.

6. Can a Combined Authority submit an application/lead a consortium application?

Yes, any Body which is defined as a Local Authority for the purposes of Section 31 (see Section 33(1) of the Local Government Act 2003) can submit an application to the SHDF, this includes Combined Authorities.

7. How are consortium applications assessed?

Consortium applications are assessed in the same way as a non-consortium application. All applications are assessed in a fair and equitable manner and are all assessed using the same application form and the same marking criteria. The consortium applications are assessed as one application, rather than an as individual applications under a Lead LA.

Application size

8. Is there a maximum or minimum application size/value that can be submitted?

BEIS will not specify a maximum or minimum application size/value – although BEIS would not encourage applications looking to treat only a small number of properties, and RPs wishing to apply with a small number of properties are encouraged to join a consortium.

9. Is there any flexibility in the amount of grant to be awarded?

BEIS reserves the right to vary the allocation of grant funding (through negotiation with the applicant), taking account of the scheme criteria and the number and size of Value for Money proposals it receives.

10. Is the £160 million pot the maximum value of funding available?

Depending on the number and value of applications and the in-year resource position, BEIS may consider varying the size of pot available to support grants.

UK subsidy control rules

11. Will there be limits on how much Housing Associations can be funded under subsidy control rules?

Currently there are no upper limits to the amount of money that can be applied for under the TCA.

Where a subsidy is being awarded, applicants need to ensure compliance with the TCA principles, including a justification as to why the subsidy is proportionate and limited to achieve the relevant objective.

Eligible properties

12. What properties are eligible for social housing?

All social housing provided by Registered Providers (RPs) including Private and Local Authority providers are eligible for SHDFG Wave 1 funding, regardless of archetype (including high rise blocks). Homes both on and off the gas grid are eligible for funding.

As per Housing Regeneration Act 2008, sections 68-70, ‘social housing’ means:

• low cost rental accommodations (defined by section 69)
• low cost home ownership accommodation (defined by section 70)

13. Where stock is spread across a region, do we need to apply for each group of properties separately, or can one application be written for all properties?

One application can be submitted for all properties across a region or regions.

14. Are void properties eligible for funding?

Void properties are eligible for Wave 1 funding. If at the time of compiling the application, the applicant is unsure what properties will be void and which will be occupied the applicant should still ensure mechanisms are in place to be able to deliver the project by January 2023.

15. Can an entire application be comprised of void properties?

An application can be entirely composed of void properties. It is the responsibility of the applicant to ensure that this application still complies with the eligibility criteria set out in Section 2 of the competition guidance and the SHDF Wave 1 questions and answers.

Eligible installers

16. Are BEIS working with the industry to address any delivery capacity issues and increase the number of skilled accreditors in the sector?

BEIS continues to work closely with Trustmark and other industry bodies to address delivery capacity issues in the retrofit sector. The SHDF, in conjunction with other government schemes such as the Sustainable Warmth Fund, aims to stimulate and support the continued growth of the retrofit sector by continuing to launch future waves of funding over the next 10 years.

Safety and quality

17. If we have to follow PAS2035, which training do people need to complete?

The full details of the qualifications required for each of the roles defined in the PAS2035 standard are detailed in Annex A of the PAS2035:2019 guidance document. Under PAS 2035:2019 guidance, all domestic retrofit projects should use a Retrofit Coordinator, who would hold a Level 5 Diploma in Retrofit Coordination and Risk Management. It is possible for multiple roles to be fulfilled by the same person if they are suitably qualified.

18. Do personnel required by the PAS pass standard need to be internal (in house) or external (contracted via a delivery partner)?

The only requirement is to have suitability qualified PAS personnel. They may be either internal or external.

19. Can accreditation be achieved by a successful contractor during the project? Can one company that is accredited lead a consortium?

When referring to a retrofit coordinator (RC), an RC can work on PAS2035 projects if they are working towards the qualification with over 75% completed and plans to complete the course within 3 months.

Mixed tenure

20. How should shared owners be considered as part of the mixed tenure picture? Will they need to pay for works done to their property?

Shared ownership properties will be eligible for funding in the same way as leaseholders under SHDF Mixed Tenure policy.

21. What if leaseholders do not agree to pay the £3,300 contribution set out within mixed tenure policy?

If it is not possible for a Local Authority to recover the £3,300 contribution from leaseholders, the Local Authority may instead provide the funding for mixed tenure measures themselves.

22. I have a residential block that has less than 70% social homes in it, can I use the SHDF mixed tenure funding?

If the overall application to the SHDF consists of a minimum of 70% social homes that meet SHDF eligibility criteria, it is possible to apply for mixed tenure funding for the remaining 30% or less of mixed tenure properties, regardless of how these are spread across residential blocks. However, the infill policy is still limited to situations in which social homes would be adversely affected if the Infill policy is not applied.

23. How will the SHDF define what low income is and will there be flexibility in its definition?

The SHDF defines low income as homes with an annual income of no more than £30,000 gross, before housing costs and where benefits are counted towards this figure or verified using alternative methodologies, such as means tested benefits, charity, and health referrals, locally held data (for example, Council Tax reductions), and advanced statistics/machine learning. Homes that cannot be verified as low income will still be eligible to receive measures under the SHDF’s infill policy, however they would be expected to contribute.

24. I have a mixed-use building that contains social housing but is also partially used for non-domestic purposes, for example one floor used commercially. Can I use SHDF mixed tenure funding for the whole building?

SHDF funding is reserved for social housing stock (except in the purposes of infill for mixed tenure, as outlined in the guidance), and cannot be used for other purposes. Works to non-domestic buildings would need to be 100% funded by applicants, in addition to their one third co-funding contribution.

25. Does a mixed tenure application have to install external wall insulation or ventilation to be successful, or can for example double glazing only be installed on the mixed tenure properties?

An application wishing to install double glazing only as part of their application form to treat mixed tenure properties would be eligible as long as it meets the performance requirements of SHDF Wave 1, and is limited to situations where social homes would be adversely affected without it, for example where social homes may not be able to meet the performance requirements of the scheme, or where works are undertaken on a whole block for planning or logistical reasons; and would have to be justified as part of the application form.

Where an RP plans to install measures such as double glazing or solar PV, which are typically less cost effective, the proposal should quantify how many double-glazing installations are planned and specify whether double glazing will replace single glazing only. Applications where these less cost-effective measures present a high percentage of the total costs of upgrades are likely to receive a low score in the value for money section of the application.

Eligible measures

26. What do you mean by ‘fabric first’? Does it mean that we are only permitted to install fabric measures?

A ‘fabric first’ approach ensures heat loss prevention measures are installed before other energy efficiency measures. The fabric first approach can be considered alongside the space heating demand expectation of 90 kwh/m2/year, to further understand the fabric improvements envisioned through SHDF Wave 1. As well as benefiting the comfort health and wellbeing of tenants, and helping to save money on energy bills, a fabric first approach can help to maximise the dwelling’s suitability for low carbon heating, either now or in the future.

27. To what extent can we spend SHDF money on place-based improvements?

SHDF funding may be spent on place-based improvements to the energy efficiency of a building as a whole, for example external wall insulation for an entire block. Place-based improvements outside of the scope of those outlined in the Competition Guidance Document (see section 2.9 – Eligible Measures) will not be permitted through SHDF funding or associated co funding.

28. What do you mean by ‘Low Carbon Heating can be installed where a fabric first approach is taken, and the new heating system reduces bills when compared to the existing heating system in isolation’? And how do we measure/evidence this?

In isolation refers to directly comparing heating systems, not a comparison between the original performance of the property and the performance after installation of low carbon heating and other measures (for example, fabric). It is at the discretion of the applicant to decide whether this is done using pre or post retrofit modelling.

For example, evidence of this could be showing the modelled SAP input data with the fabric changes including the old heating system and then showing the same modelled input data with low carbon heating replacing the old heating system to show the change to SAP score. There are also other alternative ways to demonstrate this, including using other types of stock modelling and manual energy system calculations.

29. Are flood proof measures eligible for funding?

Yes, if as part of wider community climate change resilience planning or PAS2035 assessments process and properties have been identified that are at flood risk and so there is a requirement for flood proof measures that are eligible for SHDF Wave 1. However as per all measures, a cost breakdown and cost justification are required as part of the application form.

30. Can my application mainly comprise double glazing installation without other measures such as insulation?

Yes, an application form can comprise mainly double glazing as long as the application meets the performance requirements of the SHDF; however, where an RP plans to install measures such as double glazing or solar PV, which are typically less cost effective, the proposal should quantify how many double-glazing installations are planned and specify whether double glazing will replace single glazing only. Applications where these less cost-effective measures present a high percentage of the total costs of upgrades are likely to receive a low score in the value for money section of the application.

31. Can cavity wall insulation be installed to blocks as an infill approach with a mix of EPC Band C and D properties?

Any application containing EPC Band C properties would need to be on an ‘infill’ basis whereby a minimum of 70% of homes across the overall application are below EPC Band C. Measures installed on an infill basis are insulation and associated ventilation however RPs may include additional measures on an exceptional basis if a justification is given as to why a whole block approach is essential for the attainment of SHDF Wave 1 performance requirements.

32. Can RPs self-fund additional measures that are not included as part of the SHDF competition criteria (for example, fossil fuel boilers)?

RPs wishing to self-fund measures not included as part of the SHDF Wave 1 competition criteria, including fossil fuel boilers, may do so – however, this would have to be separate from SHDF funding and associated minimum co-funding of 1/3 total eligible costs. Applications wishing to do this should highlight in their answer to Question 3F their reason for doing so. The criteria on heating systems being eligible for replacement only where the new heating system reduces bills when compared to the existing heating system in isolation remains for any home receiving SHDF funding.

33. Can I install a heat pump without installing fabric upgrades?

No, applications to SHDF Wave 1 must adhere to the competition guidance for SHDF Wave 1, and so must follow a fabric first approach (of insulation and heat loss prevention measures) to retrofitting for all projects. A ‘fabric first’ approach ensures heat loss prevention measures are installed before other energy efficiency measures. The fabric first approach can be considered alongside the space heating demand expectation of 90 kwh/m2/year, to further understand the fabric improvements envisioned through SHDF Wave 1.

Modelling at bid stage

34. How should an applicant evidence the 90 kwh/m2/yr at application stage?

There are a number of options to demonstrate evidence that the application proposal will meet the space heating demand for the properties identified for retrofit. This can include modelled data from a range of retrofit planning tools including SAP/energy efficiency/PHPP based modelling tools or equivalent. It should be noted that if you chose to use a modelling tool that does not include a SAP score or EPC rating, evidence of meeting the EPC requirement of EPC Band C will need to be included in addition. The modelling evidence required for application stage is not intended to replace the PAS 2035 dwelling assessment process.

35. Do modelled energy bills have to use SAP 2012?

If you choose not to use SAP 2012 based modelling to demonstrate the impact on energy bill of the retrofit measure, you will need to briefly outline the basis and methodology for the data evidenced, meaning which retrofit building modelling tool has been used and the energy tariffs applied.

36. Should full SAP be used, or is RdSAP acceptable?

It is recommended that Full SAP is used as the acceptable modelling methodology as it would demonstrate the applicant fully understands the technical challenge they are undertaking. PHPP would alternatively be an acceptable method of modelling the design intent.

Whilst recognising that RdSAP can be used for PAS 2035 dwellings, the PAS 2035 standard recommends ‘If RdSAP is used to support a retrofit assessment, then the data should be reviewed carefully and preferably exported to Full SAP software’ thus we would prefer a higher level of modelling and more accurate level of energy demand estimation than RdSAP for the purposes of setting performance targets for this project.

It is acceptable to use recent EPC certificates combined with stock analysis at the application stage of the proposal.

37. Is the expectation that landlords identify actual works prior to application or will real world assessment need to be part of the delivery process?

We would recommend RPs undertake stock analysis, stock identification and stock modelling to evidence the basis for funding their proposal. Previous experience of retrofit project delivery suggests early tenant engagement and in-depth understanding of the pre-retrofit requirements of PAS 2035 can reduce delays early in the project development and delivery.

38. How should costing be done at the point of application?

RPs should provide information on how costs have been modelled – for example, through stock modelling, knowledge of recent work done on similar homes, or using information from a stock database. Early engagement with the supply chain is strongly encouraged as part of/alongside this work.

39. Is the requirement for bill modelling, or space heating energy use?

RPs will be expected to evidence the modelled bills associated with the end space heat demand level of the property (with this level expected to be 90kwh/m2/year or better). It is expected that this would be compared to modelled bills pre retrofit (for example through SAP 2012 or energy based modelling), to identify bill savings.

40. Is there a requirement to obtain ‘real world’ (meaning not modelled) fuel bills before and after as evidence?

No – tenants will be asked about their bills during the BEIS led evaluation, but it is not a requirement for them to respond to this, and landlords will not be required to provide this evidence either. Consent may also be sought for smart meter data from tenants whose homes have these installed, but is again not a requirement.

41. Can a valid EPC completed within the last 10 years be used to justify a property being included within a bid?

Landlords need to evidence that the energy performance of properties included in an application to SHDF meets the requirements of the programme (EPC Band D,E,F or G). Homes that have a valid EPC certificate from up to 10 years ago will be valid at application stage if no work (including for example no boiler replacements) has been carried out on the home since the certificate was issued. As part of the PAS process, dwelling assessments for successful applicants will need to be carried out pre-retrofit (please refer to PAS 2035), and if such an assessment indicates that properties are at or above EPC band C, the properties are not eligible (except for in infill scenarios as in Section 2.4 of the competition guidance) and replacements equivalent to those applied with will need to be found.

42. Does BEIS require a full stock analysis to have been completed by a consultant at application stage, or is an in-house process (provided full details of this are provided) acceptable?

No, a consultant is not a requirement. An in-house process is acceptable provided the RP has the capacity and capability to complete the modelling.

43. Will you be performance measuring retrofits pre and post installation?

Yes, we will be measuring energy performance of retrofits post-installation, including energy consumption data and building thermal performance data both pre and post retrofit (for a sample of the retrofits) , and comparing it to a modelled, pre-installation, assessment. The privacy notice issued on GOV.UK as part of the competition documents outlines how tenants’, installers’ and registered providers’ data will be processed and used by BEIS.

Funding and eligible costs

44. What funds can be used for co-funding?

RPs may not use funding from ECO or Sustainable Warmth Fund (SWF) and other BEIS grant schemes to cover the required one third co-funding contribution. In cases where RPs propose using other grant funding from other sources, it is their responsibility to ensure this approach is permissible with those funds and any approach remains compliant with UK Subsidy Control rules.

45. Is there a cost cap on properties which are allowed to be treated through an infill approach (e.g. mixed tenure and properties already rated at EPC Band C or above)?

Yes, for mixed tenure properties, the cost cap is the same as the equivalent EPC band in social housing. Where properties are at EPC Band C and above, the cost cap is the same as for an EPC Band D property (£10,000). Given the infill approach is limited to certain measures and is distributed as a proportionate cost per property, it is only in exceptional circumstances that we would expect to see these caps reached.

46. Will this co funding level be consistent for all future waves?

BEIS is still designing policy for future waves of the SHDF, however it is likely that future waves will operate in a different way to Wave 1.

47. Does the application have to comprise a mix of properties (EPC Band D/E/F/Gs) or can the entire application comprise EPC Band D homes; and is there a % cap on the number of EPC Band D homes which can be included as part of the application?

The application does not need to comprise a mix of EPC Banded properties. The application composition is at the discretion of the landlord and their stock they wish to upgrade. There is no cap on the % of EPC Band D homes which can be included in an application, and applications which contain only EPC Band D homes are viable.

48. If modelling suggests that fabric improvements improve the energy performance of a home to EPC Band D (with space heating demand of 90 kwh/m2/year or better), and modelling suggests that installing a heat pump would further improve the home to EPC Band B, is the heat pump eligible for funding?

It is expected that the grant funding applied for (along with associated co-funding) will be that required to achieve the performance metrics of the SHDF. BEIS notes that in some instances, homes may improve from below an EPC Band C to above an EPC Band C through the installation of a single measure. As long as this measure is within the scope of SHDF Wave 1, it would be eligible for being considered as part of an application for grant funding.

49. Does co-funding have to come directly from RP budgets, or can it be provided by other sources (e.g. commercial organisations, green finance)?

An RP can use funding they receive from a third-party source as part of their co-funding contribution.

50. Can future funds, that will begin during the delivery window of Wave 1 (for example, ECO 4 and Clean Heat Grant) be used in Wave 1 applications when they are launched?

Applications must be predicated upon available funding at the time of the SHDF Wave 1 competition. However, if at a later date the RP wants to undertake additional works with funding from other schemes, they may do so as long as it is not funding the same measure. This additional funding must provide additionality to the SHDF application and not be used to meet the originally required objectives of the scheme. The criteria on heating systems being eligible for replacement only where the new heating system reduces bills when compared to the existing heating system in isolation remains for any home receiving SHDF funding.

51. Can SHDF funding be used to fund existing planned projects? For example, if a tower block required changes to external wall insulation and the project is broken down into two stages 1) removal of existing cladding and 2) installation of new claddings and other fabric measures such as roofing and ventilation, is stage 2 of the project eligible for SHDF funding?

Yes, SHDF funding can be included into existing planned projects provided the project meets all the requirements of the SHDF Wave 1 and the SHDF funding is used exclusively in line with SHDF Wave 1 guidance and questions and answers. It is the RPs responsibility to ensure that any blending of funding is compliant with each individual scheme and the respective requirements and objectives for each fund is met.

52. What building works prior to installation, would classify as administration and ancillary costs?

If during the risk or assessment process, construction defects such as those evidenced by condensation and/or mould growth are identified, building works to remedy these types of defects could be classified as administration and ancillary costs. Please refer to section 2.10.3 of the competition guidance for further details on these costs, see specifically: It is acknowledged that for certain activities, there is flexibility in whether these are considered as administration and ancillary, or capital. BEIS is not prescriptive about where costs sit and understands the need for flexibility and so RPs should work with their Accounting Officers to ensure that their budgeting and allocations are fit for purpose. In addition, it is expected that admin and ancillary costs will be as low as possible and comprise less than 15% of the total project budget.

53. Does BEIS hold any financial contingency?

BEIS does not hold any financial contingency.

Tenants

54. What should we do if tenants refuse access to the property? Are we expected to treat these homes through the SHDF?

All access to individual homes is governed by the tenancy. Early and continuous engagement with tenants throughout the process is expected along with reinforcement of the positive benefits of the SHDF. The RP should take this into consideration when choosing stock to upgrade.

55. How will BEIS ensure that the scheme will be safe for members of the public given the COVID-19 pandemic? What happens in the case of a household needing to self-isolate – can delivery be extended in these circumstances?   

SHDF competition guidance states that BEIS expects all RPs, contractors etc. to work safely, following COVID-19 secure working practices. All relevant safety guidance should be followed, including on social distancing and use of Personal Protective Equipment (PPE). In exceptional circumstances, BEIS may agree to extend the delivery window by up to 2 months (to end of March 2023).

56. Do residents need to opt in for Data Sharing?

In accordance with UK GDPR all residents and installers wishing to take part in Monitoring & Evaluation activity will need to opt in and give consent. This will allow their contact details (email address, name, address and telephone number) to be passed onto BEIS’s appointed evaluation contractor. Further information about BEIS’s evaluation research can be seen in the competition guidance.

A copy of the privacy notice explaining how BEIS will use the data can be found on the SHDF Wave 1 competition gov.uk webpage.

57. Do tenants need to provide guarantees that they will allow proposed works at the point of application?

It is not expected that tenants will have guaranteed this at the point of application. BEIS encourages RPs to engage early with tenants, to support successful delivery of projects. RPs will be assessed on their engagement plans with tenants as part of the application form. The RP should take this into consideration when choosing stock to upgrade.

Social Housing Retrofit Accelerator

58. Will the Social Housing Retrofit Accelerator (SHRA) be free?

The SHRA will be a free service for all RPs who intend to apply to Wave 1 of the SHDF.

59. Do you have to receive support from the SHRA in order to apply to the SHDF?

The SHRA has been established to provide support all RPs interested in accessing funding for the SHDF and will offer support at different stages of project development. However, it is an optional service and RPs interested in applying for the SHDF do not need to use SHRA support to receive grant funding.

60. When will the SHRA be open for applications?

The SHRA is currently open for RPs to access project and application support for Wave 1 of the SHDF. Further detail is available on the SHRA website.

61. Will findings from the SHDF Demonstrator be made public to support applications to Wave 1?

The SHRA will help potential applicants for the scheme to understand previous and current retrofit projects underway, to develop applications and shape their projects.

62. Will there be support for RPs who have stock across many LAs, such as a matchmaking service?

The SHRA will work to support RPs who may require matching with a lead LA. RPs interested in this service may wish to consult the SHRA website or get in touch at info@socialhousingretrofit.org.uk.

Monitoring and evaluation

63. How much baseline data is required?

As part of the application form, RPs will be expected to provide information about how they will collect data to support monthly data reporting requirements set out in the competition guidance and MoU. A project plan will need to be submitted as annexes to support their application. These documents, coupled with the information supplied as part of the application, should contain all relevant baseline data required. However, further baseline data might be required.

Where baseline data is required relating to fuel bills or associated information, data obtained during winter heating periods will be acceptable.

Application process

64. Will applications be awarded on a first come first served basis, and will the application window be closed once the allocated amount of funding has been awarded?

No – all applications will be assessed after the competition window closes on the 15 October 2021. This is a competition-based scheme, and so all applications will be assessed at the same time and applications which perform the best as part of our assessment process will be awarded grant funding.

65. Will there be clear guidance on the privacy notice and data sharing?

Yes - we will provide a Wave 1 privacy notice in the Memorandum of Understanding when competition documents are published. We will also include the SHDF Demonstrator Data Sharing Agreement for RP’s reference – this will be indicative and for reference only. We will provide an updated version of the DSA this autumn but do not expect it to deviate significantly from what is set out in the SHDF Demonstrator DSA.

66. What should we do if we need to change the project parameters?

Where RPs are issued funding, but wish to make a deviation from their submission, they will be requested to follow a change control process. The change request will then be reviewed by the Project Team in accordance with the process outlined in the Memorandum of Understanding.

67. Are BEIS providing templates for the annexes required as part of the application form?

No, BEIS will not provide templates for the annexes required as part of the application form. The applicant is expected to draft their own annexes and submit these as part of the application process. Where BEIS has stipulated the format of the annexes, please comply with these stipulations.

68. If retrofit works are in progress but not completed by 31 Jan 2023, does BEIS demand return of grant for any properties not completed?

Applicants should develop project plans evidencing their ability to complete projects by the 31 January 2023 deadline, noting the risks to this plan. If exceptional circumstances arise during delivery of certain projects, BEIS reserves the ability to grant an extension of up to 2 months, to these projects to allow completion by 31 March 2023. If the grant is not fully spent by March 2023 then BEIS reserves the right to request return of all or any proportion of the grant. Please refer to the draft memorandum of understanding for the details on grant repayment.

Future ownership of properties

69. Is there a requirement for RPs to keep (meaning not sell) stock for a certain period of time following retrofit works?

The SHDF seeks to improve the condition of the social housing stock, facilitating the improvement of the worst performing social homes to enable landlords to improve the condition of their stock, and help the social housing stock as a whole to offer good places for tenants to live. There will not be a condition to this effect in the Memorandum of Understanding for SHDF Wave 1.