Communities and Local Government CommitteeWritten evidence submitted by the Bradford District Tenants and Residents Federation

As a group we have for many years been concerned at the poor quality housing offered by some landlords in the private sector not just locally to Bradford but in all areas around the country. We do stress that this is not an attack on the sector as a whole but rather on that portion that brings the whole sector into disrepute.

Added to this is our concern at the levels of rent charged in some areas for homes whatever the quality delivered.

As an organisation we are aware that Local Authorities may be offered the option to discharge their duty regarding the homeless into the private sector following recent consultation, this leaves us with an additional layer of concerns regarding the sector which we would address as follows:

Security of Tenure

We should like to see a standard 12 month Assured Shorthold Tenancy issued by licensed private sector landlords who wish to be eligible to take part in the rehoming of the homeless.

Licensing of Private Rented Sector

We should like to see all landlords licensed by the local authority before they are allowed to rent out homes. We are not looking for an onerous regime to be imposed, rather that landlords prove they meet a basic minimum standard of both their property and of the service they give to tenants.

This would we envisage being that they provide:

1.Gas safety certificates.

2.Electrical safety certificates.

3.Energy efficiency ratings.

4.Certificate showing homes met minimum standard expected (see below).

We should also expect that landlords wishing to register would be checked against authority records for complaints regarding landlord property or conduct.

Certification of Landlords and Landlord Properties

Here we are not proposing some HCA style regulation and monitoring, rather a basic set of standards should be met prior to a landlord being allowed to rent out a property.

These to include as a minimum:

1.Doors and windows that open and close and can be secured.

2.Double gazing.

3.Central Heating.

4.Kitchen and bathroom of acceptable standard.

We acknowledge that in these times of financial hardship for Local Authorities they will be hard pressed to find the monies required to put these conditions in place. However we believe that this is no reason to allow the unlicensed market that currently prevails and is bringing misery to thousands. Rather than put in place an entire new department or layer of staff within the Housing Department a partnership be developed with a local Tenants Federation or tenant led social enterprise whereby trained and experienced tenants can perform the review of landlords.

To finance such a system we would advocate an annual licensing fee for landlords of say £20.00 for first five properties, and £110.00 for more than five. In return we would suggest that landlords be offered the opportunity to advertise their properties as Council Licensed and the option to have tenants nominated from the waiting list.

Rent Setting

Potentially this is the most controversial element of this enquiry due largely to it being in direct conflict with the Localism Act, Welfare Reform policies and the best interest of both landlord and tenant.

We firmly believe that landlords should be able to make a reasonable margin of profit on their investments so do not advocate a punitive regime of rent levels which forces them out of the market. However we do advocate that rental levels are set at a level relative to the local economy but also that the Local Housing Allowance (LHA) be set to mirror these values.

Where we see potential clashes with the two Acts is in the areas of bedroom numbers required, our reading is that the Localism act sets different criteria to the Welfare Reform Bill as to at what age children are entitled to their own bedroom and that the Localism Act sets out space criteria for numbers allowed to occupy a bedroom something not included in the proposed Housing Benefit calculation for number of bedrooms required.

In order to protect those in lower paid work but living in comparatively high rental areas of a city we would advocate LHA be set at 80% market rent for the relevant district. This would alleviate the potential for the workforce being priced out of the market by either rent levels or the cost and ability of public transport to meet their needs.

Rental Agencies

Whilst we acknowledge that there are only a small minority of agents who behave badly they do bring the profession into disrepute and so we should like to see them licensed by the Local Authority. Again we are not looking at onerous conditions, simply that they limit their services to licensed landlords and that they do not charge potential tenants for their services, they are after all agents of the landlord.

Houses of Multiple Occupancy (HMO)

We are relatively happy with the current licensing of HMOs, where they are identified, our concern is the potential for the proliferation of unlicensed premises with the revoking of Housing Benefit entitlement to the under 35s. Already we are seeing the advent of the “rooms to let £50.00 per week” advert in local shop windows which gives rise to our concerns. We should like to see local authorities taking positive steps to identify where abuses of the situation are occurring and take action to penalise offenders and/or bring the relevant properties up to standard.


We should like to see the Private Rental Market regulated but not to the point where it becomes either too bureaucratic or costly to appeal to landlords. We should like to see partnerships between, landlords, local authorities and tenants formed to make the sector more appealing to all concerned. Letting agents should only be allowed to service licensed landlords and charge only the landlord for the service provided. The potential for abuse of the system of HMOs means in our view that a review of how licensing operates will be needed.

Cautionary note: with the proposal under Universal Credit to pay Housing Benefit direct to tenants we are concerned that this document could well be irrelevant as private landlords give up the market. Already we are seeing signs of the withdrawal of landlords from the market for those on Housing Benefit, a potentially dangerous development when 70% of new claimants are in work.

January 2013

Prepared 16th July 2013