Communities and Local Government CommitteeWritten evidence submitted by E J Wilamowski
I have seen a couple of submissions to yourselves (EMPO and NetRent), but want to add as follows. This relates to—Regulation, in particular of HMO’s/discretionary schemes/Local authorities discharging their duties.
I fear that the current/proposed HMO related schemes are going to have a two fold effect. On the one hand, a divisive one, where many homeless people under HMO, whilst homeless, are going to be housed in accommodation that is superior to what others can afford whilst in work, or to what the homeless will end up in.
On the other, that the homeless and the young will end up being housed in inner city areas, of lower standards than average, thus creating ghettos of unemployment, reversing any regeneration gains of recent years, and reversing gains, if any, from reduction in student numbers in such areas. I draw your attention to the fact that HMO regulation under the 2004 Act, when one considers exemptions, as for example, buildings owned or managed by a public body such as NHS or Police, a local housing authority or a registered social landlord etc, is directed primarily at the PRS, exempting just about every one else. Coupled with discretionary HMO licensing, for example one side of the road in HMO land and the other not, will mean that a property on one side of the road will be treated differently to a property on the other side. This is very divisive and will impact on prices. I know which side of the road I would want to own a property in the above circumstances, and which side of the road is likely to be let. Here is an analogy on divisiveness, in a school class, the children with parents in the public sector do not have to abide by rules that apply to other children. The same applies to HMO legislation/application. Discriminatory in effect.
The currently proposed systems of HMO regulation as suggested are going to give only marginal benefits, and are likely to cause more crime and inner city problems, at best shift them to adjacent areas, whilst not solving the young people’s problem of required additional housing in HMOs resulting from benefit changes, whilst causing divisiveness between the public and PRS sectors. When coupled with the view of some Council employees that PRS is the dump for their problem I fear that we will not improve on matters but possibly aggravate them, particularly in the current austerity climate that councils and others operate.
The fact is that problems associated with the imbalance of Supply and Demand, and poor behaviour, cannot be solved merely by increased regulation. The proposals I have seen in particular with HMO’s seem to try to deal with symptoms not the real problems. The regulation medicine is unlikely to make the housing ills better, there is already a considerable amount of regulation affecting the PRS. There is no better solution than to build more HMO’s or convert more properties into HMO’s, perhaps with the assistance of grants.
The milk cow of PRS is not infinite. PRS has been growing and providing a valuable service, effecting a switch from the public to private sector provision, increased regulation is likely to stifle its progress.
My comments are not intended against the safety aspects of HMO’s, rather some of the provisions, such as room sizes and number of people permitted (which do not apply to owner occupied property for example), and where a newborn child can tip a property into HMO status, with a newborn considered to be a person on the premises, under the 2004 Act. My personal opinion is that the 2004 Act is very poorly written, and does not take account of the real world situation and the increasing demand for multiple occupation.
The matter is further aggravated by the insurance position, and insurance companies either refusing to insure DSS occupied properties, or putting on heavy increased premiums, at a time when income from such persons via benefits is falling and is becoming less and less certain. There is an urgent need for a Government funded insurance scheme to cover some properties, something on the lines of pooling together of premiums on a non profit basis.
The increasing imposition of discretionary HMO licensing as things stand, with insurance and other problems, seems to me to be a recipe for disaster, which will not improve matters and if anything create more homelessness.
January 2013