79.In the last chapter, we noted that local authorities had a range of powers to tackle low standards in the private rented sector. We heard, however, that the existence of such powers did not mean that they were enforced. This Chapter explores the issue of enforcement in more detail. We look at rates of enforcement by local authorities, investigate why they have tended to be so low, and make recommendations for how enforcement rates might be improved. We move on to reflect on whether selective licensing schemes are a useful enforcement tool for local authorities, if there is evidence that they lead to an improvement in the quality of accommodation, and whether the process of implementation is fit for purpose.
80.We heard that local authority enforcement levels were extremely low in the private rented sector. ARLA Propertymark told us, “Laws are passed but not enforced” and, while there were some local authorities who were proactive, “the vast majority do absolutely nothing”. The NLA agreed, with Adrian Jeakings telling us, “there does not appear to be enough enforcement going on”. This was also acknowledged by the Minister, who told us that low rates of enforcement were “shockingly surprising”.
81.The RLA reported that in 2016–17, among the 296 councils in England and Wales that responded to its survey, there were just 467 prosecutions of landlords, despite receiving 105,359 complaints. Dan Wilson-Craw from Generation Rent highlighted statistics that showed the average local authority received 433 complaints a year, of which 260 were inspected, 70 Category One hazards identified, and only 17 enforcement notices issued—suggesting local authorities were not following up adequately on complaints. In this context, the English Housing Survey estimated that there were 800,000 private rented homes containing one or more Category One hazards.
82.However, these averages belie the significant variations in enforcement activity, which is heavily concentrated in a very small number of local authorities. Kate Webb from Shelter told us that tenants were subject to a “postcode lottery”, dependent upon the number of officers in a council, whether they favoured a formal or informal approach, and “where they rank in the grand scheme of things”. David Smith from the RLA went further, telling us:
I do not think it is a postcode lottery, because a lottery implies that you might win occasionally. The reality is that with local housing authorities, in terms of enforcement activity, you can point to maybe five or six that are aggressively and actively enforcing, and after that the numbers just die.
Statistics support this analysis. One freedom of information request found that six out of 10 councils had not prosecuted a single landlord in 2016, with 80% prosecuting fewer than five. The London Borough of Newham was alone responsible for 60% of all prosecutions in London and 50% across the country.
83.However, many local authorities argued that enforcement statistics that focused on prosecutions were not representative of the informal work they undertook in the private rented sector, which they argued was equally effective. Tamara Sandoul of the CIEH highlighted that the HHSRS encouraged local authorities to pursue an informal approach with landlords before following more punitive routes. Andy Fisher told us that Boston Borough Council had only prosecuted three landlords in the last year, but that his team preferred to work with landlords rather than take formal enforcement action. He explained, “Enforcement is the end product. It is very disappointing to have to get to that enforcement route”. Similarly, Councillor Clare Salier told us that the London Borough of Wandsworth had only prosecuted one landlord in the last 12 months, but that “prosecution is a last resort”, highlighting that only a very small number of landlords refused to co-operate with the council to make repairs to their properties.
84.We recognise that enforcement activity undertaken by local authorities is often informal in nature and not fully reflected in prosecution statistics. Nevertheless, the evidence is clear that enforcement levels—formal or otherwise—are far too low in the vast majority of local authorities. This strongly suggests that vulnerable tenants are being left without the protection to which they are legally entitled. The Government has introduced a range of new powers for local authorities to intervene in the private rented sector to address low standards. However, these powers are meaningless if local authorities do not, or cannot, enforce them in practice.
85.The RLA identified three reasons why levels of formal enforcement activity undertaken by local authorities were so low. They told us that, first, the legislation was “too patchy and complicated, and far too much of it is cross-cutting”, meaning that EHOs found it difficult to use their powers (as explored in detail in Chapter 2). Second, local authorities had insufficient resources to undertake their enforcement duties. Finally, many local authorities lacked the political will to address low standards in the sector; David Smith explained that, “Not every local authority is prepared to commit aggressively to this area, which is unfortunate”. The evidence we received during the inquiry supports this analysis, and the following sections consider each in turn.
86.As we have noted, resources are at least as much of an issue for local authorities as the powers available to them. The LGA emphasised the financial challenges which they say will mean “a funding gap of at least £5.8 billion by 2019–20”. Crisis told us that 1,272 jobs were lost in environmental health offices between 2010 and 2012, while the Chartered Institute of Housing highlighted that local authorities had reduced spending on enforcement activity by a fifth between 2009–10 and 2015–16, an average annual reduction of £8.75 per privately rented home in England.
87.These statistics are even more stark when considered from a local perspective. ARLA Propertymark highlighted that Birmingham City Council only had five EHOs to cover a city of 1.1 million people. Andy Fisher explained that he had just 1.6 people in his housing enforcement team, for the entire town of Boston. Derby City Council’s Housing Enforcement Team said they, “still don’t have enough enforcement capacity to really get on top of the problem” in the private rented sector. We expect there must be many more similar stories from local authorities across the country. We heard from several councils that the low level of resources available for enforcement made it difficult to attract sufficiently trained and suitably competent EHOs.
88.The Government told us they recognised that enforcement was difficult and complex work, and highlighted the changes brought in through the Housing and Planning Act 2016, which allowed local authorities to keep money received through civil penalties—up to £30,000—and rent repayment orders, where rent was paid through state benefits, and reuse it for housing enforcement purposes. The Minister described these changes as, “a massive incentive for councils to do more”. The Government also introduced the Controlling Migration Fund in 2015, which made £100 million available over four years for local authorities to tackle local service pressures associated with recent increased migration, including criminal landlords. In light of these measures, the Government called on local authorities “to assess their priorities and allocate their resources accordingly”.
89.Local authorities welcomed the new powers and funding brought forward by the Government. However, many, including London Councils, noted that while civil penalties could now be spent on enforcement, it was too early for councils to know how much funding this would generate and therefore to have the confidence to start recruiting more staff on this basis. It is also logically the case that those local authorities that prioritised informal enforcement activity would not be able to benefit from the income received through civil penalties they had not levied. Bristol City Council and Boston Borough Council both told us that they had successfully bid under the Controlling Migration Fund and had used the funding to undertake work in addition to their core statutory housing functions. The Minister confirmed that there was £47 million still to be allocated from the Fund, and that it would be reopened for bids in the summer.
90.Concerns were raised with us around the ability of local authorities to recover costs from prosecutions. The LGA highlighted that, although some of the powers and tools were available to councils to allow them to recover some of their costs, these were “rarely sufficient to meet the full cost” of enforcement activity. A criminal court can order an offender to pay just and reasonable costs, which can include the prosecutor’s costs of investigating. However, where those costs are disproportionate to the fine imposed, they are unlikely to be awarded in full, especially where the cost of investigating officers would have been incurred anyway because they are employed by the prosecuting authority and carrying out their normal duties. We heard that this created a disincentive for local authorities to prosecute criminal landlords. Councillor Lawton told us:
[ … ] you have to be careful that a decision to prosecute is not coloured by the cost to the council [ … ] If you spend £5,000 prosecuting Mr A or Mrs X and you get £100 back, understandably, given the budget pressures we are under these days, you might get that bit in the local paper and you start to wonder whether it was worth it. I know this is a terrible indictment, but it is a fact of life.
Councillor Salier agreed: “If you put on a new burden and make it cost-neutral, we have to say, “How much are we getting back for carrying out that prosecution?””. The Minister told us she was “frankly appalled” and “hugely disappointed” by such sentiments, explaining:
I hear what you are telling me but I do not accept that. It is that council’s duty to do that. I am sure that if any leader of any council heard their officers talk about a cost-benefit analysis on this, that would be outrageous. It is their duty to do this on behalf of clearing rogue landlords out of it.
91.The level of fines levied, both through civil penalties and prosecutions in the courts, were also considered to be too low by many local authorities. Sir Robin Wales believed that many of the worst, criminal landlords, considered the civil penalties and fines to be a cost of business:
If people are running businesses where they break the law, the punishment needs to break the business model [ … ] Landlords get caught, they pay a fine, and it is part of the business model [ … ] If you have 25 people in a home, which is not unusual [ … ] that is £12,500 per month. I am sorry, but we think there needs to be confiscation of the property. There needs to be a proper thing that says, “Your business model will be broken. If we catch you doing these things consciously, we will take the property.” [ … ] That means fines will have to be properly substantial.
Other local authorities agreed that fines were often far too low. Andy Fisher highlighted an example in Boston, where a landlord had committed 23 breaches of the Housing Act, and received a fine of just £10,000. Councillor Lawton supported this, explaining that “some of the fines levied are pitiful”—often just £100 or £200—particularly in the context of the thousands of pounds local authorities spend in taking criminal landlords to court.
92.We have received evidence that civil penalties are not strong enough to deter landlords who are prepared to commit the most serious offences, and fines issued through the courts are often insufficient to make prosecutions worthwhile. We believe local authorities should have the power to levy more substantial fines, which might stand a chance of breaking the business models of the worst offenders. Further, local authorities should have the power to confiscate properties from those landlords committing the most egregious offences and whose business model relies on the exploitation of vulnerable tenants. Coupled with the banning orders which came into force in April, this would act as a more powerful deterrent than the existing provisions.
93.We believe that courts should require offenders to pay costs that reflect the actual costs to local authorities of enforcement action. There should be no financial disincentive for local authorities to fulfil their statutory duties and pursue prosecutions against criminal landlords.
94.Additional funding should also be made available by the Government through a new fund to support local authorities that primarily undertake informal enforcement activities and are unable to benefit from funding through civil penalties.
95.While reduced resources are clearly a factor in low rates of enforcement in the private rented sector, this cannot explain the significant variation in activity between local authorities. The London Borough of Newham faces the same resource pressures as any other authority, and yet accounted for 50% of all prosecutions in the country. Sir Robin Wales told us that Newham “took a decision that it was more important to do this than most other things”, which suggests that there may also be a question of political will and the prioritisation of resources.
96.The Association of Tenancy Relations Officers described the “striking lack of consistency across authorities which cannot credibly be explained by local factors other than a lack of will, commitment or knowledge”. This was supported by David Smith-Milne from Placefirst, who told us that the quality and calibre of leadership within a local authority made a key difference as to whether enforcement of standards was effective. David Smith from the RLA highlighted the “hard work” Newham had put into making its enforcement teams work so well:
The reality is that most local authorities want to do what Newham are doing but without doing all of the really hard work that Newham had to do to make that happen. It is important to bear in mind that there is a huge amount of effort that has gone on in Newham, in terms of immigration, the police, HMRC, and the TROs, building proper policies and putting a vast level of effort into really tackling these issues. Unless every local authority does that, simply throwing money at it is not enough.
97.Tamara Sandoul from the CIEH told us “it is about leadership, exactly” and local priorities for resource allocation within councils. She explained that, where environmental health teams were well resourced, they tended to be more proactive and perform better. In many local authorities, there was a lack of alignment between different departments, including building control and planning, housing enforcement and trading standards. Ms Sandoul called for better joint working between departments and external organisations, or the transfer of all housing duties to a single department. This was supported by Alison Farrar, from the Chartered Trading Standards Institute, who explained that while trading standards and environmental health teams work in different ways, there were “plenty of opportunities for collaboration” and that this was “something that we would be happy to develop in some areas”.
98.It was also noted that there were opportunities for local authorities to promote the sharing of information between council tax and enforcement teams, to help councils identify private rented properties in their areas. As confirmed in correspondence with the Minister, local authorities have existing powers under the Local Government Finance Act 1992 to collect data for the purposes of Council Tax administration, while Section 237 of the Housing Act 2004 allows data that has been collected for this purpose to be used for the exercise of the local authority’s housing functions. Furthermore, the Housing Tenure Information Working Group recently confirmed that councils already have scope to collect housing tenure information through their council tax registration forms.
99.It is clear that local authorities have fewer resources to enforce standards in the private rented sector than they did in 2010. However, this does not fully explain the variation in enforcement levels that exist between different local authorities. It is clearly the case that some local authorities have placed a higher priority on addressing low standards in the private rented sector than others have done. We believe this disparity in effective action can only be resolved through political leadership.
100.We call on local authorities to reflect on whether their Environmental Health, Trading Standards and other relevant departments are suitably aligned to promote enforcement activity, and whether effective mechanisms exist to work collaboratively with neighbouring authorities. Local authorities should also make full use of their existing powers to obtain information about the tenure of a property on Council Tax returns, which should then be used by enforcement teams to identify private rented properties in their areas.
101.To support local authorities with enforcement activity, Councillor Salier recommended that a national benchmarking scheme be established by the Government. Such a scheme could provide council officers with clear targets on what is expected of them, as well as comparisons to other local authorities. Best practice could be shared between housing enforcement teams in different councils, encouraging co-operative working and maximising the use of limited resources.
102.We believe that a national benchmarking scheme should be introduced—funded and administered by the Government and implemented through the Local Government Association—to support local authorities with their enforcement activity. Local authorities should publish data on the number of complaints they receive and how these are resolved, whether through informal routes or more formal enforcement mechanisms, while local residents should be able to compare enforcement levels in their areas with similar authorities across the country.
103.It is also apparent that there is greater scope for local authorities to work together and share best practice, and to make more efficient use of limited resources. To support this, and to provide greater transparency for residents, local authorities should publish their enforcement strategies for the private rented sector online.
104.Section 80 of the Housing Act 2004 permits local authorities in England and Wales to implement selective licensing of privately rented properties in areas experiencing low housing demand and/or suffering from anti-social behaviour. The same Act also introduced a new licensing regime for Houses in Multiple Occupation (HMOs). In areas with selective licensing, all private landlords are obliged to obtain a licence. The local authority is permitted to take enforcement action against any landlord who fails to obtain a licence, or does not achieve the minimum acceptable requirements. The Government told us that it would undertake a review of the current selective licensing framework before the summer.
105.In 2013, our predecessor Committee urged the Government to give councils greater freedom over when licensing schemes can be introduced and more flexibility over how they are implemented. Consequently, in April 2015, the Government broadened the criteria under which selective licensing may be introduced, so that a designation can now be made if the area to which it relates satisfies one or more of the following conditions: low housing demand (or is likely to become such an area); significant and persistent anti-social behaviour; poor property conditions; high levels of migration; high level of deprivation; or high levels of crime. It has also extended licensing for HMOs.
106.The LGA told us that, “While landlord licensing schemes will not be appropriate in every council area, they can have significant benefits for landlords and tenants”. The RLA supported targeted, specific licensing, because it “helped to break up tenant ghettos and spread tenants out across the whole area”—although they continued to oppose borough-wide schemes. The Minister told us that, where schemes were shown to be working well, the Government wanted to “make sure this good practice spreads out to other areas that are similar”.
107.We heard that there were several advantages for local authorities that implemented selective licensing schemes. Sir Robin Wales—who was responsible for implementing the high-profile, borough-wide licensing scheme in the London Borough of Newham—believed that licensing allowed councils to set tougher basic conditions for private landlords to meet. For example, licensed landlords were required to inspect their own properties every six months and provide gas safety certificates to the council. Councillor Blackburn told us that selective licensing gave council officers the ability to “get behind the front door of properties that we would never otherwise have gotten into”. He highlighted the multi-agency approach adopted in Blackpool, which enabled officials to intervene in situations that would have otherwise remained hidden. Councillor Newman explained that selective licensing increased the likelihood of a positive outcome when criminal landlords are prosecuted, noting the “very clear focus to a set of conditions that should be met”.
108.Local authorities that had implemented selective licensing schemes cited improved enforcement statistics as proof of their success. The London Borough of Newham told us they had issued 39,321 licences to 26,072 landlords and, since 2013, 1,225 prosecutions had been brought against criminal landlords, with 28 having been banned from the sector. In Waltham Forest, where a borough-wide licensing scheme had also been implemented, the council had prosecuted 60 private landlords between February 2016 and April 2017, resulting in fines and costs of approximately £200,000. In Blackpool, there were 875 properties licensed, 752 schedules of work and 87 formal notices issued, and 16 prosecutions.
109.However, David Cox from ARLA Propertymark told us that, far from demonstrating success, these statistics were evidence of failure. He set out the London Borough of Newham’s prosecution record:
Newham have done 1,200 prosecutions, or 240 a year, out of 47,000 properties. That is 0.5% of properties in their area that they have done anything about and have done prosecutions. I would note that that is with 140 officers. They have 40 police officers, 100 enforcement officers and they have done 240 prosecutions a year. That is less than two prosecutions an officer. If that is what is classed as success—and it is classed across the industry as the most successful licensing scheme in the country—really what does that say? It is pitiful.
110.Low levels of enforcement within selective licensing areas were a key concern for many of our witnesses. Dr Julie Rugg told us that there was little empirical evidence that selective licensing schemes had a beneficial impact on the quality of private rented accommodation where they have been implemented, and that many appeared to be, “a bureaucratic exercise of making lists of people, charging amounts of money, receiving those moneys and just maintaining lists”. David Smith from the RLA agreed, telling us, “there is no substantive evidence that licensing does anything better than get people to have licences”, while David Smith-Milne of Placefirst said, “the lack of evaluative evidence is a real concern”. The lack of such evidence was not denied by advocates of selective licensing, with Sir Robin Wales telling us, “I cannot, if I am honest, say that I have absolute proof” of a general increase in the quality of private rented housing in Newham since the introduction of licensing in 2013.
111.Having received written evidence primarily from local authorities who were in favour of selective licensing schemes, we proactively sought evidence from councils that had considered, but ultimately rejected, such schemes for their areas, to ask them why they had taken this approach. Councillor Lawton told us that Bournemouth Borough Council had rejected selective licensing was because they were concerned costs would be passed on to tenants in higher rent. He explained:
[ … ] If you charge a landlord £500 per unit over five years—the licence would last for five years—it is £100 a year. That is £2 a week, and they would probably increase the rent by that amount. As I said earlier, although the people at the higher end of the market could probably afford that, people at the lower end may find it difficult. It really could just tip the balance against them.
He was also concerned about the possibility of judicial review from landlords’ representatives, and the potential cost that could be incurred as a result. Councillor Salier told us that, in Wandsworth, it was felt that only a very small number of private rented properties were of an insufficient standard, and that selective licensing would not be the best use of council resources, and would place an unfair burden on the majority of landlords who were doing a good job. In Boston, consultation responses indicated that landlords, tenants and businesses were unanimous in their opposition to selective licensing, and that “we were prejudicing everybody for the risk of the minority and that, instead, we should be focusing our enforcement action on targeting the worst”.
112.Furthermore, the British Property Federation highlighted several selective licensing schemes that they felt had not been well-deployed, or failed to meet their objectives. One example was Manchester City Council, which decided to withdraw their selective licensing scheme after five years, stating: “Members and landlords have criticised the scheme as being overly bureaucratic, with too much effort focused on the paperwork and administration and not enough on tackling the poorer landlords through enforcement and prosecution”. They also noted Rochdale Council which, despite having had selective licensing for 10 years, continued to have problems of “poor quality landlords offering very poor quality and often illegal properties for rent”.
113.We also heard suggestions for alternatives to selective licensing schemes. ARLA Propertymark told us that local authorities should adopt collaborative approaches to tackling issues within the private rented sector, citing as an example the London Rental Standard—a voluntary minimum set of rules that landlords and letting agents must agree to adhere to in order to operate in London. This enabled local authorities to target their resources on intelligence-led enforcement, rather than the administrative burdens of a licensing scheme. The NLA strongly advocated landlord accreditation as an alternative to licensing, explaining that it looked to work with local authorities to address issues using existing powers and encourage engagement with the local landlord community. The British Property Federation supported proposals for a national register of landlords, which would provide a registration number to be used in all interactions with public bodies.
114.Since April 2015, local authorities have had to seek approval from the Secretary of State for selective licensing schemes which would cover more than 20% of their geographical area or would affect more than 20% of privately rented homes in the area. In correspondence with the Minister, it was confirmed that—of the seven applications that the Secretary of State had considered since 2015—one had been rejected completely, two were confirmed in part, and four had been confirmed in full.
115.We heard that this application process was not fit for purpose. Councillor Blackburn told us that it took 20 weeks for the Government to respond to Blackpool Council’s application for a selective licensing scheme, far longer than the eight weeks it should have taken according to Government guidance. The London Borough of Newham also experienced delays with its recent application to the Government, leaving a significant gap between the expiry of the old licensing scheme and the commencement of its replacement. Councillor Blackburn was also concerned that the Minister’s decision was “heavily dependent upon the advice of civil servants”, who could not be expected to appreciate the local challenges in different parts of the country.
116.Others objected in principle to the application process. The LGA told us that, “requiring approval from the Secretary of State for licensing in a large area is an unnecessary intervention in local decision-making and should be removed”. Councillor Blackburn described the process as “contrary to the spirit of localism”, while Bristol City Council expressed their view that, “authorities should be able to make informed local decisions themselves on what is best to improve the private rented stock in their areas”. Even local authorities that had decided against implementing a selective licensing scheme of their own, agreed with the principle that the decision should ultimately rest with the local authority concerned. However, in response, the Minister highlighted the importance of having a high threshold for the implementation of selective licensing schemes:
Believing in localism, they will come to me with the evidence, and the evidence will say whether it is acceptable or not. There has to be a high threshold. If we are bringing in very strong laws and a quite bureaucratic workload for different groups, which therefore will have a knock-on effect on cost, let alone the licence to register at all, then it has to have a high threshold. That is appropriate.
The Minister later confirmed that the application process would form part of the review of selective licensing that was due to take place before the summer.
117.We have received mixed evidence on the value of selective licensing schemes, which reflects the different circumstances that exist in different parts of the country. Our predecessor Committee called on the Government to bring forward proposals for a reformed approach to selective licensing, which would give councils greater freedom over when licensing schemes can be introduced and more flexibility over how they are implemented. We support the changes the Government has introduced since then, including the extension to HMO licensing and the broader criteria that were introduced for selective licensing. The Government has said that it intends to review the current selective licensing framework before the summer, and this will be an opportunity for further improvements to the selective licensing system.
118.We believe that the current process of application to the Secretary of State is not fit for purpose. Decision-making is too slow, lacks transparency, and is overly bureaucratic and unduly expensive. In our view, decisions to implement such schemes should be made locally, where there is greater understanding of local needs and politicians are directly accountable to the electorate for their decisions. We recommend that the Government therefore remove the 20% cap above which local authorities must seek permission from the Secretary of State to implement selective licensing schemes because it is contrary to the spirit of localism. However, we believe that the Secretary of State should retain a power to require local authorities to reconsider a decision to implement a licensing scheme that does not meet the strict criteria already set out by the Government, and should monitor the effectiveness of schemes once they have been implemented.
154 ARLA Propertymark () and Q177 (David Cox, ARLA Propertymark)
155 Q114 (Adrian Jeakings, National Landlords Association)
156 Q307 (Heather Wheeler MP, Minister for Housing and Homelessness)
157 Residential Landlords Association Briefing for Second Reading Debate: Homes (Fitness for Human Habitation and Liability for Housing Standards) Bill 2017–19, January 2018
158 Q89 (Dan Wilson Craw, Generation Rent), highlighting statistics found in: , December 2015
159 17% of private rented dwellings had at least one Category One hazard: Department for Communities and Local Government, , March 2017, para 4.15
160 Q10 (Kate Webb, Shelter)
161 Q114 (David Smith, Residential Landlords Association)
162 , The Guardian, 28 October 2017
163 Q159 (Sir Robin Wales, London Borough of Newham)
164 Q232 (Tamara Sandoul, Chartered Institute for Environmental Health)
165 Q213 (Andy Fisher, Boston Borough Council)
166 Q204 (Andy Fisher, Boston Borough Council)
167 Q211–3 (Councillor Clare Salier, London Borough of Wandsworth)
168 Q115 (David Smith, Residential Landlords Association)
169 Q115 (David Smith, Residential Landlords Association)
170 Local Government Association (), para 3.7
171 Crisis ( ), para 18, and Chartered Institute of Housing ()
172 ARLA Propertymark ()
173 Q204 (Andy Fisher, Boston Borough Council)
174 Shelter (), para 17
175 For example, Q211 (Andy Fisher, Boston Borough Council) and Q212 (Councillor Clare Salier, London Borough of Wandsworth)
176 DCLG (), para 14
177 Q307 (Heather Wheeler MP, Minister for Housing and Homelessness)
178 DCLG (), para 15
179 London Councils ()
180 Q204 (Andy Fisher, Boston Borough Council) and Bristol City Council ()
181 Q310 (Heather Wheeler MP, Minister for Housing and Homelessness)
182 Local Government Association (), para 4.4
183 Prosecution of Offences Act 1985, s 18; Associated Octel Ltd  1 Cr App R (S) 435
184 BPS Advertising Ltd v London Borough of Barnet  EWHC 3335 (Admin). See, generally,Archbold, Criminal Evidence, Pleading and Practice 2018 para 6–34.
185 Q222 (Councillor Robert Lawton, Bournemouth Borough Council)
186 Q222 (Clare Salier, London Borough of Wandsworth)
187 Q308–9 (Heather Wheeler MP, Minister for Housing and Homelessness)
188 Q155 (Sir Robin Wales, London Borough of Newham)
189 Q213 (Andy Fisher, Boston Borough Council)
190 Q210 (Councillor Robert Lawton, Bournemouth Borough Council)
191 Q159 (Sir Robin Wales, London Borough of Newham)
192 Association of Tenancy Relations Officers (), para 9
193 Q133 (David Smith-Milne, Placefirst)
194 Q115 (David Smith, Residential Landlords Association)
195 Q246 (Tamara Sandoul, Chartered Institute for Environmental Health)
196 Q230 (Tamara Sandoul, Chartered Institute for Environmental Health)
197 Q230 (Alison Farrar, Chartered Trading Standards Institute)
198 Q238 (Melanie Rees, Chartered Institute of Housing)
199 , 13 March 2018
200 National Landlords Association (), para 8
201 Q207 and Q211 (Clare Salier, London Borough of Wandsworth)
202 , House of Commons Library, 9 June 2017
203 Q312 (Heather Wheeler MP, Minister for Housing and Homelessness)
204 , 2013–14, CLG Committee, para 49
205 , Department for Communities and Local Government, March 2015
206 Local Government Association (), para 5.1
207 Q119 (David Smith, Residential Landlords Association)
208 Q312 (Heather Wheeler MP, Minister for Housing and Homelessness)
209 Q153 (Sir Robin Wales, London Borough of Newham)
210 Q160 (Councillor Simon Blackburn, Blackpool Council)
211 Q164 (Councillor Tony Newman, Local Government Association)
212 London Borough of Newham ()
213 London Councils ()
214 Q159 (Councillor Simon Blackburn, Blackpool Council)
215 Q183 (David Cox, ARLA Propertymark)
216 Q23 (Dr Julie Rugg)
217 Q119 (David Smith, Residential Landlords Association) and Q121 (David Smith-Milne, Placefirst)
218 Q160 (Sir Robin Wales, London Borough of Newham)
219 Q219 (Councillor Robert Lawton, Bournemouth Borough Council)
220 Q219 (Clare Salier, London Borough of Wandsworth)
221 Q219 (Andy Fisher, Boston Borough Council)
222 British Property Federation ()
223 As found in , House of Commons Library, 9 June 2017, page 25
224 ARLA Propertymark (), para 16
225 National Landlords Association ()
226 British Property Federation ()
227 , 13 March 2018
228 Q166 (Councillor Simon Blackburn, Blackpool Council)
229 Q159 (Sir Robin Wales, London Borough of Newham)
230 Q166 (Councillor Simon Blackburn, Blackpool Council)
231 Local Government Association (), para 5.6
232 Q166 (Councillor Simon Blackburn, Blackpool Council) and Bristol City Council ()
233 Q220 (Councillor Clare Salier, London Borough of Wandsworth, and Councillor Robert Lawton, Bournemouth Borough Council)
234 Q321 (Heather Wheeler MP, Minister for Housing and Homelessness)
235 , 13 March 2018
Published: 19 April 2018