All Quiet On The Licensing Front
Since the Consultation finished 2 months ago, the stony silence on the subject of Licensing smaller HMO's in Portsmouth has been almost relaxing – no worries about unachievable kitchen widths, whether the alcove by the door is counted as part of the room or not, where the washing machine is in relation to sleeping rooms – the absence of all that nonsense has been bliss.
But it will not last….
What Happens Next?
We were expecting a proposal to be made at the housing cabinet meeting in November, but that has now been scheduled for December 8th – so we do not expect proposals to be made public until that week, either at the HMO Governance Board (of which the PDPLA is a member) or at the Cabinet meeting itself – though one assumes they will be discussed behind closed doors prior to that.
What Are We Hoping For?
For us, the only sensible decision is NOT to proceed with licensing for smaller HMOs. In a time of extreme housing shortage, to raise the bar and make the cheapest accommodation unaffordable would-be madness, especially given the lack of evidence to support the introduction, the evidence that prior schemes did nothing to improve the issues that so concern residents and the lack of resources to manage the current workload within the council.
What Are We Expecting?
Sadly, even though many council employees have told us privately that they see no justification for Licensing and that they struggle to manage with current workloads or to recruit suitably skilled staff, our expectation is that council staff will find a presentation of the 'facts' to justify the introduction of licensing because they know that local councillors are determined to proceed with such a scheme and it would be a foolish employee who pushed back against those expectations.
The driver for Licensing, according to Cllr. Sanders, is a desire to increase the standard of HMO housing in the city. An admirable sentiment but sadly a minefield.
Firstly, there is a question of affordability. A 10 square metre room is going to cost twice as much as a 5 square metre one – maybe not exactly double, but capital outlay for the land, the build cost, the furnishing, etc all needs to be recovered – then there are the heating costs, insurance etc – they all have a bearing and 2 identical houses, one housing 5 people and the other 4 are going to have similar costs but when split between the occupants, the 4 person house is going to be 20% more expensive than the 5.
The second big issue is the debate about what is an acceptable standard. Does a student need the same facilities as a single mum with baby or a contract worker down here on a long-term contract have the same needs as a long-term resident working in the NHS? Yes – all housing should be safe – that is a given and it should have adequate heating – the days of waking up to ice on the inside of the windows or all huddling round a small fire in the sitting room have fortunately, long past, but as soon as we specify more than that we start adding cost and excluding perfectly acceptable properties for silly reasons.
Yes, it makes sense to have 60cm of worktop on each side of a hob – but in some circumstances, a hob at the end of the worktop makes more sense than in the middle. Yes, a 2.4m wide galley kitchen allows multiple people to pass while doors are open and the kitchen is busy - but if, like many Portsmouth kitchens, it is only 2.2m wide is that such a big deal? The issue with clearly defined standards is that houses are unique and however hard you try, you end up with a specific rather than a generic standard – and most houses don't meet all the details in examples we have seen, so require modification or alteration and that adds cost.
Our concern is that the much needed update to the HMO standards document was included in the 'Small HMO Licensing' consultation and whether PCC decide to proceed with Licensing or not, they will introduce the new standards based on the review at consultation – this will impact ALL of the larger HMOs, landlords of which will probably not have participated in the consultation as it did not affect them – so apart from our prediction that most 3 and 4 bed HMOs will leave the market to avoid the overheads of Licensing, the impact on the 1,400 larger HMOs in the city has yet to be quantified and could be even more damaging.