PDPLA Rejects Additional Licensing
Well it is obvious we would not vote for it - but it is not the extra regulation, cost or bureaucracy that we are objecting to, it is the fact that the current proposals will make 1,000-1,500 people homeless and the impact on the city and across the council, in terms of rehousing the most vulnerable, the burden on Adult Social Care and many other groups, as well as the impact on local rents and house prices cannot be justified by this action.
An Overview Of Our Objections
The Portsmouth & District Private Landlords Association reject the need for Additional Licensing in the city on the grounds that it is not justified by the evidence, it did not work last time, it will not resolve the issues that are being raised this time and it will make a large number of vulnerable residents homeless.
Much of the logic used to justify the introduction of Additional Licensing is flawed. PCC assert that there are 6,000 HMOs in the city, yet our evidence shows only 2,600. The proposed scheme is overblown and excessively expensive and sets standards which will push thousands out of their homes in the city as they will no longer be able to afford to live here.
There is no evidence whatsoever presented that suggests the need for a city-wide scheme and the restrictions planned appear to bear no relation to the issues raised and will not resolve them. Additional Licensing can ONLY be introduced IF "a significant proportion of the HMOs (that will be subject to the proposed designation) in the area are being managed sufficiently ineffectively as to give rise, or likely to give rise, to one or more particular problems either for those occupying the HMOs or for members of the public" – the evidence does NOT support a citywide implementation even if there may be a case for limited action in some specific cases.
PCC state that "the council have found upon inspection that approximately one third of HMOs in the city have significant hazards, which present potential health and safety issues to the occupants" and asserts that as HMOs are used to house the poorest and most vulnerable and that this group are least likely to complain about poor conditions, then a scheme that ensures conditions are checked automatically would be a good thing.
We have 4 main issues with this logic:
- 1.The data is flawed. Assuming that small HMOs are the same as large HMOs, with no evidence to support this view, is illogical
- 2.It did not work last time (See 'Additional Licensing Failed 2013-2018')
- 3.The supporting evidence is worthless (See 'PCC 'Survey' Data Inadmissible'')
- 4.The Risk Analysis grossly underestimates the possible negative impact (Risk Analysis)
The proposal is to extend Licensing to all 3 and 4 bed HMOs city wide and 'other self-contained flat type HMOs – PCC attempted to include '257' type properties before and it just does not work. (See 'Why You Cannot Include 257s') and is not justified on the evidence provided.
To proceed with Additional Licensing, the council must consider whether "there are any other courses of action available to them that might provide an effective method of dealing with the problem or problems in question." We make several suggestions which will help resolve the perceived issues without the need for the overhead of Additional Licensing – we urge Portsmouth City Council to seriously consider them before deciding.
For the full report with detailed analysis and evidence supporting all of the above facts, see the full document here: https://pdpla.com/public-documents/388-pdpla-response-to-portsmouth-city-council-proposal-to-introduce-additional-licensing