Portsmouth Landlord Applies For HMO Licence In Less Than 1 Hour!
You would think it was not news – but we have been arguing for 3 months since the new licensing application software was introduced that it is badly written, hard to use and asks for too much information. We have members who have spent 2 weeks trying to get a single application completed. The PCC response has been to largely ignore us and tell us it only takes an hour and then it is done – even when members take all the necessary documentation in and sit and watch while PCC staff perform the task it takes them 2 hours per property.
Well, we need to apologise – after 3 months training and extensive practice, one of our members completed their final application in just 59 minutes and 44 seconds.
How Was It Done?
The application was completed under laboratory conditions. A timer was started when the application was started and stopped whenever the landlord left the application to get documents from another folder or for any other reason. The total elapsed time was over 2 hours but the time 'actually applying' was, as stated, just under 1 hour.
To achieve this time, the landlord started his 1st application late on the 1st September when the application process belatedly went live, he had multiple trial runs over the following 3 months before this 'exam condition' trial at the end of November and, in the interim, was fully aware of all of the issues experienced by other members via our very active Facebook group – so he knew to avoid long file names, scans into multiple files and all the other minor things that had floored prior applicants.
Why Is It So Bad?
Simply put, this application process should be simple and intuitive because users will invariably be 'new users' only ever having to use it a small number of times, it should be logical, it should help by preloading fields with what it already knows and avoid repetition, it should work on most browsers, accept inputs in a range of formats and styles and should only ask for the information essential to the task.
Sadly, it fails miserably on every single one of these points (and a few others). Some examples from our 'trial' applications:
Simple and intuitive? A couple manage a small HMO jointly so they want to both be licence holders. Imagine the additional pain if one of them dies during the licence period and, on top of everything else, the surviving spouse has to re-apply for a licence as it was in the others name. The good news is, the process does support joint applicants BUT to do so:
- In section 2, when you enter your personal details you have to say you are NOT the licence holder
- Having said you are NOT the licence holder, this presents section 3 where you enter your personal details stating you ARE the licence holder
- Then, at the bottom of the screen, you click 'add another' and enter your spouses personal details as the other licence holder
Given that there is no help text or guidance through any of this – the likelihood of a landlord stumbling on this solution is slim. One landlord thought he'd cracked it by ticking the 'Partner' option but that has resulted in a completely wrong licence which he is now trying to get corrected (more work for all).
Preloading Fields? On our record-breaking application our landlord only had to enter his personal details including address etc four times – we are told that it is worse for 257's though have yet to confirm that.
Work on most browsers? Oddly the quirks seem to be different from one users screen to the next. On our record attempt, every time we hit 'next' at the bottom of the page, the application would jump (very slowly) to the bottom of the next page – once the initial disorientation is overcome and one gets used to it, all one needs do is scroll back to the top and continue – but as a page can often be 4 or 5 screens long, that in part contributes to the extended time required to complete an application.
Accept inputs in a range of formats and styles? One of the big issues with the application software is that there is no exception handling. A key part of any software development is where the programmer writes code to handle situations that can cause errors. If something unexpected happens, like a user inputting incorrect data or a resource not being available, the error handling code will catch these issues and provide a response, such as an error message, instead of allowing the programme to crash or behave unpredictably. This makes the software more robust and user-friendly. With the PCC software, we have examples of users spending more than 2 weeks trying to upload files with no idea that the only reason the screen would hang for an hour or two before dropping was because the name of the file being uploaded was longer or in a different form to what the program expected. Similarly, users who for example, drew their house plan on 2 sheets (1 per floor) and tried to upload them as 2 files failed miserably as the system would only accept 1 file at this point and gave no indication that additional files could be uploaded later in the process (often much later as file uploads were typically required in steps 6 – 9 whereas additional files came in at the end of the 18 stage application process).
And don't ask why there are 18 stages, there are only 7 to get to the top of Everest!
Perhaps the worst fault of the whole process is the sheer volume of information required.
- You have to upload a plan of the property and that plan needs to include room sizes and the like
- You then have several screens where you have to enter the individual room sizes that are already on the plan
- You have to specify that you have an EPC and state the rating
- Next you have to upload the EPC certificate. To do this, you have to go onto the government site, open the EPC, download it to your computer and then upload it to the application
- Wouldn't it just be quicker and easier for everyone for PCC to check it on the government site? If they don't trust us and think we may be lying about having one, isn't it also logical that the one we upload is not real or is one we have doctored? What is the point…..?
And when you upload one of your many files – don't expect to simply 'drag and drop' the file into place. Sadly the resources were obviously not available when that piece of code would normally have been added.
Total Lack Of Trust
The worst thing is the total lack of trust that has been embodied in the process around Licensing and the software used to support it.
A good landlord, who has been practising for a number of years without issues, who is accredited with an appropriate organisation and signed up to their code of conduct, who was licensed in previous schemes without issues, without any history of problems, convictions, etc with a property largely unchanged from last time around and with the same tenure ought, you would have thought, to have sailed through the process – freeing up council resources to focus on those that do not meet these criteria.
Sadly, that is not the case. It is obvious that the PCC team are solely interested in creating a labour-intensive bureaucracy which will allow them to be very industrious 'managing' the good landlords and free them from having to do anything about the rest.
A question we often hear: "I am accredited, I am an active member of the local landlord association, I have signed up for Licensing which as a condition says I need to keep certificates up to date. Why do PCC want me to send a copy every year when they are renewed when nearly every other local authority in the country trusts me to do so while reserving the right to view the certificates should they need to do so?"
Cumbersomeness…..
The infinite monkey theorem states that if you have an infinite number of monkeys with an infinite number of typewriters hitting random keys an infinite number of times, eventually one of them will type out the entire works of Shakespeare.
You can debate issues of dependencies on the monkey that achieves this task also having correctly loaded paper and the like – but that just complicates things and the underlying principle is valid.
Sadly, on the day PCC sat down to design their application process, it appears that no monkeys were available……
Evidence in support – when applying for a simple, small HMO. Just 4 beds – you have already stated it is a shared property in earlier questions. We now get to bathing facilities: question 7 of the process asks how big the bathroom is. That's fair enough.
7.2 then asks how many of these (1) bathrooms are for sole use. Odd as we have previously stated the whole property is let to a group on a shared basis but fair enough, we enter '0'
7.3 then asks how many of these (1) bathrooms are shared. Bit odd – obviously just the one as we already stated it is not for anyones sole use. OK, we will type in '1'
Now we get 7.4 asking for each bathroom which letting rooms are intended to share it. Bit odd but we guess there are some strange living arrangements among PCC staff…..
We then get the same 3 questions repeated relating to the toilet(s) in the shared bathroom….
Surely they can't be thinking of more than 1 toilet in a bathroom
Even more unlikely, the concept of a sole use toilet in a shared bathroom – we are beginning to wish the monkeys had been available on the day they sat down to do this….
We then move onto toilets which are not in bathrooms and have the same string of illogical and badly phrased questions.There must be a rash of rogue landlords overcrowding bathrooms with multiple toilets each labelled for the personal use of one of the tenants – why else could they possibly be so suspicious of our motives?
You think the water torture has ended but then you move onto wash basins (sinks in kitchens get a similar treatment elsewhere in the process). Having worked out how many bathrooms are shared and how many are not and whether those bathrooms contain toilets and whether they are shared and if not who they are for and also having worked out how many toilets there are not in bathrooms and how many of these are shared and for those that are not, who is authorised to use them – you then have to do the same for wash basins. We are baffled as to what type of rogue wash basin installation one might encounter that would generate the need for this level of interrogation.
We fully expect PCC to start asking landlords for monthly testing of wash basins with full logs sent to PCC to confirm only the correct people are using them in the correct way – if there is any evidence of a drunken tenant pee'ing in a basin, the landlord should expect a stiff penalty!
Did we mention there was a similar and equally bizarre rigmarole on kitchens and how many sinks they have and who can use each one…
Our Recommendation
As we have said all along. This is a PCC created problem designed to give them work at our expense – so do not tear out any little hair you have left trying to navigate the uncharted reefs of licensing, book an appointment at the Civic Offices (hopefully the phones will start being answered before Christmas) and let them do the work.
When you encounter issues or if you find the level of detail unnecessary or inappropriate do please complain. Our aim is to collate all complaints and ask the Local Government Ombudsman for a ruling to improve this process and to reduce the level of information demanded.
If you do nothing, this bureaucracy will continue to grow and the pain inflicted upon us in terms of time, stress and money will also increase. If you have finished your Additional applications and think, "well that is finally done, I can forget about it now" what you are doing is consigning Mandatory Licence holders to the same pain for evermore – so please do your bit and register your dissatisfaction – it may not help you as the pain has been endured, but it will help reduce the pain for others and hopefully stop things getting even worse.
If PCC are correct and there are 6,000 HMOs, assuming that 20% get 5-year licences, 20% get 1 year licences and the rest get 2.5 year licences, that equates to an income for PCC over 5 years of more than £10.4M – taken out of local landlords pockets and out of the local economy for no purpose and with no added value in the local area.
Worse, even if every landlord manages to get their application in during a morning – possible given this test but based on experience, at best an average and more likely, an underestimate. 6,000 properties entered in a time of 3 hours per application – that equates to over 10 man years of landlord time, when they could be doing something that actually adds value to their properties rather than just filling in this form. For comparison, our trial landlord applied for gun – it took less than 20 minutes to make a licence application and we feel compelled to ask, what is more dangerous, a gun or an HMO? And also, now we have one – can we resist the urge to use it?
Editor note: No idea who wrote the last paragraph but a landlord waving a gun was seen screaming while running from the building. It is no wonder landlords are leaving Portsmouth in droves.