London Lockdown Project Operation Lockdown

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1 London Lockdown Project Operation Lockdown Carlene M. Thomas Environmental Health Team Manager London Borough of Lambeth

2 Why & How We Started? In 2015, 6 London Authorities identified that a group investors were acquiring properties in their areas and converting these into self-contained units. Lewisham Lambeth Hackney Haringey Greenwich Southwark Croydon,Islington,Bexley, Bromley, Hounslow, Brent *Joined Later

3 The Lettings Model (1) The conversion of two storey houses into six room dwellings with their own bathroom and a shared kitchen. Each dwelling has its own very basic, sometimes portable, cooking facilities. Not classed as an HMO for planning purposes (comes within permitted development rules C3-C4 unless an Article 4 Direction is in place) and not licensable as an HMO under Mandatory Licensing. Let to over 35s in order to attract the highest rate of Housing Benefit paid for a self-contained unit (often nearly twice the shared room rate).

4 The Lettings Model (2) Some landlords have obtained Registered Provider status to avoid HMO Licensing requirements. Owners/agents market properties to Local Authority Homelessness Teams who are often desperate for accommodation and whose clients will usually qualify for Housing Benefit. Model being marketed for new investment

5 Problems Associated with the Model (1) Certification from private Building Control companies which can be unreliable. Poor space standards and ergonomics. High demand on the electrical circuits and evidence of sub-standard installations. *However, on the surface attractive finishes.

6 Problems Associated with the Model (2) Changes to the character of neighbourhoods as several properties in single streets are bought up and a domino effect created. Anti-social behaviour. Some anecdotal evidence of serious physical violence as individuals from different ethnic and cultural backgrounds are placed together. Additionally, women have experienced harassment from both their landlords and other tenants. High cost of Housing Benefit and poor value for money which the lettings represent

7 Our Approach (1) DCLG rogue landlord funding for Greenwich, Hackney, Haringey, Lambeth, Lewisham, Southwark/Bexley. Monthly meetings at Lambeth External Sharepoint site Legal Advice Member Awareness Intelligence Officer (investigate links between companies and Individuals)

8 Our Approach (2) Tried to develop a common approach, methodologies varied Investigations EHO, Planning or Intel. Led Contract with NAPIT Information sharing with HMRC (one way). Raising awareness with Homelessness and Social Services placement teams. Not all using Setting the Standard although currently that only covers nightly lets.

9 Housing Benefit Rules (1) A one bedroom rate must include exclusive use of at least two rooms (bedroom, living room, dining room) but not necessarily a bathroom or kitchen; OR, exclusive use of one room plus a bathroom and toilet and a kitchen or facilities for cooking. A decision was made in 2013 at the Upper Tribunal (Administrative Courts Tribunal) by Judge West under the reference CH/756/2013. It concerned Crawley Council and an appeal by a tenant in relation to facilities for cooking.

10 Housing Benefit Rules (2) The claimant had one room plus a separate bathroom. The cooking facilities consisted of a single pot plug-in Breville cooker together with a kettle. Any plates and utensils had to be washed in the hand basin. The appeal was dismissed and the judge went on to describe what he considered to be facilities for cooking. The ruling should allow councils to restrict use of this model by paying the shared room rate in many cases. If more extensive cooking facilities are installed, Planning may consider the work to amount to a conversion to S/C units.

11 Raising Awareness DCLG HMRC* London Building Control Officers London Fire Brigade UK Power Networks EDF GLA Conference EHN

12 Reported Achievements (2016) 3,204 property inspections 68 raids 785 enforcement notices served 39 Prohibitions on use issued 58 prosecutions/poca actions commenced Landlords usually comply with notices The above went wider than Lockdown and included HMO licensing outcomes during the course of the project The basis of a more effective and proactive way of working Bexley decision on HB restriction

13 Project Progress Interim Report sent to DCLG (October 2016) Intelligence Gathering Continues Continue with the programme of inspections Raising Awareness incl. Housing Benefits & Third Sector Prosecution Cases Work Programme for 2017/18 (including further funding)

14 Press & Publicity Lambeth Council Communications Team & CIEH Publicity Officer (coordinated press releases) Dispatches EHN Article Sunday Times Newspaper LGA BBC & ITN FOIs * Twitter

15 Thank You Any Questions?