A Proposal for Selective Licensing in the Royal Borough of Greenwich
Page | 1 Table of Contents
Section Page No. 1 Introduction 3
2 Executive summary 3
3 Background 4
4 Legislative Background 5
5 Strategic Context 8
6 Evidence Base 13
7 Licensing Criteria 42
8 Proposed Fees 44
9 Proposed Conditions 50
10 References 51
Appendices 52 Appendix 1 : List of Streets within proposed area Appendix 2 : Royal Borough of Greenwich Financial Incentive Policy Appendix 3 : Case Studies Appendix 4 : List of Accredited Landlord and Letting Agent Organisations Appendix 5 : Proposed Selective Licensing Conditions Appendix 6 : HHSRS 29 Hazards
Page | 2 1. Introduction
1.1 The Royal Borough of Greenwich has considered a range of evidence as laid down in the Housing Act 2004 and subsequent legislation to determine whether the whole borough or a part of the borough would benefit from the designation of a discretionary Selective Licensing scheme.
1.2 In considering the evidence the Royal Borough has considered the criteria set down by legislation and the priorities set by the Royal Borough through its corporate aims and objectives.
1.3 As a Royal Borough we recognise that a person’s home is fundamental to every aspect of life and;
1.3.1 We are committed to driving up standards in the private rented sector to achieve safer communities and contribute positively to the local economy and;
1.3.2 We want to improve private rented property management and conditions to provide good quality accommodation and;
1.3.3 We know some of our migrant communities and vulnerable people are at risk and are unlikely to report poor accommodation.
2. Executive Summary
2.1 The Royal Borough of Greenwich is proposing to implement discretionary Selective Licensing in a defined area of the Royal Borough to ensure that the private rented sector provides decent quality accommodation, that anti-social behaviour is effectively managed and issues of social deprivation and crime in areas of the Borough are addressed.
2.2 The Royal Borough of Greenwich has considered the criteria set down by the Housing Act 2004 and subsequent legislation and produced evidence under 5 out of the 6 specified criteria which supports the introduction of Selective Licensing in a defined area of the Royal Borough.
2.3 The evidence does not support a borough wide Selective Licensing scheme currently. The Royal Borough will continue to review conditions and related issues within the private rented sector to determine whether further areas of the Royal borough should be so designated in future.
2.4 Map 1 shows the proposed area for designation and section 6 of this report details the evidence for why this area is proposed.
Page | 3 MAP 1 Proposed Area for designation of Selective Licensing
2.5 A list of the streets involved is available in Appendix 1 to this report. It is proposed that a postcode checker will be available on the Royal Borough website for landlords to identify whether a property is licensable.
2.6 The proposed area represents 18.9% of the total private rented stock in the borough excluding HMOs and less than 20% of the geographical area of the Royal Borough.
2.7 The proposed area demonstrates significant combined issues relating to anti-social behaviour; crime; poor property condition; deprivation and migration.
2.8 The proposed area, and no area in the Royal Borough can demonstrate the criterion for low housing demand.
3. Background
3.1 The Royal Borough of Greenwich is a key tourist destination; home to a World Heritage Site, The O2 arena, London’s prettiest royal park and the Prime Meridian of the World – longitude zero. It is also ranked the 60th most deprived (with 1 being the most deprived) borough in the UK and ranks 13th out of all London Boroughs.
3.2 Royal Greenwich is a diverse borough with settled and new migrant communities of all nationalities and has in recent years seen major regeneration and new housing developments along the Thames river frontage including the redevelopment of Greenwich Peninsula and Woolwich Arsenal, new transport links through the DLR and Jubilee Line and is a destination for Cross Rail at Woolwich and Abbey Wood. Regeneration of the river frontage and town centres is ongoing.
Page | 4 3.3 To the south of the borough is more established long term white British communities, owner occupation and social housing.
3.4 Because of recent new migration and the increasing PRS, the Royal Borough has seen a significant change in demography with a reduction in owner occupation from 46% in 2014 to less than 40% in 2020 and an increasing private rented sector (PRS), from 19.7% in 2014 to more than 32% in 2020. The total PRS can be further broken down between HMOs and single households, 6.7% and 26% respectively. This compares to a national trend of increasing PRS nationally at 19% in 2019 from 17.9% in 2014.
3.5 Much of this growth in PRS in the borough stems from new build, particularly flats, some of which are let in multiple occupation.
3.6 The Royal Borough implemented a borough wide Additional Licensing scheme from 1st October 2017 and also licenses Mandatory HMOs. Noncompliance with HMO licensing is running at 84% and there is an active enforcement programme in place. The numbers of HMOs in the Royal Borough continue to increase.
3.7 The HMO licensing programme is a key theme within integrated enforcement seeking to improve housing conditions and reduce crime and anti-social behaviour.
3.8 We believe that the introduction of a Selective Licensing scheme into an area of the borough will further support overall regeneration and the improvement of conditions in the wider private rented sector and help tackle crime and anti-social behaviour.
4. Legislative Background
4.1 The Housing Act 2004 gives Local Authorities the power to declare Discretionary Licensing. It is intended to provide Local Authorities with greater controls on maintaining the condition of the private rented housing stock including management and can be used to seek to address through conditions and a greater liaison with landlords, poor management including nuisance and anti-social behaviour by requiring Landlords to address issues directly with their tenants.
4.2 With effect from 1 April 2015 Local Authorities are required to obtain approval from the Secretary of State for any Selective Licensing scheme which would cover more than 20% of their geographical area or would affect more than 20% of privately rented homes in the local authority area. A designation may be made to combat problems in an area experiencing poor property conditions, an influx of migration, a high level of deprivation or high levels of crime or Anti-social Behaviour. 4.3 An independent review of Selective Licensing was carried out in 2019 and concluded that overall selective licensing can be an effective policy tool with many schemes
Page | 5 achieving demonstrable positive outcomes. 91% are assessed as “fairly effective or better”.1 However, the study also indicated that when implemented in isolation, the effectiveness of selective licensing is often limited. Schemes appear to be more successful as part of a wider, well planned, coherent initiative with an associated commitment of resources. This finding entirely consistent with the aims of the Housing Act.
The review also highlighted that the most effective schemes are those where a realistic approach to area definition is taken with boundaries carefully drawn to focus on areas with demonstrable problems.
4.4 Criteria for Declaration of Selective Licensing
When considering whether a Selective Licensing scheme is appropriate, the quantity and spread of private rented houses, not being houses in multiple occupation, must be determined and measured against the national average.
4.4.1 A selective licensing designation may be made if the area to which it relates satisfies one or more of the following conditions. The area is one experiencing one or more of:
• low housing demand (or is likely to become such an area); • a significant and persistent problems caused by anti-social behaviour; • poor property conditions; • high levels of migration; • high level of deprivation; • high levels of crime.
4.5 Methodology for Declaration: Prior to declaration the Council must:
• ensure that the exercise of the power is consistent with their overall housing strategy; and
• seek to adopt a coordinated approach in connection with dealing with homelessness, empty properties and anti-social behaviour affecting the private rented sector as regards combining licensing with other action taken by them or others.
• consider whether there are any other courses of action available to them (of whatever nature) that might provide an effective method of achieving with the objective or objectives that the designation would be intended to achieve, and
1 An independent review of the use and effectiveness of Selective Licensing MHCLG 2019
Page | 6 • consider that making the designation will significantly assist them to achieve the objective or objectives (whether or not they take any other course of action as well). And: • Consult with residents and relevant groups and bodies and publish the results • Ensure that the criteria applicable to the form of discretionary licensing is met • Produce an evidence base supporting the form of discretionary licensing to be adopted.
Page | 7 5 Strategic Context
5.1 The World Health Organisation Housing & Health Guidelines 2018 state:
Improved housing conditions can save lives, prevent disease, increase quality of life, reduce poverty, help mitigate climate change and contribute to the achievement of the Sustainable Development Goals (SDGs), including those addressing health (SDG 3) and sustainable cities (SDG 11). 5.2 The Royal Borough of Greenwich Corporate Plan 2018 -22 Priorities supporting the improvement of the Private Rented Sector and resulting issues are:
5.2.1 A Safer Greenwich
• To ensure safe and legally compliant housing • To take a tougher approach to anti-social behaviour by working with partners and involving local communities at every opportunity
5.2.2 Delivering Homes through Economic growth
• To work with all landlords and tenants to ensure the safety of our residents and tenants and specifically to ensure that residents who are living in Private Rented accommodation are living in safe environments, but also that landlords ensure their tenants behave in a responsible manner.
5.2.3 A Cleaner, Greener Greenwich
• Reduce anti-social behaviour in our public and green spaces
5.2.4 Economic Prosperity for All
• To improve the town centres
5.2.5 Within these priorities, the Royal Borough has implemented Integrated Enforcement in 2019 focussing on priority areas of the Borough where change is needed. These are split into priority areas and themes:
• Priority areas Town Centres and surrounding areas within Woolwich, Greenwich, Plumstead and Eltham • Priority Themes
Page | 8 • Drug detritus - evidence of drug use • Fly tipping • Parking Infringements • HMOs and associated enforcement activities • Street drinking and rough sleeping
Whilst work currently being undertaken in all priority areas and under each theme is showing significant strides towards overall improvement it is suggested that aligning a Selective Licensing scheme alongside those Town Centres where there is a significant proportion of private rented accommodation including HMOs; where property is older and in poorer condition; and, where there are significant issues relating to ASB, crime and deprivation; would further assist in achieving changes. 5.3 Housing Strategy
5.3.1 The Royal Borough is in the process of drafting a new Housing and Homeless Strategy 2020-2025 within which it is recognised that the private rented sector in the Royal Borough represents a significant proportion of housing at just over 32% of all dwellings, equating with the social sector (council and RSL’s). Owner occupation is falling at now less than 40% of all dwellings compared to 52% in 2011 and 46% in 2014.
5.3.2 Key Priority 3: Safe and Sustainable Homes for All We are committed to improving the quality and safety standards across all housing tenures in the borough. High quality, suitable housing supports good physical and mental health, reduces fuel poverty and carbon emissions, reduces hospital admissions and helps people live independently for longer. We will use all available means to improve conditions in existing housing including the private rented sector.
5.3.3 We recognise the importance of making homes more sustainable in the borough and the broader role we can play through our policies. We will with our partners, aim to reduce carbon emissions and tackle fuel poverty. 5.3.4 To improve housing conditions for private renters and owner occupiers in the borough, we will use a range of interventions including advice, education and financial assistance. Whilst acknowledging the important role that the private rented sector plays in the housing market in the Royal Borough of Greenwich, we will utilise our enforcement powers to tackle the minority of landlords who act unlawfully. We will continue to target badly managed and unsafe street properties that have been poorly converted into houses in multiple occupation (HMOs).
5.3.5 We will continue to operate and promote our five-year House in Multiple Occupation (HMO) Additional licensing scheme until October 2022 alongside mandatory HMO Licensing and consider whether there is a need to continue our Additional HMO Licensing scheme for a further 5 year term. Licensing schemes require landlords to licence their properties and failure to do so is a criminal offence. Our robust enforcement strategy includes taking proportionate, appropriate and robust escalating enforcement action when breaches occur
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5.3.5 We will consult on a proposal to introduce a new selective licensing scheme aimed to further improve private rented sector standards in single family private rented property. Benefits would include tackling rogue landlords and improving safety standards of properties in the private rented sector. 5.4 Greenwich Fairness Commission Report 20172
This report concluded under section 7 Housing; recommendation 13; that, the Royal Borough should consider introducing selective licensing on areas or types of properties which have above average incidence of poor conditions, either through utilising the 20% maximum allowance, or by applying to the Secretary of State for further powers.
The outcomes and priorities from the Fairness Commission report are outlined within the Royal Greenwich Social Mobility Delivery Plan 2019.
5.5 Royal Greenwich Social Mobility Delivery Plan 2019
Highlights that having a safe, warm and stable home is a vital part of people’s lives. Good housing helps people to flourish, acting as an anchor that supports many aspects of their wellbeing.
Conversely, poor housing can be detrimental to people’s physical and mental health, financial stability and development. Poor housing includes cold and/ or damp conditions, overcrowding, inadequate and unsafe kitchen facilities (e.g. lack of a fridge/freezer or oven or no safe place to prepare food) and insecure tenancy (e.g. risk of eviction, temporary accommodation).
The wider socio-economic impacts of poor housing have been linked to damaging children’s educational attainment and development, an increase in anti-social behaviour and breakdown of community trust.
5.5.1 Fuel Poverty
The Department for Business, Energy and Industrial Strategy estimates that as of 2016 (most recent data published), there were an estimated 2.55 million households in fuel poverty in England. Fuel poverty tends to be more prevalent in older buildings, households with poor insulation, and in the private rented sector households. The most recent statistics estimate that 19.3% of households in the private rented sector experience fuel poverty, compared to 7.7% in privately owned homes and 13.3% in social rented homes. Households in the private rented sector also tend to be deeper in fuel poverty, with an average fuel poverty gap of £383, compared to £205 for those in local authority homes.
2 Greenwich Fairness Commission Report 2017 ‘Our Future Together’
Page | 10 5.5.2 Eviction
Insecurity in the private sector means that renters are more cautious about making complaints or asking landlords to make improvements to the accommodation, for fear of being evicted.
5.5.3 Selective licensing is a discretionary scheme that requires private sector landlords to license their property. Selective licensing can be introduced as a borough-wide license or can target specific areas of the Borough where there are known to be issues. Discretionary licensing schemes allow Local Authorities to set a minimum set of standards for housing and require landlords to provide fair and legal tenancy agreements. This could be used to combat fuel poverty (e.g. ensuring all homes have an EPC rating above E), improve kitchen facilities and provide more secure and transparent tenancy agreements.
5.6 Integrating Communities
5.6.1 Royal Greenwich was awarded funding in 2019 to specifically look at integrating migrant communities to improve service delivery that addresses the needs of all residents and includes engagement at a local community level to encourage private renting tenants to report poor conditions within their homes; and, more widely to challenge Rogue Landlords.
The aim is to seek improvements in property condition in the private rented sector (including HMOs) and to reduce harassment and illegal eviction.
Royal Greenwich has seen one of the highest levels of new migration since 2011 both Nationally and in London, an increase of 5.1%. The highest levels of new migration are within Eastern European (particularly Romanian) and Nepalese.
The introduction of Selective Licensing in the Royal Borough will support the work already being achieved in engaging with existing and new migrant communities.
5.6.2 The Greenwich Race Equality Scorecard3 published in November 2019 has initiated the launch of a Racial Equality Partnership in Royal Greenwich; a multidisciplinary forum aimed to bring different public sector organisations and community services together to understand and address inequalities with a holistic approach, develop new initiatives and maximise our networks. The themes of the Race Equality Scorecard have been used to guide discussion and prioritise areas. Part of the Partnership’s work will also include mapping current projects and data in relation to race equality currently taking place in the Borough.
5.7 Priority Regeneration Areas
5.7.1 Regeneration areas in Royal Greenwich seek to address a range of issues to improve transport; housing; public realm, jobs and business opportunities. Regeneration areas currently undergoing improvements are:
3 Greenwich Race Equality Scorecard 2019 – Runnymede Trust
Page | 11 • Woolwich • Greenwich • Thamesmead and Abbey Wood • Plumstead • Charlton Riverside • Eltham • Kidbrooke
5.7.2 Woolwich Regeneration focusses on the regeneration of the town centre and the development of new housing including affordable housing. There is a proposed redevelopment of Spray Street in Woolwich which would fall within the proposed designated area.
5.7.3 Plumstead ‘Love Your Place’ Plumstead is a priority regeneration area for the Royal Borough of Greenwich and the Royal Borough is focusing substantial resources from both the public and private sector to bring forward positive change in the area. Improvements to the High Street, Lakedale Road and White Hart Road are being funded by the Mayor of London’s Good Growth Fund and matched by the Council. Key improvements which align with Selective Licensing include:
• More places where you could stop and sit, allowing social activity and discouraging anti-social behaviour. • More bins and better waste management.
Page | 12 6 Evidence Base
6.1 Analysis of each criteria specified within legislation to be considered when seeking to determine whether or not a Selective Licensing scheme would be an appropriate course of action for the Royal Borough has been undertaken. Outcomes for each criterion are detailed below. 6.1.1 In summary, 5 out of 6 criteria are met in the proposed area of the borough with the exception of low housing demand which in Royal Greenwich and London as a whole cannot be met.
6.2 The Private Rented Sector (PRS)
6.2.1 The private rented sector in Royal Greenwich has been assessed at 26% excluding HMOs which relate to 6.7% of the total housing stock. This is far higher than the National average of 19% and equates with other London Boroughs. This figure supports the proposal to introduce Selective Licensing in the Royal Borough.
6.2.2 There has been a substantial increase in the total private rented sector since 2014 from 19.7% to 32.7% (including HMOs) and to 26% excluding HMOs. Some of this increase can be attributed to new housing developments and buy to let.
6.2.3 Analysis of the spread of private rented accommodation indicates that it is not evenly spread across the borough and there are significant areas with high concentrations in West Greenwich and Woolwich Riverside Wards where new build, particularly multi storey flats, has taken place. We recognise that this is a significant impact on the overall movement to an increasing private rented sector however the Royal Borough is prioritising older properties in poor condition in terms of this proposal.
6.2.4 MAP 2 Private Rented Sector in Royal Greenwich
Page | 13 6.2.5 Excluding the hottest spot areas in Woolwich Riverside and West Greenwich, the area with the highest concentration overall for the private rented sector is within the proposed area and represents 18.9% of all PRS excluding HMOs.
6.2.6 There has been a spread of PRS into Shooters Hill Ward where previously most properties were owner occupied. 64.3% 2011 (Greenwich 43.3%)
6.3 Low housing demand (or is likely to become such an area);
6.3.1 Demand for Housing in London and for Royal Greenwich is high and is not likely to become an area of low demand.
6.3.2 Royal Greenwich plays a major role in London's housing provision as the second largest provider of new dwellings of all London councils. In the past ten years over 11,000 new homes have been built4.
6.3.3 While new build has taken place in every Ward, the areas with the most development are in Greenwich West, Peninsula, Thamesmead and Woolwich Riverside Wards. In a 15 Year period, on average 2595.00 had been built in each of these areas. These 3 wards alone account for 45% of the new properties built within the 2000 – 2015 period. New build has continued along the Thames riverside.
6.3.4 Table 1 New homes built between 2000 – 2015
6.3.5 There is a shortage of affordable housing in Royal Greenwich. The South-East London Strategic Housing Market Assessment5 found for Royal Greenwich, that a significant proportion of households could not afford to buy or rent on the open market and forecasted a need for between 57% and 68% of new supply in Royal Greenwich to be affordable homes.
4 Royal Borough of Greenwich Core Strategy 2014 5 The South East London Strategic Market Assessment 2010
Page | 14 6.3.6 The Mayor of London published a draft London Plan6 in 2017, which proposed to significantly increase housebuilding targets in London. Our target is to help to deliver 32,040 new homes of all tenures over ten years from 2019/20, which is the third highest housebuilding target out of the 33 London boroughs. The draft London Plan also sets a strategic target for 50%of all new homes delivered across London to be genuinely affordable, and that new developments should provide a minimum of 30%low cost rented homes (London Affordable Rent or Social Rent). We will continue to aim to maximise the low-cost social/affordable rented housing element of every development.
6.3.7 The Royal Borough started a housing acquisition programme7 to purchase street properties using Right to Buy receipts and address the increasing need for temporary accommodation (TA) in the borough. Since 2014, the number of households in TA has increased from 293 to 1,155. Increases in TA use can be observed across the capital and is due to several factors including the increased demand for homelessness services following the government’s welfare reform agenda and the introduction of the Homelessness Reduction Act. This demand for TA has meant that the we are spending increasing amounts of money on expensive emergency overnight accommodation.
6.3.8 Using the private rented sector for long term and temporary accommodation is a key strategy for Royal Greenwich due to the shortage of affordable homes overall and to meet the affordability targets indicated. Whilst Section 106 agreements with developers will seek to maximise the number of affordable homes delivered the Royal Borough has established an incentive programme8 with private sector landlords to encourage a greater level of provision.
6.3.9 In partnership with the National Landlords Association we work with private sector landlords through our Landlord Business Club to provide training and support, including the development of incentives. These include landlord grants and accreditation and financial incentives where landlords will lease their property to the council for use as temporary; move on or permanent accommodation. The current financial incentive programme can be found in appendix 2.
6.3.10 To align with this work, the proposed Selective Licensing scheme proposes to offer discounts where landlords lease to the council.
6.4 A significant and persistent problem caused by anti-social behaviour;
6.4.1 We have reviewed Anti-social behaviour (ASB) using both Metropolitan Police data and that contained within the Royal Borough. Data has included; people ASB; Animal ASB; Vehicle ASB; noise nuisance; fly tipping and environmental nuisance. The greatest concentration of overall ASB can be clearly demonstrated within the proposed area
6 The London Plan 2019 7 Draft Royal Borough of Greenwich Housing and Homelessness Strategy 2020-2025 8 Improving Private Renting in Royal Borough of Greenwich
Page | 15 for designation. In particular, hate crime and sexual offences are almost wholly confined to the proposed area.
6.4.2 Metropolitan Police data overall shows the highest numbers of ASB issues occur in the Wards of Shooters Hill and Woolwich Riverside with Greenwich West, Peninsula, Plumstead and Thamesmead Moorings Wards also factoring highly.
6.4.3 Table 2 ASB Contraventions per Ward (Met)
6.4.4 The most common types of ASB reported to the Police are harassment and noise nuisance followed by rowdy behaviour and drug litter.
6.4.5 Table 3 Types of Contravention in the Royal Borough of Greenwich (Met)
6.4.6 People ASB : (Met data) includes noise; rowdiness and nuisance behaviour. The map below clearly identifies a concentration of these issues within the proposed Selective Licensing area.
Page | 16 6.4.6.1 MAP 3 People ASB
6.4.7 Animal ASB: (Met data) includes dog fouling; dangerous dogs and noisy dogs. While this type of nuisance is seen more predominantly in Woolwich Riverside and to some extent in Charlton there is clear evidence of a significant issue within the proposed designated area.
6.4.7.1 MAP 4 Animal ASB
Page | 17 6.4.8 Vehicle ASB: (Met data) includes abandoned vehicles, vehicle damage and other vehicle related offences. The map shows significant issues within the proposed area which extends into Abbey Wood and Thamesmead.
6.4.1 MAP 5 Vehicle ASB
6.4.9 Noise Nuisance: (RBG data) The Royal Borough received over 3750 reports of noise nuisance in the year to December 2019.
6.4.9.1 Table 4 Noise Issues by Ward
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6.4.9.2 Noise nuisance reports can be grouped by type and range from building works to residential noise. Most complaints arise from residential noise.
6.4.9.2.1 Table 5 Type of Noise nuisance
6.4.9.3 Residential noise can be further broken down and identifies loud music as the most common type of noise nuisance by far.
6.4.9.3.1 Table 6 Residential Noise by Type
6.4.9.4 The severity of a noise nuisance will result in enforcement action. The table below demonstrates that severe noise is predominantly found in Glyndon, Woolwich Riverside, Woolwich Common and Plumstead. All these wards are within the proposed Selective Licensing area.
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6.4.9.4.1 Table 7 Noise Abatement Notices by Ward
6.4.9.5 Noise nuisance was mapped across the whole borough and clearly demonstrates that noise issues are predominant within the proposed area, while Greenwich and Peninsula also factor highly.
6.4.9.5.1 MAP 6 Noise Nuisance
Page | 20 6.4.10 Fly tipping There are a range of issues dealt with under fly tipping including abandoned and untaxed vehicles as well as large items such as beds ad furniture left on pavements and highways. The map below indicates that the principle area where these issues occur is within the proposed area.
6.4.10.1 MAP 7 Fly Tipping
6.4.11 Environmental nuisance includes dog fouling; littering, highways obstruction and refuse. Complaints are widespread particularly across the north of the borough and more particularly within the proposed area which extends into Abbey Wood.
Page | 21 6.4.11.1 MAP 8 Environmental Nuisance
6.4.12 Dog fouling nuisance appears predominantly within the proposed area.
6.4.12.1 MAP 9 Dog Fouling Nuisance
Page | 22 6.4.13 Drug Litter is a significant issue within the proposed area with another particular hotspot in Eltham West.
6.4.13.1 MAP 10 Drug litter
6.4.14 Over all categories when combined to demonstrate the areas of the borough where issues are worst we have identified that the proposed area is significantly more affected by ASB than any other area of the Royal Borough
Page | 23 6.4.14.1 MAP 11 Total ASB
6.5 Poor property conditions: Overall, a concentration of older property in poor condition can be demonstrated within the proposed area for Selective Licensing. Examples of poor property conditions within the proposed area as case studies can be found in Appendix 3 to this report.
6.5.1 Parameters used to determine the age profile of property across the borough are detailed in Table 8
6.5.1.1 Table 8 Age Profile Royal Greenwich
Wards 1900 1900 1919- 1930- 1945- 1955- 1965- 1973- 1983- 1993- 2000- 2010- - 1929 1939 1954 1964 1972 1982 1992 1999 2009 2015 1918 Abbey Wood 151 1250 270 353 72 3500 161 13 12 42 241 51 Blackheath 2710 1511 401 644 485 4040 921 533 254 104 462 224 Westcombe Charlton 1890 2011 582 1374 1496 4301 1183 1023 376 325 753 265 Coldharbour 90 220 152 2160 1800 280 182 180 151 10 31 33 and New Eltham Eltham 143 1570 1210 1540 71 391 132 90 82 11 53 4 North Eltham 371 311 420 1200 891 1060 241 311 110 33 213 51 South Eltham West 0 100 491 2270 261 1 91 60 1 280 83 1011
Page | 24 Glyndon 1821 591 1 1 92 571 841 1290 421 121 924 171 Greenwich 2041 84 271 411 172 790 601 351 190 1021 871 2252 West Kidbrooke 481 70 443 2530 342 380 301 411 101 12 803 14 with Hornfair Middle Park 172 100 190 2440 661 1321 331 122 133 162 73 32 and Sutcliffe Peninsula 2670 113 1 161 243 262 162 640 241 142 1590 1421 Plumstead 1790 1440 112 1033 92 570 180 283 223 232 112 64 Shooters Hill 860 990 152 2000 341 150 183 510 152 21 44 91 Thamesmead 0 0 0 0 0 0 1 2210 1180 741 2940 1 Moorings Woolwich 1920 452 4 171 431 340 550 1980 121 92 171 584 Common Woolwich 1490 362 81 71 214 1551 950 891 580 660 1391 443 Riverside
Parameters were further broken down for mapping to:
• 1855 - 1902 • 1903 - 1932 • 1933 - 1949 • 1950 - 1974 • 1975 – present
6.5.2 Property age was mapped against pest control reports as an indicator of property more likely to be in poor condition. The oldest property in the borough is concentrated in Greenwich West, Blackheath and Charlton where there is a higher proportion of owner occupation and listed buildings such as the Naval College and where property prices are much higher. Woolwich Common and Plumstead also factor highly where there is a higher proportion of private rented property in the older accommodation, property prices are much lower and generally the quality and condition of the property is of a poorer quality.
Page | 25 6.5.2 Map 12 Property Age & Pest Control
6.5.3 We then reviewed the number of service requests received relating to property condition together with the most common hazards identified under the Housing Health & Safety Rating System (HHSRS). The number of service requests in 2019 was 959, 35% in single households. This reflects that tenants in single households are less likely to complain which may be due to a feeling of insecurity and that they risk their home if they do complain. Tenants of HMOs have a tendency to make more complaints and this is likely attributed to an increase in enforcement in HMOs following the introduction of the Royal Borough’s Additional Licensing scheme in 2017.
6.5.4 Assessment of hazards: the most common hazard in private rented property is damp and mould, closely followed by fire and electrical hazards; pests and refuse (domestic hygiene) and personal hygiene (poor bathroom facilities). Structural collapse and falls between levels also factor highly.
Page | 26 6.5.4.1 Table 9 Most Common Hazards
6.5.5 Hazard Distribution by Ward: most hazards occur in Plumstead, Woolwich Common, Glyndon and Shooters Hill which are all Wards within the proposed Selective Licensing area.
6.5.5.1Table 10 Hazard distribution by Ward
Page | 27 6.6 High levels of migration9;
6.6.2 Greenwich ranks 17th nationally on fastest growth rates in non-White British (WB) and is 6th fastest growing borough in London with an overall growth rate of 5.1% since 2011.
6.6.2.1 Table 11 Percentage Non-white British Increase
6.6.3 Greenwich predominantly consists of growing and changing communities which despite an already high non-WB level are continuing at a fast pace of change.
However, sitting on the border between inner and outer London, the borough also contains ‘Cosmopolitan settled’ areas where non-WB growth has stopped, and in some cases reversed and even ‘Newly diversifying’ areas are seeing high levels of non- WB growth from a low base.
9 Origins 2019 Cohesion Atlas for Royal Borough of Greenwich – The Campaign Company 2020
Page | 28 6.6.3.1 Table 12 Range of diversity in Greenwich – Main Migrant Communities
Nigerian
Other Black African, Ghanaian and Caribbean
Other Eastern European
Polish
Hindu Indian
Nepalese
Sikh
Other South Asian
Turkish
East Asian
6.6.4 The composition of the migrant communities indicates those migrant communities where the highest growth has occurred. This is within the East European (other than Polish) and Nepalese communities.
6.6.4.1 Table 13 Percentage Migration by Nationality
6.6.5 Much of the increase of migration has taken place in the north of the borough with the highest increases in Plumstead and Abbey Wood closely followed by Shooters Hill, Glyndon, Woolwich Riverside and Charlton,
Page | 29 6.6.5.1 Map 13 Highest Levels of Migration by Ward
.
Higher increase
Lower increase
The largest single non-WB community in Greenwich is Nigerian and the biggest increases have been amongst Other Eastern European (non-polish)
6.6.6 Migration churn is an indicator of where new migration can be absorbed or where this may lead to potential cohesion issues. Churn is measured against the level of migration and the level of existing diversity. Communities with high levels of diversity tend to adapt better to change. Areas where diversity is lower but which are seeing high increases in migration are more likely to experience community cohesion issues.
6.6.6 Ward typology
Map 14 below indicates which wards are undergoing change and the type of change by diversity and migration.
• Thamesmead Moorings - V high level, V slow change, More uni-diverse; • Peninsula; Greenwich West; Kidbrooke with Horsefair; Eltham West and Middle Park and Sutcliffe - Average level, Slower change; • Woolwich Riverside; Woolwich Common and Glyndon - Very high level, Average change; • Plumstead and Abbey Wood - High level, Very fast change, More uni-diverse; • Charlton and Shooters Hill - Average level, Fast change, Fewer newcomers
Page | 30 • Eltham North, Eltham South and Coldharbour with New Eltham - Low level, Slow change, Fewer newcomers • Blackheath and Westcombe - Low level, Very slow change, Fewer newcomers
6.6.6.1 MAP 14 Ward Typology
6.6.7 Those areas increasing most rapidly and showing the greatest churn are within the proposed Selective Licensing area. In particular the area of Shooters Hill included shows fast change from a low base which indicates potential cohesion issues. Woolwich Common and Plumstead were already very diverse communities where churn can be more easily accommodated.
6.6.8 The communities which have increased the greatest are Nepalese and Romanian.
6.6.9 Nepalese Community are concentrated in Glyndon; Plumstead and Woolwich Common with Plumstead and Glyndon experiencing very rapid growth.
Page | 31 6.6.9.1 MAP 15 Nepalese Community
6.6.10 Romanian Community The greatest increases are found in Woolwich Riverside, Plumstead and Thamesmead with high concentrations in Glyndon, Woolwich Common and Kidbrooke.
6.6.10.1 MAP 16 Romanian Community
Page | 32 6.6.11 Combining the above information and noting the highest increasing communities provides indicators of where the need for intervention is required and where a Selective Licensing scheme would be most beneficial. This has been determined as being predominantly within the proposed area.
6.6.11.1 MAP 17 Migration Churn within proposed area
6.7 High levels of deprivation10;
6.7.1 Greenwich ranks 60 out of 322 local authorities nationally for multiple deprivation where 1 is the most deprived and is the 13th most deprived of the 32 London Boroughs. Greenwich has improved 10 ranks from 50 to 60 since 2015.
6.7.2 The Indices of Multiple Depravation (IMD) contains seven domains which relate to income, employment, health and disability, education skills and training, barriers to housing and services, living environment, and crime.
6.7.3 Barriers to housing and services ranks lowest at 17 indicating significant issues overall in terms of housing.
10 Office of National Statistics (ONS) Indices of Multiple Deprivation 2018
Page | 33 6.7.3.1 Table 14 – Domain Rankings for Greenwich based on 322 Local Authorities
Domain Rank of Average - 2019
IMD 60
Income 39
Employment 90
Education, skills and training 193
Health and disability 132
Crime 36
Barriers to housing and services 17
Living environment 73
6.7.4 The IMD deciles are calculated by grading all the 32,844 LSOAs in England from most deprived to least deprived and separating them into 10 equal groups. LSOAs in decile 1 fall within the most deprived 10% of LSOAs nationally and LSOAs in decile 10 fall within the least deprived 10% of LSOAs nationally.
The average decile for wards in London is 5.12. Only 6 out of 18 wards in the Royal Borough fall above this average ranking. The most deprived ward in the Royal borough is Woolwich Common.
Page | 34 6.7.4.1 Table 15 IMD London Average Deciles by Ward
6.7.5 Map 18A below shows the most deprived areas of the borough however, this should be viewed in context against tenure (Map 18B). Areas are based on lower super output areas and indicators, for example Greenwich Peninsular, ranked as a most deprived area of the borough is mostly commercial and new build with one small social housing estate. Other areas ranking high deprivation can be discounted as commercial/open space in Abbey Wood and Woolwich Riverside.
Other key areas ranking with high deprivation relate to areas of social housing in Middle Park & Sutcliffe; Eltham West; Abbey Wood; Kidbrooke with Hornfair; Woolwich Riverside; Coldharbour with New Eltham, Abbey Wood and Charlton.
Page | 35 6.7.5.1MAP 18A IMD 2019
high to low
6.7.5.2 MAP 18B Tenure
Page | 36 6.7.6 Areas of high deprivation relative to the PRS are identified in Plumstead, Glyndon, Woolwich Riverside and Woolwich Common with Woolwich Common being the most deprived ward of the Royal Borough IMD.
6.8 High levels of crime.
6.8.1 The Office for National Statistics11 tracks overall crime by rating Index. Ratings run from 1 – 10 with 1 being the most crime. The higher the rating the less severe that overall crime will be in that area. The graph below demonstrates that there had been a drop in crime in multiple wards in the borough. The biggest decrease has been in Thamesmead Moorings which had seen a 42% drop in the crime index. Conversely there had been a rise in the crime in Eltham West, Kidbrooke with Hornfair, Peninsula and Plumstead. 6.8.1.1 Table 16 Crime Levels by Ward 2015 – 2019
11 Office of National Statistics - Indices of Crime
Page | 37
8.8.1.2 Table 17 Percentage Change Per Ward for Crime from 2015 - 2019
Ward Crime +/- Abbey Wood 22% Blackheath Westcombe 10% Charlton 11% Coldharbour and New Eltham 18% Eltham North 7% Eltham South 34% Eltham West 7% Glyndon 32% Greenwich West 20% Kidbrooke with Hornfair 20% Middle Park and Sutcliffe 25% Peninsula 22% Plumstead 11% Shooters Hill 8% Thamesmead Moorings 42% Woolwich Common 13% Woolwich Riverside 15%
6.8.2 Overall, while there have been improvements in many areas of the Royal Borough, crime is still higher in Royal Greenwich than the average for London with only Coldharbour with New Eltham, Eltham North and Eltham South scoring higher than the London average. 6.8.2.1 Table 18 Crime Index in Royal Greenwich to London Average
Page | 38 6.83 Further detailed analysis of local Metropolitan Police data was undertaken in terms of hate crime, sexual offences, criminal damage and violence. These are individually mapped across the Royal Borough and collated into a single map which demonstrates that crime is a greater issue within the proposed designated area than anywhere else in the rest of the borough. 6.8.3.1 MAP 19 All crime with proposed area for designation
6.8.4 Each element of crime analysed is detailed below: 6.8.4.1 Hate Crime Hate crime is demonstrably higher within the proposed area than anywhere else in the Royal Borough.
Page | 39 6.8.4.1.1 MAP 20 Hate Crime
6.8.4.2 Sexual Offences Similarly, sexual offences are predominant within the proposed area. 6.8.4.2.1 MAP 21 Sexual Offences
Page | 40 6.8.4.3 Violence against person Again, violence against the person is predominant within the proposed area. 6.8.4.3.1 MAP 22 Violence against the person
6.8.4.4 Criminal Damage Criminal damage is again predominant within the proposed area although there is extension of this aspect of crime within Abbey Wood, Thamesmead and further into Woolwich Riverside. 6.8.4.4.1 MAP 23 Criminal damage
Page | 41 7. Licensing criteria 7.1 It is proposed that all applicants will be required to submit an application for licence. An application will be deemed to be complete when submitted with the required additional information and the first part of the fee. 7.2 It is proposed that a complete application will contain:
• Application form duly completed
• DBS – we are consulting on whether or not a DBS will be included or, as an alternative that there is a self-declaration element contained within the application form.
• Plan of property indicating position of smoke detectors if present
• Gas Safety certificate if gas is present
• Tenancy agreement
• First part of fee
7.3 Under the terms of any licensing scheme a local authority must undertake an assessment of whether or not the proposed licence holder and the proposed manager is a Fit and Proper person to manage the property. Under the Royal Borough’s existing Additional and Mandatory HMO licensing schemes, both the proposed licence holder and the manager (if different) are required to submit a DBS certificate as evidence of offences which may or not be recorded against the person for particular types of offences. These include Fraud and Drugs offences. As in 7.2 above we are consulting on whether or not this should also apply to Selective Licensing. The alternative is for applicants to self-declare whether or not they have been found guilty of such offences. Additionally, local authorities are required to consider other relevant information such as offences under the Housing Acts and associated Regulations both within and outside of the Royal Borough. 7.4 Example of criteria for fit and proper person assessment As an alternative to submission of a DBS an applicant would be required to declare whether the proposed licence holder, the manager and/or any person associated with either of them had:
• Committed any offence involving fraud or other dishonesty (including benefit fraud), violence, drugs, or any offence listed in Schedule 3 to the Sexual Offences Act 2003 (subject to the Rehabilitation of Offenders Act 1974) • Practised unlawful discrimination on grounds of sex, colour, race, ethnic or national origins or disability in, or in connection with, any business • Contravened any legislation relating to housing, public health, environmental health or landlord and tenant law
Page | 42 • Been refused a licence under Part 2 or 3 of the Housing Act 2004 • Had a licence revoked for breach of any conditions under Parts 2 or 3 of the Housing Act 2004 • Been subject to a Control Order under the Housing Act 1985 (in the past 5 years) • Been subject to a Management Order under the Housing Act 2004 • Failed to comply with a Housing Notice (requiring works etc.) served by a local authority • Been subject to complaints from tenants or other sources, regarding serious or repeated breaches of the conditions of a licence under the Housing Act 2004
7.5 Exemptions Certain properties in the rented sector are exempt from Selective Licensing. These are:
• a house in multiple occupation • a house or dwelling that is subject to a prohibition order • a business tenancy • a licensed premise • tenancies of agricultural land and holdings • local housing authority and registered social landlord tenancies • Police, national health & fire and rescue tenancies • Student accommodation • A lease or tenancy where the full term is more than 21 years; • A holiday home – this currently includes properties occupied on a temporary basis under Airbnb.
Page | 43 8 Proposed Fees 8.1 Royal Borough of Greenwich estimates it has 5500 units in the private rented sector within the proposed area. 8.2 The fee structure is designed to ensure that the scheme will be self-funded and to encourage professionalism in property letting by discounts for accredited landlords and letting agents. 8.3 Fees are calculated in accordance with legislative requirements and are split into 2 payments, administration fee on application and enforcement fee prior to issue of licence. 8.4 Licences will be issued for a period of up to 5 years and renewal applications must be submitted before the expiry of the current licence 8.5 Where the Royal Borough of Greenwich has had to take enforcement action a licence may be revoked and a new application and fee be made. It is proposed that incomplete applications will be refused. If an application is refused, the applicant will need to re-apply. The Royal Borough may also revoke a licence. Examples of when a fee will apply due to actions either by the applicant or the council are given in Table 20 below.
8.6 Other fees and charges 8.6.1 These fees are proposed as applicable as appropriate per property in relation to licence applications, or where the property is currently licensed and apply to all property licenses issued by the Royal Borough of Greenwich.
8.6.2 Table 19 Proposed other fees and charges
Application type Application fee and charge
Revocation of licence No fee
Application to licence following Initial Application fee revocation of licence
Application refused by the council Initial Application fee with no refund
Application withdrawn by the applicant Initial Application fee with no refund
Application made in error No fee, and a refund will be made
Page | 44
Temporary Exemption Notice (TEN) No fee made by the council
Application received following the expiry of a Temporary Exemption Notice (TEN) Initial Application fee made by the council
Incorrect Selective application made where application under Mandatory & Initial Application fee for Mandatory HMO Licensing Additional HMO Licensing Scheme less any fees paid for initial application made in error required
Change of licence type e.g. if a single dwelling is re-let as a house in multiple occupation (this will require a change New application fee from a selective licence to an additional licence).
8.7 Discounts 8.7.1 The Royal Borough proposes to offer a discount of 60% of the total fee to those landlords who take advantage of an invitation to apply as an early bird in the 2 months prior to the proposed designation to declare a licensing scheme coming in to force. 8.7.2 The Royal Borough proposes to offer a 25% discount for landlords who agree with the Royal Borough to lease their property for use as temporary accommodation or offer an Assured Shorthold Tenancy (AST) to a council nominated tenant for a minimum period of 12 months. Applicants will be required to provide a copy of their agreement with the Royal Borough on application with their application. 8.7.3 The Royal Borough proposes to offer a 20% discount to landlords who are accredited with an approved association. A list of approved associations is provided in appendix 4 8.7.4 The Royal Borough proposes to offer a 45% discount to those landlords who are accredited and in an agreement with the Royal Borough as in 8.6.2 above. 8.7.5 The Royal Borough proposes to offer a discount of 55% to landlords who apply to licence a new build property (including a flat, house or apartment) within the first month of the first tenancy. 8.7 Licence variation fees There is no charge proposed to vary a licence. Variations include: • Change of licence holder – licenses are not transferable – a new licence holder must apply for a new licence.
Page | 45 • Change of manager (unless they are also the licence holder) • Change of address details of any existing licence holder or manager. • Variation of licence instigated by the council • Reduction in the number of maximum occupiers and/or households for licensing purposes • Increase in the number of maximum occupiers and/or households for licensing purposes, through increasing the number of habitable rooms, change in room sizes, and/or amenity provision (unless there is a change of licence type - from selective to additional)
8.8 Proposed Fees 8.8.1 The table below shows the indicative fees for Selective Licensing with proposed discounts and fees payment on application and prior to licence being issued. 8.8.2 Table 20 – Summary of Proposed Licence Fees
On On issue of Period of full fee application Licence Licence Applicants who apply before the commencement date. No further £312 £187 £125 5 years discounts apply.
Applicants who apply after the £780 £468 £312 5 years commencement date.
Applicants who apply after the commencement date with previous £780 £468 £312 1 year management contraventions and are of concern
Discounted Fees
Applicants who agree to lease or offer an AST to a council nominated tenant to the £585 £351 £234 5 years Royal Borough of Greenwich for a minimum of 12 months.
Applicants who are accredited with an approved Landlord or Letting Agent £624 £375 £249 5 years Association.
Page | 46 Applicants who are both accredited and who agree to lease or offer an AST to a council nominated tenant to the Royal £429 £257 £172 5 years Borough of Greenwich for a minimum of 12 months.
New build properties where application is received within 1 month of first tenancy. £351 £211 £140 5 years No further discounts apply
8.9 Current Fees
These fees are for applications for a Mandatory or Additional HMO property licence.
8.9.1 Table 22 HMO licence (Additional and Mandatory) application fees
Fee type Current fee Fee as of 1 October 2019
Standard £388 per unit £400 per unit
Member of a landlord's professional association £322 per unit £332 per unit or accreditation scheme Enhanced (where the Council have discovered the HMO use and £505 per unit £520 per unit written to the property owner/landlord) - no discounts apply Standard rate for applications for £315 per unit £315 per unit renewing a licence Member of a landlord's professional association or accreditation scheme £278 per unit £278 per unit rate for applications for renewing a licence Assistance with completing an £150 £150 application
Page | 47 8.10 Cost of Scheme 8.10.1 Existing property licensing processing structures are in place 8.10.2 Income generation is based on 85% of landlords licensing their property within the 5 year period of the scheme, 35% of landlords taking advantage of the substantial discount prior to the date of commencement and 50% of landlords securing discounts during the scheme. 8.10.3 The total estimated number of PRS properties within the proposed area is 5500. 8.10.3.1 Table 23 Income Generation – 5 years @ 85% Compliance - £2,391,675
Applications Number of Cost (£) Total (£) applications
Estimated pre- 1925 312 600,600 commencement
Post declaration with and 2,750 429 - 780 1,791,075 without discount(s)
Remaining PRS 825 0 0
Total 2.391,675
8.10.4 Expenditure is calculated at current rates based on the time to process the number of applications, carry out compliance inspections and take enforcement action over the 5 year period of the proposed scheme. 8.10.4.1 Table 24 Expenditure – 5 years - £2,384,999
Post Full salary cost £ Posts Total 5 year £ Team Leader 61,904 1 309,520
Housing Enforcement 51,629 3 774,435 Officer
Licensing Technical 26,279 4 525,580 Support Officer
Intelligence Officer 45,016 1 225,080 Supplies and Services
Overheads & 550,384 disbursements Total 2,384,999
Page | 48
8.11 Benchmarked Fees Fees for Selective Licensing vary between £500-£900 per property across London. The table below shows the type of Selective Licensing scheme and fees charged. 8.11.1 Table 25 Analysis of London Selective licensing schemes 201912
LOCAL Date Area of Fees Estimated No licences No AUTHORITY scheme Scheme no. approved as applicatio commenced properties of 1/5/191 ns requiring received licence1 & not yet approved as of 1/5/191 Barking & 1/7/2014 100% £900 18500 12435 989 Dagenham
Bexley 1/10/2018 20% £690 2451 301 939
Brent 2014 and 2018 20- 100% £540 8274 8140 134
Croydon April 2015 100% £750 38500 34351 450
Ealing 1/1/2017 20% £500 6830 5746 1084
Hackney 1/10/2018 20% £500 4149 0 1502
Hammersmit 5/6/2017 20 – 100% £560 1644 61511 144 h & Fulham
Harrow 5/12/15 20% £500 1533 1412 121
Newham P1 1/1/2012 100% £750 34600 32086 8 P2 1/1/2018
Redbridge A1 13/7/17 20% £604 19000 3179 9385 A2 1/10/18 Southwark 1/1/2016 20% £536 5000 790 278
Tower May 2016 20% £532.50 6000 5192 389 Hamlets Waltham 1/4/2015 100% £650 26886 26204 682 Forest TOTALS 173367 130451 16105
1analysis of London property licensing schemes 2019 Safeagent 9 October 2019
12 London property licensing survey 2019 Safeagent 9 October 2019
Page | 49
9. Proposed Conditions 9.1 There are mandatory conditions set down in legislation that must be included in any proposed conditions. These are:
• the production of a gas safety certificate (if there is a gas supply to the house)
• keeping any electrical appliances and furniture in a safe condition
• the installation of smoke alarms in proper working order
• a requirement that the licence holder supplies the occupiers of the house with a written statement of the terms of occupancy
• a requirement that the licence holder obtains references from persons wishing to occupy the house
• such other conditions as may be imposed by regulations, e.g. the provision of Energy Performance Certificates.
9.2 Additionally a council can apply conditions at their discretion in relation to:
• restrictions or prohibition on the use or occupation of particular parts of the house
o This item relates to the size and use of rooms within the property in relation to the number of occupants. It is proposed that a licence will specify the maximum number of adults and children who may be accommodated.
• a requirement for the landlord to take reasonable steps to prevent antisocial behaviour by occupiers or visitors.
9.3 Having reviewed these criteria, the Royal Borough has developed a set of proposed conditions which would be required of landlords in licensed properties as part of this overall proposal. The proposed conditions can be viewed in appendix 5 9.4 When a property is licenced, it is a criminal offence to breach the conditions attached to the licence. A breach of a licence condition can incur prosecution or a civil penalty up to £30,000. 9.5 Once licenced, it is proposed that each property will be inspected for compliance with the conditions attached. Enforcement for breach of licence will be taken in accordance with the Royal Borough’s enforcement policy. 9.6 It is proposed that the inspection will also take into account any deficiencies or hazards identified in accordance with the Housing Health & Safety Rating System which will be subject to enforcement in accordance with the Royal Borough’s enforcement policy. Details on the 29 Hazards can be found in Appendix 6
Page | 50 References
1. Housing Act 2004 2. Housing Act 2004: Licensing of Houses in ?Multiple Occupation and Selective Licensing of Other Residential Accommodation (England) General Approval 2015 3. The Selective Licensing of Houses (Specified Exemptions)(England) Order 2006 4. Approval Steps for Selective Licensing CLG 2010 5. Selective Licensing in the Private Rented Sector Guidance for Local Authorities CLG 2015 6. An Independent Review of the Use and Effectiveness of Selective Licensing MHCLG 2019 7. London Property Licensing Survey 2019 – Safeagent 8. World Health Organisation – Housing and Health Guidelines Executive Summary 2018. 9. The Royal Borough of Greenwich Corporate Plan 2018 -22 10. Royal Borough of Greenwich issues and options for a new Housing and Homelessness Strategy 2020 11. Greenwich Fairness Commission Report 2017 ‘Our Future Together’ 12. Royal Greenwich Social Mobility Delivery Plan 2019 13. Greenwich Race Equality Scorecard 2019 – Runnymede Trust and Greenwich Inclusion Project 14. Royal Greenwich Core Strategy 2014 15. South East London Strategic Housing Assessment 2010 16. Royal Greenwich Regeneration Strategy
Page | 51 Appendix 1 : List of Streets within Proposed Area
Area Boundaries – Roads
Road Boundaries
Road Name Plum Lane West Swingate Lane West Church Manorway West John Wilson Street East Beresford Street West Plumstead Road South Kingsway North Kingsdale Road West Highgrove North Red Lion Lane East Herbert Road South Eglinton Road West Nightingale Vale South Woolwich New Road East Marmadon Road South Reidhaven Road South Shooters Hill Road North
Page | 52
List of Streets
Roads Abery Street Barth Mews Burrage Road Connaught Mews Elmley Street Acland Close Barth Road Burwash Road Connaught Road Ennis Road Admaston Road Bassant Road Butterfield Mews Constitution Rise Enthoven House Alabama Street Bateson Street Calderwood Street Conway Road Erindale Albatross Street Bathway Caldwell Close Coupland Place Erindale Terrace Amar Court Bebbington Road Callis Close Coxwell Road Felspar Close Amardeep Court Benares Road Cambridge Row Crescent Road Ferry Place Ancaster Street Beresford Steet Campbell Close Creton Street Flaxton Road Ancona Road Bignell Road Cantwell Road Dallin Road Foreland Street Anglesea Avenue Black Prince Street Cardiff Street Dawson Close Fox Hollow Close Anglesea Mews Bleak Hill Lane Castile Road De Haviland Drive Fredrick Place Anglesea Road Blendon Terrace Ceres Road Donaldson Road Gallosson Road Ankerdine Crescent Bloomfield Road Chelsworth Drive Doran Grove Garibaldi Street Ann Street Bramblebury Road Cheriton Drive Dothill Road Garland Road Arthur Grove Brent Road Chesnut Rise Downend Genesta Road Ashlar Place Brewery Road Church Hyde Drawell Close Gilbourne Road Badgemore Path Brinklow Crescent Church Manorway Duncroft Glenmount Path Balgowan Street Brookdene Road Clara Place Durham Rise Glyndon Road Bannockburn Road Brookhill Close Claydown Mews Earl Rise Goldsmaid Street Barden Street Brookhill Mews Clendon Way Eastview Avenue Gossage Road Bargate Close Brookhill Road Clothworkers Edge Hill Grand Depot Road
Page | 53 Barnard Close Brumwell Avenue Condover Crescent Eglington Hill Granite Street Barnfield Gardens Bunton Street Conduit Road Eglinton Road Greens End Barnfield Road Burrage Grove Congleton Grove Elmdene Road Griffin Road Barrington Villas Burrage Place Congo Road Elmley Street Griffin Road
Roads Grosmount Road Irwin Avenue Majendie Road Old Mill Road Purrett Road Gunner Lane Isla Road Malton Street Old Tramyard Quilter Street Gunning Street Ivermore Place Manthorp Road Olven Road Raglan Road Hare Street Jago Close Market Steet Orchard Road Ravine Grove Hartville Road Jessup Close Marmadon Road Orissa Road Rayleas Close Hatton Close Jim Bradley Close Masons Hill Paget Rise Raymere Garden Hawksmoor Close Kashgar Road Maxey Road Paget Terrace Red Lion Lane Heath Villas Kentmere Road Mayplace Lane Palmerson Crescent Reeves Road Heathfield Terrace Kings Highway Melling Street Parkdale Road Reidhaven Road Heavitree Close Kingsdale Road Michel Walk Parry Place Revell Rise Heavitree Road Kirk Lane Mill Lane Pegwell Street Richmond Place Hector Street Kirkham Street Mineral Street Pendrell Street Ripon Road Helen Street Lakedale road Miriam Road Perrot Street Rippolson Road Herbert Road Landstead Road Monk Street Philimore Close Riverdale Road Heverham Road Leghorn Road Moordown Piedmont Road Robert Street High Grove Lenton Street Mortgramit Square Plum Lane Rockmount Road Plumstead Common Hill End Liffler Road Mount Pleasant Place Rolfe Terrace road Hillend Long Walk Mountbatten Close Plumstead High Street Rowton Road Hinstock Road Lord Rorberts Terrace Moy Lane Plumstead Road Roydene Road Plumtead Common Hudson Place Love Lane Myrtle Alley Ruddstreet Close Road Hylton Street Lucknow Street Nightingale Place Polthorne Grove Sandbach Place Ingledew Road Macbean Street Nithdale Road Polytechnic Street Sandham Point Inverary Place Macoma Road Nyanza Street Polythorne Grove Sandy Hill Invermore Place Macoma Terrace Occupation Lane Powis Street Sandy Hill Avenue Page | 54 Road Sandy Hill Road The Oaks Warland Road Saunders Road The Slade Warwick Terrace Scott Passage Thomas Street Waverly Crescent Shooters Hill Thornhill Avenue Waverly Road Shrewsbury Lane Timbercroft Lane Wellington Street Sladedale Road Tormount Road Welton Road Slater Close Tuam Road Wernbrook Street South Rise Way Tuscan Road White Hart Road Southport Road Tynemouth Road Whitworth Road Speranza Street Uplands Close Wickham Lane Spinel Close Upton Road Willenhall Road Spray Street Vambery Road Willowfields Close Springwater Close Vernham Road Wilmount Street St James Close Vicarage Park Winn Common St John Terrance Vicarage Place Woolwich New Road St Margarets Grove Vicarage Road Wrekin Road St Margarets Terrace Vicarge Park Wrottesly road St Merryn Close Viewland Road St Nicholas Road Villas Road Strandfield close Vincent Road Sutcliffe Road Voce Road Swingates Lane Walker Close Taylor Buildings Walmer Terrace Tewson Road Walpole Place
Page | 55 Appendix 2 Incentive Programme
Improving Private Renting in Royal Borough of Greenwich
The Royal Borough of Greenwich is working in partnership with Local Agents and private landlords to meet the need of supplying good homes in the private rented sector. In order to meet this need, we have two attractive schemes to offer: Assured Shorthold letting scheme 1. We will offer a cash incentive payment at sign up of 12 month tenancy of: • 1 bed £3,000 • 2 bed £4,500 • 3 bed £4,500 • 4 bed £4,000 2. A further cash incentive payment equal to what was granted above will be offered to landlords if they continue to maintain the tenancy for a period of 24 months. 3. One month’s rent in advance after signup of tenancy agreement 4. We have partnered with an Insurance company to insure your property [Buildings and Contents] for 1 or 2 years, at no cost to you to include tenant damages 5. Provide rent cover as part of the landlords home insurance up to £2,000 per month up to a maximum of £12,000 or for up to 6 months, whichever is equal to the lesser amount 6. Up to 4 tenants will normally be introduced 7. Electrical certificate paid for at start of tenancy if certificate has expired 8. Schedule of condition [inventory] at commencement of tenancy* 9. Six monthly property inspections 10. End of AST [outgoing] inspection 11. The above will be subject to the Royal Borough of Greenwich having a need for the type of property to meet its needs 12. If your property needs improvements, the council may consider offering a Landlord Grant of up to £15,000 subject terms and conditions
Greenwich Leasing Scheme (full management to include minor repairs*) 13. We will offer a guaranteed income 14. A one off cash incentive payment for: • 1 bed £3,000 • 2 bed £3,000 • 3 bed £3,000 • 4 bed £3,000 15. Schedule of condition [inventory] at commencement of tenancy [incoming inspection]
Page | 56 16. Minimum 2-year lease, with a maximum of 5 years 17. Six monthly property inspections 18. End of lease [outgoing] inspection 19. Carryout emergency minor repairs on your behalf up to the value of £500 at no cost to you 20. If repairs cost more than £500 then you will be notified to arrange for these to be carried out 21. Carryout a Gas Safe inspection and provide a certificate 22. Carryout an electrical inspection and provide a certificate 23. Provide a EPC certificate if you need one 24. No commission or setup fees 25. Named officer dealing with your case
Additional savings if you sign up with us Estate agent Agent commission fee 10 - 15% Inspection fee £100 on average plus VAT Renewal fee 8 - 12% Court costs and legal fees Rechargeable Rent cover/arrears Rent not guaranteed Annual certificates £200
26. The above will be subject to the Royal Borough of Greenwich having a need for the type of property to meet its needs 27. Damages of up to £3,000 for the term of the lease 28. Property to be returned at the end of the lease in a good condition except for fair wear and tear*
Page | 57 Appendix 3 : Case Studies Case Study: 1 A 3-storey terraced property illegally converted into two single family flats, the ground floor flat occupied by a tenant, his partner and 1 children under the age of 10. The family was awaiting immigration status and had no recourse to public funds. Gas Safety engineer had determined that the gas system within the property was unsafe and shut off the mains supply leaving the family without heating, hot water or means of cooking food in winter. The family had reported the problem to the landlord who failed to respond and threatened the family with eviction if they informed the council to the extent he changed the locks on the front door while the family was taking the child to school. Inspection found that the ground-floor kitchen was a poorly converted addition to the premises, with limited space. The kitchen had a gas cooker, with an old gas boiler situated within very close proximity. The flue from the boiler was next to a window to the living room, which could not be closed. The Gas Engineer had affixed warning stickers to the boiler, cooker and mains gas consumer unit.
Figure 1: Boiler with warning label.
Figure 2: Gas cooker with warning label
Figure 3: Mains unit shut off
Page | 58
Figure 4: Flue next to window which could not be closed.
The Flat had several deficiencies including 4 Category 1 Hazards (Excess Cold, Fire, Explosions and Carbon Monoxide/fuel combustion products) and 9 Category 2 Hazards (Damp & Mould, Entry by Intruders, Domestic Hygiene, Pest and Refuse, Food Safety, Personal Hygiene, Sanitation and Drainage, Falls between Levels and Electrical Hazards)
On contact the owner became irate and aggressive and refused to deal with the matter. He was given verbal notice of entry for the following day and advised that if the work had not commenced, the Council may carry out the works and re-charge the cost. He did not carry out works.
Emergency Remedial Action was taken to deal with the urgent issues of lack of heating, hot water and cooking of food and the costs recovered through demand charges on the landlord.
Improvement Notice under section 11 & 12 of the Housing Act 2004 was served and the Landlord traced to 7 properties within the borough. Compliance is being monitored and Civil Penalties will be issued if the Landlord fails to comply.
Figure 5: Condition of ceiling in shower cubicle Figure 6: Kitchen sink coming away from wall.
Figure 7: Insufficient counter space in kitchen. Figure9: Evidence of fixed electrical system not inspected since 2002
Page | 59 Case Study 2
A single mum with a 2 year old child and the grandfather complained to the council about multiple issues in their home including dampness, cracked ceiling, bedbug infestation and inoperative central heating in a two- bed mid-terraced house with solid brick work built around 1920. Neither the landlord nor the letting agent had taken any action to remedy the issues despite numerous complaints.
Inspection under the Housing Health and Safety Risk System (HHSRS) identified hazards including:
excess cold (no heating to ground floor and no thermostat; lack of loft insulation; single glazed window in kitchen, missing window pane in one bedroom and broken seals to second bedroom window);
damp and mould (severe condensation to bathroom and kitchen due to lack of ventilation);
Page | 60 domestic hygiene (defective worktop to kitchen and pests – severe bed bug infestation);
Carbon monoxide and fuel combustion; fire (no smoke detectors); electrical hazards (insufficient sockets);
structural collapse (cracked wall and ceiling) defective gutters.
The landlord was given time to comply and failed. An Improvement Notice was served and the landlord again failed to comply and was issued with a Civil Penalty of £5,000.
Page | 61
Case study 3 The neighbour of vulnerable elderly Nepalese tenants complained to the council concerned about structural defects including defective brickwork and damaged roof in a 2 storey, three bed property. It is notable that these tenants did not complain to the council themselves, common within this community particularly the elderly. The Asian landlord had visited monthly to collect rent and was fully aware of the issues but had taken no action. An inspection under HHSRS was carried out and Category 1 Hazards identified included: Excess cold (defective, insufficient and inappropriate heating provisions (electric storage heaters) The tenants were paying £148 per month in bills and the heating system could only provide and maintain room air temperature of around 15°C even when the external temperature was 2°C). This is a clear indicator of fuel poverty in addition to this category 1 hazard. Fire (polystyrene tile ceilings throughout the dwelling - highly flammable allowing rapid fire and smoke spread and producing deadly toxic fumes when in flame) and inoperative smoke detector to the first floor landing;
Damp and Mould (condensation mould to the bathroom and kitchen);
Page | 62 Falls between levels (stairs balustrade of horizontal planks with gap of 200mm - risk of small child falling between, the family often had children visiting.
Structural collapses or falling elements cracks and broken bricks and missing plaster works to external front bay window and defective ridge tiles)
The owner was given time to comply but failed and Improvement Notice was served. He again failed to comply and was prosecuted. He pleaded guilty and was ordered to pay £1000 penalty plus the legal cost of £3000.
Page | 63 Appendix 4 Landlords' professional or accreditation bodies
Examples of professional landlord and accreditation bodies include:
• London Landlord Accreditation Scheme
• National Landlords Association
• Southern Landlords Association
• Residential Landlords Association
• The Guild of Residential Landlords
• Association of Residential Letting Agents (Propertymark)
• National Approved Lettings Scheme (Safeagents)
• UK Association of Letting Agents
• British Landlords Association
Additionally, if your organisation isn't on the list, email us to check if it's eligible for a discount.
Page | 64 Appendix 5 Selective Licensing – Proposed Licensing Conditions
1.Tenancy Management The license holder shall: 1. Provide a tenancy agreement including that occupiers are responsible for both their own behaviour and that of their households and visitors and; 2. A copy of the licence and conditions attached to it. 3. The address and telephone number of the person managing the property 4. The name, address and telephone number of the landlord’s appointed local emergency out of hours contact 5. A copy of a valid gas safety certificate if gas is present 6. A copy of an energy performance certificate (EPC) for the property 7. A copy of the Deposit Bond agreement with an approved Deposit Bond Protection Scheme (if applicable) 8. A copy of ‘How to Rent’, and shall; 9. Ensure that ‘right to rent’ checks have been carried out in accordance with the Immigration Act 2014. 10. Obtain references from tenants before entering into an agreement
2. Notification of Changes The licence holder shall inform the Royal Borough of Greenwich within 21 days of 1. Change of address 2. Change of managing agent 3. Change of Licence Holder
3. Number of Persons permitted to occupy The licence holder shall ensure that the numbers of households and/or persons residing in the property do not exceed the maximum numbers specified in the licence.
4. General maintenance of the property The license holder shall 1. ensure the property is maintained in good repair and safe condition and complies with current standards 2. resolve any Category 1 Hazards within a reasonable period 3. inspect the property at least every six months
Page | 65 4. keep records of inspections for the duration of the licence.
5. Gas Appliances Where present the licence holder shall ensure that all gas appliances are serviced annually
6. Carbon Monoxide The licence holder shall 1. ensure that a carbon monoxide alarm is fitted and kept in proper working order in any room that contains a solid fuel burning combustion appliance. 2. keep in proper working order a carbon monoxide alarm fitted in any room containing a gas appliance (including gas boiler).
7. Furniture and Soft Furnishings Where provided, the Licence Holder shall ensure all furniture and soft furnishings are kept in a safe condition and comply with current regulations
8. Supply of Water, Gas and Electricity The licence holder shall 1. ensure a constant supply of water, gas and/ or electricity and; 2. not unreasonably cause the supply of water, gas and/or electricity to the house to be interrupted 3. provide access and obtain readings of all utility meters 9. Electrical installations and appliances The licence holder shall 1. ensure that the electrical system is maintained in a safe condition and inspected and tested at least every 5 years and 2. keep all electrical appliances supplied in a safe condition. 3. Where provided, that all portable appliances are maintained in a safe condition 4. periodically check for electrical appliance recalls and take the required action without undue delay. 5. register any new appliances provided with the manufacturer so that they can be informed of any safety notifications. 10. Minimum Energy Rating E
Page | 66 The Licence Holder shall 1. Ensure a minimum rating of E 2. carry out the works detailed on the EPC for the property to improve the energy efficiency of the property to achieve an EPC rating of ‘E’ or above, or 3. register a valid exemption on the national exemptions register
11. Anti-Social Behaviour The licence holder shall take reasonable and practicable steps to prevent or address problems of anti-social behaviour resulting from the conduct of occupiers or visitors to the property and shall: 1. Report all incidences of anti-social behaviour to the appropriate authority, for example the police or the Royal Borough of Greenwich 2. Ensure adequate security arrangements are in place to prevent unauthorised access to the premises. 3. Ensure all gardens, yards and forecourts within the curtilage of the property are kept in a reasonably clean and tidy condition. 12. Refuse The licence holder shall provide suitable and adequate refuse and recycling receptacles
13. Labelling of furniture, soft furnishings, kitchen appliances and white goods. The licence holder shall 1. indelibly label any furniture, soft furnishing and kitchen appliances and white goods provided with the address and postcode. 2. ensure that any items of bulky household furniture are disposed of in a responsible manner
14. Fire Safety The licence holder shall 1. Ensure that smoke alarms are installed on each storey of the house on which there is a room used wholly or partly as living accommodation. 15. General The licence holder shall 1. allow access by authorised officers to inspect at any reasonable time 2. not obstruct council officers carrying out their statutory duty 3. provide copies of any safety or other certificates/information on demand
Page | 67 Appendix 6 HHSRS 29 Hazards The housing health and safety rating system (HHSRS) is a risk-based evaluation tool to help local authorities identify and protect against potential risks and hazards to health and safety from any deficiencies identified in dwellings. Officers assess the risk (the likelihood and severity) of a hazard in relation to the health and safety of occupants or visitors. There are 29 hazards established, graded A-C as Category 1 Hazards and D-G as Category 2 hazards. Local Authorities have a duty to ensure no Category 1 hazards exist in residential accommodation and may take action to eradicate Category 2 hazards. The 29 Hazards are: 1 Damp and Mould Growth Health threat from dust mites and mould caused by dampness and/or high humidity. Includes threats to mental health from living with damp and condensation. 2 Excess Cold Health threat from low indoor temperatures from lack of central heating or affordable heating, poor insulation, disrepair of heating system or building components etc. 3 Excess Heat Health threat from high indoor temperatures caused by lack of ventilation, excess heating or heat gain in summer from poor insulation, large expanses of glass etc. 4 Asbestos (and manufactured mineral fibres) Health threat caused by exposure to asbestos fibres and manufactured mineral fibres (MMF) e.g. from insulation of pipework, lofts and cavity walls. Inhalation of fibres. 5 Biocides Health threat from chemicals used to treat timber, insect infestation and mould growth in dwellings. Health effects may vary. 6 Carbon Monoxide (CO) and fuel combustion products Health threat from excess levels of CO, nitrogen dioxide (e.g. from gas cookers), sulphur dioxide (e.g. from coal fires) and smoke in the dwelling. 7 Lead Health threats from high levels of lead e.g. in old paintwork and old lead plumbing. 8 Radiation Health threats from radon gas building up in sub-floor space from radiation emitting rock as part of normal ground conditions.
9 Uncombusted Fuel Gas
Page | 68 Health threat from escaping gas within a dwelling causing potential explosions/fire. 10 Volatile Organic Compounds (VOCs) Health threats from organic chemicals such as formaldehyde found in a wide variety of materials in the home. 11 Crowding and Space Psychological as well as infectious disease health threats from overcrowding due to lack of living space including sleeping, cooking, washing etc. 12 Entry by Intruders Psychological and actual health threat from intruders or fear of intruders due to poor security against unauthorised entry e.g. inadequate/broken door and window locks, fences. 13 Lighting Lack of natural and/or artificial light or poorly positioned lights. Includes psychological effect from lack of a view. Assessment is of whole dwelling. 14 Noise External noise from railways, airports, factories or roads, internally from adjacent dwellings lacking sound insulation (between flats), internal noise from plumbing, for example. 15 Domestic Hygiene Pests and Refuse Due to poor design and construction, damaged surfaces, access and harbourage for pests. 16 Food Safety Inadequate facilities for storage, preparation and cooking of food. 17 Personal hygiene, sanitation and drainage. Infectious disease and effects on mental health associated with poor personal hygiene due to inadequate washing and clothes washing facilities, sanitation and drainage. 18 Water Supply Disease, poisoning and parasitic infections due to poor quality or contaminated domestic water supply. 19 Falls associated with Baths Slipping getting in or out of bath or showers resulting in injury, fractures , cuts etc. 20 Falling on Level Surfaces Falling on floors, yards, paths, trip steps less than 300mm resulting in injury, fractures, cuts etc. 21 Falling on Stairs etc. Falls associated with internal or external stairs, steps over 300 mm and ramps resulting in injury. 22 Falling Between Levels Where difference in level is over 300 mm - includes injuries arising from falls from balconies, landings, windows, accessible roofs, basement wells, retaining walls etc.
Page | 69 23 Electrical Hazards Shocks and burns from electrocution due to defective wiring, plugs etc. Includes lightning strikes. 24 Fire Potential fatality from burns and smoke inhalation caused by uncontrolled (accidental) fires frequently associated with cooking appliances, chip pans, defective heating/electrical appliances, dangerous wiring etc. 25 Flames and Hot Surfaces Burns caused by contact with hot flames/surfaces or controlled fires or liquids (e.g. when cooking or from heaters) or scalds from hot liquids and vapours. 26 Collisions, Cuts and Strains Physical injury from a) trapping body parts in architectural features, doors or windows; or b) collisions with architectural glazing, windows, doors, low headroom, ceilings and walls. 27 Explosions Injury and the threat of injury from explosions from mains or stored gas. 28 Position and Operability of Amenities Strains and injuries from awkward positioning of windows, amenities such as sinks and wash hand basins, kitchen cupboards, switches etc. 29 Structural Collapse and Falling Elements Injury arising from falling slates, bricks, ceiling plaster or windows etc. and collapse from structural failure of roofs, walls or floors, guard rails etc.
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