Tackling Criminal Landlords and Achieving Licensing the Royal Greenwich way
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1 Tackling Criminal Landlords and Achieving Licensing the Royal Greenwich way Cllr Jackie Smith Cabinet Member for Community Safety & Environment Presentation to cover Background key learning points from our approach to enforcement Key learning points from our approach to licensing
2 Background Private rented sector housing issues identified: overcrowding/ subletting/ illegal & HMO conversions/ serious disrepair / exploitation, harassment, eviction Small enforcement team, capacity to respond to tenant complaints only Political priority project: to improve standards in the private rented sector through 4 work streams High intensity enforcement programme Consider discretionary licensing schemes Extra help and support for tenants Additional support and advice for landlords
3 Project Approach with High Level Governance Political Focus & Reports: extra funding provided, high level/ cabinet member priorities and scrutiny Project plan agreed by cabinet Officer Project board chair Director All Directorates represented at Asst Director level London Fire Brigade & Metropolitan Police Others by invitation eg Home office/immigration and HMRC Officer Steering Groups x2 One focussed on enforcement and regulation RBG services and external partners represented Landlord and tenant support involved Community groups Added value joint working developed and strengthened through external partnerships and between internal services Publicity - launch, regular press releases - case reports
4 Enforcement Programme Delivery Led by Environmental Health division, New team formed Intelligence driven and process led approach Information sharing/ Data Access - wider range of data made available, predictive modelling to find HMOs Referrals services, external partners, residents, members Intelligence: use of data analyst + intelligence officers Enforcement and criminal Investigations enforcement officers always risk based, properties and persons of interest
5 Introducing a Data Analyst Analytical tools used to identify areas/ properties/ persons of interest for investigation Portfolio landlord operations uncovered A focal point for intel gathering and systems access/interrogation for internal and external partners Able to respond reactively and promptly to emerging intel Pivotal in establishing the extent of the PRS, in terms of numbers, addresses, location and type (i.e. HMO or single occupancy) Vital to the development of the evidence base to support the introduction of licensing Makes effective use of GIS mapping to assist in the targeting of resources and interventions.
6 The data analyst s work
7 Introducing Intelligence Officers Intel process refined: gather visit bespoke risk assessment - prioritise enforcement cases Access to wide range of Intel sources Bespoke risk assessment developed based on property, responsible parties, track record, occupiers, time weighting Complete Intel package handed to enforcement officers Portfolio landlord operations scrutinised Focus on rogues interface with criminal behaviours Support criminal investigations through the investigators ABC (Assume nothing, Believe nothing, Check everything)
8 Maximising Value of Enforcement Officers Work prioritised on intelligence risk assessments Inspections always of worst cases first Focus on persons and organisations of interest Intelligence package provided when allocated cases Faster response and progress maximise use of specialised professional enforcement officers Process led and time managed approach Cases always moving forward Joint working/operations to disrupt criminal behaviours Gaining entry: voluntary + court warrants Assessment of hazards and management standards Escalating or risk based enforcement action Worst cases: prohibition/remedial action/ prosecution/ works in default Most cases: improvements by agreement / legal notice No landlord engagement: cases pursued robustly and tenaciously
9 A Flavour of what we found Unsatisfactory facilities/ harassment Illegal conversions, Makeshift extension fire risk, gates restricting exit Fire damage bedroom space created in porch.
10 And more. extensive mould/damp Dangerous electrics overcrowding Disrepair and neglect Damp
11 Statistics and Outputs April March ActivityHazards Identified Formal Enforcement Action Legal Action
12 Statistics and Outputs April March Category One Category Two
13 Outcomes April March 2017 Outcomes more difficult to quantify, some evidence of behaviour change: number of mandatory HMO licenses issued has doubled Increased levels of voluntary compliance by landlords over time More improvements carried out in a timely manner when we ask BUT more work to do. Criminals still operating Increasing prevalence of worrying HMO practices rent to rent models and exploitation of vulnerable tenants Unauthorised development incl beds in sheds Avoidance rental models - exploitation of planning and housing benefit rules through creating London Lockdown type properties Beds to rent Proliferation of HMOs created article 4 intervention by planning service
14 Achieving Borough Wide HMO licensing Scheme approved to start in October 2017 Evidence developed in house using internal and external data sources compiled to show evidence of poor HMO management and standards A multi-agency/service project led approach taken: Evidence gathering and collation Presentation of the evidence Legislative requirements, e.g. statutory consultation Resourcing requirements Properly costed to cover full administration and enforcement Takes account of local needs, e.g. waste management in the Plumstead Waste Taskforce Area Online application and payments systems essential to efficient administration. IT infrastructure/development is integral
15 Licensing Learning Points IT development will always take longer than anticipated! User Testing to test your online application before launch to pick up on issues. Involve landlords in testing online application/payment systems. Make good use of the consultation feedback to gather further evidence to support the scheme. Always expect challenge! An effective scheme takes resourcing, consideration of local needs and should support partners for the benefit of the Borough, e.g. tackling waste issues through waste assessments of HMOs and bespoke license conditions.
16 licensing still more to do Selective Licensing case: Evidence currently strong in some wards/ parts of wards Currently evidence based upon the poor condition of PRS property Challenges Can we make a robust case for widest possible/borough wide scheme to withstand all challenge? Can we prove the case without big expenses such as a property condition survey? Secretary Of State approval is likely to be required Resourcing a scheme How we intend to approach this In house with data analyst Ranked matrix analysis of ward/area data across all the statutory eligibility criteria
17 For more information Please Contact Carole Zelenka Head of Environmental Health (Pollution and Residential) Services
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