HMO of any size create the same risk issues for both
tenants, their neighbours and the wider community and should therefore be
subject to the same regulatory framework.
We have seen an expansion of multiple occupancy properties
of various sorts in the centre of Bath. This increase is both in terms of
numbers of such properties and types of multiple occupation models ranging from
large traditional HMO to holiday let party house models. We have also seen an
erosion of traditional constraints and controls on this type of property both
from legislative action and inaction and the ongoing attack on existing lease
restrictions and covenants.
Two or more households in a building require as much
external oversight as much as larger HMO both to protect tenants and their
neighbours
Bath city centre is unique in the number and socio-economic
diversity of its residents. This requires managing and protecting.
The nature of many of the buildings in Bath city centre
presents particular challenges in terms of fire risk, noise pollution and waste
management which require external oversight.
Fees proposed are designed to cover the administration cost
not make a profit. HMO operators should be liable for the regulatory regime
necessitated by their chosen business model.
The proposed conditions cover the basic risks and
responsibilities that any responsible landlord should be held to
The current reactive response to complaints leaves landlords
and tenants unsure of the rules. It also is a much more resource intensive
approach and similar models of reactive response fail because of both
resourcing issues and reporting issues as many tenants in this type of property
feel vulnerable.
With the increased use of multiple occupancy models by
landlords a lack of effective regulation will almost inevitably lead to abuses
and increased nuisance and risk both for tenants and the community.