Additional HMO Licensing consultation

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.