Croydon HMO Licence “Evidence” Dubious

Croydon are doing a consultation so they can implement borough wide Article 4 restriction on HMOs. Their main claim is that 3 bed or more houses are being lost to HMO conversions. Details can be found: Click here

The ‘evidence’ is dubious. If you look at there evidence report, there is Figure 1, page 10 showing licenced HMOs (green dots). There is figure 2, page 11, showing family homes lost to conversion/change of use. I’ve done a basic overlay of this maps in photoshop. Where full black dots show, is where a loss property has been converted to a licence HMO (partial black dots are only because the map is too small and properties next to each other are overlapping – data point should be ignored).

There is very few full circles so councils claim just doesn’t stack up. Other problems with the data I’ve identified:

– claim that 900 homes have been lost. No breakdown provided as to their subsequent use breakdown. So could have been ‘lost’ to flats, commercial premises, knocked down house and built apartment blocks, and of course, HMO conversion

– Claiming percentage of family homes (3+ bedrooms) across the borough is down. Croydon has had massive conversion of office towers to flats/microflats. This will naturally ‘dilute’ the percentage of family homes. One office tower might have 200+ new properties added (council is basing this off losing 900 family homes in a 10 year period)

– level of ‘investigation’ is only on the surface. They searched the council database for ‘complaints’, not for outcomes. I could complain that my neighbour Santa Clause is making noise every night launching his reindeer off the roof. A complaint doesn’t necessarily make it true

– the official evidence sighted is only, Data from HMO and planning database. Not very rigours and appears to be only a high level keyword search.

– Figure 3 is in reference to improvement notices. There is no breakdown as to severity and bias in this. If council isn’t issuing improvement notices, how does this justify the manpower/ employment required/needed.

– page 14 refers to 15 out of 33 London Boroughs having introduced Article 4 Direction, but don’t break down how many have been blanket borough wide ones.

– page 14 refers to 21 counts of HMO related fire events over a 4 year period, so 5 incidents a year. No comparison made with general fire activity in the rest of housing. Given HMO requirements, suspect this is quite low when compared with wider social housing / owner occupier incidents.

If 5 incidents a year is such an overwhelming stat, then you’d anticipate alternative forms of housing would being having less problems. Lets say it is on par and 5 incidents a year also. Croydon fire department must be one of the quietest departments in the council, as they would be responding to less than 1 fire a month (at best).

– page 14 paragraph 5 infers that growth of households living in HMOs is overcrowding. There is never any definition of overcrowding, stats or facts presented otherwise.

– page 14 talks about 270 complaints reported to council about HMOs. Again no reference to baseline standard for other types of housing.