Written evidence submitted by Soho Road East Neighbourhood Watch, Birmingham [EXA 038]

              Soho Road East Neighbourhood Watch is a group founded in 2019 to support local residents and organisations in creating a safer, stronger and active community. Based in Handsworth, north-west Birmingham, our geographic remit includes east Soho Road, Soho Avenue, St Michael’s Road, Scholars Close, Piers Road, Ivy Road, part of Whitehall Road and Rose Hill Road. Soho Road East Neighbourhood Watch serves over 750 residents in an area which includes three schools, places of worship, numerous businesses, and a pharmacy.

We write this letter to share our experiences and concerns with the current private sector renting industry, namely the use and abuse of properties with Exempt Accommodation (EA) status. We hope that our lived experiences as local residents within an area of high EA concentration will carry weight in any decisions and recommendations which are put forward following the inquiry.

According to a report on Exempt Accommodation filed by the Overview & Scrutiny Committee of Birmingham City Council (2021), the number of EAs in Birmingham has increased from 11,445 to 22,017 between 2016 and 2021. The report outlines that Soho Road and Jewellery Quarter Ward, within which part of this Neighbourhood Watch sits, has the third highest EA concentration in the city of 207 units (4.9%). It is outlined that the stock profile of houses in Birmingham and the Handsworth area encourage HMO and EA usage in particular. We are aware of this given the high number of large, early 20th century houses, with multiple floors, rooms, and space for tenants. This housing stock is made more attractive given the comparatively low house prices in the area compared with other parts of Birmingham.

Having provided some context, we will now go onto explain and elaborate the specific concerns our Neighbourhood Watch has identified in relation to EAs which impinge the lives of residents, businesses, community stakeholders and many EA tenants.

What is the quality of exempt housing provision?

In terms of housing type and structure, we have seen EAs which are a mix of older, 20th century Victorian housing as well as more modern new-builds. The older buildings are often large and contain a high number of rooms. These make them prime selection for EAs. The older houses often have unmaintained gardens at the front and rear as well as issues such as damp and mould, especially if not well-maintained. Newer stock is often smaller and is built in blocks or estates. These houses are more cramped but are usually more well-maintained. However, this is entirely dependent on the tenants and EA service provider.

Regarding the quality of service provided by EA provision there are a number of issues:

-          Lack of transparency around EA provision - it is hard to easily find out what is EA provision and what isn’t. Furthermore, providers can be hard to contact. There must be a publicly available register of EAs as well as some physical indication on EA properties as to their status.

-          Tenant involvement in anti-social behaviour, exploitative activity, and exploitative economies also indicate the quality of service, or lack thereof, in EAs. Locally, we have seen residents purchasing and using drugs as well as the services of sex workers which has increased demand and presence in the area.

Is the current model of exempt accommodation financially viable, and does it represent value for money?

For Landlords and service providers, EA offer an opportunity to enhance provision and also increase income. However, this is met with a widespread lack of regulation which reduces quality assurance across services. However, the profit incentive still exists as there seem to be a lack of performance-based measures to financially incentivise high quality service provision. Issues have been raised around both landlords and over-capacity quality assurance processes which have been described as ‘tickbox exercises’.

For communities the current model of exempt accommodation is a drain on financial, social, and community capital due to a number of reasons:

-          Transient tenants mean that community links are harder to build and sustain with residents.

-          Uncontrollable factors like landlord commitment, quality of provision, and level of care required can cause disharmony and social distrust.

-          Demand for owner-occupied properties will decrease given the culture of HMO and EA provision, meaning that more will appear over time.

-          Fuels exploitative economies which both channel public funds into criminal organisations and into underground markets as well as reducing the involvement of residents in local economies.

Ultimately, for a wide range of reasons, EAs present financial viability for landlords and service providers due to a lack of regulation and quality assurance. This has a direct and immediate impact on local residents, decreasing their financial, social and community cohesion.

Are there significant geographical and regional differences in the provision and the problems of exempt accommodation?

The report cited earlier by the overview and scrutiny committee (2021) highlights the regional differences in EA provision. Birmingham is an area with distinctly high EA provision compared to other cities in the UK. Within Birmingham, Soho and Handsworth wards contain a high concentration of EAs due to the aforementioned details regarding housing stock, type, pricing, and lack of community planning consultation.

How should the regulatory oversight of exempt accommodation be organised?

Currently there is little usable community oversight for the approval of EAs. Following the Localism Act, Neighbourhood Forums were intended to be developed and they have not been hugely supported in a sustained way. This has meant that forums have disappeared, reducing community oversight of planning and development.

Each council ward should have a community board who oversees and consults on planning and development. This would involve working with neighbourhood forums to develop neighbourhood plans as well as consulting on a short-term basis around new planning applications. Furthermore, there should be a review of EAs in a ward every two years by a local scrutiny committee, which takes into account interests of local residents, businesses, and the local authority.

Is there sufficient publicly available information about exempt accommodation?

Definitions about EA are available widely online, as well as the legal and practical basis for their creation. However, the EA system is hard to navigate when trying to understand the composition of housing stock in a local area. We find that:

-          There is a lack of publicly available information on EAs located in particular localities.

-          There is not a clearly understandable complaints process to follow if raising concerns about EA service provision.

-          EA properties do not display that they are EAs making it harder to ensure that service quality is kept satisfactory

Recommendations

-          More publicly available or displayed information about which properties are EAs.

-          Easier process to raise complaints about EAs as well as evidence required to share in complaints processes

-          More local community consultation on planning and development strategies as well as shorter-term planning applications.

-          More Birmingham City Council infrastructure in areas of high concentration of EAs - namely drug/alcohol recovery services and sexual health services.

-          Better regulation and checks as to whether areas/landlords can support increased complexity and acuity of tenants in properties - primary health provision and probation services

-          Greater ownership of issues by Landlords and service providers

Thank you for considering our lived experiences and evidence on this contentious but ultimately important topic.

January 2022

References Cited:

Birmingham City Council (2021) ‘Exempt Accommodation: A report from Overview & Scrutiny’.