Luton Borough Council Housing Strategy 2019-2022

Luton Borough Council recently published their Housing Strategy for 2019-2022. A copy of which can be downloaded here

Our response to the consultation is as follows: 

Lenwell’s formal response to Luton Borough Council’s Housing Strategy Consultation 

Scope of Consultation 

Whilst the draft document at Appendix 3, sets out a very comprehensive range of consultees, private sector landlords and managing agents are not specifically mentioned. From Lenwell’s perspective and experience, we were not engaged in this consultation process and as we were not included, we wonder if any other landlords and/or agents were also similarly not included. 

That being the case, we feel that the Council have missed an opportunity to engage with a very significant sector in the provision of housing in the Borough. 


Condition of PRS Housing - Quality of Housing is Key

The strategy acknowledges that the private rented sector (PRS) now accounts for 23% of the housing stock in the town, a % which is running higher than national and regional comparisons and has seen an increase from 17% in 2009.

Added to this, the strategy estimates that the level of private sector properties not achieving the ‘decent homes standard’ is at 32%, but this estimate is based on the 2009 private sector stock condition survey.

This estimate is higher the national estimates of ‘non-decency’ reported in the English House Condition Survey 2015 at 28%. The national evidence also highlights that the PRS experiences the highest proportion of Category 1 Hazards under the Housing Health and Safety Rating Scale of any tenure. 

Couple this with a very high proportion of the PRS being in the wards of the Borough with highest levels of deprivation and poverty in the town, presents a concerning picture about the condition of the PRS stock.

We support and welcome the proposal for a refresh of the House Condition Survey.  To achieve an up to date picture of the issues around the condition of the housing stock in the Borough, will need to be the catalysis for the development of strategic responses to the evidence that comes forward. However, accepting that resources are limited, delaying the survey until to 2020, cannot be the preferred approach.

Pending the delivery of the new condition survey, the Council needs to develop a more proactive approach tackling poor conditions. The draft strategy makes some reference to enforcement action being taken to improve conditions in the PRS, and action being taken against rogue landlords, but the strategy has no targets for further action. 

The introduction of further selective licensing has been laboured and not well received by some elements within the PRS. Again, Lenwell are and continue to be supportive of the introduction of the scheme and have offered practical assistance in achieving a smooth implementation.  However, our concerns are that the strategy has no measurable or ambitious targets for what the licensing scheme, when implemented is aiming to achieve, which in our view is an omission. 

The Council’s Relationship with the PRS 

The formal relationship with the Council and the PRS seems to have stalled. The Landlords Forum and the Landlords Accreditation Scheme, whilst both being positive initiatives, are ineffective. This is at least partly the responsibility of the PRS, where there appears to be a lack of willingness to engage from some landlords and agents.    

But having an effective Forum and Accreditation Scheme with such a large proportion of the housing stock now privately rented, the Council ought to consider placing greater emphasis of working with the PRS and for that to be a key action point within the delivery plan for the strategy. 

This is important on a number of counts:

  1. The Luton Investment Framework(LIF) is heralded by the Council and referenced in the draft strategy as the vehicle to achieve a step change in attracting significant inward investment and prosperity in the town, for the benefit of all the communities of Luton. 
  2. Housing and the quality of the housing is singled out as a key objective, a view we support, but the PRS despite representing nearly a quarter of the Town’s housing stock has not been included or engaged in the LIF. 
  3. If the Council are serious about seeking a step change in the quality of housing in the town as part of this inward investment strategy – then the PRS, that is growing faster than any other tenure, needs to be engaged and supportive of the Council’s ambitions.  

Homelessness – The continuing high levels of homelessness, are clearly both worrying and challenging at a number of levels. The draft strategy highlights that the main reason for homelessness presentations in 2018 was the ending of Assured Shorthold Tenancies. Yet looking at the Homeless Reduction Strategy the role of the PRS is effectively absent from the various interventions and actions that are described to tackle the problem. 

Involving an effective Landlord Forum in the challenges of homelessness would seem to be an intervention that at the very least is worth exploring.

From a Lenwell perspective, we feel that there are opportunities for Landlords and Agents to work directly with the Council and particularly Luton Access to help support private sector tenants with advice, information and guidance to prevent homelessness. Our offer to make that connection, although welcomed by Council officers has frustratingly stalled, due to LBC IT implementation issues. 

Not connecting Luton Access and the PRS, we see as a missed opportunity for the PRS, the Council and most importantly the people who find themselves homeless, when there were other options to avoid homelessness.  

Safeguarding – the draft strategy references extensively the vulnerability of people and the importance of safe and secure housing. More emphasis needs to be made to highlighting these issues to the PRS, and ensuring that PRS staff working in the community are adequately trained to help and support vulnerable tenants affectively and appropriately.

We hope our response to your consultation will be helpful and look forward to hearing from you.

A copy of the letter sent to Luton Borough Council can be seen here.

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