Description: logo                                                                                                                                  

Form to be used for the Full Equalities Impact Assessment

 

Service Area:

Regulatory Services and Community Safety

 

 

Section:

HMO Enforcement Team

 

Date of Initial assessment:

6th April 2020

 

Key Person responsible for assessment:

Gail Siddall

 

Date assessment commenced:

 

 

Name of Policy to be assessed:

Review of Additional HMO licensing scheme

1. In what area are there concerns that the policy could have a differential impact

Race

Disability

Age

Gender reassignment

Religion or  Belief

Sexual Orientation

 

 

 

Other strategic/ equalities considerations

Safeguarding/ Welfare of Children and vulnerable adults

Mental Wellbeing/ Community Resilience

 

2. Background:

 

Give the background information to the policy and the perceived problems with the policy which are the reason for the Impact Assessment.

 

Licensing of all HMOs in Oxford has been in operation since 2011 and following a review of the current scheme the aim is to undertake a consultation with all relevant parties on the proposal to renew the scheme for a further 5 years.

A statutory consultation exercise of a minimum of 10 weeks must be undertaken before the scheme can be renewed. The current scheme expires in January 2021 and failure to make a new designation will result in some parts of the sector being regulated and some not  which could put occupiers at risk.

3. Methodology and Sources of Data:

 

The methods used to collect data and what sources of data

 

Data held on the Council’s systems has been used to identify those HMOs that would not require a licence if the scheme was not renewed. With the affordability of housing in Oxford continuing to rise, the private rented sector and HMOs in particular are the often the only viable option, with home ownership being unachievable for a large part of the resident population.

4. Consultation

 

This section should outline all the consultation that has taken place on the EIA. It should include the following.

•           Why you carried out the consultation.

•           Details about how you went about it.

•           A summary of the replies you received from people you consulted.

•           An assessment of your proposed policy (or policy options) in the light of the responses you received.

•           A statement of what you plan to do next

If Cabinet approve the recommendations to consult upon renewing the scheme, consultation will be carried out for a minimum of 10 weeks – this consultation will be widespread and will include consultation with key stakeholders. It is proposed that the consultation is carried independently from the council. Consultation on the impact assessment has not been carried out as the proposals are still subject to approval by Cabinet.

5. Assessment of Impact:

Provide details of the assessment of the policy on the six primary equality strands. There may have been other groups or individuals that you considered. Please also consider whether the policy, strategy or spending decisions could have an impact on safeguarding and / or the welfare of children and vulnerable adults

The project is based on the need to fulfil national legislative requirements. The consultation must be widespread and aims to reach all those who are likely to be affected by the renewal of the scheme. Any representations will be considered and taken into account where appropriate.

Data gathered as part of the consultation exercise will assist in informing the potential impacts on target groups such as landlords from BME groups, tenants, students and migrants. Impacts will vary across each group with young people likely to access HMOs and an increase in families and those in vulnerable groups living in HMOs, as well an estimated 25% of landlords operating HMOs in the city being from BME groups being the key considerations. 

 

6. Consideration of Measures:

 

This section should explain in detail all the consideration of alternative approaches/mitigation of adverse impact of the policy

 

The groups most likely to be affected by these proposals have been identified and a draft consultation plan has been prepared, this will be finalised before the cabinet meeting. The consultation exercise if approved, will be undertaken in accordance with the agreed plan.



 

6a. Monitoring Arrangements:

 

Outline systems which will be put in place to monitor for adverse impact in the future and this should include all relevant timetables. In addition it could include a summary and assessment of your monitoring, making clear whether you found any evidence of discrimination.

 

The council reviews the fees and charges in relation to HMO licensing to ensure the scheme is operating at a cost neutral position and to consider impacts on HMO landlords generally. The flexible design of the fee structure ensures that changes can be recommended to address any impacts that are identified.

Enforcement activity is reviewed in each case by senior officers and by Law and Governance to ensure that the council is being fair, consistent and proportionate in its responses as well as acting in the public interest.

 

7. Date reported and signed off by Cabinet:

 

8. Conclusions:

 

What are your conclusions drawn from the results in terms of the policy impact

 

9. Are there implications for the Service Plans?

YES/NO

10. Date the Service Plans will be updated

 

11. Date copy sent to Equalities Lead Officer

 

 

.13. Date reported to Scrutiny and Cabinet

 

14. Date reported to Cabinet

 

12. The date the report on EqIA will be published

 

 

Signed (completing officer)                                                                                                Signed (Lead Officer)

 

Please list the team members and service areas that were involved in this process:

 

Equalities Lead Officer

Service Manager

Legal Services Manager