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:

20th April 2020

 

Key Person responsible for assessment:

Gail Siddall

 

Date assessment commenced:

 

 

Name of Policy to be assessed:

Introduction of a Selective Licensing Scheme for Oxford

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

Homelessness Reduction

2. Background:

 

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

 

Oxford City Council maintains a reactive approach to improving the standards of properties in the Private Rented Sector (PRS). The council has worked on numerous other initiatives within the city to achieve, yet despite our efforts the PRS has the highest amount of significant hazards within properties. Through our Additional and Mandatory schemes for Houses in Multiple Occupation (HMO) HMO property standards have been improved and as such the council is exploring expanding on these success with the introduction of a Selective Licensing Scheme. Selective licensing is similar to our existing schemes but would have the scope expanded to include all properties in the PRS in any area we designate.

 

A statutory consultation exercise of a minimum of 10 weeks must be undertaken before the scheme can be introduced.

 

As Oxford has one of the highest percentage of residents living in the PRS any changes have the potential to impact a large number people. Should landlords choose to remove properties from the PRS to avoid the scheme, or choose to carry on illegally this could potentially place vulnerable tenants and children at risk of living in poor accommodation.

3. Methodology and Sources of Data:

 

The methods used to collect data and what sources of data

 

The data used to support the councils exploration of selective licensing has been drawn from existing internal data sources including property, council tax, electoral roll and service request information. This has been supplemented by freely available data from the ONS and energy performance data.

 

 

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 introduction of the scheme.

Data gathered as part of the consultation exercise will assist in informing the potential impacts on target groups such as landlords from BAME groups, tenants, students and migrants. Impacts will vary across each group but as Oxford has a challenging and expensive rental market it would be expected that those with lower financial security and those groups with English as second language would be more likely to be impacted. There are also significant proportions of landlords operating the in the city that are from BAME or overseas backgrounds which also forms another key consideration. 

 

As this scheme shall be operating as cost neutral, current positions should not be affected in their capacity to continue their role in safeguarding vulnerable individuals. Costing for the scheme is inclusive of training additional staff, which is inclusive of relevant safeguarding training.

 

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 licensing schemes to ensure the scheme is operating at a cost neutral position and to consider impacts on landlords generally. It is our position that landlords who are forthcoming with applications and the relevant documentation will be charged a lesser fee commensurate with their cooperation.

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

Although the proposed scheme may affect vulnerable groups, the overall aim of the scheme is to reduce inequalities in the Private Rented Sector and with robust consultation it is believed that risks can be managed effectively by incorporating consultation results received by effective and widespread engagement

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)            Gail Siddall                                                                           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