2. Introduction

Arun District Council (the “council”) ran a public consultation for 10 weeks between 12 June and 20 August 2023 on a proposal to introduce Additional HMO Licensing in River ward in Littlehampton and Hotham and Marine wards in Bognor Regis.

A consultation document was produced which set out why the council was considering implementing an additional HMO licensing scheme, what that would look like in practice, specific information on items such as HMO standards, fees and charges, which properties would be covered, and in which wards it was proposed to introduce it. The consultation document also included information and data from the Building Research Establishment (BRE) to support the proposed scheme. BRE Housing Stock Model Data information was contained within the consultation document and the full report “BRE integrated Dwelling Level Housing Stock Modelling and Database for Arun District Council: Additional Analysis of the Private Rented Sector, including HMOs (21 September 2022)”, was appended to the council’s document.

The council wanted to know the views about the proposals from tenants, landlords, residents, letting agents and businesses living or operating in the area and that could be affected by the proposals outlined in the consultation document. The consultation also wanted to know the views of those that operate outside of the proposed licensing area who might be indirectly affected.

The consultation results and feedback will help us to understand and identify any parts of the proposal that may need further consideration before deciding whether to introduce any scheme and help shape the decision on how we proceed, and what that will look like in practice, and how it will be implemented if the designation of an additional licensing scheme is made.

The consultation document and BRE Housing Stock Model Data was available on a dedicated webpage on the council’s website in both accessible HTML and PDF format.

An online survey was available for consultees to complete on the dedicated website page. Paper copies of this survey were also available if requested by those unable to complete the survey online.

The consultation was advertised through a variety of means including:

  • A dedicated Additional HMO Licensing webpage on the council’s website.
  • A QR code directing people to the website.
  • Displays for the duration of the consultation at The Arun Civic Centre in Littlehampton and at Bognor Regis Town Hall.
  • Paper copies of the full consultation document were available to view at The Arun Civic Centre in Littlehampton and at Bognor Regis Town Hall.
  • Paper copies of the full consultation document were available to view at local libraries within the district for the duration of the consultation.
  • Over 12,700 letters sent to every address within the three proposed wards (River, Marine and Hotham).
  • E-mails sent to managing and letting agents within Arun district.
  • Paper copies of the full consultation document were available to view at the University of Chichester Bognor Regis campus accommodation office for the duration of the consultation. The University accommodation office and Student’s Union also sent out e-mails advising of the consultation to their students.
  • Advertising of the consultation in local media and on the council’s Twitter and Facebook accounts.
  • E-mails and/or letters were also sent to adjacent local authorities, West Sussex Fire and Rescue Service, Citizen’s Advice, local Councillors, national landlord associations, Tenant’s Union, Parish Council’s in the proposed wards, Bognor and Littlehampton Town Councils, landlords currently registered on the Chichester and Arun Landlord Accreditation Scheme, and current mandatory licensed HMO licence holders.
  • E-mail signatures containing details of the consultation sent out with all e-mails from the Private Sector Housing and Public Health team.
  • Landlords Forum event – in person on 26th July
  • Landlords Forum – online Zoom session organised by NRLA on 18th July

Although the council advertised the proposals widely and tried to reach as many groups and different relevant persons and groups as it could, it is acknowledged that this isn’t a guaranteed way to reach all those individuals or groups that might be affected by the proposals or who might have wished to have responded. For example, there will be some landlords who live outside of the district or those proposed wards who won’t have heard about the consultation if their tenants didn’t pass on the letter received; didn’t look at local media; their agents didn’t advise them; or they are not part of a national landlord association or scheme or aren’t in regular contact or liaison with the council. At the current time there is no requirement to be registered as a landlord and the Private Sector Housing team do not hold a list or register of local landlords. Similarly, there will have been tenants who didn’t receive the letter sent to their address as it may have been picked up by another tenant in the same building, for example. The majority of respondents to the online survey was expected to be from owner-occupiers of properties within the proposed wards and where the targeted letter-drop was undertaken, and that proved to be the case. One paper version of the survey was sent out, but it was not returned.