Melanie Leech, Suzannah Young and Timothy Douglas gave evidence.

Q This panel can go on until 4.20 pm. Perhaps we could start off with Timothy Douglas introducing himself.

Timothy Douglas:

Good afternoon, and thank you very much for the opportunity to give evidence today. I am Timothy Douglas, the head of policy and campaigns at Propertymark, which is the UK’s leading professional membership body for property agents. We have 18,000 members working across the UK in lettings, sales, commercial property, as valuers, auctioneers and inventory service providers in commercial property.

Melanie Leech:

Thank you very much for the opportunity to give evidence this afternoon. My name is Melanie Leech. I am the chief executive of the British Property Federation, which represents institutional investment into the private rented market, which is everything from student accommodation to the build-to-rent sector to co-living and senior living.

And Suzannah Young, who is joining us on Zoom.

Suzannah Young:

Thank you, Chair. I am Suzannah Young, a policy officer at the National Housing Federation. We represent housing associations in England—social landlords providing 2.7 million homes to 6 million people. I will say a word about housing associations, if I may, because the Bill will have implications for them, as they offer assured tenancies. As they are not for profit, housing associations invest any income back into the development and maintenance of homes and into supporting residents and communities. They seek to provide tenants with long-term stability and security of tenure in good-quality, safe and affordable homes. We are a sector that has always offered assured tenancies and lower rents, and that delivers housing types unlikely to be found in the private rented sector, including three quarters of supported housing for people on low incomes with care and support needs. We therefore support the Bill’s aims to give greater rights and protections to renters.

Q This is a very broad-based panel with different perspectives. My first question is about the impact on housing associations. Could you each give us a brief introduction from the perspective of your organisations on what you think the impact of the Bill will be, in particular on the supply of private rented sector homes in the UK?

Melanie Leech:

Shall I kick off? Thank you for the question. The first thing to say is that we support the aims of the Bill and the drive to raise standards in the private rented sector. In particular, I would highlight measures such as the compulsory ombudsman—of course, many institutional landlords are already voluntarily members of the housing ombudsman service—along with the landlord database, which we have been calling for since 2008, the application of the decent homes standards and Awaab’s law to the sector, and recognition of the particular nature of the purpose-built student accommodation sector, which of course you have just been talking about.

Our major concern with the Bill is that the courts will not be ready for the abolition of section 21. A cross-party consensus that a better functioning court system is an essential part of the reforms has been a significant factor in maintaining landlord support for rental reform. Its importance has consistently been recognised in the political debate—by the Select Committee on Housing, Communities and Local Government in the last Parliament, which looked at the previous Government’s reforms, and by the Mayor of London in his work on a London model. However, despite serious discussions starting on rental reform in 2017, we have made almost no progress on court reform, which leaves landlords with little confidence that sufficient improvements will be made to make these reforms work well. That, of course, should be the objective: not just to pass these reforms, but to ensure they work well for both landlords and tenants.

One way of improving the court process is to digitalise both the process and the interface with claimants and defendants. We are really pleased that the Housing Minister is committed to continuing with the digitalisation project, but that is not going to deliver improvements any time soon. We are therefore heartened to hear the Housing Minister also talking about additional resource. This is essential because with section 21 gone, the courts will need to consider and process possession cases under section 8. Government data suggests that it currently takes just over seven months to process section 8 possession cases, including cases related to antisocial behaviour and rent arrears. It is worth stressing that that is an average. It is not uncommon to hear of cases taking more than a year.

There is also a huge shortage of court bailiffs in parts of the country. For example, in some London boroughs it can take five months to secure the services of a court bailiff, even when your claim has been vindicated. That also, of course, has consequences for people who cannot access those homes that would be freed up, for example in cases of poor behaviour and rent arrears.

While we recognise that improving the courts will not be a precondition of section 21 ending, at the very least we can call on the Government to outline what the justice system being ready means, both for tenants and responsible landlords; to commit to bringing waiting times down when it comes to the courts considering and processing legitimate possession cases; to ensure that the courts have clear and commonly agreed key performance indicators, which the Select Committee in the last Parliament recommended; and to improve staffing of the courts and tribunals, including recruiting more bailiffs.

We would also urge this Committee to scrutinise that aspect of the Bill in detail, and to consider calling for evidence from the Ministry of Justice—so far as we are aware, we have never actually heard directly from the Ministry of Justice, which is best placed to explain what procedures will be in place to make sure the courts are strengthened to deal with these cases—and to ask what progress is being made on digitalisation. We urge the Committee to scrutinise the justice impact test shared between the Ministry of Housing, Communities and Local Government and the Ministry of Justice—which will contain the projections on which the impact for this part of the Bill is based—so that we can all see that those have been properly scrutinised and that the court reforms that we need can be delivered.

Timothy Douglas:

At Propertymark, we recognise that there is an ongoing cost of living crisis and there is huge demand for private rented property. We also recognise the manifesto commitments from this Government and the other parties to the changes contained in the legislation. We certainly acknowledge a drive towards improved standards, but we all have to recognise the unintended consequences and the impact of the changes on landlords, agents and the supply of property.

Certainly, our members are left wondering how this Bill will help to meet the huge demand for private rented property. Our data shows that on average there are almost 10 new applicants registered for each available property. One member in the west midlands, who has 13 offices across the region, has seen their lets—the number of properties—reduced from 5,348 to 5,006 since the start of the year, so we cannot underestimate the incentives for landlords or the investor appetite. These are significant changes. As has been said, we must get a commitment to reform the courts, the grounds have to be robust, and we must see enforcement of the existing rules by local authorities, never mind the raft of additional heavy-handed measures included in this legislation. We must retain fixed-term tenancies as an option where mutually beneficial for all parties, to retain flexibility and choice in the market.

Suzannah Young, do you wish to add to your initial remarks?

Suzannah Young:

In response to the specific question on the private rented sector, it is not an area where I have the most evidence to give, as my main area is the impact on housing associations. However, one thing I can say specifically is that we think that the proposed private rented sector housing ombudsman is absolutely right. Residents in the private rented sector should have access to an ombudsman. It is important that access is clear and easy to navigate for tenants, and that they have routes to redress where things have gone wrong.

From that perspective, and from the perspective of housing associations, we would like to ensure clarity about the remit of the new ombudsman. There is already an ombudsman service for social housing. However, some housing associations also provide market rent homes. It will therefore need to be clear what the expectations on housing associations are, in terms of reporting on their market rent homes, and it should also be clear to tenants which ombudsman they should go to. For example, sometimes there will be social and market rent tenants in the same building with the same landlord. We need clarity on remits so that there is no confusion.

I would like to comment on the points that Melanie Leech made about the readiness of the courts. Housing associations have experience of the impact of delays in the courts and the fast-tracking of possession cases during lockdown. Our members have experience that could be of use in the future. Our members report to us that there are already delays in the court system, which we heard earlier. It can take many months to get a possession hearing. That is a particular problem where possession is being sought, for example, for serious antisocial behaviour or domestic abuse, where delays to possession can increase the risk to tenants from perpetrators.

If the Government wish to implement, for example, a system of fast-tracking of serious cases, there will need to be a robust mechanism. If all cases are fast-tracked, we will be in the same position as if no cases are fast-tracked. We had some feedback from our members about how the courts could have helped with improving their capacity, such as increasing bailiff availability, increasing clerk availability to help to deal with the paperwork and logging of cases on the new online portal, ensuring training for district judges, and addressing the health and safety concerns of bailiffs. If the Committee wishes, I can also give some evidence, either now or later, on the impact on housing associations.

I think we will stop there for the moment and hear some further questions.

Q I have two related questions. First, as has been said by all three of you, there will be an ombudsman, a tribunal and a court, all of which will have a slightly different role. I am interested in how you think the Bill can provide clarity for both tenants and landlords on where to go with different issues, thereby ensuring that they can enforce their rights and deal with things appropriately.

Timothy Douglas:

I think more clarity is needed in the letting agent space. Letting agents are already required to sign up to one of the two Government-approved redress schemes, but those two schemes do not adjudicate in the same way. The property ombudsman will work to a code of practice, and the property redress scheme would work to that code of practice or common law in order to make the adjudication. We are adding an additional layer to that through a landlord ombudsman. Our recommendation would be that those landlords who are fully managing property should sign up to a redress scheme, but we realise that that argument is not necessarily in the legislation and has not been won.

We must look at the myriad management practices—let and rent collection, or fully managed. As a tenant, working with both a landlord and an agent, we have to get adjudication of this new scheme and the existing schemes, and get a code of practice in place for the sector, so that we are all working to the same standards and the same adjudication. Are we also expecting landlords, like agents, to have a complaints procedure that tenants have to work through? We need that parity before we even talk about tribunals and the other things.

We must use the existing schemes and that expertise in the sector. There are 19,000 letting agents in England, and roughly 50% of landlords use an agent, so 50% of landlords are already plugged into those schemes. They have knowledge and experience. Let us get a code of practice built in, so that we are all adjudicating on the same level. Let us get some sort of housing complaints portal across tenures, so that the tenant can make a complaint that is filtered to the relevant ombudsman. We must help the consumer. We are adding a layer of complexity and we need to iron out some of those issues first.

Melanie Leech:

I will build on that, but by standing back slightly from the question, because I think this is a subset of a much broader set of issues around transition. This will be hugely complex. We have 4.6 million tenants who will need new leases. Some of them are sub-letting and so on. We have all those new agreements to draft. We are going to need lots of training for the professionals who are managing this. We will need new processes and guidance for agents and local authorities. We will need adjustments to insurance and mortgage policies. The lesson from Wales and Scotland is that a big bang approach does not necessarily work because you cannot get all of that right in one go. We are keen to work with the Government to start thinking now about the implementation strategy. Clarity for tenants and landlords about how the new system will work, where to go and so on is critical to that, but we need to start thinking about that now and to create an implementation framework, because if we do not, these new reforms will not work well.

Timothy Douglas:

Scotland has been talked about as an example, but of course, it has phased in private residential tenancies—there still are assured tenancies working in Scotland. But Scotland has a long-standing landlord register, and it has letting agent registration and regulation. There is a tribunal that is free to use for both landlords and tenants. Scotland definitely had a 12 to 15-month phase-in approach for the PRT to kick in. From what we are hearing, we will have Royal Assent, three months and a commencement, and then all these tenancies will switch over. That is an issue for all agents, but certainly for our larger agents, who are managing thousands of tenancies up and down the country. A consideration of the impacts of the transition and extending that would be welcome before the implementation of this legislation.

Q Briefly, there is another subset of a broader issue around things like the decent homes standard. We have heard from various sources of evidence that there is a need to ensure that property owners have the time and necessary support to achieve that. We know in the rest of the UK housing stock that that can be a challenge due to the physical nature of it. What are your views as to how the Bill addresses that issue?

Timothy Douglas:

From Propertymark’s point of view, we want to see warm, decent homes. The agent can actually be a layer of enforcement, whether they instruct the landlord to take on that property or not, as well as mortgage providers. Unlike social housing, which is designed to specific specifications, the property redress scheme comprises a range of property without specification. The decent homes standard was argued about in the previous Session. It was consulted on by the last Government. There were numerous working groups with the last Government and, yes, it is going to be consulted on again.

From Propertymark’s point of view for the private rented sector, we have to link up with local authority assessments. We have to focus on fit-for-purpose. I know that local authorities—certainly a local authority in the midlands—will, without fail, change all the boilers every five years in their housing stock. I am sorry, but private rented landlords do not have the money to do that, and the social rented sector has received billions of pounds in eco funding as well. If we are to get that parity between the private and social rented sector, the private rented sector needs to see that funding come forward, certainly in the thermal comfort space—cool in the summer, warm in the winter. Why, for the 18 different archetypes of property across the country, are we going for a one-size-fits-all energy efficiency target? That is going to nullify older properties in England and Wales where the regulations extend and rural properties. Let us simplify the HHSRS as well. There are existing levers that we need.

Finally, on this point about extending decent homes and Awaab’s law, we welcome these steps as long as we get them right for the uniqueness of the private rented sector. In the Social Housing (Regulation) Act 2023, which was passed in the last Parliament, there is a requirement for all property managers in the social rented sector to be qualified. We think that should be extended to the private rented sector to all letting agents as well. If we can get that code of practice in place through adjudication and redress, we can qualify our letting agents. We get parity, drive up standards and help enforcement. That would certainly go a long way towards the decent homes standard and Awaab’s law being implemented in this sector.

Q Melanie, can I address a specific question to you about suppliers? There has been a lot of discussion today about the mismatch between supply and demand. We have touched on the provisions in the Bill about how tenants can challenge within-tenancy rent increases and so on. In terms of overhauling the private rented sector, the Bill is part of a wider transformation of the housing system that we want to carry out. There is absolutely a chunk of private renters, particularly in the bottom half of the market, who should be in social rented housing, and we want to build more of that, but we also want to grow future supply in the PRS. What do you think the Bill will do specifically to build-to-rent providers? Do you think they will accommodate themselves to these changes? Are there lingering concerns that you think will impact on investment in that future supply and professionalising the private rented sector as we grow it?

Melanie Leech:

The first thing to say, as you know, is that institutional investment into the build-to-rent sector specifically is a growing part of the housing supply mix. It is bringing in genuinely additional investment, because it is the type of investment that does not typically invest in build to sell—you have people wanting to use large amounts of capital to generate secure income streams so that they can match against pension liabilities, insurance liabilities and so on. Probably the key word in that is “secure”. Anything that damages investors’ confidence that the income they will get from their investment is at risk will undermine our potential to unlock investment into homes and the rental sector. Currently, the peak year for build-to-rent delivery was 15,000 homes. We think that you can double that to 30,000 homes, with the right conditions, and some of my members would go further and say that you can double that again. We are looking at an investment stream that could be a very significant part of helping to deliver the Government’s aspirations to build more homes.

What I have already talked about, in terms of the ability of the courts to cope with the reforms, is an important indicator of confidence. Investors will look at that and think, “This changes the basis on which I have invested. It makes it more difficult for me to manage the property efficiently.” I think the issues around rent determination also have that potential, so there is nervousness around needing to use section 13 and rent increases. There is a suspicion that tenants have nothing to lose by challenging any rent increase, so it is about getting the framework right around how we define what an unreasonable rent increase might be and how we manage those cases that might come before tribunals. There are some issues around that that we would like to see more clarity around and redressed.

In general, we are really supportive, because in the part of the market that I represent the decent homes standard already would not cause us an issue in terms of implementation and so on. We are trying to raise standards in the private rented sector, and we are raising standards in the private rented sector, but the key thing is to implement the reforms in a way that does not undermine investor confidence, so that we do not inhibit the supply of homes.

Q While I have got you on that point, we heard from Ben Beadle earlier a view that landlords would adapt to the date payable of a rent when challenged—I think this is what he implied—by changing the point at which they serve their section 13 notices to perhaps account for that lead-in time. What would you expect to see? Would annual increases be standard or given at a particular time? How do you think that the sector, build-to-rent and the more typical cottage landlords would adapt to that change?

Melanie Leech:

This is pure speculation, because I have not asked members this question. History suggests that once legislation is passed, those affected by it figure out the best way to protect their interests in the light of the new framework, so I would broadly expect that to happen. But if we are asking ourselves how we get back to a position where investors can have confidence, we should probably ask ourselves why we are asking that question in the first place. We should be creating a framework within which investors can have that confidence.

For example, some of the nervousness will be around the fact that, if you have a litigious tenant who takes you to the tribunal and ultimately to the courts over a rent increase, and the decision goes in the landlord’s favour, you have still lost several months. You cannot backdate the reasonable rent increase for which you have just won the court’s authority, so you have lost a lot of money in terms of both the rent accruing and the amount of time you have to spend going through that process. Let us just remind ourselves that when I talk about landlords here, I am primarily talking about pension funds and insurance funds, so it is our money.

Timothy Douglas:

I think that is the point. While we need supply—and we need supply from all sources—landlords in the private sector are a broad community. The bulk of private rented sector landlords have one, two or three properties. What is disincentivising investor confidence is not necessarily the competence of this Bill, but the sector would welcome a review of all taxes and costs that have impacted private landlords in the past five years. We have seen the reduction in mortgage interest relief, the 3% additional surcharge when you buy a rented property, tinkering with capital gains tax—some are taxed as businesses while some are not—and changes to the wear and tear allowance. If we really focus and want to be sensible about incentivising landlords and the investment community, we have to shine a spotlight on taxes and costs.

Alongside this legislation, we need to enact the registration requirements in the Levelling-up and Regeneration Act 2023 on short-term lets as well. Otherwise, we are going to see a further exodus of landlords to the short-term lets market, which is less regulated and has fewer controls in place.

We need to build more social homes. Ultimately, as you will know, Minister, our argument remains that we need to retain fixed-term tenancies as an option. They give the landlord and the tenant a guarantee of the length of time they will be there and the rent that they will pay. Families renting with children near schools, as well as nurses who have placements, are coming to our agents saying that they want to know how long they are going to be in situ. As I say, we need to provide long-term tenancy options for those who want them and ensure that people do not go to the unregulated short-term lets market.

Q Can I challenge you on that point, because I have never understood it? Under the rolling, periodic tenancy system that we are introducing, a family that moves into a property can determine when they leave. As long as there is no antisocial behaviour, for example, they can decide when they leave, so they have all the advantages of a fixed-term tenancy. I am not picking up on this cry among tenants for fixed-term tenancies. Perhaps you can elaborate on where you are coming from on that point? What are the additional advantages that are not provided by this rolling, periodic system?

Timothy Douglas:

We have just been talking about the other side of the coin, which is investors.

No, not investors. You made a point about tenants.

Timothy Douglas:

Yes, but that is the crux of it. Unfortunately, if you push too far on the fixed-term tenancy option, the grounds are not robust enough for landlords. Unfortunately, they do not know how long the tenant is going to be in situ. They cannot plan their investment, and they do not know the return on their rent. It is a mutual agreement. We are not saying that it is one or the other. We are saying retain it as an option. Why are we legislating to reduce choice and flexibility?

Agents are telling me up and down the country that that is what tenants want. The leading letting agent in London, which manages 65,000 tenancies, says that fixed-term contracts are popular within the private-rented sector. Many tenants opted for tenancies between one and three years, with the average first term lasting 23 months. At the end of the initial term, 65% of tenants choose to renew. Only 1% of tenancies are ended early by landlords; 5% are ended by tenants. People know where they stand and where they are going to be. It is an option that should be included in the legislation. We have talked today about students as well. It would solve all the problems in the student market.

We are tinkering there with issues that just do not exist. Retain fixed-term tenancies for all, or at least within the student market, or extend ground 4A to one or more sharers. You are tying yourselves in knots in so many ways.

Q We covered extending the grounds to more than three sharers in the previous evidence session, and I think everyone knows where I stand on that. If you are right that the biggest effect of the move away from fixed-term tenancies is on investment into the build-to-rent, or corporate, sector that you are talking about, and if the Bill were to allow fixed-term tenancies—perhaps the first tenancy of a build-to-rent new build—would that help the sector up from delivering 15,000 units to 30,000 more units?

Timothy Douglas:

I was actually saying that fixed terms should be retained regardless of landlords.

Q In response to the Minister, you did also mention the corporate sector—but it does not matter. My point is, can you comment on retaining that fixed-term option for the first tenancy in new build premises? Would that deliver some of the incentives that you want to see?

Melanie Leech:

A minimum tenancy would certainly help with investor confidence.

Q Of what length?

Melanie Leech:

Ideally, we would want a year—perhaps six months.

On the impact, to answer the Minister’s point, it is not that families cannot stay for as long as they want to. This is a high-quality product—I am talking particularly about the build-to-rent sector. The risk for build-to-rent providers is that people will treat build to rent more like an Airbnb-type product. That could transform what should be rental products for families to move into for the long term. That is what we want—we want people to stay somewhere to make it their home. But this proposal will inhibit the supply of those products to long-term tenants, because we are vulnerable to short-term tenancies flipping all the time. That is the concern. It is not that people cannot stay for long if they want to; it is that those products will be easier for people to treat more like a short let—an Airbnb-style product.

Timothy Douglas:

We need build to rent, but let us not forget that in build to rent, on average, the rents are a lot higher, because people are paying for a concierge and the other services, so it is not the ultimate answer for all parts of the sector. We are not going to support everyone. I do not think that there should be a timeframe on the fixed term, but we can make use of grounds that landlords cannot use as levers, and you could put break clauses in as well.

My question goes back to the decent homes standard, and the first part of the question is potentially more for Suzannah. What insights do you have into the impact of the application of the decent homes standard in the social rented sector and then, potentially, on everyone else? How do you see it translating across to the private sector, in terms of the impact on the standard of homes thereQ ?

Suzannah Young:

We believe that everyone has the right to a warm, dry, safe, secure and affordable home, and social housing has a greater proportion of decent homes than housing of any other tenure. That could suggest that having a decent homes standard helps to bring up standards in housing. We also recognise that housing associations exist to fulfil a social purpose, and we are rightly held to a higher standard. We welcome the Government’s commitment to reviewing the decent homes standard. We are pleased to continue to work with the Ministry of Housing, Communities and Local Government as this develops.

In terms of some feedback for the private rented sector, we agree that it is important to have a clear, modern and meaningful standard that reflects what residents would expect a decent home to be. It is also important that all landlords should have a clear understanding of the condition of all their homes. In the social sector, we are doing work to develop a more consistent approach in that area, as part of our response to “The Better Social Housing Review”. It would need to be something that private landlords were able to do as well to bring up standards.

Specifically—this has been mentioned in terms of the private sector—it is important to recognise that the housing association sector faces multiple and competing pressures, with budgets that are already stretched. We would like to see investment in existing homes at the same time as development of the desperately needed new and affordable homes in the Government’s long-term housing strategy. I suggest that similar attention would be needed for the private sector.

Timothy Douglas:

May I pick up on that point? That argument was used in Scotland on the Cost of Living (Tenant Protection) (Scotland) Act 2022. I gave evidence on that legislation two or three times to the Committee up there. In the end, the argument was that the cap was lifted for the social rented sector because it needs to plan for its investment. That is the crux, and it goes back to my previous points—there is no parity here with the incentives, the business planning and the costs that private landlords are facing. We have to have that parity. If the legislation is extending across, the funding needs to be the same. We have to have parity in the investment, the caps and everything else—that needs to be the same. We need that review into all the taxes and costs impacting private landlords, because, quite frankly, we are not getting legislation from either Government Department—the Treasury or MHCLG—that understands the investor appetite for the private rented sector. This legislation is not helping.

Q This is a question mostly for Timothy. At the beginning of your contribution, you mentioned the unintended consequences we see from the Bill, and you gave the example of landlords departing the market. I know there is often the argument that they are still providing a home somewhere else if those properties get purchased. I am interested in the statistics you might have—representing both estate agents and landlords—on the impact on the housing market in full. How many properties stay in the private rented sector? Do they move from one landlord to another, or is that ultimately a property that is then lost permanently from the private rented sector?

Timothy Douglas:

It is difficult to say. We know anecdotally that if you are in an agent branch and a landlord wants to sell, the branch would try to push that property towards a bigger landlord who could perhaps take it on before it goes on to the open market. We know that that happens in order to retain property. Anecdotally, we know that, because of legislative uncertainty and costs of legislation, as well as the cost of living, which has also hit landlords with their costs, landlords have left the sector—I gave the example of the agent in the west midlands previously. However, it is difficult to ascertain hard data across the board. That could be another recommendation to the Government: to come back with an annual review to Parliament on the state of the private rented sector.

Suzannah Young:

May I come in on that?

We are going to have to go on to the next question, because we are running short of time. I call Michael Wheeler, who has been waiting.

Thank you, Sir Christopher. I appreciate that Suzannah was asking to come in, and my question is actually for her, so this might give her an opportunity to respond. It is a slightly broad question: what concerns might housing associations have around the Bill? Could any aspects of it be constructively improved to address those concernsQ ?

Suzannah Young:

Thank you for your question. As I said, we welcome the Bill, and we support the Government’s ambition to give greater rights and protections to people renting their homes, and to value the contributions made by responsible landlords who provide quality homes. We do think it is crucial that the details of the legislation do not have unintended consequences for housing associations and for people living in social housing. We would like to ensure that the changes do not impact housing associations’ ability to provide decent, safe, secure and affordable homes for people who need them most. It is clear that care has been taken in drafting the Bill to minimise the impacts on social housing and tenants of social housing, and we are grateful for the engagement on these issues from MHCLG so far.

However, there remain a few areas that we feel need ironing out to avoid impacting the ability of our housing association members to deliver housing in what is a challenging environment, while still keeping rents affordable. Those specifically relate to the changes to rent increases, with ground 1 being the rent to buy ground and ground 6 being the redevelopment ground. First, we would like to see the proposals around rent increases made clearer or changed to make absolutely certain that they retain social landlords’ ability to increase rent in a harmonised way, which is to avoid impacts on the supply of social housing and to ensure fair rent levels for neighbours and the ability to deliver repairs, maintenance and services to tenants. That is because, as I mentioned earlier, all rental income is reinvested into providing those services. So any loss of rent would have an impact on tenants who receive those services, and repairs and maintenance.

We would also like to see ground 1B extended to apply when the home is converted to another rental product, which is not currently in the ground. That would be in order to help housing associations to meet local housing need where there is no demand for rent to buy or purchase. We would like housing associations to have access to ground 6 in all cases, so that they can carry out essential works that are of benefit to tenants.

We will follow up with more detail in our written evidence, and we would be happy to meet any members of the Committee if they would like to discuss any of these points in more detail.

Thank you very much, and I thank all the panel for the evidence that they have provided to us. I am sorry that we do not have any discretion, but we now have to move on to the next panel.