Housing in Multiple Occupancy (HMO) is an important shared housing solution for a diverse group of people in urban areas. HMOs are poorly understood by policies governing energy efficiency and fuel poverty, due to methodological problems of energy efficiency assessment, a deep-seated lack of representation and recognition of HMOs in general, and the societal marginalisation and stigmatisation of this type of housing. People in HMOs (e.g. new migrants, asylum seekers, students, young people) typically have reduced housing and welfare rights, whereas the buildings are extremely energy inefficient. Yet, HMOs have been substantially excluded from the UK government’s proposed minimum energy efficiency standard for the private rented sector. There is no definition of fuel poverty that applies if rent is inclusive of energy costs, the bills are shared, or where rental agreements are nonexistent or illegal; these are everyday occurrences in HMOs. There is a substantial coming together of socio-political and material issues giving rise to higher energy vulnerability in HMOs than in traditional single-family homes. This article focuses on the dynamic between UK policy mechanisms and regulations, and energy vulnerability in HMOs. An indicative typology of HMOs is proposed with the aim to provide a basis for the recognition and inclusion of HMOs in legal and policy frameworks.

1. HMOs – a problem that policy
forgot
Dr Jenni Cauvain
jenni.cauvain@nottingham.ac.uk
With acknowledgements to Stefan Bouzarovski, Future
Climate and eaga charitable trust
14 May 2015, Manchester

2. 1. What is Housing in Multiple Occupancy?
2. What is the problem?
3. How could we plan a progressive response?

3. “From respectability to invisibility”

4. Multiple definitions for multiple
occupancy
• The Housing Act 2004 (1985)
– Private rented properties occupied by three or more
people who make up at least two households and who
share some facilities (s254);
• Town and Country Planning (Use Classes) Order 1987
(amended) ‘Use class’ C4 if 3-6 unrelated people share
facilities
• Council tax regulations: HMO landlords (rather than
occupiers) are liable to pay the tax if two or more
people in separate households are sharing
• ‘Beds in sheds’ (e.g. attics, shipping containers and
garden sheds, and rooms which are let out in shifts)

5. HMO typology
• Individual rooms in a shared house/flat
(several tenancy contracts)
• Group of sharers (one tenancy contract)
• Bedsits (non-self contained flats)
• Poorly converted flats (self contained)
• Informal/ illegal
(Viitanen and Weatherall 2014)

6. Energy payment
Utility contract holder
Example heating system
Building typology
Assessment method
Pathway to enforcement/ improvement
“Rooms in
a shared
house”
“Group of
sharers”
“Bedsits” “Poorly
converted
flats”
“Illegal/
informal”

7. 1 “Illegal/informal” 2 “Rooms in a
shared house”
3 “Group of
sharers”
4 “Bedsits” 5 “Poorly
converted flats”
Shared
housing
scenario
Informal house/ flat/ room
share, tenancy agreements
informal, absent, or illegal
Formal house/ flat share
(individual tenancies)
Formal house/ flat
share (tenants jointly
and severally liable)
Bedsits or other non-fully self-
contained dwelling units (
individual tenancies). May be
hostel/ B&B.
Section 257 HMO: self-
contained, converted
building non-compliant
with building regs
(individual tenancies)
Energy
payment
Paid pro
rata by
tenants
Inc in rent Theft
of
elec.
Paid pro rata by
tenants
Inc in rent Paid pro
rata by
tenants
Inc in rent Individual
meter
Inc in rent Paid to
landlord
separately
from rent
Individual
meter
Included in
rent
Utility
contract
holder
Tenant Landlord n/a Tenant Landlord Tenant Landlord Tenant Landlord Landlord Tenant Landlord
Example
Heating
system
Portable electric room heaters Gas central heating Gas central heating Electric storage heaters in each unit Various
Building
typology
Very varied - non-domestic or
domestic properties used as
shared accommodation.
Unconverted, self-contained
property with tenants each
renting a room
Unconverted, self-
contained property with
tenants renting a house
or a flat as a group.
House converted into partially self
contained units (ie with mini-kitchen
and/or bathroom) sharing some
facilities or otherwise not fully self-
contained (eg toilet on separate floor).
House converted into fully
self-contained units.
Assessment
method*
SAP/SBEM SAP SAP SBEM SAP
Pathway to
enforcement
/
improvemen
t, EPCs
Very challenging. Potentially
environmental health officers/
use other frameworks (e.g.
council tax, overcrowding) to
deal with compliance.
Potentially at the point of
rental – but EPC not currently
required. Letting agents could
be key, also landlord
accreditation. Tenant
awareness/ behaviour change
has potential.
At the point of rental,
EPC is required. Letting
agents/ could be key,
also landlord
accreditation. Tenant
awareness/ behaviour
change has potential.
Potentially through local authority or
government agencies referral and/ or
HMO licensing (locally agreed
standards). EPC not currently required
at the point of rental.
At the point of rental, EPC
required. Letting agents
key, but usually poor
quality housing and
expensive to retrofit.
Indication of
numbers in
this group**
By definition, hard to say.
Ealing estimates 60000
residents affected in their
borough; Slough between
3,000 and 6,000 properties
Census: 0.5% full-time student households, plus 3%
‘other’ multi-person households in England. The
2010/2011 English Housing Survey identifies only 1.1%
of homes shared by 2 or more families or more than 3
lone individuals.
Census estimates 0.1% of properties
are bedsits. Non-fully self contained
flats may be an additional group
currently not recognised in official
statistics.
4.3% of dwellings are in
converted properties, but
very far from all will be
non-compliant with
modern building regs.

10. 1. What is Housing in Multiple Occupancy?
2. What is the problem?
3. How could we plan a progressive response?

11. HMO demographies
• Students
• Young people
• Recent migrants
• Asylum seekers
• Prison and care leavers
• Homeless
→ (often vulnerable) people with fewer housing and welfare
rights than those in single family accommodation
→ the Welfare Reform creates more demand for HMOs “race
to the bottom”
→ A problem of justice

12. Out of sight, out of mind
• Under-representation in official systems and
statistics depicting mainstream population
and housing stock
– Census (Simpson and Middleton 1997)
– English Housing Survey
– CLG HMO database
• Informality and incentives to stay under the
radar (e.g. Layard 2012)

13. What does this mean for energy
vulnerability?
People in HMOs aren’t in control of their energy
services to the same extent as those in single
family housing.
Research and policy on fuel poverty and energy
efficiency have overlooked HMOs.

14. (Deliberate) omission of HMOs from
fuel poverty and energy efficiency
frameworks
• The Energy Act 2011: PRS minimum standards
• Energy Performance Certificates
• Fuel poverty definition (10% or ‘low
income/high energy cost’ as per Hills)
• HMO licensing and Housing Health and Safety
Rating System (HHSRS)
• Green Deal/ ECO

15. The evidence suggests
• Very poor condition of the HMO housing stock
• Marginal status of HMOs and the residents who
‘fall through the cracks’ of policy and regulation
• Lack of clarity how key energy and fuel poverty
measures and metrics ought to be applied
• Concerted policy effort to identify and improve
the HMO housing stock is needed – instead, we
have various loopholes

16. 1. What is Housing in Multiple Occupancy?
2. What is the problem?
3. How could we plan a progressive response?

17. Cultural route:
Acknowledge and
accept HMOs as part
of the ‘normal’
housing mix
Regulatory route:
Close regulatory
loopholes around
energy standards
in HMOs
Welfare route:
Improve HMO
tenants’ rights

18. Government should aim to achieve a
widespread “EPC D” standard for HMOs
(amendment to the Energy Act 2011):
• EPCs to be issued to HMO tenants at point of letting;
• Official guidance around the methodology to be used
in undertaking energy assessments in HMOs;
• Both DECC and CLG should support local authorities
with better resources and data;
• A private rented sector “ringfence” within the ECO
programme (+monitoring of take-up)

19. Local Authorities’ licensing and HHSRS
responses:
• Consider additional licensing programmes in areas
where there are concentrations of fuel poverty and
very energy inefficient HMOs;
• Introduce minimum EPC “D” standard (alongside a
requirement for EPCs) as a condition of HMO licensing;
• Take more robust action in requiring insulation and
lower cost heating systems in HMOs identified as an
excess cold risk in housing health and safety
inspections;
• Other (referring) agencies: more active interest in
minimum energy standards, education/ awareness

20. Literature
• Groth, Paul. Living Downtown: The History of
Residential Hotels in the United States. University
of California Press, 1999.
• Layard, A. (2012) Law and localism: the case of
multiple occupancy housing. Legal Studies 32,
551–576
• Simpson, S. and E. Middleton (1997) Who is
Missed by a National Census?: A Review of
Empirical Results from Australia, Britain, Canada
and the USA.