pets survey | queries + response

In response to the CoL Pets Survey (see previous update) and after many communications from concerned residents GLERA, wrote to Liam Gillespie, Head of Housing Management on 18 September. On the same day we received a response from the Resident Involvement Officer shown below in orange italics

The initial deadline to respond was 22 September, but has since been extended to 7 October.

18 September 2024

Dear Liam

In response to your letter, booklet and survey the Golden Lane Estate Residents Association would like to raise the following observations and questions about the CoL Pet Policy survey consultation. 

The survey
The survey was titled pets policy but there was just one question on this with a closed yes or no answer. The remaining questions were about tenancy, however there was no breakdown between CoL tenant and leaseholders sub tenant. 

• As the survey was posted and emailed were nonresident leaseholders included?
  The survey was sent to the contact details leaseholders have given us and that are on their file, including email addresses. 
• How have you ensured there is only one response per household? Are responses from resident sub tenants or nonresident leaseholders counted?
  Each address has a unique code and response attached to it, so only one result can be submitted via Acuity’s survey management system. When an address submits a response, that address is closed and no further response for that address can be submitted.
• What is the total number of households surveyed? Is 500 an adequate response?
  500 responses is the minimum we are aiming for with the aim of statistical certainty, as advised by Acuity and in line with the Housing Regulator’s guidance. The survey was sent to all of our occupied properties, so approximately 2750.
• At what level do you consider an agreement to change the policy 51%, 60%, 75%?
  This depends on the closeness of the result, but we are following the guidance provided by the Housing Regulator and Acuity in order to achieve statistical certainty of the result. In essence, the closer the result, the more responses we require to achieve statistical certainty.  If the result is to change the policy, then we will draft and consult on the new policy in the usual way, and ultimately the decision of whether to approve the policy or not will lie with the elected Members responsible.
• There is no indication of an end date. Does this mean that when you reach 500 +1 responses you will close the survey?
  No, there is no suggestion of this. We are aiming for as many responses as possible. We have already received well over our minimum target of 500.
• Can you confirm when and how the survey will be closed?
  We have a working date of October 7^th by which we hope to have achieved a result with statistical certainty. This was the route suggested by Acuity, however due to Members raising the question of a deadline, we have now agreed with Acuity to send an additional mailout to those who have not yet returned their survey with this date and will update our internal communications to match this.

There is lack of clarity about the voting system ie we assume because of the unique number there is only one vote per household but that is not made clear and many residents are worried that duplicate votes can be submitted. This is not an issue that residents take lightly and the CoL need to be more responsible in how it explains how the survey works. Can you confirm that duplicate voting is not possible?
I can confirm duplicate voting is not possible. The information booklet states in the ‘How Will This Vote Work?’ section that it is ‘one vote per household’.

We expect to see the survey response broken down by estate and tenancy.
I will enquire with Acuity as to whether this is possible.

One policy for all CoL estates
We disagree with your proposal for a one size fits all policy. The range of CoL estates vary greatly in location from suburban to inner city with very different accessibility to open space. The spread of home types varies from individual houses to small studios with a range of densities. We believe that a one size fits all policy is wrong and the individual estates should choose. It is clear from the 2020 survey that the response was split along estate lines:

‘We have surveyed residents on our Pets Policy on several occasions previously. On the last occasion in late 2020, 49% of residents said “no” to dog ownership, 45% said “yes” and 6% said “don’t know”. However, on some estates, a majority supported dog ownership; on others, most people did not support it.’
https://www.cityoflondon.gov.uk/services/housing/resident-involvement/pets-policy-consultation

It is not fair to those who want pets on an estate where the majority vote for them to be disallowed because the overall majority is against any more than it is to impose pets on estates where the majority of residents do not want them or feel that they are inappropriate for the location.

The issue of mobility is overstated. Tenants move by request and allocation, if they have pet requirements these can be accommodated in a policy where it is clear that not all properties are suitable for pets because of size or location. If tenants choose to move through swapping they are free to do that within the specific estate policy.  Emergency moves can, if necessary, be dealt with by exception as they currently are.

Having a pet policy with different rules for dogs on named estates would be consistent with the majority of residents wishes and easy to amend in future. It is the management of those policies that also needs consistency.

As laid out in the information booklet, we understand some residents wished for there to be different policies across the different estates, but explained how and why this was not possible. Some estates may have larger green spaces than others for example, but when tenants are allocated social housing through the City or via their own local authority who may end up living on a City estate outside the Square Mile, these things are not taken into consideration. It therefore wouldn’t be fair if two people with equal need for housing, and the same desire to have a dog, had different policies because they’d been allocated the same size property on different housing estates. To do so otherwise would open us up to be challenged. It’s worth stating that all of our policies, not just this Pets Policy, operate in this way.

Management

• Dog register: this must be subject to annual review and open for all residents on the estate to see.
• Dog size and breed: this is woolly and relies on the judgement of individual officers – a mongrel/rescue puppy may be small but grow into a large dog. How large is a large dog?

Responsible dog ownership
CoL has a poor record of enforcement, in fact many of the conditions of the current leases are ignored and not enforced, non resident dog owners use our open spaces to toilet their dogs despite signs banning dogs. We have little faith in the ability to administer and enforce this policy.

As with management the definitions are woolly and would need to be specific to enable enforcement.

Impact on Service Charges
We believe your “small cost” is unrealistic.

• Addition cost for administration
  To be properly administered ie annual checks on vaccinations, record keeping, vigilance and enforcement, we consider there will be additional work. We are aware that you fail to administer sub tenancy’s register for which you charge – a free service to administer pets policy will add additional cost to all leaseholders. How will it be reclaimed from tenants?
• Considerable extra work for staff if dog poo waste bins installed due to misuse and the need to sort waste.
  Waste bins have been removed from our estate due to the amount of waste dumped in them. Any dog poo waste bins will be misused for general waste and will require staff to separate before disposal. This will mean considerably more (unpleasant) work.

If the change in policy is agreed, have you considered charging a fee to register a dog, and an annual renewal fee that would cover staff costs?

A number of these points in the above 3 sections are comments on a potential future policy, which I will note and include when we do further consultation on the details of the actual policy, should the vote be in favour of allowing dogs. I will pass GLERA’s comments on to the Housing Management team who will draft the new policy. We have provided the information to residents to the best of our knowledge at this stage, however as stated in the information booklet, any future pets policy will remain under review, as with all our policies.

Leaseholders
It is our understanding that any change in the lease terms have to be agreed by referendum of all leaseholders. We do not believe that you can make changes like this to the lease without a large majority of all leaseholders agreeing. There is no clarity if this survey was sent to all leaseholders or residents only. 

In the legal advice provided in the information booklet, we hope it is clear that this is simply an indicative question to see if there is appetite for these changes, and that if we were to make the changes, further communication would follow in due course. This survey is not what will be used. This was the method suggested by the City of London legal advice we instructed to support the leaseholder implication questions from the consultation sessions.

Context
Can you please send further details of consultation to date including:

• Number of residents attending on line (by estate) 22
• Number of residents attending in person events at each individual estate consultation (by estate) 62
  In their report on the consultation, Calm Mediation did not provide this information broken down into estates. I will enquire as to whether they have that information.
• A breakdown of leaseholders and tenants and sub tenants (by estate)
  Calm have also not provided this information in their report. As above I will see if they have it.
• Number of households in each individual estate
  The number of properties on each estate is available on our website here. Housing Estates – City of London
• The number of survey invitations sent out 2742

I look forward to you reply

Kind regards

Sue Pearson

Chair, Golden Lane Estate Residents Association