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Keeping It Real Estate

News and Trends in UK Real Estate, Disputes and Planning Law

Posted in Real Estate News

Consumer disputes in the housing sector: a long-awaited reform

Consumer access to remedy has long been a neglected part of what many consider to be an already broken housing market. Housing disputes are heard in a number of different legal settings and the process is often convoluted and opaque. As a result, this vulnerable part of the real estate sector (private renters, social housing residents, leaseholders and buyers of new build homes) can face insurmountable barriers in bringing their cases to justice.  Following a White Paper on the topic in early 2017, and a consequential consultation, the Secretary of State for housing, communities and local government published his response to the issue at the end of last month.  The response sets out a number of proposals for reform.  Although a number of programmes are envisaged, the predominant feature consists of a single, accessible portal which will streamline disputes by referring complaints to the appropriate ombudsman, whilst maintaining the various specialisms needed in this area.

The government has highlighted three key sectors that will be impacted by the reform: the private rented sector; leasehold properties and new builds.

Compulsory membership and justice without courts

The government wants people to be able to access help in resolving housing complaints without needing to apply to the court system The government is going to introduce legislation which will require all private rented sector landlords, regardless of whether they employ a managing agent, to be part of a scheme for remedying complaints.  Notably, this includes all private providers of purpose-built student accommodation.  As for developers of new build homes, the government is also proposing to bring forward legislation that will require all developers of new build homes to belong to a New Homes Ombudsman.  These enhanced requirements for developers fulfil the government’s promise to “champion homebuyers” and protect their interests.  It is anticipated that failure to comply with the legislation will result in fines of up to £5,000.

Helping consumers find resolution

The obligation to belong to such a scheme only addresses part of the issue. What became clear during the consultation was that the multiplicity of schemes currently available is creating confusion, which deters people from actually bringing forward their complaint.  This is where the proposed Housing Complaints Resolution Service will come into its own: a new single access portal where help will be available in resolving complaints or disputes with their landlord, property agent or developer.  This service will be available for social housing residents, tenants and buyers of new build homes.

On-going consultation

A new Redress Reform Working Group will examine and critique the existing standards for dealing with housing disputes and publish voluntary guidance on how improvements can be made. Any particularly pertinent pieces of guidance can then be consolidated through legislation or regulation.  The ultimate goal is to produce a comprehensive “Code of Practice” which will cover the entire housing sector.  Expectations for how complaints are handled will be clarified and set out in a format that will be readily accessible for everyone.

With the proportion of households in the private rented sector having doubled over the last ten years, these reforms look to be timely. The aim is to speed up the rate at which cases are heard and to create a more accessible justice system for everyone.  It remains to be seen whether these new reforms will have the positive impact hoped for, or whether in practice this will be harder to achieve.

Posted in Real Estate News

Non-resident SDLT surcharge: adding 1% and more complexity

When the government announced in 2018 that foreign investors into the UK property market were to be targeted with an additional SDLT levy, we said that the devil would be in the detail. The consultation document published this week gives that detail. But just how devilish is it?

The government is going ahead with a 1% SDLT surcharge on top of the existing SDLT rates for non-UK residents purchasing residential property in England or Northern Ireland. Both freehold and leasehold interests will be caught but existing reliefs will generally apply as normal. Indeed, the distinct lack of specific reliefs from the new charge is straightforward (if likely to be unpopular). Mixed use schemes and purchases of 6 or more dwellings will at least continue to be treated as non-residential and therefore outside the scope of the surcharge.

Multiple Dwellings Relief will also be available. The government states that the minimum rate of 1% of the total amount paid will remain at the same level for those subject to the surcharge. This would appear to mean a minimum effective rate of 2% for non-residents benefitting from the relief once the surcharge is applied, although clarification of what is intended will be needed.

However, the surcharge looks set to add a further layer of complexity to the myriad of SDLT rules. In terms of calculating the amount due, adding 1 percentage point to the rate may sound simple. But once you factor in the surcharge, there will be (at least) 32 different permutations as to the rate of SDLT payable on a purchase of freehold residential property. The top rate of SDLT will become 16% for those within scope.

Given that it is branded a non-UK resident surcharge, you would be forgiven for thinking that it would not complicate things for a UK resident purchaser. Not so. The rules propose introducing either new or modified tests of residence for these purposes. (Ironically, using the existing tests was seen as too complicated.) An individual who is UK resident for income tax purposes could therefore still find themselves non-resident for SDLT purposes. Non-UK resident companies are in scope but closely held UK companies can also be caught if a non-UK resident could exercise control over them.

Even the government’s stated aim of helping to control house price inflation seems fraught with difficulty. Reliably predicting the impact of tax measures on house prices is notoriously difficult at the best of times. At least the rules are not coming in until a future Finance Bill (which year is not stated). Hopefully this will allow time for a bit of a re-think about the complexity of the SDLT rules for residential projects, which will only be made worse by this proposed charge.

The consultation can be accessed here


Posted in Planning

A beginners’ guide to affordable housing in London

It is estimated that the population of London will reach 10.8 million by 2041. According to the Mayor of London, around 43,500 affordable homes are required each year in order to meet London’s housing needs. Yet the issue as to how these homes will be delivered is one that remains controversial.

The provision of “genuinely affordable housing” was a key part of the Mayor’s election manifesto and plays a large part in the new London Plan which was issued in draft for consultation in December 2017.

The Examination in Public of the draft New London Plan is now taking place and is set to continue over the next five months. It came as no surprise that the drive to build more affordable housing was an overriding message in the opening remarks of the Deputy Mayor, Jules Pipe.

So, what does the draft Plan say about affordable homes in the Capital? Well, first of all, it says that half of all new homes should be affordable. However, a key part of the draft Plan is the implementation into policy of the threshold approach to viability assessment (Policy H6) which has been named the Fast Track Route.

What is the Fast Track Route? If a developer agrees to provide 35% or more affordable housing, it does not have to provide a viability assessment which usually means that it can secure a planning decision more quickly. This is because the lengthy periods of public and local authority scrutiny of the viability assessment are avoided. The type of affordable housing is also set so that: 30% of the affordable homes should be low cost housing; 30%  intermediate; and the remainder determined by the particular borough’s needs.

The Fast Track Route was first introduced in August 2017 in the Mayor’s affordable housing Supplementary Planning Guidance, so developers have had a while to get used to it. Despite initial uproar, it seems to be working quite well, with some developers appreciating the certainty that it brings to the planning process. However, the draft Plan states that a review of the threshold figure will be held in 2021 with a view to increasing this number, if deemed appropriate. So that’s something to watch out for.

The high cost of both land and labour and the imminent threat of Brexit mean that developing in the Capital is already risky, challenging and costly. In such a climate, the need for a smooth and quick planning system which provides certainty for developers is even more important.   Yes, many more affordable homes are needed, but with limited provision from the public sector, private developers need to be sufficiently incentivised if they are going to deliver the number of homes that the Mayor wants and London needs.

It will be interesting to see how this emotive and highly political issue is dealt with during the Examination in Public, and of course the Panel’s final report, which is expected in Summer 2019.

Posted in Real Estate News

The impact of drones on real estate

The use of unmanned aerial vehicles, more commonly known as drones, is increasing across the real estate sector, and for good reason. Drones have incredible safety and efficiency benefits for business. They are flexible and labour saving, and the ways in which drones are used across the real estate sector is increasing and seems likely to increase further. Organisations are already using drones to conduct external property inspections, at a cost far cheaper than any manual inspection regime. Drones are now being used for insurance valuations and heat seeking drones can be instrumental in ascertaining whether a building has damp. All of this information can then be shared digitally. It has even been suggested by trend analysts that drone inspections could replace physical property viewings entirely by 2025.

Of course all technology can be used for good and for bad, and drones are no different. Here in the UK, as the number of drones in the air continues to grow exponentially, lawmakers are grappling with drone safety and security concerns. At the same time, public awareness around the misuse of drone technology is growing. In recent months, we have seen a drone cause a main infrastructure bridge to close down and major airports brought to a standstill by the unlawful use of drone technology.

As a result, despite the clear technological and economic advantages to drone technology for the commercial market sector, we have seen some resistance to drone technology from members of the public and landowners. Coventry City Council has recently joined other councils and announced plans to implement a general ban on drones in parks and open spaces unless permission to fly a drone is sought and granted from the council. As landowners, councils are primarily concerned about the liabilities they could incur from any damage caused to people or property on council land and also from increases in trespass and nuisance incidents.

In response to recent drone incidents, the government has announced plans to extend the no-fly parameters around major infrastructure and to provide the police with greater powers to seize drones and fine their misuse. Currently however, the laws surrounding the interaction of drones and property remain untouched.

Article 95 of the Air Navigation Order states that drones cannot be flown within 50m of a person, vehicle or building “not under your control”. There is little guidance on the meaning of “not under your control” when it comes to airspace but the case of Bernstein of Leigh v Skyviews & General Ltd [1978] establishes that a landowner’s airspace extends to such height as is necessary to ensure the ordinary use and enjoyment of the land. However, drones flying closer than 50m to private property do not necessarily trigger claims of trespass, as demonstrated in Anchor Brewhouse Developments Ltd v Berkeley House (Docklands Developments) Ltd [1987]; there must be a degree of regularity and permanence to the infringement.

As drones become more popular and their uses evolve, it is clear that the law and drone technology need to develop, particularly as landowners are likely to want to embrace this new technology and take advantage of the unique opportunities and perspectives that drones present. We must strike the right balance between innovation and security in order to enable the many benefits of commercial drones, while preventing the bad.

Posted in Real Estate News

ACM Cladding: Where are we now?

On 21 December 2018 the government’s promised ban on the use of aluminium composite (ACM) cladding on residential buildings came into force. Paul Tonkin answers some key questions.

Does the ban apply to all buildings?

No, the ban applies to new buildings over 18 metres tall containing flats, as well as new hospitals, residential care premises, dormitories in boarding schools and student accommodation over 18 metres.

What about buildings under construction?

The ban will not apply where building working started before or within 2 months after 21 December 2018.

What is the effect of the ban?

The regulations prohibit the use of combustible materials on the external walls of new buildings. Any materials which form part of external walls and attachments such as balconies or sun-shades must achieve the requirements of European Classification A2-s1, d0 or A1 (classified in accordance with BS EN 13501-1:2007+A1:2009 entitled “Fire classification of construction products and building elements”). There are limited exceptions – for example for windows and doors.

What about existing buildings?

The ban does not apply retrospectively to existing buildings. However, the government has made clear that it expects the owners of privately owned buildings to replace ACM cladding without passing the costs on to flat owners. The government has identified 289 privately owned residential high-rise buildings containing combustible cladding panels and has introduced new powers for local authorities to remove cladding on privately owned buildings and to recover the costs from the owners. Whilst the government has said that costs should not be passed on to flat owners, this is not currently legally binding and the position will be governed by the terms of the leases. There have already been cases in which the First Tier Tribunal has held that flat owners were responsible for the costs of replacement cladding and associated fire safety measures. That said, a number of building owners have publicly committed to funding the works themselves and not passing the costs on to flat owners.

Hogan Lovells has a team of real estate, construction and regulatory lawyers ready to advise on these complex and fast-moving issues. Should you require further information please contact Paul Tonkin or your usual Hogan Lovells contact.

Posted in Real Estate News

Can tolerances be intolerable? What happens when a building is built the wrong size?

It’s commonplace for the floor area of a proposed development to be set subject to certain agreed tolerances. These provide an amount of flexibility to a developer and are usually set out in the development agreement. But what happens if these tolerances are not met? You might think that this should entitle the parties to bring the agreement to an end. Interestingly, the High Court recently decided not, in Mears Limited v. Costplan Services (South East) Limited, Plymouth (Notte Street) Limited and J.R. Pickstock Limited.

The case concerned the development of two blocks of student accommodation which Mears (the tenant) intended to manage following construction. Mears entered into an agreement for lease with Plymouth (the landlord) which required Mears to take a lease of the blocks following practical completion. The agreement for lease specified that Plymouth could not vary the development so as to make any “distinct area” more than 3 per cent smaller than the size set out in the agreement. It transpired that many of the rooms within each block were in excess of 3 per cent smaller. Mears sought declarations from the High Court including: that any breach of the agreed tolerances enabled Mears to terminate the agreement for lease.

In effect, Mears’ argument was that any breach of the agreed tolerances was, by its very nature, sufficiently material to enable Mears to wipe its hands of the transaction.

The High Court held that each room within the development was a “distinct area” for the purpose of applying the tolerances. The Court then made an important distinction between the materiality of the variation in the size of a room and the materiality of the resulting breach of contract. The former is purely a case of arithmetic whereas the latter requires an appreciation of the context of the development – how important is the breach to the property in question? For example, even if a room was 5 per cent smaller than stated in the agreement for lease and, despite this, could still be let at a similar rent, it would be unlikely that the resulting breach of contract would be sufficiently serious so as to enable Mears to terminate the agreement. This was so even though the breach in this case was irremediable (the rooms could not be altered to make them any bigger).

The Court refused to make the declaration requested by Mears. It held that a breach of the tolerances did not always equate to a breach sufficiently serious to permit Mears to terminate. However, notably, the Court refused to address the question of whether the extent of the actual breach in this case was sufficiently serious to enable Mears to terminate. This was because it was not necessary to answer that question in order to decide whether or not to grant the declaration.

This case emphasises the importance of being clear as to the consequences of particular breaches of contract. If either party is intended to have a right to terminate for a breach, then this should be expressly stated so as to avoid the lottery of the courts. Claimants may have other avenues for redress (including claims for damages against the professional team engaged in procuring the development) but they may not be attractive – particularly given the risk of contractor insolvency and the application of extensive exclusions of liability. As always, the best policy when it comes to drafting remains that if there is any doubt, it is prudent to spell it out.

Posted in Real Estate News

Service Charge – RICS code gets new teeth

As 2019 begins, the property sector is gearing up for the introduction of the new RICS professional statement, which will supersede the current code of practice from 1 April 2019. The statement cannot override the terms of a lease but, as long as it is read in conjunction with the lease, the statement will guide the practical implementation of service charge provisions in the lease to ensure services are managed properly.

The key change from the current regime is the inclusion of nine mandatory obligations for RICS members and regulated firms (i.e. firms that have chosen to be regulated by the RICS and agree to work to its standards). The professional statement also identifies best practices. Whilst not mandatory, the RICS warns that it may seek justification from members who depart from best practice.

The professional statement calls out both managers and owners who display a lack of transparency in their service charge procedures and consultants engaged by occupiers to pick over the detail of service charges, a practice which can encourage tenants to withhold disproportionate amounts of payments for disputes. Instead managers, owners and occupiers alike should, the statement says, look to behave in a way that reduces the likelihood of a dispute arising.

The professional statement also recognises the confusion surrounding terms such as sinking funds, reserve funds and depreciation charges and sets out definitions for them.

And it suggests a new set of exclusions for service charge costs, including:

  • capital costs for the building;
  • improvement costs beyond normal maintenance, repair or replacement, though “enhancement of fabric, plant or equipment” can be justified following a review of options and a cost benefit analysis;
  • future redevelopment costs; and
  • costs relating to the owner’s own investment interest or void premises.

Another new section discusses the Minimum Energy Efficiency Standards. Environmentally conscious Landlords will be encouraged to see the RICS note that, subject to the terms of the lease and the rest of the professional statement, “any subsequent costs of improving energy efficiency might comprise a legitimate service charge item as long as there is a proportionate cost benefit to tenants”.

The changes to the current regime made in the professional statement add more clarification, consistency and accountability to the service charge procedure. The professional statement comments that it is likely a judge or equivalent would take into account the requirements under the professional statement during any legal proceedings. Landlords, occupiers and professionals alike should consider how the changes to the current scheme should influence their current practices.

You can read the professional statement in full by clicking here.

Posted in Real Estate News

What’s ahead in 2019?

New real estate disputes partner Paul Tonkin shares some predictions for 2019.

Crystal-ball gazing is always a dangerous business and this is more so than ever in the current global economic and political climate. However, there are a few areas where I can predict with some certainty (and for better or worse) that we will see change in 2019.

Further pressure in the retail and casual dining sector

This one will come as no surprise. Even before 2019 got truly underway, we saw the news of HMV’s (second) administration as the effects of a sluggish Christmas trade compounded what was already a difficult year. 2018 was the year of the CVA with retailers and restaurant groups using CVAs to rationalise their portfolios and reduce lease liabilities. Unless the tide is stemmed, or at least controlled, then we could see a more seismic shift in the fundamentals which underpin the retail investment market. Put simply, how can underlying investment value be assessed where tenants can use CVAs to re-write their lease liabilities? The Hogan Lovells real estate disputes team is acting on a challenge to one of the major CVAs of 2018 and I, for one, hope that this will provide much needed clarity for both landlords and tenants.

A recalibration of residential

The government has committed to tackling the housing shortage and has put forward various measures to achieve this, including changes to the planning system and the removal of red tape around local authority housing development. At the same time, the government has proposed widespread changes to the use of leaseholds in the residential sector, the most significant being a proposed ban on new leasehold houses and a £10 per annum cap on ground rents for leasehold flats. The changes are a reaction to the perceived scandal of consumers being caught out by unfair ground rents. But do they go too far? A blanket ban on leasehold houses may seem like a simple solution but it ignores the fact that many urban regeneration schemes, carried out jointly by local authorities and private developers, rely upon complex leasehold structures. An outright ban on leasehold houses will require a fundamental rethinking of these structures. Similarly, the effective abolition of ground rents ignores the fact that ground rent income (and particularly the ability to sell that income stream) is often a significant line in a developer’s financial appraisal. Removing this will place further pressure on viability which will result in developers finding it even more of a challenge to meet already ambitious affordable housing targets. If the effect of the ban is ultimately to reduce affordable housing allocations, this will be an own goal. My prediction (or hope) for 2019 is that the government takes seriously the industry’s concerns over these proposals and considers whether a sledgehammer really is needed to crack this particular nut.

Flexible working vs flexible leasing

We’re all very familiar with the growth in the flexible business space sector. As uncertainty continues to deter tenants from signing up to long-term lease commitments we will, I’m sure, continue to see more and more landlords rolling out their own flexible working products. However, even within the traditional office leasing model, flexible working cannot be ignored. Collaborative working and co-working arrangements will continue to grow and in that context the traditional lease restrictions on sharing of occupation will become increasingly outmoded. To thrive, landlords will need to embrace flexible working and flexible leasing as an opportunity rather than seeing it as a threat.

Congratulations to Paul Tonkin who was promoted to partner effective 1 January 2019.

Posted in Planning, Real Estate News

Ten Takeaways from The Student Accommodation Conference 2018

It was great to see lots of familiar faces at Property Week’s 2018 Student Accommodation Conference. There was a packed agenda with four different “streams” to choose from – and smart tech talks in the coffee breaks. So what did I learn? Here are my top ten nuggets of information:

  1. The success of the Student Accommodation industry depends on the success of our universities and colleges – Austerity measures; increased competition from abroad and problems attracting and retaining the best talent are all issues which threaten the excellent reputation that British institutions have worked so hard to establish.
  2. UK student debt is at £100 billion and rising – Tuition fees have increased by 721% since 1994, significantly higher than inflation. The Government’s Augar Review is, amongst other things, looking at how to reduce the cost of higher education. Some predict that one of the outcomes will be increased fees for science subjects because science graduates are more likely to repay the debt. Whilst a reduction in fees for non-science subjects would be welcomed, there are fears that these measures may result in fewer science graduates, contaminating the UK skills supply, and may create social mobility issues as students choose cheaper courses.
  3. The Brexit threat is a real one – Interestingly, it was not the threat to undergraduate numbers that the speakers were most concerned about this year, but the postgraduate, particularly PhD, numbers. This has a knock on effect in terms of quality of provision, research and reputation if universities start to lose their PhD students. Competing institutions in countries like Australia and Canada are waiting in the wings, or rather, are on active marketing campaigns…
  4. Keep an eye on the horizon – A longer term vision is needed to weather the storm. The industry needs to keep an eye on institutions in the emerging markets such as China and India, and on the changing higher education culture: shorter degree courses; multi-careers; and the rise in online courses, to name a few.
  5. “Build the best Ford Mondeo style product” – Probably my favourite quote from the conference by Stewart Moore of CRM Students. His point was that trendy pilates studios only get you so far – there is a natural rent saturation level. Providing a good quality product at a good price increases your chances of success, especially in the current climate.
  6. Location, location, location – Being as close to the institution as possible is key. HMO operators also agreed with this. The only exception conceded was London where locating out of centre (but as close to a fast tube line as possible), can reduce rents significantly. This is particularly true in the “affordability” crisis, which was another conference buzz-word this year.
  7. The draft London Plan is worrying developers – The requirement for at least 35% affordable housing provision on top of the other expected developer contributions has set hares running. What’s more the need for a nominations agreement covering the majority of beds before first occupation and throughout the life of the development is a cause for concern for some operators. The Leaders of Redbridge Council and the London Borough of Barking and Dagenham were confident that the draft Plan’s requirements are workable but said that aspirational boroughs will need to reach out to developers and work together to make it happen.
  8. The tech doesn’t have to be swanky – Yes wifi is as important as a bed, but reliability, not speed of service, is crucial. The student panel all agreed that “fancy apps” that are not user-friendly were pointless and frustrating. They wanted technology to enhance and enable human interaction, not replace it. This was a general theme across the conference which also considered mental health issues and solutions.
  9. The days of campus education are not numbered (yet) – The rise in online courses and the cost-saving of staying at home to study have not brought down campus education yet. Going away to study is still very much part of UK culture. Roughly 25% of students are “commuter students” and apparently this proportion has not changed dramatically in the last ten years. That said, some of the panellists were cautious and said that the outcome of the Augar Review may threaten this further.
  10. Only one of the five fastest growing universities in the UK is from the Russell Group – I was both surprised and concerned by this. One of the main reasons that the non-Russell Group universities are doing better is their focus on student employability. Some newer universities are offering industry-led initiatives which connect students with employers and ensure better preparation for working life. Student experience rankings are also significant. As students are now paying directly for their education, they expect value for money and want to ensure their voices are heard. Who can blame them?
Posted in Real Estate News

Proposed new access rights for Code operators

The government is currently consulting on proposed changes to the UK Electronic Communications Code (the “Code“), to make it easier for Code operators to access premises to install digital infrastructure enabling full fibre, gigabit-capable connections for the benefit of tenants. The consultation closes on 21 December 2018 and a link to the consultation can be found here.

Why is the government consulting?

While the UK has good superfast connectivity, “full fibre” network coverage is only available to around 5% of premises, compared with close to 100% in South Korea, for example. The consultation and proposed changes are part of a move to make the UK a hub for digital business.

The consultation follows the Future Telecoms Infrastructure Review, published in July 2018, which set out strategic priorities to deliver nationwide coverage of “gigabit-capable” broadband by 2033. One of the key barriers identified by Code operators was that some landlords are overseas or unidentifiable and do not engage with requests for entry to install digital infrastructure.

Currently, a Code operator needs formal permission from a landowner in order to enter premises and install digital infrastructure. The consultation reports that requests for entry go unanswered in up to 40% of cases. Code operators can apply to the Lands Chamber of the Upper Tribunal for permission to enter premises, but rarely use this route because of the time and expense required.

What is the government proposing?

The proposed changes aim at giving Code operators certainty and incentivising re-engagement by unresponsive landlords. The government proposes amending the Code so that landlords are obliged to facilitate installation of digital infrastructure on their premises where a tenant makes a request for service and an operator gives the landlord suitable notice.

The consultation also proposes allowing operators to seek a warrant of entry via a magistrates’ court. This reduces the period of time taken and the cost to obtain permission where a landlord does not respond. The existing right for operators to go to the Upper Tribunal will be reserved for cases which require the specialist knowledge of the Tribunal.

The proposed amendments are not intended to be alternatives to formal access arrangements. Once a landlord engages with the operator and negotiates an agreement, the temporary measures will fall away.

What does this mean for landlords?

It means that Code operators will be able to install digital infrastructure in premises without the need to obtain specific consent. This raises a number of concerns for landlords:

(a) Risers in buildings could become full of redundant cabling.  Whilst the Code contains provisions for the removal of apparatus, it is a “one size fits all” piece of legislation and does not specifically cater for wayleave agreements.  Wayleaves can be temporary in nature as the apparatus is usually only installed for the period that the tenant requesting the service is actually in occupation of the premises.  The issue could be exacerbated if operators could just install additional equipment.
(b) There could be complex property ownership structures which mean that the relevant landlord may not be easily ascertainable. This could mean that a landlord is not “absent and not engaging” but simply has not been notified.
(c) The landlord may need to juggle conflicting third party ownership rights over a property before granting access.  These competing rights should be taken into account if an operator applies for an access order.
(d) Although the proposed amendments are intended to be temporary measures, once an operator has access and has installed the equipment, what incentive will there be for  a Code operator to enter into a written agreement?

If the government’s proposals become law, landlords and agents will need to streamline their processes to ensure that requests for installation and upgrades of telecoms equipment do not go unanswered.  Not to do so could result in some surprise visitors.