Notes on 2025 GR Handbook
The following markups [viz comments] have been made.
Page 1: Marked up by Eur Ing Richard Townsend-Rose MA CEng MICE on 19th May 2025
Page 4: Remove Cheong as Director
Page 5: Car Parking, First Bullet: Except of course for Charalambous' boyfriend's van ! £70,000 dues in £50 charges since 2000.
Page 5: CCTV: NOT in the lease nor the law GDPR Regulations do not cover doorbells or CCTV Front Doors belong to the lessees as do the windows.
Page 6: Doors knobs etc: Original doors are FD30 compliant. Only those supplied by Charalambous as agent for Sun Trade Windows are not compliant
Page 6: Business's: Charalambous uses her flat as a business premises for interior design. Planning permission is required
Page 7: Entry Phone: The door entry phone system was not approved by lessees under the Landlord & Tenant Act
Page 8: Insurance: It is probable that the declaration made is false . . . less than 10% of the walls and roof must be non-flammable. [Have asked Grace Miller to calculate %. Walls and Roof only - no doors or windows] [Do NOT Forget end walls, water tanks, and stairway]
Page 9: Refurbishment: If the scope of refurbishment requires planning permission, then a Licence to Alter is required. Routine Repair & Renewal does NOT.
Noted that several ground floor lessees purchased "garden doors" via Charalambous which explicitly require planning permission, which was NOT obtained.
Page 10: Window [Cleaning] The lease says monthly, so Charalambous has arranged it on a quarterly basis
Page 12: Fire: The Board of KML have ignored and continue to ignore the instruction by London Fire Brigade to make safe the protected fire routes which Charalambous, Daffy, Taul and Lawrence made dangerous by erecting cladding in 2017 without planning permission let alone consent of the lessees under the landlord & Tenant Act
Page 13: Alterations: See note on page 9
Page 14: Costs of Licence: This is not in the lease and so is unlawful. [Comes in the category "I can so I will"]
Page 17: CCTV: See previous note on page 5.
From 1st April 2025
PLEASE use landscape mode on a mobile phone, or much better use a pc.
If you wish to view the correspondence etc then please email the
Conference - Rendal & Rittner
There are two parts to this article: First is the introduction that might have been about the speaker [Richard Townsend-Rose], and second a summary of the points he might have raised:
The Introduction
You might ask if Richard is competent to conduct an investigation? And secondly is he competent to document the findings of his investigations ?
He is a Chartered Engineer and has been for some 50 years. He also bears the title “European Ingenieur” [Eur. Ing. for short]. He has worked in Africa, Europe, India, and the Far East.
At one time, Richard belonged to the Chartered Institute of Arbitrators by sitting the entrance examination. However after a few years his career path changed and he resigned.
Regarding his competence, Richard has considerable experience in matters of contract and in making contract claims on major projects, which after all are only disputes. He is an expert on document control where many failures occur and developed TDOC - a software product to manage the problem - so he knows about record keeping.
Richard is Treasurer of Accountability Scotland and has been since its inception. He runs its web site [AccountabilityScotland.org.uk], and assisted the late Secretary in publishing scholarly articles on what might be termed the Failings in Administrative Justice in Scotland. Richard also runs a web site called UnaccountableScotland.org.uk that reports on matters involving members of Accountability Scotland in taking action.
His latest web site PropertyRegulation.org.uk deals with Cladding and Regulation etc etc on one small estate in Putney, where a friend [as a lessee] owns a flat.
For more on Townsend-Rose see:
- https://tdocplus.co.uk/01_ROPA/index.php/the-report#appendix-three-the-author and
- https://www.rgtr.tdocplus.co.uk/
The summary
The typical situation [in a block of flats]
It is to be expected that lessees become unhappy with a multitude of things about the management, and the service charges, and what needs to be done.
Firstly, the single most important thing, which cannot be stressed enough: get a group of like minded lessees together, and remember the following:
- You will win some and lose some. Do NOT give up
- A war is not won or lost by a single battle.
- You are NOT alone.
About Townsend-Rose
Townsend-Rose has been at odds with Factors [Scottish for Property Managers] for many years - since he bought a flat in 1988 and found that rental for the door entryphone system [which was owned] was being included in the servce charges !
About the Property Management Industry
The amount of money which the Property Management Industry [PMI] will throw at trying to keep an estate is enormous and unwarranted in normal business terms. It indicates the profitability of the PMI.
The personal abuse which the managers [mostly Members of the RICS et al] which is likely to be poured on protesters is often grossly unprofessional - so be warned.
About Garden Royal and Research
To sum up the research on the Cladding [at Garden Royal] where he was authorised by a lessee to investigate and complain etc.
- The lessee did not even know what the board was erecting in 2017. In 2020, some £2,000 for damage to cladding was demanded when the lessee put a new boiler in with a high level flue as opposed to being in a kitchen cupboard. Th lessee refused and has never paid, nor been pursued.
- The lessee has never thrown a piece of paper away since buying the flat in 1984. Keep records. He spent several months reading every word, talked to many of the previous managers, and board members. He found that the current chairman [lady] frequently ignored rules e.g. on parking, and letting out her garage to a business. As she was unemployed she was probably short of cash. So check your board.
- Do your research - e.g. get the accounts together in a spreadsheet one column for every year. It will show what was happened . . .
- Regulation simply does not exist in realistic terms. See propertyregulation.org.uk which send you to https://tdocplus.co.uk/01_ROPA/. Things to note on the web site:
- How to Complain. It is much much more than just writing a snotty letter to a firm which gets thousands. R&R, like the rest, are geared up to shield themselves. You will be required to jump through several hoops taking months.
- Take notes of all the research that has gone into complaining and follow it.
- Findings about Regulators does not make happy reading.
- The Report is mostly "unlocked". The main problems are explained in the first four sections and the last one.
A Question - How much time and effort has been put into all this ?
And excellent queastion . . .
The answer is far too much time and effort. Best guess is some 3,500 hours over four years and three months. So say a couple of hours every day.
Comment: Had Townsend-Rose not been retired it would have been impossible.
The article
It was recommended to the aggrieved lessees that an article should be written and published. This was duly done, and it was published in The Daily Mail [on line]. It was "pulled". How long are the arms of the Property Management Industry ?
Noted that the Article was written by a senior journalist who had retired from The Times Newspaper group.
See https://tdocplus.co.uk/01_ROPA/index.php/the-article.
The London Fire Brigade
The London Fire Brigade have been without any doubt the most useful of all bodies who have regulatory powers.
Once advised of the cladding at Garden Royal which was on 29th June 2021, they arranged to visit and make a detailed inspection.
Having completed the inspection, on 6th September 2021 they served a notice on the "responsible person" at Garden Royal.
The notice required that the necessary works should be completed by 7th March 2022. At September 2024 no works to ensure the safety of the Protected Fire Routes has been carried out.
Complaint to the Skinners
History of the Complaint to the Worshipful Company of Skinners
The complaint submitted to the Worshipful Company of Skinners of which the Author has been a Liveryman since 1972 preceded by a period as a Freeman, and before that as an Apprentice is simply a cut down version of that submitted to the Institution of Civil Engineers.
The complaint was received by the Clerk to the Company Andrew Kennett CB CBE who forwarded it to the Author on 19th August 2023, and commented in the following terms:
I am forwarding this unusual correspondence simply to make you aware of it. I and the Court of Skinners’ Company have absolutely no interest in this matter whatsoever and wish you every success in dealing with what is an entirely private and/or professional matter that has nothing to do with your membership of Skinners’ Company
On responding to the Clerk, the Author received a last comment from him as follows:
I most certainly have ignored it and have no intention of gracing it with a reply !
The Author comments that the Institution of Civil Engineers could well have reviewed the original complaint and come to the same conclusion as the Clerk. They did not.