National HMO Lobby


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Students & Community

National HMO Lobby



Local HMO Plans

Concentrations of houses in multiple occupation (HMOs) have a detrimental impact on the character and amenity, indeed the sustainability, of neighbourhoods in many towns in the UK. The activities nationally of the National HMO Lobby to address these impacts are documented on other pages of the website. Meanwhile, frequently in response to local campaigns by our members, local planning authorities (LPAs) around the country have developed local HMO plans – either to address the problem of concentrations of HMOs in general, or more particularly, their principal cause, the demand for student housing.


There is ample justification for local HMO plans to be found in national planning policy. Indeed, where there is demographic imbalance (for instance, due to HMO concentrations) local plans are essential to achieve national policy. For instance, Planning Policy Statement 1 (PPS1) Delivering Sustainable Development (2005) states "Planning should facilitate and promote sustainable development by ... ensuring that development supports existing communities and contributes to the creation of safe, sustainable, liveable and mixed communities" (paragraph 5). PPS3 Housing (2006) goes further: "The Government is seeking to create sustainable, inclusive, mixed communities in all areas … The specific outcomes that the planning system should deliver are a mix of housing, both market and affordable, particularly in terms of tenure and price, to support a wide variety of households in all areas" (paragraphs 9-10); in particular, paragraphs 20-24 are concerned specifically with 'Achieving a mix of housing.'

Many authorities already had generic policies. Nevertheless the development of concentrations of HMOs has revealed the inadequacy of such policies. Their weakness was largely due to the lack of any planning controls on the development of HMOs.

More recently, many LPAs have developed more proactive policies, specific and targeted. Some have been developed under the current planning regime of Local Plans and Unitary Development Plans (UDPs), and a few are adopted. But many LPAs are taking advantage of the new regime of Local Development Frameworks (LDFs). Some policies take the form of Development Plan Documents (DPDs), which carry greater weight, but take a long time to adopt; other policies are being introduced as Supplementary Planning Documents (SPDs), which are quicker but less weighty. Many of these are currently under development.

Since 2010, local HMO plans in England have become viable, following the amendment in April 2010 of the Use Classes Order: a new Class C4 was introduced, specifically for HMOs. This meant that they were now in a different class from Dwellinghouses (C3); conversion from C3 to C4 became a 'change of use', and therefore required planning permission. For a brief six months, this was a national requirement. However, in October 2010, the General Permitted Development Order was amended, making change of use from C3 to C4 'permitted development', exempt from planning permission. LPAs may still require planning permssion for HMOs - but first they must introduce an Article 4 Direction, removing permitted development rights for change of use from C3 to C4.

The policies developed so far are of three broad kinds. (1) One of these is Areas of Restraint: here, an area within the authority is designated, and within that area, restraints are imposed on certain forms of development. In most cases, the restraint is on student housing, including both purpose-built accommodation and student houses. This approach was pioneered in Birmingham, and is being followed in Leeds, Sheffield and Newcastle. However, in Oxford, the restraint is on HMOs.

The Inspector's Report on the Leeds UDP Review rejected its ASHORE (Area of Student Housing Restraint) proposal, suggesting instead an 'Area of Housing Mix'.

(2) Another kind of policy is the Threshold Approach: here, a ceiling is set, beyond which certain forms of development are not permitted. There are two variants, the Scottish and the English. The Scottish version might be called the ‘blanket’ approach: a ceiling is set which applies to every street within the authority; this was pioneered by Glasgow, and is being followed by Fife. Normally, no more than 5% of the properties in any street may be HMOs. The English version might be called the ‘rolling’ approach. This approach is pioneered by Loughborough: development proposals for student housing are considered individually, and permitted only if such developments are below a set percentage of properties in the neighbourhood. This approach is also being followed by Sheffield, but here it applies to HMOs.

[In the case of the Threshold Approach, it is important to bear in mind the distinction between the percentage of properties and the percentage of the population. The average occupancy of HMOs is twice that of the average household (which is 2.4, see ODPM, Survey of English Housing 2003-04). Thus, in an area where 10% of the properties are HMOs, in fact 18% of the population will be HMO occupants. The National HMO Lobby identifies 10% of properties or 20% of the population as the ‘tipping-point’ for HMO-dominance in a neighbourhood: see the discussion in Chapter 2 of Balanced Communities & Studentification (2008).]

A number of observations may be made about both Areas of Restraint and the Threshold Approach. First of all, in both cases, the restraint or prohibition should be applied to HMOs, rather than to student houses (hence, AMOR or Area of Multiple Occupancy Restraint). Problems arise from concentrations of HMOs because their tenants are transient – and this is true of all HMOs, whether their tenants are students or benefit claimants or migrant workers or young professionals. Again, definition of ‘student’ is problematic in various respects; but there is now a broadly accepted definition of HMO in most of the UK (based on the Housing Act 2004 and the equivalent legislation in Northern Ireland and in Scotland). Prohibitions on student housing can be misrepresented as discriminatory. And HMOs are easier to monitor (especially with HMO licensing). A second point to be made is that restraint should be applied, not only to new HMOs, but also to any development which increases the capacity of existing HMOs. The new planning definition of HMO in the Use Classes Orders in England and in Northern Ireland makes Areas of Restraint and Threshold policies a realistic option for LPAs.

(3) A third kind of policy developed by LPAs affected by student HMOs is Purpose-Built Development: here, areas within the authority are designated for the development of purpose-built accommodation for students. Since demand by students (rather than claimants or professionals) is the main driver of concentrations of HMOs, this policy addresses the cause of the problems arising. This policy is being followed by Newcastle, for instance.

Such PBD policies are strongly recommended, but they are not unproblematic. The siting of purpose-built development is an essential consideration. Purpose-Built Development in the wrong place (within areas of existing concentration) can exacerbate the situation; and insensitively sited, can actually generate new problems. First of all, the key problem is not the HMOs as such (though conversion of family homes is of course a serious problem in itself) – rather, the key problem is the concentration, and hence the demographic imbalance (which generates social, economic and environmental problems, and undermines the community’s capacity to tackle these problems). Purpose-Built Development can contribute to imbalance as much as (if not more than) HMO conversions. Secondly, Purpose-Built Development attracts additional HMO conversions – on the one hand, students leaving the accommodation look for housing in the familiarity of the surrounding neighbourhood; and on the other, their friends (not in the accommodation) look for housing nearby. Finally, Purpose-Built Developments are actually a deterrent to the rebalancing of a community by the immigration of long-term residents, especially families. [In Leeds, for instance, Kirkstall Brewery and Sugarwell Court have been developed as purpose-built residences outside the main student colony – and both have attracted their own local colonies.]


All of these policies are necessary, none on its own is sufficient. Areas of Restraint address concentrations themselves. The Threshold Approach tackles developing concentrations. Purpose-built Development is designed to deflate their causes. Therefore, in order to address the impacts of concentrations of HMOs comprehensively, the National HMO Lobby recommends –
# that LPAs with concentrations of HMOs develop local HMO plans which are proactive, specific and targeted;
# that LPAs consider local HMO plans which comprise a three-fold strategy, including Areas of Restraint and a Threshold Approach and
(in university towns) Purpose-Built Development, as complementary policies;
# that in all of these policies, LPAs take account of the problematic issues raised by each.

Local HMO plans are more realistic than they used to be, now that planning legislation in relation to HMOs, specifically the Use Classes Order, in Northern Ireland and in England, provides a clear definition of HMO (however, Scotland and Wales still await changes in their UCOs).

LOCAL HMO PLANS AUTUMN 2005 [partially updated, Spring 2007, Summer 2010, Spring 2011, Autumn 2011, Winter 2012, Summer 2013]

Ashford Borough Council, Article 4 Direction adopted 15 March 2012

London Borough of Barking & Dagenham Notice of Article 4 Direction, effective 12 March 2012; LDF Borough Wide Development Policies DPD, Policy BC4: Residential Conversions and Houses in Multiple Occupation, adopted March 2011

Basingstoke & Deane Borough Council Notice of Article 4 Direction, effective 22 July 2012

Bath & North East Somerset Council Local Plan Revised Deposit 2003 (Policy HG.12 Development for the use of buildings for residential purposes; and Policy HG.17 Development of student accommodation); notice of Article 4 Direction 31 May 2012, confirmed 12 June 2013; HMOs in Bath Supplementary Planning Document adopted 12 June 2013. [See also Additional HMO Licensing]

Bexhill-on-Sea: see Rother District Council

Birmingham City Council Selly Oak Local Plan Policy 11.22 'Area of Restraint (Student Accommodation)' adopted 2001; LDF, Core Strategy (Policy SP 28, Student Accommodation), consultation March 2011; Planning Policy Document, HMOs in the Article 4 Direction Area, 17 November 2014.

Bournemouth Borough Council: notice of Article 4 Direction, effective 16 December 2011; LDF Core Strategy (Policy CS 24 Houses of Multiple Occupation, p56), adopted 30 October 2012 [see also Additional HMO Licensing]

Brighton & Hove City Council LDF City Plan (Policy CP21 Student Accommodation and Houses in Multiple Occupation), proposed submission version, 31 January 2013; Article 4 Direction, agreed at Cabinet, 15 March 2012, to come into force on 5 April 2013 [see also Additional HMO Licensing]

Bristol City Council LDF Draft Site Allocations and Development Management Development Plan Document ( Policy DM2: Residential Sub-divisions, Shared and Specialist Housing), publication version, 15 January 2013; notice of Article 4 Direction (in five wards), effective 11 December 2011; notice of a second Direction (in two further wards), effective 21 October 2012.

Canterbury City Council LDF Balanced Housing Provision: Housing in Multiple Occupation SPD, consultation 2010; notice of Article 4 Direction, due to be effective 2 December 2011, but this has not been confirmed; Local Plan, Policy HD6, Housing in Multiple Occupation, consultation due June 2013; notice of Article 4 Direction, due to come into effect 25 February 2016.

Charnwood Borough Council [Loughborough] LDF, Student Housing Provision in Loughborough SPD, 2005; Core Strategy Further Consultation (proposed student accommodation policy), 2008; notice of Article 4 Direction, effective 12 Feb 2012.

Cheshire West & Chester Council: Executive decision 10 December 2012 to introduce Article 4 Direction in Garden Quarter, effective 8 July 2013; a Houses in Multiple Occupation and Student Accommodation in the Chester Area SPD was approved by the Council's LPWG committee, on 29 February 2016.

Clacton: see Tendring District Council

Cornwall Council: despite HMO problems in Falmouth, arising from the presence of University College Falmouth and the Cornwall Campus of the University of Exeter, no Article 4 Direction is proposed.

Durham County Council, City of Durham Local Plan Policy H9 Multiple Occupation (saved policy 2007); consulting on an Article 4 Direction, March-May 2012, and again September 2015, Article 4 Direction due to be introduced, September 2016; on 16 March 2016, the Council's Cabinet considered an Interim Student Accommodation Policy, and agreed to recommen adoption to full Council [see also Additional HMO Licensing]

Enfield Council: notice of Article 4 Direction, effective 22 October 2013

Exeter City Council SPG Student Accommodation in Residential Areas 2008; LDF Houses in Multiple Occupation SPD, adopted 21 January 2014; notice of Article 4 Direction, effective 31 December 2011 [see also Additional HMO Licensing]

Falmouth: see Cornwall Council

Harlow Council: notice of Article 4 Direction in Morley Grove, effective 1 July 2013

Hastings Borough Council: notice of Article 4 Direction, effective 2 July 2012; LDF Core Strateg (Policy H4 Houses in Multiple Occupation), Proposed Submission Planning Strategy, 31 October 2012 [see also Additional HMO Licensing]

Hatfield: see Welwyn Hatfield Borough Council

London Borough of Hillingdon, Council resolves to introduce an Article 4 Direction, effective 24 March 2013, and to consult on an Interim Planning Policy for Houses in Multiple Occupation in Brunel and Uxbridge South Wards, until 21 February 2013 [see also Additional HMO Licensing]

Hull City Council: notice of Article 4 Direction, 9 October 2012, effective 9 October 2013

Leamington Spa: see Warwick District Council

Leeds City Council, Leeds UDP Review, Policy H15 ‘Area of Housing Mix’, adopted 19 July 2006; Local Development Framework Core Strategy (Policy H6 Houses in Multiple Occupation) Publication Draft 2013; notice of Article 4 Direction, effective 10 Feb 2012.

Leicester City Council formally adopted the Student Housing Supplementary Planning Document (SPD) on 12 June 2012; the City Council is proposing introducing an Article 4 Direction.

City of Lincoln Council agreed on 25 January 2016 to introduce an Article 4 Direction effective from 1 March 2016.

North East Lincolnshire Council, SPG02 Conversion of Properties to Flats and Houses in Multiple Occupation, adopted 2002

Loughborough: see Charnwood Borough Council

Manchester City Council, Core Strategy DPD (Policy H11 HMOs) adopted 11 July 2012; notice of Article 4 Direction, effective 8 October 2011.

Milton Keynes Council: two notices of Article 4 Directions, one immediate (29 December 2010), one effective 23 December 2011; Houses in Multiple Occupation Supplementary Planning Document, consultation October 2011-January 2012.

Margate: see Thanet District Council

Newcastle City Council, Local Development Framework Supplementary Planning Document on Shared Housing, February 2008, revoked 25 November 2011; Interim Planning Guidance on Purpose Built Student Accommodation, November 2007; notice of Article 4 Direction, effective 24 November 2011; LDF Maintaining Sustainable Communities SPD, adopted 25 November 2011; notice of second Article 4 Direction, effective 9 December 2012; third Article 4 Direction, 9 August 2013.

Northampton Borough Council: two notices of Article 4 Directions, one effective immediately (14 February 2011), one effective 14 March 2012.

Nottingham City Council, Building Balanced Communities, SPD, adopted March 2006, re-issued March 2007 (see Appendix 2); notice of Article 4 Direction, effective 11 March 2012 [see also Additional HMO Licensing]

Ormskirk: see West Lancashire Borough Council

Oxford City Council, Oxford Local Plan: Section 7 Housing Policies (Policies HS.13-HS.15) adopted 2005; LDF Sites & Housing DPD (Policy HP7 Houses in Multiple Occupation), February 2013; notice of Article 4 Direction, effective 24 February 2012 [see also Additional HMO Licensing]

Plymouth City Council: LDF Core Strategy, Housing Provision (Policy CS15[3]), adopted 2007; a SPD on Residential Standards is proposed in the Core Strategy (10.33); notice of Article 4 Direction, effective 14 September 2012; the Development Guidelines SPD First Review was formally adopted by Full Council on 22 April 2013.

Borough of Poole LDF Site Specific Allocations & Development Management Policies Development Plan Document (Policy SSA16 Talbot Village HMOs), adopted April 2012; notice of Article 4 Direction, effective 11 February 2013.

Portsmouth City Council: notice of Article 4 Direction, effective 1 November 2011; LDF Portsmouth Plan Submission Draft, Policy PCS19 HMOs: ensuring mixed and balanced communities, 2011; regrettably revised at public examination, July 2011; Supplementary Planning Document (SPD) Houses in multiple occupation: ensuring mixed and balanced communities, adopted 16 October 2012.

Preston City Council: Notice of Article 4 Direction, effective February 2012

Reading Borough Council, Supplementary Planning Guidance House Conversions & Houses in Multiple Occupation adopted 22 September 2003; notice of Article 4 Direction, effective 16 May 2013.

London Borough of Richmond upon Thames, UDP Policy HSG15 Non Self-Contained Accommodation [HMOs] adopted 2005

Rother District Council: notice of Article 4 Direction in Bexhill-on-Sea, effective 7 March 2012

Sheffield City Council, Sheffield Development Framework, Core Strategy (Policy CS41 Creating Mixed Communities), adopted 2009; notice of Article 4 Direction, effective 10 December 2011.

Southampton City Council, Core Strategy (Policy CS16 Housing Mix & Type) adopted 2010; notice of Article 4 Direction, effective 23 March 2012; HMO SPD, adopted 23 March 2012 [see also Additional HMO Licensing]

London Borough of Southwark, notice of Article 4 Direction in Henshaw Street, effective 17 October 2014

Tendring District Council [Clacton], notice of Article 4 Direction, 20 December 2011, due to come into effect 24 December 2012.

Thanet [Margate] District Council SPG Residential accommodation in Cliftonville West Renewal Area, 2007; notice of Article 4 Direction, effective 4 February 2012.

Torbay Council: Article 4 Direction effective 1 August 2103

Warwick District Council: notice of Article 4 Direction in Leamington Spa, effective 1 April 2012; Local Plan Preferred Options, PO6: Mixed Communities & Wide Choice of Housing, May 2102; Policy for Houses in Multiple Occupation (HMOs) and Student Accomodation SPG, consulting July-August 2013

Welwyn Hatfield Borough Council: notice of Article 4 Direction in Hatfield, effective 12 January 2012; Houses in Multiple Occupation SPD, February 2012.

West Lancashire Borough Council [Ormskirk]: notice of Article 4 Direction in Ormskirk and Aughton, effective 24 December 2011; West Lancashire Local Plan 2012-2027 Preferred Options, Policy RS3 Provision of Student Accommodation, 2012.

Worcester City Council, Article 4 Direction consulting March-April 2013.

City of York Local Plan, Chapter 7 Housing (Policy H8 Conversions) approved by Council 2005; notice of Article 4 Direction, effective 20 April 2012; LDF Houses in Multiple Occupation Technical Paper, January 2011; Controlling the Concentration of Houses in Multiple Occupation SPD, approved April 2012

Belfast Planning Service (NI) Houses in Multiple Occupation (HMOs): Subject Plan for Belfast City Council Area 2015 adopted 15 December 2008

Coleraine Planning Service (NI) Coleraine Borough HMO Subject Plan 2016: Issues paper April 2006, consulting

Dundee City Council, Supplementary Planning Guidance Houses in Multiple Occupation November 2006

Glasgow City Council City Plan Policy RES 13 'Multiple Occupancy' adopted 2004; City Plan 2 Consultative Draft March 2006 reviews Policy RES 13

St Andrews Fife Council Fife Development Plan Policy H6 'Houses in Multiple Occupation', 2005, consulting; in 2011, moratorium introduced on HMOs, renewed in 2014, and renewed again in 2016 for another year.


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