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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, either
on HMOs, or on student accommodation, or both (Bath is a case in
point). Nevertheless the development of concentrations of HMOs has
revealed the inadequacy of such policies.
Accordingly (belatedly), 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
consultation.
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
studentification or other 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, there is an argument to
be made that in both cases, the restraint or prohibition is better
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 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 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 policies are strongly promoted, 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 concentration)
can exacerbate the situation; and insensitively sited, can actually
generate new problems. First of all, the key problem is not
the HMOs themselves (though conversion of family homes is of course
a serious problem in itself) – rather, the key problem is
the demographic imbalance (which generates social, economic and
environmental problems, and undermines the community’s capacity
to tackle these problems). Purpose-Built Development contributes
to this 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 Purpose-Built Development, as complementary policies (as
Sheffield proposes);
# 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, and Summer 2010]
ENGLAND
Bath & North East Somerset 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)
Birmingham City Council Selly Oak Local Plan
Policy 11.22 'Area of Restraint (Student Accommodation)' adopted
2001
City of Durham LDF, Housing
Development Plan Document (Issue 8, Provision of Balanced
Communities) 2005, consulting
Leeds City Council, Leeds
UDP Review, Policy H15 ‘Area of Housing Mix’,
adopted 19 July 2006; Local Development Framework Core
Strategy (2009) (paras 5.3.45-50).
North East Lincolnshire Council, SPG02 Conversion
of Properties to Flats and Houses in Multiple Occupation,
adopted 2002
Loughborough Charnwood LDF, Student
Housing Provision in Loughborough SPD, 2005
Manchester City Council, Core Strategy Proposed
Option (Policy
Approach H6) 2010
Thanet District Council, Margate Cliftonville
West Renewal Area: HMO consultation, October 2006
Newcastle City Council, Local Development
Framework
Supplementary Planning Document on Shared Housing, February
2008; Interim
Planning Guidance on Purpose Built Student Accommodation,
November 2007
Nottingham City Council, Building
Balanced Communities, SPD, adopted March 2006, re-issued
March 2007
Oxford City Council, Oxford Local Plan: Section
7 Housing Policies (Policies HS.13-HS.15) adopted 2005
Reading Borough Council, Supplementary Planning
Guidance House
Conversions & Houses in Multiple Occupation adopted
22 September 2003
Sheffield City Council, Sheffield Development
Framework, Core
Strategy (Policy CS41 Creating Mixed Communities), adopted
2009
Southampton City Council, Core
Strategy (Policy CS16 Housing Mix & Type) under Examination,
2009
City of York Local Plan, Chapter
7 Housing (Policy H8 Conversions) approved by Council 2005
NORTHERN IRELAND
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
SCOTLAND
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
National HMO Lobby
email: hmolobby@hotmail.com
website: www.hmolobby.org.uk
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