National HMO Lobby


National HMO

What is a HMO?
Local HMO Plans
Ten Point Plan


Leeds HMO Lobby
Nottingham Action Group

National Developments
Sustainable Communities
Use Classes Order
HMO Licensing
Taxation of HMOs
Students & Community

National HMO Lobby



Ten Point Plan
and 57 Varieties of Action
Briefing Bulletin

1 What’s the Problem? All local communities, as communities, want to be sustainable. The government has a definition of a sustainable community, with eight characteristics. But this definition entirely overlooks the obvious fact that what’s necessary for a sustainable community is a resident population willing and able to sustain that community. Local populations can be disabled in a number of ways, all of which are types of polarisation. Polarisation can mean opposition – where the neighbourhood becomes a place of contest between competing factions. Or polarisation can mean one-sidedness. Again, this can take a variety of forms – exclusive communities (dominated by gated enclaves of the privileged) or excluded communities (dominated by ghettos of the deprived). Another is domination by transience. A transient population lacks the ability to be sustainable (community campaigns often take years of concerted action). It also lacks the will (clearly, members of the population are only briefly committed to the neighbourhood). (Of course, one type of polarisation can easily slide into the other.) Studentification is one form of transient polarisation (similar in many ways to the part-time populations of coastal resorts and rural resorts). It is defined by the National HMO Lobby as the substitution of a local community by a student community - that is, of a balanced resident population by a one-sided transient population. (NB the measures considered here could be applied to any form of polarisation caused by high turnover.) Dealing with the problems of polarisation, and restoring sustainability, requires concerted action. No one policy will resolve polarisation, nor will one party. Everyone concerned must act together.
1.1 What can be done? Since polarisation in general, and studentification especially, involve a particular pattern of land-use, planning measures are crucial. At the same time, housing measures have a vital bearing. Finally, if cumulative action is necessary, it needs to be co-ordinated – so management measures are needed. In all, ten key actions need to be taken: see 2 below.
1.2 Who can do it? Five local stakeholders are involved in studentification, and one national. The local stakeholders include both sides of Higher Education, Universities and Students, local Councils and their Communities, and the Private Rented Sector (PRS), which dominates studentified housing. The national stakeholder is the Government. Each of these may act as leader in some actions, while others provide support – or lobby for action to be taken: see 3 below.
So, ten lines of action, and five local actors (with additional national acts), together generate fifty-seven varieties of action to tackle HMO-based polarisation. [For further discussion, see the Lobby's Balanced Communities & Studentification.]

2 What can be done? Tackling studentification as a form of polarisation needs a range of measures, concerned with managing, housing and planning. Together they make a Ten Point Plan.
2.1 Accommodation Audit The first requirement is to establish the breadth and depth of the problem – where is the transient population located, and to what degree of penetration? The local university is the key actor here, as it knows where its students live (of course, collective not individual data on distribution is what is needed). Students of course provide their university with this information. If necessary, the council and the community may need to lobby the university to provide it.
The University of Leeds provides annual data on the distribution throughout the city of its students.
2.2 Co-ordination In order to work together, stakeholders need some form of forum. All are responsible for actively engaging, but it is up to the local authority to set up such a forum.
Leeds City Council has established a Shared Housing Group, comprising representatives of all local stakeholders, and Nottingham has Student Strategy Leadership Group.
2.3 Action Plan Each stakeholder will need its own strategy (see 3 below). But these will be ineffective without coordination. Again, the local authority needs to take the initiative, but other stakeholders must support the council.
Nottingham is drafting a Student Housing Action Plan.
(National government is not directly involved in any of these first three action-lines.)
2.4 Mandatory HMO Licensing Through the Housing Act 2004, the government has introduced licensing of HMOs, where most students live. With regard to polarisation, licensing’s most useful role is in identifying the location of HMOs, hence where the transient population is located. By law, local authorities now have to issue licences, and the PRS has to apply for them. (HEIs are also required to adopt codes of practice for their properties.) Communities and students have a shared interest in supporting licensing – for instance, by reporting licensable HMOs to the council.
Leeds HMO Lobby has produced a Notification Form for this purpose.
2.5 Additional HMO Licensing Mandatory licensing applies only to larger HMOs. But the Housing Act provides also for the licensing of all additional HMOs in designated areas. Additional HMO licensing is essential, to take full advantage of licensing (and to remove an escape route for any landlords trying to avoid mandatory licensing). Since April 2010, local authorities in England have a 'general consent' to introduce additional licensing. Responsible members of the PRS can support the council. The community, students and universities have a shared interest in lobbying the authority to take action. (In Scotland, all HMOs are already subject to licensing. In Northern Ireland, all are in selected areas, and very large HMOs elsewhere. In Wales, additional HMO licensing is already delegated to local authorities.)
Oxford is consulting on introducing additional HMO licensing throughout the city (2010).
2.6 Restoration of Balance A destabilised neighbourhood will not easily re-balance itself. Studentification makes this very difficult. In due course, ‘de-studentification’ may provide opportunities. Only the resident population itself can restore sustainability to a community. Above all, it needs commitment, in order to do so. But all stakeholders can lobby for, and provide support to, the re-introduction of long-term residents, especially families (whether partners only, or partners with dependants, or single people with dependants), especially within policy frameworks set by local and national government.
Headingley Development Trust in Leeds is hoping to be involved in the local housing market, to this end.
2.7 Areas of Restraint Local planning authorities around the country are adopting a range of local HMO plans to deal with the problems of concentrations of HMOs or student accommodation (the new planning regime of Local Development Frameworks gives opportunities to do this). One of these plans is the idea of an ‘Area of Restraint’, in order to resist further development where there are already high concentrations. The council is of course the lead actor here. Community associations can lobby for some form of restraint, while universities, students and the PRS can offer their support. National government too, through the Planning Inspectorate, can support such policy initiatives.
The best-known such policy is Leeds ASHORE (Area of Student Housing Restraint), which has been supported by Planning Inspectors, though modified as an ‘Area of Housing Mix’.
2.8 Threshold Policy Another measure that has been proposed by local councils is the idea of some sort of threshold, beyond which further development of HMOs or student accommodation will be resisted. This is meant to prevent concentrations developing in the first place. Again, the council takes the lead. Universities, students and the PRS can support the council by encouraging the dispersal of student accommodation. The community can lobby for both. And the Planning Inspectorate can support such a policy initiative.
Glasgow and Fife have set ceilings for the proportion of HMOs in a neighbourhood. Loughborough is adopting a series of thresholds which will govern planning permission. In Leeds, Unipol has published a guide to neighbourhoods throughout the city suitable for student accommodation.
2.9 Purpose Built Development Some councils also support the development of purpose-built housing for students. Such housing takes the pressure off conversion of family homes into HMOs (and in a time of housing shortage, this is far better than the conversion of family homes into seasonally-occupied second homes). At the same time, the siting of purpose-built development has to be carefully handled, so that it does not in fact increase polarisation. Universities, student unions and developers can take initiatives, independently or together. The council can suggest locations, and communities can lobby for this sort of development. The Planning Inspectorate can be supportive of developments endorsed locally.
There are many joint HEI/PRS ventures of this sort.
2.10 Use Classes Order Many council ideas have hamstrung by national planning legislation. They could control only developments which needed planning permission. Restraint and threshold policies in particular were undermined by the limitations of the Use Classes Order – which allowed family homes to be converted to HMOs without planning permission. However, on 6 April 2010, the Use Classes Order in England was amended, defining HMOs, placing them in a new Use Clas C4, and subjecting them to planning permission. Action by the government was a belated response to lobbying by stakeholders, especially communities and councils, and their elected representatives.
In Northern Ireland, the Dept of the Environment changed its Use Classes Order in 2004. The National HMO Lobby has lobbied for years, for changes elsewhere: in 2010, the government changed the Use Classes Order in England. Scotland and Wales still await amendment.

3 Who can do it? All stakeholders supporting this Ten Point Plan need to adopt a strategy towards the polarisation which arises from concentrations of student housing.
3.1 Community Associations The local community has the strongest motive to do so, as its very survival depends on resisting polarisation – yet at the same time, it is the weakest of the stakeholders. The community’s first job therefore is to build its capacity – organisation is essential (and in a large town, where more than one community association may be involved, co-ordinated action is invaluable). The community may look for outside help – it may even consider setting up a local Development Trust. Otherwise, the local community depends on lobbying – for local housing and planning policies especially – and community associations can support their council’s initiatives (especially the introduction of a local Student Housing Strategy). It is important therefore to adopt a clear guiding strategy.
Leeds HMO Lobby and the Nottingham Action Group are examples of umbrella community organisations. Leeds HMO Lobby has adopted a Grand Strategy. The council has appointed a dedicated Community Planning Officer, to advise residents. Also in Leeds, the community has established Headingley Development Trust, which aims to intervene locally.
3.2 Local Authorities The council is the local ringmaster. It has a responsibility to its communities (not to mention a self-interest) to maintain their sustainability. It also has many powers and resources (though not as many as it needs). So, frequently the local council has to take the initiative – in setting up a management structure, in licensing HMOs, and in introducing planning policies. It can support initiatives by other local stakeholders, and it can lobby local universities and national government for supportive action. All councils have a housing strategy – this should include a specific Student Housing Strategy, so that developments take place to benefit both students and communities.
Leeds City Council has established a Shared Housing Group, which has adopted a Shared Housing Action Plan, and is preparing a Student Housing Strategy.
3.3 Higher Education Institutions For too long, universities kept aloof from their effect on their host communities (and their government department, the DfES, still does). But their organisation, Universities UK, has now acknowledged the problems, in their report Studentification: a guide to opportunities, challenges and practices (2006): “it is incontrovertible that the negative effects of studentification are evident in several towns and cities across the UK” (para 3.12). Universities can of course provide accommodation for their students, and indeed most do – though rarely for more than a minority. So universities should also support initiatives taken by their local councils to deal with the problems raised by their students living in the private rented sector – ‘in the community’. Indeed, since it is universities which recruit students, they have an obligation to develop a strategy for housing them.
Leeds University has indeed produced a Housing Strategy.
3.4 Student Unions Regrettably, NUS remains in denial over the issue of studentification, though it is students who are at its sharp end (see NUS Report Students in the Community, 2007). This is not always the case however with local student unions (and not at all with many individual students). Student unions can support housing and planning initiatives by their local councils, and there are some issues where they share an interest with the local community (like additional HMO licensing). Certainly, they too have an interest and an obligation in preparing a strategy for the accommodation of their members.
Leeds University Union’s Housing Guide has included advice to students to look for accommodation outside the areas of concentration.
3.5 Private Rented Sector It is both practically and logically difficult for the PRS to develop a strategy. Logically, the PRS is the main agent in developing studentification, and it has the least interest in doing anything about it (in fact, many landlords vigorously oppose local housing and planning strategies). At the same time, practically, the PRS is the least co-ordinated stakeholder – it is made up not only of landlords in competition with each other, but also increasingly with the developers of large-scale purpose-built housing (it also includes letting and managing agents). Nevertheless, responsible landlords and developers can act on and support local council strategies, such as local voluntary accreditation schemes.
A unique organisation grounded in the PRS is Unipol, the student housing charity based in Leeds, which has now organised three national conferences on the issue of studentification.
3.6 Her Majesty’s Government The ultimate responsibility for the mess of studentification however lies with the government, and its incoherent policy development. On the one hand, the government has (laudably) promoted access to higher education – but without a moment’s thought to its housing implications, still less to the local effects these will have. On the other hand, national government has steadfastly resisted giving local government the powers it needs to pick up the pieces. Government has turned a deaf ear to lobbying over studentification, and a blind eye to its consequences. (Indeed, ODPM commissioned Universities UK’s Studentification Guide – but specifically excluded any attention to changes in legislation from its terms of reference.) Stakeholders around the country badly need a coherent strategy for student accommodation from the government.
In 2010, the government in England finally accepted that there was a problem - and agreed to planning control of shared houses.

National HMO Lobby, June 2006 (amended 2010)

See also, Balanced Communities & Studentification, 2008


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