Managing Multiple Occupancy
A Document Produced for a Meeting between
The Rt. Hon. Keith Hill, Minister of State for Housing and Planning,
Office of the Deputy Prime Minister, with Representatives from Nottingham
City Council, the National HMO Lobby and the Nottingham Action Group
We welcome the opportunity to meet with the Minister and to convey
to him our concern about the impact of concentrations of Houses
in Multiple Occupation (HMOs), on the sustainability of certain
communities. The following points represent opportunities to address
1. THE HOUSING BILL: We recognise that this legislation
is not intended to address the problems caused by concentrations
of HMOs. Nevertheless the Bill will play an essential part in starting
to solve these problems.
(a) Mandatory Licensing is most welcome. However,
we share the concerns of Shelter and the National Union of Students
that the most vulnerable will not be sufficiently protected by the
proposed criteria. Risk increases not just with size and number
of occupants, but also with the type and behaviour of residents,
and the standard of management imposed on the property. We are further
concerned that the proposed criteria present an incentive for property
owners to avoid licensing by reducing the occupancy of their properties.
This will exacerbate the impact on communities by increasing overall
demand for HMOs in affected areas. We strongly support a revision
of the criteria so that properties with three or more storeys OR
four or more occupants are included.
(b) Additional Licensing is also welcome since
it can address the problems of anti-social behaviour associated
with concentrations of HMOs. Such problems can and do affect these
areas, clearly landlords have a role to play in dealing with this
problem. We are concerned that the need for government to approve
the designation of an area will delay urgently needed action. If
clear guidance is given local authorities will not designate areas
gratuitously and their judgement should be trusted to decide where
this measure will be of benefit.
(c) The Definition of an HMO
badly needed reviewing. However, the Bill could be enhanced by a
clear and simple summary.
2. HIGHER EDUCATION ISSUES: We welcome the Minister's
recognition of the concern expressed around the country about student
accommodation and the so-called phenomenon of ‘studentification’.
The proposed threefold strategy to address the problem is welcome.
(a) Accreditation can help to improve the quality
of the private rented sector. However its voluntary nature means
it is no substitute for licensing as a measure to address concentrations
of HMOs. Licensing will provide an invaluable database for planning
policies, and the introduction of licensing will help to deter irresponsible,
speculative and opportunistic landlords, thereby reducing the concentration
of HMOs and improving standards in this sector.
(b) Land Use Planning has an important role to
play in shaping neighbourhoods. It is essential that planning legislation
adopts the same definition of an HMO as housing legislation, that
HMOs are explicitly recognised by the Use Classes Order, and that
change of use from family housing to HMO is subject to planning
(c) Liaison Between Universities and Local Authorities
is very important, and must involve all stakeholders. This takes
place in some towns and cities, but Government has a role to play
in encouraging meaningful partnerships. It is essential that key
issues are identified and higher education establishments are given
the powers to address them effectively. These issues include the
recruitment of students (their numbers, type and origin), accommodation
when they arrive (dispersal of off-campus, purpose-built residences
throughout the host city) and their discipline once they are in
residence (using procedures which are transparent to the host community).
It seems to us that Universities have a significant role to play
in the Government's wider social agenda of regeneration, tackling
crime and anti-social behaviour, local economic development and
improved educational opportunities. Their recent expansion has not
worked to bring about the dividends in all of these areas that might
have been expected. We welcome the Minister's intention to discuss
matters with the Minister of State for Life Long Learning and Higher
Education and would seek his commitment to ensure universities address
these issues in a meaningful partnership.
National HMO Lobby