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Leeds HMO Lobby
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Representation on the
Article 4 Direction
proposed by Leeds City Council
01 Leeds HMO Lobby is an association of all the local community
associations within the Area of Housing Mix (designated in Leeds
UDP Policy H15), in Inner NW Leeds, currently comprising a dozen
active organisations: for details of the Lobby, visit the website.
As its name indicates, the Lobby was established to lobby on the
issue of houses in multiple occupation (HMOs) in Leeds, in particular
"to redress their effects on local communities."
02 Addressing the effects means addressing the causes. So the Lobby
was pleased to see the amendment of the Use Classes Order last April,
which brought HMOs into development control, by making conversion
to HMO a change-of-use, thus requiring planning permission. And
of course, the Lobby regretted the amendment of the General Permitted
Development Order in October, which took them out of development
control, by making such change-of-use permitted development.
03 The Lobby therefore welcomes the proposal by Leeds City Council,
published on 10 February 2011, to introduce an Article 4 Direction,
withdrawing permitted development rights for change of use of properties
from Use Class C3 (dwellings) to Use Class C4 (HMOs), and thereby
restoring development control of HMOs. The need for such a Direction
was amply demonstrated by the fact that at a meeting of the full
Council on 17 November 2010, the proposal received unanimous support
from members, from all parties and from all parts of the city.
04 The Lobby considers that there are many good reasons to introduce
a Direction in Leeds. First of all, in principle, HMOs are the only
form of housing development that is not subject to development control.
In the present housing conditions, this is especially significant,
as HMOs do not make a contribution to housing provision: rather,
they consist simply of the transfer of stock from one sector to
another (from either owner-occupation or social renting, to the
private rented sector).
05 The Lobby's immediate concern is with the uncontrolled development
of concentrations of HMOs, and the impact these have on their host
communities. The impacts are well known in Leeds, indeed the Area
of Housing Mix was established specifically to address these impacts.
The effects are social (increased antisocial behaviour, crime),
environmental (squalor, over-intensive development of properties)
and economic (the development of a local 'resort economy'). But
more fundamental is the destabilisation of the host community, as
settled residents are replaced by transient tenants.
06 The Lobby is also concerned at the detrimental impact of uncontrolled
HMOs on overall housing provision in Leeds. Many HMOs serve a useful
function of providing housing for individuals who require short-term
accommodation, for diverse reasons. But in Leeds, a majority of
HMOs are the result of the conversion of first homes for families
into second homes for students. As a result, some five thousand
properties have been taken out of the general market, to provide
temporary (and seasonal) secondary accommodation.
07 Further, the Lobby considers that there are some locations where
the development of even a single HMO is inappropriate (for instance,
a small enclosed cul-de-sac). Under present legislation, there are
no powers to control such developments.
08 There are therefore good reasons to introduce a Direction. The
main reason is to enable the Council to prevent the development
of further concentrations of HMOs, such as those in the Area of
Housing Mix, which have been so detrimental to community cohesion
(indeed, Headingley has been identified by Sheffield University
research as having the least cohesive community in the country).
In fact, on-going internal migration by students, impending changes
to housing benefit, and the continuing housing shortage, all mean
that demand for HMOs will continue. The Lobby recommends to the
Council, that following the introduction of the Direction, a register
of HMOs is maintained, in order to monitor their development, and
to alert Development Control to the emergence of future concentrations.
09 Since the need for controls of HMOs has been precipitated by
concentrations within the Area of Housing Mix, the Lobby welcomes
the inclusion of this Area within the designated scope of the Direction.
10 Further, the Lobby supports the overall extent of the proposed
Direction. As well as the Area of Housing Mix in north-west Leeds,
it also includes the Selective Licensing area in east Leeds, and
HMO areas in south Leeds. The overall Direction area was determined
through consultation between officers and members from all wards
- who of course know the housing issues in their own localities.
11 Given the reasons for a Direction outlined above (04-07), the
Lobby considers that there may be a case for considering extending
the Direction over the whole of the urban area of the Leeds district.
However, for reasons given below (13), any such extension should
be the subject of a further, second Direction.
12 The Lobby was established eleven years ago, when the impact
of concentrations of HMOs had begun to be felt in Inner NW Leeds.
It took a decade of lobbying by the Lobby, and fellow community
organisations throughout the UK, to convince national government
to introduce legislation providing control of HMOs. This delay has
had catastrophic consequences for communities in Leeds. Further
delay would be intolerable. The Lobby therefore urges that the Direction
be introduced at the earliest opportunity, namely 10 February 2012.
13 In order to avoid any further delay, the Lobby argues that the
Council should not consider any reduction in the area covered by
the Direction (which would entail the whole consultation process
beginning anew). For the same reason, the Lobby argues that any
proposed extension of the Direction area should be the subject of
a second and subsequent Direction, with its own period of consultation
and implementation.
14 Some opposition to the proposed Direction arises from the misconception
that it is equivalent to a ban on HMOs. Of course, the truth is
that the Direction simply requires a planning application for a
change of use from C3 to C4. It has no bearing on whether or not
that application is approved or refused. The decision will in fact
be determined by such planning policies on HMOs as are in place.
The Lobby welcomes the Council's commitment to introduce such policies
in the Core Strategy and to develop a specific Supplementary Planning
Document on HMOs.
15 In conclusion, therefore, Leeds HMO Lobby
# supports wholeheartedly the principle of the introduction of an
Article 4 Direction in Leeds, withdrawing permitted development
rights for change of use from Class C3 to C4;
# supports the whole of the proposed area specified in the Direction;
and
# supports confirmation of the Direction by the Executive Board
at the earliest opportunity, that is, 10 February 2012: no amendments
should be considered which would delay the introduction of the Direction.
Dr Richard Tyler, Co-ordinator, Leeds HMO Lobby, February 2011
Leeds HMO Lobby
email: hmolobby@hotmail.com
website: www.hmolobby.org.uk/leeds
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