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AIRE VALLEY LEEDS AREA ACTION PLAN
Leeds HMO Lobby has made representations on the Aire Valley Leeds
Area Action Plan of the Local Development Framework
in April and June 2006,
and in November 2007.
Representation on
AIRE VALLEY LEEDS AREA ACTION PLAN
Preferred Options Main Report October 2007
Preferred Option 2 Housing
2A Promote new housing at Clarence Road (Area 1):
Strongly Agree
2 Comment: Policy H15A of the Revised UDP (2006)
states, “the Council will work with the universities and with
accommodation providers to promote student housing developments
in other areas by identifying and bringing forward for development
sites that would satisfy the criteria.” The supporting text
adds, “the process of identifying such areas would be achieved
through preparation of the Local Development Framework’s Area
Action Plans.” Leeds HMO Lobby therefore requests that the
Aire Valley Leeds Area Action Plan acknowledge its obligation under
this Policy, and recognises that the Plan should provide for a share
of student housing in the city, which would contribute to the mix
of housing provision in the Area.
Character Area Proposals
Area 1, Clarence Road: Strongly Agree
CA Comment: As the Proposals Map for Area 1 (p43)
shows, “This area close to the City Centre has been undergoing
major change over the last decade exemplified by # the opening of
the Royal Armouries Museum and # Clarence Dock.” The latter
of course includes new student accommodation. Within the consultation
on the companion Area Action Plan for the City Centre (April 2007),
Preferred Option PO-08 was To encourage the development of purpose
built student accommodation. Leeds HMO Lobby supported this
Option, as among other things, such development implements Policy
H15A of the Revised UDP (referred to in Comment 2), and it is also
in accordance with the Council’s Strategy for Housing
Students in Leeds (2007). Since half of Area 1 is within the
existing boundaries of the City Centre, the Lobby proposes that
in accordance with Policy H15A, further development of student accommodation
should be considered in Sites 1.1, 1.2 and 1.5.
Leeds HMO Lobby, November 2007
^Top
Representation on
AIRE VALLEY LEEDS AREA ACTION PLAN
Alternative Options, April 2006
1. Leeds HMO Lobby is a coalition of local community
associations concerned to redress the impact on their communities
of concentrations of houses in multiple occupation (HMOs). In principle,
the Lobby is concerned with the whole city of Leeds. In practice,
most of the city’s HMOs (arising from demand for student housing)
are in fact concentrated in Headingley Ward and adjacent parts of
neighbouring wards. So, the Lobby has been especially concerned
with Inner NW Leeds.
2. In some respects, in the light of its historic
concerns, the Lobby has some diffidence in making representations
on the Aire Valley Leeds Area Action Plan of the Local
Development Framework. However, if there are concentrations
of HMOs causing concern within the Aire Valley, then the Lobby would
be pleased to make contact with any local community associations.
At the same time, the Lobby considers that solutions to the problems
of local concentrations of HMOs must be city-wide. This view is
supported by Leeds City Council in the Revised
UDP (whose endorsement by the Council is anticipated shortly).
The Section on ‘Student Housing’ (paras 7.6.28 –
7.6.31d) “deals with planning policy to control the growth
of the student population in the wider Headingley area and measures
to disperse students to other appropriate parts of the City.”
These two objectives are addressed by Policies H15 and H15A respectively.
Paragraph 3.4 of the AVL AAP acknowledges that ‘local plans’,
doubtless including the Revised UDP, have been particularly important
in helping to frame the Plan’s options (bullet-point six,
page 5).
3. Policy H15A states, “the Council will
work with the universities and with accommodation providers to promote
student housing developments in other areas by identifying and bringing
forward for development sites that would satisfy the criteria set
out below.” The five criteria are concerned with transport
connections, viability, integration, regeneration and impact on
local housing stock. Specific sites are not identified. “The
Council thinks that the process of identifying and agreeing such
areas with stakeholders ... would be better achieved through preparation
of the Local Development Framework’s Area Action Plans.”
This is the reason for the Lobby’s present representation:
the Lobby asks that the Revised UDP does inform the Aire Valley
Leeds Area Action Plan, and that the AVL AAP considers the promotion
of student housing developments.
4. The Lobby supports the Plan’s commitment
to ‘sustainable patterns of development’, to ‘mixed
communities’ and to ‘a balanced mix of house types and
sizes’ (4.33, page 23). It is our own commitment to mix and
balance which prompted the founding of the Lobby. Concentrations
of HMOs (whoever they accommodate) undermine sustainability, by
replacing a stable population with a transient population. This
is not to say however that transience in general nor students in
particular are a bad thing. A community distorted by transience
or by students is not balanced and sustainable. But nor does a community
devoid of transience or of students represent the mix
which sustains the diversity and therefore the vitality of a community.
The member communities of the Lobby have hosted a student presence
literally for generations – and can vouch for the fact that,
while studentification will destroy a community, on the
other hand, a student presence can enhance it.
5. Within the options described in Chapter 4 of
the Plan, the Lobby’s representation is concerned neither
with (A) Employment Uses nor with (C) Transport, but with (B) Alternative
Uses, and specifically ‘Housing’ and ‘Leisure
& Recreation’. The following paragraphs provide answers
to Section 3, Questions 09-12, of the Options Questionnaire.
6. In answer to Question 11 of the Options Questionnaire,
Overall, which housing option do you prefer? of the Housing
Options proposed on pages 23-28 of the AVL AAP, Leeds HMO Lobby
recommends consideration of Option H2, In addition to the sites
identified in Option H1, allocate one or more of the following sites
for new housing development. The Lobby proposes that in accordance
with Policy H15A of the Revised UDP, the AVL AAP specifically considers
student housing at the following sites.
6.1 Area 1, The Armouries As the Plan points out
in 3.9 (p10), this area “has undergone major changes over
recent years with ... new student accommodation” among other
developments, and “there is pressure for more change.”
Indeed, “half the area is within the existing boundaries of
the City Centre.” Within the consultation on the companion
Area Action Plan for the City Centre, one of the Residential Options
proposed is Student Accommodation: “Recently, the city centre
and fringe has proved to be a popular choice for the development
of purpose built student accommodation.” One option proposed
is specifically “in peripheral city centre locations.”
Clarence Dock in the Armouries Area is one such ‘peripheral’
development. In answer to Question 09 of the Options Questionnaire,
Do you support mixed use development on the fringe of the city
centre which incorporates housing? therefore, the Lobby proposes
that further development of student accommodation in Area 1 be considered.
6.2 Area 2, Hunslet Riverside “This area
... has been allocated as a strategic housing and mixed use development
site in the review of the UDP” (3.9, p10). During the Leeds
UDP Review, Leeds HMO Lobby responded to Proposed Alteration
15/014, Hunslet Riverside Strategic Housing Site: “Development
of the site will take into account the opportunity for student housing
development, in accordance with Policy H15A” [Representation
0308/22151]. Area 2 “spans the Riverside incorporating ...
the former Copperfield College campus to the north.” This
site is part of the Cross Green/East End neighbourhood, which has
been identified by Unipol Student Homes as one of a number of community
areas suitable for student accommodation. “East End Park/Cross
Green comprises predominantly a mix of older terraced housing but
is also very close to the waterside developments in the East Street
Corridor, the Unipol student housing development at Mill Street,
and the Royal Armouries/Cavalier House. It is very close to the
city centre and its amenities and housing costs are cheap”
(Unipol Student Homes, Housing tabloid, January 2006, p31).
In answer to Question 09 of the Options Questionnaire, again, therefore,
the Lobby proposes that development of student accommodation in
Area 2 be considered.
6.3 Areas 4 & 6, Proposed New Village in the Aire Valley
A new village is proposed for the Aire Valley in paras
4.34-4.36. The Lobby suggests consideration of student accommodation
for two reasons: (a) a student presence will add to the mix and
therefore the sustainability, sought in 4.33; and (b) in terms of
markets, it is important to note the on-going demand for accommodation
by the students of the two major HEIs located in Leeds. With regard
to both reasons, it should be born in mind that the student body
in Leeds is now very diverse, and in addition to the traditional
‘typical’ students, it also includes many mature and
overseas students, some with families, who are an asset to any community.
In answer to Question 10 of the Options Questionnaire, Do you
consider there is a need for a new ‘village’ or other
large-scale housing development in AVL? therefore, the Lobby
proposes that development of student accommodation be considered
in any new village, and that Areas 4 and 6 seem the most suitable
sites.
7. In answer to Question 12 of the Options Questionnaire,
Which option do you prefer for leisure development? of
the Leisure Options proposed on pages 29-33 of the AVL AAP, Leeds
HMO Lobby recommends consideration of Option L1, Focus new leisure
development in locations within or on the edge of the City Centre,
at least. As is noted in para 4.47 (p29), “the areas around
the edge of the City Centre are increasingly becoming the focus
for new development as the City Centre and its area of influence
expands. There may be potential for leisure activities on the fringe
of the City Centre, including the Aire Valley.” Development
of student accommodation in Areas 1 and 2, as recommended in 6.1
and 6.2 above, would not only increase demand in these areas for
leisure facilities, but also provide part of the necessary labour
force.
Leeds HMO Lobby, June 2006
^Top
Aire Valley Area Action Plan
Date: 26 April 2006
From: Leeds HMO Lobby
To: richard.askham@leeds.gov.uk
Dear Mr Askham
I write on behalf of Leeds HMO Lobby regarding the Aire Valley
Area Action Plan.
As you will know, the Council's Response to the Inspector’s
Report and Proposed Modifications of the Leeds UDP Review included
Policy H15A, which states "THE COUNCIL WILL WORK WITH THE UNIVERSITIES
AND WITH ACCOMMODATION PROVIDERS TO PROMOTE STUDENT HOUSING DEVELOPMENTS
IN OTHER AREAS BY IDENTIFYING AND BRINGING FORWARD FOR DEVELOPMENT
SITES THAT WOULD SATISFY THE [FIVE] CRITERIA SET OUT BELOW."
The Council rejected the Inspector’s recommendation to re-word
Policy H15A, involving listing the areas of Leeds where student
housing developments will be promoted. The Council thought that
the process of identifying and agreeing such areas with stakeholders
would take too long, would hold up adoption of the Plan, and would
be better achieved through preparation of the Local
Development Framework’s Area Action Plans.
Accordingly, I would like to ask whether Policy H15A has been taken
on board in the preparation of the Aire Valley Area Action Plan?
And also, whether Leeds HMO Lobby can contribute to the consultation
on the Plan, to encourage such consideration?
Best wishes, Dr Richard Tyler, Leeds HMO Lobby
^Top
Leeds HMO Lobby
email: hmolobby@hotmail.com
website: www.hmolobby.org.uk/leeds
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