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EASEL AREA
ACTION PLAN
Leeds HMO Lobby has made representations on the EASEL Area Action
Plan of the Local Development Framework
in June and July 2006 and
July 2007.
EASEL Area Action Plan
Date: 26 April 2006
From: Leeds HMO Lobby
To: sue.speak@leeds.gov.uk
Dear Ms Speak
I write on behalf of Leeds HMO Lobby regarding the EASEL 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 EASEL 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
Representation on
EASEL AREA ACTION PLAN
Alternative Options Looking to the Future June 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 EASEL Area Action Plan. However, if there are concentrations
of HMOs causing concern within EASEL, 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. Looking to the Future acknowledges
in Section 2 that “the UDP and its recent revisions ... will
also inform the Area Action Plan” (p6).
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 Plan, and that
the EASEL AAP considers the promotion of student housing developments
within the Plan.
4. The Lobby supports Looking to the Future’s
commitment to sustainability (p6). It is our own commitment to sustainability
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 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. In view of its diffidence noted above, Leeds
HMO Lobby’s representation is concerned with parts only of
the Consultation Comments Form for the EASEL AAP, specifically Questions
07, 24 and 26. Regarding the first of these, Question 07 Overall
which Option do you think brings about the most benefits to the
EASEL area? the Lobby recommends Option 3. If the overall aim
of the Area Action Plan is to “strengthen existing communities
and provide new opportunities for existing and new residents (Looking
to the Future, p8), then it is Option 3 especially which “would
allow new people to move into the area” - including students.
6. Question 24 of the Consultation Comments Form
asks Which proposed mixed use sites do you support and why?
Leeds HMO Lobby recommends that two sites in particular be
considered for student accommodation, Lincoln Green and Harehills.
6.1 Site M25, Lincoln Green This site is flagged
for development in Option 1 (M4 and M5) and Option 2 (M14 and M16),
but most fully developed in Option 3 as the enlarged Site M25. When
the Student Housing Project Group was established in 2001 (now redesignated
the Shared Housing Group), one of its earliest site visits was to
Lincoln Green on 4 July 2001 as a potential location for student
accommodation. As Looking to the Future notes “it
lies close to the City Centre” (p14). The EASEL AAP indeed
abuts immediately onto the City Centre Area Action Plan –
and in fact, one proposed extension of the City Centre extends into
EASEL, alongside Site M25. As the City Centre AAP notes, “recently,
the city centre and fringe has proved to be a popular choice for
the development of purpose built student accommodation.” One
of the Residential Options there proposed is that “purpose-built
student housing should be allowed to develop in peripheral city
centre locations.” Lincoln Green offers just such a site.
6.2 Site M23, Harehills This site is also flagged
for development in Option 1 (M3) and Option 2 (M12 and M13), but
more fully developed in Option 3 as Site M23. It is located within
one of the community areas which have been identified by Unipol
Student Homes as suitable for student accommodation. “Harehills
is located in inner east Leeds close to St James Hospital. It has
a diverse population including a large Asian population. There are
numerous and diverse shopping and eating facilities. The housing
is mostly in older terraced and back to back housing. Housing costs
are still relatively cheap but rising” (Unipol Student Homes,
Housing tabloid, January 2006, p31). Leeds HMO Lobby therefore
proposes that development of student housing in Site M23 be considered.
7. Question 26 of the Consultation Comments Form
asks Are there any other sites, new uses or improvements which
we should consider? It is on the far side of the Area Action
Plan, and it is not identified for development in any of the Options.
But Leeds HMO Lobby wishes to suggest that Cross Gates be considered,
not necessarily for purpose-built development, but for the encouragement
of student accommodation in the private rented sector, in the spirit
of Policy H15A of the Revised UDP. Proportionate development of
student housing need “not unacceptably affect the quality,
quantity or variety of the local housing stock.” The amenities
of Cross Gates should “be attractive to students to live.”
And Cross Gates has “good connections by public transport
to the universities,” already existing (Overground Bus Service
56 links Cross Gates directly with the campuses of both universities).
This part of EASEL offers another possibility for the development
of student housing, for those students who genuinely wish to live
in a community.
Leeds HMO Lobby, July 2006
^Top
Representation on
EASEL AREA ACTION PLAN
Preferred Options Main Report June 2007
Section 1: Strategic Themes
Preferred Option PO1 Housing Strongly Agree
Comment PG: Policy H15A of the Revised UDP 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 EASEL 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.
Section 2: Neighbourhood Proposals
Lincoln Green, Burmantofts & Harehills
Preferred Option LO1 Strongly Agree
Comment LG: In the light of Comment PG above, Leeds
HMO Lobby requests that the EASEL Area Action Plan consider provision
of student housing specifically within this Neighbourhood, at two
sites in particular.
(a) Site M7: This location has been identified by Unipol Student
Homes as suitable for student accommodation. “Harehills is
located in inner east Leeds close to St James Hospital. It has a
diverse population including a large Asian population. There are
numerous and diverse shopping and eating facilities. The housing
is mostly in older terraced and back to back housing. Housing costs
are still relatively cheap but rising” (Unipol Student Homes,
Housing tabloid, January 2006, p31).
(b) Site M10: The City Centre AAP noted, “recently, the city
centre and fringe has proved to be a popular choice for the development
of purpose built student accommodation.” Site M10 offers just
such a location.
Leeds HMO Lobby, July 2007
^Top
Leeds HMO Lobby
email: hmolobby@hotmail.com
website: www.hmolobby.org.uk/leeds
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