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Leeds HMO Lobby
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Representation on
Local Development Framework
Core Strategy
1 Leeds HMO Lobby is an association of associations,
a coalition of all the local community groups in Inner NW Leeds
concerned about the impact of concentrations of HMOs on the sustainability
of their communities. As such therefore, since its inception in
2001, the Lobby has taken an active interest in relevant planning
policy. The Lobby played an active role in the Leeds UDP Review
(especially in relation to the Area of Housing Mix), and is contributing
to the consultations on the Local Development
Framework – the Lobby has made representations on all
the Area Action Plans and on the Statement of Community Involvement.
2 Leeds HMO Lobby welcomes the Core Strategy of
the LDF. In broad terms, its vision, objectives and themes are incontestable.
But this is not to say that, as they stand, they are unproblematic.
2.1 The Lobby of course supports the Vision of
a ‘sustainable city’ (p9), and undoubtedly, the five
key Themes are essential elements in that sustainability –
the Environment, New Development, Regeneration, Good Connections
and Provision for Communities.
2.2 However, the Lobby finds no assurance in the
Strategy that its member communities will find their sustainability
promoted. The Lobby identifies general and particular reasons for
this.
3 Leeds HMO Lobby identifies tensions at the heart
of the Core Strategy. The Introduction explains that the LDF’s
‘approach is intended to allow greater flexibility for local
authorities in responding to changing circumstances’ (1.4,
p4). But the Strategy itself appears to lack that very flexibility.
3.1 The Strategy is inflexible in space. Para 2.1
(p7) points out that Leeds is large, 217 square miles, and ‘is
an extremely diverse district, consisting of a main urban area,
surrounded by small towns, villages and countryside. In fact, two
thirds of the district is Green Belt.’ Yet no sense of this
diversity emerges through the Themes – neither the particular
concerns of ‘small towns and villages’, nor the particular
concerns of the very distinctive suburban neighbourhoods (like Inner
NW Leeds).
3.2 The Strategy is inflexible in time. Para 10.2
(p21) states that ‘regeneration is focussed in the Area Action
Plan areas’, and three of the current AAPs are identified
(Aire Valley, EASEL, West Leeds; not City Centre). The point is
reiterated in 10.6 and 10.9. There is no indication that the LDF
itself might develop, and (for instance) further AAPs be added to
the portfolio.
3.3 The Strategy is inflexible in the actions it
proposes – or at least, it doesn’t acknowledge the problems
these contain. There are in fact inherent contradictions within
the Strategy.
(1) A key objective is to ‘promote economic success’
(p9), and ‘Leeds economic performance stands out with high
economic growth’ (2.3, p7). But at the same time, ‘reflecting
its economic prosperity, Leeds has experienced higher average house
prices than the rest of West Yorkshire’ (2.7, p7). The effect
is noted in para 8.1, ‘home ownership is out of reach to many
low to middle income households’ (p18). There is in fact a
real problem of affordable housing in the district (the Golden Triangle
in the Green Belt north of the city, not mentioned in the Strategy,
is but one example).
(2) Another key objective is to ‘protect the environment’
(p9). Yet it is also noted that at Leeds-Bradford International
Airport ‘passenger numbers are projected to double by 2020’
(2.8, p8).
(3) Higher education provision is acclaimed in para 2.10 (p8). Yet
no acknowledgment is made of the way the two universities in Inner
NW Leeds have entirely undermined the sustainability of this Area.
4 Leeds HMO Lobby would like to see additional
options considered, so that sustainability can be more precisely
targeted.
4.1 Housing Much attention is given to meeting
housing requirements (especially 5.1 – 5.9 and 5.12, pp13-14).
But there is no recognition that a major contribution to housing
shortage is the appropriation of family housing as second homes
in Inner NW Leeds, by student landlords, perhaps some 5,000 properties.
This an injustice to those in Leeds seeking decent homes, and it
is a liability to the sustainability both of Inner NW Leeds in particular
and of the city in general. It needs to be addressed by the Strategy.
4.2 Planning The present Area Action Plans seem
to be set in stone. The Strategy gives no indication that any new
AAPs might come on stream during the lifetime of the Strategy. Yet
it is precisely such localised and proactive planning that the LDF
is intended to facilitate – and which would begin to address
the issues of sustainability in Inner NW Leeds.
5 Leeds HMO Lobby is disappointed to discover
that none of the three possible Scenarios outlined in Section 10
(pp21-22) offer any prospects of the particular problems of the
sustainability of Inner NW Leeds being addressed.
Leeds HMO Lobby, 8 January 2007
The Lobby responded to the consultation on the Core
Strategy Issues & Options, in December 2007.
Leeds HMO Lobby
email: hmolobby@hotmail.com
website: www.hmolobby.org.uk/leeds
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