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Leeds HMO Lobby
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Representation on
Local Development Framework
Core Strategy
Preferred Approach
1 Leeds HMO Lobby is a coalition of all the local community associations
in the Area of Housing Mix (Revised UDP 2006, Policy H15) concerned
about the impact on their communities of concentrations of HMOs.
Information on the Lobby, its aims, structure and membership, is
available online. The Lobby's response to the consultation on the
Preferred
Approach to the Core Strategy of the Local Development Framework
is concerned specifically with Question 12, on policy on student
and other specialist housing.
2 The Lobby agrees with the commitment in paragraph
5.2.1 of the Preferred Approach to "sustainable communities,
which offer a high quality of life and strong sense of place for
the people who live and work within them." The Lobby supports
the Regeneration Priority Areas identified in Policy SC1, and notes
that "other areas in need of regeneration" may be identified.
Some characteristics of areas in need of regeneration are listed
in paragraph 5.2.4 (including deprivation, unemployment, unattractive
environments, etc). To these, the Lobby recommends that another
be added, specifically demographic imbalance (i.e. where
the local demographic profile departs significantly from the city
norm), and especially where this includes high population turnover.
A polarised, transient population is not a secure foundation for
a sustainable community.
3 The Lobby agrees broadly with the account of
HMOs in general, and of student housing in particular, in paragraphs
5.3.45-5.3.48.
# First of all, however, the Lobby disagrees that "the
HMO sector has been contracting" (5.3.47); on the contrary,
numbers of HMOs in & around Headingley have increased
hugely, such that they now outnumber all other forms of tenure.
There are currently estimated to be 5,444 in the area.
# Secondly, the Lobby agrees that HMOs frequently offer
poor living conditions for occupants (5.3.47), that "where
there are clusters", the density of occupation can have a detrimental
impact on amenity (5.3.48), and that such impacts arise especially
as a result of "uneven distribution of the student population",
especially in Headingley and adjacent areas (5.3.45) (paragraph
3.2 notes "the high proportion of young people [in Leeds],
reflecting the city's role as a major provider of Higher and Further
Education" - but not the fact that they are concentrated in
Inner NW Leeds; meanwhile, the benefits of the universities are
noted in 5.2.29, but not the costs). In addition, such "pressure
on the housing stock available for other sectors of the population
… reduces that stock suitable for families" (5.3.45).
# Finally, the Lobby agrees that "the population overall
[in Headingley] is out of balance … and action is needed
to ensure a sustainable community" (5.3.45). Specifically,
"Planning has an important role to continue managing these
issues by using powers at its disposal to ensure that communities
are well balanced and sustainable for the long term" (5.3.46).
4 In the light of the last point above, the Lobby agrees
with Policy H6: Location of Specialist Housing (and in particular,
with the reference in the Summary document to 'student accommodation'),
"development proposals will be controlled to ensure that specialist
forms of accommodation are distributed around Leeds to reflect the
location of needs and the characteristics of local communities."
Policy SC6 confirms that this refers to student housing.
In particular, the Lobby agrees with the need to maintain "the
balance and health of communities."
5 Also in the light of the commitment to the use of planning powers
"to ensure that communities are well balanced", the Lobby
agrees with the proposal in paragraph 5.3.50 to
prepare "supplementary planning advice for inner North West
Leeds, to establish housing mix targets for local neighbourhoods"
- if the recent consultation on the Use
Classes Order results in planning controls on HMOs.
6 However, the Lobby disagrees that in fact "Planning
[is] managing these issues by using powers at its disposal."
At paragraph 1.6, reference is made to 'Saved UDP Policies', and
it is stated, "where it is considered that 'saved' policies
are still relevant and necessary in managing development, it is
the Council's intention that these should be retained. Cross reference
is therefore made throughout this document to 'saved policies'."
Appendix 3 provides a Schedule of Saved Policies, and this includes
Policy H15, Student Housing (page 25). This Policy was adopted in
the Revised UDP in 2006, precisely in order to address the problems
summarised in paragraph 5.3.45. It seeks to discourage further student
housing at the expense (and to the detriment) of family occupation.
Policy H15 should surely be cross-referenced at this point. The
Lobby therefore recommends that Policy H15 is cross-referenced
at this paragraph, and that the Core Strategy undertakes to retain
this Policy, or better still, to update it in the light of PPS3
Housing (2006), the Regional Spatial Strategy (2008, Policy
H5) and any new legislation on HMOs which may come into place.
7 In conclusion, Leeds HMO Lobby recommends:
# that in paragraphs 5.2.3-5.2.7, the Preferred Approach identifies
demographic balance as an essential pre-requisite for Sustainable
Communities;
# that paragraph 5.3.47 be amended to recognise the expansion of
HMOs in Inner NW Leeds;
# that Policy H6 be adopted, with specific reference to student
housing;
# that supplementary advice to establish housing mix targets in
Inner NW Leeds be prepared, if the Use Classes Order is amended;
and
# that Policy H15 (or a new, improved version) be retained in the
Core Strategy.
Leeds HMO Lobby, 4 December 2009
Leeds HMO Lobby
email: hmolobby@hotmail.com
website: www.hmolobby.org.uk/leeds
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