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Leeds PRS Strategy
Response to Draft 3, February 2006
1 Purpose The Strategy is welcome. As the Draft
states, "The strength of the private rented sector in Leeds
lays in its flexibility and adaptability to changing housing demand
and choice and changing housing market conditions." However,
the Lobby has three major reservations.
#01 A Strategy is needed for the PRS by the very
fact that this Sector is problematic. Yet no indication of these
problems is given. There are two in particular. (1) The PRS is parasitic
on the basic housing stock. Some indeed is purpose-built, but a
high proportion is converted, either from owner-occupation or from
social housing. In this respect, when there are 500 homeless families
and 5,000 overcrowded in Leeds, the PRS is actually detrimental
to housing provision in the city - especially as many converted
properties (student HMOs) are for seasonal occupation only. (2)
Like all mindless markets, the PRS tends towards concentrations.
And in concentrations, the PRS can be very problematic for community
cohesion - by the very fact of its high flexibility (ie its provision
of short-term accommodation). High concentrations of a transient
population undermine community sustainability.
#02 The Draft attempts no appraisal of how the
PRS meets housing needs in Leeds. For instance, some markets would
be far better served by purpose-built development, rather than by
the conversion of family homes. But the Strategy gives no critical
attention to this issue.
#03 "This strategy seeks to set out the roles
and responsibilities of" key stakeholders. Yet apart from supervision
and support services within Leeds City Council, these are not identified.
The key stakeholders include (1) landlords of course - but what
about developers and other provider agencies? They also include
(2) tenants - but who and how? But (3) the Draft takes no account
at all of communities as stakeholders (the community is the invisible
third party in the PRS - both tenants and landlords rely on
the neighbouring community for the viability of private rented properties).
2 Context
#04 Scale: In many parts of 'Leeds 6' the PRS is
far in excess of 50%.
#05 Markets: The impression is given that the PRS
is evenly spread. But Allsopp's have estimated that 80% of HMOs
are student-occupied. And the distribution through the city is enormously
varied.
#06 Stakeholders: As noted above, the catalogue
of stakeholders has significant omissions, especially tenants and
community. But above and beyond that, the community (through the
Lobby) has played an active role in the development of the Leeds
Landlord Accreditation Scheme and the Accredited Tenant Scheme.
3 Drivers
#07 Economy and Well-being: The very fact that
the PRS assists 'labour mobility' means that it can have a detrimental
impact on the well-being of neighbourhoods over-subscribed by the
PRS.
#08 Choice: One person's choice is another's restraint.
The invasion of areas like 'Leeds 6' by the PRS has severely limited
the choices available to existing residents.
#09 ASB: The PRS is not only a bolt-hole for serious
ASB. Low-level ASB is endemic to the PRS, as a result of its inherently
transient nature (as any Headingley resident will tell you).
#10 Cohesion: It is worth noting that the average
PRS tenancy is eighteen months. In 'Leeds 6' in 2001, the annual
turnover of the electorate was 60%.
#11 Student Housing: Students don't "live
in shared housing in the community" - in 'Leeds 6'
they overwhelm the community.
#12 Quality & Condition: It may be the case
that "In those areas accommodating students, the higher expectations
of students and their parents have driven up standards." But
this is not immediately obvious if you take a tour of, say, South
Headingley. The immediate impression is of the squalor of the environment,
especially the curtilages of student houses.
#13 Meeting Housing Needs: No consideration is
given to whether the current PRS is the best way to meet the needs
of (a) vulnerable groups (the homeless, refugees) on the one hand,
or of (b) short-term (and seasonal) residents (like students and
young professionals) on the other.
4 Objectives
#14 Vision: The Vision's reference to
sustainable & balanced housing provision is welcome - but it
isn't mentioned in the following three priority themes.
Objective A1 To ensure that there is a healthy and prosperous
private rented sector that forms part of a balanced and sustainable
structure of housing provision across the city and within neighbourhoods
#15 This Objective is certainly welcomed by Leeds
HMO Lobby.
#16 However, the Lobby disputes the Role of
Private Landlords. These stakeholders have no part "to
negotiate and agree the most appropriate levels of private rented
housing across the city and within various neighbourhoods."
(a) It is the actions of private landlords which generate inappropriate
(unbalanced) levels of the PRS in the first place. (b) Such landlords
are on record as opposing all attempts to restrain such action (for
instance, ASHORE, the Letting Boards Direction).
#17 It is an utter disgrace that there is no role
for the community in determining "the level of private rented
housing that enables a balance of housing from different tenures
within neighbourhoods to help create and maintain mixed, sustainable
communities." After all, they have more of a stake than either
the Council or landlords.
#18 One of the first things the community would
say is that the ceiling should apply to population, not
properties - since PRS properties are heavily occupied
(HMOs have twice the occupancy level of family homes).
Objective A2 To enable private landlords to help meet
the needs of specific groups such as students, homeless and vulnerable
people and asylum seekers or refugees
#19 Leeds HMO Lobby welcomes the Role of the
Council "to work with the Council, UNIPOL, Students Unions
and community associations to develop and implement a student housing
strategy for Leeds," and the Outcome of "Increasing
% of students living outside traditional areas."
Objective A4 To ensure that appropriate planning policies
are in place to support sustainable and appropriate private rented
housing
#20 This seems to be concerned with the operation
of planning policies, not the policies themselves. Surely
there should be reference to Leeds UDP Policy H15 and H15A? To the
Role of the Council, ADD: 'To ensure that as far as possible,
planning policies are in place to manage the distribution of the
PRS (for instance to discourage concentration, and to encourage
dispersal).'
Objective B1 To ensure that the highest possible standards
of housing provision, amenity and management in private rented housing
#21 The Lobby welcomes the Role of the Council
"to introduce and operate the Licensing of HMOs" and "to
consider the need for additional HMO licensing powers to regulate
the management of lower risk HMOs."
Objective C2 To ensure that private tenants take advantage
of community engagement processes to represent and promote their
interests
#22 Any local community would welcome the involvement
of private tenants. Do the references to the community refer to
local community associations, like those which comprise
Leeds HMO Lobby? If so, why are such stakeholders not acknowledged
elsewhere? What they would immediately tell you is that the problem
of engagement (e.g. of students) arises precisely from the issue
of community cohesion (transience) raised above.
5 Outcomes
#23 Despite the Vision and the Objectives
there is no reference at all to balanced & sustainable housing
provision.
6 Action Plan
#24 Use of this is very difficult without numbered
Action Points.
#25 Promotion of PRS: Optimum level of PRS:
Landlords are not a relevant agency. Communities are.
#26 Meeting Needs: Student Housing Strategy:
This is welcomed by the Lobby.
#27 Enforcement: HMO Licensing: Both forms
of HMO Licensing are welcome by the Lobby.
#28 Tenant Involvement: Community Membership:
Aren't Community Associations the relevant agents here?
#29 Planning Policies: Add an Action Point
on Policies H15 and H15A of Leeds UDP Review.
Appendix A: A PARTNERSHIP WORKING MODEL
#30 Again, reference to balanced & sustainable
communities is omitted.
Leeds HMO Lobby, 6 March 2006
Leeds HMO Lobby
email: hmolobby@hotmail.com
website: www.hmolobby.org.uk/leeds
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