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Response to
DRAFT SHAP REVIEW
Contents
1 SHAP
2 Review
3 Review of Aims
4 Review of Developments
5 Review of Actions
6 Review of Plan
7 The Draft Report
8 The Draft Plan
9 Review of SHAP
Appendix
Appendix A, SHARED
HOUSING ACTION PLAN REVIEW 2004
Appendix B, PRIVATE RENTED SHARED HOUSING IN LEEDS: ACTION PLAN
2002 [omitted]
Appendix C, LEEDS
HOUSING STRATEGY 2002/3 – 2006/7
Appendix D, UNIVERSITY
OF LEEDS HOUSING STRATEGY: PRIVATE RENTED SECTOR
Appendix E, STUDENTIFICATION
Appendix F, STUDENTS ON STUDENTIFICATION [omitted]
Appendix G, LEEDS
UDP REVIEW POSITION STATEMENT
Appendix H, POLICY PAPERS
Appendix J, REPRESENTATIONS
Appendix K, PROPOSED SHAP2
Response to Draft SHAP Review
1 SHAP Shared houses (HMOs) developed as an issue
in & around Headingley during the 1990s: by the end of the decade,
they predominated in the area, causing a wide range of problems.
In 1999, the local community responded: Headingley Against Landlordism
was founded, and South Headingley Community Association held a public
meeting on Headingley, heading where? In 2001, Cllr David
Morton (Headingley) tabled a White Paper on Shared Housing in
Leeds at Leeds City Council, and as amended by Cllr Liz Minkin,
the Paper was adopted on 28 February. The principal outcome was
Privately Rented Shared Housing in Leeds: A Review Paper and
Action Plan, which was adopted by Council in 2002. The Shared
Housing Action Plan (SHAP) comprised 53 action-points, in eight
sections, addressing both the causes and the effects of the problems
identified. Responsibility for overseeing its implementation was
allocated to the Student Housing Project Group (SHPG), comprising
representatives of all interested parties (Council, community, universities,
students, landlords).
2 Review The Action Plan has been pursued by the
SHPG (and its sub-groups), meeting regularly, and seeing many action-points
achieved. However, the community was concerned that shared housing
continued to increase in the areas already affected, and indeed
to expand into new adjoining areas. Accordingly, after two years,
Leeds HMO Lobby (representing the community) requested the SHPG
on 13 February 2004 to review the success of SHAP, which was agreed.
The purpose of a review of course is to evaluate the success of
a course of action, and to consider how it may be improved. To this
end, the Lobby prepared a brief paper, identifying key issues to
be considered (see Appendix
A) and presented to the Project Leader and Project Manager on
5 October 2004.
3 Review of Aims Any Plan should be clear about
its aims and objectives, and its means of identifying whether or
not these have been achieved – or there is no way to tell
whether it has been successful. The present SHAP has no clearly
stated aims and objectives, and no identified targets to measure
its effectiveness. The present Review makes no
attempt to make good these omissions
Leeds HMO Lobby proposes:
A The Shared Housing Action Plan has a clear
purpose.
Aa The aim of SHAP is to ensure
that the development of shared housing (HMOs) in Leeds is supportive
of sustainability, in accordance with Leeds City Council’s
policies on sustainability (Corporate Plan, Vision for Leeds), and
in the interests of all concerned, students and universities, Council
and communities. In essence, this means the pursuit of balance
– both balance between HMOs and other housing in & around
Headingley, and also balance between Headingley and other areas
of the city in the distribution of HMOs.
Ab The objectives of SHAP target
both the causes and the effects of imbalance, and they are specific,
measurable, agreed, realistic and timescaled (SMART). The principal
cause of imbalance is the demand for student housing in & around
Headingley. (1) The first objective therefore is to reduce the proportion
of students in Headingley to 33% of the population by the next Census
in 2011. (2) The second objective is to increase the proportion
of students accommodated outside ASHORE to 33% by the same date.
(3) The third objective is to increase the sustainability of the
Headingley area on an on-going basis. [The Lobby proposes that
the indicators of sustainability identified by the Egan Review 2004
be adopted.]
Ac The progress of SHAP towards these objectives
is monitored annually, by means of feedback on the objectives and
evaluation of SHAP itself.
4 Review of Developments Progress towards achievement
of SHAP's objectives can be measured by monitoring developments
in & around Headingley and throughout the city. The present
Plan makes no proposals for doing so. The present Review
makes no attempt to document current developments.
Leeds HMO Lobby notes:
B The most recent data shows imbalance increasing,
rather than decreasing.
Ba For the Headingley area, the Development Department
produced a map of Student
Population 2000, and more recently, Main Student Areas
2002. Comparison of the two maps shows
two things: (1) student penetration has increased in existing areas
(for instance, the whole of the area between Woodhouse Moor and
St Michael’s Lane is now saturated, rather than only parts),
and (2) the student housing area has expanded (for instance, across
North Lane and into Beckett Park, into Far Headingley, into Meanwood,
through Burley as far as Kirkstall Lane, and across the river around
Kirkstall Brewery).
Bb More recent data on balance across the city
is available from Leeds University’s Student Distribution
Maps (2004) and these also show increasing imbalance. Figures
for 2003 show three Community Areas with very high numbers of students
(over 2,000: Headingley, Hyde Park and Burley Lodge), another seven
with large numbers (up to 2,000), seven more with less than 500,
thirteen with under 100, and the great majority with negligible
numbers (under 50: 76 Areas). But figures for the following year,
2004, show that, on the one hand, numbers increased in the most
heavily populated Areas, and on the other hand, the numbers of students
in other Areas actually decreased.
Bc The CIT Amenity Audit (2004) indicated
the persistence of problems in & around Headingley. Issues recorded
were of three main types, noise, visual amenity and antisocial behaviour.
The Audit concluded “The audit responses clearly indicate
that a number of local residents have suffered as a result of the
poor behaviour from some students, and the lack of responsibility
shown by landlords also adds to the area’s problems”
(4.1). What is lacking is any longitudinal study: but a monitoring
project of letting boards by SHCA shows an increase of a fifth in
2004 over 2001.
5 Review of Actions The Lobby proposed that each
of the 53 action-points of SHAP be assessed as to whether (a) it
had been achieved, (b) action was on-going, (c) no action had yet
been taken, but should be, or (d) action had become redundant. And
then each action should be evaluated for its success (or not). The
present Review claims to have done so (para 1.3).
But no assessment of the action-points is provided, so it is not
possible to evaluate the success or failure, and thereby the strengths
and weaknesses, of the present Plan.
Leeds HMO Lobby proposes:
C An assessment of SHAP indicates a range of
strengths and weaknesses (see Appendix B). Most of the action-points
are either on-going, or have been completed but need to be sustained:
these need to be carried forward. Some action-points have been completed,
and need no further action. Others have been overtaken by events.
A few now seem marginal to SHAP as it is developing.
6 Review of Plan The 53 action-points of SHAP
were identified four years ago. In addition to the individual strengths
and weaknesses of the present Plan, the Plan as a whole needs evaluation.
In particular, are there new threats or new opportunities which
should be addressed? The present Review does not
examine the unfolding situation of HMOs, either locally or nationally.
Leeds HMO Lobby notes:
D Many significant changes have taken place
since 2002 in relation to HMOs in general and to student housing
in particular.
Da Several relevant developments have taken place
nationally in the last few years. The Housing Act 2004 has been
passed, providing for both mandatory and additional HMO licensing.
The Use Class Order has been amended, but without reference to HMOs
(unlike Northern Ireland). The government has commissioned a report
on Students & Community. Major developers (like UNITE) have
take an interest in the student housing market (see UNITE’s
Student Experience Reports). Initiatives have taken place
throughout the UK, and have been shared, especially at the Unipol
conference Students, Housing & Community, and also through
the new National HMO Lobby. Meanwhile, the Planning Act 2004 and
the Licensing Act 2003 are coming into effect.
Db Many changes in the local context have arisen
directly or indirectly from SHAP itself. The most significant is
the Area of Student Housing Restraint (ASHORE) proposed in the Leeds
UDP Review. Within the Council, the local CIT has established CHEF,
initiated what is now Headingley Renaissance, and appointed
a Community Planning Officer (these are now under the auspices of
the Area Committee). Otherwise, the Council has introduced Headingley
Streetscene, a Cumulative Impact Policy for alcohol licensing, the
Noise Nuisance service, parking schemes, poster drums, and has applied
to government for control of letting boards. The Council’s
Code of Standards for landlords has been succeeded by Leeds Landlords
Accreditation Scheme and the Accredited Tenant Scheme, and Unipol
has also revised its Code of Standards. Leeds University has published
a Housing Strategy, appointed a Community Project Officer
and maintained a Neighbourhood Helpline (and is revising its Community
Strategy). Leeds HMO Lobby publishes a quarterly newsletter,
Headway. Meanwhile, national developers have entered the
student housing market, with several purpose-built developments
(including the de facto developing ‘Little Woodhouse Student
Village’).
Dc In response to such developments, new actions
have been proposed by Leeds HMO Lobby, including a Community
Code, a map for Students in the City, Leeds Left Bank,
Kept in the Community, and proposals for Diversity Zones,
Additional HMO Licensing and a local HMO Officer. [Only one
of these appears (unacknowledged) in the present Review.]
7 The Draft Report Leeds HMO Lobby welcomes the
draft Report, but has many reservations about its
content.
7.1 Background Section 1 outlines the context
of the Review, but omits any reference to the initiative of the
local community, either in developing SHAP or in its review. Contrary
to 1.3, many issues raised in the consultation have not been incorporated,
either into the Report or into the Plan (see 6 Dc above).
7.2 Introduction The data on voids in 2.6 is clearly
relevant to a review of developments: but the date is not given,
the areas are not defined, and the significance of the figures is
not evaluated (given the high proportion of the PRS in Headingley,
a high number of voids might be expected). The relevance of 2.7-2.11
on voids elsewhere is not made clear. The point in 2.13 about potential
increase in voids in Headingley if SHAP is successful is clearly
important – but no action is proposed.
7.3 Shared Housing in the Community It is certainly
the case that there are markets for shared housing (HMOs) other
than students (3.1, also 4.11-12); nevertheless students account
overwhelmingly for the demand. With regard to redistribution of
student housing, the objective of Leeds’ Housing Strategy
cited in 3.7 is entirely inadequate – four or five times the
number proposed is necessary for this policy to be effective (see
Appendix
C for a critique of the Strategy). Leeds University’s
Housing Strategy (cited in 3.8) was very welcome, and so
is its revision in the light of the Lobby’s appraisal (see
Appendix
D). The Report does not note that Leeds Metropolitan University
has still not developed a Housing Strategy – and indeed, has
plans to actually increase student housing in Headingley!
7.4 Students & the Community The statement
that students “are all part of the community in which they
live” (4.1) is naively over-simplified. The National HMO Lobby
has attempted to analyse the complexity of community relations arising
from studentification (see section 4 of the discussion paper in
Appendix E; see also Appendix
F for evidence of this complexity). There is no doubt in the community
that “recognition [is] given to the huge amount of community
involvement that some students partake in throughout their time
at university and beyond” (4.1). However, if a cost-benefit
analysis is to be made of the presence of students in & around
Headingley, then a number of factors need to be recognised also.
(1) The majority of student volunteering is not related to Headingley.
(2) The involvement that does take place there addresses the effects
of studentification, not the causes, and avoids campaigning on fundamental
issues (like HMO licensing, alcohol licensing, letting boards, etc).
(3) Projects like ‘Up Your Street’ are independent of
long-established local community associations (which rather belies
the assertion in 4.9 that students are an “an integral part
of the communities in Leeds”). Finally, “huge amount”
exaggerates the degree of community involvement, given the total
number of students.
7.5 Key Issues
7.5.1 The six themes in the present SHAP are noted
(5.1), but no reference is made to the key distinction between the
causes of the central issue (imbalance) and the effects
of this issue. It is important to tackle the latter, of course,
but quite pointless unless priority is given to the former (see
also 1.1 and 1.2 in Appendix E).
7.5.2 Greater Communication (1) Residents
hope that “students generally would like to be involved in,
and be part of ‘the community’ “ (5.2.5), and
certainly “a sense of belonging can also be achieved through
direct involvement with the local communities” (5.2.6). Local
community associations would welcome student members. But the Report
fails to recognise the significance for this of “the transient
nature of the student population” (5.2.3).
(2) Paragraphs 5.2.8-10 refer to SHPG and CHEF. First of all, the
latter is not at all concerned with management: it was established
as a Forum for dialogue between all interested parties; in principle,
therefore, it does not duplicate the role of the SHPG (the Terms
of Reference do make this clear). Having said that, there is a need
to review CHEF itself, to assess whether it is achieving it objectives.
The proposal to delegate both groups to North West (Inner) Area
Committee (5.2.10) is misconceived (CHEF is already a sub-group
of Area Committee). The housing of students in Leeds is a city-wide
issue: in principle therefore it is the responsibility of the Council
itself, not one of its Areas; and in practice, most of the actions
in SHAP are far beyond the remit of an Area Committee. (The proposal
is tantamount to ‘blaming the victim’.)
7.5.3 Noise & Nuisance The reference
to the University of Ulster (5.3.3) is a useful indication that
the HEIs in Leeds could take a more visible approach to the discipline
of the students they bring to Leeds. Regarding cab contacts (5.3.8)
this is practiced already by some drivers.
7.5.4 Environment The assessment of Streetscene
in 5.4.1 is unduly optimistic. There are serious problems with its
implementation, in consequence of the peculiar demographics in &
around Headingley (as is implied in 5.4.4). A ‘Transport Strategy’
is proposed in 5.4.5: what is its objective?
7.5.5 Regulation This section refers to
accreditation and licensing. ASHORE and Policy H15 in the Leeds
UDP Review (5.6.2-4) belong here as they are also concerned with
regulating student housing in & around Headingley. It should
be noted that there was considerable consensus between the academic
and the community interests over the shortcomings of these policies
as proposed by LCC (see Appendix
G).
7.5.6 Development across the City Little
attention is given to the lack of progress with the South Leeds
Student Village, nor to the unplanned development of private purpose-built
accommodation elsewhere.
7.6 Conclusion There remains an enormous amount
to be done, not just to “further improve the quality of life
for those individuals living in, or close to areas of high densities
of shared housing” (if it has improved at all) (6.1), but
also to retain a sustainable community in Headingley. In the light
of this, the observation that “not least of all the residents
involved need to take responsibility for ensuring that these issues
are addressed” (6.2) is insensitive, if not offensive. Some
thirty Policy Papers produced by Leeds HMO Lobby are listed in Appendix
H, and another thirty or so representations to government in
Appendix J.
8 The Draft Plan The present Plan is grounded
in the key distinction between actions which address the causes
of the central issue (imbalance) and those which address its effects.
The proposed Plan replaces this key distinction with a bureaucratic
separation between City Management (Section One) and Area Management
(Section Two).
8.1 Development across the City
A1: necessary, currently ineffective; how can it be improved?
A2: already implemented by Unipol’s annual Owners’
Briefing.
A3: essential; Metro is a crucial partner.
8.2 Lobbying
B1: redundant; the Use Classes Order has been amended.
8.3 Greater Communication
A1: what’s needed is a HEI Community Liaison Team.
A2: these are two quite distinct issues; (a) needs clarification,
(b) is effected by LLAS.
A3: requires clarification.
A4: necessary to students.
A5: best pursued by Unipol (if not already)?
A6: does this not duplicate the role of Unipol?
A7: review is necessary, but not primarily of Terms of Reference.
A8: the need is to establish monitoring arrangements (there
are none yet to review).
8.4 Noise & Nuisance
B1: the need is for a more visible disciplinary process altogether.
B2: useful action.
B3: the real need is for customer-dispersal from pubs in Headingley.
B4: needs clarification.
B5: the house alarm issue needs more comprehensive review.
B6: surely part of B5?
8.5 Environment
C1: needs clarification.
C2: useful action.
C3: see also D1
C4: useful action.
C5: the garden competition needs to be developed yet.
C6: useful action.
C7: LPA has a Man-with-a-Van proposal under consideration.
C8: it’s not clear what is meant here.
8.6 Regulation
D1: why is this separated from C3?
D2: unclear: does this refer to Letting Boards?
D3: useful action, but how?
D4: essential action.
D5: needs to be co-ordinated with Wardens and PCSOs generally.
D6: the latter part of this duplicates D4.
D7: undoubtedly worth doing, but it’s unclear how this is
directly relevant to SHAP.
D8: does the Cumulative Impact Policy cover take-aways?
D9: Does this refer to Neil’s ‘Hit Squad’?
9 Review of SHAP
9.1 The draft Report and Plan are unacceptable
to Leeds HMO Lobby as they stand. They provide neither an evaluation
of the present SHAP, nor a sound basis for its development in the
future.
9.2 There may as yet be insufficient data to review
SHAP as comprehensively as is desirable. Nevertheless, significant
omissions can be rectified (especially SHAP’s objectives and
monitoring), and a thorough SWOT analysis of the present SHAP can
be undertaken.
9.3 Leeds HMO Lobby recommends that its proposals
above (paragraphs italicised) and the attached SHAP2 (Appendix
K) be adopted as the basis for a revised Review.
Leeds HMO Lobby
9 May 2005
Leeds HMO Lobby
email: hmolobby@hotmail.com
website: www.hmolobby.org.uk/leeds
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