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A Strategy for Housing Students in Leeds
Representation on the First Draft of the Strategy

01 Leeds HMO Lobby welcomes the First Draft of the Strategy for Housing Students in Leeds. Indeed, the Lobby is pleased that after six years, Leeds City Council has caught up with its proposals: the first policy we published as an organisation was a proposal for a Student Accommodation Strategy, presented to the Council’s HMO Working Group in 2000. The Lobby broadly supports the objectives of the Strategy, its analysis of the current situation in Leeds, and its proposed themes.

02 Having said that, the Lobby also has significant reservations about the Draft’s account of the processes (Section 2), the participants (Section 3) and the proposals (Sections 1 & 4). The Strategy has been prompted, not by the paucity of student housing in Leeds (indeed, there is a surplus), but by the damage this surplus has done to some of the communities of the city. Fundamentally, the Draft does not acknowledge the real needs which must be addressed by the Strategy.

03 The purpose of the Strategy is not simply to serve the interests of students in Leeds, but rather, to balance the interests of both students (our guests) and of the communities of the city (their hosts). This is not as clear as it might be. The Lobby therefore recommends amendment of the Purpose of the Strategy (Section 1, p4), to read “To provide a strategic framework for interventions aimed at housing appropriately the students coming to Leeds, in the best interest both of students and of the city; achieving a balance in provision for students throughout the city; and supporting the sustainability of areas containing student populations.”

04 Within the Objectives (p4), two related but distinct intentions are included within Objective (f). These two should be separated in the Strategy.

05 The Lobby also recommends revision of the Strategic Themes in Section 4, including the Vision and of the Priority Themes. The roles of the different agencies could also be ordered more consistently, as indicated in the Annex to this Representation [below].

06 The preamble to Section 4 should be clearer that the Strategy serves the interests of the city as a whole, not only our student guests (some of whom may become residents), but also the host communities of Leeds.

07 The Vision in Section 4 (p17) should include a clear commitment that the intent of the Strategy is ‘To provide housing for students in Leeds, which is beneficial both to students and to the city.’ Likewise, the consequent themes should be amended.

08 Theme 1’s objectives (p17) cannot include “enable choices and preferences [of students] to be met ...” It is precisely the untrammelled exercise of choice by students (facilitated by the PRS, allowed by default by the universities and government, both local and national) which has led to the problems which have precipitated the Strategy. A range of housing options may well be offered to students, but the purpose of the Strategy must be to moderate students’ choice, in the interests of residents’ choice.

09 Responsible behaviour by students is of course primarily their own responsibility. Landlords have a role to play (but not a straightforward one). But the only agencies which can be really effective are the universities – their Role therefore (p18) should include discipline.

10 It is not only the role of landlords to subscribe to licensing and accreditation. Within the PRS, developers and parents as housing providers should also take on this responsibility (p18).

11 With regard to monitoring compliance with licensing and accreditation, it is students who are best placed to monitor the PRS (p18). On the other hand, it would be good to see the students unions exploring the possibilities raised by NUS for co-operative student housing.

12 Given the genesis of the Strategy, it is a bit rich to expect the community to ‘welcome’ students, without qualification (p18). However, the communities of Leeds are always happy “to welcome responsible students, in proportionate numbers.”

13 In accordance with the Strategy’s overall purpose (para 03 above), Theme 2 (p19) should be amended to read “Achieving balance in the distribution of the locations of housing for students throughout the city.” The preamble to this Theme should make clear that this re-balancing has to be twofold – first, effecting a balanced distribution of student accommodation across the city as a whole (rather than allowing a weighting in one area only), and secondly, in that weighted area, restoring a balance between students and residents.

14 Student dispersal is articulated as Policy H15A of the UDP. It should be implemented through the Area Action Plans of the Local Development Framework, and among other things, it is the role of the Council to demonstrate that it is doing so (p19).

15 Redistribution of student housing, especially in shared housing, depends crucially on promotion of information to students about the alternatives available. The universities have a key role to play here (p19).

16 Students themselves have a responsibility to take into account, not only the costs and benefits to themselves of the housing choices they make, but also the implications for their host city of those choices (p19).

17 Again, in accordance with the Strategy’s overall purpose (para 03 above), Theme 3 (p20) should be much more proactive. As articulated, it seems resigned to simply doing its best to manage a bad situation. Positive promotion of the community’s sustainability should be emphasised. The Theme should read, “Supporting the sustainability of the communities in which students live.”

18 Furthermore, in pursuit of the theme, the objectives should include “providing equal opportunities for residents’ housing choices and preferences to be met.”

19 In addition to the Council’s action-points listed (p20), numerous initiatives should be undertaken by the Area Committee.

20 Students and their unions (p21) could take a much more proactive role in monitoring landlords’ compliance with licensing and accreditation, and engaging with the local community’s strategies and structures.

21 The proposals fail to recognise the range of actions already undertaken by the community, its members and its representatives (p21).

22 As the agencies which bear ultimate local responsibility for the impacts for their students, the universities have a much wider role to play than that indicated (p21).

23 Other agencies also have roles to play in the restoration of Inner NW Leeds, especially the North West District Partnership and Marketing Leeds.

24 The Outputs should be reconsidered (p21). As in Theme 2, the basic issue is proportions. Since imbalance is the fundamental problem, the Outputs should comprise targets for the restoration of balance, especially of types of housing tenure.

25 Finally, the objectives of the Strategy are almost identical with those of SHAP (though in reverse order). In the Action Plan therefore, a separate plan would seem to be redundant.

26 When it comes to participants in the Strategy (Section 3), the Lobby of course welcomes the Draft’s acknowledgement of the Lobby itself. But at the same time, we regret the numerous ways in which the Lobby and the community it represents is minimised by the Draft – for instance, as an authority on the experience of studentification, and as an agent in addressing this phenomenon in Leeds.

27 The Lobby (and its counterparts around the country: see 32 below) are indebted to Dr Darren Smith for coining the term studentification (p9) and thus facilitating articulation of the problems. His report on Studentification for Universities UK (2006) has established the term as a nationally-recognised concept. However, as the National HMO Lobby’s website makes clear, it has major reservations about Dr Smith’s account of studentification. The Lobby is disappointed that his account is taken as authoritative, in preference to our own. (In fact, Dr Smith’s account relies on data provided to him by the National HMO Lobby.)

28 The Draft lacks any empathy with the affective aspect of the community’s experience of studentification. The process has been profoundly alienating to residents. The marginalisation of their role in the Draft is disappointing, to say the least. And the proposals for action, especially the monitoring of the impacts of studentification, fail to acknowledge how profoundly demoralising this is.

29 The Lobby is offended by its demotion to the tail-end of the list of agencies in Section 3 (p16). A strong case could be made for the Lobby taking priority over all other agencies. First of all, in large part, action by other agencies has been taken only in response to pressure from the community. The Strategy itself, though its first priority is the quality of student housing, has not been initiated by students, nor indeed by their universities. Action on student housing in Leeds was only instigated by the Council in response to campaigns by the community in the late 1990s, initially individual community associations, subsequently collectively by the Lobby (as indicated in 01 above). Subsequently, initiatives like Leeds University’s Housing Strategy and Unipol’s Where to Live were prompted by community pressure, through the Lobby. Secondly, the substance of many initiatives is grounded in community proposals – examples are the action-points of the Shared Housing Action Plan and the ‘community dimension’ of Leeds Landlords Accreditation Scheme (as well as the Tenants Accreditation Scheme).

30 The contribution of the Lobby and the communities it represents is under-estimated by the Draft. In their own time, and largely at their own expense (unlike the other agencies involved, which enjoy the services of paid, professional officials), the community associations in Inner NW Leeds have set up the Lobby, which has met on a monthly basis for nearly seven years, and attended an enormous range of meetings. Its lobbying was instrumental in establishing (and maintaining) the Shared Housing Group. Its Grand Strategy served as the foundation for the revised Shared Housing Action Plan (SHAP2). It played a major role in the development of the UDP policy on student housing, and is now involved in consultations on the LDF. Long before HMO licensing was introduced, it argued for a HMO Registration Scheme in Leeds. And it contributed to the review of the Leeds Landlord Accreditation Scheme. It has also lobbied the universities (over housing strategies and student discipline) and Unipol (leading to the Where to Live guidance). And it has tabled discussion documents on Studentification, Balanced Communities and Accounting for Sustainability. Meanwhile, local community associations have fought an incessant campaign against the erosion of their communities by landlords (of both properties and pubs), exploiting studentification commercially, and they have provided evidence in support of the Cumulative Impact Policy and the DPPO, the Direction on Letting Boards and the Flyer Control Zone. These associations and the Lobby have promoted innovative policies to tackle studentification, including the Community Code, Neighbourhood Design Statements, Headingley Renaissance, Leeds Left Bank, and so on. Headingley Development Trust is intervening directly in the infrastructure and superstructure of Headingley (Headingley Primary School, the Deli Market, HeadingleyHomes). And Heal Headingley, through its website, its activists mailing list, and Headway, the quarterly community newsletter, has kept the community continuously informed. Above all, those individual local residents who are left, despite it all, have simply stuck it out.

31 In the higher education sector, the Draft distinguishes between the universities and their students. In the private rented sector, it distinguishes between Unipol and the rest of the sector. However, when it comes to the community – all are lumped in with the Lobby. But the whole point is that the Lobby represents those communities affected by studentification. Their interests are the complete antithesis of those communities which are not. And contrary to what is implied on p16, the latter have made no contribution to the issue.

32 While it may be outside the remit of the Strategy, no indication is given that Leeds HMO Lobby has played a central role nationally, first in developing the National HMO Lobby (which now numbers 45 groups in 30 towns), and secondly, in many ways, in getting studentification onto the national agenda (not least by providing the impetus behind the Smith/UUK report on Studentification).

33 Apart from its concerns about the representation of its own role in existing strategies, the Lobby questions the Draft’s account of other agencies. Some are omitted (para 34 below). Others are exaggerated (paras 35-38 below). In particular, the bland phrase “Has positively engaged in the Shared Housing Group and the implementation of the Shared Housing Action Plan” is applied to all agencies. But this fails to do justice to some (Leeds HMO Lobby), and it exaggerates the contribution of others (some of whom have merely attended, passively and spasmodically).

34 The actions of the PRS (private rented sector) are pivotal to the development of studentification in Inner NW Leeds, and will be crucial to the development of the Strategy. Yet the sector is omitted from Section 3. From its inception, local landlords (through Leeds Property Association) have been members of the Shared Housing Group. And their perspectives have been articulated throughout recent developments – for instance in the revision of LLAS, in the consultations on the UDP Review, in the implementation of HMO licensing (and in other measures, like the Direction on Letting Boards). Landlords have been vocal. Other elements of the PRS are essential, but have not participated at all. The greatest omission is the developers, whose intervention has precipitated the current stages of both studentification and de-studentification. Smaller in scale, but also significant, are parent purchasers – whose interventions may be brief, who may be ill-informed, but whose actions therefore function as something of a wild card.

35 Leeds City Council is rightly prominent among the agencies listed (p15). It alone has the ability to draw all the agencies together (including its own various departments). As noted, the Council established the SHG (in 2001) and developed SHAP (in 2002). But both of these were in response to community pressure (and when they lapsed in 2005, they were only revived for the same reason). In addition to the measures noted, the Council has introduced regulation in order to manage studentified neighbourhoods, such as the Cumulative Impact Policy, the DPPO, the Direction on Letting Boards, the Flyer Designated Control Zone, and so on. But at the same time, its departments have allowed the situation to deteriorate. Long before mandatory HMO licensing, the Housing Dept could have introduced HMO registration (under the terms of the previous Housing Act). And it is the Planning Dept which has given permission for the development of an ad hoc student village in Little Woodhouse.

36 The Lobby is not aware of the contribution made to student housing issues by the Leeds Housing Partnership (p15).

37 It is true that both universities are members of SHG (p15). But one of them still lacks any public strategy for housing its students at all, and the other developed its Housing Strategy only in response to external pressure. Both have continued to develop student housing within Inner NW Leeds since the establishment of SHG (Leeds University at James Baillie Flats in 2003, Leeds Met at Beckett’s Park currently). And though both rely overwhelmingly on the PRS to accommodate their students, neither have articulated policies or strategies towards this provision.

38 Leeds University Union briefly pioneered promotion of areas other than Headingley for student housing. But otherwise, contrary to the assertion by the Draft, neither student union has engaged with any strategic aspect of student housing (neither even contributed to the consultation on the Area of Student Housing Restraint) (p16).

39 Alone among the other agencies, Unipol has been proactive and co-operative with the community on student housing issues (its three national conferences are worth noting) (p15). But if credit is to be given to agencies, then first it should be accurate, and secondly, it should be accompanied by realistic appraisal of their overall performance.

40 It is untrue to say that “these action have been undertaken individually” (p16). SHG itself is a collaborative venture. And Leeds HMO Lobby at least has worked long and hard to liaise with the Council, with both universities, with students unions, with Unipol, and with landlords.

41 The Draft’s analysis of the processes of studentification in Leeds (in Section 2) recognise what is neglected by its proposals and its account of the parties concerned, namely the huge impact of student housing on local communities. Nevertheless, there are a number of points which need to be added.

42 In the Introduction (p3), all that is said about the way that student housing “dominate and cause difficulties for residential and often long-standing populations” is that “this has had a significant impact on the residential communities of those areas.” The Introduction could at least indicate that “in a very short space of time (barely ten years), a very broad area (two square miles) has been very deeply affected (students outnumber residents, profoundly affecting their society, environment and economy, not to mention their community cohesion.”

43 Section 2 surveys a number of Key Drivers (pp5-6). Nationally, given the significance of sustainability for the genesis of the Strategy, these could also include the government’s definition of Sustainable Communities on the DCLG website(notwithstanding its serious limitations). Locally, one key driver is surely the recruitment policies of the city’s universities. The North West District Plan is certainly another significant local strategy – but a key feature is its lack of any adequate “actions relating to student housing and the management and improvement of inner North West Leeds.”

44 In the consideration of the provision of “Decent, well-managed and affordable housing for Students” (p6), one factor which is omitted is parent purchasing. This is not perhaps on the scale of provision by the universities or by developers or by landlords. Yet it is increasingly significant in Inner NW Leeds. As noted above, parents constitute something of a ‘wild card’ in the local student housing market. Their concern is solely with economy (and doubtless, also profit). But unlike professional landlords, they have little awareness of local geography nor of the regulatory frameworks (especially licensing and accreditation).

45 PBD is noted (p7), and criticism is noted of the lack of infrastructure provided in the de facto ‘student village’ in Little Woodhouse. No acknowledgement is made of the enormous impact of these developments on local residents.

46 Section 2 considers “Diversifying the locations of housing for students throughout the city” (pp9-11), and the role of the UDP Review is mentioned. Two points should be added. It is true that in his judgement, the “Planning Inspector proposed [that] purpose-built student accommodation rather than shared private rented housing could better meet student housing needs without taking up family residential housing.” But it is important to note that he added the qualifications “that will improve the total stock of student accommodation, relieve pressure on conventional housing and assist in regenerating areas in decline or at risk of decline.” Secondly, the Area of Housing Mix constitutes Policy H15. In addition, Policy H15A proposes “the Council will work with the universities and with accommodation providers to promote student housing developments in other areas.”

47 Section 2 considers “Student Demand and Preferences” (p11). Some points may be added. Despite a surplus of student housing in the city, and especially in Inner NW Leeds, properties are still being bought as student houses in the latter, especially by parents (see above), but also by some landlord investors. This is evidently the outcome of internal migration by students within the area of studentification. The depth of student penetration varies, and it is most intense in the older Victorian terraces (in South Headingley, also Central Headingley). Hitherto, it has been least intense in inter-war semi-detached developments. But as the former have deteriorated in amenity, students (and their parents) have sought the greater amenity of the latter [thereby placing these in turn under threat].

48 Contrary to the assertion that “Students are unlikely to move in ones or twos to other areas” (p12), this is in fact precisely the case. ‘Significant numbers’ may not move away from Inner NW Leeds, and a ‘critical mass’ may be necessary to encourage them to do so. But surveys show that small numbers of students (doubtless seeking the benefits of genuine ‘living in the community’) do move to other areas.

49 With regard to cost issues (p12), it is relevant to note that a high proportion (25%) of the University of Leeds’ students come to Leeds from public school backgrounds. (The contrary is the case at Leeds Met.)

50 The last part of Section 2 focuses on Inner NW Leeds, the largest area of Leeds (in fact, the largest in the country) to be subject to studentification. Darren Smith’s account of the consequent problems is cited (p13). But this account is inadequate. Leeds HMO Lobby (with endorsement by the National HMO Lobby) identifies fifteen ‘symptoms of studentification’, as follows.
01 Anti-Social Behaviour: endemic low-level ASB, including noise nuisance, minor vandalism, evacuation.
02 Crime: high rates, especially burglary.
03 Insurance: owners pay top premiums for house, contents, vehicle insurance.
04 Squalor: litter, rubbish, flytipping.
05 Dereliction: neglect of houses and gardens, over-development of houses and gardens.
06 Street Blight: letting boards, flyposting, grilles.
07 Distorted Retail: orientation towards a very specific market, manifest in the particular range of lines in shops, and the range of retail outlets (especially increased numbers of pubs, take-aways and letting agencies).
08 Fluctuating Market: from high demand (term) to low demand (vacation).
09 Casualised Employment: local employment becomes increasingly seasonal (term) and part-time (evening).
10 Carparking: obstructs pavements for pedestrians, and access by emergency vehicles, cleansing, buses, and residents.
11 Services Overwhelmed: not only disproportionate demands on public services like cleansing and policing, housing and planning, but also indirectly the drain of resources away from provision in other neighbourhoods.
12 Decimation: student demand gives rise to high property prices and low amenity, encouraging emigration and making immigration almost impossible, with the result that there are fewer elders (retaining past memories), fewer adults (present activists) and fewer children (the community’s future).
13 Disruption: most owners and occupiers are absentees (hence disengaged), the young and the old especially are isolated (losing their peers), and the neighbourhood loses its social capital or ‘community spirit’ (its social networks, social norms and social sanctions).
14 Distress: deep and rapid changes are felt acutely: the population imbalance itself is stressful (public oppression, private isolation), the declining amenity is alienating (fear of crime, revulsion from squalor, exclusion by the economy), and residents feel anger and despair at their disempowerment.
15 Services Underwhelmed: school closures (ironically, reducing education).

51 SHAP is rightly noted (p13), and the Draft notes that “more is needed to be done to restore balance to the area and develop an agreed long-term strategic plan for the area to deliver long-term sustainability.” Two particular measures have long been advocated by Leeds HMO Lobby, on which the Council continues to prevaricate – the introduction of Additional HMO Licensing in the Area of Housing Mix, and the development of an Area Action Plan for Inner NW Leeds.

52 The Area of Housing Mix has now been tested locally, with the refusal of a planning application for a student residence on St Michael’s Lane by Plans Panel West, on the grounds that it was contrary to Policy H15. (The decision may yet be tested at appeal.)

53 A number of neighbourhood measures have been introduced in Inner NW Leeds, to compensate for the breakdown in social capital. HMO licensing covers the whole Area, and the Area of Housing Mix a good part of it. In addition, Central Headingley now benefits from a Cumulative Impact Policy and a DPPO, a Direction on Letting Boards and Flyer Designated Control Zone.

54 One final point needs to be made. According to recent figures from Shelter, there are five hundred homeless families in Leeds, and five thousand in overcrowded accommodation. Quite apart from the damage done to local communities by studentification, present student housing provision is an abuse of the housing stock in Leeds. When thousands of Leeds residents lack adequate housing, it is a scandal that thousands of properties are appropriated as de facto second homes for seasonal and transient students. This alone makes a Strategy essential.

55 Leeds HMO Lobby looks forward to the revision of the First Draft of the Strategy for Housing Students in Leeds.

Abbreviations: ASB = Anti-Social Behaviour, DCLG = Dept for Communities & Local Government, DPPO = Designated Public Places Order, HDT = Headingley Development Trust, HMO = House in Multiple Occupation, LDF = Local Development Framework, LLA = Leeds Letting Agents, LLAS = Leeds Landlords Accreditation Scheme, LPA = Leeds Property Association, NDS = Neighbourhood Design Statement, PRS = Private Rented Sector, RLA = Residential Landlords Association, SHAP2 = revised Shared Housing Action Plan, SHG = Shared Housing Group, UDP = Unitary Development Plan, UUK = Universities UK.

The Representation also included a detailed Recommended Revision of Section 4 of the Draft Strategy, on 'Key Strategic Themes': copies are available from Leeds HMO Lobby.

Leeds HMO Lobby, October 2006

Leeds HMO Lobby
email: hmolobby@hotmail.com website: www.hmolobby.org.uk/leeds