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Ten Point Plan
and 57 Varieties of Action
Briefing Bulletin
1 What’s the Problem?
All local communities, as communities, want to be sustainable. The
government has a definition of a sustainable
community, with eight characteristics. But this definition
entirely overlooks the obvious fact that what’s necessary
for a sustainable community is a resident population willing and
able to sustain that community. Local populations can be disabled
in a number of ways, all of which are types of polarisation.
Polarisation can mean opposition – where the neighbourhood
becomes a place of contest between competing factions. Or polarisation
can mean one-sidedness. Again, this can take a variety
of forms – exclusive communities (dominated by gated enclaves
of the privileged) or excluded communities (dominated by ghettos
of the deprived). Another is domination by transience.
A transient population lacks the ability to be sustainable
(community campaigns often take years of concerted action). It also
lacks the will (clearly, members of the population are
only briefly committed to the neighbourhood). (Of course, one type
of polarisation can easily slide into the other.) Studentification
is one form of transient polarisation (similar in many ways to the
part-time populations of coastal resorts and rural resorts). It
is defined by the National HMO Lobby as the substitution of
a local community by a student community - that is, of a balanced
resident population by a one-sided transient population. (NB the
measures considered here could be applied to any form of polarisation
caused by high turnover.) Dealing with the problems of polarisation,
and restoring sustainability, requires concerted action. No one
policy will resolve polarisation, nor will one party. Everyone concerned
must act together.
1.1 What can be done? Since polarisation in general,
and studentification especially, involve a particular pattern of
land-use, planning measures are crucial. At the same time,
housing measures have a vital bearing. Finally, if cumulative
action is necessary, it needs to be co-ordinated – so management
measures are needed. In all, ten key actions need to be taken: see
2 below.
1.2 Who can do it? Five local stakeholders are
involved in studentification, and one national. The local stakeholders
include both sides of Higher Education, Universities and
Students, local Councils and their Communities,
and the Private Rented Sector (PRS), which dominates studentified
housing. The national stakeholder is the Government. Each
of these may act as leader in some actions, while others
provide support – or lobby for action to
be taken: see 3 below.
So, ten lines of action, and five local actors (with additional
national acts), together generate fifty-seven varieties
of action to tackle HMO-based polarisation. [For further discussion,
see the Lobby's Balanced Communities
& Studentification.]
2 What can be done? Tackling
studentification as a form of polarisation needs a range of measures,
concerned with managing, housing and planning. Together they make
a Ten Point Plan.
2.1 Accommodation Audit The first requirement is
to establish the breadth and depth of the problem – where
is the transient population located, and to what degree of penetration?
The local university is the key actor here, as it knows where its
students live (of course, collective not individual data on distribution
is what is needed). Students of course provide their university
with this information. If necessary, the council and the community
may need to lobby the university to provide it.
The University of Leeds provides annual data on the distribution
throughout the city of its students.
2.2 Co-ordination In order to work together, stakeholders
need some form of forum. All are responsible for actively engaging,
but it is up to the local authority to set up such a forum.
Leeds City Council has established a Shared Housing Group, comprising
representatives of all local stakeholders, and Nottingham has Student
Strategy Leadership Group.
2.3 Action Plan Each stakeholder will need its
own strategy (see 3 below). But these will be ineffective without
coordination. Again, the local authority needs to take the initiative,
but other stakeholders must support the council.
Nottingham is drafting a Student Housing Action Plan.
(National government is not directly involved in any of these
first three action-lines.)
2.4 Mandatory HMO Licensing Through the Housing
Act 2004, the government has introduced licensing
of HMOs, where most students live. With regard to polarisation,
licensing’s most useful role is in identifying the location
of HMOs, hence where the transient population is located. By law,
local authorities now have to issue licences, and the PRS has to
apply for them. (HEIs are also required to adopt codes of practice
for their properties.) Communities and students have a shared interest
in supporting licensing – for instance, by reporting licensable
HMOs to the council.
Leeds HMO Lobby has produced a Notification Form for this purpose.
2.5 Additional HMO Licensing Mandatory licensing
applies only to larger HMOs. But the Housing Act provides also for
the licensing of all additional HMOs in designated areas. Additional
HMO licensing is essential, to take full advantage of licensing
(and to remove an escape route for any landlords trying to avoid
mandatory licensing). Since April 2010, local authorities in England
have a 'general consent' to introduce additional licensing. Responsible
members of the PRS can support the council. The community, students
and universities have a shared interest in lobbying the authority
to take action. (In Scotland, all
HMOs are already subject to licensing. In Northern
Ireland, all are in selected areas, and very large
HMOs elsewhere. In Wales, additional HMO
licensing is already delegated to local authorities.)
Oxford is consulting on introducing additional HMO licensing
throughout the city (2010).
2.6 Restoration of Balance
A destabilised neighbourhood will not easily re-balance itself.
Studentification makes this very difficult. In due course, ‘de-studentification’
may provide opportunities. Only the resident population itself can
restore sustainability to a community. Above all, it needs commitment,
in order to do so. But all stakeholders can lobby for, and provide
support to, the re-introduction of long-term residents, especially
families (whether partners only, or partners with dependants, or
single people with dependants), especially within policy frameworks
set by local and national government.
Headingley
Development Trust in Leeds is hoping to be involved in the local
housing market, to this end.
2.7 Areas of Restraint Local planning authorities
around the country are adopting a range of local
HMO plans to deal with the problems of concentrations of HMOs
or student accommodation (the new planning regime of Local
Development Frameworks gives opportunities to do this). One
of these plans is the idea of an ‘Area of Restraint’,
in order to resist further development where there are already high
concentrations. The council is of course the lead actor here. Community
associations can lobby for some form of restraint, while universities,
students and the PRS can offer their support. National government
too, through the Planning Inspectorate, can support such policy
initiatives.
The best-known such policy is Leeds ASHORE
(Area of Student Housing Restraint), which has been supported by
Planning Inspectors, though modified as an ‘Area of Housing
Mix’.
2.8 Threshold Policy Another measure that has been
proposed by local councils is the idea of some sort of threshold,
beyond which further development of HMOs or student accommodation
will be resisted. This is meant to prevent concentrations developing
in the first place. Again, the council takes the lead. Universities,
students and the PRS can support the council by encouraging the
dispersal of student accommodation. The community can lobby for
both. And the Planning Inspectorate can support such a policy initiative.
Glasgow and Fife
have set ceilings for the proportion of HMOs in a neighbourhood.
Loughborough is adopting a series
of thresholds which will govern planning permission. In Leeds, Unipol
has published a guide to neighbourhoods throughout the city suitable
for student accommodation.
2.9 Purpose Built Development Some councils also
support the development of purpose-built housing for students. Such
housing takes the pressure off conversion of family homes into HMOs
(and in a time of housing shortage, this is far better than the
conversion of family homes into seasonally-occupied second homes).
At the same time, the siting of purpose-built development has to
be carefully handled, so that it does not in fact increase polarisation.
Universities, student unions and developers can take initiatives,
independently or together. The council can suggest locations, and
communities can lobby for this sort of development. The Planning
Inspectorate can be supportive of developments endorsed locally.
There are many joint HEI/PRS ventures of this sort.
2.10 Use Classes Order Many council ideas have
hamstrung by national planning legislation. They could control only
developments which needed planning permission. Restraint and threshold
policies in particular were undermined by the limitations of the
Use Classes Order – which
allowed family homes to be converted to HMOs without planning permission.
However, on 6 April 2010, the Use Classes Order in England was amended,
defining HMOs, placing them in a new Use Clas C4, and subjecting
them to planning permission. Action by the government was a belated
response to lobbying by stakeholders, especially communities and
councils, and their elected representatives.
In Northern Ireland, the Dept of the
Environment changed its Use Classes Order in 2004. The National
HMO Lobby has lobbied for years, for changes elsewhere: in 2010,
the government changed the Use Classes Order in England. Scotland
and Wales still await amendment.
3 Who can do it? All stakeholders
supporting this Ten Point Plan need to adopt a strategy towards
the polarisation which arises from concentrations of student housing.
3.1 Community Associations The local community
has the strongest motive to do so, as its very survival depends
on resisting polarisation – yet at the same time, it is the
weakest of the stakeholders. The community’s first job therefore
is to build its capacity – organisation is essential (and
in a large town, where more than one community association may be
involved, co-ordinated action is invaluable). The community may
look for outside help – it may even consider setting up a
local Development Trust. Otherwise, the local community depends
on lobbying – for local housing and planning policies especially
– and community associations can support their council’s
initiatives (especially the introduction of a local Student Housing
Strategy). It is important therefore to adopt a clear guiding strategy.
Leeds HMO Lobby and the Nottingham
Action Group are examples of umbrella community organisations. Leeds
HMO Lobby has adopted a Grand
Strategy. The council has appointed a dedicated Community Planning
Officer, to advise residents. Also in Leeds, the community has established
Headingley
Development Trust, which aims to intervene locally.
3.2 Local Authorities The council is the local
ringmaster. It has a responsibility to its communities (not to mention
a self-interest) to maintain their sustainability. It also has many
powers and resources (though not as many as it needs). So, frequently
the local council has to take the initiative – in setting
up a management structure, in licensing HMOs, and in introducing
planning policies. It can support initiatives by other local stakeholders,
and it can lobby local universities and national government for
supportive action. All councils have a housing strategy –
this should include a specific Student Housing Strategy,
so that developments take place to benefit both students and communities.
Leeds City Council has established a Shared Housing Group, which
has adopted a Shared Housing Action
Plan, and is preparing a Student Housing Strategy.
3.3 Higher Education Institutions For too long,
universities kept aloof from their effect on their host communities
(and their government department, the DfES, still does). But their
organisation, Universities UK, has now acknowledged the problems,
in their report Studentification:
a guide to opportunities, challenges and practices
(2006): “it is incontrovertible that the negative effects
of studentification are evident in several towns and cities across
the UK” (para 3.12). Universities can of course provide accommodation
for their students, and indeed most do – though rarely for
more than a minority. So universities should also support initiatives
taken by their local councils to deal with the problems raised by
their students living in the private rented sector – ‘in
the community’. Indeed, since it is universities which recruit
students, they have an obligation to develop a strategy for housing
them.
Leeds University has indeed produced a Housing
Strategy.
3.4 Student Unions Regrettably, NUS remains in
denial over the issue of studentification, though it is students
who are at its sharp end (see NUS Report Students
in the Community, 2007). This is not always the case however
with local student unions (and not at all with many individual students).
Student unions can support housing and planning initiatives by their
local councils, and there are some issues where they share an interest
with the local community (like additional HMO licensing). Certainly,
they too have an interest and an obligation in preparing a strategy
for the accommodation of their members.
Leeds University Union’s Housing Guide has included
advice to students to look for accommodation outside the areas of
concentration.
3.5 Private Rented Sector It is both practically
and logically difficult for the PRS to develop a strategy. Logically,
the PRS is the main agent in developing studentification, and it
has the least interest in doing anything about it (in fact, many
landlords vigorously oppose local housing and planning strategies).
At the same time, practically, the PRS is the least co-ordinated
stakeholder – it is made up not only of landlords in competition
with each other, but also increasingly with the developers of large-scale
purpose-built housing (it also includes letting and managing agents).
Nevertheless, responsible landlords and developers can act on and
support local council strategies, such as local voluntary accreditation
schemes.
A unique organisation grounded in the PRS is Unipol,
the student housing charity based in Leeds, which has now organised
three national conferences on the issue of studentification.
3.6 Her Majesty’s Government The ultimate
responsibility for the mess of studentification however lies with
the government, and its incoherent policy development. On the one
hand, the government has (laudably) promoted access to higher education
– but without a moment’s thought to its housing implications,
still less to the local effects these will have. On the other hand,
national government has steadfastly resisted giving local government
the powers it needs to pick up the pieces. Government has turned
a deaf ear to lobbying over studentification, and a blind eye to
its consequences. (Indeed, ODPM commissioned Universities UK’s
Studentification Guide
– but specifically excluded any attention to changes in legislation
from its terms of reference.) Stakeholders around the country badly
need a coherent strategy for student accommodation from the government.
In 2010, the government in England finally accepted that there
was a problem - and agreed to planning
control of shared houses.
National HMO Lobby, June 2006 (amended 2010)
See also, Balanced Communities
& Studentification, 2008
National HMO Lobby
email: hmolobby@hotmail.com
website: www.hmolobby.org.uk
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