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AIRE VALLEY LEEDS AREA ACTION PLAN

Leeds HMO Lobby has made representations on the Aire Valley Leeds Area Action Plan of the Local Development Framework in April and June 2006, and in November 2007.

Representation on
AIRE VALLEY LEEDS AREA ACTION PLAN
Preferred Options Main Report October 2007

Preferred Option 2 Housing
2A Promote new housing at Clarence Road (Area 1): Strongly Agree
2 Comment: Policy H15A of the Revised UDP (2006) states, “the Council will work with the universities and with accommodation providers to promote student housing developments in other areas by identifying and bringing forward for development sites that would satisfy the criteria.” The supporting text adds, “the process of identifying such areas would be achieved through preparation of the Local Development Framework’s Area Action Plans.” Leeds HMO Lobby therefore requests that the Aire Valley Leeds Area Action Plan acknowledge its obligation under this Policy, and recognises that the Plan should provide for a share of student housing in the city, which would contribute to the mix of housing provision in the Area.

Character Area Proposals
Area 1, Clarence Road: Strongly Agree
CA Comment: As the Proposals Map for Area 1 (p43) shows, “This area close to the City Centre has been undergoing major change over the last decade exemplified by # the opening of the Royal Armouries Museum and # Clarence Dock.” The latter of course includes new student accommodation. Within the consultation on the companion Area Action Plan for the City Centre (April 2007), Preferred Option PO-08 was To encourage the development of purpose built student accommodation. Leeds HMO Lobby supported this Option, as among other things, such development implements Policy H15A of the Revised UDP (referred to in Comment 2), and it is also in accordance with the Council’s Strategy for Housing Students in Leeds (2007). Since half of Area 1 is within the existing boundaries of the City Centre, the Lobby proposes that in accordance with Policy H15A, further development of student accommodation should be considered in Sites 1.1, 1.2 and 1.5.

Leeds HMO Lobby, November 2007

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Representation on
AIRE VALLEY LEEDS AREA ACTION PLAN
Alternative Options, April 2006

1. Leeds HMO Lobby is a coalition of local community associations concerned to redress the impact on their communities of concentrations of houses in multiple occupation (HMOs). In principle, the Lobby is concerned with the whole city of Leeds. In practice, most of the city’s HMOs (arising from demand for student housing) are in fact concentrated in Headingley Ward and adjacent parts of neighbouring wards. So, the Lobby has been especially concerned with Inner NW Leeds.

2. In some respects, in the light of its historic concerns, the Lobby has some diffidence in making representations on the Aire Valley Leeds Area Action Plan of the Local Development Framework. However, if there are concentrations of HMOs causing concern within the Aire Valley, then the Lobby would be pleased to make contact with any local community associations. At the same time, the Lobby considers that solutions to the problems of local concentrations of HMOs must be city-wide. This view is supported by Leeds City Council in the Revised UDP (whose endorsement by the Council is anticipated shortly). The Section on ‘Student Housing’ (paras 7.6.28 – 7.6.31d) “deals with planning policy to control the growth of the student population in the wider Headingley area and measures to disperse students to other appropriate parts of the City.” These two objectives are addressed by Policies H15 and H15A respectively. Paragraph 3.4 of the AVL AAP acknowledges that ‘local plans’, doubtless including the Revised UDP, have been particularly important in helping to frame the Plan’s options (bullet-point six, page 5).

3. Policy H15A states, “the Council will work with the universities and with accommodation providers to promote student housing developments in other areas by identifying and bringing forward for development sites that would satisfy the criteria set out below.” The five criteria are concerned with transport connections, viability, integration, regeneration and impact on local housing stock. Specific sites are not identified. “The Council thinks that the process of identifying and agreeing such areas with stakeholders ... would be better achieved through preparation of the Local Development Framework’s Area Action Plans.” This is the reason for the Lobby’s present representation: the Lobby asks that the Revised UDP does inform the Aire Valley Leeds Area Action Plan, and that the AVL AAP considers the promotion of student housing developments.

4. The Lobby supports the Plan’s commitment to ‘sustainable patterns of development’, to ‘mixed communities’ and to ‘a balanced mix of house types and sizes’ (4.33, page 23). It is our own commitment to mix and balance which prompted the founding of the Lobby. Concentrations of HMOs (whoever they accommodate) undermine sustainability, by replacing a stable population with a transient population. This is not to say however that transience in general nor students in particular are a bad thing. A community distorted by transience or by students is not balanced and sustainable. But nor does a community devoid of transience or of students represent the mix which sustains the diversity and therefore the vitality of a community. The member communities of the Lobby have hosted a student presence literally for generations – and can vouch for the fact that, while studentification will destroy a community, on the other hand, a student presence can enhance it.

5. Within the options described in Chapter 4 of the Plan, the Lobby’s representation is concerned neither with (A) Employment Uses nor with (C) Transport, but with (B) Alternative Uses, and specifically ‘Housing’ and ‘Leisure & Recreation’. The following paragraphs provide answers to Section 3, Questions 09-12, of the Options Questionnaire.

6. In answer to Question 11 of the Options Questionnaire, Overall, which housing option do you prefer? of the Housing Options proposed on pages 23-28 of the AVL AAP, Leeds HMO Lobby recommends consideration of Option H2, In addition to the sites identified in Option H1, allocate one or more of the following sites for new housing development. The Lobby proposes that in accordance with Policy H15A of the Revised UDP, the AVL AAP specifically considers student housing at the following sites.
6.1 Area 1, The Armouries As the Plan points out in 3.9 (p10), this area “has undergone major changes over recent years with ... new student accommodation” among other developments, and “there is pressure for more change.” Indeed, “half the area is within the existing boundaries of the City Centre.” Within the consultation on the companion Area Action Plan for the City Centre, one of the Residential Options proposed is Student Accommodation: “Recently, the city centre and fringe has proved to be a popular choice for the development of purpose built student accommodation.” One option proposed is specifically “in peripheral city centre locations.” Clarence Dock in the Armouries Area is one such ‘peripheral’ development. In answer to Question 09 of the Options Questionnaire, Do you support mixed use development on the fringe of the city centre which incorporates housing? therefore, the Lobby proposes that further development of student accommodation in Area 1 be considered.
6.2 Area 2, Hunslet Riverside “This area ... has been allocated as a strategic housing and mixed use development site in the review of the UDP” (3.9, p10). During the Leeds UDP Review, Leeds HMO Lobby responded to Proposed Alteration 15/014, Hunslet Riverside Strategic Housing Site: “Development of the site will take into account the opportunity for student housing development, in accordance with Policy H15A” [Representation 0308/22151]. Area 2 “spans the Riverside incorporating ... the former Copperfield College campus to the north.” This site is part of the Cross Green/East End neighbourhood, which has been identified by Unipol Student Homes as one of a number of community areas suitable for student accommodation. “East End Park/Cross Green comprises predominantly a mix of older terraced housing but is also very close to the waterside developments in the East Street Corridor, the Unipol student housing development at Mill Street, and the Royal Armouries/Cavalier House. It is very close to the city centre and its amenities and housing costs are cheap” (Unipol Student Homes, Housing tabloid, January 2006, p31). In answer to Question 09 of the Options Questionnaire, again, therefore, the Lobby proposes that development of student accommodation in Area 2 be considered.
6.3 Areas 4 & 6, Proposed New Village in the Aire Valley A new village is proposed for the Aire Valley in paras 4.34-4.36. The Lobby suggests consideration of student accommodation for two reasons: (a) a student presence will add to the mix and therefore the sustainability, sought in 4.33; and (b) in terms of markets, it is important to note the on-going demand for accommodation by the students of the two major HEIs located in Leeds. With regard to both reasons, it should be born in mind that the student body in Leeds is now very diverse, and in addition to the traditional ‘typical’ students, it also includes many mature and overseas students, some with families, who are an asset to any community. In answer to Question 10 of the Options Questionnaire, Do you consider there is a need for a new ‘village’ or other large-scale housing development in AVL? therefore, the Lobby proposes that development of student accommodation be considered in any new village, and that Areas 4 and 6 seem the most suitable sites.

7. In answer to Question 12 of the Options Questionnaire, Which option do you prefer for leisure development? of the Leisure Options proposed on pages 29-33 of the AVL AAP, Leeds HMO Lobby recommends consideration of Option L1, Focus new leisure development in locations within or on the edge of the City Centre, at least. As is noted in para 4.47 (p29), “the areas around the edge of the City Centre are increasingly becoming the focus for new development as the City Centre and its area of influence expands. There may be potential for leisure activities on the fringe of the City Centre, including the Aire Valley.” Development of student accommodation in Areas 1 and 2, as recommended in 6.1 and 6.2 above, would not only increase demand in these areas for leisure facilities, but also provide part of the necessary labour force.

Leeds HMO Lobby, June 2006

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Aire Valley Area Action Plan
Date: 26 April 2006
From: Leeds HMO Lobby
To: richard.askham@leeds.gov.uk

Dear Mr Askham

I write on behalf of Leeds HMO Lobby regarding the Aire Valley Area Action Plan.

As you will know, the Council's Response to the Inspector’s Report and Proposed Modifications of the Leeds UDP Review included Policy H15A, which states "THE COUNCIL WILL WORK WITH THE UNIVERSITIES AND WITH ACCOMMODATION PROVIDERS TO PROMOTE STUDENT HOUSING DEVELOPMENTS IN OTHER AREAS BY IDENTIFYING AND BRINGING FORWARD FOR DEVELOPMENT SITES THAT WOULD SATISFY THE [FIVE] CRITERIA SET OUT BELOW."

The Council rejected the Inspector’s recommendation to re-word Policy H15A, involving listing the areas of Leeds where student housing developments will be promoted. The Council thought that the process of identifying and agreeing such areas with stakeholders would take too long, would hold up adoption of the Plan, and would be better achieved through preparation of the Local Development Framework’s Area Action Plans.

Accordingly, I would like to ask whether Policy H15A has been taken on board in the preparation of the Aire Valley Area Action Plan? And also, whether Leeds HMO Lobby can contribute to the consultation on the Plan, to encourage such consideration?

Best wishes, Dr Richard Tyler, Leeds HMO Lobby

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Leeds HMO Lobby
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