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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.

#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