Leeds HMO Lobby


Leeds HMO Lobby

What is a HMO?

The Lobby

Local Action
Policy Papers
Studentification in Leeds

National Action
Use Classes Order
HMO Licensing
Students & Community

National HMO Lobby

Leeds HMO Lobby



Response to

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 C, LEEDS HOUSING STRATEGY 2002/3 – 2006/7

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