Leeds HMO Lobby
What is a HMO?
Studentification in Leeds
Use Classes Order
Students & Community
National HMO Lobby
Leeds HMO Lobby
A Strategy for Housing Students
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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