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University of Leeds
Housing Strategy

The University of Leeds published a Draft Housing Strategy for consultation on 14 March 2003. The response by Leeds HMO Lobby is reproduced below. Subsequent to the consultation, a revised draft was prepared, which was presented to the Student Housing Project Group on 8 December 2003, and again, Leeds HMO Lobby responded. The University's Housing Strategy 2003/04-2007/08 was finally published on 23 March 2004: the Lobby's response is below. On 26 June 2007, the University published a Housing Strategy Update Report May 2007, which addressed most of the issues previously raised by the Lobby.

Leeds HMO Lobby Response to Draft Housing Strategy 7 April 2003

1 Welcome Leeds HMO Lobby welcomes the University of Leeds' Consultation Document Draft Housing Strategy.
1.1 Especially, of course, the Lobby welcomes the University's new commitment to a policy for housing its students.
1.2 Also, the Lobby welcomes the commitment to consultation, and looks forward to beginning a constructive dialogue with the University.

2 Strategy Though the Housing Strategy is very welcome, the Lobby sees the Draft as limited. A strategy is usually understood as 'a set of plans to resolve a problem or achieve an objective.'
2.1 Problem: It is surprising that little reference is made to the report on the student housing market in Leeds, commissioned from Dr Darren Smith by the University. In particular, in Processes of Studentification in Leeds, Dr Smith coins the concept of 'studentification' (by analogy with gentrification) to characterise the impact on a community of intensive development of student accommodation. The first paragraph of the Draft in fact suggests a basic misunderstanding of the issue: the problem is not how students are accommodated (university or private provision0, but where they are accommodated. Demographics is not mentioned: there is no account of the numbers of students in Leeds, and where they are located. All other interested parties recognise that 'studentification' is the imperative which lies behind plans to manage the issue of student housing.
2.2 Objectives
2.2.1 The Consultation Document nowhere identifies the objective of the Housing Strategy. To be sure, it is implied in paragraphs which refer to 'dispersal'. But the Strategy would be more promising if it began with an explicit statement of the outcomes it was intended to achieve.
2.2.2 Furthermore, it would be useful to know what specific plans were envisaged to achieve these, who exactly takes responsibility for their implementation, and within what timeframes. [LMU's Transport Strategy (May 2002) and LCC's Housing Strategy (2002) make interesting comparisons.]
2.2.3 The aim of the Strategy might be: to develop the accommodation of higher education students in Leeds to the best advantage both of the students themselves and of theirhost communities. The objectives might then be: (a) to reduce the pressure of demand for accommodation by the University's students; (b) to establish minimum accommodation standards in University and private provision; (c) to resist concentrations of student accommodation in any one area of the city; (d) to develop student accommodation throughout Leeds; (e) to address problems arising from studentification; (f) to exploit the regenerative potential of student housing developments; and so on.
2.3 Evaluation: One advantage of clear objectives is that progress towards their achievement can be evaluated. We welcome the intention of an annual review. But this will require an evaluation plan to identify what needs changing and why. And this in turn will require quantification, targets and criteria. The Strategy needs measures of all these.
2.4 Accommodation Plans
2.4.1 The University's accommodation sites do indeed 'stretch from Clarence Dock ... to Bodington Hall and flats in LS16.' This in fact is the root of the problem, according to the Smith Report. University provision is not dispersed at all, it is concentrated in the A660 corridor, which has the effect of focusing student attention on Headingley in particular and Leeds 6 in general.
2.4.2 It would be interesting to know how the University's current expansion of the James Baillie Flats contributes to the Strategy. The plans were submitted for approval as late as 2001. Is this development intended as part of the Strategy - or is it a profound error?
2.4.3 The Lobby is pleased that 'the University is keen that future developments take place outside the LS6 area.' We hope that the University will go further and repudiate any development of student accommodation in this and adjacent areas.
2.4.4 Support for regeneration through student housing development is very welcome. An indication of where and how this will take place would be helpful.
2.5 Recruitment Plans: One consequence of the lack of clarity of the Strategy is that it focuses primarily on housing. The root of the problem that the Strategy needs to address is the sheer weight of student numbers concentrated in one area of the city, consequent on the expansion of higher education. One tactic of course is to disperse these numbers elsewhere. Another is actually to reduce the numbers. Higher education recruitment can expand without increasing housing demand in Leeds, if this recruitment is localised. Leeds is situated in one of the largest conurbations in Western Europe, and so is well placed for a policy of local recruitment. (Such a policy could also make a significant contribution to the government's aim to widen participation in HE. Many other benefits also accrue from local recruitment.)
2.6 Transport Plans: Wider distribution of student housing around the city cannot be developed independently of transport provision. Supertram will pass the University and therefore has implications for housing development. Meanwhile, existing public transport must be exploited and developed.
2.7 Other Plans: Another advantage of a clear objective is that it enables plans to be prioritised. 'Involvement in the community' is not at all the same as addressing housing issues. (Two of the schools mentioned as beneficiaries are in fact under threat of closure as a result of studentification.) The first half of the Consultation Document is mainly concerned with tackling the symptoms of studentification. Necessary though this is, the principle objective must be to address its causes.

3 Consultation The Consultation Document's commitment to just that is very welcome. It is indeed an assumption of Leeds City Council's Shared Housing Action Plan that addressing the issue of student housing must necessarily be a multi-agency initiative. It would be encouraging to see the University's commitment informing the Draft Strategy.
3.1 Commitment: One measure of an institution's commitment to a policy is the level of managerial participation. The Lobby hopes that the University's Strategy will be pursued with the same seriousness as is accorded its involvement with Unipol. Hitherto, this has not been the case.
3.2 Past Consultation: The Lobby hopes that the University's history of consultation is not a guide to its future. For instance, problems arising from the intake in 2002 were not shared with other stakeholders, to the detriment of the Shared Housing Action Plan. The only positive contribution made by the University's representative to the Student Housing Project Group was the unilateral announcement of the expansion of the James Baillie Flats.
3.3 Current Consultation: It is not encouraging that the Student Housing Project Group is mentioned only in a footnote. The Consultation Document reiterates a few of the action points of the Shared Housing Action Plan, managed by this Group. But it gives no indication of the University's response to current policies emerging from that Plan. What is the University's position on the following proposals?
3.3.1 Government Policies: The draft Housing Bill, for which both Council and community have lobbied, proposes definition of HMO and mandatory licensing.
3.3.2 Council Policies (a) The UDP Review proposes an Action Area in Headingley on student (HMO) housing. (b) Leeds' Landlord Accreditation Scheme is also introducing a Tenant Accreditation Scheme.
3.3.3 Community Policies: On behalf of its constituent members, Leeds HMO Lobby has put a number of policy proposals to the Student Housing Project Group (a) A Grand Strategy proposes a threefold multi-agency approach to concentrations of shared housing. (b) SHAPE (Shared Housing Action Plan Enterprise) proposes a joint planning-housing initiative to control shared housing in and around Headingley. (c) Student Settlements proposes a multi-agency approach to the development of student housing in other areas of the city. (d) Campus by Bus proposes a multi-agency approach to public transport in Leeds, to facilitate city-wide access to the universities.
3.4 Future Consultation: Would it not be useful to liaise with LMU? As by far the largest HEI in Leeds, it would be encouraging to see the University taking the initiative in co-ordinating the action of the HEIs, who ultimately bear responsibility for the rise of the problems associated with studentification.

4 In conclusion, the University's commitment to consultation over a strategy for the housing of its students is encouraging. Leeds HMO Lobby looks forward to the development by the University, in association with the Shared Housing Action Plan and Leeds Housing Strategy, of a comprehensive Student Housing Strategy for the city.

Leeds HMO Lobby, 7 April 2003
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9 December 2003
From: Leeds HMO Lobby
To: Dennis Hopper, University of Leeds

Dear Dennis

Thank you for providing the presentation yesterday, to update us on the University's Housing Strategy. We were pleased to be informed, and your outline of the intent of the Strategy indicates that it is moving on productive lines. As always, as Martin would say, the devil is in the detail. We will be pleased to see the text of the Strategy in due course. In the mean time, I have a few observations and questions on behalf of Leeds HMO Lobby (these follow the sequence of your presentation slides).

Feedback from the initial consultation
The first feedback point is that this should be a strategy. It would be interesting to know what the objectives are. It was clear from what you said that you are of course addressing the concerns of a number of parties, the University itself, your students, and also externally, the community and the Council. The external concerns are to do with the impact of concentrations of student housing in 'ASHORE' [the inverted commas indicate the reservations we discussed over its boundaries]. (These concerns were well summarised in an article in Leeds Student on 21 November.)
Will the Strategy call a spade a spade, and adopt as one of its aspirations a redress of the housing imbalance which has developed in 'ASHORE'?

Student numbers
Here you indicated a growth of 3000 additional FTEs, mainly overseas and returning students. You also indicated the sale of some properties. As you know, the Lobby has advocated the use of restrictive covenants in pursuit of the aim noted above. We understand that you have to follow a Best Value policy. But commercial housing developments in Headingley show that there is no shortage of non-student demand for housing; and LCC has adopted covenants (for instance, in the case of Buckingham House).
Will the Strategy consider the adoption of restrictive covenants in pursuit of its aims?

Students in accommodation
Your figures indicate that the University will require c1300 additional beds by 2007/8. The implication is getting on for 2000 beds in the PRS. My concern is with the demand for private accommodation; and Neil's was with the impact on 'ASHORE'. Both of us would like to know whether we can anticipate more? the same? or less?
Will the Strategy estimate the potential on-going demand for non-University accommodation in 'ASHORE' and/or elsewhere?

New developments
Your slide indicates there will be redevelopment, partnerships, and new developments.
Will the Strategy give details of where, when and what will be developed?

Working with Leeds Met
It was unfortunate that there was no-one at your presentation representing Leeds Met. (TASC also has a part to play here.)
Will the Strategy indicate what frameworks for HEI liaison are proposed?

The University in the community
This is where the aims/objectives of the Strategy again become relevant. The University's contribution to the community at large is valued, of course. But much of its involvement in the community is not to do with the area with which we are concerned. Where it is, it is mostly concerned with the effects of the concentrations of accommodation (a 'sidetrack', in HEAL's terms). Very little is directed towards the problem itself.
Will the Strategy show how the University will engage with the local community's concerns?

Timetable for publication
You mentioned that a process of review and evaluation is intended.
Will the Strategy include a timetable for on-going review?

Your presentation showed that the Strategy has moved forward considerably from the first draft. We look forward to the detail in the final publication early next year. Thanks again for the discussion.

Best wishes, Richard (for Leeds HMO Lobby)
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Response to
University of Leeds
HOUSING STRATEGY
2003/04 - 2007/08

1 Welcome The community has long anticipated a response by the University of Leeds to concerns about the impact of its students' accommodation on the sustainability of the community. This impact increased steadily throughout the 1990s (about 20% of Headingley Ward's population was students in 1991; by 2001, this had increased to 61%). The local community called for action (for instance, with the founding of HEAL in 1998, and at SHCA's meeting Headingley: heading where? 1999). Leeds HMO Lobby was founded in 2000, and proposed a Student Accommodation Strategy. The following year, Leeds City Council began preparing a Shared Housing Action Plan, adopted in 2002. Meanwhile, even in 2003-04, the University was still expanding in Headingley, and re-opened James Baillie Park with a major increase in bedspaces, adding to the local imbalance. Leeds HMO Lobby therefore welcomes the University's Housing Strategy as finally responding to local concerns about the impact of student housing.

2 Significance In correspondence with the Lobby, both the DfES and HEFCE have made it clear that student accommodation is not their problem, let alone its impact on communities. "Higher Education Institutions are independent, autonomous bodies and as such there is no obligation on universities to provide student accommodation" (Elaine Underwood, DfES, 11 March 2004). "Student accommodation is not something with which the HEFCE can become involved, as it is not an item covered under the terms of our agreement with institutions" (Sir Howard Newby, HEFCE, 24 September 2002). Correspondence with communities in other university towns makes it clear that many HEIs are only too ready to take DfES and HEFCE at their word. It is very encouraging to us therefore that the University repudiates this attitude, and embraces openly its responsibilities, not only to its students, but also to its local community. The Vice-Chancellor says "our housing stock has an impact on the social and economic life of the city" (p02), and the Executive Summary "recognises the impact which its students have on local communities" (p03); both universities in Leeds "recognise their responsibilities to the communities of which their students form a substantial part" (p25). In many respects, this is the real significance of the Housing Strategy. We hope that the VC is right that "it will be seen as a landmark in the development of the University's ... relationship with the wider community" (p02).

3 Strengths The University's Housing Strategy makes available some very valuable information. The Community Maps in Appendix 1 show graphically the present imbalance in the distribution of student housing across the city. And Table Four (p08) generally shows a levelling-off in the numbers of University students over the coming five years. This data sets the parameters in space and time, as it were, within which the Strategy will operate. In this context, the aims and objectives of the Housing Strategy are commendable. They are stated in slightly different forms in the different sections, 2 Summary, 3 Need, 4 Objectives, 13 Action Plan and 15 Working with Leeds Met - the last perhaps states them most systematically. Two aims in particular are welcomed by the Lobby.

3.1 "To restrict the growth of student housing in residential areas of Leeds where imbalance has occurred, particularly in the Headingley and Hyde Park communities" (p25). This is also noted in section 3, Need: "one of the main aims of the Housing Strategy is to reduce or slow down the growth of students seeking private rented accommodation in the particularly affected communities of Headingley and surrounding areas" (p04). The Lobby is pleased to see that one of the grounds for rejecting nomination agreements with private developers is that "they are located within or near to the communities in Headingley and surrounding areas already affected by housing imbalance" (p14). It is also reassuring that the proposals for redeveloping residences in order to provide higher density are focused on accommodation outside the affected areas (p13). The Executive Summary states that "the Housing Strategy is aimed at easing symptoms of demographic imbalance" (p03) - this imbalance can be rectified only if student housing in and around Headingley is reduced.

3.2 "Promoting student housing developments in new areas of the city" (p25). This is pointed out in the Summary: "target new developments in communities away from currently highly-populated areas" (p03). It is taken up in sections 3, Need (pp04, 05) and 4, Objectives (p06), and in particular, in section 7, Development, where the proposed new student village at Holbeck Moor in South Leeds is outlined (pp13-14). The other side of the coin to reducing student housing in and around Headingley is increasing it elsewhere. The Holbeck proposal represents a major initiative in this direction. Hopefully, over time, the Community Maps will demonstrate the success of this objective (as noted in 6.3, p10).

3.3 These two are the main immediate actions which are necessary to address the problems which prompted the establishment of Leeds HMO Lobby in the first place. Other objectives are also welcome as contributions to alleviating the problems.
3.31 "Develop new accommodation so that we can house a greater proportion of our students" (p03), and more specifically, "increasing the proportion of University owned or managed accommodation available for returning students from c5% to c12.5%" (p06). Measures to achieve this aim are Priority 1 in section 7, Development (pp13-14). The higher the proportion of University provision, the lower the demand for private provision, and hence the less the pressure on family houses in Headingley. Relatively stable recruitment will make this feasible.
3.32 "It is expected that a greater proportion of Leeds' students will, in future, come from local areas (particularly in light of changing student financial arrangements), which would reduce the demand for student housing" (p04). An increase in local study by the University's students will mean a decrease in demand for accommodation, in the context of relatively stable recruitment. (Local study also has a number of other benefits.)
3.33 "The Housing Strategy is aimed at easing the symptoms of demographic imbalance" (p03). The point is reiterated in section 4, Objectives, "addressing problems arising from the housing imbalance which has developed in Headingley and certain surrounding areas" (p06). Approaches to this end are outlined in section 8, The University in the community.
3.34 "Ensuring that liaison between the University and key partners ... is maintained and focuses on student housing issues" (p06). It was the lack of liaison which delayed the University's Housing Strategy. The difference between the first and final drafts shows how well the University has benefited from liaison. The issue of student housing in Leeds can only be managed through on-going liaison between all parties concerned - communities and Council, HEIs and PRS.

4 Weaknesses From the community's perspective therefore there are many positive aspects to the University's Housing Strategy. At the same time, there are a number of elements which could be developed. The Vice-Chancellor holds that "the Housing Strategy looks outwards as well as inwards" (p02) - but the weaknesses arise from the University's difficulty in stepping down from the ivory tower.

4.1 The Strategy remains a hermetic document. Despite its commitment to liaison, there is hardly any evidence of this. The University attends the Private Rented Sector Strategic Working Group and the Student Housing Project Group (established by the Council) and the Community & HE Forum (initiated by the community). All of these are working to the agenda of the Shared Housing Action Plan. This is noted by the Strategy (p17), but little reference is made to the action-points in SHAP, nor to how the Strategy helps achieve these. Also, out of these Groups, a number of initiatives have emerged (after all, the Holbeck proposal is just what was intended by the Lobby's paper on Student Settlements of 2002) - these might be acknowledged. What is most surprising however is the complete absence of any reference to the major policy initiative emerging from the SHPG and from SHAP, namely, the Council's policy on Student Housing, specifically Policies H15 and H15A and the Area of Housing Restraint (ASHORE), in the Review of the Leeds Unitary Development Plan.

4.2 The Strategy is not consistent as a document. It's clear that the basic aim of any housing strategy is to manage student accommodation in Leeds to the benefit of the HEIs, the students and the host community. This emerges perhaps most clearly right at the end of the document, in the 'Overarching aims' of section 15, Working with Leeds Met. But the aims stated here do not always follow through other sections. In particular, for instance, the aim "to restrict the growth of student housing in residential areas of Leeds where imbalance has occurred" emerges elsewhere (see 3.1 above). But it is not mentioned in the Executive Summary nor the Objectives, nor does it feature at all in the Action Plan. In general, the connections are not clear between the overarching Aims, the Objectives, the Action Plan and (crucially) the Community Maps. (These are alluded to, but not explicitly, in the Action Plan - though they are in fact the principal measure of the Strategy's success as far as community and Council are concerned.) Monitoring and Review will be difficult without these connections - which actions will achieve which objectives? More fundamentally, none of the Priorities in the Action Plan (p22) are concerned with the key issues of concern to the community, that it, reducing the imbalance towards student housing in and around Headingley, and reducing the imbalance of student housing across Leeds.

4.3 Though one of its main aims is "to reduce or slow down the growth of students seeking private rented accommodation" (Summary, p03), the Strategy says little about the private rented sector (PRS). It is primarily concerned with the University's own provision. Section 3 notes that "such housing [PRS] can positively influence other sectors of the rental market and benefit the wider community" (p04; it's not at all clear how). However, Table One (p05) shows clearly that throughout the period of the Strategy, the University will rely on the PRS to accommodate two-thirds of its students. Quantitatively then the PRS dominates student housing in Leeds. Qualitatively too it dominates the problems generated by student housing. The fundamental problem in & around Headingley (as the Strategy recognises) is demographic imbalance. But the symptoms of this imbalance are aggravated when students are housed, not in managed, purpose-built accommodation, but in former family houses amongst the resident community. It is of course much easier to devise a strategy for the accommodation which the University owns itself. Nevertheless, any adequate strategy needs also to address the much less tractable (and larger) problem of the PRS. This is where the absence of any reference to LCC Planning Policy is remarkable.
4.31 On the one hand, the UDP has always resisted concentrations of student housing. The current Review proposes ASHORE, and Policy H15 which resists various forms of new student housing in this Area. We know that the University supports this policy: "The University supports in general terms Policy H15 (§1.4) ... There is no problem in principle with defining an ASHORE (§3.7)" (UoL, Representations on Leeds UDP Review, 2003). A clear statement of support-in-principle for the UDP would at least send appropriate messages to the community, to the Council and to the PRS. With regard to disposing of unsuitable property (to the PRS), the Lobby appreciates the University's consideration of restrictive covenants, and understands the difficulties involved (p15). We hope the University might consider alternatives, such as long leases with conditions (like the Council), to support the Council's and the university's policies to restrain student housing within ASHORE. (Passing reference is made to HMO legislation [p06] - the implications might be elaborated, given the significance of HMO licensing for PRS accommodation.)
4.32 On the other hand, the UDP has also always supported wider dispersal of student housing, and the current Review reinforces this policy. Again, the University is supportive: "Policy H15A is also supported in principle (§1.4)" (UoL, Representations on Leeds UDP Review, 2003). This is not easy to effect. But a lot more could be done to inform students (and the PRS), and thereby to widen the choice of PRS accommodation (not all students want to live in a student ghetto). Section 9 describes Unipol. Its Accommodation Bureau for instance could be far more proactive in promoting Leeds as a whole for accommodation (currently, maps in the Bureau and in published information show only 'The Main Student Areas'). Likewise, Leeds University Union claims to "encourage students to live outside LS6" (p21). But in fact, this year's literature (for the first time) tables pros and cons of living within and without the main student areas, with no indication of where the latter might be (and LUU resists promoting any particular location).

4.4 The Strategy seems based on a misunderstanding of the significance of the University to the community. The community of course appreciates the University's "aim of 'putting something back' into the community" (p05). But none of the measures described, especially in section 8, The University in the community, actually put back what the University has taken out. The Summary rightly identifies the key problem as 'demographic imbalance' (p03). Two consequences follow from this - first, the diversity which enriches a community is lost (more fundamentally, the children who might sustain the community are lost); and secondly, when this imbalance is towards a constantly changing population, the networks which actually constitute a community are lost. This is apparent first of all in the operation of the University in the community. On the whole, there are effectively two parallel operations under way - students are engaged in one, local residents in the other, with very little interaction (the employees of local agencies tend to provide what connection there is). This is not surprising - it reflects the different orientation of the different populations. And then again, the operations are not necessarily relevant. Section 8 notes that 1500 students took part in voluntary projects last session. These of course are very welcome, especially to the beneficiaries. But a great many are not relevant at all to the key problem in and around Headingley. Many do address symptoms of this key problem. Up Your Street (Case Study 1) is an example - it is concerned primarily with the effects which follow from the key problem (issues which wouldn't be there otherwise). But few if any address the key problem itself. A case in point is Royal Park Primary School, mentioned on page 17: this school certainly benefited from mentoring and tutoring; but it is closing down - precisely because of the local demographic imbalance, the absence of schoolchildren. Ironically, the volunteers there were themselves the cause of the problem. Another case in point is crime: it is the very concentration of student housing which attracts a phenomenally high rate of burglary. Efforts towards good community relations (the Community Liaison Officer, the Community Week), efforts to address the effects of imbalance (the Neighbourhood Helpline, Up Your Street) - these are certainly appreciated. But to the local community, they remain marginal, when the community itself is made unsustainable by the impact of student housing.

5 Prospects Leeds HMO Lobby therefore welcomes the Housing Strategy. We look forward to development of its weaker elements. As this happens, its real strengths will clearly make a difference to "the impact which students have on local communities." We share the VC's view of the Strategy's potential significance. This significance will be assessed by what follows. It's clear that housing cannot be isolated from other aspects of the University's presence in Leeds, and it is clear therefore that the University's commitment to liaison is crucial. In this spirit, the Lobby looks forward to further debate with the University, in the appropriate fora, on other routes to addressing adverse impacts.

5.1 Recruitment The Lobby supports the University's commitment to wider participation. We are convinced that local study can make a significant contribution to achieving this (as well as having a wide range of other benefits). We hope our forthcoming Discussion Document Local Study will be helpful.

5.2 Accommodation The biggest problem facing the Housing Strategy is accommodation in the PRS. We hope that the Lobby's Campus by Bus proposal and our new proposal Students in the City can make a contribution to its resolution.

5.3 Discipline The Lobby welcomes the University's commitment to good community relations. Such relations are especially undermined by poor behaviour, usually thoughtless (sometimes not). As a positive contribution towards our mutual objectives, the Lobby has proposed a simple Community Code. To complement this, we hope the University can make its disciplinary processes more transparent.

Leeds HMO Lobby
March 2004

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Leeds HMO Lobby
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