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Concentrations of houses in multiple occupation (HMOs) have a detrimental impact on the character and amenity, indeed the sustainability, of neighbourhoods in many towns in the UK. The activities nationally of the National HMO Lobby to address these impacts are documented on other pages of the website. Meanwhile, frequently in response to local campaigns by our members, local planning authorities (LPAs) around the country have developed local HMO plans – either to address the problem of concentrations of HMOs in general, or more particularly, their principal cause, the demand for student housing.

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Many authorities already had generic policies, either on HMOs, or on student accommodation, or both (Bath is a case in point). Nevertheless the development of concentrations of HMOs has revealed the inadequacy of such policies.

Accordingly (belatedly), many LPAs have developed more proactive policies, specific and targeted. Some have been developed under the current planning regime of Local Plans and Unitary Development Plans (UDPs), and a few are adopted. But many LPAs are taking advantage of the new regime of Local Development Frameworks (LDFs). Some policies take the form of Development Plan Documents (DPDs), which carry greater weight, but take a long time to adopt; other policies are being introduced as Supplementary Planning Documents (SPDs), which are quicker but less weighty. All of these are currently under consultation.

The policies developed so far are of three broad kinds. (1) One of these is Areas of Restraint: here, an area within the authority is designated, and within that area, restraints are imposed on certain forms of development. In most cases, the restraint is on student housing (hence, ASHORE, or Area of Student Housing Restraint), including both purpose-built accommodation and student houses. This approach was pioneered in Birmingham, and is being followed in Leeds, Sheffield and Newcastle. However, in Oxford, the restraint is on HMOs.

The Inspector's Report on the Leeds UDP Review has rejected its ASHORE proposal, suggesting instead an 'Area of Housing Mix'.

(2) Another kind of policy is the Threshold Approach: here, a ceiling is set, beyond which certain forms of development are not permitted. There are two variants, the Scottish and the English. The Scottish version might be called the ‘blanket’ approach: a ceiling is set which applies to every street within the authority; this was pioneered by Glasgow, and is being followed by Fife. Normally, no more than 5% of the properties in any street may be HMOs. The English version might be called the ‘rolling’ approach. This approach is pioneered by Loughborough: development proposals for student housing are considered individually, and permitted only if such developments are below a set percentage of properties in the neighbourhood. This approach is also being followed by Sheffield, but here it applies to HMOs.

[In the case of the Threshold Approach, it is important to bear in mind the distinction between the percentage of properties and the percentage of the population. The average occupancy of HMOs is twice that of the average household (which is 2.4, see ODPM, Survey of English Housing 2003-04). Thus, in an area where 10% of the properties are HMOs, in fact 18% of the population will be HMO occupants. The National HMO Lobby identifies 10% of properties or 20% of the population as the ‘tipping-point’ for studentification or other HMO-dominance in a neighbourhood.]

A number of observations may be made about both Areas of Restraint and the Threshold Approach. First of all, there is an argument to be made that in both cases, the restraint or prohibition is better applied to HMOs, rather than to student houses (hence, AMOR or Area of Multiple Occupancy Restraint). Problems arise from concentrations of HMOs because their tenants are transient – and this is true of all HMOs, whether their tenants are students or benefit claimants or young professionals. Again, definition of ‘student’ is problematic in various respects; and though the definition of HMO is problematic in planning legislation, the Housing Act 2004 does provide a realistic definition (as does the equivalent legislation in Northern Ireland and in Scotland). Prohibitions on student housing can be misrepresented as discriminatory. And HMOs are easier to monitor (especially with HMO licensing). A second point to be made is that restraint should be applied, not only to new HMOs, but also to any development which increases the capacity of existing HMOs. And a final point to consider is invoking the definition of HMO in housing legislation for the purposes of the Area of Restraint or the Threshold policy.

(3) A third kind of policy developed by LPAs is Purpose-Built Development: here, areas within the authority are designated for the development of purpose-built accommodation for students. Since demand by students (rather than claimants or professionals) is the main driver of concentrations of HMOs, this policy addresses the cause of the problems arising. This policy is being followed by Newcastle, for instance.

Such policies are strongly promoted, but they are not unproblematic. The siting of purpose-built development is an essential consideration. Purpose-Built Development in the wrong place (within areas of concentration) can exacerbate the situation; and insensitively sited, can actually generate new problems. First of all, the key problem is not the HMOs themselves (though conversion of family homes is of course a serious problem in itself) – rather, the key problem is the demographic imbalance (which generates social, economic and environmental problems, and undermines the community’s capacity to tackle these problems). Purpose-Built Development contributes to this as much as (if not more than) HMO conversions. Secondly, Purpose-Built Development attracts additional HMO conversions – on the one hand, students leaving the accommodation look for housing in the familiarity of the surrounding neighbourhood; and on the other, their friends (not in the accommodation) look for housing nearby. Finally, Purpose-Built Developments are actually a deterrent to the rebalancing of a community by the immigration of long-term residents, especially families. [In Leeds, for instance, Kirkstall Brewery and Sugarwell Court have been developed as purpose-built residences outside the main student colony – and both have attracted their own local colonies.]

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All of these policies are necessary, none on its own is sufficient. Areas of Restraint address concentrations themselves. The Threshold Approach tackles developing concentrations. Purpose-built Development is designed to deflate their causes. Therefore, in order to address the impacts of concentrations of HMOs comprehensively, the National HMO Lobby recommends –
# that LPAs with concentrations of HMOs develop local HMO plans which are proactive, specific and targeted;
# that LPAs consider local HMO plans which comprise a three-fold strategy, including Areas of Restraint and a Threshold Approach and Purpose-Built Development, as complementary policies (as Sheffield proposes);
# that in all of these policies, LPAs take account of the problematic issues raised by each.

Regrettably, all local HMO plans continue to be hamstrung by the inadequacy of planning legislation in relation to HMOs, specifically the Use Classes Order (except in Northern Ireland).

LOCAL HMO PLANS AUTUMN 2005 [partially updated, Spring 2007]

ENGLAND
Bath & North East Somerset Local Plan Revised Deposit 2003 (Policy HG.12 Development for the use of buildings for residential purposes; and Policy HG.17 Development of student accommodation)

Birmingham City Council Selly Oak Local Plan Policy 11.22 'Area of Restraint (Student Accommodation)' adopted 2001

City of Durham LDF, Housing Development Plan Document (Issue 8, Provision of Balanced Communities) 2005, consulting

Leeds City Council, Leeds UDP Review, Policy H15 ‘Area of Housing Mix’, adopted 19 July 2006

North East Lincolnshire Council, SPG02 Conversion of Properties to Flats and Houses in Multiple Occupation, adopted 2002

Loughborough Charnwood LDF, Student Housing Provision in Loughborough SPD, 2005, consulting

Thanet District Council, Margate Cliftonville West Renewal Area: HMO consultation, October 2006

Newcastle City Council, Local Development Framework Supplementary Planning Document on Shared Housing, February 2008; Interim Planning Guidance on Purpose Built Student Accommodation, November 2007

Nottingham City Council, Building Balanced Communities, SPD, adopted March 2006, re-issued March 2007

Oxford City Council, Oxford Local Plan: Section 7 Housing Policies (Policies HS.13-HS.15) adopted 2005

Reading Borough Council, Supplementary Planning Guidance House Conversions & Houses in Multiple Occupation adopted 22 September 2003

Sheffield City Council, Sheffield Development Framework, Core Strategy: Housing Strategy (Issue H6 Student Housing), 2005, consulting

City of York Local Plan, Chapter 7 Housing (Policy H8 Conversions) approved by Council 2005

NORTHERN IRELAND
Belfast Planning Service (NI) Houses in Multiple Occupation (HMOs): Subject Plan for Belfast City Council Area 2015 adopted 15 December 2008

Coleraine Planning Service (NI) Coleraine Borough HMO Subject Plan 2016: Issues paper April 2006, consulting

SCOTLAND
Dundee City Council, Supplementary Planning Guidance Houses in Multiple Occupation November 2006

Glasgow City Council City Plan Policy RES 13 'Multiple Occupancy' adopted 2004; City Plan 2 Consultative Draft March 2006 reviews Policy RES 13

St Andrews Fife Council Fife Development Plan Policy H6 'Houses in Multiple Occupation', 2005, consulting

National HMO Lobby
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