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HMO SUBJECT PLAN FOR BELFAST
Thirty Three Theses
Introduction
(pp1-2)
#01 Concentrations of HMOs cause profound social damage.
The Issues Paper on the HMO
Subject Plan for Belfast does not recognise the social impact
of HMOs. Their occupants are overwhelmingly transient. In concentrations,
therefore, a transient population replaces a stable population. The
community is thereby decimated, its social networks are disrupted,
and its members are profoundly demoralised. This is the most important
reason to resist concentrations of HMOs. (See also #22 and #24.)
#02 The Issues Paper is responsive to public consultation.
It is encouraging that initial proposals (Policy HOU6 of BMAP),
when found to be insufficient, have been succeeded by a much more
comprehensive consultation. We trust that this will be as responsive.
#03 A spatial dimension is essential to address the issue
of concentrations of HMOs. Policies addressed towards individual
HMOs, piecemeal, are inadequate. Individual HMOs are always problematic.
But it is concentrations of HMOs, their distribution as
a whole, which cause real social problems.
#04 A coherent planning & housing approach to control
of HMOs, with powers, is essential. The use of the same
definition of HMO in both planning and housing legislation is obvious
– but in this respect, Northern Ireland is the envy of the
rest of the UK. Furthermore, uniquely in the UK, NI subjects HMOs
to effective planning control through the Use Classes Order.
#05 Partnership is essential to the management of concentrations
of HMOs. Numerous institutions are responsible for the
rise of HMOs (e.g. HEIs), for their control (e.g. planning/housing
services) and for responding to their effects (police, environmental
services). The Inter-Agency Strategy Group is an invaluable initiative.
#06 Representation of communities affected by concentrations
of HMOs is essential. No-one is better acquainted with
the impact of HMOs than those affected, and none has a stronger
motive to address the issue. Local communities therefore should
be formally represented at the Inter-Agency Strategy Group.
#07 The importance of the issue of HMOs for individuals,
for communities, and for the City, should be acknowledged.
The Chairing of the Inter-Agency Strategy Group by Belfast City
Council’s CEO is an invaluable demonstration of its status.
#08 The HMO Subject Plan must be not only comprehensive,
but also prioritised. The purpose of the Plan, as stated,
is welcome, including both the management of HMOs, and of their
impacts. But it is important (a) to distinguish these two aspects
of the issue, and (b) to prioritise the former. (The impacts matter:
but it is too easy to be diverted into reactive measures, to the
neglect of proactive controls of HMOs.)
Policy Context (p3)
#09 Sustainability is crucial to well-being. Sustainability
more than anything defines a community (whatever else it is, a community
is a group of people able to maintain itself through time). And
it is the community (and in the end, only the community) which promotes
well-being, and keeps a neighbourhood clean and quiet and safe.
Concentrations of HMOs are anathema to sustainability, as their
occupants are inherently transient.
#10 Balance is fundamental to sustainability. In
a locality, the community (and hence, sustainability) is strengthened
by social diversity, and weakened by social domination. (A ghetto
is a biased community.)
Trends (p4)
#11 The Private Rented Sector (PRS) is inherently transient.
It is important to recognise that the PRS is the vehicle for social
mobility. In England, for instance, this housing sector (only 10%
of the whole) now accounts for over half of all moves (into, within
or from the PRS), 45% of all new households, and the average length
of stay was only eighteenth months (Survey of English Housing, 2003).
A community can accommodate a proportion of privately-rented accommodation
(indeed, an element is essential), but too much kills the community.
#12 Student demand must be documented. Students
are a principal market for HMOs, and a principal cause of concentrations.
Data on their numbers, distribution and proportion, past and projected,
is essential for effective management.
Issue 1, Housing Needs (p5)
#13 What is the likely future need for HMO
accommodation? The demand for HMOs needs to be radically
re-assessed. In an era of housing shortage, the conversion
of family homes into HMOs is an abuse of the housing stock. The
government has identified three main markets for HMOs, but all would
be better met by alternative provision. (a) Vulnerable claimants
would be better accommodated in social housing than left to the
mercies of the PRS. (b) Students effectively use HMOs as
second homes, and would be better housed in purpose-built accommodation.
(c) Young professionals make use of HMOs as short-term
accommodation: again, their needs would be better met by purpose-built
apartments.
#14 What role can HMOs play in regeneration?
The contribution of HMOs to regeneration is questionable at best.
Areas in need of regeneration need committed communities (see #09
above). HMOs however are inherently transient (see #11 above).
Issue 2, Spatial Policy
(p6)
#15 Should future HMO development be concentrated
or dispersed? No concentrations of HMOs should be allowed
to develop. If concentrations of HMOs develop, the community
becomes unbalanced (dominated by a young and transient population).
An unbalanced community is an unsustainable community. Any future
HMO development should be dispersed. (The ASHORE policy in Leeds
proposes dispersal.)
#16 What criteria should be applied in identifying
areas where further HMO development may be restricted?
HMO occupants (like any other social segment) should not exceed
20% of the population. 20% has been identified as the ‘tipping-point’
by the National HMO Lobby. Any social group (e.g. children, pensioners
– normally 20% each of the population) which exceeds this
proportion is perceived to become dominant (and in fact increasingly
distorts amenities, facilities, services, etc). (See also #21.)
#17 Should the HMO Subject Plan include policies
to control HMO development outside those areas where HMOs are concentrated?
The HMO Subject Plan should control all HMO development.
If HMO demand continues to increase, and if existing concentrations
are constrained (and especially if they are reduced), then controls
will be necessary to prevent new concentrations emerging.
#18 Should a percentage limit be introduced
on the proportion of HMOs in certain areas? A cap of
10% should be set for the number of HMOs in any area. The
average occupancy of HMOs (4-5) is twice that of the average household
(2.3). 10% of properties therefore, on average, represents 18% of
the population – which approaches the ‘tipping-point’
(#16 above).
#19 Are there other means by which the Plan
could address spatial policy issues? The distribution
of HMOs could be managed by means of Registration. The
number of registrations of HMOs allowed in any street could be limited
to no more than 10% of properties. Where HMOs exceed this proportion
at present, their numbers could be reduced by a policy of non-renewal
of registrations, until the target cap is achieved.
#20 Should planning policy seek to control
flat or apartment development in those areas where there is a high
concentration of HMOs? The development of flats should
be controlled. The main problem of HMOs is not the HMOs
themselves, but the transience of their occupants. All forms of
the PRS accommodate a transient population (#11 above). Flats and
apartments are not necessarily rented, but they commonly are, especially
in HMO areas. As such therefore they contribute to the dominance
of a transient population, and their development should also be
controlled.
Issue 3, Balanced Communities(p6)
#21 A balanced community is one that approximates national
demographic norms. A community “that is not dominated
by one particular household type, size or tenure” would comprise
(say) one-third each of owner-occupation, social renting and private
renting. This however would be a peculiar community when in the
UK now, the normal proportion is 70% owner-occupation, 20% social
renting and 10% private renting. By the same token, the normal proportion
of young adults (15-30) in a community is 20%; and the turnover
of population is under 10% per annum. Any community which exceeds
such norms becomes unbalanced.
#22 Concentration of HMOs damages not only the balance,
but also the sustainability of host communities. Residents
do not only feel marginalised, with a poorer quality of
life, where HMOs are concentrated. In fact they are marginalised
as their numbers are reduced (and they may well be outnumbered by
the transient HMO population) – this means fewer older people
to preserve the community’s past history, fewer adults to
campaign in its present interest, and fewer children to maintain
it in the future. Attenuated numbers means broken social networks,
the life-blood of communities, as residents are replaced by absentee
owners and occupiers. The breadth and depth of such changes generates
profound demoralisation. (See also #01 above and #24 beloiw.)
#23 In what ways can the Plan promote more
balanced communities in areas where HMOs are concentrated?
Balanced communities can be promoted by restraint, reorientation
and revival where HMOs have concentrated. Further development
of HMOs in areas of concentration must be unequivocally restrained
(e.g. by planning controls). Demand for HMOs, from whatever source,
must be re-orientated to other parts of the city (e.g.
by development of purpose-built accommodation). Diversity of provision
in HMO areas must be revived, in order to re-balance the
community (e.g. by registration controls, and by the use of Special
Purpose Vehicles in order to reclaim HMOs for family accommodation).
(Leeds City Council’s ASHORE policy [Area of Student Housing
Restraint] implements the first two of these.)
Issue 4, Area Amenity (p6)
#24 Transience is the key issue where HMOs concentrate.
HMO accommodation is not “often characterised by
short-term tenancies” but normally characterised
thus (see #11). High turnover means loss of commitment to the area’s
amenity. It also means loss of the very community which would otherwise
tackle amenity problems.
#25 How can the negative impact of HMOs on
the physical appearance of an area be reduced? In the
end, the only way in which their negative impact can be reduced
is by the reduction of HMOs themselves.
#26 What can planning policies do to encourage
owners, landlords, agents and short-term residents to address the
issues that can damage an area’s amenity? Some
planning policies can address amenity issues, but they must be augmented
by other policies. Conservation Area status might be used
to protect an area’s character; an alternative might be the
adoption of Neighbourhood Design Statements (adapted from the Countryside
Agency’s Village Design Statements). Otherwise, accreditation
schemes can go some way towards tackling social and environmental
issues. ANUK’s model codes, for both landlords and tenants,
include clauses on management of the appearance of properties and
of the behaviour of tenants.
Issue 5, Physical Infrastructure
(p7)
#27 What alternatives are there to the provision
of parking in HMO areas? Sustainable transport provision
could help to reduce demand for parking.
#28 Should consideration be given to ‘Residents
Only’ parking schemes in certain HMO areas? Parking
schemes should be considered for all areas afflicted by HMOs.
Since HMO occupancy is double the norm (see #18), demand for parking
per household is higher (student household demand is two-and-a-half
times the average in Leeds). (In England, many HMOs are exempt from
Council Tax: free permits might be issued to Council Tax households,
while all other permits carry a high charge.)
Issue 6, Anti-social Behaviour
(p7)
#29 ASB associated with HMOs is offensive and hazardous
in many ways. The Issues Paper does not mention one of
the most offensive forms of ASB, what may be called ‘evacuation’
– comprising vomit, urination and defecation.
#30 Are there any particular ways in which
the built environment contributes to ASB in HMO areas?
It is the tenure of HMOs, not the buildings, which contributes to
ASB. The occupancy of HMOs demonstrates a number of characteristics,
all of which facilitate ASB. (1) The occupancy is very
intensive; (2) the occupants are overwhelmingly young adults;
(3) the occupiers lack internal government (unlike a family);
(4) the occupation is transient (discouraging respect for
the neighbourhood).
#31 Are there any ways in which the planning
system can help reduce ASB in areas where HMOs are concentrated?
The way to reduce ASB is to reduce concentrations of HMOs.
Issue 7, Area Management
(p7)
#32 How can management be improved in areas
where HMOs are concentrated? Management in areas of
HMO concentration needs status, direction and resources. (1)
The importance of HMO area management should be demonstrated by
high-status leadership. (2) HMO area management should be directed
by a clear agenda, spelled out in an Action Plan. (3) The implementation
of HMO area management should be resourced by dedicated officer
support.
#33 Are there any additional measures that
could be implemented within HMO areas? The agenda of
HMO area management should follow a clear Action Plan. A
HMO Area Action Plan could comprise a wide range of measures.
(1) Measurable targets should be agreed, and regular monitoring
undertaken.
(2) Measures to restrain HMOs should be adopted (e.g. planning
and registration control, like ASHORE).
(3) HMO demand should be reoriented (e.g. by purpose-built
accommodation, as in ASHORE).
(4) An ‘exit strategy’ should be introduced for the
revival of HMO areas (intervention into the housing market).
(5) All stakeholders should co-operate to address the impact
of HMOs (especially through communication and codes of behaviour).
(6) Social impacts should be addressed (e.g. through explicit
disciplinary procedures).
(7) Environmental impacts should be addressed (e.g. control
of Letting Boards).
(8) Economic impacts should be addressed (e.g. planning
and licensing restraint of the ‘resort economy’).
(9) Action elsewhere should be monitored (e.g. the forthcoming
Universities UK guide on students and communities).
Dr Richard Tyler, Co-ordinator, National HMO Lobby, September 2005
National HMO Lobby
email: hmolobby@hotmail.com
website: www.hmolobby.org.uk
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