National HMO Lobby


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National HMO Lobby



From Decent Homes to Sustainable Communities

1. The National HMO Lobby is a network of forty community groups in thirty towns throughout the UK. Its concern is specifically with HMOs (houses in multiple occupation) in housing supply, and especially with addressing the problems these pose for local communities. To this end, while its members campaign locally, the Lobby itself campaigns nationally. We have made representations on the Housing Green Paper Quality & Choice (DETR, 2000), Modernising the Private Rented Sector (Shelter Commission, 2001), Selective Licensing of Private Landlords (DTLR, 2001), Use Classes Order (DTLR, 2002), Planning Policy Statement 1, Creating Sustainable Communities (Minister for Planning, 2004), Housing Bill (representations, 2004), Consultation on the Implementation of HMO Licensing (ODPM, 2005), Householder Consents (ODPM, 2005), Affordability & the Supply of Housing (Commons Select Committee, 2005) and so on. And our lobbying was instrumental in initiating Universities UK’s report on Studentification (2006). On this basis, the Lobby wishes to respond with three main points to DCLG’s discussion paper From Decent Homes to Sustainable Communities – first, on the usage of existing housing stock for decent homes; second, on the pre-requisites for sustainable communities; and third, on integrated ways of approaching both these issues. [For more information on the Lobby, visit our website.]

2. First of all, the National HMO Lobby wishes to raise the issue of second homes. More new homes are certainly necessary – but surely the existing stock should be used as justly as possible? To our mind it seems little short of criminal that there are people who are homeless, families who are overcrowded, households anxious to establish their own homes – when others enjoy the luxury of not only a secure home, but also an additional second home which they can also enjoy at their whim. Second homes take a variety of forms. Best-known of course is the town-dweller who buys a country cottage as an occasional weekend or holiday retreat. But a recent report by Direct Line has drawn attention to student second homes also, where parents buy a house in a university town for use by their children in term-time [reverse holiday-homes] (1). In many cases, both types of second home are bought directly by the users. But the burgeoning buy-to-let market, not to mention the professional private rented sector, has taken advantage of both of these sources of demand. Of course, much of the PRS serves a genuine temporary need, for those moving from the family home to their own home, or from one place of work to another. The PRS also serves those who can’t afford to buy. But to some degree, this is a vicious circle - would-be owners are outbid by property investors. This is especially invidious when investment properties are let as second homes, to holidaymakers or to students. (For these markets, there are perfectly viable alternatives, in the form of purpose-built development, hotels or halls.) The numbers of houses from existing stock lost to second homes runs into the millions. Answers are needed.

3. Secondly, the National HMO Lobby wishes to interrogate the DCLG’s concept of sustainable community. The Department’s website provides short, medium and long definitions of ‘sustainable community’, but all are based on eight elements - Active, inclusive & safe, Well run, Environmentally sensitive, Well-designed and built, Well-connected, Thriving, Well-served, and Fair for everyone. The Lobby has no problem with the validity of these elements. All appear to us to be necessary to sustaining a community. But neither separately nor indeed collectively are they sufficient. Above all, obviously, a community rests on its population base. It is that population which makes the community harmonious, or the environment green, or the neighbourhood attractive, and so on. What this means is that a sustainable community is absolutely dependent on a population base which is both willing and able to do these things. Lacking this base, no amount of external intervention will achieve any of the necessary elements. The discussion paper refers to polarisation as undermining sustainability (paragraph 4, page 4). This can mean both division and one-sidedness. It can be between exclusive (privileged) and excluded (deprived) neighbourhoods (2). Deprivation may undermine the ability of a resident population to sustain the community. But at the same time, transience may undermine the will of a population to be bothered at all about sustainability. So, any conception of a ‘sustainable community’ needs the pre-requisite of a willing and able population. Deprivation and transience often (not always) go hand in hand (3). Answers here too are needed.

4. Finally, the National HMO Lobby wishes to point out one measure which would contribute at least part of an answer to these issues concerning both decent homes and sustainable communities. The measure centres on the role of HMOs. On the one hand, a significant proportion of second homes (no longer available as decent homes) are student houses. Virtually all of these are shared houses, and therefore fall within the definition of HMO newly provided by the Housing Act 2004. On the other hand, a significant factor in transience (undermining sustainable communities) is the private rented sector. Turnover of occupants is highest in this housing sector (the average tenancy is eighteen months), and it is highest of all in HMOs. They have their uses for short-term accommodation, but very few would care to reside for long in a HMO. The new Housing Act provides for licensing of HMOs (mandatory licensing of larger and less safe HMOs, potential additional licensing of others), but these controls are in the interest of the welfare of the tenants. They are concerned with quality, not quantity. But it is quantities which need to be managed, if houses are not to be lost as decent homes, and if sustainable communities are not to be lost to transience. Proliferation of HMOs is a matter of planning (not housing) control. But no controls are available in English planning legislation. The relevant Statutory Instrument is the Use Classes Order (specifically the Town & Country Planning (Use Classes) Order 1987 [SI 1987 764]). But HMOs are not identified there as a distinct usage, and so there is no planning control of HMOs. As part of an answer to achieving decent homes and sustainable communities, the National HMO Lobby proposes revision of the Use Classes Order, such that (a) a common definition of HMO is adopted in both housing and planning legislation, and (b) change of use to HMO becomes subject to planning permission. (Both these steps have been taken in Northern Ireland’s Planning [Use Classes] Order [Northern Ireland] 2004 [Statutory Rule 2004 458].) Such revision would enable local authorities to control proliferations of HMOs.

5. The National HMO Lobby recognises that From Decent Homes to Sustainable Communities is a discussion paper on housing, whilst our proposals concern planning. But too often, a failure to resolve a problem adequately arises from ‘silo thinking’ – that is, considering a problem defined in one set of terms within that set of terms only – rather that thinking ‘outside the box [or silo]’, to seek other solutions. The National HMO Lobby urges the Department for Communities & Local Government, which after all comprises both housing and planning, to consider a planning contribution to the move from Decent Homes to Sustainable Communities.

National HMO Lobby, September 2006

(1) Reported by the Press Association, 7 August 2006, Second Homes for Students: “Around 83,000 homes were bought on behalf of students by last year, a 26% increase since 2000, according to the study by finance firm Direct Line. The number of houses occupied by students was predicted to reach 100,000 by the year 2010. The so-called university effect helped increase the number of "second properties" to 2.6 million, up from 2.3 million five years ago. Around 1.6 million of the second properties were buy-to-let, while others included holiday homes and work bases.” In Leeds, for instance, there are currently 500 homeless families and 5000 overcrowded (according to Shelter), while the Council estimates that over 5000 homes have been converted to student HMOs.
(2) See Anna Minton, Building Balanced Communities, RICS, 2002
(3) See Nick Bailey, Population turnover & area deprivation, JRF, forthcoming, September 2006


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