National HMO Lobby


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National HMO Lobby



Sustainable Communities

If the National HMO Lobby resists concentrations of HMOs, this is because of our concern for the sustainability of our communities. (Indeed, sustainability is in the title of some of our members - Sustainable Communities [Scotland], Swansea Sustainable Community Initiative.) Concentrations of HMOs present a unique threat to these communities. They tend not only to have a detrimental impact on the character and amenity of a neighbourhood - they also undermine the very pre-requisite for a sustainable community, which is a balanced and stable population. By their very nature, concentrations of HMOs distort the population balance and introduce a transient population. (For a discussion of the idea of community, see 'Compehending Community'.)

The Lobby therefore welcomes the government's professed commitment to sustainable communities. 'Creating sustainable communities' was adopted as its motto when the Office of the Deputy Prime Minister was established in 2002. Since then, the concept of sustainable community has been explored by ODPM. Sustainable Communities: building for the future was published in February 2003. In February 2004, a consultation was undertaken on Planning Policy Statement 1, Creating Sustainable Communities, followed in April by the Egan Review Skills for Sustainable Communities. Leeds HMO Lobby responded to both of these. (PPS1 has since been published as Delivering Sustainable Development, 2005.) 'Sustainable Communities' is currently defined in Appendix 1 of Sustainable Communities: People, Places & Prosperity (31 January 2005), which is reproduced on the ODPM website. The Lobby has criticised this definition in Students, Communities & Sustainability.

Upon her appointment in May 2005 (following the General Election), the National HMO Lobby wrote to the new Minister for Housing & Planning, Yvette Cooper. Then in July, Leeds HMO Lobby wrote to David Miliband, Minister for Communities & Local Government, on his speech to the Together We Can Conference. In September, David Miliband visited Leeds for a Core Cities summit, and Leeds HMO Lobby took the opportunity to draw local issues to his attention.

In September 2006, the Lobby responded to the DCLG's discussion paper From Decent Homes to Sustainable Communities. In December 2006, Any Reed MP asked a question in the House of Commons about sustainable communities in areas of high density student housing.

In 2012, the National Planning Policy Framework superseded PPS1: at paragraph 50, the NPPF states, "To ... create sustainable, inclusive and mixed communities, local planning authorities should plan for a mix of housing." On 24 July 2012, DEFRA launched an Informal Consultation on Sustainable Development Indicators, one of which concerned Social Capital: "in terms of its importance for sustainable development, social capital is essential for sustainable communities and a strong and cohesive society underpins our economic development and our current and long term wellbeing."

Below may be found -
Our New Minister, representation to Minister Yvette Cooper, 10 May 2005
Building a Modern Social Contract, represemntation to Minister David Miliband, 1 July 2005
Leeds Summit, representation to Minister David Miliband, 15 September 2005
and Re: Leeds Summit, correspondence with, 18 November 2005

Date: 10 May 2005
From: National HMO Lobby
To:, FAO Yvette Cooper

Dear Minister

I am writing on behalf of the National HMO Lobby, first of all to congratulate you on your appointment as Minister for Housing & Planning, and to wish you well in your new post.

Secondly, I write to introduce the National HMO Lobby. I was pleased to meet Keith Hill a year ago, in my capacity as Co-ordinator of the Lobby - I hope in due course I shall have the opportunity to meet you also. The Lobby is an association of over thirty community groups throughout the UK, who are concerned about the detrimental impact of concentrations of HMOs on the sustainability of their communities. Jointly and severally, we have been campaigning for some five years for action to be taken. Information on the Lobby and on its concerns and activities is on our website.

Thirdly, I would just like to identify three issues of particular concern.

# HMOs and HE: the chief cause of concentrations of HMOs is currently the expansion of HE. No provision has been made for the accommodation of increased student numbers, so the lack has been made up by the private rented sector - hence, concentrations of shared student houses, now defined as HMOs. Mr Hill acknowledged this as a key issue, and initiated a project to research the problems and recommend solutions. Dr Darren Smith is due shortly to report. We look forward to the ODPM encouraging both local authorities and universities to act swiftly on his recommendations.

# HMOs and Licensing: one of the main contributions of the last government to tackling the problem was the Housing Act, which introduced licensing of HMOs. We are pleased that larger HMOs are subject to mandatory licensing, though disappointed that licensing was not required of all HMOs (as it is in Scotland). We are urging local authorities to introduce additional HMO licensing where HMOs are concentrated (as in areas of 'studentification'). We hope ODPM will consider such applications favourably and speedily.

# HMOs and Planning: however, HMOs in concentration are of course primarily a planning issue. Local authorities can act only within the powers they have available. All concerned are agreed that the single most useful measure that the government could take to address the problems arising from HMO concentrations would be to introduce planning controls on HMOs - as has been done in Northern Ireland. We were very disappointed that the recent amendment of the Use Classes Order omitted to do so. We urge you to give this matter further and urgent consideration.

We all want our communities to be sustainable. But when HMOs exceed (say) 10% of households, and thereby 20% of the population (as HMOs are disproportionately crowded) - then communities lose balance. The transient population increases, generating social, environmental and economic problems - and the resident population, which normally tackles such problems, declines.

We trust that in pursuit of creating sustainable communities, you will take measures actively to support our beleagured communities.

Best wishes, Dr Richard Tyler, Co-ordinator, National HMO Lobby

The Lobby also wrote in similar vein to David Miliband, the new Minister of Communities & Local Government. No reply was received from either.


Building a Modern Social Contract
Date: 01 July 2005
From: Leeds HMO Lobby

Dear Mr Miliband

In the spirit of Together We Can, I am writing in response to your speech on 'Building a Modern Social Contract' at the launch of the new action plan. I write on behalf of Leeds HMO Lobby to welcome your speech warmly.

Leeds HMO Lobby is an association of community associations working to do exactly what you are advocating, building the sustainability of our communities (do visit our website). As you do in the fifth point in your speech, we emphasise the importance of the community sector. And we agree wholeheartedly with your quote from Jane Jacobs. It's the community which keeps a neighbourhood clean and quiet and safe. If the state has to intervene, it's because the community has failed.

Regrettably, this is the case in the communities in & around Headingley in Leeds. And regrettably too, the failure is actually a direct consequence of government policy. I notice that one department in particular was missing from the Together We Can launch, and that was DfES. It is the enormous recent expansion of HE which is the source of our problems. We fully support access to HE for all those who can benefit. But an enormous price is being paid, not only in Leeds, but in most university towns in the UK (see the National HMO Lobby). The huge influx of students is weakening the sustainability of communities. For understandable reasons, students like to congregate together. But this means that communities are overwhelmed by a population which is young (and inexperienced in social contracts) and which is continually changing. In Headingley for instance, 61% of the population (students) changes every year.

This of course does untold damage to the social networks which Jane Jacobs refers to. We have been working very hard to repair this damage. Leeds City Council has set up a Student Housing Project Group. And I am sure you will be pleased to hear that local residents are in the process of setting up a Headingley Development Trust, just like Turkshead in Wapping.

But there is a good deal the government, and especially ODPM, can do to help us. We are pleased that ODPM initiated Universities UK's research project into students and communities (even the universities recognise there is a problem). We hope you will encourage local authorities to follow the Guidance due to be published in October.

We are pleased too that HMO licensing will help to curtail the worst abuses inflicted on communities by the landlords of student HMOs. We hope ODPM will be sympathetic to university towns who seek additional HMO licensing to help manage their student colonies.

But more than anything, local authorities need powers to manage the market forces which have created these colonies. We were very disappointed that the recent revision of the Use Classes Order did not include any new requirement for planning permission for HMOs (unlike the example set by Northern Ireland). It is this loophole in planning legislation which leaves thriving communities vulnerable to devastation by unrestricted growth of HMOs. In the interest of restoring the social contract in our beleagured communities, we do exhort you to urge your colleague, the Planning Minister, to revisit this legislation.

We hope that together we can (re)build a Modern Social Contract.

Best wishes, (Dr) Richard Tyler, Co-ordinator, Leeds HMO Lobby

No reply was received.


Leeds Summit
From: Leeds HMO Lobby
Date: 15 September 2005

Dear Mr Miliband

I was pleased to meet you at the Core Cities summit in Leeds on Tuesday, 13 September. You will remember that I raised an issue of concern to the grass-roots community in & around Headingley (actually affecting three constituencies in Leeds). I'm writing so that you have the main points on paper (or at least, on file).

The issue is the profound destabilisation of the communities in our area, as a result of their invasion by the private rented sector, especially HMOs. Ironically, this is as a result of the expansion of HE (which you remarked on in your interview with the Yorkshire Evening Post). The effect is that the burglary rate is the highest in the city, the squalor is the worst, and we have the only Cumulative Impact Policy for alcohol licensing outside the city centre. All this is the result of the substitution of a stable local community by a transient HMO population - HMO occupants now outnumber residents. In consequence, Headingley's contribution to the flourishing of Leeds is disabled.

The community does what it can. The 'resident rump' is very active. We are setting up the Headingley Development Trust, as you know. We have produced a 'Headingley Renaissance' strategy. And we are preparing Neighbourhood Design Statements.

The Council is supportive. An Area of Student Housing Restraint is proposed for the Revised UDP. We have successfully applied to ODPM for control of Letting Boards. We hope to apply also for Additional HMO Licensing.

But Government could also help. Community and Council are struggling with one hand tied behind our backs. There is no means of controlling the proliferation of HMOs, the root cause of our problems. What we request is amendment of the Use Classes Order, such that HMOs are realistically defined (as they are in the Housing Act) and that they count as change-of-use, and therefore require planning permission (as in Northern Ireland's Use Classes Order).

As you suggested, I spoke to David Prout, Director of Local Government Policy, who said that our proposal had been "considered and rejected." Well, we know it has been rejected, because it was excluded from the amended UCO earlier this year. But we would dispute that it has been considered. The report on which the amendments were based was mainly concerned with other issues, and gave no serious consideration to problems arising from HMOs. Since then, these have been recognised by ODPM, and a report is in preparation by Universities UK on the problems caused for local communities by student housing.

Alan Simpson MP has recently written to you on this matter (which affects nearly all the Core Cities), and received a reply from Baroness Andrews, which was not all satisfactory. Given your interest in communities, we do urge you not only to consider ways of regenerating failing communities, but also to take action which will enable thriving communities to resist a collapse into unsustainability.

Best wishes, Dr Richard Tyler

PS I attended the summit as representative of Greg Mulholland, MP for Leeds NW. He asked me to attend as I am Co-ordinator of Leeds HMO Lobby, a coalition of local community groups campaigning on this issue, with members in Leeds Central, NW and West. I also co-ordinate the National HMO Lobby, a national alliance of groups with the same concerns. Our website is at

A reply in David Miliband's name was received, but it merely reiterated the provisions of the current Use Classes Order. Leeds HMO Lobby pointed this out, and has received a second response - to which we sent the following reply:

From: Leeds HMO Lobby
Date: 18 November 2005

Dear Mr McKinlay

Thank you for forwarding the letter from David Miliband dated 15 November. I appreciate receiving a second response to my email of 15 September [above].

However, it is not a little frustrating that the Minister's second letter misses the point we wished to raise. First of all, our primary concern is not burglary rates or alcohol licensing (which are outside ODPM's remit) - but with the origins of these problems, concentrations of HMOs. Nor is our primary concern with student numbers or student housing - though these are the main drivers of concentrations of HMOs.

No, our main concern is with concentrations of HMOs themselves. And our original request was "amendment of the Use Classes Order, such that HMOs are realistically defined (as they are in the Housing Act) and that they count as change-of-use, and therefore require planning permission (as in Northern Ireland's Use Classes Order)."

This request is not peculiar to Leeds. Far from 'creating sustainable communities', concentrations of HMOs are in fact destroying the sustainability of communities around the country. This has been recognised as a national issue, for instance in ODPM's own commissioning of research, shortly to be published in Universities UK's Students & Communities Guide. And it is engaging local authorities around the UK, a dozen of which have adopted, or are consulting on, planning policies to control concentrations of HMOs. But these dozen towns are unanimous that their efforts are emasculated by the inadequacy of current planning legislation.

(1) Change of use: it is incontrovertible that HMOs are a quite distinctive use of property. Their usage has four distinctive features. (a) The occupancy of HMOs is intensive, twice that of an ordinary dwelling house. (b) The occupants of HMOs are predominantly from one narrow age range, young adults (students, professionals, claimants). (c) The occupiers of HMOs, by the very fact of multiple occupation, lack the internal government of a single household. (d) The occupation of HMOs is short-term. Collectively, the impact of the use of a property changes radically if it is converted to HMO. These features differentiate HMOs much further from most properties within Use Class C3 (family homes) than other residential uses, like hotels or care homes - which are in different Use Classes.

(2) Definition: there is no difficulty in defining HMOs, in distinguishing them (whether their occupants are students or professionals or claimants) from "a family of six (with four teenagers)". The Housing Act 2004 does so without difficulty, and so does equivalent HMO Licensing legislation in Northern Ireland and Scotland.

(3) Permission: there is no problem in incorporating this definition into planning legislation, by amendment of the Use Classes Order - as has been demonstrated by the recent amendment of the UCO in Northern Ireland. In this respect, far from reducing the burden on local authorities, the current UCO in fact increases those burdens.

To my mind, none of these points have been satisfactorily addressed in either letter from the Minister. The second letter acknowledges that "planning regulations allow a dwelling house to be used as small scale student [or other] accommodation and would not need planning permission, provided that there were six students [or others] or less and living as a single household." In fact, landlords have successfully argued at appeal that larger numbers of students (or others) are also single households. The effect of this is that there are no planning controls on HMOs - therefore no means of controlling concentrations - therefore no means of resisting the destruction of sustainable communities.

If ODPM really wishes to sustain communities, then effective national planning legislation, as we have requested, is essential.

Yours sincerely, Dr Richard Tyler, Leeds HMO Lobby (and also, National HMO Lobby)

On 21 November, David McKinlay (Customer Liaison Unit, ODPM) replied as follows: 'Dear Dr Tyler, Thank you for your further email dated 18 November. As David Miliband has explained in his previous correspondence, we do not think it is appropriate to amend the UCO with regard to HMOs. I appreciate that this is not the response you were hoping for, but there is nothing further we feel we can add.'

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