National HMO Lobby


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Students & Community

National HMO Lobby



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


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