Consultation on HMOs

The local planning policy on HMOs – Houses of Multiple Occupation – (Supplementary Planning Document or SPD) is currently being reviewed by B&NES for effectiveness and impact.  Our response is as follows:

Response to consultation on HMO SPD review May 2017

The understanding and resolution of the ongoing issue of housing availability in Bath and the particular challenges faced by the city in terms of physical and environmental constraints, land values and conflict in development/supply priorities is of paramount importance to the stable and successful future of the city.

The housing supply issues presented by our expanding universities is a nettle that must be grasped in the upcoming Core Strategy review. However, student housing should not be considered in isolation. Housing supply is also curtailed by the growth in holiday let/ AirBnB accommodation and these should also be covered by an Article 4 SPD as soon as possible. Our starting position on this is that B&NES should allocate more resources to this issue in order to tighten up the data held for this sector and to discover’ hidden’ data to give a more accurate picture of the actual HMO densities within Bath and the people who reside in them. In the meantime we are pleased to respond to the questions raised in the informal consultation.

  1. Should the threshold be maintained as 25% or be lowered to 20%, 15% or 10%?

 

BPT believes the threshold should be lowered to 10%. This would encourage a much greater spread of HMOs across the city, resulting in less ‘studentification’ in specific areas, and appropriately balanced and mixed local communities. In many cases the proliferation of HMOs directly relate to housing prices in conjunction with transport links, but we would assert that all areas of Bath are adequately serviced by public transport and that no given area is any less or any more appropriate as an area for HMOs.  The ‘tipping point’ where communities become unbalanced in favour of a particular community group is widely acknowledged to be 10% or where the per head density is over 20%[1].

Based on the ARUP report there is a projected need for over 1000 new HMOs (equating to over 4,000 bedspaces) in Bath to 2029 (based on no new PBSA’s coming forward).  This projected need is ample evidence that a much greater scattered spread of HMOs and a much lower overall student density in specific areas would be the best option for the future health of the city’s housing stock and the vitality, vibrancy and diversity of local communities. Should already concentrated areas shown on the maps for 20% and 15% density be allowed to increase to 25% then over a third of Bath’s suburbs would reach the tipping point and be unbalanced in favour of students.

With regards to the Stage 1 and 2 tests, we note the Oxford City model which uses street by street analysis to determine applications (i.e for Oxford the HMO is only permitted if there are no more than 20% of HMOs in the street 100m each side of the application property) which is similar to our own Stage 2 test. This approach would be highly responsive to local demographics; in some cases ‘blanket’ area thresholds could result in some HMO free streets where capacity for an HMO exists even though the overall area is concentrated. We suggest that this approach be considered as our Stage 1 test (rather than the current Stage 1 ‘blanket’ area), negating the need for Stage 2 test though we appreciate that this would require extra resources and time from B&NES to manage a locally responsive scheme.

A locally responsive approach could also allow the consideration of ‘lower tier’ place-making and community criteria, for example car parking (already in place) and proximity of proposed new HMOs to family friendly facilities e.g primary schools, nurseries and children’s play areas (where the HMO would preclude a family use for the dwelling). In any case we would recommend that these types of considerations are included in the new SPD.

 

  • Do you agree to introduce the sandwich HMO policy? Why?

 

BPT supports this policy, it makes sense in the name of balanced local communities for HMOs to be scattered amongst streets rather than taking up sections of them.

  • Is there a convincing case for any of the above options to be pursued as well or instead of the 2 above?

 

Yes. We strongly recommend that PBSA accommodation is included in the overall threshold calculations. The influx of students to an area results in changes to local demographics and they will use local services and transport. If the HMO policy’s primary aim seeks to create balanced communities without undue concentrations of different groups of people, then students should be counted in their entirety, whether residing in an HMO or in PBSA. For example, the recent application at the Wansdyke Business Centre for student accommodation would equate to a further 30 HMOs in this area that is already at the 25%+ concentration.

We accept that this issue is part of wider review in the Core Strategy, but we see the general issue of PBSA and its impact on the housing supply in Bath to be of great importance. In particular we will continue to draw attention to the question of whether PBSA’s are actually contributing meaningfully  towards reducing student housing needs in the city, given that they generally are priced way above a normal student budget and market themselves as exclusive and for the luxury post grad or foreign market. We also note that a significant proportion of the Green Park block has been occupied for several months by people working on the Apex Hotel and we regard such private sector lettings in a PBSA as against both the letter and the spirit of their planning status.

Of course when one talks of HMOs one generally thinks of students, but there is a group also affected by this SPD; young professionals. Part of the reason BPT usually objects to PBSA’s on sustainable city centre or close centre sites is that we see these sites as having potential to contribute to housing for younger workers and flat sharers, and as Bath develops the Riverside business district, the need for housing for key workers (who have been priced out of the house buying market) will become even more urgent.  It is these issues and more that must be thoroughly grasped, researched and addressed within the upcoming Core Strategy Review.

We also support the consideration of ideas contained in 5.4.5 of the Arup report relating to site allocation for PBSA’s (though a better phasing for this would be; ‘areas within which PBSAs are likely to be acceptable’ rather ‘site allocations’) and 5.4.3 relating to further exploration of the Local Plan policies to mitigate impacts of university growth on the wider city.

With regards to the Stage 1 and 2 tests, we note the Oxford City model which uses street by street analysis to determine applications (i.e for Oxford the HMO is only permitted if there are no more than 20% of HMOs in the street 100m each side of the application property) which is similar to our own Stage 2 test. This approach would be highly responsive to local demographics; in some cases ‘blanket’ area thresholds could result in some HMO free streets where capacity for an HMO exists even though the overall area is concentrated. We suggest that this approach be considered as our Stage 1 test (rather than the current Stage 1 ‘blanket’ area), negating the need for Stage 2 test though we appreciate that this would require extra resources and time from B&NES to manage a locally responsive scheme.

A locally responsive approach could also allow the consideration of ‘lower tier’ place-making and community criteria, for example car parking (already in place) and proximity of proposed new HMOs to family friendly facilities e.g primary schools, nurseries and children’s play areas (where the HMO would preclude a family use for the dwelling). In any case we would recommend that these types of considerations are included in the new SPD.

 

  • Do you agree to introduce the sandwich HMO policy? Why?

 

BPT supports this policy, it makes sense in the name of balanced local communities for HMOs to be scattered amongst streets rather than taking up sections of them.

  • Is there a convincing case for any of the above options to be pursued as well or instead of the 2 above?

 

Yes. We strongly recommend that PBSA accommodation is included in the overall threshold calculations. The influx of students to an area results in changes to local demographics and they will use local services and transport. If the HMO policy’s primary aim seeks to create balanced communities without undue concentrations of different groups of people, then students should be counted in their entirety, whether residing in an HMO or in PBSA. For example, the recent application at the Wansdyke Business Centre for student accommodation would equate to a further 30 HMOs in this area that is already at the 25%+ concentration.

We accept that this issue is part of wider review in the Core Strategy, but we see the general issue of PBSA and its impact on the housing supply in Bath to be of great importance. In particular we will continue to draw attention to the question of whether PBSA’s are actually contributing meaningfully  towards reducing student housing needs in the city, given that they generally are priced way above a normal student budget and market themselves as exclusive and for the luxury post grad or foreign market. We also note that a significant proportion of the Green Park block has been occupied for several months by people working on the Apex Hotel and we regard such private sector lettings in a PBSA as against both the letter and the spirit of their planning status.

Of course when one talks of HMOs one generally thinks of students, but there is a group also affected by this SPD; young professionals. Part of the reason BPT usually objects to PBSA’s on sustainable city centre or close centre sites is that we see these sites as having potential to contribute to housing for younger workers and flat sharers, and as Bath develops the Riverside business district, the need for housing for key workers (who have been priced out of the house buying market) will become even more urgent.  It is these issues and more that must be thoroughly grasped, researched and addressed within the upcoming Core Strategy Review.

We also support the consideration of ideas contained in 5.4.5 of the Arup report relating to site allocation for PBSA’s (though a better phasing for this would be; ‘areas within which PBSAs are likely to be acceptable’ rather ‘site allocations’) and 5.4.3 relating to further exploration of the Local Plan policies to mitigate impacts of university growth on the wider city.

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