Action for Balanced Communities (ABC) will be asking questions and making a statement about the Houses of Multiple Occupation (HMOs) supplementary planning document (SPD) at the Communities Scrutiny Committee meeting on 7th December (see below).
This policy is will be VERY important for Totterdown as the University of Bristol campus is developed at Temple Meads.
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There is a Communities Scrutiny Committee that is looking at the HMO SPD, and the links between licensing and planning permission that sits on the 7th December (Information can be found here – the HMO Scrutiny Report can be found at Agenda Item 9).
You are able to ask questions of the Committee, which must be submitted by 5pm on 1st December, or make a statement/petition, but this must be done by 12pm on 4th Dec. Please note that the role of the Communities Scrutiny Commission is the overview and scrutiny of matters that affect Bristol communities, including housing, citizens’ services, crime and disorder (including the statutory scrutiny function), recycling, waste and environmental issues, parks, libraries, sport and leisure, and neighbourhoods.
A representative of ABC intends to both ask questions, and make a statement on behalf of ABC Bristol in strong support of the HMO SPD and HMO licensing enforcement, and the positive impact it will have on communities across Bristol where an Article 4 direction is in place, and additionally the positive impact on living conditions for those within HMOs. The statement will focus on:
- Where will HMO development now take place? The potential impact of developers now turning their attention to areas of Bristol without an Article 4 direction restricting permitted development of HMOS
- Applying the HMO SPD without additional licensing in place? The difficulty of applying the HMO SPD where additional licensing isn’t in place but HMO numbers are very high has become very apparent (eg areas around UWE, ie Fishponds, Henleaze, etc); this difficulty being that small HMOs in place prior to the Article 4 direction coming into force are not recorded anywhere to enable cumulative impact to be assessed by the Planning Office in planning applications.
- Planning v Licensing. The lack of a joined up approach between licensing and planning (Para 26 reflects)- it would be useful to state both sets of local policy would be enhanced in effectiveness if they were more closely interlinked as is being considered in other parts of England (eg Warwickshire).
- Para 28 reflects the current interlinks between planning and licensing – for me the point to note here would be that there is no indication of how planning determine if planning consent is required (noting that for the majority of properties licenced without planning permission they would be required to prove that the property has been operating as an HMO or Sui Generis HMO from prior to the Article 4 direction coming into place and then continuously since this time (ie not been used as any other use class under permitted development thereby rendering their C4 use class previously obtained as invalid)).
- Temporary Use. The scrutiny report doesn’t pick up and report on the temporary uses permitted for a C4 HMO (or Sui Generis HMO) – it is noted that there is no temporary use of a C4 HMO as a C3 (family dwelling house) for any period in accordance with the General Permitted Development Orders (GPDO) (which is part of the Town and Country Planning Act). ABC believes this area is key for people to understand in order for planning enforcement to be most effective.
- Purpose Built Student Accommodation (PBSA). It is totally understood why PBSA isn’t included in the HMO SPD (they are not within the HMO use class), but it would be beneficial for Planning Guidance on PBSA to be enhanced to reflect the cumulative community impacts when they exist in close proximity to high density HMOs.
Please contribute where you see fit and show your support for this key piece of planning legislation by making a statement if you wish.