Liverpool City Council’s Future Plans for HMOs between 2013 and 2033

This article takes a look at Liverpool City Council’s Proposed Local Plan that looks at how they want to shape the future of the city covering all areas of investment, transport, infrastructure, economy, and housing. In particular we are interested in what Liverpool CC have to say about their view on HMOs and the future of them in the city. Below is a link to the proposed Local Plan, and from that we have extracted all content from the Local Plan that discuss HMOs.

Here is a list of all points in the Local Plan that contain the word HMO:

6.111 The increasing number of students choosing to live in the City Centre has heightened the attractiveness of these large terraced houses for use as Houses in Multiple Occupation (HMOs), which generate significant revenues. Combined with the recent increase in planning permissions for new build student accommodation within and immediately adjacent to the Canning area, there is concern that further growth in student accommodation within the traditional Canning terraced residential area will impact on the City Council’s aim of providing family focused accommodation in the area.

6.112 Whilst HMOs can provide an affordable type of accommodation and contribute to the overall mix of housing types and tenures available, it is also recognised that high concentrations of HMOs can potentially have conflicting impacts on the local area, such as noise and nuisance; imbalanced and unsustainable communities; pressures on the physical environment and streetscape; pressures upon parking provision and community facilities; growth in the private sector at the expenses of owner occupation and restructuring of retail, commercial services and recreational facilities to suit the lifestyle of the predominant population. Therefore, in order to help further the aim of providing family focused accommodation within the Canning Georgian quarter the City Council will, where PD rights do not apply, resist applications for HMOs

8.34 Liverpool is a major university city, home to five higher education institutions – University of Liverpool, Liverpool John Moores University, Liverpool Hope University, Liverpool School of Tropical Medicine, and the Liverpool Institute for Performing Arts. Collectively, they provide places for 50,000 students, comprising approximately 11% of the City’s total population. Whilst Liverpool’s student population has grown considerably over the last decade, in tandem with the national expansion of higher education, it is anticipated that for the short to medium term, student numbers will stabilise.The City Centre has become the dominant location for student housing, mostly in the form of purpose-built and managed student accommodation schemes, whilst University Campus Halls of Residence and shared-houses and flats (HMO dwellings) continue to have a long term role in meeting student accommodation needs. In 2015, in response to changes in the student housing market, the City Council agreed a strategic approach to maximise the regeneration benefits of student accommodation and support the city’s ‘offer’ to attract students, whilst seeking to protect the residential amenity of established communities.

8.35 The strategic approach is to encourage and direct purpose-built development into the most-suitable areas of the City Centre and to discourage in the less-appropriate City Centre areas. Policy CC24 sets the locational requirements for proposals for new purpose-built student accommodation schemes in the City Centre whilst this policy sets out the criteria for assessing proposals located outside the city centre and a number of requirements that proposals across the whole City should meet, including design, measures to ensure good quality management and ensuring proposals have viable alternative uses. HMO’s are dealt with in Policies H10 and H11.

Policy H10 Conversion of Dwellings and Buildings Conversion –
sub-division of dwellings 1. Planning permission will be granted for the conversion of existing dwellings / buildings into self-contained flats, studio apartments/bedsits, and houses-in-multiple occupation providing: a. The premises are suitable for a full or part conversion in terms of location, the provision of amenities, and size for the number of households to be accommodated; b. There would be no adverse impact on the amenity of neighbouring properties and the character of the surrounding area in particular through increased activity, noise or disturbance; c. The configuration of internal space satisfactorily takes into account minimum room size, acoustic insulation, light and ventilation; The design of external space is safe and secure, and includes provision for refuse storage and adequate off-street parking, and ensures access to yards and/or gardens; e. Sufficient provision for waste management is made and it promotes good design to secure the integration of waste management facilities with the rest of the development including waste storage facilities. All proposals should comply with the City Council’s latest guidance with regard to Recycling and Waste Management. f. Bin storage is provided externally within the curtilage of the site, within a suitably designed structure located within the rear amenity space and not visible from the public realm; g. Landscaping reflects the character of the building and neighbourhood, allows for future maintenance, and avoids excessive use of hard materials; h. Where the property is within a row of existing commercial properties it is demonstrated that there is no longer demand for the commercial property; i. Living rooms, kitchens and bedrooms are not solely lit by rooflights; j. Where the proposal creates an HMO the proposal provides adequate safeguards for management k. With regard to the conversion of shops, the materials used for the front elevation, including windows and doors, reflect the design and character of upper elevations; l. The proposal complies with Policy CC17 “Protecting the Canning Georgian Residential Quarter” and Policy H11 Houses-in-Multiple Occupation (HMO): Neighbourhood Approach; and m. In the case of a conversion of a historic building, it does not harm elements which contribute to its significance.

With regard to the necessary alterations and conversion works to effect a change of use to a house-in-multiple occupation or flat, including extensions and alterations, planning permission will be granted where: a. They are of a high quality of design that matches or complements the style of the dwelling and the surrounding area; b. Provide communal lounge area(s) of a minimum 12 square metres in area and 3 square metres per person if there are more than four residents; c. The size, scale and materials of development are in keeping with the original dwelling and the surrounding area; d. Complies with Policy H8; and e. The extensions and alterations are designed so that there shall be no significant reduction in the living conditions of the occupiers of neighbouring properties. In particular, extensions must not result in: i. Loss of outlook, from the main windows of neighbouring habitable rooms; ii. A significant loss of light/overshadowing for neighbours; iii. An overbearing or over-dominant effect on the habitable rooms of neighbouring properties; and iv. A significant loss of privacy for neighbouring residents.

8.60 Generally, Houses in Multiple Occupation (HMOs) are defined as dwellings that are occupied by three or more unrelated people who share an amenity such as a lounge, kitchen or bathroom, and can have various layouts – bedsits, shared-house or flat. Although HMOs are a specific type of sub-divided dwelling, they are occupied by a range of people. In university cities and towns most HMOs are occupied by larger groups of unrelated students. HMOs are also an important source of affordable accommodation for younger people who are not students and single person households with supported living needs

8.61 A large HMO is a dwelling accommodating more than six unrelated persons sharing facilities and a small HMO accommodates between three and six unrelated persons. Housing legislation and the Planning Use Classes Order provides for different regulatory frameworks for managing HMOs. Most HMOs dwellings do not fall within either housing or planning regulation. Under housing legislation, 138 Liverpool Local Plan Submission Draft January 2018 8 a HMO requires a mandatory licence if the dwelling is three-storeys or more and in terms of Planning, planning permission for a change of use (Use Class C3 to C4/Sui Generis or vice-versa) for large HMOs is required. For Small HMOs a change of use (C3 to C4) is classed as permitted development. This policy therefore only applies where proposals require planning permission, that is a large HMOs and areas where permitted development rights have been withdrawn as set out in Policy H11.

8.62 To support the communal nature of HMO occupation, a dedicated communal lounge area is required to be provided and be identified within the internal configuration of the dwelling as part of the conversion / change of use proposal. The minimum size of communal lounge space is 12 square metres, equating to 3 square metres per person, assuming a small four person size HMO. For HMO accommodating more residents, proportionately more communal lounge space should be provided

Policy H11 Houses-in-Multiple Occupation (HMO): Neighbourhood Approach

  1. The Council will aim to ensure that there is balanced housing provision meeting the needs of families and households of varying sizes. Specifically the City Council will designate neighbourhoods where the concentration of HMO’s (including their operational and management requirements) has reached a level that is having an adverse impact on the character of the area. 2. The Council may introduce into designated neighbourhoods an Article 4 Direction requiring planning permission for small HMOs for between 3 and 6 unrelated people where there is evidence of a specific need for such measures. 3. In designated neighbourhoods in which: a. There is an Article 4 direction removing planning permission for small HMOs and/or withdrawing permitted development rights; and b. There is an HMO concentration equal to or exceeding an HMO threshold of 10% There will be a presumption in favour of refusing planning permission for a change of use 4. The following neighbourhoods (as a whole) exceed the 10% threshold: : a. The ‘Dales’ Neighbourhood; b. Smithdown Road / Gainsborough-Wellington Roads / Picton Road / Cranborne Road; and c. Kensington Fields. 5. In designated neighbourhoods in which: a. There is an Article 4 direction removing planning permission for small HMOs and/or withdrawing permitted development rights; and b. There is an HMO concentration of less than the HMO threshold of 10% An application for a change of use to an HMO will be considered against the criteria in policy H10 paragraph 1.

8.65 Whilst Houses in Multiple Occupation (HMOs) and studio’s/bedsits are an essential part of Liverpool’s housing stock to meet a diverse range of housing needs, poor quality developments and the cumulative impact of excessive concentrations of specific groups can harm the character and amenity of the wider neighbourhood.The City Council has approved a HMO Strategy (HMO Strategy, Cabinet 21 April 2017), which sets out a corporate approach to managing concentrations of HMO dwellings. The strategy acknowledges the contribution made by HMO dwellings in meeting a range of housing needs and seeks to address concerns regarding HMO over-concentration and to improve the condition and management of private sector housing.

8.66 The HMO Strategy includes extending planning policy to address HMO concentration coupled with non-immediate Article 4 Direction(s) to withdraw permitted development rights within identified neighbourhoods. The evidence has established that small HMO dwellings (occupied by six or less persons) are associated with neighbourhoods where the predominant dwelling type is small (three bedroom) terraced dwellings, privately rented, and whilst mostly occupied by students, provide accommodation for a range of people, who form single-person households and who for a variety of reasons, have transient lifestyles

8.67 Nine neighbourhoods have been identified, albeit they should not be considered as being the only places in the City that have a concentration of HMO dwellings: • Area A: The ‘Dales’ • Area B: Smithdown Road / Gainsborough-Wellington Roads / Picton Road / Cranborne Road • Area C: Grant Avenue • Area D: Sefton Park (north) periphery • Area E: Kensington Fields • Area F: Prescot Rd / Sheil Rd / Boaler St / Coleridge St • Area G: Fairfield • Area H: Prescot Rd / Fairfield St / Edge Grove / Laurel Rd • Area I: Newsham Park (north)

8.68 Patterns of supply and demand will change over time. There is a linkage between student shared-houses and the increasing provision of purpose-built student accommodation located in the City Centre. Restricting HMO supply in one neighbourhood, may prompt landlords to examine adjoining areas, displacing the concentration. Consequently, boundaries may change and new areas maybe identified.

8.69 The nine neighbourhoods have varying levels of existing HMO dwelling concentration. Also, within each of the identified neighbourhoods, concentration varies, however, the policy applies to the neighbourhood as a whole rather than at individual street level. A single threshold has been set at 10%. For neighbourhoods which exceed the threshold, no further applications to a C4 HMO dwelling, generated by the withdrawal of change of use permitted development rights will be permitted

8.70 Three neighbourhoods are identified in the policy – The ‘Dales’ area; Smithdown Road / Gainsborough-Wellington Roads / Picton Road / Cranborne Road area; and Kensington Fields – as the HMO concentration already exceeds the 10% threshold and in these neighbourhoods no further change of use to HMO dwellings will be permitted. In neighbourhoods with less than 10% threshold, HMO concentration will be monitored and the requirements set out in Policy H10 in relation to managing large HMO (Sui Generis application) is applicable.

8.71 There is the potential for unintended consequences to arise in restricting HMO that could be detrimental, requiring the Council to consider exceptional circumstances. In implementing a HMO concentration policy existing family owner-occupier residents may become ‘trapped’: due to HMO concentration, their property is not attractive to prospective family households and sale to a private landlord, seeking a change of use to a HMO, is prevented. With neighbourhoods with excessive concentrations of HMO dwellings within a changing local housing market, flexibility could be afforded to encourage the return of family households. The three neighbourhoods referred to in Policy H11 are identified below: