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Jack Straw’s Lane Association (Oxford) __________________________________________________________________________
Susan Turner Planning System Improvement Division Department for Communities and Local Government Zone 1/J10 Eland House Bressenden Place London SW1E 5DU
3 August 2009
Dear Ms Turner
Re: Consultation on Houses in multiple occupation and possible planning responses
We recognise that HMOs can make a valuable contribution to housing provision in our city (Oxford). However, they can also create problems in the community, both as individual houses and in concentrations, as recognised by the introduction of HMO Licensing in the Housing Act 2004 and by the government-commissioned ECOTEC Report of 2008 on HMOs. We are very concerned about the adverse effect that HMOs are having on communities in Oxford. Therefore, in its consultation on HMOs and possible planning responses, we request that the government take into account the following points:
(1) Some areas of Oxford have undergone a marked loss of community cohesion as a result of the massive expansion of the student population, notably as regards Oxford Brookes University, and the consequent growth in the proportion of houses used as student accommodation. In addition to the problem of degradation of the living environment (overflowing refuse containers in gardens, rats, noise and other social disturbance), the commercial mix has changed to favour the requirements of students, who pay no Council Tax, over those of permanent residents, who pay Council Tax at a high rate in this city. There is now a disproportionate number of cafés and bars in the city and businesses in some areas have become too dependent on the term-time-only custom of students.
(2) Option One proposes no more than the extension of best practice in tackling these problems. However, ‘best practice’ has been tried here and in many other towns, and has had no appreciable effect on the problems caused by concentrations of HMOs.
(3) Option Two proposes an amendment of the Use Classes Order, redefining HMOs and subjecting them to planning permission. It is only this Option which gives local planning authorities the powers to manage the distribution of HMOs, should they wish to do so.
(4) Option Three proposes removal of any planning controls on HMOs at all, except by means of Article 4 Directions. But this Option obliges local planning authorities to prepare an application for a Direction, it leaves the decision to Government, and it makes local authorities liable to compensation for refusal of HMO applications.
(5) The processing of planning applications for HMOs is in principle cost-neutral. However, the benefits of being able to manage the distribution of HMOs are incalculable.
We urge the Government to adopt Option Two, and to take action urgently to prevent further deterioration in communities affected by concentrations of HMOs. I hope you can take our views into consideration. We are sending a copy of this letter to our local MP and to local City Councillors, so that they are aware of our interest in this consultation.
Yours sincerely
Marilyn Cox, Secretary, Jack Straw’s Lane Association, on behalf of Jack Straw’s Lane Association*.
*JSLA covers about 110 households in the Headington area of Oxford. We have discussed these problems with the other residents’ associations in Headington, New Marston South (Oxford) and St Clement’s (Oxford).
Copy to: Mr Andrew Smith
MP (Oxford East) and to
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