5.1 With the city's growing population (and will grow further), there is a need to ensure that new development supports successful communities by ensuring the right mix of housing types in an area, securing appropriate design and supporting well managed properties. HMOs provide an important contribution to people's housing choice. The preferred policy approach aims to ensure that such development also preserves the residential amenity and character of an area and that harmful concentrations do not arise.

5.2 Large homes in multiple occupation (HMOs) can contribute to the overall supply of cheaper accommodation, particularly for students, young people and those on low incomes. Intensive occupation of former family dwellings such as those used for student accommodation or as a HMO can have negative impacts on residential amenity within an area, through increases in on-street and off-street parking, loss of front gardens, reductions in levels of privacy, alterations to the exterior of buildings and increased generation of refuse.

5.3 A large HMO is a property 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[1]  .

5.4 At the current time, any proposal for a small HMO is classed as permitted development. However, this DPD is being developed in parallel with a proposed Article 4 Direction which will seek to withdraw permitted development rights for small HMOs. There are significant existing concentrations of HMOs in certain wards across the city, where an Article 4 Direction will be developed (expected to be in place by 2023) removing permitted development rights for small HMO proposals (less than 6 unrelated occupants in a single dwelling).

Preferred Approach

5.5 The proposed policy approach to managing HMOs in Coventry is set out below with a suite of suggested draft policies coupled with a reasoned justification for each. Additionally, there is a proposed reasonable alternative we have suggested for each policy, but we are also keen to understand if there are other reasonable alternative options and questions for consideration. Once we have this feedback as a result of this consultation, we will undertake detailed Strategic Environmental Assessment / Sustainability Appraisal of the proposed policy options to ensure that, in line with national policy requirements, we are developing a sustainable policy approach for addressing HMOs in Coventry.

Justification and reasonable alternative 

5.6 Whilst there is an existing and corporately agreed approach to managing HMOs through the licencing regime, there is a need to strengthen existing planning policy to address HMO concentration coupled with a proposed non-immediate Article 4 Direction to withdraw permitted development rights within specific wards (expected to be in place in 2023). The evidence has established that small HMO dwellings 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. The cumulative effect of incremental intensification in an area caused by numerous changes of use from small HMO to large HMOs or the extension of existing HMOs can be also significant. For these reasons applications for such changes will be assessed using the criteria of draft policies HMO01 and HMO04.

5.7 It should be noted that the Council intends to introduce an Article 4 Direction requiring planning permission for a change of use from family dwellings (C3) to small HMOs for between 3 and 6 unrelated people (C4 dwellings) within specified wards of the city. At the current time, eleven wards have been proposed to be included as part of the Article 4 Direction area, albeit they should not be considered as being the only places in the city that have a concentration of HMO dwellings. These proposed wards are:

• Cheylesmore
• Earlsdon
• Foleshill
• Lower Stoke
• Radford
• St. Michaels
• Sherbourne
• Wainbody,
• Whoberley
• Westwood
• Upper Stoke

Please note: the Article 4 Direction is subject to a separate consultation process and is not being consulted on through this document.

5.8 The alternative approach to the proposed draft proposed policy HM01 is to do nothing and rely on the existing Local Plan policy H11 which is considered lacking an overall strategic direction to mitigate the potential impacts of further increase in HMO proposals coming forward.

Justification and reasonable alternatives

5.9 It is not the aim of the policy to reduce overall HMO numbers or to stop further HMO proposals coming forward, but to ensure that potentially harmful concentrations do not arise and that a high standard of accommodation and amenity is created, given the important role HMOs play as part of the city's housing offer. Clearly, patterns of supply and demand will change over time but there is a link 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 may be identified. Such areas would be subject to the preferred option policy. The evidence shows that high concentrations of HMOs in the city are already having an adverse impact on the character and amenity of local areas and this issue is spreading to further areas. The NPPF encourages local planning authorities to help maintain mixed and balanced communities. Over-concentration of HMOs can cause imbalance, leading to the problems identified in section 4.

5.10 The proposed eleven wards to be included within the Article 4 Direction area have varying levels of existing HMO dwelling concentrations. However, the preferred option would apply to the city as a whole rather than at individual street level. A single threshold is proposed to be set at 10% which is considered to be a modest level based on the size and scale of the challenge this DPD is aiming to address. Moreover, research based on similar size cities across the country which have already implemented a policy intervention to address HMO challenges, also suggests that the threshold would be appropriate and reasonable. 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 would be permitted.

5.11 The alternative approach is to do nothing and rely on the existing Local Plan policy H11 which is unable to address the issues of concentration and thresholds to mitigate the potential impacts of further increase in HMO proposals coming forward. Alternative thresholds were considered but we are not proposing to pursue these as the figure is based on tried and tested good practice elsewhere.

Justification and reasonable alternatives

5.12 Preventing the "sandwiching" of a non-HMO between two HMOs or a continuous frontage of three or more HMOs is an approach that aims to prevent unacceptable adverse impacts on amenity (as set out in paragraph 4.1) and to control the location of new HMOs and student accommodation in order to prevent these uses from either exacerbating existing or creating new concentrations. It is not the intention of the policy to restrict further growth in HMOs. The Council recognises the importance of HMOs and the private rented sector generally in the housing stock but seeks to ensure that the amenity of neighbouring residents is not compromised.

5.13 The alternative approach is to do nothing and rely on the existing Local Plan policy H11 which does not address the issue of sandwiching. This could lead to further issues of sandwiching and the potential impacts associated with continued increases in HMOs.

Justification and reasonable alternatives

5.14 The areas around the city centre and the campuses of both Coventry University and University of Warwick have the greatest concentrations of HMOs. These areas are popular with students and young people because they provide a good range of facilities for young people and a thriving evening economy. In addition, the housing stock lends itself well to the provision of shared houses and flats. However, one of the main problems for more settled residents living in these areas is the anti-social behaviour in the streets in the early hours of the morning. Other issues include noise from neighbouring properties, poor attendance to waste storage, increased burglaries, increased street parking, and poor property maintenance. The University and the Council work together to resolve these issues wherever possible, but the Council is firmly of the view that restricting further concentrations of HMOs will help prevent a worsening of the situation.

5.15 The policy also aims to ensure that there is satisfactory provision for the storage of waste, since a house occupied as an HMO can usually generate more waste than a family or couple. It is considered that all habitable rooms should have an adequate level of natural lighting provided via a clear glazed window or windows. Where practicable, all staircases, landings, passages, kitchens, bathrooms and toilets should be provided, with a window. Windows to bathrooms and toilets should be glazed with obscured glass.

5.16 The alternative approach is to do nothing and rely on the existing Local Plan policy H11 which does not comprehensively address the issue of amenity and design issues associated with HMO proposals.