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Comments.
HMO Consultation Feb 11 (23/02/11 to 23/03/11)
Eve Brown Ltd (Mr Stephen Brown) Comment by
HMO136 Comment ID
23/03/11 10:08 Response Date
Processed Status
Web Submission Type
0.1 Version
Commenting as?
Other (Please specify in box below)
letting Agent
Your Comments
Please add your comments below
Response to Draft Supplementary Planning Guidance: Houses in Multiple Occupation (St Andrews
Central Conservation Area) My name is Stephen Brown and I am a Director of Eve Brown Ltd. We are
a firm of dedicated property managers and we have been based in St Andrews for over 25 years. In
this time we have dealt with hundreds of largely, but not exclusively student properties, many of which
are or have been HMO licensed properties. Given the nature of our work and our long-term presence
in St Andrews I feel that I am qualified to make comment on the proposed SPG. Having carefully
studied the Draft Supplementary Planning Guidance: Houses in Multiple Occupation (St Andrews
Central Conservation Area) document I have formed the view that this proposal is ill conceived, ill
thought out, reactionary and none evidence based. The stated aims and conclusions of the SPG to
address some of the issues surrounding the intensification of HMO use namely the resultant unbalanced
community and prevention of potentially affordable housing are non sequitur of the document itself.
Rather the document appears to be predicated on false assumptions and the prejudice and bias of
certain local pressure groups and local councillors that are wholly unrepresentative of the community
as a whole It is my view therefore, that should this proposal be adopted the likely consequences may
well be the reverse of the stated aims. On this basis I wish to register my opposition to this proposal
and below I have set out my grounds for opposition in more detail. Firstly, to establish a context, it may
be useful to re-examine the intended purpose of HMO legislation, although other contributors have
already covered this. Under Statutory Guidance for Local Authorities the Scottish Government states
explicitly that: The purpose of HMO licensing is to improve standards in this part of the private rented
sector, by ensuring that the landlord or their agent is a fit and proper person, and checking standards
of physical accommodation and the management of tenancy issues. Nowhere is it stated or implied
that HMO licensing can or should be used as a mechanism for social planning or for constructing a
demographic profile of an engineered community based on a template set by this minority grouping.
Furthermore, the Scottish Government also makes it quite clear that in terms of administration of HMO
licensing, Local Authorities have a duty to comply with Human Rights legislation inter alia planning
and the author wonders whether the SPG, if adopted, would be in contravention of these statutory
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guidelines. Now let us turn to an analysis of the SPG proposal itself. Policy & Assessment Fife Council
acknowledges that it has a statutory duty under Environmental Assessment (Scotland) Act 2005 to
undertake a Strategic Environmental Assessment (SEA) on Local Plans. In this SEA Fife Councils
acknowledges that: The impacts of the proposed policy are as yet uncertain, however an initial
assessment would suggest that a restrictive planning policy will not necessarily mean that properties
prevented from becoming an HMO will become available for local people or first time buyers. There
is thus an immediate acknowledgement that one of their stated reasons for a moratorium on granting
new HMO licenses is fundamentally flawed. There is further acknowledgement that as not all HMOs
currently require planning consent using this tool to limit licenses would be undermined. More damning
still, one of the effects of this proposal which many opponents of the SPG are warning against is the
possibility that by limiting HMOs in the centre demand for HMO properties would increase in erstwhile
largely family dominated areas of the town. Were HMO demand to increase in these areas then the
exact opposite of the intended effect would result. Namely that demand for HMO properties would be
in competition with family homes in areas most suited to family use i.e. in areas of more affordable
housing where properties have gardens and garages etc. Indeed there is already some evidence that
the limited supply of HMO properties and concern over licensing are already driving investors to seek
safer less regulated properties for buy to let. These smaller properties in fact being amongst those
that would better serve local and first time buyers in areas less traditionally sought by student occupants.
As demand for HMOs is unlikely to be sated in the near future the inevitable consequence of further
limiting supply in more traditional HMO areas will be to spread demand like ripples in a pond emanating
from the town centre to areas on the outskirts more usually occupied by families. Consultation According
to the SPG senior Fife Council officials have been consulted and are in agreement with the contents
of the report. The implication being that these officials accept that impact of the proposed policy are
uncertain, that by limiting HMOs in the centre of St Andrews there is a danger that HMOs will compete
for properties in areas more suitable for owner occupation and family use. The author wonders what
the motivation and rationale for adopting such a flawed document could be in the face of such clear
and unequivocal opposition. Background It is stated in this section that the SPG has been prepared
to address issues of community sustainability. in relation to the concentration of HMOs .and for
this reason, Fife Councils Planning Committee agreed that a policy restricting any further HMOs in
central St Andrews Conservation Area be prepared as SPG. My initial reaction was to immediately
turn this on its head and ask how would the local community be sustainable without the students?
There are numerous examples of other coastal towns not dissimilar to St Andrews which do not benefit
from a world renowned university that are in obvious decline or suffering from economic malaise. The
huge economic value, which the University bring s to the town, cannot be over stated here and the
reader is referred to the statistics from the Bigger Economics Report calculated as a Gross Value
Added (GVA) to the town of 181.2 million. Nor can golf be used as any kind of argument in support
of the local economy. Again a quick comparison with similar golfing locations such as Carnoustie,
which stand in stark contrast to, the vibrant dynamic economy enjoyed by St Andrews. Hosting a major
tournament for a few days every five or six year pales into insignificance compared to the influence
on the local economy of the University. Taking into account the statutory guidelines under which local
authorities are supposed to operate it would appear that Fife Councils Planning Committee are
potentially acting ultra vires and that the SPG, if adopted, could be open to a legal challenge. The
statutory guidance issued by the Scottish Government on this point makes it quite clear that social
planning is not one of the purposes of HMO licensing and furthermore such a policy may well be in
contravention of Human Rights legislation. The sop to this flagrant disregard of statutory guidelines
and other legislation is the proposed review to be held in 24 months time. This is wholly untenable.
The premise of the SPG is entirely at odds with statutory guidelines and other legislation and is not
therefore competent at any level. The author would take issue with the argument put forward concerning
community sustainability. One of the essential characteristics of St Andrews is that it is an historic
University town. In deed as we have all recently learned St Andrews is the third oldest university in
the English speaking world and is celebrating 600 years of learning. It is not possible to think of St
Andrews as being separate from the University and in deed the University is not separate from the
community. Quite the reverse is true. It is an integral part of it of the community and has been for
centuries. It has influenced and shaped the town and its development and St Andrews is what it is
today because of the University not in spite of it. There is a limited employment base here but we have
a thriving community full of quality shops, restaurants, cafes and bars etc out of proportion to the
towns pulling power if not for the University which is either directly or indirectly at the heart of this
employment base and largely under pins the local economy. From a business perspective as a letting
agent we have four full time employees and sub-contract a massive amount of work to local tradesmen
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joiners, plumbers, electricians, decorators etc etc all employed in looking after and maintaining
properties largely within the St Andrews area and we are not unique. I would refer the reader back to
one of the main reasons for HMO licensing checking standards of physical accommodation. HMO
has been a driver of improving standards of buildings and accommodation because it is regulated and
controlled unlike other sectors such as owner occupied properties, which are not subject to such third
party scrutiny and regulation. One wonders just how many owner occupied family properties in St
Andrews would be able to achieve the same standards of fire safety for example as HMOs? How many
owner occupied or unregulated properties in the centre have been allowed to deteriorate and decay
because owner-occupiers are not compelled to undertake external upgrading or repairs? Issues and
Options The areas quoted in this sector as justification for a limitation on HMO licensing are again out
with the aim of HMO legislation and beyond the statutory guidance set out by the Scottish Government.
Issues of community services and facilities are not relevant considerations for determining HMO
licenses. On the contrary, the Scottish Government Guidelines require Local Authorities to ensure
that an adequate supply [of HMOs], is available to meet demand. It has already been argued that it
is fallacious to try and separate students from the established community. They ARE part of the
established community and a very vital and necessary part at that. To argue that they are some how
a transitory group with no long-term commitment to the area is untrue and insulting. 600 years of
history testifies to this. Purported concerns surrounding Property specific issues are also equally ill
founded and assertions are made with out basis or corroboration. Fife Council with all its resources
has produced not one survey or one scrap of evidence to support their contentions that HMOs increase
pressure on traffic movement and parking or that so called independent lifestyles increase demand
for parking, drying areas and gardens or that pedestrian movement and noise etc have an impact on
residential amenity whatever that means. One small point to bear in mind is that HMO Standards in
St Andrews actually require tumble dryers to be placed in properties which do not have adequate
external drying facilities so this assertion made in the SPG flies in the face of the actual HMO practice
as implemented by Fife Council! Siena Parker Director of Representation and Owen Wilton President
of the Students Association have argued their case eloquently in this regard and produced the only
evidence that I have seen on the subject of parking and car ownership amongst HMO occupants so
there is no need to rehearse their comments here but I would direct the reader to their submission in
response to the SPG which can be found on line at
http://fife.limehouse.co.uk/portal/hmo_consultation_feb_11?tab=list Suffice to say the evidence suggests
that HMO occupants actually have a lower car use rate than owner-occupiers and indeed personal
experience tells me that this would be so. What is also undoubtedly true is that if HMOs were forced
into the more residential areas further from the town centre car usage would increase exacerbating
the traffic problems within the centre. Perhaps if Fife Council looked more closely at their own parking
regulations and the cost of long-term parking then causes of car usage problems in the centre could
well be closer to home yet it seems easier and more convenient to blame HMOs. Nor do further
criticisms in section 2.1.3 that students dominate the make up of residents in central St Andrews stand
up to any kind objective analysis rather they seem a visceral reaction. The presumption that it is a
student rather than a mixed community is at best skewed. To reach the conclusions drawn in the
SPG it must be first accepted that students neither form part of the local community nor are equal
stakeholders in the local community, which the author wholly rejects. Fife Council then presents
absolutely no evidence to support the contention that there is even demand from families or owner
occupiers, because presumably it is they to whom Fife Council are alluding, for property with in the
centre of St Andrews. As the housing stock is undoubtedly less suitable for this kind of use and much
more expensive, facts acknowledge by Fife Council, it would be far more logical to assume that families
and owner occupiers would by choice prefer more affordable properties further from the centre with
facilities more appropriate for families such as gardens and parking etc. It is also unclear in section
2.1.4 how Fife Council expect to use HMO licensing to manipulate the local housing market by allowing
others, unspecified, to enter the housing market nor is it clear why Fife Council believe that HMO
licensing prevents potentially affordable housing being available for owner occupation. What evidence
there is suggests that limiting HMOs in central St Andrews will not lead to a reduction in house prices
but worse could result in more HMOs being sought in areas otherwise generally owner occupied and
this would lead to increases prices making such properties less affordable and less desirable to owner
occupiers. This is the exact reverse of the avowed aim the SPG. Nor are potential owner-occupiers
prevented from buying town centre properties in the open market but evidence suggests that families
do not desire such properties and it is not difficult to see why. No gardens or driveways, parking
restrictions, located with in a vibrant setting with an active nightlife and often above shops or restaurants
with no direct street access. Hardly top selling points to families. Neither should the reader be lulled
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into believing the bona fides of Fife Council in relation to granting of licenses out with the town centre
a point already made by another contributor in their response to the SPG. I can certainly endorse this
view that Fife Council and local pressure groups such as CSARA object to all HMO applications as a
matter of course and cut and paste objections have in the past been given far too much credence by
the Licensing Committee and this has, with certainty, in my own experience been used as a tool of
social engineering. In one our own HMO appeals local residents used HMO licensing to prevent Thai
occupants living the street and as I was told after the hearing by one dear old lady and I paraphrase
their objections had nothing to do with HMOs they just didnt want Thai girls living their street because
we all know what services Thai women offer after hours and its nothing to do with waiting on tables.
A genuine comment made by an elderly local resident after an HMO committee hearing. I kid you not.
In addition to the above I would also suggest that in their housing strategy Fife Council have sought
to place the blame on all perceived ills firmly at the door of HMOs (pun intended) but have not considered
one of the main brakes on the housing market and main obstacles to first time, or in deed any buyers,
that being the availability or rather non-availability of mortgage finance. Despite government pressure
the lending policies of the financial institutions have made it all but impossible for those not on high-flying
salaries to buy their own homes and indeed statistics issued today by mortgage lenders show that
lending to first time buyers is at an all time low and now represents under 2% of recent mortgage
lending. These are external factors, which cannot be blamed on HMOs. However, the role of HMOs
in increasing the supply of affordable housing in town centre locations is acknowledged in 2.1.8 of the
SPG. The hypocrisy of the SPG is shown very clearly in this regard. Furthermore, there is no link
established between the high prices of property within the town and the number of HMO licenses and
evidence from other affluent areas in Scotland where there arent HMO properties demonstrate that
this over simplified cause and effect argument is unfounded. The final irony in the SPG proposal under
2.1.10 is that this proposal will only apply to applications considered after consultation. So everything
that has gone before is sacrosanct. At best then this whole SPG procedure is going to tinker with the
edges and would not, even if the arguments of Fife Council had any validity, deal with the substantive
issues raised. It is more a visceral document rather than a practical blue print. Next Steps The author
is glad to see that at last with the haveyoursay pages on Fifedirect.org Fife Council is hearing comments
from a greater and more representative cross section of our community rather than from a minority
pressure group that have a limited support base and operate on a clique mentality. In my view given
the overwhelming rejection of the SPG by the local community and the real risk that the document
could be subject to legal challenge it is hoped that this document will consigned to the dust bin of
history as an aberration of the Planning Committee. Conclusions There can be no doubt that the
contentions of Fife Council that the intensification of HMO use have led to an unbalanced community
and that they are the cause of a lack of affordable housing are erroneous, misguided and grossly over
simplify the socio-economic factors which affect our local community as well as others throughout
Scotland. Not only have they produced no evidence to support their claims but they readily admit to
the potential adverse effects of the SPG and they are also using HMO licensing in direct contravention
of Scottish Government Statutory Guidelines. Their stated aims of rebalancing the community and
generation of affordable housing can not be achieved by artificially manipulating the social make up
of St Andrews and this back door attempt at social engineering must not be allowed to proceed. The
SPG has nothing to do with rebalancing the community but is a thinly veiled attempt to codify the
anti-HMO prejudices of minority pressure groups. If rebalancing was a genuine and legitimate argument
it would be difficult to explain the strenuous attempts made by groups like CSARA and local Councillors
to restrict HMOs to what they perceive as the student ghetto of the town centre and prevent the
unwanted spread of HMOs in suburbia. At the commencement of this response I stated my opinion
clearly that the SPG was ill conceived, ill founded and non-evidence based. I repeat this assertion and
trust that all reasonable minded people would reach the same conclusion. Should Fife Council refuse
to listen to the massed voices of St Andrews residents and implement the SPG I also think it possible
that there may well be a legal challenge to the document which does not appear to adhere to the
statutory guidelines issued by the Scottish Government nor indeed to the concept of the big society
expounded by the current government in Westminster under which local people are to have a much
greater say in determining local planning policy in their local area.
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THE HOUSING COMMISSION 6th February 2013
In the last ten years FiIe Council has proposed and the Scottish Executive has approved huge development in
FiIe, amounting to 35,200 houses. During that time the Structure, Local and TAYplan have all been
approved, and the Council is now embarking on a FiIe-wide Local Plan. The TAYplan was approved last
year and will last until 2032.
Unlike Dr Goudie, I am not a statistician and I am not putting Iorward a solution, although I do whole-
heartedly support his submission on behalI oI the Royal Burgh oI St Andrews Community Council.
However, I have over many years tried to keep a record oI population and growth Iigures in St Andrews. I
believe that the members oI the Housing Commission should be aware oI the contradictory and in some
cases unrealistic Iigures which have been around during that time.
To propose and carry Iorward the amount oI growth intended in FiIe, it is essential that there are accurate
population Iigures, so that the requirement Ior inIrastructure - roads, water and electricity supplies, hospital
beds and health centres - can be properly assessed. I believe that the Iigures which have been produced are
Ilawed, and Iail to take into account two major Iactors - the global economic crisis, which has clearly
changed everything but not the inIormation in the above Plans, and the rapid growth oI the University.
There does not appear to have been any opportunity Ior oIIicials to reassess the contents oI the Plans;
everything depends on the recovery oI the economy so that normal` development can proceed.
The Iigure in the 2012 Local Plan (adopted on 5th October 2012) says that the population oI St Andrews is
16,351, including students. The University says that student numbers are 7,750. The Higher Education
Statistics Agency (HESA) in March 2012 said that the Iigure was 9,538. I believe the latter is correct,
because Iull-time equivalents are not relevant - two students making up a Iull-time equivalent need two beds,
and may have two cars.
Since 2001 the number oI HMOs in St Andrews has ballooned, so that the town now has over 90 oI all
HMOs in FiIe - over 1,000. This means that Iew people can compete with HMO landlords in buying
property in the town centre, which now has 85 HMOs, and is deserted out oI term-time.
Assessment oI the number oI people actually living in St Andrews is complicated by the Iact that the town
can no longer accommodate all the students, meaning that some live in Strathkinness or Dundee. Students
are oI course a much-valued presence, but they are not permanent residents; neither they nor landlords can be
relied on to maintain and care Ior buildings, particularly listed buildings, oI which St Andrews has 300.
The General Register OIIice Ior Scotland (GROS) does not seem to have succeeded in establishing the
population oI the town. I know little about censuses, but I believe there has been considerable doubt about
the 2001 and the 2011 censuses, and that in both cases they were carried out while the students were away.
In 2010 I had some correspondence with the GROS (as have a number oI other people, including a FiIe
Councillor). They reIer to the student Iigures oI 5,500 to 7,500 living in St Andrews`. They also say that
the starting point Ior calculation oI recent population estimates was the 2001 census. At that time the
population oI the settlement oI St Andrews was 15,285`. This apparently included students. However, in the
1996 Local Plan the Iigure Ior permanent residents was 14,000. The GROS` method oI estimating
population is so complex that it is diIIicult Ior lay members oI the public to understand it. The GROS went
on to say we thereIore have consistent evidence (in 2010) that the maximum number oI students living and
studying in St Andrews is currently around 7,000`. I do not agree with this conclusion, and particularly with
the use oI the word consistent`.
The GROS also said that two-thirds oI the population oI St Andrews are indigenous`. This does not appear
to be supported by the Local Plan Iigure oI 16,351 and the HESA Iigure oI 9,538. But it is, oI course, true to
say that there are probably some residents who are also students, and the students who live outside the town
are presumably not counted in the town population, matters which Iurther complicate attempts to establish a
true Iigure. In consultations on the Plans there were a number oI objections to the Iigures, including Irom Dr
Goudie, Mr Wynd (Preservation Trust Chairman), and others. In common with the majority oI the 5,000
objections to the Local Plan, they were ignored.
In 2006 three local websites (World Class, FiIeDirect and the Links Trust) gave the Iollowing Iigures:
1) 14,000 excluding students
2) 14,500 plus 5,000 students
3) Nearly 15,000 plus 7,000 students
FiIe Council`s Iigure oI 16,351 has been undermined by other Iigures used by oIIicials. For example, in a
response to a Judicial Review in 2008 it was said that the population was approximately 13,500 plus
approximately 6,500 students - i.e. 20,000.
The Structure Plan says that there will be 8 growth across FiIe. I believe that growth should be based on
permanent population Iigures. II that were the case, the proposed growth in St Andrews oI a minimum oI
1,000 houses would be nearer 20 than 8, whether based on the number oI houses (6,400) or the
population.
During a consultation on the Structure Plan Housing Land Reappraisal, the Scottish Executive oIIicial
responsible Ior the Structure Plan (Mr Ken Jobling) said:
Para. 1.28 states that GROS projects an increase oI 39 extra households Ior Scotland by 2024. The
Iigure is actually 13.`
The only person in FiIe who spotted this error was Dr Goudie. Was it corrected, and were other Iigures
based on it? I have no idea.
In February 2011 I sent an FoI request on behalI oI the Community Council Planning Committee to Ms Pam
Ewen, the TAYplan Manager (previously the author oI the Structure Plan) asking why the Main Issues report
said that there would be 1.28 growth in North FiIe. The answer, eventually, included the statement that
Analysis oI population was not done at settlement level across the TAYplan area`. So what did this Iigure
mean? What are these growth Iigures based on?
UnIortunately, most oI this inIormation could be summed up in the phrase There are lies, damned lies and
statistics`. I believe that the Iigures used in the Plans to which I have reIerred are unrealistic, in many cases
incorrect, and are a dangerous platIorm Ior the Iuture oI FiIe and particularly the Iuture oI St Andrews. The
town is in the hands oI two huge organisations, FiIe Council and the University, which are partners in a
Strategic Agreement. My main concern is Ior the welIare oI the most important small historic burgh in
Scotland` (Historic Scotland), because the town and its landscape setting, the green bowl in which it sits, are
being ravaged to meet the demands oI developers and the ever-increasing numbers oI people living in it,
contributing to the lack oI green space, the Irequent gridlock, and the destruction oI views into and out oI the
town.
Dr Cant, an eminent local historian, said that iI the population rose above 20,000, the town would be
Iinished. I believe that it has done, and that it will be.
Penny Uprichard, 3rd February 2013.
Tel No: 08451 555555
David Middleton Ext 441150
ST ANDREWS ReI: FAPS/DS/FOI/JM
FiIe
Date: 26
th
September 2013
Dear Mr Middleton
FREEDOM OF INFORMATION (SCOTLAND) ACT 2002 - REQUEST FOR INFORMATION
I reIer to your inIormation request received on 29th August 2013; our reIerence FCIR:5198.
I have detailed below the inIormation you requested and trust that it meets your requirements.
1(a) The number oI private landlords residential properties in FiIe which are exempted Irom Council Tax
because oI occupation by students is 2170.
1(b) The number oI University/College residential properties in FiIe which are exempted Irom Council Tax
because oI occupation by students is 202.
2(a) The Iiscal value oI Council Tax income not collected Irom the above detailed private landlords`
residential properties is 221,516.13.
2(b) The Iiscal value oI Council Tax income not collected Irom the above detailed University/College
residential properties is 1,112,087.18.
3(a) The Iiscal value oI Water Rates income not collected on behalI oI Scottish Water Irom the above
detailed private landlords residential properties is 70,911.68.
3(b) The Iiscal value oI Water Rates income not collected on behalI oI Scottish Water Irom the above
detailed University/College residential properties is 515,369.20.
4(a) The Iiscal value oI Council Tax income collected Irom private landlords residential properties who use
exempted accommodation Ior personal use or let as holiday accommodation during University
vacations is 11,524.78. This does not include Water Rates.
4(b) The Iiscal value oI Council Tax income collected Irom University/College residential properties who
use exempted accommodation Ior personal use or let as holiday accommodation during University
vacations is 1,112,087.18. This does not include Water Rates.
5 FiIe Council do not receive any compensatory payments Irom the Scottish Government in relation to
the loss oI income Ior each oI the categories detailed in questions 2 and 3.
I would like to draw your attention to the copyright situation in relation to the material.
The Council holds the copyright Ior material provided and it may be reproduced Iree oI charge in any Iormat
or media without requiring speciIic permission. This is subject to the material not being used in a derogatory
manner or in a misleading context. The source oI the material must be acknowledged as FiIe Council and
the title oI the document must be included when being reproduced as part oI another publication or service.
II you are not satisIied with the way we have handled this request, you have the right to request a review oI
the decision. Please write to: ChieI Legal OIIicer, Corporate Services, FiIe House, North Street, Glenrothes,
KY7 5LT or e-mail to inIo.reviewIiIe.gov.uk. The law provides Ior you to make this request up to 60
working days Irom when we received your enquiry or 40 working days Irom when you receive this
correspondence, whichever is the later date. Where the outcome oI the review Iails to resolve the matter to
your complete satisIaction, you have the right to apply to the Scottish InIormation Commissioner Ior a
decision.
FiIe Council will consider and seek to resolve any request to the ChieI Legal OIIicer that Ialls outside these
timescales.
Yours sincerely
Lead OIIicer - Directorate Support
Finance & Procurement Service
Finance & Resources Directorate
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STUDENTIFICATION
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/001
Balanced Communities and Studentification
________________________________________________________________________________________________________________


2%&#3&#4


loreword 3

1 Introduction 4

2 Balanced Communities 5

3 Studentification 8

4 Problems 10

5 Solutions 11

6 Conclusion 13

Reerences 15



















5*.& lMOs are deined as in housing legislation throughout the UK ,see the National lMO Lobby`s Brieing
Bulletin \hat is a lMO`,



/
Balanced Communities and Studentification
________________________________________________________________________________________________________________
5%637%68

1lL NA1IONAL lMO LOBB\ is a network o local community associations trying to
redress the impact on their communities o concentrations o shared houses or houses in
multiple occupation ,lMOs,. Begun in 2000, the Lobby now comprises some ity
groups in oer thirty towns, in all the countries and regions o the UK. Inormation on
the Lobby and its lobbying is aailable on the website at www.hmolobby.org.uk.
Oer the years, the Lobby has proided support or its members. It has circulated inormation
on lMOs in Brieing Bulletins, and it has enabled debate through its Discussion Documents.
And the Lobby o course has lobbied - or recognition o the problem o lMOs, and or
national legislation to tackle this, especially in housing and planning - speciically or licensing o
lMOs and or planning controls in the UK`s Use Classes Orders. In this, we are supported by
our elected representaties.
Nationally, last year, many o our MPs joined
orces to set up the All-Party Parliamentary
Group or Balanced & Sustainable
Communities, and in Parliament, members o
this Group hae raised the issue o lMOs.
Locally, also last year, many o our local
councillors joined orces to set up the
Councillors Campaign or Balanced
Communities. Meanwhile, councils hae sent
delegations to \estminster, and hae adopted
motions calling or national action on the issue
o lMOs.
In act, national goernment has
acknowledged that concentrations o lMOs
cause problems or communities. 1hree
recent reports hae identiied dierent aspects
o these problems - CLG lousing Research
vvvar, 228 Deativg ritb Probtev Prirate Revtea
ov.ivg ,2006,, louse o Commons, CLG
Committee Coa.tat 1orv. ,200, and CLG,
ratvativg tbe ivact of MO ava etectire
icev.ivg: tbe ba.etive before ticev.ivg iv .rit 200.
,200,.
Local goernment has recognised the
problems caused by concentrations o lMOs
in ery practical ways. In their planning
policies, some hae sought to resist
concentrations ,like Leeds,, or hae proposed
thresholds ,like Loughborough, or again hae
promoted purpose-built deelopments as an
alternatie to student lMOs ,like Newcastle,.
1here is ater all no question that the major market or lMOs is student demand, or
studentification - hence the emphasis o atavcea Covvvvitie. c Studentification
Uniersities hae admitted that there is an
issue. In 2006, Uniersities UK published
tvaevtificatiov: a gviae to oortvvitie., cbattevge.
ava ractice. Unortunately, this guide udged
the real issue, and oered answers only to the
supericial eects o studentiication.
In 200, the National Union o Students
published tvaevt. iv tbe Covvvvit,: !or/ivg
togetber to acbiere barvov, Unortunately, this
denied the existence o the problem
altogether.
atavcea Covvvvitie. c Studentification or the irst time publishes the perspectie o those at the
sharp end, the community. But that is not the only way it is innoatie. lor the irst time, it
suggests a workable idea o balanced community`. lor the irst time, it proides a systematic
analysis o studentification`. And or the irst time, it proposes a programme o action which
tackles the root cause o the problem ,rather than tinkering with its eects,. In a gesture o
collegiality, atavcea Covvvvitie. c Studentification is launched at the Conerence o the
Councillors Campaign or Balanced Communities in Nottingham on 13 March 2008.
Dr Richard 1yler, Co-ordinator, National lMO Lobby

9
Balanced Communities and Studentification
________________________________________________________________________________________________________________
:&#6%8;<#$%&

67 )*++,$-.8 ..^CD COMM|^1 c STUDENTIFICATION is essentially about
community, its loss and restoration, what it should be, why it goes wrong, how it can be
put right. But what is a community, what is meant by the word A quick search o a
language corpus shows that the term community` is used in numerous contexts, and in
many ways. And the reason or this is that it has a long history o positie warmly
persuasie` associations. Consequently, the term is requently appropriated or polemical
purposes, to gie a positie gloss to a measure which has nothing to do with community
in any meaningul sense. A prime example was the inamous Community Charge -
immediately recognised or what it was, and re-christened the Poll 1ax. In cases like this,
community` is used simply as a synonym or people`, implying that a random group o
people has something in common, when in act it does not. 1his is the veavivgte.. sense
o community`.
69 4:-2-. Any veavivgfvt use o the term community` must go beyond the sense simply o
population`. 1he origin o the word indicates what this is - it deries rom the term common`.
A covvvvit, then is in act a group o people with .ovetbivg iv covvov. 1he word implies vav,
acting as one`. 1his commonality is sustained by what social scientists call social capital - which
includes things like social networks ,simple contacts between people, companionship, and social
norms ,ways o behaing - like neighbours looking ater each others` children, pets, gardens,
taking in parcels, holding keys, keeping the neighbourhood clean and quiet and sae, and social
sanctions ,penalties or mis-behaiour, - otherwise known as covvvvit, .irit.
6; )".&<*2-&/ O course, there are many kinds o communities. And most people belong to
seeral at once. But they tend to all into three main groups.
1here are origivat covvvvitie.,
and what they hae in
common ,looking back, is
their origins. 1he main
examples are ethnic
communities.
1here are those which look
around, tocat covvvvitie. -
what they hae in common is
a concern or the
neighbourhood in which they
ind themseles.
Looking orward, there are
rocatiovat covvvvitie., groups
o people with common
goals - such as a religious
ocation or an occupational
ocation ,like being a
student,.
6= 1*#-%8 \ith the new millennium, the idea o community` igured large in goernment
policy. A key principle in the lousing Green Paper Qvatit, c Cboice ,DL1R, 2000, was
Promoting sustainable deelopment that supports thriing, balanced communities.` \hen the
Oice o the Deputy Prime Minister succeeded the DL1R in 2002, it adopted the motto Creativg
v.taivabte Covvvvities, and in 2006, it was succeeded in turn by the Department or Communities
& Local Goernment. Local authority plans requently reer to balanced communities`. 1he
idea o the balanced community` thereore is prominent in national and local policy, requently
combined with sustainable community`. But has goernment gien adequate consideration to
the concept o community
See or instance, Belast: ..ve. Paer ov MO.: 3 Balanced Communities`, Coleraine: Balanced
Communities Reiew Group, Durham: Ptavvivg for ov.ivg: 8 Proision o Balanced Communities`,
Loughborough: tvaevt ov.ivg Prori.iov: In search o a balanced community`, Nottingham: vitaivg
atavcea Covvvvitie..


=
Balanced Communities and Studentification
________________________________________________________________________________________________________________
>"'"&<38 2%??;&$#$34
6> 4,/."-$"3-#-.8 ALL LOCAL COMMUNI1ILS, as communities, want to be sustainable.
1he Department or Communities & Local Goernment explains sustainable
communities` as places where people want to lie and work, now and in the uture. 1hey
meet the dierse needs o existing and uture residents, are sensitie to their enironment,
and contribute to a high quality o lie. 1hey are sae and inclusie, well planned, built and
run, and oer equality o opportunity and good serices or all.` CLG identiies eight
components - sustainable communities are actie, inclusie & sae, well run,
enironmentally sensitie, well designed & built, well connected, thriing, well sered, and
air or eeryone. But this deinition entirely oerlooks the obious act that what`s
necessary or a sustainable community is a resident population willing and able to sustain
that community.
6? 1*#"2-/".-*$ Local populations can be disabled in a number o ways, all o which are types
o polarisation. Polarisation can mean oo.itiov - where the neighbourhood becomes a place o
contest between competing actions. Or polarisation can mean ove.iaeave... Again, this can take
a ariety o orms - exclusie communities ,dominated by gated enclaes o the priileged, or
excluded communities ,dominated by ghettos o the depried,. Another is domination by
trav.ievce. A transient population lacks the abitit, to be sustainable ,community campaigns oten
take years o concerted action,. It also lacks the ritt ,clearly, members o the population are only
briely committed to the neighbourhood,. O course, one type o polarisation can easily slide
into the other.
6@ !"#"$%& Localities certainly need balanced communities. 1here is no possibility o a
sustainable community without an appropriate balance between settled residents and a transient
population. But balance is also needed or social justice. All orms o polarisation are based on
exclusion - the oluntary segregation o an exclusie group, or the disadantaged, excluded
inoluntarily. And balance is also needed or the common welare. Lery social grouping has its
strengths and weaknesses, whether this arises rom age or gender or culture. A balance between
dierse groups maximises the potential social capital o any local community. But goernment
makes no attempt to deine what is meant by a balanced community`. It is nowhere deined in
national policies, and rarely in local policies.
1he Belast Metropolitan Area Plan ..ve. Paer ov MO. ,2005, deined a balanced community as one
that is not dominated by one particular household type, size or tenure.` 1his would imply a community
made up, or instance, o equal shares o the three main housing tenures - owner-occupation, social
renting and priate renting. But this would be a ery odd community, quite at odds with normal
experience, where owner-occupation dominates.
6A B&C-$-.-*$ 1he key problem identiied by the members o the Lobby is aevograbic ivbatavce
in their neighbourhoods, which leads to rising problems and declining community, in short, to
unsustainability. 1he imbalance arises rom concentrations o lMOs, whose distinctie
demographic ,typically, young, high-density, transient, and unstructured, destabilises the local
community. 1he members o the Lobby seek to restore batavce to their communities, in order to
restore their .v.taivabitit,. Belast`s eort shows that eqvat proportions in the mix are not the
answer. As an alternatie, the Lobby proposes reerence to vorvat proportions, that is, the mix or
balance which is experienced by most people.


@
Balanced Communities and Studentification
________________________________________________________________________________________________________________
A balanced community is " %*++,$-.8 DE-%E "::2*F-+".&/ $".-*$"#
'&+*<2":E-% $*2+/. A number o points must be made.
lirst o all, this deinition is not re.critire: it is not intended to speciy that all
communities should match these norms ,rather, it proides guidance to those
communities who eel that they hae become imbalanced,.
Secondly, it is ae.critire: that is, it is based on the norms as they are, here and now
,they were dierent in the past and will change in the uture, they are dierent in
other countries, - the point being that they relect contemporary experience.
1hirdly, the reerence is to aroivatiov., not tight criteria.
linally, the deinition is rariabte - dierent norms will be releant in dierent
circumstances.
6G 5*2+ A whole range o norms might be inoked in dierent situations. 1he latest Census
proides a ariety o statistics, such as the ie main age bands o the population - children ,up to
15 years, comprise 20, young adults` ,16-29, comprise 1.5, adults ,30-44 and 45-59,
comprise 41.5 together, and older people ,60 plus, comprise 21. 1he current vrre, of vgti.b
ov.ivg proides the proportions o dierent orms o housing, such as - ov.ivg 1evvre: 0 are
owner-occupied, 18 social rented, and 12 priate rented ,1able 1,, ov.ebota 1,e: 64 are
amilies, 29 one-person, and lMO ,1able 5, |preious year, .ccovvoaatiov 1,e: 82 are
houses, and 1 lats ,1 other,|. 1he Lobby`s concern is with the sustainability o
communities - the most releant batavce thereore is between household types ,since amilies in
general hae a stronger commitment to permanence than single people or multiple households
|indeed, priate rented housing which includes lMOs has an aerage tenancy o only eighteen
months|,. Allowing or a degree o deiation rom the norm |see para 76 below| the Lobby`s
particular criteria or a batavcea covvvvit, are ;a) vot te.. tbav 0 favitie., ;b) vot vore tbav ove
er.ov bov.ebota., and ;c) vot vore tbav 10 MO.. ,It is important to note that household
proportions and population proportions are not the same, as households ary in size. One-
person households are single o course, while the aerage amily household comprises about two-
and-a-hal persons, and the aerage lMO at least ie persons. On this basis, the normal
population balance is 2 in amilies, 12 single people and 15 in lMOs.,

76 H::2*F-+".-*$ \hat degree o deiation
rom the norm remains acceptable A standard
deiation could be adopted ,10, 20, 25,
33, 50,. But a low igure is clearly
inappropriate i the norm is low ,or instance, a
10 deiation rom a norm allows or a
range o 6-8 only, - while a high igure is
equally inappropriate or a high norm ,a 50
deiation rom 66 allows or a range rom 33-
99!,. 1he answer eidently is a ariable
deiation - that is, a deiation which aries rom
low or a high norm, rising to a high deiation
or a low norm. ,1hus, the Lobby`s criteria in
para 6G aboe are based on a 10 deiation or
amily households |norm 66|, a 20 deiation
or single persons |norm 28| and a 50
deiation or lMOs |norm |. As a rule o
thumb, the deiation |\| rom a norm |X| can
be calculated as \ ~ ,100 - X, 2.,


77 H::#-%".-*$ low large should the area
coered be 1here is a range o possibilities. ,a,
treet or block ,which is the basis or Glasgow`s
policy on lMOs - not more than 5 per street
generally, or 10 in certain areas,. ,b,
^eigbbovrbooa, comprising seeral streets ,the
basis or Loughborough`s 1hreshold Approach`
to student housing - using Small Output Areas
rom the Census, a neighbourhood is
understood as the lome Output Area plus all
other Small Output Areas sharing a boundary
with that area,. ,c, Covvvvit,, comprising
seeral neighbourhoods ,Leeds City Council
deines Community Areas or the purpose o
allocating Section 106 unds - they correspond
to areas recognised as communities by local
residents |or a ariation, based on Output
Areas, see R Unsworth & J Stillwell, 1revt,ir.t
Cevtvr, eea., Uniersity o Leeds, 2004, pp18-
20|,.


A
Balanced Communities and Studentification
________________________________________________________________________________________________________________
79 I-::-$< 1*-$. 1he tipping-point is the threshold at which a deiation departs so ar rom
the norm that a community tips rom balance to un-balance. \ith regard to lMOs, the tipping-
point can be expressed in terms both o population ,20, and o properties ,10,.
,1, 1he lMO tipping-point occurs rbev MO occvavt. eceea 20 of tbe ovtatiov. Normally,
lMO occupants account or about 15 o the population - the tipping-point represents a 33
deiation. It also signiicantly exceeds the whole o the young adult` band o the population ,16-
29 year-olds are 1.5,. ,Any community begins to seem unbalanced when any o the ie main
age-bands exceeds one-in-ie o the population.,
,2, 1he lMO tipping-point also occurs rbev MO. eceea 10 of tbe roertie.. Normally, lMOs
account or o households - the tipping-point represents a 50 deiation. At the same time,
gien the comparatiely large numbers in lMO households, i lMOs are 10 o households,
then their occupants account or about 20 o the whole population ,depending on the local
balance o amilies and one-person households,.
1he most common cause o a tipping-point or lMOs is demand by students or shared houses
- or studentification.


B
Balanced Communities and Studentification
________________________________________________________________________________________________________________
Studentification

7; )*$%&:. STUDENTIFICATION is a term coined ,by Darren Smith in 2002, to identiy
the process and the product o concentrated student settlement in uniersity towns in the
UK. It may be deined as .E& /,3/.-.,.-*$ *C " #*%"# %*++,$-.8 38 " /.,'&$.
%*++,$-.8. lere, substitute` means displacement o one community, and
replacement by another, community` means a group o people with a common ground
and continuity through time ,para 69,, local community` means one whose ground is
their locality, and student community` means one with a ocational ground ,para 6;,.
7= 4.2,%.,2"# :2*3#&+/ Studentification comprises dierent sorts o problem. 1he principal,
.trvctvrat robtev is demographic: studentiication entails demographic imbalance. Until the last
decade, high concentrations o students were unusual. But now, in the new millennium, it is
common in uniersity towns or a core o seeral ,or many, streets to be dominated by a student
population, with three particular characteristics - this population is transient ,moing annually,
leaing ater three years,, it is seasonal ,resident or two-thirds o the year, and it is young ,late
teens, early twenties,. 1he demographic pattern aries: Leeds, or instance, is a large city, with a
large student population concentrated in a ery compact area ,though proportionately small in
the city as a whole, |the redbrick model|, Loughborough by contrast is a small town with a
proportionately ery high student population |the smalltown model|.
7> J,$%.-*$"# :2*3#&+/ 1he secondary, fvvctiovat robtev. ,eects, arise directly and indirectly
rom the primary problem, the cause. At least iteen symptoms o studentification` may be
identiied ,para 96,. On the one hand, these include a ri.e in a range o problems, social,
enironmental, economic ,especially crime, squalor and a resort economy,. On the other hand,
secondary problems consist o aective o local social capital ,or community spirit,.
7? KF:&2-&$.-"# :2*3#&+/ Studentification is also an eerievce, which produces a sense o
alienation among residents. 1his eeling arises rom a number o actors. 1he structural
problems ,the demographic imbalance, lead to a sense o oppression in public places ,the
crowding,, and by contrast a sense o isolation at home ,the loss o networks,. 1he unctional
problems lead to ear o crime, to a reulsion rom the squalor o the enironment, and a sense
o rejection by the resort economy. Underlying these, residents eel anger at the sel-interest o
uniersities & landlords, and despair at their neglect by goernment.
7@ )",/& Many parties bear responsibility or the deelopment o studentification.
^atiovat gorervvevt has expanded lL, but has ailed to proide the resources and powers
necessary to manage the accommodation implications.
|virer.itie. hae let the accommodation o their students to an unregulated market.
tvaevt. hae usually congregated in what are perceied to be student areas`.
avatora. and their agents hae exploited the demand or student housing.
ocat gorervvevt has neglected the management o local housing deelopments.
Covvvvitie. hae sometimes panicked and led areas perceied as being inaded.
7A )*,2/& 1ypical stages may be identiied in the process o studentification.
_________________________________________________________________________________________________________________
L7M 1he ror, 1orer stage: the uniersity establishes a campus to accommodate its core business
,classrooms, libs, labs, oices, etc,
__________________________________________________________________________________________________________________________________________________________________________________________________________________________________
L9M 1he Ctoi.ter stage: the uniersity proides purpose-built accommodation or non-local
students, usually close to the Iory 1ower, and cloistered rom the host community.
__________________________________________________________________________________________________________________________________________________________________________________________________________________________________


1
Balanced Communities and Studentification
________________________________________________________________________________________________________________
L;M 1he etttevevt stage: student oerspill rom the Cloister settles in priate accommodation in
the neighbouring host community.
__________________________________________________________________________________________________________________________________________________________________________________________________________________________________
L=M 1he Studentification stage: expansion o student numbers leads to urther pressure rom, and
domination by, students o the areas already settled around the Cloisters: this is the moment o
studentification. I the proportion remains at ,or below, one in ie, it is readily accommodated
,and indeed has been or many years in many uniersity towns,. But one-in-ie is the tipping-
point` ,para 79,. \hen it exceeds this proportion, stresses appear. \hen students number ove iv
fovr, this impacts on the character o the area, and challenges social cohesion. I students number
ove iv tbree, the disproportion is marked, the student community achiees autonomy and becomes
the dominant social group ,being larger than any other segment,, and cohesion is lost. In some
cases, imbalance may increase, and students equal ,or een outnumber, the rest o the population
combined.
__________________________________________________________________________________________________________________________________________________________________________________________________________________________________
L>M 1he Destudentification stage: in the atermath o studentification ,already experienced by some
communities,, eacuation o the neighbourhood , to new Cloisters` or purpose-built housing,
leads to loss o demand, and collapse o the local housing market.
__________________________________________________________________________________________________________________________________________________________________________________________________________________________________

7G )*$/&N,&$%& Studentification includes a number o effect. o demographic imbalance ,para
96,. In particular, it also generates diicult relationships between the two communities at the
sharp end - local residents and students themseles. And dierent perspecties on those
relationships hae deeloped.

Residents adopt a range o stances.
Mititavt.: some residents ,especially local youth,
deelop strong antipathy to students.
Pa..iri.t.: the majority o residents maintain a
low proile, and respond to circumstances,
eentually, pushed by declining amenity, and pulled
by rising property prices, many emigrate.
aeati.t.: some residents empathise with, support
and deend students.
Reati.t.: some resident actiists attempt to
analyse studentification as a problem, and to address
its causes.
Students also maniest a range o stances ,in parallel
with residents,.
Cotovi.t.: some students assert territorial claims
to student areas`.
Cavfottorer.: the majority o students ollow
their predecessors into student areas`, and pursue
their own interests, obliious o their
circumstances.
aeati.t.: some students identiy with the local
community, and try to put something back`.
Reati.t.: some students recognise studentification
as a problem.
1he Groundhog Lect: relations between residents and students are complicated by the range o dierent
reactions ,and their inter-relations,. But on-going dialogue is made almost impossible by the groundhog
eect` o studentification. As temporary residents, students are unaware o the a.t o an area, and hae
no knowledge that it was eer otherwise. Similarly, as temporary residents without a fvtvre in the area,
many students are unable to engage in long-term strategies. Relations between residents and students
thereore remain in an eternal re.evt, and hae to be renewed eery year, with each new cohort o
students.
Despite the aspirations o the Idealists on both sides, residents and students remain distinct communities.
1he only possible relation between Colonists and Militants is conrontation ,like the Belast Incident o 23
No 2004,. Camp-ollowers and Passiists remain largely obliious o each other. But een Idealists
ollow parallel paths: in Leeds 6, or instance, there are many local community associations addressing
neighbourhood issues ,leadingley Network, lar leadingley Village Society, South leadingley
Community Association, etc, etc,, but neertheless, students ,in good aith, hae independently
established the LS6 Project` to do exactly the same. A Realist approach is the only iable option.

C
Balanced Communities and Studentification
________________________________________________________________________________________________________________
D6%-'3?4

96 48+:.*+/ *C Studentification lIl1LLN S\MP1OMS may be identiied. 1hey arise
directly and indirectly rom the primary problem o demographic imbalance. On the one
hand, they include a ri.e in a range o problems ,especially crime, squalor and a resort
economy,: some problems are social, some problems are enironmental, and some are
economic, aecting all these are traic problems, and oerwhelming pressure on public
serices. On the other hand, secondary problems include aective o local social capital ,or
community spirit,, and loss o serices.

O5)PKH4K QJ 1PQ!RKS4
ociat Probtev.
L7M H$.-T4*%-"# !&E"U-*,2: endemic low-leel
ASB, including noise nuisance, minor andalism,
public drunkenness, eacuation.
L9M )2-+&: high rates, especially burglary.
L;M O$/,2"$%&: owners pay top premiums or
house, contents, ehicle insurance.
vrirovvevtat Probtev.
L=M 4N,"#*2: surrounded by litter, rubbish,
lytipping.
L>M B&2&#-%.-*$: neglect o houses and gardens,
oer-deelopment o houses and gardens.
L?M 4.2&&. !#-<E.: letting boards, lyposting,
security grilles.
covovic Probtev.
L@M B-/.*2.&' P&."-#: orientation towards a ery
speciic market, maniest in the particular range
o lines in shops, and the range o retail outlets
,especially increased numbers o pubs, take-
aways and letting agencies,.
LAM J#,%.,".-$< S"2V&.: rom high demand
,term-time, to low demand ,in acations,.
LGM )"/,"#-/&' K+:#*8+&$.: local
employment becomes increasingly seasonal
,term, and part-time ,eening,.
Ceveric Probtev.
L76M )"2:"2V-$<: obstructs paements or
pedestrians, and access by emergency ehicles,
cleansing, buses, and residents.
L77M 4&2U-%&/ QU&2DE&#+&': not only
disproportionate demands on public serices like
cleansing and policing, housing and planning,
but also indirectly the drain o resources away
rom proision in other areas |and neither
students nor landlords pay Council 1ax or
Business 1ax|.
BK)RO5K QJ )QSSW5OIX

L79M B&%-+".-*$: student demand gies rise to
high property prices and low amenity,
encouraging emigration and making immigration
almost impossible, with the result that there are
ewer elders ,retaining past memories,, ewer
adults ,present actiists, and ewer children ,the
community`s uture,.
L7;M B-/2,:.-*$: most owners and occupiers are
absentees ,hence disengaged,, the young and the
old especially are isolated ,losing their peers,,
and the neighbourhood loses its social capital or
community spirit` ,its social networks, social
norms and social sanctions,.
L7=M B-/.2&//: deep and rapid changes are elt
acutely: the population imbalance itsel is
stressul ,public oppression, priate isolation,,
the declining amenity is alienating ,ear o crime,
reulsion rom squalor, exclusion rom the
economy,, and residents eel anger and despair
at their disempowerment.
L7>M 4&2U-%&/ W$'&2DE&#+&': school closures
as amilies depart ,ironically, reducing
education,.
















E0
Balanced Communities and Studentification
________________________________________________________________________________________________________________
F%';#$%&

97 I&$ 1*-$. 1#"$ IS 1lLRL A SOLU1ION In many communities, the damage has been
done, and there will be no return to the preious balance. Also, there is no single solution
- numerous measures are necessary. Dealing with the problems o polarisation, and
restoring sustainability, requires concerted action. No one policy will resole polarisation,
nor will one party. All concerned must act together, council and community, uniersities
and students, and landlords. Since polarisation in general, and studentification especially,
inole a particular pattern o land-use, tavvivg measures are crucial. At the same time,
the actual land use is residential, so bov.ivg measures hae a ital bearing. linally, i
cumulatie action is necessary, it needs to be co-ordinated - so vavagevevt measures are
needed. In all, ten key actions need to be taken. ,NB the measures considered here could
be applied to any orm o polarisation caused by high turnoer.,
99 lirst, H%%*++*'".-*$ H,'-. 1he irst requirement is to establish the
breadth and depth o the problem - where is the transient population located,
and to what degree o penetration low does it change, year by year 1he
local uniersity is the key actor here, as it knows where its students lie ,o
course, collectie not indiidual data on distribution is what is needed,.
Students o course proide their uniersity with this inormation. I
necessary, the council and the community may need to lobby the uniersity to
proide it.
1he Uniersity o
Leeds proides
annual data on the
distribution
throughout the
city o its students.

Leeds and Nottingham hae established a Shared
lousing Group and a Student Strategy
Leadership Group respectiely, comprising
representaties o all local stakeholders.
9; Second, )*T*2'-$".-*$ In order to work
together, stakeholders need some orm o orum.
All are responsible or actiely engaging, but it is
up to the local authority to set up such a orum.

9= 1hird, H%.-*$ 1#"$ Lach stakeholder will need its own strategy ,see
Section 6,. But these will be ineectie without coordination. Again,
the local authority needs to take the initiatie, but other stakeholders
must support the council.
Leeds and Nottingham
hae both adopted
Student lousing Action
Plans.

1he National
lMO Lobby
has produced
a ^otificatiov
orv or
licensable
lMOs. See
also \hat is
a lMO`,
9> lourth, S"$'".*28 YSQ R-%&$/-$< 1hrough the lousing Act 2004, the
goernment has introduced licensing o lMOs in Lngland & \ales. \ith regard
to polarisation, licensing`s most useul role is in identiying the location o lMOs,
hence where the transient population is located. By law, local authorities now hae
to issue licences, and the landlords hae to apply or them. ,lLIs are also required
to adopt codes o practice or their properties., Communities and students hae a
shared interest in supporting licensing - or instance, by reporting licensable
lMOs to the council. ,In Scotland, all lMOs are already subject to licensing. In
Northern Ireland, all are in selected areas, and ery large lMOs elsewhere.,

9? lith, H''-.-*$"# YSQ R-%&$/-$< Mandatory licensing applies only to larger
lMOs. But the lousing Act proides also or the licensing o all additional lMOs
in designated areas, in Lngland & \ales. Additional lMO licensing is essential, to
take ull adantage o licensing ,and to remoe an escape route or any landlords
trying to aoid mandatory licensing,. 1he local authority has to apply to
goernment to introduce additional licensing. Responsible members o the priate
rented sector ,PRS, can support the council. 1he community, students and
uniersities hae a shared interest in lobbying the authority to take action. And the
goernment should support the authority`s application.
Southamp
ton is
committed
to applying
or
additional
lMO
licensing
throughout
the city.

EE
Balanced Communities and Studentification
________________________________________________________________________________________________________________

leadingley
Deelopment
1rust in Leeds is
reiing local
amenity, and
planning a
Community Land
1rust to interene
in the local
housing market.
9@ Sixth, P&/.*2".-*$ *C !"#"$%& A destabilised neighbourhood will not
easily re-balance itsel. Studentification makes this ery diicult. In due course,
de-studentification may proide opportunities. Only the resident population
itsel can restore sustainability to a community. Aboe all, it needs
commitment, in order to do so. But all stakeholders can lobby or, and
proide support to, the re-introduction o long-term residents, especially
amilies ,whether partners only, or partners with dependants, or single people
with dependants,, especially within policy rameworks set by local and national
goernment.

9A Seenth, H2&"/ *C P&/.2"-$. Local planning authorities around the
country are adopting a range o local lMO plans to deal with the
problems o concentrations o lMOs or student accommodation ,the new
planning regime o Local Deelopment lrameworks gies opportunities to
do this,. One o these plans is the idea o an Area o Restraint`, in order
to resist urther deelopment where there are already high concentrations.
1he council is o course the lead actor here. Community associations can
lobby or some orm o restraint, while uniersities, students and the PRS
can oer their support. National goernment too, through the Planning
Inspectorate, can support such policy initiaties.
1he best-known such
policy is Leeds
ASlORL ,Area o
Student lousing
Restraint,, which has
been supported by
Planning Inspectors,
though redesignated
an Area o lousing
Mix`.

Glasgow has set
ceilings or the
proportion o lMOs
in a neighbourhood.
Loughborough is
adopting a series o
thresholds which will
goern planning
permission.
9G Lighth, IE2&/E*#' 1*#-%8 Another measure that has been proposed
by local councils is the idea o some sort o threshold, beyond which
urther deelopment o lMOs or student accommodation will be
resisted. 1his is meant to preent concentrations deeloping in the irst
place. Again, the council takes the lead. Uniersities, students and the
PRS can support the council by encouraging the dispersal o student
accommodation. 1he community can lobby or both. And the Planning
Inspectorate can support such a policy initiatie.

;6 Ninth, 1,2:*/& !,-#. B&U&#*:+&$. Some councils also support the
deelopment o purpose-built housing or students. Such housing takes
the pressure o conersion o amily homes into lMOs ,and in a time o
housing shortage, this is ar better than the conersion o amily homes
into seasonally-occupied second homes,. At the same time, the siting o
purpose-built deelopment has to be careully handled, so that it does not
in act increase polarisation. Uniersities, student unions and deelopers
can take initiaties, independently or together. 1he council can suggest
locations, and communities can lobby or this sort o deelopment. 1he
Planning Inspectorate can be supportie o deelopments endorsed locally.
1here are many joint
lLI,PRS entures o
this sort. O
particular interest was
NUS`s plan or
purpose-built co-
operatie student
housing. Newcastle
has published
guidance on purpose-
built sites.

1he National lMO Lobby has
been lobbying or years. In
Northern Ireland, the Dept o
the Lnironment has in act
changed its own Use Classes
Order. On 15 January,
Planning Minister Iain \right
reported to Parliament that the
Use Classes Order in Lngland
& \ales in relation to lMOs
was to be subject to
consultation.
;7 1enth, W/& )#"//&/ Q2'&2 Many council ideas are hamstrung
by national planning legislation. 1hey can control only
deelopments which need planning permission. Restraint and
threshold policies in particular are undermined by the limitations
o the current Use Classes Order - which allows amily homes to
be conerted to lMOs without planning permission. A change
o the Use Classes Order ,redeining lMOs, and subjecting them
to planning permission, would make an enormous dierence to
the power o local councils. lere, it is up to goernment to take
action - and all local stakeholders should lobby the goernment
on this issue.

E/
Balanced Communities and Studentification
________________________________________________________________________________________________________________
2%&<';4$%&

;9 4."V&E*#'&2/ \lA1 1lLN CAN \L DO lie local stakeholders are inoled in
studentification, and one national. 1he local stakeholders include both sides o ligher
Lducation, the uniersities and their students, they include both local councils and the
communities they represent, and they include the priate rented sector ,PRS,, which
dominates studentiied housing. 1he national stakeholder is o course the goernment.
All stakeholders supporting the 1en Point Plan need to adopt a strategy towards the
polarisation which arises rom concentrations o student housing.
;; )*++,$-.8 H//*%-".-*$/ ,CAs, 1he local
community has the strongest motie to adopt a
strategy, as its ery surial depends on
resisting polarisation - yet at the same time, it
is the weakest o the stakeholders. 1he
community`s irst job thereore is to build its
capacity - organisation is essential ,and in a
large town, where more than one community
association may be inoled, co-ordinated
action is inaluable - Leeds lMO Lobby and
the Nottingham Action Group are examples o
umbrella community organisations.,. 1he
community may look or outside help - it may
een consider setting up a local Deelopment
1rust. Otherwise, the local community
depends on lobbying - or local housing and
planning policies especially - and community
associations can support their council`s
initiaties ,especially the introduction o a local
Student lousing Strategy,. It is important
thereore to adopt a clear guiding strategy.
;> 4.,'&$. W$-*$/ ,SUs, Regrettably, NUS
remains in denial oer the issue o
studentification, though it is students who are at
its sharp end ,see NUS, tvaevt. iv tbe
Covvvvit,: !or/ivg togetber to acbiere barvov,,
unortunately, despite its subtitle, this libels the
Lobby,. 1his is not always the case howeer
with local student unions ,and not at all with
many indiidual students,. Student unions can
support housing and planning initiaties by
their local councils, and there are some issues
where they share an interest with the local
community ,like additional lMO licensing,.
Certainly, they too hae an interest and an
obligation in preparing a strategy or the
accommodation o their members.
;= R*%"# H,.E*2-.-&/ ,LAs, 1he council is the
local ringmaster. It has a responsibility to its
communities ,not to mention a sel-interest, to
maintain their sustainability. It also has many
powers and resources ,though not as many as it
needs,. So, the local council has to take the
initiatie - in setting up a management
structure, in licensing lMOs, and in
introducing planning policies. It can support
initiaties by other local stakeholders, and it
can lobby local uniersities and national
goernment or supportie action. All councils
hae a housing strategy - this should include a
speciic tvaevt ov.ivg trateg,, so that
deelopments take place to beneit both
students and communities.
;? Y-<E&2 K',%".-*$ O$/.-.,.-*$/ ,lLIs,
lor too long, uniersities kept aloo rom their
eect on their host communities ,and their
goernment department, the DIUS, still does,.
But their organisation, Uniersities UK, has
now acknowledged the problems, in their
report tvaevtificatiov: a gviae to oortvvitie.,
cbattevge. ava ractice. ,2006,: it is
incontroertible that the negatie eects o
studentification are eident in seeral towns and
cities across the UK` ,para 3.12,. Uniersities
can o course proide accommodation or their
students, and indeed most do - though rarely
or more than a minority. So uniersities
should also support initiaties taken by their
local councils to deal with the problems raised
by their students liing in the priate rented
sector - in the community`. Indeed, since it is
uniersities which recruit students, they hae
an obligation to deelop a strategy or housing
them ,see or instance, Leeds Uniersity`s
ov.ivg trateg,,.



E9
Balanced Communities and Studentification
________________________________________________________________________________________________________________
;@ 12-U".& P&$.&' 4&%.*2 ,PRS, It is both practically and logically diicult or the PRS to
deelop a strategy. Logically, the PRS is the main agent in deeloping studentification, and it has
the least interest in doing anything about it ,in act, many landlords igorously oppose local
housing and planning strategies,. At the same time, practically, the PRS is the least co-ordinated
stakeholder - it is made up not only o landlords in competition with each other, but also
increasingly with the deelopers o large-scale purpose-built housing ,it also includes letting and
managing agents,. Neertheless, responsible landlords and deelopers can act on and support
local council strategies, such as local accreditation and licensing schemes. ,A unique organisation
grounded in the PRS is Unipol, the student housing charity based in Leeds, which has now
organised seeral national conerences on the issue o studentiication.,
;A Y&2 S"Z&/.8[/ \*U&2$+&$. ,lMG, 1he ultimate responsibility or the mess o
studentification howeer lies with the goernment, and its incoherent policy deelopment. On the
one hand, the goernment has ,laudably, promoted access to higher education - but without a
moment`s thought to its housing implications, still less to the local eects these will hae. On the
other hand, national goernment has steadastly resisted giing local goernment the powers it
needs to pick up the pieces. Goernment has turned a dea ear to lobbying oer studentification,
and a blind eye to its consequences. ,Indeed, ODPM commissioned Uniersities UK`s
tvaevtificatiov Guide - but speciically excluded any attention to changes in legislation rom its
terms o reerence., Stakeholders around the country badly need a coherent strategy or student
accommodation rom the goernment.
;G P&/.*2".-*$ Since its inception, the National lMO Lobby has lobbied or
legislation, both housing and planning, to enable regulation o lMOs. All parts o the
UK now hae some orm o licensing. Northern Ireland has shown the way with
planning legislation. 1he Lobby trusts that the other national authorities will ollow suit.
\ith adequate powers, local authorities throughout the UK will be able to address the
problem o concentrations o lMOs - whether student lMOs in uniersity towns, or
claimant lMOs in seaside towns, or migrant worker lMOs in market towns. Not only
may local communities be saed rom urther erosion - but maybe also, they can begin to
see a restoration o their balance and cohesion, and hence their sustainability.


E=
Balanced Communities and Studentification
________________________________________________________________________________________________________________
G3H363&<34


Richard I8#&2, Comprehending Community` ,pp21-28,, in S lerbrechter & M liggins, eds, Retvrvivg ;to)
Covvvvitie.: 1beor,, Cvttvre ava Potiticat Practice of tbe Covvvvat, Rodopi, Amsterdam & New \ork,
2006

Darren 4+-.E] Patterns and processes o studentiication in Leeds`, Regiovat Rerier 12:1 ,2002, pp14-16.
W$-U&2/-.-&/ W^, tvaevtificatiov: a gviae to oortvvitie., cbattevge. ava ractice UUK, London, January 2006
5".-*$"# W$-*$ *C 4.,'&$./, tvaevt. iv tbe Covvvvit,: !or/ivg togetber to acbiere barvov,, NUS, London,
11 June 200

National lMO Lobby, \hat is a lMO`
National lMO Lobby, Local lMO Plans`

_K!4OIK4
R*%"# Some members o the National lMO Lobby:
Broomhill Action & Neighbourhood Group Sheield
De lailland Resident's Association latield
Lgham Residents Association Surrey
lighield Residents Association Southampton
lillhead Community Council Glasgow
Jesmond Residents Association Newcastle-upon-1yne
Leeds lMO Lobby Leeds
Nottingham Action Group Nottingham
Redland & Cotham Amenities Society Bristol
Spon Lnd & Chapelields Community lorum Coentry
1albot Village Residents Association Poole
\inton Community lorum Bournemouth
5".-*$"#
National lMO Lobby an association o community groups concerned to ameliorate the impact o
concentrations o lMOs on their communities
National lMO Network aims to promote a wider understanding o all aspects o lMOs
O$.&2$".-*$"#
1own Gown \orld on town and gown planning rom around the world

Q.E&2 Q2<"$-/".-*$/
Department or Communities & Local Goernment responsible or housing and planning in Lngland &
\ales
1he Scottish Goernment responsible or housing & planning in Scotland
Northern Ireland Lxecutie responsible or housing & planning in Northern Ireland
Local Goernment Association representing local authorities
Uniersities UK representing ligher Lducation Institutions
National Union o Students representing students
Landlords UK proiding links to landlord associations




E@
!"#"$%&' )*++,$-.-&/ "$' Studentification



























!"#$%&"' )*+ ,%--.
)"2'-<"$ )&$.2&] 7=>T7=@ )"2'-<"$ P*"'] R&&'/ R4? 7R`
/001

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!* +,-./012 3 $44,5 6/07 8 $ 9:2*-05 -; &,<,=->?,.*
3| leorards 3c|oo|, W||c| occup|ed |||s 14.5 acre (5.4 |ec|are) s||e lor ou|door spor|s lac|||||es ard
res|der||a| accorroda||or, dec|ared || surp|us |o requ|rerer|s, |r 2000, ard er|ered |r|o ar agreerer|
W||| Kr|g||sor|dge, ||e uprar|e| d|v|s|or ol booer|sor's lores, |o deve|op || lor |ous|rg. T|e
adjacer| |eror|a| losp||a| Was |rcorpora|ed |r|o ||e s||e lor p|arr|rg purposes, W|er || oecare
vacar|, |rcreas|rg ||e |o|a| area |o 17 acres (o.9 |ec|ares).
T|e Aooey lar| es|a|e |s ur|que W||||r 3| ArdreWs as ||e or|y surv|v|rg res|derce W||| ex|ers|ve
po||c|es, da||rg oac| |o ||e 1700s. l|s pr|rc|pa| ou||d|rg, ||e 8-||s|ed Aooey lar| louse, a|||oug| ruc|
a||ered, Was occup|ed a| ore ||re oy booer| C|aroers, au||or ol ||e ser|ra| ` ;%+"4<%+ &5 "=% >("?)(8
34+"&)/ &5 @)%("4&'' (1844), W||c| lores|adoWed C|ar|es 0arW|r's `A)4<4'+ &5 !9%B4%+' oy severa|
years. Aooey lar| louse |s des|gra|ed lor a 47-roor |o|e| deve|oprer|, ou| ro ouyer |as oeer
lourd, ard due |o ||s de|er|ora||rg cord|||or, || |s currer||y or l|s|or|c 3co||ard's 8u||d|rgs a| b|s|
beg|s|er. T|e prelererce ol ||e deve|oper Wou|d oe |o adap| || lor s|uder| accorroda||or.
1
3| leorards | Aooey lar| |s ||e |arges| s|rg|e s||e |der||l|ed lor deve|oprer| |r ||e ||s|or|c core ol 3|
ArdreWs s|rce ||e ou||d|rg ol ||e ca||edra| |r red|aeva| ||res. T||s |s re|evar| |o ||e suosequer|
||s|ory ol ||e s||e, as || prov|des ||e oac|grourd lor ||e |ers|ors oe|Weer corserva||or ol ||e |oWr's
||s|or|ca| asse|s ard ||e asp|ra||ors ol ||e deve|oprer| |rdus|ry. l| a|so serves as ar a||egory lor ||e
exper|erce ol roderr deve|oprer| |r ||e |oWr as a W|o|e.
Apar| lror Aooey lar| louse, aro||er rajor ou||d|rg or |||s s||e, 3| leorards l|e|ds louse, Was
corver|ed |o prov|de 28 l|a|s |r 2003. 3| N|c|o|as louse (1930), ||e secord ||s|ed ou||d|rg or ||e s||e,
Was reluro|s|ed lor res|der||a| deve|oprer| (14 l|a|s) |r 2012. A lur||er sra||er ou||d|rg, 3| leorards
lodge, |s currer||y aWa|||rg dero||||or. T||s s||e ray oe used lor e|||er 14 l|a|s or as ous|ress | oll|ce
accorroda||or.
TWo corsecu||ve p|arr|rg app||ca||ors lor ||e erec||or ol lour |Wo-s|orey dWe|||rg |ouses ard 24 l|a||ed
dWe|||rgs or ||e lorrer sc|oo| p|ay|rg l|e|ds Were relused |r Augus| 2001 ard |ay 2005 respec||ve|y.
Ar app||ca||or |o erec| 30 dWe|||rg |ouses |r ||e Wa||ed garder Was W|||draWr oelore de|err|ra||or |r
|ay 2005. T|e reW-ou||d Adarsor Cour| (28 l|a|s) or |||s s||e Was occup|ed oy 200o. T||s Was
|r|||a||y relused p|arr|rg perr|ss|or oy ||e Nor|| Fas| l|le Area Corr|||ee (NFlAC) lor ra|r|y
aes||e||c reasors, ou| a||oWed or appea|. loca| op|r|or |s ||a| |||s ou||d|rg |s ra|r|y u||||sed lor secord
|ores.
T|e 3| N|c|o|as | Aooey lar| |ard Was |rcorpora|ed |r|o ||e 200o ||era||or ol ||e dral| 3| ArdreWs ard
Nor|| Fas| l|le loca| l|ar, |oge||er W||| ||e adjacer| lorrer |eror|a| losp||a| as deve|oprer| s||e
3TA08 ard des|gra|ed lor r|xed use W||| ar |rd|ca||ve capac||y ol 120 |ores, a |o|e|, ard a ous|ress |
oll|ce lac||||y. T|e ex|s||rg 3| leorards l|e|ds ard Adarsor Cour| Were ro| |rc|uded |r 3TA08 ard are
ro| lur||er cors|dered |ere. A requ|rerer| ol ||e 200o dral| p|ar Was ||e produc||or ol a ras|er p|ar
oy ||e Courc||.
0u|||re p|arr|rg perr|ss|or lor dero||s||rg ||e |eror|a| losp||a| ard cors|ruc||or ol a res|der||a|
deve|oprer| ol 40 l|a|s |r ||ree o|oc|s Was approved oy ||e NFlAC |r 0eceroer 2011. T||s
deve|oprer| Was rever |a|er lorWard ard ||ere |s roW a proposa| |o deve|op |||s s||e lor a |o|e| ard
raraged s|uder| accorroda||or. T|e |o|e| e|erer| ray rep|ace ||e proposa|s lor Aooey lar|
louse. Ar app||ca||or lor a 241-s|uder| oedroor deve|oprer| Was suor|||ed |r Ju|y 2013 ard
approved oy ||e NFlAC or 9 0c|ooer 2013.
1
booer|sor lores suor|||ed a p|arr|rg app||ca||or (29 Ju|y 2013) |o corver| Aooey lar| louse |o pr|va|e s|uder|
accorroda||or W||| capac||y lor 98 s|uder|s.
1
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T|e coro|red s||e Was carr|ed lorWard |o ||e Adop|ed loca| l|ar (2012), re-des|gra|ed 3TA07, W||| ||s
|ous|rg capac||y |rcreased |o 2o0, a| ||e reques| ol ||e deve|opers. T|e or|g|ra| (200o) |ous|rg
ruroers Wou|d |ave produced a ders||y ol approx|ra|e|y 21 |ouses |o ||e |ec|are, a| ||e |oWer erd ol
||e ders||y ol a |yp|ca| suouroar deve|oprer|, W|||e |||s reW a||oca||or Wou|d prov|de a ders||y ol
approx|ra|e|y 37 ur||s |o ||e |ec|are, c|arac|er|s||c ol roderr l|a||ed deve|oprer|s. T|e |oca| p|ar
po||cy erv|sages a ders||y ol oe|Weer 25 ard 45 |ous|rg ur||s per |ec|are.
T|e 2009 Adop|ed loca| l|ar passed respors|o||||y lor ||e produc||or ol a ras|er p|ar lror ||e Courc||
|o ||e deve|opers ard |||s Was ||er c|arged |o a `3|ra|eg|c 0eve|oprer| lrareWor|' (30l), a ||g|er
|eve| p|ar W||| |ess prescr|p||or. l|ra||s|rg |||s proved proo|era||ca| lor ||e |Wo deve|opers (||e o||er
oe|rg l|le lea||| 8oard), due |o d|ll|cu|||es |r reac||rg a corror urders|ard|rg. Fllor|s |o |a|e
|rd|v|dua| e|erer|s ol ||e sc|ere lorWard |r ||e rear||re lourdered or ||e oas|s ||a| |||s Wou|d
represer| p|ecerea| deve|oprer|.
T|e 30l Was ever|ua||y produced W||| |rpu| lror ||e Courc|| uroar 0es|gr Tear ard adop|ed oy ||e
NFlAC as supp|erer|ary p|arr|rg gu|darce |r 0c|ooer 2011. A cord|||or ol ||e assoc|a|ed l|arr|rg
Agreerer| Was ||a| allordao|e |ous|rg, educa||or ard puo||c ar| cor|r|ou||ors Wou|d oe rade oy ||e
deve|opers.
A p|arr|rg app||ca||or W||c| coro|red ||e reluro|s|rer| ol 3| N|c|o|as louse (14 l|a|s) W||| ||e
cors|ruc||or ol 28 l|a||ed dWe|||rgs |o ||e ror|| ol 3| N|c|o|as Was relused oy ||e NFlAC |r Noveroer
2011, ra|r|y |r re|a||or |o ||e |e|g||, rass|rg ard |rpac| ol ||e reW ou||d or ||e adjacer| ||s|ed
ou||d|rgs |r 0reers|de l|ace ard ||e Corserva||or Area. T||s dec|s|or Was appea|ed |o 3co|||s|
||r|s|ers ou| ||e appea| Was relused. T|e allordao|e |ous|rg requ|rerer| lor |||s deve|oprer| Was
d|sergaged lror |||s relused app||ca||or ard seers |o |ave oeer lu|l|||ed oy ||e 9 l|a|s |o oe ou||| oy
K|rgdor lous|rg Assoc|a||or adjacer| |o 0reers|de l|ace, a proposa| W||c| rece|ved p|arr|rg
corser| ard secured lurd|rg lror ||e 3co|||s| 0overrrer| |r 2011. l| aWa||s ar a||oca||or ol par||rg
space lror ||e deve|opers oelore || car proceed. Kr|g||sor|dge arrourced a re|rerc|rer| ard
reorgar|sa||or ol ||s ous|ress alla|rs due |o d|ll|cu|| cord|||ors |r ||e |ous|rg rar|e|. T|e 3| N|c|o|as
|ouse reluro|s|rer| ||er proceeded or ||s oWr urder aro||er deve|oper, Fas|acre lrves|rer|s lll.
T|ere are currer||y 115 dWe|||rgs W||| p|arr|rg corser| or a|ready ou||| or |||s s||e, W||| a lur||er 11o
proposed. ll a|| Were ra|rs|rear |ous|rg, ar allordao|e |ous|rg y|e|d ol 70 ur||s Wou|d resu||. A| ||e
||re ||e 30l Was agreed |r 0c|ooer 2011, || Was assessed ||a| ||e 44 |cCar||y ard 3|ore re||rerer|
l|a|s or ||e |err|s cour| s||e Wou|d ro| a||rac| ar allordao|e |ous|rg cor|r|ou||or. T|e allordao|e
|ous|rg cor|r|ou||or Wou|d oe oased or a |o|a| ol 219 ur||s W||| a y|e|d ol 50 allordao|e |ores. T|e 9
K|rgdor lous|rg Assoc|a||or l|a|s |r 0reers|de l|ace are |rc|uded |r ||e l|gure lor allordao|e |ores.
loWever ||e |o|a| ol 50 allordao|e |ores |s ur|||e|y |o oe rea||sed oecause ol ||e reasors |der||l|ed
oe|oW.
Kr|g||sor|dge cor||rues as deve|oper lor ||e Wa||ed garder s||e ard |as oo|a|red p|arr|rg corser| |o
|rcrease ||e approved ruroer ol `ursuos|d|sed allordao|e l|a|s' lror 48 |o 78. l| Wou|d appear
a|||oug| ||e or|g|ra| l|gure ol 48 l|a|s |ere Wou|d |ave produced 12 allordao|e |ores, ||a| rore ol
||ese W||| roW produce ar allordao|e |ous|rg cor|r|ou||or. T||s `up||l|' |r ruroers W||| |rcrease ||e |o|a|
|ous|rg ur||s or ||e s||e (|rc|ud|rg ||e r|re K|rgdor lA |ouses) |o 249. loca| l|ar lo||c|es a||oW or|y
sra|| |rcreases |r |oca| p|ar a||oca||ors, so || appears ||a| ||e capac||y ol |||s s||e (2o0 ur||s) |as
a|ros| oeer reac|ed oy currer| approva|s.
2
!" $%&'()! T0wN C0||l33l0N or l0u3lN0 !" $%&'()*+ , -..%/ 0()1 2 - 34+"&)/ &5 6%7%8&9:%'"
A lur||er p|arr|rg app||ca||or, lor 18 serv|ced s|e||ered dWe|||rgs a| ||e oac| ol 0reers|de l|ace, Was
suor|||ed oy |cCar||y ard 3|ore |r |a|e 2012. T||s app||ca||or d|d ro| |rcorpora|e s|gr|l|car| c|arges
|o address ||e (esser||a||y aes||e||c ard erv|rorrer|a|) reasors W|y ||e Kr|g||sor|dge appea| lor ||e
sare s||e |ad la||ed, ard || Was |urred doWr lor s|r||ar reasors oy ||e NFlAC |r leoruary 2012.
Courc|||ors |ad prev|ous|y expressed corcerrs ||a| raragerer| c|arges ray pus| ||ese l|a|s oeyord
||e reac| ol peop|e W||| ||r||ed rears. No allordao|e |ous|rg cor|r|ou||or Wou|d |ave oeer ga|red
lror |||s deve|oprer|. loca| courc|||ors |ave reques|ed (Jure 2013) ||a| ||e allordao|e |ous|rg po||cy
oe rev|eWed |o de|err|re |l || |s ree||rg ||s oojec||ves.
T|e |eror|a| losp||a| s||e, W||c| d|d ro| l|gure |r ||e 30l Assessrer| ol Allordao|e lous|rg
cor|r|ou||ors as || Was a| a `l|arr|rg |r lr|rc|p|e' s|age, W|||, |l || proceeds, prov|de s|uder|
accorroda||or (W||c| W||| oe exerp|ed lror ||e allordao|e |ous|rg cor|r|ou||or), ard |o||day |e|s lor
||e surrer ror||s. T|e ex|ra prov|s|or ol |our|s| roors a| |||s |oca||or Wou|d a||oW Aooey lar|
louse, or|g|ra||y des|gra|ed lor ||e |o|e| deve|oprer|, |o oe adap|ed lor res|der||a| use.
A|| ||ese p|arr|rg proposa|s |ave oeer suojec| |o corsu||a||or. T|e 30l rece|ved ar er|arced |eve| ol
corsu||a||or ard ||e ou|core Was repor|ed |o ||e NFlAC. lrd|v|dua| deve|oprer|s Were a|so suojec|
|o corsu||a||or ever|s. A gerera| |rpress|or ol ||ese corsu||a||ors |s, |oWever, ||a| ||ey se|dor resu||
|r ary lurdarer|a| c|arges |o ||e p|ars ard a success|or ol suc| ever|s car resu|| |r corsu||a||or
la||gue.
w|||draWa| ol app||ca||ors, c|arges |o ex|s||rg corser|s ard repea| app||ca||ors lor projec|s prev|ous|y
relused p|arr|rg corser|, rary ro| rer||ored |r |||s accour|, |ave |r|ers|l|ed |||s proo|er. A
sugges||or oy ||e 3| ArdreWs lreserva||or Trus| ||a| ||e W|o|e s||e oe deve|oped |r co-opera||or W|||
||e corrur||y us|rg C|arre||e pr|rc|p|es |o avo|d corl||c| ard speed progress Was ro| |a|er up oy ||e
Courc|| or ||e deve|opers.
T|e lreserva||or Trus| |ad prev|ous|y ergaged W||| Kr|g||sor|dge |o |der||ly a corserva||or arc|||ec|
W|o ||er urder|oo| Wor| W||| ||e l|rr ard ||e Trus| |o |rprove ||e e|eva||ors ol ||e ou||d|rgs, ac||eve
a cors|s|er| approac| ard |r|egra|e ||er rore successlu||y W||| ||e ||s|or|c erv|rorrer|. l| |s ro|
|roWr W|e||er |||s Wor| W||| surv|ve c|arges ol deve|oper as eac| orgar|sa||or |erds |o |ave ||s oWr
|ouse s|y|e.
l| |s d|ll|cu|| |o avo|d ||e corc|us|or ||a| a |ac| ol c|ear processes ard co-ord|ra||or ol ||e var|ous
s|a|e|o|ders |rvo|ved |r deve|op|rg |||s s||e, as We|| as a la||ure ol ||e deve|opers |o ga|r corrur||y
suppor| lor ||e|r success|or ol proposa|s, |as cor|r|ou|ed |o de|ays |r ||e corp|e||or ol ||e overa|| p|ar
lor |||s |rpor|ar| projec|.
3

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