Houses In Multiple Occupation Planning Consultation

Option 1 (see Option 1)

Option 1 is to make no changes to the existing Article 4 Direction area.

We have identified this as an option because:

• Since 2010, changes in the number of HMOs have been relatively limited and
• The University of Exeter expects the growth in student numbers to be slower in the future. This could mean less demand for HMOs.

However, option 1 is not our preferred option because:

• We cannot be certain that the growth in student numbers will slow
• The evidence report indicates that some enlargement of the Article 4 Direction area is justified and
• We don’t think this responds to the concerns and expectations of residents in the local area

Option 2 (see Option 2)

Option 2 is our preferred option. This would result in the Article 4 Direction area enlarging to include:

• Postcodes where student-only homes are currently 20% or more, or which are expected to exceed that threshold in the near future based on evidence
• The University of Exeter’s Streatham Campus and areas of purpose built student accommodation (PBSA) that are contiguous with the affected postcodes
• Minor rounding off to create a more contiguous / logical area and
• No change to the “exempt areas” (i.e. streets within the Article 4 area where permitted development rights have not been removed because doing so could cause severe personal hardship to homeowners. This is on grounds that the streets already have a very high concentration of student properties.  The exempt areas are Culverland Road, Danes Road, Edgerton Park Road, Hillsborough Avenue, Mowbray Avenue, Old Park Road, Springfield Road, Victoria Street and Wrentham Estate)  

This is our preferred option because:

• It will help to maintain some balance between student and non-student housing in the area
• It will not unduly restrict the provision of HMOs for non-student residents, such as lower income households and households with specialist requirements who need this type of housing
• We think it responds to the concerns and expectations of residents in the area and
• It conforms with the Government’s requirement (set out in the National Planning Policy Framework, or NPPF) that Article 4 Directions are justified by clear evidence and applied to the smallest geographical area possible

A possible drawback with this option is that it could result in increased private rents, due to further restrictions on the supply by HMOs. However, this impact is uncertain.

Option 3 (see Option 3) 

Option 3 is to enlarge the Article 4 Direction area more than our preferred option, to include:

• Postcodes with 10% or more student properties (with a minimum of 2 student properties)
• The University of Exeter’s Streatham Campus and areas of purpose built student accommodation (PBSA) that are contiguous with the affected postcodes
• Minor rounding off to create a more contiguous / logical area and
• Enlarging or adding to the existing "exempt areas" to cover other streets with very high concentrations of student properties, so that some HMOs can still be provided in the area to meet needs

We have identified this option because:

• It will not substantially restrict the provision of HMOs in Exeter for non-student residents, such as low income households and households with specialist requirements who need this type of housing
• We think it will be supported by residents in the enlarged area

However, option 3 is not our preferred option because:

• Small postcodes either side of the Article 4 Direction’s new boundary may regularly change between meeting and not meeting the 10% threshold. This will not conform with the NPPF requirement that Article 4 Directions are justified by clear evidence and applied to the smallest geographical area possible
• Additional work will be needed to identify new “exempt areas”. This will delay our ability to introduce a new Article 4 Direction
• It will mark a significant change from our current planning policy on HMOs, potentially requiring a new planning policy which will take time for us to adopt.   This will delay our ability to introduce a new Article 4 Direction and
• Subject to changes in student numbers, it will require PBSA to be provided at higher rates in order to meet student housing needs

Option 4 (see Option 4)

Option 4 is to make a city-wide Article 4 Direction.

We have identified this option because:

• It has received some support in stakeholder discussions

However, option 4 is not our preferred option because:

• It is not justified by the evidence gathered
• It is highly contrary to the NPPFs requirement that Article 4 Directions are justified by clear evidence and applied to the smallest geographical area possible
• It will severely inhibit the delivery of HMOs for non-student residents, such as low income households and households with specialist requirements who need this type of housing
• It will mark a significant change from our current planning policy on HMOs, requiring a new planning policy which will take time for us to adopt.  This will delay our ability to introduce a new Article 4 Direction
• Subject to changes in student numbers, it will require PBSA to be provided at higher rates in order to meet student housing needs
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