The Consultation Paper asks sixteen questions, but it is not necessary to answer them all.

We would recommend the following responses to five key questions. The Questions are in bold, and suggestions for responses in italics. See also the longer Model Response below.

First of all, the Consultation asks you to say who you are. If you are writing as an individual, mention how long you have lived in your neighbourhood. If you are writing on behalf of an organisation, outline your role in it, its area of interest and its membership.

1. Do you experience problems/effects which you attribute to high concentrations of HMOs? [Consultation Question 1]
a) Outline the scale of the local HMO problem: size of the area? for how long? proportion of HMOs?
b) Summarise the effects of the HMOs: noise? antisocial behaviour? crime? rubbish? houses & gardens? streets? local shops? local amenities? traffic? parking? etc?
c) Outline the effects on the local community: population balance? population turnover? local schools? neighbourliness? control over the community’s future? community spirit?
d) Give evidence of the problems.

2. Option One proposes no change to legislation, instead relying on measures that have been tried in university towns (like university community strategies, student liaison officers, landlord accreditation, extra council resources in student areas, and when students come and go). Could promotion of such measures sufficiently deal with the problems associated with HMOs? [Consultation Question 3]
a) These measures will not tackle all the problems in 1b above. They are not effective anyway.
b) Such measures will do nothing at all for the problems described in 1c.
c) And they depend on voluntary action by councils and universities.

3. Option Two proposes changing the ‘Use Classes Order’, so that planning permission is needed to convert a home to a HMO. Should planning legislation be amended along the lines of option 2? [Consultation Q4]
a) Councils need the power to be able to control HMOs, if this is necessary locally.
b) Should planning legislation introduce a definition along the lines of the Housing Act 2004? [Consultation Question 5] The main problem is that there is no definition of ‘HMO’ in the present legislation.

4. Option Three proposes changing the ‘General Permitted Development Order’, so that HMOs are allowed everywhere; councils can then apply to the government for an ‘Article 4 Direction’, permitting them to refuse HMOs in particular areas. Should planning legislation be amended along the lines of option 3? [Consultation Q4]
a) This will remove all control over HMOs from councils everywhere.
b) This will oblige councils to apply for a Direction. And it leaves the decision to the government.
c) Landlords can claim compensation if they are refused: this will prevent councils from applying.

5. Would the benefits of greater control over HMOs outweigh the costs of processing more planning applications? [Consultation Question 16]
a) The Consultation itself says, “local planning authorities are assumed to have no additional costs given that the fees cover the administrative costs,” p28.
b) The costs of HMOs to councils and Council Tax-payers of the problems outlined in 1 above are enormous.

If individuals or organisations want to make a fuller response, contact Cllr Shaun McGall for guidance or you the longers version of the suggested response below.

The deadline for responses is 7 August 2009.

Send responses by email to:

UCOHMOConsultation@communities.gsi.gov.uk (subject: HMO Consultation)

Or by post to:

Susan Turner, Planning System Improvement Division, Department for Communities and Local Government, Zone 1/J10, Eland House, Bressenden Place, London SW1E 5DU.

Cllr Shaun McGall would appreciate a copy of any response sent to the government.