At this months meeting of PRED (Portsmouth City Council's committee responsible for Portsmouth's Regeneration and Economic Development) various councillors petitioned for the Article 4 Direction which limits the number of HMO's in any area to 10% to be tightened up.
In contrast, the PDPLA argued that:
- The current measurement method works (we have observed several planning committee meetings where members have sought alternative measurements with a view to arriving at an alternate outcome but in our view, none of the alternatives suggested improve the overall methodology or rigour currently in place).
- Although it works, it is expensive - it is apparent that a lot of time is spent identifying which dwellings need to be included and whether they are currently HMO's or not.
- We suggested improvements to the implementation to simplify and reduce the overall cost as follows:
- The Article 4 direction needs to be brought into line with Additional Licensing. Asking people to go through this process in the north of the city has resulted in several cases where multiple residents have objected only to see the application approved as the density is so low. This is not good for local democracy as it leaves large numbers of aggrieved residents and also, each of these applications cost PCC money. (For example, 22 Priorsdean Avenue, PO3 6AH - submitted in Aug2013 generated 19 objections but was passed as there were no grounds to reject the application)
- The current 10% limit does not build 'mixed and balanced' communities. We are not aware of any other authority with a threshold so low. We'd argue that 20% or 25% is normal and acceptable and that staying with the 10% will financially impact the University by limiting its opportunity for short term growth and thus it will also impact the city.
- The previous administration agreed there was a problem with "trapped C3's" but never came up with a satisfactory solution. We recommend that where a C3 property is surrounded by C4 dwellings, it is unsellable (do you remember the Playfair Road example where the owner could not sell at the C3 price level as it was surrounded by C4's) and as such, policy needs to be updated to allow such properties to be granted C4 status. Our recommendation would be to allow a move to C4 from C3 where completely surrounded as a trapped C3 becoming C4 has minimal impact on the community and it is not fair forcing a family to live sandwiched. Also putting sharers in a trapped dwelling has less impact on the larger community than inserting a new C4 in virgin territory.
- Our final request was that the 'dual use C3/C4 status' be reviewed. At present two identical C4 dwellings will be treated differently depending on whether the owner has applied for C3/C4 dual use or not and if he has, it will have cost him time and the council in excess of £150 processing the application. We obviously need the ability for a 'term time' C4 to be used for holiday lets during the summer and in years when the Uni contracts, for landlords to take on families or professionals without losing the ability to go back to student lets the following year, but this could simply be achieved with an automatic C3/C4 for, say, 3 years after last C4 usage after which an automatic reclassification to C3 would appear logical. This approach would avoid all of the cost and administration that PCC currently faces and also simplify some of the current 'HMO counting' where properties which have C3/C4 are included but may not be used as C4's for some considerable time.
Councillor Luke Stubbs who chairs PRED appeared to take some of these arguments onboard and has asked planning officers to look at options to improve the scheme and to include simplifying the whole C3/C4 dual status issue. No decisions yet, but we will be back at the next meeting in March and developments will be reported here.