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Portsmouth Local Plan Consultation (Again)

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Langstone

The Portsmouth Local Plan is the document which drives all planning and development decisions in the city – it defines what can be built where, which sites are earmarked for development and which green spaces are protected. This edition will be in force until 2040 and you have 1 final chance to share your view.   (Lots of updates including on student halls and HMOs plus the introduction of co-living).

What Is Different?

We participated in a major consultation in 2019 which was the point where the public got their say (known in Planning circles as Reg18) and having been updated because of that consultation, it is now out for 'technical review' (Reg19) before submission to the Planning Inspector for final approval. In this context, 'technical review' generally means that if something is wrong, it can be corrected but if something is legal it is unlikely to be changed however many people object.

Some of the changes between this version and the previous one include, the introduction of PLP16 – a policy document detailing housing supply targets and how they will be met. "Under Policy PLP16, site allocations and HMOs have been included as new sources of housing supply. HMOs play a key part in housing delivery within the City, which is evidenced in the latest Housing and Economic Development Needs Assessment (HEDNA)." This is potentially good news as it is the 1st time PCC have ever acknowledged the role of HMOs in the local housing mix and also,  an HMO room counts as a dwelling so converted houses will now count toward the councils 'new homes' target. There are also changes which will have implications for Purpose Built Student Accommodation (PBSA) under another new policy document, PLP19, which relates to housing for specific groups.

The HMO specific changes are as follows:

  • 10% concentration test and 50m radius remain the same in Reg 18 and Reg 19 policies.
  • New anti-sandwiching element of the policy added at Reg 19 Plan, to ensure development does not result in a non-HMO property being 'sandwiched' between HMO properties – we had hoped that a sandwiched property would be allowed to convert to an HMO and will raise this again as part of our response.
  • Strengthened Reg 19 policy ensures 'accordance' of proposals with HMO SPD, from wording that sought to 'take account' of the SPD at the Reg 18 stage.
  • Reg 19 Policy provides new guidance to ensure that where concentrations of HMOs exceed the 10% threshold, any development proposals that further intensify HMOs are only permitted in exceptional circumstances – this is designed to stop, for example a 5-bed being converted to a 6-bed. If it gives them a tool with which they can object to super-HMOs it makes sense, but on the basis that the vast majority are in North End where the 10% threshold is hardly ever met, then just one more misguided change.

    • Additionally, we now have 'co-living'  (this is a block HMO that does not need to meet the HMO rules because it is not an HMO and if it is big enough, it will not need a licence either).  So, if we understand it correctly - a few people sharing a house in a community is a bad thing as the neighbours don't like it but a few dozen living in a co-living block (think hostel or hall of residence) is fine.  PCC seem to justify this approach on the basis that those living in co-living facilities will not be there permanently and their normal place of residence will be elsewhere yet if you read the examples, that just does not work and will not be the case.

    Their statement, "However, it is anticipated that increased provision of purpose built student accommodation and communal or co-living homes, as well as the provision of studio and one-bed properties, may reduce demand for HMOs."  - the issue is affordability, the people who can only afford a room in an HMO in North End will not be able to afford the en suite accommodation prices outlined.

    If you want to argue the point or just better understand it, try these two paragraphs:

    6.84 Communal or co-living schemes are commonly designed with communal spaces to foster and facilitate a sense of community and to tackle loneliness. Additional shared facilities like gyms and laundry rooms are usually part of communal and co-living schemes.


    6.85 One of the features of communal or co-living schemes is the ability to offer short-term contracts. Co-living accommodation is for rental periods longer than traditional short stay accommodation, but not for permanent occupation. This is usually seen as an advantage for the target user.


    Yet more HMO apartheid - yes we need them, but not next to us. perhaps the local plan needs to allocate an area and call it 'HMO Soweto'.

    There is much more in the Plan, covering everything from workplaces to drainage, trees to design standards, heritage, town centres and a whole host more.

    The consultation runs until 3rd September - full details here:  Portsmouth Local Plan - Portsmouth City Council 

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    About the author

    Martin Silman

    Martin began his landlord journey 18 years ago, while working in an international role for a global telecommunications company. Since retiring he has extended his portfolio, which he manages with his wife, but has always focussed on the ‘small student HMO’ sector preferring to offer homes in the community for small groups to the more common ‘pack them in and take the money’ mentality. He has chaired the PDPLA for the past 9 years and has overseen the Associations transition from small local self-help group to a much larger and more professional institution which is recognised and listened to nationally. Alongside his PDPLA role, he also has leadership roles in a number of other local organisations – bringing his unique perspective, driving for change and increased use of technology while respecting the history that brought us here.

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