SPP3 - Planning for Housing

• Shelter is by no means convinced that there is a sound case for promoting the use of planning controls over HMO accommodation. We call for careful consideration of the impact of existing planning restrictions on the availability of affordable housing and existing HMO licensing enforcement before revised guidance is published.

• As long as promoting the guidance in Circular 4/2004 to SPP3 does not indicate an increase in status, we have no objections as a matter of process to doing so. However, we would like to see changes to the wording of draft SPP3 to remove the assumption that local authorities should apply planning control over HMOs in a particular geographic area, or demonstrate why control is not needed in that area.

• Guidance should be amended to emphasise that a high standard of proof is required to show that a concentration of HMO accommodation in a certain area is having negative impacts on a community, and that these impacts are not more appropriately tackled through HMO licensing, landlord registration or anti-social behaviour powers.

• Revised guidance should also be amended to emphasise to local authorities the necessity of monitoring the impact of any planning policy to restrict the numbers of HMOs in an area. Monitoring should cover the availability of affordable accommodation, compliance with licensing requirements among existing HMOs, and the standards of HMOs that continue to operate in an area subject to planning restriction.