Manchester City Council Item 6 Communities and Neighbourhoods Overview and Scrutiny Committee 8 March 2011

Manchester City Council Report for Resolution

Report to: Communities and Neighbourhoods Overview and Scrutiny Committee – 8 March 2011

Subject: Student Strategy Implementation Plan

Report of: Director of Neighbourhood Services

Summary

To provide a report on the progress of the Student Strategy Implementation Plan

Recommendations

That Members note the content of this report.

Wards Affected: Primarily , , , , , and .

Community Strategy Spine Summary of the contribution to the strategy

Performance of the economy of The universities play a key role in the economy of the region and sub region the city. The plan demonstrates a partnership approach in tackling some of the issues that impact at a local level

Reaching full potential in Through the Corridor Partnership, universities will education and employment be able to maximise their contribution to the success and prosperity of the city

Individual and collective self Improved resident’s wellbeing and cohesion within esteem – mutual respect neighbourhoods by tackling significant issues such as crime and disorder.

Neighbourhoods of Choice Improved resident satisfaction, making neighbourhoods a place where people want to live and stay

Full details are in the body of the report, along with any implications for:

 Equal Opportunities Policy

19 Manchester City Council Item 6 Communities and Neighbourhoods Overview and Scrutiny Committee 8 March 2011

 Risk Management  Legal Considerations

Financial Consequences – Revenue None

Financial Consequences – Capital None

Contact Officers:

Name: Vicky Rosin Position: Director, Neighbourhood Services Telephone: 0161 234 3718 E-mail: [email protected]

Name: Ingrid Daly Position: Business Support Manager Telephone: 0161 234 4228 E-mail: [email protected]

Name; Andy Wilson Position: Regeneration Manager Telephone: 0161 277 1880 E-mail: [email protected]

Name: Peter Babb Position: Head of Planning Telephone: 0161 234 4501 E-mail: [email protected]

Background documents (available for public inspection):

The following documents disclose important facts on which the report is based and have been relied upon in preparing the report. Copies of the background documents are available up to 4 years after the date of the meeting. If you would like a copy please contact one of the contact officers above.

Report to Executive 21st October 2009 approving the Student Strategy Implementation Plan Report to Executive 10th March 2010 approving the Change to Planning Use Classes Order South Manchester Strategic Regeneration Framework (SRF) Manchester City Council’s response to CLG Consultation “Houses in Multiple Occupation and Possible Planning Responses” Minutes of Communities and Neighbourhoods Overview and Scrutiny Committee meeting on 22 June 2010

20 Manchester City Council Item 6 Communities and Neighbourhoods Overview and Scrutiny Committee 8 March 2011

1.0 Introduction

1.1 In October 2009 a report was presented to the Executive which detailed the work that had been undertaken in the development of the Student Strategy Implementation Plan and the issues that were being addressed in partnership with the University of Manchester and Manchester Metropolitan University.

1.2 The Implementation Plan identified the actions that were necessary in addressing the issues associated with a large student population, particularly in certain areas of the City, with a particular focus on neighbourhood management and student housing. A study was undertaken, which identified a number of key issues which need to be addressed under four main objectives;

 Develop and improve neighbourhood management approaches in areas with concentrations of student households.  Provide better accommodation for students in appropriate locations  Address the need for resident parking schemes in Ardwick and Hulme.  Take all available steps to prevent further encroachment of students lets into areas characterised by traditional family housing.

1.3 In addition to an update of the Implementation Plan further information has been requested by this Committee on the following issues:

 The approach to the creation of houses of multiple occupancy following the retraction of the change to the Planning Use Classes Order;

 The impact of student’s alcohol consumption on local communities;

 How the problem of traffic on is being addressed, particularly regarding the slow journey for residents of wards to the south of those areas heavily populated by students, for example ; and

 Information on new student development in Hulme.

2.0 Progress to Date

2.1 Progress on the Student Strategy Implementation Plan is attached as Appendix 1.

2.2 Further information requested by this Committee is detailed as follows;

21 Manchester City Council Item 6 Communities and Neighbourhoods Overview and Scrutiny Committee 8 March 2011

The approach to the creation of houses of multiple occupancy following the retraction of the change to the Planning Use Classes Order.

The Government amended the General Permitted Development Order on 1st October 2010 to make a change of use from a Class C3 dwellinghouse to a Class C4 House in Multiple Occupation (HMO) 'permitted development', i.e. planning permission is no longer needed for this. The only way for local authorities to control further HMOs now is to introduce an 'Article 4 Direction' to remove the permitted development rights so that planning permission is needed for change of use from a C3 dwelling house to C4 HMO again.

It is considered that the loss of control over changes of use from a dwelling house to a HMO will harm the sustainability of certain neighbourhoods within Manchester in the long term, as HMOs encroach further into areas which have traditionally provided accommodation for families. Therefore, the City Council made an Article 4 Direction on 7th October last year and gave notice of this on the 8th October. The Council has to wait for a year after giving notice of the Article 4 Direction before it can come into effect to avoid liability for compensation claims in respect of the loss of permitted development rights. As such, the Direction will come into force on 8th October 2011. The Direction was confirmed on 17th January.

The LDF Publication Draft Core Strategy, reported to Executive in December 2010, contains a draft threshold policy for controlling HMOs. The policy would not permit a change of use to a C4 HMO where concentrations of properties occupied by students or recorded by the Council as licensed HMOs exceed 10% within 100 metres of the application site. This approach will be complemented by a policy on purpose built student accommodation which sets out criteria for new proposals. This policy was approved as an interim policy in the October 2009 Student Strategy Implementation Plan and has already been used by the Planning Inspectorate to dismiss an appeal for a purpose built student accommodation scheme in . The planning inspector stated in the appeal decision in November 2010 that the proposal would be "contrary to the Council's strategy for the provision of a balanced mix of housing and maintenance of a sustainable community" and would be "contrary to... the Student Strategy Implementation Plan and Interim Planning Policy on new Purpose Built Student Accommodation".

The impact of student’s alcohol consumption on local communities

This has been separated into five main elements;

1. Attendance at local meetings and facilitating a more pro-active approach to licensing

Officers from Licensing and Public Protection attend monthly Community Guardian meetings in Fallowfield to provide support and advice to local resident representatives. The meetings are attended by local councillors as well as other

22 Manchester City Council Item 6 Communities and Neighbourhoods Overview and Scrutiny Committee 8 March 2011 agencies and Council services including Private Sector Housing, Waste and Recycling and the local Street Environment Manager.

Recently residents objected to the extension of hours for a local bar in Fallowfield, resulting in the application being rejected by the Licensing Sub-Committee.

Licensing officers also attend a residents meeting with one of the prominent licensed premises in the Fallowfield area, to facilitate co-operation between licensed premises and the residents, and ensure that all relevant issues are addressed as effectively as possible.

There has also been an increase in licence-related police enforcement in the area, with a greater co-ordination between the Metropolitan and South Police Licensing Units which has resulted in action taken against a number of licensed premises. Consequently, the Council's Licensing Committee has cut the hours back for an establishment on Wilmslow Road, from 2.30 to 1am throughout the week and imposed a number of new conditions on the licence for another bar, including requiring the use of polycarbonate drinking vessels and an enhanced security presence at the venue.

The Council conducted its statutory review of its Licensing Policy last year and the revised policy came into effect in January 2011. The revised Licensing Policy will facilitate and encourage a more pro-active approach to preventing licensed premises causing problems or being situated in areas where they are more likely to be problematic. The Policy introduces a wide range of proposed management standards designed to ensure best practice. The policy also introduces limitations in respect to particular locational considerations such as an expectation on earlier licensing hours in residential areas.

2. Night Time Enforcement

The Public Protection team continue to carry out proactive licensing enforcement work every Friday and Saturday night from 9pm to 4am. This involves proactively patrolling the area and dealing with complaints arising about noise and other issues related to licensed premises. Proactive monitoring is also carried out during Freshers week to deal with the increased activity around licensed premises during this time.

3. Addressing Noisy parties

A multi agency initiative, involving a number of council departments from across Neighbourhood Services, as well as Crime and Disorder, GMP and the Universities, deals with complaints arising from noisy parties. Any addresses where parties have caused problems over the weekend which have been reported to the GMP, the University helpline, ASBAT or Public Protection team are visited on the following Tuesday by officers from these teams. The residents are advised of the problems they have caused and the action that can be taken against them if there is a repeat of the problem. This initiative has been successful in reducing the number of repeat parties. In total approximately 60 student properties have been visited since September and 19 Noise Abatement Notices served.

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4. Proposed Area Review of the Licensing Policy

During the consultation on the proposed revision of the Licensing Policy, a number of responses were received from local residents as well as Councillors, in the Fallowfield, Old Moat and Withington wards, citing concerns over the effect the night time economy has on those areas with complaints of increased anti-social behaviour, crime as well as other associated issues such as litter.

Whilst the revised Licensing Policy provides a pro-active tool in the decision-making process for licence applications, it was considered that a review of the problems being experienced would be conducted to assess the need for any particular restrictive licensing policies in the Fallowfield/Withington areas.

This area review will consist of analysis of: a) current and historic crime statistics relevant to the night time economy b) current and historic licensed premises, including charting the change of the late night economy in those areas c) consultation with residents and businesses in the area d) information and evidence gathering from relevant authorities (including Street Environment, Waste and Recycling, Environmental Health)

Dependant on the results, appropriate remedial measures will then be explored and proposed with a view to most-effectively addressing the issues experienced as a result of the night time economy in this area. The findings from the area review will be presented to the Council's Licensing Committee for their consideration on any further action.

Currently, the review is in the early stages of working with Police analysts to ascertain relevant data as well as charting the development of licensed premises in the Fallowfield/Withington areas over the past 5 years.

5. Designated Public Place Order

Recently, the Licensing Committee granted an extension to the existing Designated Public Place Order in Withington, to prevent on-street drinking in the area. Currently, work is ongoing between agencies including the Crime and Disorder Team, Greater Manchester Police, Public Protection and Licensing through the Tackling Alcohol Related Crime (TARC) group in ensuring clear and consistent signage for the area to enable effective enforcement of the Order.

6. Best Bar None

A working group has been established in respect of the annual Best Bar None awards scheme for recognising best-practice in the licensed trade. A key aspect will be to ensure an increased participation in the scheme by premises in the Fallowfield area, which has traditionally been under-represented in previous years. Best Bar None has been shown to reduce problems associated with the late night economy and it is anticipated that having an increased number of premises in Fallowfield that

24 Manchester City Council Item 6 Communities and Neighbourhoods Overview and Scrutiny Committee 8 March 2011 are Best Bar None accredited, the greater the impact upon reducing crime and problems related to licensed premises.

Issues Concerning Traffic Flow on Wilmslow Road

Highway Services is addressing the problems of traffic flow along Wilmslow Road by seeking to deal with short, medium and long term congestion, disruption and traffic safety issues.

In the short term, operational activities are being undertaken to keep the highway network functioning with minimal disruption from works, events, incidents and the weather.

A recent example of this was the Gas main replacement works along the Wilmslow Road/Oxford Road corridor which began in May 2010. Through careful co-ordination with other proposed works and close scrutiny of the potential impact of the works congestion, disruption and delay to road users was kept to a minimum.

In addition Civil Enforcement Officers are deployed along the Wilmslow / Oxford Road corridor on a daily basis. All parking restrictions are enforced on and around the main arterial route with a minimum of 2-3 visits per day from these Officers.

In the medium term the route is being analysed to identify the causes of congestion and improvements and actions are being identified to tackle congestion. In developing improvements the emphasis is placed on encouraging the use of more sustainable modes of transport, such as buses, cycling and walking. Recent examples of this include :

 Improvements to Rusholme District Centre, which delivered a safer environment for pedestrians and rationalised on-street parking.  Bus improvements in Withington Village, Owens Park and between Fallowfield and Rusholme to improve bus journey times and encourage additional bus patronage.  Improved cycle facilities through Fallowfield, to encourage people to cycle into the city centre.  Parking improvements along Wilmslow Road, to reduce disruption and improve journey times.

In the longer term Highway Services are attempting to influence and manage the effect that developments have along the route. The collective impact of appropriately managing development is to reduce the dependency on the private car, which cumulatively will assist with journey time reliability along radial routes such as Wilmslow Road.

Table 1 below shows peak hour traffic flows along Wilmslow Road and suggests that car usage is generally decreasing. Bus provision has increased over recent years with 1,320 bus journeys now taking place each day compared to 432 on Stockport Road.

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New Student Development in Hulme

Birley Fields:

The Manchester Metropolitan University proposals for Birley Fields are progressing and a planning application has been submitted. The scheme includes outline details for 5 student accommodation blocks around the proposed campus which will contain a maximum of 1,200 student bed spaces. This figure could be reduced down however, depending on the demand for student halls over the next few years, given changes to Higher Education may lead to a reduction in student numbers or more students choosing to live at .

MMU are working closely with residents, local Councillors and officers over the Campus proposals. This partnership will closely monitor the impact of the increase in student numbers within the ward. The benefits to the local area of the increase in the population include the additional footfall and local spend which will result in a positive boost to the local economy.

The planning application will also be accompanied by a s.106 contribution from MMU that will create a residents parking zone around the campus.

Additional sites:

The development of the former Arch Bar public house on Stretford Road, for approx 120 student bed spaces, is currently on site and is targeted at opening for the next academic year in September 2011.

In addition to the above, several other site enquiries have been received regarding student halls in Hulme – none of which are at Planning stage.

3.0 Summary

3.1 While good progress has been made across the identified four objectives contained within the Implementation Plan it is important that the level of activity is maintained and the partnership approach which has developed between the city and the University of Manchester and Manchester Metropolitan University continues. There is a need to regularly review the objectives to ensure that they continue to reflect the issues that arise from a

26 Manchester City Council Item 6 Communities and Neighbourhoods Overview and Scrutiny Committee 8 March 2011

large student population within the city. The impact on neighbourhoods of the development of new build student halls and the use of powers to regulate the growth of HMO’s will also need to kept under regular review.

4.0 Contributing to the Community Strategy

(a) Performance of the economy of the region and sub region

4.1 The universities play a key role in the economy of the city. Attracting and retaining talent is essential in building the knowledge economy which contributes to making the City and City Region more competitive economically.

(b) Reaching full potential in education and employment

4.2 The Corridor Partnership is supported through the implementation of the plan as better connections between the Universities and residents will ensure that the development of skills and employment will be supported and that the Universities will be able to maximise their contribution to the success and prosperity of the city

(c) Individual and collective self esteem – mutual respect

4.3 The implementation of the plan will assist in the improvement of resident wellbeing and cohesion within neighbourhoods. Improved communication with residents which will be supported by the use of student volunteers, will result in greater opportunities for residents to influence decisions at a local level which will raise levels of self esteem and respect

(d) Neighbourhoods of Choice

4.4 The Student Strategy Implementation Plan will respond to the needs of neighbourhoods. It demonstrates that the issues that residents raise are being addressed both across services and together with the Universities. The aim is to improve resident satisfaction in the neighbourhoods with concentrations of student households

5.0 Key Polices and Considerations

(a) Equal Opportunities

5.1 The Student Strategy Implementation Plan will make a significant contribution to the promotion of equal opportunities through the joined up delivery of services at a neighbourhood level

(b) Risk Management

5.2 None Identified

(c) Legal Considerations

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5.3 None Identified

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Appendix 1 Student Strategy Implementation Plan

Progress to March 2011

This plan has been developed in partnership between MCC the University of Manchester and Manchester Metropolitan University to address the key issues associated with a large student population in the city.

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OBJECTIVE 1 – Develop and improve Neighbourhood Management approaches in areas with concentrations of student households

PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 1 Better co-ordinated Ongoing MCC Mainstream - Environmental - Implementation of a delivery of MCC street Neighbourho improvements co-ordinated, based services and that od Services - Ability to target targeted approach of key partner agencies Crime and resources at key in the delivery of all Disorder points in front line services in GMP University managing Manchester calendar environmental and Student noise nuisance Homes issues

2 Put in place off-campus By Dec 09 Off Campus Mainstream - Single point of - Off Campus Manager and Lead Manager – contact for Manager in post 28 Council Officer University of residents and June 2010 Manchester/ members - Lead Council MMU - Co-ordination of Officer in post Lead City MCC services October 2009 Council - Identification and - Student helpline Officer – proactive launched MCC management of September 2010 anti social student tenant households 3 The Students' Unions of Early 2010 Student Mainstream - Assist in the - Ongoing both Universities have Unions development of engagement of

30 Manchester City Council Item 6 – Appendix 1 Communities and Neighbourhoods Overview and Scrutiny Committee 8 March 2011

PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 indicated a willingness to more cohesive student support the communities in representatives with work of the Off-Campus the community groups Manager with neighbourhoods communities and containing a large organisations in student developing solutions to population address the impact that large numbers of students have in particular neighbourhoods

4 Improve the quality and Within 2 years MCC Mainstream/ - Complete - Review of the management of Houses Neighbourho Mandatory Property approach to current in Multiple Occupation od Services HMO and Inspections of HMO licensing will (HMOs) (Private Additional all Mandatory be completed by the In areas with Sector HMO licensing HMO’s end of March 2011. concentrations of Housing) fees - Roll out The potential for students Additional HMO introducing licensing additional licensing schemes for non- will need to be mandatory explored following HMO’s where discussions with problems can be partners demonstrated - Expand use of Interim and Final Management Orders where landlords fail to

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PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 manage properties effectively - Increase coverage of landlords accreditation scheme in student areas (Note: Mandatory licensing – 5 unrelated people living in a property of 3 or more storeys Additional licensing 2/3 unrelated people living in any property) 4a Proposed new licensing Old Moat MCC License Fees Additional HMO schemes submission in Neighbourho scheme around the October 2009 od Services Victoria Rd/ PSH Wellington Rd areas of Old Moat to be submitted to CLG in October. 4b Proposed Consultation Withington . MCC License Fees Evaluation of area scheme Ongoing Neighbourho undertook. One

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PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 evaluation of od Services additional licensing new schemes PSH scheme identified. in 2 year Consultation to begin rolling after feed back to programme Ward Councillors Sept 2009 4c Proposed Evaluation Rusholme. MCC License Fees Evaluation in schemes Ongoing Neighbourho progress of 5 evaluation of od Services identified areas of new schemes PSH Rusholme. Future in 2 year schemes include rolling , programme Fallowfield, Longsight and 5 Crime and Disorder By Oct 09 GMP & Mainstream Reduction in crime New governance Objectives Crime and related to students, structures established Disorder specifically burglary, within CDRP – Student Review governance and Team robbery, vehicle Tactical Action CDRP structures relating crime and sexual Partnership and to student issues. offences. Student Strategy Group Reduction in anti- Meeting regularly social behaviour related to student population

Produce a detailed By Sept 09 GMP Mainstream Activity to address Problem profile problem profile that crime and disorder to produced Sep 09 and analyses the crime and be coordinated updated April 10 disorder and community across the A B and Student TAP and

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PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 safety implications C Divisions, with Student Strategy Group surrounding the university appropriate agencies have met and community of Manchester delivering activity coordinated activity accountable to the across 3 divisions. Implementation of wider partnership. They have also picked recommendations from up local concerns problem profile raised by students e.g. Whitworth Park which is now closed dusk til dawn to address local issues of crime.

Ensure operations to Academic year Student Mainstream Community Operation Safe Return address crime and 09/10 Partnership engagement with has run across disorder are joined up Cllrs, Neighbourhood Divisions from 31st across A, B and C Partnerships and October and will run divisions Respect activity to until March. This has identify local run to target offenders, concerns of ASB. increase awareness This will be about home safety and addressed through to address issues of coordinated activity ASB and noisy parties. Coordinated activity with Initial meeting GMP and Mainstream by CDRP agencies Coordinated activity Student Safety Tactical July 09 Crime and and additional and fed back to Cllrs between Action Partnership and Disorder funded and local residents Neighbourhood Local Tasking Meetings to Team operations Services, GMP, ASBAT address anti-social and Safer behaviour Neighbourhoods has delivered a quick coordinated response

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PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 to residents complaints about student parties resulting in 60 visits and 19 notices being served.

OBJECTIVE 2 – Provide better accommodation for students in appropriate locations

PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 1 Put in place agreed Interim policy Head of Clear criteria that  Initial criteria based criteria as an interim reported to Planning could be applied to policy approved for planning policy for Executive the development of development control development of additional alongside this any new student purposes October purpose built student document, to access regardless of 2009. accommodation be approved location  Amended criteria for policy is now in the Development draft Local Control Development purposes. Framework Core Policy within Strategy. This was LDF Core consulted on in Strategy 2011 August 2010 and also currently as part of the Core Strategy Publication

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PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 document (consultation finishes on 24th March 2011) 2 Explore the potential for Within 3-5 Regeneratio Encourage dispersal  Continue to explore providing accommodation years n Teams / of students and opportunities where in non-traditional student Head of support regeneration there are areas Planning projects across the neighbourhood city benefits for new development outside the University campus and City Centre.

3 Encourage the Within 5 years Universities University/ - Increase in  Ongoing review of development of new MMU Privately number of hall proposed schemes managed student halls in University of funded places by in Planning pipeline accordance with above Manchester between 10%- to ensure criteria in: 20% compatibility with - Corridor - Hall spaces agreed criteria. nd Manchester area available for 2  This policy has - Birley Fields, and 3rd year been used by the Hulme students (not Planning - Fallowfield, Owens currently Inspectorate to Park Campus available) dismiss an appeal - Relieving for a purpose built pressure of student students accommodation occupying family scheme in homes in Longsight established

36 Manchester City Council Item 6 – Appendix 1 Communities and Neighbourhoods Overview and Scrutiny Committee 8 March 2011

PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 communities - Reducing cost of delivering street based services

OBJECTIVE 3 – Address the need for resident’s parking schemes in Ardwick and Hulme

PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 1 To deliver a strategy for September Deputy Chief MCC - Implementation of  Ardwick – Additional resident’s parking 2010 Executive MMU resident’s parking resident parking (Regeneratio UoM schemes to reduce scheme introduced n) Hospital Trust negative effects of in Groves MMU Use of S106 non-residential neighbourhood. UoM agreements parking Consultation Hospital completed on new Trust scheme in Grove Village) – implementation in summer 2011.  Hulme –Additional schemes Hulme High Street and it's neighbourhood, & the Aquarius Estate which are being funded by a mix of s106 monies from Asda and Highways

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PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 WNF  MMU to fund additional scheme across central area of Hulme in association with Birley Fields Community Campus proposals

OBJECTIVE 4– Take all available steps to prevent further encroachment of student lets into areas characterised by traditional family housing

PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 1 The Council has Core Strategy Head of Mainstream  Policy enables  A new Use Class responded to the scheduled to Planning the Council to for HMOs, Class Government consultation be adopted in refuse planning C4, was introduced that includes an option to September permission for in April 2010 amend the Planning Use 2011, following HMOs in  Amendments to the Classes Order, which consultation in appropriate General Permitted would give greater 2010. locations. Development Order planning controls to the  Further loss of in October 2010 Council to prevent the family housing to resulted in need to loss of family housing to students introduce ‘Article 4 student lets. If the law prevented. Direction’ on 8th changes in this respect More students are October 2010 then, put in place a Core encouraged to live in  To avoid Strategy policy using halls which are compensation criteria to restrict further easier to manage in claims this does not

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PROGRESS TO ACTIONS TIMESCALES WHO RESOURCES OUTCOMES MARCH 2011 HMO’s where they are terms of negative come into force until inappropriate in areas environmental 8th October 2011 which have experienced a impacts on  Once the Article $ loss of traditional family neighbourhoods. Direction is in place housing to student lets, and the Core meaning that the Strategy policy character of the area has adopted planning changed. permission will not Prepare a Supplementary be granted for Planning Document to change of use from consult on alongside the C3 to C4 in areas draft Core Strategy policy where which will contain the concentrations of detailed approach. student houseshares or licensed HMO’s exceed 10% within 100m of the application site

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