SUMMARY REPORT

Application Ref: 20160138

Site Address: 88 Pelham Road, Gravesend, , DA11 0JB

Application Change of use from guest house (Class C1) to a house in Description: multiple occupation (Class C4).

Applicant: Mr G Peters PCD Homes

Agent: As Applicant

Ward: Pelham Ward

Parish: Non-Parish Area

Decision due date: 02.05.2016

Publicity expiry date: 08.04.2016

Decision level: Planning Regulatory Board - 07 September 2016

Reasons for referral: At request of Cllr Brian Sangha. Concern from high number of existing conversions, balance of housing and apartments, loss of the guest house, impact on the neighbours.

Recommendation: Permission subject to conditions and informatives as per the report to Board on 20 July 2016

Summary of Reasons for Recommendation

This report serves as an additional assessment to the application for 88 Pelham Road. It should be considered in conjunction with the conclusions of the previous report from the Regulatory Board held on the 20th July 2016.

The conclusion of the assessment set out in this report finds that there is a diverse community on Pelham Road, with a range of ages, occupations etc. The introduction of a HMO will therefore not be out of keeping due to the heterogeneous community that exists. It is noted that there is a significant level of social deprivation in the area and the provision of affordable rented accommodation will be beneficial to this group. Moreover, an assessment of the infrastructure finds that the site is adequately served by transportation due to its location and there are ample facilities within close proximity. There are a range of housing types with a clear demand for single occupancy housing which the proposal will serve. To reduce any problems that may be associated with a HMO a management plan is being required before the change of use can be implemented which will allow effective scrutiny that the site will be appropriately managed, an approach supported by the Department for Communities and Local Govt.

The proposal is considered to be in accordance with local and national planning policy and it is for these reasons that permission is recommended. ______

MAIN REPORT

1. Application Background

This application was originally reported to the Regulatory Board on the 20th July 2016 with an officer recommendation for permission subject to planning conditions.

Members of the Board are requested to bring to this meeting a copy of the previous report (Agenda Item 5b).

The application is for the change of use from the existing Guest House at No. 88 Pelham Road to a house of multiple occupation (HMO) with eight bedrooms. The existing dwelling is currently being used as a Guest House with five rooms on the first and second floor and a two bedroom flat on the ground floor. The ground floor flat is used by the owners of the property who manage the Guest House.

It was resolved by the Board that the application be deferred to receive further information on the demographics of the area due to concern over the impact of conversions of properties in Pelham Ward into smaller units of accommodation and the implications for community and social infrastructure. An assessment of this is made below.

This report serves as a subsequent report with further analysis based on Member comments and requests at the previous Regulatory Board meeting.

The previous assessment considered the following key issues:

• Permitted Development Rights • Change of Use • Design • The impact on the character of the surrounding area. • Conservation Area • Housing need in the area • Tourist facilities • Suitability of the site for future residents • Impact on neighbouring amenity. • Highways

2. Conclusion of Previous Report

The previous report set out that a C3 single family dwelling with its permitted development rights can operate as a 6 bed HMO without requiring planning permission. Moreover, case law finds that an eight bed HMO is not materially different from a six bed HMO. In this case it would not be permitted development because of the condition attached to the existing planning permission restricting the use to a Guest House and the fact remains that permission would be required and an assessment has been made on the merits of this application. However, weight should be given to the above, in that any house in the borough, subject to having permitted development rights intact, could operate as a HMO without the need for planning permission.

The applicant has provided information to show that the property is not running as a tourist facility, as the guests are not tourists but are instead people from out of area who are working locally. This is supported by the references made to the current guests within the neighbour objection letters. Moreover, the evidence submitted indicates that the Guest House has low level occupancy and is not a viable business. There is evidence that the property has been advertised as a Guest House for 18 months with no purchasers. Therefore, there is no loss of a fully functioning Guest House and the proposed is not contrary to Gravesham Local Plan Core Strategy Policy CS09 (Culture and Tourism).

Objections have been raised that the HMO would have a detrimental impact on the amenity of the neighbouring properties. However, it is necessary to question the harm in comparison to the existing use and as a large family dwelling. Many of the objections raised to the HMO would also apply to the Guest House and a large family dwelling, therefore are unsubstantiated. Moreover, GBC Regulatory Services have confirmed that they have the ability to enforce against noise nuisance and a proper management regime would be required as part of the licensing. The proposal has been found to be acceptable in terms of the living requirements and amenity of future residents.

A HMO would provide a form of living accommodation that contributes to the council’s need and contributes to the makeup of the community. The proposal is therefore in accordance with Policy CS14 (Housing Type and Size), Policy CS15 (Housing Density) and Saved Policy H6 (Provision to Meet Special Housing Needs - clustering of residential hostels and homes). It is not found to create a clustering of similar uses and is not harmful to the social sustainability of the community. Moreover, there is no impact on the character of the surrounding area and the conservation area as the application relates to the change of use and is therefore in accordance with Policy CS19 (Development and Design Principles), Policy CS20 (Heritage and the Historic Environment) and Saved Policy TC3 (Development Affecting Conservation Areas).

The Guest House has been in existence since the 1970s and therefore its use as a large family dwelling has been lost for a significant amount of time. As such, the proposed is not contrary to Policy H5 (Increasing the Housing Stock by the Conversion of Existing Buildings).

The existing guest house would have visitors that require parking provision and the net increase for the Guest House would not cause harm on the highways. Moreover, case law finds that HMOs have been permitted in well-connected areas with no parking provision. The site is well connected to the town and public transport and has provision for two vehicles.

Overall, it is considered that there is no harm on the amenity of the neighbouring properties or the highways. The loss of the existing guest house is not found to be detrimental to the tourism in the area and would be an insufficient ground for refusal. The proposed is in accordance with local and national planning policy and it is for these reasons that permission is recommended.

3. Planning Analysis and Service Manager (Development Management) Comments

There was a lengthy discussion by the Board at the meeting in April, with the Ward Councillors for Pelham Ward raising concerns with the impact that conversions have on the area. Their concerns relate to a high percentage of flat and multiple occupation housing, and whether there is an unbalance in the community in comparison to family dwellings.

Concerns about the community mix were addressed as part of the original assessment as presented at the Board on 20.07.2016. Cllr Sangha referred to local statistics for the area which show that there have been a larger number of conversions in the Pelham Ward, when compared to other wards in the borough.

It is worth noting that this application stands to be determined on the current local and national planning policies. At present, there are no planning policies applicable in this case, that suggest the council should resist conversion due to existing conversions in the area. The necessary policy to consider is saved policy H5 of the Gravesham Local Plan First Review 1994. The preamble states that there is a need to accommodate the growing number of smaller households and to provide low cost housing in the borough, indicating that a way to achieve this is by allowing more flexible arrangements within the existing housing stock. The preamble goes on to explain that ‘regard must be paid to the character and amenity of existing housing areas where single family occupancy is the norm and where traffic and other environmental considerations make intensive forms of occupancy unacceptable’. Moreover, the preamble indicates that adaptions will be targeted at properties closer to the town centre.

Under Policy CS14 of the Gravesham Local Plan Core Strategy the Council will resist conversion of family sized residential units to smaller units. It is therefore worth noting that in this case, this has already been lost. As highlighted in the previous report the Guest House has been in existence since the 1970s and therefore its use as a large family dwelling has been lost for a significant amount of time.

The key aspects to consider in this case, taking account of Policy H5, is that the conversions are favoured towards to town centre and in areas where family housing is not the norm. It is considered that 88 Pelham Road meets this criterion. The site is 0.5 miles from the train station on Rathmore Road, 0.5 miles to bus terminals on Garrick Street and the taxi rank on New Road. It is a prime location for local shops and facilities. Moreover, the current policy requirements favour areas where conversions are the norm which it considers to be a way to ensure the proposal is in keeping with the character of the of the existing housing area.

It is pertinent that the Council consider the sustainability of any proposal. This is in accordance with paragraph 7 of the NPPF. As noted in the previous report the NPPF separates sustainability into three dimensions. In respect of sustainability it states that “these dimensions give rise to the need for the planning system to perform a number of roles”, one of which being a social role. In respect of the social role, the NPPF states that the planning system should be: “supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being”.

The information referred to by Cllr Sangha indicates a concern that the conversions in the Pelham Ward would create an unsustainable community. It is therefore necessary to give this careful consideration.

The following information gives some statistics and further information for Pelham Road. This information is taken from streetchecker.co.uk. Demographics

Age

0-15 15% 16-29 19% 30-44 22% 45-59 23% 60-74 11% 75-84 5% 90+ 4%

There appears to be a fairly even balance of ages on Pelham Road.

Gender Male 50% Female 50%

Even split in terms of gender.

Social Grade AB – 20% (Higher and intermediate managerial, administrative, or professional positions)

C1 – 28% (Supervisory, clerical, and junior managerial/administrative/professional positions)

C2 – 23% (Skilled manual workers)

DE – 29% (Semi-skilled and unskilled manual workers; those on state benefit/unemployed, & lowest grade workers)

There appears to be a fairly even balance of social classes on Pelham Road

Relationship Status Married 36% Same Sex 2% Single 40% Divorced 10% Separated 2% Widowed 11%

Only 37% of people in Pelham Road are in formal relationship status as recognised by streetchecker.co.uk, lower than the national average of 47%. 63% are therefore single, separated, divorced or windowed and may require more flexible housing arrangements.

Employment Full-Time 33% Part-Time 9% Self-Employed 12% Unemployed 10% Full-time Student 8% Retired 9% Looking After Home or Family 4% Long-Term Sick or Disabled 13% Other 2%

There appears to be a wide range of employment types for occupants on Pelham Road.

Employment Industry Agriculture 3% Manufacturing 7% Construction 10% Retail 15% Transportation 6% Accommodation and Food 7% Information and Communication 3% Financial Services 10% Real Estate 1% Professional, Scientific, and Technical 8% Administration 2% Public Administration and Defence 8% Education 9% Health 8% Other 4%

There appears to be a wide range of employment industry types for occupants on Pelham Road.

Alternative sources of information provide further data about the Pelham area. For instance: The above map showing the levels of deprivation within each ward boundary.

A closer image of the Pelham Ward shows that the part of the worst quintile in terms of deprivation (each quintile representing 20% of the Kent population) and therefore has high levels of deprivation. An assessment of the demographics of Pelham Road finds that the community is diverse. This is a key aspect of creating a socially sustainable community. It is therefore not considered that the proposal would be contrary to the aims of the NPPF in regards to sustainability. Moreover, as evidence suggests, there is a high level of deprivation in the Pelham Ward and therefore affordable housing alternatives are an important aspect of ensuring the community and population found in the Pelham area are adequately catered for.

In support of this, the Gravesham Housing Needs Survey in 2006 found that: “The social rented stock in the Borough at 17.9% is lower than the national average and provides 350 units annually from the flow of the existing stock”. As such, the provision of rentable and affordable accommodation would stand to benefit the area.

Infrastructure

Turning from the demographics of an area, it is important that an area be served by adequate infrastructure to accommodate the population. This information is again taken from streetchecker.co.uk.

Railway Stations

3 stations within 2 miles

(Gravesend, Northfleet, Ebbsfleet International)

Primary Schools

10 primary schools within 1 mile

(Cecil Road Primary & Nursery, Wrotham Road Primary, Copperfield , Holy Trinity church of Voluntary Aided Primary, St Botolph’s Church of England Primary, Rosherville Church of England Academy, Shears Green Infant School, Shears Green Junior School, Chantry Community Academy, St Joseph’s Catholic )

Secondary Schools

8 secondary schools within 2 miles

(Mayfield , St George’s Church of England School, Northfleet Technology College, Northfleet School for Girls, , St John’s Catholic Comprehensive, , The Ebbsfleet Academy)

Doctor’s Surgery/GP Practices

9 Doctor’s surgeries within 1 mile

(Dr Singh J & Partner, Dr Morgan S G & Partners, Old Road West Surgery, Dr Todd R G & Partners, Dr Shah S U D, Gravesend Medical Centre, Dr Karunaharan V M, The Gateway Medical Practice, White Horse Surgery)

Dentists

10 dentists within 0.6 miles (Shoker SS MR, Pelham Dental Studio, Mr A A Tikare, PMA Dental Care, Mr S S Photay, Dental Surgery, J F Lynch & Associates, Beaconsfield Dental Practice, Parrock Street Dental Care, 43 The Grove)

Hospitals

1 hospital within 0.5 miles

(Gravesham Community Hospital)

2 hospitals within 4.3 miles via an accessible route

(Gravesham Community Hospital, Darenth Valley hospital)

10 hospitals within 9 miles via an accessible route

(Gravesham Community Hospital, Darenth Valley hospital, Littlebrook Hospital, BMI Fawkham Manor Hospital, Livingstone Hospital, Erith and District Hospital, Medway Maritime Hospital)

Opticians

5 opticians within 0.6 miles

(Boots – Gravesend - New Road, Specsavers – Gravesend, Asda Opticians – Gravesend, Boots – Gravesend – Kempthorne Street, Medical Eye Centre)

Alternative source of information provide further data about the Pelham area. For instance the Health & Social Care maps for Gravesham Overview produced by the Kent Public Health Observatory provides further information by the borough and highlights that there are a higher number of nursing homes and residential homes in the Pelham Ward.

Nursing Home and Residential Homes Pelham Ward – 10 Central Ward – 9 Northfleet North Ward – 2

The above assessment finds that the area is served by adequate infrastructure to support the community in place on Pelham Road.

Housing in Pelham Road

Having established an assessment of the community and infrastructure supporting Pelham Road, it is necessary to consider the type of housing and occupancy to establish the needs of the residents in this area

Housing Type Detached – 7% Semi-Detached – 27% Terrace – 19% Flat (purpose-built) – 12% Flat (converted) – 33% Residence in Commercial Buildings – 2% Detached, semi-detached and terrace properties form 53% of the housing type in this area and are thus the most common. It is noted that there are a high number of flats, whether purpose built or converted, with this making up 45% of the housing type in this area.

Housing Tenure Owned Outright – 21% Owned with mortgage – 24% Shared Ownership – 1% Rented: from Council – 1% Rented: Other Social – 11% Rented: Private Landlord – 39% Rented: Other – 2% Rent Free – 1%

The national average for rented housing is 16% and therefore the amount of rented accommodation (totalling 53%) is much higher, suggesting there is a large demand for rented accommodation in this area.

Housing Occupancy One person – 45% Two people – 25% Three people – 9% Four people – 7% Five people – 8% Six people – 4% Seven people – 0% 8 + people – 2%

There are a high number of single person occupancies in this area, meaning the proposed HMO suits the needs of the current demographics.

General Impact of Houses of Multiple Occupation

Having established an assessment of the community, infrastructure and the housing in Pelham Road it is then necessary to consider the impact of Houses of Multiple Occupation on a community.

The Department for Communities and Local Government produced a report in 2007 researching Housing, the report set out to evaluate the Impact of Houses in Multiple Occupation and the Licensing of such properties. The report found that often rented accommodation can cause distress for neighbouring properties as there is potential for landlords to being living separately and operating the business remotely. To address this, the report highlights the importance of licensing and management and how this leads to better managed properties.

As such, an informative is added to the decision notice notifying the applicant of the licensing procedure and a condition has been recommended requiring that the change of use will not be implemented until a written management scheme demonstrating how the home is to be managed to adequately control disturbance to surrounding residents, is submitted to, and approved in writing by the Local Planning Authority. This will allow for an effective assessment of the management plan to ensure necessary arrangements are in place to control any potential disturbance.

At this point, it is worth noting the guidance as discussed in the previous report from the Development Control Practice:

Proposals which threaten ‘amenity’ by the introduction of increased numbers of people, possibly those with different social characteristics, invariably attract vociferous objection from local vested interests. The planning system is obliged to take this factor into account to a point, but often objection is based on prejudice, intolerance or fear of the unknown … These are matters not normally held to be proper planning considerations.

As the above states, making a prejudgment about the types of people that will move into certain accommodation and their behaviour is often not supported by reason. Therefore, it is not possible for this to be a planning consideration as it would be prejudicial and would make generalisations about types of people and how they live.

4. Conclusion

This report serves as an additional assessment to the application for 88 Pelham Road. It should be considered in conjunction with the conclusions of the previous report.

The conclusion of the above assessment of the area finds that there is a diverse community on Pelham Road, with a range of ages, occupations etc. The introduction of a HMO will therefore not be out of keeping due to the heterogeneous community that exists. It is noted that there is a significant level of social deprivation in the area and the provision of affordable rented accommodation will be beneficial to this group. Moreover, an assessment of the infrastructure finds that there the site is adequately served by transportation due to its location and there are ample facilities within close proximity. There are a range of housing types with a clear demand for single occupancy housing which the proposal will serve. To reduce any problems that may be associated with a HMO a management plan is being required before the change of use can be implemented which will allow effective scrutiny that the site will be appropriately managed, an approach supported by the DCLG.

The proposed is considered to be in accordance with local and national planning policy and it is for these reasons that permission is recommended.

Recommendation: Permission subject to planning conditions