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Houses in Multiple Occupation Study

Evidence for making an Article 4 Direction

Prepared on behalf of

Bedford Borough Council

September 2019

Bedford Borough Council- HMO study

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Document: Houses in Multiple Occupation Study Report

Project: Houses in Multiple Occupation Study

Client: Bedford Borough Council

Job Number: A113051

File Origin:

Revision: First Draft Client Issue

Date: August 2019

Prepared by:

Eleanor Gingell and Annabel Le

Lohé

Checked by:

Eleanor Gingell and Annabel Le

Lohé

Approved By:

Eleanor Gingell

Description of revision:

Revision: Final Draft Client Issue

Date: September 2019

Prepared by: Eleanor Gingell and

Annabel Le Lohé

Checked by:

Annabel Le Lohé and Nick

Stafford

Approved By:

Nick Stafford


Revision:

Date:

Prepared by:

Checked by:

Approved By:




Contents

1.0 Executive Summary ................................................................................................ 1

2.0 Introduction .......................................................................................................... 5

Background ................................................................................................................ 5

Understanding the Issues............................................................................................ 5

Study Purpose ............................................................................................................ 6

Project Scope and Status ............................................................................................ 7

Report Structure ......................................................................................................... 9

3.0 Background and Context ...................................................................................... 10

What is a HMO? ........................................................................................................10

Planning Use Classes .................................................................................................10

Permitted Development .............................................................................................12

Article 4 Directions ....................................................................................................13

Appeal Decisions .......................................................................................................23

4.0 Methodology ....................................................................................................... 24

Research Questions ...................................................................................................24

Data Sources .............................................................................................................24

Data quality and assumptions.....................................................................................25

Processing and Mapping ............................................................................................27

Consultation and Engagement ....................................................................................28

5.0 Bedford Background and Context .......................................................................... 31

Overview ..................................................................................................................31

Bedford Urban Character ...........................................................................................32

The Planning Background in Bedford: .........................................................................38

Housing Background ..................................................................................................39

Supressed, shared and concealed households .............................................................44



Housing Quality and Overcrowding .............................................................................45

Existing Measures to Manage HMOs ...........................................................................48

6.0 Results ................................................................................................................ 50

HMO Locations and Types ..........................................................................................50

Visual Character and Environmental Complaints ..........................................................58

Anti-Social Behaviour and Crime .................................................................................67

Planning Data ............................................................................................................71

Focus Groups and Public Consultation .........................................................................74

7.0 Discussion and Evaluation ..................................................................................... 79

Visual Character and Environmental Complaints ..........................................................79

Crime and Anti-social Behaviour .................................................................................83

Planning Controls ......................................................................................................83

8.0 Conclusions and Recommendations ....................................................................... 85


1

1.0 Executive Summary

1.1.1 This report has been commissioned by Bedford Borough Council to examine what evidence there

is of the impacts of HMO use in the urban areas of Kempston and Bedford and what justification

there might be to support the introduction of additional planning control in the form of an Article

4 Direction. An Article 4 Direction would remove permitted development rights that currently

allow family homes to be converted into Houses of Multiple Occupation (HMOs) for up to 6

people1 and, if one were justified, to what geographical area should this be applied?

1.1.2 The Study area includes the following wards;

• Brickhill Ward

• Caudwell Ward

• Castle Ward

• De Parys Ward

• Goldington Ward

• Harpur Ward

• Kempston Central and East Ward

• Kempston North Ward

• Kempston South Ward

• Kempston West Ward

• Kingsbrook Ward

• Newnham Ward

• Putnoe Ward

• Queens Park Ward

1.1.3 This report is set out in the following sections: Introduction, Background and Context,

Methodology, Bedford Background and Context, Results and Findings, Discussion and

Evaluations, and Conclusion and Recommendations.

1.1.4 A HMO is defined as a property where occupants share one or more basic facilities (i.e. a toilet,

personal washing facilities or cooking facilities) and the property is occupied by 3 or more people

who do not form a single household.

1.1.5 An Article 4 direction is a planning tool that can be used by a Local Planning Authority.

1 Use class C3 to C4

https://historicengland.org.uk/advice/hpg/historic-environment/article4directions/

https://historicengland.org.uk/advice/hpg/hpr-definitions/l/536333/


2

It restricts the scope of permitted development rights either in relation to a particular area or

site, or a particular type of development anywhere in the authority’s jurisdiction. Where an

Article 4 direction is in effect, a planning application may be required for development that

would otherwise have been permitted development.

1.1.6 Local planning authorities should consider making Article 4 directions only in exceptional

circumstances where evidence suggests that the exercise of permitted development rights

harms local amenity or the proper planning of the area.

1.1.7 The methodology for this Study utilises a combination of qualitative and quantitative resources

to assess the following research questions, which fit into the overall aim of the study, to assess

the potential impact of HMOs on the Bedford and Kempston urban areas.

• How many HMOs are there in Bedford and where are they?

• What types of HMOs are there in Bedford and where are they distributed?

• In areas of HMO concentration, is there a discernible impact on the visual character of

the area?

• Is there any correlation between environmental complaints and HMO concentrations?

• Is there any correlation between crime data and HMO concentrations?

• How many planning applications, enforcement cases and appeals related to HMOs

have there been in the last five years?

• How does the local community perceive HMOs?

1.1.8 There is a total of 814 known HMO properties within the study area. There is a total of 2,478

households within the total 814 HMO properties. Whilst this number is not particularly high (in

relation to the percentage of overall housing stock), our analysis does show that these are

disproportionately concentrated in particular areas of the town and in areas of higher density

development.

1.1.9 There are four main hot spots of high HMO density: immediately to the south-west of the town

centre; to the north of the Bedford Midland train station; to the south-west of Bedford Park;

and nearby to Bedfordshire University’s Polhill Campus. Overall, the majority of the HMO

properties are within a 1km radius of a major transport hub, the hospital (a major employer),

or the University.

1.1.10 Site visits were undertaken in both the ‘hot spot’ areas of HMOs and other areas that were less

https://historicengland.org.uk/advice/hpg/hpr-definitions/p/536385/


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densely occupied. In total, 57 streets were visited. The site visits showed that many of the visual

character-related issues are evident at all types of properties (i.e. those within single residential

use, including flats, and those in HMO use) within these areas and that therefore these issues

cannot be solely attributed to the presence of HMOs. However, there are instances where HMOs

alone are causing harmful impacts on visual character therefore the use of an Article 4 to control

the location and distribution of HMOs would assist with mitigating these impacts.

1.1.11 The distribution of waste and noise complaints showed concentrations around the town centre,

which is to be expected though the area around Ampthill Road is a slight outlier and indicates

a possible link between HMOs and waste and noise complaints. The distribution of pest reports

does not show any conclusive link between pests and HMOs.

1.1.12 There is a moderate correlation between environmental complaints and HMO concentrations.

Whilst there are issues and these are acknowledged, they would not, in themselves, justify

making an Article 4 direction though they should be taken into account in terms of them having

a cumulative impact.

1.1.13 The distribution of anti-social behaviour records shows concentrations around the town centre,

which again is to be expected and does not illustrate a conclusive relationship between HMOs

and Anti-Social Behaviour (ASB) records due to the influence of the town centre location. The

area around Ampthill Road is a slight outlier and indicates a possible link between HMOs and

ASB records.

1.1.14 There is a moderate correlation overall between the crimes reported and HMO concentrations.

The majority of the crime reports are within the MK40 1 postcode area where there is an evident

hot spot as it is the town centre which appears to be heavily influencing the results and therefore

it is not possible to demonstrate a conclusive relationship between the two. A series of other

hotter areas is identified including Ampthill Road and near to the university campus, indicating

a potential relationship between HMO concentrations and reported crimes.

1.1.15 There has been an increase in planning applications for large HMOs, enforcement cases and

appeals across the last five years. There has also been a decrease in planning applications for

changing existing HMOs back into other uses including family accommodation.

1.1.16 There is no evidence that the Council is failing to react to issues with HMOs but that there has

been an increase in the need to do so across the last 5 years. They have responded and closed

18 planning enforcement cases, are pursuing 9 further enforcement cases and have won 5 out


4

of 6 planning appeals determined by Government inspectors related to HMOs in the last 5 years.

1.1.17 In order to gather detailed evidence from those most knowledgeable about HMOs, consultation

in the form of small focus groups was considered necessary. Three focus group sessions were

arranged, comprised of the following:

A. Higher Education Establishments and Registered Social Landlords B. Letting Agents and Licensed Operators of HMOs

C. Community Representatives, Residents Groups and Elected Members

1.1.18 In order to reach a wider audience and ensure residents of Bedford Town and Kempston Town

Wards are aware of and had an opportunity to participate in the Study, a drop-in event was

organised for 4th July 2019.

1.1.19 The outcome of the public consultation exercises was that, while accepting that HMOs provided

a source of affordable low cost housing, those who responded largely associated HMO’s with;

loss of character, poor maintenance, waste and rubbish, overcrowding and noise.

1.1.20 Based on the data, there is evidence that, in some areas, concentrations of HMOs are leading

to a change in character which is having an impact on the amenity and proper planning of the

area. This is principally related to visual character and appearance though there is a moderate

correlation between environmental complaint indicators and HMOs which should also be taken

into account as part of a cumulative impact. Overall, an Article 4 direction is considered justified

on the grounds of assisting with the proper planning of the area.

1.1.21 It has been noted that, at a national level, many of the areas that introduced tightly defined (in

terms of geographical area) Article 4 directions have since extended the area they cover. It is

therefore recommended that an Article 4 is made for the whole of the current Bedford/Kempston

urban area to avoid the risk of creating clusters of HMOs around the perimeters of Article 4

areas and prevent further directions becoming necessary in the future.

1.1.22 If an Article 4 direction is made by Bedford Borough Council, it is recommended that a

Supplementary Planning Document be prepared to accompany this and to assist in guiding

future planning queries and applications.


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2.0 Introduction

Background

2.1.1 In recent years, areas of high HMO concentrations in Bedford Town are reported to have

increased. There are local concerns that this has resulted in; increasing levels of anti-social

behaviour (noise, litter), a decline in visual amenity through – for example – a proliferation of

lettings boards, satellite dishes and poor maintenance of properties, as well as the impact that

concentrations of HMOs have on the stability of local communities as first time buyers and

renters compete with buy-to-let landlords.

2.1.2 However, whilst there are local concerns, there is also an acknowledgement of the important

contribution that HMOs make to housing supply through offering a source of accommodation to

those who require additional flexibility regarding length of tenancy or who are unable to

purchase or rent self-contained accommodation. Based on the Strategic Housing Market

Assessment (SHMA), “there is likely to be a continued (and possibly growing) role for HMO

accommodation”2. This study does not investigate the extent to which demand for HMOs is a

result of individuals wishing to live in shared accommodation, or if this is a by-product of

affordability. However, the potential consequences of additional planning controls on the supply

of housing options for specific groups is an important consideration.

Understanding the Issues

2.2.1 HMOs serve an important purpose in providing accommodation for specific groups including

students, individuals in small households unable to afford self-contained accommodation and

other casual/transient workers. Nationally, the private rented sector, of which HMOs form part,

has undergone significant growth and now accommodates around 4.3 million households in

England3.

2.2.2 However, due to the way data on HMOs is collected by individual authorities and the patchwork

of licencing schemes particularly for smaller HMOs, it is unclear precisely how many HMOs

operate across the country. Estimates from the National HMO network in 2013/14 assessed that

there were at least 543,000 HMOs and the number was increasing.

2 Paragraph 4.14-4.17 Opinion Research Services (2018) Bedford Strategic Housing Market

Assessment Update 2016 and addendum report. 3 House of Commons Library 2017


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2.2.3 Issues that can arise from high concentrations of HMOs are well-reported and include:

• Anti-social behaviour, noise and nuisance

• Imbalanced and unsuitable communities

• Negative impacts on the physical environment and streetscape

• Pressures on parking provision

• Increased crime

• Growth in private rented sectors at the expense of owner occupation

• Pressure on local community facilities and

• The restructuring of retail, commercial services and recreational facilities to suit the

lifestyles of the predominant population.

2.2.4 Due to the transient nature of many HMO tenancies, where individuals may be vulnerable and

strangers to each other, concerns can arise with the management of these properties. Poor

management may impact on both the residents of HMOs, and the wider neighbourhood. Whilst

most HMOs are reportedly well-managed, on a national basis, in some areas there remains a

particular issue with management and the quality of accommodation.

2.2.5 Since October 2010 it has been possible to convert a family home into a small HMO for up to 6

people (and back again) without the need to apply for planning permission. However, this right

may be removed through an Article 4 direction, where there is enough evidence that the

permitted development right is harming the amenity and proper planning of an area.

Study Purpose

2.3.1 This report has been commissioned by Bedford Borough Council to examine the effects of HMOs

and if there is evidence to support the making of an Article 4 Direction within their Borough to

remove permitted development rights that currently allow family homes to be converted into

HMOs for up to 6 people4 and, if justified, the geographical area to which this should apply.

4 Use class C3 to C4


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Project Scope and Status

Study Area

2.4.1 The study area for this project was defined by Bedford Borough Council as the built-up urban

area of Bedford and Kempston. The study area is shown in Figure 1: Study Area:

Figure 1: Study Area

2.4.2 For some datasets, we have also looked at the whole of Bedford Borough.


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Project Timescales and Next Steps

2.4.1 This report is intended to provide an objective, professional view to inform Bedford

Borough Council’s decision as to whether, or not, an Article 4 direction is justified. The

recommendations are non-binding and the Council may reach alternative conclusions to

those of this report. Should the Council seek to make a non-immediate Article 4 direction,

this will be subject to a statutory period of 12 months before the Direction comes into

force (it should be noted that the Council does have the option of making an immediate

Article 4 Direction but this carries with it a compensation liability and is not, therefore,

recommended). It is advised that additional Planning Guidance to assist the determination

of planning applications relating to new HMOs should be prepared during this period, if

required.

2.4.2 The key project stages are set out below in Figure 2, below.

Figure 2: Project Milestones

Comissioned in April 2019

May- June 2019 Assess Data

July 2019 Community and Stakeholder

Engagement

Autumn 2019 Issue report to Bedford Borough Council

Autumn 2019 Bedford Borough Council

Executive take a formal decision

OPTIONAL: Article 4 12 month consultation

period

Winter 2020 (OPTIONAL) Article 4 comes into force and Planning Guidance is

adopted


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Report Structure

Section 3: Background and Context

2.5.1 This Section sets out the relevant planning background regarding Houses in Multiple Occupation,

the planning use classes and permitted development rights. This includes a commentary on

relevant planning legislation and appeal decisions.

2.5.2 In this section, we also provide case studies of areas that have introduced Article 4 Directions.

Section 4: Methodology

2.5.3 Many of the results are presented through a series of different mapping layers. The methodology

section provides details of the evidence examined and the source(s) of this information. It

explains any identified gaps within the data and steps that have been taken to overcome

weaknesses or inconsistencies. In addition, it sets out the design of the public and stakeholder

engagement.

Section 5: Bedford Background and Context

2.5.4 This section examines the specific circumstances relating to Bedford and HMOs.

Section 6: Results and Findings

2.5.5 Within the results and findings section, we seek to present the information to:

• Quantify the number of HMOs presently operating within Bedford

• Identify the areas in which they operate, and any key clusters

• Establish if there is a correlation between numbers of HMOs and environmental and

other complaints

• Examines recent planning applications and appeals in Bedford Borough Council

• Present the findings of the stakeholder and public engagement

Section 7: Discussion and Evaluation

2.5.6 It is important to ensure that this research is objective. This section draws together the results

and findings, applying the relevant context.

Section 8: Conclusion and Recommendations

2.5.7 This section of the report will recommend if an Article 4 should or should not be made and

summarises the reason for the recommendation.


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3.0 Background and Context

What is a HMO?

3.1.1 There are a range of different definitions of a House in Multiple Occupation (HMO), which largely

come out of legislation relating to the private rented sector i.e. the Housing Act 2004. In simple

terms, a HMO is defined as a property where occupants share one or more basic facilities (i.e.

a toilet, personal washing facilities or cooking facilities) and the property is occupied by 3 or

more people who do not form a single household. Rent must be payable by at least one

occupant.

3.1.2 This study has been commissioned to examine the planning impacts of HMOs on Bedford. As

such, unless stated otherwise, this study refers to the definitions set out within Town and

Country Planning (Use Classes) Order 1987 (as amended). It is acknowledged there are further

definitions, for example in respect of Council Tax. However, these are not considered further

within this report.

Planning Use Classes

3.2.1 Within planning, different types of development are classified within the ‘Use Classes Order’.

Residential development usually falls within the ‘C’ classes. Until 2010, there was no separate

use class for HMOs. However, large HMOs (i.e. occupied by more than 6 persons) often fell

outside the residential use class and, due to their characteristics were placed in the ‘sui generis’

category.

3.2.2 Following consultation by the Government in 2008/2009 regarding the issues caused by high

concentrations of HMOs in certain areas, particularly for student housing, it was decided to

create a new and separate use class to enable tighter planning controls through the creation of

a new class, C4 Small HMOs. This separated shared houses for up to 6 people from the previous

C3 use class. Use Class C4 came into effect from the 6th April 20105 and remains unchanged.

3.2.3 Circular 08/10 explains the interactions between the various use classes that apply to residential

properties and the relevant changes to the planning definitions that occurred following the

introduction of use class C4 ‘Small HMO’. The circular was withdrawn and replaced by the

Planning Practice Guidance in 2014, however it remains a useful reference.

5 The Town and Country Planning (Use Classes) (Amendment) (England ) Order 2010 (SI 653/2010)


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Use Class C3:

3.2.4 Most dwellings, such as family homes, fall into Class C3 (dwelling houses). There are three

distinct parts to this class:

• C3(a): those living together as a single household as defined by the Housing Act 2004.

This is essentially a ‘family’6.

• C3(b): those living together as a single household and receiving care, and

• C3(c): those living together as a single household who do not fall within the C4

definition of a house in multiple occupation.

3.2.5 Unlike use class C3(a) and C4, ‘single household’ is not defined in legislation for use class C3(b)

or C3(4), although the limit is no more than six people. However, C3(b) is usually associated

with supported housing schemes such as those for people with disabilities or mental health

problems. This is separate to residential institutions, where staff and residents are unlikely to

live together as a single household, irrespective of size.

3.2.6 Use class C3(c) allows for the specific groups that do not fall into the definition of a HMO, for

example religious communities or homeowners who are living with a lodger.

Use Class C4:

3.2.7 Use class C4 covers small shared houses or flats occupied by between three and six unrelated

individuals who share basic amenities. The use class also applies to small bed-sits. Circular 08/10

also applies further guidance, namely that to fall within the definition of a HMO the property

must be occupied as the main residence. Whilst this excludes guests it does include students,

migrants and others even if they do not occupy the property for the whole year.

3.2.8 Social housing is excluded from C4 uses, as are care homes, children’s homes, bail hostels,

properties for students managed by the educational establishment, religious communities. Other

exclusions include properties where the owner resides with two lodgers.

‘Sui Generis’ (Large HMOs)

3.2.9 Large houses in multiple occupation, e.g. those with more than six people sharing, are

unclassified by the Use Classes order. They are therefore ‘sui generis’

6 A single household under C3(a) is formed by a family (a couple whether married or not with members of the family of one of the couple to be treated as members of the family of the other), an employer and certain domestic employees (such as an au pair, nanny, nurse, governess, servant, chauffeur, gardener, secretary and personal assistant), a carer and the person receiving the care and a foster parent and foster child.


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Permitted Development

3.3.1 The requirement to obtain planning permission for certain types of development is set out within

the Town and Country Planning Act (1990). This covers new building work as well as changes

of use to building or land.

3.3.2 Changes within a class do not usually require an application for planning permission e.g. C3(a)

to C3(c) as there is no ‘material’ change e.g. it is not considered as development. However,

there are other changes that can be enacted through legislation, which enable changes of use

across classes and are known as ‘permitted development’.

3.3.3 The introduction of the C4 use class in 2010 was accompanied by an amendment to the General

Permitted Development Order (GPDO) which enabled properties that had been re-classified from

C3 to C4, to change back to C3 without the need to apply for planning permission, e.g. a small

HMO could change back to a family home.

3.3.4 Following a series of changes to the GDPO in October 20107, a further amendment was

introduced which enabled a change from use class C3 to C4 without the need to apply for

planning permission. This means that, unless local restrictions have been enacted through an

Article 4 Direction, there is no requirement to apply for planning permission to convert a

dwellinghouse (C3) to a Small HMO (C4) or back again.

3.3.5 Permitted development rights do not apply to changes from a dwelling house (C3) to a ‘large

HMO’ which falls under Sui Generis use and, therefore, planning permission is required for such

a change. However, whilst there is a limit of six persons to define the scope of C3(b), C3(c) and

C4, a breach of planning control may not occur if the threshold number is exceeded. This is

because a material change of use needs to occur e.g. that the use has intensified to a point

where it becomes a different ‘character’ or that the residents no longer form a single household.

This is explored in further detail in Section 3.5 Appeal Decisions.

7 The Town and Country Planning (Use Classes) (Amendment) (England) (No2) Order 2010 (SI 2134/2010).


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Article 4 Directions

3.4.1 An Article 4 direction is a planning tool that can be used by a Local Planning Authority.

It restricts the scope of permitted development rights either in relation to a particular area or

site, or a particular type of development anywhere in the authority’s jurisdiction. Where an

Article 4 direction is in effect, a planning application may be required for development that

would otherwise have been permitted development. The use of an Article 4 direction does not

mean that development is not allowed or would not receive planning permission, it simply means

that an application is required to give a Local Planning authority the opportunity to consider

each proposal in more detail and on its own merits.

3.4.2 The Planning Policy Guidance (PPG) sets out circumstances where the use of an Article 4

direction may be appropriate. It states:

“The use of Article 4 directions to remove national permitted development rights should be

limited to situations where this is necessary to protect local amenity or the wellbeing of the

area. The potential harm that the direction is intended to address should be clearly

identified.”8

3.4.3 Where removal is to be applied across a wide area e.g. the entire area of a local planning

authority, the PPG states that there should be a particularly strong justification.

3.4.4 Whilst there are a number of different uses for Article 4 directions, for example to control works

that could threaten the character of a conservation area, this particular study is looking at

removing the right that currently allows the conversion of residential properties to small HMOs

(C3 to C4). The making of an Article 4 in respect of the permitted development rights from C3

to C4 would only apply to this change and would not remove other rights9.

Additional controls possible by making an Article 4 direction

3.4.5 A range of controls upon HMOs is already possible through planning and licensing procedures,

these are listed within Table 1, below, alongside the additional controls that an Article 4 direction

would provide.

8 PPG Paragraph: 038 Reference ID: 13-038-20140306 9 Unless there is a further direction that applies to that area, for example a Conservation Area

https://historicengland.org.uk/advice/hpg/historic-environment/article4directions/

https://historicengland.org.uk/advice/hpg/hpr-definitions/l/536333/

https://historicengland.org.uk/advice/hpg/hpr-definitions/p/536385/


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Table 1: Current Council controls and additional controls through an Article 4 Direction

The process of making an Article 4 direction

3.4.6 The process of making an Article 4 direction is set out within legislation10 and there are two

types of direction: immediate or non-immediate. An immediate direction comes into force the

day it is made and must be confirmed within 6 months. A non-immediate direction is made

following a decision being taken by the relevant local planning authority, a 12-month notice and

consultation period, and then is confirmed when it comes into force.

3.4.7 Since 2010, where the Local Authority gives 12 months’ notice in advance of a direction taking

effect (non-immediate), there is no liability to pay compensation11. As part of the brief associated

with this project, we have been instructed that Bedford Borough Council is unlikely to make an

10 The Town and Country Planning (General Permitted Development) (England) Order 2015 11 Immediate Directions (or less than 12 months’ notice) compensation is payable in relation to planning applications submitted

within 12 months of the effective date of the direction which are then either refused or granted subject to conditions.

Topic Controlled under existing


powers

Controlled by an Article 4

direction and SPD

Bedroom size within both small

and large HMOs

Location and quantity of large

HMOs

Location and quantity of small

HMOs

Approval of cycle and waste

storage facilities for large

HMOs

Approval of cycle and waste

storage facilities for small

HMOs

Restriction of number of

residents/households permitted

in small and large HMOs

Restriction of ability to convert

flats to small HMOs

Ability to apply outdoor

amenity space standards or

criterion


15

immediate direction. This is due to the financial risks of the compensation payable to those that

may have benefitted from the right.

Where and why have Article 4 directions been used?

3.4.8 There is no definitive Government source that lists areas with Article 4 directions in place relating

to HMOs. As part of this project, we have undertaken a high-level desk-based assessment to

understand where and, if possible, why some authorities have chosen to adopt Article 4

directions and others have not.

3.4.9 A list of the authorities that have made an Article 4 direction relating to HMOs (e.g. C3-C4 uses),

the year the direction came into force, and the principal reason for doing so is contained in

Appendix A. Our research identified that 62 of the 343 Local Planning Authorities (18%) have

an Article 4 direction. Almost half of the directions were made in 2011/2012 shortly after the

permitted development rights were introduced and the most recent direction being introduced

in Doncaster, which comes into force in October 2019.

3.4.10 Of the authorities identified with Article 4 directions, 19 covered the whole of the Local Planning

Authority area when initially made compared to 36 covering part e.g. specific wards. However,

of those that made article 4 directions, 6 subsequently extended the areas of which 2 were

amended to cover the whole of the LPA area12. It was also noted that of those that had

introduced an Article 4 for part of the area, 10% (6) authorities later extended the area to

include additional wards or to cover the whole of the urban area.

3.4.11 Of the authorities identified with an Article 4 in place to control smaller HMOs, the principal

reasons appeared to be increasing control upon student housing (particularly for those that

introduced Article 4 directions shortly after the permitted development rights were introduced),

followed by the need to protect local amenity and preserve an appropriate mix of households.

12 One area did not publish an electronic version of the alongside the direction.


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Figure 3: Reason for making an Article 4 direction

3.4.12 In some areas, detailed justification has been published alongside the Article 4 direction which

provides more detail on the categories (above). For example:

“The principal impacts in Ashford have been from noise and disturbance, impact on the

environment from neglected gardens, litter, overflowing bins etc and pressure on parking

due to more people living in HMO than would generally live in the same size house.”

“These areas [in Preston City Centre] are particularly vulnerable because they are dominated

by terraced housing and narrow streets; have little, if any, off-street carparking and have

minimal space for refuse/ recycling storage within the curtilage of the properties.”

“The aim of the Direction is to assist in maintaining a mix of residential accommodation in

the neighbourhood (family homes and HMOs). This was in response to considerable local

concern that the number of HMOs in Stanmore was increasing and reaching a point where it

was affecting the stock and availability of family accommodation”. -Winchester City Council

Case Studies

3.4.13 In order to provide additional context, we have looked at the justification for Article 4 directions

in the South Midlands area, Milton Keynes and Northampton. For the case studies, Northampton

was selected for its similarities to Bedford in terms of housing stock (age, type and tenures) and

demographic profile, whilst Milton Keynes also provides a useful comparison as it sought to

make an immediate Article 4 direction for a limited area, which was later extended to cover the

whole of the Borough. In addition, we have looked at Doncaster as the most recent example.


17

Northampton

3.4.14 Like Bedford, Northampton is a university town, has employment opportunities tied to nearby

logistics, distribution and industrial estates and is within easy reach of London for key workers

and professionals. Coupled with these cross-cutting factors is the demand for private rented

housing from economically deprived individuals and families in light of an acknowledged under-

supply of social rented housing.

3.4.15 Northampton presently has three directions in place:

• Far Cotton and Delapre which came into effect in 2018 replacing the previous

‘immediate’ direction;

• Cliftonville which came into effect in 2018; and

• Northampton North and Central covering the wards of: Castle, Abington, Trinity,

Phippsville, Semilong, Kingsley, Kingsthorpe, St Davids, Sunnyside, Spring Park,

Obelisk and Delapre, and Briar Hill, which came into force in March 2012.

3.4.16 In 2018, Northampton Borough Council commissioned Loughborough University to carry out a

review of HMO policy for Northampton13. The report indicates there were 876 licensed HMOs in

Northampton at the time of writing, although the Borough Council had identified up to 800

‘suspect’ properties which may be operating as HMOs without a licence e.g. across the town

there could be almost twice as many HMOs as are presently recorded.

3.4.17 For Northampton, the researchers concluded that the coming together of factors such as;

location in relation to London and the jobs market, demographics, a significant lack of access

to social rented housing, together with the re-location of the university, resulted in a

“[…] high latent demand for HMOs in Northampton which is increasingly unlocked by

private investors and landlords resulting in a surge of the conversion of single family

residential dwellings to multi-person households. This results in higher levels of

population transience and concerns locally regarding the downgrading of physical

environments.”. – page 11.

13 Loughborough University (2018) A study of Housing in Multiple Occupation (HMO) policy: Report to

Northampton Borough Council online https://www.northampton.gov.uk/downloads/file/10737/2018-hmo-study last accessed 02/08/19

https://www.northampton.gov.uk/downloads/file/10737/2018-hmo-study

https://www.northampton.gov.uk/downloads/file/10737/2018-hmo-study


18

3.4.18 The study identified the following characteristics of areas with high concentrations of HMOs in

the town:

• incidence of the general poor upkeep and maintenance of private rented housing.

• dilapidation of some housing stock and housing facades (e.g. windows, doors and

guttering).

• unkempt gardens and yards, with the dumping of some unwanted white goods and

furniture.

• removal of some garden hedges/fences/walls to allow tarmacking for car parking on

gardens and driveways.

• predominance of loft conversions and housing extensions.

• prevalence of to-let signs, and non-removal of signs.

• seasonal depopulation, pointing to relatively high levels of population transience and

turnover.

• overspill from refuse bags and wheelie bins, particularly in alleyways.

• some fly-tipping of white-goods and unwanted furniture in backs of streets of terraced

housing.

• Streets crammed with parked cars

• Whilst the initial concentrations of HMOs were in the terraced streets and larger

properties around the town, particularly the larger town houses, in recent years there

has been a spread outward. A map of licensed HMOs for Northampton is set out in

Figure 4, below, page 20.

3.4.19 Two reasons are cited for the spread of HMOs:

• the relocation of the university from two campuses to the Waterside Location, and,

• an increase in the demand for affordable accommodation within the town from other

social groups seeking private rental accommodation.

3.4.20 Notably, the recommendation of the report suggests that, in order to manage the trend and

spread, the making of Borough-wide direction would be appropriate.

3.4.21 It was raised through liaison with Bedford Borough Council that the introduction of an Article 4

may cause issues in the provision of low-cost shared housing, if it is likely that the majority of


19

planning applications for small HMOs are refused.

3.4.22 Therefore, taking Northampton as an example, we have researched how many planning

applications for both small and large HMOs were approved and refused in the authority since

2011, noting that the first Article 4 direction in Northampton came into effect in 2012

3.4.23 Table 2, below, page 19 illustrates that the majority of small HMO planning applications are

approved (78%), therefore the Article 4 implementation has not resulted in the prohibition of

this valuable source of accommodation. However, the implementation of an Article 4 did also

enable the authority to assess the suitability of each application and to refuse 72 unsuitable

applications for small HMOs. Only 9 refusals were taken through to appeal.

Table 2: Applications and Appeals for HMOs in Northampton between 2011 and 2019

Year Planning Applications

for change of use to

small HMO

Planning Applications for

change of use to large

HMO

Planning Appeals

Approved Refused Approved Refused Allowed Dismissed

2011 1 0 1 0 0 1

2012 18 2 2 0 0 0

2013 14 1 0 0 0 0

2014 14 5 1 0 1 0

2015 19 4 1 1 0 0

2016 35 13 2 0 3 0

2017 82 22 3 0 2 0

2018 46 19 3 0 0 1

2019 33 6 0 1 0 1

Total 262 72 13 2 6 3


20

Figure 4: HMO distribution, Northampton

Milton Keynes

3.4.24 Milton Keynes was one of the first Local Planning Authorities to put in place an Article 4 direction

in respect of HMOs. An immediate direction was approved on the 6th December 2010 covering

the main built up area of the town; the non-immediate direction that was subsequently brought

into force covers the whole of the administrative area including the rural wards to the north of

the town. In preparing the evidence to support the Article 4 direction it was estimated there

were approximately 907 (0.5% of the housing stock) properties operating as a HMO.

3.4.25 Milton Keynes has been selected as a case study as it is not a university or a coastal town and

therefore provides an insight into other types of HMO residents and if there are any different

impacts or considerations.

3.4.26 Issues identified with HMOs in Milton Keynes included:

• Parking- particularly the capacity to accommodate additional parking on newer

estates;

• Bin storage and drying areas- where a fully occupied 5-bed HMO will generate more

waste that the average household size (2.4 persons); and

• Character and concentration, where the greatest concentration of HiMOs at a grid


21

square level can be found in Conniburrow (6.2%) and Fishermead (5.5%).

Fishermead has 92 known or suspected HiMOs, which equates to 16.8% of all known

or suspected HiMOs in the Borough.

3.4.27 The evidence to justify the making of an Article 4 direction in Milton Keynes was prepared by

Opinion Research Services (ORS) and was published alongside the “HiMO SPD supporting

evidence base14”. This highlighted several trends for the demand and residents of HMOs.

• In terms of dwelling stock, almost half of the HMOs are terraced properties with only

16% being detached and 12.7% semi-detached. For Milton Keynes, these findings

were significant given that the Borough has substantially more detached and semi-

detached properties (55%), whilst only 32% of the dwelling stock is terraced.

• The majority of those living in HMOs were between 21 and 30 years old (65%), and

economically active (80%) with the majority working in manufacturing, wholesale and

retail trade.

• Residents of HMO accommodation within the Borough were predominantly from Black

and Minority Ethnic (BAME) or ‘other white’ background (25%) with these groups

accounting for 60% of HMO residents. This contrasts strongly with the Borough’s

general population where ‘White British’ accounts for over 80%.

3.4.28 The study also provided evidence in respect of:

• Lower than average incomes;

• Higher migration/turnover of residents

• Fewer children in areas with higher concentrations of HMOs

3.4.29 In conclusion, the report highlights that, “HiMOs in Milton Keynes appear to be fulfilling a vital

role in the borough in providing accommodation for young workers in low income jobs who

would otherwise struggle to afford to live in the area.”

Doncaster

3.4.30 Doncaster Metropolitan Borough Council consulted on the introduction of additional licencing

and an Article 4 Direction in October 2017. It has been selected as it is the most recent area to

14 See: Milton Keynes Council (October 2011) Housing in Multiple Occupation Supplementary Planning Document Supporting Evidence and Regulation 17 documents. Online: https://www.milton-

keynes.gov.uk/assets/attach/9519/HiMO_Evidence_Paper_FINAL_reduced_file_size.pdf last accessed 02/08/2019

https://www.milton-keynes.gov.uk/assets/attach/9519/HiMO_Evidence_Paper_FINAL_reduced_file_size.pdf

https://www.milton-keynes.gov.uk/assets/attach/9519/HiMO_Evidence_Paper_FINAL_reduced_file_size.pdf


22

introduce an Article 4 direction to control HMOs. The town is not a major university town nor is

it a coastal area.

3.4.31 Doncaster is aware of over 1,000 properties currently being used as HMOs, although they

believe that the actual number may be much higher than this. The majority (83%) are located

within central wards, close to the centre. Many of these are properties which fall outside of

mandatory licencing, as such, Doncaster Council is seeking to introduce additional licencing

alongside an Article 4 direction. HMOs in Doncaster have become an increasingly attractive

option for investors due to the cost of housing (house prices are generally relatively low) and

the potential increase in rental income that can be gained through the letting of terraced

properties ‘by room’, rather than as a whole property.

3.4.32 Like other areas and as reported nationally there are disproportionately more environmental

complaints e.g. noise, waste and anti-social behaviour than other tenures. Whilst this may be a

reason in itself to ‘make’ an Article 4, the Council have also cited the link between poor housing

and poor health, something which is not explicit in many of the other areas examined. The

report states:

“Poor housing can lead to poor health and exacerbate existing health conditions. The

English Housing Survey has identified a higher prevalence of poor housing in the

private rented sector compared to other tenures. The areas identified for the A4D and

additional licensing scheme fall within the 10% most deprived communities which

experience poorer health outcomes than more affluent areas of the borough.

It will be beneficial if the planning and licensing proposals consider the importance

that the physical condition of the accommodation has on health and wellbeing and it

addresses the need to ensure the housing is safe, warm, well-constructed (e.g to

reduce noise) but also provides a health promoting environment providing good

facilities for the preparation and consumption of food, secure cycle storage etc.”15

3.4.33 As such, in making an Article 4, Doncaster Council consider there are much wider links and

benefits through additional planning controls in terms of controlling the location but also in

ensuring that those properties which are converted and let provide a healthy environment linking

to other corporate and social objectives.

15 Doncaster Council (1st May 2018) report to Planning Committee Article 4 direction relating Houses in Multiple Occupation online:

https://doncaster.moderngov.co.uk/documents/s16421/i7%20010518%20HMO%20Planning%20Committee%20Report%20Final.pdf (last accessed 0

https://doncaster.moderngov.co.uk/documents/s16421/i7%20010518%20HMO%20Planning%20Committee%20Report%20Final.pdf

https://doncaster.moderngov.co.uk/documents/s16421/i7%20010518%20HMO%20Planning%20Committee%20Report%20Final.pdf


23

Appeal Decisions

3.5.1 Appeals determined in relation to both small and large HMOs between 11th March 2019 and 11th

September 2019 across England, have been reviewed to ascertain the repeated concerns arising

when cases are dismissed and the positive reasoning for the appeals allowed. Overall, more

appeals were dismissed than allowed (Table 3, below)

Table 3: Appeal decisions across England between March 2019 and September 2019

3.5.2 The reasons for these dismissals are varied, albeit the potential for unacceptable levels of noise

and disturbance was the most referred to concern. Other concerns cited include;

• exacerbation of imbalance of housing

• cramped accommodation with inadequate amenity space

• substandard living conditions

• increased vehicle movements

• harm to the character and appearance of the area from overdevelopment

3.5.3 Observations made upon the appeals that were allowed included the following points;

• activity related to small HMOs is similar to that of families and neighbour amenity

unlikely to be harmed

• there would be no harm to the amenity or character of the area

• providing accommodation for single people outweighed the loss of a family-sized unit.

• extra people locally would contribute to the local area being sustained

3.5.4 Evidently, each case is determined upon its own merits and within the relevant context.

However, the appeal research does highlight that there are many planning related impacts that

can be attributed to the presence of HMOs, both positive and negative.

Appeals Allowed for

Small HMOs

Appeals Dismissed for

Small HMOs

Appeals Allowed for

Large HMOs

Appeals Dismissed

for Large HMOs

3 5 6 10


24

4.0 Methodology

Research Questions

4.1.1 The methodology for this Study utilises a combination of qualitative and quantitative resources

to assess the following research questions, which fit into the overall aim of the study to assess

the potential impact of HMOs on the Bedford and Kempston urban areas.

• How many HMOs are there in Bedford and where are they?

• What types of HMOs are there in Bedford and where are they distributed?


the area?


• Is there any correlation between crime data and HMO concentrations?

• How many planning applications, enforcement cases and appeals related to HMOs

have there been in the last five years?

• How does the local community perceive HMOs?

Data Sources

4.2.1 The following table (Table 43, below) details the datasets used in the study and the source of

this information. The majority of the quantitative data was provided by Bedford Borough Council

from their relevant specialist departments, this was shared with WYG using password protection

to ensure security during the transfer and with some data anonymised to ensure compliance

with General Data Protection Regulations (GDPR). The majority of the qualitative data was

collected by the WYG consultant team directly.

Table 4: Data Sources

Data set Source Type of Data

List of Authorities with Article

4’s restricting HMOs

Local Authority Websites Qualitative

Conservation Area Appraisals

and Boundaries

Bedford Borough Council Qualitative

HMO Complaints Bedford Borough Council Quantitative

Council Tax Bedford Borough Council Quantitative


25

Anti-Social Behaviour Reports Bedford Borough Council Quantitative

Police Recorded Anti-Social

Behaviour

Bedfordshire Police via Bedford

Borough Council

Quantitative

Police Recorded Crime Bedfordshire Police via Bedford Borough Council

Quantitative

Pests Reports Bedford Borough Council Quantitative

Noise Complaints Bedford Borough Council Quantitative

Waste Complaints Bedford Borough Council Quantitative

Controlled Parking Zones Bedford Borough Council Quantitative

Licensed HMOs (Mandatory) Bedford Borough Council Quantitative

Licensed HMOs (Additional) Bedford Borough Council Quantitative

Strategic Housing Market

Assessment

Opinion Research Services via


Qualitative

Housing Stock Modelling Report BRE via Bedford Borough Council

Quantitative

Local Insight Bedford Borough Council Quantitative

Planning Applications for Large HMO’s

Bedford Borough Council Qualitative

Planning Enforcement related

to HMOs

Bedford Borough Council Quantitative

Appeals related to HMO Appeals Inspectorate Qualitative

Open Electoral Register Bedford Borough Council Quantitative

Land Registry Land Registry Business Services Quantitative

Site Visit Photos and Notes WYG Qualitative

Focus Group Session Notes WYG Qualitative

Drop-in Session Notes and

Feedback Forms

WYG Qualitative

Data quality and assumptions

4.3.1 The data utilised was largely collected by standardised Bedford Borough Council processes and

have been checked by the relevant departments. Therefore, the data quality is generally very

good with minimal assumptions and limitations, as listed in the following table (Table 5, below,

page 25) the impact level of the limitation and the mitigation measures taken are also detailed.

Table 5: Assumptions and Limitations

Assumption/Limitation Impact Level

(Low/Medium/High)

Mitigation Measure (if

applicable)

The HMO licensing data may not represent all HMOs in the Borough.

Although it is mandatory for both small and large HMOs to have a licence within

Bedford Borough Council, there may be

some operating without a licence.

Medium A sample of electoral roll data has been used to

check if there are many properties with multiple

independent residents

which are not shown in the licensing data. The number

of anomalies or lack thereof assists in confirming the

accuracy of the licencing data.


26

It was not possible to accurately show the

growth of concentrations in HMOs over

time. This is because changes in legislation which consequently required

more HMOs to apply for licences and the implementation of an additional licensing

scheme would skew the results by

highlighting peaks in HMO’s presence. These peaks may not be representative of

when the HMOs came into existence but rather show when they required or

choose to apply for a license

Low This study looks at the

current amenity, character

and wellbeing of an area, primarily because an Article

4 direction cannot act retrospectively.

The electoral roll data that was used for the cross-referencing exercise will not

contain information relating to the residents of all properties, as many

residents may not register to vote for a

number of reasons, including the duration of residence at an address

Medium These gaps in the electoral roll data does limit the

ability to cross-reference against the licensing

information, however if

another source such as Call Credit/Trans Union data

were to be used there may be similar issues with

capturing resident

information

Only a sample of streets were visited as

part of the study

Low This sample is considered to

be varied and representative

Some of the complaints data is recorded

via a ‘self-service’ process where residents log their details themselves online, this

results in some complaints showing only

partial data or incorrect classifications of data

Low This only impacted a small

quantity of data

Complaint reports data is by its nature limited to those residents that choose to

make a complaint to the Council and may

not encompass complaints made directly to landlords or lettings agents

Low Landlords and lettings agents were invited to the

focus groups and contacted

via telephone. However, no representations/comments

were made by this group.

Anti-social behaviour and Crime data is also by its nature limited to those

residents that choose to report incidents.

Low

The Council tax data does not include properties where there is an exemption

from payment of council tax in place, for example where all residents are students

Low The Council tax data has not been solely relied upon

for HMO identification. HMO Licensing data provides

more results.

The Local Insight data is retrieved from the 2011 Census and other government

open data, however the ward boundaries have changed since 2011

Low This is the most recently available information of its

type and can still be interpreted for the report

background

Although invites for the focus groups were sent to landlords of HMOs, local

letting agents, Registered Social

Low Attempts to contact the other invitees were made

via telephone after the


27

Landlords (RSL’s), university

representatives and community

representatives, all the attendees were community representatives

focus groups with very

limited success. However,

communication with the Housing team from Bedford

Borough Council has been made, this team maintain

contact with HMO

Landlords, RSL’s, agents and universities in relation

to their responsibilities. Online data relating to

letting prices were also

sourced

Processing and Mapping

4.4.1 Upon receipt of each quantitative dataset, all personal data and data that could be used to

identify a specific residence was removed. Full postcodes remained within the datasets for

mapping purposes, however street numbers/property names were deleted. Data that was not

considered to be relevant, relating to commercial or public properties for example was also

removed.

4.4.2 Pivot tables and GIS mapping were then used to allow the grouping and analysis of data. The

pivot table process automatically generates statistics including sums and averages, this was

particularly valuable when calculating the sums of the number of HMO households on each given

street. To ensure the accuracy of the automatic processing of the data through these pivot

tables, a sample of sums from each dataset was checked manually.

4.4.3 The mapping of the data was undertaken using ArcGIS with a secure login to ensure that the

background data tables were not shared outside of WYG. Most of the quantitative datasets used

in this study lend themselves to heat mapping, enabling the easy identification of concentrations

as hot spots. All heat maps were produced using the same ‘area of influence’ meaning that the

size of hot spots would be accurately comparable.

4.4.4 Where further detail needed to be mapped or the heat maps were not visually understandable,

the quantitative data was mapped using a ‘counts and amounts’ drawing style. This shows

symbols across the map in sizes relative to the amount of data points at each given location.

4.4.5 A number of illustrative maps have also been produced to support the study. These are listed

as follows; conservation areas, streets where site visits were undertaken, locations of higher

education, transport and healthcare facilities, ward areas, postcode sectors, and the streets of

residence of the attendees of the public drop-in session.


28

Consultation and Engagement

4.5.1 WYG prepared a Consultation Strategy at the project inception and agreed this with Bedford

Borough Council. The Strategy remained under review for the duration of the Study and was

adapted accordingly to incorporate additional engagement and/or to mitigate any limitations of

the study.

4.5.2 An initial stakeholder analysis was undertaken to assist in developing the Strategy. This

established that the following stakeholders should be encouraged to engage in the evidence

gathering for the Study; community group representatives, higher education establishments,

licensed operators of HMOs, lettings agents, RSLs, elected members and residents of Bedford

Town and Kempston Town Wards.

Focus Groups

4.5.3 In order to gather detailed evidence from those most knowledgeable about HMOs, consultation

in the form of small focus groups was considered to be an appropriate starting point. Three

focus groups were scheduled, comprised of the following:

D. Higher Education Establishments and Registered Social Landlords E. Letting Agents and Licensed Operators of HMOs

F. Community Representatives, Residents Groups and Elected Members

4.5.4 A list of invitees was collated by WYG in collaboration with Bedford Borough Council and a letter

was sent out on 17th June 2019 with background information about the Study and an explanation

of the purpose of the focus groups (Appendix B).

4.5.5 The focus groups all took place on 24th June 2019 at The Castle Room, The Higgins between

10am and 4.30pm, with each group having up to 2 hours of dedicated time with WYG staff.

Introductory presentations were prepared for each group covering; the purpose of the Study,

the Study area, the definitions of HMOs, how HMOs relate to the planning system and how the

views received from the groups will be used to shape the results of the Study.

4.5.6 Following the presentation, a more interactive session was instigated using a series of topics

and questions to facilitate feedback and discussion. Those used for focus group C are noted

below.


29

4.5.7 Notes were taken by WYG staff during the presentation and the interactive discussion, this

documented the queries that attendees posed to the staff and the comments made in response

to the three topics above. A series of broad themes and keywords mentioned by attendees were

written up onto a flipchart during the session.

4.5.8 Focus Group C for the Community Representatives, Residents Groups and Elected Members was

attended by 7 people, the other focus groups had no attendees. This lack of participation from

the groups A and B is identified as a limitation of the study.

Drop-in Event

4.5.9 In order to reach a wider audience and ensure residents of Bedford Town and Kempston Town

Wards are aware of and had an opportunity to participate in the Study, a drop-in event was

organised for 4th July 2019. This was hosted at Borough Hall between 12 noon and 8pm, two

WYG members of staff were available to answer questions.

4.5.10 This was advertised via press release, by informing local community groups, using Bedford

Borough Council social media and both Bedford Borough and WYG websites. The WYG website

was published on 12th June 2019 and remains accessible for informational purposes, including

a digital copy of the exhibition boards.

4.5.11 22 people attended the drop-in event, with 5 feedback forms completed at the event, 2 received

via post and 5 received via email.

4.5.12 Eight exhibition boards were created (Appendix C) which detailed the following; the Study area,

background and scope, definition of HMOs in planning, locations of licensed HMOs, location of

Topic 1- Perceptions of HMOs

• What do you think of when you think about a HMO?

• Who lives there? [possibility of using post it notes/ markers/ dots]

• Where are HMOs concentrated?

Topic 2- Experiences living in/near HMOs

• What are the biggest concerns?

• How do you think your area has altered?

• What has caused this?

Topic 3- Feedback (to inform drop in exhibition)

• Do you know what the licencing scheme does?

• How might planning controls help address concerns?


30

site visits, heat mapping of environmental complaints, perceptions of HMOs and the next steps

following the exhibition.

4.5.13 Within the exhibition boards, a series of questions was posed for attendees using stickers to

indicate their answers and in some instances their reasoning. For example, on exhibition board

four, attendees were asked if the pattern of HMO concentrations shown on the heat map

matched their expectations. If they answered no, they were asked to indicate on the map which

other areas they thought would have HMO concentrations.

4.5.14 In addition to the questions on the exhibition boards, feedback forms were offered to attendees

(Appendix D). These allowed attendees to share their views and raise any specific queries.

Feedback forms were also displayed on the webpage for people to download and return via post

or to the bespoke email address set up for the project. All feedback forms were requested to be

returned by the end of July 2019, allowing four weeks for responses.


31

5.0 Bedford Background and Context

Overview

5.1.1 Within particular areas of Bedford, there is a perception that an increase in HMO accommodation

is having impacts on amenity, character and the quality of life for non-HMO residents. In 2018

a ‘task and finish group’ was convened at the request of the ‘Environment and Sustainable

Communities Overview and Scrutiny Committee’ (ESCOSC) specifically to look at issues within

the Midland Road and Town centre. The area spans three wards: Castle, De Parys and Harpur.

5.1.2 Local planning authorities should consider making Article 4 directions only in exceptional

circumstances where evidence suggests that the exercise of permitted development rights

harms local amenity or the proper planning of the area.

5.1.3 This section of the report looks at the key contextual information relating to the study area

including:

• Urban Character of Bedford

• Population and Distribution

• Information relating to the Private Rented Sector “PRS” in Bedford (e.g. rental prices,

availability etc)

• The local planning background

• Steps that have been taken in respect of managing HMOs within Bedford including the

introduction of additional licencing

5.1.4 The mapping within this section of the report has been produced using Bedford Local Insight,

an open access mapping system hosted by Bedford Borough Council. This information source

maps various government statistical releases. Two types of mapping have been used from Local

Insight: All Areas and hotspot areas. The explanation of these different sources is set out below

and are comparable to England as a whole (rather than Bedford Borough):

• All areas: The colours on the map are based on grouping all areas across England

into 20% bands. The top 20% of areas on an indicator are shaded dark red, the next

20% shaded light red, and so on. However, in some views, the whole map may be a

single colour, due to all areas in view being in the top (or bottom) 20%.

• Hotspot areas: The colours on the map are be based on the top 20% of areas


32

across England only. The 5 colour bands are based on the top 1%, 1-5%, 5-10%, 10-

15% and 15-20%. Other areas are unshaded.

Bedford Urban Character

5.2.1 Bedford’s rich history is reflected in the urban character of the town be this the street layout or

the built form. Following the introduction of the railway linking the town to London, Bedford

expanded rapidly particularly to the west and north with a pattern of dense, urban terraced

streets. Much of Bedford’s town centre, including a number of these streets, fall within a

Conservation Area (Figure 5, below,). During the 20th and 21st centuries, the expansion of the

town has continued, with the most recent development taking place as additional ‘urban

extensions’ to the town.

Figure 5: Bedford Borough Council Conservation Areas


33

5.2.2 Across Bedford Borough, detached and semi-detached properties account for almost 60% of

total housing stock compared to just under 22% of terraced homes. However, in the older areas

around the town-centre, whilst terraced housing accounts for almost 50% of the total housing

stock, there is a mix of house types and sizes which includes streets of larger detached and

semi-detached period properties and mansion blocks. In these areas, it is noted that flats in

converted properties can account for between 5-22% of household spaces.

Figure 6: Terraced Housing Stock (% of total stock)


34

Figure 7: Flats in a converted house

5.2.3 The urban character appears to correlate broadly with population density. Figure 8 and

5.2.4 Figure 9, below, show the population density (by ‘hotspot’). In addition to the predominent

type of housing stock, there are other factors such as the prescence of open spaces and non-

residential uses (e.g. the town centre has a person per hectare density of around 52).

5.2.5 Within Bedford, even with areas considered broadly similar in terms of built form and land uses,

population density at the LSOA level ranges ranges from 142.31 persons per ha in the streets

to the east of Beford Midland Railway Station to around 69.11 in the streets north of Russell

Park (excluding the park). The ‘hotspot’ mapping in

5.2.6 Figure 9 shows this more clearly.

5.2.7 In summary, within the study area, population density is highest in the areas immediately

surrounding the town centre, largely reflective of the housing stock and relative density.


35

Figure 8: Population Density

Figure 9: Population Density- Town Centre (North)


36

5.2.8 Figure 10, below shows the Index of Multiple Deprivation which combines 37 social, economic

and environmental indicators to produce an overall deprivation score. This broadly correlates

with Figure 11 and Figure 12, both below, highlighting average life expectancy between males

and females. The areas which are most deprived are centred around MK40 1, loosely

corresponding with population density. The lowest male life expectancy ranging from 65 to 77

years can be seen to the north of the town centre, around Tavistock Street and Kimbolton Road.

The lowest female life expectancy can be seen to the north of the town centre, and along

Cardington Road.

Figure 10: Index of Multiple Deprivation (Health)


37

Figure 11: Male life expectancy

Figure 12: Female life expectancy


38

The Planning Background in Bedford:

Planning Policy:

5.3.1 Bedford Borough Council is currently in the latter stages of preparing a Local Plan that will set

out how much growth there should be in the Borough in coming years (housing, jobs and

associated infrastructure) and where it should take place. The examination of this Plan took

place during June 2019. It is likely that this plan will be adopted in the early 2020, replacing the

existing Core Strategy.

5.3.2 The Local Plan 2030 is presently subject to ‘main modifications’, which are subject to

consultation (September 2019). For the avoidance of doubt, the updated figure subject to

modification is included within brackets.

5.3.3 The Local Plan 2030 makes provision for 3,636 (3,169) new dwellings over the plan period. This

is in addition to existing allocations from previous plans which are currently being built out. Of

these homes, 2,532 (2,647) (of which 1,785 (1,900) are to be delivered by 2030) are directed

to the Bedford Urban Area. This area is the same as the Study area of this report.

5.3.4 The Local Plan 2030 does not contain any specific policies relating specifically to Houses in

Multiple Occupation. However, the Plan does identify that “Achieving an appropriate housing

mix is an important element in seeking to create sustainable, inclusive and mixed communities”16

5.3.5 In addition, the following specific policies relate to development proposals, which may include

conversions of existing properties, where this constitutes ‘development’:

• 29S- Place Making particularly “ii. To have a positive relationship with the

surrounding area, integrating well with and complementing the character of the area

in which the development is located”

• 30- Design quality and principles, again ensuring positive contributions to the

area’s character and identity, promote accessibility and permeability and the

incorporation of measures to promote community safety ensuring private and public

amenity spaces are clearly defined and, integrate functional needs such as refuse/

recycling storage and collection points, car and cycle parking.

• 31- The impact of development- design impacts to include the relationship with

the context, quality regarding scale, density massing, height and materials.

16 Bedford Local Plan 2030 (submission version) Paragraph 10.11


39

• 32- The impact of development- access impacts which relates in part to parking

provision, safety or general disturbance and access arrangements

• 33- The impact of development- disturbance and pollution impacts which

covers a range of considerations such as noise, vibration, smell, tranquillity, the

suitability of the existing environment and factors which might give rise to disturbance

of neighbours including overlooking, crime and community safety

• 34- The impact of development- infrastructure impacts which seeks to ensure

that proposals are not harmful (including cumulative impacts) on the adequacy of

existing infrastructure for example on utilities, schools, health and community

facilities.

5.3.6 The Strategic Housing Market Assessment (SHMA) was prepared by Opinion Research Services

(ORS) in October 2016 and subsequently updated in August 2018 to include consideration of

more recent updates to household projections and to account for a change in the plan period.

Based on the evidence, Bedford Borough Council concluded that there was no reason to alter

the findings of the SHMA on the grounds of revised household projections.

Housing Background

5.4.1 Based on the data from the Office of National Statistics, in May 2019, the median property price

across Bedford was approximately £272,587, with median gross annual work-place earnings

£28,520, resulting in an affordability ratio of 9.8217. This means that someone working in

Bedford would need to borrow around 9.82x their salary in order to purchase a property.

5.4.2 By contrast, affordability in the surrounding areas is as follows:

• Milton Keynes 8.81

• Northampton 7.60

• Aylesbury Vale 11.20

• Central Bedfordshire 10.86

17 Office of National Statistics (28th March 2019) House Price to workplace-based earnings ratios

https://www.ons.gov.uk/peoplepopulationandcommunity/housing/datasets/ratioofhousepricetoworkplacebasedearningslowerquartileandmedian




40

5.4.3 This means that, for people who work within Bedford housing is relatively more expensive

compared to Milton Keynes and Northampton, but more affordable than Aylesbury Vale or

Central Bedfordshire.

5.4.4 Across Bedford, there is variation in house prices, this variation is shown below in map form

with the data taken from the Land Registry.

Figure 13: Average House Price (2018/19)18

Rental Sector

5.4.5 Across England as a whole, the Private Rented Sector “PRS” has grown significantly. This tenure

accounts for the rental of ‘whole’ houses or flats as well as HMOs and shared properties. The

Office of National Statistics reports that since 2007 the number of households in the PRS has

increased from 2.8 million in 2007 to 4.5 million. Of these households, those aged 25-34

represented the largest group19.

5.4.6 The Housing Strategy20 reports a significant increase in the Private Rented Sector households

18 Bedford Insight (2019) taken from Land Registry (http://landregistry.data.gov.uk/) June-18 to May-19 19 English Housing Survey Headline Report 2015-16 Introduction and main findings, Department for Communities and Local

Government Pg.2 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/595785/2015- 16_EHS_Headline_Report.pdf 20 Bedford Borough Council (2016) Housing Strategy Review 2016-2020

https://bbcdevwebfiles.blob.core.windows.net/webfiles/Housing/ENV125_16%20Housing%20Strategy%20Review%20and%20Appendix%20COMBINED%20-%20WEB.pdf

http://landregistry.data.gov.uk/




41

from 5,921 (9.8% of all dwellings) in 2001 to 10,110 (15.9%) in 2011, reflecting the growth in

the number of buy-to-let properties, higher purchase costs and difficulties in securing

mortgages. In 2011 the Social Rented sector accommodated 10,252 households, (16.1%), only

142 more than the Private Rented Sector.

Cost of renting

5.4.7 The cost of rented accommodation within Bedford is set out below21 for ‘whole’ properties.

General Needs Housing is commonly considered as ‘social rent’ e.g. it is the subsidised rental

costs payable to a registered provider (Bedford Borough Council do not own any stock

themselves). Affordable rent is another type of affordable product, with rental costs discounted

below the market value.

Table 6: Bedford average rental costs

Unit Size

General Needs

Housing

Gross Rent

Affordable Rents Market Rent

(Median ret)22

Weekly PCM Weekly PCM Weekly PCM

Non-self-contained £0.00 £0.00 £0.00 £0.00 No data No data

Bedsit £90.44 £391.90 £83.29 £360.92 No data No data

1 Bedroom £94.81 £410.84 £101.89 £441.52 £144 £624

2 Bedroom £103.01 £446.38 £124.59 £539.89 £185 £802

3 Bedroom £112.32 £486.72 £141.50 £613.17 £219 £949

4 Bedroom £126.39 £547.69 £174.32 £755.39 £315 £1363

5 Bedroom £141.83 £614.60 £177.25 £768.08 £346 £1499

6 Bedroom £138.60 £600.60 £0.00 £0.00 No data No data

All £104.83 £454.26 £128.48 £556.75 £242 £1047

5.4.8 Based on the median incomes for workplace earnings in Bedford, an individual seeking to rent

a 1-bed property in the private rented sector would be spending approximately 32% of their

take home pay on rent, excluding any other associated household bills and commitments such

as utilities, or council tax. For affordable rent, this would equate to approximately 23%.

Rents in shared houses

5.4.9 There are differing eligibility requirements for affordable rented products due to restrictions on

21 Source: SDR 2018 22 From: https://www.home.co.uk/for_rent/bedford/current_rents?location=bedford (09/08/2019)

https://www.home.co.uk/for_rent/bedford/current_rents?location=bedford


42

assistance with housing costs. To compare the costs (above), current rental prices for rooms in

shared homes across the study area were taken from online rental agents such as Zoopla and

SpareRoom.com and analysed. On the date the research was undertaken, there were around

200 rooms to let (excluding those rooms where the advert made it clear tenants would be

sharing with the landlord). Several properties had multiple rooms to let. Whilst a snapshot of

the market, these prices are considered to provide a useful comparator to the median prices set

out within the SHMA

5.4.10 Across the study area, average rental for a single room was calculated at approximately

£390pcm, with doubles at an average of £408pcm (this increased slightly where rooms had

an ensuite bathroom). The median rent for a room in a shared house was calculated at

approximately £400 pcm, or the equivalent to a 1-bed social rented property.

5.4.11 This information indicates that a room in a shared house is a more affordable option that a 1-

bed self-contained property. Based on the median annual income, rental in a shared house is

likely to account for 20% of income. Furthermore, many of the shared properties advertised

included household bills such as utilities or the option for these to be split between tenants.

5.4.12 Importantly, and for those investing in property, whilst an affordable option to tenants, it also

demonstrates a property rented by the room is likely generate more rental. E.g. a 3-bed property

rented at £400pcm to each tenant would generate £1,200 v. £815 when rented to a single

household (or an additional £385pcm).

Distribution of PRS housing

5.4.13 Within Bedford, the distribution of PRS stock has been mapped using the ‘hot spot’ tool on the

Local Insight portal. This shows that there are areas within Bedford where, compared to England

as a whole, PRS is within the top 1-5 and 5-10% of areas. The distribution of the rooms available

on the 16th July 2019 is shown overleaf.


43

Figure 14: Private Rented Housing (Hotspot Data)

Figure 15: Rooms in shared houses- Spare Room (16th July 2019)


44

Supressed, shared and concealed households

5.5.1 Shared households can be common. Within Bedford, the SHMA23 seeks to make an adjustment

upwards of 342 homes to account for what is known as supressed household formation. This is

the adjustment that is needed to provide for those in shared housing that may otherwise not

be accounted for in the calculations. In addition to homeless households (those with no fixed

address, which may include informal arrangements with friends and families as well as rough

sleepers) there are two types of supressed households that will contribute to this number:

concealed households and shared households. Shared households will predominantly be housed

within the PRS.

Concealed Households

5.5.2 Concealed households may include couples or lone parents and sharing households. Concealed

Households may choose to live together e.g. as extended families whilst others are forced to

live together due to affordability. In general, concealed families with younger family

representatives are more likely to demonstrate un-met need for housing. Whilst concealed

households have an impact on the overall demand for housing across Bedford and may be

characteristic of a lack of affordable housing choices, they are of less significance to this study

as ‘concealed’ households e.g. those living with their families or another relative would not fall

into the definition of a ‘small HMO’.

Sharing Households

5.5.3 The SHMA reports that the number of sharing households has increased from 181 to 291 over

the 10-year period 2001-2011 - an increase of 110 households or 61%.The number of multi-

adult households has increased from 2,769 to 2,847 over the same period - an increase of 78

(3%). This statistic includes individuals living within HMO accommodation in addition to

individuals living with lodgers.

5.5.4 The growth in multi-adult households is focussed particularly in the Private Rented Sector with

an increase in single persons choosing to live with friends24 or in HMOs. The SHMA indicates

many living in HMOs or with friends are only able to afford shared accommodation (with or

without housing benefit support) and that the changes to housing benefit to cover all single

persons up to 35 years has resulted in many more young people only able to afford shared

23 Opinion Research Services (2018) Bedford Strategic Housing Market Assessment Update 2016 and addendum report. 24 Note: some properties shared with friends would fall into the ‘small HMO’ category where these individuals are not related.


45

accommodation resulting in increased demand for HMOs. The SHMA states,

“There is therefore likely to be a continued (and possibly growing) role for HMOs, with more

of the existing housing stock possibly being converted.”

Housing Quality and Overcrowding

5.6.1 The Decent Homes Standard provides a broad measure which was intended to be a minimum

standard that all housing should meet, and that to do so should be easy and affordable. In order

to meet the standard a dwelling must achieve all of the following:

• Be above the legal minimum standard for housing (currently the Housing Health and

Safety Rating System, HHSRS); and

• Be in a reasonable state of repair; and

• Have reasonably modern facilities (such as kitchens and bathrooms) and services; and

• Provide a reasonable degree of thermal comfort (effective insulation and efficient

heating).

5.6.2 In general, conditions of homes within Bedford have improved year-on-year (largely due to

energy efficiency initiatives). Notably, the recent housing returns for registered providers

indicates that there were only 2 properties that had failed to meet the required standard in 2018

(from a total stock of 12,085). However, whilst social rented properties are more likely to comply

with the standard, over a quarter of the private rented sector (29.8%) remains non-decent.

5.6.3 The Bedford Housing Strategy Review 2016-2020 highlights vulnerable households (defined by

government in relation to households in receipt of certain benefits) in non-decent dwellings

were estimated to form 31% of private sector households, with the highest concentration in

the private rented sector in the inner area of Bedford where 76.1% of vulnerable households

live in non-decent homes. (Source: House Condition Survey 2011). However, compared to the

national averages, stock in Bedford generally performs better or the same for various ‘hazards’

and the number of properties in ‘disrepair’.

5.6.4 The quality of housing is also measured through the Indices of Deprivation (ID) 2015 Indoors

sub-domain (see Figure 16) and includes the following indicators:

• Houses without central heating: The proportion of houses that do not have central

heating;


46

• Housing in poor condition: The proportion of social and private homes that fail to

meet the Decent Homes standard.

5.6.5 A higher score indicates that an area is experiencing high levels of deprivation e.g. that more

properties are ‘non-decent’. The distribution of these homes is shown mapped in Figure 16.

Figure 16: Index of Multiple Deprivation Indoor Sub-Domain Score

Overcrowding

5.6.6 Overcrowding can be linked to issues of amenity. Where there are two or more residents, the

ONSs assume that they will require a minimum of two common rooms plus one bedroom for:

• each couple (as determined by the relationship question)

• each lone parent

• any other person aged 16 or over

• each pair aged 10 to 15 of the same sex

• each pair formed from any other person aged 10 to 15 with a child aged under 10 of

the same sex

• each pair of children aged under 10 remaining

• each remaining person (either aged 10 to 15 or under 10)


47

5.6.7 In Bedford, overcrowding increased from 4,530 to 4,885 households (an increase of 355) over

the 10-year period 2001-11 (growth of 8%) this is significantly lower than comparator

authorities including: Aylesbury Vale (20%), Colchester (32%) and Northampton (43%). It is

also notably lower than the national increase for England (23%). However, in Bedford, the

reduction in overcrowding in owner-occupied housing has offset the increase in the private

rented sector where the number of overcrowded households has increased from 1459 to 2035

or 576 households in 10 years – an increase of 39%. (Source: Bedford Strategic Housing Market

Assessment Update August 2018).

5.6.8 Figure 17, below, maps the areas of Bedford as a proportion of all households living in

overcrowded conditions (both PRS and Owner Occupation).

Figure 17: Overcrowding (Hotspot data)

5.6.9 In addition to the ONS data, there are two legal definitions of overcrowding under the Housing

Act 1985, the space standard and the room standard. If either or both of them apply, the

dwelling will be statutorily overcrowded. The space and room standards apply to any premises

let as a separate dwelling (such as a house, a flat or even just a room if it is let separately from

the rest of the building).


48

5.6.10 The room standard is based on the number and gender of people who must sleep in one room.

The room standard will be contravened in a situation where two people of the opposite sex must

sleep in the same room. The exceptions to this rule are: cohabiting or married couples, who can

live in the same room without causing overcrowding and children under the age of ten, who are

completely ignored in the calculation.

5.6.11 All living rooms and bedrooms are included in the calculation (this could include a large kitchen).

The space standard is based on the number of people who may sleep in a dwelling of a particular

size. The number of people depends on the size of the room, the number of living rooms and

bedrooms in the building and the age of the occupants.

5.6.12 In addition to the above, crowding and space is 1 of the 29 hazards that can be assessed under

part 1 of the Housing Act 2004 using the Housing Health and Safety Rating System (HHSRS).

The HHSRS crowding and space hazard is a far higher standard than that contained within the

Housing Act 1985 and is not solely based on the floor area or room sizes of the dwelling.”

Existing Measures to Manage HMOs

5.7.1 Since 2006, larger HMOs have required a licence prior to being let to tenants. Mandatory

licensing of large HMOs applies nationwide as these properties are considered ‘high risk’

regarding tenant health and safety. It was estimated by the Government that the change in the

October 2018 definition removing the three-storey requirement from the definition of ‘large

HMO’ would bring approximately 160,000 additional HMOs into the mandatory licencing regime.

5.7.2 Some Local Authorities, including Bedford Borough Council, operate a voluntary or ‘Additional’

licencing scheme. The criteria for additional licencing schemes are set by the relevant local

authority and are operated under a discretionary power devolved from Central Government

through section 56 of the Housing Act 2004.

5.7.3 The Bedford Borough Scheme is intended to target higher risk housing that is not classified as

mandatory due to its size andlayout of conversion quality. The BBC Additional HMO Licensing

Scheme was introduced in May 2012 and reviewed again in 2018 following the changes to the

national definition which brought many 2-storey properties that housed 5 or more tenants under

the mandatory scheme. The Bedford scheme also licences self-contained flats (S257 HMOs) to

ensure that these properties are safe.


49

5.7.4 HMO licencing is intended to ensure that properties are safe and have the relevant safety

certificates e.g. gas and electrics, as well as fire alarms and escapes. In addition, licensed HMOs

(where a licence was applied for on or after 1st October) must also ensure that the bedroom

sizes meet the following requirements:

• 6.51 square metres for an adult

• 10.22 square metres for two adults

• 4.64 square metres for a child under 10 years old

5.7.5 Councils may set higher standards through their own licencing scheme.


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6.0 Results

HMO Locations and Types

6.1.1 Using the licensing data, open register and Council tax data, the following section answers the

first two research questions, as identified in the Methodology. These relate to the quantity of

HMO properties, population density, distribution and the type of HMOs presently provided in

Bedford Town and Kempston.

Locations of HMOs

6.1.2 The results show there are a total of 842 HMOs in Bedford Borough, 814 of which are within

the Study area. The remaining 28 are outside of Bedford Town and Kempston Town in locations

such as Clapham, Great Denham, Elstow and Stagsden. Map 1, below, page 50 shows the

geographic spread of the licensed HMO properties within the Study area.

Map 1: Heat Map of HMO Property Locations

6.1.3 The heat map indicates four main ‘hot spots’, these are located; immediately to the south-west

of the town centre, to the north of the Bedford Midland train station, to the south-west of

Bedford Park and nearby to Bedfordshire University’s Polhill Campus. Overall, the majority of


51

the HMO properties are within a 1km radius of a major transport hub, the hospital (a major

employer), or the University, as shown on Map 2, below, page 51.

Map 2: Heat Map of HMO Property Locations and 1 kilometre radius to major hubs

Types of HMOs:

6.1.4 Table 7, below, shows the quantity of HMOs in the study area grouped into two size categories;

‘Smaller HMOs’ where up to 4 residents are permitted to live in the property and ‘Larger HMOs’

where 5 or more residents/2 or more households are permitted to live in the property. These

sizing categories are used as it correlates with Bedford Borough Council’s additional and

mandatory licensing definitions, although these sizes are different to the planning definitions

e.g. a ‘smaller’ HMO being used for up to 6 residents without the need for planning permission.

Table 7: Quantity of HMOs in Bedford Town and Kempston

Smaller HMOs Larger HMOs Total HMOs

562 252 814

6.1.5 The distribution of Smaller and Larger HMOs were mapped respectively to establish if there was

any difference in the patterns. Map 3, below, shows that the general spread of both Smaller

and Larger HMOs are very similar, with the largest clusters being evident around Bedford Town

centre for both sizes of HMOs.


52

Map 3: Distribution of Smaller and Larger HMOs

6.1.6 There are considerably more Smaller HMOs than Larger HMOs, when each category is broken

down by the type of dwelling that is licensed, this indicates that there are a significant number

of flats and bedsits which are classed as Smaller HMOs (Table 8, below, page 52).

Table 8: HMOs by dwelling type

HMO Household Density

6.1.7 In order to understand the density of the population which reside within these HMO properties,

the quantity of HMO ‘households’ have also been analysed. There is a total of 2,478 households

within the total 814 HMO properties. When the households are mapped in the same manner as

Type of Dwelling Smaller HMOs Larger HMOs

Flat in Multiple Occupation 20 0

Flat(s) over the Shop/Premises 10 0

HMO bedsits 181 0

Residential 3 storeys 0 106

Residential 4+ storeys 0 6

Residential Up to 2 storeys 0 140

S257 Converted flats 131 0

Shared House 1 0

Shared House - Private Landlord 118 0

Shared House - University

Scheme

65 0

Sheltered/extra care 1 0

Whole house converted s257 Fla 35 0

Grand Total 562 252


53

the properties, it is evident that there are a greater number of hot spots (Map 4, below, page

53). This is likely due to the more varied disbursement of Larger HMOs which will contain greater

numbers of households.

Map 4: HMO Households Heat Map

Site Visits

6.1.8 Site visits were undertaken in both the ‘hot spot’ areas of households and other areas less

densely occupied, a total of 57 streets were visited. Map 5, below, page 54 shows the site visit

streets.


54

Map 5: Site Visit Street Locations

6.1.9 The results gathered using the site visits pro-forma are outlined in section 6.2. The same streets

were also used for desk-top analysis upon the percentage density of HMO properties and as a

sample set to cross-reference the household numbers against the Open Electoral Register data

as set out in the Methodology.

6.1.10 Table 9 and Table 10, below, show the results of this analysis and cross-referencing exercise.

The maximum percentage of HMOs on any given street was 33%, however the average

percentage was only 6%. When undertaking the cross-referencing exercise, there were 22

potential anomalies identified, specifically 12 streets were thought not to contain HMOs.

However, when reviewing the Open Register these streets did contain HMOs and 10 streets

were thought to contain HMOs which did not. The analysis section of this report details why

these anomalies may exist.

Table 9: Percentage of HMOs on Site Visit Streets

Street Name Total Number of

Properties

Quantity of HMO

Properties

Percentage of HMO

Properties on Street (%)

Alexandra Road 107 16 15

Ampthill Road 243 20 8

Ashburnham Road 201 12 6

Aspley Road 42 5 12

Balliol Road 74 3 4


55

Barnstaple Road 30 0 0

Battison Street 36 0 0

Cater Street 39 0 0

Champion Way 6 0 0

Churchville Road 28 2 7

Clovelly Way 34 5 15

College Road 53 0 0

Conduit Road 264 8 3

Coventry Road 98 2 2

Dawlish Drive 47 1 2

De Parys Avenue 197 8 4

Dunville Road 55 0 0

Eastville Road 32 1 3

Edward Road 64 3 5

Eugster Avenue 29 2 7

Foster Hill Road 210 20 10

Foster Road 131 1 1

Galloway Close 30 0 0

Gibbons Road 19 0 0

Goldington Road 378 33 9

Grafton Road 58 15 26

Gratton Road 54 0 0

Hartland Avenue 25 7 28

Hillgrounds Road 114 0 0

Hurst Grove 275 12 4

Kempston Road 48 5 10

Kimbolton Road 239 8 3

King Street 86 2 2

Mabel Road 39 4 10

Manor Road 40 0 0

Margetts Road 137 1 1

Midland Road 119 9 8

Moulder Close 14 0 0

Muswell Road 37 0 0

Ouse Road 19 0 0

Park Avenue 90 3 3

Pattern Close 16 2 13

Pemberley Avenue 45 0 0

Penlee Close 31 2 6

Portland Close 55 2 4

Prebend Street 154 14 9

Preston Road 43 3 7


56

Queen’s Drive 231 1 0

Rutland Road 35 9 26

Salcombe Close 30 9 30

Savannah Close 18 6 33

Silverdale Street 60 1 2

Southville Road 55 2 4

St Andrews Road 103 4 4

St Michael’s Road 166 13 8

Tiverton Road 38 0 0

Victoria Road 179 10 6

Table 10: Open Register Cross Referencing with Licencing Data

Street Name Identified as likely to have

HMOs properties (Y/N)

through Open Register

Identified as

having licensed

HMO properties

(Y/N)

Notes made while

reviewing Open Register

Alexandra Road Y Y Lots of converted flats are identifiable – not

necessarily all HMOs

Ampthill Road Y Y

Ashburnham Road Y Y Lots of flats

Aspley Road Y Y

Balliol Road N Y

Barnstaple Road Y N

Battison Street N N

Cater Street N/A N No data

Champion Way N N

Churchville Road N Y

Clovelly Way N Y

College Road Y N

Conduit Road Y Y Lots of flats

Coventry Road Y Y

Dawlish Drive Y Y

De Parys Avenue Y Y Mixture of flats and residential institutions

Dunville Road Y N

Eastville Road Y Y

Edward Road Y Y

Eugster Avenue N Y

Foster Hill Road Y Y Mixture of flats and residential institutions

Foster Road N/A Y No data

Galloway Close Y N

Gibbons Road Y N


57

Goldington Road Y Y Lower than anticipated

Grafton Road Y Y

Gratton Road Y N

Hartland Avenue Y Y

Hillgrounds Road Y N

Hurst Grove Y Y

Kempston Road N Y

Kimbolton Road Y Y Mixture of flats and residential institutions

King Street Y Y

Mabel Road N Y

Manor Road Y N

Margetts Road N/A Y No data

Midland Road Y Y

Moulder Close N N

Muswell Road Y N

Ouse Road N N

Park Avenue N Y

Pattern Close N Y

Pemberley Avenue N N

Penlee Close N Y

Portland Close N Y

Prebend Street Y Y

Preston Road Y Y

Queen’s Drive N Y

Rutland Road Y Y

Salcombe Close N Y

Savannah Close N/A Y No data

Silverdale Street N/A Y No data

Southville Road Y Y

St Andrews Road Y Y Mixture of flats and

residential institutions

St Michael’s Road Y Y Lots of flats

Tiverton Road Y N

Victoria Road Y Y


58

Visual Character and Environmental Complaints

6.2.1 This section provides results to answer research questions 3 and 4;


the area?


Site Visits and Conservation Area Appraisals

6.2.2 The site visits undertaken used a proforma to assess each street for whether there was evidence

of alterations to visual character and potential environmental issues. The indicators were as

follows;

1. Fly-tipping

2. Large quantity of bins

3. Litter

4. Daytime noise

5. Multiple letting signs

6. Multiple satellite dishes

7. Untended front gardens

8. Visible decay to properties

9. Multiple letter boxes and/or doorbells

10. Increased presence of off-licences/takeaways/lettings agents

11. Car parking causing amenity issues

12. Car parking causing safety issues

6.2.3 Where evidence of these impacts was noted, a log was made as to whether this was in

association with an HMO or not. A summary of the information collected is shown in Table 11,

below, page 59.


59

Table 11: Presence of Environmental and Character Impact Indicators at HMOs and Non-HMOs

Key

Presence at HMOs

Presence at Non-HMOs

Presence at both HMOs and Non-HMOs

No presence

Street Name 1 2 3 4 5 6 7 8 9 10 11 12

Alexandra Road

Ampthill Road

Ashburnham Road

Aspley Road

Balliol Road

Barnstaple Road

Battison Street

Cater Street

Champion Way

Churchville Road

Clovelly Way

College Road

Conduit Road

Coventry Road

Dawlish Drive

De Parys Avenue

Dunville Road

Eastville Road

Edward Road

Eugster Avenue

Foster Hill Road

Foster Road

Galloway Close

Gibbons Road

Goldington Road

Grafton Road

Gratton Road

Hartland Avenue

Hillgrounds Road

Hurst Grove

Kempston Road

Kimbolton Road

King Street

Mabel Road


60

Manor Road

Margetts Road

Midland Road

Moulder Close

Muswell Road

Ouse Road

Park Avenue

Pattern Close

Pemberley Avenue

Penlee Close

Portland Close

Prebend Street

Preston Road

Queen’s Drive

Rutland Road

Salcombe Close

Savannah Close

Silverdale Street

Southville Road

St Andrews Road

St Michael’s Road

Tiverton Road

Victoria Road

6.2.4 Overall, Table 11, above, shows that there were 110 records of environmental and visual

character indicators across the 57 streets. Out of these records, 42 related to both HMOs and

non-HMOs, 24 related solely to HMOs and 44 related solely to non-HMOs.

6.2.5 The Conservation Area Appraisal highlights that the character of residential occupation appears

to be changing across much of the area from single family occupation to flats. In addition,

several buildings have been adapted for educational use (either as boarding houses or teaching

accommodation) or have been converted to rest homes, to medical use or (towards the south

end of Kimbolton Road) to offices.

6.2.6 The CAA indicates that this has “clear implications for the character of the area and its

architectural and visual integrity. The loss of historic fabric and details, such as timber sliding

sash windows, is evident, along with inappropriate ‘maintenance’, including the painting of stone

dressings. So too is the creation of on-site car parking space or garaging either by the creation

of forecourts in place of enclosed front gardens or by the conversion of complete rear gardens

to car parks. In several locations ranks of wheelie bins bear testimony to flat conversions.”


61

6.2.7 Part or all of 9 of the streets are located within the Conservation Area, this equates to 15% of

the street visits. On these streets the site visits recorded 28 character and environment impact

indicators, equating to 25% of the total records. Of these records, 12 related to both HMOs and

non-HMOs, 10 related to just HMOs and 6 related to just non-HMOs.

Noise, Waste and Pests

6.2.8 Turning to the quantitative data in respect of environmental complaints, the following maps

illustrate the geographic distribution of noise, waste and pest complaints independently and

then as a collective. This data is collected on a borough-wide basis; therefore, the maps do

extend beyond the study area.

6.2.9 Map 6, below, illustrates the spatial distribution of waste complaints. The types of complaints

relate to; fly tipping, build-up of rubbish bags and bins and untended gardens. In total there

were 1,498 waste complaints across the Borough between 2014 and 2018. Of these complaints

321 were reported with no address, the majority of those that provided a postcode were logged

within MK42 9, MK40 1, MK42 0 and MK40 4. These areas are located surrounding the Town

Centre, extending along Ampthill Road and towards the west of Bedford.

Map 6: Waste Complaints Heat Map with Postcode Boundaries


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6.2.10 Considerably more pest complaints were made in the period 2014 to 2018 than waste

complaints, with 6,412 in total, all of which provided postcodes. The pests logged include; ants,

bed bugs, bees, cockroaches, fleas, flies, mice, mites, pharaoh ants, pigeons, rats and wasps.

Of these wasps, rats and bees are the most reported, these are also subdivided into internal,

external and high priority categories.

6.2.11 The spatial distribution of the pest complaints does not highlight many hotspots, withl a much

more even spread across the Borough (Map 7, below, page 62). The key identifiable hotspot is

located between MK40 2 and MK40 3, to the east of the Town Centre. The majority of the

complaints within these two postcode areas relate to external and internal sightings of rats.

Map 7: Pest Complaints Heat Map with Postcode Boundaries

6.2.12 The noise complaints data ranges between 2016 and 2019 due to availability of information,

1,876 complaints (that were not related to commercial businesses) were collected during this

period. Table 12, below, demonstrates the types and amounts of complaints received.


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Table 12: Types of Noise Complaints

Map 8: Noise Complaints Heat Map with Postcode Boundaries

Type of Noise Complaint Total

Alarm 58

Animals/Birds(Not dog) 34

Barking Dog 297

DIY 54

Fireworks 4

Low frequency 5

Machinery (fixed and mobile) 179

Music 529

Party 98

People 445

Shooting 12

TV/Radio 23

Unidentified/other 75

Vehicle repairs 14

Vehicles 49


64

6.2.13 Map 8, above, shows one dominant hot spot of noise complaints and a series of smaller and

less defined hot areas. The main hot spot is located upon the boundary of MK40 1 and MK40 3

in close proximity to the Town Centre, the other hot areas are located near to Ampthill Road,

within the remainder of the MK40 1 area and within MK40 2 also.

6.2.14 Once the waste, pest and noise complaints are combined to form the wider environmental

complaints, the results of this compilation are shown in Map 9, below. There is now a single

central hotspot evident at the border of MK40 1 and MK40 3 to the east of the Town Centre.

Patches of hot areas are spread across; MK40 1, MK40 2, MK40 3, the north of MK42 9 and the

south east of MK40 4.

6.2.15 When the environmental complaints heat map is compared to the HMO properties heat map,

there is evidently some similarities between the geographic patterns (Map 10, below, page 65).

In order to test the strength of this pattern a correlation analysis has been undertaken using

the site visit streets as a sample. Chart 1, below, shows that there is a correlation between the

number of HMOs on a street and the number of environmental complaints on that street. This

correlation is moderate with an R value of 0.523907, where 1 is the measure of the strongest

correlation.

6.2.16 When expanding the correlation analysis to all streets with environmental complaints, the R

value is even lower at 0.467026, demonstrating a slightly weaker correlation (Chart 2, below).

Notably this is excluding two outliers which distorted the data (High Street, 311 complaints, 0

HMOs and Bedford Road, 119 complaints and 0 HMOs).


65

Map 9: Environmental Complaints Map with Postcode Boundaries

Map 10: HMO Properties Heat Map with Postcode Boundaries


66

Chart 1: Environmental Complaints Correlation Chart for Site Visit Streets

Chart 2: Environmental Complaints Correlation Chart Across All Streets with Complaints Reports

0

5

10

15

20

25

30

35

0 10 20 30 40 50 60 70 80 90

Quantity

of

HM

Os

Environmental Complaints

Correlation Chart of Environmental Complaints and Number of HMO Properties on Site Visit Streets

-5

0

5

10

15

20

25

30

35

0 10 20 30 40 50 60 70 80 90

Quantity

of

HM

Os

Environmental Complaints

Correlation Chart of Environmental Complaints and Number of HMO Properties on All Streets


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Anti-Social Behaviour and Crime

6.3.1 In order to ascertain any potential safety implications of the concentration of HMOs, the

correlation of anti-social behaviour (ASB) data and crime reports with HMO property locations

have been tested respectively.

6.3.2 The ASB data has been collected from Bedford Borough Council’s own recorded incidents and

those recorded by Bedfordshire Police from 2016 to 2018, providing a total of 657 reports. These

include incidents related to; criminal damage, drug use and supply, drunken behaviour, loutish

behaviour, noise, threatening behaviour and vehicle related nuisance. 129 reports lie outside

these categories and are noted as ‘other’, the most dominant category is loutish behaviour with

195 reported incidences.

6.3.3 Map 11, below, illustrates a clear hot spot of ASB records in the MK40 1 postcode area which

includes the Town Centre. Second to this hot spot is another area of heat around Ampthill Road,

the remainder of the reports appear to be reasonably evenly spread.

6.3.4 As with the environmental data, the ASB data has been correlated against the quantity of HMOs

on the site visit streets and subsequently all streets with ASB reports. Chart 3, below, page 68

shows that there is a correlation between the number of HMOs on a street and the number of

ASB reports on that street. This correlation is relatively weak with an R value of 0.280852 where

1 is the measure of the strongest correlation. When expanding the correlation analysis to all

streets with ASB reports, the R value is higher at 0.384637, demonstrating a slightly stronger

correlation (Chart 4, below).


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Map 11: ASB Reports Heat Map with Postcode Boundaries

Chart 3: ASB Reports Correlation Chart Across Site Visit Streets

0

5

10

15

20

25

30

35

0 2 4 6 8 10 12

Quantity

of

HM

Os

ASB Reports

Correlation Chart of ASB Reports and Number of HMO Properties on Site Visit

Streets


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Chart 4: ASB Reports Correlation Chart Across All Streets with Reports

6.3.5 The crime data has been collected from Bedfordshire Police reported incidents from 2016 to

2018, providing a total of 33,109 reports. These include incidents related to; arson, burglary,

criminal damage, possession of drugs or weapons, sexual offences, shoplifting, vehicle offences

and violence with or without injury. The most dominant category is violence without injury

(5,581 reports), followed by vehicle offences (3,926 reports), criminal damage (3,704 reports)

and violence with injury (3,472 reports).

6.3.6 Map 12, below illustrates that the majority of the crime reports are within the MK40 1 postcode

area where there is an evident hot spot. A series of other hotter areas are identified including

Ampthill Road and near to the university campus, indicating a potential relationship between

HMO concentrations and reported crimes.

6.3.7 When correlated against the quantity of HMOs on the site visit streets and subsequently all

streets with crime reports, moderate correlations of 0.506366 and 0.40749 respectively. Chart

5 and Chart 6 show the trendlines, which again illustrate the moderate correlation between

streets with a presence of HMOs and reported crimes.

0

5

10

15

20

25

0 2 4 6 8 10 12 14 16

Quantity

of

HM

Os

ASB Reports

Correlation Chart of ASB Reports and Number of HMO Properties on All Streets


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Map 12: Crime Reports Heat Map with Postcode Boundaries

Chart 5: Crime Reports Correlation Chart Across Site Visit Streets

0

200

400

600

800

1000

1200

0 5 10 15 20 25 30 35

Crim

e R

eport

s

HMO Properties

Correlation Chart of Crime Reports and Number of HMO Properties on Site Visit

Streets


71

Chart 6: Crime Reports Correlation Chart Across All Streets with Reports

Planning Data

6.4.1 Utilising the planning data from Bedford Borough Council the following table has been used to

show the quantity of planning applications, enforcement cases and appeals that the Council

have dealt with across the last five years.

Table 13: Summary of planning data

Year Planning

Applications for

change of use to

large HMO

Planning Applications

for change from HMO

to another use

Enforcement

Cases

Planning

Appeals

2014 1 1 3 0

2015 0 0 3 1

2016 1 0 2 1

2017 8 1 9 2

2018 5 0 9 0

2019 1 0 1 2

Total 16 2 27 6

0

200

400

600

800

1000

1200

1400

1600

1800

0 5 10 15 20 25 30 35

Crim

e R

eport

s

HMO Properties

Correlation Chart of Crime Reports and Number of HMO Properties on All Streets


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6.4.2 Table 13, above, shows that there has been an increase in; planning applications for large

HMOs, enforcement cases and appeals across the last five years. There has also been a decrease

in planning applications for changing existing HMOs into other uses including family

accommodation.

Taking each of these elements of the planning data in turn, a series of summary tables of the outcomes of the application, enforcement cases and appeals are shown below (Table 14,

6.4.3 Table 15, and Table 16, all below).

Table 14: Summary of planning applications related to HMOs

Year Reference

Number

Planning

Application

Type

Description Decision

2014 14/01901/COU Change of

use

Change of use from house in multiple

occupancy (HMO) to Children's Home (C2)

Returned

2014 14/02911/S73A Retrospective

change of use

application

Change of use from single dwelling house (C3)

to house in multiple occupancy (HMO) (C4)

Approved

2016 16/03032/FUL Full planning application

Single storey rear extension, removal of external steel staircase, replacement windows,

provision of parking to front, provision of

photo-voltaic roof panels to rear roof slope, internal alterations to provide 9 living rooms

under the HMO.

Approved

2017 17/00183/MAF Full planning application

and change of use

Conversion and change of use from HMO (C4) to Residential (C3), demolition of bungalow

and garage and erection of rear extension and coach house to form 13 apartments.

Approved


use

Conversion of 3 storey dwelling (C3) to 11

bedroom House in Multiple Occupancy (HMO) (Sui-Generis)

Refused


change of use

application

Retention of six-bedroom House in Multiple

Occupation (HMO) (C4) and two bed flat to rear (C3).

Approved

2017 17/01438/FUL Full planning

application

and change of use

Change of use from HMO (Class C4) to House

in Multiple Occupancy (Sui-Generis) for up to

10 persons

Returned


change of use

application

Subdivision of HMO to form 2 separate units

comprising of a 6 bedroom HMO and a separate one bedroom dwelling (development

already carried out).

Approved


use

Change of use from a HMO for up to 6 people

(Use class C4) to a HMO for 7 people (Sui

Generis)

Refused


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use

Change of use from HMO (Class C4) to House

in Multiple Occupancy (Sui-Generis) for 8

persons.

Approved


use

Subdivision of HMO for 9 people to form 1 self-

contained flat and HMO for 7 people.

Approved

2017 17/03577/S73A Retrospective change of

use

application

Conversion and alterations to garage to form 3 additional bedrooms and kitchen and change

of use of 6 bed HMO (C4) to 9 bed HMO (Sui

Generis) (Development already carried out).

Refused

2018 18/00302/LDE Change of

use

Use of premises as House in Multiple

Occupation (HMO)

Approved

2018 18/00549/COU Change of use

Change of use from a residential dwellinghouse (C3) to a House in Multiple Occupation (HMO)

with 9 bedrooms (Sui Generis)

Withdrawn

2018 18/01210/S73A Retrospective change of

use application

Conversion and alterations to garage to form 2 additional bedrooms, kitchen, shower room

and living room and change of use of 6 bed HMO (C4) to 8 bed HMO (Sui Generis)

(Development already partially carried out).

Approved

2018 18/02309/FUL Full planning application

Single storey rear extension, garage conversion, loft conversion and external

alterations to existing 5 bedroom HMO (C4) to create an 8 bedroom HMO (Sui-Generis)

Refused

2018 18/02728/FUL Full planning

application

Single storey rear extension forming 7

bedroom HMO, following removal of function hall.

Refused


use

Change Of Use Of 6 Bed HMO (C4) To 7 Bed

HMO (Sui Generis)

Refused -

Appeal dismissed

Table 15: Summary of enforcement cases related to HMOs

Year Description Outcome

2014 Being used as a large HMO, with one separate flat Closed

2014 Use of private members club as a HMO Closed

2014 Property being used as HMO - approximately 11 residents at address. Closed

2015 Property let as HMO, could contravene planning consent. Closed

2015 Property being converted into 8 bedsits (HMO) Closed

2015 MCOU from B1 (offices) to mixed use Sui Generis comprised of Studio Flats and HMO rooms.

Application submitted

2016 Property now used as HMO. Closed

2016 Use of ancillary restaurant for a large HMO. Closed

2017 Use of property as HMO. Closed

2017 Large HMO 11 residents 2015/04/07 Notice

issued

2017 Property being occupied as a HMO by 10 people. Closed

2017 Possible use as HMO Closed

2017 Use of flat 4 as a 7 bedroom HMO. Closed

2017 Extension to property and use of property as HMO. Closed

2017 Converting property to HMO Closed


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2017 Alterations to roof and loft conversion. Possible HMO use Closed

2017 The property consists of 9 HMO bedsit rooms, only has a licence for 6. Pending

2018 Conversion from HMO to flats Pending

2018 Creation of separate dwellings in garage. House possible being used as

HMO.

Pending

2018 Property being used as an HMO. Pending

2018 Alleged HMO - 7 bedrooms and 1 self-contained flat. Pending

2018 Conversion to mixed HMO and residential flat development Notice issued

2018 Property being used as a HMO Closed

2018 Erection of garage. House and garage being used as a HMO. Closed

2018 Property being used as a HMO Closed

2018 Change of use to HMO, dormer and side extension and loft conversion Pending

2019 Property being used as a HMO and internal alterations. Pending

Table 16: Summary of planning appeals related to HMOs

Year Reference

Number

Appeal Type Description Decision

2015 15/00022/REF Written

Representations

Change of use of dwelling house (C3) to

house in multiple occupation (C4) - six persons.

Dismissed

2016 16/00034/REF Written Representations

Change of use of a 6-bed House of Multiple Occupation (C4) to a 7-bed

House of Multiple Occupation (Sui

Generis).

Allowed

2017 17/00038/REF Written

Representations

Change of use to form a House in

Multiple Occupation with 12 letting

rooms. Formation of on-site car parking at rear and associated external works

(development already carried out).

Dismissed

2017 17/00066/ENFNOT Written

Representation

Without planning permission, the

material change of use of Land from a

(Class C3) dwelling to a large House in Multiple Occupation (sui generis) and

associated works.

Dismissed

2019 19/00003/REF Written Representation

Demolition of conservatory and Change of use to form a House in Multiple

Occupation with 11 letting rooms. Formation of on site car parking at rear

and associated external works

Dismissed

2019 19/00029/8WEEK Written Representation

Change Of Use Of 6 Bed HMO (C4) To 7 Bed HMO (Sui Generis)

Dismissed

Focus Groups and Public Consultation

6.5.1 As noted in the methodology two main consultation methods have been used in this Study to

collect qualitative data primarily on how the local community perceive and experience HMOs.

The results of the focus group and drop-in session are noted as follows.


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Focus Groups

6.5.2 The focus groups took place on 24th June 2019, Focus Group C for the Community

Representatives, Residents Groups and Elected Members was attended by 7 people, the other

focus groups had no attendees.

6.5.3 The session began with the presentation from Eleanor Gingell, Principal Planner at WYG, this

explained first and foremost that the study is focussed on planning and the mechanisms that

planning can control. During and following the presentation, the floor was opened up to

questions and comments, a summary of which is provided in Table 17, below, page 75.

Table 17: Focus Group Questions and Comments

Questions Asked Comments Received

Would an Article 4 direction mean that HMOs

could convert back to family homes? There is a

desire to try and convert HMOs back to family

housing, particularly to cater for multi-

generational families and larger families.

Landlords may like the fact that the price of

already existing HMOs may rise once the Article

4 transition period is over, as it will make them

rarer/more desirable, somewhat closing the

market off.

In the context of understanding the potential

risk of additional properties converting to HMOs

in the 12 month transition period that would

follow the making of any non-immediate Article

4 direction. The question was raised about

whether other authorities had received a

significant increase in HMO’s in this transition

period or if they were all at saturation point

prior to the Article 4 coming into effect anyway?

The Lansdowne road area is particularly

interesting because it used to have a lot of

student accommodation/HMOs but since the

university moved, the student tenants have left.

Quite a few of the properties are now back to

family homes and some are still HMOs but with

other users. It shows how a change in

circumstances can change an area. There was

also some previous work/research done by the

ward for the Poet’s area relating to HMOs

although this may not be relevant/out of date.

Would the study be applied across the whole

borough, whole urban area or specific areas? Is

there a chance that areas that are being

negatively impacted by HMOs would lose out

because the whole borough isn’t being

negatively impacted?

Would we be looking into selective licensing?

Would pre-application charging and planning

application fees be applicable to future

applications for change of use to a HMO, if an

Article 4 direction was made?

How are you going to get landlords/agents to

support an Article 4 direction if it is going to make

it harder and more expensive to convert

properties to HMOs?


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How is the study looking at occupant numbers?

Particularly trying to establish size of households.

Does this study incorporate the 16-18 care

homes, care homes for vulnerable people?

6.5.4 The discussion session, using maps and images as aids then began, with the following topics

covered; perceptions of HMOs, concerns relating to HMOs, and what would the attendees like

an Article 4 direction to achieve if it were implemented, including how it might change areas

Table 18, below.

Table 18: Focus Groups Discussion Session Responses

Perceptions of HMOs and

residents

Concerns relating to HMOs

Future of integrating and

controlling HMOs (what

would ‘good’ look like?)

Bedsits/one room dwellings Parking Trying to achieve balance in the community

Residents are young males

(unemployed)

Pressure on facilities

(particularly rubbish collection)

Fewer back gardens being

tarmacked over for parking and loss of habitat/trees/gardens

Young professionals and

students

Fly tipping Incorporating principles of

planning out crime in street design

Victorian terraced streets have

more

High concentrations (an

unbalanced community)

Additional open areas

Recent migrants Concentration of noise

problems (internal or

gatherings outside HMOs). Noise across all hours because

of ‘different timetables’

Query about can

conditions/restrictions be

places on occupant numbers

Large variation in who lives in

HMOs

Complaints not consistent

across different areas –

possibly due to reporting being less common or people not

knowing how/what to do

Robust guidance to assistance

the determination of

applications

Vulnerable people (complication as to whether

this is C2 use)

Difficult to communicate with residents of HMOs, they don’t

always have individual letterboxes

Reduction of other high density housing stock, it’s not just

HMOs

There were concerns relating

to families living in single rooms – this was thought to be

increasing

Crime concerns (increased

closure orders)

Protection for Victorian and

Edwardian buildings

State of repair Additional services – more GPs

Fewer takeaways

Restriction on cars (although

understood this is difficult to enforce beyond CPZs)

A feeling of more control

Avoiding HMO saturation


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Public Consultation Drop-In

6.5.5 22 individuals attended the drop in at Bedford Borough Council on the 4th July. As part of the

sign-in process, individuals were asked to provide their postcode. Map 13, below, page 77 shows

the locations of those attending.

Map 13: Drop-in Attendees Map

6.5.6 Of those that attended some questions were asked about HMOs and the emerging data.

• All attendees agreed that the mapped concentration of HMOs corresponded to their

perception.

• Of those that responded 13 agreed that the mapped areas of waste complaints

corresponded to their perception. 3 respondents identified additional areas where they

thought there were waste issues/ fly tipping.

6.5.7 HMOs were most associated with:

• Loss of character (22)

• Poor Maintenance (22)


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• Waste/ rubbish (21)

• Overcrowding (19)

• Noise (19)

6.5.8 Only 10 attendees associated HMOs with affordable housing and 3 with flexible accommodation.

6.5.9 Whilst the instructions were to provide feedback on terms they associated within HMOs, the

term ‘safe’ generated discussion during the drop in with attendees unsure if they were being

asked to comment if a property was ‘safe’ or ‘unsafe’. This has therefore been excluded from

the results.

6.5.10 Of 10 feedback forms received:

• 7 were completed by residents who live in Bedford

• 2 were completed by members elected to Bedford Borough Council

• 2 were completed by representatives of resident’s associations (community

representatives)

• 1 was completed by a resident of a HMO


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7.0 Discussion and Evaluation

7.1.1 The use of Article 4 directions should be limited to situations where it is necessary to protect

local amenity or the wellbeing of the area. The potential harm that the direction is intended to

address must be clearly identified.

7.1.2 The results section details three key areas that have been investigated as part of this study:

• Character and Environment

• Anti-Social Behaviour and Crime

• Existing planning controls.

7.1.3 The following sections take each of the key areas in turn and analyses whether the results

provide evidence to support the making of an Article 4 Direction or not. In addition, it is

acknowledged that a range of concerns were raised which cannot be dealt with via the planning

system.

Visual Character and Environmental Complaints

7.2.1 The results show there are a total of 842 HMOs in Bedford Borough, 814 of which are within

the Study area. Whilst this number does not represent a particularly high percentage of stock,

our analysis does show that these are disproportionately concentrated in particular areas of the

town and in areas of higher density development.

7.2.2 Overall, the majority of the HMO properties are within a 1km radius of a major transport hub,

the hospital (a major employer), or the University, as shown on Map 2.

7.2.3 In areas where the community representative focus group reported greater issues related to

HMOs, there appears to be a slightly higher concentration of larger HMOs (e.g. over 6 persons

and therefore in sui generis use which currently requires planning permission). However, the

Local Insight and electoral data also showed that in these areas there were often significantly

more properties that had been converted to flats (Figure 7). This makes it challenging to

understand if the issues are solely related to HMOs or are more characteristic of a high

population density (as discussed in paragraphs 5.2.3 to 5.2.7).

7.2.4 One of the potential issues with converted flats is the extent to which these are then able to be

sub-divided into small HMOs without the need for planning permission. If each converted flat is

then let as a ‘small’ HMO (over which the council has no control) this is likely to lead to a


80

significant increase in population. The focus group and drop-in session suggested that this was

a significant area of concern, whereby landlords/developers could effectively bypass the

necessity for planning permission to create a large HMO by converting flats into a series of small

HMOs in a single building ultimately having the same number of occupants as a large HMO.

7.2.5 The licensing data revealed that 166 of 562 licenced small HMOs are converted flats, with 35 of

these being whole houses that have been converted to flats and subsequently are ALL used as

small HMOs. However, at present there is no breach of planning rules in undertaking this type

of conversion. An Article 4 direction would require a planning application to be submitted for all

small HMOs including those to be converted from flats, thus supporting the proper planning of

the area. While planning conditions could be used to prevent the conversion of flats for which

planning permission has not been yet granted, the only mechanism to control the conversion of

existing flats to small HMOs would be an Article 4 Direction.

7.2.6 The 57 streets selected as a sample for analysis are from both ‘hot spot’ areas of households

and other areas less densely occupied with HMOs. The percentage of HMOs on each of these

streets was calculated to assess the degree to which the whole street may be impacted by

HMOs.

7.2.7 Map 14, below, on page 81 illustrates that most of the streets are with the 0-5% and 6-10%

brackets, however there is an identifiable cluster of streets to the west of the town centre where

there are 26-30% HMOs. This cluster is an area identified at the focus group and drop in session

where there had been concerns about the impact of HMOs. The single outlier in Kempston with

33% HMOs appears to be an anomaly and is not within an area where issues had been raised.


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Map 14: Percentages of HMOs on Site Visit Streets

7.2.8 In terms of smaller HMOs (as defined by licensing for mapping purposes), these tend to be

relatively scattered although their location remains related to the identified transport, education

and employment radii. Where there are concentrations of smaller HMOs, this is likely to be a

result of the type of stock available within these areas i.e. 2 to 3 bed terraces or subdivided

larger Victorian/Edwardian properties.

7.2.9 The site visits showed that there were 110 records of environmental or visual character issue

indicators across the 57 streets. Of these records, 42 related to both HMOs and non-HMOs, 24

related solely to HMOs and 44 related solely to non-HMOs. 18 of the recorded

character/environment issues were logged on roads where no HMO properties were located.

7.2.10 Taking a look at the streets where there are 26-30% HMOs and how many visual character and

environment indicators were present, there is some evidence that HMOs are having an impact.

Using Grafton Road as an example, where there is 26% HMOs, there were 3 indicators of visual

character and environment issues that were identified at known HMOs. However, comparing

this to the neighbouring Rutland Road, although 4 visual character and environment issues were

present, only one was recorded just at a known HMO.

7.2.11 This illustrates that many of the environmental and visual character related issues are evident


82

at both types of properties within these areas and that therefore these issues cannot be solely

attributed to the presence of HMOs. However, there are instances where HMOs alone are

causing character and environment issues, therefore the use of an Article 4 to control the

location and distribution of HMOs would assist with mitigating these impacts.

7.2.12 As noted within the Bedford Conservation Area Appraisal (CAA), the character of residential

occupation appears to be changing (or has changed) across significant parts of the area from

single family occupation to flats. In addition, several buildings have been adapted for

educational use (either as boarding houses or teaching accommodation) or have been converted

to rest homes, to medical use or (towards the south end of Kimbolton Road) to offices.

7.2.13 The CAA indicates that this has “clear implications for the character of the area and its

architectural and visual integrity. The loss of historic fabric and details, such as timber sliding

sash windows, is evident, along with inappropriate ‘maintenance’, including the painting of stone

dressings. So too is the creation of on-site car parking space or garaging either by the creation

of forecourts in place of enclosed front gardens or by the conversion of complete rear gardens

to car parks. In several locations ranks of wheelie bins bear testimony to flat conversions.”

7.2.14 During our site visits we visited 9 streets that are either partially or completely within the

Conservation Area. In general, these properties exhibited fewer character changes and as such

externally it was less apparent which were HMOs and which were not.

7.2.15 This may indicate that the additional planning controls in Conservation Areas can result in fewer

harmful visual impacts arising from changes of use to HMO. However, fundamentally,

designation as a Conservation Area does not alter permitted development rights in relation to

changes from C3 to C4 use so there remains a risk of harmful impacts as a result of the limited

control over a change of use to HMO. Therefore, in both Conservation Areas and outside of

them, there is an opportunity to implement an appropriate way to manage the proper planning

of an area and to achieve balance in the character of residential occupation.

7.2.16 The distribution of waste and noise complaints show concentrations around the town centre,

which is to be expected and does not illustrate a conclusive relationship between HMOs and

waste and noise complaints. The area around Ampthill Road is, however, a slight outlier and

indicates a possible link between HMOs and waste and noise complaints. The distribution of

pest reports does not show any conclusive link between pests and HMOs.

7.2.17 There is a moderate correlation between environmental complaints and HMO concentrations.

Whilst there are issues and these are acknowledged, they would not, in themselves, justify


83

making an Article 4 direction though they should be taken into account in terms of them having

a cumulative impact.

7.2.18 Overall, while the issues raised in relation to visual character and environment are not wholly

attributable to HMOs, there is considerable evidence that HMOs are causing harm and the

making of an Article 4 Direction would assist the Council is exercising greater control over certain

issues. For example, waste storage plans could be required to accompany HMO planning

applications where currently there is only very limited control over that.

Crime and Anti-social Behaviour

7.3.1 The distribution of anti-social behaviour records shows concentrations around the town centre,

which, again, is to be expected and does not illustrate a conclusive relationship between HMOs

and ASB records. The one exception is the area around Ampthill Road which is a slight outlier

and does indicate a possible link between HMOs and ASB records.

7.3.2 There is a moderate correlation overall between the crimes reported and HMO concentrations.

The majority of the crime reports are within the MK40 1 postcode area where there is an evident

hot spot, as it is the town centre which appears to be heavily influencing the results and

therefore it is not possible to demonstrate a conclusive relationship between the two A series of

other hotter areas are identified including Ampthill Road and near to the university campus,

indicating a potential relationship between HMO concentrations and reported crimes.

7.3.3 This ASB and Crime data cannot provide a strong link between HMOs and reports, however

areas of the town with a higher population density overall do appear to show increased reports.

An Article 4 direction will be unlikely to provide any discernible change in ASB and Crime

patterns, although it would provide the Council with a way to manage population density

increases to an extent.

Planning Controls

7.4.1 There has been an increase in; planning applications for large HMOs, enforcement cases and

appeals across the last five years. There has also been a decrease in planning applications for

changing existing HMOs into other uses including family accommodation.

7.4.2 There is no evidence that the Council are failing to react to issues with HMOs but there has

been an increase in the need to do so across the last 5 years. They have responded and closed

18 enforcement cases, are pursuing 9 enforcement cases and have won 5 out of 6 appeals


84

related to HMOs in the last 5 years.

7.4.3 In addition, the research has found that there are a number of other concerns that arise in areas

with relatively higher concentrations of HMOs. Whilst not considerations for the purposes of

making an article 4 direction, they are important to include here as they add to a perception of

change in local character, make up etc. This includes:

• The concentration of ‘care’ uses

• The use of HMOs for the housing of potentially vulnerable individuals, including

younger people recently released from care;

• The use of ‘HMO accommodation’ for families e.g. where reports of families living in

rooms in HMOs are reported.

7.4.4 These are significant concerns and highlight deeper issues in terms of the provision of suitable

housing coupled with alterations to the health and social care system. Unfortunately, such

matters cannot currently be addressed via the planning system.

7.4.5 Due to their nature, the making of an article 4 direction is highly unlikely to have any significant

impact on them.


85

8.0 Conclusions and Recommendations

8.1.1 Based on the data, there is evidence that in some areas, concentrations of HMOs are leading to

a change in character which is having a harmful impact on the amenity and proper planning of

the area. This is principally related to visual character and appearance though there is a

moderate correlation between environmental complaint indicators and HMOs which should also

be taken into account as part of a cumulative impact. Overall, an Article 4 direction is considered

justified on the grounds of assisting with the proper planning of the area.

8.1.2 In some other areas there are relatively high concentrations of smaller HMOs with no discernible

impact. The main characteristic of areas where high concentrations of smaller HMOs are causing

an impact is the number of large properties that have been converted into flats and then sub-

divided into small HMOs without the need for planning permission. An Article 4 direction would

assist in allowing a greater degree of control over the future use and occupancy of these

buildings.

8.1.3 Moreover, as some areas may become more popular/appealing for HMO use in the future, it

would be helpful to introduce planning controls here proactively, so the situation can be

monitored more effectively.

8.1.4 It has been noted that many of the areas that introduced Article 4 directions in quite tightly

defined areas have since extended the area due, to some degree, to a subsequent clustering of

HMOs just outside the area boundary. This was the situation in Northampton which is one of

the case studies discussed here. Given the similarities in terms of dwelling stock, urban character

and demographics (no single group), it is recommended that an Article 4 is made for the whole

of the current Bedford/Kempston urban area.

8.1.5 In addition, we know there is a link between housing and health. The latest appeal that was

dismissed in relation to HMOs on St Michaels Road was dismissed on the grounds of impact

upon physical and mental health (Reference 3230280). The need for planning permission would

allow consideration of issues such as amenity space allocation and the imposition of conditions

that could assist in creating a healthier environment through measures such as improved waste

storage and bike storage.

8.1.6 Overall, an Article 4 direction is considered justified on the grounds of ensuring proper planning

of the area.


86

8.1.7 In the event that an Article 4 direction is made by Bedford Borough Council, it is recommended

that a Supplementary Planning Document be prepared to guide and assist those considering

such proposals including both external parties (e.g. owners and consultants) and internal groups

such as officers and members. This Document would include percentage threshold limits beyond

which proposals for further HMOs in an area or street would not be supported. Although this

would not act retrospectively to reduce the number of HMOs on streets with a greater number

than the agreed threshold, it would restrict further harm and potential for harm. However, it

may also be appropriate to consider specific concentrations such as adjacency of properties in

addition to percentage thresholds. This will require further consideration in due course.

Appendix A

www.wyg.com

1

creative minds safe hands

Local Authority Full or part Year Summary reason

Ashford Borough Council Part 2012 Amenity

Basingstoke and Deane Borough Council Part 2011 Community balance

Bath and North East Somerset Council Whole 2013 Students

Birmingham City Council Part- to be replaced by whole

2014 Students

Blackburn and Darwen Borough Council Part 2013 Community balance

Bournemouth Borough Council Whole 2019 Students

Brighton and Hove City Council Part- to be replaced by whole

2012 Community balance

Bristol City Council Part 2011 Students

Canterbury City Council Whole 2015 Students

Charnwood Borough Council Part 2012 Students

Cheshire West and Cheshire Part 2013 Students

City of York Part 2011 Students

Cornwall Council Part 2016 Students

Crawley Borough Council

Doncaster Part 2019 Community balance

Durham County Council Part 2015 Students

Exeter City Council Part 2014 Students

Great Yarmouth Borough Council Whole 2012 Character

Harlow Council Part 2013 Character

Hastings Borough Council Whole 2012 Community balance

Hull City Council Part 2013 Community balance

Liverpool City Council Part 2018 Students

London Borough of Barking and Dagenham Whole 2011 Community balance

London Borough of Barnet Whole 2016 Community balance

London Borough of Haringey Part 2013 Community balance

London Borough of Havering Part 2015 Community balance

London Borough of Hillingdon Part 2013 Students

London Borough of Hounslow Part 2017 Community balance

London Borough of Waltham Forest Whole 2014 Community balance

London Borough of Southwark Part 2014 Character

Appendix A

www.wyg.com

2

creative minds safe hands

Leeds City Council Part 2011 Students

Leicester City Council Part- extended 2013 Students

Lincoln City Council Whole 2016 Students

Manchester City Council Whole 2011 Students

Milton Keynes Council Part-extended to whole

2011 Community balance

Newcastle upon Tyne City Council Part- extended 2011 Students

Newcastle-under-Lyme Council Unknown Unknown Unknown

Northampton Borough Council Part-extended 2011 Students

Nottingham City Council Whole 2012 Students

Oxford City Council Whole 2011 Students

Plymouth City Council Part 2012 Students

Portsmouth City Council Whole 2011 Students

Preston City Council Part unknown Character

Reading Borough Council Part 2013 Students

Rother District Council Part 2011 Community balance

Royal Borough of Greenwich Part 2017

Salford City Council Part 2018 Community balance

Sefton Council Part 2017 Community balance

Sheffield City Council Part 2011 Students

South Somerset District Council Part 2016 Community balance

South Tyneside Metropolitan Borough Council

Part 2018 Community balance

Southampton City Council Whole 2012 Students

Stevenage Borough Council Whole 2016 Character

Sunderland City Council Part 2013 Community balance

Tendring District Council Whole 2011 Character

Thanet District Council Whole 2012 Community balance

Trafford City Council Whole 2017 Students

Warwick District Council Part 2012 Students

Welwyn Hatfield Council Part 2012 Amenity

West Lancashire District Council Part 2011 Students

Winchester City Council Part 2018 Community balance

Worcester City Council Whole 2014 Community balance

York City Council Part 2012 Students

Our Ref: BedfordHMO-C Your Ref:

Midsummer Court, 314 Midsummer Boulevard, Milton Keynes, Buckinghamshire, MK9 2UB

www.wyg.com WYG Group Limited. Registered in England & Wales Number: 6595608 Registered Office: Arndale Court, Headingley, Leeds, LS6 2UJ

Appendix B

17th June 2019

Dear Sir/ Madam

Bedford Borough Council: Houses in Multiple Occupation Study

Bedford Borough Council has recently appointed WYG to undertake a study about the impact of Houses in

Multiple Occupation (HMOs) in Bedford Borough. HMOs include a range of accommodation types, from shared houses rented by groups of friends through to individually let rooms, bedsits and flats that were

converted before 1991. One option being considered to control HMOs is to use a planning tool known as an ‘Article 4 direction’, which removes the automatic planning approval to change a family home into a HMO

for up to 6 persons.

Whilst local concerns have been raised regarding the impact of increasing numbers of HMOs and the

consequences this has on character and amenity of the local area and in particular areas of Bedford Town Centre, it is also acknowledged that HMOs provide a source of low-cost, private sector housing for those on

lower incomes, students and individuals seeking temporary accommodation. The study must therefore

consider a range of different views and perspectives prior to considering what, if any, action might be appropriate

To support the research, a series of small focus groups and workshops will be held with key stakeholders

to better understand the role HMOs play in meeting specific accommodation needs in Bedford.

We are contacting you specifically to understand the perception of HMOs locally, and any experiences that

you or your organisation has regarding this type of housing. This session is likely to take the form of a workshop, rather than a traditional focus group, and no prior knowledge is required. Further information,

including FAQs about HMOs and the study are available via: https://www.wyg.com/planning/consultations/bedford-hmo-study

The workshop group will take place at: The Castle Room, The Higgins, Castle Lane, Bedford MK40 3XD on 26th June 2019 at 10am.

It is envisaged that the workshop will last approximately 2 hours. There will be opportunities to follow up

on any of the points raised over the telephone, as appropriate.

Please note: this session is being specifically organised for community representatives and is for the

named individual or organisation only. A separate drop-in session is being held for interested members of the public on the 4th July 2019. This will be publicised separately by the council.

We would be grateful if you could confirm attendance to Annabel Le Lohe at [email protected] by

Monday 24th June 2019.

Should you have any further questions, or require additional information please do not hesitate to contact

Eleanor Gingell- Principal Planner ([email protected])

Yours sincerely,

https://www.wyg.com/planning/consultations/bedford-hmo-study

Eleanor Gingell Principal Planner For and on behalf of WYG

HMO Study, Bedford

1. Welcome

WYG Planning and Environment have been commissioned by Bedford Borough Council to examine if there is evidence to support extra planning controls for Houses in Multiple Occupation (HMOs). The study focuses on the urban areas of Bedford and Kempston. The relevant wards are shown on the map below.

Exhibition Content

Why the study is being

undertaken

What is aHouse in Multiple

Occupation

Data collectedto date

Understanding yourviews

HMO Study, Bedford

2. Study Background

Evidence gathered through today’s drop-in will also be used to gather the views of communities and see if there are additional topics we need to research.

On some of the boards you will see questions. We would encourage you to answer as many as possible.

Local concerns have been raised regarding the impact of increasing numbers of HMOs and the consequences this has on character and amenity of the local areaand areas of Bedford Town Centre.

Elected members have requested that a study be undertaken to look at if there are planning tools that could be used to help manage HMOs.

WYG were commissioned in April 2019.

Why is the study being done now?

Aims and ObjectivesAt present, family homes can be converted into HMOs for up to 6 persons without the need to apply for planning permission. The study will investigate whether there is enough evidence to support the removal of this permitted development right through the use of an Article 4 Direction.

Article 4 Directions are intended to be used in exceptional circumstances and where there is evidence that permitted development harms local amenity or prevents the proper planning of an area. This study investigates these matters through looking at existing data the council holds, undertaking site visits across Bedford and Kempston visiting areas with known HMOs and no known HMOs, surveys and conversations with local stakeholders.

HMO Study, Bedford

3. Definition of a HMO for this Study

What is a House in Multiple Occupation (HMO)?There different definitions used to define what a HMO is.

In summary, HMOs are homes that areshared by more than one household. A household is defined as a single person, members of the same family (including stepfamilies and half relativese.g. Aunts, uncles, siblings), or people who are living together as a couple.

This study focuses on the planning definition of a HMO taken from the Use Classes Order. Since the 1st October 2010, a dwellinghouse (C3) can be converted into a small HMO (C4) and back to a family home with no need for planning permission.

Planning permission is required to convert a house to a large HMO (and back to a family home).

A ‘small HMO’ (Use Class C4)is defined as:

Use of a dwelling house by not more than six residents

as a “house in multiple occupation”.

‘Large HMOs’ for 7 or more

residents are a different

use class known as

‘sui generis’.

Who lives in a HMO?

There is no single type of person who lives in a HMO. The researchundertaken to date shows that HMOs offer a source of affordable and flexible accommodation to different groups from young professionals to those on lower incomes who may be unable to access support for other types of affordable housing.

Would an Article 4 Direction stop all HMOs?An Article 4 Direction removes Permitted Development Rights. It means that proposals for HMOs will need to apply for planning permission before they can be converted.

The Direction would not apply retrospectively, and existing HMOs would not need to apply for any planning permission to continue to operate.

Definitions

HMO Study, Bedford

4. Location of Licensed HMOs

WYG have analysed where licensed HMOs are located across Bedford and created maps to illustrate this. The heat map shows that there are concentrations around the Town Centre, Ampthill Road and Goldington Road. Other areas also have HMOs, although they are more mixed.

Does this pattern match what you expected? Please stick a dot next to Yes or No below. If there are other areas where you think there may be a HMOconcentration please stick a dot on the map, so we can look into it.

?YES NO

HMO Study, Bedford

5. Location of Licensed HMOs & Site Visits

To provide further detail, the map to the left illustrates how small and large licensed HMOs are distrbuted across Bedford and Kempston.Generally, the HMO concentrations are comprised of a mix ofboth small and large HMOs. Although, there are a greater proportion of smaller HMOs along Goldington Road and near to Bedford Midland train station.

Using Bedford BoroughCouncil data,WYG undertook site visits across Bedford and Kempston to understandthe areas where HMOs are morehighly concentrated.

Whilst on the site visitswe took notes on thecondition of the street overall. The main factors assessed relateto character and appearance of the area.

HMO Study, Bedford

6. Environmental Complaints

Environmental complaints include those received by the council about noise, waste (including fly tipping) and pests.

For noise, we have removed complaints about events and commercial buildings to help ensure that the maps reflect noise in residential areas. Similarly, for pests we have removed reports relating to public and commercial buildings.

The maps show that on the whole there are environmental complaints across the whole of the town with an increase in the town centre area.

Does this pattern match what you expected? Please stick a dot next to Yes or No below. If there are other areas where you think there may be environmental issues (e.g. waste or noise) please stick a dot on the map.

?YES NO

HMO Study, Bedford

7. Perceptions of HMOs

It would be useful to understand what factors those attending this drop-in associate with HMOs. Please put a dot in each category that you think applies to HMOs. This information will be used to help us finalise our report and make recommendations. There are no right or wrong answers.

Noise Rubbish

AffordableHousing

Loss of Character

PoorlyMaintained

FlexibleAccommodation

Safe Overcrowded

HMO Study, Bedford

8. Your Input and Next Steps

Thank you for attending today. The next steps are summarised below.

Feedback forms are available should you have any further questions or comments. Please note comments andpersonal details (if given) may be shared with Bedford Borough Council. If you have provided personal information, this will only be used and stored as part of the Study and in accordance with WYG and Bedford Borough Council’s GDPR policy.

To view the consultation webpage and download an electronic feedback form, please scan the QR code below.

Draft report and submit to the council for review

(Summer 2019)

Publication of report for consideration by Councillors

(Autumn 2019)

If recommended to make an Article 4 direction 12-month consultation plus additional planning guidance to help

If not recommended, suggest other options

and monitor/review the data periodically.

Complete the consultationand engagement

to inform the study research.

See if the view correlatewith other data e.g. council

records, site visitsand historic research.

Bedford HMO Study Feedback Form Please return feedback forms to [email protected]

or WYG, Midsummer Court, 314 Midsummer Boulevard, Milton Keynes, MK9 2UB

Interest in the project:

……………………………………………………………………………………………………………………………………………………………………………

Comments/Questions:

……………………………………………………………………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………………………………………………………………

mailto:[email protected]

If you would like to be involved in any further consultation on this project, please provide your details

below:

Name:

……………………………………………………………………………………………………………………………………………………………………………

Postcode:

……………………………………………………………………………………………………………………………………………………………………………

Email Address:

……………………………………………………………………………………………………………………………………………………………………………

Please tick the box below to confirm that you understand the following: By providing my personal

details I am consenting to WYG storing my information and contacting me to assist with their

research as required. I understand that my personal information may be passed to Bedford Borough

Council.

Please note: no personally identifiable information will be published within the study.

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