Response to planning application - 13/01669/F - 7 Myrtle RoadBristolBS2 8BL - Change of use of dwellinghouse (Use Class C3) to a 4-bed House in Multiple Occupation (Use Class C4).

Summary

KCG encourages new development that makes a positive contribution to the character and local distinctiveness of the historic environment. KCG supports the University and welcomes the student residents to the city and it does not complain about general student behaviour. The majority of local residents have been students themselves. KCG opposes this further student development because of the over-concentration of temporary student residents. There is strong evidence that the ascendancy of student occupation is driving out the permanent population. Some of the student residents now assert that they occupy a ‘student area’. A major attraction of BristolUniversity is its situation in the middle of a working city.

KCG objects to the creation of the huge demographic imbalance caused by transitory residents, which cripples the area's sustainability. Local residents’ groups have said for many years that this community cannot cope with further hollowing out of families, older people and working couples. An entire community of young, single, transitory residents reduces the local services to almost nothing except bars and fast-food outlets. This is unsustainable, and loads huge costs onto future generations to restore the community's sustainability. The proposal would remove another viable family home from an already inadequate local stock. The house is economically viable as a family home. Kingsdown has a long-established need to recruit and maintain a permanent, sustainable residential community.

Relevant planning policies

Bristol Core Strategy

10th December 2010, Article 4 direction

Site description

This is a modest mid-19th century terraced villa in an area that is rapidly losing its residential accommodation through formal and informal conversion to houses in multiple occupation (HMO). Until the current planning application, KCG believes that this property, has been a single dwelling.

The key issue - would the proposed change of use to a HMO acceptable in principle?

National and local planning justifies KCG's objection.

Policy BCS5 (housing) explains the delivery of objectives 1, 2 and 4 of the CoreStrategy at paragraphs:

4.18.1 This policy will ensure that new residential development provides for arange of housing types to help support the creation of mixed, balancedand inclusive communities.

4.18.4 …………………………. The increasing concentration of flats at high densitiesin certain parts of the city may not provide opportunities for families.

4.18.7 The policy criteria will help to achieve an appropriate mix of housing in allnew residential development. Schemes will be expected to take accountof housing need and demand, to have regard to the composition of thelocal housing stock and demographic changes and to respond to siterelated issues through imaginative design solutions……

On the 10th December 2010, the Council passed a direction under Article 4 of theTown and Country Planning (General Permitted Development) Order 1995 to directthat article 3 shall not apply to development consisting of the change of use of abuilding to a house in multiple occupation within an area, which includes 7 Myrtle Road.

The officer’s report to the committee gave these reasons why permitteddevelopment of HMOs would harm the area:

  • “HMO concentrations are having a negative impact on residential amenityand character within a number of the city’s central wards;
  • Housing mix issues including household and housing size/tenure imbalanceshave been identified within a number of the city’s central wards;
  • Exercise of permitted development rights within a number of the city’s centralwards would undermine objectives to protect residential amenity andcharacter and to create or maintain mixed communities;”

Appendix A summarised the evidence to support the direction.

The evidence in the appendix showed Cotham top the table with the most fulltimeBristolUniversity or UWE student residents at 4,708 and Cabot to be third with 2,956students. The report says that Officers will have better estimates of HMOs when2011 census data becomes available. The report concluded

“Existing HMO concentrations are having adverse impacts in certain areas whichrequire some level of planning intervention. The High Kingsdown estate is one of thestreets that the report identified as having the particular problems that it described.”

7 Myrtle Road abuts the boundary of the heavily student populated High Kingsdown estate. KCGrequest that the planning officer asks the Private Sector Housing Team to provide further information in respect of existingunlicensed and licensed HMOs in the immediate area. When these HMOs are mapped it will be clear that this is an area of the city where HMOs are highly concentrated. As such, the proposal will have an unacceptable effect the balance and mix of housing in the area. Thiswould also add to problems raised by neighbours of noise and disturbance from the`studentification' of the area.

The economic and social problems that justified the local intervention to disapplysome general development rights apply to this scheme. The council identified thatthe High Kingsdown estate suffered from the negative impact on its residentialamenity and character caused by an over concentration of student occupants beforethe current planning application. 50% of the housing of the High Kingsdownestate is student occupied. The student occupation rate of the Holly Court flats onthe High Kingsdown estate is higher because the owners advertise theblock as student accommodation.

KCG invites the Private Sector Housing Team to provide information in respect ofexisting unlicensed and licensed HMOs in the immediate area from information inthe council’s possession to include returns for exemption from Council Tax and fromthe electoral returns.

There is overwhelming local evidence to show that the probable occupants will be students because:

• BristolUniversity is the scheme’s neighbour.

• 50% of the surrounding residentialaccommodation is student occupied.

KCG understands that the council must decide every planning application on its ownmerits. However, it draws attention to the decision in planning application No.10/02852/F – 1 Woodfield Road, Redland. On the 23rd July 2010, the council refusedan application to change a dwellinghouse to multi-occupancy under the policies ofthe Bristol Local Plan (1997). The Core Strategy has given the council greater powersof planning intervention where it considers that over-concentration of a particularuse, harms an area.

KCG distinguishes the decision made at appeal in Appeal Ref: APP/Z0116/A/12/2176229 - Kings Arms, High Kingsdown against a refusal to grant planning application - 11/04527/F. That development proposed is conversion and extension of a former uneconomically viable public house to student cluster flats. the proposal did not result in the loss of existing family housing andfurther student colonising High Kingsdown houses.

Planning balance

In his decision in the planning appeal, the Inspector made clear at paragraph 29 that the public house conversion scheme was a very different entity from organic,unsupervised, unmanaged and disparate process of HMO colonisation. That development, he said, would bring a valued but long neglected local historic building backinto active economic use and, on that basis would not conflictwith policy BCS18 of the Bristol Civic Society. Unlike the appeal application, this planning application would reduce the stock of family housing. It would intensify the current harmful imbalance between the area’s shared and family accommodation.

Planning conclusion

A planning permission would exacerbate accelerate the loss of family homes and compromise the delivery of local commercial and community services in the locality. A planning permission would further reduce the range of housing types and increase the concentration of HMOs with a transient population and would reduce the area’s capacity to support a mixed and sustainable community.

Satisfactory provision for refuse and recycling storage has not been addressed. A HMO household will have very different requirements to that of a family home. Enhanced storage andrecycling facilities are required for this number of residents. The area has some of the highest concentrations of HMOs so a refusal should not be hardly surprising because the levels of activity associated with the new use would be fargreater than the existing use and be a detriment of the area's residential amenity. This planning application should be refused.

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