Draft Greater Cambridge Local Plan for consultation

I have sent a longer submission by email to localplan@greatercambridgeplanning.org, because the full comment could not fit in this box. Here is an executive summary of the longer submission:

This comment is made on behalf of the Guest Road Residents’ Association (GRARA), representing residents of Willis Road, Guest Road, Mackenzie Road, Collier Road and the odd-numbered properties from 3 to 39 Mill Road in Petersfield, Cambridge.

We strongly support the introduction of a clear numerical threshold defining “over-concentration” of Houses in Multiple Occupation (HMOs) in the Cambridge Local Plan and recommend that this threshold be set at 10% of dwellings within a defined local radius. We also strongly support the introduction of an Article 4 Direction, ideally covering central Cambridge and, at a minimum, the Petersfield area.

A 10% HMO threshold is a well-established and evidence-based approach used by a large and growing number of UK local authorities, including comparable university cities such as Durham, Bristol and York. Evidence from the National HMO Lobby and multiple local planning authorities identifies 10% as the point at which concentrations of HMOs begin to undermine community balance, residential amenity and neighbourhood character. Cambridge is now an outlier among UK university cities in having neither a defined HMO threshold nor an Article 4 Direction.

The draft Local Plan’s reliance on an undefined concept of “over-concentration” is insufficient. Without a clear numerical threshold, decision-making becomes subjective, refusals are harder to defend at appeal, and speculative applications continue. A defined threshold would provide clarity, reduce unnecessary applications, save officer time and public resources, and create a more robust and defensible planning framework.

Evidence from Petersfield demonstrates the urgency of this issue. At least 33% of properties across the streets represented by GRARA are registered HMOs, with the true figure likely higher once unlicensed small HMOs are included. In some streets, HMO concentrations far exceed levels permitted by other local authorities. Residents report significant and ongoing impacts including pressure on parking and waste services, noise and antisocial behaviour, loss of family housing, and erosion of long-established community character.

The absence of an Article 4 Direction allows small HMOs to be created under permitted development rights, bypassing important Local Plan safeguards relating to refuse storage, cycle parking, parking stress, suitability of buildings, and management arrangements. This undermines the effectiveness of the Local Plan’s stated objectives and prevents the Council from addressing harmful concentrations where they already exist.

In 2012, Cambridge City Council stated there was insufficient evidence to justify an Article 4 Direction. That position is no longer sustainable. There is now clear evidence of high HMO concentrations and associated impacts across central Cambridge, including Petersfield.

For these reasons, we urge the Council to:

- define “over-concentration” in the Local Plan using a clear 10% HMO threshold, and

- introduce an Article 4 Direction to ensure that further HMO and short-term let conversions are subject to proper planning scrutiny in areas of high concentration.

I have sent a longer submission by email to localplan@greatercambridgeplanning.org, because the full comment could not fit in this box. Here is an executive summary of the longer submission:

This comment is made on behalf of the Guest Road Residents’ Association (GRARA), representing residents of Willis Road, Guest Road, Mackenzie Road, Collier Road and the odd-numbered properties from 3 to 39 Mill Road in Petersfield, Cambridge.

We strongly support the introduction of a clear numerical threshold defining “over-concentration” of Houses in Multiple Occupation (HMOs) in the Cambridge Local Plan and recommend that this threshold be set at 10% of dwellings within a defined local radius. We also strongly support the introduction of an Article 4 Direction, ideally covering central Cambridge and, at a minimum, the Petersfield area.

A 10% HMO threshold is a well-established and evidence-based approach used by a large and growing number of UK local authorities, including comparable university cities such as Durham, Bristol and York. Evidence from the National HMO Lobby and multiple local planning authorities identifies 10% as the point at which concentrations of HMOs begin to undermine community balance, residential amenity and neighbourhood character. Cambridge is now an outlier among UK university cities in having neither a defined HMO threshold nor an Article 4 Direction.

The draft Local Plan’s reliance on an undefined concept of “over-concentration” is insufficient. Without a clear numerical threshold, decision-making becomes subjective, refusals are harder to defend at appeal, and speculative applications continue. A defined threshold would provide clarity, reduce unnecessary applications, save officer time and public resources, and create a more robust and defensible planning framework.

Evidence from Petersfield demonstrates the urgency of this issue. At least 33% of properties across the streets represented by GRARA are registered HMOs, with the true figure likely higher once unlicensed small HMOs are included. In some streets, HMO concentrations far exceed levels permitted by other local authorities. Residents report significant and ongoing impacts including pressure on parking and waste services, noise and antisocial behaviour, loss of family housing, and erosion of long-established community character.

The absence of an Article 4 Direction allows small HMOs to be created under permitted development rights, bypassing important Local Plan safeguards relating to refuse storage, cycle parking, parking stress, suitability of buildings, and management arrangements. This undermines the effectiveness of the Local Plan’s stated objectives and prevents the Council from addressing harmful concentrations where they already exist.

In 2012, Cambridge City Council stated there was insufficient evidence to justify an Article 4 Direction. That position is no longer sustainable. There is now clear evidence of high HMO concentrations and associated impacts across central Cambridge, including Petersfield.

For these reasons, we urge the Council to:

- define “over-concentration” in the Local Plan using a clear 10% HMO threshold, and

- introduce an Article 4 Direction to ensure that further HMO and short-term let conversions are subject to proper planning scrutiny in areas of high concentration.

I have sent a longer submission by email to localplan@greatercambridgeplanning.org, because the full comment could not fit in this box. Here is an executive summary of the longer submission:

This comment is made on behalf of the Guest Road Residents’ Association (GRARA), representing residents of Willis Road, Guest Road, Mackenzie Road, Collier Road and the odd-numbered properties from 3 to 39 Mill Road in Petersfield, Cambridge.

We strongly support the introduction of a clear numerical threshold defining “over-concentration” of Houses in Multiple Occupation (HMOs) in the Cambridge Local Plan and recommend that this threshold be set at 10% of dwellings within a defined local radius. We also strongly support the introduction of an Article 4 Direction, ideally covering central Cambridge and, at a minimum, the Petersfield area.

A 10% HMO threshold is a well-established and evidence-based approach used by a large and growing number of UK local authorities, including comparable university cities such as Durham, Bristol and York. Evidence from the National HMO Lobby and multiple local planning authorities identifies 10% as the point at which concentrations of HMOs begin to undermine community balance, residential amenity and neighbourhood character. Cambridge is now an outlier among UK university cities in having neither a defined HMO threshold nor an Article 4 Direction.

The draft Local Plan’s reliance on an undefined concept of “over-concentration” is insufficient. Without a clear numerical threshold, decision-making becomes subjective, refusals are harder to defend at appeal, and speculative applications continue. A defined threshold would provide clarity, reduce unnecessary applications, save officer time and public resources, and create a more robust and defensible planning framework.

Evidence from Petersfield demonstrates the urgency of this issue. At least 33% of properties across the streets represented by GRARA are registered HMOs, with the true figure likely higher once unlicensed small HMOs are included. In some streets, HMO concentrations far exceed levels permitted by other local authorities. Residents report significant and ongoing impacts including pressure on parking and waste services, noise and antisocial behaviour, loss of family housing, and erosion of long-established community character.

The absence of an Article 4 Direction allows small HMOs to be created under permitted development rights, bypassing important Local Plan safeguards relating to refuse storage, cycle parking, parking stress, suitability of buildings, and management arrangements. This undermines the effectiveness of the Local Plan’s stated objectives and prevents the Council from addressing harmful concentrations where they already exist.

In 2012, Cambridge City Council stated there was insufficient evidence to justify an Article 4 Direction. That position is no longer sustainable. There is now clear evidence of high HMO concentrations and associated impacts across central Cambridge, including Petersfield.

For these reasons, we urge the Council to:

- define “over-concentration” in the Local Plan using a clear 10% HMO threshold, and

- introduce an Article 4 Direction to ensure that further HMO and short-term let conversions are subject to proper planning scrutiny in areas of high concentration.

I have sent a longer submission by email to localplan@greatercambridgeplanning.org, because the full comment could not fit in this box. Here is an executive summary of the longer submission:

This comment is made on behalf of the Guest Road Residents’ Association (GRARA), representing residents of Willis Road, Guest Road, Mackenzie Road, Collier Road and the odd-numbered properties from 3 to 39 Mill Road in Petersfield, Cambridge.

We strongly support the introduction of a clear numerical threshold defining “over-concentration” of Houses in Multiple Occupation (HMOs) in the Cambridge Local Plan and recommend that this threshold be set at 10% of dwellings within a defined local radius. We also strongly support the introduction of an Article 4 Direction, ideally covering central Cambridge and, at a minimum, the Petersfield area.

A 10% HMO threshold is a well-established and evidence-based approach used by a large and growing number of UK local authorities, including comparable university cities such as Durham, Bristol and York. Evidence from the National HMO Lobby and multiple local planning authorities identifies 10% as the point at which concentrations of HMOs begin to undermine community balance, residential amenity and neighbourhood character. Cambridge is now an outlier among UK university cities in having neither a defined HMO threshold nor an Article 4 Direction.

The draft Local Plan’s reliance on an undefined concept of “over-concentration” is insufficient. Without a clear numerical threshold, decision-making becomes subjective, refusals are harder to defend at appeal, and speculative applications continue. A defined threshold would provide clarity, reduce unnecessary applications, save officer time and public resources, and create a more robust and defensible planning framework.

Evidence from Petersfield demonstrates the urgency of this issue. At least 33% of properties across the streets represented by GRARA are registered HMOs, with the true figure likely higher once unlicensed small HMOs are included. In some streets, HMO concentrations far exceed levels permitted by other local authorities. Residents report significant and ongoing impacts including pressure on parking and waste services, noise and antisocial behaviour, loss of family housing, and erosion of long-established community character.

The absence of an Article 4 Direction allows small HMOs to be created under permitted development rights, bypassing important Local Plan safeguards relating to refuse storage, cycle parking, parking stress, suitability of buildings, and management arrangements. This undermines the effectiveness of the Local Plan’s stated objectives and prevents the Council from addressing harmful concentrations where they already exist.

In 2012, Cambridge City Council stated there was insufficient evidence to justify an Article 4 Direction. That position is no longer sustainable. There is now clear evidence of high HMO concentrations and associated impacts across central Cambridge, including Petersfield.

For these reasons, we urge the Council to:

- define “over-concentration” in the Local Plan using a clear 10% HMO threshold, and

- introduce an Article 4 Direction to ensure that further HMO and short-term let conversions are subject to proper planning scrutiny in areas of high concentration.