Greater Cambridge Local Plan: Proposed Submission

1. Lack of controls on HMO over-concentration
Alongside a city-wide Article 4 Direction bringing small C4 HMOs into the planning system, Policy H/MO needs effective controls on the number of C3-to-HMO conversions. Strong demand for HMOs risks reducing the supply of family housing and allowing HMOs to dominate neighbourhoods. The Council's own evidence, the Iceni Greater Cambridge Houses in Multiple Occupation Study (2026), recognises the impact on neighbourhood character, residential amenity and housing mix, and recommends managing cumulative concentration.

2. No objective measure of concentration
Policy H/MO does not define over-concentration in measurable terms. It should set a maximum of 10% HMOs within a 100-metre radius, a standard test used by other councils. This should complement, not replace, the sandwich and three-adjacent-property tests, and any exceptions should be tightly controlled.

3. Excessive subjectivity
Terms such as "harm", "suitable", "appropriate", "high-quality", "high concentration" and "sufficiently high" have no clear definitions or thresholds. This leaves them open to inconsistent interpretation and decision-making, and subject to challenges and appeals.

4. Limitations of the sandwich and three-adjacent-property tests
These tests deal only with the relationship between neighbouring properties, not with concentration across a wider area. A repeating pattern of two HMOs followed by two family homes would meet both tests, yet around half the houses in a terrace could become HMOs. A wider measure of concentration is therefore needed.

5. Incomplete evidence
The Iceni study leaves university and college-managed student accommodation out of its main analysis of HMO concentration. This risks understating both the amount of student accommodation and how concentrated it is in particular areas. This accommodation should be included in the analysis or identified separately. There is a lot of it in Cambridge and it impacts the character of neighbourhoods and communities.

6. HMO register
The policy should require an accurate, regularly updated register of all HMOs. Without reliable data, concentration cannot be accurately assessed, monitored or consistently controlled.

7. Existing concentration should not justify further concentration
As drafted, paragraph 9.100 would allow more HMOs in areas where concentration is already high.

8. Space standards and management
Meeting minimum space standards does not guarantee good-quality accommodation, particularly in small Victorian terraced houses. The policy should distinguish between technical compliance and quality. Management plans work only when backed by adequate resources, ongoing monitoring and robust enforcement. Current staffing levels and budgets do not give sufficient assurance that these requirements can be delivered in practice.

The policy should set out a clear, objective and enforceable framework for managing the cumulative concentration of HMOs. It should work alongside a city-wide Article 4 Direction and apply a threshold of 10% of properties within a 100-metre radius. It should be supported by a comprehensive HMO register, clearly defined concentration criteria, and enough resources for monitoring and enforcement. Without these measures, the policy risks allowing HMOs to build up gradually in established neighbourhoods, and it leaves too much room for subjective interpretation.