You can read the full objection in principle at the end of this post. To summarise the policies referred to, it quotes:
Paragraphs 92, 97 and 130 of the National Planning Policy Framework
And refers to paragraphs 8, 97,106,108,110, 112 and 119 being relevant (in context).
It draws on The Bristol Development Framework Core Strategy and the Bristol Local Plan – Site Allocations and Development Management Policies – (Adopted July 2014) section DM28.
It ends by highlighting ‘evidence to suggest that instances of non-domestic violence are more prevalent in HMO’s nondom violence HMO.pdf.’
The key local issues are quoted here:
I have viewed the planning application and have the following comments.
A&S Police recognise that HMOs are an important source of low-cost housing within the private rented sector, particularly for those on low incomes, students, young people and vulnerable groups who cannot access other types of market or affordable housing. HMOs are also an important source of flexible housing for those seeking temporary accommodation, however.
The above location immediately neighbours a stretch of Church Road which is the subject of a Police problem solving plan due to consistent anti-social behaviour.
There has been concerted partnership working between the Police, local community, and the street intervention team (BCC) to try an address the anti-social behaviour being conducted in this area.
The Avon and Somerset Police anti-social behaviour coordinator for the locality has commented:
‘Church Road is currently an ASB hot spot, and the neighbourhood beat teams & anti-social behaviour team focus a large amount of attention on problem solving the ongoing ASB in the area. The ASB if often linked to street drinking, begging and general rowdy behaviour. The local businesses report how their businesses are affected by the ASB and prevents the community wanting to visit their businesses, we have also had similar reports from the community outlining how unsafe they feel accessing Church Road because of the ongoing ASB. I am concerned that a 44 bed HMO would cause additional worry to the community and add to the ongoing ASB in the area which we are trying to tackle.’
Neighbourhood Officers also comment:‘I have been the Police Community Support Officer covering the area of St George including Church Road for the last 4 and half years. During this time Church Road has always been an area which has drawn heavily on resources, myself and my team spend a larger amount of time in this area than other locations on our beat. We regularly have incidents of Anti-Social behaviour, this is partially due to the make-up of the area, with offenders being drawn to the pubs, take aways and numerous off-licenses in this location. We regularly receive calls regarding the impact this is having on local residents.’
In addition, an application (20/06252/F) for HMO of 2 x eight bed apartments and 1 x 4-bedroom apartment (16 rooms) has been approved, approx. 170 yds away, at 163A Church Road with the possibility that there are smaller HMO’s also in the vicinity that we are not able to identify due to the lack of a requirement for planning consent /licensing.
The very nature of an HMO means that they are designed for single occupancy with a transient occupancy. Research from Nottingham Trent University identifies those residents of a property with three or more adults experience ‘Around 15% more property crimes than (otherwise identical) two adult households and their members are victims of 51% more personal crimes (Tseloni and Pease 2015)’.
Nationally, it is generally accepted that an over-concentration of HMOs occurs when 10% of properties in a neighbourhood are HMOs. Research argues 10% concentration is the tipping at which HMOs may give rise to harmful effects and where neighbourhoods go from balanced to unbalanced communities (Lewisham review and Evidence paper May 2022).
There is also evidence to suggest that instances of non-domestic violence are more prevalent in HMO’s nondom violence HMO.pdf. Although the applicant would be obliged to adhere to the BCC mandatory HMO licensing scheme, which does mention the need to address any anti-social behaviour, I do not accept that this would be adequate to ensure the long-term guardianship of an HMO of this size, or mitigate the demand on Police resources in this location.
Clare Hawkins
Designing Out Crime team superviser
Full Objection in Principle from Avon and Somerset Police available to read and download below.
