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Thursday, 4 February 2021

TARA's Comment on the Local Plan Update JANUARY-FEBRUARY 2021.

In this submission TARA requests that the Council give serious consideration to a revision of its policies relating to HMOs. (Homes of Multiple Occupation).

BACKGROUND

On March 16th  2020, under delegated powers, The Council granted consent for the conversion of a two bedroom flat at 75 Rosewell Court in the city centre to an HMO (20/00127/FUL).  

This approval was retroactive, in that the conversion had already taken place but the law required that planning permission should have been applied for and granted, had not been, and needed to be.

As is normal, the council based its approval on its policies in relation to HMOs.  These include Policy H2 of the council’s Core Strategy and Placemaking Plan which, inter alia, is designed to ensure that an HMOs will be ‘compatible with the character of adjacent uses’, will not ‘significantly affect the amenity of adjoining residents’ or result in the ‘unacceptable loss of accommodation in a locality in terms of mix, size and type.’  In addition, the council’s Supplementary Planning Document, Homes in Multiple Occupation in Bath, adopted in November 2017, is intended to ensure that similar undesirable consequences are avoided by preventing the accumulation of HMOs beyond a specified limit in any particular residential area.

But these were not normal circumstances.  Providing about two hundred and twenty homes, mostly two and three bedroom flats in four to five storey buildings with balcony access Rosewell Court makes an important contribution to the limited supply of affordable family accommodation in the city centre.  The conversion for which planning consent was granted provides for the transformation of a typical two bedroom flat into a three bedroom unit with a single bathroom and no shared space of the type favoured by short term renters, holiday renters and students.

In approving this conversion, the council is in danger of bringing about the exact opposite of what its policies are designed to achieve.  Having set a precedent, the council will find it hard to resist pressure from other owners to follow suit.  Rosewell Court has a history of serious social problems including drug dealing and abuse, petty crime, noise and disturbance and other forms of anti-social behaviour resulting in police visits.  Any accumulation of HMOs in a development that lacks any shared external facilities other than a council car park will be likely to make all these problems worse.  In due course, if HMO conversions multiply, the council may feel justified in refusing further applications under Policy H2, but by that time it will be too late.


REQUEST

The above case suggests an inherent potential conflict between Policy H2 and Supplementary Planning Document, Homes in Multiple Occupation in Bath.  TARA therefore requests that the Council consider adding to, or amending, its policies in relation to HMOs so that an application for an HMO will be refused where its presence would be in conflict with other Council policies such as Policy CP9, Affordable Housing, relating to the provision, or protection, of housing provided for, or occupied by, specific groups in need.


BATH RUGBY AT THE REC

TARA has consistently supported the principle of development of a rugby stadium at the Rec and continues to do so subject to details and conditions.  We do not consider that any outstanding legal issues in connection with any specific proposal are planning matters.  We do have a number of specific concerns including building height and bulk, traffic, parking and pedestrian flows and the amenity of TARA members living at the Empire but these are detailed matters to be resolved if and when a planning application has been submitted.

We therefor conclude that the Council has no overt basis for altering existing policy and request that Policies B1 and SB2 should be retained in their existing form.