Enfield’s proposed new Local Plan has sparked considerable debate and is currently being examined by the Government’s Planning Inspector. One concern we have about the Plan, is the absence of policies for Houses of Multiple Occupancy (HMOs).
HMOs are houses or flats that are shared by 3+ tenants who form two or more households and share a kitchen, bathroom, or toilet. They are crucial in providing affordable housing options for various demographics, including low-income families, students, and young professionals.
However, HMOs have also been associated with a range of problems for tenants, including overcrowding, lack of privacy, and poor living conditions such as damp and mould, as well as increased risk of fire hazards. There are also problems in terms of the impact on local neighbourhoods, including noise complaints, antisocial behaviour, and issues with parking, sanitation, and waste disposal. At a borough level it can mean the loss of much needed family housing.
Enfield Council has reported that 65% of HMOs it investigates have some form of hazard including fire, damp and mould growth, electrical hazards, and excess cold. Every year, the Council receives around 1,000 complaints regarding HMOs. Concerningly, the Council does not seem to know how many HMOs there are in the borough, with estimates ranging between 4,366 and 9,661.
The new plan will not control HMOs in Enfield.
Currently, one of the ways Enfield controls the number and quality of HMOs is through its planning policies, which ensure that HMOs meet a suitable high standard, do not adversely impact the local area, and do not result in a loss of family-sized housing.
However, the Council’s proposed new Local Plan, which will replace the existing plan, has removed these policies, and as a result will enable properties to be converted to HMOs without planning permission. This will have significant implications for Enfield.
In this post, we explore some of the risks to removing these HMO policies and why it is crucial for Enfield Council to reconsider its approach. Risks include:
1. The borough of Enfield will be a target for HMO landlords
If the new Local Plan is adopted, Enfield will become the only London Borough without planning policies to control the number and quality of HMOs. This risks Enfield becoming a target for investors looking to maximise profits by converting family homes into HMOs. In short, the number of poor-quality HMOs in Enfield is likely to significantly increase, unless the Council changes tact and implements policies to regulate this.
2. Health and Safety Concerns
One of the primary reasons for regulating HMOs is to ensure the health and safety of tenants. Without specific policies, there is a risk that poor conversions could result in hazardous and unhealthy living conditions, such as inadequate fire safety measures, poor sanitation, and insufficient space. The well-being of tenants should be a top priority, and planning policies play a vital role in achieving this.
3. Increased Housing Insecurity
HMOs play a vital role in providing affordable housing options for individuals who cannot afford to rent or buy a home on their own. Without clear policies to regulate HMOs, there is a risk that some landlords may exploit vulnerable tenants by offering substandard living conditions at inflated prices.
4. Strain on Local Services and Infrastructure
The absence of HMO policies will result in an unregulated increase in the number of HMOs in Enfield. This surge in population density can strain local services and infrastructure, including healthcare, education, and public transportation. Overcrowded areas may experience higher levels of waste generation, increased traffic congestion, and greater demand for services. Without proper planning and regulation, the quality of life for all residents could be adversely affected.
5. Impact on Community Cohesion
HMOs, when not responsibly managed, can disrupt the social fabric of neighbourhoods. High tenant turnover rates can lead to a transient population that is less invested in the local area. This can weaken community cohesion and reduce the sense of belonging among residents. Additionally, poorly maintained HMOs can become eyesores, negatively impacting the aesthetic appeal and property values of surrounding homes. Planning policies can help to ensure HMOs are appropriately designed and located so that that they do not overwhelm a particular area.
6. Loss of family-sized homes
The Council currently considers around 250-300 applications per year to convert family-sized homes into HMOs. This suggests that if the policy controls are removed – as the Council is proposing – that at least a further 6,000 family-sized homes will be converted into HMOs by 2041 (i.e. the time period covered by the Council’s proposed new Local Plan).
7. Legal and Regulatory Challenges
The lack of HMO policies in Enfield’s Local Plan could lead to legal and regulatory challenges for both landlords and the Council. Landlords may face uncertainty regarding their obligations and the Council may struggle to enforce housing standards. This ambiguity can result in costly legal disputes and hinder the effective management of the rental housing market. Planning policies provide an important enforcement tool for the Council and help provide clarity for all parties.
What does this mean for Enfield?
Enfield’s new Local Plan is important because it helps ensure that we can plan for the type and quality of housing needed. It is a significant concern that Enfield Council have decided to remove policies that regulate Houses of Multiple Occupancy from its new Local Plan. Quite simply, the Council are giving away the control it currently has over HMO conversions and quality.
The risks are too great to ignore.
Enfield Council must take the following steps to address this issue:
- Evidence: The Council needs a much better understanding of the number, type and location of HMOs across the borough, as well as the level of need for different types of HMOs. Only then can appropriate evidence-based planning policies be created.
- Explanation: The Council needs to explain why it took the highly unusual decision to exclude HMO-related planning polices from its proposed new Local Plan, especially as the only beneficiaries would be HMO landlords, and not tenants or local communities.
- Planning Policy: The Council needs to take proactive steps to address this issue by implementing clear and comprehensive HMO policies. By doing so, they can help to ensure that residents have access to safe, affordable, and well-maintained housing, while also preserving the quality of life and community cohesion in Enfield
Better Homes Enfield remains committed to advocating for policies that promote sustainable and inclusive housing solutions. We urge the Council to reconsider their approach and prioritise the need to regulate HMO housing in the new Local Plan
Below are some key details provided in Enfield Council’s reports about HMOs:
- The Council does not know how many HMOs there are in Enfield. In 2019 they predicted there were 9,661 HMOs, but in 2024 claimed there are 4,366. [1] [2]
- Over 80% of HMOs are converted family houses i.e. the type of home that the Council’s proposed Local Plan claims is most urgently needed.
- The number of tenants occupying HMO properties in Enfield ranges between 3 – 34 persons. The average HMO in Enfield is occupied by 5-6 tenants.
- Of the HMOs the Council has inspected, 65% were found to have some form of hazard including fire, damp and mould growth, electrical hazards, and excess cold.
- The Council receives around 1,000 complaints per year regarding HMO related Anti-Social Behaviour. The issues most reported are mostly related to noise, nuisances, waste, rubbing and fouling.
NOTES ON CURRENT HMO PLANNING POLICIES
Development Management Document
Policy DMD5 of the Development Management Document (adopted November 2014) sets out specific policies and requirements designed to ensure HMO conversions:
- Are of a suitably high standard
- Do not have an unacceptable adverse impact on the local area.
- Do not result in an unacceptable loss of family-sized housing.
Article 4 Direction
Amendments to legislation in 2010 allowed changes of use from houses (Use Class C3) to some Houses in Multiple Occupation (Use Class C4) to take place without the need for planning permission. In October 2013, Enfield Council confirmed an Article 4 Direction covering the whole borough, withdrawing permitted development rights for this change of use. As a result, DMD5 (above) is used to assess planning applications for HMOs, however, without such a policy, as the Council is now proposing, the Article 4 direction cannot function as envisaged.
Footnotes
[1] London Borough of Enfield Private Rented Sector: Housing Stock Condition and Stressors Report March 2019
[2] London Borough of Enfield Houses in Multiple Occupation: Housing Stock Condition and Stressors Report May 2024
Better Homes Enfield 