Houses in Multiple Occupation
A House in Multiple Occupation (HMO) is a house or flat which is occupied by three or more unrelated people who share facilities such as a kitchen or bathroom. HMOs are an important part of the local housing market, particularly within Bath, providing affordable accommodation for students, professionals, low-income workers and migrant workers among others.
The council exerts greater planning controls over HMOs in Bath, and in July 2013 introduced a citywide Article 4 Direction to control the future growth and geographic spread of HMOs. Local plan policy H2 sets out criteria to be considered when assessing planning applications for the change of use to a HMO, intensification of existing HMOs, and the provision of new build HMOs. This operates together with the Houses in Multiple Occupation Supplementary Planning Document (HMO SPD), with the aim of encouraging a sustainable community in Bath and the wider district by avoiding an over concentration of HMOs and retaining an appropriately balanced housing mix.
Evidence produced by the council shows that, following adoption of the HMO SPD in January 2022, HMO creation is being displaced from traditionally high concentration areas to the wider city, where market housing is more affordable. Notably, the intended outcome of the SPD is to avoid overconcentration of HMOs in specific areas. However, concerns persist that the displacement of HMO creation to more affordable housing areas is leading to the loss of affordable housing options for families.
Paragraph 63 of the National Planning Policy Framework (NPPF December 2024) requires local authorities to assess the size, type and tenure of housing needed for different groups in the community, including families with children, and reflect the results of this assessment in their planning policies. In addition, the LHNA identifies the overall housing need for Market Housing in Bath and states that 3-bedroom properties represent the largest proportion of housing need in the city.
Therefore, it is appropriate to propose an option to update policy H2, to include an approach to prohibit the creation of an HMO where it would result in the loss of 3-bed C3 dwellings suitable for owner occupation by families and first-time buyers among others. This policy would restrict the loss of 3-bed class C3 dwellings of a defined gross internal area considered to be an appropriate threshold for indicating that a property would constitute a ‘family home’. Coverage of this policy approach is proposed at a citywide level or for the relatively more affordable market housing areas identified in Bath, where the median housing affordability (average income to average house price) ratio is below the median affordability ratio for B&NES. There is scope to monitor affordability ratios through an updated HMO SPD.
H/HMO: Houses in Multiple Occupation (HMO) – Proposed Options
| No | Options | Advantages | Disadvantages |
| 1 | Update policy H2 to include an additional criterion which states that in affordable market housing areas (based on affordability ratios), the creation of an HMO which would result in the loss of a 3-bed C3 dwelling which size is considered suitable for a ‘family home’ will be prohibited. | Protects dwellings suitable for family housing in affordable market areas. | There could be significant adverse impacts of overly restricting the availability and supply of HMOs, which cater for the housing needs of specific groups (students, professional house sharers, low-income workers, single people relying on housing benefits, etc.) |
| 2 | Update policy H2 to include an additional criterion which states that across the City of Bath HMO Article 4 Direction area, the creation of an HMO which would result in the loss of a 3-bed C3 dwelling which size is considered suitable for a ‘family home’ will be prohibited. | Protects dwellings suitable for family housing in Bath. | There could be significant adverse impacts of overly restricting the availability and supply of HMOs, which cater for the housing needs of specific groups (students, professional house sharers, low-income workers, single people relying on housing benefits, etc.) |
| 3 | No change proposed to policy H2. | Reflects the national approach for managing HMOs | Continued dispersal of HMOs and loss of single private dwellings. |