On Thursday 30 July 2020, the National HMO Lobby published a response to recent SAGE papers on Higher Education and Covid-19 pointing out that the papers significantly underestimate the seriousness of the threat from Covid-19 in Higher Education Institutions to public health and safety. ...

National HMO Lobby

Response to

SAGE Papers on Higher Education and COVID-19

01 The National HMO Lobby is a national association of some sixty local residents’ associations, in forty towns throughout the UK, concerned about the impact on their communities of concentrations of houses in multiple occupation (HMOs). Since the main driver of such concentrations has been demand by students at Higher Education Institutions (HEIs), the Lobby welcomes the recent papers from the Scientific Advisory Group for Emergencies (SAGE), SAGE Paper on Further and Higher Education (published 24 July 2020) (cited as SAGE FHE), together with TFC subgroup of SPI-M-O: Comments on schools and universities Response to DfE commission (published 24 July 2020) (cited as TFC Comments). However, the Lobby considers that these papers significantly under- estimate the seriousness of the threat of COVID-19 in HEIs to public health and safety, and this Response therefore intends to indicate omissions.

Enabling the reopening of the HE Sector

02 SAGE FHE states “Our objectives should be to: enable the reopening of as much face to face provision within the HE sector as possible; and ensure that this does not lead to a resurgence of the disease ...” Like schools and FE institutions, a major concern of HEIs is the safety of their staff and students. Universities UK’s Principles and Considerations: Emerging from Lockdown is devoted to these matters, as are most of the initial paragraphs of SAGE FHE. Meanwhile, TFC Comment 24 notes only that staff as well as students may be affected. SAGE FHE is keen to understand “The potential implications for internal migrations at the start and end of terms, and the relative risk for new cohorts of students in forming new ‘households’ and course groups.” However, SAGE FHE doesn’t say that the clientele of schools and FE is overwhelmingly local – while, on the other hand, every individual HEI recruits nationally (and even internationally), which means their students have to be accommodated. Thus, an immediate major distinction between HEIs and other educational institutions is that there are in fact two locales where health and safety must be considered – the study locale (the campus) and the accommodation locale (where students actually live). These are obviously related, but they are quite distinct, and the latter has several specific features.

03 First of all, large numbers are involved. SAGE FHE does note, “A significant movement of over 1 million students across the country, with potential impact on the transmission of the virus, at the beginning and end of terms,” and is concerned about “the potential impact of such a significant level of movement across the country.” (In fact, there are 1.94 million students in HEIs in England alone (DfE).) But a significant point to add is that these students congregate in large numbers in the local communities which host HEIs. For instance, 6,000 students in Leamington, 19,000 students in Durham, 50,000 students in Nottingham, 75,000 in Greater Manchester, and so on. Such large numbers increase the potential for infection.

04 A second feature of the accommodation locale is the very high degree of mix among the students. SAGE FHE notes, “Students move from their family households to set up new, temporary households during term time” (74% of students do so (DfE).) But important also to note is that universities recruit from the whole country (as well as from overseas), and many students travel great distances to get there (most travel over 50 miles, some 200,000 over 150 miles; 62% of the total were enrolled at a provider outside of their region of home domicile (DfE)). Once arrived, unlike schools and FE, they mix with other students from innumerable different origins – so strongly increasing the opportunities for infection. TFC Comments 31-36 consider segmentation of the university population to reduce risk; but as the paper notes, “this will be more difficult to achieve in universities where students do not already self-select in this way, and for students in private accommodation” (comment 34).

05 Thirdly, in the accommodation locale, the accommodation of students is highly intensive. “This may vary from small shared households with fully mixed living environments [HMOs], to large scale university accommodation blocks [purpose built student accommodation, or PBSA]” (SAGE FHE). PBSA may be on or off campus, but SAGE does not point out that HMOs are entirely off-campus. The former may contain thousands of students. Individual HMOs are relatively small – but commonly a three-bed house is converted to accommodate five or more students, and some HMOs may have ten or more occupants. In all this accommodation, students share basic facilities – for cooking and washing and toilets. Such proximity again vastly increases the chances of infection.

06 Sometimes the accommodation locale of a university may coincide with the study locale, the campus (such as collegiate universities). But in the great majority of cases, the accommodation locale may be near the campus, but it is quite distinct. And it is often entirely embedded among the residents of the host community. The two communities live, not just side-by-side, but one superimposed upon the other – the student community and the local community (this local community will include university staff, another transmission route). Again, proximity offers much increased chances of infection.

07 Finally, the HEIs’ accommodation locales are inhabited by the age group which is most casual about health and safety measures. As young adults, students frequently gather (party) in large numbers, they are poor at physical distancing, and they rarely wear masks (this has been the experience of many of our members since lockdown). Back in their accommodation, their dedication to hand-washing and to deep cleaning of that accommodation may be doubted. This is another factor which makes infection more likely. (SAGE FHE states, “for the purposes of any modelling or assessment of risk, university students should be treated on the same basis as the wider adult population [and] we could expect the pattern of behaviour [if] students remain at home to be broadly the same.” This is patently not the case.)

08 HEIs with their distinctive accommodation locales therefore are quite different from other educational institutions. As such, they are unique in the socio-economic profile of the UK – no other sector is based on its participants living away from home, in second homes. As such, colleges are susceptible to becoming seeding grounds for infection, like care homes or cruise ships, or (as in Singapore) the dormitories for migrant workers – all of which have been catalysts for outbreaks of COVID-19 (see Mack and Yamey).

Ensuring against a resurgence of the disease

09 SAGE FHE notes, “It would be useful to understand what, if any, evidence we may have about the impact of the concentration of students within university towns including on wider social contact and transmission beyond the university.” TFC Comment 44 notes, “The potential for ‘spillover’ into the local community during term-term will depend on the characteristics of the university (or universities) and level of integration with the wider population.” Among the additional risks that do need to be managed, SAGE FHE notes “additional pressure on public transport infrastructure around universities.” But there are many other risks for the local community, not recognised here.

10 As noted above (03), the numbers of students in accommodation locales are large, and they live alongside the resident population (04). In fact, the student community often dominates the local community – in Durham, in Headingley (Leeds), in Nottingham and in Fallowfield (Manchester) for instance, the former outnumbers the latter by two-to-one. In such places, students crowd public spaces, such as shopping streets, and bus and tram stops, endangering residents.

11 In most student accommodation, students cater for themselves. So they use the local shops – indeed, due to their domination, the local economy becomes increasingly geared towards the student market. Local residents necessarily share shopping facilities with students.

12 Students also share all local amenities with local residents, especially eating and drinking venues, cafes, restaurants, bars, pubs, as well as facilities like doctors’ surgeries. There is therefore huge potential for intermixing between students arriving in their accommodation locale and the permanent residents already living there.

13 TFC Comment 43 notes, “Students are also more likely to be integrated with the wider community at their home address than at their term-time address.” But this is in fact not at all likely in light of these local interactions. Students are in fact deeply embedded in their term-time accommodation locales. (An exception is Northern Ireland, where students commute on a weekly basis.)

What we need to do

14 TFC Comment 43 notes, “The group thought that migration at the end of term warranted more attention than that at the start of term, as universities may act as amplifiers. If there is an outbreak at a university (even if not widespread transmission), then students returning home could pose a risk for spread across the UK.” But this overlooks (a) the fact of accommodation locales at HEIs, and (b) the potential for infection raised by these locales. A far more likely sequence of infection would comprise three phases: first, a rapid spread of infection within students’ accommodation, whether PBSA or HMO (due to the vulnerability of the accommodation locale); second, immediate transmission of infection to the local community, due to the predominance of the student presence, and their endemic disregard for social distancing and other guidelines provided by universities, as well as Government; and only lastly, subsequent dissemination of infection nationwide, as students return to their homes at the end of each of the three terms of the academic year (where in fact, personal hygiene and distancing are more likely to be observed).

15 SAGE FHE notes, “the Coronavirus Act 2020 does give the Secretary of State exceptional temporary powers to direct providers to take reasonable steps to secure that specified persons do not attend some/all of their premises,” and “the government [could] choose to exercise these powers to direct universities away from face to face provision.” The Lobby urges SAGE to recommend to government that it use its powers in the interests of the health and safety of HEIs themselves, of the communities who live ‘in the shadow of the ivory tower’ (the study locales of HEIs), and within the accommodation locales of those HEIs, and of the nation at large.

[Dr Richard Tyler, Co-ordinator, National HMO Lobby, July 2020]


Dept for Education, Introduction to Higher Education Settings in England, July 2020, at in-england-1-july-2020

Mack, Katie and Yamey, Gavin, ‘After Cruise Ships and Nursing Homes, Will Universities Be the Next COVID-19 Tinderboxes?’ Time, July 16, 2020, at

National HMO Lobby, at

SAGE Paper on Further and Higher Education 9 July 2020, updated 21 July 2020, published 24 July 2020, at further-and-higher-education-9-july-2020

TFC subgroup of SPI-M-O: Comments on schools and universities Response to DfE commission 8 July 2020, published 24 July 2020, at education-settings-in-september-8-july-2020

Turner, Camilla ‘Universities accused of ignoring local residents’ fears over students returning en masse for Freshers’ Week’ Daily Telegraph, 28 July 2020, at residents-fears-students/

Universities UK Principles and Considerations: Emerging from Lockdown June 2020, at and-considerations-emerging-from-lockdown-june-2020.pdf


The Nottingham Action Group on HMOs wishes to thank those who sent comments about the draft of the Lobby's paper: these were all forwarded on to the Lobby. Our thanks also to the Co-ordinator of the Lobby for putting together a paper that the NAG is happy to endorse, and also to the other members of the Lobby who have been sharing their experiences and ideas with the NAG.

Through you we know that we are not alone!

The NAG has sent the paper to the Director of Public Health (City of Nottingham), to Lilian Greenwood MP (Nottingham South Constituency) and Nadian Whittome MP (Nottingham East Constituency), to the Leader and Deputy Leader of Nottingham City Council, and the portfolio Holder for Communities at Nottingham City Council. It has also been circulated to the NAG's local mailing list with the suggestion that those on the list who do not live in the City of Nottingham may wish to send the paper to their Directors of Public Health and their local Members of Parliament, Ward Councillors and others.

The National HMO Lobby response has been circulated in the hope, rathen than in the expectation, that the information it contains will help to address the concerns so often heard of late in our neighbourhoods (and which we know are shared by others in the HMO Lobby) that, although much is being written and said about how (and quite rightly) to ensure student safety when the new academic year begins, there do not appear to have been similar considerations expressed, at least as far as the NAG is aware, about the safety and wellbeing of the people in whose neighbourhoods students will be arriving en masse in little over a month's time. (*see the Note below)

The NAG is abundantly aware of the fact that there is a risk that there will be a conflation with the anti-social behaviour of a percentage of the student population (the most recent experience of which has been reported on elsewhere on this website). No doubt there are those who will attach the 'anti-student' label as well to this document and to these comments. However, to do so is to under-estimate what is, at time when Covid-19 continues to be a real and present danger, a public health issue, and not one confined to any of Nottingham's so-called studentified areas, or indeed to Nottingham itself.

*Note: As of November 2019, there were 6,701 'student households' in Nottingham solely occupied by students claiming Council Tax student exemption. In addition to being HMOs, these 'student households' also include non-HMO houses and flats in non-student blocks located in and around the city. They do not include university halls and other purpose built student accommodation (PBSA).

Nottingham University provides 4,227 student bed spaces; Nottingham Trent University provides 4,451 bed spaces, and other providers of PBSA contribute another 15,439 bed spaces, totalling 24,117 bed spaces in university halls and other PBSA.