Nottingham Action Group on HMOs
Submitted 2 May 2019

On 31 October 2018 the Nottingham Action Group on HMOs (NAG) submitted comments supporting its objection to Planning Application 18/01082/PFUL3 where the applicant, Mr. Sam Burt, sought permission for refurbishment of, alterations and extensions to the Grove Hotel in order to facilitate the provision of specifically student accommodation: in total 38 student bed spaces. In what we hope helps the Inspectorate, we are including these comments as an appendix to this submission. Also, in view of the fact that this submission is in response to an appeal to the Inspectorate, we hope that a brief background to the NAG and to its principal aims will be of use as a precursor to the additional comments included in this document 

A. The Nottingham Action Group on HMOs. The NAG is a community-based organisation with a network of members who volunteer their time in support of the Group and other members. It formally constituted in 2004 in response to the concerns raised by a large number of people resident in neighbourhoods located across the City of Nottingham about the detrimental impact of demographic imbalance and transient occupancy in their neighbourhoods, primarily, but not wholly, focused on the high concentration of students and the now well-documented problems associated with noise and disturbance, loss amenities (including skewing of the local retail profile), difficulties in maintaining school rolls, and the services which long-term residents and their families need in order to live and work and thrive. 

Over the last 15 years, locally and as a part of the National HMO Lobby, the NAG has actively supported changes to planning legislation enabling LPAs to address issues connected to the balance and sustainability of local communities. It has also supported changes to and local implementation of housing legislation aimed at improving the quality and management of rented accommodation, and ensuring that vulnerable tenants have a safe and secure home for the duration of their tenancies.

B. Additional Comments.In this submission to the Inspectorate the NAG wishes to add to the comments it made in October 2018 in the hope that these will reinforce the reasons given by Nottingham City Council for refusing Mr. Burt’s application.

B1. Balance and Sustainability: There is no evidence that PBSA (purpose built student accommodation), including conversion of existing buildings, has in any way reduced the concentration of students in Lenton, and evidence from the Council’s surveys as well as from other towns and cities with similar problems, supports the conclusion that the proposed redevelopment of the Grove Hotel will merely exacerbate the imbalance in Lenton and further contribute to, amongst others, the amenity issues of noise and anti-social behaviour which are the focus of so much distress for local residents (whether they are long-term, established residents or recently arrived occupants of Nottingham City Homes’ recently completed social housing estate very close to the Grove Hotel) , and which continue to be a barrier to the future development of Lenton.

The NAG draws the Inspectorate’s attention to the judgement in an appeal decision dated 19 October 2017 (APP/Q3060/W/17/3177036) regarding a proposal to erect PBSA at 31 Gregory Street. Although not directly comparable in so far as the proposal for the Grove Hotel is a conversion of an existing building (with additional new-build), whilst that for the 31 Gregory Street site was redevelopment after the demolition of an existing building, the reasons given by the Inspector regarding balance and sustainability and noise and anti-social behaviour we suggest are highly pertinent to this case. In particular we refer to:

Para.20 where the Inspector concludes that: ‘… the proposed scheme, by further increasing student households in the area, would exacerbate the high percentage of such households and cause material harm to the social mix and fabric of the area. …

Para.22 where the Inspector points out that ‘… there would be little control over any noise and disturbance occurring late at night from students once they have left the property or when they are returning. A development housing 43 students would be capable of generating a significant number of movements to and from the building. … late night activity associated with students and visitors leaving and returning … is likely to material increase noise and disturbance in the area to the detriment of the living conditions of local residents.’

In fact not only is the Grove Hotel only a short distance away from 31 Gregory Street, but, as is all too apparent, the anti-social behaviour experienced by local residents is not confined to the immediate vicinity of a student property, or group of properties: it is a peripatetic as the tenants themselves are and is experienced over a much wider area and by many more residents living in other neighbourhoods.


B2. Design: The NAG supports Nottingham City Council’s conclusions about the impact of the proposed extension on the character and appearance of the existing building, on the streetscene as a whole, and on the amenities of the neighbouring property. We also support the conclusion that the lack of vehicular drop off/pick up facilities, etc. within the curtilage of the site is detrimental to highway and pedestrian safety.

However, our concerns are not limited to this particular aspect of the application. The NAG is very much concerned about the quality of the accommodation on offer, the lack of amenity space, the lack of management facilities and proposals, and the lack of any genuine communal facilities. These points, and the latter is particularly significant, highlight the paucity of concern for the welfare and safety of what is a cohort of young, inexperienced and really rather vulnerable tenants.

It is sad to reflect on the fact that there is an increasing awareness on the part of the universities, the local authority, residents like ourselves, and those developers who are socially aware and responsible, that, for whatever reason (and no doubt there are many) students, are experiencing increasing amounts of stress and isolation, doubly so if they have come from societies with very different social and behavioural norms, and whose communication skills are limited.

The proposal for the Grove Hotel shows a singular lack of appreciation for the responsibility of the developer to ensure that what is being developed and its future management is fit and proper for its intended purpose rather than merely a cynical attempt to capitalise on an investment by claiming to (a) provide accommodation for students; (b) provide the wider society with a public amenity (the ground floor public house).

Yes, the proposal will provide accommodation for students, but accommodation that is not fit for purpose in the developing student housing market. Yes, it will provide a public house, though it is questionable as to how much of an amenity it will be for the wider public bearing in mind that it will have no on-site parking space, and that, in spite of the large student population in the area, as a business concern/public house, the Grove Hotel failed. 

Concluding Remark: The NAG supports the re-use of the Grove Hotel building. However, we cannot support its redevelopment and conversion into student purpose built accommodation. Rather, after consultation (which we would be glad to help to facilitate) between the owner/developer and the local community, we would be prepared to support a scheme which brings good-quality apartments for a less transient and potentially more affluent clientele than that provided by the student market, and which can assist in rebalancing and restabilising Lenton as a whole.

Comments by the Nottingham Action Group on HMOs (NAG) on Planning Application 18/01082/PFUL3
Grove Hotel, 273 Castle Boulevard, Nottingham NG7 1HS

This application seeks permission for a refurbishment of the existing Grove Hotel building and ground floor retention of a public house, whilst converting the upper two floors and the existing loft space into student accommodation. In addition, the applicant wishes to erect new, purpose built student accommodation as an extension to the original building. In total, the applicant envisages the provision of 38 student bed spaces.

By and large, the NAG is sympathetic to planning applications which aim to refurbish, rather than demolish, buildings which have character, but which are no longer fully able to fulfil the use for which they were originally built. In this instance the application refers to a late 19thCentury building, the Grove Hotel (or Grove Public House), which has been vacant and boarded up for a number of years. In principle, therefore, the fact that the applicant wishes to retain the structure of the Victorian building and, in part at least, its use as a public house, is something the NAG would want to support. However, there are aspects of this application which make it difficult for the Group to do so.

Student Accommodation: The applicant has not submitted any support in this application to show that this location is suitable for student accommodation.

Lenton is quite regularly described as the ‘epicentre’ of studentification in Nottingham, and no area of Lenton more so than the streets around Lenton Boulevard, Castle Boulevard and Abbey Bridge where the concentration of student accommodation in HMOs is substantially higher than the threshold set out in the Building Balanced Communities SDP.

Although significant development of purpose built accommodation (new build and conversion of existing buildings), particularly around the city centre, has resulted in students moving out of HMO accommodation in parts of the city, the evidence is that this is not happening in Lenton. Therefore, it is highly questionable whether the student accommodation proposed in this application will in any way contribute towards the restoration of balance and sustainability to Lenton. In fact, it is more than likely that it will merely add to the imbalance, potentially attract more students into the area and in doing so will exacerbate the well-documented problems which Lenton’s long-term residents are being required to deal with.

Put simply, and brutally, Lenton is almost saturated with students, and to permit this development to take place will not only increase the number of students, but will encourage other casual developers to put in applications to convert other premises into yet more student accommodation.

However, the NAG has looked beyond the unsuitability of student accommodation in this area, and has considered the application in more detail, and it wishes to raise further concerns about the proposals.

Design Considerations. We believe there are a number of aspects of the proposed design which need to be considered in light of the proposed use of the building and the extension, and which have not been sufficiently well addressed. Prime amongst these is that noise and amenity considerations connected to the location of the development of living accommodation above and alongside the public house have not been sufficiently dealt with.

There is a distinct lack of amenity space (internal and external). For example, the location of the communal areas on the ground floor does not:

            (a) provide a safe, inclusive and healthy environment;

            (b) provide for clear and easy movement through and within the new development area.

Furthermore, there are concerns about the lack of features which could be incorporated into the design in  order to reduce opportunities for crime, fear of crime, and anti-social behaviour. There are a number of dark and unmanned areas within the design which will provide opportunities for anti-social behaviour. This concern is amplified by the fact that there does not appear to be any provision within the design for office accommodation associated with  management of and assistance for the tenants.

In addition, attention is drawn to the fact that, in it current form, the proposed development does not provide for any disabled students, and does not provide disabled parking spaces. Neither does it provide any drop down parking spaces for turnover of students at the start and end of terms. Given the location of the site on a main transport route, close to a very busy roundabout, these spaces should be provided as pat of the safety and accessibility of the development. Therefore, the applicant should be prepared to provide a safe and secure vehicular access to the site.

Another consideration is that there will be many students, particularly those coming from overseas, who, for a variety of social/religious reasons, will not want to have accommodation above, or alongside a public house. This is a particularly significant point to make since the applicant has made the statement that ‘… we have acknowledged the need for purpose built self-contained units, which has a huge appeal to overseas students as it can be extremely intimidating for foreign students being forced to socialise in new surroundings. …’

Clearly, what the applicant has done is identify a lucrative market, but has not gone in depth into what the provision of what first class, safe and desirable student accommodation really means. In this, the applicant is no better than many of the opportunistic and unprofessional HMO landlords who have over the years profited at the expense of their tenants and the rest of the community.

Although it may not be a direct planning consideration, we also question what the applicant may do in the not too distant future should the public house part of the development fail, as the original Grove Hotel public house did? It is of course a matter conjecture, but we have to consider the possibility that, in due course, the applicant will submit a second application to convert the ground floor into student accommodation.

Alternative Use. As we have already stated, we are supportive of the idea that by redevelopment the Grove Hotel building can be saved from demolition. Our own suggestion is that the application would be welcome if it were it to be redesigned to provide good-quality accommodation for non-student residents. Of course this would require the provision of, in addition to bedrooms,  kitchen, utility, bathroom and lounge facilities within each apartment, long with, in addition to the other issues we have raised, sufficient sound proofing.

The applicant has gone to great lengths to highlight the location of the Grove Hotel, the retail and other provisions available in the area, transport links, etc. It is unfortunate that the applicant has not seen that the factors favouring student accommodation which have been highlighted in the application, are equally applicable to the redevelopment of the building as apartments for a less transient and, probably, more affluent clientele, which would serve to assist in the rebalancing and restabilising of Lenton as a whole.

The Nottingham Action Group on HMOs asks Nottingham City Council to reject this application in its present form and, if at all possible, to engage with the applicant in the development of a more suitable residential scheme for the Grove Hotel.