COMMENT: Belatedly, I'm posting the comments I submitted to Bristol City Council as part of its consultation on proposals to control the spread of HMOs (Houses in Multiple Occupation).
The consultation closed in mid-March, just as we were all becoming transfixed with Covid19.
My submission is available here.
I supported the basic proposals in the council's Supplementary Planning Document for HMOs but pointed to some areas that need clarification. (To understand those comments, you might need to refer to the SPD itself, which is available here.)
I also suggested a list of practical steps that HMO landlords or developers should be required to implement in order to mitigate noise in or from HMOs—some of which are fairly simple, such as soft closers that would prevent doors slamming and waking neighbours.
Finally, I included a substantial section arguing that council enforcement of existing HMO regulations and noise laws needs to be improved. The section includes detailed comments on the present weaknesses in enforcement in those areas. It's important these issues are addressed because the SPD, while welcome, has a fundamental limitation: Its aim, which is to prevent the creation of "harmful concentrations" of HMOs, cannot apply retrospectively. For residents in areas where "harmful concentrations" already exist, relief from problems such as noise is available only through more-effective application of existing licensing standards and noise regulations.
(I could go further and argue that if enforcement were fit for purpose, the problems the HMO proposals are designed to address would have been nipped in the bud long ago and HMOs wouldn't generate so much anxiety.)
I understand the council has been evaluating submissions over the past few months and the next step will be to publish the public's comments and the council's responses. A final version of the proposals will then go to a further round of consultation later this year.
The council's consultation page, where I assume the next stages will be announced, is here.