SCREENING
Planning for Houses in Multiple Occupation (HMO) – Article 4 Direction
Last updated 25 November 2025
The assessment
New or existing service or policy?
New
Directorate/service area
Strategic growth
Officer(s) responsible for:
- Service/policy/project: Helen Hawkes, Planning Manager
- Completing equality impact assessment: Fred Stuart, Planning Officer
Date
25 November 2025
What is the purpose? What are the outcomes?
The purpose of this report is to provide Cabinet with background information on the current issues relating to Houses in Multiple Occupation (HMOs) in Kidderminster to seek authorisation to make a non-immediate Article 4 Direction. This Direction would remove permitted development rights allowing the change of use from Class C3 (dwelling houses) to Class C4 (small HMOs) within the town. Once confirmed, the Direction would require all proposed HMOs in Kidderminster to obtain planning permission. Therefore, the introduction of an Article 4 Direction will provide opportunities for community members and councillors to comment on potential applications. It will also promote fairer opportunities for families and residents, helping neighbourhoods across the town to thrive and fostering a more balanced, sustainable community for those who live and work in Kidderminster.
Are there any statutory requirements? Who are the main customer groups / stakeholders?
An Article 4 Direction on HMOs specifically refers to powers granted under the Town and Country Planning Act 1990, and it is exercised through the Town and Country Planning (General Permitted Development) (England) Order 2015. The key statutory requirements for making an Article 4 Direction (under the Town and Country Planning (General Permitted Development) Order 2015) include:
- Public consultation – The local planning authority must carry out statutory consultation for a minimum period (usually 21 days).
- Public notices – A notice must be published locally, site notices displayed, and affected parties notified in accordance with the regulations.
- Consideration of representations – The authority must consider any representations received before confirming the Direction.
- Confirmation process – A non-immediate Article 4 Direction must be formally confirmed by the authority prior to taking effect.
- Justification – The Direction must be justified with evidence and meet national policy tests (e.g., necessity to protect local amenity or well-being, proportionality, and covering the smallest area necessary).
- Notification to the Secretary of State – The Secretary of State must be notified both when the Direction is made and when it is confirmed.
The main stakeholders affected by, or interested in, an Article 4 Direction on HMOs typically include:
- Residents and Community Groups
- Property and Housing Sector
- Tenants
- Local Authority and public services
- Wider Community and Infrastructure stakeholders
Who is intended to benefit from this service/policy? How will they benefit?
The Article 4 Direction is intended to benefit residents, local communities, and future occupants of Houses in Multiple Occupation (HMOs) within the town. By bringing the change of use to HMO under planning control, the policy aims to achieve the following outcomes:
Improved quality of the local environment, including better management of waste, parking pressures, and associated impacts on neighbourhood amenity.
Enhanced community well-being, particularly in areas where high concentrations of HMOs have contributed to issues such as noise, disturbance, or community imbalance.
Improved housing standards for future tenants by enabling the Local Planning Authority to assess proposals against relevant space, amenity, and design requirements.
The policy also supports the Local Planning Authority by:
- Improving oversight of HMO provision, enabling better monitoring of the number, distribution, and quality of HMOs across the town.
- Supporting the delivery of safe, good-quality accommodation, which may positively benefit groups who are more likely to live in HMOs, including younger people, lower-income households, and some protected groups.
Overall, the Direction is intended to promote more balanced, inclusive, and sustainable communities while ensuring that new HMOs meet appropriate standards that safeguard the well-being of occupants and neighbouring residents.
What information are you using? What does the evidence show you?
The assessment draws on a range of evidence sources, including:
- Local crime and anti-social behaviour statistics, with specific attention to incidents recorded at or near HMO properties.
- Data and operational intelligence from housing, environmental health, and waste services, including records of complaints and service pressures.
- Parking-related complaints submitted to the Council, particularly in residential areas where smaller HMOs used as supported housing generate higher levels of parking demand than typical family homes.
Taken together, this evidence indicates that:
- A notable proportion of reported crime and anti-social behaviour incidents occur at HMO addresses, particularly in areas where HMOs are concentrated.
- Clusters of HMOs correspond with increased pressures on local services, including waste management and neighbourhood management functions.
- Parking stress is frequently reported in areas with increasing numbers of HMOs, especially where occupancy levels or staffing arrangements differ from those associated with standard residential use.
This evidence supports the need to manage the scale and distribution of HMOs through planning controls to help address these localised impacts.
What impact does the service/policy/project have on the following equality strands?
Protected characteristics: definitions
Before the Equality Act 2010, there were 3 separate public sector equality duties covering race, disability, and gender. The Equality Act 2010 replaced these with a new single equality duty covering the following protected characteristics.
| Characteristic and definition | Impact and evidence |
|---|---|
|
1. Age |
Neutral |
|
2. Disability |
Neutral |
|
3. Gender Reassignment |
Neutral |
|
4. Marriage and Civil Partnership |
Neutral |
|
5. Pregnancy and Maternity |
Neutral |
|
6. Race |
Neutral |
|
7. Religion of belief |
Neutral |
|
8. Sex |
Neutral |
|
9. Sexual Orientation |
Neutral |
|
Other e.g. deprivation, health inequalities, urban/rural divide, community safety |
Neutral: Positive. Evidence: Evidence indicates that the impacts associated with concentrations of HMOs in the town intersect with several wider social factors, including deprivation, health inequalities, and community safety. Deprivation and Housing Conditions Local housing and environmental health data show that areas with higher concentrations of HMOs often coincide with wards experiencing higher levels of deprivation. In some cases, poorer housing conditions and overcrowding within HMOs have been linked to increased service demand from environmental health and housing teams. Ensuring that new HMOs are subject to planning control may help reduce risks associated with poor-quality accommodation, which can disproportionately affect lower-income households and individuals experiencing housing vulnerability. Health Inequalities Evidence from housing and public health teams indicates that substandard or overcrowded accommodation can contribute to negative health outcomes, including stress, noise disturbance, and reduced environmental quality. By requiring planning permission for new HMOs, the Direction supports improved housing standards, which can help mitigate some environmental determinants of poor health. Urban/Rural Divide The evidence shows that HMOs within the authority are predominantly located in the urban town of Kidderminster, with limited presence in rural areas. As a result, the impacts, both positive and negative, are concentrated in these urban locations. The Article 4 Direction therefore, primarily seeks to address urban housing pressures and is not expected to generate disproportionate impacts in rural communities. Community Safety Local crime and anti-social behaviour statistics demonstrate that a proportion of incidents occur at or near HMO properties, particularly in areas where these uses are clustered. Residents have also raised concerns relating to noise, disturbance, and neighbourhood cohesion. The introduction of the Article 4 Direction may help improve community safety by managing concentrations of HMOs and supporting more balanced and stable communities. |
Review
Can any differential impact be justified? (for example, promoting equality of opportunity)
Not applicable
Does any adverse impact amount to unlawful discrimination?
Not applicable
What alternative actions could be taken to mitigate any adverse impact? (Add these to the action plan)
Not applicable
Consultation
Detail any specific consultation on this service/policy (if there is insufficient data, further consultation will need to be undertaken and included in the action plan)
Public consultation will be required going forward
Conclusion
Can the service/policy proceed?
Yes
How will the service/policy be monitored and reviewed? (please give a timescale)
The implementation of the Article 4 Direction will be monitored through the planning application process. All property owners seeking to convert a dwelling into an HMO will be required to submit a planning application to Wyre Forest District Council. This will enable the Council to maintain accurate and up-to-date records on the number, location, and type of HMOs being proposed and approved.
Is a full assessment required?
No
Signed: Fred Stuart, Planning Officer
Date: 25 November 2025