The Planning Policy Advisory Panel of Harrow Council met on Tuesday 11 November 2025 to discuss several key policy documents. The panel considered a scoping report for a potential Article 4 Direction to control the conversion of dwelling houses into small Houses in Multiple Occupation (HMOs), reviewed a scoping report for a replacement Planning Obligations Supplementary Planning Document (SPD), and provided comments on the draft West London Waste Plan.

Scoping Report for Article 4 Direction on Houses in Multiple Occupation (HMOs)

The panel discussed the potential introduction of an Article 4 Direction to remove permitted development rights for converting dwelling houses into small Houses in Multiple Occupation (HMOs). This measure would require planning permission for such changes of use, allowing the council to better manage the impacts of HMOs on local amenity and the well-being of the area. David Hughes, Head of Planning Policy, presented the report, explaining that an Article 4 Direction is a significant step that requires robust evidence and justification, and that the Secretary of State has the power to modify or revoke such directions.

The report highlighted that small HMOs, defined as properties occupied by three to six unrelated individuals, currently benefit from permitted development rights, meaning planning permission is not required for their creation. This limits the council's ability to apply local plan policies concerning issues such as over-concentration, loss of family housing, and impacts on parking and waste management. The proposed Article 4 Direction would address this gap, particularly as the new Harrow Local Plan includes stronger policies to manage HMOs, such as limiting their concentration in any given street.

Councillors expressed strong support for the proposal, citing numerous resident complaints and casework issues related to HMOs. Councillor Stephen Greek, Vice Chair of the panel and Portfolio Holder for Performance, Communications and Customer Experience, commended the report as an excellent piece of work and stated it would be really welcomed by residents. Councillor Graham Henson, Roxburgh Ward, noted the significant private rented sector in Harrow and the potential impact on landlords, but acknowledged the measure's aim to protect the amenity of other residents.

The panel was informed that a non-immediate Article 4 Direction would be pursued to avoid compensation claims, which could arise with an immediate direction. This type of direction comes into effect 12 months after it is made, providing a notice period. The council would need to gather further evidence, including data from planning enforcement complaints, licensing records, and council tax records, to demonstrate the necessity of a borough-wide direction. The process involves notification to the Secretary of State at both the introduction and confirmation stages. The panel requested to note the report's content, provide comments on the proposed approach, and acknowledge the risk of compensation claims and the role of the Planning Committee in authorising the direction.

Replacement Planning Obligations Supplementary Planning Document (SPD)

The panel also received a scoping report for a replacement Planning Obligations SPD. This document will update the existing SPD from 2013 to align with the new Harrow Local Plan (2021-2041), the latest National Planning Policy Framework (NPPF), and the London Plan 2021. Councillor Marilyn Ashton, Deputy Leader of the Council and Portfolio Holder for Planning & Regeneration, highlighted the importance of this document in supporting the new local plan.

The SPD will provide further detail and guidance on how planning obligations, secured through Section 106 agreements or unilateral undertakings, will be used to mitigate the impacts of development. This includes obligations related to affordable housing, transport, public open space, employment and training, sustainable design, flood risk, and biodiversity net gain. The report detailed proposed changes to thematic chapters, including updated guidance on tenure mix for affordable housing, financial viability review mechanisms, and considerations for new housing types such as Build to Rent and co-living developments.

The panel discussed the distinction between planning obligations and the Community Infrastructure Levy (CIL), with officers clarifying that CIL is for strategic infrastructure funding, while planning obligations are site-specific. Concerns were raised about the strength of wording regarding waste disposal within the SPD, with Councillor Greek suggesting it needed to be stronger. Officers explained that waste management issues are primarily addressed through policy and a separate prospectus for new developers, and that Section 106 agreements are more applicable to redevelopment rather than standard conversions. The panel endorsed the proposed preparation of the replacement SPD.

Draft West London Waste Plan

Finally, the panel reviewed the draft Regulation 18 consultation version of the West London Waste Plan (WLWP). This joint plan, prepared by seven West London authorities including Harrow, sets out local policy for waste management development and identifies sites to be safeguarded for waste use. The current WLWP, adopted in 2015, is considered out-of-date and requires updating to align with current national and regional planning policy.

The draft plan aims to manage waste arisings up to 2041, focusing on Household, Industrial, and Commercial (HIC) waste, Construction, Demolition and Excavation (C, D & E) waste, and Hazardous waste. It includes a vision, strategic objectives, and six policies covering site safeguarding, provision of additional capacity, residual waste management, quality of facilities, and the circular economy. Two sites in Harrow, Forward Drive and 151 Pinner View, are identified as safeguarded waste sites within the plan.

The plan indicates that West London currently has sufficient waste management capacity to meet projected needs, with a surplus in most waste streams. The consultation will run for eight weeks from mid-December 2025. The panel was asked to note the report, comment on the proposed consultation arrangements, and provide any comments on the draft plan for consideration in the preparation of the subsequent Regulation 19 version. Councillor Graham Henson raised points regarding the design and operational efficiency of the Victoria Road site, which is owned by the West London Waste Authority. The panel noted the report and its appendices.