- Decision
- dismissed, 14 September 2026
- Decided by
- Planning Inspector: R Standfield
- Authority
- Coventry (West Midlands)
- Appeal reference
- 6008646
- Application reference
- PL/2025/0001873/FUL
- Procedure
- written representations
- Development
- Change of use of dwelling (C3) to small HMO (C4) for supported housing
- Site context
- inside settlement
- Green Belt
- No
- Framework applied
- August 2026 NPPF
- Determinative policies
- S4(1), P3, TR6(4)
- Development plan policies
- Coventry HMO DPD 2025 HMO2, Coventry Local Plan 2017 AC3, H11
- Main issues
- balance of housing provision; parking
Summary
A C3-to-C4 supported-housing HMO in a Coventry terrace was dismissed. The appellant had not shown the HMO would avoid a harmful concentration, or that parking and visitor demand could be absorbed on a full street. Under S4, the P3 and TR6(4) conflicts were described as "very substantial harm". That outweighed a supported-housing benefit whose need was not evidenced (DL ¶20-22).
What made the difference
Evidence gaps on both sides. The appellant, a social housing provider, gave "minimal evidence" on HMO concentration, need, management and parking (DL ¶8-9, 14, 20). The inspector resolved the uncertainty against the appellant. The finding of "very substantial harm" from a single 4-bed HMO is strong language given the evidence base.
Policy findings
Policy codes are those of the National Planning Policy Framework (August 2026) unless a development plan is named.
| Policy | Finding | Weight | Note |
|---|---|---|---|
| S4(1) | fail | supported-housing benefit reduced for lack of need evidence; P3 and TR6(4) conflicts called very substantial harm (DL 19-22) | |
| TR6(4) | fail | on-street parking already at capacity; no parking survey or care-visitor management evidence (DL 12-15, 21) | |
| HO7 | benefit | reduced weight - no robust evidence of express need for supported accommodation (DL 20) |
Key facts
- HMO concentration within 100m disputed (council 19% against 10% threshold); neither party gave detailed evidence (DL 6-8)
- Article 4 Direction (2023) covers C3 to C4 (DL 4)
Related decisions
Sources
This note is one of the decisions behind the NPPF 2026 Navigator, which shows how each Framework test has been applied across all the decisions in the database. Also available as Markdown.