# 52 Hugh Road, Coventry

- **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
- **Tags:** tier-2, s4-within-settlement, s4-substantially-outweighed, hmo, supported-housing, parties-consulted-on-2026-framework

## 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
- **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)

## Sources
- https://appeal-planning-decision.service.gov.uk/comment-planning-appeal/appeals/6008646
- https://appeal-planning-decision.service.gov.uk/published-document/68997fca-5623-426e-a629-e75f42a7de25

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Source: https://planningdistilled.org/research/england/nppf-navigator/decisions/PINS-6008646.html

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