The local plan says:
"New student accommodation/ HMOs will be required to meet locational criteria to ensure they are not located in areas which already have a high concentration of such accommodation"

I am in strong support of this new policy as it is very much required in areas of south town Leamington.
The problems of unbalanced communities in this area (economic imbalance, loss of amenity e.g. harm to existing residents from noise, rubbish, parking issues etc.) have been well documented.
However I note that there appear to be no details on the "locational criteria" requirements.

My view is that for the goal of maintaining or achieving a balanced and sustainable community, then the locational criteria should focus on the concentration of HMO & student *residents* (rather than the properties) on a street or neighbourhood, since it is the transient residents that are behind the issues, and because the concentration of residents is much usually higher in an HMO or student accommodation than in an owner-occupier household.

Also the policy should encompass a three-fold strategy, including the below as complementary policies:

1) Areas of Restraint
An area within the authority is designated, and within that area, restraints are imposed on certain forms of development e.g. both purpose-built accommodation and student houses. An example is Leeds CC's policy H15 "Area of Housing Mix" - see subnote 2 on the last page of http://www.leeds.gov.uk/docs/pln%2078%20dwelling%20houses%20and%20houses%20in%20multiple%20occupation.pdf .

2) The Threshold Approach
Development proposals for HMOs & student housing should be considered individually, and permitted only if such developments are below a set percentage of properties in a neighbourhood.

3) Purpose-Built Development
Areas within the authority are designated for the development of purpose-built accommodation for students.

All of these policies are necessary, none on its own is sufficient. Areas of Restraint address concentrations themselves. The Threshold Approach tackles developing concentrations. Purpose-built Development is designed to deflate their causes.