Hi All, 

Firstly thank you for supporting this important issue. To date we have been trying to raise awareness via this petition to the potential issues relating to Mary Morris House. 
We have also been in touch with Counsellors and Alex Sobel MP, who worryingly has stated that he supports the plan, but will listen to residents and raise issues with Home Office. 

The main path to opposition right now is technical, and if possible I'd like to ask you to contact the planning department with the below email content, or part of it, to use the specific technical grounds identified to oppose the current plan and force a full consultation. 

Thank you for your ongoing support, every email to planning is another win. 

Please also contact Alex Sobel, and the Headingley Counsellors with your concerns. on the following details. 

MP: alex@alexsobel.co.uk 
Cllr: Jonathan.Pryor@leeds.gov.uk
Cllr: Abdul.Hannan@leeds.gov.uk

Letter to planning - Please copy the below content and email planning on the following email. 

dec@leeds.gov.uk 

Subject: Formal Objection to Certificate of Proposed Lawful Development – Mary Morris House, 24 Shire Oak Road

To: Development Management, Leeds City Council

Dear Sir/Madam,

I am writing to object to the application for a Certificate of Proposed Lawful Development (CPLD) relating to Mary Morris House, 24 Shire Oak Road, Headingley. The Home Office has indicated that it intends to repurpose this site from Purpose-Built Student Accommodation (PBSA) into large-scale institutional housing for asylum seekers.

For the reasons set out below, I submit that this constitutes a material change of use under the Town and Country Planning Act 1990 and associated case law, and therefore cannot lawfully be authorised through a CPLD. A full planning application is required.

 
1. Description of development and existing lawful use
The lawful use of Mary Morris House is as Purpose-Built Student Accommodation (PBSA).
The Grant of Full Planning Permission (Ref. 15/01919/FU, 17 Dec 2015) approved alterations and extensions to provide “41 additional bedrooms to existing student accommodation.”
The Plans Panel Committee Report (17 Sept 2015) assessed the scheme against Core Strategy Policy H6B (PBSA) and justified approval on the basis of its contribution to student housing stock and alignment with student-specific management and behavioural impacts.
A Section 106 package was calibrated specifically to student impacts (Travel Plan, TRO funding, greenspace contribution).
It follows that the lawful use of the site is not a generic hostel or C1/C2 accommodation but PBSA tied to the student housing policy framework.

 
2. Material difference in character of use
The proposed repurposing into asylum accommodation is a material change in the character of the use, with clear planning consequences:

Demographic and occupancy profile: Students typically attend lectures/placements during the day and leave Leeds during vacation periods. By contrast, asylum seekers are not permitted to work, meaning a large daytime presence on-site and in the immediate area. This represents a different land-use character and trip generation profile.
Management regime: The original approval rested on a Student Accommodation Management Plan to mitigate student lifestyle impacts (noise, parties, pedestrian cut-throughs). No equivalent management framework is proposed for asylum housing, and the impacts (safeguarding, safeguarding of vulnerable residents, neighbourhood integration) are fundamentally different.
Neighbouring uses: The site abuts a nursery, a primary school, a care home for the elderly, and sits within the Headingley Conservation Area. The character of interaction between hundreds of young men accommodated in groups of six and these sensitive neighbours is materially different to that of students. This raises safeguarding and cultural concerns that have never been assessed.
Trip generation and pedestrian flows: The Plans Panel Report explicitly considered and dismissed concerns about student pedestrian flows past Hinsley Hall and Shire Oak Road on the basis that they were manageable. The replacement cohort and trip purposes are qualitatively different and require fresh assessment.
 
3. Section 106 obligations and planning balance
The original planning permission was granted on the basis of specific Section 106 obligations: £20,000 for TRO, £30,501.95 for greenspace, £2,500 for Travel Plan measures, all justified by student-related activity.
Repurposing the building to an institutional hostel removes the basis for those obligations and creates an entirely different impact profile, undermining the lawfulness of treating it as the same use.
 
4. Legal test for a CPLD
Under s.192 of the Town and Country Planning Act 1990, a CPLD may only be issued where the use described would be lawful if instituted at the time of the application. The test is objective and based on evidence.

The description of development (15/01919/FU), the policy basis (H6B PBSA), the officer report, and the S106 obligations all confirm that the lawful use of the site is PBSA.
A shift to asylum housing is not PBSA. It is not ancillary to or synonymous with student accommodation.
It therefore cannot be considered lawful under the existing permission.
As confirmed in case law (e.g., Brodigan v SSE [1973], Richmond upon Thames LBC v SSE [1991]), a material change in the character of the use constitutes development requiring permission.

 
5. Amenity and safeguarding considerations
Beyond the legal test, there are substantial material planning considerations which demonstrate why a full planning application is necessary:

Concentration of up to 250 residents, 70% male, in a site where the only pedestrian route to Headingley high street runs directly past a nursery, a primary school, and a care home.
Staff (predominantly young women) and parents with prams must use this route daily. Encountering large groups of men walking in the opposite direction, particularly in the evenings, raises significant safeguarding and community safety concerns.
These amenity and cultural impacts were never assessed in the original PBSA approval and cannot be lawfully assumed acceptable under a CPLD.
 
Conclusion
The proposal to reclassify Mary Morris House through a Certificate of Proposed Lawful Development is unlawful and inappropriate. The differences in use, character, and impact are material.

I therefore urge the Council to:

Refuse the CPLD application on the grounds that the proposed use constitutes development requiring planning permission.
Require the applicant/Home Office to submit a full planning application, supported by:

A comprehensive risk and safeguarding assessment.
A management plan proportionate to the institutional nature of the use.
Updated transport and amenity impact assessments.
An appropriate package of mitigation and Section 106 obligations.
Anything less would deny both residents and asylum seekers the protections afforded by the planning system.

Yours sincerely,

[Address / Contact]