Opposition to Proposed Article 4 Direction and Selective Licensing – East Marsh, Grimsby

Reference: Public Submission to North East Lincolnshire Council & Secretary of State

📄 Introduction

Areton Ltd. and our partners have formally submitted the following letter to North East Lincolnshire Council’s Planning and Housing Strategy teams and to the Secretary of State for Levelling Up, Housing and Communities.

This letter outlines our strong objection to the introduction or confirmation of any Article 4 Direction or Selective Licensing Scheme covering East Marsh, Grimsby — until the severe derelict housing crisis in the area has been addressed.

The letter and photographic evidence below are provided publicly in the interest of transparency and community awareness.

📬 Official Letter

To:
Planning Policy & Housing Teams – North East Lincolnshire Council
📧 planning@nelincs.gov.uk | housingstrategy@nelincs.gov.uk

CC:
Secretary of State for Levelling Up, Housing and Communities
📧 Ministerial.Correspondence@communities.gov.uk

Dear Sir / Madam,

I write as a property investor and stakeholder active in the regeneration of East Marsh and Cleethorpes, within the North East Lincolnshire Council area.
I am deeply concerned about the ongoing discussion of introducing an Article 4 Direction for HMOs and expanding selective licensing across East Marsh.

These measures, while perhaps well-intentioned, would in practice discourage investment, prolong vacancy, and worsen an already fragile housing market.

🏚 1. The real problem is derelict housing – not HMOs

The principal issue in East Marsh is the sheer volume of empty, boarded-up, and derelict houses, not a proliferation of HMOs.
A short walk along Harold Street, Wellington Street, Brereton Avenue, Rutland Street, and Weelsby Street shows rows of vacant and neglected properties.

This decay is the result of chronic under-investment, not over-development.
Investment should be encouraged, not red-taped.

💷 2. Current freedom from Article 4 supports regeneration

The absence of Article 4 restrictions is one of the few reasons investors still risk purchasing and refurbishing older housing stock.
If Article 4 were introduced, regeneration would stall immediately — costs would rise, and many homes would remain empty for years.

⚖️ 3. A borough-wide Article 4 would breach national policy

The National Planning Policy Framework (NPPF) clearly states that Article 4 Directions should only be used when necessary and must cover the smallest possible geographical area.
Any blanket or borough-wide Direction would be inconsistent with national policy and open to challenge.

🧾 4. No evidence that HMOs cause problems – in fact, the opposite

Assertions that HMOs cause anti-social behaviour or degrade neighbourhoods are unsupported by evidence.
HMOs are regulated under the Housing Act 2004, and responsible operators maintain high standards.
In East Marsh, the real issue is abandoned housing, not shared accommodation.

🚫 5. Any Article 4 for East Marsh would be indefensible

Photographic and video evidence shows numerous boarded-up homes — proof that the problem is disuse and under-investment, not HMOs.
An Article 4 Direction here would contradict the government’s policy goal of encouraging regeneration.

🏘 6. Consequences of over-regulation

Combining Article 4 controls with selective licensing would:

  • Deter refurbishment and redevelopment

  • Reduce affordable shared housing

  • Leave derelict homes empty longer

  • Increase deprivation and decay

📣 7. Requested actions

  1. Do not make or confirm any Article 4 Direction covering East Marsh or the wider borough until the derelict housing crisis has been addressed.

  2. Withdraw any plan for a borough-wide Article 4.

  3. Encourage investment and rehabilitation through grants, loans, and simplified planning.

  4. Recognise that HMOs are well-regulated and vital for affordable housing.

  5. Engage with local investors to develop regeneration-friendly policy.

A brief walk through East Marsh reveals the truth clearly: empty homes and boarded windows, not an oversupply of HMOs.
This community needs encouragement — not red tape.

Yours faithfully,

Andreas Russo
Areton Ltd.
📧 info@areton-ltd.com

🏚 Photographic Evidence of Derelict Housing – East Marsh

Below are only some of the derelict and boarded-up properties currently visible across East Marsh.
These demonstrate the scale of neglect and vacancy in the area.

Address Image
168 Rutland St
105 Rutland St
49 Tunnard St
Stanley street
Stanley street

(Photographs are for evidence and transparency. All data was collected from publicly visible locations.)

🔗 Future Updates

Should the proposed Article 4 Direction proceed, Areton Ltd. will publish additional photographic and video evidence of derelict housing across East Marsh to further document the area’s true condition.

For any enquiries or to submit additional evidence, please contact:
📧 info@areton.net