CONSIDER NOTICE OF REVIEW REQUEST: 24/0014/LRB: Grianaig, Lochawe, PA33 1AW (REF: 23/02065/PP)
Argyll and Bute Council · 8 October 2024
Back to Argyll and Bute Local Review Body — 8 October 2024 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Page 1
1 24/0014/LRB Response to Council’s Statement of Case Argyll and Bute Council Local Review Body 24/0014/LRB Planning Permission 23/02065/PP Applicant’s Response to Representations made by Planning Authority, Consultees and Interested Parties Further to the email from Hazel MacInnes, Senior Committee Member, Legal and Regulatory Support, Argyll and Bute Council, to me dated 29th August, I thank you for the opportunity to respond to the representations made by the Argyll and Bute Planning Authority (Planning Authority) and interested parties. This request for review relates to Condition No.5 attached to the planning consent 23/02065/PP, namely: 5. The development hereby permitted shall be occupied solely as two residential flats for permanent occupancy. No part of the development shall be utilised as a short-term holiday let (or lets) without the express permission of the planning authority through the submission and approval of a planning application in that regard. Reason: To reflect the development applied for, as confirmed by email dated 16th May 2024, and in order to comply with NPF4 Policy 30 which seeks to prevent the loss of existing permanent residential accommodation to short-term holiday letting uses. Statement of Case (by Planning Authority) A Statement of Case (SoC) was sent as an attachment to the email of 29th August 2024, referenced above, which I will assume is from one of the Council’s planning officers. However, the SoC is not signed and there is no name or designation attached to it. Having read this SoC there are a number of issues which I would like to respond to (these are in addition to my original statement which is reproduced in Appendix 1 of this document): i. Firstly, I must state for the record that at no time did I seek to be ambiguous or to obfuscatory, in any way, in relation to the proposed development or how the residential property might be used. It is very disappointing that the author of the SoC has levelled a personal accusation at me of ambiguous and obfuscatory behaviour in the SoC, inferring underhanded behaviour. I do not know how this conclusion was arrived at and I would have expected a more professional approach from the author of the SoC. Phrases such as “it is unrealistic and unreasonable to expect the planning officer to somehow divine the unrevealed intentions of the applicant” are not what I would have expected to read in a Statement of Case document. ii. As background information I would like the Local Review Body to know that I have previously engaged with the planning process in Argyll and Bute over a period spanning more than 20 years and have successfully created some high quality developments including the conversion of a derelict barn to form a dwelling house (which won a design award from Argyll and Bute Council), erection of a new dwelling house and erection of 2 eco-cabins. In all of these cases I have sought the advice of the Planning Authority at an early stage and responded to any changes sought by the Planning Authority. I have always taken a professional approach which has continued in relation to the current proposed development.
Page 2
2 24/0014/LRB Response to Council’s Statement of Case iii. I would also like to take this opportunity to confirm, once again, that it is not currently my intention to use the proposed development at Grianaig for short-term holiday letting (STHL). It is not a development “specifically for STHL use” as the author of the SoC seems to think and I am confused as to how this view was arrived at. Notwithstanding this, the use of the proposed development may change in the future in response to changing economic circumstances or due to a change in ownership of the proposed development and this is one of the reasons that I am seeking the removal of the restriction imposed by Condition No 5. I state again, that as far as I can ascertain, no other consent for new residential development in the Argyll and Bute Council area has had such a condition attached to it and it would appear that Condition No. 5 has been an arbitrary decision in relation to the proposed development at Grianaig. The author of the SoC has stated that “Condition 5 is a minor variation to one of our standard planning conditions and is widely used where appropriate to do so”. (Please note that I was unable to check the veracity of this statement as I was advised by Argyll and Bute Council Planning Department on 10.09.24 that it does not have a published list of standard planning conditions). Whether Condition No. 5 is minor variation of a standard planning condition or not, the fact remains that Condition No. 5 has, as far as I can determine, never been used in relation to any other development proposal. iv. The Planning Authority’s SoC is helpful in that this is the first opportunity that I have had to see the explanation as to why the Planning Authority has chosen to apply Condition No. 5. The author of the SoC is clearly of the view that the onus was on me to clearly state whether I intended to use the property for STHL and by not doing so I was being ambiguous and obfuscatory. This is absolutely not the case. The SoC says that: With hindsight, one might consider it unfortunate that the case officer did not seek to robustly clarify the ambiguities inherent in both the pre-application submission and the subsequent planning application and to insist on a direct and unequivocal clarification of the exact specifics of the proposed development at an earlier stage. I would absolutely agree that this is indeed unfortunate. I would have expected that if the prospect of any future use as STHL was critical in the determination of the application, that the Planning Authority would have enquired this of me at the pre-application stage, where we pay a fee for expert local planning advice, at application stage when validating the planning application and agreeing the description of the development or during the course of discussions. Only at the 11th Hour was this raised, in an email dated 15th May 2024. The SoC does not give any explanation of how or why potential use of the proposed development as a STHL suddenly became a relevant matter. The author of the SoC states: …this matter was finally resolved when the area team leader intervened prior to signing off the officer’s ROH [Report of Handling]. I can only conclude that it was the area team leader who introduced the idea that this proposal may be for STHL.
Page 3
3 24/0014/LRB Response to Council’s Statement of Case v. The purpose of the ROH is to set out the considerations relevant to the determination of the planning application including all the relevant plans and policies. If NPF4 Policy 30 became a material consideration, albeit at the 11th hour, then this should have been assessed in the ROH. Each relevant policy of NPF4 is afforded a detailed description and statement of how the proposed development has been assessed against it. NPF4 Policy 30 has no such assessment in the ROH. The SoC seeks to explain why the policy was not included in the ROH: The ROH does not mention NPF4 Policy 30 simply because the policy was not relevant to the development as proposed at the time. Had the planning application been submitted on the basis that the intended use of the development was for STHL units then Policy 30 would have been a material planning consideration and would have carried substantial weight. It is an unfounded assumption, that has been made by the author of the SoC, that the intended use was for STHL. In response to this I would refer to my comments at paragraphs iii. and iv. above. At no point did I change the development proposal yet it is inferred that I did. The only change that was made was to the description of the development from that which was originally validated. Original validated description: Amendments to and extension of existing two storey room in roof dwelling to form 2 apartments. Revised Planning Authority description: Alterations to existing dwelling house to form 2 residential flats. This change was made by the planning authority without any consultation with me and without explanation. The application was not changed by me at any time. I consider that it is not reasonable to attach a condition to the planning consent in the absence of any mention of, or assessment against NPF4 Policy 30, on which it relies, and I do not accept the explanation that NPF4 Policy 30 was introduced to reflect a change in the application. I would also contend that if Condition No. 5 was not relevant to the development as proposed at the time (I can only assume that the “time” being referred to is on completion of the ROH), and there has been no change to the development, then it cannot be relevant to the planning decision and should be removed. vi. The SoC advises that STHL is a sui generis use of a building, meaning that it is a use class entirely on its own. I was not previously aware of this definition, which has prompted me to investigate further. I have consulted The Scottish Government’s STHL -Planning Guidance for Hosts and Operators which states that: It would be expected that a change of use between classes and sui generis uses and from one sui generis use to another would represent a material change of use and so require planning permission.
Page 4
4 24/0014/LRB Response to Council’s Statement of Case I would conclude from this guidance that it would depend on whether the planning authority considered that STHL was a material change of use. It would seem that by imposing Condition No. 5 on my proposed development, that the Planning Authority has already decided that a change of use to STHL in this case would be a material change of use, without undertaking any assessment, and that STHL would be a materially different development to residential development. The Scottish Government’s Planning Guidance sets out what would constitute a material change of use in relation to STHL. These are set out Sections 2.18 to 2.31 and are reproduced in Appendix 2 of this report. My proposed development has already been assessed as conforming to national and local policies on sustainable and high-quality places, connected places, sustainable communities and high-quality environments. It is possible that the scale, design and location of my proposed development, should I ever propose to use it for STHL, would not result in a material change of use. However, the time to consider this would be if I, or any future owner, ever decided to use the property for STHL, when the Planning Authority could objectively consider the matters listed in Appendix 2, to determine whether a change of use to STHL would constitute a material change requiring planning consent. As the author of the SoC correctly states in the conclusion: It remains the assessment of the planning authority that any future use of the building from the 2 residential flats approved under planning permission 23/02065/PP to a use consisting of STHL Units in a flatted residential block is, at time of writing likely to require planning permission and will be subject to an appropriate assessment against the planning policies in force at the time. I accept that this outcome may be likely. However, is not certain and I see no justification for the imposition of Condition No. 5 which potentially places an undue requirement on my proposed development and a restriction in its use. vii. I have undertaken research on where STHLs have required planning permission for change of use, in order to assess the likelihood of the need for a future planning application should I, or any future owner, wish to apply for a change of use to STHL. According to Argyll and Bute Council’s public register of Short Term Let Licences there are currently (as of 09.09.24) 254 licences that have been approved for self-contained flats. Of these approved licences, only 19 planning applications have been made for a change of use from residential self-contained flats to use as STHLs. This suggests that the likelihood of requiring planning permission for a change of use to STHL is small, as only 7% of STHL have been required to obtain planning consent. I would also conclude that the overwhelming majority of STHL licences for self-contained flats, namely 235 out of 254 properties, did not represent a material change of use and that no planning permission has been required. Further scrutiny of planning applications for change of use to STHLs reveals that of these 19 planning applications, 14 have been given planning consent. However, 5 have been
Page 5
5 24/0014/LRB Response to Council’s Statement of Case awaiting a decision for over 1 year because the Planning Authority has stated that it is still developing its policy position in relation to STHL. This is another reason that I consider that Condition No. 5 should be removed, as it seems that Planning Authority policy is emerging and there is uncertainty as to whether planning consent will be required in the majority of cases. Currently it can be concluded that planning permission is not required for the majority of STHL Licenses. viii. Finally, I would like to make comment on the concerns expressed by neighbours of Grianaig. I acknowledge that there was a single, unfortunate incident as a result of an impromptu party in the summer of 2018, which resulted in disturbance to neighbours. However, there has been no recurrence of such anti-social behaviour in the 7 years that have elapsed since the incident. The proposed development incudes installation of a new septic tank addressing the concerns raised regarding this issue. It is also worth noting that Grianaig is not in a “relatively dense residential area” as referred to in the SoC, as it has significant open space between detached properties. Should a STHL Licence be sought at any time in the future, by me or a future owner of Grainaig, management measures to ensure that there was no disturbance to neighbours would be required to be put in place by the STHL licence. Indeed, any good neighbour would want to ensure this as a matter of course. ix. Conclusion I would request that the Local Review Body removes Condition No. 5 from planning permission 23/02065/PP for the following reasons: ▪ There has been no change to the development originally proposed in the pre application enquiry, and Condition no 5 has been imposed based on unfounded assumptions made by the author of the SoC that it is my intention to use the proposed development for STHL. ▪ NPF4 Policy 30 was not considered relevant to my original planning application, that is why it was not mentioned in the ROH. Therefore, it cannot be relevant to apply Condition No. 5 to the planning consent for my proposed development. ▪ No other planning consent, that I can find, has a similar restrictive planning condition like Condition No. 5, applied to it. The consequences of Condition No. 5 are that I would be required to go through a potentially unnecessary further planning process and that the value of the proposed development would be negatively impacted by restricting its use to permanent residential use only. Regarding the latter consequence, I would have to reassess the impact of the restriction on development risk and question whether undertaking the proposed development was worth the investment. ▪ The overwhelming majority of self-contained flats with STHL licences in Argyll and Bute have not been required to obtain planning permission for a change of use to a STHL. Therefore, I conclude that the operation of the associated properties as
Page 6
6 24/0014/LRB Response to Council’s Statement of Case STHLs has not been considered a material change of use, and this could also potentially be the case with Grianaig. ▪ The Planning Authority has stated that its policy in relation is change of use from residential to STHL is still emerging. Therefore, it would not seem reasonable to impose a restrictive condition, like Condition No. 5, in this uncertain policy environment. ▪ The author of the SoC, in the conclusion, states that if the decision of the Local Review Body is to remove Condition No. 5 that, in any event, the proposed change of use to STHL would likely require planning permission. I would therefore question why the condition was imposed in the first place. I simply wish to be on a level playing field with all other property owners in Argyll and Bute. Should I, or any future owner, of the property wish at any point in the future to use the property for STHL, the relevant procedures in place at that time would be followed and any proposition would be assessed against the relevant policies prevailing at the time. This may or may not include a planning application (see paragraph vii). Currently, with Condition No. 5 I am being disadvantaged by imposition of a potentially unnecessary planning process and a potentially negative impact on the future value of the proposed development. I trust that I have made a reasoned justification for the removal of Condition No. 5 from planning consent 13/02065/PP. Should the Local Review Body require any further information from us we would be happy to provide this. Tracey Peedle 11th September 2024
Page 7
7 24/0014/LRB Response to Council’s Statement of Case Appendix 1 Planning Application 23/02065/PP Statement for Local Review Body Background Grianaig is located in the village of Lochawe and was built circa 1940’s. We purchased this house in 2018. The previous owners had used this as a holiday home. The house is not constructed to modern standards and is in need of refurbishment. In considering refurbishment and extension of our property, Grianaig, Lochawe we undertook a pre application planning enquiry with the Planning Authority in January 2023. The purpose of this was to identify any issues which may prevent or constrain our proposed refurbishment and development. The Planning Authority issued a Pre Application Advice Report on 10th February 2023. This report requested some design changes, but we were encouraged that no significant constraints were identified and following a positive response from Transport Scotland we decided to proceed with a formal planning application, incorporating the design changes requested. The Pre Application Advice Report identified no significant constraints and made no mention of Short Term Letting being part of the consideration of any future planning application Based on the pre application advice, we applied for consent to refurbish and extend our property in October 2023. After a very elongated process, largely due to the unexpected and costly requirement to conduct a flood risk assessment, planning consent was granted in May 2024. Description of Proposed Development The description of our proposal was set out in our planning application form as: “Amendments to and extension of existing two storey room in roof dwelling to form 2 apartments” This description was validated by the Planning Authority and we proceeded on this basis. When the Decision Notice and the Report of Handling were issued, it was a surprise to us that the Planning Authority had changed the description of the development to: “Alterations to existing dwelling house to form 2 residential flats” We were not advised or consulted on this and are not sure why the Planning Authority chose to change the description of the development. We raise this because one of the reasons for imposing Condition no 5 on the planning consent was stated as “to reflect the development applied for”. We applied to form 2 apartments, not 2 residential flats. Planning Condition No 5 and Short Term Letting The Planning Decision Notice which was issued has the following condition attached to it: “ 5. The development hereby permitted shall be occupied solely as two residential flats for permanent occupancy. No part of the development shall be utilised as a short-term holiday let
Page 8
8 24/0014/LRB Response to Council’s Statement of Case (or lets) without the express permission of the planning authority through the submission and approval of a planning application in that regard. Reason: To reflect the development applied for, as confirmed by email dated 16th May 2024, and in order to comply with NPF4 Policy 30 which seeks to prevent the loss of existing permanent residential accommodation to short-term holiday letting uses. This condition represents a considerable restriction on the property, which is not consistent with decisions on similar planning applications in Argyll and Bute and does not have any local development plan policy justification. We request that this condition is removed from the planning consent. The likelihood of imposing such a restriction on the property was not raised in the Pre Application Advice Report or throughout any on-going discussions with the planning officer. Had this been the case, we would not have proceeded with the planning application, but we were never given this opportunity. Restricting the use of the property to permanent occupancy and requiring planning consent for short term letting, would have a negative effect on the value of the property and therefore makes the significant investment required unviable. We were only advised in a telephone conversation with the planning officer and subsequent email dated 15th May 2024 that the development would not be supported if it was to be used as a short term let. At this late stage having gone through a very elongated and expensive planning process we advised that currently it is not our intention to use the apartments for short term letting. We would however wish to have the option to consider this in the future on the same basis as every other householder in Argyll and Bute. The Short Term Let Licensing process is the correct process in Argyll and Bute through which to apply to use a property as a short term let and we understand that we would need to go through this process if we were to consider short term letting in the future. There are no Short Term Let Licence Control Areas designated in Argyll and Bute. Separate planning permission is not currently required in Argyll and Bute, as it is in some local authority areas who have designated Short Term Let Licence Control Areas, to use a residential property for short term letting. If we wished to use Grianaig for short term holiday letting right now we, along with all other property owners in Argyll and Bute, would not need planning consent and so it is difficult to see why this would be required if we implemented the refurbishment and extension that we propose. We therefore consider that it is not reasonable to impose this planning restriction on us. We have undertaken some research, via the on-line planning portal, with a view to establishing how restrictive planning conditions have been applied to other similar developments in the Argyll and Bute Council area. Having looked at recent decision notices for new houses, replacement dwellings and alterations (see attached), we cannot find one instance of a planning condition relating to restricting use to permanent residential development and requiring an additional planning application for short term letting. No other similar development proposal in Argyll and Bute has before or since had this type of restrictive planning condition applied. We would therefore wish to know why it has been applied here. During the public consultation process, a neighbour raised some concerns regarding the potential use for short term letting and we were asked to respond to this. Our response was that should we consider using the property for short term letting then this would be considered through the short term letting license process, during which neighbours would be notified and
Page 9
9 24/0014/LRB Response to Council’s Statement of Case any potential issues would be dealt with though this process rather than the planning process. This was accepted by the Planning Officer Our position on this is supported by the consultation response from Environmental Health. Environmental Health raised no objections to the proposed development, but requested that plans be put in place to reduce noise if short term letting was proposed via the licensing process. Environmental Health did not request any restrictive conditions be applied to the planning consent that prevented use for short term letting. NPF4 Policy 30 The primary reason for imposing condition no 5 of the planning consent is stated by the Planning Authority as “to comply with NPF4 Policy 30”. This was a surprise to us as this policy was never mentioned as being relevant to our proposed development prior to the telephone conversation and subsequent email on 15th May 2024. If it was relevant to our proposal it would have been a material consideration that should have been identified in the Pre application Planning Advice Report. It was not. Even more surprising is that The Report of Handling for the planning application makes no reference to NPF 4 Policy 30, either under the list of relevant policies against which the planning application has been assessed, or elsewhere in the report. This leaves some unanswered questions: 1. At what point did NPF4 Policy 30 become a material consideration in assessing our planning application? 2. What detailed assessment of our proposal has been undertaken against this policy? 3. Why has this condition not been applied to other similar developments? It is therefore difficult to see how NPF Policy 30 is applicable, and consequently how it is competent to apply a restrictive planning condition based on this policy. NPF4 Policy 30 only applies to existing residential property and the planning authority had previously taken the view that our proposal constituted new residential development. When SEPA were consulted on this planning application they deemed that the development we were proposing constituted new residential development and was not considered to be an extension of an existing property. The Planning Authority agreed with SEPA on this, and did not accept our argument that our proposals related to an existing development. Consequently, we were required to undertake a flood risk assessment, at considerable cost. If our proposals were considered as alterations to an existing residential property then no flood risk assessment would have been required and we would not have had to spend £5,000 on one. As the Planning Authority agreed that the application was a new residential development, then the justification for imposing the restrictive planning condition cannot apply as NPF 4 Policy 30 is applicable only to existing residential development. CONCLUSION We conclude that it is not reasonable or competent to apply condition no 5 to our planning consent: 1. Restricting our proposed development to permanent occupancy and requiring additional planning consent for use as short term letting, was never mentioned as a material
Page 10
10 24/0014/LRB Response to Council’s Statement of Case consideration in either the Pre Application Advice Report (10th February 2023) or the Report of Handling (28th May 2024). If it was a relevant consideration then it should have been fully considered in the planning application and determination process 2. If we had been advised at the pre application stage that the proposals would be restricted to permanent residential development and that further planning consent would be necessary if we wished to consider short term letting, we would not have proceeded with the planning application and incurred the significant costs associated 3. No other planning decisions for dwellings in Argyll and Bute Council have had conditions applied that require planning consent the use for short term letting. It is therefore difficult to see why this applies to our development 4. Currently, without undertaking any refurbishment, Grianaig could be used for non permanent residential development and short term letting (subject to the necessary licence) without the need for planning consent. It is therefore difficult to see why such restrictions should apply to the property if it is refurbished and extended 5. The Planning Authority had previously taken the view that our planning proposal constituted new development, in which case NPF4 Policy 30 is not applicable, as it applies to existing residential development We request that the Local Review Body remove planning condition no 5 from the planning consent 23/02065/pp Grainaig, Lochawe PA33 1AW. Tracey Peedle 7th August 202
Page 11
11 24/0014/LRB Response to Council’s Statement of Case Appendix 2 The Scottish Government Short term Lets - Planning Guidance for Hosts and Operators 2.18. Examples of material planning considerations in relation to short-term lets are set out below. This list is not intended to be either exhaustive or definitive; there may be other material planning considerations that are relevant in any particular case. This list is based on those matters which have been identified as material planning considerations in both: • determining previous planning applications; and • appeals against enforcement action taken against unauthorised changes of use. Guest arrivals and departures 2.19. Relevant considerations here include: • guest access to communal areas such as stairwells and gardens; • access to the property by the host (if they do not live there) and other service providers for maintenance and cleaning etc.; • guest arrival and departure times and whether these are at unsociable hours; 2.20. The impact on amenity for neighbours, for example caused by noise at unsociable hours, is likely to be greater in a tenement, an apartment building or similar, where stone or equivalent hard surfaces may amplify noises and cause echo. The greater the impact, the more weight might be expected to be given to it. Particular impacts on other residents in flatted buildings 2.21. Relevant considerations here include: • any reduction of physical security of a building, for example where key boxes are used; and • actual and perceived increased risks to permanent residents from guest access to communal areas. Likely frequency and intensity of noise or otherwise unsociable behaviour 2.22. Where issues arise from the behaviour of a permanent resident, a neighbour could approach the resident (or their landlord) directly or through a residents' group. They are more likely to achieve modification to problematic behaviour, either through establishing a rapport and understanding with the problematic resident over time or seeking sanctions through the landlord, council or the police, in more serious cases. The high turnover of guests in short-term lets requires new people to learn and observe the proper behaviours and increases the chance of some people wilfully or negligently failing to behave appropriately. 2.23. Where the host is letting out one or two rooms in their own home, it would generally be expected to have a lesser impact because: • the host is more likely to be known by neighbours (because they also live there);
Page 12
12 24/0014/LRB Response to Council’s Statement of Case • the host has a stronger direct interest in respecting neighbours' rights and • the host has more opportunity to monitor guest behaviour. Impact on public services and residents' amenity 2.24. Relevant considerations here include: • more household waste than would be expected from residential use, leading to full or overflowing bins (possibly leading to littering and vermin) and more journeys to the bins; • pressure from guests' cars on availability of on-street parking to neighbours and pressure on residents' private parking spaces; and • likelihood of increased noise and general disturbance compared to the occupation of the property on a permanent or long term residential basis. Cumulative impact on the character and amenity of a neighbourhood 2.25. The cumulative impact means the effect of a significant number of homes being used for short-term lets in the neighbourhood. The meaning of a significant number will depend on matters including the size and layout of the neighbourhood. 2.26. Relevant considerations here include: • the impact on the availability of affordable and appropriate housing for local residents; • the impact of seasonal variations in numbers of people in the local area, for example whether it is too overcrowded in the summer for everyone to be well-served and too empty in the winter to sustain local amenities; and • the difference in activities of guests compared to residents. 2.27. This latter point can affect the viability of local businesses and shops which are used by residents and their access to these amenities. For example, guests are more likely to spend time recreationally (e.g. outdoor sports and restaurants) than functionally (e.g. hardware stores). Guests may also have different food shopping habits than permanent residents, possibly bringing provisions with them rather than using local food retailers. Number of people staying 2.28. More people in a dwellinghouse are likely to have more impact on neighbours. Greater numbers of people staying are likely to be an amplifying factor on the previous considerations. 2.29. The number of people staying in a dwellinghouse can increase for any number of reasons, for example a couple having children, partners and their dependents moving in or a house being sold or let to a different household. The larger or new household may make changes to the dwellinghouse to increase the capacity. Hosts or operators may also want increase the capacity of a dwellinghouse used for short-term lets to accommodate more guests. 2.30. The permanent household or the short-term let host or operator might want to create additional sleeping accommodation by converting, subdividing or partitioning rooms by, for example: • converting public rooms (such a living room) to bedrooms; • using bunk beds in place of single beds; and
Page 13
13 24/0014/LRB Response to Council’s Statement of Case • partitioning a large living room or bedroom in order to create two bedrooms. 2.31. In terms of use as a short-term let, the relevant considerations include: • whether the capacity changes the nature of the use, for example accommodation for twelve guests may be more likely to be booked for stag and hen parties than accommodation for four guests; and • whether the capacity is significantly larger than that which might reasonably be expected for residential use, for example six bunkbeds to provide capacity for twelve people would be unusual for a residential household.