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Purpose built managed student accommodation

Planning and place advice note

Purpose Built Managed Student Accommodation in Belfast Planning and Place Advice Note

November 2015


1. Introduction 
2. Background 
3. Purpose 
4. Policy Context 
Planning Policy 
Non-Statutory Policy 
5. Scope of Guidance 
6. Criteria for Purpose Built Managed Student Accommodation 
A: The development should be at a location which is easily accessible to university/college campuses by sustainable transport modes. 
B: Policy designations specific to the City Centre 
C: Layout, design and facilities provided within the development are of high standards 
D. The development should be designed in a way that does not conflict with adjacent properties or the general amenity of the surrounding area 
E. The development has appropriate management in place to create a positive and safe living environment for students whilst minimising any potential negative impacts from occupants
F The development meets an indentified need for the type of accommodation proposed 
7. Use of Conditions and Developer Agreements 
Appendix A: Glossary of Terms 
Appendix B: Relevant Planning Policies Used in Relation to Recent Planning Applications for PBMSA/HMOs 
Appendix C: Policy Context 

1. Introduction
1.1. On 1 April 2015, the Department of the Environment (DOE) transferred responsibility for the majority of planning functions to local government. Belfast City Council are now responsible for:
 Creating a new Local Development Plan for the City, setting out how the area should look in the future by deciding what type and scale of development should be encouraged and where it should be located (plan making);
 Determining the vast majority of planning applications (development management); and
 Investigating alleged breaches of planning control and determining what action should be taken (enforcement).
1.2. This document is Belfast City Council’s first step as planning authority to respond to the Strategic Planning Policy Statement (SPPS) for Northern Ireland September 2015 stated objective that the planning system should secure the orderly and consistent development of land whilst furthering sustainable development and improving well-being. This requires that the Council, as planning authority, simultaneously pursue social and economic priorities alongside the careful management of the built and natural environments for the overall benefit of society.
2. Background
2.1. There is a heavy emphasis on the involvement of the public, the development industry and interested groups in plan making which is intended to make plans as comprehensive and robust as possible. However despite the best efforts of plan makers, there will always be situations that could not be anticipated. Where the development plan is absent, silent or relevant policies are out of date, permission should normally be granted unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits.
2.2. The Council recognise that students studying and living within Belfast make a significant contribution to local and regional economies and the Council wishes to support Belfast’s five Higher Education Institutions1 as they seek to grow their student numbers, particularly within the international student market. However the rapid expansion of student numbers over the last two decades has also led to a range of negative side effects or ‘externalities’ to the presence of a large student population, in particular in relation to pressures on housing, local amenities and other environmental impacts.
2.3. For Belfast, the continued growth in the number of students wishing to enter third level education in our universities and further education colleges; the re-location of the Ulster University to the north of the City Centre and growth in the international student market present significant opportunities for the city. However, taking the learning from experiences of areas such as the Holyland, student housing provision needs to be well planned and appropriately managed to ensure that there is a more positive integration with any existing communities.
1 The five higher education institutions in Belfast include, Queen’s University, Ulster University, Stranmillis University College, St. Mary’s University College and Belfast Metropolitan College (offers a limited number of undergraduate degree-level courses)

2.4. Belfast is different to most other large university cities in that the proportion of available PBMSA is considerably lower than elsewhere in the UK. However, in recent months, Belfast has experienced an influx of planning applications for PBMSA, predominantly in the City Centre. This guidance therefore seek to clarify the approach Council will take to help ensure the right supply of high quality, well-design student accommodation needed for the City.
2.5. A glossary of terms used in this Advice Note is set out in Appendix A.
3. Purpose
3.1. Whilst DOE previously published planning policy on purpose built student accommodation, no one could have reasonably foreseen the scale and degree of the proposals that have been submitted in recent times. The Council is concerned about the scale and magnitude of proposed PBMSA development and the likely impacts it could have on the character of a small geographic areas within the city.
3.2. The Council has therefore developed this guidance, which is entirely consistent with regional policy, to address how the need and demand for the student accommodation can be accommodated within the City Centre, while protecting the amenity of areas where PBMSA developments are likely to be concentrated and avoiding concerns that excessive student accommodation may undermine the character and function of the area.
3.3. The guidance given in this document is therefore intended to provide the Council with advice for considering proposals for PBMSA in Belfast City Centre. They represent non-statutory planning guidance which provides detailed advice around the City-wide approach to PBMSA and how to pro-actively encourage good quality development in the right locations.
3.4. It is not a statement of policy as to where PBMSA can or cannot take place, but rather articulates the Council’s position on student accommodation in the city and highlights the relevant planning policies and other material considerations to be referenced when considering proposals for PBMSA. It should therefore be read in the context of the existing Planning Policy framework, including the SPPS, the suite of relevant regional PPSs, the Belfast Metropolitan Area Plan (BMAP) and the Houses in Multiple Occupation (HMOs) Subject Plan for Belfast City Council Area 2015.
3.5. It will complement the proposed ‘Best Practice Guide’ to be published to encourage the provision of good quality PBMSA in suitable locations, which sets out the Council’s aspirations with regards to PBMSA in Belfast and contains guidance to be referenced by prospective developers to help shape proposals from the earliest opportunity.
4. Policy Context
Planning Policy
4.1. The provision of housing for students is required to manage housing growth and achieve sustainable patterns of development required by the Regional Development Strategy (RDS). At an operational level, the following planning policies alssupport, in principle, the provision of good quality PBMSA within Belfast City Centre:

 The Strategic Planning Policy Statement for Northern Ireland (SPPS);
 PPS6 ‘Planning, Archaeology and the Built Heritage’;
 PPS7 ‘Quality Residential Environments’;
 PPS12 ‘Housing in Settlements’;
 Policy HOU3 of the Belfast Metropolitan Area Plan (BMAP); and
 The ‘Houses in Multiple Occupation (HMOs) Subject Plan for Belfast City Council Area 2015’ (Policy HMO7)
4.2. A summary of relevant policies reference in recent planning applications within Belfast is contained at Appendix B.
Non-Statutory Policy
4.3. In addition to the formal planning policy context, the Council’s position on the provision of PBMSA in the City Centre is informed by two non-statutory policy documents, namely:
 Belfast City Centre Regeneration and Investment Strategy; and
 Framework for Student Housing and Purpose Built Student Accommodation.
4.4. Whilst these policy documents can be taken into account as a material consideration when determining planning applications for PBMSA, neither were composed within the planning framework and therefore cannot supersede existing planning policy or have determining weight in planning decisions. A summary of the policy context is contained at Appendix C.
5. Scope of Guidance
5.1. As there is no formal definition of PBMSA contained either within the Planning (Use Classes) Order (NI 2015) or the HMO Subject Plan, it is a form of development for which further guidance and clarification is appropriate. For the purpose of this guidance, the Council considers PBMSA to be ‘sui generis’.
5.2. The implications arising from this conclusion in relation to the application of existing planning policies when considering planning applications for PBMSA can be summarised as follows:
1. As PBMSA can be considered ‘residential’ in nature, planning policies relating specifically to residential development will be a significant material consideration (e.g. PPS7 Policy QD1); and
2. Although distinct from HMOs in planning terms, PBMSA are likely to have some similar locational requirements to HMOs and as such may be acceptable in similar locations (e.g. HMO Development Nodes) subject to other wider planning and environmental considerations.
5.3. As well as the use of this guidance in considering planning applications, there may be an opportunity in relation to major developments to raise matters outlined within this Advice Note as part of Pre-Application Discussions (PADs). It may also be appropriate to request additional information from prospective applicants at the pre-application stage to help inform discussions/advice given. There may also be potential for prospective developers to discuss any specific issues with local communities during Pre-Application Community Consultation (PACC) and should be considered when responding to Proposal of Application Notices (PANs).

6. Criteria for Purpose Built Managed Student Accommodation
6.1. The following will be considered when assessing applications for PBMSA:
A: The development should be at a location which is easily accessible to university/college campuses by sustainable transport modes.
6.2. PBMSA would preferably be located within a 15 min walking distance of a university/ college campus to ensure a sustainable pattern of development that supports urban regeneration and optimises existing infrastructure. This will allow relative ease of access to campus for students and will promote sustainable means of travel, thus minimising car use. Belfast City Centre is therefore an ideal location, containing the expanded Ulster University campus and being within comfortable walking distance of Queen’s University’s main campus. This also aligns with the Council’s aspiration to increase the residential population in the City Centre contained within the Belfast City Centre Regeneration and Investment Strategy.
6.3. The provision of PBMSA in some highly accessible locations outside of the city centre, such as on arterial routes, may increase pressure on existing established residential communities. This is particularly true in the north of the city where there is an increased risk of concentrations of HMO accommodation as a result of the expanded Ulster University campus. Developments in such locations may unacceptably affect amenities and the existing use of land and buildings that ought to be protected in the public interest, for example through an adverse effect on existing properties in terms of overlooking, loss of light, overshadowing, noise or other disturbance.
B: Policy designations specific to the City Centre
6.4. Within the City Centre, there are a number of policy designations that should be taken into account when considering proposals for PBMSA including:
 Protected City Centre Housing Areas: Whilst PBMSA could be considered a form of residential development the scale and impact of PBMSA is likely to be incompatible with existing residential communities.
 Primary Retail Core: Non-retail development is restricted to upper floors within the Primary Retail Core
 City Centre Conservation Areas: Developments within, or affecting a Conservation Area need to preserve or enhance the setting and character of the Conservation Area. There should be a presumption in favour of retaining any building which makes a positive contribution to the character or appearance of a conservation area.
 City Centre Listed Buildings: There should be a presumption in favour of the change of use of a listed building where this secures its upkeep and survival and a presumption in favour of retaining listed buildings and against demolition unless there are exceptional reasons. There are also tighter policy controls for developments within the vicinity of listed buildings to control the impact on the setting of a listed building.