Purpose Built Managed Student Accommodation (PBMSA) Draft Supplementary Planning Guidance

3.1 Introduction

3.1.1 PBMSA proposals raise a number of planning issues.  Developers should consider the guidance provided in relation to these issues at the earliest opportunity when planning new PBMSA developments to ensure that the final development will be of the highest quality and will respond to the relevant planning policy requirements. 

3.1.2 The Planning Act (NI) 2011 requires that prospective applicants for all regionally significant and major developments² must undertake formal public consultation prior to the submission of a planning application. This is to ensure that communities are aware of, and have an opportunity to comment on, such proposals before an application is made.

3.1.3 The ‘front loading’ of work is fundamental to the new development management system introduced through the reform of the planning in April 2015 and our Statement of Community Involvement (SCI) outlines a number of opportunities for early engagement with both the Council and local communities/stakeholders, including:

• Pre-application Discussions (PADs): The opportunity to discuss any proposals for PBMSA with the Council prior to a planning application being submitted; and
• Pre-Application Community Consultation (PACC): Due to the scale and the nature of PBMSA, pre-application community and stakeholder consultation is usually required. Even where a specific development does not meet the statutory definition of major development, the nature of PBMSA means that early engagement with affected communities is still highly recommended. 
• Proposal of Application Notice (PAN): When a pre-application consultation is required, applicants must submit a PAN to the Council detailing the proposed consultation process.  Separate guidance on the PAN process and pre-application consultation is available from the Council’s website.

3.1.4 Whilst these provisions represent the minimum requirements for pre-application consultation, early engagement with interested parties³ and the Council will help to enhance the quality of the design and reduce the potential delays at the application stage. Developers should therefore consider the need for engagement beyond the minimum level to increase the likelihood of delivering a successful PBMSA development, through better understanding of local concerns and circumstances. This early engagement ensures action can be taken to address issues before detailed designs are developed for a formal application.

3.1.5 The following sections address each of the key planning issue in turn and set out the type of supporting information that is likely to be required as part of a planning application in order to allow each of these issues to be fully considered.

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3.2  Location and accessibility

Accessibility

3.2.1 There is a need to ensure that PBMSA is easily accessible to university/college campuses by sustainable transport modes, be it walking or wheeling, cycling or public/shared forms of transport.

3.2.2 To be easily accessible, an ideal location for PBMSA would be within walking and wheeling distance to a campus. The Institute of Highways and Transportation’s ‘Guidelines for Providing Journeys on Foot’ defines a walking distance as 1,200 metres or 15 minutes walking distance/time. A location within 1,200m of an existing university or college campus will help to achieve the aspiration of this policy criterion by allowing relative ease of access to a campus for students via walking and wheeling.

3.2.3 The City Centre is a highly accessible location, almost entirely within a 1,200m walking/wheeling distance to either of the principal university campuses and is recognised as a preferred location for higher density housing, which could include PBMSA.

3.2.4 Outside of the City Centre, PBMSA may be acceptable, in principle, in highly accessible locations, such as on City Corridors, which benefit from appropriate infrastructure for cycling and public transport. Similarly, Intensive Housing Nodes (IHNs)⁴ are designated specifically because they are able to accommodate higher density residential developments with a lower impact on traditional residential areas and because they can optimise existing infrastructure for sustainable transport. Although IHNs are designated specifically because they are appropriate locations for HMOs and flats/apartments, PBMSA have many similar locational requirements.

3.2.5 While PBMSA may therefore be acceptable within IHNs, care should be taken to avoid an overconcentration particularly in areas nearby a university or college campus or in locations where increased pressure could be placed on Established Residential Areas.

Protecting Established Residential Areas

3.2.6   As well as ensuring accessibility to HEI campuses, criterion a. of Policy HOU12 also seeks to protect existing residential communities from unacceptable impacts. It does so by requiring that PBMSA developments are not located within Established Residential Areas (ERAs). There is no geographic delineation of ERAs within planning policy, instead they are defined with reference to Appendix B of the Plan Strategy. As is common case, planning policy is to be given its ordinary, natural, commonsense meaning within the policy itself. The relevant context is spelt out by the aims and justification of the policy itself.

3.2.7  Whilst it is recognised that PBMSA is residential in nature, planning legislation acknowledges PBMSA as a more intensive land use, and so is a ‘sui generis’ use class. It is acknowledged that high-quality PBMSA can make a positive contribution to the local environment, supporting regeneration through renewal of vacant/derelict sites and boosting local populations to sustain facilities and amenities. However, the greater population density associated with PBMSA can have a number of implications and the potential benefits must be balanced against potential negative impacts arising from concentrations of students which may be harmful to the sustainability of an ERA.

3.2.8   Residential areas rely on a strong relationship between the community and the locality, which is strengthened when residents invest in their community, local facilities and services. Students living in bespoke accommodation are less likely to establish strong relationships with a location given that academic study is time limited and students have access to a range of ‘on campus’ facilities and services. Students therefore often have different patterns of movement to the wider population and are often transient in nature. The different use class recognises that there is a risk that a student population within an ERA would lead to the erosion of that community.

3.2.9  No matter how well designed and managed, a PBMSA development will inevitably place additional pressure on the surrounding infrastructure, including local services, waste storage and collection, parking and road infrastructure.  Despite having a management plan in place for a PBMSA development as per criterion d. of Policy HOU12, the impacts may still disrupt the normal day to day operation of a place, particularly at key times of year, such as the start of term.

3.2.10  The use and occupation of PBMSA development also generate some differing material considerations from a planning perspective, with planning issues that often arising in relation to student accommodation which wouldn’t be relevant for regular residential accommodation.  For example, consideration is often given to the temporary uses of accommodation and the potential for flexibility in the use of the accommodation for short outside of term times.  

3.2.11  There are also a number of factors to consider when assessing proposals in relation to criterion a of this policy, which can be summarised as follows.

Protection of residential stock and land supply

3.2.12  Given the Plan Strategy requirement for 31,660 new homes in Belfast over the Plan period, the residential accommodation policies within the LDP seek to address current and future residential needs by ensuring sufficient land is made available to meet future housing requirements. Alongside Policy HOU3: Protection of existing residential accommodation, both the purpose and intent of Appendix B of the Plan Strategy is to protect housing stock for permanent occupation.

3.2.13   As a general guide where a proposed development for student accommodation is surrounded on more than two sides by residential properties then it could be concluded that it would be contrary to the aims of the policy. There is an onus on the LDP to safeguard potential future residential development opportunities and sites. Student housing is therefore not an appropriate use on residential zoned land.

Cumulative Impact

3.2.14  It is widely recognised that an overconcentration of student accommodation relative to the wider community can lead to an imbalance in the community resulting in harm to residential amenity.  Taking the learning from experiences of areas such as the Holylands, student housing provision needs to be well planned and appropriately managed to ensure that there is a positive integration with any existing communities. 

3.2.15  For PBMSA development, consideration will also be given to the cumulative impacts to ensure that balanced communities are achieved. In many locations, whilst a single PBMSA development of an appropriate scale may be accommodated without giving rise to any particular harm, multiple PBMSA developments in close proximity are more likely to be detrimental. This will be particularly important within the HMAs designated pursuant to Policy HOU10, as well as within established residential areas.

3.2.16  Areas of the city can be identified as more appropriate for PBMSA development based on existing land uses where cumulative impacts of PBMSA may be reduced and revitalising the physical fabric through re-use of vacant buildings and redevelopment of derelict and unattractive land. However the prime planning issue is the location of PBMSA on sites where there is accessibility to third-level institutions by sustainable transport needs.

3.2.17  No specific threshold is set at which a community balance is likely to be lost, and so the cumulative impact will be assessed on a case-by-case basis, taking into account the factors outlined above, including the need to protect existing residential stock and maintain an overall land supply for long-term residential development.

Supporting information

3.2.18 To allow for the full assessment of the location and accessibility of a proposal, including the cumulative impact, a PBMSA Statement must be submitted as part of any application for PBMSA developments which includes:

• A plan illustrating location of the development identifying key walking routes, distances and walking times to relevant university/college campus or public transport halts;
• An analysis of the impact of the proposed development on the surrounding area including reference to:
  • Existing student housing provision within an area; and
  • Information on the social, economic and environmental benefits of a proposal, particularly specific benefits of the proposed scheme as opposed to the well documented benefits of PBMSA in general.

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3.3 Scale of development

3.3.1  When considering the impact of PBMSA, consideration should also be given as to whether the scale of a proposed development is appropriate to the location so as to enable adequate management, to maintain a community balance and to minimise any conflict with surrounding residential neighbourhoods. 

3.3.2  PBMSA developments are required to have a minimum of 200 occupants, without precluding smaller incremental extensions or consolidations of existing accommodation and phased development of larger schemes.  However, there is no specific policy for planning applications relating to PBMSA with fewer than 200 occupants and, as such, smaller schemes may be considered to fail this policy test.  Student accommodation is measured in occupants/bed spaces and not individual units.  200 occupants would equate to 200 bedspaces.

3.3.3  However, where smaller schemes are able to meet the other requirements of this policy, such as the provision of appropriate management arrangements, planning applications may still be considered acceptable.

3.3.4  In addition, all PBMSA proposals are also subject to a range of other relevant policies, such as those relating to design quality and impact on surrounding areas (see Policy RD1).

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3.4 Quality residential environment

Design Quality

3.4.1 The layout, design and facilities provided within a development should be of a high standard to ensure a quality residential environment.  As outlined in Section 2, while Policy HOU12: Large scale purpose built managed student accommodation (PBMSA) sets out the broad policy framework for PBMSA developments, there are a range of other relevant policies within the Plan Strategy with design implications (see Figure 2.1).

3.4.2  It is important that the nature, layout and design of proposed schemes are appropriate to the location and context and would not result in an unacceptable impact on local character, environmental quality or residential amenity.  Good quality PBMSA will help to maximise the positive effects of development, including multiple regeneration benefits, whilst minimising any potential harm to local character, environmental quality or existing residential amenity. When considering design quality in the context of PBMSA, it is important to address residential design criteria, deliver development which is sustainable, and attend to matters of parking, waste and recycling, alongside open space.

Residential Design Criteria

3.4.3  Policy RD1: New residential developments relates to design quality in new residential development and is applicable to PBMSA development given that they are residential in nature. To ensure conformity with these policy standards, planning applications for PBMSA will be tested against the design criteria.  They seek to ensure integration with the surrounding context and minimal impact on neighbouring uses, the protection of the built and natural heritage, adequate provision of open space and local neighbourhood facilities, accessibility and appropriate parking provision, and the promotion of personal safety.  As well as applying to new residential developments, the same design criteria also apply when converting or changing the use of existing buildings to PBMSA.

3.4.4  Policy RD1 contains a number of design criteria aimed at minimising conflict with adjacent land uses, assisting integration with the surrounding area, ensuring adequate provision of necessary local facilities and ensuring there are no unacceptable adverse effects on existing or proposed properties in terms of overlooking, loss of light, overshadowing, noise or other disturbance.  Comments received in response to public consultation on a planning application will be considered when assessing the likely impact of a proposed development.

3.4.5  In addition to the residential design requirements, there are a number of broader policies and relevant land designations within the existing planning policy framework that provide specific design advice, depending on the specific location of a proposed development These include:

• Policy BH1: Listed Buildings: There is a presumption in favour of retaining listed buildings unless there are exceptional reasons to justify a demolition.  The change of use of listed buildings to PBMSA is likely to be appropriate where this secures its upkeep and survival and where the development is in conformity with the wider planning policy framework.  PBMSA developments within the vicinity of listed buildings will also be subject to tighter policy controls to help control the impact on the setting of the listed buildings.
• Policies BH2: Conservation Areas and BH3: Areas of Townscape Character (ATCs): PBMSA developments within, or affecting, a Conservation Area or ATC will need to preserve or enhance the character and appearance of the Conservation Area or ATC.  There is a presumption in favour of retaining any building which makes a positive contribution to the character or appearance of a Conservation Area or ATC, as identified within the Design Guides available for each Area.
• Zonings and designations: Although potential uses of the sites are not always specified, PBMSA may be acceptable as part of a mixed use developments, assuming other policy requirements are met, including specified urban design requirements relating to density of development, heights, scale, massing, etc
• Retail core: Within Belfast City Centre, non-retail development is restricted to upper floors within the Primary Retail Core. 

Sustainable Development

3.4.6  It is important that new PBMSA delivers sustainable development in its broadest sense.  There are a number of elements of PBMSA developments that will contribute to the delivery of sustainable development, such as locating developments so as to reduce the need to travel and to promote walking or cycling, the use of Green Travel Plans and providing a quality residential environment.  As with all new buildings, the design concept should consider the sustainability of the overall design from the outset.  This could include the use of energy efficiency and sustainable construction methods, such as green roofs, or the installation of energy reduction and zero-carbon generating technologies, such as solar panels and rainwater harvesting, as appropriate.  Green roofs can also contribute to the overall open space provision, as well as offering energy reductions through their isolating effect.

3.4.7 These are a number of rating systems, such as the Code for Sustainable Homes and BREEAM (Building Research Establishment's Environmental Assessment Method), available to help in the consideration of overall sustainable development.  Reference to such considerations should be included within the Design and Access Statement submitted to support any planning application.

3.4.8 There are a number of topic based environmental policies within the Plan Strategy which should be implemented for any new PBMSA developments. Policy ENV1 (Environmental quality) is intended for new developments to enhance environmental quality where possible, ensuring the development must not result in an unacceptable adverse impact on the environment including ground contamination, air and water quality, noise and light pollution. Policy ENV2 (Mitigating Environmental change) ensures new development will incorporate measures to mitigate environmental changes and reduce CHG by promoting sustainable patterns of development, while Policy ENV5 (Sustainable drainage systems (SuDS)), will be implemented for all built development, where appropriate, SuDS measures to manage surface water effectively on site, to reduce surface water runoff and to ensure flooding is not increased elsewhere.

Parking

3.4.9 The negative impacts of the parking demands from students on existing provision should be addressed when considering planning applications for PBMSA developments.  Criterion d. of Policy RD1 also sets out the policy requirement to keep hard surfacing to a minimum, which has direct relevance to car parking. Careful consideration should be given to the siting and organisation of car parking within an overall design for open space so that car parking does not negatively affect the use and appearance of open spaces. This is closely linked to the need to support walking, cycling and access to public transport referenced in criterion a. of Policy HOU12.

3.4.10 In accordance with Policies TRAN1: Active travel – walking and cycling and TRAN2: Creating an accessible environment, the provision of PBMSA in close proximity to a University/College campus can also help to justify a reduction in parking provision due to a reduced need for private cars to travel to the place of study.  However, potential reductions in parking provision need to be balanced against the risk that the provision of PBMSA without any parking provision could lead to increased demand for on-street parking.  This could be difficult to absorb in an area where demand for parking is already high and could lead to additional congestion to the detriment of highway safety, and is likely to impact on the residential amenity of existing communities.

3.4.11 In accordance with Policies TRAN 3: Transport assessment and TRAN 4: Travel Plan, detailed Transport Assessments and Travel Plans should be provided in relation to PBMSA to provide the necessary evidence to justify the level of parking proposed and detailing how walking and cycling will be promoted. For example, ‘green’ Travel Plans are now widely utilised to actively encourage the use of alternative modes of transport, particularly cycling.  Planning conditions or legal agreements will be utilised as necessary to ensure that parking and travel arrangements, such as operating as a car-free facility, can be effectively enforced as part of a wider management plan for a scheme.

Waste and Recycling

3.4.12 All new PBMSA developments should have adequate provision of waste and recycling storage facilities and appropriate arrangements for the collection of such waste. This should be designed in accordance with the Local Government Waste Storage Guide for Northern Ireland (2010)⁵ and the Council’s Supplementary Waste Storage Guidance for Purpose Built Managed Student Accommodation in Belfast.⁶

3.4.13 Developers are advised to liaise with the Council’s Planning Service and Building Control Service for support and advice at an early stage to help clarify requirements and ensure that a suitable and satisfactory design is achieved.

Open Space/Communal Spaces

3.4.14 Criteria d. of Policy RD1 requires that appropriate open space is provided for new residential development and will be applicable for new PBMSA developments given that it is residential in nature.  Adequate, quality open space is required within the development to provide recreational and social value. 

3.4.15 Criteria i-n of Policy RD1 applies to new-build apartment developments over 30 units, in addition to criteria a. to h. Given PBMSA would be developed for a minimum of 200 occupants, these latter criteria will be applicable. This includes management arrangements, communal spaces throughout the development, storage space allocated within each individual unit, storage and disposal of water, provision for safe, convenient and secure cycle parking and communal facilities.

3.4.16 Policy OS3: Ancillary open space states that all new development proposals should include appropriate provision for open space, including hard and soft landscaped areas and outdoor amenity areas, to serve the needs of the development.  A normal expectation would be at least 10% of the total site area, albeit the precise amount, location, type and design of such would be negotiated with the applicant.

3.4.17 Policy OS3 seeks to ensure that the provision of open space is integrated into the design for developments and is provided on-site. In this regard, it is important that any open space is safe and accessible, including consideration of opportunities for linkages to nearby facilities, whilst not resulting in any noise or nuisance for local occupiers and residents. It is also important that open space areas are robust and free from encroachment from unplanned or undesirable uses, including for parking, tipping and anti-social behaviour. It is recommended that, in preparing development proposals, early consideration is given to the likely open space needs of occupiers.  In accordance with the advice provided for apartment/flat developments in ‘Creating Places’,  private communal open space may take the form of gardens, court yards, patios, balconies, recessed balconies or terraces, depending on the characteristics of the development proposed and surround context.

3.4.18 PBMSA should consider well designed space around buildings which can add greatly to the attractiveness of a development especially where principles of defensible open space are applied.  Communal spaces are also often provided in student accommodation to suit the need of the occupants, which are often in the form of (but not limited to) common areas (spacious lounges, games room, recreational space), fitness area/gymnasium, cinema room, break out rooms, meeting rooms, etc. Applicants should consider function, orientation, maintenance, scale and qualities of proposed communal open space/amenity space (both indoor and outdoor). In some cases it may be necessary to provide a landscape strategy considering the provision of open space and how it meets the needs of all future residents of the development.

3.4.19 Where proposals for PBMSA are in an accessible location, close to a university campus where potential for the provision of open space is likely to be more limited, small squares or formal spaces should be considered alongside internal amenity spaces throughout the development. In these circumstances it is likely that streetscape, public realm and parking areas may become a focus for improved design.

3.4.20 Where concessions are made in open space standards, planning agreements may be sought to ensure provision of open space off-site or to secure funding for the enhancement to existing areas of public open space.  In addition, conditions or planning agreements may also be used to ensure the policy requirement for the management and maintenance of any open space provided is secured.

Space Standards

3.4.21 As PBMSA has a number of unique features, such as the provision of indoor amenity space and communal facilities, lower unit space standards are acceptable in comparison to other residential development.  Nevertheless, it is still important that new PBMSA developments create a quality and sustainable environment for future residents.  PBMSA developments are therefore still required to be built in accordance with minimum space standards for HMOs as set out in Appendix C of the Plan Strategy.  

3.4.22 Whilst the space standards within the Plan Strategy outline basic minimum standards, it should also be recognised that many institutions have standards that would exceed these levels.  However there are no direct policies which inform the layout of such accommodation.

Internal storage space

3.4.23 Whilst there remains a requirement for minimum levels of internal storage space, this could be more flexibly applied to PBMSA development given general concessions accepted on space standards generally.  However, to offset these lower general space standards, there is a general expectation that PBMSA will contain greater levels of communal space; more so than would be expected in a private housing development.  Furthermore, it is where design features, such as space standards or storage requirements are provided below those of general residential development, the occupancy of PBMSA will usually be conditioned to limit occupation to students, particularly during term times.

Adaptable and accessible accommodation

3.4.24 PBMSA developments should seek to incorporate a high level of accessibility and inclusive design and are nevertheless required to comply with the Disability Discrimination Act (DDA) requirements.   Provision should therefore be made to ensure a development is accessible to all and that accommodation could be suitable for students with disabilities.  This includes not only within individual study bedrooms but also within the accommodation as a whole and along key access routes to and from the site.

3.4.25 In addition, Policy HOU7: Adaptable and accessible accommodation sets out a series of criteria to be applied to all new homes to ensure that they are designed in a flexible way that is adaptable and accessible.  As PBMSA is residential in nature, Policy HOU7 is applicable. However, given that PBMSA is explicitly targeting students and that the accommodation would not therefore be intended for use throughout an individuals’ lifetime, it is accepted that the policy should be applied flexibly.

3.4.26 Given the limited need for adaptability throughout an individuals’ lifetime, it is not necessary for all units within PBMSA developments to meet all of the ‘adaptable’ criteria a-f of Policy HOU7.  However, there remains a requirement that a minimum of 10% of the PBMSA units to be provided as wheelchair adaptable.  This minimum requirement would help to accommodate students with a known disability in the UK and in NI⁷.

3.4.27 In relation to the specific criteria, detailed guidance relating to addressing all of the criteria of Policy HOU7 are outlined within the related ‘Residential design (including adaptable and accessible accommodation) SPG’.  However, specific notes in relation to PBMSA development and the criteria of Policy HOU7 are also provided in Figure 3.1 below:

Table 3.1: Wheelchair adaptable PBMSA Requirements

Policy HOU7 Criteria	PBMSA Wheelchair adaptable unit requirements
a. Parking provision should have a firm surface and provide level or gently sloping access to the main entrance of the property	Building Regulations NI, Technical Booklet R requires parking provision to have a firm surface, which is level or gently sloping. Access from any car parking to the principal entrance(s) should also be level, or have a gentle gradient over a long distance.
b. Main entrances should be sheltered from the weather	Building Regulations NI, Technical Booklet R requires the area immediately in front of entrance doors to be protected from inclement weather.
c. Permanent living space or dining space should be provided within or in addition to a kitchen at entrance level;	An accessible PBMSA unit can be provided either as part of a cluster unit with communal living, dining space and kitchen or as a self-contained room, with bedroom, living, dining and kitchen space in accordance with HMO Space Standards (see criterion g.). In either case, the unit should be provided on a single level.
d. Accommodation should provide entrance level WC with space to provide an accessible shower in the future if required;	The PBMSA unit should be on a single level and include an accessible bathroom/shower.
e. An accessible bathroom should be provided on the same floor as the main bedroom; and
f. Glazing in the principal living space should be sited to enable outlook when seated.	Requirement the same as all residential development. See Residential design (including adaptable and accessible accommodation) SPG for further detail.
g. A wheelchair accessible environment is provided in accordance with the space standards for wheelchair housing set out in appendix C;	There are no specific space standards outlined for an accessible HMO/PBMSA units either within the SPG or Appendix C of the Plan Strategy. However, where an accessible and adaptable wheelchair PBMSA unit is able to meet the HMO space standards set out in Appendix C of the Plan Strategy whilst demonstrating compliance with the remaining criteria of Policy HOU7, it will also be deemed to have complied with criterion g. of Policy HOU7.
h. In-curtilage or designated car parking meets disabled parking standards;	Requirement the same as all residential development. See Residential design (including adaptable and accessible accommodation) SPG for further detail.
i. Pathways are wide enough to accommodate a wheelchair and have a firm surface, level or gently sloping surface;	Building Regulations NI, Technical Booklet R requires access from the point of entrance at the boundary and from car parking provided to the principal entrance to be level, or have a gentle gradient over a long distance.
j. Entrance hallway, kitchen, living, dining area, bathroom and a main bedroom have an unobstructed turning circle;	At a minimum, an unobstructed turning circle of 1500mm should be provided within hallways, kitchens, living/dining areas, bedroom and accessible bathrooms. Within kitchens, there should be a turning circle of 1500mm clear diameter between kitchen units and other fixed objects, with additional space outside of the turning zone to assist manoeuvring throughout. Where a wheelchair adaptable unit forms part of a cluster of units with communal living/dining space and kitchen, the turning circles should be available within all communal spaces.
k. Entrances, doorways and halls should be an appropriate width and length allow for wheelchair access;	Building Regulations NI, Technical Booklet R requires accessible entrance doorway to contain a leaf which provides an effective clear width, manoeuvring space in front of the door. An unobstructed turning circle of 1500mm should be provided within hallways should permit a head-on approach to doorways.
l. Space should be provided in the entrance area to enable storage of a second wheelchair;	Requirement the same as all residential development. See Residential design (including adaptable and accessible accommodation) SPG for further detail. Provision for the storage of a second wheelchair should be at least 1100mm deep and 900mm and should not compromise the unobstructed turning circle required within the entrance or hallways. Where a wheelchair adaptable unit forms part of a cluster of units with communal living/dining space and kitchen, the storage space could be provided either within the wheelchair adaptable bedroom or at the main entrance within the cluster unit.
m. Space should be identified that is capable of accommodating a future lift accessed off circulation spaces on each floor;	Requirement the same as all residential development. See Residential design (including adaptable and accessible accommodation) SPG for further detail. This will usually be deemed to have been met if the PBMSA unit is on a single level within a building with wheelchair accessible communal lifts.
n. Adequate built-in storage should be provided;	Requirement the same as all residential development. See Residential design (including adaptable and accessible accommodation) SPG for further detail. This should be separate to wheelchair storage provision (see criteria m. and areas containing boilers and other utility infrastructure.
o. Private amenity space shall be level or gently sloping and should incorporate an area of suitable hard surfacing.	Requirement the same as all residential development. See Residential design (including adaptable and accessible accommodation) SPG for further detail. Any communal and private amenity space provided should have a firm surface, which is level or gently sloping and access should also be level, or have a gentle gradient over a long distance.

Supporting information

3.4.28 To allow for the full assessment of the design quality of a proposed development, the following information must be submitted as part of all planning applications for PBMSA developments:

• Design and Access Statement: This should explain the design principles and concepts that have been applied to the proposal, taking account of relevant built heritage considerations, especially where proposals fall within a Conservation Area or affect the setting of a listed building.  It should include:
  • Site Appraisal;
  • Concept Design;
  • A statement explaining the design objectives for the site;
  • Local design considerations; and
  • The relationship of the proposal to the surrounding context.
• Landscaping Plan: This should outline the proposed provision of any landscaped areas, open space or amenity spaces within the overall design concept for the scheme, including future maintenance arrangements required. 
• Transport Assessment: This should provide a comprehensive review of all the potential transport impacts of the proposed development, including a plan to mitigate any adverse consequences.
• Travel Plan: This should be drafted to actively encourage the use of alternative modes of transport to the private car, particularly cycling, walking and public transport, including justification for any reduction in parking standards to be considered.  Issues to be considered, including any potential mitigation measures, should include:
  • Staff and Student travel arrangements (i.e. cycle parking, showers/changing facilities etc);
  • Control of beginning and end of term traffic;
  • Provision of secure cycle parking and links to existing or planned cycle networks;
  • Travel packs for students at the beginning of each term (including appropriate routes to and from university); and
  • A Car Parking Management Plan (if parking is to be provided).

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3.5 Management

Management Plan

3.5.1 It is vital that the PBMSA provision is well managed in order to provide a safe and positive living environment for students, whilst reducing the risk of adverse impacts upon residential amenity. A management plan will be required to ensure a quality, safe and attractive place for residents.

3.5.2 Planning applications for PBMSA must be accompanied by a Management Plan addressing general management arrangements associated with the operation of the building. This should include details of:

• Arrangements for the management and maintenance of the site, including any landscape or amenity space (in accordance with proposed Landscape plan);
• Travel and transport plans, including the management of parking. This should include measures to improve access and encourage use of sustainable methods of transport, such as walking, cycling and public transport;
• Servicing arrangements, including housekeeping, cleaning, details of any deliveries required and provision for the storage and collection of waste and recycling;
• Arrangement for the storage and collection of post and deliveries for residents;
• Special features to improve the safety and security of students; including, for example, any CCTV provided, adequate lighting, intercoms, etc;
• Details of any maintenance and servicing programmes, including procedures and timescales for overseeing repairs to property and a programme of both statutory and procedural maintenance and testing requirements, including procedures for emergency light testing, fire alarm testing and equipment maintenance or servicing, portable appliance testing, legionella testing, lift maintenance, window cleaning, etc. Supporting documentation should be provided, including:
  • Health and Safety Policies;
  • A Fire Safety Strategy;
  • Waste and Recycling Policy;
  • Copies of Maintenance Reports and procedures for reporting damage or repairs; or
  • A Maintenance Lifecycle Chart, detailing the expected lifecycle of building components.
• Arrangements to ensure the well-being of residents;
• Arrangements for the management of noise and anti-social behaviour, including details of any soundproofing, noise control measures, a code of conduct to govern tenant behaviour and any proposed liaison arrangements with the relevant education institution(s), the Council and the PSNI in relation to tenant behaviour; and
• Any formal accreditation scheme (e.g. ANUK/Unipol or Universities UK) the operator plans to secure for the management of the completed development.

3.5.3 A S76 planning agreement may be required to ensure delivery of proposed management arrangements, such as any formal links to a University or College or to ensure permanent occupation as student housing. Planning Agreements, and related developer contributions, may therefore be required in relation to PBMSA where management arrangements cannot be adequately addressed by the imposition of conditions alone.  See Section 4.3 on use of Developer Contributions for more information.

Security

3.5.4  Providing details of any special features proposed to improve the safety and security of students also helps strengthen Management Plans. This could include, for example, CCTV, the provision of lighting, intercoms, and arrangements for limiting access for residents, staff and visitors, etc.

Access

3.5.5  Access arrangements should also consider the details of travel to and from the accommodation, including measures proposed to improve access and encourage use of sustainable methods of transport, such as walking, cycling and public transport. This should refer any Transport Assessments and Travel Plans prepared to support the planning application, clearly articulating how any policies, such as parking arrangements will be communicated to residents.

3.5.6  Specific consideration should also be given to the arrangements for the arrival and departure of students, especially where it is likely that large numbers of residents may arrive or depart on the same day or weekend.

Student Behaviour

3.5.7  Details of a student tenancy agreement, including any conditions to ensure that students are responsible in their behaviour to respect fellow residents, neighbours and the building, are vital in assessing the appropriateness of management arrangements for proposed PBMSA. A copy of any information provided to residents, such as a tenant handbook or guide to living in the community, could help support a planning application, providing details of how agreed management arrangements would be communicated to the students, including key contact details and hours of operation, the standard of behaviour expected from occupants, complaints procedures and any disciplinary policies.

3.5.8  The management plan should also consider how the landlord will enforce the terms and conditions of the tenancy, including any liaison arrangements with the relevant education institution(s), the Council and the police in relation to tenant behaviour. Any such plan could build upon any code of conduct provisions set out by the institution(s) to which the students belong. Consideration should also be given to the establishment of formal mechanisms to liaise between student residents and the local community.

Accreditation

3.5.9  As part of management arrangements, developers should commit to securing accreditation under one of government-approved Codes of Standards for the management of PBMSA.  This provides assurance to respective tenants that quality standards are being met and re-assures the Council that appropriate management arrangements will be in place for operation of a development.  This will help to demonstrate compliance with the HMO7 requirement that provision is made for the management of the accommodation. The Available Codes of Standards are available as follows:

• The Universities UK Code of Practice for University Managed Student Accommodation⁸ 
• The Accreditation Network UK (ANUK)/Unipol Code of Standards for Larger Residential Developments for Student Accommodation Managed and Controlled by Educational Establishments⁹
• The ANUK/Unipol Code of Standards for Larger Developments for Student Accommodation NOT Managed and Controlled by Educational Establishments¹⁰

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3.6 Need

3.6.1 The Strategic Planning Policy Statement (SPPS) for Northern Ireland expects planning authorities to consider the needs and aspirations of society and to facilitate sustainable housing growth in response to changing need when plan-making and decision-taking. The consideration of need for student accommodation is essential to ensure the right balance is struck between ensuring student housing needs are met and preventing an over-supply of accommodation that may be unsuitable for future use by non-student residents.

3.6.2 As PBMSA often involves concessions in relation to normal residential design standards (see Section 3.4 below), it cannot always be readily adapted for permanent occupation should it no longer be required for student occupation.  It is therefore important, in accordance with criterion e. of Policy HOU12 that an oversupply of PBMSA in Belfast is avoided, particularly where this is competing for land for permanent housing supply.

3.6.3 It is essential to understand the profile of local student demand and the state of current and future accommodation supply to ensure the successful delivery of student housing to meet current and future need, linked to published growth projections of the city’s further and higher education institutions.

3.6.4 This can be addressed through the preparation of statement of need within the PBMSA Statement required to support any planning applications for PBMSA, based on known demand and supply indicators at the time within the student housing sector.

Demand

3.6.5 Demand for student accommodation is generally considered to be contained within one town or city and is determined by the number of students attending local institutions. General population statistics, including the number of full-time student households are available from the Northern Ireland Statistics and Research Agency (NISRA), whilst information relating to the number of students currently attending HEIs across the UK and the various Northern Ireland institutions are available from the Higher Education Statistics Agency (HESA) and the Department for the Economy’s (DfE) websites respectively.

3.6.6 Whilst the level of full-time students, including those from non-EU countries who traditionally prefer PBMSA, is generally considered the key metric of student accommodation demand, within the Belfast context, the number of full-time students does not automatically translate into demand for PBMSA bed spaces. This is due to a number of unique local factors, including:

• A higher proportion of local students studying at Northern Ireland’s HEIs, many of whom choose to stay at home whilst studying or with a tendency to commute on a weekly basis, returning home at weekends;
• A historical preference of first year students in Belfast to live in private rented accommodation with other students whom they already know but who may be attending different HEIs. However, rising rents in the private rented sector may encourage some domestic students to live in purpose-built accommodation in the future; and
• A low number of students from the rest of the UK study at Northern Ireland’s HEIs (2,980 students, or 5.7%).

3.6.7 In the 2021/22 academic year, the total UK students which studied in Northern Ireland HEIs was 52,290. However, the majority of these students were from NI (49,310 students, or 94%).¹¹

Supply

3.6.8 There are a number of sources of information that can be accessed to assist in the evaluation of existing and future supply of PBMSA. They include:

• Information relating to the existing provision of student accommodation by Belfast’s HEIs available from the university’s respective websites¹²; and
• Planning application searches¹³ identifying any relevant planning applications for PBMSA to enable an appraisal of schemes in the pipeline, including developments with planning permission and current applications.
• Manual survey work may be required to confirm whether developments with planning consents in place are completed or under construction.

Supporting information

3.6.9 To allow for the full assessment of need, the PBMSA Statement that must be submitted as part of any planning application for PBMSA should provide evidence, as appropriate, to enable the assessment of need, based on known demand and supply indicators at the time within the student housing sector. This should include details of:

• The specific need that is being addressed, with reference to relevant Corporate Plans published by the city’s further and higher education institutions;
• Why this need is currently unmet by existing student accommodation stock, implemented and un-implemented planning permissions for PBMSA;
• The type of existing accommodation the potential student occupiers are likely to be drawn from;
• Any recorded increase in student numbers;
• University support, if available; 
• Current waiting lists for student accommodation;
• Bedspace to student population ratio/percentage comparison to other university cities; and
• Bank funding available to deliver proposals.

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Footnotes

² See the Planning (Development Management) Regulations (Northern Ireland) 2015

³ Interested parties includes individuals or organisations who stand to gain or lose from the impact of a planning proposal or decision, such as people living within the area/neighbourhood, elected representatives, voluntary groups, community forums/groups/umbrella organisations, environmental groups, residents’ groups, business interests and developers/landowners.

⁴ Policy HOU11 deals with Intensive housing nodes. Paragraph 7.1.74 of the Plan Strategy explains that intensive housing nodes will be designated in the Local Policies Plan (LPP) and that in advance of this, Policy HOU11 will be applied to existing HMO Development Nodes as outlined within designation HMO 4 of the Houses in Multiple Occupation (HMOs) Subject Plan for Belfast City Council Area 2015. Existing HMO Development Nodes outside of the city centre are concentrated along existing arterial routes.

⁵ Available from: https://www.belfastcity.gov.uk/planning-and-building-control/building-control/waste-storage-guidelines#414-1

⁶ Available from: https://www.belfastcity.gov.uk/Documents/Waste-Storage-Guidelines/Purpose-Built-Managed-Student-Accommodation-(PBMSA

⁷ In 2021/22 c. 14% of all higher education students in NI had a known disability.  Available from: https://www.hesa.ac.uk/data-and-analysis/students/whos-in-he#characteristics

⁸ Available from: www.universitiesuk.ac.uk/acop

⁹ Available from: www.nationalcode.org 

¹⁰ Available from: https://www.nationalcode.org/download-codes

¹¹ Available from: https://www.hesa.ac.uk/data-and-analysis/students/where-from

¹² Queen's University Belfast accommodation information, Ulster University accommodation information, and Stranmillis University College accommodation information

¹³ Available from: https://planningregister.planningsystemni.gov.uk/simple-search