Best practice guide

Contents

1. Introduction 
2. Policy Context 
3. Pre-Application Considerations 
4. Locational Considerations 
5. Policy Designations 
6. Design Considerations
7. Considering Impact 
8. Management Considerations 
9. Considering Need 
10. Planning Agreements and Developer Contributions

• Appendix A: Glossary of Terms
• Appendix B: Checklist of Information to Support a Planning Application for PBMSA
• Appendix C: Belfast City Centre Policy Designations 

1. Introduction

Students offer an outstanding opportunity to enhance Belfast’s role as a ‘Learning City’ with a vibrant knowledge economy, a positive international profile, a high quality of life and well-being and a revitalised and welcoming city centre. 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 all present significant opportunities for Belfast.

The Council therefore wish to support Belfast’s five Higher Education Institutions (HEIs) [Footnote 1] as they seek to grow their student numbers, particularly within the international student market. Attracting students to study and live in the city, not only requires excellent education providers, high quality campuses and a wide choice of quality courses, but also the right city infrastructure including IT connections, transport and housing.

In relation to student accommodation, the Council need to ensure that future development delivers high quality, well designed, and well managed Purpose Built Managed Student Accommodation (PBMSA) in suitable locations as a preferable alternative to ad-hoc private rented housing within established neighbourhoods. This will ensure the supply of student accommodation needed whilst delivering regeneration benefits and avoiding negative impacts on adjacent land uses and established residential communities.

This Guide is not a statement of policy as to where PBMSA can or cannot take place, but rather articulates the Council’s view on this type of development in the city to be referenced when considering proposals. It should therefore be read in conjunction with the wider planning policy framework.

2. Policy context

HMO Subject Plan

The ‘Houses in Multiple Occupation (HMOs) Subject Plan for Belfast City Council Area 2015’ sets out a number of area-based planning policies for HMOs, as well as policy relating directly to the provision of PBMSA. The HMO Strategy has four overarching objectives:

• Protect the amenity of areas where multiple occupation is, or is likely to become, concentrated;
• Accommodate the need and demand for multiple occupation, while maintaining a community balance;
• Focus HMO development in areas where it can contribute to regeneration; and
• Promote appropriate development of purpose built student accommodation.

Policy HMO7 relates to the provision of ‘Large Scale Purpose Built Student Accommodation’ and is the principal planning policy tool available when considering applications for PBMSA in Belfast City Centre.

Policy HMO 7 – Large Scale Purpose Built Student Accommodation

Planning permission will only be granted for large scale purpose built student accommodation where all of the flowing criteria are met:

• Development of any complex consists of a minimum of 50 units or a minimum of 200 occupants. This will not preclude proposals for smaller incremental extensions or consolidations of existing halls of residence and phased development of larger schemes;
• All units are self-contained (i.e. having a bathroom, w.c. and kitchen available for use by the occupiers);
• The location is not within a primarily residential area;
• Provision is made for management of all accommodation. This may require an Article 40 agreement with Planning Service; and
• Landscaping and amenity space is provided in accordance with a landscaping plan indicating all landscaping proposals for the scheme and, where relevant making provision for future maintenance.

Framework for Student Housing and Purpose Built Student Accommodation

The ‘Framework for Student Housing and Purpose Built Student Accommodation’ was published in 2014 to set out the Council’s vision and direction for the supply of student housing and PBMSA in Belfast. It contains a criteria-based approach to be applied to proposals for ‘purpose built student accommodation’ developments in the city, suggesting that planning permission for such developments should only be granted where the five criteria based around proximity, design, management, impact and need are met.

At the time of writing, it was intended that the Framework document would be used by the Council and its partners as they engage with the planning process. Whilst the document can be taken into account as a material consideration when determining planning applications for PBMSA, it was composed within the planning framework and therefore cannot supersede existing planning policy or have determining weight in planning decisions.

PBMSA in Belfast – Planning and Place Advice Note

In November 2015, the Council adopted an internal Planning and Place Advice Note on PBMSA in Belfast. As a technical guide, the document provides non-statutory planning guidance around the Council’s approach to PBMSA to pro-actively encourage good quality development in the right locations. It sets out guidance in relation to six key criteria that will be considered when assessing applications for PBMSA. These include:

A. The development should be at a location which is easily accessible to university or 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; and
F. The development meets and identified need for the type of accommodation proposed.

The document also provides guidance in relation to the use of planning conditions or legal planning agreements to mitigate perceived problems, such as noise or anti-social behaviour, etc. arising from student occupation. It builds on the criteria-based approach developed through the earlier work undertaken by the Council prior to becoming the planning authority for the City.

Belfast City Centre Regeneration and Investment Strategy

The Belfast City Centre Regeneration and Investment Strategy (September 2015) provides a framework for change in Belfast City Centre. It sets out a strong vision for the future development of the City Centre to deliver the Council’s aspirations for the continued growth and regeneration of the city core and its surrounding areas.

In relation to the provision of PBMSA, the Strategy seeks to increase the residential population in the City Centre, noting that a significant residential population is highly important for the successful functioning of the city centre. As part of this, the Strategy recognises that “the opportunity for appropriate student housing should be explored in suitable locations” and argues that “student housing should be carefully directed, located and managed”.

It sets the context for the future statutory development plan in relation to the city centre and points to some early and ongoing work on key issues, including the continued development of a balanced approach to student housing to ensure this type of development is located in suitable locations and the many associated benefits can be maximised.

3. Pre-Application Considerations

Developers are encouraged to consider the advice contained within this best practice guide at the earliest opportunity when planning new PBMSA developments. Consideration of the issues identified at the outset of a project will ensure the final development will be of the highest quality and will respond to the relevant planning policy requirements.

The ‘front loading’ of work is fundamental to the new development management system introduced through the reform of the planning system 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 or stakeholders:

• Pre-application Discussions (PADs):
  The Council welcome the opportunity to discuss any proposals for PBMSA prior to a planning application being submitted. Appendix B provides a checklist of the information that is likely to be required to enable the effective consideration of a planning application for PBMSA and it will be beneficial if this evidence is available during PADs to help facilitate discussions.
• Pre-Application Consultation:
  Although not all proposals will fall within the statutory definition of major development, the nature of PBMSA means that pre-application community and stakeholder consultation is highly recommended. Early engagement with interested parties will help to minimise objections and potential delays at the application stage, as it will help the developer better understand local concerns or circumstances, and possibly take action to address these concerns, before submitting a formal application. Where development will constitute a major application, a Proposal of Application Notice (PAN) should be submitted to the Council at least 12 weeks prior to submission outlining the detail of the application and what consultation will be undertaken. Where pre-application consultation has been undertaken, applicants should then submit a Pre-Application Community Consultation (PACC) report as part of their planning application.

Partnership Working

Further to the early engagement outlined above, the delivery of successful PBMSA can also be aided by the formation of genuine, long-lasting partnerships with other stakeholders, such as the university, the Council and local community representatives. Working in partnership with such stakeholders will bring a number of benefits, including:

• Maximising opportunities to regenerate areas of Belfast during the development of new PBMSA, perhaps as part of broader, mixed use regeneration projects;
• Minimising objections raised by local residents/communities affected by a development, allowing design solutions to mitigate future issues identified. It may be appropriate to establish formal ‘Community Forums’ to ensure effective communication between local residents and student occupants;
• Identifying opportunities for mutually-beneficial associations between educational establishments and a PBMSA development, helping to meet a university’s identified student housing needs whilst providing greater certainty in relation to rental returns for a developer; and
• Ensuring the involvement of educational establishments in addressing any management issues that may arise once the scheme is operational, such as institutional response to proven incidents of anti-social behaviour, etc.

4. Locational Considerations

There are a number of factors that can influence the suitability of a location for PBMSA, including the proximity to a university or college campus, its accessibility by sustainable transport modes and the impact on the general amenity of the surrounding area, including problems associated with concentrations of a single housing tenure or type.

When considering the suitability of any particular site for PBMSA, the following best practice should be considered:

• Student populations are often highly dependent on low cost transport modes, meaning there is a preference for PBMSA to be located within walking distance (15 minutes or 1,200m) of a university or college campus. In Dundee, for example, the two universities have or are disposing of student accommodation in sites remote from the campus areas due to changing student preferences;
• Development should respect its surrounding context in terms of layout, scale, proportions, massing and appearance of buildings, structures and landscaped and hard surfaced areas (see Policy QD1 of PPS7). Taller, higher density PBMSA is therefore likely to be more appropriate in suitable city centre locations that benefit from high accessibility and where there is less potential for conflict with existing low-rise residential accommodation (SPPS, para.6.137);
• Cumulative impact is less likely to be an issue in areas of the City Centre where there are no well-established residential neighbourhoods. However, careful consideration needs to be given to the impact of PBMSA if a site is located close to a Protected City Centre Housing Area;
• PBMSA in a ‘central location’ is likely to appeal to overseas students [Footnote 2], who will help to drive the projected increase in student numbers from both Universities in Belfast;
• City centre living delivers a range of environmental benefits including reducing the need to travel, revitalising the physical fabric through re-use of vacant buildings and redevelopment of derelict and unattractive land.
• PBMSA can form an effective part of mixed-use regeneration schemes including, for example, retail development at ground floor or an appropriate proportion of social housing as part of the overall development (depending on other policy requirements).

Within this context, Belfast City Centre is considered an ideal location in close proximity to the extended Ulster University campus and within comfortable walking distance of Queen’s University’s main campus and the Belfast Metropolitan College’s Titanic Quarter campus. This will deliver a sustainable pattern of development that will promote sustainable means of transport, such as walking and cycling, and will minimise the need for car use and 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.

5. Policy designations

As well as the overarching policy context for PBMSA outlined in Section 2 above, there are a number of policy designations that should be taken into account when considering proposals for PBMSA. Within Belfast City Centre, which is the Council’s preferred location for new PBMSA development, these include:

• Protected City Centre Housing Areas: 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.
• Listed Buildings: There is a presumption in favour of retaining listed buildings and in favour of the change of use of a listed building where this secures its upkeep and survival; and
• HMO Development Nodes: PBMSA is likely to have similar locational requirements to HMOs and as such may be acceptable in similar locations, such as the designated ‘HMO Development Nodes’. However, the potential for clustering needs to be balanced against any potentially adverse cumulative impacts arising from too high a concentration of student accommodation in one place and proposals for PBMSA at such nodes also need to accord with other relevant planning policies.

The location of these policy designations is illustrated on the map at Appendix C.

6. Design Considerations

Good quality, well-designed PBMSA, in terms of design, layout and facilities, 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. The Council therefore encourage applications for PBMSA to incorporate high quality design that is inclusive and accessible, making the most of opportunities available to improve the character and quality of the area.

General Design

Supporting good design and positive place making is one of the core principles of the planning system outlined in SPPS, alongside preserving and improving the built and natural environment. General design criteria that apply to residential developments are set out in Policy QD1 of PPS7. Policy LC2 of the PPS7 Addendum ‘Safeguarding the Character of Established Residential Areas’ also applies the same criteria when converting or changing the use of existing buildings to flats or apartments. ‘Living Places’, the Urban Stewardship and Design Guide for Northern Ireland outlines 10 qualities of urban stewardship and design that should be considered during the planning process.

General information relating to the planning context, historical development and character appraisal is available in relation to the three City Centre Conservation Areas within their respective Design Guides. This includes design guidelines for development proposals, including advice relating to:

• New development;
• Refurbishment and conversion;
• Shop and commercial frontages;
• New materials; and
• Advertisements and signage.

General advice is also set out within the Belfast Metropolitan Area Plan (BMAP) in relation to the nine designated Character Areas. For each Character Area, tailored urban design guidance is provided in relation to:

• The density of development;
• Appropriate building heights;
• Building lines (inc. heights, plinths, cornices, string course lines, etc.);
• The traditional scale of developments (plot size, urban grain, etc.)
• Roof design;
• Public Realm enhancements;
• Provision of public open space; and
• Privacy zones for adjacent residential development.

Development proposals within the Victoria Street or Oxford Street Area of Townscape Character (ATC) should also take account of the prevailing regional planning policies currently set out in the PPS6 (Addendum) ‘Areas of Townscape Character’ and any future supplementary planning guidance.

A Design and Access Statement should be provided to support planning applications for PBMSA (see Appendix B for further details). This should take account of relevant built heritage considerations, especially where proposals fall within a Conservation Area or affect the setting of a listed building.

Layout and Accommodation Mix

Research from across the UK notes that the cost of accommodation can play an important part in the attractiveness of the university and well as the health and well-being of students and the interaction of students in university life. The provision of a variety of layouts, including a range of room sizes and configurations, will also help to ensure accommodation in the city remains affordable and that students from all backgrounds and budgets can be catered for.

The provision of a mix unit sizes and types within PBMSA schemes will ensure a range of accommodation is available that will be attractive to groups who would otherwise share private rented HMOs. This could include single units or studios, 2, 3, 4 and 5-bedroom flats or apartments, clustered study bedrooms with some shared facilities and double units (which are often more suitable to post-graduate students).

PBMSA can sometimes have residential amenity that differs from properties designed for longer-term occupation, in terms of minimum space standards, open space provision, parking requirements, etc. The Northern Ireland Housing Executive’s HMO Standards provide an indication of the minimum size of rooms within PBMSA. They include:

Room or Layout Number of Occupants Minimum Size (m²)

In order to justify a reduction in standard residential requirements it may be necessary for approvals for PBMSA development to be conditioned to ensure the proposed accommodation will be restricted to use solely, or principally, by students. Planning agreements can also be utilised to make development acceptable that would otherwise be unacceptable in planning terms (see Planning Agreements and Developer Contributions below). In order to get approval to remove conditions at a later date, it will need to be demonstrated at that time that all of the policy requirements for general needs housing, including amenity standards, can be met. Giving consideration to how a PBMSA development could be reconfigured in the future to meet general housing needs will allow greater flexibility for conversion to permanent self-contained housing in the future if a building is no longer needed to house students.

Open Space

The availability of and ability to enjoy open space is very important to both students and other members of the local community. The provision of high quality and accessible open spaces as part of new student accommodation could take several forms as defined by Annex A of PPS 8. This includes parks or gardens, outdoor sports facilities, amenity green space, green corridors; natural and semi-natural urban spaces, allotments or community gardens and civic spaces.

Adequate provision would range from 10-30 sq m per unit (Creating Places), and could include private communal open space in the form of “landscaped areas, courtyards or roof gardens.” However, the appropriate level of provision should be determined by having regard to the particular context of the development and the overall design concept and evidence to justify a reduction of standards, such as distance to existing areas of open space, could be provided as appropriate.

There may be circumstances where the provision of communal open space can be reduced depending on location, existing open space in the vicinity and through the provision of internal communal space. Where it is not possible to provide adequate open space on-site, an off-site contribution may be necessary (see Planning Agreements and Developer Contributions below).

A Landscaping Plan is required to support any planning application for PBMSA outlining the proposed provision of open space or amenity spaces within the overall design concept for the scheme, including future maintenance arrangements required.

Parking

PBMSA developments are required to provide adequate provision for car parking and appropriate servicing arrangements. However, the precise amount of car parking will be determined according to the specific characteristics of the development and its location. It is acknowledged that “a reduction in parking provision may be accepted where it forms part of a package of measures to promote alternative transport modes” (PPS3, Paragraph 5.41).

A detailed Transport Assessment is required in relation to PBMSA to ensure the impact of traffic arising from the development is acceptable. A Travel Plan is also required, especially where a reduction in parking standards is to be considered. Such a Travel Plan should seek to consider a range of issues, including any potential mitigation measures, such as:

• Staff and Student travel issues;
• 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).

A pro-active and innovative approach to parking provision, including the use of planning agreements, can mean the difference between the approval of refusal of a planning application on parking or travel grounds.

Facilities

In addition to the basic amenities expected within student accommodation, such as washing and cooking facilities, most students also now expect a range of good quality facilities to be provided as part of PBMSA development. Whilst not exhaustive, the following list provides an indication of the kind of additional facilities that are provided in many PBMSA developments across the UK:

• Designated social hubs;
• Game rooms or movie rooms;
• Gyms and exercise rooms;
• Laundrette services;
• Extra rentable storage space;
• Retail operations (such as shops, restaurants, hair salon, etc.) which are often available to the public as well as students; and
• Study rooms.

It should be noted that the provision of supporting facilities as part of PBMSA will continue to be subject to other broader policy requirements and may not be appropriate in all cases.

Waste and Recycling

It is vital that all new PBMSA developments have adequate waste and recycling storage facilities and access arrangements. The Council advises developers to refer to the Local Government Waste Storage Guide for Northern Ireland (2010), as well as the Council’s Supplementary Waste Storage Guidance for Developments in Belfast. [Footnote 3]

Together, the two guides provide practical advice to help:

• Estimate the amount of waste produced for different building types;
• Calculate the numbers and types of waste containers that will be needed;
• Correctly size, site and design waste storage areas; and
• Provide satisfactory access to waste collection points.

The Council also plan to publish tailored guidance on waste storage in PBMSA and addressing this advice early in the design phase will help ensure that developments are properly laid out to provide suitable waste storage and access. Developers are also advised to liaise with the Council’s 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.

Safety and Crime Prevention

PBMSA are encouraged to incorporate design measures that promote personal safety and security and reduce crime and the fear of crime, taking full account of the principles of ‘Secured By Design’ [Footnote 4]. Design measures may include:

• Communal functions placed at the ground floor of the building to retain an active frontage;
• Card-operated access control at a main entrance;
• Audio-visual CCTV to increase the level of surveillance;
• Alarmed fire escape doors; and
• On-site accommodation management.

The Police Service of Northern Ireland also provides free ‘Secured By Design’ advice via their Crime Prevention Design Advisors and Crime Prevention Officers.

Energy Reduction

The utilisation of energy efficiency and sustainable construction methods, including the installation of energy reduction and zero-carbon generating technologies, is encouraged within all new developments. In the case of PBMSA, the use of such technologies will help ensure the attractiveness of accommodation to students by virtue of reduced energy consumption and related utility costs.

7. Considering Impact

The creation of mixed and inclusive communities is an important factor when considering the provision of PBMSA. 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.
For further details, see Secured By Design website at: www.securedbydesign.com (link opens in new window)

However, well designed, appropriately located and effectively managed PBMSA should, in a general sense, help reduce the negative impacts associated with concentrations of student housing in comparison to un-managed HMOs, whilst capturing many positive impacts. For example, HEIs and their students make a significant contribution to the economy, to the social mix of an area and support local services.

However, even with PBMSA a concentration of relatively short term residents can have an unwelcome impact on an established community, by reason of their particular social needs, the unique nature of activity associated with student life and demand for facilities and services. At appropriate locations within the City Centre, PBMSA can be provided with lesser impacts on existing communities than in established residential areas outside of the City Centre.

However, even with such cases consideration needs to be given to the impact of a PBMSA developments either in themselves or when considered alongside other existing or approved student housing provision. Key issues to be considered include:

• The need to protect residential amenity where student accommodation is, or is likely to become, concentrated, particularly in the vicinity of existing residential communities;
• The scale, form and nature of large scale PBMSA is likely to render them incompatible with Protected City Centre Housing Areas;
• Conflicts with adjacent land uses need to be minimised; and
• The adequate provision of necessary local facilities, such as doctors, dentists, leisure provision and local convenience shops.

As a form of good practice, information relating to the consideration of the impact of proposals, including the cumulative impact of any existing or approved student housing provision, will help support planning applications for PBMSA (see Appendix B for further details). There is a range of statistical information available to help inform the preparation of such a statement, but this can be supplemented through primary survey work, particularly in the City Centre where there is likely to be low proportions of residential accommodation, to identify the current mix of uses within a specific area, and to identify current provision of local facilities and services that will help to serve the new development.

8.Management Considerations

Policy HMO7 requires that “provision is made for the management of all accommodation” to ensure a safe and positive environment for students, whilst reducing the risk of potential negative impacts on the local community. It is therefore good practice to submit a Management Plan with any planning application for PBMSA (see Appendix B), addressing the management arrangements associated with the operation of the building. It should be noted that arrangements outlined within a Management Plan submitted to support the planning application may need to be reflected within specific planning conditions attached to an approval if secured.

The following sections outline a range of best practice that has been identified through an analysis of Management Plans submitted to support recent planning applications for PBMSA in Belfast.

Background and Context

It is useful to supply general background information about the proposed development, including any arrangements that have been made for the management of the building once it becomes operational, particularly where the operator may be separate from the developer or client. There are a number of mechanisms that universities and developers may use to address provision, including the following:

• University Owned Accommodation: where a university may choose to own land and buildings. The University has total control over rental costs, rent durations, and the quality of the accommodation (e.g. Queen’s University Belfast’s Elm’s Village).
• University Managed Accommodation: Accommodation alternatively may be owned by a third party but let and managed by the University (e.g. Ulster University’s managed Glenwhirry Court).
• Private Sector Arrangements: Student accommodation in the private sector may be directly let or let through an agreement between a private provider and the University (e.g. Mark Royal House).
• Co-Operative Student Housing: In a housing co-operative, the people that live in the houses are the members, who are collectively their own landlord. This could provide greater choice and potentially lower cost student accommodation.
• Social Landlord Student Housing: A social landlord could potentially develop purpose built student accommodation. Options could then be explored to cross-subsidise the housing costs from other revenues generated again increasing choice and potentially offering more affordable accommodation (e.g. SHAC, Donegall Street, Belfast).

In situations where accommodation is provided in partnership between a private supplier and educational establishment, the determination of whether the accommodation is managed and controlled by the educational establishment is decided by the outcome of an agreed series of calculations to be found within both Codes.

An overview summary of the relevant organisations’ track record in developing and managing similar PBMSA developments elsewhere will help support an application.

Code of Standards

Although there is no mandatory Code of Standards for the management of PBMSA in Northern Ireland, there are a number of voluntary accreditation schemes approved for use elsewhere in the UK by the Department for Communities and Local Government (DCLG).

Many private PBMSA operators are signed up to one, or more, of these Codes and the Council would encourage developers to commit to securing voluntary accreditation under one of the available codes. This provides assurance to respective tenants that quality standards are being met and is often be required by universities elsewhere in the UK before they will consider promotion of available accommodation to their students.

In addition, accreditation re-assures the Council that appropriate management arrangements will be in place for operation of a development, helping 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 - Guild HE Code of Practice for University Managed Student Accommodation [Footnote 5]
• The Accreditation Network UK (ANUK) or Unipol Code of Standards for Larger Residential Developments for Student Accommodation Managed and Controlled by Educational Establishments [Footnote 6]
• The ANUK or Unipol Code of Standards for Larger Developments for Student Accommodation NOT Managed and Controlled by Educational Establishments [Footnote 6]

Description

A summary of the accommodation to be provided, including key features and any supporting services, helps to set the scene for management arrangements. If available, marketing material can be provided to illustrate how the accommodation will be advertised to prospective students.

Location

It is valuable for a Management Plan to identify the location of local facilities and services, including the distances, routes and travel options to key destinations, such as the university campuses and local shops or community facilities. In addition, key to the effective management of the accommodation is the identification and understanding of any neighbouring communities and an identification of potential conflicts between students and longer-term residents. Proposed mitigation measures for such conflicts should be included where relevant.

Staffing

Many larger PBMSA developments have a fully staffed management suite or concierge to oversee the operation and management of the building. Management Plans can be strengthened through the inclusion of information in relation to any proposed staff posts, their responsibilities and their hours of operation.

This could include arrangements made for the booking of accommodation, including policies for the allocation of rooms (especially where this involves local HEIs), health and safety standards and procedures, arrangements to ensure the well-being of student residents and responsibilities for liaison with the local community. In addition, staff may be needed to ensure appropriate security, cleaning and maintenance of the building. In some cases Management Plans have included drafts of Job Descriptions and proposed performance targets to be set in relation to the management of the building.

Management Plans should seek to provide as much information as possible in relation to the general management of the facility by the staff, including what role the students themselves can play in the management of communal facilities. For example, one Management Plan proposed the appointment of ‘Student Wardens’ to help provide management cover between management staff leaving and security staff commencing night duties. Senior student wardens would also provide a point of contact for out-of-hours emergencies for students.

Management Arrangements

A range of information can be provided within a Management Plan to outline the general management arrangements for a facility, including:

• Details of services provided to occupants, such as housekeeping, cleaning and waste and recycling arrangements, and detailing the division of responsibilities between residents and the building management;
• Arrangement for the storage and collection of post and deliveries for residents;
• Servicing arrangements, including details of any deliveries required and provision for the storage and collection of waste and recycling;
• Arrangements for the maintenance of open spaces or landscape amenity space, in accordance with the proposed Landscape Plan;
•  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 for the management of noise, including details of any soundproofing or noise control measures included within the scheme design.
•  Arrangements for the management of non-student use of the building, for example during holiday periods, where such temporary uses are requested for approval as part of the planning consent.

It can be prudent to include compliance with these arrangements, policies and expectations as a condition of the occupants’ tenancy agreement.

Security and Access

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 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. Specific consideration can 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

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.

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.

9. Considering need

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.

The majority of recent planning applications for PBMSA in Belfast have given little attention to the assessment of need, providing general statements regarding the benefits of PBMSA over traditional HMO accommodation or re-iterating summary statements such as those published within the Council’s ‘Framework for Student Housing and Purpose Built Student Accommodation’. However, it is essential to understand the profile of local student demand and the state of current and future supply to ensure the successful delivery of student housing to meet current and future need.

This can be addressed through the preparation of a Need Statement to support any planning applications for PBMSA (see Appendix B for further details), based on known demand and supply indicators at the time within the student housing sector.

Demand

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) [Footnote 7], 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) [Footnote 8] and the Department for the Economy’s (DfE) [Footnote 9] websites respectively.

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 study 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 per cent according to the January 2011 update to Independent Review of Variable Fees and Student Finance Arrangements; Update to Minister for Employment & Learning).

Supply

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 websites [Footnote 10]; and
• Planning application searches [Footnote 11] 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.

10. Planning Agreements and Developer Contributions

Planning Agreements, and related developer contributions, may be required in relation to PBMSA where what is secured cannot be adequately addressed by the imposition of conditions alone. SPPS provides the policy basis for planning agreements generally, whilst Policy HMO7 notes that a planning agreement [Footnote 12] may be required to ensure delivery of agreed management arrangements relating to PBMSA such as any formal links to a designated University or College or to ensure permanent occupation as student housing.

Planning Agreements

Broadly speaking, Planning Agreements permit a planning authority to enter into a legally binding agreement with a developer or landowner to make development acceptable that would otherwise be unacceptable in planning terms. The SPPS states that they may be used to:

• Enable the development to go ahead;
• Contribute to the costs of providing necessary local facilities;
• Permit development that would otherwise be unacceptable;
• Secure an acceptable balance of uses;
• Secure the implementation of development plan policies in respect of a particular area or type of development; or
• Offset the loss of, or impact on, any amenity or resource present on the site prior to development.

There are therefore a number of areas in relation to PBMSA where the Council may consider the use of planning agreements, including:

• Securing the provision of local facilities or services;
• Ensuring provision of and access to communal facilities or open space;
• Enforcing parking arrangements, particularly where parking standards have been reduced as a result of Travel Plan recommendations;
• Contributing to planned public realm improvements in the surrounding area;
• Delivering agreed management arrangements; and
• Controlling the type of accommodation permitted or the occupiers thereof, especially if concessions are to be given on normal planning standards (e.g. parking, open space) because the development is intended for occupation by students.

Developer Contributions

In relation to financial contributions, the SPPS outlines a variety of circumstances where such payments may be required, including:

• Where a proposed development requires the provision or improvement of infrastructural works over and above those currently programmed;
• Where earlier than planned implementation of a programmed scheme is required;
• Where a proposed development is dependent upon the carrying out of works outside of the site; or
• Where archaeological investigation or mitigation is required.

Community Benefit

The Council would also encourage developers to consider any benefits that could be offered voluntarily to local communities likely to be affected by a development. The SPPS notes that this could take the form of payments to the community, in-kind benefits or shared ownership arrangements. However, it should be noted that such ‘community benefits’ cannot be considered material considerations in decision-taking and are distinct from developer contributions that may be required to enable the development to go ahead.

Appendix A: Glossary of Terms

Accreditation Network UK (ANUK)
ANUK is a network of professional and organisations that promotes accreditation in private rented residential accommodation. It was formed in response to the increasing popularity of accreditation across the UK May 2002 to publicise, promote and share good practice in accreditation.

Area of Townscape Character (ATC)
ATCs are specific areas designated within a Local Development Plan that exhibit distinct character and intrinsic qualities, often based on the historic built form or layout in many of our cities, towns and villages. In assessing planning applications within ATCs, the key consideration will be to ensure that development proposals respect the appearance and qualities of each townscape area and maintain or enhance their distinctive character.

Belfast Metropolitan Area Plan (BMAP)
The local Development Plan for Belfast and the surrounding metropolitan area. It defines the policy framework and land use proposals that will be used to guide development decisions within a specified area.

Creating Places
Creating Places is a best practice guide describing the contributions to quality and sustainability that developers in Northern Ireland will be expected to make through the design of new residential developments.

Department for Communities and Local Government (DCLG)
DCLG is the UK Government department with strategic responsibility for communities and local government in England. It was established in May 2006 and is the successor to the Office of the Deputy Prime Minister.

Higher Education Institutions (HEIs)
HEIs are organisations that provide higher education courses. Most UK higher education courses are taught by universities, but plenty are also taught at colleges, specialist art institutions, business schools and agricultural colleges.

Higher Education Statistics Agency (HESA)
HESA is a charitable company which collects a range of data every year in relation to UK-wide from universities, higher education colleges and other differently funded providers of higher education. This data is then provided to UK governments and higher education funding bodies to support their work in regulating and funding higher education providers.

House in Multiple Occupation (HMO)
For planning purposes, a HMO is a house occupied by more than 2 qualifying persons, being persons who are not all members of the same family. A “qualifying person” is a person whose only or principal residence is the HMO.

Material Consideration
Any factor that can be considered relevant when making a planning decision as to whether to grant or refuse an application for planning permission. There is no legal definition for what constitutes a material consideration but they are understood through case law to include any consideration which relates to the use and development of land. Whether a particular consideration is material in any given case will depend on the circumstances.

Northern Ireland Statistics and Research Agency (NISRA)
NISRA is an Agency of the Department of Finance and Personnel in Northern Ireland and is the principal source of official statistics and social research on Northern Ireland. These statistics and research inform public policy and associated debate in the wider society.

Planning Policy Statement (PPS)
Set out the policies of the Department of the Environment on particular aspects of land-use planning. They apply to the whole of Northern Ireland and their content must be taken into account in preparing development plans and are also material to individual planning applications and appeals.

Pre-Application Community Consultation (PACC)
For major development proposals, applicants must undertake community consultation before submitting their planning application to help to create better quality developments and place making from the outset. This process is referred to as ‘Pre-Application Community Consultation’.

Pre-Application Discussion (PAD)
A prospective applicant can hold a ‘Pre-Application Discussion’ with the Council prior to submitting a planning application to confirm whether the principle of development is acceptable, to clarify the level of detail required to enable us to determine an application and to discuss, if necessary, how the community should be involved in the decision-making process. PADs are encouraged for a range of types of applications, both major and local.

Proposal of Application Notice (PAN)
For major development proposals, developers are required to submit a ‘Proposal of Application Notice’ 12 weeks before submitting a formal planning application, explaining how they will engage with the local community. The Council then has 21 days to consider the proposal and can either confirm their acceptance of the proposal or direct the applicant to modify their approach.

Purpose Built Managed Student Accommodation (PBMSA)
PBMSA is accommodation that is built, or converted, with the specific intent of being occupied by students undertaking a full-time course of higher or further education – either individual en-suite units or sharing facilities. The inclusion of the word ‘managed’ highlights the importance of such accommodation being centrally supervised by the developer or landlord to provide welfare support for students and to ensure compliance with any code of conduct or tenancy agreements, etc.

Secured by Design
Secured by Design is a UK project promoting the principles of designing out crime from the built environment. It focuses on crime prevention at the design, layout and construction stages of residential and commercial development and promotes the use of security standards for a wide range of applications and products.

Statement of Community Involvement (SCI)
The SCI sets out how and when the Council will engage with the local community in both the preparation planning policy and decisions around planning applications.

Strategic Planning Policy Statement for Northern Ireland
The SPPS is a statement of the Department of Environment’s policy on important planning matters that should be addressed across Northern Ireland. It identifies the objective of the planning system as being to secure the orderly and consistent development of land whilst furthering sustainable development and improving well-being. Its provisions must be taken into account in the preparation of Local Development Plans (LDPs) and are material to all decisions on individual planning applications and appeals.

Student Accommodation
A generic term that covers all forms of housing suitable for occupation by student, including both HMOs and PBMSA.

Sui Generis
A Latin phrase literally meaning "of its own kind; in a class by itself; unique". It is used in planning to refer to developments that do not fall within a specific class of the Planning (Use Classes) Order (NI) 2015.

Use Classes Order (UCO)
The Planning (Use Classes) Order (NI) 2015 specifies classes of use of buildings, or other land, that are not to be taken as involving development and which therefore do not require planning permission. A change of use is not to be regarded as involving development where the former use and the new use are both within the same class specified in an Order.

Appendix B: Checklist of Information to Support a Planning Application for PBMSA

General Information
There is a range of information required for most planning applications, regardless of proposed use and scale of development, etc. This includes:

• Application Form;
• A written description of the development, along with a postal address of the land to be developed;
• A Site Location Plan, sufficient to identify the site and the surrounding locality (preferably at a scale of 1:1,250 or 1:2,500);
• A Certificate of Ownership – to inform all concerned who is in actual possession of the application site;
• Notification of the proposed development to any affected occupier on neighbouring land; and
• Drawings – Fully annotated detailed drawings of the proposed development to an appropriate scale.

The application should be accompanied by three additional copies of the application forms or plans and the appropriate application fee. Read more about the information required when applying for planning permission or other types of development.

Pre-application Information
Where pre-application consultation is undertaken (NB: for major and regionally significant developments this is a requirement):

• A Pre-Application Community Consultation (PACC) Report should be provided, outlining:
  • Details of the consultation that has been undertaken with the local community on the development proposal;
  • How comments received from the community have been responded to; and
  • If any changes or mitigating measures have been included in the proposal as a result of the consultation.

PBMSA Information
Additional information to support planning applications for PBMSA:

• Design and Access Statement – A statement explaining the design principles and concepts that have been applied to the proposal. As a minimum, for applications for PBMSA, this 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 – A statement outlining the proposed provision of any landscaped areas, open spaces or amenity spaces within the overall design concept for the scheme, including future maintenance arrangements required.
• Transport Assessment – a comprehensive review of all the potential transport impacts of a proposed development, including a plan to mitigate any adverse consequences.
• Travel Plan – To actively encourage the use of alternative modes of transport to the private car, particularly cycling, walking and public transport.
• Consideration of impact – Information relating to the consideration of the impact, including cumulative impact, of PBMSA. This should include information relating to:
  • Existing student housing provision within an area;
  • Likely impact of the proposal upon demographics and local facilities or service provision in an area;
  • 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; and
  • Details of any measures included to help protect residential amenity and mitigate any potential adverse impacts on the surrounding area.
• Management Plan – A statement detailing the general management arrangements associated with the operation of the building. This could include:
  • Arrangements for the management and maintenance of the site, including any landscape or amenity space;
  • Details of 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 details of any deliveries required and provision for the storage and collection of waste and recycling;
  • Details of special features to improve the safety and security of students; including, for example, any CCTV provided, adequate lighting, intercoms, etc;
  • 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;
  • Details of any formal accreditation scheme (e.g. ANUK and Unipol or Universities UK) the operator plans to secure for the management of the completed development.
• Evidence of Need – provision of information to enable the assessment of need for the development, including:
  • The specific need that is being addressed;
  • Why this need is currently unmet;
  • The type of existing accommodation the potential student occupiers are likely to be drawn from;
  • Confirmation that the facilities are to be used exclusively for student accommodation;
  • Any recorded increase in student numbers;
  • University support, if available;
  • Current waiting lists for student accommodation; and
  • Bank funding available to deliver proposals.

Additional Information
There is a range of additional information that may be required in order to determine your application depending upon the location and nature of the proposal. Examples of additional information typically sought include:

• Archaeological Survey and Report;
• Biodiversity Survey and Report;
• Flood Risk Assessment;
• Land Contamination Assessment; or
• Noise Assessment.

This is not an exhaustive list it provides an indication of the broad range of additional information that may be sought depending on the complexity of the proposal or the particular circumstances of the site in question.

Appendix C

Footnotes

[Footnote 1] The five Higher Education Institutions (HEIs) 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)
[Footnote 2] Estates Gazette, 30 March 2013, p71
[Footnote 3] Available from: https://www.belfastcity.gov.uk/Planning-and-building-control/Building-control/Waste-storage-guidelines
[Footnote 4] For further details, see Secured By Design website at: www.securedbydesign.com (link opens in new window)
[Footnote 5] Available from: www.universitiesuk.ac.uk/aboutus/AssociatedOrganisations/Partnerships/ACOP/Pages/default.aspx
[Footnote 6] Available from: www.nationalcode.org
[Footnote 7] www.ninis2.nisra.gov.uk
[Footnote 8] www.hesa.ac.uk
[Footnote 9] https://www.economy-ni.gov.uk/publications
[Footnote 10] Queen's University Belfast accommodation information, Ulster University accommodation information, and Stranmillis University College accommodation information
[Footnote 11] You can search for planning applications by keyword, application reference, postcode or by a single line of an address using the Public Access portal.
[Footnote 12] As part of planning reform, Article 40 agreements referred to within existing policy documents have been replaced by Planning Agreements outlined within Article 76 of the Planning Act (Northern Ireland) 2011.