2.71 Purpose Built Student Accommodation is accommodation built, or converted, with the specific intention of being occupied by students. Such accommodation is usually provided in the form of cluster flats with shared facilities, individual en-suite units, or studios, and relates to buildings which are not classified by planning use class, or licensing, as HMOs. In Bath, recently built private PBSAs are largely in the form of studios, many of which are built on former employment sites within the city.
2.72 The Council’s current policy framework seeks to address student accommodation needs arising from universities’ expansion, whilst not prejudicing other economic, environmental and social objectives from being achieved across the district.
2.73 Policy B1 in the Placemaking Plan sets out a spatial strategy for Bath, including enabling the provision of additional on-campus student bed spaces at the University of Bath and Bath Spa University, and new off-campus student accommodation (subject to policy B5), thereby facilitating growth in the overall number of students whilst avoiding growth of the student lettings market.
2.74 Policy B5 in the Core Strategy seeks to restrict off campus student accommodation in certain locations – the Central Area, the Enterprise Area and MoD land.
2.75 The Council’s preferred approach to student housing is, in principle, that future student needs are met, where possible, in purpose-built and managed schemes preferably on-campus, rather than the further conversion of family homes to Houses in Multiple Occupation. Longer term, there may be scope to provide enough students with suitable purpose-built accommodation, that demand for HMOs across the district falls, allowing the conversion of some HMOs back into general housing use.
2.76 A recent increase in the number of off-campus PBSA developments across the city has raised concerns that current policies are not strategically directing such development to suitable locations, leading to a rise in issues, comprising:
- Provision of PBSA on sites that could be used for general housing / employment uses.
- Over-provision of PBSA bed spaces.
- Over-provision of certain types of PBSA (i.e. studios).
- Provision of PBSA in locations where a high percentage of the local population is already made up of students, leading to the exacerbation of issues generally associated with these areas (i.e. noise disturbance).
2.77 Recent engagement with the Universities has specified that although there is currently uncertainty in the higher education sector due to Covid-19 and Brexit, there will likely be a continued demand for student bed spaces in Bath over the next 10 years, especially in order to address the issues with HMOs. The University of Bath’s growth strategy focuses on improving student experience by improving facilities, with broadly no net increase in student numbers. However, Bath Spa University’s growth strategy includes for a net increase of 100 students per annum, up to 2029. This is also to recover from the lower student intakes resulting from the demographic changes and COVID-19.
2.78 Other educational establishments within Bath, such as Bath College, Norland College and various language schools, may also require access to student housing.
2.79 In order to minimise the issues associated with current PBSA provision, this options document explores ways in which policies could be amended or created to provide a more strategic approach to the provision of off-campus PBSA. This includes reviewing Policy B5 to make it clearer that the strategy is to direct PBSA to on-campus opportunities and for it to only be allowed on sites elsewhere if a need can be demonstrated. Options are then presented for further policies to address this approach in greater detail.
Consultation Reference DM 21
Amend Policy B5 to clarify that as a first priority PBSA should be developed on-campus and that it will only be allowed on other sites where a need can be demonstrated (with further detail to be set out in either Policy H2B or an amended Policy H2). In the Central area and Enterprise Zone it will remain the case that PBSA will also not be permitted where it would adversely affect the realisation of the vision/strategy for the city in relation to delivery of housing and economic development.
Consultation Reference DM 22
Proposed options for consultation
Option 1 – Introduction of new policy H2B to restrict PBSA to allocated sites, or elsewhere in the district only where need is demonstrated. This seeks to direct the majority of PBSA development to allocated on-campus sites, except where an established need associated with an educational establishment can be demonstrated. Demonstration of need would be required in the form of a formal agreement between a developer and an education provider, confirming the number of bedspaces and accommodation type required. This option provides flexibility to educational establishments during a time of growth uncertainty, whilst restricting the development of off-campus PBSA in general across the city.
Option 2 – Increase the scope of policy H2 to refer to PBSA, including assessment against the HMO threshold test. This option seeks to restrict the development of PBSA in areas where a high concentration of Houses in Multiple Occupation already exists (as defined in the HMO SPD). This option would require PBSA developments to be assessed against the same criteria as HMOs, as set out in policy H2 of the Placemaking Plan.
Option 3 – No policy change and retains policy in its current form, allowing development of PBSA across the city, except for the areas specified in policy B5 of the Core Strategy.
2.80 Suggested policy wording for Option 1
Consultation Reference DM 23
Option 1: New Policy H2B – Purpose Built Student Accommodation
Purpose built student accommodation of an appropriate scale and design will be permitted:
a) On allocated sites, where student accommodation use is specified in the allocation; or
b) Elsewhere in the district (except for areas restricted by policy B5), where it can be demonstrated that there is a need for additional student accommodation.
All proposals for new, extensions to, or conversions to, Purpose-Built Student Accommodation on sites not allocated for student accommodation, will be required to demonstrate that:
i. There is a need for additional student accommodation of the type proposed, evidenced by a formal agreement between the developer and a relevant education provider, for the supply of bed spaces created by the development;
ii. The proposal will not result in a significant negative impact on retail, employment, leisure, tourism, housing or the council’s wider strategic objectives;
iii. The site is in a location accessible by sustainable transport methods, including to the educational establishment to which it is associated;
iv. The use of the site for student accommodation is appropriate in relation to neighbouring uses;
v. The development will not have an unacceptable impact on the amenity of surrounding residents. A management plan will be provided prior to occupation of the development, to ensure adequate management arrangements have been incorporated;
vi. The internal design, layout and size of accommodation and facilities are of an appropriate standard and an adequate level of outdoor amenity space is provided for use by occupiers;
vii. The proposal provides an appropriate level of car parking having regard to relevant standards (to be defined in a SPD), and provides adequate provision for servicing, pick up;
viii. The proposal provides adequate storage for recycling/refuse and bicycles, in line with relevant standards;
ix. The development has been designed in such a way that it is capable of being re-configured through internal alterations to meet general housing needs in the future if necessary; and
x. The proposal accords with other relevant Local Plan policies relating to, but not limited to, impact on the historic environment, high quality design, landscape, transport and access, flood risk and drainage, nature conservation, pollution and contamination, and responding to climate change.
Consultation Reference DM 24
Option 2: Amendment to policy H2
District-wide a change of use from residential (C3) to a large HMO (Sui Generis use class) will require planning permission. In Bath, a change of use from residential to a small HMO (C4) will also require planning permission as there is a City-wide Article 4 Direction in place. Planning permission is also required for the provision of new, extensions to, or conversions to Purpose Built Student Accommodation. The following criteria will be considered when determining these applications:
i If the site is within Bath, and within an area with an high concentration of existing HMO and PBSA (as defined in the Houses in Multiple Occupation in Bath Supplementary Planning Document, or successor document), further changes of use to HMO or provision of PBSA use will not be supported as they will be contrary to supporting a balanced community;
ii The HMO or PBSA use is incompatible with the character and amenity of established adjacent uses;
iii The HMO or PBSA use significantly harms the amenity of adjoining residents through a loss of privacy, visual and noise intrusion;
iv The HMO or PBSA use on its own or cumulatively results in a severe transport impact;
v The HMO or PBSA use results in the unacceptable loss of accommodation in a locality, in terms of mix, size and type;
vi The development prejudices the continued commercial use of ground/ lower floors.
Where new build PBSA is proposed, development should be consistent with other relevant Local Plan policies and guidance.