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Planning matters

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Housing Land – How can NPF4 ensure the housing delivery that Scotland needs?
With the world and society in the midst of a paradigm shift in how we socialise, go about business or even go to the shops, planning reform in Scotland continues. The Scottish government’s consultation on NPF4 ended on 30 April with this being the first of the major changes arising out of last year’s Planning (Scotland) Act to start filtering through. Lichfields has prepared and submitted a response to the consultation, specifically focussing on its Housing Technical Discussion Paper. The Technical Paper sets out the Scottish government’s initial thoughts on how housing need and demand will be planned for as part of an enhanced NPF which will for the first time form part of the statutory development plan. With housing supply targets/housing land requirements now being set to be included within NPF instead of strategic development plans and/or local development plans, there are a host of considerations about how best to plan for housing. Building on our experience across Scotland as well as best practice from elsewhere in the UK, we’ve set out our suggestions, the key findings and recommendations of which include: Streamlining in the setting of housing land requirements is welcomed but must not come at the expense of robustness and transparency; The focus should be on outcomes, namely the delivery of homes, not simply land that homes could be built on; We must plan looking forward, based on need, demand and policy objectives, not past trends; Consistency in approach across Scotland will lead to greater transparency and efficiency both in formulation and scrutiny; Housing Land Audits should be standardised and include housing trajectories and monitoring of delivery with realistic programming for all sites included. Lichfields ‘Start to Finish’ research is a good starting point for understanding the length of time housing sites take to come forward; NPF must require that LDPs maintain a minimum 5 year supply of truly deliverable effective land for housing at all times – this will require ongoing monitoring during the 10 year plan cycles we’re moving toward with steps for mid-cycle intervention if necessary; Deliverable land must be identified for the entire plan period; Viability and marketability should play an enhanced role in considering the effectiveness of land for housing and its distribution around plan areas. We’re looking forward to seeing how this pans out and hope that the significant opportunity to shake up how we plan for and deliver housing is grasped.

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Creating sustainable communities – the future of Edinburgh’s student housing policy
Edinburgh City Council is looking to require Purpose Build Student Housing Schemes to also provide mainstream and market housing on site and require proposed developments to be built for and managed by a university or college. Edinburgh is one of the UK’s top student cities, with four Universities and three further education colleges. The University of Edinburgh is a member of the Russell Group and is ranked within the top 20 universities in the UK, and Heriot-Watt, Queen Margaret and Edinburgh Napier all feature in the top 100. In Edinburgh, around 80,000 students were enrolled in further or higher education in 2017, one of the UK's highest student concentrations. Compared to other UK cities, Edinburgh has the highest proportion of non-UK students and the highest proportion of EU students.  Over the past 20 years, full time students enrolled in the City’s four universities have risen significantly. With student numbers increasing there is added pressure on existing housing stock.       Lichfields is preparing a case study of Edinburgh using our BedSpace toolkit.  This looks at the potential for the City to accommodate additional Purpose Build Student Accommodation. The BedSpace model draws together information relating to housing capacity, demand and market signals. If you would like a copy of this case study please contact Nicola Woodward.  If you would like this analysis carried out for other university cities in the UK please also get in touch.   Edinburgh City Council produced non statutory guidance on student housing in 2016. The guidance aims to set out how the Council will encourage the further provision of purpose-built student accommodation and balance the needs of the existing community and the need for general housing.  New policy proposals for student housing in Edinburgh The City Council are preparing a new Local Development Plan (City Plan 2030) and have published their Choices 2030 document (essentially their Main Issues Report) for consultation until end April 2020.  Here under the banner of Creating Sustainable Neighbourhoods (Choice 10) the City Council consider future policy in respect of student accommodation. The Choices document highlights Student housing as one of a number of development types that are being built at the expense of sustainable communities and states that the Council wants sites coming forward for such uses to also deliver new housing.  To this end the Council are proposing the introduction of the following requirements for new purpose-built student accommodation (PBSA): to be located on a direct walking, cycling, or public transport route by to an intended university or college, not just be generally in an appropriate location as is the requirement of the existing policy HOU10; to deliver market and affordable housing within the development; to be built for and managed by one of Edinburgh’s universities or colleges; and, to deliver a maximum of 10 % studio flats. In addition to this policy change, the Council proposes in their Choices Document that unallocated sites over 0.25 hectares coming forward for student housing will require at least 50% of the site to be for market and affordable housing development. There are 2 elements of this proposed policy change that are particularly concerning. The first is the requirement to deliver affordable housing alongside PBSA in locations that meet the needs of students, but not necessarily of affordable housing tenants; and the second, is the deliberate precluding of the private market from the provision of student accommodation in the city.  These are explored below. PBSA and affordable housing – a unhappy mix It is unclear why the locational requirements of affordable housing is thought to be the same and harmonious with those of students by the City Council. Students want to be near universities, nightlife and leisure facilities. Households in social rented housing are often families or older people who will ultimately have different housing requirements.  Being close to their social networks, being located in areas with easy access to convenience retailing where their shopping needs can be met and near facilities such as doctors, playparks and schools are far more important to them.  These are rarely found in city centre locations close to universities.  In addition, there are the potentially conflicting life styles between residents and students, which quite often result in complaints. Delivering PBSA to meet growing demand The proposed 50 % requirement for housing on unallocated sites, if adopted, will have a significant impact on the student housing sector in Edinburgh, as will the requirement for the accommodation to be built for and managed by a university or college.  It is unclear why the City Council are proposing to preclude private providers of PBSA from the city by requiring new accommodation to be managed by a university or college.  The PBSA market is well established in the UK and the quality of the product is extremely high. Indeed, very often it is of a significantly higher quality than that provided by universities and the management of the facilities is first class. This is particularly important for non-European students who have extremely high expectations in terms the quality of accommodation they will accept. This proposed policy is potentially very damaging for the prosperity of the universities and colleges of the city and their attractiveness to foreign students.  It will also have a devastating effect on the PBSA market in the city if private providers are excluded.  Our research shows the potential demand for a further 5,170 bedspaces in the city.  If these are not provided in purpose-built units, the impact on the housing stock in the city centre will continue to be felt.  Many cities have for the past 10 years or more been embracing the development of purpose-built student accommodation to remove the pressure on popular residential areas from homes in multiple occupation (HMOs).  Edinburgh is struggling to meet its mainstream housing needs and it would seem logical to put in place polices that allow the return of traditional housing stock to the mainstream market by providing more, not less, bespoke accommodation for students. Edinburgh is well reported as a ‘hotspot’ for investment in PBSA as demand continues to outstrip supply[1] and this policy change, as proposed, will not adequately address the issue.  A consequence of the proposed policy, whether intended or otherwise, is that speculative PBSA developments will drop off considerably with the ability to progress such schemes all but precluded. So what for the future? Student housing providers with an interest in Edinburgh should take note and make representations to the City Council on their emerging Local Development Plan.  Representations to this Choices document can be made until 30 April 2020 and it is expected at the end of the summer the proposed plan will be published ahead of its examination and adoption.  With a number of Local Development Plans now under review, it will be interesting to see if other local authorities follow Edinburgh’s lead and propose to introduce a similar approach to student housing. If you are interested in student housing development in Edinburgh, or elsewhere in Scotland, please get in touch with Lichfields. Arabella Stewart-LesliePlannerarabella.stewart-leslie@lichfields.uk Nicola WoodwardSenior Directornicola.woodward@lichfields.uk [1] Knight Frank Global Student Property 2019 Report

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