Object

Representation ID: 22094

Received: 13/03/2020

Respondent: Watkin Jones Group

Affordable Student Accommodation

The draft GNLP provides policy to meet the plan’s key ‘Homes’ objective. This policy wording would benefit from increased flexibility within the affordable housing requirements for purpose-built student accommodation. Policy 5- Homes of the draft GNLP states that all residential development proposals and student accommodation must provide affordable housing on site. In the wider Greater Norwich area, 33% affordable housing provision is required, with a reduction to (at least) 28% for sites within Norwich City Centre.

WJG recognise and support the need to ensure that a proportion of PBSA is provided at multiple price points in the Greater Norwich area if Higher Education Institutions (HEI’s) are to continue to attract students from a range of
backgrounds. WJG have direct experience of the impact of affordable student accommodation policy on the overall supply of PBSA especially in locations such as London, where there are similarly prescriptive policies in place. As a consequence of this policy, PBSA delivery in London has significantly contracted in the period since 2017. Bed delivery was c3,500 beds per annum prior to the introduction of the affordable student accommodation policy, but it is understood that c2,000 beds will come to market during 2020; significantly less than the 3,500-target figure. The lack of competition and constrained supply is projected to increase rental growth to the detriment of all students. In turn, this would impact on student desirability to choose HEI’s in the Greater Norwich area which will have wider, negative
effects.

Norwich City Council’s report ‘Purpose Built Student Accommodation in Norwich: Evidence and Best Practice Advice Note’ (November 2019) sets out guidance and requirements for PBSA in Norwich City Centre focussing on the University of East Anglia and Norwich University of the Arts. It is noted that this document should help to inform emerging policy relating to student accommodation in the GNLP. In reviewing this report, it is noted that affordable student accommodation is a national issue for local authorities and for HEI’s alike. The report notes that student accommodation proposals are not required to provide affordable housing, however a commuted sum is encouraged from PBSA developments on sites allocated for residential or residential- led development. This aims to mitigate any
loss of affordable housing provision from PBSA developments and allows for off-site provision. The report provides information relating to the ways that opportunities for affordable housing can be lost due to PBSA developments, however there is very limited evidence analysing the need/ benefits of affordable student accommodation within the Greater Norwich area.

WJG would recommend therefore that the Council commission further analysis before introducing a policy requirement which may have a negative impact upon the supply of PBSA within the Greater Norwich area and which may in turn affect the ability to attract talent to the area and cause a detrimental effect to both the Economy and Homes objectives set out in the draft GNLP.

Should the Council conclude there is a justifiable requirement for PBSA developments to incorporate a proportion of affordable accommodation, WJG would request that there are in-built appropriate levels of flexibility, whereby:
- A reduced level of affordable provision is capable of being justified by reference to a development viability
assessment; and
- A reduced level of affordable provision may be accepted where developments deliver other significant and substantial regeneration benefits.

WJG would also note that the following will assist with addressing issues of affordability:
- A more permissive approach, whereby an uplift in PBSA delivery can be sustained, will ensure a better
balance of demand and supply, which is undoubtedly a key driver of price; and

The policy also states that 10% of the affordable homes should be available for affordable home ownership where this meets local needs. This requirement is not applicable to PBSA. As PBSA is privately rented accommodation, this statement does not apply and is in direct opposition to objectives set out within the NPPF. The NPPF states that student accommodation should be exempt from this requirement. WJG therefore recommend that this section is removed.

Conclusion
We trust that the student accommodation comments within this representation will be considered and incorporated into
any future approved GNLP strategy or planning guidance that may follow from it. We would kindly ask that we retain the opportunity to further engage with yourselves moving forward.