City of Edinburgh Council Local Development Plan Main Issues Report Representation

Transcription

1 City of Edinburgh Council Local Development Plan Main Issues Report Representation Prepared for Watkin Jones Group January 2012

2 Contents 1 Introduction Background Purpose of Representation Format of Representation Business Case Introduction Background to Watkin Jones Group Forecast Student Growth Supply and Demand Analysis of Student Accommodation in Edinburgh Watkin Jones Group Student Accommodation Management Regime Edinburgh Main Issues Report Policy Review Introduction Student Housing Houses in Multiple Occupation (Question 8) Infrastructure Provision Developer Contributions (Question 9) Sustainable Building Design (Question 18) Other Relevant Considerations MIR Conclusions Conclusions Summary Recommendation...11 COPYRIGHT JONES LANG LASALLE IP, INC All Rights Reserved 2

3 1 Introduction 1.1 Background This Representation has been prepared by Jones Lang LaSalle and is submitted on behalf of Watkin Jones Group ( WJG ) (hereafter referred to as the Client ) in relation to the City of Edinburgh (CEC) Local Development Plan ( LDP ) Main Issues Report ( MIR ) and their land interests in the city. 1.2 Purpose of Representation WJG welcomes this opportunity to comment on the key issues and options identified within the MIR. The purpose of this Representation is to provide an assessment of the MIR against the views of WJG and influence the form and content of the Proposed LDP with specific recommendations moving forward. The approach is informed by the experience of WJG in terms of their activity and in progressing development proposals in Edinburgh, together with wider experience from across the UK. 1.3 Format of Representation This Representation is structured as follows: Chapter 2 provides a background to WJG; Chapter 3 provides a policy assessment of the MIR; Chapter 4 presents overall conclusions from this report. COPYRIGHT JONES LANG LASALLE IP, INC All Rights Reserved 3

4 2 Business Case 2.1 Introduction This Section of the representation provides the background to WJG and their interests in Edinburgh. The company is an active developer in Edinburgh at a time in the economic cycle when there are many challenges to investment in the city. The recent and proposed developments are deliverable, not reliant on external funding sources, and result in job creating opportunities, and much needed inward investment opportunities. 2.2 Background to Watkin Jones Group Established in 1791, WJG is a ninth generation family business with a proven track record in developing commercial and residential properties, and developing and managing high quality student housing: Experienced developers of student housing since 1999 Watkin Jones has developed accommodation for over 18,500 students at universities across the UK. Experienced and responsible managers of student housing through Watkin Jones Management Company, Fresh Student Living, and the company currently manage 8 student accommodation schemes housing 2,500 students. In terms of Scotland, the current planned number of bed spaces is 1320, of which 1240 bed spaces are already consented, and 724 are operating at this time. Accredited by the National Code of Standards for Student Accommodation Management Accreditation Network UK (ANUK) ensuring good standards of housing management, minimising misunderstanding and disputes, and ensuring prompt resolution of any issues. ANUK is supported by the National Union of Students, the Department of Communities and Local Government, the Association for Student Residential Accommodation, the chartered Institute of Environmental Health Officers and Universities UK. A partnership approach Watkin Jones work closely with local authorities and universities to ensure high quality, appropriately designed schemes that enhance local amenity. Comprehensive and professional approach the company s service benefits from experience at all stages of the process from project planning and finance through site preparation and construction to long-term property management. Examples of schemes in Edinburgh include the involvement in the development of schemes at Fountainbridge and Grove Street (operated by iq) and at Beaverbank, Sugarhouse Close and Nicholson Street. WJG remain committed to Edinburgh and other site acquisition exercises are ongoing. 2.3 Forecast Student Growth Over the past decade the total number of students in higher education in the UK has grown at an annual rate of 3% and the UK is now the world s second most popular destination after the USA. In terms of the UK itself, Edinburgh has one of the largest student populations after London, Manchester, Birmingham and Glasgow. Competition for University places in recent years has also intensified. This is partly due to the recent recession as weak employment opportunities has encouraged school leavers to apply to university whilst current students stay on longer. It also reflects the fact that students and their families are less likely to buy flats as investments whilst at University as they have done in the past Demand from international students has also risen annually over the past decade and competition from overseas students is expected to grow and intensify further. Whilst there remains uncertainty on how higher tuition fees and funding cuts will affect student growth figures in the short term, over the medium term the forecast number of students entering university is expected to continue to rise, especially in overseas students. This position does however require to be caveated by the degree of uncertainty associated with any predictions on future activity. COPYRIGHT JONES LANG LASALLE IP, INC All Rights Reserved 4

5 There are a number of external factors that will influence the attractiveness of UK institutions to overseas students, all of which are largely beyond the control of institutions themselves or the UK and Scottish Government. This includes: Competition from other worldwide economies such as USA and Australia, which will drive competition for places; Changes to visa regulations in terms of part time and ongoing employment opportunities; Impact of tuition fees on Rest of UK (RUK) students; Political uncertainty / unrest in developing economies In terms of Edinburgh itself, there has been a steady growth in student numbers over the past decade across all institutions in the city. 2.4 Supply and Demand Analysis of Student Accommodation in Edinburgh There is an identifiable need for more purpose built student housing in Edinburgh and it is preferable that student needs are met as far as possible in purpose built and managed schemes. Such developments help to decrease the widespread conversion and use of family housing stock, and decrease the need to travel with students located on or adjacent to campuses WJG are committed to investing in Edinburgh with suitably located student accommodation schemes, of a high quality bespoke design that compliments surrounding land uses and are economically viable to ensure deliverability. The format of the accommodation is such that the provision appeals to a variety of students including postgraduate and returning students. WJG is also committed to linking up early in the development process with higher education institutions prior to lodging planning applications to give added weight to the business case of each individual development. This has led to historic and ongoing links with recognised institutions across Scotland such as University of Glasgow WJG also undertake their own analysis of the market and commercial case for each development and this is further strengthened in Edinburgh through WJG s recent and current experience in progressing student residence developments at Beaverbank and Sugarhouse Close. WJG s assessment of the market and demand factors presents a strong economic case for proposals to be considered as appropriate and deliverable WJG is committed to introducing land uses into areas that already benefit from an appropriate level of student activity in the surrounding area, and can sympathetically accommodate their proposals. To ensure this is the case, as a matter of course WJG holds extensive consultations with community stakeholders prior to pursuing developments to ensure that they have a say in the process. This includes taking on board comments from the community and stakeholders and adapting the development approach and design as necessary, and where appropriate. This transparent way of working allows for a balanced approach to be adopted with regard to WJG s developments, in terms of the business case, physical and policy context, and community aspirations to ensure the ability to deliver viable proposals that can be successfully accommodated in chosen locations. 2.5 Watkin Jones Group Student Accommodation Management Regime A unique attribute of WJG is that they manage the majority of the student accommodation developments that they develop through Watkin Jones Management Company, Fresh Student Living. The company ensures that all their sensitively designed developments are managed accommodation with extensive CCTV camera coverage around the property and a warden on-site 24/7. As a matter of course, WJG seeks to achieve Secure by Design status, the official UK Police Flagship initiative for supporting the principles of designing out crime. The wardens on site are not only in place to assist residents of the accommodation itself but are also accessible to the general public with regard to the operation of the facilities. As a company, WJG is committed to building relationships with the local community, University and the police to ensure that all parties are part of the process not only during the pre-application and development phase, but critically once the accommodation is operational. COPYRIGHT JONES LANG LASALLE IP, INC All Rights Reserved 5

6 2.5.2 As part of the standard management strategy, students at the site are also covered by a policy, which prohibits car ownership in the vicinity of the facilities, and this is controlled by way of a clause built into the tenancy agreement signed between the operator and the tenant. Future residents are made well aware that they will have to make their own travel arrangements at all times, and the no car policy is strictly enforced through the management arrangements for each development. COPYRIGHT JONES LANG LASALLE IP, INC All Rights Reserved 6

7 3 Edinburgh Main Issues Report Policy Review 3.1 Introduction The MIR is the first stage in producing a new LDP for Edinburgh, and when adopted, will replace the Edinburgh City Local Plan (ECLP) and Rural West Edinburgh Local Plan (RWELP) in guiding future development. This chapter provides an assessment of the key issues as identified within the MIR that are relevant to WJG and their business interests in Edinburgh. WJG have invested significantly in Edinburgh in recent and are committed to furthering their economic ties in the coming years through new developments and partnerships On the key issues identified within the MIR and CEC s preferred responses, WJG wish to respond to the following identified issues: Student Housing support s the Council student accommodation policy approach, however, there is a need to ensure that policy remains flexible and includes site specific analysis rather than a generic one size fits all approach to student housing development. Housing strengthen Council policy on Houses in Multiple Occupation (HMO s) within LDP with robust capacity analysis to ensure that it is successfully applied. Infrastructure Provision ensuring that financial contributions are reasonable, address key development requirements in the first instance and reflect market conditions and the viability of the scheme. Climate Change and Environmental resources Promoting Sustainable Design Each of the above MIR issues is considered in turn below. 3.2 Student Housing There is an appreciation that with the slow down in the mainstream residential market, the pressure for student accommodation and other large scale quasi residential uses in the City has grown in recent years. It should also be noted however, that this pressure is also market driven and not speculative. This development services the needs of the student population in the City that is growing on a year by year basis and provides high quality purpose built accommodation that frees up mainstream accommodation from HMO s for much needed private residential occupation, an issue that is of particular concern in Edinburgh. As outlined within the Monitoring Report, existing and pipeline purpose built student housing development is not sufficient to address the imbalance with general housing provision that is being used by students. Equally, the number of students studying in education between 2002 and 2009 grew by 20,000 and the amount of purpose built bedspaces has not kept pace with this rate. An overview of the business case for student accommodation development is summarised in Section 2 above Whilst WJG supports the broad objectives of Edinburgh City Local Plan Policy Hou 10 Student Housing and its Supplementary Guidance (SG) to ensure that development is appropriately located close to pubic transport nodes or a University Campus, and that proposal should not result in an excessive concentration of student accommodation in any one locality to protect general amenity, we are strongly of the view that in certain circumstances the current policy approach can provide additional and unnecessary barriers and burdens on the planning and development process, and place significant constraints on the viability of schemes Key planning policy issues in relation to student housing are stated within the SG that supports Policy Hou 10 and WJG s comments on this guidance document are outlined below. Student Housing Supplementary Planning Guidance CEC s Student Housing SG was approved in February 2010 and accompanies Policy Hou 10 to provide locational guidance and assessment information in the review of student accommodation proposals. Whilst it is COPYRIGHT JONES LANG LASALLE IP, INC All Rights Reserved 7

8 accepted that that there has to be policy criteria that enforces the suitability of sites for residential development, it is important that any such wording is not overly restrictive in terms of preferred locations or employing a map or capacity based approach to where development should and should not be located. At present this is the overly restrictive approach taken within the SG. Our client would strongly support Policy Hou 10 including a flexible approach to student housing development where it can be justified as a suitable location, even if this is located outwith an identified appropriate area. The Local Plan already provides sufficient guidance on this matter to ensure that new development is located, designed, and operated at locations that protect residential amenity and sympathetic to its surrounding land use. The map based approach will only create additional unnecessary barriers to development, especially where current SG policy states that outwith areas close to University Campus or good transport links, Elsewhere student housing will generally not be permitted WJS also challenges the current policy position that In other locations with good access to University and college facilities by public transport or by walking or cycling, purpose built student housing will be acceptable provided it will not result in a student population of 30% or more in the locality. This use of percentage thresholds on what constitutes a suitable concentration of student housing within a locale is overly restrictive and does not consider the fast changing environments that students stay in or their needs. It also does not consider the level of HMO s located within identified locales that are close to/above this 30% threshold and the need to free up this accommodation for mainstream family housing. One recognised way in to do this is to increase purpose built student accommodation, even where student population exceeds 30% As major developers in Edinburgh with existing operations, WJG are well aware of the existing planning policy assessment process for such decisions and support the need for all student accommodation planning applications to include supporting documentation such as design statement, civils statement, environmental reports, transport assessment, drainage impact assessment, and flood risk assessment to be submitted to ensure that they will not impact upon residential amenity. We would also state that in terms of modern day student accommodation, they are built and designed in a manner so as to reflect the characteristics and appearance of mainstream residential housing. Furthermore they are professionally operated to ensure that there is no impact upon the quality of life of neighbouring residents with strict 24/7 management regimes. With the above, even where there is more that one student development located within the same area, it is unreasonable to assume that this concentration would automatically impact upon residential amenity - the two uses can and do easily coexist alongside mainstream accommodation and other land uses commensurate with residential dominated urban environments We therefore request that Policy Hou 10 is amended to not include a reactive and overly restrictive condition on what is a suitable concentration of student accommodation development and is flexible in its application to include individual site consideration. Should a change in policy wording be proposed we would ask that this is fully consulted with the public prior to adoption. 3.3 Houses in Multiple Occupation (Question 8) With the recognised lack of purpose built student housing in Edinburgh, many students live together in Houses of Multiple Occupation (HMO) and this provides an effective way of meeting short term housing needs. However, over concentration of HMO s is an issue that the city is facing, especially with 5,943 HMO licenses (including renewals) in operation in Whilst it is accepted that CEC is restricted by Government policy on when a planning application is required (5+ people sharing), Scottish Government policy does allow planning authorities the power to manage HMP concentrations where these are affecting residential amenity. With this level of influence, rather than deleting Policy HOU 9 and allow full control by HMO license application only, which is a process that does not assess over concentration as part of its assessment, we would suggest that Policy HOU 9 is indeed strengthened in its policy wording and that a robust analysis of capacity is undertaken and included within the LDP. This will ensure that areas of high HMO concentration are identified not only to guide planning applications, but also as a tool for Planning and HMO Licensing to work closer together in the consenting process overall. COPYRIGHT JONES LANG LASALLE IP, INC All Rights Reserved 8

9 3.3.3 It is our client s view that to remove all HMO planning control would be detrimental to residential amenity across the city and leaves the Council in a vulnerable position in terms of its level of planning influence as this will be severely restricted. 3.4 Infrastructure Provision Developer Contributions (Question 9) WJG recognises that much of the infrastructure provided by CEC is obtained through the use of legal agreements which require developers to contribute financially towards the cost of providing improved infrastructure where it is associated with the needs of the development Whilst the MIR recognises that in the current economic climate, developer contribution sums may be at a level that are high enough to affect the viability of development schemes, the preferred Council option is to retain current policy and to not reduce contribution levels The preference for WJG would be for the reasonable alternative to be adopted during the lifetime of the LDP, namely to only require contributions to measures essential to allow development to proceed. This is to reflect not only the current economic climate but also to reflect the need to provide the development sector a stimulus to push forward in the short to medium term Should the preferred option rather than alternative proceed, we would ask that the provisions of Circular 1/2010 are applied in full, especially in terms of the necessity test and reasonableness. This will ensure that unnecessary financial burdens are not applied to planning consents that make them redundant and difficult to progress over the lifetime of the LDP. 3.5 Sustainable Building Design (Question 18) WJG are supportive of the need for sustainable building design considerations to be included within major development projects in Edinburgh. With all of its developments WJG seeks to ensure that BREEAM standards are met and that national building standards complied with in full to mitigate the effects of greenhouse gas emissions The MIR proposes to revise current planning policy to introduce two new requirements, namely the introduction of green roofs in new developments where SUDS do not need to be provided and the requirement that major developments include land or floor space reserved for CHP plants. On this proposed change, WJG would stress that all developments must be considered on their individual merits and that standard sustainable design criteria should not be applied to all major developments. In its place WJG would welcome the commitment within the LDP that developments should meet standard carbon reduction targets as set out within current Building Standards, and where possible, include additional carbon reduction design requirements where these measures can be reasonably implemented, including financial considerations. 3.6 Other Relevant Considerations Whilst it is acknowledged that there has been a considerable level of activity in Edinburgh in recent years in terms of the promotion and development of purpose built student accommodation, it is important to recognise that this is being driven by market demand, and student and institution expectations of a higher quality of accommodation in terms of specification and service delivery The scale of activity within the Higher Education sector in Edinburgh is such that it is a major employer and generator of direct and indirect economic benefit to the city as a whole. There remains a mismatch between the volume of full time students to university provided bedspaces, and as such there is clear demand and an opportunity to deliver more purpose built accommodation to meet the needs of students and institutions and in doing so provide opportunities to bring HMO properties back into mainstream housing use Student accommodation will always be a mix of purpose built accommodation and general flatted properties; however, it is clear form analysis of other key university locations around the UK that Edinburgh is behind the pace of change with regard to the quantum of modern bedspaces. On this basis, Edinburgh should encourage the COPYRIGHT JONES LANG LASALLE IP, INC All Rights Reserved 9

10 appropriate development of new facilities to ensure that the higher education institutions can continue to compete and attract students and investment in the face of ever increasing competition from other locations. The economic benefits of a vibrant and dynamic higher education sector can only be realised if the full suite of functions and services is adequately provide for across the city Whilst planning policy and specific locational or capacity guidance is one obvious threat to the future viability of student residential schemes, it is also relevant to highlight other constraints to development in Edinburgh, that can be addressed through a CEC wide review of the role and function of the sector and how CEC reacts to the market demand and dynamics of the sector in terms of its dealings across a range of Council functions. WJG have previously highlighted their concerns to CEC with regard to the excessive charging regime for HMO licensing in Edinburgh, and have provided evidence from experience throughout the UK to set this in context. In addition the changing requirements of building standards do not appear to adequately address the specific user requirements of student accommodation, and as a result WJG s experience is that an overly onerous interpretation of building standards requirements has often been placed on developments The combined effect of these two issues has the potential to jeopardise the viability of more marginal schemes, and WJG would welcome open and constructive dialogue with CEC on these matters in conjunction with the approach to wider policy and controls for the sector. 3.7 MIR Conclusions The MIR states that student accommodation land use requires a degree of additional policy guidance to ensure that development is directed to the most appropriate locations and provides a high quality living experience for its occupants. WJG supports this goal; however, the level of change proposed should continue to maintain a flexible approach to ensure that a one size fits all approach is not implemented and that applications continue to be determined on their individual merits, especially on issues such as location and impact upon residential amenity. COPYRIGHT JONES LANG LASALLE IP, INC All Rights Reserved 10

11 4 Conclusions 4.1 Summary WJG welcomes this opportunity to comment on the student accommodation issues and options identified within the MIR consultation process The specific recommendations of WJG for inclusion with the Proposed LDP moving forward is the following: Forecast student growth rates for Edinburgh is projected to continue to rise during the lifetime of the adopted LDP. To ensure that student accommodation demand is met, an appropriate planning policy base has to be set within the LDP to ensure that development is not stifled by undue policy constraints that prevent demand being met. In terms of concentration of student accommodation and its impact upon residential amenity, WJG would like to stress the importance of any such wording not being restrictive in terms of preferred locations or employing a map based approach to where development should and should not be located, as included within the SG. The LDP will provide sufficient guidance on this matter to ensure that new development is located, designed, and operated at locations that protect residential amenity and sympathetic to its surrounding land use. Additional policy control on restricting locations, student population thresholds or proposing new assessment criteria is not necessary. HMO Policy HOU 9 should be strengthened rather than removed from the LDP to ensure that planning control remains on the potential over concentration of HMO s across the city. In terms of Sustainable Building Design, all planning applications should be considered on their individual merits to ensure that an unreasonable financial burden is not placed on developers. 4.2 Recommendation WJG strongly recommends that the above points are considered within the MIR process and promoted within the Proposed LDP. Further dialogue with CEC on the matters referred to ion this representation is to be encouraged and welcomed. COPYRIGHT JONES LANG LASALLE IP, INC All Rights Reserved 11

12 Craig Wallace Director 7 Exchange Crescent Conference Square Edinburgh EH3 8LL Craig.wallace@eu.jll.com Shahid Ali Senior Development Planner 150 St Vincent Street Glasgow G2 5ND Shahid.ali@eu.jll.com COPYRIGHT JONES LANG LASALLE IP, INC This publication is the sole property of Jones Lang LaSalle IP, Inc. and must not be copied, reproduced or transmitted in any form or by any means, either in whole or in part, without the prior written consent of Jones Lang LaSalle IP, Inc. The information contained in this publication has been obtained from sources generally regarded to be reliable. However, no representation is made, or warranty given, in respect of the accuracy of this information. We would like to be informed of any inaccuracies so that we may correct them. Jones Lang LaSalle does not accept any liability in negligence or otherwise for any loss or damage suffered by any party resulting from reliance on this publication.