St Joseph’s ... meet Woodland Court (Comment)

Since Harringay Real Estate has not yet submitted a planning application, it’s too early to say definitively how its proposals will fare when they’re assessed against Bristol City Council’s published policies governing student accommodation.

But one factor that could influence the outcome is already obvious—it stands directly opposite the St Joseph’s site on the other side of the street.

Woodland Court is a commercially managed development comprising four multi-storey blocks of student flats, providing 196 beds in total. By my reckoning, that means the council’s quota for so-called purpose-built student accommodation (PBSA) in this area has already been exceeded, making it hard to see how a further 131 beds could win planning approval.

Here’s the detail, with reference to official documents (if you just want to see the arithmetic, skip to section 4 below):

University of Bristol has roughly doubled its student rolls over the past decade, to approximately 34,000 this year. The council says it’s been told to expect about 8,000 more by 2040.

To meet the challenge, BCC has formulated detailed policies governing how much student accommodation can be built in different parts of the city. These can be seen in a series of documents setting out the city’s Local Plan:

1. We start with the 2011 Local Plan, a suite of documents, including Site Allocations and Development Management Policies, in which Policy DM2 covers “specialist student accommodation” and other forms of housing: "Proposals ... will not be permitted where: (i) The development would harm the residential amenity or character of the locality as a result of any of the following: Levels of activity that cause excessive noise and disturbance to residents; or Levels of on-street parking that cannot be reasonably accommodated or regulated through parking control measures; or Cumulative detrimental impact of physical alterations to buildings and structures; or Inadequate storage for recycling/refuse and cycles. [or] (ii) The development would create or contribute to a harmful concentration of such uses within a locality as a result of any of the following: Exacerbating existing harmful conditions including those listed at (i) above; or Reducing the choice of homes in the area by changing the housing mix.

   It's open to argument whether, given this wording, the St Joseph’s proposal would pass or fail either of the tests I’ve highlighted in bold.
   

2. There is greater clarity in the 2023 Local Plan, a draft revision currently awaiting central government approval (held up since 2024 by a wrangle over housebuilding targets). The submitted documents are listed here, including the core Local Plan document, CSD001. This now has a whole new section, Policy H7: Managing the development of purpose-built student accommodation. Although the 2023 revised Local Plan hasn’t yet received final approval, it seems likely its contents will nonetheless have legal standing—they are essentially more fully articulated explanations of how the 2011 principles cited above should be interpreted and applied. (They have also benefitted from public consultation: BCC invited feedback on its emerging student accommodation policy in 2022; I submitted a detailed reply.)
   

3. So, how would Policy H7 apply to the St Joseph’s proposal? First, recognising that PBSA is more acceptable in some parts of the city than others, H7 divides Bristol into four buckets (my term, not theirs):

   1. UoB’s existing residential sites in Clifton and Stoke Bishop,

   2. Five growth and regeneration areas, listed as: the UoB precinct centred on Tyndall Avenue, its new site in Temple Quarter, Broadmead, the Frome Gateway, and Central Bedminster,

   3. Areas where more PBSA is “demonstrably supported by local communities”,

   4. All other locations, where “Development should: ... Not result in a local imbalance of [PBSA] within any residential, city centre commercial area or town centre; ...”
      

4. St Joseph’s doesn’t fit a or b, and likely won’t fit c. So it’s d. This is significant, because as paragraph 6.87 of Policy H7 explains:“As a guide the council considers that a local imbalance of [PBSA] is likely to occur where bed space numbers within 200 metres of the site (including the proposal) exceed a threshold of 100 bed spaces within residential areas ...” In practical terms, you draw a 200m-radius circle on a map, centred on St Joseph’s, and count all PBSA beds within the circle—existing plus proposed. If the result exceeds 100, you’re over the limit. Woodland Court is within St Joseph’s 200m circle and has 196 beds, so the limit is exceeded even before we add anything else. (For comparison, the acceptable beds limit in other areas such as those within the city centre is 1,000. The full methodology is shown in a supporting document: Topic paper TPC006 on PBSA.)

   
   

5. For good measure, H7 recognises that PBSA is just one kind of student accommodation; another kind is student-occupied HMOs. It says: “In all cases the proximity and concentration of houses in multiple occupation should also be taken into account.” By my rough calculations, St Joseph’s 200m circle would also include 35 to 40 HMOs in nearby streets. Probably nearly all are occupied by students, adding 250 or more beds. So the full count of student beds at this location (131 at SJ + 196 at WC + 250 in HMOs) would be approaching 600—nearly six times the limit.