Towards a new London Plan: balancing PBSA in London’s next growth chapter

Balance

The plan acknowledges that PBSA can help release private housing stock back to the general market – a crucial benefit in a city with significant unmet housing need. However, it also raises concerns about PBSA dominating local development and reshaping neighbourhood character, particularly in central and high-demand locations.

The current London Plan sets a strategic requirement of 3,500 new PBSA bedspaces annually (without borough-led targets), recognising that the distribution of student demand and development opportunities varies across London. In our view, this London-wide approach should remain unchanged. 

Introducing borough-level PBSA targets or mandatory site allocations risks limiting delivery in areas with high student need and viable sites. Borough-led targets may potentially be perceived as arbitrary, leading to refusals once limits are exceeded; therefore, we believe they should be treated as minimum rather than maximum targets. Demand for PBSA tends to follow where there are higher education campuses where the provider will have their own accommodation requirements, often across multiple boroughs. Therefore individual borough targets would not be appropriate.

Affordability

Affordability remains a central theme of the new London Plan. Current policy requires 35% of PBSA units be affordable (defined as no more than 55% of the maximum maintenance loan), and the consultation asks whether this rigid approach is fit for purpose. We agree that greater flexibility is warranted, particularly if it allows high quality schemes to come forward that might otherwise stall.

Importantly, the consultation suggests that university nomination agreements, currently required for PBSA, will be limited to just affordable student accommodation. This is a change we support in principle. It would allow providers to serve a broader student demographic, including those studying outside the borough, while ensuring affordable units remain institution-linked, often locally and within the borough.

Contributions

The role of PBSA in contributing to wider affordable housing objectives is also under review. The new London Plan asks whether student and affordable general housing should be treated interchangeably when it comes to affordable provisions. From a delivery standpoint, this poses a challenge. While PBSA buildings can be designed to allow for future conversion to an alternative use (dwellinghouses, co-living or hotel) if required, delivering PBSA and conventional C3 affordable housing within the same scheme poses significant operational, management and fire safety (as C3 residential generally cannot share a core with PBSA) challenges, potentially making a mixed-tenure model on a single site unfeasible in most cases. There may be some larger sites within boroughs that can accommodate multiple buildings and therefore this should be considered on a site-by-site basis.

We therefore advocate that PBSA schemes contribute affordable student rooms only, aligned with their purpose and design.

Maintaining delivery

As the plan seeks feedback on the balance between borough and city-wide regulation, we support retaining London-wide strategic targets while preserving borough-led flexibility. Importantly, we consider that individual borough targets could constrain the market and hinder progress towards London’s broader housing goals.

At a time when planning must focus on enabling – not restricting – delivery, it’s vital that PBSA is recognised as a specialised, essential component of London’s housing ecosystem.

We look forward to continuing the conversation and working with stakeholders to ensure the next London Plan is responsive, evidence-based, and delivery-focused.

Further information

Contact Scott Hudson or Harriet Young