Build Homes Now! - Report by Participation and Practice of Rights and Equality Can't Wait - Participation and the Practice of Rights
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Build Homes Now! A sustainable solution for Dunnes/Hillview, North Belfast Report by Participation and Practice of Rights and Equality Can’t Wait
Table of Contents
p.3-4 Equality Can’t Wait Residents’ Foreword
p.5 Who we are
p.6 Introduction
p.7-8 Housing need in north Belfast
p.9-25 What obligations must be discharged when making a planning
application decision at Dunnes/Hillview?
4.1 Human Rights Obligations
4.2 Equality legislation and policy including Section75 (1)
of the Northern Ireland Act 1998
4.3 Programme for Government (PfG) 2016-2021
4.4 Planning Guidance and Strategies in Northern Ireland
4.5 Key Themes for Planning Decisions
a) The identification and facilitation of land
b) The need to build housing
c) Sustainable development
d) ‘The Belfast Agenda‘
e) Strong preference for use of existing land in
building housing
f) Any other material considerations (including
community opinions)
p.26-27 An Alternative Proposal - a sustainable solution for
Dunnes/Hillview
p.28 Conclusion
p.29-30 Appendix - Political Party messages of support
2
Equality Can’t Wait
Residents’ Foreword
Dear Private Developers
Minister for Communities
Minister for Infrastructure
Belfast City Council Planning Committee
Belfast City Councillors
MLAs
Northern Ireland Housing Executive
Housing Association Chief Executives
This is an open letter to decision makers in our society regarding recently announced plans by private
developers to exclude social housing on precious empty land at Dunnes/Hillview retail park, north
Belfast.
With this letter you will find a detailed report of how you can take decisions which will lead to more
social housing for the many thousands on the waiting list.
We hope you take the time to read it
Equality Can’t Wait standing up for
and act on your responsibilities to
homeless families at Dunnes/Hillview site
protect and promote the human right to
housing.
We are the residents of the Equality
Can’t Wait campaign and our rights are
being denied. We are suffering because
of ongoing religious inequality in social
housing provision. Our campaign began
in north Belfast but has since grown and
supports many people from all
communities across the city.
We are families, mostly mothers and children, who have been waiting for years for a place to call
home. Between us we have thousands of social housing need points. If we could move safely to
areas of low demand we would be rehoused tomorrow. But it is not safe because our city is divided,
so we wait.
While we wait we live in hostels, in temporary private single let accommodation, in such poor
conditions that our children are made sick. While we wait we live in expensive insecure housing with
unaccountable landlords. While we wait we are homeless and sleeping rough or dependent upon the
charity of family and friends. While we wait our children grow up with nowhere to play, nowhere to call
home, nowhere to make friends.
3
We have all complained and written to politicians, ministers and housing providers. We have supplied
detailed evidence of how our human rights are being denied. We’ve had councillors, MLAs, doctors,
social workers, advice workers, family support workers and human rights campaigners speak on our
behalf to stress just how badly our families are affected.
Three times the United Nations have called for action to tackle religious inequality and three times the
NI Assembly Executive done nothing. In the last year the Children’s Commission, the Human Rights
Commission and the Equality Commission have all spoken out as well.
For years we have watched land which could become homes and communities being used up and
sold off. Over 2000 student housing units are planned for Belfast City Centre but where are the homes
for families on all the empty land we have found?
At the same time we are blamed. We are told our housing problems are somehow our fault because
we were born in areas of high demand. We are told there is no money or land. This is this untrue. We
know from our research that the money is not the problem and we have identified all the land in our
communities including five big sites across the city in areas of high demand.
In the last year representatives from five political parties at the assembly (Sinn Féin, SDLP, Alliance,
People Before Profit, Green Party) have met with us, demonstrated with us, signed our petitions and
publicly called for social and affordable housing at these big sites;
• North Belfast - Dunnes Stores/Hillview Retail Park and Nelson Street
• South & East Belfast – Sirocco Works
• West Belfast - Mackies site/Monagh bypass
• Belfast Harbour
All seven parties that sit on the Belfast City Council planning committee made pledges to deliver
social housing in recent Assembly and local government manifestos.
Now it’s time for action in support of families. We can’t wait any longer.
Below are our objections to the current plans to exclude social housing from the Dunnes / Hillview site
in north Belfast.
More importantly, we explain how developers and elected representatives can work with families’ to
see precious land used to meet the needs of the people of the city.
Signed
Kelly Mon
on behalf of the Equality Can’t Wait campaign
4
1. Who we are
Participation and the Practice of Rights (PPR) is a human rights organisation located in
Belfast, Northern Ireland. Established in 2006 by human rights activist and trade unionist Inez
McCormack, PPR supports marginalised groups to use human rights tools to realise their
social and economic rights. In 2012, PPR’s unique approach was recognised by the United
Nations Office of the High Commissioner for Human Rights as a good practice example of how
communities can claim their rights.
Equality Can’t Wait
(ECW) is a group made Equality Can’t Wait Families with representatives of Sinn
up of people who are Féin, Alliance and SDLP
directly impacted by the
shortage of social
housing across Belfast,
and the well
documented housing
inequality impacting the
Catholic community
within North Belfast.
PPR supports ECW to
campaign for the
realisation of their
human right to adequate
housing.
This report is in response to the consultation being carried out by Killultagh Properties who
have issued a Pre Application Notification (PAN) to Belfast City Council of plans to develop the
Dunnes/Hillview site in North Belfast
The report, by PPR in support of the Equality Can’t Wait group, should be treated as a
formal submission to the PAN application process, and a formal objection to the plans
in their current form as well as providing supplementary information to inform all future
stages of the planning process regarding this site. Please note the attached copies of
political party objections and a petition signed by over 1000 Belfast residents calling for social
housing on the Dunnes / Hillview site.
5
2. Introduction
We are concerned that the current proposal fails to meet a range of human rights,
equality, legislative and policy obligations which together govern decision making at
Belfast City Council and the NI Executive.
These concerns are detailed below.
Alongside this we propose a solution which
will satisfy and strengthen employment retail
opportunities, provide long term
sustainability on the site which has failed as
‘retail only’ usage in the past, fall in line with
Council and Departmental planning
objectives, deliver on human rights
commitments and most importantly meet
the needs of the thousands of people on the
waiting list for social housing in the
surrounding communities.
PPR and ECW recognise that this
application is at the PAN stage, and the
developer must take in views of the
community about the plans. Belfast City
Council’s Statement of Community
Involvement (SCI) guidelines state that,
inter alia, community groups, elected
reps, and people in an area, are “in
particular, the views which shall be
sought” (p7).
We hope to see our concerns below
considered and reflected in full in the
pre-application consultation report in
line with guidance, including how the proposal will change in light of the issues
raised.
6
3. Housing need in north Belfast
According to the Northern Ireland Housing Executive’s (NIHE)1 ‘Belfast Housing
Investment Plan 2015 – 2019’ there were almost 12,000 people on the social housing
waiting list in Belfast in 2015 and almost 7,000 in ‘housing stress’. Around 6,000
families presented as homeless and over 3,000 were accepted as such.
To deal with this crisis only 542 social homes were built in Northern Ireland last year.
The failure to build social homes is having a disproportionate impact in areas where there are
already chronic housing shortages, including for the Catholic community in North Belfast. This
is one of the areas that experienced the highest number of conflict deaths, and displacement
of communities during the conflict, and is still impacted by socio-economic deprivation,
sectarian tensions and violence. As a result, North Belfast remains a highly segregated area of
Belfast, with communities living together along religious/community background lines.
According to figures received under the Freedom of Information Act, in North Belfast between
September 2013 – September 2014 Protestants waited 11.5 months on the social housing
waiting list before allocation while Catholics waited 20.7 months. In 2008 the Department for
Social Development projected in an Equality Impact Assessment that between 2008-2012 96%
of the need for additional social housing in North Belfast would be in the Catholic community,
however no action was taken to address this. In 2009
the Northern Ireland Housing Executive’s previous
policy of ‘ring-fencing’ of new build social housing 700
units for North Belfast, West Belfast and Londonderry
in recognition of housing inequality in those areas 666
Catholic Community
ended. Information from the Minister’s office Background
confirmed that removal would lead to a 29% drop in Protestant Community
new build social housing in North Belfast. Background
300
Stark differences exist in provision of social housing
units across the two main communities which do not
in any way reflect objective need. In 2014 there was a
surplus of 72 housing units in Protestant areas of -72
North Belfast in contrast with a deficit of 666 units in -100
Catholic areas. The housing situation for Catholics in New Housing Needed
in North Belfast
North Belfast has twice attracted comment from the
NIHE Data (2014)
United Nations Committee on Economic, Social and
1 The Northern Ireland Housing Executive is the public body with responsibility for social housing
in Northern Ireland.
7
Cultural Rights 2, as well as the Council of Europe Human Rights Commissioner Thomas
Hammarberg3 and UN Special Rapporteur on the Right to Adequate Housing.4
Land with potential to address the inequality and need is extremely limited across Belfast, and
particularly in North Belfast.
2Concluding observations on the fifth periodic report of the United Kingdom of Great Britain and
Northern Ireland, UN Committee on Economic, Social and Cultural Rights, 20 October 2008.;
Concluding observations on the sixth periodic report of the United Kingdom of Great Britain and
Northern Ireland, UN Committee on Economic, Social and Cultural Rights, 14 July 2016
3‘Commissioner for Human Rights Thomas Hammarberg Visits Seven Towers, North Belfast, as
Part of His Visit to the UK’, December 2011, http://www.pprproject.org/commissioner-for-
human-rights-thomas-hammarberg-visits-seven-towers-north-belfast-as-part-of-his
4Report of the Special Rapporteur on right to housing regarding mission to the United Kingdom of
Great Britain and Northern Ireland, 30 December 2013
8
4. What obligations must be discharged
when making a planning application
decision on Dunnes/Hillview?
A successful planning application for the Dunnes/Hillview site should take into account
a range of obligations including the following:
Human rights obligations including those deriving from the YES NO
International Covenant on Economic, Social and Cultural Rights
Equality legislation and policy, including Section75 (1) of the YES NO
Northern Ireland Act 1998
The Programme for Government YES NO
Planning guidance and strategies:
o the Local Development Plan (LDP)
o Strategic Planning Policy Statement for Northern
YES NO
Ireland (SPPS)
o the Regional Development Strategy 2035 (RDS)
The following key principles/planning functions which are especially relevant
within the planning guidance
o The identification and facilitation of land YES NO
o The need to build housing + indicators YES NO
o Sustainable development commitments YES NO
o Community Plan/’The Belfast Agenda’ YES NO
o Strong preference for use of existing land in building
YES NO
housing
o Any other material considerations (including
YES NO
community opinions)
It should be noted that the planning guidance in the SPSS applies to the whole of Northern
Ireland which is in conformity with the RDS 2035 and must be taken into account in the
preparation of any LDP, and is material to all decisions on individual planning applications and
appeals. It has a statutory basis under Part 1 of the NI Planning Act (2011).
9
4.1 Human Rights Obligations
The Dunnes/Hillview site provides an opportunity to begin to address a significant and
longstanding inequality which has remained
unaddressed in Northern Ireland and has attracted
significant international attention. “[The UK government and NI
Executive must] [i]ntensify its
efforts to address the
As a signatory to the International Covenant on
challenges to overcome
Economic, Social and Cultural Rights (ICESCR) the persistent inequalities in
government of the United Kingdom, and through it the housing for Catholic families
Northern Ireland Executive, Minister for Communities, in North Belfast, including
Minister for Infrastructure, Belfast City Council (and through meaningful
other statutory bodies with housing functions) have participation of all actors in
certain obligations to realise the right to housing. decision-making processes
related to housing.”
These include Article 11(1) of ICESCR which states: United Nations Committee
on Economic, Social and
“1. The States Parties to the present Covenant Cultural Rights, June 2016
recognize the right of everyone to an adequate
standard of living for himself and his family,
including adequate food, clothing and housing, and to the continuous improvement of
living conditions. The States Parties will take appropriate steps to ensure the realization
of this right, recognizing to this effect the essential importance of international co-
operation based on free consent.”
Article 2 of ICESCR also places an obligation on the Northern Ireland Executive to ensure
that the government “take steps to the maximum of its available resources” to progressively
realise the right to housing.
The United Nations Committee with responsibility for oversight of ICESCR has clarified that
such steps must be “deliberate, concrete and targeted” towards the realisation of rights.
Article 2 also provides that State Parties guarantee that the right to housing be exercised
without discrimination of any kind as to race, colour, sex, language, religion, political or other
opinion, national or social origin, property, birth or other status.
ICESCR also mandates that the Northern Ireland Executive give due priority to those social
groups living in unfavourable conditions by giving them particular consideration. Policies and
legislation should correspondingly not be designed to benefit already advantaged social
groups at the expense of others. Significantly, the Committee also notes that the obligation to
ensure the protection of the rights of vulnerable groups is relevant even in times of severe
economic constraint or recession.
104.1 Conclusion
In failing to address both the broad need for social housing in Belfast and the specific need for
social housing for the Catholic community in North Belfast, the current plans for Dunnes/
Hillview do not discharge these obligations.
Human rights obligations including those deriving from the YES NO
International Covenant on Economic, Social and Cultural Rights
114.2 Equality legislation and policy including
Section75 (1) of the Northern Ireland Act 1998
The Executive and its departments are bound by equality obligations, both internationally and
through domestic obligation such as Section 75 (1) of the Northern Ireland Act 1998. In
addition to international human rights obligations, the NI Executive and all public bodies with
housing, or housing related responsibilities, are under local legislative obligations to tackle
inequality and target objective need.
Section 75 (1) requires all public authorities to have due regard to the promotion of equality of
opportunity amongst nine specified groups and to have regard to the desirability of promoting
good relations in all their functions.
In practice, this requires public authorities
Virginia Bras-Gomes, United Nations including Belfast City Council and the
ESC Rights Committee member at Department for Infrastructure to submit an
Dunnes/Hillview site Equality Scheme to the Equality Commission
for Northern Ireland detailing how they will
fulfil their duties, including by using tools
such as Equality Impact Assessments which
are intended to gauge the impact of
government policies on the nine groups and
ensure equality outcomes are achieved.
As with all council duties, the Local
Development Plan and other planning
agreements must meet Section 75
obligations, which are relevant due to religious aspect of the housing inequality in North
Belfast, which is one of the nine groups named in Section 75.
4.2 Conclusion
In leaving housing inequality in North Belfast unaddressed, the current plans for Dunnes/
Hillview do not discharge this obligation.
Equality legislation and policy, including Section75 (1) of the YES NO
Northern Ireland Act 1998
124.3 Programme for Government (PfG) 2016-2021
The Executive’s recent PfG uses an outcome based framework, and sets itself the target if
“improve[ing] the supply of suitable housing”. It will measure its success by measuring the
number of household in housing stress.5 This will complement ‘Facing the Future’ the NI
Executive’s Housing Strategy, which seeks “to ensure that everyone has the opportunity to
access good quality housing at a reasonable cost”.6
4.3 Conclusion
Including housing at the Dunnes/Hillview site would help the Executive meet one of its key
Programme for Government indicators in assessing its success, while furthering the aims and
objectives of the Housing Strategy. The current proposal does not deliver on these objectives.
The Programme for Government YES NO
5 Indicator 8, Draft Programme for Government Framework, NI Executive, pages 57-58
6 ‘Facing the Future: The Housing Strategy for Northern Ireland 2012-17’
134.4 Planning Guidance and Strategies in Northern
Ireland
Planning in Northern Ireland is increasingly the role of
Councils, with the Department of Infrastructure retaining
a role (especially in regards to planning guidance and in
developing regional developments). The main sources
of planning guidance the Councils and the Department
must adhere to derive from the Regional Development
Strategy 2035 (RDS), the Strategic Planning Policy
Statements of NI (SPPS), planning guidance notes, and
for Councils the Local Development Plan. All guidance
compliments each other, and the LDP is informed by
the RDS and the SPPS.
When Council is making a planning decision it must
take into consideration it’s LDP, sustainable
development goals, any representations and any other
material considerations, as well as departmental and
executive guidance.
The Regional Development Strategy (RDS) focuses on
the future development of Northern Ireland to 2035 and is the spatial strategy of the Executive.
The RDS was developed in 2010 by the Department of Regional Development (whose
responsibilities have now passed to the Department of Infrastructure).7
The SPPS has been agreed by the NI Executive and has a statutory basis under Part 1 of the
Planning Act (NI) 2011.8 The SPPS brings together around twenty separately developed policy
papers into one document, setting out strategic planning policy across a wide range of
planning matters;
“the SPPS is a statement of the Department’s policy on important planning matters [...] It
reflects the [...] Ministers expectations for delivery of the planning system. It has been
agreed by the NI Executive and is to be in conformity with RDS 2035.” 9
The SPPS states that:
7 Regional Development Strategy, RDS 2035, Building a Better Future, Strategic Planning and Co-
ordination Division, Department for Regional Development
8Strategic Planning Policy Statement for Northern Ireland (SPPS), Planning for Sustainable
Development, September 2015, Department of Environment, page 6
9 Ibid
14“Creating places where communities flourish and enjoy a shared sense of belonging,
both now and into the future, is fundamentally what planning is about.”
The SPPS further states that:
“The planning system operates in the public interest of local communities and the region
as a whole, and encompasses the present as well as future needs of society. [...]The
basic question is [...] whether the proposal would unacceptably affect amenities and the
existing use of land and buildings that ought to be protected in the public interest.”
4.4 Conclusion
In light of the housing need, and unaddressed religious inequality in housing which runs
counter to equality legislation, it is clear that a proposal for Dunnes/Hillview that did not include
social housing would not be in the public interest.
Planning guidance and strategies:
o the Local Development Plan (LDP)
o Strategic Planning Policy Statement for Northern
YES NO
Ireland (SPPS)
o the Regional Development Strategy 2035 (RDS)
154.5 Key Themes for Planning Decisions
Throughout the main planning and development guidance (RDS, SPPS, LDP), some themes
are key and reoccurring.
a) The identification and facilitation of land
A main function of planning is to ensure an adequate supply of land for planning needs.
Section 1 of the Planning Act NI 2011 states:
“The Department must formulate and co-ordinate policy for securing the orderly and
consistent development of land and the planning of that development”.10
The RDS sets out guidance for the Department to:
“Ensure adequate supply of land to facilitate sustainable economic growth” 11.
The SPPS reiterates this by stating that:
“The objective of the planning system […] is to secure the orderly and consistent
development of land whilst furthering sustainable development and improving well-
being.”
Following from this, a core aim of the LDP will be for the Council to:
“facilitate growth by coordinating public and private investment to encourage
development where it can be of most benefit to the wellbeing of the community”,
This includes:
“Allocat[ing] sufficient land to meet the needs of the city”.12
This is important because official planning legislation states that council/department planning
must have regard to the LDP, and:
“the determination must be made in accordance with the plan unless material
considerations indicate otherwise”13.
This is a legal requirement.
10Development Management Practice Note 16, ‘The Determination of Planning Applications’ April
2015, Department of Environment, page 5
11 RDS 2035, p31
12Local development plan, Belfast City Council, http://www.belfastcity.gov.uk/buildingcontrol-
environment/Planning/localdevelopmentplan.aspx
13 Section 6 (4) of the 2011 Planning Act NI
164.5a Conclusion
One of the Belfast’s key needs is social housing.
In 2016 PPR / ECW published research by prominent economist Paul Gosling called ‘Funding
for Social Housing’14 which found that the Northern Ireland Federation of Housing
Association identified the lack of suitable land with planning approval as the main barrier to
building social housing in Northern Ireland.
As such, the current plans for the Dunnes/Hillview site do not discharge the LDP’s aim of
allocating sufficient land to meet the needs of the city.
o The identification and facilitation of land YES NO
Killultagh Propteries’ Planning Proposal - An ineffective and unsustainable
use of land in an area of chronic social housing need and inequality
14Available
at http://www.pprproject.org/sites/default/files/Funding%20for%20New%20Social
%20Housing%20July%202016.pdf
174.5 Key Themes for Planning Decisions
b) the need to build
housing
A main function of planning is to
ensure an adequate supply of
land for housing development.
This must be informed by
housing need.
The RDS requires the
Department to:
“Manage housing growth to Current Plans by Killultagh Properties. Where is
achieve sustainable the social housing?
patterns of residential
development”.15
The Local Development Plan process is the main vehicle for assessing future housing land
requirements and managing housing growth. SPPS: 6.137 states:
“In preparing Local Development Plans (LDPs) councils shall bring forward a strategy for
housing, together with appropriate policies and proposals that must reflect the policy
approach of the SPPS, tailored to the specific circumstances of the plan area. Planning
authorities must deliver:... increased housing density without town cramming: higher
density housing developments should be promoted in town and city centres and in other
locations that benefit from high accessibility to public transport facilities.”
Section 6.143 of the SPPS also requires reliance on the Housing Needs Assessment
undertaken by the Northern Ireland Housing Executive, in order to identify the range of specific
housing needs, including social/affordable housing requirements.
Section 6.139 states that housing allocations in LDPs should be informed by the RDS Housing
Growth Indicators which require 50100 homes/housing growth in Belfast urban area between
2008-2025. According to figures released by the NIHE under the Freedom of Information Act
since 2011, only 5315 new build social homes have been completed, just over 10% of this
figure. They should also consider Urban capacity studies to take account of housing
development opportunities arising from previously developed land (i.e. brownfield sites), and
windfall sites defined by the RDS as:
15 RDS 2035, p 40
18“Housing sites that were
neither zoned nor anticipated
during the formulation of the
development plan but which
have become available during
the lifetime of the plan.” 16
Announcing the timetable for
its Local Development Plan
(LDP). Planning Committee
Equality Can’t Wait group gathering support in
Chair Councillor Peter
Ardoyne for social housing on Dunnes/Hillview
Johnston (UUP) acknowledged
this duty stating that:
“we have a requirement to identify an adequate supply of housing land; without an LDP,
Belfast is susceptible to speculative development proposals that may not deliver the aims
of the council and wider needs of the city.” 17
4.5b Conclusion
The Northern Ireland Housing Executive’s Social Housing Development Programme’s Unmet
Social Housing Need Prospectus identifies Belfast as the area of Northern Ireland with the
highest unmet need, with a need for 4,434 social housing units identified outside of those
already planned in the Social Housing Development Programme.
In light of this and the statistics identified in the ‘Housing Need’ section of this paper the failure
to include social housing on the Dunnes/Hillview site is likely to mean the proposals to do not
meet the requirements of the Local Development Plan.
o The need to build housing + indicators YES NO
16 RDS 2035, p. 109
17‘Council sets out timetable for new Local Development Plan consultation’, Belfast City Council,
29 Jun 2016, http://www.belfastcity.gov.uk/News/News-68705.aspx
194.5 Key Themes for Planning Decisions
c) Sustainable development
A statutory duty exists
on government
departments and district
councils to promote
sustainable
development under
Section 25 of Northern
Ireland (Miscellaneous
Provisions) Act 2006.
The NI Executive
published ‘Everyone’s
Involved - A Sustainable
Development Strategy’
in May 2010, which sets
out a number of priority
areas for action and a
number of strategic objectives to achieve in the pursuit of sustainable development.”18
The strategy above lists in its ‘Key Priorities’ the aim to strengthen society, by:
“ensur[ing] that everyone has access to decent housing that enables them to live
sustainably."19
Therefore, Council has a statutory duty to promote sustainable development in its decision
making, of which access to decent housing is a key priority.
The notion of sustainable development also forms part of the RDS:
“Sustainable development is at the heart of the Regional Development Strategy.”20
The SPPS further iterates this by stating that:
“The overall objective of the planning system is to further sustainable development and
improve well-being for the people of the North.”
18 Development Management Practice Note 16, p. 6
19 Everyone's Involved, Sustainable Development Strategy, NI Executive
20 RDS 2035, p. 16
20It goes on to say that planning authorities should deliver on all three pillars of sustainable
development, of which social and affordable housing is a key element by:
“facilitating sustainable housing growth in response to changing housing need”.
Sustainable development must compliment with the aims of the RDS and the PfG:
“In furthering sustainable development and improving well-being it is crucial that our
planning system supports the Executive's Programme for Government commitments and
priorities as well as the aims and objectives of the Regional Development Strategy 2035
(RDS)”21
Housing as an element of sustainable development must be reflected in the Council’s LDP.
This must also be achieved;
“through the recycling of land and buildings and the encouragement of compact town
and village forms.”22
LDPs also call for local facilities, services and adequate infrastructure integrated into new
housing development to meet the needs of the community as a way to meet sustainable
development and housing obligations.
“A design concept should be sought from and agreed with the developer incorporating
sustainable elements such as good linkage of housing with schools, community facilities
and public transport; provision for cycling; adequate provision of open space and
landscaping integrated with broader green and blue infrastructure systems; energy
efficient design of housing units and use of sustainable drainage systems, where
appropriate.”23
These guidelines are reflected in our proposal for the site as outlined as below.
4.5c Conclusion
A decision to continue with plans that would exclude the possibility of social housing would not
discharge Councils statutory obligation to promote sustainable development, and facilitate
housing growth in response to housing need.
o Sustainable development commitments YES NO
21 SPPS, p. 10
22 SPPS, p.70
23 SPPS, p. 70
214.5 Key Themes for Planning Decisions
d) ‘The Belfast Agenda’
A statutory link exists between the forthcoming LDP and the council’s
emerging Community Plan, known as the Belfast Agenda24 . The Agenda is
also informed by the ‘Belfast Conversation’, where a key response/theme
from residents of the city to the question “What would you like Belfast to be
like in 2030?” was:
“A clean, healthy and safe city where everyone has access to good
housing, quality green spaces, services and facilities that enable them
to be happy, safe and active”.25
The Belfast Agenda states it will be informed by earlier planning work, such
as the Belfast City Master Plan, which again identified issues with social
housing supply and demand as inhibitors “currently affecting Belfast and its
potential”.26
4.5d Conclusion
It is clear then, that not including social housing on the Dunnes/Hillview site
will hinder the Council in fulfilling its duties and the vision of Belfast
articulated above.
o Community Plan/’The Belfast Agenda’ YES NO
24Belfast Planning Service, Belfast City Local Development Plan (LDP) 2035: Timetable June 2016,
p2
25 The Belfast Conversation, Summary Report, April-June2015, p7
26Belfast City Masterplan 2004 – pp38-39 http://www.belfastcity.gov.uk/nmsruntime/
saveasdialog.aspx?lID=937&sID=687
224.5 Key Themes for Planning Decisions
e) Strong preference for use of existing land in building
housing
The planning guidance and
obligations stresses the need for
responsible planning decisions, that
ensure an adequate supply of land,
and that a priority for this land must
be housing, especially in areas of
high housing stress, compatible
with sustainable development
obligations. The guidance shows a
strong preference for the use of
existing land (‘brownfield’ or
‘windfall’ sites) to be put towards Current Plans by Killultagh Properties. Not a
the aim of meeting housing
obligations.
For instance the RDS:
“recognises that there are significant opportunities for new housing on appropriate
vacant and under-utilised land”27
It continues:
“The policy approach must be to facilitate an adequate and available supply of quality
housing to meet the needs of everyone”.28
The SPPS states that:
“When place-making, planning authorities should make efficient use of existing capacities
of land [...] in order to achieve sustainable communities where people want to live, work
and play now and into the future.”
Thus, using a site like Dunnes/Hillview, which has already been developed but is not in use,
would be in keeping with this principle. The SPPS further states that:
“Identifying previously developed land within settlements [...can assist with the return to
productive use of vacant or underused land.]”
27 RDS 2035, p. 69
28 RDS 2035, p. 41
23The LDP must be informed by the principles in the SPPS and RDS.
4.5e Conclusion
As a currently vacant site in an area of high housing stress, failure to include social housing on
the Dunnes/Hillview site does not deliver on the RDS policy approach to facilitate an adequate
supply of housing to meet the needs of everyone.
o Strong preference for use of existing land in building
YES NO
housing
244.5 Key Themes for Planning Decisions
f) Any other material considerations (including community
opinions)
Official planning guidance states that there
“is no legal definition for material considerations; however they are held to include all the
fundamental factors involved in land-use planning. Essentially a material consideration is
one which is relevant to making a planning decision as to whether to grant or refuse an
application for planning permission. Material considerations will vary depending on the
specific circumstances of each case.”
The SPPS states that: Thousands sign-up in support of
housing on Dunnes/Hillview
“There are two main tests in deciding
whether a consideration is material and
relevant: (i) it should serve or be related
to the purpose of planning - it should
therefore relate to the development and
use of land; and (ii) it should fairly and
reasonably relate to the particular
application.”
“Examples of material considerations
include the local development plan;
planning policy; planning history; need;
public opinion; consultation responses;
existing site uses and features; layout,
design and amenity matters; precedent;
alternative sites and planning gain”.29
29 Planning note 16, p. 7
255. An Alternative Proposal
-
a sustainable solution for Dunnes/Hillview
Below we put forward a proposal for a sustainable solution at Dunnes/Hillview from multiple
award-winning Architects, McCartan Muldoon Architects, outlining a model of mixed social
housing, amenities and employment opportunities.
This proposal, which has been developed in discussion with PPR, takes into consideration
important material considerations, the historic failure of retail only developments on the site,
and the need to create sustainable homes and employment in the area.
At Dunnes/Hillview McCartan and
Muldoon Architechts can start
afresh with a proposal to create a
new sustainable urban
neighbourhood.
Plans for the Dunnes/Hillview site
should include the introduction of
quality social housing that is low
e n e r g y a n d z e r o c a r b o n , Climate Innovation District - River Aire Leeds
constructed with and
incorporating the
latest sustainable construction methods and international best practice to create a super green
eco-village. This would draw on examples of 'Climate Innovation Districts' constructed in
England, the Netherlands and Denmark which are exemplars for healthier, smarter and better-
connected zero carbon cities.
Mixed uses would be introduced into the overall site in order to create a sustainable urban
neighbourhood. McCartan and Muldoon Architechts propose the adoption of 'Home Zone'
principals as implemented widely in England, designed primarily to meet the needs of
pedestrians, cyclists, children and residents and where the speeds and dominance of cars
is reduced. Furthermore all the necessary community support facilities and amenities would be
incorporated within the layout of the proposed project including work units or studio work
spaces, crèche facilities, meeting rooms / group rooms and / or activity rooms. Depending
upon the local need and provision this could be widened out to incorporate demo rooms,
sound studio, exhibition rooms, youth facilities and sports facilities.
A number of other initiatives could be introduced to increase skills / capacity and deliver a
greater sense of community ownership. For example a recent social housing project in Chile
introduced the concept of self-build social housing. The local authority constructed half of the
house and the occupier completed it by finishing the other half (See 'Chilean half houses') and
as a concept, Cohousing/Housing Cooperatives could be developed on part of the site.
26Introducing multiple uses (most importantly housing) is “The Dunnes/Hillview
the proper way to improve the economic viability of site is more than twice
the site and to make it a more sustainable the size of a former
development overall. This proposal could integrate industrial site being
some of the proposed retail facilities or changes - developed by CITU
again to show that there is no loss to the economics of along the River Aire in
the site as may be perceived by the developer. Leeds as a ‘Climate
Innovation District’
The Dunnes/Hillview site is more than twice the size of where they are
a former industrial site being developed by CITU along p l a n n i n g
the River Aire in Leeds as a ‘Climate Innovation
approximately 200
District’ where they are planning approximately 200
dwellings with
dwellings with commercial and community support
facilities. commercial and
community support
As such, there is more than enough room to facilities.”
accommodate the many needs and wants of the
community and developers given negotiation and
sensitive consideration.
This proposal will not only meet the various human rights, statutory, and housing
requirements, but will also provide greater financial stability for the commercial
element, and be a significant move away from the previous similar commercial
development on this site which failed to generate sufficient revenue and closed leaving
the land vacant.
276. Conclusion
The chronic housing shortage and religious inequality in north Belfast is long-standing and well
documented both at the local and international level. Housing rights activists of the ECW
campaign worked alongside PPR to identify areas of land which are not in use and which
could be used to begin to address the housing shortage and religious inequality. The plan
proposed above would incorporate social housing while allowing for commercial development,
thereby meeting the government’s obligations and allowing for full economic potential of site to
be realised.
Equality Can’t Wait families launch their north Belfast mural
It is clear that the Executive, the Departments and Council have strong obligations and
strategic objectives that would support such a proposal. Alongside their human rights and
equality obligations, the Executive’s PfG and their housing strategies would be advanced by
this proposal. Planning guidance which the Department for Infrastructure and the Council must
follow in developing planning strategies and making planning determinations show a
requirement for:
• Housing need to be identified and met
• For an adequate amount of land be obtained for this purpose
• For such plans to correspond with sustainable development obligations and in line with
community development plans
• And for the preference of brownfield or windfall sites to be used for housing.
Therefore we believe that the plan proposed by ECW and PPR should be the basis for
Council’s development of this site, and that the principles in this document should inform future
planning determinations in areas of high housing need.
28Appendix
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31
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