The council want to turn the Keiller Centre into student flats.
Purpose built student accommodation (PBSA) is wrecking our city centre. Developers know they can make a killing building exclusive student flats, so they won't build affordable housing. These rooms are expensive, small, and poorly built, so they aren't good homes for the students that may live there either.
At the moment, developers are walking all over Dundee City Council. We need to come together and tell the council we want good homes for everyone, not expensive student flats.
Use our template objection to tell the council that we've had enough of PBSA.
We understand the council does not make it easy for residents like us to object. You have to understand planning policy to know what is a 'competent objection' and this takes a lot of time. To make it easier we have written up detailed reasons why you should object. Our template is here.
Send the council your objection here.
The more people object, the more loudly we can say no to PBSA.
If you the google word document does not work you can copy from below and Send the council your objection here.
Any issues email [email protected]
__________________________________________________________________________________________
COPY AND PASTE THE BELOW INTO THE ‘YOUR COMMENT’
ONCE COPY PASTED FILL IN DATE, NAME AND ADDRESS
Date:
Name:
Address:
Objection to Planning Application 26/00373/FULM regarding Keiller Centre redevelopment
To whom it may concern,
I am writing to object to planning application 26/00373/FULM for the erection of purpose built student accommodation (PBSA) with commercial units, landscaping, and associated works on the site of The Keiller Shopping Centre, Chapel Street, Dundee, DD1 1DQ.
The proposed works violate the Dundee Local Development Plan and the National Planning Framework 4 in multiple areas. The council has correctly recognised that PBSA supply already outstrips demand in Dundee. This planning application argues that the proposed type of PBSA is in fact undersupplied in Dundee: on closer inspection, these claims are at best unfounded. The details of the proposal also violate or fail to respect a number of policies.
Additionally, the Keiller Centre is a valuable site which has been highlighted in the Dundee City Centre Strategic Investment Plan.
The current proposal fails to fulfil the aims identified in the Investment Plan, and forecloses the possibility of doing so. It would be of detriment to the city to lose such an opportunity, and to have it replaced by PBSA which will inevitably stand largely empty, given the existing over-supply.
This is a proposed development which fails to serve any existing demand, violates multiple policies, and risks wasting a valuable city centre development location.
The violations of the local development plan and NPF4 policies are detailed below.
Violation of LDP Policy 15.1: lack of demand for type of student accommodation proposed
This proposal violates LDP Policy 15.1, which states:
“[Student accommodation will only be supported where] it can be suitably demonstrated that a demand exists within the particular area for the level and type of student accommodation proposed”
Precedent: recognised oversupply of PBSA
The council has already identified an oversupply of PBSA in Dundee, and that new developments must therefore respond to a demonstrated demand. There have been recent recommendations not to approve recent similar proposals.
Planning officers recently recommended that a PBSA development on South Ward Road not be approved because “the proposed development of student accommodation would not address any identifiable gap in provision. The applicant has failed to demonstrate that need and demand exists for the proposal, and approval of the application could result in an oversupply of the type of accommodation proposed.” (Planning Committee 27 April 2026).
Similarly, planning officers recommended that permission be refused for a PBSA development on Barrack Street because “the proposed development of student accommodation would not address any identifiable gap in provision and could result in an oversupply of the type of accommodation proposed.: (Planning Committee 19 June 2026).
Both proposals were also recommended for refusal due to not according with NPF4 policy 16c.
The cited lack of demand or gap in provision apply equally here, as will be demonstrated.
Same situation as precedent cases: implausible claims about demand pool
Document 27 of the application, the Dundee Student Housing Supply and Demand Report by CBRE, attempts to demonstrate demand and a gap in provision. However, its claims are not credible, as they rely on a significant misunderstanding of both current student housing and the student population of Dundee.
The CBRE report treats students not living in PBSA as students who “cannot access” PBSA due to under-supply. The report claims that there are up to 8,331 students “potentially” unable to secure PBSA beds in Dundee. There are not 8,331 students currently living on the streets of Dundee: most choose not to live in PBSA. The CBRE figure is calculated by treating all students outside a parental home or PBSA as students whose demand for PBSA is not being met, including those who self-describe as living “in their own residence”. The inflated estimate here is thus inaccurate.
There is no indication that students who do not live in PBSA are unable to access spaces. This is undeniably demonstrated by the fact that many PBSAs in Dundee are already reported as significantly underoccupied, e.g.:
- Nov. 2024: 300 vacant rooms in UoD accommodation, a vacancy rate of 20%: https://www.thecourier.co.uk/fp/politics/scottish-politics/5135558/dundee-university-empty-student-halls/
- July 2025: PBSA property manager describes achieving an occupancy rate of 80% as aspirational for academic year 25/26:
https://www.thecourier.co.uk/fp/news/5287574/dundee-student-accommodation-rooms-flats/
Private PBSA is rented at above market rate relative to regular residential apartments or rooms in a HMO. The most recent data released by the National Union of Students (2024) reports that 49% of students in Scotland spend at least 61% of their monthly budget on rent (https://www.whatstudentsthink.org.uk/housing-and-renting-data).
Combining high cost of living with the demonstration of under-occupancy of PBSA, students currently using other private rentals absolutely cannot be assumed to constitute a demand pool for higher-cost PBSA.
Reduction in demand: changing student demographics
One student population with a higher rate of PBSA preference is international students. The collapse in international student numbers from 2024 onwards is not acknowledged by the CBRE report.
The highly-publicised financial crisis at the University of Dundee (news breaking October 2024) long pre-dates the CBRE report, which is dated August 2025. The report fails to acknowledge the UoD crisis, which has made national headlines. This demonstrates a serious lack of knowledge underlying the claims about Dundee’s student population. The report also fails to mention the impact on student numbers, which have been reported as decreasing over the past 2 years. The student population of the University of Dundee has also shifted toward more local students, rather than international students who are more likely to prefer PBSA.
By contrast, the report highlights the high numbers of Indian and Nigerian students attending the University of Dundee in 2023/24; this is grossly out-dated information. Failure to respond to a collapse in Indian, Nigerian and Chinese student populations from 2024 onwards has been identified by the Gillies report as a factor in the university’s financial crisis (p.13, https://www.sfc.ac.uk/wp-content/uploads/2025/06/Gillies-Report.pdf). By contrast, the report emphasises how in 2023/24 this cohort accounted for 69% of UoD’s international student population, and highlights how it had grown over the previous 5 years, and actively highlights UoD’s significant growth in Indian and Nigerian students since 2019/20.
While some student populations are served by PBSA, this population has collapsed, which the CBRE report does not acknowledge, and rather implies is undergoing significant growth.
Provision of facilities: not as described, and not in demand
The proposal argues that existing PBSA is unattractive as it fails to provide “the space standards that modern students require”, and that the proposal will supply higher-quality facilities, thereby attracting student renters. Given that HMOs provide no PBSA-style facilities such as gyms, it is not credible that there is a hidden PBSA demand pool which has chosen facility-free HMO occupancy over existing PBSA on these grounds.
Further, the claim that this development will provide improved facilities relative to existing PBSA is inaccurate. In reference to this policy the attached planning policy statement also says that “In Dundee a large proportion of the student housing stock is dated and does not provide the facilities or space standards that modern students require.”
The proposal does nothing to set itself apart from the facilities in this ‘dated’ accommodation. To the contrary: the communal facilities in the scheme consist of a gym and 3 seating areas designated as “coffee bar,” “lounge/tv room” and “lounge/study space”. These 4 areas bring the indoor amenity to 400sqm. The seating areas and gym provide as comprehensively listed below:
a television; two small counter spaces with attached sink; gym equipment
This offering is significantly less than even some of the most dated accommodation in Dundee. Residential amenities and facilities in other Dundee PBSA blocks go beyond a gym, a TV, seating, and a sink. Examples of facilities in existing PBSA include the following:
pool tables; other games tables; bookable kitchen/dining rooms; bookable cinema rooms; rooftop public areas (which were present in earlier iterations of this scheme); yoga studios.
Although the application claims to be responsive to the “space standards that modern students require”, the majority of its accommodation (209 beds) is studio flats, the majority of these under 12sqm (some are slightly larger). This space per unit is lower than in many existing PBSA schemes. An apartment area of 12sqm is extremely restrictive, and cannot be reconciled with claims of offering a high living standard. It would not be possible for residents to engage in normal social activities in their homes, even a simple as hosting shared meals: there is only room for a single desk and chair. Living in these apartments would be isolating and constricted – essentially, miserable.
The proposal reads closer to fantasy than bearing much relation to the reality of the proposed plans.
Violation of NPF4 Policy 16c.: Non-adaptable homes, fails to address gaps in provision
This proposal violates NPF4 Policy 16.c, which states:
“Development proposals for new homes that improve affordability and choice by being adaptable to changing and diverse needs, and which address identified gaps in provision, will be supported. This could include [homes for people undertaking further and higher education]”
The proposal fails to improve affordability and choice, and is not easily adaptable to diverse needs. As already stated, the council has explicitly identified an oversupply of PBSA, not a gap in provision, with previous proposals rejected on grounds of studio over-concentration. Despite an extant over supply, 67% of beds in the proposed development are studios.
The CBRE report argues that this development will improve affordability and choice in Dundee more generally by reducing the number of students using mainstream rental properties. For the reasons outlined in the previous section on LDP Policy 15.1, there is no reason to believe that the proposed development will attract students renting non-PBSA residences and thereby recirculate other housing stock.
It also fails to improve affordability and choice among students. Although the attached planning policy statement claims that “This policy positively supports student housing.”, it only does so conditionally. The proposal will not improve affordability, as new build PBSA is significantly more expensive than existing PBSA and HMOs. There are no affordable units in the proposal, and PBSA is unaffordable to many students; especially PBSA marketed as “luxury”.
The proposal is also not adaptable to changing or diverse needs, as the convertibility of the proposal is quite limited. The plans include no proposals for what a future retrofit into normal residential accommodation could look like, and include no indication that this is possible.
Violation of LDP Policy 14.6: excessive concentration of non-mainstream residential use
This proposal violates LDP Policy 14.6, which states:
“[Residential accommodation for particular needs] will not lead to an excessive concentration of non-mainstream residential uses to the detriment of the character of the particular area.”
If approved, this proposal would contribute to a “concentration of non-mainstream residential uses to the detriment of the character” of the area in the following ways:
- An over-concentration of studio apartments. 209 out of 314 beds (67%) in the proposed development are studios. Studios are associated with poorer mental health, worse academic attainment, and social isolation. This also represents a poor mix of properties in terms of choice. A nearby redevelopment of the former post office building had initial plans rejected in pre-application due to too many (non-student) studio flats: there should not be a double standard for student properties.
-Further concentration of PBSA and HMOs in the area. The development increases the concentration of non-mainstream residential uses in an area already dominated by (mostly student) HMOs and, once looking even slightly beyond the 500m radius recognised by the CBRE report, other PBSA developments.
-Exacerbation of and failure to plan for anti-social behaviour. As highlighted in the proposal’s documents, the area surrounding the Keiller Centre is a frequent site of anti-social behaviour, often involving illegal substances.
The proposal risks exacerbating this behaviour through the removal of ‘eyes on the street,’, planting and the thoroughfare from the southeast entrance.
Anti-social behaviour exacerbated in this way will have an adverse impact on all city centre residents and visitors.
The proposal provides no student management plan, as is often included in PBSA applications. This includes having no plan for site security, as is often standard in PBSA schemes. There is thus no evidence of how the scheme plans to deal with anti-social behaviour, or even an indication it has been recognised as a risk that requires management.
-Increased noise and disturbance. The proposal creates a high-density student population to the site. It is not unreasonable to recognise that highly concentrated student populations are populations with higher noise levels, especially at night.
Creation of a transient student-only community. By their nature, PBSA resident populations can only ever be transient: students who continue to work and live in Dundee must leave PBSA on completion of their studies, as must any who wish to share a household with a non-student.
-Failure to plan for increased waste and litter. There is a basic lack of foresight or provision for increased rubbish and mess.
The landscaping and ground floor plans omit any additional external litter bins or smoking bins. This should be a requirement due to the high-density residential nature of the site.
Although the plans provide for general residential bin provision, there is no mention of managing waste around move-out dates. This is an issue unique to the PBSA property type, due to the large-scale fluctuations in residents based on term times. The West End-to-City Centre area is especially dirty during annual large-scale student move-outs: this risk should not be taken with the City Centre proper. Existing PBSA properties have issues with limited bin capacity, and the proposed development does not mitigate this.
Failure to reflect Dundee City Centre Strategic Investment Plan (Consultant Masterplan): lack of public uses, wasted opportunity
Failure to realise potential of the Keiller Centre site
This proposal completely fails to reflect the opportunities recognised by the DCCSIP, which states:
“The Keiller Centre site offers a unique opportunity to create a new destination at the heart of the city centre combining public realm and a mix of uses.”
“Redevelopment of the Keiller Centre to create a new public space fronted by a mix of uses.”
“The Keiller Centre site could deliver a distinctive destination at the heart of the city centre fronted by a mix of Food & Beverage and leisure uses that contribute to Dundee’s evening economy. These uses and activities could be supplemented by employment uses at upper levels.”
The proposal fails to truly provide a mix of uses, with only two commercial units and minimal street interaction. It does not establish a destination or provide public space. Instead, it delivers non-mainstream residential use, which was not identified as a target for the site.
The proposal justifies this by claiming that a ‘destination’ use of the site is infeasible. However, ambitious destination and other non-residential uses are possible in the city centre, as demonstrated by the Green Transport hub, the waterfront regeneration project and the ongoing Eden project.
Dundee 1881 (the applicants, and property managers of the extant Keiller Centre) have not invested in the centre or encouraged its regeneration. This is evidenced by their failure to install wifi, a basic business utility, which made the centre less appealing to potential tenants, and failure to repair broken entrances, thereby making access more difficult and the centre less appealing.
The failure of the Keiller Centre was exacerbated by a lack of investment from Dundee 1881. A ‘destination’ at the Keiller Centre site, as proposed in the DCCSIP, is still possible: it just needs investment. Dundee 1881 has evidenced that they are unable to provide this, and unwilling to engage with local stakeholders or funders in good faith to try to create this. The claim that the site cannot serve as a destination is not an objective conclusion reached after seeing the centre fail despite efforts to revitalise it: the claim is part of a larger pattern which encouraged that failure.
Variety of housing types in the City Centre
Strategic Outcome 2 seeks to:
“provide a variety of residential types and tenures to meet the needs of different households and to create a diverse community”
More specifically, it states that:
“We will make the city centre desirable and liveable with a choice of attainable high-quality residential properties with a variety of size, type and tenure. This will attract a wide demographic including opportunities for older people and family homes.”
“We will support the growth of our two universities by promoting the regeneration and reuse of existing buildings for student accommodation whilst encouraging an improvement in the quality of Houses in Multiple Occupation in the city centre. Working with social and private housing providers, we will encourage greater housing choice.”
The proposal fails to accord with all of the above points.
The proposal would not contribute to a “variety of residential types [...] to meet the needs of different households and to create a diverse community”. Student housing in the city centre is already well-supplied. DCC’s Evidence Report for planning indicates that 67% of city centre flats are HMOs. Although not all are occupied by students, this is a rental type already favoured by students. There are already plenty of PBSA and HMOs in the city centre: what this area lacks in housing options is everything else.
As addressed in the section on LDP 15.1, the proposal does not contribute to a “choice of high-quality residential properties”, as the majority of proposed flats are <12sqm studios. These cannot meaningfully be regarded as “high-quality”. It also creates a large residential block which excludes the highlighted demographics of older people and those seeking family homes.
As mentioned in the sections on LDP 15.1 and NPF4 16c, the proposed PBSA is extremely unlikely to attract students living in other property types, and therefore will not absorb student demand to improve choice for others. The proposal itself does not improve choice, given the existing oversupply of PBSA in Dundee.
The strategic outcome supports “the regeneration and reuse of existing buildings” for student housing, not comprehensive redevelopment of sites through creation of PBSA newbuilds.
In all respects, this proposal does not “encourage greater housing choice”, and does not come under the identified cases for addressing concerns about student housing.
Violation of LPD Policy 2: failure to allocate costs for public art projects
This proposal violates LDP Policy 2, which states:
“All developments in Dundee with construction costs of £1 million or over will be required to allocate at least 1% of construction costs for the inclusion of art projects in a publicly accessible/visible place or places within the development.”
There are zero arts projects included in the development. The Design and Access Statement only includes the word ‘art’ in reference to the nearby McManus Galleries.
Further failure to reflect NPF4: applying Place Principle
This proposal fails to reflect the NPF4 Policy 14 intent, which is:
“To encourage, promote and facilitate well designed development that makes successful places by taking a design-led approach and applying the Place Principle.”
There are multiple issues with the ground floor and landscaping design with regard to this intent:
The public space creation is situated out to only cater to residents and commercial units, and is generally insular in design. It does not create a public space as supported in the DCCSIP, in which a ‘street’ in the centre takes the form of a public space physically welcoming to all.
Gated access on the east side is inaccessible to the public.
The Rankine’s Court entrance will be worsened relative to the current design. The proposed entrance faces onto a gate and a back-of-house commercial area.
By contrast, the existing entrance features windows facing the high street, a garden, signage, and a public entrance.
