8.1
Set out below are a range of positive actions that the Council is putting in place to increase housing supply and to address the low rates of housing delivery against the City Plan housing target.
A. Direct delivery of housing
i) New Homes for Neighbourhoods
8.2
The Council has set a target to deliver 800 new affordable homes by 2023. The New Homes for Neighbourhoods (NHFN) programme seeks to develop new rented Council homes on Council-owned land. It works with local resident associations, ward councillors, council staff and partners to improve council estates and neighbourhoods, while making best use of council housing land and buildings to deliver new, affordable rented homes that the city needs.
8.3
Since 2015, 226 Council homes for affordable rent have been completed in 14 projects under NHFN with a further potential identified supply of around 600 homes identified, including 46 which already have planning permission. In addition, there is potential for redevelopment of some existing council housing.
8.4
The current programme and projected next phases are shown below.
Programme phase |
Number of homes |
Date/target date |
Phase 1 (completed homes) |
172 |
Complete June 2018 |
Phase 2 (on site/with agreement to progress) |
54 |
Complete Dec 2020 |
Phase 3 (next phase of projects) |
80 |
Due for completion by Mar 2022 |
Phase 4 (medium term pipeline) |
c387 |
Due for completion 2022/23 |
Phase 5 (longer term pipeline) |
c268 |
Due for completion 2023/24 |
Projected total |
c961 |
N/A |
8.5
The Council is currently developing an accelerated pipeline of NHFN projects to take advantage of the Government’s lifting of the Housing Revenue Account (HRA) borrowing restrictions. The removal of the HRA Borrowing Cap will enable substantial growth in the numbers of homes that can be built or purchased within the HRA alongside the continued investment in existing homes. The delivery of viable schemes and therefore the levels of future borrowing are likely to depend on the availability of Right to Buy (RTB) receipts and other forms of grant funding available. Current rules only allow RTB receipts to pay for 30% of build costs, although the Government has recently consulted on the use of receipts.
ii) Homes for Brighton & Hove (Living Wage Joint Venture)
8.6
Homes for Brighton & Hove is a partnership between Brighton & Hove City Council and the Hyde Group set up to create 1,000 new affordable homes for rent and sale for lower income, local working households in the city. The combined additional investment will total over £100m. The new developments will be 100% affordable housing, with 50% of the new homes available to rent at levels affordable for working Brighton & Hove residents earning the new National Living Wage, and the remaining 50% provided as shared ownership homes.
8.7
By working together through the Homes for Brighton & Hove partnership, it is intended to speed up the delivery of new homes and address the need demonstrated by the City Plan and Housing Strategy. All the housing will be for people living and/or working in the city.
8.8
The target is to build 1,000 new homes over five years, with over 500 new homes planned in the first wave of the development. The first developments are:
- Land at Coldean Lane, Brighton – Development of 242 residential apartments in on urban fringe site. Planning permission granted March 2020.
- Former Belgrave Day Centre, Clarendon Place, Portslade – Redevelopment of a former training centre for 104 residential apartments. Planning permission granted April 2020.
Identification of further sites is underway.
8.9
The Homes for Brighton & Hove initiative gives the Council a method of increasing the supply of affordable homes that does not require HRA funding or land, which will ensure that HRA land can be prioritised for Council led development. It includes investment of approximately £60m in affordable housing from both the Council’s General Fund and from Hyde Housing, and uses Hyde’s expertise in development management to take forward these sites without impacting on the capacity of Council teams.
iii) Hidden Homes initiative
8.10
This is a Council programme to refurbish and convert under-used or unused spaces within existing Council stock into new homes. Fifteen new homes have been delivered to date, with a further 11 due to be delivered in 2020/21. There is a pipeline of potential sites to deliver approximately 20 further units.
iv) Home Purchase Policy
8.11
This scheme was initially set up to enable the Council to buy back homes that have been sold under ‘right to buy’ to be used for general needs or temporary accommodation. However, in September 2018, the Council’s Housing & New Homes Committee agreed the expansion of the scheme to allow the Council to look at purchasing affordable housing units secured under s106 agreements as part of new housing developments in schemes where there is a lack of interest from other affordable housing providers. The Council is now actively looking at acquisition opportunities.
v) Community Led Housing
8.12
The Council is working in partnership with the Brighton & Hove Community Land Trust which delivers the community led housing programme in the city. A pathway has been developed for Council owned sites to ensure there is clear route for considering when land or building opportunities may be suitable for community led housing, in line with the council’s Corporate Plan commitment. At present five sites have been identified which could be used for community housing schemes. The Council is currently reviewing options for further sites.
B. Partnership working to accelerate delivery and unlock stalled sites
i) King Alfred/RNR site
8.13
The site is allocated in City Plan Part One for redevelopment involving the replacement of the existing indoor public sports facilities along with a minimum of 400 residential units and potentially other leisure uses. Following the withdrawal of the Council’s preferred developer in August 2019, the Council has restated its commitment to delivering housing-led redevelopment on the site, but now considers that relocating the sports facilities elsewhere within the city will be necessary in order to bring forward a financially viable scheme. The process of establishing a new project began in early 2020 and includes consideration of alternative sites in the west of the city on which to deliver the sports centre. The delivery of housing will remain central to any future redevelopment proposals.
ii) One Public Estate
8.14
One Public Estate (OPE) is a Government funded programme which aims to make better use of public sector sites, cut running costs, and free up space for new homes and jobs while improving services to residents. OPE funding has been obtained for several projects in Brighton & Hove including:
- Hove Station Area: This is currently a mainly industrial area which is identified in the City Plan Part One for comprehensive mixed use redevelopment with a strategic allocation to deliver a minimum of 200 homes with retention/replacement of existing employment. The City Plan identifies potential for a minimum of 525 homes in the wider Hove Station area. The Council is preparing a masterplan in liaison with the relevant landowners and Hove Station Neighbourhood Forum which is intended to be adopted as a Supplementary Planning Document (SPD). Public consultation on the draft Masterplan/SPD will take place in early 2021, following which the SPD will be formally adopted by the Council. This will help bring forward coordinated development and ensure that the development potential of the area is achieved.
- Brighton General Hospital: Sussex Community NHS Foundation Trust is looking to consolidate their existing uses on the site which offers surplus public land with potential for comprehensive re-use and redevelopment. The site is proposed for allocation in the City Plan Part Two Proposed Submission for a minimum of 200 residential units, together with a health and care facility and community facilities. The Council is currently working with the NHS trust to bring forward a comprehensive scheme for the site.
- Moulsecoomb Neighbourhood Hub: This project aims to consolidate and improve a range of public services and facilities in the Moulsecoomb area, which will free up land to provide new low-cost housing. The area offers longer term potential to provide more than 200 affordable homes, which will be developed through the Council’s New Homes for Neighbourhoods programme. The Council has undertaken early engagement with the local community through a series of ‘Planning for Real’ session held in January 2020 and is currently preparing detailed proposals leading towards submission of a planning application in late 2021 following further community engagement.
C. Improving communication with housing providers
i) Strategic Housing Partnership
8.15
The Strategic Housing Partnership is a sub-group within the Local Strategic Partnership (Brighton & Hove Connected) which brings together representatives of organisations with direct involvement or interest in addressing local housing needs (including the requirements of specific groups such as students, older persons, vulnerable and homeless people). The aim of the SHP is to improve housing, access to housing, and housing support to maintain the independence of vulnerable residents within the City. SHP members include Brighton & Hove Council, the Brighton and Hove Economic Partnership, Affordable Housing Partnership, and representatives of local planning professionals and local estate agents, landlords, the city’s two universities, health providers etc. Meetings are held every two months.
8.16
The key objectives of the SHP are to:
- Provide leadership and vision to improve housing for all within the City;
- Co-ordinate cross tenure action to improve housing conditions and housing options;
- Influence policy and decision-making which maximises housing opportunities for all within the City and develop new policies where appropriate;
- Communicate with and secure participation of local communities;
- Support action to address the housing needs of vulnerable and socially excluded groups.
ii) Affordable Housing Delivery Partnership
8.17
The Affordable Housing Delivery Partnership brings together the Council’s preferred partner Housing Associations which are the main Registered Providers operating in the city. The current preferred partners are signed up to the Brighton & Hove Housing Strategy and actively contribute to the Council’s strategic housing objectives.
8.18
Meetings take place every three months and are attended by representatives of the preferred partner Housing Associations and Homes England, together with Council housing and planning officers. The meetings provide an opportunity to discuss progress in delivering new affordable housing and related planning policy and housing market issues.
iii) Planning Agents’ Forum (PAF)
8.19
The Planning Agents’ Forum (PAF) comprises planning agents who regularly submit planning applications to the City Council. PAF was established following the recommendations of a Planning Peer Challenge carried out in March 2016 and organised by the Local Government Association (LGA) with the Planning Advisory Service (PAS).
8.20
PAF is now recognised by the Council as a key mechanism for engaging with local planning agents. Regular meetings are held approximately every three months which are chaired by PAF and are attended by the Head of Planning and other senior officers. PAF also organises workshops with the Council. The Forum has provided a useful vehicle enabling the Council to obtain views and feedback from the local development industry, and to discuss issues of joint interest, including matters relating to improvement of the Council planning service.
8.21
As noted elsewhere in this document, the Council has used PAF to provide views from planning agents and developers on the constraints to housing delivery in Brighton & Hove and how these could potentially be addressed, including through Council actions.
D. Improving the performance of the Council Planning Service
i) Encourage pre-application enquiries and discussions
8.22
Pre-application discussion/advice enables potential planning issues relating to proposed development to be identified and addressed ahead of a planning application being submitted (covering issues such as policy compliance, design, development impacts etc). This improves application quality and reduces the time needed for the Council to determine the subsequent application. The Council provides pre-application advice on a fee charging basis. In 2019/20 a total of 273 requests for pre-application advice were received. However, the Council has identified a need to improve the timescales for delivery of pre-application advice. This forms part of the quarterly monitoring of Development Management performance and is reported to Planning Committee members.
ii) Use of Planning Performance Agreements (PPAs)
8.23
Planning Performance Agreements (PPAs) are agreements between the local planning authority and planning applicants that set timescales for pre-application advice, planning applications and the implementation of development. The Council encourages the use of PPAs, subject to financial charging based on an officer hourly rate to cover the cost of the service. PPAs set out officer resourcing and provide developers with agreed timescales, but do not influence the final decision on an application. The use of PPAs enables the Council to identify capacity and allocate resources to the planning application process in advance, which improves deliverability and timescales for determining the planning application.
8.24
In September 2018, committee approval was obtained for the introduction of a ‘fast track’ fee option for PPAs, based on the applicant/developer covering the cost of the additional resource, including hourly rates plus the council’s additional costs around IT, office accommodation and administration of the staff’s agency contract.
iii) Improve timescales for determining planning applications
8.25
The Council has been consistently in the top 25% of unitary councils in determining major applications within the target determination timescales (usually 13 weeks or other agreed time). It is these applications that have the most significant impact in terms of delivery of new housing.
8.26
The Council historically ranked in the lowest 25% of unitary councils for determining minor applications within the target determination timescales (usually 8 weeks or other agreed time), however performance has improved significantly and is now equal with that of Unitary comparators. The impact of small applications is less significant in terms of overall housing delivery, but the Council is steadily improving timescales for determining small applications through the corporate modernisation programme including use of better IT systems, streamlined procedures, smarter working, training, and development.
iv) Improve timescales for Section 106 agreements
8.27
For most major planning permissions in Brighton & Hove, s106 agreements are completed within three months of the Planning Committee resolution to permit. Council Committee reports include provisions which authorise the Head of Planning to refuse planning permission if s106 agreements are not completed within a 16-week period, which will be reduced to 12 weeks in future to further expedite development. The range and scope of matters covered in s106 agreements has been reduced by the introduction of CIL from 5 October 2020 and this will further reduce the timescales needed.
8.28
In general, the most complex and time-consuming elements of s106 agreements relate to affordable housing provision (particularly issues of phasing/trigger points and provision for any viability reviews). These are areas where there is limited scope to reduce Council requirements without compromising key objectives of the City Plan.
v) Improve timescales for discharge of planning conditions
8.29
The Council acknowledges that there are currently some specific issues affecting timescales for the discharge of planning conditions. These relate particularly to the timescales for the agreement of Construction Management Plans (CMPs), which can cause delays to commencement of development; and also agreement of Travel Plans which can delay the final occupation of built residential units. These issues have arisen mainly due to resourcing issues in the Council’s sustainable transport service. The Council is looking to address these issues by recruiting more staff and through use of consultancy support.
E. Progressing work on the City Plan
i) Brighton & Hove City Plan Part Two
8.30
The City Plan Part Two (CPP2) will support accelerated housing delivery in three main ways:
- By assisting the implementation on the development strategy and strategic policies
- already set out in City Plan Part One (adopted in March 2016);
- By identifying and allocating additional sites for housing development; and
- By providing detailed development management policies to assist in the determination of planning applications, replacing the current retained policies from the 2005 Brighton & Hove Local Plan.
8.31
The Council’s work on CPP2 has included assessment of all sites identified in the SHLAA to determine if they are suitable for allocation for housing and/or mixed uses (including housing). Following this analysis, the majority of SHLAA sites which do not already have planning permission (or where permissions have not yet commenced) have been proposed for allocation in CPP2 and many of these sites are already coming forward through planning applications.
8.32
The draft CPP2 was published for Regulation 18 consultation in Summer 2018, after which further work was undertaken to amend the draft policies, including seeking further evidence on a range of matters (including issues related to housing delivery). The Proposed Submission version of CPP2 was agreed by the Council on 23 April 2020 and published for consultation over an 8-week period from 7 September to 30 October 2020 (the consultation period having been delayed for several months due to the COVID-19 restrictions). It is intended that the Proposed Submission Plan will be submitted for examination in Spring 2021.
ii) City Plan Review
8.33
This is a longer term objective that will follow the adoption of City Plan Part Two. The Council is currently undertaking initial assessment of the scope of the Review which is intended to be reported to the Tourism, Equalities, Communities & Culture (TECC) Committee in March 2021.