Authority Monitoring Report 2021 to 2022 - Residential development

1. Residential completions                            
2. Affordable residential                            
3. Extant permissions                                
4. Purpose built student accommodation
5. Houses in multiple occupation                        
6. Gypsy and Traveller provision

Table 1: Net completions by development type 2010/11-2021/22 

BHCC 2022

There were 1073 net housing completions in 2021/22. This is a substantially higher completion figure than any previous year over the City Plan period to date (since 2010) and comfortably exceeds the annualised housing requirement of 660 dwellings per year. However, due to the under-provision in previous years, the implied annual delivery rate required to meet the Plan target remains high at 909 dwellings per year (Table 2). 

Table 2: City Plan housing requirement

BHCC 2022

The highest proportion of housing delivery in 2021/22 was completed through new build developments, which provided a total of 813 net dwellings. This is a significant improvement on previous monitoring years. 

Table 3: Net Completions by development size 2011/12-2020/21

BHCC 2022

There has been a substantial increase in residential completions on large developments which are at the highest level of the Plan period (Table 3), with completions in small developments remaining at a similar level to previous years. Of the 925 units completed on large sites, 376 were within Development Areas, as defined in the City Plan Part 1 (Policies DA1-DA8); these include developments within DA3 at Preston Barracks, DA4 at 25-28 Elder Place and within DA5 at the former Amex House on Edward Street. The residential completions on sites of 10 or more dwellings are summarised in Table 4, these sites delivered a total of 887 units.  

Table 4: Major Developments Completed 2021/22 

BHCC 2022

Table 5 illustrates the net annual residential completions in the city over the past 15 years. The average rate of residential completions over this period (from 2007/08) and since the start of the City Plan period (2010/11) has been 506 and 494 units per year respectively. Annual completions then increased each year between 2010/11 until 2015/16. In 2016/17 the number of completions dipped again and remained below the required City Plan delivery rate of 660 units per year, until the 2021/22 monitoring year which has significantly surpassed the annual requirement.  

Table 5: Total residential completions in Brighton & Hove 2007/08– 2021/22 

BHCC 2022

In 2021/22 flats comprised 84% of new residential completions; 80% of which were 2 bed flats or smaller. Of the 16% completed as houses, 63% were 3 bed houses or larger. Overall, 1 and 2 bed units comprised 86% of the residential units completed in 2021/22. This is a higher percentage than in the previous 2 monitoring years (Table 6). 

Table 6: Proportion of Gross Number of Units per Unit Size 2019/20 - 2021/22 

BHCC 2022 

For the purposes of Government housing completions data, self-contained student accommodation has been included as part of the self-contained housing stock recorded in the housing supply data returns since 2018/19.  With the inclusion of self-contained student accommodation, the total figure for self-contained residential accommodation increases to 1,260 units (Table 7).  

Table 7: Total net residential and self-contained student accommodation 2019/20-2021/22 

BHCC 2022 

Table 8: Total net prior approval completions by size 2013/14 - 2021/22 

BHCC 2022 

The permitted development right (PDR) for a change of use from office to residential use was introduced in 2013 and was subsequently extended to include retail, financial and professional services, light industrial and storage or distribution uses. These developments require prior approval from the local authority but are not subject to the standard planning application process. A new PDR for the change of Commercial, Business and Service use (E use class) to residential use came into force in August 2021 which covers and extends the previous PDR. 

Table 9: Prior Approval PD completions and completions through planning applications 

BHCC 2022 

There were 73 residential units completed through permitted development in 2021/22 (Table 8). 64 of these were the result of a change of use from office floorspace. Although these rights have increased residential delivery since 2013/14, the council has limited controls to ensure that the residential units permitted meet amenity standards and cannot use planning policies to seek a proportion of affordable housing. Change of use to residential through permitted development also reduces the supply of office space in the city. 

Housing affordability is a major issue within the city as house prices in Brighton & Hove are high relative to incomes. Policy CP20 in City Plan Part 1 requires the provision of affordable housing (or an equivalent contribution) as part of all developments of 5 or more dwellings. Affordable housing is defined as housing for sale or rent for households whose needs are not met by the market (for example, affordable rented housing or shared ownership).

Table 10: Total gross affordable completions by tenure 2010-2021 

BHCC 2022 

A total of 479 affordable homes were completed in 2021/22 (Table 10), this comprises 45% of all gross completions, significantly high than any other year since the start of the Plan period. 478 affordable units were delivered through major developments which represents 54% of all units within major developments. Of the 8 completed major developments with affordable housing, 2 were 100% affordable. There were no off-site affordable financial contributions in lieu, as all affordable housing units were delivered on-site. 35% of the affordable units were 1-bed units, 46% were 2-bed and 17% were 3-bed. 

There were 4,255 net housing units with extant permissions at the end of March 2022 of which 3,197 units are in schemes that have commenced8. There were 1,080 net affordable housing units with extant permissions at the end of March 2022. Of that, 758 units in schemes have commenced. There were 543 new net housing units permitted9 in 2021/22 (Table 11), 35 of which were affordable housing units.  

Table 11: Number of new residential units permitted 2010/11-2021/22 

BHCC 2021

City Plan Part 1 Policy CP21 encourages the provision of purpose-built student accommodation (PBSA) to help meet the housing needs of the city’s students and reduce the demand from students for alternative accommodation in the private rented sector, including Houses in Multiple Occupation (HMOs).  

There were 1,487 net bedrooms completed in PBSA in 2021/22 (Table 12) distributed in 187 cluster units 10 and 187 single-occupancy self-contained flats within PBSA (Table 13). The completed bedrooms are a result of the completions of student accommodation at 41-42 Park Wall Farm Cottages in Falmer, 118-132 London Road, Preston Barracks and 1 Moulsecoomb Way. Since 2010/11; 6,658 new bedrooms have been developed within Brighton & Hove. A further 2,223 bedrooms were under construction at the end of 2021/22. 

Table 12: Number of New Communal Student Bedrooms Completed 2010/11 – 2021/22 

BHCC 2022 

Table 13: Number of New Communal Student Units Completed 2015/16 - 2021/22 

BHCC 2022 

There are approximately 3,600 licensed Houses of Multiple Occupation (HMOs) in the city. On 5 April 2013, an Article 4 Direction relating to HMOs (use class C4) came into force in 5 electoral wards within Brighton & Hove which overrides national permitted development rights and requires a planning application to be submitted for such changes of use. The Article 4 Direction was expanded to cover the whole city in June 2020. This enables the impact of concentrations of HMOs in certain areas of the city to be considered by the council using the criteria in City Plan Part 1 Policy CP21 and City Plan Part 2 Policy DM7 when assessing proposals for new HMOs.  

Table 14: Decisions on HMO applications in initial 5 Article 4 Wards 2013/14-2021/22 

BHCC 2022 

There have been 355 planning applications, for the change of use of a single dwelling house to a small HMO between April 2013 and March 2022 in the 5 wards where an Article 4 Direction took effect in April 2013 (Table 14). Of these, 196 were approved and 159 refused. Of those refused, 65 have been subject to an appeal, of which 32 appeals have been allowed.  

Table 15: Decisions on HMO applications from City-Wide Article 4 from June 2020 to April 2022 

BHCC 2022 

Between the implementation of the citywide Article 4 Direction, on 3 June 2020, and the 31 March 2022 there have been 64 planning applications, 46 approved and 18 refused, for the change of use of a single dwelling house to a small HMO (Table 15). Of those refused, 13 have been subject to an appeal, of which 10 have been allowed.  

Policy CP22 ‘Traveller Accommodation’ in City Plan Part 1 sets out the council’s approach to providing traveller accommodation based on assessments of local need. 

An updated Gypsy and Traveller Accommodation Needs Assessment (GTAA) was published in 2019, details of which are outlined in the 2018/19 AMR. A joint site search exercise undertaken by Brighton & Hove City Council and the South Downs National Park Authority in 2016-17 did not identify any suitable and available sites. No neighbouring authorities have indicated any ability to assist in meeting the unmet need via the Duty to Cooperate process.