Authority Monitoring Report 2023 to 2024

How to view this document

Download a PDF version of the Authority Monitoring Report (AMR) or continue to view it on this page.

1. Introduction

This Authority Monitoring Report (AMR) 2023 to 2024 meets the requirement of Section 35 of the Planning and Compulsory Purchase Act 2004 and Localism Act 2011 amendments, to prepare a report, at least annually, which sets out progress on the implementation of the Local Development Scheme (LDS) and the extent to which the policies set out in the local development documents are being achieved. This report covers the most recent ‘monitoring year’ from 1 April 2023 to 31 March 2024.

The AMR reports on progress in preparing Development Plan Documents (DPDs) and monitors the implementation of adopted policies by reporting on indicators the Implementation & Monitoring plans for City Plan Part One, City Plan Part Two and Supplementary Planning Documents (SPDs).

The data has primarily been compiled from the annual monitoring undertaken by the Planning Policy Team. The team monitors all residential, commercial, and industrial planning permissions for each monitoring year.

Sites are visited to assess the progress of development on each site with planning approval. Other areas monitored by the team include appeals, housing land, retail, and sustainability.  Further data is gathered from other sources within the council.

Data from some of these indicators is set out in the report and all are summarised in the Appendices.  The monitoring informs whether current planning policies are effective or need revision or comprehensive review.

2. Local Development Scheme

This section reports on progress against the timetable for the preparation of documents set out in the Brighton & Hove Local Development Scheme (LDS). The LDS sets out a 3-year timetable for the production of Development Plan Documents by the council, with the most recent version covering the period 2023 to 2026 approved on 10 March 2023.

The LDS identifies the main Development Plan Documents to be prepared over a 3-year period including their spatial coverage, purpose, and status. It also sets out the status of supplementary planning guidance and other planning documents.

Updating the programme

There were no Local Development Plan documents adopted during the 2023 to 2024 monitoring year; however, the following documents have been approved or adopted post 31 March 2023:

• City Plan 2041 Key Issues Consultation – approved October 2024
• East Sussex, South Downs and Brighton & Hove Waste and Minerals Local Plan Revised Policies – adopted October 2024

The following background documents were completed since April 2023:

• Strategic Housing Market Assessment (SHMA) – August 2023
• Green Infrastructure (GI) Study – March 2024
• Employment Land Study – April 2024
• Sustainability Appraisal Scoping Report – October 2024

City Plan 2041

The ‘City Plan Part One Review’ referred to in the LDS is now known as ‘City Plan 2041’. The timetable in the LDS states that a Scoping Consultation (Reg. 18) would take place in Spring 2024. This consultation was delayed and took place 4 November 2024 until 20 January 2025. As a result, future stages of the plan’s preparation will also take place later than previously expected.

It is now expected that the timetable will be:

• Key Issues consultation: Autumn 2024
• Draft Plan consultation: Winter 2025 to 2026
• Proposed Submission consultation: Spring and summer 2026
• Submission to Secretary of State: Winter 2026
• Adoption: Autumn 2027

This timetable has been publicised as part of the promotional documentation supporting the consultation. The LDS will be updated in early 2025 to reflect the new timetable.

Full review of the Waste and Minerals Local Plan

Due to the delay in the adoption of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Local Plan Revised Policies, which took place in October 2024, work has not yet started on the Full Review. A revised timetable for the preparation of this document will be included in the forthcoming revised LDS.

3. Duty to co-operate

At present, the 2011 Localism Act, and the National Planning Policy Framework (NPPF) (NPPF December 2024, paragraphs 24 to 27) still place a duty on local planning authorities and other prescribed bodies to cooperate with each other to address strategic planning issues relevant to their areas. The Levelling Up and Regeneration Act 2023 proposes to abolish the duty to cooperate and replace it with ‘a flexible alignment policy’ which is yet to be consulted on).

To date, the council has been engaging on an ongoing and collaborative basis with its neighbouring planning authorities and other bodies to address relevant strategic planning issues and comply with the Duty.

Key areas of engagement are summarised briefly below.

City Plan 2041

A review of the City Plan focussing on the strategic policies in City Plan Part 1 has commenced. The new plan will be known as City Plan 2041.

The first stage of public consultation on key issues took place for 11 weeks from 4 November 2024 to 20 January 2025. A duty cooperate workshop was held on 11 December 2024 to which all neighbouring authorities and other bodies covered by the duty to cooperate were invited. The purpose of the workshop was to introduce the new plan and discuss which issues would be of cross-boundary significant and require joint working to address.

Shoreham Harbour

Brighton & Hove City Council, Adur & Worthing Councils, West Sussex County Council, the Environment Agency, and Shoreham Port Authority, adopted a Joint Area Action Plan for the Shoreham Harbour area in October 2019.

Waste and minerals

Brighton & Hove City Council is a Waste and Minerals Planning Authority and works jointly with East Sussex County Council and the South Downs National Park Authority (the authorities) on waste and minerals planning policy matters.

During 2017, the authorities commenced a partial review of the adopted Waste and Minerals Plan (2013) and Waste and Minerals Sites Plan (2017). This review focused on the Provision of Aggregates, Mineral Resources and Infrastructure Safeguarding and improvements to the effectiveness of certain policies within the Plan and the Revised Policies were adopted by the Authorities in 2024. A full review of the joint Waste and Minerals Local Plan is expected to commence in 2025.

4. Neighbourhood planning

Neighbourhood planning was introduced by the Localism Act 2011 and came into force in April 2012. Neighbourhood plans allow communities to create a vision and planning policies for the use and development of land in their area. They can be prepared by a parish council or (in unparished areas) by a designated neighbourhood forum.

The council has a duty to support neighbourhood planning and is expected to undertake the following responsibilities within meeting specified time periods and requirements set out in the Regulations:

• consider applications for the designation of a neighbourhood area made by a parish council or body, capable of being a neighbourhood forum
• consider applications made by local groups to become the recognised neighbourhood forum for a designated area
• provide advice or assistance to a parish council, neighbourhood forum or community organisation that is producing a neighbourhood plan or Order
• publish neighbourhood plans and Orders prepared by neighbourhood groups for pre-submission consultation and submit them for independent examination
• following the publication of the Examiner’s Report determine whether it should proceed to referendum, with or without modifications
• organise a referendum and, where more than half of those voting are in favour, formally make the neighbourhood plan or Order

There are 2 neighbourhood areas in the city with ‘Made’ Neighbourhood Plans that have been examined, been through referendum and adopted by the council.

These are:

• Hove Station Neighbourhood Plan – formally made on 28 March 2024
• Rottingdean Neighbourhood Plan – formally made on 28 March 2024

There are a further 5 neighbourhood areas which have been designated within the city, one of which was designated a ‘Business Area’:

• Hove Park Neighbourhood Area
• Brighton Marina Business Neighbourhood Area
• Hangleton & Knoll Neighbourhood Area
• Coldean Neighbourhood Area
• West Saltdean Neighbourhood Area

There are currently 5 designated Neighbourhood Forums in addition to Rottingdean Parish Council which is a qualifying body for the purposes of neighbourhood planning. Neighbourhood forums last for 5 years from their date of designation. The formal designation for the Hove Park Neighbourhood Forum lapsed in 2020 and no application to redesignate the forum has yet been submitted.

• Hove Station Neighbourhood Forum – designated 23 December 2014; re-designated 18 September 2019
• Hove Park Neighbourhood Forum – designated 9 July 2015 (lapsed after 5 years)
• Brighton Marina Neighbourhood Forum – designated 18 June 2015; re-designated 3 November 2020
• Hangleton & Knoll Neighbourhood Forum – designated 7 November 2018 (lapsed after 5 years)
• Coldean Neighbourhood Forum – designated 25 November 2021
• West Saltdean Neighbourhood Forum – designated 23 August 2022

Neighbourhood Plan Progress

All neighbourhood groups can prepare a neighbourhood development plan for their area following prescribed requirements set out in the Neighbourhood Planning Regulations.

On 15 August 2024, the council and Neighbourhood Forum received the Examiner’s Report for the Brighton Marina Neighbourhood Plan. It concluded that the Neighbourhood Plan, subject to several recommended modifications, meets the Basic Conditions and can proceed to the two referendums (one for businesses and one for residents), on13 February 2025.

West Saltdean Neighbourhood Forum published their draft Neighbourhood Plan for their Regulation 14 public consultation from 12 May to 30 June 2024. They submitted their Neighbourhood Plan to the council in November 2024 and the city council will be running the Regulation 16 consultation on 27 January 2025 for 6 weeks.

Coldean Neighbourhood Forum published their draft Neighbourhood Plan for their Regulation 14 public consultation from 18 June to 30 July 2024. They are currently working on the submission version of their plan. It is expected that the submission plan will be submitted to the city council late 2024 to early 2025.

5. Supplementary Planning Documents

All of the SPDs can be accessed through our Supplementary Planning Documents page and are listed below:

• SPD01 - Brighton Centre: Area Planning and Urban Design Framework
• SPD02 - Shop Front Design
• SPD03 - Construction and Demolition Waste
• SPD05 - Circus Street Municipal Market Site
• SPD06 - Trees and Development Sites
• SPD07 - Advertisements
• SPD09 - Architectural Features
• SPD10 - London Road Central Masterplan
• SPD11 – Biodiversity and Nature Conservation
• SPD12 - Design Guide for Extensions and Alterations
• SPD13 - Shoreham Harbour Flood Risk Management Guide
• SPD14 - Parking Standards
• SPD15 - Toads Hole Valley
• SPD16 – Sustainable Drainage
• SPD17 - Urban Design Framework
• SPD18 - Hove Station Masterplan

6. Implementing the Statement of Community Involvement

The council’s Statement of Community Involvement (SCI) sets out how and when the council will involve stakeholders in the preparation of its planning policy documents. The SCI was adopted by the council on 12 March 2015.

A review and update of the SCI is expected to take place in 2025.

7. Community Infrastructure Levy

In May 2020 the Community Infrastructure Levy (CIL) Charging Schedule was approved at Full Council and implementation started on planning permissions from 5 October 2020.

1. Residential completions 

Table 1: Net completions by development type 2010 and 2011 to 2023 and 2024 

Year	New build	Conversions	Change of use	Total
2010 to 2011	125	106	52	283
2011 to 2012	164	42	103	309
2012 to 2013	281	52	41	374
2013 to 2014	329	56	51	436
2014 to 2015	390	25	166	581
2015 to 2016	422	43	222	687
2016 to 2017	175	37	127	339
2017 to 2018	253	39	152	444
2018 to 2019	167	31	182	380
2019 to 2020	369	24	150	543
2020 to 2021	295	43	141	479
2021 to 2022	813	43	217	1073
2022 to 2023	555	36	269	860
2023 to 2024	854	14	207	1075

Key findings are:

• the 1075 net housing completions in 2023 to 2024 is the highest completion figure in the current plan period of 2010 to 2030 and comfortably exceeds the annualised housing requirement of 660 dwellings per year.
• due to the under-provision in previous years, the implied annual delivery rate required over the remainder of the plan period to 2030 to meet the overall Plan target of 13,200 homes remains high at 890 dwellings per year
• new build developments accounted for the largest share of housing delivery in 2023 to 2024, yielding a total of 854 net dwellings

Table 2: City Plan housing requirement

	Plan requirement	Implied annual rate
Plan Period 2010 to 2030	13,200	660
Remaining period 2022 to 2030	5,337	890

The 5,337 number takes into account recorded net completions from 2010 to 2024 (7,863 units)

Table 3: Net completions by development size from 2010 and 2011, to 2022 and 2023

	Large (over 5 units)	Small (1 to 5 units)	All
2010 to 2011	131	152	283
2011 to 2012	137	172	309
2012 to 2013	262	112	374
2013 to 2014	337	99	436
2014 to 2015	440	141	581
2015 to 2016	495	192	687
2016 to 2017	198	141	339
2017 to 2018	286	158	444
2018 to 2019	225	155	380
2019 to 2020	392	151	543
2020 to 2021	328	151	479
2021 to 2022	925	148	1073
2022 to 2023	685	175	860
2023 to 2024	905	170	1075

Key findings are:

• residential completions on large developments of 6 or more units in 2023 to 2024 was the second highest total in the Plan period
• out of the 905 units completed on large sites, 351 were located within Development Areas (DAs) as defined in City Plan Part One (Policies DA1 to DA8) resulting from the ‘Hove Gardens’ development at Unit 1 to 3 Ellen Street within DA6 Hove Station Area and ‘The Blockhouse’ development at Pelham Street within DA4 New England Quarter
• 467 units were completed within site allocations as identified in the City Plan, including 242 affordable housing units on the Bluebell Heights development on the ‘Land to the East of Coldean Lane’ site. 

A full list of residential development completions of 10 or more dwellings is set out in Table 4, with these sites yielding a total of 876 net units. 

Table 4: Major developments completed 2023 to 2024

Address	Development	Net units completed
Land to the East of Coldean Lane, North of Varley Halls, South of the A27	Erection of two 7-storey buildings and four 6-storey buildings to provide 242 residential units (H2 site allocation)	242
Unit 1 to 3 Ellen Street, Hove	Demolition of existing buildings and redevelopment to provide mixed use scheme including 216 residential units	216
Greater Brighton Metropolitan College, Pelham Street, Brighton	Mixed use redevelopment of Greater Brighton Metropolitan College site including the provision of 135 residential units	135
Palmer & Harvey House, 106 to 112 Davigdor Road, Hove	Prior Approval for change of use from offices to 92 residential units (SSA3 site allocation)	92
113 to 119 Davigdor Road, Hove	Mixed use development including 52 residential units (SSA3 site allocation)	52
St Aubyn’s School, 76 High Street, Rottingdean	Remaining 48 residential dwellings on Former St Aubyn’s School site delivered (H1 site allocation)	48
239 to 243 Kingsway, Hove	Demolition of existing buildings and erection of 8-storey building to provide 34 residential flats	34
Land South of Ovingdean Road, Brighton	Remaining 33 residential dwellings on Land adjacent Ovingdean and Falmer Road site delivered (H2 site allocation)	33
Montpelier House, 99 Montpelier Road, Brighton	Prior Approval for change of use from offices to 12 residential flats	12
51 to 53 West Street, Brighton	Prior Approval for change of use from offices to 12 residential flats	12

Table 5: Total residential completions in Brighton & Hove 2009 to 2024

2009 and 2010 to 2013 and 2014

Year	2009 to 2010	2010 to 2011	2011 to 2012	2012 to 2013	2013 to 2014
Total net completions	380	283	309	374	436

Five-year average

356 

2014 and 2015 to 2018 and 2019

Year	2014 to 2015	2015 to 2016	2016 to 2017	2017 to 2018	2018 to 2019
Total net completions	581	687	339	444	380

Five-year average

486

2019 and 2020 to 2023 and 2024 

Year	2019 to 2020	2020 to 2021	2021 to 2022	2022 to 2023	2023 to 2024
Total net completions	543	479	1073	860	1075

Five-year average

806 

Table 5 illustrates the net annual residential completions in the city since the start of the Plan period (2010 to 2011).  

Key findings are: 

• the average rate of residential completions over this period has been 562 units per annum, less than the plan requirement at adoption of 660
• completions have increased significantly since the 2021 to 2022 monitoring year, exceeding the annual requirement

Table 6: Proportion of gross number of units per unit size 2021 and 2022 to 2023 to 2024

	1 Bed	2 Bed	3 Bed	4+ Bed
2021 to 2022	42.1%	44.2%	11.3%	2.4%
2022 to 2023	60.3%	26%	9.8%	3.9%
2023 to 2024	44.8%	38.3%	11%	5.9%

In 2023 to 2024, flats comprised 88% of newly completed residential units, with 81% of these flats featuring 2 bedrooms or fewer. The remaining 12% of newly completed residential units were houses, 75% of which were 3-bedroom houses or larger.  

Whilst one and 2-bedroom units remains the largest proportion of all residential units completed in 2023 to 2024 (83% of all units), there was a higher proportion of 3 and 4-bedroom units completed than in previous monitoring years (17% of all units).  

Table 7: Total net residential and self-contained student accommodation 2020 and 2021 to 2022 and 2023

Date	Residential	Student	Total
2020 to 2021	479	303	782
2021 to 2022	1,073	187	1,260
2022 to 2023	860	99	959
2023 to 2024	1,075	155	1,230

For government housing completion data (annual housing flows reconciliations submitted by the council to central government for monitoring housing completions and the housing delivery test), self-contained student accommodation has been included as part of the self-contained housing stock recorded in the housing supply data returns since 2018 to 2019. 

With the inclusion of self-contained student accommodation, the total figure for self-contained residential accommodation increases to 1,230 units.  

Table 8: Total net prior approval completions by size 2013 and 2014 to 2023 and 2024 

	10 units and above	Below 10 units
2013 to 2014	0	3
2014 to 2015	67	44
2015 to 2016	100	65
2016 to 2017	22	42
2017 to 2018	53	32
2018 to 2019	75	32
2019 to 2020	10	19
2020 to 2021	0	14
2021 to 2022	54	19
2022 to 2023	183	29
2023 to 2024	116	41

A Permitted Development Rights (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 as a proportion of total net residential completions 2013 and 2014 to 2023 to 2024 

	Prior approval PD completions	Other residential completions	Total residential completions
2013 to 2014	3	433	436
2014 to 2015	111	470	581
2015 to 2016	165	522	687
2016 to 2017	64	275	339
2017 to 2018	85	359	444
2018 to 2019	107	273	380
2019 to 2020	29	514	543
2020 to 2021	14	465	479
2021 to 2022	73	1000	1073
2022 to 2023	212	648	860
2023 to 2024	157	918	1075

In 2023 to 2024, 157 residential units were completed through permitted development, which represents a decrease compared to the previous year. Whilst permitted development has boosted residential delivery since 2013 to 2014, the council's ability to ensure that permitted residential units meet amenity standards and secure affordable housing contributions is limited. 

Additionally, a change of use to residential through permitted development can diminish the city's office space supply. 

2. Affordable residential

Housing affordability remains a severe challenge in Brighton & Hove, as house prices have risen, substantially outpacing income levels. To address this issue, Policy CP20 of City Plan Part One requires the inclusion of affordable housing (or an equivalent financial contribution) in all new developments comprising 5 or more net 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).

Policy CP20 states that the council will require the provision of affordable housing on all sites of 5 or more dwellings (net) and will negotiate to achieve the following affordable housing targets:

a) 40% onsite affordable housing provision on sites of 15 or more (net) dwellings;

b) 30% onsite affordable housing provision on sites of between 10 and 14 (net) dwellings or as an equivalent financial contribution;

c) 20% affordable housing as an equivalent financial contribution on sites of between 5 and 9 (net) dwellings.

The overall target for Policy CP20 is to achieve approximately 30% affordable housing of all housing delivery as affordable housing.

Key findings are:

• in 2023 to 2024 318 affordable homes were completed (Table 10), comprising approximately 28% of all gross completions
• over the past 5-year period, 30% of all homes completed were affordable, in line with the City Plan target (Table 11)
• over the plan period since 2010, 24% of all homes have been affordable, slightly less than the overall target
• Table 12 below shows that out of the units delivered through major developments, 36% were affordable homes, an increase on the previous monitoring year
• the Bluebell Heights major development on the Land to the East of Coldean Lane site comprised of 242 residential units, all of which are affordable housing

Table 10: Total gross affordable completions by tenure from 2010 and 2011, to 2022 and 2023

Year	Affordable housing for rent (affordable rent)	Shared ownership	Affordable housing for rent (social rent)	Affordable homes provided
2010 to 2011	5	3	0	8
2011 to 2012	66	0	0	66
2012 to 2013	69	44	0	113
2013 to 2014	53	110	0	163
2014 to 2015	44	88	0	132
2015 to 2016	34	65	0	99
2016 to 2017	56	0	0	56
2017 to 2018	94	0	2	96
2018 to 2019	20	60	0	80
2019 to 2020	54	117	8	179
2020 to 2021	35	86	31	152
2021 to 2022	85	333	61	479
2022 to 2023	117	55	0	172
2023 to 2024	159	147	12	318

Table 11: Affordable proportion (%) of total gross units completed 2023 to 2024 

Monitoring year	Gross units completed	Gross affordable units completed	Affordable proportion (%)
2010 to 2011	384	8	2%
2011 to 2012	378	66	17%
2012 to 2013	374	113	30%
2013 to 2014	509	163	32%
2014 to 2015	645	132	20%
2015 to 2016	751	99	13%
2016 to 2017	423	56	13%
2017 to 2018	490	96	20%
2018 to 2019	424	80	19%
2019 to 2020	613	179	29%
2020 to 2021	529	152	29%
2021 to 2022	1,130	479	42%
2022 to 2023	957	172	18%
2023 to 2024	1,149	318	28%
Sub-total  2019 and 2020 to 2023 and 2024	4,378	1,300	30%
Total since 2010 to 2011	8,756	2,113	24%

Table 12: Affordable proportion (%) of gross units completed in major developments 2023 to 2024 

Monitoring year	Gross units completed	Gross affordable units completed	Affordable proportion (%)
2018 to 2019	119	80	67%
2019 to 2020	377	169	45%
2020 to 2021	320	147	46%
2021 to 2022	896	478	53%
2022 to 2023	624	172	28%
2023 to 2024	879	318	36%

3. Extant permissions

Key findings are: 

• there were 804 new net housing units permitted in 2023 to 2024 (Table 11)
• of these, 331 of which are affordable housing units (41%)
• if delivered, this would be above the Plan target of 30% 

Table 11: Number of new residential units permitted 2010 and 2011 to 2023 to 2024 

Date	New units permissioned
2010 to 2011	682
2011 to 2012	551
2012 to 2013	497
2013 to 2014	659
2014 to 2015	1,130
2015 to 2016	567
2016 to 2017	516
2017 to 2018	1,278
2018 to 2019	1,257
2019 to 2020	1,216
2020 to 2021	1,628
2021 to 2022	543
2022 to 2023	1,169
2023 to 2024	804

4. Purpose built student accommodation

City Plan Part One 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). 

Key findings are:

• there were 252 net student bedrooms in 171 self-contained units completed in PBSA in 2023 to 2024 (Table 12)
• over the plan period since 2010 to 2011, 7,009 new student bedrooms have been developed within Brighton & Hove

Table 12: Number of new communal student bedrooms completed 2010 and 2011 to 2023 and 2024

Monitoring year	Student bedrooms
2010 to 2011	798
2011 to 2012	0
2012 to 2013	744
2013 to 2014	127
2014 to 2015	390
2015 to 2016	0
2016 to 2017	100
2017 to 2018	125
2018 to 2019	444
2019 to 2020	1,720
2020 to 2021	723
2021 to 2022	1,487
2022 to 2023	99
2023 to 2024	252

Table 13: Number of new communal student units completed 2015 and 2016 to 2023 and 2024

Monitoring year	Clusters	Self-contained	Total
2015 to 2016	0	0	0
2016 to 2017	14	0	14
2017 to 2018	7	95	102
2018 to 2019	11	0	11
2019 to 2020	225	15	240
2020 to 2021	63	303	366
2021 to 2022	187	187	374
2022 to 2023	0	99	99
2023 to 2024	16	155	171

5. Houses of Multiple Occupation

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 One Policy CP21 and City Plan Part Two Policy DM7 when assessing proposals for new HMOs. 

Table 14: Decisions on HMO applications in initial 5 Article 4 Wards from 2013 and 2014, to 2022 and 2023

Decision	Percentage of decisions
Approved	56%
Refused	44%
Of those refused appealed	42%
Of those appealed allowed	51%
Of those appealed dismissed	49%

There have been 367 planning applications, for the change of use of a single dwelling house to a small HMO between April 2013 and March 2024 in the 5 wards where an Article 4 Direction took effect in April 2013 (Table 14). Of these, 206 were approved and 161 refused. Of those refused, 67 have been subject to an appeal, of which 34 appeals have been allowed.  

Table 15: Decisions on HMO applications from citywide Article 4 from June 2020 to March 2024

Decision	Percentage of decisions
Approved	73%
Refused	26%
Of those refused appealed	75%
Of those appealed allowed	80%
Of those appealed dismissed	20%

Between the implementation of the citywide Article 4 Direction, on the 3 June 2020, and the 31 March 2024 there have been 76 planning applications, 56 approved and 20 refused, for the change of use of a single dwelling house to a small HMO (Table 15). 

Of those refused, 14 have been subject to an appeal, of which 12 have been allowed.  

6. Gypsy and Traveller provision

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

We have recently completed an updated Gypsy and Traveller Accommodation Needs Assessment (GTAA) which concludes that there is a need for 7 additional permanent pitches in the City Plan area, based on the assumption that 10% of the households identified as being of gypsy and traveller origin through the 2021 Census, and living in bricks and mortar, require a pitch. We will consider this issue further as work progresses on City Plan 2041. 

The GTAA will be available to view on the council website. 

1. Change of use through permitted development  

The majority of floorspace data in this section is gathered through monitoring planning applications. There are, however, changes which occur through Permitted Development Rights (PDRs) that do not require planning permission and are more difficult to monitor. Some of these changes of use require prior approval from the Local Planning Authority and can therefore be monitored. 

Retail health-checks of shopping centres can also identify changes which may not have been identified through planning processes.  

In September 2020 the use class order was amended to introduce a new Class E (commercial, business and service) and Class F (Local Community and Learning) use classes and revoke classes A, B1 and D.

The new Class E incorporates the previous use classes:

• A1 (shops)
• A2 (professional and financial services)
• A3 (restaurants and cafes)
• B1 (Business)

It also incorporates gyms, nurseries, and health centres previously in classes D1 (Non-residential institutions) and D2 (Assembly and leisure).

Uses previously falling into A4 (drinking establishments) and A5 (hot food takeaways) as well as cinemas, concert, dance, and bingo halls are now Sui Generis (SG) uses.

The analysis below includes changes of uses both prior to and after the change to the use class order and this will continue to be the case while applications submitted before September 2020 remain extant.

From August 2021 new permitted development rights came into force which reflected the ‘new’ use classes including the right to change use from the new ‘E’ use class to a C3 dwelling. These are summarised below.

Since 2013, changes of use from B1a offices to residential were allowed through permitted development subject to prior approval. The council introduced an Article 4 Direction in 2014 which removed these permitted development rights and required planning permission in three parts of the city. These were:

• Central Brighton, New England Quarter and London Road Area
• Edward Street Quarter, Edward Street, Brighton
• City Park, The Droveway, Hove

Office uses now fall under the wider Use Class E ‘Commercial, business, and service’ and following a transitional period, the Article 4 Direction lapsed on 31 July 2022.

A new permitted development right (Class MA) came into effect in 1st August 2021 which allows the change of use of E use to residential subject to conditions and prior approval.

In February 2023 the council introduced a new Article 4 Direction which overrides the Class MA PDR in an area broadly corresponding to the previous office to residential Article 4 direction together with primary retail frontages within the city’s retail centres and the city’s local centres and parades.

Summary of Permitted Development Rights relating to Changes of Use August 2021

E (Commercial, business and service)

Can change use class to:

• a permanent:
  • C3 of no more than 1,500m² (prior approval required)
  • mixed SG use comprising of a betting office or a pay day loan shop
  • E and C3 of up to 2 flats (prior approval required)
• a temporary or flexible (for up to three years)::
  • F1b
  • F1c
  • F1d
  • F1e

Eb (Restaurants and cafes)

Can change use class to a temporary or flexible SG (hot food takeaways) (until March 2022)

SG (Public house, wine bar, or drinking establishment)

Can change use class to a permanent SG (Drinking establishment with expanded food provision).    

SG (Drinking establishment with expanded food provision)

Can change use class to a permanent SG (Public house, wine bar, or drinking establishment).          

B2 (general industrial)

Can change use class to a permanent B8 (of no more than 500m²)             

SG (hot food takeaways)

Can change use class to:

• a permanent:
  • E (prior approval required)
  • C3 of no more than 150m² (prior approval required)
• a temporary or flexible (for up to three years)::
  • E
  • F1b
  • F1c
  • F1d
  • F1e

SG (Agricultural Building)

Can change use class to:

• a permanent C3 with a limit of five separate dwellings (prior approval required)
• a flexible (of no more than 500m²):
  • B8
  • C1
  • E (prior approval required)

SG (Amusement Arcade)

Can change use class to a permanent C3 of no more than 150m² (prior approval required)               

SG (Betting Office or Pay day loan)

Can change use class to:

• a permanent:
  • E (prior approval required)
  • C3 of no more than 150 m2 (prior approval required)
  • D2
  • mixed SG use comprising of a betting office or a pay day loan shop
  • E and C3 of up to 2 flats (prior approval required)
• a temporary or flexible (for up to three years):
  • E
  • F1b
  • F1c
  • F1d
  • F1e

SG (Casino)

Can change use class to a permanent:

• E (prior approval required)
• C3 of no more than 150m² (prior approval required)         

SG (Launderette)

Can change use class to a permanent C3 of no more than 150m² (prior approval required)                

E/C1/C2/SG (Agricultural Building)   

Can change use class to a permanent F1a (State funded School or registered nursery) of no more than 500m² (prior approval required)

2. Business development

This section summarises the development of employment floorspace in the city in 2023 to 2024. Use classes for employment floorspace prior to 2021 include:

• B1a (Offices)
• B1c (Industrial processes)
• B2 (general industrial, other than E(g)
• B8 (storage and distribution)

Since 2021, B1a, and B1c have been replaced by Eg(i) (offices to carry out any operational of administrative functions) and Eg(iii) (uses which can be carried out in a residential area without detriment to its amenity: industrial process).

The supply of employment land and premises is limited in the city. Policy CP3 ‘Employment Land’ of the City Plan Part One (CPP1) sets out a framework to safeguard and upgrade current employment sites in the city and create new employment floorspace through the regeneration of key sites. 

An indicative Employment Land Supply Trajectory (Table 2) was updated in December 2017 which guides the monitoring of new employment floorspace delivery through the City Plan period to 2032. The trajectory was produced by looking at the potential supply of floorspace through strategic site allocations and extant permissions at the time it was produced.  It does not consider overall city-wide windfall floorspace changes which are reported in the AMR. 

Table 1: Indicative delivery trajectory for Employment Land Supply by 5-year period

	2017 to 2022	2022 to 2027	2027 to 2032
Office- Indicative Floorspace Delivery (m²)	34,965	40,635	18,900
Industrial - Indicative Floorspace Delivery (m²)	6,926	3,463	3,463

Completions

There was an overall net loss of 207m² employment floorspace in 2023 to 2024. However, in terms of office floorspace there was a net increase of 1,770m², which includes:

• the completion of the ‘Portland Building’ on Church Street, Brighton
• the change of use of the former Kings School to the ‘Portslade Hub’ (occupied by the council’s children’s services) 
• redevelopment at 9 to 12 Middle Street, Brighton

The loss of office floorspace was primarily due to the completion of Palmer & Harvey House on 106-112 Davigdor Road, Hove (prior approval change of use office to residential).  

There was a net loss of 2,092m² in storage and distribution mainly, as a result of the completed ‘Hove Gardens’ development (a mixed commercial and residential scheme) at Unit 1 to 3 Ellen Street within DA6 Hove Station Area.  

Table 2: Gains, losses, and net change of employment floorspace 2023 to 2024

	B1a/Eg(i)	B1b/Eg(ii)	B1c/Eg(iii)	B2	B8	Mixed B/Eg	Total
Gross	7,763	0	0	288	0	0	8,051
Loss	-5,993	0	-173	0	-2092	0	-8,258
Net	1770	0	-173	288	-2092	0	-207

Part 3 of City Plan Part One Policy CP3 ‘Employment Land,’ seeks to protect the listed primary industrial estates and business parks for business, manufacturing, and warehouse use. In 2023 to 2024, there was no loss of employment floorspace on these sites.  

There was a net gain of 4,098m² of employment floorspace within the Policy SA2 Central Brighton area, much of which was attributed to the completion of the ‘Portland Building’ on Church Street.  

Table 3: Total employment floorspace change, by type 2010 and 2011  to 2023 and 2024

	B1a/Eg(i)	B1b/Eg(ii)	B1c/Eg(iii)	B2	B8	Mixed B/Eg	Total
Net floorspace change	-6,311	-668	-2,506	-11,003	-5,583	-6,580	-37,648

There has been a cumulative net loss of 37,648m² in employment floorspace since 2010 to 2011. Table 4 outlines the changes in employment floorspace since 2010/11. There has been an 8,267m² loss of employment floorspace over the past 5 years which represents an average annual net loss of 1,653m² of employment floorspace over that period.

Table 4: Employment floorspace change by type, between 2010 to 2011 and 2023 to 2024

Year	B1a/Eg(i)	B1b/Eg(ii)	B1c/Eg(iii)	B2	B8	Mixed B/Eg Use	Total
2010 to 2011	3,431	0	447	-2,244	134	0	1,767
2011 to 2012	8,691	0	2,211	27	279	0	11,209
2012 to 2013	-8,821	0	0	-528	-1,387	2,372	-8,364
2013 to 2014	4,073	82	-1,158	-190	2,146	0	4,953
2014 to 2015	-3,486	-410	-181	-394	373	0	-4,098
2015 to 2016	-8,358	-31	-924	-571	-5,997	1,852	-14,029
2016 to 2017	-2,584	-181	188	-130	-886	508	-3,085
2017 to 2018	-224	0	-4,483	-310	-1,906	0	-6,923
2018 to 2019	-466	-128	139	-3,521	597	-7,432	-10,811
2019 to 2020	1,766	0	-33	-460	232	0	1,505
2020 to 2021	1,139	0	2,843	-2,438	50	2,558	4,152
2021 to 2022	-1472	0	-1555	-244	782	-1118	-3,607
2022 to 2023	-5,105	0	-1,630	-1,078	3023	-5,320	-10,110
2023 to 2024	1,770	0	-173	288	-2,092	0	-207
Total	-6,311	-668	-2,506	-11,003	-5,583	-6,580	-37,648

Commencements

When all developments under commencement at the end of the monitoring year are completed, they will contribute to a 2,535m² net loss in employment space (Table 5). A large proportion of the loss of office floorspace results from the co-living scheme at Enterprise Point, Melbourne Street, and Gemini Business Centre on Old Shoreham Road, Hove (prior approval change of use office to residential). 

However, these losses will be partially mitigated by new office space to be provided as part of the Moda redevelopment at Sackville Trading Estate on Sackville Road, Hove.  

Table 5:  Potential gains, losses, and net change of employment floorspace from developments under commencement 2023 to 2024

	B1a/Eg(i)	B1b/Eg(ii)	B1c/Eg(iii)	B2	B8	Mixed B/Eg	Total
Gross	8,616	0	0	0	1074	0	9690
Loss	-9,039	0	-748	-70	-2,368	0	-12,225
Net	-423	0	-748	-70	-1,294	0	-2,535

Decisions

Planning applications approved in 2023 to 2024 are projected to result in a net loss of approximately 8,641m² in employment floorspace if all developments are constructed. This figure includes a net loss of 7,777m² in office floorspace, predominately as a result of the co-living scheme at Enterprise Point, Melbourne Street and Boundary House on Boundary Road, Hove (prior approval change of use office to residential). 

Prior approvals for change of use from offices to residential

The government introduced a permitted development right on 30 May 2013 (made permanent in April 2016) which allows conversions from offices to residential use without the need for planning permission. This PDR was superseded on 31 July 2021 by the PDR to change Use Class E uses to residential which became effective on 1 August 2021, which is reflected in the subsequent monitoring years.  

Table 6: Permitted development office to residential completions, from 2013 and 2014 to 2022 and 2023

Year	Residential units gain	Office floorspace loss
2013 to 2014	3	198
2014 to 2015	115	5,997
2015 to 2016	158	7,724
2016 to 2017	58	3,761
2017 to 2018	83	4,329
2018 to 2019	97	7,405
2019 to 2020	22	1,382
2020 to 2021	4	186
2021 to 2022	64	3,311
2022 to 2023	207	6,250
2023 to 2024	126	4,699
Total	937	45,242

Whilst these rights have facilitated an increase in residential development, they also result in a loss of office accommodation. 

Since the introduction of permitted development rights in 2013, there has been a loss of 45,242m² of office floorspace for the gain of 937 residential units. 

There was a decrease in the completion of office to residential prior approval developments in 2023 to 2024, with 126 residential units completed for a loss of 4,699m² of office floorspace (this includes B1a and Eg)(i) floorspace), the majority of this loss was due to the completion of the conversion of Palmer & Harvey House on 106 to 112 Davigdor Road, Hove. 

3. Shops, services, food and drink developments

This section summarises the development of retail and non-retail ‘A use class’ floorspace in the city in 2023 to 2024. 

The use class for retail floorspace is:

• A1 (Shops) and non-retail A use classes include the use classes
• A2 (Financial and professional services)
• A3 (Restaurants and cafés)
• A4 (Drinking establishments)
• A5 (Hot food takeaways)

Since September 2020 A1, A2 and A3 have been replaced by E(a) (shops), E(b) (restaurants and cafés), and E(c) (financial and professional services) while A4 and A5 are now sui generis uses.

The city’s need for additional retail floorspace over the City Plan period was estimated in 2011 to be 58,313m² of comparison floorspace and 2,967m² of convenience retail (Brighton & Hove City Council, Retail Study Update 2011, CBRE 2011).

Completions

There was a net loss of 6,672m² in all shops, services and food and drink floorspace in 2023 to 2024.

In terms of retail floorspace (A1/Ea), the net loss of 5,112² includes the demolition of the Co-op supermarket at 56 to 57 Lewes Road, Brighton and completion of the new ‘Ravilious House’ student accommodation block and a smaller retail unit. 

In addition, the demolition of the retail units on 5 to 8 London Road, Brighton (loss of Peacocks, Iceland and Poundland) and redevelopment to provide the new ‘Promenade Student Living’ block and a smaller retail unit was also completed. 

There was a higher net loss of shop, services and food and drink floorspace inside designated shopping centres in the city, identified in the City Plan, in the monitoring year, than outside these centres. This was predominantly due to completions of the developments mentioned previously. 

Table 7: Change in floorspace of A1 retail and non-retail A use classes 2023 to 2024

	A1/Ea	A2/Ec	A3/Eb	A4/ SG Drinking Est	A5/ SG Takeaway	Mixed A Uses	Total
Gross	172	0	1,482	50	263	554	2,521
Loss	-5,284	-2,603	-854	-207	-245	0	-9,193
Net	-5,112	-2,603	628	-157	18	554	-6,672

Table 8:  Shop, services and food and drink floorspace completions within designated shopping centres 2023 to 2024

	A1/Ea	A2/Ec	A3/Eb	A4/SG Drinking	A5/ SG Takeaway	Mixed A	Total
Within designated shopping centre	-3874	-2015	-78	0	-78	211	-5834
Outside designated shopping centre	-371	-63	665	-157	97	343	514

Since 2016 to 2017, there has been a successive net loss of shop, services and food and drink floorspace each year, with the past monitoring year of 2023 to 2024 representing the second-largest loss since 2010 to 2011. There has been a total loss of 15,633m² of retail floorspace since 2010 to 2011. There has, however, been a year-on-year increase in restaurant floorspace with a total net increase of 16,498m² since 2010 to 2011, including 628m² in the 2023 to 2024 monitoring year.  

Table 9: Change in floorspace of A1 retail and non-retail A use classes 2010 and 2011 to 2023 to 2024

Year	A1/Ea	A2/Ec	A3/Eb	A4/ SG (Drinking Est)	A5/ SG (Takeaway)	Mixed A Uses	Total
2010 to 2011	213	264	1,442	-43	284	316	2,476
2011 to 2012	-312	199	717	546	164	925	2,239
2012 to 2013	-1,766	-332	2,812	-462	40	0	292
2013 to 2014	65	-702	860	370	84	750	1,427
2014 to 2015	2,357	-499	903	-256	149	316	2,476
2015 to 2016	-1,805	-168	1,273	-214	121	2,861	2,068
2016 to 2017	-8	-232	1,217	-380	28	271	896
2017 to 2018	-2,984	-518	1,156	0	140	1,490	-716
2018 to 2019	-3,674	-336	1,526	-280	-108	1,827	-1,044
2019 to 2020	-13,118	-947	1,650	-349	8	329	-12,427
2020 to 2021	-2,663	-619	439	-1,310	-60	1,017	-3,196
2021 to 2022	-2,709	-18	861	-259	71	334	-1,720
2022 to 2023	-2,086	-438	899	0	0	-149	-1,774
2023 to 2024	-5,112	-2,603	628	-157	18	554	-6,672
Total	-33,602	-6,949	16,498	-2,794	866	10,841	-15,633

Commencements

Once completed, the shops, services and food and drink developments which were under construction, but not completed, in the monitoring year, would lead to an additional net loss of 6,503m² of retail floorspace.  

Decisions

A 1,429m² net loss of shops, services and food and drink floorspace was permitted in 2023 to 2024. 

Prior approval change of use retail to residential

Permitted development rights came into force in April 2014 to allow a change of use from retail or financial and professional services to residential when the area of floor space does not exceed 150m². 

There was a loss of 253m² of retail floorspace in 2023 to 2024 due to permitted development to residential through 3 applications, resulting in 4 new dwellings in total.

Retail health check

To safeguard the vitality and viability of Local, District, Town and Regional Centres as well as the newly identified Important Local Parades, retail centre health checks are carried out. 

The health check monitoring informs the application decision process to keep the correct balance of uses in each centre. In 2022, health check monitoring covered the primary frontages of Regional, Town and District centres as well as the entirety of Local Centres and Important Local Parades.  

In 2025, it is anticipated that a Retail Capacity Study will be commissioned as a background study for the City Plan 2041. This will involve an update to Retail Health Checks for the centres in the Retail Hierarchy and provide us an up-to-date picture of the type of units within our centres, some of which may have changed without the need for planning permission under Class E

4. Mixed use developments

There was a net gain of 573m² mixed-use development floorspace, which includes a mix of shops, services, food, and drink uses or employment uses with other use classes in 2023 to 2024. This was predominantly due to completions of the ‘Hove Gardens’ redevelopment at Unit 1 to 3 Ellen Street, the redevelopment at 9 to 12 Middle Street, Brighton and completion of the new ‘Ravilious House’ at 56 to 57 Lewes Road, Brighton.  

5. Leisure and cultural developments

CPP1 Policy CP2 Planning for Sustainable Economic Development recognises the importance to the local economy of employment-generating uses which do not fall within the former B use Class uses. Certain strategic site allocations in City Plan Part 1 and City Plan Part 2 include non-B Class uses. 

There was a net loss of 8,104m² in Non-Residential Institution floorspace (D1/Ee/Ef) in 2023/24. This includes the completion of ‘The Blockhouse’ (a residential scheme) as part of the redevelopment of Greater Brighton Metropolitan College on Pelham Street, and the change of use of the former Kings School to the ‘Portslade Hub’. 

There was a net increase of 157m² in Assembly and Leisure floorspace (D2/F1/F2) in 2023 to 2024. This includes the completion of the new Performing Arts Building at Brighton College, Eastern Road.  

6. Hotel development

The Brighton & Hove Visitor Accommodation Study Update 2018 forecasted a need for 2 new hotels (assuming an average size of a hotel of 150 bedrooms) in Brighton by 2022. This is in addition to the planned pipeline hotels that are set to open in the next 2 to 3 years (including Hotel Indigo and the Premier Inn West Street) with longer-term forecasts (2023 to 2030) indicating potential demand for further 4 to 8 hotels in the city. 

Given the sensitivity of the longer-term forecasts the City Plan is guided by the low-growth forecast requirement of up to 5 new hotels over the plan period. 

There was a net increase of 199 hotel bedrooms in 2023 to 2024, primarily through the completion of the 221 bedrooms at the new Maldron Hotel to the rear of the Hilton Brighton Metropole. In terms of loss of hotel bedrooms, 10 bedrooms were lost at Lichfield House, 30 Waterloo Street, Hove (change of use to HMO), and 9 bedrooms were lost at The Moreland, 33 Montpelier Road, Brighton (change of use to residential flats).

There were 236 hotel bedrooms under commencement at the end of the monitoring year, mainly through planning applications on West Street, Brighton. No new hotel developments or bed spaces were permitted in 2023 to 2024.  

City Plan Part One Policy CP15 and City Plan Part 2 (Policies DM26 to DM32) all aim to ensure that the historic environment plays an integral part in the future of the city. In addition to these policies, the Conservation Strategy clarifies the council’s responsibilities and reaffirms its commitment to the conservation of the city’s historic assets conservation including a programme of action for the future management of the city’s historic built environment.  A review of the Conservation Strategy commenced in 2024.

There are 480 Listed Buildings graded I and II* in the city. There are 10 buildings graded I and II* on the current Historic England ‘At Risk’ Register 2024, including five listed places of worship. The number of buildings at risk has decreased by one since the previous year, as Saltdean Lido (grade II*) was removed from the list following completion of its restoration programme.

Five of the 34 conservation areas in the city are currently included on the Historic England ‘At Risk’ register. These are:

• Benfield Barn
• East Cliff
• Old Town
• Sackville Gardens
• Valley Gardens

Since 2017, the Royal Pavilion Gardens, which is a grade II registered park and garden, has remained on the At-Risk Register. In January 2024, the council and Brighton & Hove Museums received a National Lottery Heritage Fund grant to restore the gardens and improve facilities. Once complete, this will help with the aim of removing the Royal Pavilion Gardens from the At-Risk Register.

In January 2024, councillors approved a new Character Statement for the College Conservation Area which will help address threats to the architectural and historic features in this area.

In July 2024, technical guidance for improving energy saving and sustainability in conservation areas and listed buildings in Brighton & Hove was published in accordance with the latest guidance Note 18 from Historic England.

Find more information about our conservation areas and listed buildings.

The Council declared a Climate and Biodiversity Emergency in December 2018 and has made a commitment as a city to become carbon neutral by 2030. The implementation of planning policies in the City Plan can help achieve this commitment.

Energy efficiency standards are sought through Policy CP8 of the City Plan Part One. In 2023/24, 63% of new build residential completions were completed with a requirement for the standard to achieve a reduction in carbon emissions of 19% (Table 1).

Table 1: Net New Build Housing Completions 2023/24: Proposed Sustainability Standards

	Completed new build dwellings	Percentage of completed dwellings
Reduction in carbon emissions of 19%	536	63%
No standard	318	37%
Total units	854	100%

Only developments applying for full planning are required to submit a Sustainability Checklist, consequently, the energy performance of other applications such as prior approvals are not recorded.

There were 804 new residential units permitted in 2023/24, of which 678 units were new build, with 98% indicating to achieve a reduction in carbon emissions of 19%.

Policy CP8 also requires that all development proposals will be expected to demonstrate how the development will facilitate on-site low or zero carbon (LZC) technologies. Applicants are asked to indicate via the Sustainability Checklist whether LZC technologies will be introduced into the development. Of the new build residential applications approved in 2023/24; 34% percent had indicated in their sustainability checklist that they would install LZC technologies.

The following indicators further demonstrate planning policy performance in terms of sustainability. These indicators are also reported in the Appendices, with reference to the relevant planning policy.

Sustainable Buildings

• 6% of new build residential applications approved with Sustainability checklist and completed in 2023/24 incorporated green walls and roofs.

Sustainable Transport

• 55% of new build residential and PDSA development, approved through a full planning application, and completed 2023/24 provided cycle parking creating 995 spaces.
• 12% of new build residential development, approved through a full planning application, and completed 2023/24 included car free units, totaling 60 car free units.
• An estimated 259.8 kilotonnes of transport-related greenhouse gases was emitted in 2022; a minor reduction on 259.6 kilo tonnes in 2021.

Open Space

• £895,662.00 was secured through developer contributions towards ‘recreation’ in 2023/24, which includes contributions towards open space and leisure. 

Flooding and Climate Change impacts

• 10% of new build residential development approved through a full planning application indicated that Sustainable Urban Drainage systems would be incorporated into the development 

The main types of waste are:

• Local Authority Collected Waste (LACW) – Household waste comprises approximately 95% of local authority collected waste, the remainder coming from sources such as street sweepings and public parks and gardens.
• Commercial and Industrial Waste (C&I) - This is produced from shops, food outlets, businesses, and manufacturing activities and comprises about 27% of waste in the Plan Area as a whole.
• Construction, Demolition and Excavation Waste (CDEW) -Produced from building activity, with a considerable proportion of it is inert. CDEW comprises an estimated 51% of all waste arisings.
• Other wastes - This includes hazardous waste, liquid waste (other than wastewater), and wastes arising from the agricultural sector.

The City Council monitors the quantity of local authority collected waste (LACW), but it does not directly monitor the quantity of commercial and industrial waste or construction, demolition, and excavation waste arisings. The best estimate for C&I waste arisings for East Sussex and Brighton & Hove in 2018 was 516,420 tonnes, the best estimate for annual arisings of CDEW remains 906,000 tonnes. Further detail can be found in the East Sussex Waste and Minerals Annual Monitoring Report4 2019/23.

An updated Monitoring Report from East Sussex is expected to be published in March/April 2025.

Table 2: Local Authority Collected Waste in Brighton and Hove by management type – (ESCC, 2023)

Waste	2016/17	2017/18	2018/19	2019/20	2020/21	2021/22	2022/23
Reuse	3,119	3,164	3,469	3,546	2,754	3,218	3,139
Composted	4,169	3,083	5,684	5,534	4,774	5,977	5,977
Recycled	22,869	24,219	21,555	21,359	22,710	21,452	21,452
Disposal to Land	5,234	5,824	4,273	2,688	1,707	571	921
Energy Recovery	74,749	75,130	76,198	75,767	78,080	78,279	79,392
Total	110,140	111,420	111,179	108,894	110,025	109,497	108,860

Key figures for Local Authority Collected Waste in Brighton and Hove are:

• 108,860 tonnes of household LACW were produced in Brighton & Hove in 2012/23, a reduction on the 109,479 tonnes in the previous monitoring year.
• Most of the waste (73%) in 2022/23 was sent for energy recovery, a slight increase on the previous three monitoring years.
• Only 0.85% of LACW was sent to landfill which contrasts with 59% sent to landfill in 2007/08.
• 28% was recycled, composted, or reused, a similar proportion to recent monitoring years

Minerals

Brighton & Hove does not have any active mineral extraction sites, however the minerals wharves at Shoreham Harbour are of strategic importance for the landing of marine-won sand and gravel for use in the construction industry in Brighton & Hove and elsewhere.

It is a requirement of the NPPF to produce an annual Local Aggregate Assessment (LAA) to assess the demand for and supply of aggregates in their area. The LAA is produced jointly with East Sussex County Council and the South Downs National Park Authority. The most recent assessment was published in May 2022. 

The following indicators are taken from Annex 1 Implementation & Monitoring of the Submission City Plan Part One (Proposed Modifications).

DA1 - Brighton Centre and Churchill Square  

Strategic Objectives: SO1, SO3, SO5, SO7, SO8, SO9, SO11, SO12, SO13, SO16, SO17, SO18, SO23

Take forward the development of replacement conference centre and a minimum of 20,000 sqm net comparison retail floorspace for Churchill Square

Target and Timescale

By 2018 development has commenced that will secure:

• a replacement conference centre
• extension to Churchill Square shopping centre (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Planning application not submitted by 2015
  • Action: Development Management Intervention

2023 to 2024 Data and update

No planning application submitted in 2023/24.

In November 2023, Ingka Centres, part of the Ingka Group, announced the freehold acquisition of Churchill Square with plans to open a new IKEA City store on the site of the former Debenhams.

DA2 - Brighton Marina, Gasworks & Black Rock Area

Strategic Objectives: SO1, SO2, SO3, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO13, SO17, SO18, SO19, SO21, SO22

Delivery of development for DA2

Target and Timescale

Development to include by 2030:

• Inner Harbour:
  • 1,000 residential units
  • 5,000 sqm retail (A1-A5)
  • 3,500 sqm leisure & recreation
  • Community centre
  • Health facility
• Gas Works site:
  • 2,000 sqm employment floorspace (B1a, B1c)
  • 85 residential units
  • To be provided during 11 – 16-year supply period.
• Outer Harbour:
  • 853 residential units
  • 400 units to be completed by 2019
• Black Rock
  • 7,000 sqm recreation and leisure floorspace

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

Inner Harbour

• Trigger: planning application for 500 residential units in Inner Harbour not submitted by end of 2018
  • Action: Development Management intervention

Gas Works site

• Trigger: planning application not submitted by end of 2023
  • Action: Development Management intervention

Outer Harbour

• Trigger: works not commenced by end of 2014
  • Action: Development Management intervention

Black Rock

• Trigger: planning application not submitted by 2020
  • Action: Development Management intervention

2023 to 2024 Data and update

Inner Harbour

• No planning application submitted in 2023/24.
  • Action: Ongoing discussions with landowners.

Gas Works site

• 22 May 2024 - application BH2021/04167 for mixed-use development including 533 residential units refused at Committee.
• 5 November 2024 - the Planning Inspectorate announced that an inspector has been appointed and the dates for the Inquiry set for 18 March 2025.

Outer Harbour

• Application BH2006/01124 approved for 853 units; Phase 1 Completed 2015/16 (195 units); Pre commencement conditions have been discharged and work on Phase 2 has therefore technically commenced. Development on the site stalled following completion of Phase 1, and the previous developer determined that the remaining phases of BH2006/01124 were not deliverable in the current market.
• 11 November 2021 -  Secretary of State dismissed appeal and upheld the council’s decision to refuse planning permission for planning application BH2019/00964.
  • Action: Funding being sought to deliver masterplan for City Plan Development Area DA2 including the Outer Harbour area. Work with Marina Company and developers to produce an acceptable development for the remaining phases.

Black Rock

• Phase 1 regeneration works (approved through application BH2020/00442) of the Black Rock Project to make the site development ready is near completion.
• Phase 2 of the Black Rock Project agreed at the 1 December 2022 Policy & Resources Committee is to use the site for meanwhile uses and entertainment space whilst preparation of a Development Brief to guide the future development at Black Rock is prepared. Anticipated appointment of development partner stage by summer 2025.

Produce and implement an ecological masterplan for the Brighton Marina and Black Rock areas

Target and Timescale

Masterplan to be produced by 2019. Implementation ongoing to 2030 (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: draft Ecological Masterplan not produced by mid-2019 (linked to Inner Harbour development)
  • Action: Work with developers and landowners to assist in masterplan implementation. Review funding sources for masterplan work

2023 to 2024 Data and update

No Masterplan prepared in 2023/24.

Action: Following unsuccessful council bid for government funding the council is in discussion with landowners regarding the potential for master planning/design codes.

The Eastern Seafront Masterplan SPD which includes Black Rock is under preparation and will provide landscaping/ public realm guidance to support and enhance ecology in the area. Early stakeholder consultation took place in late 2021/early 2022.

DA3 - Lewes Road Area

Strategic Objectives: SO1, SO2, SO3, SO4, SO7. SO8, SO9, SO10, SO11, SO12, SO15, SO18, SO19, SO20, SO21, SO22, SO23

Delivery of development for DA3

Target and Timescale

• Preston Barracks site:
  • New Business School
  • 10,600 sqm B1 employment floorspace
  • 750 student rooms
  • 300 residential units
  • 150 residential units completed by 2019  
• Woollards Field South:
  • 5,000 sqm B1 business space or alternative employment generating development for city’s infrastructure needs
  • Completion by 2020

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

Preston Barracks

• Trigger: Planning application not submitted for 150 residential units by early 2017
  • Action: Development Management intervention

Woollards Field South

• Trigger: Planning application not submitted by 2017
  • Action: Development Management intervention

2023 to 2024 Data and update

Preston Barracks

Application BH2017/00492 approved 2018; Commenced 2017/18; 207 residential units completed 2021/22 (Blocks B-F), with remaining 162 residential units near completion (Blocks A and J).

Proposals include:

• New Business School (6,400 sqm)
• 4,902 sqm B1 employment floorspace
• 1,338 student rooms
• 369 residential Units

Woollards Field South

Application BH2014/00310 for an Ambulance Make Ready Centre (MRC) completed in 2019/20.

Improve levels of air quality in the Lewes Road area

Target and Timescale

Ensure that the annual mean concentrations (µg/m³) of NO2 decrease towards target of 36µg/m³ at Lewes Road continuous analyser.

Required to meet the 40 µg/m3 level annual legal limit under the English Air Quality Strategy and EU directive. Aiming for 90% of the legal limit to be beyond all reasonable doubt

(Source: Interplan)

Trigger and Actions to be taken if target not being achieved

• Trigger: No annual mean decrease in NO2 concentrations
  • Action: Review Air Quality Action Plan and Transport Strategy for improving air quality

2023 to 2024 Data and update

The Lewes Road continuous analyser was removed and ceased to collect data in 2022. Information on air quality in the city is available on our website.

DA4 - New England Quarter and London Road Area

Strategic Objectives: SO1, SO2, SO3, SO4, SO7. SO8, SO9, SO10, SO11, SO12, SO13, SO16, SO18, SO19, SO20, SO21, SO22, SO23

Delivery of development for DA4

Target and Timescale

• 1128 net additional dwellings:
  • 161 (2010 to 2014)
  • 453 (2014 to 2019)
  • 391 (2019 to 2024)
  • 123 (2024 to 2030)
• Net gain 20,000 sqm B1 floorspace:
  • By 2014 to 2019:
    • Block J Brighton Station Site 2,973 sqm Block K Brighton Station Site 3,428 sqm
    • GB Liners site, Blackman Street 3,327 sqm
  • By 2019 to 2024:
    • 3,000 sqm - Trade Warehousing (Longley Industrial Estate) 4-6 New England Street 
    • 3,000 sqm - Richardson's Scrapyard and Brewers Paint Merchant Site,
• New England Street
  • 2,000 sqm Blackman Street Site (land adjacent to Britannia House)

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Current office schemes with unimplemented planning permission not started by 2016
  • Actions:
    • Negotiation on particular sites to overcome specific economic viability issues.
    • Explore alternative funding mechanisms and/or the potential for enabling development.
    • Consider scope to help accelerate the phasing of later schemes if 2014-2019 sites do not come forward as anticipated.

Refer to CP1

2023 to 2024 Data and update

• Application BH2010/03999 for 147 residential units (Block J) completed in 2014/15; 2,460sqm B1a office space and hotel completed in 2017/18.
• Application BH2008/01148 for 3,554sqm B1a office space (Block K) completed in 2015/16.
• Longley Industrial Estate; application BH2018/02598 for 3,270sqm of office/research/development floorspace, 308sqm of flexible commercial/retail floorspace completed in 2022/23.
• Since relocation of removal operations to Woodingdean Business Park, GB Liners currently operating domestic storage operation at Blackman Street site.
• Additional residential units in DA4:
  • 135 (2023/24)
  • 201 (2022/23)
  • 13 (2021/22)
  • 31 (2020/21)
  • 8 (2019/20)
  • 67 (2018/19)
  • 5 (2017/18)
  • 45 (2016/17)
  • 4 (2015/16)

Maintain and enhance the healthiness of the London Road Town Centre  

Target and Timescale

Annual retail health checks to show an improvement from the 2011 baseline, across the Plan period.

Net additional retail floorspace provided city-wide and in designated centres. (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Annual retail check shows decline from 2011 baseline over 3 consecutive years
  • Action: undertake health check assessment

2023 to 2024 Data and update

Health Check carried out in 2021/22, only within Primary Frontage through revised Article 4 Direction work.

• Action: In 2025, it is anticipated that a Retail Capacity Study will be commissioned as a background study for the City Plan 2041. This will involve an update to Retail Health Checks for the centres in the Retail Hierarchy.

Adoption and implementation of the London Road Central Masterplan SPD

Target and Timescale

Implementation of public realm improvements throughout the Plan period in accordance with the SPD Implementation Plan:

• By 2016/17:
  • Providence Place - Ann Street
  • London Road
• By 2018/19
  • Oxford St and Baker St

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Public Realm improvements work not commenced by 2016 (Providence Place - Ann Street, London Road) and 2018 (Oxford Street and Baker Street)
  • Action: Review London Road SPD Implementation Plan

2023 to 2024 Data and update

Providence Place-Ann Street – Commenced; completed except for part of Ann Street which is awaiting funding to enable implementation.

Public realm improvements have been undertaken in London Road. De-cluttering and improvements to Ann Street-London Road crossing implemented.

Improvement levels of air quality in the London Road area (This indicator to be reviewed following adoption of revised Air Quality Action Plan in 2014)

Target and Timescale

Ensure that the annual mean concentrations (µg/m³) of NO2 decrease at London Road monitoring sites.

(Currently using C18 and C19, C20 and C23 Diffusion Tube Results)

Trigger and Actions to be taken if target not being achieved

• Trigger: Annual mean increases in NO2 concentrations
  • Action: Review Air Quality Action Plan and Transport Strategy for improving air quality

2023 to 2024 Data and update

Information on air quality in the city is available on our website.

DA5 - Eastern Road and Edward Street Area

Strategic Objectives: SO1,SO2, SO3, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO19, SO20, SO21, SO22, SO23

Delivery of development for DA5

Target and Timescale

• Royal Sussex County Hospital
  • 74,000 sqm hospital floorspace
  • to be completed by 2019
• Edward Street Quarter
  • 15,000 to 20,000 sqm employment floorspace
  • 65 residential units
  • to be completed by 2024
• Circus Street
  • 400 student bedspaces
  • 160 residential units
  • 3,200 sqm office space
  • Dance studio
  • 3,800 sqm education
  • to be completed by 2019   
• Freshfield Road Business Park and Gala Bingo Hall:
  • comprehensive site redevelopment, to include minimum 110 residential units, B1 office/light industrial floorspace and B8 warehousing.
  • to be completed by 2024

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

Royal Sussex County Hospital

Planning permission granted in January 2012 (see app BH2011/02886) with 5 years to implement.

• Trigger: Work not commenced by 2017
  • Action: Work with developers and partners to review barriers to development

Edward Street Quarter

• Trigger: Planning application not submitted by mid-2018
  • Action: Development Management intervention

Circus Street

• Trigger: Work not commenced by 2016
  • Action: Development Management intervention

Freshfield Road Business Park and Gala Bingo Hall

• Trigger: Planning application for Gala Bingo Hall site not submitted by 2018
• Trigger: Planning application for rest of site not submitted by 2020
  • Action: Development Management intervention

2023 to 2024 Data and update

Royal Sussex County Hospital

• Application BH2011/02886 completed in 2019/20.
• Application BH2021/03056 (part retrospective) approved October 2022 proposed some design amendments to the approved redevelopment plans.

Edward Street Quarter

• Application BH2012/04086 for new part five and part four-storey building comprising 450 sqm of office space and 9 residential flats completed in 2017/18.
• Application BH2018/00340 for 168 dwellings (C3), 16,684sqm commercial floorspace (B1), and 1,080 sqm flexible floorspace completed in 2021/22.

Circus Street

• Application BH2012/04086 for new part five and part four-storey building comprising 450 sqm of office space and 9 residential flats completed in 2017/18
• Application BH2018/00340 for 168 dwellings (C3), 16,684sqm commercial floorspace (B1), and 1,080 sqm flexible floorspace completed in 2021/22

Freshfield Road Business Park and Gala Bingo Hall

• No planning application submitted in 2023/24.

Preparation of design guidance for the DA5 area and involvement of local communities in preparing guidance  

Target and Timescale

Preparation of guidance by 2016

Implementation of targets in guidance by 2030

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Work not commenced by beginning 2015
  • Action: Review of resources and Planning Policy and Major Projects Teams

2023 to 2024 Data and update

A final planning brief was approved in September 2013.

DA6 - Hove Station Area

Strategic Objectives: SO1, SO2, SO3, SO4, SO6, SO7, SO8, SO9, SO10, SO11, SO12, SO13, SO16, SO19, SO20. SO22, SO23

Delivery of development for DA6

Target and Timescale

Development to include by 2030:

• Outside Conway Street Industrial Area
  • 325 residential units
  • 1,000 sqm additional employment floorspace
• Conway Street Industrial Area
  • 200 residential units
  • retention/replacement of 12,000 sqm employment floorspace with a shift into high quality flexible office/business (B1) floorspace
  • 525 net additional dwellings:
    • 0 (2010 to 2014)
    • 117 (2014 to 2019)
    • 228 (2019 to 2024)
    • 179 (2024 to 2030)

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

Triggers:

• Redevelopment of Sackville Trading Estate (to deliver minimum of 92 res units and 5,080 sqm B uses) not commenced by 2017
• Redevelopment of Conway Street Industrial area (to deliver a minimum of 200 res units and retain a minimum of 12,00 sqm B uses) not commenced by 2022
• Delivery of 50 residential units outside the above areas not commenced by 2022
• Delivery of 150 res units (in addition to the 50 by 2022) outside the above areas not commenced by 2026

Action: Development Management intervention

2023 to 2024 Data and update

• 216 residential units completed 2023/24.
• Application BH2020/00917, known as the ‘Hove Gardens’ development at Unit 1-3 Ellen Street for 216 units completed in 2023/24.
• 2 residential units permitted 2023/24.

Preparation of design guidance for the DA6 area and involvement of local community in preparing guidance

Target and Timescale

Produce guidance by 2016. Ongoing implementation to 2030 (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Draft guidance not produced by end of 2015 (in consultation with landowners and Hove Station Area Neighbourhood Forum/community)
  • Action: Review the approach to the preparation and delivery of guidance in view the neighbourhood area and forum are formally designated and a neighbourhood plan is in preparation which could now be the appropriate method.

2023 to 2024 Data and update

• Hove Station Area Masterplan SPD adopted in September 2021.
• Hove Station Neighbourhood Plan formally ‘made’ on 28 March 2024

DA7 - Toads Hole Valley

Strategic Objectives: SO1, SO2, SO3, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO13, SO14, SO15, SO19, SO20. SO22, SO23

Adoption of Masterplan

Target and Timescale

By end of 2014 (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Work not commenced by December 2013
  • Action: Review resources and priorities in Planning Strategy and Projects Team

2023 to 2024 Data and update

Toads Hole Valley SPD adopted September 2017.

Delivery of development for DA7

Target and Timescale

Development to include by 2020:

• 700 residential units
• 25,000 sqm employment
• Secondary school
• Public open space (2ha)
• Community facility

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Planning permission submitted no later than end of 2015
  • Action: Development Management intervention; work closely with developer to overcome problems

2023 to 2024 Data and update

• Outline application BH2022/00203 approved June 2022 for:
  • Up to 880 residential units
  • 3.5 ha land for provision of 25,000 sqm employment space
  • 5ha Land for a Secondary school
  • Public open space (5.8ha)
  • Neighbourhood centre inc 790sqm retail space, 750sqm doctor’s surgery & 555sqm community building
• Outline application BH2022/02534 approved 26 April 2023 for up to 182 residential dwellings, replacing the approved 5ha land for a Secondary School (BH2022/00203) as it has been deemed no future requirement for a new school.
• Application BH2022/03483 approved September 2024 for an Aldi with 1,315sqm of retail supermarket floorspace.

Percentage of development meeting BREEAM “Outstanding” Rating or Code for Sustainable Homes Level 5 or with mitigation measures and/or achieving a One Planet Approach.

Target and Timescale

100% of new development on site (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Planning permission – with requirement to meet code level 5 for sustainable homes or mitigation measures and with an action plan on achieving One Planet Principles (subject to recession measures) – granted no later than mid 2015
  • Action: Development Management intervention; advice and support given to Development Management team.

2023 to 2024 Data and update

• BH2022/00203 and BH2022/02534 approved with condition that the masterplan scheme must meet a BREEAM Communities Assessment standard of ‘Excellent’, and subsequent phases.
• BH2022/03483 officer report recommends a condition that the development should achieve the BREEAM ‘Excellent’ score. 

DA8 - Shoreham Harbour Area

Spatial Objectives: SO1, SO2, SO3, SO4, SO6, SO7, SO8, SO9, SO10, SO11, SO12, SO13, SO16, SO17, SO18, SO19, SO20, SO21, SO22, SO23

Adoption of Joint Area Action Plan

Target and Timescale

By 2016 (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Pre-submission consultation not started by February 2015
  • Action: Review of resources and priorities in Planning Strategy and Projects Team.

2023 to 2024 Data and update  

Shoreham Harbour JAAP adopted 2019.

Delivery of development for DA8

Target and Timescale

Development to include by 2030 and after approximately:

• 300 residential units
• 7,500 sqm employment floorspace

Detail to be included within Joint Area Action Plan

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: sufficient applications for planning permission have not been submitted by mid-2019 to allow for completion of 150 residential units by 2024
  • Action: Development Management Intervention; Review JAAP

2023 to 2024 Data and update

• Residential units completed:
  • 1 (2023/24)
  • 104 (2022/23)
  • 0 (2021/22)
  • 6 (2020/21)
  • 8 (2019/20)
  • 20 (2018/19)
  • 4 (2017/18)
  • 5 (2016/17)
• Residential units permitted:
  • 0 (2023/24)
  • 0 (2022/23)
  • 0 (2021/22)
  • 106 (2020/21)
  • 2 (2019/20)
  • 6 (2018/19)
  • 2 (2017/18)
  • 18 (2016/17)

SA1 - The Seafront

Secure the redevelopment of the King Alfred/ RNR site to deliver sports facilities for local community and the city.

Target and Timescale

By 2018 development has commenced that will secure:

• new indoor wet/dry sports facilities delivered
• minimum 400 residential units

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Application not submitted by 2016.
  • Action: Regular reviews and risk management will be undertaken by King Alfred Project Board and preferred developer.

Development Management intervention

2023 to 2024 Data and update

The Council consulted residents on two potential sites for a replacement facility during January – February 2024; the existing King Alfred site and the council-owned land south of Sainsbury’s fronting Old Shoreham Road site. In July 2024, Cabinet decided to develop the new facility on part if the existing King Alfred site. A full planning application is expected to be submitted in the summer of 2025.

Net change in the area of natural habitat and Brighton & Hove Local Biodiversity Action Plan (Local BAP) habitats and species located on the seafront.

Target and Timescale

To see a net increase in the area of natural habitat and Local BAP habitats and species located on the seafront over the plan period

(Source: Planning & Parks & Green Spaces)

Trigger and Actions to be taken if target not being achieved

• Trigger: Failure to see a net increase over first 5 years of plan period
  • Action: Work with relevant stakeholder e.g. Natural England, landowners, wildlife and conservation groups to further promote and implement Local BAPs.

2023 to 2024 Data and update

No data available.

Coastal erosion and risk management  

Target and Timescale

• Revision of Brighton Marina to River Adur Defence Strategy to be completed by 2014.
• Brighton Marina to Saltdean strategy to be revised and updated by 2015
• Ongoing Coastal Defence Maintenance

(Source: Coastal Defence team)

Trigger and Actions to be taken if target not being achieved

Updated Target and Trigger 2014/15;

• Trigger: Implementation of identified 10 year programme of works (Brighton Marina to River Adur Strategy 2014) not commenced at start of 2016.
• Target: Brighton Marina to River Adur Defence Strategy - implementation of identified 10 year programme of works

2023 to 2024 Data and update

• Revised Brighton Marina to River Adur Defence Strategy adopted 2014.
• Outline Business Case (OBC) submitted to the Environment Agency (EA). Environment Transport & Sustainability Committee Agreement delegated authority to the Executive Director for Economy, Environment & Culture to procure and award a contract for the detailed design contracts June 2020.
• Brighton Marina to Newhaven Coastal Management Implementation Plan Published 2016.

SA2 - Central Brighton

Strategic Objectives: SO2, SO3, SO5, SO9, SO12, SO13, SO16, SO18, SO22, SO23

Reduction in anti-social behaviour and violent crime

Total crime in Regency Ward is used to monitor the impact of this policy, with further breakdowns into types of crime, where possible

Target and Timescale

Annual reduction in anti-social behaviour and violent crime

Baseline:

• Total crime in Regency Ward: 5,235 (2011/12)
• Violence against the Person in Regency Ward: 930 (2011/12)

(Source: Community Safety Partnership Team)

Trigger and Actions to be taken if target not being achieved

Triggers and actions are set out in the Community safety and crime reduction strategy 2023 to 2026.

2023 to 2024 Data and update

Crime data is available to view at www.police.uk/pu/your-area/sussex-police/

Improvements to urban realm

Target and Timescale

Completion of identified programme of urban realm improvement -  Station Gateway Project - by 2016 and ongoing:

(Source: Local Transport Plan 3)

Trigger and Actions to be taken if target not being achieved

Public Realm improvements priorities and phasing and progress reviewed through LTP reviews.

2023 to 2024 Data and update

The Station Gateway Project was completed in July 2015.  

Retain a healthy, viable Regional Shopping Centre

Target and Timescale

Annual health checks to show no net increase in vacancies. 

Annual completions of new retail floorspace in the Regional Centre (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Annual retail health check shows decline from 2011 baseline over 3 consecutive years
  • Action: Undertake health check assessment.

2023 to 2024 Data and update

• 2021/22 – 59 Vacancies (only recorded within Primary Frontage)
• 2018/19 – 98 Vacancies
• 2017 – 69 Vacancies
• 2015/16 – 59 Vacancies
• 2014- 71 Vacancies

Action: Health Check scheduled for 2024/25 as part of background study for City Plan 2041.

SA3- Valley Gardens

Strategic Objectives: SO10, SO11, SO12, SO13, SO15, SO16, SO17, SO20, SO22, SO23

Implementation of comprehensive landscape/townscape scheme

Target and Timescale

Approval of scheme by 2015; funding identified and in place by 2020. Completion of scheme by 2030 (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Review of scheme at end of 2014 finds approval not on track.
• Trigger: Review of scheme mid 2019 finds projected funding shortfall.
  • Action: Review priorities and resources in Planning Strategy & Projects Team and Sustainable Transport department.

Review scope and aims of scheme, consider consulting on alternative approach.

2023 to 2024 Data and update

• Phases 1 and 2 completed in September 2020
• Detailed Valley Gardens Phase 3 Design Scheme presented at Environment, Transport and Sustainability Committee 18 January 2022
• Phase 3 commenced in November 2024, and anticipated completion by summer 2026

Implementation of a landscaping scheme for The Level

Target and Timescale

Completion by 2013

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

Landscaping scheme is underway, on schedule for completion by end of 2013. No trigger or action necessary.  

2023 to 2024 Data and update   

Landscaping scheme has been completed.

Decrease in the number of Buildings at Risk over five year period.

Target and Timescale

Monitor across the Plan period. Baseline at 2009/2010: 6 buildings (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Number of Buildings at Risk has not decreased by 2015.
  • Action: Resource priorities in the Heritage team to be reviewed.

2023 to 2024 Data and update

Two Buildings at Risk in Valley Gardens area 2023/24.

(Historic England – Heritage at Risk Register 2024)

SA4- Urban Fringe

Strategic Objectives: SO9, SO10, SO13, SO14, SO15, SO17, SO23

Single Data List - Monitor number of planning permissions granted contrary to Environment Agency advice

Target and Timescale

Zero planning consents unless appropriate mitigation secured. Monitor annually across the Plan period  

(Source: Planning and the Environment Agency)

Trigger and Actions to be taken if target not being achieved

• Trigger: Any consent without appropriate mitigation
  • Action: review Development Management processes

2023 to 2024 Data and update

0 planning applications granted contrary to Environment Agency advice in 2023/24.  

Monitor the number of planning permissions granted contrary to an objection from the South Downs National Park Authority for development affecting the setting of the South Downs National Park

Target and Timescale

Monitor annually. Zero planning consents unless appropriate mitigation secured. (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Any consent without appropriate mitigation.  
  • Action: Review Development Management processes.

2023 to 2024 Data and update

No data available.

Net change in Local BAP habitats and number of Local BAP species

Target and Timescale

To see a net increase in Local BAP habitats and species located within the urban fringe over the plan period.

(Source: Planning & Parks & Green Spaces)

Trigger and Actions to be taken if target not being achieved

• Trigger: Failure to see a net increase over first 5 years of plan period
  • Action: Work with relevant stakeholder e.g. Natural England, landowners, wildlife and conservation groups, to further promote and implement Local BAPs.  

2023 to 2024 Data and update

Percentage of planning applications with species records within 200m buffer 2023/24:

• European Protected species: 68 %  
• Wildlife & Countryside Act species: 98%  
• Section 41 species: 100%  
• Bats: 60%  
• Notable birds: 100%
• Rare species: 94%  
• Invasive non‐native species: 79%
• Ancient tree: 6%

(Brighton & Hove Biodiversity Annual monitoring report 2023/24- Sussex Biodiversity Record Centre)  

SA5 - The Setting of the South Downs National Park

Strategic Objectives: SO10, SO14, SO15, SO17, SO22, SO23

Number of planning permissions granted contrary to an objection from the South Downs National Park Authority for development affecting the setting of the South Downs National Park  

Target and Timescale

No applications granted contrary to an objection from SDNPA during the plan period - Monitored annually.

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Application granted contrary to an objection from SDNPA
  • Action: Review development management procedure and practice. Work in Partnership with SDNPA to agree appropriate approach to development/land uses within the setting to minimise harmful impact upon the National Park.

Review requirement for SPD on development affecting South Downs National Park

2023 to 2024 Data and update

No data available.

SA6- Sustainable Neighbourhoods

Strategic Objectives: SO2, SO3, SO4, SO7, SO8, SO9, SO10. SO11,  SO12, SO13, SO15, SO16, SO17, SO18, SO19, SO20, SO21, SO22, SO23

Proportion of children in poverty

Target and Timescale

Baseline in 2007/08 - 20% (data from child poverty)

Yearly decrease targets:

• 2008/09 - 19%
• 2009/10 - 18%
• 2010/11 - 17%

(Source: Department for Work and Pensions – Children in low income families: local area statistics: 2014 to 2023).  

Trigger and Actions to be taken if target not being achieved

• Trigger: No decline by 2017
  • Action: review sustainable community strategy; review employment skills plan.

2023 to 2024 Data and update

Number and Percentage of Children living in Relative low-income families:

• 2023/24: 13%
• 2022/23: 15%
• 2021/22: 14%
• 2020/21: 14%
• 2019/20: 14%
• 2018/19: 14%
• 2017/18: 13%
• 2016/17: 12%  

Single Data List - Percentage of Local Authority Collected Waste sent for reuse, recycling and composting

Target and Timescale

Targets to be:

• 45% by 2015/16
• 50% by 2020/21
• 55% by 2025/26

(Source: Single Data List)

Trigger and Actions to be taken if target not being achieved

Targets for waste recycling and recovery are transposed from the adopted East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan (WMP). Should they not be met, actions will be taken through the monitoring and implementation framework of the WMP.

2023 to 2024 Data and update

• 2022/23: 26%
• 2021/22: 28%
• 2020/21: 27%
• 2019/20: 28%
• 2018/19: 28%
• 2017/18: 27%
• 2016/17: 27%  
• 2015/16: 26%
• 2014/15: 27%  
• 2013/14: 25%

2020/21: Rest - Energy Recovery 71% Landfill 1% (ESCC)

Action: The targets in the WMP relate to the Plan Area of East Sussex and Brighton & Hove. No specific trigger and actions are identified in the WMP.

CP1 – Housing Delivery

Single Data List -Monitor net additional homes provided per annum

Target and Timescale

Average annual housing completions over a 3 year period to comply with the delivery rates outlined in HIS delivery framework  

(Source: Single Data List)

Trigger and Actions to be taken if target not being achieved

• Trigger: Annual completions over a 3 year period fall below anticipated delivery rates outlined in HIS by more than 15%
  • Action: Review housing trajectory and review HIS delivery rates in HS delivery framework.  
  • Action: Promote sites and residential development through working with delivery partners.

2023 to 2024 Data and update

2021 to 2024 – 3,008 net dwellings completed (average 1,003 net dwellings per year) compared to HIS trajectory target of 2,568 (856 dwellings per year). This is 17% above anticipated delivery rates.

Action: Housing trajectory reviewed annually through SHLAA.

Supply of ready to develop housing sites

Target and Timescale

To have a rolling 5 year supply of deliverable housing plus NPPF buffer of 5%.

To be reported annually in SHLAA Update and the Authority Monitoring Report (Source: Single Data List)

Trigger and Actions to be taken if target not being achieved

• Trigger: Lack of a 5 Year Supply for 2 consecutive years.
  • Action: Review actions listed in HIS to promote sites and residential development through working with delivery partners. Undertake new SHLAA with call for sites.

2023 to 2024 Data and update

3.9 Years Supply measured against CPP1 Policy CP1 target (including 5% buffer) (BHCC SHLAA Update 2023)

1.7 Years Supply measured against local housing need calculated using the Government standard method (including 5% buffer).

Note: CPP1 reached 5 years since adoption on 24 March 2021. National planning policy requires that local housing need is now calculated using the Government’s standard method in place of the CPP1 housing requirement. The local housing need using the standard method is 2,333 homes per year (which includes the 35% uplift applied as one of the top 20 cities in the urban centres list).

Action: Housing trajectory reviewed annually through SHLAA. Shortfall against identified local housing need will need to be addressed through City Plan 2041.  

CP2 - Sustainable Economic Development

Strategic Objectives: SO1, SO2, SO3, SO6, SO7,  SO9, SO13, SO20, SO21

Growth in number of digital media businesses

Target and Timescale

Review annually

(Source: Corporate Plan)

Trigger and Actions to be taken if target not being achieved

For monitoring only (no trigger or action necessary)

2023 to 2024 Data and update

Sectors which have experienced the largest proportional increases in jobs are digital (+40%), creative (+38%) and professional (+33%)  

(Source: Brighton & Hove Economic Evidence Report (January 2024); Business & job count change, 2015 to 2022/23)

Growth of the environmental industries sector  

Target and Timescale

Review annually

(Source: Corporate Plan)

Trigger and Actions to be taken if target not being achieved

For monitoring only (no trigger or action necessary)

2023 to 2024 Data and update

No data available.

SME take-up of high-speed broadband connection voucher scheme

Target and Timescale

Uptake of voucher scheme by 1,000 SME by 2015

(Source: City Regeneration)

Trigger and Actions to be taken if target not being achieved

• Trigger: Voucher scheme not taken up by at least 500 SME by end of 2014
  • Action: Prioritise Promotion of voucher scheme to SME in Central Brighton area; review resources for voucher scheme project

2023 to 2024 Data and update

Extended Voucher Connection Scheme opened April 2015.

Extended voucher scheme - 601 vouchers (against a total target of 300) and 482 connections made (Oct 2015)

Providing local employment and apprenticeships on development sites.

Target and Timescale

Achieve minimum 20% target for local employment and apprenticeship training on development sites across the plan period.

(Source: BHCC Annual Infrastructure Funding Statement 2023/24)

Trigger and Actions to be taken if target not being achieved

• Trigger: Target not achieved for two consecutive years.
  • Action: Review Brighton & Hove Local Employment Scheme

2023 to 2024 Data and update

5 S106 Agreements secured requiring minimum 20% local labour on development sites (2023/24)

CP3 - Employment Land

Strategic Objectives: SO1, SO2, SO3, SO9, SO13, SO20, SO21

Total amount of office floorspace within central Brighton

Target and Timescale

No net loss of existing office floorspace in central Brighton over plan period unless the tests in policy SA2 are met.  To be monitored annually (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Target not met for two consecutive years
  • Action: Review Development Management processes.

2023 to 2024 Data and update

4,098 sqm net gain of office floorspace (SA2 area) 2023/24.

Total amount of employment floorspace by type (gross and net) within the eleven industrial estates and business parks

Target and Timescale

No net loss of employment (B1, B2 and B8) floorspace within any area listed in part 3 of the policy to be monitored annually  

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Target not met for two consecutive years
  • Action: Review Development Management processes.

2023 to 2024 Data and update

207 sqm net loss of employment floorspace 2023/24.

Total amount of additional employment floorspace - by type (gross and net).

Target and Timescale

Average annual  employment floorspace completions over a 3 year period to comply with the average annual delivery rates outlined in the Employment Land Supply Trajectory (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Average annual completions over a 3 year period falls below anticipated delivery rates outlined in Employment Land Supply Trajectory by more than 15%
  • Action:
    • Negotiation on particular sites to overcome specific economic viability issues;
    • Exploring alternative funding mechanisms and/or the potential for enabling development.  
    • Consider scope to help accelerate the phasing of later schemes if 2014-2019 sites do not come forward as
    • Review Employment Land Supply Trajectory.  
    • Seek further employment sites to allocate through Part 2 of City Plan.

2023 to 2024 Data and update

Net

• Offices: B1a/b or Egi/ii: 1,770sqm
• Industrial: B1c or Egiii/B2/B8 or: -1,977 sqm
• Mixed B: 0 sqm

Gross

• Offices: 7763 sqm
• Industrial: 288 sqm
• Mixed B: 0 sqm

CP4 - Retail Provision

Strategic Objectives: SO3, SO5, SO18

Review/update of Retail Study (2011) for Brighton and Hove.  

Target and Timescale

Review at least every 5 years across the Plan period (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Council’s annual retail health checks show decline from 2011 baseline over 3 consecutive years in Regional Centre.
  • Action: undertake review of study earlier.

2023 to 2024 Data and update

Regional Centre Health Check  

• 2021/22 – 59 Vacancies (only recorded within Primary Frontage)
• 2018/19: 98 Vacancies  
• 2017: 69 Vacancies  
• 2015/16: 59 Vacancies
• 2014: 71 Vacancies

Action: Health Check scheduled for 2024/25 as part of background study for City Plan 2041

CP5 - Culture and Tourism

Strategic Objectives: SO6, SO9, SO10, SO11, SO12, SO15

Improving the visitor economy

Target and Timescale

Annual Improvement

Target:

• 2011/12 - £732m; and
• 2012/13 - £746m  

Baseline 2009 - £732 million

(Source: City Performance Plan)

Trigger and Actions to be taken if target not being achieved

The City Performance Plan is regularly reviewed with strategic partners. No further triggers and actions necessary.

2023 to 2024 Data and update

Total (Direct) Value of Tourism 2023 in Brighton & Hove; £876 million (slight decrease of 0.5% on 2022).

• 2022: £880  
• 2021: £612
• 2020: £370  
• 2019: £976

(Source: Economic Impact of Tourism, Brighton & Hove 2023: direct turnover derived from trip expenditure)

CP6 - Hotel and Guest House Accommodation

Strategic Objectives: SO3, SO5, SO13

Creation of apprenticeship scheme between BHCC and hoteliers

Target and Timescale

Commence operation of scheme by 2016  

(Source: Visit Brighton)

Trigger and Actions to be taken if target not being achieved

• Trigger: No significant interest from city hoteliers in joining apprenticeship scheme by 2015
  • Action: Liaise with Visit Brighton to review priorities and resources; work proactively with city hoteliers to publicise and scheme and review reasons for lack of uptake.

2023 to 2024 Data and update

Two hotels pledged apprenticeships under Greater Brighton Employer Skills Task Force 1,000 apprenticeships challenge.

Gains/ losses in  hotel bedrooms (linked to demand forecasts set out in the Hotel Futures study)

Losses of hotel bedrooms outside Hotel Core Zone

Target and Timescale

15% net increase by 2016  

(Source: Planning and Visit Brighton)

Baseline: 2006 160 hotels and guest accommodation establishments with 4,293 letting bedrooms (Source Hotel Futures Study 2006)

Trigger and Actions to be taken if target not being achieved

• Trigger: Indicative target for net additional serviced rooms in 2016 is significantly exceeded.
  • Action: Undertake review of Hotel Future Study to update assessment of future demand and inform application of CP5 Visitor Accommodation.

2023 to 2024 Data and update

Net increase of 199 hotel bedrooms in 2023/24, primarily through the completion of the new Maldron Hotel, to the rear of the Hilton Brighton Metropole.

Loss of 22 hotel bedrooms in 2023/24.  

CP7 - Infrastructure and Developer contributions

Strategic Objectives: SO1, SO4, SO11, SO13, SO20, SO21

Preparation and adoption of CIL

Target and Timescale

Progress and determine adoption of CIL post 2014  

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: No decision made regarding adopting CIL prior to draft City Plan Part 2
  • Actions:
    • Review priorities and resources in Planning Strategy & Projects Team.  
    • Developer contributions to be provided through necessary s106 obligations only subject to meeting statutory tests if CIL not progressed

2023 to 2024 Data and update

Charging schedule adopted and implementation of CIL commenced September 2020.

Provision of appropriate social, environmental and physical infrastructure to support new development

Target and Timescale

100% compliance on all annual implemented development  - Ongoing monitoring throughout the Plan period  

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Developer contributions not forthcoming following implementation of development
  • Actions:
    • Review developer contributions/s106 monitoring and project management processes
    • Annual review of Developer Contributions temporary recession ‘relief’ measures
    • Review development management processes

2023 to 2024 Data and update

100% compliance is being achieved where appropriate contributions are secured.

Review and update Infrastructure Delivery Plan Annex 1

Target and Timescale

Ongoing monitoring and annual review, and update -throughout the Plan Period

Trigger and Actions to be taken if target not being achieved

• Trigger: Annual review 3 months overdue.
  • Action: Review developer contributions/s106 monitoring and project management processes

2023 to 2024 Data and update

Infrastructure Delivery Plan update published June 2017.  

Annual Infrastructure Funding Statement Published 2023/24

CP8- Sustainable Buildings

Strategic Objectives: SO4, SO7, SO10, SO22

% of new developments that meet minimum building standard requirements for B&H - Residential new build

Target and Timescale

To be monitored annually throughout plan period;

Targets as set out in policy CP8.

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Annual % of developments that meet targets fall below 70%
  • Action: Review Development Management procedures; review Sustainable Buildings SPD

2023 to 2024 Data and update

63% new build units, completed to achieve a reduction in carbon emissions of 19% against 2013 Part L Building Regulations requirements (2023/24).

Percentage of applications approved for new dwellings that meet minimum standards for energy and water

Target and Timescale

To be monitored annually throughout the plan period  

Targets for new dwellings (to be met by 2017):

• energy standards (19% improvement on Part L2013): 75% of new dwellings
• water standards 110 litres/person/day: 75% of new dwellings  

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Target is not met by 2015
  • Action: Review Development Management procedures; review Sustainable Buildings SPD

2023 to 2024 Data and update  

63% new build units, completed to achieve a reduction in carbon emissions of 19% against 2013 Part L Building Regulations requirements (2023/24).

No data update on water standards for 2023/24.

CP9 - Sustainable Transport

Strategic Objectives: SO1, SO3, SO11, SO14

Delivery of bus priority infrastructure improvements on the A259 Seafront and London Road

Target and Timescale

Delivery of improvements by:  

2024, dependent on funding and democratic approval (A259 Seafront and London Road schemes)

(Source: Planning and Local Highway Authority)

Trigger and Actions to be taken if target not being achieved

Lewes Road:

• Works already commenced and due for completion in 2013. No trigger/action necessary.

Edward Street: 

• Trigger: Traffic orders not started by end of July 2014 (due to go to Committee mid Oct 2013).
  • Action: review work programme and funding sources (LTP3; regional and national sources)

Seafront, London Road:

• Long-term targets. Progress to be reviewed in 2020 AMR; appropriate trigger/action to be added.

2023 to 2024 Data and update

• Lewes Road Scheme completed in September 2013. Vogue Gyratory Complete December 2014.
• Edward Street completed 2015.
• Arches under A259 Regency Square subway to the Metropole Hotel completed 2017.
• Work to reconstruct the former West Street Shelter Hall completed in 2020.

Local bus journeys originating in the Local Authority Area

Target and Timescale

Average increase of 800,000 passenger journeys per year (annual check based on 5-year average) (Source: BHCC)

Trigger and Actions to be taken if target not being achieved

• Trigger: Average annual increase in journeys is below 500,000
  • Action: review transport strategy; review targets in LTP4

2023 to 2024 Data and update

• 2023/24: 41.1 million
• 2022/23: 38.8 million
• 2021/22: 30.5 million
• 2020/21: 15.3 million*
• 2019/20: 45.9 million
• 2018/19: 47.0 million
• 2017/18: 45.7 million
• 2016/17: 47.2 million
• 2015/16: 45.6 million
• 2014/15: 46.1 million
• 2013/14: 46.4 million  

*2020/21 data has been affected by Covid-19 pandemic and the changing restrictions during this time period

(Source: DfT – Bus statistics data tables: Passenger journeys on local bus services by local authority: Table BUS01e)  

• Action: The Council is developing a fifth Local Transport Plan (LTP5) for Brighton & Hove which will set out the outcomes and priorities for transport and travel across the city to 2030

Reduction in CO2 emissions from transport within Brighton and Hove (This indicator to be reviewed following adoption of revised Air Quality Action Plan in 2014).

Target and Timescale

Reduction of 4% per year in transport related CO2 emissions throughout plan period.

Trigger and Actions to be taken if target not being achieved

• Trigger: no reduction by 2016
  • Action: review measures in Air Quality Action Plan

2023 to 2024 Data and update

• 2022: 259.8 kt CO2
• 2021: 259.6 kt CO2
• 2020: 254.5 kt CO2
• 2019: 315.5 kt CO2
• 2018: 322.7 kt CO2
• 2017: 338.4 kt CO2
• 2016: 339.9 kt CO2  
• 2015: 336.9 kt CO2  
• 2014: 335.2 kt CO2  
• 2013: 334.8 kt CO2
• 2012: 341.3 kt CO2

(DBEIS: UK local authority and regional estimates of greenhouse gas emissions statistics, 2005 to 2022: transport total)

CP10 – Biodiversity

Strategic Objectives: SO1, SO10, SO14, SO15

Amount of open space within the NIA and/or classified “Natural and Semi Natural” lost to development annually

Target and Timescale

Target: zero – unless appropriately mitigated  

(Source: Planning; Sustainability Checklist)

Trigger and Actions to be taken if target not being achieved

• Trigger: target not met for three consecutive years
  • Action: review Development Management procedures and practices / review the need for a report to document the cause and reason for the loss to inform future planning decisions

2023 to 2024 Data and update

8,610m² net created 2023/24

Increased biodiversity and achieving Biodiversity Action Plan targets

Target and Timescale

All development proposals to deliver a net increase in biodiversity in accordance with the requirements of the Nature Conservation and Development SPD and Biodiversity Action Plan by 2030 (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Annual net decrease in biodiversity for three consecutive years
  • Action: Review Development Management procedures and practices  
• Review the need for a report to document the cause and reason for the decrease in biodiversity to inform future planning decisions
• Where appropriate review Nature Conservation and Development SPD and Biodiversity Action Plan.  

2023 to 2024 Data and update

No data available.

CP11 - Flood Risk

Strategic Objectives: SO1, SO8, SO9, SO17

Review of the SFRA

Target and Timescale

Update at least every five years across the Plan period (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Work on review of SFRA not commenced within five-year period.  
  • Action: Review priorities and resources in Planning Strategy & Projects team.  

2023 to 2024 Data and update

The SFRA will be updated in 2025 to inform the City Plan 2041.

Single Data List - Number of planning permissions granted contrary to the advice of the Environment Agency on flood defence grounds

Target and Timescale

No planning permissions granted; to be monitored annually across the Plan period

(Source: Single Data List)

Trigger and Actions to be taken if target not being achieved

• Trigger: Any such planning permission granted.
  • Action: Review development management processes.

2023 to 2024 Data and update

0 planning permissions.  

(Source: EA Objections List 2023/24)

Production of a Surface Water Management Action Plan for the city

Target and Timescale

Adoption by 2015 and reviewed regularly throughout the plan period  

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Work on Surface Water Management Action Plan not commenced by start of 2015.  
  • Action: Review priorities and resources in Planning Strategy & Projects team.  

2023 to 2024 Data and update

Surface Water Management Plan published in April 2014.

CP12 - Urban Design

Strategic Objectives: SO4, SO9, SO12, SO16, SO23

A city-wide urban design framework SPD to be adopted

Target and Timescale

Adoption by 2017  

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Formal public consultation not underway by August 2016.  
  • Action: resources and priorities in the Heritage, Planning Strategy and Projects Teams to be reviewed.

2023 to 2024 Data and update

SPD17 Urban Design Framework adopted 2021

Appeal success rate for schemes where design is a principle issue.

Target and Timescale

Annual target of 70% appeals dismissed where urban design and Policy CP2 are principal issues  

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Target not achieved
  • Action: Review Development Management design practice; review design-related supplementary planning documents.

2023 to 2024 Data and update

Data not updated for 2023/24.

CP13 - Public Streets and Spaces

Strategic Objectives: SO12, SO13, SO16, SO22, SO23

Number of developments permitted with planning obligations to provide mitigation in relation to the surrounding area towards public realm improvements

Target and Timescale

Target not applicable. Indicator to be monitored annually across the Plan period  

(Source: BHCC Annual Infrastructure Funding Statement 2023/24)

2023 to 2024 Data and update  

2023/24: £412,152.00

(Public Realm Contributions)

CP14 - Housing Density

Strategic Objectives: SO1, SO4, SO9

Net density levels across the city and within defined Development Areas (DA’s)

Target and Timescale

Achieve a net density of at least 50 dph in 85% of all new developments across the city and 100dph in 100% of new developments within Development Areas excluding DA7 – Toads Hole Valley.  To be monitored across the plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: Target not achieved annually
  • Action: review Development Management practice regarding density of developments; review Annex 3 (Housing Implementation Strategy).

2023 to 2024 Data and update

No data available.

CP15 - Heritage

Strategic Objectives: SO6, SO9, SO10, SO11, SO12, SO15

Preparation and reappraisal of conservation area appraisals/studies

Target and Timescale

100% coverage of conservation area appraisals by 2020.  

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: 80% coverage not completed by 2018
  • Action: Review resources and priorities in Heritage, Planning Strategy and Projects Teams.

2023 to 2024 Data and update

100% coverage achieved.

Production of new Local List of Heritage Assets.

Target and Timescale

New Local List adopted by 2014  

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

Local List consultation is complete and assessment is underway, on schedule for adoption by end of 2014. No trigger or action necessary.

2023 to 2024 Data and update

A review of the Local List was completed in March 2023.  

CP16 - Open Space

Strategic Objectives: SO10, SO13, SO15, SO23

Amount of open space lost to development annually  

Target and Timescale

Target: zero – unless appropriately mitigated  

(Source: Planning; Sustainability Checklist)

Trigger and Actions to be taken if target not being achieved

• Trigger: target not met for three consecutive years
  • Action: review Development Management procedures and practices / Review the need for a report to document the cause and reason for the loss of open space to inform future planning decisions

2023 to 2024 Data and update

0sqm open space lost 2023/24  

(Sustainability Checklist)

Amount of all developer contributions/CIL provided towards open space enhancement/ improvement

Target and Timescale

Target not applicable – monitored annually across the plan period  

(Source: BHCC Annual Infrastructure Funding Statement 2023/24)

Trigger and Actions to be taken if target not being achieved

For monitoring only; no trigger and action necessary

2023 to 2024 Data and update

2023/24: £895,662.00

(Recreation Contributions)

Amount of new open space created within the city

Target and Timescale

No target applicable. To be monitored annually across the Plan period  

(Source: Planning; Sustainability Checklist)

Trigger and Actions to be taken if target not being achieved

For monitoring only; no trigger and action necessary

2023 to 2024 Data and update

17,109m² net open space created 2023/24

CP17 - Sports Provision

Strategic Objectives: SO15, SO20, SO22

Amount of indoor and outdoor sports facilities and space lost to development annually  

Target and Timescale

Target: zero – unless appropriately mitigated  

(Source: Planning; Sustainability Checklist)

Trigger and Actions to be taken if target not being achieved

• Trigger: target not met for three consecutive years
  • Action: review Development Management procedures and practices / Review the need for a report to document the cause and reason for the loss in sports facilities and space to inform future planning decisions

2023 to 2024 Data and update

0 m² net indoor or outdoor sport facilities lost 2023/24

Number of developments providing sports facilities and/or space on site or through developer contributions

Target and Timescale

No target applicable. To be monitored annually across the Plan period.  

(Source: BHCC Annual Infrastructure Funding Statement 2023/24)

Trigger and Actions to be taken if target not being achieved

For monitoring only; no trigger and action necessary

2023 to 2024 Data and update

2023/24: £895,662.00

(Recreation Contributions)

CP18 - Healthy City

Strategic Objectives: SO20, SO22, SO23

Review of Health Impact Assessment and scoping exercises to establish effectiveness of CP18

Target and Timescale

At least every 5 years across the plan period.

(Source: Planning) 

Trigger and Actions to be taken if target not being achieved

• Trigger: Formal challenge by Health and Wellbeing board or Director Public Health 
  • Action: report to partnership boards or H&W Board

2023 to 2024 Data and update

Health and Equalities Impact Assessment Published with City Plan with Addendums at each different stage of City Plan Part Two Preparation.

Adoption and implementation of the City Plan Part 2

Target and Timescale

Adoption by 2016

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: slow adoption of City Plan Part 2
  • Action: Assess requirement for planning briefs or SPD to bring forward provision

2023 to 2024 Data and update

Action: The City Plan Part Two was adopted in October 2022

Submission of a Health Impact Assessment as part of planning applications for strategic developments.

Target and Timescale

HIA submitted with 100% of strategic developments in the city over plan period

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Approval of planning permission for strategic development without HIA
  • Action: Review Development Management processes

2023 to 2024 Data and update

100% of strategic developments approved with HIA submitted in 2023/24 - 1 Outline Application BH2022/02534 approved at DA7 Toads Hole Valley strategic allocation. 

• Action: HIA by relevant applications is now a validation requirement

CP19 - Housing Mix

Strategic Objectives: SO4, SO9, SO12, SO19, SO20

Adoption of City Plan Part 2 setting out key housing mix objectives

Target and Timescale

Target: Secure appropriate policies and site allocations for different housing types to meet range of accommodation needs in Part 2 of City Plan.

(Source: Planning) 

Trigger and Actions to be taken if target not being achieved

• Trigger: City Plan Part 2 not adopted by 2017.
  • Action: Review programme for Part 2 of City Plan.
• Promote the need for range of housing types and sizes through City Partnerships.
• Review Housing Strategy for different accommodation needs. 

2023 to 2024 Data and update

• Action: The City Plan Part Two was adopted in October 2022.

Housing Strategy currently being reviewed

Monitor the number of 1, 2 and 3+ beds completed annually. Benchmark against 2011 census

Target and Timescale

Target: To see an increase in the proportion of family sized units over the first five years of the plan. 

(Source: Planning) 

Trigger and Actions to be taken if target not being achieved

• Trigger: Target not met in year 4 of monitoring period
  • Action: Promote the need for range of housing types and sizes through City Partnerships.
• Review Housing Strategy for different accommodation needs.

2023 to 2024 Data and update

• 1 bedroom: 44.8%
• 2 bedrooms: 38.3%
• 3+ bedrooms: 16.9%

(2023 to 2024)

• 3+ bedrooms:
  • 2022/23: 13.7%
  • 2021/22: 13.7%
  • 2020/21: 27.0%
  • 2019/20: 14.2%
  • 2018/19: 22.4%
  • 2017/18: 22.2%
  • 2016/17: 26.0%
  • 2015/16: 21.5%
  • 2014/15: 23.7%
  • 2013/14: 20.6%
  • 2012/13: 29.9%

CP20 - Affordable Housing

Strategic Objectives: SO1, SO4, SO9, SO11, SO19, SO20

Single Data List Monitor net affordable housing completions secured across the city.

Target and Timescale

To achieve approximately 30% of all housing delivery as affordable housing. (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Affordable housing delivery across a 3-5 year period falls below 30%
  • Action: Work with Registered Providers to secure greater delivery.
• Promote council owned sites for affordable housing.
• Review Policy.

2023 to 2024 Data and update

2023/24: 318 affordable homes (28% of all housing delivery)

• 2022/21: 172
• 2021/22: 479
• 2020/21: 152
• 2019/20: 179
• 2018/19: 80
• 2017/18: 96
• 2016/17: 56
• 2015/16: 99

Monitor annually % of affordable housing completed reflecting a unit size mix indicated in Policy. 

Target and Timescale

To broadly achieve unit size mix indicated in policy CP20 over a 5 year period.

Policy: 1 Bed: 30%, 2 Bed: 45%, 3+ Bed 25% 

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: affordable housing unit size mix falls below citywide preferred unit size mix across a 5 year period.
  • Action: Work with Registered Providers to secure a better mix.
• Promote council owned sites for specific types of affordable housing.
• Review Policy.

2023 to 2024 Data and update

2023/24: 1 Bed; 35%, 2 Bed; 49% and 3+ bed; 15%

• Action: Continuing Council liaison with RPs regarding affordable housing needs in terms of unit types and sizes. Council action to address identified shortfalls in affordable housing provision through its affordable housing delivery programmes

Financial contributions secured per annum 

Target and Timescale

No target applicable. Annual monitoring of contributions secured for affordable housing.

(Source: BHCC Annual Infrastructure Funding Statement 2023/24)

2023 to 2024 Data and update

2023/24: £1,445,218.05

(Affordable Housing Contributions)   

CP21 - Student Accommodation and Houses in Multiple Occupation

Strategic Objectives: SO4, SO11, SO19, SO21

Number of new purpose built student bedspaces developed

Target and Timescale

Completion of commenced allocations by 2014

• Varley Halls
• East Slope

By 2018 development has commenced that will secure the following sites

• Preston Barracks
• Pelham Street
• Circus Street

(Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Planning applications for Preston Barracks, Pelham Street and Circus Street not submitted by 2015 
  • Action: Development Management Intervention

2023 to 2024 Data and update

2023 to 2024: 252 net student bedrooms completed. 

Number of developments for student accommodation allowed on appeal within the Article 4 wards

Target and Timescale

No appeals allowed (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Over 25% appeals allowed annually
  • Action: review Development Management procedures; review policy 

2023 to 2024 Data and update

Data not updated for 2023 to 2024.

Percentage of appeals allowed for HMO developments within the Article 4 wards

Target and Timescale

No appeals allowed (Source: Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Over 25% appeals allowed annually
  • Action: review Development Management procedures; review policy 

2023 to 2024 Data and update

2023 to 2024: 0% appeals allowed (0 allowed, 0 dismissed) all within original Article 4 wards.

• 2022/23: 66%
• 2021/22: 100%
• 2020/21: 56%
• 2019/20: 60%
• 2018/19: 58%
• 2017/18: 15%
• 2016/17: 25%
• 2015/16: 50% 

CP22 - Traveller Accommodation

Strategic Objectives: SO1, SO4, SO19, SO20

Update of Traveller Accommodation Assessment

Target and Timescale

Review Traveller accommodation needs assessment to inform longer term pitch requirements (post 2019) for the City. Source Housing & Social Inclusion and Planning)

Trigger and Actions to be taken if target not being achieved

• Trigger: Needs Assessment Update not completed by October 2014.
  • Action: Work with partner authorities to complete update of assessment. Review resources in Planning Policy & Projects Team.

2023 to 2024 Data and update

Updated GTAA completed in 2024.

Net additional pitches provided 

Target and Timescale

Identify sufficient deliverable sites for the provision of 18 permanent residential pitches before 2019.

Provision of additional pitches to meet assessed requirements over plan period. 

Trigger and Actions to be taken if target not being achieved

• Trigger: Sufficient pitches are not in development pipeline by 2017.
  • Action: Undertake revised site search to identify further site opportunities.

Work with HCA and other providers to secure appropriate funding where necessary.

2023 to 2024 Data and update   

A permanent Traveller site at St Michael's Way, Brighton, was completed in June 2016 adding 12 permanent pitches.

Updated GTAA (2024) concludes that there is a need for 7 additional permanent pitches in the City Plan area.

The following indicators are taken from the City Plan Part Two Implementation & Monitoring Plan (October 2022).

DM1 - Housing Quality, Choice and Mix

Strategic Objectives: SO4, SO9, SO12, SO19, SO20

Delivery of housing meeting acceptable space standards

Indicator Reference / Indicator

LOI: Percentage of residential units permitted not meeting nationally described space standards.

Target / Timescale

• No specific target
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

Not currently monitored.

Delivery of accessible and adaptable housing

Indicator Reference / Indicator

LOI: Percentage of residential units permitted that do not meet the minimum accessibility and adaptability standards set out in the Building Regulations (M4 (2)).  

Target / Timescale

• No specific target
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

Not currently monitored.

Provision of wheelchair accessible housing

Indicator Reference / Indicator

LOI: Percentage of residential units permitted1 suitable for occupation by a wheelchair user in accordance with Building Regulation M4(3)

Target / Timescale

• Target: 10% of affordable residential and 5% of all residential units to meet standards in Building Regulation M4(3)  (includes residential accommodation that does not fall within a C3 use class (e.g extra care accommodation, assisted living housing and HMOs and residential extensions where relevant)
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: Under 10% of affordable residential and/or under 5% of residential permissions1 not meeting M4(3) standards
• Action: Review reasons for not achieving M4(3) standards and if necessary, review DM procedures.

2023/24 Data and update

Not currently monitored.

DM4 - Housing and Accommodation for Older Persons

Strategic Objectives: SO4, SO9, SO12, SO19, SO20

Provision of housing/ accommodation for older persons to meet identified demand/needs

Indicator Reference / Indicator

LOI: Number and type of specialist residential units/ accommodation2 for older persons completed annually

Target / Timescale

• Target: To meet the indicative projections of outstanding need for specialist housing/ accommodation for older people as set out in supporting text to the policy.
• Timescale: Annual monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Review policy and approach to provision with the council’s Housing and Adult Social Care services.

2023/24 Data and update

• Total 0 no of specialist residential units/ accommodation2 for older persons completed in 2023/24.
• 2 Includes residential accommodation for older persons both within and outside the C3 use class.

DM5 - Supported Accommodation (Specialist and Vulnerable Needs)

Strategic Objectives: SO4, SO9, SO12, SO19, SO20

Provision of specialist housing/ accommodation to meet specialist and vulnerable needs

Indicator Reference / Indicator

LOI: Number and type of supported accommodation units3 for specialist and vulnerable needs completed annually

Target / Timescale

• No specific target
• Timescale: Annual monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

• Total 0 no of supported accommodation units3 for specialist and vulnerable needs completed in 2023/24.
• 3 Includes supported accommodation for specialist and vulnerable needs both within and outside the C3 use class.

DM6 – Build to Rent Housing

Strategic Objectives: SO4, SO9, SO12, SO19, SO20

Provision of Build to Rent housing that contributes to meet identified demand/ need

Indicator Reference / Indicator

LOI: Number of build to rent dwellings completed annually

LOI: Number & percentage of affordable dwellings completed annually as part of build to rent developments

Target / Timescale

• No specific target
• Timescale: Annual monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

• 216 dwellings completed as part of ‘build to rent’ developments in 2023/24.  
• 16 affordable dwellings (7%) completed as part of ‘build to rent’ developments.

(Total dwellings provided by application BH2020/00917)

DM9 - Community Facilities

Strategic Objectives: SO1, SO7, SO9, SO11, SO13, SO16, SO18, SO19, SO20, SO22

Provision and retention of community facilities

Indicator Reference / Indicator

No specific indicator – requirement for community facilities is addressed through the Infrastructure Delivery Plan (IDP)

Target / Timescale

• No specific target
• Timescale: Ongoing monitoring through the IDP

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

No data available.  

DM10 – Public Houses

Strategic Objectives: SO13, SO16, SO18, SO19, SO20

Retention of public houses

Indicator Reference / Indicator

Number of planning permissions involving loss of public houses to other uses

Target / Timescale

• Target:  No specific target
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable  

2023/24 Data and update

0 planning permissions in 2023/24.  

DM12 – Regional, Town, District and Local Shopping Centres

Strategic Objectives: SO3, SO5, SO7, SO9, SO13, SO18, SO19

Maintaining vitality and viability of defined retail centres

Indicator Reference / Indicator

LOI Increase in the number of active commercial units in defined centres.

Target / Timescale

• Target: Net gain in number of commercial units
• Timescale: Ongoing monitoring through health checks  

Trigger and Actions to be taken if target not being achieved

• Trigger: Increase in vacancies in two successive health checks  
• Action: Review policy approach and Development Management practice

2023/24 Data and update

In 2025, it is anticipated that a Retail Capacity Study will be commissioned as a background study for the City Plan 2041. This will involve an update to Retail Health Checks for the centres in the Retail Hierarchy.

DM14 - Commercial and Leisure Uses at Brighton Marina  

Strategic Objectives: SO3, SO5, SO13, SO17, SO18, SO19

Maintaining vitality and viability of Special Commercial and Leisure Area - Brighton Marina  

Indicator Reference / Indicator

LOI: Increase in the number of active commercial units at Brighton Marina

Target / Timescale

• Target: Net gain in number of commercial units
• Timescale: Ongoing monitoring through health checks

Trigger and Actions to be taken if target not being achieved

• Trigger: increase in vacancies in two successive health checks
• Action: Review policy approach and Development Management practice

2023/24 Data and update

In 2025, it is anticipated that a Retail Capacity Study will be commissioned as a background study for the City Plan 2041. This will involve an update to Retail Health Checks for the centres in the Retail Hierarchy.

DM15 -  Commercial and Leisure Uses on the Seafront

Strategic Objectives: SO3, SO13, SO16, SO17, SO22, SO23

Maintaining and enhancing the diversity and mix of uses in Special Commercial and Leisure Area

Indicator Reference / Indicator

LOI: Number and type of uses on the seafront

Target / Timescale

• No specific target  
• Timescale: Ongoing monitoring through retail health checks

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

In 2025, it is anticipated that a Retail Capacity Study will be commissioned as a background study for the City Plan 2041. This will involve an update to Retail Health Checks for the centres in the Retail Hierarchy.

DM20 - Protection of Amenity

Strategic Objectives: SO4, SO9, SO12, SO16, SO22, SO23

Protection of amenity

Indicator Reference / Indicator

Appeal success rate for schemes where protection of amenity is a principal issue

Target / Timescale

• Target: 70% appeals dismissed where conflict with Policy DM20 is a principal reason for refusal
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: Target not achieved
• Action: Review Development Management practice  

2023/24 Data and update

Not currently monitored.

DM21 - Extensions and Alterations

Strategic Objectives: SO8, SO9, SO12, SO16, SO22, SO23

Delivery of high-quality design

Indicator Reference / Indicator

Policy CP12 indicator  

LOI: Appeal success rate for schemes where design is a principal issue

Target / Timescale

As for Policy CP12

Trigger and Actions to be taken if target not being achieved

As for Policy CP12

2023/24 Data and update

See update for Policy CP12

DM24 - Advertisements

Strategic Objectives: SO11, SO12, SO13, SO16, SO23

Protection of amenity and public safety

Indicator Reference / Indicator

LOI: Appeal success rate for applications for advertisement consent

Target / Timescale

• Target: 70% appeals against refusal of advertisement consent dismissed
  • (Note: This is the same target as used for appeals success in Policy CP12)
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: Target not achieved
• Action: Review policy approach and Development Management practice

2023/24 Data and update

Not currently monitored.

DM25 - Communications Infrastructure

Strategic Objectives: SO12, SO13, SO14, SO16, SO23

Managing the location and design of telecommunications development

Indicator Reference / Indicator

LOI: Appeal success rate for applications where appearance/ impact on setting/ clutter are principal issues.

Target / Timescale

• Target: 70% appeals dismissed where appearance/ impact on setting/ reducing clutter are principal issues.  
• Timescale:  Annual monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

Not currently monitored.

DM26 - Conservation Areas

Strategic Objectives: SO9, SO10, SO11, SO12, SO13, SO16, SO22

Preserving and enhancing the historic environment and heritage assets

Indicator Reference / Indicator

LOI: Appeal success rate for applications where impact on the historic environment and heritage assets is a principal issue

Target / Timescale

• Target: 70% appeals dismissed where impact on the historic environment and heritage assets is a principal reason for refusal
• Timescale: Annual monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: Target not achieved
• Action: Review policy approach and Development Management practice  

2023/24 Data and update

Not currently monitored.

DM32 - The Royal Pavilion Estate

Strategic Objectives: SO5, SO8, SO10, SO12, SO13, SO15, SO16, SO22, SO23

Preserving and enhancing the historic environment and heritage assets

Indicator Reference / Indicator

LOI: Restoration and improvement works to the Royal Pavilion Estate so that the Gardens are no longer ‘at risk’

Target / Timescale

• Target: Removal of the Pavilion Gardens from the Historic England ‘at risk’ register
• Timescale: By 2023

Trigger and Actions to be taken if target not being achieved

• Trigger: No funding in place by 2021
• Action: BHCC review meeting with Historic England and Brighton Dome & Festival Ltd

2023/24 Data and update

In January 2024, the Council and Brighton & Hove Museums received a National Lottery Heritage Fund grant of £4,369,755 to restore the gardens and improve facilities.  

DM34 - Transport Interchanges

Strategic Objectives: SO1, SO3, SO7, SO11, SO14, SO19,  SO22

Provision of transport interchanges

Indicator Reference / Indicator

LOI: New transport interchange facilities provided

Target / Timescale

• No specific target  
• Timescale: Ongoing monitoring through plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

No data available.  

DM36 - Parking and Servicing

Strategic Objectives: SO1, SO7, SO11, SO19, SO20, SO22

Delivery of appropriate parking and servicing provision

Indicator Reference / Indicator

Covered under City Plan SA indicator 6

• Percentage of development where cycle parking provided
• Percentage of residential units delivered that are car-free

Target / Timescale

• No specific target  
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

• 55% new build residential and PDSA development approved through a full planning application and completed 2023/24; providing a total of 995 spaces.
• 12% new build residential development approved through a full planning application and completed 2023/24 included car free units; a total of 60 car free units.

DM38 - Local Green Spaces

Strategic Objectives: SO13, SO15, SO22

Protecting and enhancing Local Green Spaces

Indicator Reference / Indicator

LOI: Development/ loss of Local Green Space

Target / Timescale

• Target: 100% retention of designated Local Green Spaces
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: Loss of Local Green Space resulting from development
• Action: Review reason(s) for loss and consider need for any change to policy or Development Management practice

2023/24 Data and update

No loss of Local Green Space in 2023/24. There are four designated sites:

• Hollingbury Park
• Three Cornered Copse
• Ladies’ Mile
• Benfield Valley

DM40 - Protection of Environment and Health – Pollution and Nuisance

Strategic Objectives: SO6, SO7, SO8, SO10, SO11, SO12, SO14, SO15, SO16, SO22, SO23

Preventing adverse impacts on air quality

Indicator Reference / Indicator

Covered under City Plan SA indicator 2

Extent of air quality management area in Brighton & Hove

Target / Timescale

• No specific target
• Timescale:  Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

There are currently six AQMAs in Brighton & Hove:  

1. Central Area
2. Rottingdean High Street
3. South-west Portslade
4. Sackville Road/Old Shoreham Road
5. The Drove-South Road/Preston Road
6. Eastern Road (Royal Sussex County Hospital

DM41 - Polluted Sites, Hazardous Substances and Land Stability

Strategic Objectives: SO1, SO7, SO9, SO22, SO23

Avoiding risks to health, safety and/or the environment

Indicator Reference / Indicator

No specific indicator

Partly covered by City Plan SA indicator 9  

Number of sites of previously developed land that have been identified as having potential for contamination under Part 2A of the Environment Protection Act

Target / Timescale

• No specific target
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

There is currently no contaminated land sites listed under Part 2 A of the Environmental Protection Act 1990.  

See: https://www.brighton-hove.gov.uk/environment/register-formally-determined-contaminated-land-sites  

DM42 - Protecting the Water Environment

Strategic Objectives: SO7, SO8, SO14, SO17, SO22

Protection of water quality

Indicator Reference / Indicator

Covered under City Plan SA indicator 7

Status of the groundwater resource as measured by the requirements of the Water Framework Directive

Target / Timescale

• Target: Aim to achieve ‘good’ chemical status by 2027
• Timescale:  Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: Failure to meet target by 2027
• Action: Review reasons. If related to new development permitted, review Development Management practice and if necessary consider need for updated policy review or guidance.

2023/24 Data and update

10% new build residential development approved through a full planning application and completed 2023/24; all SUDS within development.

DM43 - Sustainable Urban Drainage

Strategic Objectives: SO7, SO8, SO14, SO17, SO22

Management of surface water run off  

Indicator Reference / Indicator

LOI: Preparation and adoption of Sustainable Drainage SPD

Target / Timescale

• Target: Adoption of SPD by date of CPP2 adoption
• Timescale: See above

Trigger and Actions to be taken if target not being achieved

DM14

2023/24 Data and update

SPD16 Sustainable Drainage formally adopted in September 2019.  

DM44 - Energy Efficiency and Renewables

Strategic Objectives: SO1, SO7, SO8, SO19, SO20, SO22

Reduction in carbon emissions

Indicator Reference / Indicator

LOI: % of new developments that meet minimum building standard requirements for B&H:

• Residential  (already monitored through Policy CP8)
• Non Residential (already monitored under City Plan SA indicator 20)

Target / Timescale

• Target:  New residential created through conversions and changes of uses of existing buildings and for non-residential development (non-major and major) including conversions and changes of use to achieve at least 19% improvement on carbon emission targets set by Part L of Building Regulations until superseded by Future Homes Standards and Future Building Standards or interim uplift in Part L if greater than 19%.  
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: Annual % of developments meeting targets fall below 70%
• Action: Review Development

Management practice. If necessary, provide updated technical guidance.

2023/24 Data and update

See update for Policy CP8

Delivery of energy efficient development

Indicator Reference / Indicator

LOI: % of applications approved that meet minimum Energy Performance Certificate (EPC) rating of:

• EPC ‘C’ for conversions and changes of use of existing buildings
• EPC ‘B’ for new build

Target / Timescale

• Target: All developments including conversions and changes of use to achieve EPC ratings as set out in Policy DM44
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: Annual % of developments meeting targets falls below 70%
• Action: Review Development

Management practice. If necessary, provide updated technical guidance.

2023/24 Data and update

Not currently monitored.

Reduce City carbon emissions

Indicator Reference / Indicator

Covered under City Plan SA indicator 18

KT of CO2 emissions per capita in the LA area (domestic)

(Source: DBEIS: UK local authority and regional estimates of greenhouse gas emissions statistics, 2005 to 2022)

Target / Timescale

• Target: 4% reduction annually, or progress towards 80% reduction by 2050 (target set in Sustainable Community Strategy)
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: To be determined
• Action: Review Development Management procedures

2023/24 Data and update

2.9KT of CO2 emissions per capita (2022)

DM45 – Community Energy

Strategic Objectives: SO1, SO7, SO8, SO19, SO20, SO22

Reduction of carbon emissions

Indicator Reference / Indicator

LOI: Number of developments permitted that incorporate or link to community energy projects

Target / Timescale

• No specific target
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

Not currently monitored.

DM46 - Heating and Cooling Network Infrastructure

Strategic Objectives: SO1, SO7, SO8, SO19, SO20, SO22

Promotion of sustainable energy and reduction of carbon emissions

Indicator Reference / Indicator

LOI: Number of developments permitted that include integrated heat networks and/or communal heating systems

Target / Timescale

• No specific target
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

Not currently monitored.

SA7 – Benfield Valley

Strategic Objectives: SO10, SO14, SO15, SO22

Protection and enhancement of designated Special Area

Indicator Reference / Indicator

Indicator: Addressed by Policies DM37, DM38 and H2

Protection of open space & biodiversity will be covered through other monitoring indicators.

Improvements to management, public access etc will be recorded.

Target / Timescale

As set out for Policies DM37, DM38 and H2

Trigger and Actions to be taken if target not being achieved

• Trigger: Addressed by Policies for Policy DM37, DM38 and H2

2023/24 Data and update

• Application BH2024/01720 submitted in July 2024, not yet determined.  
• Proposal includes 101 residential units, works to Benfield Barn to create a ‘community hub’ facility, retention of public open space on southern site.  

SSA1 – Brighton General Hospital site, Elm Grove, Freshfield Road

Strategic Objectives: SO1, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO16, SO19, SO20, SO22, SO23

Delivery and amount of development

Indicator Reference / Indicator

LOI: Delivery of development for SSA1

Target / Timescale

• Target: Delivery of development to include:
  • 10,000 – 12,000 sq.m health and care facility (E(e));
  • 200 residential units
  • community facilities
• Timescale: Development to be completed by 2027

Trigger and Actions to be taken if target not being achieved

• Trigger: Planning application not submitted by 2021
• Action: Development Management intervention

2023/24 Data and update

No planning application submitted in 2023/24.  

SSA2 – Combined Engineering Depot, New England Road

Strategic Objectives: SO1, SO2, SO3, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO19, SO20, SO22, SO23

Delivery and amount of development

Indicator Reference / Indicator

LOI: Delivery of development for SSA2

Target / Timescale

• Target: Delivery of development to include:
  • 100 residential units
  • 1,000 sq.m E(g) workspace & managed starter office units
• Timescale: Development to be completed by 2027

Trigger and Actions to be taken if target not being achieved

• Trigger: Planning application not submitted by 2021
• Action: Development Management intervention

2023/24 Data and update

No planning application submitted in 2023/24.  

SSA3 – Land at Lyon Close, Hove

Strategic Objectives: SO1, SO2, SO3, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO19, SO20, SO22, SO23

Delivery and amount of development

Indicator Reference / Indicator

LOI: Delivery of development for SSA3

Target / Timescale

• Target: Delivery of development to include:
  • 5,700 sq m net E(g) office floorspace
  • 300 residential units
  • health facilities (GP surgery) and/or community uses
  • ancillary small scale retail uses
• Timescale: Development to be completed by 2027

Trigger and Actions to be taken if target not being achieved

• Trigger: Planning applications sufficient to deliver combined targets not submitted by 2021
• Action: Development Management intervention

2023/24 Data and update

Application BH2018/01738 commenced in October 2021.  

Proposal includes:

• 152 residential units
• 697sqm of E(g) office floorspace.

*Note approved application only covers half the allocated area.  

SSA4 – Sackville Trading Estate and Coal Yard

Strategic Objectives: SO1, SO2, SO3, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO15, SO19, SO20, SO22, SO23

Delivery and amount of development

Indicator Reference / Indicator

LOI: Delivery of development for SSA4

Target / Timescale

• Target: Delivery of development to include:
  • 500 residential units
  • 6,000 sq.m E(g) employment floorspace
  • ancillary retail and food/drink outlets
  • public realm improvements including a public square
  • Children’s playspace and/or informal multi use sports area  
  • community facilities
• Timescale: Development to be completed by 2027

Trigger and Actions to be taken if target not being achieved

• Trigger: Planning application not submitted by 2021
• Action: Development Management intervention

2023/24 Data and update

• Application BH2019/03548 for 564 units, known as the ‘Moda development’ due for completion in 2024/25.
• Blocks D, E, F complete with residents living in, remaining Blocks A, B, C still under construction as of 2023/24.  
• No application submitted in 2023/24 for remaining “northern parcel” of allocation.

SSA5 – Madeira Terraces and Madeira Drive

Strategic Objectives: SO3, SO13, SO16, SO17, SO22, SO23

Restoration, regeneration and improvements to public realm

Indicator Reference / Indicator

LOI: Restoration of Madeira Terrace (first 3 arches to act as showcase for terrace)

Target / Timescale

• Target: Completion of restoration of 3 arches as pilot project
• Timescale: Subject to final agreed works  

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

Application BH2022/02577 for Phase 1 restoration of 40 arches approved in November 2022. Work commenced November 2024 and is expected to be completed in summer 2026.

SSA6 – Former Peter Pan Leisure site (adjacent Yellow Wave), Madeira Drive

Strategic Objectives: SO3, SO13, SO16, SO17, SO22, SO23

Delivery and amount of development

Indicator Reference / Indicator

LOI: Delivery of development for SSA6

Target / Timescale

• Target: Delivery of development and infrastructure improvements
• Timescale: Development to be completed within Plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: Planning application not submitted by 2021
• Action: Development Management intervention

2023/24 Data and update

Application BH2020/01018 approved in March 2021 for permanent swimming pool and temporary commercial modular buildings for 10-year period. ‘Sea Lane Brighton’ facilities opened in June 2023.  

SSA7 – Land adjacent to American Express Community Stadium, Village Way

Strategic Objectives: SO1, SO2, SO3, SO8, SO14, SO16, SO20, SO21, SO22

Delivery and amount of development

Indicator Reference / Indicator

LOI: Delivery and amount of development for SSA7 (B1a office floorspace to be monitored through Policy CP3 indicators)  

Target / Timescale

• Target: Delivery of development (no specific timescale)
• Timescale: Ongoing monitoring through Plan period

Trigger and Actions to be taken if target not being achieved

Not applicable

2023/24 Data and update

No planning application submitted in 2023/24.

H3 – Purpose Built Student Accommodation  

Strategic Objectives: SO4, SO9, SO11, SO19, SO21

Provision of additional purpose built student accommodation

Indicator Reference / Indicator

LOI: Delivery of allocated sites

Target / Timescale

• Target: Delivery of student accommodation on allocated sites.
• Timescale: Development to be completed by end of Plan period

Trigger and Actions to be taken if target not being achieved

• Trigger: Planning applications not submitted by 2025
• Action: Development management intervention

2023/24 Data and update

• Application BH2020/03263 -May Cottages, 39-47 Hollingdean Road,  
• Brighton site completed in 2023/24.
• No planning application submitted in 2023/24 for Lewes Road Bus Garage.