This Authority Monitoring Report (AMR) 2022/23 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 2022 to 31 March 2023.
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.
Brighton & Hove City Council produces waste and minerals plans jointly with East Sussex County Council (ESCC) and the South Downs National Park Authority (SDNPA). Key data on waste arisings is presented in this AMR and further data regarding waste and minerals can be found on the ‘East Sussex Minerals and Waste Authority Monitoring Reports’ page of the ESCC website.
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 three-year timetable for the production of Development Plan Documents by the Council, with the most recent version covering the period 2022 to 2025 approved on 10 March 2022.
The LDS identifies the main Development Plan Documents to be prepared over a three-year period including their spatial coverage, purpose, and status. It also sets out the status of supplementary planning guidance and other planning documents.
The following documents were approved or adopted during the monitoring year:
Background Documents:
Progress on Documents set out in the Local Development Scheme:
At present, the 2011 Localism Act, and the National Planning Policy Framework (NPPF) (NPPF July 2021, paragraphs 24-27) 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 (provisions with the Levelling Up and Regeneration Bill propose that the Duty to Cooperate will be deleted).
To date, the City 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.
Most cross-boundary strategic planning issues affecting the city were addressed through the preparation and examination of the adopted City Plan Part 1.
Two outstanding strategic issues were addressed through the City Plan Part 2:
The City Plan Part 2 examiner was satisfied that all the requirements regarding the Duty to Cooperate had been met.
The Council is a member of the West Sussex & Greater Brighton (WS&GB) Strategic Planning Board (SPB). The constituent authorities have prepared a Local Strategic Statement (LSS) which sets out long term Strategic Objectives and Spatial Priorities for delivering these in the short to medium term. The LSS was last updated in 2015.
The WS&GB authorities continue to recognise that a full review of the LSS would be required to address the longer-term strategic planning issues facing the area, in particular the gap between housing needs and housing delivery, and the continuing challenges around supporting sustainable economic growth and infrastructure investment.
With the publication of the Levelling Up and Regeneration Bill, which repeals the Duty to Co-Operate provisions, authorities are awaiting further guidance on how cross boundary strategic planning matters are to be formally addressed. Brighton & Hove continues to work collaboratively with neighbouring authorities in terms of responding to consultations on local plans as they move forward.
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.
Brighton & Hove City Council works jointly with East Sussex County Council and the South Downs National Park Authority on waste and minerals planning policy matters. The Waste & Minerals Local Plan (WMLP) comprises the Waste & Minerals Plan (adopted 2013) and Waste and Minerals Sites Plan (adopted 2017).
A targeted review of some policies in the WMLP, primarily focussing on the issue of aggregate supply, is at a late stage and on 13 May 2022, the ‘East Sussex, South Downs and Brighton & Hove Waste and Minerals Local Plan – Revised Policies Document’ (RPD) was submitted to the Secretary of State for public examination. The Examination of the RPD is ongoing, with public hearing sessions having taken place in November 2022. Consultation on modifications to the Plan took place in October to December 2023. As part of the production of the RPD, cross-boundary working took place with several authorities to address strategic waste and minerals issues.
Following the conclusion of this process, the three Authorities have agreed to progress a full review of the WMLP with substantive work expected to start in 2024.
Brighton & Hove City Council is a member of the South East Waste Planning Advisory Group, a forum for all south-east WPAs to work jointly to address cross-boundary waste planning issues.
The council is also a member of the South East England Aggregates Working Party (SEEAWP), which brings together representatives from the minerals industry and the mineral planning authorities of the south east to monitor the supply and demand for aggregate, including assessing the potential for supply of secondary and recycled materials, and reserves (land bank) of primary aggregate.
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:
Seven Neighbourhood Areas have been designated within the city, one of which was designated a ‘Business Area’:
There are currently three designated Neighbourhood Forums in addition to Rottingdean Parish Council which is a qualifying body for the purposes of neighbourhood planning. Neighbourhood forums last for five 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. The Hangleton & Knoll Forum also lapsed in November 2023; however, it is understood that the Forum would like to renew this designation in 2024.
All neighbourhood groups can prepare a neighbourhood development plan for their area following prescribed requirements set out in the Neighbourhood Planning Regulations.
Hove Station Neighbourhood Forum submitted their draft Neighbourhood Plan to the Council in May 2021. The Council undertook Regulation 16 consultation on the draft Plan over an eight-week period from 20 May to 15 July 2021 and the Plan examination commenced on 24 January 2022. During the examination, the examiner identified some issues with the Basic Conditions Statement supporting the Plan and therefore temporarily suspended the examination in May 2022. A supplementary consultation on the Basic Conditions Statement took place over the period 3 November 2022 to 15 December 2022. The Examination of the Neighbourhood Plan resumed in 2023 and the Examiner’s report was received on 8 October 2023. The report recommends that the Neighbourhood Plan should, subject to the recommended modifications, proceed to referendum. The Council has prepared a Decision Statement setting out the actions to be taken in response to the Examiner’s recommendations and this will be discussed at a Full Council meeting in December 2023 recommending that the plan proceeds to Referendum in 2024.
Rottingdean Parish Council undertook pre-submission (Regulation 14) consultation on their draft Neighbourhood Plan over the period 14 February to 9 April 2021. In accordance with Regulation 16 of the Neighbourhood Planning Regulations 2012 (as amended), the Neighbourhood Plan and associated documents went out for consultation from 2 February to 16 March 2023 for 6 weeks. The examination of the Plan took place on 17 July 2023 and the Examiners Report was received on 18 October 2023. The report recommends that the Neighbourhood Plan should, subject to the recommended modifications, proceed to referendum. The Council has prepared a Decision Statement setting out the actions to be taken in response to the Examiner’s recommendations and this will be discussed at a Full Council meeting in December 2023 recommending that the plan proceeds to Referendum in 2024.
Brighton Marina Business Neighbourhood Forum undertook pre-submission (Regulation 14) consultation on their draft Neighbourhood Plan over the period 9 November 2022 to 4 January 2023. The Forum formally submitted its plan and associated documents to the council in November 2023. Regulation 16 consultation on the submission plan will take place in January 2024 before the appointment of an independent Examiner. The Examination of the Plan is likely to take place in mid 2024.
The performance of policies in Supplementary Planning Documents (SPD) is summarised in the Appendices. Significant effects indicators are produced as part of the sustainability appraisal process. They enable a comparison to be made between the predicted effects of the SPD on society, the environment and the economy and the actual effects measured during implementation of the SPD.
All previously adopted SPDs have been summarised in previous AMRs. All of the SPDs can be accessed through our Supplementary Planning Documents page and are listed below:
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 12th March 2015.
In the summer of 2020, temporary amendments to the SCI were published in response to the COVID-19 restrictions. Changes to the temporary amendments of the SCI have since been updated in January 2022 to reflect current working arrangements and the opening hours of services. The council are currently preparing an update to the SCI, which is likely to be consulted upon for at least 6 weeks in Spring 2024.
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.
| 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 |
There were 860 net housing completions in 2022 to 2023. This is a lower completion figure than the previous year, however, it comfortably exceeds the annualised housing requirement of 660 dwellings per year. However, due to the under-provision in previous years, the implied annual delivery rate required to meet the Plan target remains high at 916 dwellings per year (Table 2).
| Period | Plan Requirement | Implied Annual Rate |
|---|---|---|
| Plan Period 2010 to 2030 | 13,200 | 660 |
| Remaining Period 2022 to 2030 | 7,272 (takes into account recorded supply net completions from 2010 to 2022 (5,928 units)) | 916 |
New build developments accounted for the largest share of housing delivery in 2022 to 2023, yielding a total of 555 net dwellings. Although this figure is lower than that of the preceding monitoring year, it represents a substantial increase compared to the levels observed in prior years.
| Year | 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 |
There has been a decrease in residential completions on large (six units and over) developments compared to the previous year, but despite this, this year’s figure of 685 units is the second highest of the Plan period (Table 3). Completions in small (five units and under) developments have also increased to 175 units. Out of the 685 units completed on large sites, 305 were located within Development Areas (DAs) as defined in City Plan Part One (Policies DA1-DA8). This contribution stemmed from the Longley Industrial Estate development within DA4 (New England Quarter and London Road Area) and the Belgrave Centre development in DA8 (Shoreham Harbour). Residential completions on sites comprising 10 or more dwellings are set out in Table 4, with these sites yielding a total of 634 units.
| Address | Development | Net Units Completed |
|---|---|---|
| Longley Industrial Estate, New England Street & Elder Place, Brighton | Mixed use development including 201 residential units | 201 |
| Crown House, 21 Upper North Street, Brighton | Prior approval for a change of use from offices to residential to form 183 self-contained residential units | 183 |
| Belgrave Training Centre, Clarendon Place, Portslade | Demolition of existing building and development of 104 apartments | 104 |
| 29 to 31 New Church Road, Hove | Demolition of mosque and surrounding buildings and erection of a mixed-use development including 104 residential units | 45 |
| Victoria Road Housing Office, Victoria Road, Portslade | Erection of 2 buildings to form 42 residential units | 42 |
| Sussex County Cricket Ground, Eaton Road, Hove | Mixed use development including the demolition and erection of 9-storey building comprised of 36 residential units | 36 |
| Land South of Ovingdean Road, Brighton | 12 units constructed of the 45 dwellings proposed | 12 |
| The Meeting House, Park Close, Brighton | Demolition of existing dwelling and erection of 2 two/three story buildings to provide 12 flats | 11 |
Table 5 illustrates the net annual residential completions in the city since the start of the City Plan period (2010 to 2011). The average rate of residential completions over this period has been 522 units per year. Annual completions have generally been below the required City Plan delivery rate of 660 residential units per year but have increased significantly in the past two monitoring years (2021 to 2022 and 2022 to 2023), significantly exceeding the annual requirement.
| Year | Total Net Completions |
|---|---|
| 2008 to 2009 | 721 |
| 2009 to 2010 | 380 |
| 2010 to 2011 | 283 |
| 2011 to 2012 | 309 |
| 2012 to 2013 | 374 |
| Five year average | 413 |
| Year | Total Net Completions |
|---|---|
| 2013 to 2014 | 436 |
| 2014 to 2015 | 581 |
| 2015 to 2016 | 687 |
| 2016 to 2017 | 339 |
| 2017 to 2018 | 444 |
| Five year average | 497 |
| Year | Total Net Completions |
|---|---|
| 2018 to 2019 | 380 |
| 2019 to 2020 | 543 |
| 2020 to 2021 | 479 |
| 2021 to 2022 | 1073 |
| 2022 to 2023 | 860 |
| Five year average | 667 |
In 2022 to 2023, flats comprised 88 percent of newly completed residential dwellings, with 92 percent of these flats featuring two bedrooms or fewer. Among the remaining 12% houses completed, 56 percent were three-bedroom houses or larger. Overall, one- and two-bedroom units constituted 86 percent of all residential units completed in 2022 to 2023, reflecting the proportion from the previous year and exceeding the figures recorded in the preceding two monitoring years (Table 6).
| Year | 1 bed | 2 bed | 3 bed | 4 beds or more |
|---|---|---|---|---|
| 2020 to 2021 | 36.1% | 36.9% | 20.8% | 6.2% |
| 2021 to 2022 | 42.1% | 44.2% | 11.3% | 2.4% |
| 2022 to 2023 | 60.3% | 26% | 9.8% | 3.9% |
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 2018/19. With the inclusion of self-contained student accommodation, the total figure for self-contained residential accommodation increases to 959 units (Table 7).
| Year | Residential | Student | Total |
|---|---|---|---|
| 2020 to 2021 | 479 | 303 | 782 |
| 2021 to 2022 | 1,073 | 187 | 1,260 |
| 2022 to 2023 | 860 | 99 | 959 |
| Year | 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 |
The permitted development right (PDR) for a change of use from office to residential use was introduced in 2013 and was subsequently extended to include retail, financial and professional services, light industrial and storage or distribution uses. These developments require prior approval from the local authority but are not subject to the standard planning application process. A new PDR for the change of Commercial, Business and Service use (E use class) to residential use came into force in August 2021 which covers and extends the previous PDR.
| Year | 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 |
In 2022 to 2023, 212 residential units were completed through permitted development (Table 9). This represents a significant increase compared to previous years, primarily due to the conversion of Crown House to 183 units. While 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.
Housing affordability remains a significant 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 five or more dwellings. Affordable housing is defined as housing for sale or rent for households whose needs are not met by the market (e.g., affordable rented housing or shared ownership).
| 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 |
A total of 172 affordable homes were completed in 2022 to 2023 (Table 10), which comprises 20 percent of all gross completions. These affordable units were all delivered through major developments, representing 28 percent of all units within major developments. Of the four completed major developments with affordable housing, two were 100 percent affordable (Belgrave Training Centre, Victoria Road Housing Office). Additionally, off-site affordable financial contributions were made by five major developments in lieu of delivering affordable housing units on-site. Of the completed affordable units, 49 percent were one-bedroom units, 40 percent were two-bedroom units, and 11 percent were three-bedroom units.
There were 4,524 net housing units with extant permissions (planning permissions which are still valid and able to be implemented) at the end of March 2023; of which 2,694 units are in schemes that have commenced (Some sites are technical commencements or have remained commenced for an extended period of time, which, although are able to be implemented are likely not to continue to come forward on the current permission). There were 1,452 net affordable housing units with extant permissions at the end of March 2023; with 666 units in schemes which have commenced. There were 1,169 new net housing units permitted9 in 2022/23 (Table 11); 372 of which were affordable housing units.
| Year | 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 207 | 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 |
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).
There were 99 net bedrooms completed in PBSA in 2022 to 2023 (Table 12) made up of solely single-occupancy self-contained flats within a PBSA development at 39 to 47 Hollingdean Road. Since 2010 to 2011, 6,757 new student bedrooms have been developed within Brighton and Hove. A further 2,124 bedrooms were under construction at the end of 2022 to 2023.
| 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 |
| 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 |
There are approximately 3,600 licensed Houses of Multiple Occupation (HMOs) (properties lived in by three to six people where facilities such as a kitchen or bathroom are shared) in the city. On 5 April 2013, an Article 4 Direction relating to HMOs (use class C4) came into force in five electoral wards within Brighton and 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.
| Decision | Percentage of Decisions |
|---|---|
| Approved | 55% |
| Refused | 45% |
| Of Those Refused Appealed | 41% |
| Of Those Appealed Allowed | 50% |
| Of Those Appealed Dismissed | 50% |
There have been 358 planning applications, for the change of use of a single dwelling house to a small HMO between April 2013 and March 2023 in the five wards where an Article 4 Direction took effect in April 2013 (Table 14). Of these, 198 were approved and 160 refused. Of those refused, 66 have been subject to an appeal, of which 33 appeals have been allowed.
| Decision | Percentage of Decisions |
|---|---|
| Approved | 72% |
| Refused | 28% |
| Of Those Refused Appealed | 72% |
| Of Those Appealed Allowed | 77% |
| Of Those Appealed Dismissed | 23% |
Between the implementation of the citywide Article 4 Direction, on 3 June 2020, and 31 March 2023 there have been 67 planning applications, 48 approved and 19 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 11 have been allowed.
Policy CP22 ‘Traveller Accommodation’ in City Plan Part One sets out the council’s approach to providing traveller accommodation based on assessments of local need.
An updated Gypsy and Traveller Accommodation Needs Assessment (GTAA) was published in 2019, details of which are outlined in the 2018 to 2019 AMR. A joint site search exercise undertaken by BHCC and the SDNPA in 2016 to 2017 did not identify any suitable and available sites. No neighbouring authorities have indicated any ability to assist in meeting the unmet need via the Duty to Cooperate process.
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:
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:
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.
Can change use class to:
Can change use class to a temporary or flexible SG (hot food takeaways) (until March 2022)
Can change use class to a permanent SG (Drinking establishment with expanded food provision).
Can change use class to a permanent SG (Public house, wine bar, or drinking establishment).
Can change use class to a permanent B8 (of no more than 500m²)
Can change use class to:
Can change use class to:
Can change use class to a permanent C3 of no more than 150m² (prior approval required)
Can change use class to:
Can change use class to a permanent:
Can change use class to a permanent C3 of no more than 150m² (prior approval required)
Can change use class to a permanent F1a (State funded School or registered nursery) of no more than 500m² (prior approval required)
This section summarises the development of employment floorspace in the city in 2022to 2023. Use classes for employment floorspace prior to September 2020 include:
Since September 2020, B1a, B1b and B1c have been replaced by Eg(i) (offices), Eg(ii)(research and development) and Eg(iii) (industrial processes).
The supply of employment land and premises is limited in the city. Policy CP3 ‘Employment Land’ of the City Plan Part One1(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 (Brighton & Hove City Council Housing and Employment Land Study, DLP 2017). 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 citywide windfall floorspace changes which are reported in the AMR.
| 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 |
There was an overall net loss of 10,110m² employment floorspace in 2022 to 2023 (Table 3). This included a net loss of 5,105m² of office space (3,458m² of new office space was provided while 8,563m² was lost to other uses).
The loss of office floorspace was primarily due to the completion of Crown House (prior approval loss of 5,437m² office floorspace) and Rayford House, Hove (prior approval change of use).
In addition, there was a net decrease in light industrial floorspace of 1,630m² which includes completions at Longley Industrial Estate (DA4.C.1 strategic allocation for mixed use allocation for 3,000 sq of office floorspace and residential).
There was a net gain of 3,023m² in storage and distribution mainly as a result of the new Southern Section Argus House completion on Crowhurst Road.
| Class | Gross change in floorspace | Loss change in floorspace | Net change in floorspace |
|---|---|---|---|
| B1a/Eg(i) | 3,458 | -8,563 | -5,105 |
| B1b/Eg(ii) | 0 | 0 | 0 |
| B1c/Eg(iii) | 0 | -1,630 | -1,630 |
| B2 | 0 | -1,078 | -1,078 |
| B8 | 4,557 | -1,534 | 3,023 |
| Mixed B/Eg | 3,270 | -8,590 | -5,320 |
| Total | 11,285 | -21,395 | -10,110 |
Part three 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 2022 to 2023, there was a loss of 4,415m² of employment floorspace on these sites. This was a result of the completion of Argus House on Crowhurst Road, Brighton, leading to a loss of mixed use employment floorspace but an increase in B8 storage space.
There was a net loss of 2309m² of employment floorspace within the Policy SA2 Central Brighton area, much of which (1,541m²) was attributed to the change of use from office to residential at three sites: 20 New Road, 2 Bartholomew’s, and Clarence House.
| Class | Net Floorspace Change (m² ) |
|---|---|
| B1a/Eg(i) | -11,416 |
| B1b/Eg(ii) | -668 |
| B1c/Eg(iii) | -4,136 |
| B2 | -11,003 |
| B8 | -2,560 |
| Mixed B/Eg Use | -6,580 |
| Total | -37,441 |
Table 5 outlines the changes in employment floorspace since 2010 to 2011. There has been a cumulative net loss of 37,441m² in employment floorspace since 2010 to 2011 (Table 4). There has been a 20,488m² loss of employment space over the past five years which represents an average annual net loss of 1,576m² of employment floorspace over that period.
| 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 |
| Total | -11,416 | -668 | -4,136 | -12,081 | -2,560 | -6,580 | -37,441 |
When all developments under commencement at the end of the monitoring year are completed, they will contribute to an 8,579m² net loss in employment space (Table 6).
| Class | Gross change in floorspace | Loss change in floorspace | Net change in floorspace |
|---|---|---|---|
| B1a/Eg(i) | 10,700 | -15,226 | -4,527 |
| B1b/Eg(ii) | 0 | 0 | 0 |
| B1c/Eg(iii) | 418 | -748 | -330 |
| B2 | 288 | 0 | -288 |
| B8 | 795 | -6,041 | -5,246 |
| Mixed B/Eg | 1,236 | 0 | 1,236 |
| Total | 13,437 | -22,015 | -8,579 |
A large proportion of the loss of office floorspace results from Preece House (-3,254m2). However, these losses will be partially mitigated by a speculative and purpose build Grade A four storey office building at 27-31 Church Street, Brighton (3625m2).
Planning applications approved in 2022 to 2023 are projected to result in a net loss of 5,934m² in employment floorspace if all developments are constructed. This figure includes a net loss of 4,207m² in office floorspace, with the change of use of 62-63 Old Steine and 3 Palace Place contributing to 1,189m² of that loss.
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 and is reflected in the 2022/23 monitoring year.
| 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 |
| Total | 604 | 34,293 |
Whilst these rights have facilitated an increase in residential development, they also result in a loss of office accommodation. It should be noted that the Class MA permitted development right is subjected to a threshold, capping the permissible loss at up to 1,500 sqm in a single building and requiring an office to be vacant for 3 months.
Since the introduction of permitted development rights, there has been a loss of 40,543m² of office space has been lost for the gain of 811 residential units. There was a significant increase in the completion of office to residential prior approval developments in 2022 to 2023, with 207 residential units completed for a loss of 6,250m² of office floorspace (this includes B1a and Eg(i) floorspace), the majority of this loss was due to the conversion of Crown House.
This section summarises the development of retail and non-retail ‘A use class’ floorspace in the city in 2022 to 2023. The use class for retail floorspace is:
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 retail3.
There was a net loss of 1,773m² in all shops, services and food and drink floorspace in 2022 to 2023 (Table 8). In terms of retail floorspace (A1/Ea), the net loss of 2,086² includes the change of use from the existing retail units at 118-132 London Road to a café. There was a higher net gain of shop, services and food and drink floorspace outside designated shopping centres in the city, identified in the City Plan (Table 9), in the monitoring year, than inside these centres. This was predominantly due to completions at mixed use developments including Edward Street and Preston Barracks.
| Class | Gross change in floorspace | Loss change in floorspace | Net change in floorspace |
|---|---|---|---|
| A1/Ea | 389 | -2,474 | -2,085 |
| A2/Ec | 742 | -180 | 562 |
| A3/Eb | 511 | -612 | -101 |
| A4/ SG (Drinking establishment) | 0 | 0 | 0 |
| A5/ SG (Takeaway) | 0 | 0 | 0 |
| Mixed A uses | 7 | -225 | -149 |
| Total | 1,719 | -3,492 | -1,773 |
| Use class | A1/Ea | A2/Ec | A3/Eb | A4/SG Drinking | A5/ SG Takeaway | Mixed incl A/Ea/Eb/Ec Use | Total |
|---|---|---|---|---|---|---|---|
| Within Designated Shopping Centre | -593 | -526 | -191 | 0 | 0 | 0 | -1,310 |
| Outside Designated Shopping Centre | -1,493 | 88 | 1090 | 0 | 0 | -149 | -410 |
| 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 |
| Total | -28,490 | -4,346 | 15,870 | -2,637 | 848 | 10,287 | -8,961 |
There has been a successive net loss of shop, services and food and drink floorspace, in the past five years after consistently increasing each year between 2010 to 2011 and 2016 to 2017. The monitoring year represented the third largest loss in the past ten years. There has been a total 26,404m² loss of retail floorspace since 2010 tp 2011. There has, however, been a year-on-year increase in mixed shop, services or food and drink floorspace with a total increase of 10,436m² since 2010 to 2011. There has also been a net gain in restaurant floorspace of 15,870m² since 2010 to 2011 (Table 10) including 899m² in the 2022 to 2023 monitoring year.
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 9,533m² net loss of floorspace.
A 3,260m² net loss of shops, services and food and drink floorspace was permitted in 2022 to 2023.
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 379m² loss of retail floorspace completed in 2022 to 2023 due to permitted development to residential through four applications, resulting in five new dwellings in total.
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.
There was a net gain of 5,352m² mixed use development floorspace, which includes a mix of shops, services, food, and drink uses or employment uses with other use classes in 2022 to 2023. This was predominantly due to completions at strategic development sites including Edward Street (DA5) and Preston Barracks (DA3).
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. Following the growth in non-residential institution (D1/Ee/Ef) floorspace over the past five monitoring years; 2022 to 2023 saw a further 903m² net increase of floorspace.
There was a net increase of 1,793² Assembly and Leisure floorspace (D2/F1/F2) in 2022 to 2023. This included completions of Brighton Hove And Sussex Sixth Form College, The Hyde, and the Studio Theatre on New Road.
The Brighton & Hove Visitor Accommodation Study Update 2018 forecasted a need for two 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). 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 no change to the number of hotel bedrooms in 2022 to 2023, however there was a net increase of 507 bedrooms under commencement at the end of the monitoring year primarily through applications to the rear of Hilton Brighton Metropole, and West Street in Brighton.
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 toward 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 will commence in 2024.
There are 480 Listed Buildings graded I and II* in the city.
There are 11 buildings graded I and II* on the current Historic England ‘At Risk’ Register in 2022, including five listed places of worship. This is an increase from 7 in 2013 to 2014. We are likely to have more additions to the buildings 'At Risk' register soon, for example the Royal Albion Hotel. The fire at the Royal Albion Hotel summer 2023 means that this building could also be added to the register as the building suffered significant damage.
Five of the 34 conservation areas in the city are currently included on the Historic England ‘At Risk’ register. These are:
We have just completed the consultation of the College Conservation Area Character Statement and hope to have this adopted in January 2023. These actions are important steps towards addressing the current threats in conservation areas.
Get more information about 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 2022 to 2023, 71% of new build residential completions were completed with a requirement for the standard to achieve a reduction in carbon emissions of 19% (see Table 1) and a water efficiency standard of not more than 110 litres per person per day maximum indoor water consumption.
| Completed new build dwellings | Percentage of completed dwellings | |
|---|---|---|
| Reduction in carbon emissions of 19% | 393 | 71% |
| No standard | 161 | 29% |
| Total units | 554 | 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 1169 new residential units permitted in 2022 to 2023, of which 66 units were new build, with 47% 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 2022 to 2023; 20% 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.
24% of new build residential applications approved with Sustainability checklist and completed in 2022 to 2023 incorporated green walls and roofs.
1.17 tonnes of greenhouse gases were emitted per capita from domestic buildings for energy provision in 2020; a reduction on 1.19 tonnes in 2019.
44% of new build residential and PDSA development, approved through a full planning application and completed in 2022 to 2023 provided cycle parking - creating 816 spaces.
12% of new build residential development, approved through a full planning application and completed in 2022 to 2023, included car free units - totalling 404 car free units.
An estimated 267.6 kilotonnes of transport related greenhouse gases was emitted in 2020 across the whole city. This is a reduction on 329 kilotonnes in 2019 .
£1,084,852 was secured through developer contributions towards the enhancement of open space or leisure in 2022 to 2023.
46% of local sites - sites designated locally for their substantive nature conservation importance, either for wildlife or geology - were in positive conservation management in 2022 to 2023. There was no data for 2019 to 2020 or 2020 to 2021 due to restrictions relating to the COVID-19 pandemic.
The average level of nitrogen dioxide showed an improvement at all three key recording sites in the city between 2019 and 2021. All measurements are in microgrammes per cubic metre (μg/m).
| Area | Target | 2019 | 2020 | 2021 |
|---|---|---|---|---|
| Lewes Road, Brighton | 40 μg/m | 26.9 μg/m | 18.9 μg/m | 18.3 μg/m |
| London Road, Brighton | 40 μg/m | 39.5 μg/m | 30.6 μg/m | 28.3 μg/m |
| High Street, Rottingdean | 40 μg/m | 32.7 μg/m | 28.4 μg/m | 26.6 μg/m |
All of our positive trends and targets were met.
30% of new build residential development approved through a full planning application indicated that Sustainable Urban Drainage systems would be incorporated into the development.
Brighton & Hove City Council is a Waste and Minerals Planning Authority and works in partnership with East Sussex County Council and the South Downs National Park Authority on waste and minerals planning policy. The three Authorities adopted the Waste and Minerals Plan in February 2013 and Waste and Minerals Sites Plan in February 2017. A review of the Waste and Minerals Plan is currently at the public examination stage, with a focus on the supply of minerals.
The main types of waste are:
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 AMR.
| 2016 to 2017 | 2017 to 2018 | 2018 to 2019 | 2019 to 2020 | 2020 to 2021 | 2021 to 2022 | 2022 to 2023 | |
|---|---|---|---|---|---|---|---|
| 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:
Brighton & Hove does not have any active mineral extraction sites and the level of production in East Sussex is exceptionally low by regional standards. Actual production figures are bound by confidentiality constraints, caused by commercial sensitivities due to the small number of operators in place.
National policy is to increase the use of secondary and recycled aggregates as an alternative to reducing reserves of primary aggregates and this is reflected in Waste and Minerals Plan Policy WMP36.
Background work undertaken indicates that capacity in the plan area for secondary and recycled aggregates is currently around 310,000 tonnes per annum. Current secondary and recycled aggregates facilities in the plan area and further explanation and detailed figures for East Sussex and Brighton & Hove can be found in the East Sussex Waste and Minerals AMR.
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 latest LAA was produced jointly with East Sussex County Council and the South Downs National Park Authority and published in May 2022.