Strategic Housing Land Availability Assessment (SHLAA) Update 2021

1.1

This report presents the annual review of the council’s Strategic Housing Land Availability Assessment (SHLAA) for 2020/21. It incorporates the latest information regarding housing land supply in the city and presents an updated housing trajectory and five-year housing land supply position.

1.2

The purpose and role of the SHLAA is set out in the National Planning Policy Framework (NPPF) and accompanying Planning Practice Guidance (PPG) ; that is to identify a future supply of land which is suitable, available and achievable for housing over the local plan period. This involves identifying all sites with housing potential; assessing their potential for delivery taking account of identified constraints, availability, viability etc; and determining the likely amount of housing and timescale for development. The guidance recognises the SHLAA as an important part of the evidence base to inform plan-making, but notes that it does not in itself determine whether a site should be allocated for housing development.

1.3

A key output of the SHLAA is the preparation of an indicative trajectory setting out the potential future housing supply. The NPPF states that planning policies should identify a supply of:

• a) specific deliverable sites for years 1 to 5 of the plan period; and
• b) specific developable sites or broad locations for growth for years 6-10 and, where possible, for years 11-15 of the plan.

1.4

The NPPF sets a requirement that local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement set out in adopted strategic policies. Where the strategic policies are more than five years old, local housing need should be calculated using the standard method as set out in national guidance . The supply of specific deliverable sites should, in addition, include a buffer (moved forward from later in the plan period) of 5% to ensure choice and competition in the market for land. Where there has been significant under delivery of housing over the previous three years, a 20% buffer should be included to improve the prospect of achieving the planned supply. The NPPF indicates that past delivery will be measured through the Housing Delivery Test (which is discussed in further detail in Section 5 of this report). Further information on the approach that should be taken to assessing housing supply and delivery is provided in Planning Practice Guidance (PPG).

1.5

The council’s approach set out in this SHLAA meets the NPPF requirements and is set out in detail below.

2.1

The 2021 SHLAA has taken account of the latest information on housing land supply in the city. The information included is set out below.

• a) Annual monitoring of housing development with planning permission
  • i) Sites gaining planning consent for housing in the year from 1 April 2020 to 31 March 2021, including both newly identified sites and sites previously identified in the SHLAA which did not previously have planning consent;
  • ii) Updated progress on previously identified sites with planning consent recording whether development on the site has yet to commence, is under construction, or has been completed;
  • iii) The type of residential development (whether new build, change of use or conversion); and
  • iv) The adjusted supply position where sites have been developed and completed.
• b) Sites without planning permission that have identified housing potential
  • i) Sites without planning permission that are allocated for housing in the City Plan, or have been assessed as suitable, available and achievable for housing. This includes sites that have been promoted through the council’s pre-application advice service or have been submitted for consideration by landowners, agents and/or developers and sites in response to a ‘call for sites’ (e.g. as part of the update for the Brownfield Land Register). The SHLAA includes all sites allocated for housing in City Plan Part One or proposed for allocation in City Plan Part Two Proposed Submission which was submitted to the Secretary of State for examination in May 2021 with examination hearings taking place in November 20216.

Assessment of site availability, capacity and timescales

2.2

The availability, capacity and delivery timescale for all identified sites of 6 or more dwellings (net gain) has been reviewed as part of the SHLAA update to take account of further information received during the monitoring year from landowners, agents and/or developers. On sites with planning permission which have not commenced or where development has stalled, the relevant developers/agents have been contacted by the council requesting updated information. Discussion has also been undertaken with relevant council officers (e.g with BHCC Development Management, Housing and Estate Regeneration officers).

2.3

The availability and housing capacity of sites has been updated to reflect updates to the housing site allocations proposed in the City Plan Part Two Proposed Submission following Regulation 19 consultation in September to October 2020 and further amendments proposed by the Council before and during the examination hearings. The assessment of potential delivery timescales and rates of housing delivery have also been informed by analysis of historic delivery rates for residential developments completed over the past decade.

Assessment of implementation rates and discounting

2.4

The assumptions relating to implementation rates for developments not yet started on small sites with planning permission (<6 units net gain) and large sites with Prior Approval for permitted development (+6 units net gain) have been reviewed as part of this SHLAA update. 

As set out in Paragraphs 2.2 and 2.3, all large identified sites (6+ units net gain) with planning permission or otherwise identified in the SHLAA have been assessed on an individual site by site basis and therefore no further discounting has been applied to these sites.

This review has taken into account past implementation rates for those types of permission in order to provide updated evidence to underpin assumptions about implementation rates and levels of discounting that should be applied.

2.5

For developments on small sites overall implementation rates were calculated to be around 70 percent and therefore the non-implementation discount for small sites has been adjusted to 30 percent. The analysis has also informed the expected development lead times for the identified supply of small sites. For large sites with Prior Approval the implementation rate was calculated as around 70 percent, therefore the non-implementation discount will continue to be set at 30 percent as in previous SHLAAs.

3.1

Summary Tables 1 to 7 set out the results of the 2021 SHLAA. In overall terms, the SHLAA has identified a total housing land supply of around 17,607 housing units of which 14,566 units are projected to be deliverable by the end of the City Plan period in 2030. This projected housing supply substantially exceeds the minimum target of 13,200 homes set out in Policy CP1 of City Plan Part One. Large Identified Sites (6+ units net gain)

3.2

Summary Tables 1 and 2 indicate the potential supply from sites of 6 units and above. Over the City Plan period to 2030, there is an identified supply of 6,240 units within the eight City Plan Development Areas (DA1-DA8) (Table A) and a further 5,231 are across the rest of the city (Table B). The overall supply from sites of 6+ units therefore is 11,471 units. Small Identified Sites (<6 units net gain)

3.3

Summary Table 3 sets out the supply expected from small identified sites, which includes small sites already completed and those with current planning permission. The total identified supply from small sites is 2,032 units, comprising 1,612 units completed in the period 2010-2021 and a further 420 units expected to be delivered on small sites with planning permission at 1 April 2021. This includes 160 units on sites which have commenced (already under construction) and 260 units on sites not yet started where a 30% discount for non-implementation has been assumed (Table C). As shown in Table C, housing delivery from the small identified sites has been assumed to take place over Years 1 to 4 (2021-2025), with sites already commenced divided between Years 1 and 2, and sites where development has not yet started phased across Years 1 to 4.

Other Sources of Housing Supply

3.4

Summary Table 4 indicates the potential additional housing supply from two further sources, firstly Prior Approvals for change of use to residential under permitted development rights and secondly the council’s Estate Regeneration Programme (‘New Homes for Neighbourhoods’).

3.5

The SHLAA Update 2021 identifies a total of 214 net residential units with Prior Approval for change of use to residential (Class C3) under permitted development rights (i.e without the need to apply for planning permission). To account for potential non-implementation, a 30% discount has been applied to this figure, giving a revised estimate of 150 additional residential units expected to be delivered from this source (Table D).

3.6

The council’s Housing Revenue Account (HRA) Estate Regeneration Programme known as ‘New Homes for Neighbourhoods’ (NHFN) was endorsed by the council in March 2013 and has a target to deliver 500 affordable homes on council-owned sites throughout the city. A total of 199 units have been completed on HRA sites, and a further 72 units have planning permission and are projected for delivery in Years 1-5. The HRA sites which have been completed, have planning permission, or have been identified for development are included in SHLAA Tables A and B. There are a further 389 units identified on HRA sites for delivery in Years 6-9. Subtracting the total number of units under the NHFN programme which have been completed, permitted or identified from the overall target of 500 homes illustrates that the number of units identified now exceeds the delivery target. Therefore, no additional allowance for the HRA programme has been included in the housing supply figures. As additional sites come forward, they will continue to be identified in the annual SHLAA updates. A breakdown of delivery from the NHFN programme is provided in Table E. Small Site Windfall Allowance (less than 6 net units)

3.7

Table 6 identifies the supply estimated to come from small unidentified sites of less than 6 net units (‘small windfall sites’) over the next 15 years. The NPPF allows for windfall sites to be included as part of projected housing figures where there is compelling evidence that they will provide a reliable source of supply. It states that such allowance should be realistic having regard to the strategic housing land availability assessment, historic windfall delivery rates and expected future trends.

3.8

Table F illustrates how the windfall allowance has been calculated for small sites. The estimated windfall supply is based on average delivery on small sites of less than 6 net units over the past 5 years. Over the period 2016-2021 there was an average annual delivery of 149 units per year on small sites. For comparison, the average delivery over the past 10 years (2010-2020) was slightly lower averaging 145 units per year. These figures indicate that small sites have consistently provided an important component of the city’s housing supply, and this supply shows no sign of decreasing. The analysis shows that a large majority of small windfall development takes place through conversions and changes of use (62%). It is difficult to anticipate where these types of developments are likely to arise and therefore small site development cannot realistically be identified on a site-by-site basis as is the case for larger sites of 6+ units. For these reasons, the inclusion of a windfall allowance for small sites is considered to be supported by robust evidence.

3.9

To avoid double counting with small sites which already have planning permission (those included in Table C), allowance for small site windfall has only been included in the housing supply from Year 3 (2023/24) onwards. As shown in Table F, it is assumed the small site completions in Years 1 and 2 will comprise sites which already have planning permission (commenced and not yet started) and that completions in Years 3 and 4 will include a mix of both existing small site permissions (not yet started) and windfall sites not yet identified. From Year 5 (2025/26) onwards, an annual small site windfall allowance of 149 units per year has been included in the housing supply figures.

4.1

Chart A presents a housing trajectory based on the sources of housing supply listed above. The housing trajectory shows the annual net housing completions since the start of the City Plan period in 2010 and the projected annual housing delivery to the end of the Plan period in 2030 and over the next 15 years to 2036.

5.1

The 2021 SHLAA Update has been used to update the five-year housing land supply position. In previous updates to the SHLAA the calculation of five-year housing supply was based on the Phased Requirement Method which is set out in the City Plan Part One Housing Implementation Strategy. This approach was endorsed by the City Plan Part One examination inspector when finding the Plan sound in February 2016 .

5.2

However, on 24 March 2021 the City Plan Part One reached five years since adoption. National planning policy states that where strategic policies are more than five years old, local housing need calculated using the Government’s standard method (paragraph 74) should be used in place of the local plan housing requirement. In addition, following an amendment to the standard method set out in national planning practice guidance, from 16 June 2021 onwards Brighton & Hove is required to apply an additional 35% uplift as one of the top 20 cities in the urban centres list.

5.3

The local housing need requirement using the standard method for the 2021 SHLAA Update, therefore, takes into account both the local housing need figure of 1,712 homes per year until 16 June 2021 and the figure of 2,311 homes per year, reflecting the 35% uplift, for the remainder of the five-year period.

5.4

The NPPF states that the five-year supply of deliverable sites should include a buffer (moved forward from later in the plan period) of 5% to ensure choice and competition in the market for land. Where there has been significant under delivery of housing over the previous three years, as indicated by a Housing Delivery Test figure under 85% when measured against the housing requirement, a 20% buffer should be included. Details of how the Housing Delivery Test is calculated are set out in the Government’s Housing Delivery Test Measurement Rulebook.

5.5

The Housing Delivery Test figure for the period 2018-2021 was published by the Government in January 2022 and gives a housing delivery figure of 136% against the City Plan housing requirement over that period21 . Since average completions over this period exceeded 85% of the City Plan minimum target a 5% buffer has been applied to the five-year housing land supply.

5.6

The current five-year housing land supply position is summarised in Table G. In accordance with national policy this has been calculated based on the housing need figure using the Government’s standard method. This method, including a 5% buffer produces a five-year housing requirement of 12,002 residential units over the period 2021-2026. As a result the adjusted housing requirement is now 2,400 residential units per year which is substantially higher than the annualised requirement set out in City Plan Part One and also much higher than the annualised requirement set out in previous SHLAA Updates.

5.7

The 2021 SHLAA Update shows a potential housing supply of 5,087 residential units over the period 2021-2026. The sources of supply that make up this figure are set out in Summary Tables 1-7, whilst Tables A and B show the projected delivery and phasing of individual sites of 6+ units that fall within the first five years.

5.8

As illustrated in Table G, comparison of the projected five-year housing supply (5,087 units) with the five-year housing requirement (12,400 units) indicates an overall fiveyear housing shortfall of 6,915 residential units (equivalent to 2.1 years housing supply).

5.9

Although the City Plan housing requirement has been superseded it is still useful to compare with the five-year supply of deliverable sites in order to measure the performance of the Plan. Table H illustrates the five-year housing supply against the City Plan Requirement using the Phased Requirement Method. The requirement, as set out in the City Plan Part One Housing Implementation Strategy, has been adjusted to include the shortfall in housing delivery over the period 2014-2021 (1,445 units) and a 5% buffer, resulting in a City Plan requirement of 5,787 residential units over the period 2021-2026. As a result the adjusted City Plan housing requirement has increased to 1,157 residential units per year; substantially higher than the annualised requirement set out in City Plan Part One.

5.10

Comparing the projected five-year housing supply (5,087 units) against the phased City Plan requirement (5,787 units) (Table H) indicates a shortfall of 699 residential units over the five-year period against the City Plan.

Five Year Housing Supply Requirement

Table G: Five Year Housing Supply Requirement: Standard Method including 5% Buffer

Table H: Five Year Housing Supply against City Plan Requirement: Phased Requirement Method including 5% Buffer

6.1 Housing Supply Summary Tables

Summary Tables 1 to 7 set out the results of the 2021 SHLAA and provide a summary of the calculations in Tables A to F.

Overall the SHLAA has identified a total housing land supply of 17,607 housing units of which 14,566 units are projected to be deliverable by the end of the City Plan period in 2030.

This projected housing supply substantially exceeds the minimum target of 13,200 homes set out in Policy CP1 of City Plan Part One.

Download the Summary tables.

6.2 Table A: Identified Housing Supply (6+ Units) in Development Areas (DAs)

The potential supply from sites of 6 units and above within the 8 City Plan Development Areas (DA1 to DA8). Over the City Plan period to 2030, there is an identified supply of 6,240 units within these Areas.

Download Table A.

6.3 Table B: Identified Housing Supply (6+ Units) outside Development Areas

The potential supply from sites of 6 units and above across the rest of the city (outside the City Plan Development Areas). Over the City Plan period to 2030, there is an identified supply of 5,231 units across the rest of the city.

Download Table B.

6.4 Table C: Small Identified Sites (<6 units net)

a) Small Identified Sites as at 1 April 2021

Adjusted units includes 30% non-implementation discount applied to small sites not yet started.

6.5 Table D: Prior Approvals for Conversion to Residential

a) Calculation of Supply from Prior Approvals (> 6 Units)

Total with 30% Discount assumes 70% implementation rate

b) Outstanding Prior Approvals (> 6 Units)

6.6 Table E: Housing Supply from Estate Regeneration Programme

Existing and projected housing delivery from HRA sites

Delivery target: 500

Unidentified delivery is the required number of units to meet delivery target now identified in tables A and B

6.7 Table F: Small Site Windfall Allowance

a) Net Completions on Small Sites (<6 units) 2010-2021

Source: BHCC Residential Monitoring.

b) Average Net Completions on Small Sites

c) Assumed Five Year Supply from Small Windfall Sites

Projected annual small site completions

6.8 Chart A: Housing Trajectory

Housing Trajectory Revised Position 2021

The graph represents a housing trajectory based on the sources of housing supply summarised in Summary Tables 1 to 7.

The housing trajectory shows the annual net housing completions since the start of the City Plan period in 2010 and the projected annual housing delivery to the end of the Plan period in 2030 and over the next 15 years to 2036.