Strategic Housing Land Availability Assessment (SHLAA) Update 2022

1.1

This report presents the annual review of the council’s Strategic Housing Land Availability Assessment (SHLAA) for 2021 to 2022. It incorporates the latest information regarding housing land supply in the city and presents an updated housing trajectory and 5 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
• 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 to 10 and, where possible, for years 11 to 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 5 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. 

2.1

The 2022 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 2021 to 31 March 2022, 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)n 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’ - for example, 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 the draft City Plan Part Two which was submitted to the Secretary of State for examination in May 2021 with examination hearings taking place in November 2021 and proposed Main Modifications published in March 2022. 

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 (for example, with Brighton & Hove City Council Development Management, Housing and Estate Regeneration officers).  

2.3

The availability and housing capacity of sites reflect 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 which were published for consultation as Proposed Main Modifications in March 2022. 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) were reviewed as part of the SHLAA 2022 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 took 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 is set at 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 is set at 30 percent.

3.1

Summary Tables 1 to 7 set out the results of the 2022 SHLAA. In overall terms, the SHLAA has identified a total housing land supply of around 17,976 housing units of which 13,818 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 5,577 units within the 8 City Plan Development Areas (DA1 to DA8) (Table A) and a further 5,103 are across the rest of the city (Table B). The overall supply from sites of 6+ units therefore is 10,680 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 2,167 units, comprising 1,760 units completed in the period 2010 to 2022 and a further 407 units expected to be delivered on small sites with planning permission at 1 April 2022. This includes 205 units on sites which have commenced (already under construction) and 202 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 (2022/2023 to 2025/2026), 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 2 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 2022 identifies a total of 246 net residential units with Prior Approval for change of use to residential (Class C3) under permitted development rights (meaning 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 172 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 to 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. A further 389 units have been identified on sites which will potentially form part of the NHFN programme, including at Moulsecoomb Hub where a planning application has been submitted and is under consideration. 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 2017/2018 to 2021/2022, there was an average annual delivery of 150 units per year on small sites. For comparison, the average delivery over the past 10 years (2012/2013 to 2021/2022) was slightly lower averaging 143 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 (2024 to 2025) 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 (2026 to 2027) onwards, an annual small site windfall allowance of 150 units per year has been included in the housing supply figures.   

4.1

The trajectory table presents a housing trajectory based on the sources of housing supply. 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 2037.  

5.1

The 2022 SHLAA update has been used to update the 5 year housing land supply position. In previous updates to the SHLAA, the calculation of 5 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 5 years since adoption. National planning policy states that where strategic policies are more than 5 years old, local housing need calculated using the government’s standard method 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. The local housing need requirement calculated using the standard method (including the 35% uplift) is 2,328 homes per year. 

5.3

The NPPF states that the 5 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 3 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. 

5.4

At the current time, the government has not published the Housing Delivery Test figures for the period 2019 to 2022. Applying the calculation methodology set out in the Housing Delivery Test Measurement Rule Book to the completions data for Brighton & Hove submitted by the council to DLUHC in Autumn 2022 (the housing completions figures include adjustments for net student and other communal accommodation in accordance with the Housing Delivery Test Measurement Rule Book) would give a housing delivery figure of around 109% against the housing requirement over the period 2019 to 2022. Since average completions over this period exceeded 85% of the City Plan minimum target a 5% buffer has been applied to the 5 year housing land supply.  

5.5

The current 5 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 5 year housing requirement of 12,222 residential units over the period 2022 to 2027. As a result the adjusted housing requirement is now 2,444 residential units per year which is substantially higher than the annualised requirement in City Plan Part One.  

5.6

The 2022 SHLAA Update shows a potential housing supply of 4,511 residential units over the period 2022 to 2027. The sources of supply that make up this figure are set out in Summary Tables 1 to 7, whilst Tables A and B show the projected delivery and phasing of individual sites of 6+ units that fall within the first 5 years.  

5.7

As illustrated in Table G, comparison of the projected 5 year housing supply (4,511 units) with the 5 year housing requirement (12,222 units) indicates an overall 5 year housing shortfall of 7,711 residential units (equivalent to 1.8 years housing supply).  

5.8

Although the City Plan housing requirement is now considered out of date for the purposes of calculating housing land supply, it is still useful to compare with the 5 year supply of deliverable sites in order to measure the performance of the Plan.

Table H illustrates the 5 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 cumulative shortfall in housing delivery over the period 2014 to 2022 (1,302 units) and a 5% buffer, resulting in a City Plan requirement of 5,408 residential units over the period 2022 to 2027. The adjusted City Plan annual housing requirement is now 1,082 residential units per year, which is substantially higher than the annualised requirement set out in City Plan Part One. 

5.9

Comparing the projected 5 year housing supply (4,511 units) against the phased City Plan requirement (5,408 units) (Table H) indicates a shortfall of 897 residential units over the 5 year period against the City Plan (equivalent to 4.2 years housing supply).  

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 2022 SHLAA and provide a summary of the calculations in Tables A to F.

In overall terms, the SHLAA has identified a total housing land supply of 17,976 housing units of which 13,818 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 Summary tables 1 to 7.

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 5,577 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 5,103 units across the rest of the city 

Download Table B.

6.4

Table C: Small identified sites (<6 units net)

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 2,167 units, comprising 1,760 units completed in the period 2010 to 2022 and a further 407 units expected to be delivered on small sites with planning permission at 1 April 2022.

This includes 205 units on sites which have commenced (already under construction) and 202 units on sites not yet started where a 30% discount for non-implementation has been assumed.

As shown in Table C, housing delivery from the small identified sites has been assumed to take place over Years 1 to 4 (2022 to 2026), with sites already commenced divided between Years 1 and 2, and sites where development has not yet started phased across Years 1 to 4. 

a) Small identified sites as at 1 April 2022

*30% non-implementation discount applied to small not started sites

b) Projected phasing of completions on small identified sites

6.5

Table D: Other windfall: Prior approval applications

Indicates the potential additional housing supply from sites with prior approval for change of use to 6 or more residential units (Class C3) under permitted development rights (without the need to apply for planning permission). A total of 246 potential net residential units is identified.

To account for potential non-implementation, a 30% discount has been applied to this figure, giving a revised estimate of 172 additional residential units expected to be delivered from this source.

a) Calculation of supply from prior approvals (> 6 units)

* Assumes 70% implementation rate.

b) Outstanding prior approvals of 6+ units

Planning status: not started 2021/2022

6.6

Table E: HRA Estates New Homes for Neighbourhood Programme

Provides a breakdown of delivery and potential additional housing supply from the council’s Housing Revenue Account (HRA) Estate Regeneration Programme known as ‘New Homes for Neighbourhoods’ (NHFN).

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 to 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.

A further 389 units have been identified on sites which will potentially form part of the NHFN programme, including at Moulsecoomb Hub where a planning application has been submitted and is under consideration. 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.

Existing and projected housing delivery from HRA sites

Delivery target: 500

Required number of units to meet delivery target now identified in tables A and B.

6.7

Table F: Small sites windfall allowance 

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. Table F illustrates how the windfall allowance has been calculated for small sites.

a) Illustrates previous net completions on small sites between 2010 to 2022. 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.

b) Illustrates the average net completions on small sites over the past 5 and 10 years. The estimated windfall supply is based on average delivery over the past 5 years. Over the period 2017 to 2022 there was an average annual delivery of 150 units per year on small sites. The average delivery over the past ten years is included for comparison and was slightly lower averaging 143 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.

c) lllustrates the assumed 5 year supply from small windfall sites. Allowance for small site windfall has only been included in the housing supply from Year 3 (2024/25) onwards to avoid double counting with small sites which already have planning permission (those included in Table C). 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 (2026/2027) onwards, an annual small site windfall allowance of 150 units per year has been included in the housing supply figures.  

a) Net completions on small sites (<6 units) 2010 to 2022

Source: Brighton & Hove City Council residential monitoring.  

b) Average net completions on small sites

c) Assumed 5 year supply from small windfall sites

Projected annual small site completions

Housing trajectory revised position 2022

Chart A is graph representing 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 2037.