Strategic Housing Land Availability Assessment (SHLAA) Update 2024

1.1

This report presents the annual review of the council’s Strategic Housing Land Availability Assessment (SHLAA) for 2023/24. It sets out the city’s housing land supply, housing trajectory and five-year housing land supply position. 

1.2

The purpose of the SHLAA 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 such as availability and viability;
• and determining the likely amount of housing and timescale for development.

 The SHLAA is an important part of the evidence base to inform the preparation of the City Plan 2041, but inclusion in it does not provide a judgement on 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 and beyond. 

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. 

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. Significant under-delivery is considered to be housing delivery below 85% of the housing requirement, as measured by the Housing Delivery Test. 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). Planning Practice Guidance (PPG) provides further information on the approach that should be taken to assessing housing supply and delivery.

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 2024 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 2023 to 31 March 2024, 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’ (for example, as part of the update for the Brownfield Land Register, or the recent City Plan 2041 Key Issues consultation). The SHLAA includes all sites allocated for housing in City Plan Part One (adopted March 2016) and City Plan Part Two (adopted October 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 to take account of any further information received 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. 

2.3

The availability and housing capacity of sites takes account of existing planning policy relating to minimum densities and any assessment work undertaken by council officers, as well as planning applications and permissions granted, and site details submitted for a ‘Call for Sites’ or Brownfield Land Register. The potential delivery timescales and rates of housing delivery has 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 (less than 6 units net gain) and large sites with Prior Approval for permitted development (6 or more units net gain) were reviewed as part of the SHLAA update in 2022. (As set out in Paragraphs 2.2 and 2.3, all large, identified sites 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 considered 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 as also calculated to be around 70 percent, so a 30 percent non-implementation discount has again been applied.

3.1 

Summary Tables 1 to 7 set out the results of the 2024 SHLAA. In overall terms, the SHLAA has identified a total housing land supply of around 19,767 housing units of which 13,907 units are projected to be deliverable up to 2041. 

Large Identified Sites (6 or more units net gain) 

3.2

Summary Tables 1 and 2 indicate the potential supply from sites of 6 units and above. Up to 2041, there is an identified supply of 8,671 units within the eight City Plan Development Areas (DA1-DA8) (Table A) and a further 6,343 units are across the rest of the city (Table B). The overall supply from sites of 6 or more units therefore is 15,014 units. 

Small Identified Sites (less than 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 2,363 units, comprising 2,103 units completed in the period 2010 to 2024 and a further 260 units expected to be delivered on small sites with planning permission on 1 April 2024.

This includes 115 units on sites which have commenced (already under construction) and 145 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 (2024-2025 to 2027-2028), 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 2024 identifies a total of 162 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 113 additional residential units expected to be delivered from this source (Table D12). 

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 had a target to deliver 500 affordable homes on council-owned sites throughout the city A breakdown of delivery from the NHFN programme is provided in Table E13. 

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 F14 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 2019-2020 to 2023-2024, there was an average annual delivery of 157 units per year on small sites. For comparison, the average delivery over the past 10 years (2014-2015 to 2023-2024) was the same averaging 157 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 (61%). It is difficult to anticipate where these types of developments are likely to arise and therefore small site development are not identified on a site-by-site basis. For these reasons, the inclusion of a windfall allowance for small sites is appropriate. 

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 (2026 to 2027) 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 (2028 to 2029) onwards, an annual small site windfall allowance of 157 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 over the next 17 years up to 2041.

5.1 

The 2024 SHLAA Update has been used to update the five-year housing land supply position. For the five years immediately following adoption of the City Plan Part One in March 2016, 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 should be used in place of the local plan housing requirement. The local housing need requirement calculated using the standard method is 2,498 homes per year.

5.3

The NPPF requires the five-year supply calculation to include a 20% buffer where delivery has fallen below 85% of the housing requirement over the previous three years as measured by the Housing Delivery Test. The most recent published Housing Delivery Test figures for the period 2019 to 2022 show a housing delivery figure of 84% for Brighton & Hove which means a 20% buffer is added to the five-year housing land requirement to produce a requirement of 14,988 residential units over the period 2024-2029.

5.4

The current five-year housing land supply position is summarised in Table G. There is a potential housing supply of 4,345 residential units over the period 2024-2029. 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 or more units that fall within the first five years. 

5.5 

Below is calculated the projected five-year housing supply (4,345 units) with the five-year housing requirement (14,988 units) indicates an overall five-year housing shortfall of 10,643 residential units (equivalent to 1.4 years housing supply).

Five-Year Housing Supply Requirement 

• Five-year Requirement 2024-2025 to 2028-2029 (based on 2,498 dpa): 12,490 residential units
• Five-Year Requirement with 20% buffer 2024 to 2029: 14,988 residential units
• Annualised Requirement: 2,998 residential units
• Deliverable Housing Supply 2024 to 2029
  • supply identified in 2024 SHLAA: 3,947 residential units
  • other windfall sources: 397 residential units 
• Total Supply: 4,345 residential units
• Surplus/Shortfall against Requirement: -10,643 residential units (1.4 years supply)

6.1 Housing Supply Summary Tables

Summary Tables 1 to 7 set out the results of the 2024 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 19,767 housing units of which 13,907 units are projected to be deliverable up to 2041.

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 eight City Plan Development Areas (DA1-DA8). Up to 2041, there is an identified supply of 8,671 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). Up to 2041, there is an identified supply of 6,343 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 2,363 units, comprising 2,103 units completed in the period 2010 to 2024 and a further 260 units expected to be delivered on small sites with planning permission at 1 April 2024. This includes 115 units on sites which have commenced (already under construction) and 145 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 (2024 to 2028), with sites already commenced divided between Years 1 and 2, and sites where development has not yet started phased across Years 1 to 4. 

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

6.5 Table D: Prior Approvals for Conversion to Residential

Indicates the potential additional housing supply from sites with Prior Approval for change of use to six or more residential units (Class C3) under permitted development rights (i.e without the need to apply for planning permission). 

A total of 162 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 113 additional residential units expected to be delivered from this source.

Total assumes 70% implementation rate

Total sites: 162

6.6 Table E: Housing Supply from Estate Regeneration Programme

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 had a target to deliver 500 affordable homes on council-owned sites throughout the city. 

A breakdown of delivery from the NHFN programme is provided in Table E.

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

6.7 Table F: Small Site 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 2010-2024. The analysis shows that a large majority of small windfall development takes place through conversions and changes of use (61%). 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 five and ten years. The estimated windfall supply is based on average delivery over the past 5 years. Over the period 2019-2024 there was an average annual delivery of 157 units per year on small sites. The average delivery over the past ten years is included for comparison and was the same averaging 157 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 five year supply from small windfall sites. Allowance for small site windfall has only been included in the housing supply from Year 3 (2026/27) 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 (2028/29) onwards, an annual small site windfall allowance of 157 units per year has been included in the housing supply figures.

Average small site completions over past 5 years - 157

6.8 Table G: Five Year Housing Supply Requirement: Standard Method

Describes the updated five-year housing land supply position calculated using the Government’s standard method. For the five years immediately following adoption of the City Plan Part One in March 2016, 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.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 should be used in place of the local plan housing requirement. The local housing need requirement calculated using the standard method is 2,498 homes per year. 

The NPPF requires the five-year supply calculation to include a 20% buffer where delivery has fallen below 85% of the housing requirement over the previous three years as measured by the Housing Delivery Test. The most recent published Housing Delivery Test figures for the period 2020-2023 show a housing delivery figure of 84% for Brighton & Hove which means a 20% buffer is added to the five-year housing land requirement to produce a requirement of 14,988 residential units over the period 2024 to 2029.

The current five-year housing land supply position is summarised in Table G. There is a potential housing supply of 4,345 residential units over the period 2024to 2029. 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.

Table G calculates the projected five-year housing supply (4,345 units) with the five-year housing requirement (14,988 units) indicates an overall five-year housing shortfall of 10,643 residential units (equivalent to 1.4 years housing supply).

Surplus/Shortfall against Requirement: -10,643

Years Supply: 1.4

6.9 Chart A: Housing Trajectory

A 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 over the next 17 years up to 2041.