Strategic Housing Land Availability Assessment (SHLAA)

1.1

This report presents the 2020 annual review of the council’s Strategic Housing Land Availability Assessment (SHLAA). 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 both specific:

• deliverable sites for years 1 to 5 of the plan period
• 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 need that local planning authorities should identify and update a supply of specific deliverable sites each year. These should be enough to provide at least five years’ housing against their housing need. This will be set out in adopted strategic policies, or against their local housing need where the strategic policies are more than five years old. 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 2020 SHLAA has taken account of the latest information on housing land supply in the city. The information included is set out below:

Annual monitoring of housing development with planning permission

• sites gaining planning consent for housing in the year from 1 April 2019 to 31 March 2020, including both newly identified sites and sites previously identified in the SHLAA which did not previously have planning consent
• 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;
• the type of residential development (whether new build, change of use or conversion); and
• the adjusted supply position where sites have been developed and completed.

Sites without planning permission that have identified housing potential

• 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 City Plan Part Two Proposed Submission which was published for consultation between 7 September and 30 October 2020.

Assessment of site availability, capacity and timescales

2.2

The availability, capacity and delivery timescale for all identified sites 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 BHCC Development Management, Housing and Estate Regeneration officers.

2.3

The availability and housing capacity of sites has been updated to reflect the housing site allocations proposed in the City Plan Part Two Proposed Submission. The assessment of 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.

3.1

Summary Tables 1 to 7 set out the results of the 2020 SHLAA. In overall terms, the SHLAA has identified a total housing land supply of around 17,829 housing units of which 15,151 units are projected to be deliverable by the end of the City Plan period in 2030. This projected housing supply would substantially exceed the 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 6,330 units within the eight City Plan Development Areas (DA1-DA8) (Table A) and a further 5,215 are across the rest of the city (Table B). The overall supply from sites of 6+ units therefore is 11,545 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 1,871 units, comprising 1,461 units completed in the period 2010-2020 and a further 410 units expected to be delivered on small sites with planning permission at 1 April 2020. This includes 171 units on sites which have commenced (already under construction) and 239 units on sites not yet started where a 10% 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 3 (2020-2023), with sites already commenced divided between Years 1 and 2, and sites where development has not yet started phased across Years 1 to 3.

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 2020 identifies a total of 429 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 300 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 42 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. Subtracting the total of 241 HRA units completed or permitted from the overall target of 500 homes gives an outstanding figure of 259 units on sites yet to be identified as shown in Table 4. A number of additional council owned sites are currently under consideration for housing development under the NHFN programme and the council is confident that at least 500 dwellings will be delivered. As additional sites come forward, they will be identified in the annual SHLAA updates. A breakdown of delivery from the NHFN programme is provided in Table E[1].

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 2015-2020 there was an average annual delivery of 157 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 (63%). 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 (2022/23) 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 Year 3 will include a mix of both existing small site permissions (not yet started) and windfall sites not yet identified. From Year 4 (2023/24) 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 to the end of the Plan period in 2030 and over the next 15 years to 2035.

5.1

The 2020 SHLAA Update has been used to update the 5 year housing land supply position. The calculation of five year housing supply is based on the Phased Requirement Method which is set out in the City Plan Part One Housing Implementation Strategy[1]. This approach was endorsed by the City Plan Part One examination inspector when finding the Plan sound in February 2016.

5.2

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, and that where there has been significant under delivery of housing over the previous three years, a 20% buffer should be included. It also states that from November 2018, the assessment of ‘significant under delivery’ will be based on the Housing Delivery Test, indicating that the 20% buffer will apply where housing delivery has been below 85% of the housing requirement over the past 3 monitoring years. Details of how the Housing Delivery Test will be calculated are set out in the Government’s Housing Delivery Test Measurement Rulebook.

5.3

At the current time, the Government has not published the Housing Delivery Test figures for the period 2017-2020. Applying the calculation methodology set out in the Housing Delivery Test Measurement Rule Book to the completions data for Brighton & Hove as supplied by the council to MHCLG in Autumn 2020[4] would give a housing delivery figure of around 104% against the City Plan housing requirement over the period 2017-2020. Since average completions over this period exceeded 85% of the City Plan minimum target, a 5% buffer should be applied to the five year housing land supply.

5.4

The current five year housing land supply position is summarised in the table below. The five year housing requirement has been adjusted to include the shortfall in housing delivery over the period 2014-2020 (1,142 units) and a 5% buffer, resulting in a requirement of 5,542 residential units over the period 2020-2025. As a result the adjusted housing requirement is now 1,108 residential units per year which is substantially higher than the annualised requirement set out in City Plan Part One.

5.5

The 2020 SHLAA Update shows a potential housing supply of 5,200 residential units over the period 2020 to 2025. 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.

5.6

As illustrated in the table below, comparison of the projected five year housing supply (5,200 units) with the five year housing requirement (5,542 units) indicates an overall five year housing shortfall of 342 residential units (equivalent to 4.7 years housing supply).

Five Year Housing Supply Requirement

Phased Requirement Method including 5% buffer

6.1

Housing Supply Summary Tables

Source Tables A, B and C.

Explanatory text can be found for this image in 3. 2020 SHLAA Update Results.

Explanatory text can be found for this image in 3. 2020 SHLAA Update Results.

6.2

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

Explanatory text can be found for this image in 3. 2020 SHLAA Update Results.

Explanatory text can be found for this image in 3. 2020 SHLAA Update Results.

6.3

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

Explanatory text can be found for this image in 3. 2020 SHLAA Update Results.

Explanatory text can be found for this image in 3. 2020 SHLAA Update Results.

Explanatory text can be found for this image in 3. 2020 SHLAA Update Results.

Explanatory text can be found for this image in 3. 2020 SHLAA Update Results.

6.4   

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

a. Small Identified Sites as at 1st April 2019

*Includes 10% non-implementation discount applied to small sites not yet started.

b. Assumed Delivery Phasing for Small Identified Sites

6.5

Table D: Prior Approvals for Conversion to Residential

a. Calculation of Supply from Prior Approvals

* Assumes 70% implementation rate

b) Outstanding Prior Approvals of 6+ Units

6.6

Table E: Housing Supply from Estate Regeneration Programme

Existing and projected housing delivery from HRA sites.

6.7

Table F: Small Site Windfall Allowance

a. Net Completions on Small Sites (<6 units) 2008-2018

Source: BHCC Residential Monitoring.

b. Average Net Completions on Small Sites

c. Assumed Five Year Supply from Small Windfall Sites

6.8

Chart A: Housing Trajectory