Brighton & Hove City Plan Part 1 Schedule of Main … & Hove City Plan Part 1 Main Modifications...

Brighton & Hove City Plan Part 1 Main Modifications Schedule V3 7 October 2013

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Brighton & Hove City Plan Part 1 Schedule of Main Modifications

The modifications below are expressed in the conventional form of strikethrough for deletions and underlining for additions of text. The page numbers and paragraph numbering below refer to the submission Core Strategy, and do not take account of the deletion or addition of text. Please note changes since V1 of this document are as follows;

• Further modification to policy CP21 as at 17th September 2013, please see modification reference MM42 (page 18)

• Further modifications made 7th October Ref Policy/

Paragraph Main Modification

MM1 Paragraph 1.4 and Footnote reference 2, Page 5

• Waste and Minerals Local Plan – the council… is preparing a Waste and Minerals Local Plan…

Footnote 2 - Waste and Minerals Core Strategy is anticipated to be adopted March 2013.The East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan was adopted 19 February 2013 and work has commenced on a waste and minerals sites plan.

MM2 Paragraph 1.4 Table 1, Page 5

Delete table 1: Table 1 City Plan Part 1 Preparation Timetable Stage

Date

Reg 18: Options Consultation

October-November 2011

Reg 18: Draft City Plan Consultation

May - July 2012

Publication of the Document

February – April 2013

Date for submission to Secretary of State

May 2013

Pre-examination meeting with Inspector

July 2013

Examination in Public (estimated)

September 2013

Estimated date for adoption by the council

February 2014

MM3 Paragraph 1.6, page 5

Delete paragraph 1.6: 1.6 The Localism Act sets out the government's intention to revoke regional spatial strategies. lt is acknowledged that any move to revoke existing


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regional strategies is subject to the outcome of the consultation on the related environmental assessment (SEA of Revocation of the South East Regional Strategy Environment Report) which was published 11 October 2012. The South East Plan remains part of the list of documents which local authorities must have regard to when preparing their development plans until the government orders revoking the existing Regional Plans are published and take effect. Therefore although it is considered that the draft City Plan remains in conformity with the South East Plan, it is not referred to explicitly within the City Plan.

MM4 Paragraph 1.7, Page 6

Brighton & Hove provides jobs, entertainment, shops and leisure, health and education facilities for people living in neighbouring areas. The city is a regionally significant retail and visitor economy destination and a transport hub

MM5 Footnote 4, Page 7

Footnote 4: Brighton & Hove City Plan Part 1 Duty to Cooperate Compliance Statement December 2012 June 2013

MM6 Table 3, paragraph 2.23, Page 31

Amend Table 3: Table 3 Summary of Development proposals New

Homes New Employment Floorspace (sq m)

New Retail floorspace (sq m net)

DA1 Brighton Centre and Churchill Square

20 Minimum 20,000 comparison goods

DA2 Brighton Marina

1940 2,000 5,000

DA3 Lewes Road

810 15,600

DA4 New England Quarter and London Road

1185 20,000

DA5 Eastern

470 18,200 – 223,200


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Road and Edward Street DA6 Hove Station

630 1,000

DA7 Toad’s Hole Valley

700 25,000

DA8 Shoreham Harbour

400 7,500

Rest of the City

3945 11,2571

Small site development2

1250

Total 11,350 100,500 to 105,500

25,000

MM7 DA2 Brighton

Marina, Gas Works and Black Rock Area Page 41-43

DA2. B. Provision will be made for the following amounts of additional development to be provided by 2030: 1,940 1,938 residential units (including the 853 residential units already granted planning permission for the outer harbour, 1000 residential units allocated for the inner harbour and 85 residential units allocated for the Gas Works site); DA2.C.1. Brighton Marina Inner Harbour Provision is made for a mixed use development comprising a minimum of 1,000 residential units (excluding the outer harbour scheme), 5,000 sq m of retail development (A1-A5), 3,500 sq m of leisure and recreation use, community facilities (including health facility and community centre). DA2.C. 2 The Gas Works site has been identified for approximately 2,000 sq m of business employment (B1a, B1c) floor space to the north of the site…’ a) Employment provision - development should provide an appropriate mix of employment floor space of varying sizes that cater for business uses ranging from office to light industrial, including

1 Includes extant planning permissions not included within Development Area floorspace

figures and potential of 6,500 sq m of employment floorspace at Patcham Court Farm (see CP3) 2 Development from small identified sites estimated to be 650 units pre-plan adoption and

small windfall development in last 6 years of the plan allowance is for 600 units.


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small starter units or managed units (Use Classes B1a, B1c); DA2.C.3 The Black Rock site has been allocated for 7,000 sq m of community leisure and recreation use purposes, in addition to not including ancillary retail and café uses associated with the primary leisure use. Proposals will be assessed against the citywide policies and the following specific criteria:

MM8 DA3 Lewes Road, Pages 50 - 51

At DA3.C.2 Woollards Field Provision of 5,000 sq m of B1 office business space or alternative employment generating development that helps to meet the city’s infrastructure needs on land to the south of the new archive centre, known as The Keep. And add new criterion: g) The development must ensure that groundwater sources are protected to the satisfaction of the Environment Agency. At DA3.C.3 Falmer Released Land, Former High School add new criterion: f) The development must ensure that groundwater sources are protected to the satisfaction of the Environment Agency.

MM9 DA3 Lewes Road, Paragraph 3.36, Page 54

Insert at end of last sentence of paragraph: ‘… adopted in September 2011. and will assist in the delivery of development and guide developers on the form and content of development and infrastructure requirements for the strategic allocation.’

MM10 DA3 Lewes Road, Paragraph 3.37, Page 54

Planning permission was granted in 2011 for an archive centre with related conference, education and research facilities on the Woollards Field site to the south of Falmer Station. The remainder of the site to the south is allocated for office business (B1) floorspace or other employment generating uses in connection with meeting the city’s infrastructure needs totalling 5,000 square metres.

MM11 DA4 New England Quarter and London Road Area, Page

Amend DA4.C. ii ii. An appropriate mix of uses including residential (C3) and ground floor ancillary retail (A1) and


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58 restaurants and cafes (A3) at ground floor will be permitted;

MM12 DA5 Eastern Road and Edward Street Area, page 66

Amend DA5.C.1 1. Royal Sussex County Hospital Comprehensive redevelopment and enlargement of the hospital to provide 74,000sqm additional hospital (D1 C2 use) floorspace ...

MM13 DA7 Toad’s Hole Valley, page 81

Amend Policy – DA7.C1 part e

e) Environmental sustainability will be central to the design and layout of the scheme, which will be expected to meet Code for Sustainable Homes Level 6, BREEAM Outstanding and be zero carbon (or carbon neutral) in accordance with CP8.

MM14 DA8 Shoreham Harbour, Illustrative diagram and Key Diagram, page 87& 233

Amend Key Diagram and Key Illustration indicative boundary map to remove Boundary Road / Station Road from Development Area boundary to be consistent with Development Area Brief. See revised boundary map attached at Appendix 1.

MM15 DA8 Shoreham Harbour, paragraph 3.103, page 88

Additional bullet point:

• To maximise opportunities to support the City’s sustainability objectives through large-scale zero and low-carbon energy technologies to serve the Harbour and wider city, particularly those that take advantage of the Harbour’s coastal location.

MM16 DA8 Shoreham Harbour page 89 - 90

B (ii) Aldrington Basin: d) To improve townscape and access arrangements and townscape upgrades to create better linkages to surrounding areas Add new point f): f) To ensure that new development proposals take account of noise and local air quality impacts and that improvements are sought wherever possible. B (iii) North Quayside / South Portslade: Amend point e):


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e) To ensure that new development proposals take account of impact on local of noise and local air quality impacts and that improvements are sought wherever possible.

MM17 DA8 Shoreham Harbour, Paragraph 3.105 and foot note 84, Page 91

These aspirations for the Shoreham Harbour area were subsequently identified in the Regional Spatial Strategy (RSS) for the South East (May 2009). The published South East Plan84 indicatesd that the Sussex Coast was a priority area for regeneration (SCT2) and specifically identifiesd Shoreham Harbour as a Growth Point (SCT1). The harbour is one of three sites in Adur District described as requiring coordinated action to unlock economic development potential (Policy SCT3). An interim figure of 10,000 dwellings was identified subject to detailed studies. 84 Regional strategies remain part of the development plan until they are abolished by Order using powers taken in the Localism Act. The Regional Strategy for the South East (Part Revocation) Order 2013 came into force on 25 March 2013. Therefore, the South East Plan no longer forms part of the Development Plan for the Plan area.

MM18 DA8 Shoreham Harbour, Paragraph 3.109, Pages 91 - 92

The Port is important regionally for the landing, processing and handling of minerals and as such mineral wharf facilities are safeguarded under "Policy WMP15 - Safeguarding railheads and wharves" of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan (adopted February 2013). As a result development proposals affecting minerals wharves are required to demonstrate that there is no net loss of capacity for handling minerals within the Port. A similar policy is likely to may be included within the emerging West Sussex Minerals Local Plan. The two waste mineral planning authorities (Brighton & Hove and West Sussex) are currently preparing guidance in liaison with the Port Authority to set out clearly what the implications of the policy are and what is required of applicants as part of the planning process. The mechanism for safeguarding minerals handling capacity within the Port is to be considered in detail in the JAAP.

MM19 SA1 The Seafront, Paragraph 3.123, Page 99

Insert new sentence at end of paragraph: The Marine Management Organisation will be preparing a marine plan for the south coast of England which will inform and guide marine users and regulators and seek to manage the sustainable development of marine industries such as wind farms, shipping, marine aggregates and fishing alongside the need to conserve


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and protect marine species, habitats and leisure uses. Where appropriate regard will be had to the marine plan in Part 2 of the City Plan.

MM20 SA1 The Seafront, Paragraph 3.124, Page 99

The ‘Brighton Marina to River Adur Strategy’ recommends the maintenance of existing coastal defences with some enlargement of groynes and beaches in the King Alfred area and a scheme to upgrade defences between the western end of Hove Lagoon and the River Adur through Shoreham Port. The Strategy will be is being revised following advice and funding from Defra.

MM21 SA4 Urban Fringe, Paragraph 3.157, pages 112 - 113

Insert new paragraph between 3.157 and 3.158: Under Part 2 of the City Plan (Development Policies and Site Allocations) a comprehensive review of the built up urban area boundary will be undertaken which could amend the spatial extent of the city’s urban fringe. This may allow some (former) urban fringe sites to be brought within the built up area boundary and be considered as site allocations to contribute towards meeting some of the city’s development needs including those for housing. This will be the subject of a sustainability appraisal and consultation with residents and stakeholders.

MM22 SA5 The South Downs, pages 114 - 117

Amend Policy: SA5 The Setting of the South Downs National Park The Council will work in partnership with the South Downs National Park Authority and adjoining authorities and landowners to protect and enhance the natural beauty of the South Downs National Park. Proposals within the setting of the National Park must have regard to the impact on the National Park, in particular the purposes of the National Park and the ability of the South Downs National Park Authority to deliver its duty. Development within the setting of the National Park: a. Should be consistent with and not prejudice National Park purposes and, where appropriate, the duty of the National Park Authority; b. Must respect and not significantly harm the National Park and its setting, in accordance with Section 62 of the Environment Act 1995. Any adverse impacts must be minimised and appropriate mitigation or compensatory measures included. Such measures, including proposed


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enhancements, should have regard to landscape character and impacts; and c. Should have due regard to the City Council’s priorities for the South Downs where appropriate. The council, which is not the planning authority for the National Park but is a key landowner, recognises the following priorities for the south downs and National Park land that falls within the city’s administrative area: 1. To promote Biosphere Reserve principles and objectives, bringing people and nature together. 2. To promote sustainable land use management systems on the downs with greater emphasis on local healthy food production, diversification and farming practices that are sympathetic to wider downland objectives; 3. To conserve and enhance downland habitats and species to meet Biodiversity Action Plan (BAP) targets and recognise the role of the Downs in the city’s Green Network/Nature Improvement Area/open space framework (see CP10 Biodiversity and CP16 Open Space); 4. To protect scheduled ancient monuments111 and other downland features; 5. To protect sensitive aquifer protection zones and address catchment flood management issues. 6. To increase the amount of accessible land adjacent to the urban area and enhance access from the urban area to the Downs by sustainable transport including by walking, cycling and public transport modes (see CP9 Sustainable Transport and CP18 Healthy City). 7. To promote a stronger visitor experience between the city and the South Downs, facilitate sustainable eco tourism in the South Downs and the provision of gateway facilities to the South Downs National Park. In particular, to recognise the role of Stanmer Park within the National Park and the need to manage parking and traffic in order to reduce the risk of degradation of gateway areas and facilitate improved sustainable transport links.


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(See SA4 Urban Fringe, CP5 Culture and Tourism and CP9 Sustainable Transport).

MM23 SA5 The South Downs, amendments to paragraphs 3.165, 3.166, 3.168, Footnote 111, pages 116 - 117

Amend the following parts of the following paragraphs: 3.165 The purpose of this policy is to provide clear planning guidance for proposals within the setting of the National Park and also as a strategic policy, to set out the council’s aspirations for the South Downs to inform planning proposals or including land within the National Park future partnership working with the National Park Authority as appropriate. The majority of this land the countryside within the city’s administrative boundary is owned and leased to tenants by the city council…. 3.166 An important role of the National Park Authority is to promote understanding of the South Downs and to promote access to the National Park by sustainable means………is a major recreational resources for residents of and visitors to the city. Stanmer Park itself will be covered by the South Downs National Park Local Plan, however, there may be planning implications for the City Council because it Brighton & Hove City Council seeks to promote access to the South Downs by developing Stanmer Park as a gateway, promoting access and improving public transport. Similarly There is also the need to manage parking at gateway locations in order to reduce the risk of degradation of these areas and to link them to a sustainable transport system could have planning implications for the City Council. 3.168 The council, which is not the planning authority for the National Park but is a key landowner, recognises the following priorities for the South Downs within the city’s administrative area and will take them into account in future partnership working with the National Park Authority: 1. To promote Biosphere Reserve principles and objectives, bringing people and nature together; 2. To promote sustainable land use management systems on the Downs with greater emphasis on local healthy food production, diversification and farming practices that are sympathetic to wider downland objectives; 3. To conserve and enhance downland habitats and


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species to meet Biodiversity Action Plan (BAP) targets and recognise the role of the Downs in the city’s Green Network/Nature Improvement Area/open space framework (see CP10 Biodiversity and CP16 Open Space); 4. To protect scheduled monuments113 and other downland features; 5. To protect sensitive aquifer protection zones and address catchment flood management issues; 6. To increase the amount of accessible land adjacent to the urban area and enhance access from the urban area to the Downs by sustainable transport including by walking, cycling and public transport modes (see CP9 Sustainable Transport and CP18 Healthy City); and 7. To promote a stronger visitor experience between the city and the South Downs, facilitate sustainable eco tourism in the South Downs and provide gateway facilities to the South Downs National Park. In particular, to recognise the role of Stanmer Park within the National Park and the need to manage parking and traffic in order to reduce the risk of degradation of gateway areas and facilitate improved sustainable transport links. (See SA4 Urban Fringe, CP5 Culture and Tourism and CP9 Sustainable Transport). Renumber footnotes 112 and 113 to take into account the deletion of footnote 111. Reinsert footnote 111 as shown above as footnote 113 respectively, to read as follows: 113

A statutorily protected building, structure or feature of national importance because of its archaeological and historic interest.

MM24 SA6 Sustainable

Neighbourhoods,Footnote 115, Page 119

Amend footnote as shown below: Child Poverty Strategy 2011 Brighton & Hove Child Poverty Commissioning Strategy 2012-2015 (2012)

MM25 SA6 Sustainable Neighbouhoods,Footnote 122, page 124

Open Space, Sport and Recreation Study 2009 2008 establishes a baseline…

MM26 CP1 Housing Delivery, Paragraph 4.2 and footnote 127, Page 128

Based on demographic factors, (reflecting scenarios of population and household growth), the city’s full (unconstrained) housing requirement, for both market and affordable housing, over the plan period has been assessed at 15,800 new homes to 2030. This would


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equate to an annual average of 790new homes per annum)127.A series of studies indicate that to meet in full the city’s ‘objectively assessed housing need’ (housing demand and need) over the plan period to 2030 could mean needing to build between 800 – 1000 dwellings per annum or 16,000 – 20,000 dwellings to 2030. Amend footnote 127: Brighton & Hove City Council, Housing Requirements Study Update, GL Hearn, October 2012 Brighton & Hove City Council, Housing Duty to Co-Operate Study, May 2013.

MM27 CP1 Housing

Delivery, paragraph 4.7, page 129

Insert new paragraph between 4.7 and 4.8: Under Part 2 of the City Plan (Development Policies and Site Allocations) a comprehensive review of the built up urban area boundary will be undertaken which could amend the spatial extent of the city’s urban fringe. This may allow some (former) urban fringe sites to be brought within the built up area boundary and considered as site allocations to contribute towards meeting some of the city’s development needs including those for housing. This will be the subject of a sustainability appraisal and consultation with residents and stakeholders.

MM28 CP1 Housing Delivery Paragraph 4.10 and footnote 130, Page 130

Delete second sentence and replace as follows: Based on the 2012 SHLAA update, the trajectory130 anticipates that housing delivery is likely to achieve at least this rate in the first ten years after plan adoption (2014-2019). The revised 2012 trajectory indicates that housing delivery over the first ten years of the plan period (up to 2019) may be below this reflecting ongoing impacts of economic recession and a gradual return to higher rates with market recovery. Amend Footnote 130: As informed by the 2012 SHLAA Update the 2012 Revised Trajectory.

MM29 CP1 Housing Delivery, Figure 2 Page 130

Replace Figure 2 with revised Housing Trajectory: Figure 2: Housing Trajectory 2010 – 2030 (Based on 2012 SHLAA)


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Brighton & Hove Housing Trajectory as at 1st April 2012

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Total Identified Supply Small Unidentified Supply (Small windfall) Total Actual Supply City Plan Target (565 pa) 2013 SHLAA – Revised Housing Trajectory.

MM30 CP3

Employment Land, pages 138-139 and insert new footnote

Amend CP3: 3. Protection of the following primary industrial estates and business parks for business, manufacturing and warehouse (B1, B2 and B8) use: Centenary Industrial Estate English Close Industrial Area, Old Shoreham Road Home Farm Industrial Area Hove Technology Park, St Josephs Close, Old Shoreham Road Moulsecoomb & Fairways Industrial Estate Sussex House (including BT depot) Woodingdean Business Park Hyde Business Park, Bevendean Bell Tower Industrial Estate Hollingbury Industrial Estate Hollingdean Industrial Estate Victoria Road Industrial Estate


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Newtown Road Industrial Estate The council will support proposals for the upgrade and refurbishment of these estates and premises so that they meet modern standards required by business, are more resource efficient and improve the environment or townscape of the site or premise.

Sui generis uses, including waste management facilities, appropriate in nature to an industrial estate location will also be acceptable, provided that they generate employment which is quantitatively and qualitatively comparable to uses within B1-B2 B8 Use Classes1; do not harm the continuation of existing uses within those Classes and comply with other City Plan policies and for waste management facilities the Waste and Minerals Plan.

4. In order to secure good quality modern, flexible employment floorspace the council will allow employment-led (residential and employment) mixed use development on the following employment sites:

Franklin Road Industrial Estate School Road, Hove Melbourne Street Industrial Area Portland Road Trading Estate (including EDF and Martello House) Land North of Newtown Road

There should be no net loss in employment floorspace. unless this can be justified. Paragraph 4.36 sets out the factors that will be taken into consideration. 5. Loss of Uunallocated sites or premises in, or whose last use was, employment use (Use Classes B1-B8) will not be released to other uses unless only be permitted where the site or premises it can be demonstrated to be both redundant and incapable of meeting the needs of modern alternative employment uses (Use Classes B1-B8). Where release loss is permitted the preference priority for re-use will be for alternative employment generating uses or affordable housing (in accordance with CP20 Affordable Housing). Insert new footnote:


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1 Employment generation as compared with average employment densities as set out in Table 3 of the HCA/Offpat Employment Densities Guide, 2010 or subsequent updates.

MM31 CP3 Employment Land, amendments to paragraphs 4.30 – 4.36, 4.39, pages 140 - 143

Amend the following parts of the following paragraphs: 4.30 ... This will be informed by the preparation of an office delivery trajectory setting out a realistic pipeline of supply of The Employment Land Supply Trajectory1 indicates the potential delivery of new employment floorspace employment sites over the short, medium and long-term…. Insert new footnote: 1Employment Land Supply Trajectory 2013

4.31 In light of the Employment Land Study Review 2012 identifying a qualitative and quantitative need for additional employment land over the plan period it is important that the strategic allocations set out in the Development Areas bring forward high quality employment floorspace as indicated in Table 5 to meet the council’s priorities regarding high quality job creation and to support its growth potential over the next 20 years, with appropriate flexibility. It is important that the strategic allocations set out in the Development Areas bring forward high quality employment floorspace. The Employment Land Supply Trajectory indicates the need for close monitoring of the office developments identified to come forward in 2014-2019 to ensure they are delivered. However, it is also important to allow for reasonable flexibility, in the short term to promote successful regeneration and enable viable schemes to be delivered. Therefore proposals which bring forward employment floorspace less than proposed on sites identified in Table 5 will be considered, taking into account whether:

1. There is demonstrable benefit for early redevelopment and clear commercial and financial viability evidence that the figures in Table 5 are unlikely to be delivered within the next 5 years;

2. Allowing a different scale or mix of development will secure particularly strong planning benefits;

3. It is appropriate in light of ongoing monitoring of delivery of new employment floorspace against the 2013 Employment Land Supply Trajectory


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and subsequent updates. regarding the delivery of the overall employment forecast targets and of economic growth.

To ensure that this is assessed on a consistent basis a delivery trajectory for employment sites will be prepared to inform the implementation of the policy. 4.34 These industrial estates/ premises are also considered suitable for certain “sui generis” uses, that is, those with industrial characteristics which are not included within the Use Classes Order. For example, car breaking, or metal recycling which could potentially harm residential amenity are thus likely to be considered most suited to an industrial estate. With modern design and operation techniques, waste management facilities can increasingly be accommodated in general industrial areas as a B2 use1. Insert new footnote: 1See Policy WMP 7 of the Waste and Minerals Plan for East

Sussex, South Downs and Brighton & Hove, adopted February 2013

4.36 In considering proposals where a net loss of employment floorspace is being proposed the council will take into consideration the following factors:

- Site constraints (current site coverage and opportunities for more effective and efficient use of the site)

- The need for environmental and townscape improvements

- Access arrangements (improved access/circulation space).

- Safeguarding the amenity of surrounding users and occupiers

- The quality of the employment offer in terms of the type of employment and density of jobs.

- viability

MM32 CP6 Visitor Accommodation,Paragraph 4.58, Page 153

The city has a significant stock of hotel and guest accommodation; a total of 160 hotels and guest accommodation predominantly located in central Brighton and along the seafront. The council undertook a capacity and needs analysis of hotel bedspacesrooms in the city to understand the future capacity of the city to absorb new hotel accommodation (2007 Hotel Futures Study). Since the study was completed 3 new hotels have come into operation


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(Jury’s Inn, MyHotel and Royal York hotel) adding 365 bedspaces rooms. Furthermore there is the potential for an additional 372 bedspacesrooms through recent outstanding planning commitments175.

MM33 CP8 Sustainable Buildings, page 161

Amend criterion k: Reduces air, land and water pollution;

MM34 CP8 Sustainable Buildings, Footnote 185, Page 162

Last sentence: ….At present, the bulk of Brighton & Hove’s untreated waste is disposed to landfill The adopted East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan identifies a need for additional waste recycling and recovery capacity to support further increases in the diversion of waste from landfill”

MM35 CP9 Sustainable Transport, Page 168

6. Parking Co-ordinate the provision of parking and traffic management measures across the city through an integrated approach to car parking charges, car park improvements (including signing and information), controlled parking zones and ensure that the capacity of public car parks used by the public are is not increased in central areas.


At the end of the second sentence: “… The boundary of the NIA/Green Network is shown on the proposals policies map…”


Add new sentence at start of paragraph 4.142: The Council has a developing new role as Lead Local Flood Authority with a responsibility for surface and groundwater flooding, SuDS approval and other responsibilities derived from the Flood and Water Management Act 2010 and is as a source of information and technical assistance. Amend monitoring target in Annexe 1 Implementation & Monitoring Plan to include Council’s decisions on planning applications to reflect future changes to roles and responsibilities for flooding issues

MM38 Footnote 205, Page 185

205 The anticipated adoption date for the Urban Design Framework is 20134.


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Delete sentence: The South East Plan sets an overall regional target of 40 dph and states that there are significant opportunities to provide quality housing development in excess of 50 dph in many urban and suburban areas.

MM40 CP16 Open Space, Page 194

Amend the following criteria in Policy CP16: 1. The council will require the retention of and seek better, more effective and appropriate use of all existing open space, as shown on the proposals policies map, having regard to the… 2 b) …which comprises the open spaces shown on the proposals policies map, the Nature Improvement Area…. 2 d) The community use of private and schools open spaces will be sought when considering proposals affecting these sites including the temporary use of redundant or undeveloped sites. All open space proposals will be expected to have an agreed funded maintenance plan for the space. The council will seek to allocate new open space in the City Plan Part 2…. 2 f) Seek proactive and appropriate management of open spaces including the enforcement of by-laws and seek the enhancement and improvement of open spaces and features. All open space proposals will be expected to have an agreed funded maintenance plan for the space. Lighting proposals, including floodlighting, will be required to minimise light pollution, help reduce crime and not cause significant harm. .”

MM41 Page 206 Insert footnote definition of Lifetime Neighbourhood principles related to part 4 of policy: The CLG (Lifetime Neighbourhoods - December 2011) has recognised the importance of neighbourhood as a determinant of well-being in later life and its crucial role in supporting older people’s independence. The main components that make up a lifetime neighbourhood includes: supporting residents to develop lifetime neighbourhoods – especially resident empowerment; access, services and amenities, built and natural environments, social networks/well-being and housing.


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MM42 CP21, Page 217, 218

i) Purpose Built Student Accommodation A 6. Schemes should demonstrate that they have entered into a formal agreement with the support of one of the city’s two Universities or other existing educational establishments within Brighton & Hove. A 7. Permanent purpose built student Accommodation will not be supported on sites allocated for housing or with either an extant planning permission for residential development or sites identified as potential housing sites.

ii) Houses in Multiple Occupation (HMO’s) In order to support mixed and balanced communities and to ensure that a range of housing needs continue to be accommodated throughout the city, applications for new build, the change of use to a Class C4 (Houses in multiple occupation) use, a mixed C3/C4 use or to a sui generis House in Multiple Occupation use (more than six people sharing) will not be permitted where: More than 10 per cent of dwellings within a radius of 50 metres of the application site are already in use as Class C4, mixed C3/C4 or other types of HMO in a sui generis use.


The city’s educational establishments and their students make an important contribution to the economic and cultural life of the city. There are approximately 35,200 37,000 students at the Universities of Brighton and Sussex, which includes 4,000 5,200 international students from non EU countries. 150 countries Insert new footnote source: HESA 2011/12

MM44 Paragraph 4.234, page 220

In assessing planning applications for new Houses in Multiple Occupation, a circle with a radius of 50 metres will be drawn from the centre point of the application site’s highway frontage front curtilage boundary.

MM45 Footnote 254, page 223

Additional wording at end of footnote: ‘ A summary of the partial review process is provided in the paper ‘Joint Evidence Paper – Provision for Gypsies and Travellers in East Sussex’ April 2011 produced by ESCC, East Sussex District and BHCC officers.’


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Further Main Modifications Submitted 8th October MM46

CP1 Housing Delivery, Page 127

Amend Part B of Policy: B: Distribution of new housing. New housing will be delivered broadly in line with the following distribution: Area / Source of Supply No. of new homes Development Area DA1 – Brighton Centre and Churchill Square Area

20

DA2 – Brighton Marina, Gas Works and Black Rock Area

1940

DA3 – Lewes Road Area 810 DA4 – New England Quarter and London Road Area

1185

DA5 – Eastern Road and Edward Street Area

470

DA6 – Hove Station Area 630 DA7 –Toad’s Hole Valley 700 DA8 – Shoreham Harbour

400

Development Area Total

6155

Development Across Rest of City

3945

Small identified sites 650 Small Windfall Development

600125

Total 11,350


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New housing will be delivered broadly in line with

the following distribution: Area / Source of Supply No. of new homes Development Area DA1 – Brighton Centre and Churchill Square Area

20

DA2 – Brighton Marina, Gas Works and Black Rock Area

1940

DA3 – Lewes Road Area 810 850

DA4 – New England Quarter and London Road Area

1185 1130

DA5 – Eastern Road and Edward Street Area

470 515

DA6 – Hove Station Area 630 525

DA7 –Toad’s Hole Valley 700 DA8 – Shoreham Harbour

400

Development Area Total

6155 6080

Development Across Rest of City

3945 3980

Small identified sites 650 Small Windfall Development

600125

Total 11,350

11,310 Note: wording of footnote is unchanged and is as follows: 125

An allowance for small windfall development has been made for the final 6 years of the plan period 2024 – 2030; although it is anticipated that small windfall development will contribute to meeting the housing target in earlier parts of the plan period.

MM47 Paragraph 4.10 page 130

Amend paragraph to read: The city’s housing target implies an annual average rate of 565 dwellings per annum over the plan period as a whole. Based on the 2012 SHLAA 2013 SHLAA update, the trajectory anticipates that housing delivery is likely to achieve this rate in the first ten years after plan adoption


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(2014 – 2019). over the first ten years of the plan period may remain below this reflecting the ongoing impacts of economic recession and further time required for market recovery. Rates from 2014-19 are anticipated to recover towards an average of 500-550 dwellings per annum. Between 2019/20 and 2030, delivery is expected to average around 630 units per annum. The council’s Housing Implementation Strategy (HIS) identifies a range of planning management actions to assist in bringing forward sites for development. should this prove necessary. The HIS also identifies that further site allocations will be made through the preparation of Part 2 of the City Plan.

MM48 Amend footnote 130

As informed by the 2012 2013 SHLAA Update

MM49 Amend footnote 131

SHLAA 2012 2013 Update

MM50 Amend paragraph 4.12 page 131.

Amend first sentence: The table illustrates that approximately 3230 3,270 dwellings have either already been built since 2010 or are currently ‘committed’ for development in terms of sites having an extant planning permission or allocated in the 2005 Brighton & Hove Local Plan.

MM51 Amend Table 4 page 131

Table 4: Housing Delivery, Supply Breakdown 2010 – 2030 (Based on 2012 SHLAA)

Spatial Area

Already Built or Committed

Strategic Allocations

Broad Locations

Further Capacity Identified in SHLAA

Allowance For windfall

Total

DAs

DA1 13 0 7 20

DA2 855 1085 0 1940

DA3 120 300 390 810

DA4 285 615 285 1185

DA5 0 335 135 470

DA6 120 200 310 630

DA7 0 700 0 700

DA8 0 400 400

DA Total

1390 3235 400 1130 6155

Rest of City

1190 400 500 1856 3945

Small id. Sites

650 650


22

Small Windfall

600 600

Total 3230 3635 900 2985 600 11350

Table 4: Housing Delivery, Supply Breakdown 2010 – 2030 (Based on 2012 SHLAA)

Spatial Area



Broad Locations



Total

DAs

DA1 13 0 7 20

DA2 855 1085 0 1940

DA3 120 140

300 390 410

810 850

DA4 285 320

615 285 195

1185 1130

DA5 0 10

335 135 170

470 515

DA6 120 90

200 310 235

630 525

DA7 0 700 0 700

DA8 0 400 400

DA Total

1390 1428

3235 400 1130 1017

6155 6080

Rest of City

1190 1190

400 500 440

1856 1950

3945 3980

Small id. Sites

650 650

Small Windfall

600 600

Total 3230 3268

3635 900 840

2985 2967

600 11350 11310

MM52 Policy CP1,

Paragraph 4.16 page 132

Amend second sentence to read: The trajectory illustrates that the rate of housing delivery in the city is expected to steadily increase over the first ten years of the plan period (post adoption) reflecting anticipated recovery in the economy and financial markets which has severely affected development rates


23

in the early years of the plan period. MM53

Policy CP19 Housing Mix page 209

Add new criterion a. iii) to the policy: iii) introduce dwelling space standards in Part 2 of the plan to secure quality and sustainability in new residential development.

MM54

Amend paragraph 4.202 page 210

Insert new penultimate sentence within paragraph 4.202: Part 2 of the plan will introduce minimum dwelling space standards, similar to those of the GLA or compatible with those emerging from the government’s 2013 Housing Standards Review.

MM55

Policy SA6, Part A.8, page 120

8. Deliver balanced communities through the requirement for new residential development to provide an appropriate amount of affordable housing, mix of dwelling sizes and tenure types and to ensure new housing meets lifetime homes standards and minimum dwelling space standards. In areas where there is a concentration of social rented housing, a better choice of housing tenures will be sought (see CP1 Housing Delivery, CP19 Housing Mix and CP20 Affordable Housing).

MM56

Paragraph 3.172 page 121

Add an additional bullet point to the list of aims:

• ensure new residential development provides for an appropriate mix of dwelling types and tenures and meets minimum space standards.

MM57

DA5 Eastern Road and Edward Street Quarter A8, page 65

Amend reference to water and waste water infrastructure to:

8. Ensuring that there is satisfactory provision of water and wastewater infrastructure to serve new development Development will need to provide connection to off-site water distribution and sewerage systems at the nearest point of adequate capacity.

MM58 CP8 Sustainable

Buildings, part 2k. page 161

Amend criterion k in addition to MM33 to add reference to protecting groundwater sources: Reduces air, land and water pollution and safeguards water supplies if development is within groundwater Source Protection Zones;

MM59 DA5 Eastern Road and Edward Street Quarter, C2, page 66

Amend introductory paragraph to C2 Edward Street Quarter to add following: Employment-led redevelopment of the Edward Street Quarter (including former Amex House and the Job Centre) comprising demolition of the former Amex


24

House and replacement with 15,000-20,000 sq m of high quality B1a office floorspace, a minimum of 65 residential units and ancillary shops (A1) and cafes and restaurants (A3). The proposal will be considered in the context of citywide policies and the following criteria:

MM60 DA1 Brighton Centre & Churchill Square Area, page 34

Amend introductory paragraph to the policy The strategy for the development area is to secure a new state of the art conference centre in a landmark new building to benefit the city and the region and to sustain the tourism and service economy for the next 30 years, positioning Brighton & Hove as one of Europe’s leading conference and meeting destinations. The redevelopment of the Brighton Centre will form part of a comprehensive scheme including the extension of the Churchill Square Shopping Centre and new leisure facilities.

MM61 DA1 Brighton Centre & Churchill Square Area, page 34

Amend Local Priority 3 3. Support the extension of the Churchill Square shopping centre to provide a minimum 20,000 sq m net of new retail comparison goods37

floorspace and A2/A3 use floorspace;

MM62 DA1 Brighton Centre & Churchill Square Area, page 35 Part B and remove accompanying footnote 38

1. New Brighton Centre and expansion of Churchill Square. Redevelopment of the Brighton Centre Area38

to provide a new 25,000 sqm conference centre, and expansion of Churchill Square shopping centre to provide a minimum of 20,000sqm net new comparison goods A1 floorspace (and A2 and A3 use classes). New hotel and leisure facilities including a cinema will also be permitted. Proposals will be assessed against the local priorities set out above, citywide policies, informed by the adopted Brighton Centre SPD and the following criteria: 38

As defined in the Brighton Centre SPD01 a core 'block' has been identified (comprising a number of smaller blocks) bounded by Western Road, West Street, Queensbury Mews and Cannon Place. Further detail is set out in the adopted SPD

MM63 DA1 Brighton Centre & Churchill Square Area , page 36 Remove para 3.4 and renumber subsequent paragraphs to

3.4 The City Council will ensure that a strategy is devised so that the redevelopment of the Brighton Centre is adequately managed and does not result in a shortfall of music/conference venue space should Black Rock not be available.


25

reflect change MM64 Policy CP4 Retail

Provision Page 145

Applications will be required to complete an impact assessment at a locally set threshold of 1,000 sqm (gross) (net) floorspace or more.

MM65

Annex 1 – Implementation and Monitoring Plan

Full Annex shown with amendments in Appendix 2 below.

MM66 Annex 2 – Infrastructure Delivery Plan

Extract from Annex with amendments in Appendix 3 below.

MM67 Annex 3 – Housing Implementation Strategy

Full Annex shown with amendments in Appendix 4 below.

MM68 Table 3, paragraph 2.23, Page 31

Further Amend Table 3 (see also MM6): Table 3 Summary of Development proposals New

Homes New Employment Floorspace (sq m)

New Retail floorspace (sq m net)

DA1 Brighton Centre and Churchill Square

20 Minimum 20,000 comparison goods

DA2 Brighton Marina

1,940 2,000 5,000

DA3 Lewes Road

810 850

15,600

DA4 New England Quarter and London Road

1185 1,130

20,000

DA5 Eastern Road and Edward Street

470 515

18,200 – 223,200

DA6 Hove Station

630 525

1,000

DA7 Toad’s Hole Valley

700 25,000


26

DA8 Shoreham Harbour

400 7,500

Rest of the City

3,945 3,980

11,25735

Small site development36

1,250

Total 11,350 11,310

100,500 to 105,500

25,000

Note: wording of footnotes is unchanged and is as follows: 35 Includes extant planning permissions not included within Development Area floorspace figures and potential of 6,500 sq m of employment floorspace at Patcham Court Farm (see CP3) 36 Development from small identified sites estimated to be 650 units pre-plan adoption and small windfall development in last 6 years of the plan allowance is for 600 units.

MM69 DA3 Lewes Road Area, page 49

Amend DA3.B B. Provision will be made for the following amounts of additional development to be provided by 2030. Provision will be made through strategic site allocations (below) and through allocations made in the City Plan Part 2 for:

• 810 850 residential units; … MM70 DA4 New

England Quarter and London Road, page 58

Amend DA4.B B. Provision will be made by 2030 for the following minimum amounts of development through strategic allocations (below) and through allocations in the City Plan Part 2:

• 1185 1,130 residential units; …

MM71 DA5 Eastern Road and Edward Street, page 66

Amend DA5.B B. The minimum amounts of development to be secured by 2030 through strategic allocations (below) and through allocations in the City Plan Part 2 are:

• 470 515 residential units; … MM72 DA6 Hove

Station Area, page 74

Amend DA6.B B. Provision will be made by 2030 for the following minimum amounts of development within this


27

Development Area:

• 630 525 residential units; ... MM73 DA8 Shoreham

Harbour, paragraph 3.103, page 88

Additional sentence to proposed modification MM15 to add to end of proposed new bullet point:

• … In particular the City Council will encourage any opportunities that arise to incorporate waste heat or other heat sources into the heat networks for the city.

MM74 CP2 Sustainable Economic Development, page 133, 136-137

Include new criteria between CP2.5 and CP2.6: 6. Recognise the importance of employment-generating non-B Class uses to the local economy. Appropriate allocations for non-B Class uses will be made through the City Plan Part 2. and at paragraph 4.26: 4.26 The city contains a number of major employment generators including the two universities and the Royal Sussex County Hospital and the council will work with the higher and further education sector, Sussex University Hospital NHS Trusts and NHS Brighton & Hove to support appropriate expansion (see DA3 Lewes Road Area, DA5 Eastern Road and Edward Street Area and CP18 Healthy City). Other non- traditional employment generators (non B-class uses) in the city include retail and leisure uses. Non-B Class uses are estimated to account for approximately 71% of all jobs in Brighton & Hove. This is expected to remain broadly consistent over the plan period to 2030. Development Area proposals, SA2 Central Brighton, CP4 Retail Provision and CP6 Culture and Tourism set out how the City Plan will address addresses retail, culture, leisure and tourism needs to 2030. Appropriate allocations for employment-generating non-B Class uses will be included in the City Plan part 2.

MM75 CP3 Employment Land, Paragraph 4.40 page 143

4.40 Alternative employment generating uses are any uses that generate employment but are not classified as an employment use (uses falling outside the Use Class B1- B8) including educational teaching space and health facilities. This excludes retail or leisure uses unless they comply with the tests of national planning policy.

MM76

DA3 Lewes Road Area, pages 49-50

Amend DA3.C C. Strategic Allocations in the Lewes Road Development Area are:


28

1. Preston Barracks and Brighton University (Mithras House and Watts/Cockcroft Site) The city council will work with the University of Brighton and other partners to provide a mixed use employment-led development comprising a new business school, 10,600sqm B1 employment floorspace, including an Innovation Centre; 750 rooms of student accommodation; 300 residential units and other ancillary supporting uses. Proposals will be assessed against the priorities for DA3 Lewes Road, citywide policies, guidance in the adopted Planning Brief for the site and the following criteria: a) Proposals will be required to have a high standard of public realm, including a central square, and effective links across the Lewes Road and to Moulsecoomb Station in order to improve the quality and permeability of the area. b) Residential development should provide for a mix of dwelling type, tenure and size to cater for a range of housing requirements and to improve housing choices. c) The development should aim to be zero carbon and through creative landscaping solutions (including features such as green walls) should contribute towards Biodiversity Action Plan objectives, green infrastructure and wider landscaping enhancements through creative landscaping solutions. …

MM77

DA3 Lewes Road Area, pages 50

Amend and add footnote to DA3.C.3.c

c) As a greenfield site, the development will be expected to be zero carbon and to achieve an Outstanding BREEAM rating50 and, through creative landscaping solutions (including features such as green walls), should contribute towards Biodiversity Action Plan objectives, green infrastructure and wider landscaping enhancements.

50

This will be subject to viability considerations and potential mitigation measures, as set out in policy CP8.

MM78 DA3 Lewes Road Area, page 50

Amend DA3.C.3 3. Falmer Released Land, Former Falmer High School


29

Redevelopment for some or all of a range of uses including housing, purpose built student accommodation, offices (B1), and/or educational use., Redevelopment should include a car park related to the American Express Community Stadium and the provision, on or off site, of permanent accommodation for the Bridge Community Education Centre and for Brighton Aldridge Community Academy’s Pupil Referral Unit. Proposals will be assessed against the priorities for DA3 Lewes Road, citywide policies and the following criteria: a) The development will be required to achieve a

high standard of design. b) Sustainable transport infrastructure will be

required to support the scheme and to ensure that there is no adverse air quality impact.

c) Development should ensure that there will be no

adverse impacts on the setting of the South Downs National Park or any locally or nationally designated landscape, historic or ecological sites.

d) The development should aim to be zero carbon

and through creative landscaping solutions (including features such as green walls) should contribute towards Biodiversity Action Plan objectives, green infrastructure and wider landscaping enhancements through creative landscaping solutions.

e) The developer will be required to enter into a

training place agreement to secure training for local people.

MM79 DA5, Part A,

page 65 and add sentence to supporting text 3.60 p. 70

Add paragraph 11 to Part A of policy: 11. Support improvement to higher education teaching and library space in the Eastern Road and Edward Street Area. Insert at end of paragraph 3.60 Expansion and provision of additional teaching and library space for the universities, particularly the University of Brighton, at Circus Street and within the wider development area will be supported as an alternative use where other policy requirements are met


30

(see paragraph 4.40 of CP3 Employment Land). MM80 DA8 Shoreham

Harbour page 88 first paragraph

DA8 – Shoreham Harbour The Council will work with Adur District Council, West Sussex County Council, Shoreham Port Authority and other key partners to support the long term regeneration of Shoreham Harbour and immediately surrounding areas. A Joint Area Action Plan (JAAP) is currently being prepared that will contain detailed policies for the harbour area. to address a range of issues, including the provision of infrastructure.

MM81 CP7 Infrastructure and Developer Contributions page 157

Insert in to supporting text 4.73 after 2nd sentence: …to support the needs of new development. The timely connection to provision of utilities including water, wastewater infrastructure and sewerage systems will be required by developer’s liasing directly with service/utility providers. Priorities will also derive…


31

Appendix 1

• DA8 Shoreham Harbour Current Boundary Map (submission version June 2013)

• DA8 Shoreham Harbour Proposed Boundary Amendment


32

Appendix 2

Annex 1 Implementation and Monitoring

of the City Plan, Part 1


33

Implementation The implementation of the City Plan will depend on effective action from a range of different agencies as well as directly through planning. The city council, as Local Planning Authority, will be a key player through managing development, the preparation of development briefs, design guidance, masterplans to bring forward proposals in the Development Areas; and through detailed guidance in Supplementary Planning Documents. However, other parts of the city council and other agencies will also play an important role in helping to deliver or support different elements of the City Plan – either as a provider or facilitator of new development or through their statutory roles in helping to manage and implement development. The support of other partners and the private sector, whether as an agencies for development or in providing services in local communities, it remains important that the city council maintains close engagement through the Local Strategic Partnership. Central to this approach is the need to ensure the involvement of the wider community. The city council will continue to engage with the local community to build on capacity to engage and influence change; to ensure the new plans deliver sustainable development; and reflect the kind of city residents want to live in. The implementation of a number of policies will also depend on the production of other documents for example, Part 2 of the City Plan and Supplementary Planning Documents. Monitoring The City Plan needs clear arrangements for monitoring and reporting to residents, stakeholders, partners and councillors to ensure that policies are and continue to remain effectively implemented. The implementation and monitoring framework for the City Plan is outlined in the following tables. For each policy the table sets out:

• implementation/ issue(s) relating to each policy;

• delivery mechanism/partners related to each implementation/issue;

• indicator reference / indicator;

• targets that are to be used to measure progress towards the objectives and their timescale; and

• strategic objectives - to show which strategic objective each policy will deliver; and

• triggers and actions, showing what will be done if the targets are not being achieved.

The Annual Monitoring Report (AMR) will provide this monitoring information and will be published annually. It will:


34

• assess the performance of the City Plan and other development plan documents by showing progress against the indicators in Brighton & Hove’s City Plan Monitoring Indicators document;

• set out the Council’s updated housing trajectory (see policy CP1);

• identify the need to reassess or review any policies or approaches;

• make sure the context and assumptions behind our strategy and policies are still relevant; and

• identify trends in the wider social, economic and environmental issues facing Brighton & Hove.

Indicators and Targets The indicators for each policy have been chosen to ensure that they allow comprehensive monitoring of the performance of the preferred option against its objectives and also provide a contextual setting. The indicators are derived from a number of sources and include some that are compulsory, nationally set indicators, and some that are locally set. Each indicator has been assigned a unique identifier, and part of this prefix identifies its source.

• Single Data List - part of the remaining set still collected by central government

• LOI/ - Local Indicator – a locally derived indicator deemed to be appropriate for the needs of LDF monitoring;

• LOI/LTP - Local Transport Plan Indicator The indicators have been selected based not only on their appropriateness, but on the availability of data. It is deemed that generally, the listed indicators should have data that is both available at the local level and that is updated on at suitable interval. Where there may be issues in obtaining the data at present it is expected that it will become available for monitoring purposes in the future. Indicators will be replaced as and when updated by the Government. Where local circumstances require specific targets these have been developed and are included within the framework. Triggers and Action Points Following comments made by the Inspector for the City Plan Part 11 specific triggers relating to each policy have been added along with action points, describing what will be done if the targets are not being achieved. These have been added to improve the effectiveness of the City Plan Part 1 and to give a detailed and practical component to the monitoring and implementation of the Plan.

1 ID-01 Letter from Inspector dated 22

nd July 2013


35

Development Management Intervention Where implementation of the City Plan relies on specific development coming forward, an action point of “Development Management intervention” has been prescribed. This action would involve the following: Co-ordinated action between Strategic Planning, Development Management and other partners to investigate or reinvigorate stalled strategic allocation, through some or all of:

• Promotion of site with relevant partners and developers

• Review development management priorities and analysis

• Review existing or draft new planning brief for site

• Review allocation in light of changed economic circumstances


36

DA1 - Brighton Centre and Churchill Square

Strategic Objectives: SO1, SO3, SO5, SO7, SO8, SO9, SO11, SO12, SO13, SO16, SO17, SO18, SO23

Implementation / Issue

Delivery Mechanism / Partners

Indicator Reference & Indicator

Target & Timescale Trigger and Actions to be taken if target not being achieved

Delivery of a new 25,000 sqm Replacement conference centre and extension to Churchill Square

National policy; LTP; Brighton Centre SPD; developer contributions; Landowners and BHCC

LOI Take forward the development of a the Brighton Centre replacement conference centre and a minimum of 20,000 sqm net comparison retail floorspace for Churchill Square

By 2020 2018 development has commenced that will secure

• a replacement conference centre

• extension to Churchill Square shopping centre (Source: Planning)

Trigger: Planning application not submitted by 2015 Action: Development Management Intervention

Delivery of expanded Churchill Square shopping centre (minimum 20,000 sqm additional A1 floorspace)

National policy; LTP; Brighton Centre SPD; developer contributions / Landowners and BHCC

LOI Minimum of 20,000 sqm of new retail floorspace in the Churchill Square shopping centre

By 2020 - provide at least 20,000 sqm of additional retail floorspace in Churchill Square shopping centre (Source: Planning)


37

DA2 - Brighton Marina, Gasworks & Black Rock Area

Strategic Objectives: SO1, SO2, SO3, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO13, SO17, SO18, SO19, SO21, SO22





Development to include by 2030: Inner Harbour

• 1,000 residential units

• 5,000 sqm retail (A1-A5)

• 3,500 sqm leisure & recreation

• Community centre

• Health facility (Source: Planning)

Trigger: planning application for 500 residential units in Inner Harbour not submitted by end of 2018 Action: Development Management intervention

Amount of development BHCC; landowners and developers; transport providers; businesses; residents; other public sector bodies; statutory consultees and non-statutory consultees; PCT; health providers; education providers; voluntary and community sector; retailers

LOI Delivery of development for DA2

Gas Works site

• 2,000 sqm employment floorspace (B1a, B1c)

• 85 residential units

To be provided during 11 – 16 year supply period. (Source: Planning)

Trigger: planning application not submitted by end of 2023 Action: Development Management intervention


38







Outer Harbour


400 units to be completed by 2019. (Source: Planning)

Trigger: works not commenced by end of 2014 Action: Development Management intervention

Black Rock

• 7,000 sqm recreation and leisure floorspace

To be implemented by 2030 (Source: Planning)

Trigger: planning application not submitted by 2020 Action: Development Management intervention.

Enhance the biodiversity and geodiversity of the Marina

Ecological masterplan to be produced jointly by developers and landowners; guidance from BHCC and statutory consultees

LOI Produce and implement an ecological masterplan for the Brighton Marina and Black Rock areas

Masterplan to be produced by 2019. Implementation ongoing to 2030 (Source: Planning)

Trigger: draft Ecological Masterplan not produced by mid 2019 (linked to Inner Harbour development) Action: Work with developers and landowners to assist in masterplan implementation.


39






Target & Timescale Trigger and Actions to be taken if target not being achieved Review funding sources for masterplan work.

DA3 - Lewes Road Area Strategic Objectives: SO1, SO2, SO3, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO15, SO18, SO19, SO20, SO21, SO22, SO23





Amount of development Development industry; Public sector investment; BHCC; Developers; Universities; Registered Providers


Preston Barracks site:

• New Business School

• 10,600 sqm B1 employment floorspace

• 750 student rooms

• 300 residential units 150 residential units completed by 2019 (Source: Planning)

Trigger: Planning application not submitted for 150 residential units by early 2015 Action: Development Management intervention


40






Woollards Field South:

• 5,000 sqm B1 business space or alternative employment generating development for city’s infrastructure needs

Completion by 2019 (source: Planning)

Trigger: Planning application not submitted by 2015 Action: Development Management intervention

Improve sustainable transport links in Lewes Road

National policy; LTP; Developer contributions; Infrastructure Delivery SPD; comprehensive design guide; train and bus service providers; developers

LOI/LTP Implement current and future LTP priorities for Lewes Road

Ongoing to 2030 Completion of works by 2014 (Source: Sustainable Transport)

Work has commenced and is due for completion in 2013 (no trigger/action necessary)

Improvements to local air quality

Air Quality Action Plan / BHCC; Landowners; Developers; Bus service providers; Residents; Businesses

LOI Improve levels of air quality in the Lewes Road area (This indicator to be reviewed following adoption of revised Air

Ensure that the annual mean concentrations (Fg/m3) of NO2 decrease at three monitoring sites DT29, 30 and 32 across the Plan period Baseline 2009: DT29 45.9 Fg/m3 DT30 60.7 Fg/m3 DT32 47.1 Fg/m3

Trigger: Annual mean increase in NO2 concentrations Action: Review Air Quality Action Plan and Transport Strategy for improving air quality


41






Quality Action Plan in 2014).

(Source: Air Quality Further Review and Assessment (2010), the Air Quality Action Plan (2011) and subsequent updates through the plan period)

DA4 - New England Quarter and London Road Area

Strategic Objectives: SO1, SO2, SO3, SO4, SO7. SO8, SO9, SO10, SO11, SO12, SO13, SO16, SO18, SO19, SO20, SO21, SO22, SO23





Amount of development BHCC; landowners; developers; City College; University of Brighton


1128 net additional dwellings: 161 - 2010-2014 453 - 2014-2019 391 - 2019-2024 123 - 2024-2030 Net gain 20,000 sqm B1 floorspace: By 2014-2019: Block J Brighton Station Site 2,973 sqm Block K Brighton Station Site 3,428 sqm GB Liners site, Blackman Street 3,327 sqm By 2019-2024: 3,000 sqm - Trade Warehousing

Trigger: Current office schemes with unimplemented planning permission not started by 2016 Actions: Negotiation on particular sites to overcome specific economic viability issues. Explore alternative funding mechanisms and/or the potential for enabling development. Consider scope to help accelerate the phasing of later schemes if 2014-


42







(Longley Industrial Estate) 4-6 New England Street 3,000 sqm - Richardson's Scrapyard and Brewers Paint Merchant Site, New England Street 2,000 sqm Blackman Street Site (land adjacent to Britannia House) (Source: Planning)

2019 sites do not come forward as anticipated. Refer to CP1

LOI Maintain and enhance the healthiness of the London Road Town Centre

Annual retail health checks to show an improvement from the 2011 baseline, across the Plan period (Source: Planning) Net additional retail floorspace provided city-wide and in designated centres. (Source: Planning)

Trigger: Annual retail check shows decline from 2011 baseline over 3 consecutive years Action: undertake health check assessment

Improve retail health and streetscape/public realm of London Road Shopping Centre

City Plan Part 2; SPD; Retail Studies and Retail Monitoring; Development Management process /BHCC; Developers; LTP; external funding mechanisms

LOI Adoption and implementation of the London Road Central Masterplan SPD.

Implementation of public realm improvements throughout the Plan period in accordance with the SPD Implementation Plan: By 2016/17:

• Providence Place - Ann Street

Trigger: Public Realm improvements work not commenced by 2016 Action: Review London Road SPD Implementation Plan


43







• London Road

• Oxford Street and Baker Street

(Source: Planning)

Improvements to local air quality

Air Quality Action Plan / BHCC; Landowners; Developers

LOI Improvement levels of air quality in the London Road area (This indicator to be reviewed following adoption of revised Air Quality Action Plan in 2014).

Ensure that the annual mean concentrations (Fg/m3) of NO2 decrease at three monitoring sites DT14, 13 and 12 across the Plan period Baseline 2009: DT14 52.1 Fg/m3 DT13 48.1 Fg/m3 DT12 44.9 Fg/m3 (Source: Air Quality Further Review and Assessment (2010), the Air Quality Action Plan (2011) and subsequent updates through the plan period)

Trigger: Annual mean increase in NO2 concentrations Action: Review Air Quality Action Plan and Transport Strategy for improving air quality


44

DA5 - Eastern Road and Edward Street Area

Strategic Objectives: SO1,SO2, SO3, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO19, SO20, SO21, SO22, SO23





Royal Sussex County Hospital

• 74,000 sqm hospital floorspace

To be completed by 2019 (Source: Planning)

Planning permission granted in January 2012 (see app BH2011/02886) with 5 years to implement. Trigger: Work not commenced by 2017 Action: Work with developers and partners to review barriers to development

Amount of development BHCC; Developers; Universities NHS Health Trust; University of Brighton; American Express


Edward Street Quarter 15,000 – 20,000 sqm employment floorspace 65 residential units To be completed by 2024 (Source: Planning)

Trigger: Planning application not submitted by mid 2018 Action: Development Management intervention


45







Circus Street

• 400 student bedspaces


• 3,200 sqm office space

• Dance studio

• 3,800 sqm education To be completed by 2019 (Source: Planning)

Trigger: Planning application not submitted by mid 2014 Action: Development Management intervention

Freshfield Road Business Park and Gala Bingo Hall: Comprehensive site redevelopment, to include minimum 110 residential units, B1 office/light industrial floorspace and B8 warehousing. To be completed by 2024 (Source: Planning)

Trigger: Planning application for Gala Bingo Hall site not submitted by 2016 Trigger: Planning application for rest of site not submitted by 2018 Action: Development Management intervention

Sustainable transport, public realm and townscape

Comprehensive Design Guide Implementation

LOI Preparation of design guidance for the DA5 area

Preparation of guidance by 2016 Implementation of targets in

Trigger: Work not commenced by beginning 2015


46







improvements funded by the LTP and developer contributions / BHCC; Developers, Neighbourhood Planning

and involvement of local communities in preparing guidance

guidance by 2030 (Source: Planning)

Action: Review of resources and priorities in Planning Strategy and Projects Team.

DA6 – Hove Station Area Strategic Objectives: SO1, SO2, SO3, SO4, SO6, SO7, SO8, SO9, SO10, SO11, SO12, SO13, SO16, SO19, SO20. SO22, SO23





Amounts of development

City Plan Part 2; BHCC; developers; landowners; Registered Providers


Development to include by 2030: Outside Conway Street Industrial Area

• 430 325 residential units

• 1,000 sqm additional employment floorspace

Conway Street Industrial Area


• retention/replacement of 12,000 sqm employment floorspace

Triggers:

• Redevelopment of Sackville Trading Estate (to deliver minimum of 92 res units and 5,080 sqm B uses) not commenced by 2017

• Redevelopment of Conway Street Industrial area (to deliver a minimum of 200 res units and retain a minimum of 12,00 sqm B uses) not


47

DA6 – Hove Station Area Strategic Objectives: SO1, SO2, SO3, SO4, SO6, SO7, SO8, SO9, SO10, SO11, SO12, SO13, SO16, SO19, SO20. SO22, SO23





with a shift into high quality flexible office/business (B1) floorspace

525 net additional dwellings: 0 - 2010-2014 117 - 2014-2019 228 - 2019-2024 179 - 2024-2030 (Source: Planning)

commenced by 2022

• Delivery of 50 residential units outside the above areas not commenced by 2022

• Delivery of 150 res units (in addition to the 50 by 2022) outside the above areas not commenced by 2026

Action: Development Management intervention

Improving townscape; public realm; open space; and public safety

BHCC; developer contributions; Neighbourhood Action plan (for Clarendon);Developers; landowners

LOI Prepare and implement guidance on enhancements for the area Preparation of design guidance for the DA6 area and involvement of local community in preparing guidance

Produce guidance by 2016 Ongoing implementation to 2030 (Source: Planning)

Trigger: Draft guidance not produced by end of 2015 (in consultation with landowners and Hove Station Area Neighbourhood Forum/community) Action: Review resources and priorities in Planning Strategy and Projects Team. Work with developers, landowners and community to produce guidance by end of 2016.


48

DA7 – Toads Hole Valley Strategic Objectives: SO1, SO2, SO3, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO13, SO14, SO15, SO19, SO20. SO22, SO23





Preparation of Planning Brief

BHCC; landowners, Highways Agency and partners, local community

LOI Adoption of Masterplan

By end of 2014 (Source: Planning)

Trigger: Work not commenced by December 2013 Action: Review resources and priorities in Planning Strategy and Projects Team

Amounts of development Development Policies and Sites Allocations DPD; Masterplan; BHCC; developers; landowners; health service providers


Development to include by 2020:


• 25,000 sqm employment

• Secondary school

• Public open space (2ha)

• Community facility

(Source: Planning)

Trigger: Planning permission submitted no later than end of 2014 Action: Development Management intervention; work closely with developer to overcome problems

Ensure a high standard of sustainability for new development at Toads Hole Valley

BHCC; Masterplan; developers

LOI Percentage of development meeting BREEAM “Outstanding” Rating or Code for Sustainable Homes Level 6 or with mitigation measures and/or achieving a One

100% of new development on site (Source: Planning)

Trigger: Planning permission – with requirement to meet code level 6 for sustainable homes or mitigation measures and with an action plan on achieving One Planet Principles (subject to recession measures) – granted no later than mid 2015 Action: Development Management


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DA7 – Toads Hole Valley Strategic Objectives: SO1, SO2, SO3, SO4, SO7, SO8, SO9, SO10, SO11, SO12, SO13, SO14, SO15, SO19, SO20. SO22, SO23





Planet Approach. intervention; advice and support given to Development Management team.

DA8 – Shoreham Harbour Area Spatial Objectives: SO1, SO2, SO3, SO4, SO6, SO7, SO8, SO9, SO10, SO11, SO12, SO13, SO16, SO17, SO18, SO19, SO20, SO21, SO22, SO23





Preparation of Joint Area Action Plan for Shoreham Harbour

BHCC; Shoreham Port Authority; Shoreham Harbour Regeneration Partnership; Adur District Council; West Sussex County Council

LOI Adoption of Joint Area Action Plan

By 2014 2015 (Source: Planning)

Trigger: Draft JAAP not completed by February 2014 Action: Review of resources and priorities in Planning Strategy and Projects Team.

Amount of development BHCC; Shoreham Port Authority; Shoreham Harbour Regeneration Partnership; Adur District Council; West


Development to include by 2030 and after approximately:


• 7,500 sqm employment floorspace

Trigger: sufficient applications for planning permission have not been submitted by mid 2019 to allow for completion of 200 residential units by 2024 Action: Development Management Intervention; Review JAAP


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DA8 – Shoreham Harbour Area Spatial Objectives: SO1, SO2, SO3, SO4, SO6, SO7, SO8, SO9, SO10, SO11, SO12, SO13, SO16, SO17, SO18, SO19, SO20, SO21, SO22, SO23





Sussex County Council; Developers; Registered Providers; Shoreham Harbour Joint Area Action Plan

Detail to be included within Joint Area Action Plan (Source: Planning)

SA1 - The Seafront Strategic Objectives: SO1, SO3, SO5, SO8, SO10, SO11, SO12, SO13, SO15, SO16, SO17, SO22, SO23



Indicator Reference / Indicator

Target / Timescale Trigger and Actions to be taken if target not being achieved

Amount of development; Improvement and regeneration of the seafront

BHCC; Developers; Planning Brief;

LOI Secure the redevelopment of the King Alfred/ RNR site to deliver sports facilities for local community and the city.

By 2018 development has commenced that will secure:

• new indoor wet/dry sports facilities delivered

• minimum 400 residential units

(Source: Planning)

Trigger: Application not submitted by 2016. Action: Regular reviews and risk management will be undertaken by King Alfred Project Board and preferred developer. Development Management intervention


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Monitor, conserve and expand coastal habitats; secure improvements to marine and coastal environment

City Plan Part 2; Developer contributions; BHCC; Natural England; DEFRA

LOI Net change in the area of natural habitat and Brighton & Hove Local Biodiversity Action Plan (Local BAP) habitats and species located on the seafront.

To see a net increase in the area of natural habitat and Local BAP habitats and species located within the development area on the seafront regular assessment over the plan period (Source: Planning & Parks & Green Spaces)

Trigger: Failure to see a net increase over first 5 years of plan period Action: Work with relevant stakeholder e.g. Natural England, landowners, wildlife and conservation groups to further promote and implement Local BAPs.

Maintain coastal protection

BHCC; City Plan Part 2; Developer Contributions; Shoreline Management Plan and Coastal Defence Strategies; Lewes District Council; Seafront Strategy

Coastal erosion and risk management

Single Data List Flood and coastal erosion risk management Revision of Brighton Marina to River Adur Defence Strategy to be completed by 2014. Brighton Marina to Saltdean strategy to be revised and updated by 2015 Ongoing Coastal Defence Maintenance

Trigger: Work on Brighton Marina to River Adur strategy not on course at start of 2014. Work on Brighton Marina to Newhaven strategy not started by mid 2014 Action: Work with Coastal Defence team, Lewes District Council, Environment Agency and partners to prioritise coastal defence strategies


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(Source: Coastal Defence team)

SA2 - Central Brighton Strategic Objectives: SO2, SO3, SO5, SO9, SO12, SO13, SO16, SO18, SO22, SO23





Reduction of crime Local Public Service Agreement; Community Safety, Crime reduction and Drugs Strategy 2011- 2014; Crime and Disorder Reduction Partnership; Sussex Police; Partnership Community Safety Team; East Sussex Fire and Rescue and BHCC

LOI Reduction in anti-social behaviour and violent crime Total crime in Regency Ward is used to monitor the impact of this policy, with further breakdowns into types of crime, where possible]

Annual reduction in anti-social behaviour and violent crime Baseline: Total crime in Regency Ward; 5,235 (2011/12) (Source: Partnership Community Safety Team)

Triggers and actions are set out in the Community Safety, Crime Reduction and Drugs Strategy 2011-14, which is annually updated and sets out priorities, and describes how priorities will be achieved


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SA2 - Central Brighton Strategic Objectives: SO2, SO3, SO5, SO9, SO12, SO13, SO16, SO18, SO22, SO23





Urban realm improvements

BHCC; Developer contributions; LTP2; SPDs; Public Space Public Life Study; City Plan Part 2; transport providers.

LOI Improvements to urban realm

Completion of identified programme of urban realm improvement - Station Gateway Project - by 2016 and ongoing: (Source: Local Transport Plan 2 3)

Public Realm improvements priorities and phasing and progress reviewed through LTP reviews.

Continuing role of Brighton as a Regional Shopping Centre

BHCC; City Plan Part 2; SPDs; landowners and developers

LOI Retain a healthy, viable Regional Shopping Centre

Annual health checks to show no net increase in vacancies. Annual completions of new retail floorspace in the Regional Centre (Source: Planning)

Trigger: Annual retail health check shows decline from 2011 baseline over 3 consecutive years Action: Undertake health check assessment.


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SA3- Valley Gardens Strategic Objectives: SO10, SO11, SO12, SO13, SO15, SO16, SO17, SO20, SO22, SO23

Implementation / Issue Delivery Mechanism / Partners



Comprehensive landscape/townscape scheme including improved pedestrian and cycle routes to regenerate Valley Gardens from the Level to Old Steine.

BHCC; funding from various sources including S106 funds; Local Transport Plan; developers; Heritage Lottery Fund.

LOI Implementation of comprehensive landscape/townscape scheme

Approval of scheme by 2015; funding identified and in place by 2020. Completion of scheme by 2030 (Source: Planning)

Trigger 1: Review of scheme at end of 2014 finds approval not on track. Trigger 2: Review of scheme mid 2019 finds projected funding shortfall. Action: Review priorities and resources in Planning Strategy & Projects Team and Sustainable Transport department. Review scope and aims of scheme, consider consulting on alternative approach.

Landscaping scheme for The Level

BHCC; funding from various sources, including S106 funds, Heritage Lottery Fund, Big Lottery Fund, and developers.

LOI Implementation of a landscaping scheme for The Level

Completion by 2013 (Source: Planning)

Landscaping scheme is underway, on schedule for completion by end of 2013. No trigger or action necessary.


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SA3- Valley Gardens Strategic Objectives: SO10, SO11, SO12, SO13, SO15, SO16, SO17, SO20, SO22, SO23




Repair and restoration of historic buildings

BHCC pro-active campaign and use of statutory powers; possible historic area grant scheme; Landowners; Building Preservation Trusts; English Heritage and/or Heritage Lottery Fund.

LOI Decrease in the number of Buildings at Risk over five year period.

Monitor across the Plan period - baseline at 2009/2010: 6 buildings (Source: Planning)

Trigger: Number of Buildings at Risk has not decreased by 2015. Action: Resource priorities in the Heritage team to be reviewed.


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SA4- Urban Fringe Strategic Objectives: SO9, SO10, SO13, SO14, SO15, SO17, SO23




Target / Timescale Trigger and Action to be taken if target not being achieved

Protection of groundwater source protection zones

EU Water Framework Directive and Environment Agency Flood Management Plans; Surface Water Management Action Plan; Farmers; Landowners; Environment Agency; BHCC; Developers

Single Data List Monitor number of planning permissions granted contrary to Environment Agency advice

Target to be zero planning consents unless or appropriate mitigation secured. Monitor annually monitored across the Plan period (Source: Planning and the Environment Agency)

Trigger: Any consent without appropriate mitigation. Action: review Development Management processes.

Protect and enhance the South Downs natural beauty

BHCC; City Plan Part 2; The Downland Initiative; Green Network; PAN 01; Sheepcote Valley Management Plan; Farmers; Landowners; Developers

LOI Monitor the number Number of planning permissions granted contrary to an objection from the South Downs National Park Authority for development affecting the setting of the South Downs National Park

Monitored Monitor annually. Zero planning consents unless appropriate mitigation secured. No applications during the plan period. (Source: Planning)

Trigger: Any consent without appropriate mitigation. Action: Review Development Management processes.

Conserve and enhance downland habitats and species

BHCC; Natural England; landowners; wildlife and conservation groups

LOI Net change in Local BAP habitats and number of Local BAP species

To see a net Net increase in Local BAP habitats and species located within the urban fringe over the plan period. (Source: Planning & Parks & Green Spaces)

Trigger: Failure to see a net increase over first 5 years of plan period Action: Work with relevant stakeholder e.g. Natural England,


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SA4- Urban Fringe Strategic Objectives: SO9, SO10, SO13, SO14, SO15, SO17, SO23




Target / Timescale Trigger and Action to be taken if target not being achieved landowners, wildlife and conservation groups, to further promote and implement Local BAPs.

SA5 - The Setting of the South Downs National Park

Strategic Objectives: SO10, SO14, SO15, SO17, SO22, SO23




Protect and enhance the South Downs natural beauty with South Downs National Park Authority

South Downs National Park Authority, BHCC; City Plan Part 2; The Downland Initiative; Green Network; Brighton and Hove and Lewes Downs Biosphere Partnership; South Downs Way Ahead Nature Improvement Area; PAN 01; Sheepcote Valley Management Plan; Farmers;

LOI Number of planning permissions granted contrary to an objection from the South Downs National Park Authority for development affecting the setting of the South Downs National Park

Monitored annually - No applications granted contrary to an objection from SDNPA during the plan period - Monitored annually. (Source: Planning)

Trigger: Application granted contrary to an objection from SDNPA Action: Review development management procedure and practice. Work in Partnership with SDNPA to agree appropriate approach to development/land uses within the setting to minimise harmful impact upon the National Park. Review requirement for SPD on development


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Landowners; Developers

affecting South Downs National Park

Achieving Biosphere status South Downs National Park Authority, Brighton and Hove and Lewes Downs Biosphere Partnership; BHCC; Lewes District Council; Mid Sussex District Council; Environment Agency; Natural England; National Trust; farmers; landowners; wildlife and conservation groups;

LOI Achieving Biosphere status and implementation of management plan

UNESCO decision on proposed Biosphere by 2014 Management plan implementation ongoing across plan period. (Source: UNESCO, City Infrastructure and Planning)

Conserve and enhance downland habitats and

BHCC; Natural England;

LOI Net change in BAP

Net increase in BAP habitats and species located within

Trigger: No average net increase for five consecutive


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species

landowners/tenants; South Downs National Park Authority; wildlife and conservation groups

habitats and number of BAP species

the setting of the National Park and on Council owned land within the National Park (Source:Parks and Green Spaces)

years Action: Work with Parks and Green Spaces department and external partners to publicise need to conserve and enhance downland habitats and species; consider need for habitat regulation statements with planning applications in downland areas


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SA6- Sustainable Neighbourhoods Strategic Objectives: SO2, SO3, SO4, SO7, SO8, SO9, SO10. SO11, SO12, SO13, SO15, SO16, SO17, SO18, SO19, SO20, SO21, SO22, SO23




Reducing Inequality Sustainable Community Strategy; City and Employment Skills Plan; developer contributions’ Infrastructure Delivery SPD; comprehensive design guide / Universities; community and voluntary sector; Police Service; developers; BHCC

LOI Proportion of children in poverty

Baseline 07/08 20% (data from child poverty) Yearly decrease Targets 08/09 (19%), 09/10 (18%) 10/11 (17%) (Source: BHCC)

Trigger: No decline by 2015 Action: review sustainable community strategy; review employment skills plan.

Reducing waste BHCC; Public Sector and Community and Voluntary Sector Partners

Single Data List Percentage of household waste sent for reuse, recycling and composting.

Targets to be: 1. 45% by 2015/16 2. 50% by 2020/21 3. 55% by 2025/26

(Source: Single Data List)

Targets for waste recycling and recovery are transposed from the adopted East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan (WMP). Should they not be met, actions will be taken through the monitoring and implementation framework of the WMP.


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SA6- Sustainable Neighbourhoods Strategic Objectives: SO2, SO3, SO4, SO7, SO8, SO9, SO10. SO11, SO12, SO13, SO15, SO16, SO17, SO18, SO19, SO20, SO21, SO22, SO23




CP1 – Housing Delivery Strategic Objectives: SO4, SO9, SO12, SO19, SO20 Implementation / Issue Delivery Mechanism /

Partners Indicator Reference / Indicator


Housing delivery Net additional homes completed per annum in accordance with Housing Implementation Strategy (HIS) delivery framework

BHCC; Developers; Registered Providers

Single Data List Monitor net additional homes provided per annum

Average annual housing completions over a 3 year period to comply with the delivery rates outlined in HIS delivery framework Annually monitor net housing completions within the city. (Source: Single Data List)

Trigger: Annual completions over a 3 year period fall below anticipated delivery rates outlined in HIS by more than 15% Action: Review housing trajectory and review HIS delivery rates in HS delivery framework. Promote sites and residential development through working with delivery partners.

Rolling 5 Year Supply of ‘Deliverable’ sites

BHCC; Developers; Registered Providers; SHLAA; and residential

LOI Supply of ready to develop housing sites

To Annually have a rolling 5 year supply plus 5% of deliverable housing plus

Trigger: Lack of a 5 Year Supply for 2 consecutive years.


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CP1 – Housing Delivery Strategic Objectives: SO4, SO9, SO12, SO19, SO20 Implementation / Issue Delivery Mechanism /



monitoring /BHCC; Stakeholders, Housing Implementation Strategy

NPPF buffer of 5%. sites in pipeline taking account of net annual completion rates. To be reported annually in SHLAA Update and the Annual Authority Monitoring Review Report (Source: Single Data List)

Action: Review actions listed in HIS to promote sites and residential development through working with delivery partners. Undertake new SHLAA with call for sites. Seek further housing sites to allocate through Part 2 of City Plan.

CP2 Sustainable Economic Development Strategic Objectives: SO1, SO2, SO3, SO6, SO7, SO9, SO13, SO20, SO21





Review annually (Source: Corporate Plan)

For monitoring only (no trigger or action necessary)

BHCC; developers; businesses; Wired Sussex



Move to low carbon economy/growth of digital media and environmental technology companies

LOI Growth in number of digital media businesses LOI Growth of the environmental industries sector LOI Increase the number of businesses relocating to the city




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CP2 Sustainable Economic Development Strategic Objectives: SO1, SO2, SO3, SO6, SO7, SO9, SO13, SO20, SO21





Delivery of ICT infrastructure

Government funding; BHCC; BT and Virgin Media

LOI Delivery of ultra-fast broadband in key areas of city. SME take-up of high-speed broadband connection voucher scheme

Roll out by 2015 Uptake of voucher scheme by 1,000 SME by 2015 (Source: BHCC City Regeneration)

Trigger: Voucher scheme not taken up by at least 500 SME by end of 2014 Action: Prioritise Promotion of voucher scheme to SME in Central Brighton area; review resources for voucher scheme project

Apprenticeships, training and job opportunities for local residents

BHCC; developers; Brighton and Hove Local Employment Scheme

LOI Providing local employment and apprenticeships on development sites.

Achieve minimum 20% target for local employment and apprenticeship training on development sites across the plan period. (Source: Planning)

Trigger: Target not achieved for two consecutive years. Action: Review Brighton & Hove Local Employment Scheme

CP4 - Retail Provision Strategic Objectives: SO3, SO5, SO18





Assessment of need/capacity for additional retail provision and health of retail centres

Update or review of Brighton and Hove Retail Study / BHCC

LOI Review/update of Retail Study (2011) for Brighton and Hove. at least every 5 years

Review at least every 5 years across the Plan period (Source: Planning)

Trigger: Council’s annual retail health checks show decline from 2011 baseline over 3 consecutive years in Regional Centre.


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Action: undertake review of study earlier.

CP3 Employment Land Strategic Objectives: SO1, SO2, SO3, SO9, SO13, SO20, SO21





Protection of prime office floorspace in central Brighton

BHCC; developers; landowners

LOI Total amount of office floorspace within central Brighton

No net loss of existing office floorspace in central Brighton over plan period unless the tests in policy SA2 are met. To be monitored annually (Source: Planning)

Trigger: Target not met for two consecutive years Action: Review Development Management processes.

Protection of primary industrial estates and business parks


LOI Total amount of employment floorspace by type (gross and net) within the eleven industrial estates and business parks

No net loss of employment (B1, B2 and B8) floorspace within any area listed in part 3 of the policy to be monitored annually (Source: Planning)

Trigger: Target not met for two consecutive years Action: Review Development Management processes.

Creation of modern, flexible floorspace on identified employment sites


LOI Modern employment floorspace created on redeveloped sites within the identified employment sites Total amount of additional employment floorspace - by type (gross and net).

Redeveloped floorspace within the five identified sites Average annual employment floorspace completions over a 3 year period to comply with the average annual delivery rates outlined in the Employment Land Supply Trajectory (Source:

Trigger: Average annual completions over a 3 year period falls below anticipated delivery rates outlined in Employment Land Supply Trajectory by more than 15% Action:

• Negotiation on particular sites to overcome specific


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CP3 Employment Land Strategic Objectives: SO1, SO2, SO3, SO9, SO13, SO20, SO21





Planning) economic viability issues;

• Exploring alternative funding mechanisms and/or the potential for enabling development.

• Consider scope to help accelerate the phasing of later schemes if 2014-2019 sites do not come forward as

• Review Employment Land Supply Trajectory.

• Seek further employment sites to allocate through Part 2 of City Plan.

CP5 Culture and Tourism Strategic Objectives: SO6, SO9, SO10, SO11,

SO12, SO15





Improve the cultural, tourist and historic offer of the city

BHCC; Tourism Strategy; Brighton and Hove Economic Partnership; Tourism South East; developers; landowners

LOI Improving the visitor economy

Annual Improvement Target: 2011/12 - £732m; and 2012/13 - £746m Baseline 2009 - £732 million (Source: City Performance Plan)

The City Performance Plan is regularly reviewed with strategic partners. No further triggers and actions necessary.


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CP6 Hotel and Guest House Accommodation

Strategic Objectives: SO3, SO5, SO13





Sequential approach to site selection for new major hotel facilities

BHCC; developers and landowners

LOI All proposals for new major hotel facilities to use the sequential approach (central Brighton first)

100% of applications during the Plan Period (Source: Planning)

Creation of apprenticeship schemes / local jobs

Hotel industry and BHCC

LOI Creation of apprenticeship scheme between BHCC and hoteliers

Commence operation of scheme by 2016 (Source: Visit Brighton)

Trigger: No significant interest from city hoteliers in joining apprenticeship scheme by 2015 Action: Liaise with Visit Brighton to review priorities and resources; work proactively with city hoteliers to publicise and scheme and review reasons for lack of uptake.

Ongoing monitoring of the implementation of hotel commitments and proposals in central Brighton Managing visitor accommodation growth

Through ongoing monitoring in house / BHCC, and developers and landowners

LOI Gains/ losses in Number of new hotel bedrooms (linked to demand forecasts set out in the Hotel Futures study) Losses of hotel bedrooms outside Hotel Core Zone

12% 15% net increase by 2016 (Source: Planning and Visit Brighton) Baseline: 2006 160 hotels and guest accommodation establishments with 4,293 letting bedrooms (Source Hotel Futures Study 2006)

Trigger: Indicative target for net additional serviced rooms in 2016 is significantly exceeded. Action: Undertake review of Hotel Future Study to update assessment of future demand and inform application of CP5 Visitor Accommodation.


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CP7 - Infrastructure and Developer contributions






Determine a decision, following outcome of further study evidence for progressing and adopting a Community Infrastructure Levy (CIL)

BHCC; consultants; developers; landowners and agents

LOI Preparation and adoption of CIL

Progress and determine adoption of CIL post 2014 (Source: Planning)

Trigger: No decision made regarding adopting CIL prior to draft City Plan Part 2 Actions: Review priorities and resources in Planning Strategy & Projects Team. Developer contributions to be provided through necessary s106 obligations only subject to meeting statutory tests if CIL not progressed

To secure the necessary works and contributions towards appropriate infrastructure to support new development

BHCC; Developer Contributions process including S106 and CIL following adoption post 2014; Infrastructure Delivery Plan Annex 1; developers, public and private sector

LOI Provision of appropriate social, environmental and physical infrastructure to support new development

100% compliance on all annual implemented development - Ongoing monitoring throughout the Plan period (Source: Planning)

Trigger: Developer contributions not forthcoming following implementation of development Actions: Review developer contributions/s106 monitoring and project management processes Annual review of Developer Contributions temporary recession ‘relief’ measures


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CP7 - Infrastructure and Developer contributions






service providers

Review development management processes

Review and update Infrastructure Delivery Plan Annex 1

BHCC; external infrastructure providers/partners

Review and update Infrastructure Delivery Plan Annex 1

Ongoing monitoring and annual review, and update -throughout the Plan Period

Trigger: Annual review 3 months overdue. Action: Review developer contributions/s106 monitoring and project management processes


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CP8- Sustainable Buildings Strategic Objectives: SO4, SO7, SO10, SO22 Implementation / Issue




Sustainable building standards assessment

Sustainability Checklist; SPD;

BHCC; Developers; landowners

LOI % of new developments and conversions that meet minimum building standard requirements for B&H:

a) Residential new build;

b) Residential conversions

To be monitored annually throughout plan period; Targets as set out in policy CP8. (Source: Planning)

Trigger: Annual % of developments that meet targets fall below 70% Action: Review Development Management procedures; review Sustainable Buildings SPD

Reducing carbon emissions

Sustainability Checklist; SPD; BHCC; Developers; landowners

LOI Percentage of applications approved for new developments or conversions % of developments and conversions that are:

• zero carbon

• carbon neutral

To be monitored annually throughout the plan period Targets (to be met by 2015):

• Zero carbon: 50% of new developments

• Carbon Neutral: 50% of new developments and conversions

(Source: Planning) Target to be reviewed in 2016 and 2019 following uplift in building standard requirements

Trigger: Target is not met by 2015 Action: Review Development Management procedures; review Sustainable Buildings SPD


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CP9 - Sustainable Transport Strategic Objectives: SO1, SO3, SO11, SO14 Implementation / Issue




Bus Priority Infrastructure Improvements

BHCC; Local Transport Plan; public transport providers; developer contributions

LOI/LTP Delivery of bus priority infrastructure improvements on the following corridors

• Lewes Road (A270)

• Edward Street and Eastern Road

• A259 Seafront

• London Road

Delivery of improvements by:

• 2016 (Lewes Road (A270) and Edward Street and Eastern Road schemes)

• 2024, dependent on funding and democratic approval (A259 Seafront and London Road schemes)

(Source: Planning and Local Highway Authority)

Lewes Road: works already commenced and due for completion in 2013. No trigger/action necessary. Edward Street: Trigger: Traffic orders not started by end of July 2014 (due to go to Committee mid Oct 2013). Action: review work programme and funding sources (LTP3; regional and national sources) Seafront, London Road: Long-term targets. Progress to be reviewed in 2020 AMR; appropriate trigger/action to be added.

Local bus journeys originating in the Local Authority Area

BHCC; Local Transport Plan; public transport providers; developer contributions

LOI/LTP City Performance Plan – Promoting sustainable transport

Average increase of 800,000 passenger journeys per year (annual check based on 5-year average) (Source: BHCC)

Trigger: Average annual increase in journeys is below 500,000 Action: review transport strategy; review targets in LTP4

Contribute to creating a cleaner, safer and quieter city

BHCC; public transport providers; taxi

LOI Reduction in CO2 emissions from

Reduction of 4% per year in transport related CO2 emissions throughout plan period.

Trigger: no reduction by 2014 Action: review measures in Air


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CP9 - Sustainable Transport Strategic Objectives: SO1, SO3, SO11, SO14 Implementation / Issue




firms, car clubs, developers; landowners and businesses in the city (through Green Travel Plans) and Schools, Colleges and Universities; residents; developer contributions

transport within Brighton and Hove (This indicator to be reviewed following adoption of revised Air Quality Action Plan in 2014).

Baseline 1.2 tonnes per capita – 2009 (Source: www.decc.gov.uk – formerly NI 186)

Quality Action Plan

CP10 – Biodiversity Strategic Objectives: SO1, SO10, SO14, SO15 Implementation / Issue Delivery

Mechanism / Partners



Establish a ‘green network’

Developers; landowners; developer contributions; South Downs Way Ahead Nature Improvement Area; Nature Conservation and Development SPD; regional and

LOI Adoption of a ‘green network’

Creation of 60 ha of new BAP habitat by 2030, in accordance with the requirements of the Open Space Strategy to deliver new accessible natural green space. (Source: Planning & Parks & Green Spaces)


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national agencies Proposals Map / BHCC; Natural England Sussex Wildlife Trust South East England Biodiversity Forum

Implement a strategic approach to Nature Conservation/Biodiversity

South Downs Way Ahead Nature Improvement Area (NIA); Nature Conservation and Development SPD; developer contributions/CIL; Local BAP; Brighton and Hove and Lewes Downs Biosphere Partnership; Developers; Landowners; BHCC; Natural England; Sussex Wildlife Trust;

LOI Amount of open space within the NIA and/or classified “Natural and Semi Natural” lost to development annually

Target: zero – unless appropriately mitigated (Source: Planning)

Trigger: target not met for three consecutive years Action: review Development Management procedures and practices / review the need for a report to document the cause and reason for the loss to inform future planning decisions


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South East England Biodiversity Forum

Maximising opportunities to conserve and enhance biodiversity

SPD; City Plan Part 2; Biodiversity Action Plan; Developers; developer contributions; landowners; BHCC

LOI Increased biodiversity and achieving Biodiversity Action Plan targets

All development proposals to deliver a net increase in biodiversity in accordance with the requirements of the Nature Conservation and Development SPD and Biodiversity Action Plan by 2030 (Source: Planning)

Trigger: Annual net decrease in biodiversity for three consecutive years Action: Review Development Management procedures and practices. Review the need for a report to document the cause and reason for the decrease in biodiversity to inform future planning decisions. Where appropriate review Nature Conservation and Development SPD and Biodiversity Action Plan.


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CP11 - Flood Risk Strategic Objectives: SO1, SO8, SO9, SO17




Identification of flood risk areas

Proposals Map; Strategic Flood Risk Assessment (SFRA); BHCC

LOI Review of the SFRA

Update at least every five years across the Plan period (Source: Planning)

Trigger: Work on review of SFRA not commenced within five year period. Action: Review priorities and resources in Planning Strategy & Projects team.

To prevent inappropriate development in areas of high flood risk

City Plan Part 2; BHCC; Environment Agency;

Single Data List Number of planning permissions granted contrary to the advise of the Environment Agency on flood defence grounds

No planning permissions granted; to be monitored annually across the Plan period (Source: Single Data List)

Trigger: Any such planning permission granted. Action: Review development management processes.

Managing flood risk and mitigating climate change

BHCC; Environment Agency; DEFRA

Production of a Surface Water Management Action Plan for the city

Adoption by 2015 and reviewed regularly throughout the plan period (Source: Planning)

Trigger: Work on Surface Water Management Action Plan not commenced by start of 2015. Action: Review priorities and resources in Planning Strategy & Projects team.


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CP12 - Urban Design Strategic Objectives: SO4, SO9, SO12, SO16, SO23 Implementation / Issue Delivery




Urban Design Framework BHCC; developers and landowners

LOI A city-wide urban design framework SPD to be adopted

Adoption by 2014 (Source: Planning)

Trigger: Formal public consultation not underway by June 2014. Action: resources and priorities in the Heritage, Planning Strategy and Projects Teams to be reviewed.

Design criteria BHCC; City Plan Part 2; masterplans; Developers and landowners

LOI Appeal success rate for schemes where design is a principle issue.

Annual target of 70% appeals dismissed where urban design and Policy CP2 are principle principal issues (Source: Planning)

Trigger: Target not achieved Action: Review Development Management design practice; review design-related supplementary planning documents.


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CP13- Public Streets and Spaces Strategic Objectives: SO12, SO13, SO16, SO22, SO23




Improving the public urban realm

LTP; Area Action Plans; Planning Obligations; and Business Improvement Districts / BHCC; developers; landowners and BID partnership boards

LOI Number of developments permitted with planning obligations to provide mitigation in relation to the surrounding area towards public realm improvements

Target not applicable. Indicator to be monitored annually across the Plan period (Source: Planning)

CP14 Housing Density Strategic Objectives: SO1, SO4, SO9 Implementation / Issue Delivery




Achieving density targets BHCC; Area Action Plans; area-based SPDs; Urban Design Framework SPD; developers and landowners

LOI Net density levels across the city and within defined Development Areas (DA’s)

Achieve a net density of at least 50 dph in 85% of all new developments across the city and 100dph in 100% of new developments within Development Areas excluding DA7 – Toads Hole Valley. To be monitored across the plan period

Trigger: Target not achieved annually Action: review Development Management practice regarding density of developments; review Annex 3 (Housing Implementation Strategy).


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CP15 Heritage Strategic Objectives: SO6, SO9, SO10, SO11, SO12, SO15




Preserve and enhance the historic environment and heritage assets (conservation areas)

BHCC; Conservation area appraisals / studies; Article 4 Directions; SPD on ‘Architectural Features’; Repairs Notices; English Heritage; Heritage Lottery Fund; National and local amenity societies.

LOI Preparation and reappraisal of conservation area appraisals/studies

100% coverage of conservation area appraisals by 2018. (Source: Planning)

Trigger: 80% coverage not completed by 2017 Action: Review resources and priorities in Heritage, Planning Strategy and Projects Teams.

Preserve and enhance the historic environment and heritage assets (locally listed buildings)

BHCC; Conservation area appraisals / studies; Buildings At Risk register; Local List; SPD on ‘Architectural Features’; Repairs Notices; English Heritage; Heritage Lottery Fund; National and local amenity societies.

LOI Production of new Local List.

New Local List adopted by 2014 (Source: Planning)

Local List consultation is complete and assessment is underway, on schedule for adoption by end of 2014. No trigger or action necessary.

Preserve and enhance the historic environment and heritage assets (listed

BHCC; Conservation area appraisals / studies;

LOI Introduction of Supplementary Planning

New guidance adopted by 2017 (Source: Planning)

Trigger: SPD preparation not underway by 2016


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CP15 Heritage Strategic Objectives: SO6, SO9, SO10, SO11, SO12, SO15




buildings) Buildings At Risk register; SPD on ‘Architectural Features’; Repairs Notices; English Heritage; National and local amenity societies.

Document on Listed Buildings

Action: Review resources and priorities in Heritage, Planning Strategy and Projects Teams.

CP16 - Open Space Strategic Objectives: SO10, SO13, SO15, SO23 Implementation / Issue Delivery




Retention of existing open space

BHCC; open space and sports studies and strategies; landowners; developers; schools, Neighbourhood Plans

LOI Amount of open space lost to development annually


Trigger: target not met for three consecutive years Action: review Development Management procedures and practices / Review the need for a report to document the cause and reason for the loss of open space to inform future planning


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CP16 - Open Space Strategic Objectives: SO10, SO13, SO15, SO23 Implementation / Issue Delivery



Target / Timescale Trigger and Actions to be taken if target not being achieved decisions

Enhancement and improvement of existing open space

BHCC; City Plan Part 2; open space and sports studies and strategies; developers and landowners; schools

LOI Amount of all developer contributions/CIL provided towards open space enhancement/improvement

Target not applicable – monitored annually across the plan period (Source: Planning)

For monitoring only; no trigger and action necessary

Creation of new open space

BHCC; City Plan Part 2; open space and sports studies and strategies; developers and landowners; schools (including dual use of sites); farmers

LOI Amount of new open space created within the city

No target applicable To be monitored annually across the Plan period (Source: Planning)



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CP17 – Sports Provision Strategic Objectives: SO15, SO20, SO22 Implementation / Issue Delivery




Retention of existing sports provision

BHCC; City Plan Part 2; Existing and future sports strategies; educational establishments; landowners; developers

LOI Amount of indoor and outdoor sports facilities and space lost to development annually


Trigger: target not met for three consecutive years Action: review Development Management procedures and practices / Review the need for a report to document the cause and reason for the loss in sports facilities and space to inform future planning decisions

Creation of new sports facilities and space

BHCC; City Plan Part 2; Existing and Future Sports Strategies, Developer Contributions, educational establishments (including the dual use of school grounds where appropriate);

LOI Number of developments providing sports facilities and/or space on site or through developer contributions

No target applicable To be monitored annually across the Plan period (Source: Planning)



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CP18 - Healthy City Strategic Objectives: SO20, SO22, SO23 Implementation / Issue Delivery




Positively influencing the determinants of health

LTP; Planning Obligations; Public Health and other health authorities; BHCC; Highway authority; Developers; Landowners and BID partnership boards

LOI Review of Health Impact Assessment and scoping exercises to establish effectiveness of CP18

At least every 5 years across the plan period. (Source: Planning)

Trigger: Formal challenge by Health and Wellbeing board or Director Public Health Action: report to partnership boards or H&W Board

Provision of future health services in the city

City Plan Part 2 / BHCC

LOI Adoption and implementation of the City Plan Part 2

Adoption by 2016 (Source: Planning)

Trigger: slow adoption of City Plan Part 2 Action: Assess requirement for planning briefs or SPD to bring forward provision

Health impact assessments (HIA) for strategic developments devts

Developers; BHCC LOI Submission of a Health Impact Assessment as part of planning applications for strategic developments.

HIA submitted with 100% of strategic developments in the city over plan period (Source: Planning)

Trigger: Approval of planning permission for strategic development without HIA Action: Review Development Management processes


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CP18 - Healthy City Strategic Objectives: SO20, SO22, SO23 Implementation / Issue Delivery




CP19 – Housing mix Strategic Objectives: SO4, SO9, SO12, SO19, SO20 Implementation / Issue Delivery




Improve housing choice and mix across the city. Policy on housing mix

BHCC; Developers, Registered Providers. Preparation of Part 2 of City Plan.

LOI Adoption of City Plan Part 2 setting out key housing mix objectives

Target: adoption date of 2016 Secure appropriate policies and site allocations for different housing types to meet range of and accommodation needs in Part 2 of City Plan. (Source: Planning)

Trigger: City Plan Part 2 not adopted by 2017. Action: Review programme for Part 2 of City Plan. Promote the need for range of housing types and sizes through City Partnerships. Review Housing Strategy for different accommodation needs.

Provide additional family sized housing. Achievement of appropriate housing mix

BHCC; Developers; Registered Providers

LOI Monitor the number of Number of 1, 2 and 3+ beds completed annually. Benchmark against 2011 census

Target: To see an increase in the proportion of family sized units over the first five years of the plan. To improve housing choice and provide additional

Trigger: Target not met in year 4 of monitoring period Action: Promote the need for range of housing types


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CP19 – Housing mix Strategic Objectives: SO4, SO9, SO12, SO19, SO20 Implementation / Issue Delivery




family housing across the plan period in accordance with adopted DPD. Between 2016 – 2030 (Source: Planning)

and sizes through City Partnerships. Review Housing Strategy for different accommodation needs.

CP20 – Affordable Housing Strategic Objectives: SO1, SO4, SO9, SO11, SO19, SO20 Implementation / Issue Delivery Mechanism /


Target / Timescale Trigger and Actions to be taken if policy not being achieved

Achieve a net increase in Achieving affordable housing numbers

BHCC; Developer Contributions SPD; Developers; Registered Providers; Housing Corporation

Single Data List Net Monitor net affordable housing completions secured across the city.

To achieve approximately 30% of all housing delivery as affordable housing. Monitor annually proportion of affordable housing provided (or delivered?) on (1) sites of 15 dwellings or more; (2) sited of 10 – 14 dwellings; and (3) sites of 5 – 9 dwellings. (Source: Planning Single Data List)

Trigger: Affordable housing delivery across a 3-5 year period falls below 30% Action: Work with Registered Providers to secure greater delivery. Promote council owned sites for affordable housing. Review Policy.

Affordable housing mix of unit sizes

Developer Contributions; Developers; Registered Providers; BHCC

LOI Monitor annually % of affordable housing completed reflecting a unit size mix indicated in Policy. mix comprising

To broadly achieve unit size mix indicated in policy CP20 over a 5 year period. To be monitored annually throughout the plan

Trigger: affordable housing unit size mix falls below citywide preferred unit size mix across a 5 year period.


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CP20 – Affordable Housing Strategic Objectives: SO1, SO4, SO9, SO11, SO19, SO20 Implementation / Issue Delivery Mechanism /


Target / Timescale Trigger and Actions to be taken if policy not being achieved

30% one bedroom units; 45% two bedroom units and 25% 3+ bedroom units

period. (Source: Planning)

Action: Work with Registered Providers to secure a better mix. Promote council owned sites for specific types of affordable housing. Review Policy.

Financial contributions towards the provision of affordable housing

BHCC; developers; Registered Providers

LOI Financial contributions secured per annum

No target applicable. Annual monitoring of contributions secured for affordable housing. (Source: Planning)

CP21 Student Accommodation and Houses in Multiple Occupation

Strategic Objectives: SO4, SO11, SO19, SO21




Ongoing monitoring of the implementation of purpose built student accommodation

BHCC; educational institutions; developers

LOI Number of new purpose built student bedspaces developed

100% of allocated sites (Pelham Street, Circus Street, Varley Halls, Preston Barracks and East Slope) delivered by 2020 Completion of commenced allocations by 2014

• Varley Halls

Trigger: Planning applications for Preston Barracks, Pelham Street and Circus Street not submitted by 2015 Action: Development Management


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• East Slope By 2018 development has commenced that will secure the following sites

• Preston Barracks

• Pelham Street

• Circus Street (Source: Planning)

Intervention

Ongoing monitoring of concentrations of Houses in Multiple Occupation

BHCC; landlords; developers; letting agents; education providers

LOI Number of streets covered by the article 4 direction with proportion of Houses in Multiple Occupation (mixed C3/C4, C4 or sui generis) in excess of 10%.

Less than 175 streets with 10% or more properties in use as a House in Multiple Occupation (Source: Planning)

Ongoing monitoring of the implementation of purpose built student accommodation

BHCC; educational institutions; developers

LOI Number of developments for student accommodation allowed on appeal within the Article 4 wards

No appeals allowed (Source: Planning)

Trigger: Over 25% appeals allowed annually Action: review Development Management procedures; review policy

Ongoing monitoring of concentrations of Houses

BHCC; landlords; developers; letting agents;

LOI Number of developments

No appeals allowed (Source: Planning)

Trigger: Over 25% appeals allowed


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in Multiple Occupation education providers for HMOs allowed on appeal within the Article 4 wards

annually Action: review Development Management procedures; review policy

CP22 –Traveller Accommodation Strategic Objectives: SO1, SO4, SO19, SO20




Target / Timescale

Trigger and Actions required if policy not being achieved

Assessing Update Traveller Accommodation Requirements

Gypsy and Traveller Accommodation Assessment updates / BHCC; GTAA Partners and Stakeholders.

LOI Update of Traveller Accommodation Assessment

Review at least Traveller accommodation needs assessment to inform longer term pitch requirements (post 2019) for the City. every 5 years across the Plan period. (Source Housing & Social Inclusion and Planning)

Trigger: Needs Assessment Update not completed by April 2014. Action: Work with partner authorities to complete update of assessment. Review resources in Planning Policy & Projects Team.


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CP22 –Traveller Accommodation Strategic Objectives: SO1, SO4, SO19, SO20




Target / Timescale

Trigger and Actions required if policy not being achieved

Provision of Traveller accommodation

BHCC; Part 2 of City Plan or Site Allocations DPD; Registered Providers; Landowners; Developers

LOI Net additional pitches provided

Identify sufficient deliverable sites for the provision Provision of 18 permanent residential pitches before 2019. Provision of additional pitches to meet assessed requirements over plan period. (Source Planning)

Trigger: Sufficient pitches are not in development pipeline by 2017. Action: Undertake revised site search to identify further site opportunities. Work with HCA and other providers to secure appropriate funding where necessary.


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Appendix 3 – Infrastructure Delivery Plan (updates only)

Infrastructure Type – and Area

Development Area/ Strategic Allocation – due for construction

Infrastructure need and Requirements

Area and /or Scale

Responsibilities for Delivery/Partners and Funding Sources

Short, Medium or Long Term Phasing and Costs

Flood Defences - Shoreham Harbour Development Area

Essential Important infrastructure for development DA8 Shoreham Harbour - Comprehensive development of Port: Phases

Upgraded flood defence and essential on-site highways - if land uses change from current port water compatible uses Repair / replacement of wharf walls for development sites adjacent to the wharf frontage may be required, including corrosion control measures where appropriate.

DA8 Shoreham Harbour – South Portslade/Aldrington Basin, in accordance with requirements in Development Brief as part of emerging JAAP for the area; informed by updated SFRA

Environment Agency, Landowners, Developers

Completion before each phase of development bought forward £3m (indicative) Costs dependant on scale, type and impacts of development Condition survey of walls currently underway

Waste and Wastewater Essential infrastructure for development Strategic allocations on Eastern Road and Edward Street – first site RSCH

Water and wastewater management and infrastructure.

DA5 Eastern Road and Edward Street - Southern Water has identified the need for water and wastewater infrastructure to serve new development at RSCH, Edward Street Quarter and Freshfield Road Business Park

Universities NHS Trust, Southern Water, Developers

By 2016


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Essential infrastructure for development (general)

Timely provision of new or improved water and wastewater infrastructure through connection to water distribution and off site sewerage system at nearest point of adequate capacity

Across all DA areas and city wide - to be co-ordinated to meet needs generated by new development

Southern Water, Developers

In time to serve all new development Throughout the life of the Plan Costs dependent on site circumstances


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Annexe 3 Housing Implementation Strategy

Revised June September 2013


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1. Introduction 1.1 Housing Implementation Strategies were introduced by national planning guidance in Planning Policy Statement 3 – Housing1. Local planning authorities were advised that their Local Development Documents should set out a Housing Implementation Strategy (HIS) that described the approach to managing the delivery of housing and previously-developed land (PDL) targets and trajectories (PPS3, paragraph 62). 1.2 The National Planning Policy Framework (NPPF) was published in March 2012 and replaces the national planning guidance set out in the former Planning Policy Statements. At paragraph 47, the NPPF guidance advises that local planning authorities should: ‘for market and affordable housing, illustrate the expected rate of housing delivery through a housing trajectory for the plan period and set out a housing implementation strategy for the full range of housing describing how they will maintain delivery of a five-year supply of housing land to meet their housing target’ (para.47, fifth bullet point). 1.3 In Brighton & Hove, the housing trajectory anticipates the delivery of both market and affordable housing and both will count towards meeting the city’s overall housing target. In many instances, new affordable housing is provided as a percentage or ‘quota’ of the total amount of housing proposed on (otherwise) market housing sites. Given the degree of uncertainty regarding future funding mechanisms for the delivery of affordable housing it is difficult to anticipate with any accuracy the delivery of affordable housing provision over the full plan period. The housing trajectory set out below therefore illustrates the affordable housing already in the development pipeline and indicates a minimum target level of affordable housing that the council’s planning policies are aimed at achieving. 1.4 This paper gives an overview of the level of housing outlined for delivery in the City Plan followed by an outline of the approach to managing housing delivery over the plan period. Without further guidance, it is assumed that the scope of an ‘HIS’ referred to in the NPPF reflects that as previously envisaged by advice in PPS3. 2. City Plan - Housing Overview 2.1 The City Plan for Brighton & Hove sets a housing target of 11,300 new homes over the plan period 2010 – 2030. This equates to an annual average provision of 565 net additional dwellings (see City Plan Policy CP1) 2.2 The housing target set by the City Plan is similar to the 11,400 housing target set for the city by the South East Plan in May 2009. The South East Plan examination and approval process accepted that in a tightly constrained

1 Planning Policy Statement 3: Housing, latest edition June 2011.


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urban area like Brighton & Hove, it would not be possible to accommodate the full extent of demographically driven housing demand and there needed to remain a balance between opportunities for housing and employment provision and a recognition of the significant environmental constraints to further expansion. As a result, the South East Plan housing target for the City was essentially ‘capacity’ driven and was based on estimates of future housing potential to be achieved through (then) existing planning consents, planned allocations and a significant proportion of projected ‘windfall’ development2. 2.3 The housing target set for the city in the City Plan has been informed by a series of studies regarding the city’s overall housing requirements (demand and need); and the 2010 Strategic Housing Land Availability Assessment (SHLAA) and three subsequent annual updates undertaken in 2011, and 2012 and 2013. The 2012 2013 SHLAA Update reported an overall citywide ‘capacity’ for around 11,500 dwellings over the plan timescales to 2030. This includes:

• Identified sites of 6+ units with potential for around 9,200 9,250 dwellings;

• Small identified sites with an extant planning permission and assessed as likely to achieve approximately 650 680 dwellings;

• Broad locations for development which offer potential for a further 900 840 units (400 at Shoreham Harbour and 500 440 through longer term Housing Revenue Account Estates Masterplan/Renewal);

• Development projected from small unidentified/windfall development in the latter part of the plan period at approx. 780 720 dwellings (130 120 per annum).

2.4 The City Plan housing target of 11,300 also reflects the average rate of residential development achieved over the last 16 15 years (see Appendix A); a timescale which spans both a prolonged period of housing boom and more recently a downturn in the housing market. In a tightly constrained urban area bound by the sea to the south and the South Downs National Park to the north, the city’s housing target is considered realistic, robust and deliverable. Spatial distribution of housing supply 2.5 In terms of spatial distribution, the strategy for housing delivery reflects the overall spatial strategy for the City Plan and seeks to concentrate a significant amount of new residential development within the most accessible areas of the city and those with the most capacity. The eight Development Areas identified in the Plan account for just over half (54%) of the planned level of new housing delivery for the city. Within the Development Areas, the City Plan makes strategic allocations to secure the delivery of some 3235 new dwellings (see spatial policies DA2 – DA8). In other parts of the city, there are also significant opportunities for new residential development (for example through redevelopment, conversions and changes of use) and this will help to

2 Which at that time was permissible as target construction was pre PPS3.


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promote and secure the establishment of mixed and sustainable communities. Development will be required to respect the local character and distinctiveness of neighbourhoods (see SA6 and CP14 Housing Density). Components of housing land supply 2.6 Table 1 illustrates a breakdown of housing land supply for the period 2010 - 2030. It draws upon the council’s 2012 2013 Strategic Housing Land Availability Assessment (SHLAA) exercise3. Table 1: Housing Delivery, Supply Breakdown 2010 – 2030 (Based on 2012 SHLAA) Spatial Area



Broad Location



Total

DAs DA1 13 0 7 20 DA2 855 1085 0 1940 DA3 120 300 390 810 DA4 285 615 285 1185 DA5 0 335 135 470 DA6 120 200 310 630 DA7 0 700 0 700 DA8 0 400 400 DA Total

1390 3235 400 1130 6155

Rest of City

1190 400 500 1855 3945

Small id. Sites

650 650

Small Windfall

600 600

Total 3230 3635 900 2985 600 11,350 Spatial Area



Broad Locations



Total

DAs DA1 13 0 7 20 DA2 855 1085 0 1940 DA3 120

140 300 390

410 810

850 DA4 285

320 615 285

195 1185

1130 DA5 0 335 135 470

3 SHLAA 2012 2013 Update, BHCC.


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10 170 515 DA6 120

90 200 310

235 630

525 DA7 0 700 0 700

DA8 0 400 400

DA Total

1390 1428

3235 400 1130 1017

6155 6080

Rest of City

1190 1190

400 500 440

1856 1950

3945 3980

Small id. Sites

650 650

Small Windfall

600 600

Total 3230 3268

3635 900 840

2985 2967

600 11350 11310

2.7 The table illustrates that approximately 3230 3270 dwellings have already either been built since 2010 or are currently committed for development in terms of having an extant planning permission or being allocated in the 2005 Brighton & Hove Local Plan. The plan makes strategic site allocations to achieve a further 3635 dwellings across the city. Further capacity is identified for an additional 3885 3810 dwellings and appropriate site allocations will need to be made in Part 2 of the City Plan (Development Policies and Site Allocations). These ‘identified sources’ comprise more than 95% of the overall housing target to 2030. 2.8 Development from small windfall4 sites will contribute to land supply throughout the course of the plan period. However, for the purposes of Policy CP1 in the City Plan only a minimal allowance for development from small windfall development has been included only for the last 6 years of the plan. Guidance in the NPPF specifically requires local planning authorities to identify sufficient sites or sites and broad locations for the first ten years of the plan period. 2.9 In summary, the City Plan sets a housing target to achieve at least 11,300 additional dwellings over the plan period 2010 – 2030. A significant proportion of this delivery will be secured within the plan’s eight Development Areas. Residential development across the rest of the city will also make a significant contribution to overall housing delivery.

4 Windfall sites are sites which have not been specifically identified as available in the Local

Plan process. They normally comprise previously-developed sites that have unexpectedly become available.


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3. Scenario and Contingency planning 3.1 Over the last 16 15 years the average rate of new housing development in Brighton & Hove has been about 540 dwellings per annum. More recently rates of housing delivery in the city have been far lower than this reflecting the ongoing impacts of economic recession and the housing market downturn. The decline in the availability of development finance and funding has resulted in a number of major developments and regeneration schemes being delayed or put on hold. This is reflected particularly in the last 2/3 3/4 years figures for actual housing completions (see Appendix A) The net dwelling completion figure for 2010/11 was just 283 units, the lowest housing completion figure in the city for 20 years. 3.2 The expected rate of housing delivery over the Plan period is illustrated through a ‘housing trajectory’. This illustrates the housing development that has already been built in the city since 2010 and that which is currently anticipated over the rest of the plan period. The housing trajectory will be monitored and updated on an annual basis through the council’s annual Authority Monitoring Report (AMR) and also through roll forward and further reviews of the Strategic Housing Land Availability Assessment (SHLAA) for the city. The most up to date trajectory is based on a review of the 2012 reflects the 2013 SHLAA position. The amended housing delivery trajectory reflects the following key factors:

• The ongoing impacts of economic recession which are continuing to constrain the recovery of the housing market within the city;

• The particular impact this is having on bringing forward the larger development sites within the city;

• The loss of a number of housing sites to student housing proposals for which there is a strong current demand; and

• A revised assessment of annual outputs on identified housing sites. 3.3 The amended housing trajectory indicates that there is sufficient overall ‘capacity’ within the city to meet the planned housing requirement (11,300). 3.4 The planned housing requirement for the city implies an annual average rate of 565 dwellings per annum over the plan period. At present, the housing trajectory indicates that delivery over the first ten years of the plan period (up to 2019/20) may be lower than this, reflecting the very low completions 2010–2012, the ongoing impacts of economic recession and time needed for full market recovery. Rates from 2014 to 2019 are anticipated to steadily increase towards an average of around 500 – 550 units per annum5. Between 2019/20 and 2024 delivery rates are expected to increase more rapidly with delivery coming through from a number of the city’s larger development sites which will make a major contribution towards housing supply. For the period 2019/20 – 2030 as a whole, delivery from identified

5 This is particularly so given ongoing small site development and windfalls from permitted

development rights from office to residential conversions.


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sites is likely to average around 630 units per annum. Development from small windfall sites and other sources of windfall (e.g. changes of use from office to residential through permitted development) is anticipated to supplement this supply. Five year housing land supply position 3.5 Taking account of the revised housing trajectory position and the key factors which have been impacting upon housing delivery in the city as outlined above, it is possible to establish what a realistic five year land supply requirement for the city might be (see Appendix B and C). Appendix B illustrates a table of ‘ramped’ or staggered housing delivery rates which reflect the revised housing trajectory and which can be used to calculate rolling 5 year supply delivery requirements. 3.6 Such an approach makes realistic provision for the process of market recovery and reflects the fact that recovery (particularly for flatted forms of development) may take longer than previously anticipated. This approach is considered a more realistic and pragmatic basis against which to calculate ongoing five year housing land requirements. The more standard approach of calculating an ‘annualised’ (flat rate) residual plan requirement across the period to 2030 is not considered appropriate as it would set an unrealistically high delivery requirement particularly for the early plan years. 3.7 The 5 year land supply position is therefore set out as at Appendix C. This demonstrates that, for the 2012 – 2017 2013-2018 five year period there is a sufficient 5 year supply of housing in accordance with NPPF requirements and a 5% buffer.

3.8 Positive planning measures will be required to ensure that sites come forward for development as anticipated in the trajectory (see section 7 below) and, where possible, that sites are brought forward more readily where this is practicable and feasible. This is in order to ensure a more even rate of residential development, assist with the provision of required infrastructure and to maintain a healthy five year supply of deliverable sites.


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3.9 The SHLAA and the consequent housing trajectory is largely based upon identified sites of 6+ units. Small site development (sites up to 5 units) makes a significant contribution to the total amount of residential development achieved in the city1 and will continue to count towards meeting the overall housing target and ongoing five year land supply requirements. The NPPF allows for the inclusion of an allowance for windfall sites in the five-year supply where local planning authorities have compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply. Small site development across the city is therefore likely to supplement development achieved on the larger sites or provide a useful contingency measure should there be an element of non-delivery on the larger identified sites. 3.10 The housing trajectory also illustrates the amount of affordable housing anticipated to come forward over the plan period. Affordable housing in the development pipeline (schemes with an extant consent) has been illustrated for the five year period 2012 – 2017 2013-2018. Beyond this, affordable housing anticipated is illustrated as a minimum target of 30% of overall housing delivery. Given the sliding scale of affordable housing requirements set out in CP20 of the City Plan and the fact that not all schemes will deliver these targets in full, a 30% estimate of overall delivery is considered realistic. This is also consistent with recent development trends which demonstrate that 29% of housing development over the 2006–11 period has been for affordable housing2. 3.11 A significant proportion of housing delivery will be dependent upon the private sector for delivery but other stakeholders will also have an important part to play in helping sites to come forward for development. This includes Registered Providers active in the city and the council as land owner and in the form of area regeneration programmes. 4. Risk assessment of obstacles and constraints for housing

delivery 4.1 To a certain extent the SHLAA already provides an assessment of the risks associated with potential constraints to site delivery. Identified risks (for example, policy constraints, infrastructure requirements, ownership constraints and/or marketing constraints) are reflected in the potential phasing of development in relation to site delivery. In accordance with SHLAA good practice guidance, sites are evaluated in terms of suitability, availability and achievability. Sites that are severely constrained and do not offer reasonable development potential do not form part of the overall housing land supply. 4.2 The SHLAA is a dynamic process and will, through regular monitoring, be reviewed at least annually to ensure the most up to date and relevant site

1 36% of all residential development over the last 10 years has been through small site

development. 2 Residential monitoring, annual Authority Monitoring Reports, BHCC.


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information is incorporated for each identified site and followed through into an updated housing trajectory. 4.3 The main identified risk to housing delivery in Brighton & Hove is the delayed recovery of economic conditions and how this continues to impact upon the construction industry and the housing market. Site viability has been identified as an issue affecting many of the city’s major development sites. Some developers have sought to renegotiate policy requirements including levels of affordable housing, standards for sustainable buildings, the development mix and/or to renegotiate terms of S106 agreements to address viability. Whilst viability has constrained or delayed the delivery of a number of sites, house prices and land values remain relatively buoyant in the city which appears to indicate that viability issues are likely to improve over time. 4.4 The risk of housing delivery being constrained by any lack of infrastructure is considered to be very low. However, where there is any element of uncertainty in relation to the delivery of infrastructure then that will be identified in the Infrastructure Delivery Plan. 5. Engagement with house builders and key stakeholders 5.1 The council recognises the importance of engagement with key stakeholders and local communities throughout the preparation of its City Plan (and the former Core Strategy preparation up to Publication and Submission stage). 5.2 The process of, and approach to, engagement is set out in the council’s adopted Statement of Community Involvement. In addition, the council maintains a Consultation Database which has contact details of all interested parties (e.g. developers, private landowners, agents, businesses, community groups, etc). The council’s Consultation Statement sets out further details regarding the process of consultation on the various preparation stages of the City Plan and how consultation has helped to shape the policies and overall approach. 5.3 House builders, developers and other key stakeholders have been involved in the development of the City Plan at all preparation stages. Many are also included as part of ongoing citywide working groups such as the Brighton & Hove Affordable Housing Partnership, the city’s Strategic Housing Partnership and the city’s Economic Partnership. Developers, agents and landowners were are contacted in the SHLAA ‘call for sites’ exercise. They are also actively encouraged to enter into early dialogue with the council on pre-application discussions regarding potential housing schemes. 5.4 The council’s ‘Major Projects Team’ works with public and private sector partners to promote the implementation of council owned key regeneration schemes and infrastructure projects across the city. Successful delivery of these projects helps to provide new business space and employment opportunities, new homes, and community and leisure facilities.


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Development can also act as a regenerative catalyst encouraging further investment in the city. 5.5 The role of the ‘Planning Projects Team’ is to facilitate and promote development on key sites in the city by providing advice to the council as landowner (Major Projects Team) and by preparing advice for developers and to encourage development interest. This advice comes in the form of planning briefs (for example Royal Alexandra Children’s Hospital, supplementary planning documents (Preston Barracks, London Road Masterplan) and publishing development site schedules on the city council website. The planning briefs and SPDs are prepared in consultation with developers, stakeholders and residents and are often used to promote sites for development. Development Site Schedules give site specific planning information, advice and data intended to be useful to developers and the wider public. 6. The approach to regular monitoring and review 6.1 City Plan Policy CP1 indicates that housing delivery will be monitored annually through a framework of monitoring and implementation indicators (See Annex to the City Plan) and an annual review and roll forward of the SHLAA. 6.2 The results of residential development monitoring will be published annually in the council’s AMR. The AMR will include an updated housing trajectory and five year land supply position. The AMR also monitors the type of housing built in the city and the percentage of housing built on previously developed land. 7. Circumstances in which specific management actions may be

taken and an indication of such management actions 7.1 The AMR will be used to closely monitor housing delivery performance in the city. It has already been noted that completions over the last 2/3 years have been significantly below average levels and that this is strongly related to the impacts of ongoing economic recession and a slow down in house building rather than to any shortage of sites for development. 7.2 Underperformance in any single year may not require immediate intervention but indications of prolonged underperformance has implications for the city’s five year land supply position and longer term implications in terms of meeting the City’s planned housing target for housing provision over the plan period. The current housing trajectory together with Appendix B and Appendix C currently indicate that a five year supply can be demonstrated and that the city’s housing requirement for 11,300 new homes by 2030 is achievable. Should annual monitoring over the next 3-5 years indicate that there is significant risk to the achievement of anticipated housing delivery rates then early Plan review may be necessary. Annex 1 to the City Plan sets


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out a monitoring and implementation framework. This identifies appropriate targets and trigger points to enable Policy CP1 to be effectively implemented over the plan period. 7.3 In the meantime, a number of specific development management actions are already underway to assist sites coming forward for development. These measures include:

• Production of detailed Planning Briefs and/or area based Supplementary Planning Documents to increase certainty to developers of sites progressing through the planning process;

• As part of the preparation of Planning Briefs, the indication of different development scenarios to accommodate different viability scenarios.

• Pre-application discussions with developers, landowners and their agents to increase certainty in the development management process;

• Flexible application of policy and S106 requirements where scheme viability and deliverability issues have been clearly and robustly demonstrated (see below);

• Renegotiation of S106 requirements where market conditions have demonstrably affected scheme viability since planning permission secured (see below).

Recession Measures 7.4 There is recognition that in certain circumstances s106 planning obligation requirements may impact on the viability and deliverability of a development. Therefore the Council has been responsive to the need for flexibility in the short term to reflect current market conditions and will negotiate with developers in such situations. 7.5 In response to the economic downturn, in early 2010, the Council introduced a range of temporary ‘recession’ relief measures that prioritised and allowed for reductions in certain types of s106 planning obligations where issues of viability / deliverability were raised. These temporary measures provide flexibility on securing provision towards necessary infrastructure provision in order to enable development to be acceptable and to proceed in a timely manner. The temporary relief measures will be reviewed in 2014. The current recession relief measures include:

� Free of charge pre-application advice service; � Deferring or allowing for phased payment of contributions on major

schemes, or deferred of payment of contributions or provision of infrastructure to a later date in the development or on occupation of the development;

� Reduction in the type and level of contributions being sought by suspending requirements for financial contributions to sustainable building and nature conservation;

� Waiving “indexation” on financial contributions so that infrastructure payments due are not updated to current prices;


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� Changing the threshold level at which sustainable transport contributions are sought so that a lesser percentage of developments would be liable.

� Suspending seeking financial contributions towards Sustainable Buildings and Nature Conservation measures. Contributions will instead focus on securing best quality development design.

7.6 Other actions to ensure site delivery occurs in a timely manner also include:

• Programme of work for Part 2 of City Plan (Site Allocations and Development Management Policies) to give greater certainty to sites and enable additional development sites to be put forward and assessed;

• Where feasible to seek public sector intervention and potential funding streams through the Homes and Communities Agency.

• Prioritise council owned land through regeneration programmes and initiatives;

• Ongoing liaison with key stakeholders;

• Survey of house builders/landowners to identify main causes of supply problems and where appropriate act on feedback received;

8. Conclusion 8.1 This paper indicates that the City Plan makes sufficient provision to meet the minimum planned housing requirement of 11,300 additional homes. Housing delivery from small sites will also continue to make a significant contribution to supply throughout the plan period and in this way provides a useful measure of contingency should there be an element of non-delivery on some of the larger identified sites. Further windfall housing delivery is also anticipated through the temporary change of permitted development rights to allow changes of use from office to residential. 8.2 The main risk to housing delivery in Brighton & Hove is identified as a delayed recovery of national economic conditions and how this continues to impact upon financial institutions, the construction industry and the local housing market. A number of specific management actions have already been identified to assist sites coming forward for development sooner than is currently indicated in the housing trajectory. 8.3 Housing delivery performance will continue to be monitored and progress will be reported in the council’s AMR which will include an updated housing trajectory to compare delivery against planned housing targets.


103

HIS: Annex Appendix A Total Residential Completions in Brighton & Hove 1991/2 – 2011/12 Year Residential

Completions 5 year average

1991/2 837 1992/3 430 1993/4 1017

1994/5 441 1995/6 1229

791

1996/97 458 1997/98 496 1998/99 423 1999/00 407 2000/01 459

449

2001/02 960 2002/03 608 2003/04 684 2004/05 602 2005/06 539

677

2006/07 797

2007/08 567 2008/09 721 2009/10 380 2010/11 283 2011/12 309

510 490

2012/2013 374 Total (22 years) 12647

13,021 602 592

BHCC Residential Monitoring.

Average of last 5 years 452 413 Average of last 10 years 549 526 Average of last 15 years 549 541 Average of last 20 years 590


104

Residential Completions by large and small sites Large (6+) Small (<6

units) Total

2001/2 636 324 960 2002/3 250 358 608 2003/4 522 162 684

2004/5 388 214 602 2005/6 226 313 539 2006/7 515 282 797 2007/8 410 157 567 2008/9 572 149 721 2009/10 269 111 380

2010/11 131 152 283 2011/12 138 171 309 2012/2013 262 112 374 Source: BHCC residential monitoring

Small site development (all) : Last 5 year annual average = 148 140 Last 10 year annual average = 207 182 Small windfall (pdl) allowances: 70% small site development arises from changes of use/conversions (pdl) 70% 148 = 104 70% 207 = 145 Mid point between 104 - 145 = 125


105

Appendix B Managed Housing Delivery – Ramped Delivery Requirements Year Annual Delivery Average over

phased period Cumulative Delivery over period 2012 - 2030

2010/11 283 Actual delivery

2011/12 309 Actual delivery

592

2012/13 420

2013/14 420 840 (420) 1432 2014/15 500 2015/16 500 2016/17 500 2017/18 550 2018/19 550 2600 (520) 4032 2019/20 650 2020/21 650 2021/22 700 2022/23 700 2023/24 700 3400 (680) 7432 2024/25 700 2025/26 650 2026/27 650 2027/28 650 2028/29 600

2029/30 600 3850 (642) 11,282


106

Appendix C: 5 Year Housing Land Supply a) 2012 – 2017 Five year land supply requirement calculation Delivery rate expected 2012/13 420 2013/14 420 2014/15 500

2015/16 500 2016/17 500 Total 2340 Annual average requirement 2012 - 17

468

5% NPPF buffer 24 Annual requirement with 5% buffer

492

5 Year land supply requirement 2012 - 2017

2460

b) 2012 – 2017 Land Supply Supply 2012-2014 Identified Supply (see note 1)

839

2014-2017 Identified Supply (see note 2)

1349

Small site windfall (pdl) development allowance (see note 3)

250

Other ‘windfall’ allowance (see note 4)

225

Total Supply 2663 Years’ Supply 5.4 Source: 2012 SHLAA – Trajectory Review Note 1: ‘Pre-Plan Adopt’ Supply (1431 – 592 completions for 2010 – 2012) Note 2: 1-5 Year Supply (2248) divided by 5, multiplied by 3. Note 3: Small site windfall allowance – see Appendix 5 Note 4: Other windfall, e.g. pdr Change of use from office to residential at 75 units per annum over 3 years. A: Calculation of Five Year Land Supply Requirement 2013 - 2018 Delivery Rate Expected a. 2013/14 420 b. 2014/15 500 c. 2015/16 500 d. 2016/17 500 e. 2017/18 550


107

Delivery Rate Expected f. Shortfall from 2012/13 (374 units completed against expected rate of 420)

46

g. Total (sum of a-f) 2516 h. Annual average requirement 2013-2018 (g/5)

503

i. Addition of NPPF 5% Buffer 25 j. Annual Requirement with 5% Buffer (h+i)

528

k. Five Year Land Supply Requirement for 2013-18 (5 x 528)

2640

B: Five Year Housing Land Supply - 2013 – 2018 Supply (without student

cluster units included) Supply with student cluster units included.

a. 2013-2018 Identified Supply on sites of 6+ units (see note 1)

2209 2209

b. Small site Identified Supply (see note 2)

257 257

c. Small pdl site windfall allowance (see note 3)

240 240

d. Other windfall (see note 4) 90 90 e. Student cluster accommodation (see note 5)

n/a 103

f. Total supply 2013-2018 2796 2899 g. Years’ Supply 5.3 5.5 Note 1: Derived from 2013 SHLAA Update; Table of 5 Year Supply Sites of 6+ units 2013/14 to 2017/18. Note 2: Derived from 2013 SHLAA Update; Table C, Small Identified Sites Supply. Note 3: Derived from 2013 SHLAA Update: Table F, Windfall Supply Note 4: Other windfall development, e.g. PDR change of use from office to residential at 30 units per annum over 3 years. Note 5: Student cluster flat accommodation classified as ‘dwelling’ in CLG guidance, Table H, 2013 SHLAA.

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