BHT Submission to the Brighton & Hove City Plan Part Two Scoping Paper

(This is a submission I made to Brighton and Hove City Council in response to its consultation on the last phase of the development of its City Plan)

Brighton Housing Trust is pleased to respond to Brighton & Hove City Council’s consultation on the City Plan Part Two Scoping Paper

Brighton Housing Trust (BHT) is at the very heart of initiatives in Brighton and Hove – and elsewhere – to address both the causes and effects of homelessness in the city.

BHT offers services, advice and support for those forced to live on the streets through its First Base day centre in Montpelier Place with 14,708 visits to our early morning session by 955 different clients in 2015/16. We provide housing advice to those with housing problems including those threatened with losing their homes and for those seeking access to the private rented sector.  In 2015 through the advice centre we prevented homelessness in 436 cases.  We provide skills training both at First Base and at the Whitehawk Inn and run an intern placement programme.  Through our Addiction Services, we provide addiction treatment with some 74 per cent of our clients still abstinent 18 months after their treatment was completed.  We provide community housing in the city including Phase One, a 52 bed high support hostel for single homeless men and women; Route One which provides support and accommodation for 60 adults with mental health needs and Richardson’s Yard, an award winning scheme for housing those in need.

The housing crisis in Brighton and Hove is acknowledged in Part One of the City Plan itself as well as through:

It is hoped, the position does not need restating in this submission.

BHT recognises the important role played by strategic planning, planning policies and individual planning decisions in aiding the provision of much needed housing in the city and, in particular, the provision of housing for those most in need.

In recognising this, BHT is fully aware of the burgeoning constraints placed on the planning system that increasingly restrict its ability to require truly affordable housing to be delivered through the development process. We have seen with dismay, for example, the change in the definition of affordable to one that means that housing delivered through planning within this category is not affordable to those in need and those on low and average incomes in the city.

This requires that the City Plan looks for innovative solutions. BHT has already called for Brighton & Hove to be designated as a ‘Housing Crisis Zone’ ( This designation and some of the necessary actions that could follow are matters for central government working with the City Council but BHT urges the City Council to use the City Plan to spell out clearly the extent of the housing crisis and to use that evidence base to support and justify the introduction of strong policies and the unswerving implementation of those that exist.

For example, we acknowledge the strength of the existing policy CP20 setting the affordable housing requirement. However, first, the City Council cannot be seen to be wavering in enforcing its own requirements.  Second, BHT believes that the nature and depth of the housing crisis in the city – coupled with the lack of available larger sites – means that the Council should resist revising this policy to raise the threshold in line with the result of R (West Berkshire District Council and Reading Borough Council) v. Secretary of State for Communities and Local Government [2016] EWCA Civ 441.

Further, BHT asks that consideration should be given to an even more joined-up approach to affordable housing provision through s.106. This may include using receipts from commuted affordable housing payments to support initiatives such as the Council’s own empty homes strategy or in supporting bodies in the city, such as housing co-operatives, which provide housing for those most in need.

As part of this strategic approach, we believe that there needs to be greater co-ordination and mutual reinforcement between the City Plan and the Council’s housing strategy. We note that the diagram of ‘The Housing Strategy Family’ on page 4 of the Housing Strategy does not include the City Plan.

One of the – if not the – most import roles of Part Two of the City Plan is to find means of providing housing to meet the objectively assessed housing need for new housing. As paragraph 37 of the Inspector’s report () points out clearly:

The City Plan Part One, as proposed to be modified, seeks to meet only 44% of the objectively assessed need for new housing. This is a very significant shortfall which has important implications for the social dimension of sustainable development. However, as noted above, the City is subject to significant constraints in finding land for new development. The target of 13,200 new homes is expressed as a minimum, which offers scope for that number to be increased when more detailed consideration of individual sites is undertaken for the preparation of the City Plan Part Two.

To meet the other 56 per cent of previously assessed need – let alone any additional need that may be identified as part of the Part Two preparation process – is an extremely challenging task. BHT urges the City Council to make full use both of identified sites and of windfall sites by maximising densities in line with good practice in sustainable development.  It also urges the Council to examine the scope for encouraging the densification of housing within existing developments – including through the call for sites exercise to be undertaken as part of the Strategic Housing Land Availability Assessment update process.

The Part Two Scoping Paper poses a number of consultation questions. In this submission to the consultation, BHT wants to focus on three of these.

Question H4 asks whether proposed housing site allocations in City Plan Part 2 should seek to specify a range of dwelling types and sizes or should this be left to a more general criteria-based type of planning policy?

The scoping Paper has already identified that:

For affordable housing, the analysis suggests that a greater proportion of one and two bedroom affordable properties will be required. However, the study notes that this does not reflect any specific priorities for family households in need or that smaller homes typically offer more limited flexibility in accommodating changing requirements of households.

BHT believes that, given the constraints put on local authorities in delivering truly affordable housing, the City Plan should use all possible approaches to try to ensure that the supply of housing matches the needs of those in need as evidenced through, for example, data on homeless acceptances. This would require that the City Plan – as the statutory document – does specify a range of dwelling types and sizes.

Question H11 asks whether policies in City Plan Part 2 should resist the loss of housing from within the existing housing stock. Given the existence of a housing crisis in Brighton & Hove, BHT’s answer is an unequivocal ‘yes’.

Finally, Question H18 asks whether the City Plan Part 2 should include a policy that seeks to protect existing HMOs?

BHT recognises that HMO’s can give rise to problems such as noise but we believe that such is the depth of the housing problems in the city that any accommodation that potential serves those who are excluded by purchase or rental cost from other types of accommodation is protected.

This response to Brighton & Hove City Council’s consultation on the City Plan Part Two Scoping Paper is designed both to demonstrates BHT’s willingness to contribute its expertise and informed viewpoint to the development of Part Two of the City Plan and to put forward a number of key issues related to the focus of our work.

BHT would be pleased to discuss any of these matters covered above further and looks forward to being engaged as the process of drafting Part Two develops.


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