Full Statement on Brighton & Hove City Plan Part 2
Brighton & Hove Lib Dems welcome the publication of the council's Proposed Submission for the City Plan Part 2, to follow on from the adoption of the City Plan Part 1 in March 2016. All parties in Brighton & Hove are in total agreement that we have a significant housing shortage - in particular of affordable housing - in the city, which we need to take prompt action to address. However, we do have some concerns with approach and results the council has been achieving on housing which we believe must be addressed going forward.
Over the past decade we have had councils led by both the Green Party and the Labour Party. Both parties have spoken openly of the need for significantly more affordable housing to be made available in the city, yet the reality is that their actions have very rarely lived up to those words. The 2015 Labour manifesto committed to building 500 new council homes, yet four years later their 2019 manifesto quietly conceded that less than 200 were actually achieved in that timeframe.
The City Plan Part 1 commits to requiring all developments over 5 dwellings to include the provision of affordable housing, with a target of 40% affordable housing on any developments of 15 or more dwellings. The council has consistently failed to meet this target. Too often we are seeing developments green-lighted with only a cursory nod to affordable housing requirements included in the plans, regularly as low as just 10% of dwellings at best.
The council has set these targets themselves and failure to meet such targets is the sole responsibility of the council. They must up their game in delivering on their promises or, if they feel the targets they've set are too difficult for them to achieve, be open and honest with people about what they are capable of delivering.
Build to Rent:
The proposals laid out in City Plan Part 2 do, however, raise their own concerns on the delivery of sufficient quantities of affordable housing. On Build to Rent developments, there is a commitment only to seek to negotiate 'up to 20%' affordable housing provision. This gives no minimum for the council to seek and implies that there are circumstances where developments with zero affordable housing provisions could be considered acceptable.
Given that even with minimum targets set, the council is struggling to provide enough affordable housing, there is a risk that this simply gives carte blanche for developers to ignore the requirements for affordable housing altogether, whilst providing little accountability to the council if they fail to meet their objectives. We call on the council to re-evaluate this requirement and set a minimum affordable housing criteria which must be met on each development.
The plan also acknowledges that Build to Rent is a growing industry in the housing sector. Whilst we agree that Build to Rent can play an important role in meeting the housing needs of the city, we must ensure that the balance is kept between these and Sell to Market developments, which must ultimately remain the preferred option. Propping up an already extremely inflated rental market in the city is not necessarily the best method for solving our housing crisis.
Focus must also be placed in particular on the mix of housing we are providing, not only in whether we're building to rent or to sell but in terms of the types of homes we are actually building. There has been a significant focus on just increasing numbers to meet headline targets, but this can be to the detriment of actually meeting the housing needs of the city. The increasing propensity of developments to provide blocks of flats comprising a significant portion of studio and one Bedroom flats is concerning, particularly considering our biggest housing deficit is in Residential Family homes.
The council commissioned an 'Objectively Assessed Need' report into the city's housing demand in 2015, whilst drawing up the initial proposals for City Plan Part 1. This report outlined that for homes designated at market rate, just 15% of these should be 1-bedroom homes, the same proportion as should be 4-bedroom homes. For such homes to market, it outlined that we should seek to build more than double each of 2-bedroom and 3-bedroom homes than we are providing 1-bedroom homes. Instead, the tendency appears to be to pack as many properties into blocks of flats as possible, leading to an unbalanced market and only increasing the deficit of family homes. To put it simply, we will not solve the housing crisis in the city by introducing to the market swathes of Studio flats at £1,000 a month or 1-bedroom flats at £1,200 a month.
It is welcome that City Plan Part 2 aims for a diverse range of dwelling types, tenures and sizes that reflect and respond to the city's housing needs and changing demographic. Sadly, the council's latest housing and development track record has not lived up to this ambition. Too much of the focus to date has been on smaller starter homes to rent and purchase. Whilst this certainly has its place in overall plans, by building larger family homes we enable people to move on from their starter homes, freeing up availability at the same time as helping those who are outgrowing their home to move on. This simple shift has the effect of helping two households into new homes in one go, providing more bang for our buck and creating a far healthier market for all.
There are a number of prominent developments where concerns can be raised. Many of the residents in the city are aware of the issues raised regarding Phase One of the Brighton Marina development. A dearth of affordable housing (and even less so genuinely affordable) with a high proportion sold off to investors or as second homes, as was the case, does not serve residents well and lessons must be learnt. Whilst it is welcome that the future plans do include increased affordable housing provisions, it is concerning that the proportion of this seems to be decreasing over time and the phase 2 application put forward in 2019 proposed only 15% designated as affordable and a further viability assessment required to finalise phase 3. Concerns can also be raised on the housing mix, with Phase 2 proposing nearly 40% of flats as studio or 1 bed whilst a paltry 6.25% is designated for flats larger than 2 bedrooms.
Similar concerns can be raised around the recently approved Build to Rent development at Sackville Road. Just 10% of homes across the development are voluntarily designated to comply with affordable housing provisions, whilst 45% of flats are proposed to be Studio and 1-bedroom flats with just 7.4% larger than 2-bedrooms.
Proposals like these, which fall well short of local planning guidelines and are heavily weighted towards providing small flats in large blocks, do not best serve the interests of residents of Brighton & Hove and the council must be more robust when considering these.
Hollingbury Golf Course Proposal:
Brighton & Hove Liberal Democrats are also disappointed at the lack of consideration given to our proposal to re-purpose the land at Hollingbury Golf Course. The golf course, on council-owned land, is a considerably underused resource in a well-served location. It could be better utilised by converting a portion of the land for development, providing high quality, eco-friendly and genuinely affordable family homes along with council houses, contributing to increasing the diversity of housing developments as well as putting a significant dent in the council's housing list, which now stretches to over 19,500 people. The remaining land could be converted to provide a large public park for community use and dog walkers, with a section assigned for allotments too. We call on the council to consider these proposals afresh.
Agent of Change - Protecting music venues:
We are delighted to note that, on the back of Lib Dem campaigning on the issue, the City Plan Part 2 commits to implementing the Agent of Change principle in full, putting the responsibility on developers to ensure developments near established music venues are adequately sound-proofed and protecting those music venues from noise complaints from new neighbours, preventing them being closed down as a result. We have a rich heritage of music venues as a city and too many of these have been lost in recent years, we must do all we can to protect them.
We are an ambitious and creative city and this must be reflected in our approach to housing policy. Whilst there is a need to ensure we are meeting overall targets for number of new homes, this cannot be reflected in exclusively focusing on small, expensive homes in large blocks of flats. We can be inventive in our developments whilst still meeting the increasing housing demands of the city. Ultimately, the people that should benefit from housing developments are the residents of Brighton & Hove and this will only be achieved when we are providing adequate, genuinely affordable housing and a sufficiently diverse housing mix. The council must do better.