Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Memoranda

Supplementary memorandum by Brighton & Hove City Council (HOU 08(a))


  A submission from Brighton and Hove was tabled in respect of the original inquiry time-scale for July. The re-opened inquiry carries an expanded remit. This addendum to the earlier submission contains additional evidence for consideration in respect of the revised remit.

Whether the funds in the Comprehensive Spending Review will achieve the Government's target of a decent home for everyone by 2010

  In terms of meeting the Decent Homes Standard the Reform of Housing Finance will be a major factor in meeting the target. Brighton & Hove City Council's strategic objectives are to strive to achieve both the 2004 and 2010 targets. However, the current Housing Revenue Account (HRA) funding framework and current business plan projections indicate a significant challenge for the authority in that these targets may not be met in the city. In response to this challenge Brighton & Hove are commissioning a stock options analysis, a stock investment analysis and further stock condition survey in early summer 2003. This will help inform the direction of our longer-term strategic investment approach to the 2010 target. The four current standard stock options will be assessed but early indications, are that of these options, there is no easily identified "best fit" which would provide a definitive approach to meeting investment gap requirements.

  Consideration should be given to further exploration and development of finance investment options for council housing. The parallel consultation on the "Way Forward for Housing Capital Finance" will be a key driver in facilitating fresh local approaches. Issues raised in this enquiry should link closely to the development of the housing capital finance approach.

How spending of the new resources should be balanced between social housing and options for owner occupation and the mechanisms used for their distribution

  Good quality affordable housing has a pivotal role to play in the well being of the nation. The shortage of affordable housing has key health, social and economic consequences for the region and country as a whole. It is also key to delivering both regeneration and neighbourhood renewal objectives. Housing resources should be recognised as delivering key targets on local wellbeing. For example, pivotal to sustainability objectives or indeed local health hospital care discharge pathways.

  A flexible approach to distributing affordable housing resources toward regional priority areas and in line with the "real" timing of development opportunities is welcomed.

  In areas of acute housing demand and low affordable housing capacity, such as Brighton & Hove, there is a need to provide significant resources for a "two pronged" approach to tackling needs. Traditional "affordable housing", in the main for rent and available to homeless households and those on low income. Combined with a parallel approach for those on higher, although still modest incomes, so called "key workers" who also struggle to secure affordable housing in a "high demand—high cost market".

  By increasing supply at both ends of the affordable housing supply, it may be possible to promote a greater impact on affordable housing capacity at local level. (Tables attached indicate the extreme supply and demand pressures in respect of affordable housing capacity in the city of Brighton & Hove)

  Key factors are.

  Overall funding support for affordable housing should be increased. The SHG funded programme expanded. Additional programmes of "intermediate market" accommodation at costs below market rented accommodation would be welcomed.

  Affordable housing supply should become a key component of business planning. Employers and economic partners are encouraged to see "workforce" housing requirements as an integral part of business planning. This is very important in respect of asset management and the use of property and buildings. Financial incentives should be encouraged to promote employer contributions.

  Further dedicated resources should be made available to promote and develop the "culture", the option, and the facilitation of household movement between areas of high demand and areas of over-supply of affordable housing.

  The fiscal and "business footing" of the private rented sector should be reviewed.

  Efforts to promote the appropriate investment and good practice in private rented accommodation management need to be further pursued. Investment initiatives in the private rented sector have a key role to play in respect of influencing the level of affordable housing demand in cities such as Brighton & Hove.

  To assist Authorities to meet housing need we require longer term funding programme commitments—at the minimum, a three year funding commitment will ensure a better planned and joined up approach to facilitating affordable housing provision.

  Within Brighton & Hove there is an overwhelming need for affordable rented accommodation. However shared ownership is also a valuable tool in assisting working households to get a foot on the property ladder. These schemes need to be supplemented with other sub market initiatives—both for rent and for sale. This will require additional resources and should not be top sliced from existing resources earmarked for social housing. Alternative methods of provision and funding need to be sought such as tax incentives to encourage employers to facilitate accommodation for their employees and incentives to encourage the private sector to release land and develop both affordable and sub-market housing rather than market housing.

  It is important that initiatives impact on subsidised supply rather than empower individuals to compete in the current market. It is important that subsidy arrangements provide long term and recycled affordable housing options, rather than provide subsidised homes for the benefit of just one initial incoming household.

The role of planning obligations in providing affordable housing

  The current system can deliver affordable housing opportunities if GOSE, ODPM and the Planning Inspectorate support Local Planning Authorities in delivery of local plan affordable housing policies.

  Not only does the planning system secure affordable housing development opportunities. It is now essential that an integrated regional approach to affordable housing planning policy provides the basis on which funding programme "stretch" can be achieved.

  Over the last five years the housing and economic climate has changed considerably seeing a focus on regeneration, neighbourhood renewal, high-density development and use of brownfield sites.

  However, current government guidance has not kept pace with these changes, with circular 6/98 being seen as a particular barrier to successfully delivering additional affordable housing. The circular needs updating with significant changes that allow affordable housing contributions to reflect the local circumstances of the planning authority. The thresholds within the circular do not reflect the higher density developments of urban areas and the nature of brownfield/infill sites available to many urban authorities. The definition, tenure, type and method of provision must also reflect local circumstances if it is to secure genuine affordable housing, particularly in the longer term.

  Circular 6/98 is not reflective of revised legislation in respect of local wellbeing.

  There have also been significant changes in respect of housing needs assessment and urban capacity analysis since the original guidance was developed.

  The Council recognises that planning policy needs to be transparent and consistent to give certainty to developers/landowners.

  The Authority welcomes the opportunity to seek affordable housing contributions on other sites other than residential as highlighted in planning green paper. The authority would also be keen to see incentives to provide affordable housing on sites not designated for residential use, as this would provide additional affordable housing. However there is a need to assess carefully the different scope for impact of such an approach in an urban area such as Brighton & Hove with development opportunities underpinned by high historic land values and an array of smaller scale sites and "infill" development opportunities. Changes to the tax and VAT arrangements in respect of affordable housing redevelopment opportunities would perhaps provide and additional incentive in support of the planning policy objectives.

  The Authority supports the principles of PPG3 and therefore supports on site provision of affordable housing to encourage mixed and sustainable communities. We are concerned that the use of tariffs—if not designated as an in kind on site provision—will lead to further segregation and polarisation of social housing. In areas of development constraints it may be difficult to find appropriate sites to use the tariff payment on.

How the quality of new affordable housing can be ensured & the poor design of previous housebuilding programmes avoided

  Initiatives that promote a partnership approach to development, inclusive of private sector developers, are key. The best recent examples of partnership developments in the city stem from innovative partnerships with the private sector and local communities. It has helped to commissioning specific RSLs to act as development agents. These RSLs would be the best performing and most innovative, who have built up the relevant expertise and partnerships with architects, contractors etc. This could also have the advantage of reducing costs by achieving economies of scale.

  Difficulties remain where many inner urban development opportunities are smaller scale "infill" sites. These development opportunities are often characterised by the control of small scale developers or vendors who have no "buy-in" to the principles of "partnering" or a specific interest in "design-led" solutions on the sites they control. Measures to promote a design led and partnership approach need to be encouraged beyond the larger volume housing builders contractors etc.

  There is a need for broader planning policy directives or fiscal incentives to be issued that help to promote innovative design led housing solutions. Examples would include guidance on high rise development. Incentives to promote development opportunities such as those above car parking areas, or indeed in incentives to promote residential development above existing business premises.

  Frequently the encouragement on good design led solutions is based on public funding requirements via the Housing Corporation and RSL sector. There is a need to encourage the private sector to contribute further to the Egan agenda.

  Good housing design is often characterised by active community input. The current funding and financial arrangements amongst RSL developer make it difficult to promote small self-help or co-operative based projects. It would be useful to encourage a new form of community grant or loan assistance programmes for individual or small groups of homesteaders who might wish to tackle empty property renovation as a form of "self help". In particular such grants might be used to encourage those in high demand areas to relocate to areas with oversupply.

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