Supplementary memorandum by Brighton &
Hove City Council (HOU 08(a))
ADDENDUM TO INITIAL SUBMISSION
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 demandhigh 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
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 &
To assist Authorities to meet housing need we
require longer term funding programme commitmentsat the
minimum, a three year funding commitment will ensure a better
planned and joined up approach to facilitating affordable housing
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 initiativesboth 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
The role of planning obligations in providing
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
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
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
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 tariffsif not designated as an in kind
on site provisionwill 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
How the quality of new affordable housing can
be ensured & the poor design of previous housebuilding programmes
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
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
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
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.