Agenda item - Chair's Communications

51.1       City Plan consultation

The Council has launched the first stage of consultation on our City Plan which expires on 20 January. It is very important that residents, developers and agents respond to the consultation as the requirement to determine applications in accordance with the Local Plan has been made stronger under the Levelling Up and Regeneration Act 2024 (“the LURA”).

Section 58 was inserted into the new Act which states that:
Local plans will be given more weight when decisions are made on applications so that there must be strong reasons to override the plan, providing communities with more certainty.

The same weight will be given to other types of plan, including neighbourhood plans prepared by local communities and spatial development strategies produced by Mayors or combined authorities.

The more feedback the Council receives from residents, developers and stakeholders the more informed Cllrs and officers will be regarding support for new and updated policies.

Policies should make clear where and in what circumstances new development can be supported so that more certainty can be given to the planning system with respect to decision making of applications. Certainty helps to speed up the planning process. Design guidance regarding proposals for some parts of the city will refer to design codes to indicate how design preferences and local character will be taken into account.

After this first consultation stage has been completed further consultation will be held on a full draft plan which will include draft policies and proposed site allocations. The next stage of the consultation is called “Issues and Options”. We don’t expect to get to that stage until early 2026. There is then a final stage to the consultation which includes the production of a Proposed draft Submission Plan which will be sent to the Planning Inspectorate for formal public examination.

We look forward to receiving feedback from the public. Please make your comments to the City Plan using the Council’s on line portal Your Voice so that comments can be quickly and efficiently processed and filed under the correct topic. Your Voice – consultations and engagement.

National Planning Policy Framework (NPPF) 2024

The Government published a new National Planning Policy Framework in December 2024. This NPPF is aligned with the new statutory provisions of the LURA. It places great emphasis on increasing housing supply including affordable housing, and the release of land called grey belt where previously developed land on Green Belt is identified. In 2023/24 1,075 new homes were delivered in the city, the largest annual increase in the housing stock for at least 15 years.

The updated NPPF introduces changes to the standard methodology for calculating housing need. The revisions are significant and are in line with the pro-growth NPPF to drive forward the Government’s commitment to rebuilding Britain, delivering 1.5m new homes during the current parliament along with critical infrastructure that underpins economic growth.

The Government has increased the housing need figure for Brighton & Hove from 2,333 to 2,498 homes per year. This target presents a significant challenge due to the constraints facing this coastal city with the South Downs National Park boundary tightly drawn around the urban area. Our new City Plan must robustly consider ways of increasing housing supply in the city.

NPPF headlines have also addressed changes to Green Belt policy, however, it is important to note that the City has no Green Belt and there is an even stronger emphasis on the value of brownfield redevelopment. There has been welcome clarification that while proposals for development on brownfield land should be approved unless substantial harm would be caused, this should not promote low quality unsustainable development. Most development in the city already takes place on brownfield sites with 88% of planned development in the current City Plan being on brownfield land.

We welcome the changes to the approach to affordable housing that remove prescriptive national requirements and give greater control to local areas. This means we can prioritise the delivery of more genuinely affordable homes to rent, including a clearer priority for social rent. Where a need for affordable housing is identified, planning policies should specify the type of affordable housing required (including the minimum proportion of Social Rent homes required), and expect it to be met on-site unless:

a) off-site provision or an appropriate financial contribution in lieu can be robustly justified; and

b) the agreed approach contributes to the objective of creating mixed and balanced communities.

Local Government Reform

As part of local government reform, the LURA brought in new proposals for devolution. The Government issued an invitation to the Council to respond to its call for this reform on 19 December 2024. The Council is considering how these reform proposals which were published in a Government White Paper in December 2024 may affect our unitary Council. These reforms will in due course engage with a review of the Planning Committee structure and process. The Council will update the public on the consultation process about that in due course.