Brighton & Hove Submission City Plan Part One
Proposed Modifications
February 2015
Statement of Consultation Statement of Consultation - Proposed Modifications
Statement of Representations Made and Main Issues Raised (Regulation 22(1) (c) (v) and (d) of the Town and Country Planning (Local Planning) (England) Regulations 2012
1. Introduction ...... 2 1.1 Role of the Document ...... 2 1.2 Compliance with Statement of Community Involvement...... 2
2. Consultation on the Proposed Modifications to the City Plan Part 1 ...... 3 2.1 Background...... 3 2.2 Proposed Modifications to the Submission Brighton & Hove City Plan Part 1 ...... 4 i) When the Schedule of Proposed Modifications was published...... 4 ii) The Proposed Modifications Documents...... 4 iii) Where the consultation documents were made available ...... 5 iv) Notification of Consultation ...... 6 v) Media...... 7 vi) Posters...... 7
3. The Number of Representations Received...... 8
4. Late Representations...... 10
Appendix 1 List of Consultees for the Proposed Submission City Plan (Part 1) ...... 11 Appendix 2. List of Respondents ...... 33
Appendix 3 Public Notice, press release and media coverage ...... 36
Appendix 4. Email, Letter, Guidance Notes, FAQ and Representation Form leaflet and poster ...... 70
Appendix 5 – Summary of Key Issues Raised by Representations ...... 97
1 1. Introduction
1.1 Role of the Document
Brighton & Hove City Council has prepared a Consultation Statement 1 in relation to consultation undertaken on the Proposed Modifications to the Submission City Plan Part 1. This statement sets out how the city council published the Proposed Modifications to the Submission Brighton & Hove City Plan Part 1 and advertised the opportunities for people to make formal representations to the Inspector about the soundness of the proposed modifications in accordance with the council’s adopted Statement of Community Involvement (SCI) and the Town & Country Planning (Local Planning) (England) Regulations 2012. This statement shows that the requirements set out in the adopted SCI and government regulations have been met. The statement also indicates the number of representations received and provides a summary of the key issues raised in those representations.
Annexe 1 provides a schedule of the representations ordered by proposed modification numbering (and therefore in City Plan policy order).
Copies of the original representations made in accordance with Regulation 20 are published in Annexe 2 which is available electronically from the council’s website or a paper copy from the Customer Service Centre, Hove Town Hall.
This document sets out: i) How the general and specific consultation bodies who were invited to make representations at earlier stages of the plan preparation (under regulation 18) were notified of the publication of the Proposed Modifications; ii) How and within what period the representations had to be made; iii) The procedure for making representations; and iv) A summary of main issues raised as a result of the representations received.
Previous stages of consultations are outlined in the Consultation Statement of Consultation June 2013 (BP/010) published at submission stage.
1.2 Compliance with Statement of Community Involvement
The council adopted its Statement of Community Involvement in September 2006. It sets out how, when and where the council will consult with local and statutory stakeholders in the process of planning for the local authority area, both in producing development plan documents and in carrying out the development control function. Consultation on the City Plan has been guided by the approach set out in the SCI, in particular to:
1 In accordance with Regulation 22 of the Town and Country Planning (Local Planning) England Regulations 2012
2 Enable communities to put forward ideas and suggestions and participate in developing visions, proposals and options for the city Let communities know about emerging policies and proposals in good time Consult on formal proposals Ensure that consultation takes place in locations that are widely accessible Provide and seek feedback
The SCI advocates various approaches to consultation. The council’s approach is to make the maximum use of early community and other stakeholder involvement especially when input and responses from individual and organisations would make a real difference to planning policy.
Following the Town and Country Planning (Local Development) (England) Amendments Regulation coming into force in 2012 consultation on the City Plan Part 1 conformed to the amended regulations and advice contained within PPS12 Spatial Plans until it was replaced by the National Planning Policy Framework. In addition to the council’s SCI, regard has been given to the Community Engagement Framework 2009 (CEF) developed by the Brighton and Hove Strategic Partnership, of which the council is a member. The CEF reinforces the principles of consulting and engaging with communities at an early stage to help ensure their input is meaningful and reflected in the development of a plan or policy. A revised SCI is due for adoption in March 2015. 2. Consultation on the Proposed Modifications to the City Plan Part 1
2.1 Background
The Brighton & Hove City Plan Part 1 was submitted to the government in July 20132 and is still under examination by an independent planning Inspector appointed by the government. Hearings were held in October 2013.
In accordance with section 20(7C) of the 2004 Planning and Compulsory Purchase Act (as amended) Brighton & Hove City Council formally requested that the Inspector recommend any modifications to the Brighton & Hove City Plan Part 1 needed to rectify matters that make the Plan unsound/not legally compliant and thus incapable of being adopted. The Planning Inspector published her Initial Conclusions Letter 13 December 20133 setting out her initial concerns and indicating where further work was required or where modifications to the plan were required.
2 Following approval at Full Council on the 31st January 2013, the Proposed Submission City Plan Part 1 and accompanying documents were published on the 25th February 2013 under Regulation 19 for a 7 week period from 25th February to 12th April 2013. 3 ID-21 Letter to the Council 13 December 2013
3
The published Full Schedule of Modifications4 responded to the Initial Conclusions Letter but also included proposed modifications in response to the Publication Consultation responses; arose from Statements of Common Ground prepared during the examination and arose from the discussions at the Hearing Sessions that took place in October 2013. The schedule also included a number of other modifications made to address typographical errors or provide clarity, or update. It is considered that these minor changes do not go to the heart of 'soundness' or legal compliance but were published for completeness. All modifications were consulted upon5. The Proposed Modifications have been subject to a similar process of publicity and opportunity to make representations as at the regulation 19 stage and the requirements for sustainability assessment have been met with Sustainability Appraisal of the proposed modifications undertaken (Sustainability Appraisal Addendum October 2014).
2.2 Proposed Modifications to the Submission Brighton & Hove City Plan Part 1 i) When the Schedule of Proposed Modifications was published
Following approval at the 16 October Policy & Resources Committee 2014, the Schedule of Proposed Modifications was published for a six week period of consultation starting Tuesday 3rd November and ending Tuesday 16th December 2014.
It should be noted that the Proposed Modification documents had been available to view on the council’s website in July 2014 as the Schedule of Proposed Modifications had been due to be considered at the 11 July Policy & Resources Committee. Although the report was withdrawn at the start of the Committee meeting the documents remained available on the website. ii) The Proposed Modifications Documents
Alongside the Full Schedule of Proposed Modifications (October 2014) which set out the modified policies and supporting text, the following accompanying City Plan Part 1 documents were also modified; Annexes o Annex 1 – Implementation and Monitoring Plan o Annex 2 – Infrastructure and Delivery Plan o Annex 3 – Housing Implementation Strategy
4 Seven versions of the Main Modifications schedule were published in the run up to, and after, the public hearings held into the City Plan Part One in October 2013. The schedule replaced all previously published schedules of Main Modifications. 5 It was clarified in the consultation documents that the public consultation on the proposed modifications put forward were without prejudice to the Inspector’s final conclusions on the Plan and that all representations would be taken into account by the Inspector.
4
As a consequence of the proposed modifications the following supporting documents were updated: Sustainability Appraisal Addendum (October 2014) o Annex 1 to the Sustainability Appraisal o Non Technical Summary to the Sustainability Appraisal Health and Equalities Impact Assessment Addendum update(October 2014) Appropriate Assessment Update (July 2014) Transport Assessment Update (July 2014) Exceptions and Sequential Test (flood risk) Update (July 2014)
The following new technical background studies were also published at the Proposed Modifications Stage:
Urban Fringe Assessment, July 2014 Assessment of Housing Development Needs Study: Sussex Coast Housing Market Area, May 2014
The following background evidence were also updated/ produced to inform/support the Proposed Modifications: Combined Viability Assessment update, October 2014 Duty to Cooperate Update, October 2014 Strategic Housing land Availability assessment (SHLAA) Update 2014
Other examination/ city plan documents which informed the preparation of the City Plan remained available to view on the council’s website.
iii) Where the consultation documents were made available
The Schedule of Proposed Modifications, accompanying documents, the Public Notice which set out the details of where and when the documents could be inspected, guidance notes and the response form were made available on the dedicated Proposed Submission City Plan Part 1 section of the council’s website: http://www.brighton-hove.gov.uk/content/planning/local- development-framework/city-plan-consultation#consultation and could also be accessed via the council’s consultation portal (http://consult.brighton- hove.gov.uk/portal ) and paper copies were made available at the following public deposit points:
Customer Service Centre (Brighton), Customer Service Centre (Hove), Jubilee Library (Brighton), Hove Library, All other city libraries - Coldean Library, Hangleton library, Hollingbury Library, Mile Oak Library, Moulsecoomb Library, Patcham Library, Portslade Library , Rottingdean Library,
5 Saltdean Library, Westdene Library, Whitehawk Library and Woodingdean Library.
The public deposit points had paper copies of all the Proposed Modification documents. Guidance Notes to making a representation, a ‘Frequently Asked Questions’ Note and paper copies of the response forms were also made available. The documents were made available from the 4th November 2014. iv) Notification of Consultation
A public notice was published in the Brighton & Hove Leader Thursday 6 November 2014 (see appendix 3) it was also published on the council’s website.
Emails or letters were used to notify organisations and individuals who were logged as relevant consultees on the council’s LDF database. The database includes statutory consultees and also the organisations and individuals who were invited to, or have responded to previous consultations on the Core Strategy / City Plan (Regulation 18) including the Publication (submission consultation) and examination stage.
Those groups/ individuals who had written in with respect to the Urban Fringe Assessment Study when this had been published in July 2014 were also notified of the formal public consultation. The LDF is continuously updated with new consultees that engage during or between consultation periods being added to the database.
Over 1,000 LDF database consultees were notified by email or letter of the Proposed Modifications to the City Plan – Part 1 consultation (see Appendix 1). The notification email included a website link to the council’s website where the documents could be read or downloaded and the consultation portal. Letters were sent if there was no recorded email address. The letter advised of the availability online of a guidance note for making representations and a FAQ note or that these could be sent if requested (sees Appendix 4 for copy of letter and email).
Consultees received full details of the duration of the representation period, where documents could be viewed and how to make comments. A guide to making representations (see Appendix 5) and a Frequently Asked Questions Document was made available on the council website and in deposit points.
Respondents were able to respond: Electronically via the council’s Consultation Portal (http://consult.brighton-hove.gov.uk/portal ). This is directly linked to the consultation section on the council’s website and gave respondents an opportunity to respond to the response form online and gave the option to provide more detailed written responses. By downloading from the City Plan consultation web-page and completing a response form and sending this to the council by email or by post or by hand
6 Written representations (not using form) were also accepted via post and by hand. v) Media
A public notice was placed in the local press on the 6th November and the council issued a press release on its web page. Appendix 3 of this document details the city council media press releases that were issued on the Proposed Modifications to the Submission City Plan Part 1 in October/ November 2014.
Public awareness of the proposed modifications to the City Plan had been raised in July 2014 when the Proposed Modifications were due to be considered by the 11 July Policy & Resources Committee. There were a significant number of press articles related to the Urban Fringe Assessment Study published in the local media including the Brighton & Hove Independent News, Brighton & Hove News, the Brighton & Hove Argus, and a phone-in discussion on BBC Radio Sussex (11 July 2014). vi) Posters
Posters regarding the Proposed Modifications consultation were also prepared for the deposit points as an additional way to ensure that residents were aware of the proposed modifications and the opportunity to make comments. See Appendix 4.
7 3. The Number of Representations Received.
A total of 187 respondents commented on the Schedule of Proposed Modifications. A summary of the number by type of respondent is summarised in the table below;
Type of Respondent Number of respondents Business 2 Civic and Amenity Group 16 Community & Voluntary Sector 0 Developers, landowners and consultants 24 Environmental, Transport & Wildlife Groups 13 Government Agency 4 Individual 123 Public Sector / Local Authority 5 Total 187
A full list of respondents is shown in Appendix 2.
The 187 respondents who commented on the Schedule of Proposed Modifications to the City Plan Part 1 made a total of 474 representations. A table setting out the summary of key issues raised by the representations are included at Appendix 5.
Total Number of Mod Number Support Object blank Representations PMHIS 0 1 0 1 ALL 1 0 0 1 NO COMMENT 0 0 3 3 NO MOD NO 0 0 8 8 PM003 1 0 0 1 PM007 1 0 0 1 PM008 0 2 0 2 PM009 1 0 0 1 PM010 8 24 3 35 PM011 4 8 1 13 PM012 0 2 0 2 PM013 1 0 0 1 PM014 3 2 0 5 PM015 0 2 1 3 PM016 1 0 0 1 PM017 2 2 0 4 PM018 2 2 0 4 PM019 2 6 0 8 PM020 1 1 0 2 PM021 4 1 0 5 PM022 1 0 0 1 PM023 3 4 0 7 PM025 3 1 0 4 PM026 1 2 0 3
8 Total Number of Mod Number Support Object blank Representations PM027 0 1 1 2 PM028 0 2 0 2 PM029 0 1 0 1 PM030 1 1 0 2 PM031 0 1 0 1 PM032 0 1 0 1 PM033 1 0 0 1 PM037 0 0 1 1 PM040 0 1 1 2 PM043 0 1 0 1 PM044 1 1 0 2 PM045 0 45 2 47 PM046 1 0 0 1 PM047 2 0 0 2 PM048 0 1 0 1 PM049 1 1 0 2 PM051 2 1 0 3 PM061 2 1 0 3 PM062 1 1 0 2 PM064 7 103 6 116 PM065 3 2 1 6 PM066 1 3 0 4 PM068 1 0 0 1 PM069 1 2 0 3 PM072 6 66 2 74 PM075 2 8 0 10 PM076 0 3 0 3 PM078 1 0 0 1 PM079 0 1 0 1 PM082 0 2 0 2 PM085 1 7 0 8 PM089 0 5 0 5 PM090 1 0 0 1 PM091 1 1 0 2 PM093 1 2 1 4 PM097 1 1 0 2 PM098 1 1 0 2 PM099 0 5 0 5 PM100 0 1 0 1 PM101 1 6 1 8 PM102 1 2 2 5 PM103 1 0 0 1 PM105 2 0 0 2 PM106 4 1 0 5 PM107 3 3 1 7 PM108 0 0 1 1 PM109 1 0 0 1 93 345 36 474
9 4. Late Representations
For information, 6 representations were received after the close of consultation (midnight Tuesday 16 December 2014) and these have not been accepted as duly made representations. As such they have not been included in the summary of representations or submitted to the Inspector. The late representations were received from: B. Stewert F. Considine J. Wright M.Dent Scotia Gas Networks TP Hooker
10 Appendix 1 List of Consultees for the Proposed Submission City Plan (Part 1)
Specific Consultees
Local Authorities
Adur & Worthing Council Arun District Council Chichester District Council Crawley Borough Council Ditchling Parish Council Eastbourne Borough Council East Sussex County Council Falmer Parish Council Fulking Parish Council Hastings Borough Council Horsham District Council Kingston Parish Council Lewes District Council Mid Sussex District Council Newtimber Parish Council Poynings Parish Council Pyecombe Parish Council Rodmell Parish Council Rother District Council Rottingdean Parish Council South Down National Park Authority Sussex Police Authority Telscombe Town Council Upper Beeding Parish Council Wealden District Council West Sussex County Council
Gov Organisations
CABE Civil Aviation Authority English Heritage - SE Region Environment Agency (Solent & South Downs) Homes and Community Agency Highways Agency Homes & Communties Agency Marine Management Organisation Natural England Network Rail NHS Brighton & Hove SEEDA Southeast Region Design Panel South Downs National Park Authority Sport England The Secretary of State for Transport Mike Weatherley MP
11
Utilities
British Telecommunications plc EDF Energy Mobile Phone Operators Association (O2, 3, Orange, Vodafone, T-Mobile) Openreach BT Virgin Mobile Renewable UK Scottish Power Corporate Communications Southern Water The Coal Authority UK Power Networks (Infrastructure Planning South)
Landowners
University of Brighton University of Sussex South East Coast Ambulance Service NHS Foundation Trust Shoreham Port Authority
Consultees General
Other Public Bodies
BHCC, City Sustainability Partnership Brighton & Hove Arts Council Brighton & Hove Clinical Commissioning Group Brighton & Hove Public Health Brighton & Sussex University Hospitals NHS Trust Brighton Aldridge Community Academy Brighton Dome Festival Ltd & the Royal Pav City Employment and Skills Steering Group Coast to Capital LEP Dorothy Stringer High School ESCC (The Keep Project) Jubilee & Hove Libraries NHS Brighton & Hove NHS Property Services Strategic Estates Sussex Patcham High School Planning Aid South East South Downs Health NHS Trust South East Coast Ambulance Service St Bartholomews C E School Sussex Partnership NHS Trust Sussex Probation Service Tourism South East
BME
Al Medina Mosque
12 Asian Society B&H Black Womens Group B&H Black Womens Group B&H Chinese Society B&H Inter Faith Contact Group B&H Jewish Community Foundation B&H Jewish Housing Association B&H Jewish Representative Council B&H Muslim Forum B&H Muslim Womens Group Bahai Faith Bangladeshi Community Bangladeshi Women & Children Support Group Black & Minority Ethnic Resource Centre Black & Minority Ethnic Young Peoples Project Black History Project BME Champion Brighton & Hove Reform Synagogue Brighton Asian Circle Childrens Music Play House Chinese Educational Development Project Chinese Information Pilot Coaching, Training & Consultancy Elephant Group Ethnic Minorities Representative Council Ethnic Minorities Visibility Initiative Gujarati Culture Centre Gujerati Cultural Society Hindu Women's Group Hove Pakistani Urdu Speaking Group Islamic Centre and Mosque Japanese Womens Group Migrant Helpline Mosaic Oufemi Hughes Phatho Ncube Sompriti Poets Corner Multicultural Group Polish Group Rwandan Youth Information Community Organisation Sierra Leone Brighton Association Sikh Community Society of Nigerians in Sussex Society of Nigerians in Sussex Southeast Interpreting Services Sudanese Community in Sussex Sudanese Coptic Association Sudanese Women and Children Group Sussex African Communities Project Sussex Bangladeshi Association Sussex Intepreting Services Sussex Refugee Association The Race Project Traveller Law Reform Project
13 UK China Student Union Voices in Exile
Business
Arts & Business Ltd B&H Hotels Association Brighton & Hove Chamber of Commerce Brighton & Hove Major Hotels Group Brighton BID Manager Brighton Media Centre CBI - SE Region Churchill Square Shopping Centre Community Stadium Ltd Costco Wholesale UK Ltd G Scene Herandi Management Ltd Hove Business Association Infinity Foods Komedia Miles Broe architects National Grid North Lane Traders Association Oriental Hotel Palace Street Developments Ltd Preston St Traders Association Rottingdean Trade, Business & Professional Assoc Smiths Gore St Peter's Church Traders Sussex Enterprise Sussex Society of Licensed Victuallers Telereal Trillium The Garden Centre Group The Lanes Traders Assoc Under the Bridge Studios Wired Sussex
Community & Voluntary Services
Age Concern Brighton Hove Portslade AKWAABA Association of Harbour Communities B&H and District Leaseholders Assoc B&H City Mission B&H Community Buildings Network B&H Council Leaseholders Independent Forum Blatchington Court Trust Borough St Community Group Bridge Community Education Centre Brighthelm Church & Community Centre Brighton & Hove Business Community Partnership Brighton & Hove Community & Voluntary Sector Forum Brighton & Hove Pensioners Association
14 Brighton & Hove Progressive Synagogue Brighton & Hove Speak Out Brighton & Hove YAP Brighton Housing Trust Brighton Little Theatre Brighton Old Town Local Action Team Brighton Rock Housing Coop Brighton YMCA Bristol Estate Community Association British Red Cross Brunswick Community Development Project Central Hove Local Action team CHIBAH: Co-operative Housing in Brighton and Hove Churches Together in B&H City-Gate Centre Clifton, Montpellier, & Powis Community Alliance Community Association of Portslade South Community Base Coombe Road Local Action team Cornerstone Community Centre Craven Vale Community Assoc East Sussex Association for the Blind East Sussex Strategic Partnership Engage Fishersgate Community Assoc Friends, Families & Travellers Goldsmid Local Action Team Hailsham Trust Hangleton & Knoll Project Hangleton Community Association Hanover and Elm Grove Local Action team Hanover Community Centre Hollingbury Local Action Team Hollingdean Development Trust Hollingdean Local Action Team Hollingdean Programme Hove Hebrew Congregation Hove YMCA Knoll Community Association London Road Local Action Team Marina Local Action Team Meadowview and Tenantry Community Action Group Moulsecoomb Local Action Team National Association of Gypsy & Traveller Officers National Federation of Gypsy Liaison Groups Neighbourhoods Network c/o BHCVSF North Laine Arts Old Boat Corner Community Centre Older Peoples Council Patcham Local Action Team Phoenix Arts Association Phoenix Community Association Phoenix Community Centre Poets Corner Community Society
15 Portslade Community Forum Portslade Local Action Team Preston Park and Fiveways Local Action Team Prestonville Community Association Queens Park Community Assoc Queens Park Local Action Team RAISE Relate Brighton & Hove Royal National Institute for Deaf People Saunders Park Community Association Seniors Community Project Social Enterprise Complementary Therapy Committee Somerset Day Centre South Portslade Community Group St James Community Action Group Sussex Diocesan Association for the Deaf Sussex Youth Ltd Tarner Area Partnership & Community Safety Action Terrence Higgins Health Impact Project The Aldridge Foundation The Carers Centre, Brighton & Hove The League of Hospital & Community Friends The Women's Centre Triangle Community Group Trust for Developing Communities Trust for Developing Communities Volunteer Centre, Brighton & Hove West Hill Local Action Team West Hove Forum Westdene and Withdean Local Action Team Whitehawk Community Voice Whitehawk Crime Prevention Forum Whitehawk Youth and Community Centre Woodingdean Community Association Youth Parliament Reps
Civic & Amenity
A C Green Ancient Monuments Society Another London Road Arundel St/Arundel Road Residents Assoc B&H Albion Supporters Club B&H Athletic Club Bevendean Local Action team Bevendean Tenants Action Group BHCC Resident Involvement Team Brighton & Hove Allotments Federation Brighton Area Buswatch Brighton Festival & Dome Brighton Marina Residents Assoc British Toilet Association Broadfields Tenants Assoc Brunswick & Regency Residents Group
16 Brunswick St West & Dudley Mews Residents Assoc CAG (Chair) Campaign for Real Ale Campaign to Save Toads Hole Valley CAMRA Central Whitehawk Tenants & Residents Assoc Chair of the Brighton Marina Residents Association Clarendon & Ellen Residents Assoc Clifton, Montpelier & Powis Community Alliance Deans Preservation Group Ditchling Rise Area Residents Association Downland Court Residents Assoc Dyke Road Park Action Group Essex Place Tenants Assoc Evelyn Court Residents Assoc Fabrica Faith Lee Federation of Sussex Amenity Societies Foredown Estate Residents Assoc Friends of Bevendean Down Friends of Blakers Park Friends of Brunswick Sq & Terrace Friends of Coldean Woods Friends of Devil's Dyke Friends of Easthill Park Friends of Hollingbury & Burstead Woods Friends of Hollingdean Friends of Preston Park Friends of Queens Park Friends of Sheepcote Valley Friends of Tarner Park Friends of Waterhall Friends of Whitehawk Hill Friends of William Clarke Park Friends of Withdean Park Friends of Woodingdean Goldstone Valley Residents Assoc Gregory Gray Associates Hampshire Court Residents Assoc Hangleton and Knoll 50+ steering group Hanover Community Association Hereford Court & Wiltshire House Residents Assoc Historic Building Analysis Hollingbury Circle Residents Assoc Hollingdean Tenants Assoc Hove Civic Society (Chair) Hyde & Westmount & Crown Hill Residents Assoc Jasmine Court Residents Assoc KAWHRA Committee Keep Sussex Skating Keep the Ridge Green Kemp Town Conservation Society Kemp Town Society Kings Gardens Resident Association
17 Kingscliffe Society Kingstone Close Residents Assoc Kingsway and West Hove Residents Association Knoll Residents Assoc Laburnum Grove Residents Assoc Lansdowne Area Residents Association Lavender House Tenants Assoc Leach Court Tenants Assoc Lindfield Court Tenants Assoc Manor Farm Residents Assoc Manor Farm/South Whitehawk Assoc Marine Gate Action Group Marmion Road Residents Assoc Mayflower Square Tenants Assoc Milner & Kingswood Tenants Assoc Montpelier & Clifton Hill Assoc Moulsecoomb Community Shops Group Moulsecoomb East Social Activities & Tenants Assoc Nettleton Court & Dudeney Lodge Tenants Assoc North East Hove Park Residents' Association North Laine Community Association North Moulsecoomb Tenants & Residents Assoc North Whitehawk Tenants & Residents Assoc Old Boat Corner Residents Assoc Open Spaces Society Ovingdean Residents & Preservation Soc Park Royal Residents Assoc Patcham & Hollingbury Help Group Philip Court Residents Assoc Phoenix Athletic Club Poplar Close Residents Assoc Powis Square Community Association Preston & Old Patcham Society Preston and Old Patcham Society Queens Park / Craven Road Action Group Regency Society Regency Square Area Society Residents Association East Brunswick Residents Association of Moulsecoomb Robert Lodge Residents Assoc Roedean Residents Association Rottingdean Preservation Society Saltdean Residents Association Save Brighton Save our Seafront saveHOVE Sloane Court Tenants Assoc Southdown Rise Residents’ Association St James Action Group St James House & Ardingley Court Tenants Assoc St James's House Residents Assoc Stanmer Heights Community Assoc Stanmer Preservation Society Stoneham Park Community Association
18 Sussex County Cricket Club Sussex Industrial Archaeological Society Sylvan Hall Tenants Association The Brighton Society The Friends of Brunswick Square & Terrace The Friends of Palmeira & Adelaide The Kemp Town Society The Kingscliffe Society The Regency Society The Round Hill Society The Theatres Trust The Vale Residents Association Theobald House Residents Assoc Tillstone St Residents Assoc Transition Town Shoreham by Sea Triangle Community Group Tudor Close Residents Assoc TWEACK Vale Road Residents Assoc Vallance Residents Association Valley Road & Carden Court Residents Assoc Warwick Mount Residents Assoc Wellington Road Tenants & Residents Assoc West Hill Community Association West Hove Cycling Western Esplanade Management Co (Hove) Ltd Wilbury Area Residents Assoc Woodingdean Residents Association Woodingdean Tenants & Residents Assoc Woodland Drive Residents Assoc
Community Newspapers
Fiveways Directory Hangleton Harbinger Hollingdean News Phoenix Magazine Whistler
Consultants
Batcheller Monkhouse CBRE Global Investors Chris Thomas Ltd DMH Stallard Papworth Research & Consultancy Planning Potential Regen-Nation SSA Planning Limited Strategy and Action Vail Williams Property Consultants
Environmental, Transport & Wildlife Groups
19 B&H Environmental Action Group B&H Inner City Wildlife Concern Benfield Wildlife and Conservation Group Biffa Waste Services Ltd, C/o Severn Trent Water Ltd Bike for Life Bricycles Brighton & Hove Archaeological Society Brighton & Hove Local Access Forum Brighton Conservation Volunteers Brighton Peace & Environment Centre Brighton Urban Wildlife Group Brighton's Future British Geological Survey Bus Users UK Centre for Ecology and Hydrology CPRE CPRE Brighton and Hove District CPRE Sussex Branch Cycling Support Services Earthwise Eco-logically Ecosys Environmental Consultancy Keep our Downs Public Levvel Magpie Environmental Trust Moulsecoomb Forest Garden & Wildlife Project National Trust Open Spaces Society Railfuture Roedale Allotments & Garden Society RSPB Save Toads Hole Valley South Downs Advisory Forum South Downs Society Southern Landlords Association Stagecoach South Sussex Archaeological Society Sussex Past (Sussex Archaeological Society) Sussex Wildlife Trust Sustrans Tall Trees The Carers Garden Toads Hole Valley Wildlife Group Transition Brighton & Hove Transition Energy Group
Government Agency
CABE Sport England
Landowners, Developers & Agents
20 ABIR Architects Adams Integra Housing Consultancy Adenstar Developments Affinity Sutton Alaska Group Alder King Planning Consultants Alliance Environment & Planning Ltd Amex AmicusHorizon Group Anchor Housing Trust APEC (Art Producing Economic Community) AS Planning ASB Law Ashley House plc ASP Austin Gray Commercial & Property Auctions B&H Estate Agents Association Baron Homes Corporation Ltd Barratt Southern Counties Barton Willmore Planning Partnership Beetham Organisation Ltd Benfield Investments Ltd Bowden Property Consulting Braybon Holdings Brighton & Hove Albion Football Club Ltd Brighton & Hove Housing Partnership c/o Hyde Housing Ltd Brighton and Hove Affordable Housing Partnership Brighton College Brighton Marina Co Ltd Brighton West Pier Trust Broadway Malyan (City College) Brunswick Developments Group plc Building Design Partnership BUPA Carr & Priddle Cathedral Group PLC Cathedral Ltd CB Richard Ellis Ltd (Legal & General) CBRE (American Express) Centurion Group Cherrywood Investment Ltd Church Commissioners City College Brighton & Hove CJ Planning Ltd Cliff Walsingham & Co Clifford Dann LLP Cluttons Colin Brace Colliers CRE Collins Planning Services Cook & Pecla Co-operative Group Co-operative Group Costco
21 Countrywide Commercial Crest Nicholson & Hyde Housing Crickmay Chartered Surveyors Cross Stone Urban Regeneration Development Focus Discovery Properties Ltd DMH Stallard Downland Housing Association DowsettMayhew Planning Partnership DPDS Consulting Group Drivers Jonas Deloitte DTZ DW Planning E Sussex Fire & Rescue Service Engleharts Solicitors Enplan Evolution Architects Explo're living Fairview Felce & Guy Firstplan Flude Commercial Fulbeck Land Ltd G L Hearn Genesis Town Planning George IV Guesthouse Gleeson Strategic Land Graeme Graves Jenkins Graves Son & Pilcher Harbour View Developments Ltd Hargreaves Hazel McKay Consultancy Hemsley Orrell Partnership Holmes Antill Home Builders Federation Ltd Hopegar Properties Ltd Humberts Leisure Hyde Housing Hyde Martlet Hyde Plus - Sussex & Surrey Infinity Foods Insite Planning Ltd Investec Private Bank James Breckell Architect Jones Day Jones Lang LaSalle Ltd Karis Holdings/Karis Developments Katie Jackson on behalf of Mr and Mrs Harman Khalil & Kane Kirkwells L K Robinson, Robinson & Co Landlord Association Lansdowne Investments Ltd (in administration)
22 LaSalle Investment Management Management Legal & General Lewis and Co Planning Lewis Planning Lightwood Strategic Ltd MacConvilles Maplebright LLp and C Brewer & Sons Ltd Maritime Atlantic Ltd Matsim Properties Mayfield Market Towns Ltd Mike Holland Miles Broe Architects Ltd Miller Bourne Partnership Moat Housing Assoc Montagu Evans LLP (Standard Life) Morgan Carn Partnership Mosman Developments Ltd Motoring & Leisure Services Ltd Mott MacDonald Mr Cross c/o RJ Maile Nathaniel Lichfield and Partners National Grid Properties & Scotia Gas Networks NCP Ltd Newtown Ventures Ltd Nivea Sun Yellowave Oakley Commercial Palace Pier (Noble Organisation) Parkridge Ltd Parsons Sons & Basley Peacock & Smith Periworld Ltd Persimmon Homes South East Planning Potential (Asda Stores Ltd) Planware Ltd Post Office Property Holdings c/o Atisreal Protodale Ltd PRP Architects QED (Quoin Estates and Developments Ltd) R H Partnership Rapleys LLP Retirement Housing Group RHPC Richard Nickson Design Co Roedean School Royal Mail Group Limited RPS Planning & Consultancy Savills Ltd Scottish Widows Shoreham Airport Signet Planning Smiths Gore Southern Housing Group Spenhill Ltd St James Investments Ltd
23 Standard Life Investments Stewart Ross Associates Stiles Harold Williams Stonebridge Brighton Ltd Strutt & Parker Taylor Wimpey Strategic Land Teale and Brindley Families c/o lewis planning Telegen UK Tesco Store Limited Tetlow King Planning The Crown Estate The Guinness Partnership The Home Builders Federation The Hyde Group Thornton Properties Topland Group Town and Country Planning Trust for Future Health Trustees of Toads Hole Valley & Pecla Investments Turner Associates Two Piers Housing Co-operative Ltd Urban Splash Urban Student Life Varndean School Waitrose Watkin Jones Wilks, Head & Eve Wilson Bowden Developments Wm Morrison Plc Woodwych Housing Co-op WP Properties Ltd c/o Agent X-Leisure LTD Your Student Room Ltd Zise Ltd
Utilities
National Grid Property Holdings Ltd & Scotia Gas N Renewable UK Scotia Gas Networks (SGN) South East Ambulance Foundation Trust (SECAmb) UK Power Networks (Infrastructure Planning South)
Individuals
Henrietta Adu C Alabone Mark Aldridge Prof Sydney Anglo John Armstrong Steve Atkins J Axten Dr Samer Bagaeen Navdeep Bains
24 A Baker David Ballard Tamar Bannister Mrs Anna Barden Ray Bareham Kevin Barkey Vanessa Barkley Roger & Virginia Barnacle Claudio Barone Mrs M. C. Bartlett Keith Bassant Duncan Bassett John Beal Carole Beane Lizzie Beckett Karen Belton Colin B Bennett David Bennett D & S Bernard Elizabeth Betts Bevan Stephen Biggs Carol Bishop Anthony Black Peter Blow David Botibol James Bradley Sarah Bradley Mr Bradshaw Neil Bridle Robert Brightwell Jonathan Bromberg Andy Brooker Mr & Mrs Brown Jonathon Bryant Norah Buckley L Bull J L Burchell P Burgess Dr Lydia Burgess-Gamble Jamie Burston P Butler Gavin Button Teale & Brindley Families Ian & Jo Campbell Val Cane Mr G Card Pamela Carsaniga Avis Carter Maria Cea Katie Chipping Kirit Chudasama Adrian Clarke Stephanie Clay
25 Richard Cleminson Patricia Clowser Andrew Coleman Marion Coleman Peter Coleman Peter & Pam Collins Paul Collins Annette Conkleton David Connor Phil Cooper Ronald Cooper Martyn and Michelle Cooperman Paul Corlett A Corney J Cosham Sophie Costin Steven Crockett Roger Crouch MR & Mrs Cubbage Robert Cummings Mrs Curuthers Mrs R Dabbs Karin Dahmen Anya Dathan Richard Davies Lynne Davies Mark Davies Andy Davies Pat Davis Marie Day M Day V De Schaller Marion Dent Mike Dixon Ian and Margaret Dodd Andrew Doig Jacqui Dolton Mr & Mrs Dowd John Draper Tina Duncomb Dan Dunkel Mervyn Eason Amanda El-Haffar J Elves Neil Evans G & M Evans Denise Ewens Ian Farell Kathryn Farrell Robert Farrell P Farrow S Farrow Kathleen Fay Peter Field
26 Michael Figures Sharon Finlayson Cllr Brian Fitch Gavin Fitzgerald Madeleine Fitzgibbon David Flack Sean Flannagan Kyle Fortune Graham Fowler Anthea Franks Linda Freedman Zoe Freeman Nick Fry Gwen Funnell Edward Furey Clive Gale-Smith Jane and Michael Galvin Jane Galvin C Gander John Garlinge Karen Gearing David Gerrard Paul Gibb Peter & Mary Gibbons Steve Gibson Ross Gilbert Jenny Gill A Ginnings G & J Godbolt Sue Goldhawk Rui Gomes P C Goodson Yvonne Gosby Gavin Graimes Jo Graver James Greed John Green Marina Alan & Charlotte Green David Green Careen Green A B Green J Gregory B A & A E Gregory Pru Gridley Joan Griffiths Henrique Guerreiro Fiona Hall Richard Hallam Mrs A. Hammond Colin Hancox Robert Hanslip Gemma Harding H Harman Mr Hassan
27 Jason Hausdoerfer Clifford Hawkins Jane Hawkins Robert Heale Carole Heasman Sandra Heathcoxe Tracey Hill Jon Hill V Hiscox Carl Hodder Mr and Mrs M L Holbrook Greta Holt Jamie Hooper Eamon Hourigan Richard Howells Rich Howorth Ian Hubbard Tracey Hughes Mrs H E Hughes Catherine Hunt Anna Hunter John Hutchings E S Hynson Alastair Irons Bryan Izzard Katie Jackson Michaela Jacobs Ian James Frank Jay David Jewell Michael Johnson Alzbeta Johnson Adrian Johnson Nicole Jones Ali McKinlay & Kelsey Jordan Anthony Kelly T J Kemp Colin & Chrissie Kennard Mr Mrs Kinsey Agriesuga Kraue Clive Lambert Ruth Larkin Shelagh Larman Katherine Laux Martin Lawrence John Lawrence Kirk Lee Andrew Lees Tony Lees Ken & Beverley Leonard Karen Lewis Mr & Mrs Light Roger Lightbrown Robert Lines
28 John Locke Anne Johnson & Louis Blache Adam Love Mr & Mrs Lowrence Steve Lynn Rev Alexander Mabbs Ivan Mainprize Deborah Malin Keith Manaton H Marbach Sam Marshall Brian Mascard B & R Mason Julian Mason Ewelina Masternay J Matthews J McClymont Terry McCormack Anthony McCully Philip McGregor Ian McHaffie Marie Mclachlan John McLean (Director) Maire McQueeney Nathan Meager Mrs K. Meakin-Scott Rachael Mellors Rev Michael Denis Miles Pam Miles Gwyn Millyard Guy Montague Smith Ann Montgomery Dominic Morgan Lee Morley Peggy Morris HG Mueller Kevin Murphy Howard Murray Jon Newsom-Ray Ruth Nguyen Phil Nong I J & C S Noonan Geraldine O'Brien J Oconnell M T O'Connell S O'Connell Jeremy Ogden Arthur Oppenheimer Abraham Oyekanmi Atillo Pallo Dr Gregory Parish Parkinson Emma Parnaby
29 B Parrish Steve Parry Andrew Parry A Paterson Richard Paul-Jones Tessa Pawsey A.N. Peasgood Nina Perrott John Perry Mr Perry Karen Phillips J PHILLIPS Richard Phillips Mike Philpott (Chairman) Jane Pidgeon Jolie Pierce Julia Pilgrim Steve Pine Teresa Pither John Pope Trevor Pouey Richard Pouslon Diana Praud Fiona Price Aaron Priestman Vida Prodger Janet Prodger Michael Prodger Anthony Purkiss Mr Jim Quintana Catharine Rankin Jennifer Raven Dr Michael Ray Maria Rayner Peter & Brenda Reeves Roger Reynolds Kelly Richardson Simon Rickman Dave Ridley Gavin Ritchie Simon Roberts Patrick Roberts Trudy Roberts Mr & Mrs Roden Roger Rolfe Alex Ross Martin Ross Mark Rotten Sandra Russell Geoffrey Russell Nicholas Sabine B D Sanders Esq B Sapat Derrant and Jacqueline Savage
30 Elisabeth & Peter Scarff Trevor Scoble Richard Scott Tim Selrett Derick Shaw Eddy Shears J Shirley Andy Silsby Tony Silsby James Simister Glynis Simpson Kim Sinclair Paul Skelly Mary Slack Noel Sladen John Small DR Farrogh Smarifzad Bruce A Smith Valerie Smith Andrew and Patricia Smith Doreen & Derek Sparrow Dean Spears Mark Stevens Ray Stewart Pamela Stiles Nigel Swift Carol Swift Mark Taylor David Taylor Richard Taylor Sara and Mark Telford Venetia Terry Mike Thacker Molly Thew Beth Thomas Brian Thomson A Thorpe Karen Tiltman Pip Tindall Frances Tobin Rachel Travers Nichola Traverse-Healey Sonya Trott Claire Tyers
Chris Wade David Wagg Julie Wagg Gill Wales Grace Walsh Alison Walters Barry Ward Steve & Maria Ward Clair Wavell
31 Patricia Weller Stephen Wells John & Janet Welsh S Wenham Joyce West Robert Thomas and Graham Whatley Linda Whitby Edward White Frank Williams John Williams Marie Williams Christopher Wilson Amanda Wilson Louise Windsor Gilly Wise Colin Witham William Woodville-Brown Bernard Woolf Kate Worsfold Jutta Wuttke Nikki Wyatt Robert Young Umberto Zaffmo
32 Appendix 2. List of Respondents
Respondent Number Organisation Agent/ Individuals Name 1 Dr Michael Ray 2 Tony Lees 3 The Baron Homes Corporation c/o Mr Paul Burgess 4 Gavin Fitzgerald 5 Dr G R Parish 6 Phil Belden 7 Hove Civic Society Helmut Lusser, Chairman 8 Herandi Management Ltd Emad Herandi 9 Palace Street Developments Ltd Mr William Fellows 10 Jonathon N Bryant 11 Elisabeth & Peter Scarff 12 North Laine Arts Sarah Wright 13 North Laine Community Association Sandy Crowhurst 14 George McAlpine 15 Jill and Paul Corlett 16 Steve Parry 17 Mrs C Carruthers 18 Dr Samer Bagaeen 19 Deborah Malin 20 Lewes District Council Catherine Jack 21 Brighton & Hove Hoteliers Association J Ogden 22 Sandra Russell 23 Mayfield Market Towns Ltd 24 Bouygues Development Mr James Rogers 25 South Downs Society Steve Ankers Policy Officer 26 Jamie Burston 27 The Open Spaces Society Chris Smith 28 Carer' s Garden Sara Padhiar-Tutton 29 Andy Davies 30 Tessa Pawsey 31 Kingsway and West Hove RA Susan Moffatt, Committee Member 32 Nick Fry 33 34 Duncan Bassett 35 Ovingdean Estates Limited Teale and Brindley Families 36 David Ballard 37 Jon Newsom-Ray 38 Avis Carter 39 Jane Pidgeon 40 David Jewell 41 Edwin Sears 42 Gilly Wise 43 Keith & Georgette Bassant 44 Stephen Wells 45 Mark Stephens 46 Simon Rickman 47 Karen E Tiltman 48 Carl Hodler 49 Mervyn Eason 50 Kim Sinclair 51 Geoffrey Russell 52 Heidi Mueller 53 Marina Patrignani 54 Peter Ames 55 West Sussex County Council Caroline West 56 Geraldine O'Brien 57 Brighton & Hove Economic Partnership Dean Orgill, Chair 58 Roedean Residents Association Rosemary Shepherd 59 Nigel Swift 60 Sean Flanagan 61 John Dann 62 Diana Praud 63 David Gerrard 64 Clive Gale-Smith 65 Jo Graver 66 Dr Lydia Burgess-Gamble 67 Mrs S Finlayson 68 Mr Andrew Doig 69 M J H Stimpson 70 Grenville Nation 71 Karin Dahmen
33 72 Campaign to Save Toads Hole Valley Hazel McKay 73 Brian Thomson 74 Lucia Brida 75 Mr D Hunter/The Hunter Family 76 Sport England H Clarke 77 Friends of Hollingbury & Burstead Woods Mr Adrian Peasgood 78 David and Julie Wagg 79 Colin Inns 80 Jacqueline Inns 81 Paul Davey 82 Caroline Martin 83 Graeme Forrest 84 Ann R Hayes 85 Richard Everest 86 Mark Hayes 87 Miss Jane Frowde 88 Neil Evans 89 Linnette Fellingham 90 Craven Vale & Whitehawk Hill Allotment Society James Gilderoy 91 Derek Allen 92 Wendy Barrett 93 Jenny Embleton 94 Mr John Austin Locke 95 Ovingdean Residents & Preservation Society Russell Smith 96 Deans Preservation Group James Wright 97 CPRE Sussex Penny Hudd & Georgia Wrighton 98 Marine Management Organisation Angela Gemmill (Relationship Manager) 99 R. Hatley 100 Cross Stone Regeneration Ross Barbour 101 Valerie Axcell 102 Ms Brenda Pollack 103 X-Leisure Ltd and Land Securities Polly Troughton and Mark Lomax 104 Environment Agency Emma Winchester 105 Dawn Robson 106 Preston & Patcham Society Mr Nicholas White 107 Jill Humphrey 108 Ian Robertson 109 Vivien Robertson 110 Ivor O'Mahony 111 Natural England John Lister 112 Brighton & Hove's Wildlife Forum Martin Robinson 113 Paul Tibbey 114 Dr Jo Tulloch 115 Anthony L Cooke 116 University of Sussex John L Duffy Charles Dudley 117 Lightwood Strategic n/a 118 Saltdean Residents' Association Cathy Gallagher Vice Chair and Treasurer 119 The Brighton Society Malcolm Dawes Jeremy Mustoe 120 Cathy Wenger 121 Veronica Atkinson 122 The National Trust Mrs Anna Budge 123 Sainsbury's Supermarkets Ltd 124 Mrs Kate Mullins 125 Edgar Miller 126 Roger & Sue Harper 127 Mrs Polly Charlton 128 Mrs M.Corrado and Mr R.Gokkaya 129 Friends of Hollingbury and Burstead Woods Adam Penwarden 130 The Vale Residents Association c/o Helen Trundle and Suzanne Woods 131 Anthony Rogers 132 Mr and Mrs Kinsey 133 Rottingdean Parish Council Chairman Bob Webzell 134 Richard & Theresa Pearce 135 Chris & Linda Whitby 136 Horsdean Community Sports Association Alan Wildig 137 Sussex Wildlife Trust Jess Price Conservation Officer 138 Sarah Wilkins 139 Matthew Grout 140 Left Unity Brighton & Hove Branch Dave Bangs 141 Geoff and Jean Harris 142 Saltdean Countryside Alliance J Frowde 143 Adur and Worthing Councils Catherine Hutchins 144 Crest Strategic Ltd Jonathon Calcutt 145 Ray Tyler 146 V Del Federico 147 SOC j shepherd 148 Heather smith 149 Gabriele Del Federico 150 Abby Hone 151 La Salle Investment Management c/o agent
34 152 Mr Colin Brace 153 Westfield Investments Ltd Colin Brace 154 Linden Homes (Guildford) & Cothill Educational Trust n/a 155 Taylor Wimpey (UK) LTD c/o agent 156 Paula da Luz 157 Graham Levett 158 Steve Dunnill 159 Standard Life Investments (SLI) 160 Butterfly Conservation Nigel Symington Chair, Sussex Branch 161 Brunswick Development Group Plc n/a 162 Hyde Housing Group n/a 163 South Downs National Park Authority Anna Ludford Local Plan Lead (interim) 164 Jane Moss-O'Brien 165 Select Property Group Ltd n/a 166 National Grid Holdings (NGP) and Scotia Gas Networks (SGN) n/a 167 University of Brighton Mike Clark 168 Trustees of Toads Hole Valley and Pecla Investments N/A 169 AEGON UK Property Fund Ltd c/o Kames Capital c/o agent 170 St James Street Community Action Group Jeremy Ogden, Chair 171 Ian Mallin 172 Christopher Harvey 173 WEA John Williams 174 Friends of the Earth Brighton & Hove Chris Todd 175 Becky Reynolds 176 Mrs Maureen Holt, BA (LS) 177 Richard Leggatt 178 Celia Leggatt 179 Gillian Taylor 180 Richard Scott 181 Councillor Geoffrey Theobald 182 J Raphael 183 Dr Philip Denbigh and Mrs Denise Denbigh 184 Dr James Odonnell 185 Member of Parliament for Brighton Kemptown and Peacehaven Simon Kirby MP 186 Mrs Dickins 187 John Divine
35 Appendix 3 Public Notice, press release and media coverage
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39 Brighton & Hove Independent Councillors identify 39 ‘open spaces’ as potential sites for 1,060 homes By Frank le Duc on July 3, 2014 See our map and list of the main sites with potential for housing Brighton and Hove needs up to 24,000 new homes over the next 15 years. Despite repeated efforts, city councilors and their officers have found sites for only 11,300 in the draft City Plan. A government inspector has told the council to leave “no stone unturned” in the search for places where we can build homes for our children. Part of the search should take in dozens of green spaces on the edge of our city, the planning inspector said. Next week, councillors will be asked to approve a list of 39 “urban fringe” sites to submit to the planning inspector in the hope that she will finally pass the City Plan. Councillor Phélim Mac Cafferty, the Green Party councilor and chair of planning, said: “The government is holding our green spaces to ransom. “If they don’t get the sites they want for development, virtually every open space in our city is up for grabs. “This government raid on our green spaces means that if we want any protection or high development standards across the city, we have to accept their demands. “Otherwise the whole of Brighton and Hove will be exposed to the full-blown effects of the government’s National Planning Policy Framework and a virtual free-for-all for developers. “Of course homes are needed – but new developments have to be appropriate. “This is yet another appalling example of the government’s dodgy definition of localism.” He called the government’s policy a “developers’ charter” and urged councillors of all parties to support the proposals being put before the council’s policy and resources committee next Friday (July 11). He said that these at least provided protection for parks and playing fields, cemeteries, ancient monuments, and sites of special scientific interest. Councillor Mac Cafferty said that the 39 sites would not necessarily be turned over to builders and they accounted for just 7% of the urban fringe. He said: “This won’t solve the problem. It’s our way of saying we are looking under every stone.” Even if they were turned into housing, they would provide just 1,060 extra homes out of a shortfall of up to 12,000.
40 The total area being offered up is 31 hectares, or almost 77 acres, compared with the 45 hectares or 111 acres at Toads Hole Valley, one edge-of-town site already allocated for housing. Labour councilors will be discussing the proposals in the next few days. Last night, Warren Morgan, the Labour Group leader, said he had “grave concerns”. He said: “The city finds itself in this situation thanks to the deeply-flawed National Planning Policy Framework brought in by the Tory government at Westminster, which is weighted heavily in favour of developers.”
Brighton & Hove Independent Where do we build (a fraction of) 24,000 homes we need? Your backyard? By Greg Hadfield on July 7, 2014 in News The main sites with potential for up to 1,180 homes. To enlarge, click on the map Brighton and Hove City Council, its officers and consultants, have been required to identify sites on the urban fringe that have potential – in part, at least – for building homes in the medium to long term. Inclusion in the list does not mean that homes will definitely be built on the sites. It means homes could be built on them. Council officers believe the 39 sites have potential for up to 1,180 homes; the sites cover 31 hectares – or just 7.5% of the total area of the urban fringe. Even if all 39 sites were included in the City Plan, it is not known if it will be sufficient to satisfy the independent planning inspector, working within the government’s strict National Planning Policy Framework. Full details can be downloaded from the Brighton and Hove City Council website, including the agenda and reports for the Policy and Resources Committee, which meets at 2pm on Friday, July 11.. 1 Land at Mile Oak Road, Mile Oak Hill, and Mile Oak allotments, Portslade (280 homes) 2 Land at Oakdene, Southwick Hill (25 homes) and land west of Mile Oak Road, Portslade (12 homes) 3 Land at Hangleton Bottom, Portslade (125 homes) 4. Benfield Hill, Benfield Valley (15 homes) and Benfield Valley, north of Hangleton Lane (15 homes) 5 Land at Braypool Lane (two homes) 6 Land at and adjoining Horsdean Recreation Ground, Patcham (30 homes)
41 7 Land at Ladies Mile, Carden Avenue (35 homes) 8 and 9 Land to North East of Coldean Lane (140 homes) 10 and 11 Land south of Hollingbury Golf Course and east of Ditchling Road, including land north of reservoir, Roedale allotments, and Hollingbury Park (20 homes) 12 Land east of Whitehawk Road (50 homes) 13 Land at and adjoining Brighton Racecourse (150 homes) 14 Land at South Downs Riding School and Reservoir Site (25 homes) 15 Land North of Warren Road, Ingleside Stables (30 homes) 16 Land south of Warren Road, adjacent to Nuffield Hospital (10 homes) 17 Roedean Miniature Golf Course and land south of A259 (25 homes) 18 Land at Bulstrode Farm/Ovingdean Farm (50 homes) 19 Land at Wanderdown Road Open Space and land adjacent to Ovingdean and Falmer Road, Ovingdean (50 homes) 20 Land to rear of Longhill Road (six homes) 21 Land to the rear of Bazehill Road, Rottingdean (two homes) 22 Land west of Falmer Avenue (12 homes) 23 Land at former nursery site west of Saltdean Vale, Saltdean (18 homes) 24 Land at Coombe Farm Westfield Avenue, land at Westfield Avenue North, and land at Saltdean Boarding Kennels (55 homes) The Urban Fringe Assessment can be be accessed by clicking on the following link : http://www.brighton-hove.gov.uk/content/planning/local-development- framework/city-plan-part-one-examination
42 http://bhfoe.org/2014/07/07/urbanfringecouncilrisksmaking badpositionworse/
Brighton & Hove Friends of the Earth
Urban fringe – Council risks making bad position worse July 7, 2014 by bhfoe News release issued Monday, 7 July, 2014 Council risks making a bad position worse Urban fringe report being adopted as policy without any public scrutiny Brighton & Hove Friends of the Earth (BHFOE) is calling on Brighton & Hove City Council to put on hold the consultation on the proposed modifications to the City Plan. These are due to be considered at Policy & Resources Committee on Friday [1]. BHFOE believes that going ahead with the proposed modifications is premature. The Urban Fringe Assessment Report has not been subject to any consultation or public scrutiny yet the Council appears to be adopting it as policy [2]. Instead, BHFOE would like to see a public consultation on Urban Fringe Report take place first with modifications to the City Plan coming forward after that. It is particularly concerned about the proposed amendments to the urban fringe Policy SA4 [see note 1]. Chris Todd from BHFOE said: “We understand that the Council is between a rock and a hard place because of Government changes to the planning system [3]. However, the proposed modifications to the City Plan will make a bad situation worse. These changes will give developers the green light to build on any of the sites listed in the urban fringe report, even if the consultants have got their facts wrong. “Whilst we are not saying no development anywhere, we have serious concerns about loss of green space (which is in short supply across the city) and the impact on the National Park with some of these proposals. That’s why we need to have this report properly scrutinised now before any changes are made to the City Plan. “We were also very surprised to see the amount of housing on major development areas fall [4]. This has led to housing being shifted from sustainable locations, where there is good access to services, to the urban fringe where there are not. This needs reversing. “We also need our local MPs and councillors to make strong representations to Government about the unfairness of the current planning system and the problems created by London’s distorted housing market [5].” [1] BHCC’s Policy & Resources Committee meets at 2pm, Friday, 11 July, 2014 in the Council Chamber at Hove Town Hall, to discuss the proposed modifications to the City Plan, which includes amending the amount of housing across the whole city, not
43 just the urban fringe. It is also recommending changing the policy on the urban fringe (SA4) to the following: Development within the urban fringe will be permitted where: a) a site has been allocated for development in a development plan document; or b) a site (or part of a site) has been identified in the 2014 Urban Fringe Assessment Study as having potential for residential development; or c) a countryside location can be justified; and where it can be clearly demonstrated that: d) the proposal has had regard to the downland landscape setting of the city; e) all any adverse impacts of development are minimised and appropriately mitigated and/or compensated for; and f) where appropriate, the proposal helps to achieve the policy objectives set out above. BHFOE wants b) above deleted as it believes it is premature and will prejudice which sites will be developed before there has been any scrutiny of the Urban Fringe Assessment or before they are considered in Part 2 of the City Plan. [2] The Brighton & Hove Urban Fringe Assessment by consultants LUC has been produced without any stakeholder involvement nor has it been subject to public scrutiny to test whether its recommendations are sound. For example, the South Downs National Park Authority was not involved in the production of the report, so none of the claims about possible impacts on the South Downs have been tested or assessed by the body charged with safeguarding their future. [3] The Government changed the planning system making it easier for developers to do what they want if an area does not have an up to date adopted Local Plan. Unfortunately, the time given to local planning authorities to draft, consult and adopt a Local Plan were ridiculously short. See CPRE’s website for an outline of concerns with the new planning system. [4] Housing numbers on major development areas is set to fall from 6,155 units to 6,010,a drop of 145 homes, the main drops being in the New England Quarter and London Road area, Hove Station and Shoreham Harbour. See pages 8/9, Appendix 2, Brighton & Hove City Plan Part One – Proposed Modifications Schedule. [5] See article in Planning Resource. This highlights the housing pressure many local planning authorities are under around London because of the failure to build enough housing in the capital.
44 Brighton & Hove News Brighton and Hove greenfield sites at risk of being lost forever, warns campaigner Posted On 10 Jul 2014 By : Frank le Duc Greenfield sites across Brighton and Hove are at risk of being lost forever, according to Friends of the Earth.
The campaign group urged Brighton and Hove City Council to “pull back from making a serious mistake” when it debates its “urban fringe” policy tomorrow (Friday 11 July).
Brighton and Hove Friends of the Earth said that the proposed changes to the policy “would allow development to take place on any proposed housing site listed in the Urban Fringe Assessment”.
It added: “This is before the proposals have been scrutinised and the sites allocated for development.”
The council’s Policy and Resources Committee is to discuss the proposed changes at Hove Town Hall tomorrow afternoon.
Councillors are being asked to approve the changes as part of a package of amendments to the draft City Plan, a blueprint for land use in the area up to 2030.
They were asked by a government planning inspector to look again at whether greenfield sites around the edge of Brighton and Hove should be kept as open spaces or converted into housing.
The council is under pressure to allocate more land for housing to tackle the shortage which has left 15,500 people on the local waiting list.
Friends of the Earth said that it understood the pressure that the council was under to get the City Plan approved.
It “also recognises that there will be some sites in the urban fringe suitable for development”.
But the environmental group added: “In the haste to proceed, the council could make a terrible mistake.”
Chris Todd, from Brighton and Hove Friends of the Earth, said: “The council’s proposed new policy would allow development to take place on any site listed in the Urban Fringe Assessment as soon as Part 1 of the City Plan is adopted.”
This would, he said, in effect set in stone the right to develop all of these sites before the case for doing so had been scrutinised.
45 Mr Todd added: “The council’s promise that there would be a consultation on allocating the sites at a later date is worthless.
“The council needs to step back from the brink and amend what it is proposing.
“Otherwise it will be making a grave mistake and sites wrongly assessed in the Urban Fringe Assessment could be lost forever.”
A demonstration is expected to take place outside Hove Town Hall at 1.30pm with the meeting, which is open to the public, due to start at 2pm.
46 The Argus Brighton & Hove Environmental warning over city plan 11:04am Thursday 10th July 2014 Environmentalists have warned new house-building proposals risk making a “bad position worse”. Brighton and Hove Friends of the Earth is calling on Brighton and Hove City Council to hold on the consultation on proposed modifications to the City Plan. The proposals announced last week would see 1,180 homes built in 39 open spaces across the city by 2030. The environmental group is concerned about the level of public consultation and scrutiny over changes to the City Plan. Spokesman Chris Todd said the council was between “a rock and a hard place” because of Government changes, but proposed modifications would “make a bad situation worse”. He said: “These changes will give developers the green light to build on any of the sites listed in the urban fringe report, even if the consultants have got their facts wrong. “Whilst we are not saying no development anywhere, we have serious concerns about loss of green space, which is in short supply across the city, and the impact on the National Park with some of these proposals.” Brighton and Hove City Council has been told by an independent inspector to explore further development opportunities within green spaces so the city can accommodate an anticipated demand for housing over the next 16 years. The amended proposals will be discussed at the policy and resources committee meets at 2pm on Friday. © Copyright 2001-2015 Newsquest Media Group http://www.theargus.co.uk
47 Brighton & Hove News Debate about building homes on Brighton and Hove’s green spaces is deferred Posted On 11 Jul 2014 By : Frank le Duc Comments: 6 A debate about building more than a thousand homes on green spaces around Brighton and Hove has been put back to the autumn.
Council leader Jason Kitcat said this afternoon (Friday 11 July) that it had not been possible to reach a consensus across the parties.
Most of the sites listed as having the potential for new housing are in wards represented by opposition Labour and Conservative councillors.
The Greens, including Councillor Kitcat, sit for wards nearer the centre of Brighton and Hove and away from what has become known as the urban fringe.
The news of the delay before the debate can take place was tweeted by the Brighton and Hove Independent on Twitter this afternoon.
The announcement was made at the start of the Policy and Resources Committee of Brighton and Hove City Council.
Councillor Geoffrey Theobald, leader of the Conservative group, said that he would have voted against the proposal to allocate almost 40 sites for housing.
The proposal was drawn up after a government planning inspector told the council to “look under every stone” in the quest for land for new housing.
Her instruction came in response to a shortfall in homes in the draft City Plan. The council expects to need to provide up to 24,000 private and public sector flats and houses by 2030. It has allocated land for 11,300.
Protesters, including Brighton and Hove Friends of the Earth, said that it was a mistake to look at the green open spaces on and near the edge of Brighton and Hove.
They said that more effort should be made to include more homes on brownfield sites nearer shops and services.
One councillor said before the meeting that planners faced a challenge finding sites.
He said that because Brighton and Hove was sandwiched between the Downs and the sea, planners were stuck between a rock and a hard place.
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53 Brighton & Hove News Brighton and Hove’s politicians urged to set aside differences ahead of crunch City Plan vote Posted On 30 Sep 2014 By : Frank le Duc Business, housing and conservation organisations have come together to urge Brighton and Hove’s politicians to set aside their differences over the City Plan.
The City Plan is a blueprint for the next 15 years and is the subject of a crucial debate and vote next month.
Unless the three main parties – the Greens, Conservatives and Labour – can reach agreement, the proposed City Plan could be thrown out by a government inspector.
If that happens, planning officials and politicians fear a free-for-all with developers able to take advantage of the policy vacuum and neighbours being left unprotected from unsuitable building schemes.
Developers would be bound only by national planning rules but not by locally set policies.
The government planning inspector has already examined the City Plan and said that it doesn’t allocate enough land for housing. The council originally allowed for 11,300 homes while the planning inspector believes thousands more are needed.
She urged Brighton and Hove City Council to include greenfield sites on the “urban fringe”.
One such site – Toad’s Hole Valley in Hangleton – is already set aside for housing, business premises and a school.
Now the council has conceded that almost 40 more sites, mostly around the edge of Brighton and Hove, should be considered for housing. They would yield a total of about a thousand more homes.
A number of councillors have said that developers should not be allowed to build on greenfield sites while there are brownfield sites available.
But it is cheaper for property companies to build on greenfield land which all three parties say they are keen to protect.
The parties have agreed on almost everything in the City Plan which is due to be debated at the council’s Policy and Resources Committee on Thursday 16 October.
But the remaining areas of disagreement are causing concern.
54 Among those supporting the call for politicians to agree a sound City Plan are
Environmental groups including the Food Partnership, Brighton and Hove Friends of the Earth, the Campaign to Protect Rural England, the South Downs National Park
Business groups including Wired Sussex and members of the Brighton and Hove Economic Partnership
Conservation groups including the Hove Civic Society, the Brighton Society and the Regency Society
Housing groups including Brighton Housing Trust, Central Sussex YMCA, Starlings Co-operative, Co-operative Housing in Brighton and Hove, the Living Rent Campaign, Brighton’s Future, Home Sweet Home
Community representatives and organisations including the Brighton and Hove Connected (formerly the Local Strategic Partnership), the GMB, Unison and Brighton Women’s Centre
Councillor Phélim Mac Cafferty, who has been leading on the development of the City Plan, said: “Groups across the city have re-emphasised that no plan means unaffordable homes, loss of business space and low-quality developments on precious green spaces.
“We are well and truly in last chance saloon.
“The only way we can rein in unfettered development across the city is through passing a sound local plan that insists on the kind of appropriate change we need in our city.”
The Policy and Resources Committee meeting is widely considered to be the last opportunity to agree a sound plan before it is thrown out altogether.
If it is thrown out, Brighton and Hove would be left with no locally agreed planning controls for the coming years.
For more information about the City Plan, click here.
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69 Appendix 4. Email, Letter, Guidance Notes, FAQ and Representation Form leaflet and poster
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96 Appendix 5 – Summary of Key Issues Raised by Representations
97 Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Brighton & Hove City Plan Part One Proposed Modifications - Summary of Representations February 2015
This schedule provides by way of a summary an overview of the number of representations received on each proposed modification and the key issues raised in the representations.
For full details of each representation please refer to Annexe 1 where the representations have been ordered by proposed modification numbering (and therefore in City Plan policy order).
For copies of the original, individual responses please refer to Annexe 2.
1
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref PM001 Introduction & No Overview, page 4 representations received General updates and editorial PM002 Introduction and No Overview, page 5 representations received. Paragraph 1.4 and Footnote 2
General update and editorial PM003 Introduction and 1 representation Friends of the Earth (174/1) Comment Overview, page 5 received; 1 Technically the South Downs National Park Order came noted. This can support into effect 31 March 2010 (Brighton & Hove Friends of be altered by Paragraph 1.4 the Earth 147/1) way of minor modification. General update/editorial PM004 Introduction and No Overview representations received General update/ editorial - Table 1, page 5 deleted
PM005 Introduction and No 2
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Overview representations received Delete Paragraph 1.6, page 5 General update PM006 Introduction and No Overview representation received Figure 1, page 6 - General update PM007 Introduction and 1 representation Standard Life Investments (SLI) (159/2) Support Overview 1 support Support proposed modification to include reference to welcomed. retail Paragraph 1.7, Page 6 - editorial PM008 Introduction and 2 Duty to Cooperate Duty to Overview representations There is no evidence that Coastal authorities including cooperate was 2 objections BHCC have jointly worked with Northern West Sussex debated at the Footnote 4, Page 7 authorities to assess strategic options. In particular there examination is no evidence that any joint discussions have led or are hearing and is leading to a position in which clear housing needs will continuous and actually be planned and delivered, as required by the ongoing as NPPF. It is difficult to see how the Plan can be found evidenced in the sound in these circumstances. It follows that BHCC has update to the an obligation to work directly with its neighbours to plan Duty to positively and to meet the clear housing (and Cooperate employment) needs at Mayfields if it is satisfied that a Paper published new market town at Mayfields can be considered to be along with the sustainable development within the meaning set out at proposed paragraph 14 of the NPPF (Mayfield Market Towns modifications 3
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref 23/1). [Duty to Questioned whether duty to cooperate has been Cooperate reviewed. (Colin Brace 152/9) Update Paper - October 2014] PM009 A profile of Brighton 1 Support other than the consequence of the Comments & Hove – context representation, implementation of the proposed modification is not noted. The need and challenges, 1 support with considered. There is lack of reference to St James to consider air paragraph 1.24, caveat Street in the Plan; St James Street is within the most quality for those page 13 - updated recent AQMA. Further, proposals for current & future areas of the city air quality implementation of improvements to the physical within the references infrastructure impact upon St James’ Street but this designated impact is ignored and not even commented upon within AQMA but not the City Plan. (S. Parry 16/1) within a designated Development Area is addressed by CP8 Sustainable Buildings; CP9 Sustainable Transport; CP18 Healthy City and strategic objectives SO11 and SO22. PM010 The Strategy, pages 35 Support Proposed Modifications 24, 28, 29 new representations; Hove Civic Society (7/1); Kingsway and West Hove Residents’ paragraph 2.20 – 26 objects 8 Association (31/1); The Brighton Society (119/1); University of modifications supports Brighton (167/1); Standard Life Investments (159/1); Crest 4
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref related to increased Strategic Ltd (144/2) housing target and (South Downs reassessed role of National Park support proposed housing target but believe further the urban fringe in Authority noted serious work will be required to make full use of land response to proposed mods available in the city for new housing within built up areas Inspector’s Initial made) of the city challenging policies on tall buildings, change Conclusions letter. of use of employment land to housing etc if growth of the city into the urban fringe is to be controlled. Given important constraints on the amount of Support development that can be delivered on brownfield sites welcomed including the Development areas, as demonstrated through the City Plan process, the development of undeveloped land on the urban fringe although regrettable is an inevitable necessity given the increase in housing target. In principle support the modified housing target and agree that given constraints in the city meeting the OAN in full is unrealistic without seriously compromising the essential character of the city, its historic buildings and environment, its existing amenities, attraction as a place to live and work and as a centre for tourism. Important that any new proposals for housing in the urban fringe comply with SO14. Supportive of new objectively assessed housing need figure; the sustainable growth of Brighton & Hove is essential to the success of its higher education institutions. Supports the vision to plan positively whilst recognising the unique constraints the city faces. University of Brighton is a key partner in fulfilling the emerging strategic vision for the city which needs fine 5
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref tuning to reflect the University’s future growth and reorganisation plans. Supports the strategy for delivering development on brownfield sites and specifically in development areas. Proposed Modification necessary to make City Plan effective and therefore sound however given need has not been met in full it is essential that the some urban fringe sites are brought forward, land which has been identified as having potential particularly at Mile Oak Road are considered suitable and deliverable during early part of the plan period.
Object to Revised Housing Target set out in Strategy - not gone far enough
La Salle Investment 151/1; X-Leisure Ltd and Land Securities 103/1; Palace Street Developments Ltd (9/2); Ovingdean Estates Ltd 35/2; D Hunter/Hunter Family (75/2); Left Unity Brighton & Hove Branch (140/2) Mayfield Market Towns Ltd The council (23/3, 23/4); Lightwood Strategic (117/5) consider the proposed Not positively prepared – given the increased objectively modifications assessed housing need the city plan has not recognised adequately the need to plan positively; plan has not gone far address the enough to meet the assessed need. Has not gone far Inspector’s enough to address Inspector’s concern to ‘leave no Concerns stone unturned’. The only justifications given of a significant reduction of housing delivery is the city’s green infrastructure and biodiversity and these are not sufficient to warrant the 6
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref City Plan being found legally sound.
Not positively prepared - the City Plan revised housing The 2014 Urban target should be making better use of urban fringe sites Fringe (Land to Rear of Longhill Road Ovingdean; Land to rear Assessment is of Longhill Road); critical of UFS study assessment of considered a housing potential on a number of sites which robust, recommends too low a figure and therefore too low a adequate and contribution to overall housing supply (detailed critique up to date set out in representations); evidence base In assessing/selecting development sites the City Plan from which to has applied a ‘brownfield first’ approach, reflective of assess the now revoked Planning Policy Statement 3. Such an overall approach has evidently restricted the level of additional development the Council is willing to support on residential greenfield sites across the urban fringe capacity from the city’s urban fringe.
Not positively prepared – given the increased objectively assessed housing need, which should be acknowledged Urban capacity, in paragraph 2.12, other sources of housing potential tall buildings need to be more rigorously assessed: the SHLAA, and densities potential for tall buildings; reassess opportunities in were debated development areas; review densities (Inner Harbour during the Site) and capacity in urban areas; hearing and the Rather than directing development onto the urban council has no fringe; large areas of development opportunities exist (4 further new development areas proposed see detailed comments. 7
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref representations and map) in areas of low density/low housing with underused privatised green space The council New strategic sites identified through less restrictive considers the employment land policies and release of employment proposed sites (Sackville Trading Estate and Coal Goods Yard); modifications to CP3 adequately address the Inspector’s concerns.
Not positively prepared/ ineffective and inconsistent with Duty to national policy - Plan does not set out how the housing cooperate is shortfall will be dealt with, insufficient strategic cross- continuous and border discussions with neighbouring authorities in ongoing as Northern West Sussex. Proposed Modification should evidenced in the refer to the need for joint planning initiatives with paper published neighbouring authorities to assess and potentially along with the deliver a new market town to the north of the National proposed Park between Henfield and Sayers Common as a modifications strategic development to meet, in part, the housing [Duty to needs of the City. Cooperate Update Paper - October 2014]
Object to increased housing target and inclusion of urban The council fringe as part of the spatial strategy considers the Proposed Roger & Sue Harper (126/1); Phil Belden (6/1, 6/2); V del Modifications 8
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Federico (146/1); Saltdean Countryside Alliance (142/1); G del adequately Federico (149/1); Sussex Wildlife Trust 137/1; R Everest 85/1; address the G Forrest 83/1; South Downs Society 25/3; M Grout139/1; Inspector’s CPRE Sussex 97/5; The Brighton Society 119/3; Rottingdean concerns. Parish Council (133/1); Friends of the Earth Brighton & Hove 174/2 ;
Not positively prepared - object to identified provision of housing within urban fringe - will impact on National The 2014 Urban Park and will not achieve sustainable development. The Fringe scale of housing proposed within urban fringe adjacent Assessment is to the National Park would cause permanent and considered a irreversible damage; development should be as last robust, resort/ contingency. Plan should afford appropriate adequate and priority to conservation and enhancement of the up to date National Park. evidence base Proposed modifications should include recognition that from which to much of the land within the defined Urban Fringe is also assess the of high landscape sensitivity and forms the setting of the overall National Park and in line with PPG and clarifications additional through ministerial statements particular care should be residential taken over the design of any development proposed capacity from within the urban fringe, so that potential adverse impacts the city’s urban on the quality of the urban fringe landscape and the fringe. setting and purposes of the National Park and adverse impacts on the tranquillity of the National Park through light or noise pollution are avoided/ mitigated as far as possible.
Strategy of sustainable growth put forward in the Plan is Comments 9
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref not justified and flawed. The only sensible option is to noted. The plan and manage or the city within its limit. Proposed Question whether the city’s ‘natural capital’ can support Modifications the level of development now proposed; concerned with address the the emphasis placed on the social dimension of Inspector’s sustainable development. concerns. Proposed Modifications goes against council’s commitments/ priorities – One Planet Living, green spaces as gateways to the Downs; Biosphere designation
Not positively prepared/ justified/effective - object to The 2014 Urban particular sites within urban fringe being identified as Fringe having housing potential: Hollingbury Park, Hollingbury Assessment is Park Nature Reserve, or adjacent wood/ downland considered a spaces, Benfield Valley, Land South of Ovingdean robust, Road, Land West of Falmer Avenue, sites identified adequate and within the Deans villages (Ovingdean, Rottingdean, up to date Woodingdean and Saltdean) due to detrimental impact evidence base on needed/ used open space/ outdoor sporting activities; from which to impact on biodiversity/ natural environment; impact of assess the housing on the local area, quality of life and local overall infrastructure (schools, social and medical services, additional national grid); cumulative traffic impacts and/or residential assessment of urban fringe sites within the 2012 Urban capacity from Fringe Assessment considered flawed (see the city’s urban representations for full and detailed critique). fringe. Concerned with the precedent set by Urban Fringe Assessment which will be exploited by developers to put Proposed forward large scale unsustainable, inappropriate housing modifications to 10
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref developments on the cities outlying natural spaces the supporting diverting attention from brownfield sites text to Policy (Representations include details of concerns with SA4 clarify that current schemes being put forward by developers on further urban fringe sites). consideration and a more detailed assessment of potential sites will be undertaken to inform site allocations made in Part 2 of the City Plan
Brownfield sites should be more fully investigated. There is nothing in the modified City Plan which gives This was incentives to develop brownfield sites over greenfield or debated during how this will be monitored. The development of the hearings brownfield sites should be prioritised wherever possible. and the council Emphasis on brownfield sites offers most sustainable has no further approach, providing homes close to jobs and services. comments. Neighbourhood plans should also be able to prioritise brownfield sites in meeting local housing requirements and targets.
Other South Downs National Park Authority (163/1) S.Parry 16/2; Sussex Wildlife Trust 137/6; Sport England 76/1; North 11
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Laine Community Association 13/1; J Shepherd (147/1); Friends of the Earth Brighton & Hove (174/4) Comments Notes the identification of the urban fringe as a broad noted. A more source of potential for housing development as informed detailed by the Urban Fringe Study June 2014. assessment of Recognised need for sound plan, so a limited proportion potential sites of the urban fringe as potential for housing should be will be accompanied by a thorough assessment of suitability of undertaken to sites including their ecological value being carried out at inform site Part 2 of the City Plan including commitment to a Green allocations Infrastructure Strategy. made in Part 2 of the City Plan
Rationale for increased housing target not given; inadequate evaluation of alternatives. The increased Failure to provide a reasonable solution to the housing target deficiencies the proposed modification sought to responds address degrading the original objectives of the spatial directly to the strategy. Inspector’s The Council have provisionally committed to undertaking concerns. a Playing Pitch Strategy. If this identifies a strategic need for additional pitches then the retention of some of the urban fringe sites for playing fields would need to be considered. The availability of urban fringe sites for housing will need to be reviewed at this point.
Comments Question the sustainability of the City Plan which is noted. The Plan based on housing target to the detriment of any services seeks to 12
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref (garages, shops, trade warehousing) for local residents balance the in the North Laine in particular which will increase development reliance of car. needs of the city. Comment noted Point of clarification in 2.20 - would be more accurate to this can be say that much of the area, including the urban green altered by way network, forms part of the South Downs Way Ahead. of minor modification. PM011 Table 3 Summary of 13 Housing Number for Urban Fringe unsound Development Representations Brighton & Hove Friends of the Earth (174/3); P. Belden (6/3); Proposals, page 31 4 support, 8 Saltdean Countryside Alliance (142/2); R Everest (85/2); G – figures updated objections Forrest (83/2) The 2014 Urban Figure in Table 3 for urban fringe housing potential not Fringe (South Downs justified, unsound and needs amending given the fact Assessment is National Park that some sites proposed as suitable for development considered a Authority – appear to have been forward using inaccurate and robust, 163/2 noted incorrect information in the Urban Fringe Assessment adequate and proposed mods Study. As assessment can’t be relied on, modifications up to date made) must be viewed as unsound (sites referred to: evidence base Hollingbury Park, Craven Vale Allotments; Land West of from which to Falmer Avenue); assess the Summary of development proposals unsound as Urban overall Fringe Assessment superficial as no detailed additional assessment of the cumulative impacts (traffic, demand residential for type of housing proposed, distinct identities of area, capacity from infrastructure; national grid, access to green areas/ the city’s urban SDNP) the proposed urban fringe development would fringe. create in Saltdean and other Deans Housing numbers are not justified as they are not the The increased 13
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref most appropriate strategy – you can’t keep adding housing target growth to city with a finite size. responds directly to the Inspector’s concerns.
Housing number unsound – too low Hunter Family (75/3); Ovingdean Estates Ltd (35/3); La Salle The 2014 Urban Investment Management (151/2) Fringe Assessment is Urban Fringe Assessment does not provide a robust considered a enough analysis of sites to ensure that the ability of the robust, urban fringe to help with housing supply has been adequate and maximised; has not taken full account of potential so up to date recommends too low a figure/ contribution to overall evidence base housing supply. Figure in Table 3 needs amending to from which to provide a far higher target for new homes to assess the accommodate the additional number of dwellings that overall can be provided on clients site (Land to Rear of Longhill additional Road, Ovingdean; Hunter site – see original residential representations for further details); capacity from the city’s urban fringe
The council should have undertaken a review of specific As set out in the development areas to determine whether a revised matter statement approach to the planning of these areas could result in (BHCC-11 14
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref the provision of more housing. As part of this approach Matter Statement council should have critically review approach to 5) the Council retention/re-provision of B class employment space considers that to within these areas to assess opportunities for the CP3 together Provision of more housing (submitted masterplan with the indicates the potential for 300 homes on Former Goods proposed Yard site near Hove Station if were developed for a modifications residential focussed mixed-use scheme). provide an appropriately flexible and
responsive policy
framework related to an objectively assessed need for B Use Class employment floorspace over the plan period to ensure that the City’s economy and future potential is not constrained by a lack of employment sites.
Support Modifications Standard Life Investments (159/3), Kingsway and West Hove Residents’ Associations (31/2); Crest Strategic Ltd (144/1); 15
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref University of Sussex (116/1) Support welcomed. Notes the identification of the urban fringe as a broad source of potential for housing development as informed by the Urban Fringe Study June 2014. Supports the reference to minimum retail floorspace for comparison goods. Modifications to summary of development proposals sound. Given important constraints on the amount of development that can be delivered on brownfield sites including the Development areas, as demonstrated through the City Plan process, the development of undeveloped land on the urban fringe although regrettable is an inevitable necessity given the increase in housing target. Proposed Modification necessary to make City Plan effective and therefore sound however given need has not been met in full it is essential that the some urban fringe sites are brought forward, land which has been identified as having potential particularly at Mile Oak Road are considered suitable and deliverable during early part of the plan period. PM012 DA1 Brighton 2 Standard Life Investments (SLI) (159/4); North Laine The proposed Centre & Churchill representations, Community Association (13/3) modifications Square Area, page 2 objections As the City Council is now actively exploring options for adequately 34 an off-site replacement conference venue, Policy DA1 allow for the should be amended to include reference to the provision option of off-site Amendment to of a conference centre either on or off site. provision. introductory paragraph to the The wording in 16
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref policy Object to any terminology which includes the word DA1.A.2; CP12 landmark, indicates a building that would impinge on the and CP13 seafront views from the front and rear. provides sufficient safeguards. PM013 DA1 Brighton 1 Standard Life Investments (SLI) (159/5) Support Centre & Churchill representation; Support the inclusion of ’net’ which provides clarification welcomed. Square Area, page 1 support in the policy regarding new retail comparison floorspace. 34
Clarification of net retail floorspace PM014 DA1 Brighton 5 Sustainable Transport Improvements Centre and Churchill representation Standard Life Investments (SLI) (159/6); Friends of the Earth Square Area, page s; 2 support, 3 Brighton & Hove (174/4) 34 object The Object to requirement in proposed modifications to modifications Modifications to Policy DA1 A.5 and A.6, to improve the bus interchange responded to policy wording to facilities at Churchill Square as well as improve discussions at address air quality pedestrian and cycle access through and around the the examination issues area, extending along Queens Road to the Brighton hearing [See Station. To deliver such extensive and wide ranging also Statement infrastructure provisions is excessive, and is likely of Common render any development of DA1 unviable and/or Ground SCOG- undeliverable. It also goes beyond the reasonable 015 Friends of requirements of a development of the DA1 area. the Earth B&H]. Support modifications to A5. The bus network serving Amendments to the city centre is of economic importance priorities A5-A7 are not Air Quality considered 17
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Standard Life Investments (SLI) (159/7); Friends of the Earth excessive and Brighton & Hove (174/5); S Parry (16/3) will guide the council as Object to the proposed references in A.7 to the need to Highways ensure improvements to local air quality in the Western Authority, Road, Churchill Square and North Street transport transport corridor and along Queens Road and West Street. This providers and is a large area, outside the control of any developer of freight transport the DA1 development area and it is not practical for any operators in the development of the DA1 development area to “ensure area as well as improvements to local air quality” over the whole of this developers to area. improve traffic movement and air quality.
Question whether the wording on air quality needs to be Support tightened in light of the recent Court of Justice of the welcome and European Union ruling that there is an obligation to comments address legal limits as soon as possible. noted. It is understood that the UK Supreme Court is expected to make a final ruling in 2015. Air quality improvements is a priority in this area and updated Air 18
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Quality Action Plans or national planning guidance will be material considerations.
The Air Quality Action Plan includes St James’ Street The need to yet no consideration is given to this area. consider air quality for those areas of the city within the designated AQMA but not within a designated Development Area is addressed by CP8 Sustainable Buildings; CP9 Sustainable Transport; CP18 Healthy City and strategic objectives SO11 and SO22. PM015 DA1 Brighton 3 Standard Life Investments (SLI) (159/8) (159/9); Brighton & The proposed 19
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Centre & Churchill representations; Hove Hoteliers (21/2) modifications Square Area, page 1 support; 3 Support modifications but maintains previous position adequately 35 objections that Policy DA1 should be amended to include reference allow for the to the provision of a conference centre either on or off option of off-site Clarification of net site. provision. floorspace, editorial. Footnote 38 deleted Support the proposed clarification of “net” floorspace Support and the proposed deletion of footnote 38. welcomed. The 5th bullet point of para.3.2 should be deleted or The Council qualified on the basis that the Brighton Centre SPD01 is consider this now outdated and not relevant. document is still relevant as a design framework but recognises that this may be Question whether Brighton & Hove can take additional updated. hotel rooms. Comment noted. PM016 DA1 Brighton 1 Standard Life Investments (SLI) (159/10) Centre & Churchill representation; Support the removal of paragraph 3.4 which provides Support Square Area, page 1 support further options for the provision of replacement welcomed. 36 conference facilities.
General update - deletion of sentence in 3.4 PM017 DA1 Brighton 4 Object Centre and Churchill representation; Standard Life Investments (SLI) (159/7, 159/11); S. Parry Square Area, 3 objections; 1 (16/4) 20
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref paragraph 3.5, page support Unlike PM014, PM017 does not include a specific Welcome 36-37 requirement for development of the DA1 development support. area to ensure improvements to local air quality in the Modifications to Western Road, Churchill Square and North Street policy wording to transport corridor and along Queens Road and West address air quality Street. Instead paragraph 3.7 sets out the requirements issues to consider impact on local air quality as part of any development proposal. The proposed modified wording to paragraph 3.7 is thus supported and Policy DA1 The should be amended to be consistent with paragraph 3.7, modifications and Policy SA2, as proposed to be modified. responded to The specific references in the modifications to such discussions at extensive and wide ranging infrastructure provision bus the examination interchange at Churchill Square and the need to hearings and improve the junctions including at the Clock Tower are not (Western Road, North Street and Queens Road) is considered excessive and goes beyond the reasonable excessive. requirements of a development of the DA1 area. Whilst agreeing with the proposal no consideration has Refer to been given to St James Street in relation to measures response to that will be developed to encourage sustainable lower PM014. emission urban freight distribution/ impact of new development on local air quality.
Support Friends of the Earth Brighton & Hove (174/6) Support Support but again question whether the air quality welcomed and modifications are strong enough given recent Court of comments Justice of the EU ruling. noted. Refer to response 21
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref PM014 PM018 DA2 Brighton 4representation Standard Life Investments (SLI) (159/13); National Grid Marina, Gas Works s; 2 support, 2 Holdings (NGP) and Scotia Gas Networks (SGN) (166/1) and Black Rock objections Area Support the proposed removal of the District Centre Support noted. page 38, 39 status from the Marina.
Removal of Other reference to District P.Belden (6/4); South Downs Society (25/2); The council Centre in Reinstate wording ‘Do not breach the cliff height within consider the supporting text and the Marina’. proposed policy and from modifications illustrative adequately diagram/policies address the map Inspector’s concerns.
The Black Rock area has been absorbed into the Comments grander marina development plans, which has noted. The effectively hidden or disguised this area from public proposed scrutiny and involvement. Delete the Black Rock area modifications and start again, with specific proposals and genuine sought to clarify consultation on this area. the wording of the policy. PM019 DA2 Brighton 9 Marina, Gas Works representations; Reinstate breach cliff height clause and Black Rock 9 objections The Brighton Society (119/4); Roedean Residents Association Area (58/2); North Laine Community Association (13/2); South page 39, page 44 Downs Society (25/3)
22
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Proposed Clause relating to buildings not breaching the cliff height The council modifications within the Marina should be reinstated. Any future consider the related to removal of buildings in the Marina, Gas Works Site and Black Rock proposed restriction of cliff areas should be limited in height so as not to modifications height. Add new substantially affect views of the cliffs from the sea and adequately paragraph in views from the National Park looking south. To breach address the supporting text after an Act of Parliament cannot be consistent with national Inspector’s 3.15 policy. Original wording would deter any development concerns. which would visually impair the view from the Kingscliffe Conservation Area. The present clause is a feeble reference taking into consideration the adjoining Grade 1 estate and CAs, and should be much stronger. A presumption of refusal for further tall buildings could be restricted to the Marina area. Whilst welcome the new paragraph in the supporting text after 3.15 and in particular that proposed developments should preserve and enhance views to and from the National Park clause should be reinstated.
Support removal of clause but object to wording proposed
Hove Civic Society (7/2); X-Leisure Ltd and Land Securities (103/02, 103/03); Standard Life Investments (SLI) (159/1)
Support removal of clause but do not believe that there The council should be any reference to potential cliff height consider the restrictions for the Marina development area. Proposed proposed modification is more flexible however not positively modifications prepared and contrary to Inspector’s initial conclusions; adequately 23
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref merely re-introduces the cliff height restriction within address the Policy DA2 in a different form. Issues covered in other Inspector’s policies – CP8, CP12 and CP14, Draft Policies CP8 concerns.
Other Dr G R Parish (5/1); Comment noted Proposed new para 3:15 should also reference that the reference in proposed developments should ensure the generation of the overarching a high quality marina environment - paramount for this strategy is unique location considered sufficient reference. PM020 DA2 Brighton 2 Brighton & Hove Friends of the Earth (174/7) Marina, Gas Works representations; Watering down of policy unjustified and unsound given Comment noted and Black Rock 1 support, 1 the city’s failure to meet its carbon reduction targets (ref – the proposed Area objection City Performance Plan Update, Promoting Resource changes page 39, Efficiency and Enhancing the Environment). introduce more modification of flexibility to priority related to X-Leisure Ltd and Land Securities (103/4) ensure heat and power support the proposed amendment development is opportunities deliverable.
PM021 DA2 Brighton 5 National Grid Holdings (NGP) and Scotia Gas Networks (SGN) Marina, Gas Works representations; (166/2); Brunswick Development Group Plc (161/2); X-Leisure and Black Rock Ltd and Land Securities (103/5); Standard Life Investments Area (SLI) (159/14) page 39, 40 District Centre Status Removal proposed Support removal of Marina as a District Centre modifications Disappointed that the Inspector recommended the The council 24
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref relating to removal removal of Brighton Marina’s District Centre status but consider the of district centre understand the reasons for this. The removal of District proposed status Centre status only serves to reinforce the failing nature modifications of the Marina as a commercial district and the urgent adequately need for investment and regeneration. Support the address the modifications proposed which clarify the tests to be Inspector’s applied to new retail and retail related development in concerns. the DA2 development area
Other
Brunswick Development Group Plc (161/2); Dr G R Parish (5/2) The strategy Marina inner Harbour area should be extended to and the local include all of the Brighton Marina Site. The entire site priorities set out should be included within the designated area to take in DA2 cover all account of the consented (and implemented) of the Brighton development. Marina area and The Marina is a unique environment which needs this is developing as 'a high quality marina environment - until considered to detailed development schemes are brought forward and provide a tested against their ability to generate a high quality sufficient marina environment and the requirements of A.6 and framework for paragraph 3:15, the 1000 additional units is an assessing aspiration. A good quality development of, say, 950 development units which meets the other design needs should not fail proposals. because it does not achieve the 1000 additional, and vice versa.
PM022 DA2 Brighton 1 X-Leisure Ltd and Land Securities (103/6) Marina, Gas Works representation; Welcome modification as brownfield sites often face 25
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref and Black Rock 1 support high up-front costs to resolve ownership issues, clear Support noted. Area, sites and where necessary treat contamination. page 40 - inclusion of reference to delivery and viability considerations in A.12 PM023 DA2 Brighton 7 Amounts of Development Marina, Gas Works representations X-leisure Ltd and Land Securities (103/7; 103/8) ; National Grid and Black Rock Holdings (NGP) and Scotia Gas Networks (SGN) (166/2) Area, Part B – with consistency with CP1, amounts of page 41, 42, 43 development should be expressed as minimums At DA2.c.1 1,000 should be considered a minimum. A The wording of update and minimum of 1,300 dwellings can be delivered on the the policy would clarification of Inner Harbour site whilst also bringing forward the not prohibit residential units, allocated retail, leisure and employment space. Indeed further capacity and net retail at part this quantum of development may be necessary to to come B., clarification of secure a viable development. This should be addressed forward. business floorspace in amendments. A higher housing allocation at the Inner at C.2 Harbour site would help the Council to come closer to its editorial and objective assessment of housing need and reduce removal of reliance on windfall sites and would maximise the reference to District development opportunity of this relatively central Centre brownfield site and make the city less vulnerable to large housing applications on unallocated Greenfield sites. The council is Whilst it is recognised that part B. refers to minimum 85 aware that the residential units, recent marketing of the Gas Works owners of the sites show that it is possible to provide substantially site have more on the site. recently 26
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref marketed their site and welcome commitment to redevelop key brownfield site. Policy as worded would not prohibit further capacity to come Net retail forward. X-leisure Ltd and Land Securities (103/9); Standard Life Investments (SLI) (159/15); Brunswick Development Group plc (161/3) Welcome and support the insertion of ‘net’ retail Support. floorspace and in relation to Section C.1 of Policy DA2, Comment Re: which relates to the Inner Harbour the leisure and ‘net’ retail recreation element should also read “net additional”. floorspace is The 5,000 sq m net A1-A5 floorspace should not be a noted. Part B of cap and proposals for any additional space should be the policy states judged against other relevant wider policies. that this is ‘net Do not support proposed modification of ‘net’ retail, additional concerned that major retail development at the Marina floorspace’ would compete with city centre offer. Other Standard Life Investments (SLI) (159/16) Support noted. Support the council in exploring options for the Black The council is Rock site, for a major venue/conference centre. currently Supports modifications to A.3 and C.3 in relation to the exploring 27
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Black Rock site but considers that C.3 can be further feasibility work amended to remove reference to 7,000 sq m to assist in in partnership the delivery of a new state of the art venue/ conference with SLI to allow centre. the redevelopment of the Brighton Centre and Churchill Square area and the Black Rock Site. Feasibility is at an early concept stage. The wording of the policy would not prohibit further capacity if this were identified. PM024 DA2 Brighton No Marina, Gas Works representation and Black Rock received. Area page 41
update of footnote 47 PM025 DA3 Lewes Road 4 No objection University of Sussex (116/5) Support Area, page 48, 49, representations; welcomed. 52, 53 1 support; 1 Air Quality 28
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref support with Support but with question over whether wording on air Support Modifications caveat, 2 quality needs to be tightened following recent EU ruling. welcomed and relating to air quality objections Friends of the Earth (174/8) comment noted. issues. See response to PM014
In order to “ensure new development proposals take into Comment account impact on local air quality and that noted. See improvements and/ or mitigation are sought wherever response to possible” consideration must be given to St James’ PM014. Street. Steve Parry (16/5)
Disappointed that comments made during the Comment consultation on the City Plan Part 1 with regard to the noted. Does not Amex Stadium have not been taken into account South relate to a Downs Society (25/4) specific proposed modification PM026 DA3 Lewes Road 3 University of Sussex (116/3; 116/10); Area, page 49 representations The wording of Part B of the policy underestimates the overall scale of the policy would Updated residential growth identified elsewhere within Policy DA3 as well as not prohibit units figure at Part B other policies in the Plan (for example Policy CP21). We further capacity therefore continue to seek confirmation within Part B of to come forward the Policy that the figures for additional academic if this floorspace and student accommodation be identified as appropriately minimum figures as set out in its earlier representations. addressed other The University does not object to the proposed increase planning in housing provision identified for the DA3 Development considerations Area. set out in 29
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Development Areas/ City Plan.
South Downs Society (25/12) Disappointed that comments made during the Comment consultation on the City Plan Part 1 with regard to the noted. Does not Amex Stadium have not been taken into account South relate to a Downs Society specific modification PM027 DA3 Lewes Road 2 University of Brighton (167/1) Does not relate Area, page 49, 50 representations Question whether the requirement for “no net loss of car to a specific parking” remains relevant and appropriate. modification. Modifications to include reference to University of Brighton envisages 1,300 new student The wording of adopted Planning beds at Moulsecoomb, however the policy only allocates the policy would Brief for area and 750. not prohibit removal of zero further capacity carbon to come forward requirements. if this appropriately addressed other planning considerations set out in Development Areas/ City Plan.
Positive approach to new development at Falmer and Noted. 30
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Varley Park encouraged
South Downs Society (25/13) Comment Disappointed that comments made during the noted. Does not consultation on the City Plan Part 1 with regard to the relate to a Amex Stadium have not been taken into account. specific modification PM028 DA3 Lewes Road 2 representation Sussex Wildlife Trust (137/2); South Downs Society (25/14) Area, page 50 (objects) This proposed Object to the removal of the aim to achieve an modification Editorial clarification outstanding BREEAM rating as part of this development. introduces more of business space This weakens the policy and is contrary to BHCC’s long flexibility to and removal of term aims and the NPPF. ensure reference to development is outstanding deliverable. BREAAM rating – additional footnote Disappointed that comments made during the Comment consultation on the City Plan Part 1 with regard to the noted. Does not Amex Stadium have not been taken into account relate to a specific modification PM029 DA3 Lewes Road 1 representation South Downs Society (25/15) Does not relate Area, page 51 (object) Disappointed that comments made during the to a specific consultation on the City Plan Part 1 with regard to the modification New criterion Amex Stadium have not been taken into account related to groundwater source protection PM030 DA3 Lewes Road 2 University of Sussex (116/6) Area, page 51 representation; Support continued reference to the provision of purpose Support 31
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref 1 support; 1 built student accommodation as a suitable use for welcomed Editorial, removal of object Falmer Released Land. zero carbon requirement and South Downs Society (25/16) Comment new criterion related Disappointed that comments made during the noted. Does not to groundwater consultation on the City Plan Part 1 with regard to the relate to a source protection Amex Stadium have not been taken into account specific modification
PM031 DA3 Lewes Road 1 representation South Downs Society (25/17) Does not relate Area, page 54 (object) Disappointed that comments made during the to a specific consultation on the City Plan Part 1 with regard to the modification Update supporting Amex Stadium have not been taken into account text – adopted brief. PM032 DA3 Lewes Road 1 representation South Downs Society (25/18) Comment Area, page 54 (object) Disappointed that comments made during the noted. Does not consultation on the City Plan Part 1 with regard to the relate to a Editorial and Amex Stadium have not been taken into account specific reference in modification paragraph 3.37 to role of site in meeting city infrastructure. PM033 DA4 New England 1 representation Brighton & Hove Friends of the Earth (174/17) Quarter and London received, 1 Road Area, page support with Support modification with caveat as to whether the Support 57, 63 caveat wording on air quality needs to be tightened in light of welcomed and the recent Court of Justice of the European Union ruling comments Modifications to that there is an obligation to address legal limits as soon noted. See 32
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref reference noise and as possible and in light of (representation cites a response to air quality issues in number of articles and research on this issue). PM014. part 6 and paragraph 3.52 PM034 DA4 New England No Quarter and London representations Road, page 58 received
Update residential units figure at B. PM035 DA4 New England No Quarter and London representations Road Area, Page 58 received
Editorial DA4.C.ii PM036 DA5 Eastern Road No and Edward Street representations Area, page 65 received Modification of part 8 of policy related to water/sewage connections PM037 DA5 Eastern Road 1 University of Brighton (165/3) and Edward Street representation; Opportunity to amend policy to better reflect aspirations Comment Area, page 65 and 1 objection of University of Brighton to deliver new academic noted. Not page 70 facilities at its ‘City Campus’ to enhance its offer and related to improve student experience in particular for creative proposed Add to paragraph sectors. There should be clear policy support – see modification. 3.60 and paragraph proposed amendments - for additional academic 11 to Part A of floorspace through the intensification of Grand Parade 33
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref policy in relation to Buildings. additional teaching and library space in area. PM038 DA5 Eastern Road No and Edward Street representations Area, page 66 received
Updated residential figures in part B. PM039 DA5 Eastern Road No and Edward Street representations Area, page 66 received
Editorial clarification at part 1. PM040 DA5 Eastern Road 2 Original Amex building should be retained rather than Comment and Edward Street representations, demolished. The Brighton Society (119/5) noted. This Area, page 66 2 objections does not relate to a specific Clarification of C2 - modification minimum residential St James’ Street is one of only 4 District Centres. The figure. absence of any consideration of this area ignores key Comment recommendations of the Retail Study Update 2011 noted. This (CBRE) and Government policy. (S Parry 16/6) does not relate to a specific modification. PM041 DA5 Eastern Road No and Edward Street representations Area, page 68 and received 34
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref 71
Clarification of redevelopment opportunities for allocation C.4 and in supporting text at 3.65 PM042 DA5 Eastern Road No and Edward Street, representations page 69 received
Modifications related to air quality issues. PM043 DA6 Hove Station 1 Object to Proposed Modification As set out in the Area, page 74 representation: La Salle Investment Management (151/3); matter 1 objection statement Update residential Not positively prepared; justified or effective – modification (BHCC-11 figures at DA6.B falls significantly short of addressing the assessed needs Matter (particularly housing need). Other sources of housing Statement 5) potential need to be more rigorously assessed. Similar to the Council Urban Fringe Assessment, instead of protecting viable B considers that Class uses should be about what benefits redevelopment the proposed for other uses can bring versus harm caused by loss of B modifications to uses. City Plan should therefore: reassess opportunities for CP3 increasing housing in development areas; and, review Employment approach to retention/re-provision of B Class employment Land and the space within development areas to assess opportunities for approach taken housing (Sackville Trading Estate and Coal Goods Yard in in DA6 provide 35
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref DA6). an appropriately DA6 should be modified so it is focussed on regeneration flexible and for the provision of new homes and provision of non B-Class responsive employment generating uses as well as B Class uses and it policy should seek to provide significantly more than the proposed framework 525 residential units. Whilst identification of Hove Station related to an Area and aims of regeneration supported, we object to the objectively inflexibility of policy (re employment which focuses assessed need on/restricts to B Class uses) and lack of regard to planning for B Use Class permission/principles established for Sackville Place. Policy employment should be amended to actively support redevelopment of floorspace over Sackville Trading Estate and Coal Goods Yard giving the plan period recognition to the opportunity to provide over 300 residential to ensure that units and new retail floorspace (in accord with extant the City’s consent) via a residential focussed mixed-use scheme. economy and Coal Goods Yard is not ‘safeguarded’ for waste future potential management needs it is only identified as a potentially is not suitable location within the emerging Waste Plan. constrained by a Paragraph 3.79 should be deleted and City Plan should lack of recognise redevelopment potential of the Goods Yard site. employment sites.
The Coal Goods Yard is allocated for waste management uses in the adopted East Sussex and 36
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Brighton & Hove Waste Local Plan 2006. Whilst there is an emerging Waste & Minerals Sites Plan which reviews current allocations it is not an adopted plan (Consultation Draft consulted upon between July – September 2014. Consultation on the Proposed Submission plan anticipated Summer 2015). PM044 DA6 Hove Station 2 Support for Proposed Modification Area, page 76 representations: Friends of the Earth Brighton and Hove (174/10) Support with 1 support with Support modification with caveat as to whether the wording caveat Modifications at caveat; 1 on air quality needs to be tightened in light of the recent acknowledged paragraph 3.70 objection, Court of Justice of the European Union ruling that there is related to air quality an obligation to address legal limits as soon as possible issues and in light of (representation cites a number of articles and 37
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref research on this issue).
Object to Proposed Modification La Salle Investment Management (151/4); Whilst indicates objection to PM044 the comments do not relate to air quality. They relate to an indicated need for The objection further modifications to DA6 to actively support the does not relate redevelopment of Sackville Trading Estate and Coal to this specific Goods Yard to provide a residential focussed mixed-use modification. scheme (see objection to PM043). PM045 DA7 Toad’s Hole 47 Save Toad’s Hole Valley (Hazel McKay), (72/1), David Jewel The concerns Valley, pages 79-86 representations (40/1), Mark Stephens (45/1), John Dann (61/1), Nigel Swift raised are 46 objections; (59/1), Peter Ames (54/1), Marina Patrignani (53/1), Geoffrey noted. It is Changes to policy to 1 caveated Russell(51/1), Kim Sinclair (50/1), Mervyn Eason (49/1), Carl considered that address objections support Hodler (48/1), Mike Ray (1/1), Simon Rickman (46/1), Clive the proposed (see Statement of Gale-Smith (64/1), Stephen Wells (44/1), Keith and Georgette modifications Common Ground Bassant (43/1), Gilly Wise (42/1), Edwin Sears (41/1), Jane within PM045 SOCG-10 and in Pidgeon (39/1), Avis Carter (38/1), David Ballard (36/1), Karen are minor and response to Tiltman (47/1), Mrs Dickens (186/1), Diana Praud (62/1), Mr will not unduly viability/deliverability and Mrs Kinsey (132/1), David Gerrard (63/1), Ivor O’Mahony undermine the issues. (110/1), Dawn Robson (105/1), R Hatley (99/1), Neil Evans delivery of the (88/1), David and Julie Wagg (78/1), Lucia Brida (74/1), Brian aims of the Thomson (73/1), Karin Dahmen (71/1), Mrs Maureen Holt policy. It is (176/1): considered the policy is now Amendments in PM45 represent a watering down of the more compliant aims of the policy. This represents a dilution of the with policy in the sustainability and the quality of the development. National Amendments are not in the public interest and only benefit Planning Policy the landowner Framework; it 38
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref The dilution of policy is disingenuous to residents in term of removes the type and quality of development originally sought on the repetition (in site. Expectations were raised – the public has been misled. relation to The development is no longer required to be an exemplar of matters sustainability – a concern in this sensitive green space addressed in adjacent to the National Park other policies); Concern that the amendment will lead to non-delivery of and introduces mixed use development more flexibility Undermines the commitment to provide a range of to ensure infrastructure that should be provided with the development development is No longer a commitment to re-routing King George VI deliverable. Avenue Reserves a site for a school rather than requiring the delivery of a school and completion by 2030 Employment requirement reduced from floorspace to a reserved site with dilution of phasing (not required to be completed by 2030)
Concern about relaxation in timing of delivery of community
benefits with dilution of phasing of the school and
employment development.
Reduction surface water run off outcomes from
‘improvements’ to ‘no worsening.
Concern about making important feature of the new development subject to viability and deliverability Removal of requirement for district heating infrastructure has misled the public. Community benefits reduced obligation as part of the modifications, e.g. road safety, jobs, green infrastructure, jobs, public open space, natural green space 39
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Reduced commitment to delivering links to National Park from provision to contributions towards links. Fails to identify a site for a GPs Surgery – there is a need in the area There has been a consultation deficit (lack of consultation) on the proposed modifications
Save Toad’s Hole Valley (Hazel McKay)(72/1), Mrs Maureen Holt (176/1), Gilly Wise (42/1), Marina Patrignani (53/1), These represent Geraldine O’Brien (56/1), Elisabeth and Peter Scarff (11/1), an objection to Mrs Corrado and R Gokkaya (128/1) policy DA7. This was debated Continued objection to policy DA7. during the Proposal will lead to transport harm by reason of the hearing amount of development proposed – there is congestion and sessions and pollution already. the council has There is insufficient infrastructure in the area. The proposal no further fails to address the need for additional primary school comments. places and GPs Surgery. Problems with drainage in area.
One objection to re-routing King George VI Avenue
Sussex Wildlife Trust (137/5) Comment noted The policy is weakened by the modification – change made Object to replacement of ‘reduction’ in water run-off to ‘no to ensure increase’. deliverability
South Downs Society (25/5), CPRE (97/4) Comment noted Revised wording waters down commitments – e.g. – the change 40
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref changing wording from ‘provision’ to ‘aim’ in part 2-4 of Part introduces more A of the policy. flexibility to Removal of ‘minimum’ in terms of open space provision ensure Reinstate the requirement to provide links to the National development is Park. deliverable.
North Laine Community Association (13/4), Hove Civic Society Comments (7/3) noted – the Object to removal of policies that make the development change unsustainable in terms of carbon use and natural removes environment policies. repetition in Object to removal of reference to energy infrastructure at relation to THV – retain last bullet point in section B of policy. matters addressed in other policies.
The National Trust (122/4) Comments The National Trust owns a lot of land in the National Park noted – it is and is concerned about the impact the modifications on considered the Trust land and property. changes Concern about weakening requirement for improved links to proposed allow the National Park – contrary to paragraph 14 of the NPPF. for flexibility, Policy does not plan positively for biodiversity or green deliverability infrastructure and mitigation. Request to be Require proper modification of impacts involved in NT wants to be involved in a Brief for the site Planning Brief Modifications should be made to allow appropriate welcomed. mitigation and ensure a good design approach inclusion of 41
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref appropriate green space and links to National Park.
Brighton & Hove Friends of the Earth (174/11) Prefer a higher minimum housing provision given the Comments severe shortfall in housing in the city and the need to make noted – these an efficient use of sites. matters were Higher density of housing is needed to provide more debated during housing and sustain new public transport provision. the hearing Proposal for informal Park & Ride (in paragraph 3.9) is not sessions and justified the council has Phasing – need bus service in place from day one to no further encourage public transport behaviours comments.
Trustees of Toad’s Hole Valley and Pecla Investments (168/3) It is considered Objection to reference to policy CP8 Sustainable Building in the wording of the policy whilst it remains unsound. The majority of the the policy is objection relates to CP8 and reference to the Code for sound subject to Sustainable Homes. Therefore the policy is unsound. the Planning Inspector’s conclusions on policy CP8.
Sport England (76/2) Caveated support subject to minor amendments to ensure This sufficient flexibility to take into account the findings of any representation forthcoming Playing Pitch Strategy. does not relate to a modification. PM046 DA8 Shoreham 1 Harbour, page 87& representation; Adur District Council (143/2) Support 42
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref 233 1 support Acknowledges work on Shoreham Harbour with City welcomed Council and supports modification as proposed. Amend policies map, key diagram and key illustration to remove boundary road/ station road from area. PM047 DA8 Shoreham 2 Hove Civic Society (7/4); Sussex Wildlife Trust (137/6) Harbour, paragraph representations; Support 3.103, page 88 2 support Support the proposed modifications welcomed
Additional bullet point related to large-scale zero and low-carbon energy technologies. PM048 DA8 Shoreham 1 West Sussex County Council (55/1) Harbour page 88 representation; 1 objection DA8 should make reference to the preparation of the This can be Modification to Shoreham Harbour transport Study. Suggest best fit is after addressed by policy to include PM48 way of minor reference to With regard to air quality note that there is no specific modification. provision of reference to the Sussex Mitigation Guidance 2013, which infrastructure you may wish to add. PM049 DA8 Shoreham Kingsway and West Hove Residents Association (KAWHRA) Support Harbour, page 88 2 (31/3) welcomed representations; Support reduction in housing units Updated residential 1 support,1 Comments figures in part A. object The Brighton Society (119/) noted – Change 43
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Concern as to why capacity reduced from 400 to 300 made following units detailed work on development brief/draft JAAP. PM050 DA8 No Shoreham Harbour, representations page 89 received modification of title of area i)
PM051 DA8 Support Shoreham Harbour. 3 KAWHRA (31/4); Friend of the Earth Brighton & Hove (174/2) page 89/90 policy representations Support changes to ii) received Support modifications welcomed Aldrington Basin to question whether the wording on air quality needs to be clarify employment/ 1 support tightened in light of the recent Court of Justice of the Support mixed use area; 1 qualified European Union ruling that there is an obligation to welcomed and townscape, air support address legal limits as soon as possible and in light of comments quality and flood risk 1 objection (representation cites a number of articles and research noted. See issues. on this issue). response to Object PM014 The Brighton Society (119/7) Shoreham Harbour Joint Area Action Plan should This issue is strengthen the link between Hove Lagoon and more Aldrington Basin visually and physically. City Plan appropriately should provide more vision for the area. dealt with in the JAAP PM052 DA8 No Shoreham Harbour, representations page 90, changes to received 44
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref iii) North Quayside/ South Portslade to clarify townscape, air quality and flood risk issues. Editorial.
PM053 DA8 Shoreham No Harbour, page 91, representations update paragraph received 3.105 and footnote 84 PM054 DA8 Shoreham No Harbour, pages 91- representations 92, 3.109 received
Editorial/ updates related to Waste and Minerals plan. PM055 DA8 Shoreham No Harbour, page 92, representations 3.110 received Editorial PM056 SA1 The Seafront, No page 96 representations received Clarification at SA1.c.1 minimum residential figure PM057 SA1 The Seafront, No page 97 representations 45
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Update footnote 89 received PM058 SA1 The Seafront, No page 99, 3.122 representations received Air quality update
PM059 SA1 The Seafront, No page 99, 3.123 representations received Update – include reference to Marine Management Organisation PM060 SA1 The Seafront, No Paragraph 3.124, representations page 99 received Update PM061 SA2 Central 3 Standard Life Investments (159/17); Friends of the Earth Support Brighton, page 103 representations Brighton & Hove (174/13); S. Parry (16/9) ; 2 support (1 Support Air quality with caveat) Support this modification with caveat as to whether the Support Modifications to part wording on air quality needs to be tightened in light of welcomed and 7 the recent Court of Justice of the European Union ruling comments that there is an obligation to address legal limits as soon noted. See as possible (representation cites a number of articles response to and research on this issue). PM014 It is impossible to refer to improvements in an Air Quality Management Area and ignore one part of that area – St Comment James’ Street. noted. See response to 46
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref PM014.
PM062 SA2 Central 2 Friends of the Earth Brighton & Hove (174/14); S. Parry (16/7) Brighton, page 106 representations; 1 support with Support this modification with caveat as to whether the Support Air quality caveat wording on air quality needs to be tightened in light of welcomed and modifications at the recent Court of Justice of the European Union ruling comments 3.141 and footnote that there is an obligation to address legal limits as soon noted. See as possible (representation cites a number of articles response to and research on this issue). PM014 It is impossible to refer to improvements in an Air Quality Management Area and ignore one part of that area – St Comment James’ Street noted. See response to PM014. PM063 SA3 Valley No Gardens, page 109 representations received Update policy priorities for The Level and paragraph 3.145 to reflect the restoration undertaken PM064 SA4 Urban Fringe, 116 page 111-113, representations. 1. Representations of Support for Proposed Modifications (9) amendments to policy and 9 University of Brighton (167/4), South Downs National Park supporting text to representations Authority (163/3), Brighton Society (119/8), Kingsway & West 47
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref reflect increased of support. Hove Residents Association (31/5), Preston & Patcham housing target and Society (106/1), CPRE (97/3), Rottingdean Parish Council – reassessed role of 107 objections. Chairman Bob Webzell (133/2), Brighton & Hove Economic the urban fringe in Partnership (57/1), Sussex Wildlife Trust (137/2). response to Inspector’s Initial Support for council’s aim of establishing a new Conclusions letter. authorised City Plan. Comments of Support 2014 Urban Fringe Assessment as a positive Support and thorough study in considering housing potential welcomed. from urban fringe. Look forward to opportunity to comment on further details of potential sites which might qualify for the Local Green Space designation. Development within a few areas of the urban fringe is inevitable; however great importance should be attached to the setting of the National Park in the consideration of detailed proposals. Welcome the recognition in supporting text that much of the urban fringe meets the NPPF definition of open space and represents a significant proportion of the city’s open space resource. Development of urban fringe sites should be accompanied by local planning briefs indicating the new open space required for the density of housing proposed to secure sufficient new open space. National Park requests officers from the two local planning authorities work together under Duty to Co- Operate in a more detailed assessment of the potential housing sites given some of the sites proximity to the designated landscape. This work should inform 48
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref allocations to be made in Part 2 of City Plan to ensure due regard is given to the purposes and setting of the National Park. University of Brighton supports council’s objectives with respect to the careful use and management of land within the urban fringe; does not wish to propose any changes but would direct council to linked comments for DA3 Lewes Road.
2. Representations objecting to Proposed Modifications:
a. General objections and concerns raised regarding additional residential development in the urban fringe
Brighton & Hove Wildlife Forum (112/1), Maureen Holt (176/1), The 2014 Urban Vale Residents Association (130/1), Gavin Fitzgerald (4/1), Fringe Councillor Geoffrey Theobald (181/1), Emad Herandi (8/1), Assessment is Hove Civic Society (7/5), Graeme Forrest (83/1), Dr Jo Tulloch considered a (114/1), Edgar Miller (125/1), National Trust (122/1), Deans robust, Preservation Group (96/2), Saltdean Residents Association adequate and (118/2), Dave Bangs Left Unity Brighton & Hove Branch up to date (140/1), Jenny Embleton (93/1), Steve Dunnill (158/2), Roger evidence base and Sue Harper (126/2), Friends of the Earth, Brighton & Hove from which to Branch (174/15), Richard and Theresa Pearce (134/2), Dr assess the James Odonnell (184/1), John Divine (187/2), South Downs overall Society (25/6), SOC J Shepherd (147/2), Open Spaces additional Society (27/2), (33/6), Brighton Society (119/2), Wendy Barrett residential (92/2) capacity from the city’s urban 49 Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Inappropriate to identify sites for residential fringe. development on the urban fringe. These sites have an important landscape buffer role for the wider countryside Proposed and to the National Park and are also important modifications to Gateways to the National Park. the supporting Open green spaces should be protected for their leisure, text to Policy recreation and biodiversity value. They will be needed SA4 clarify that for the future increased population of the city. further Urban fringe is important in terms of biodiversity. Public consideration bodies have a duty to promote biodiversity through and a more Natural Environment and Rural Communities Act 2006. detailed A net gain in biodiversity should be provided and any assessment of application for development should be required to potential sites provide a statement regarding this. will be Concerns regarding the 2014 Urban Fringe Assessment undertaken to of potential for some of the prominent hill top sites in inform site terms of visual impact on the landscape. allocations put Object to any development potential identified on city’s forward for allotment sites. consultation as Support for more detailed investigation and detailed part of the surveys (ecology, landscape, archaeology) of urban preparation of fringe sites and full public consultation before allocating Part 2 of the any sites. City Plan. Query robustness of the Urban Fringe Assessment and the overall figure of 1,060 as potential source of housing supply from the urban fringe as a whole as some sites seem to have been assessed using incorrect or inaccurate information (reference to site 18 and site 31).
Urban Fringe Assessment can only be an interim
assessment of development potential; a more detailed 50
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref assessment will be needed to avoid ad hoc incursions in the urban fringe. Urban Fringe Assessment looked across Brighton & Hove superficially; has not taken account of local circumstances or the cumulative impacts that additional development would create e.g cumulative traffic impacts, associated pollution, additional infrastructure requirements (e.g. schools, healthcare). Masterplanning will be required for some of the sites. Proposals will need to have regard to the downland landscape setting and inclusion of appropriate green space to provide a buffer to the National Park. Should go back to original text in paragraphs 3.154 and 3.155 and remove the wording ‘where appropriate’ in Policy SA4 as this leaves the policy too open to abuse. Delete the reference to the Urban Fringe Assessment (UFA) being a material consideration in the policy SA4. The Sustainability Appraisal fails to assess alternative urban fringe sites or other combinations of development other than that identified in the UFA. Policy not justified due to inadequate SA. Existing space within the city should be used first; there should be a sequential approach to development using brownfield sites up first before any consideration of the city’s urban fringe.
It would be more appropriate to increase densities on
brownfield sites with high architectural quality.
b. Plan should be aiming for more residential development on 51
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref the city’s urban fringe. Dr Sameer Bageen (18/1), Lightwood Strategic (117/1), Mr D Hunter (75/6), Teale and Brindley Familes, Ovingdean Estates Limited (35/5), Colin Brace (152/2), Crest Strategic Ltd (144/3), Buoygues Developments Ltd (24/2), Westfield Investments Ltd, Colin Brace (153/2). 2014 Urban Fringe There are arguments for building more widely and more Assessment is substantively on the city’s urban fringe and these have considered a not come through the proposed modifications. The case robust, needs to be put forward in a public forum. adequate and The Urban Fringe Assessment is too broad brush, desk- up to date based study with no site visits or surveys. Development evidence base capacities should be regarded as indicative only and not from which to applied as a cap on development. assess the Urban Fringe Assessment is not positively prepared; the overall capacity assessment of sites is inflexible and inefficient and has from the city’s maximised constraints and limited opportunities for urban fringe. mitigation. Capacity on some sites artificially constrained (e.g. Site 42 – annotated version of assessment). The council Urban Fringe Assessment does not go far enough; consider the certain locations are able to accommodate a higher proposed number of dwellings and contribute more to city’s modifications housing supply (e.g. Site 43, Ovingdean, Sites 10-12, respond to and Benfield Valley). address the Policy SA4 should be further amended to directly Inspector’s acknowledge that the urban fringe is a source of concerns. housing supply for the city and this should be clearly indicated (policy not positively prepared and not effective in this respect). 52
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Policy should be amended further to states that opportunities to deliver higher amounts of housing within the urban fringe (higher than anticipated in the Urban Fringe Assessment) will be supported where detailed site specific evidence demonstrates that there are no significant adverse impacts that would outweigh the benefits.
3. Urban Fringe Site Specific Objections
Mile Oak Sites - Sites 1,2, 4 -6 Jill and Paul Corlett (15/1), Jenny Embleton (93/1), Open Spaces Socieity (27/2), Dave Bangs Left Unity Brighton & Hove Branch (140/1) The 2014 Urban Use brownfield sites first before wrecking countryside Fringe Should be no building on allotment sites. Assessment is Mile Oak Valley important for landscape, wildlife, considered a archaeological and recreational importance. robust, Important gateways to wider downland and national adequate and park. up to date evidence base from which to Benfield Valley - Sites 10, 11 and 12 assess the J Raphael (182/2), Mrs S Finlayson (67/1), Dr Michael Ray overall (1/2), Ray Tyler (145/2), Ian Robertson (108/2), Valerie Axcell additional (101/2), Linette Fellingham (89/2), Derek Allen (91/2), Vivien residential Robertson (109/2), Open Spaces Society (27/2), Dave Bangs capacity from Left Unity Brighton & Hove Branch (140/1) the city’s urban One of the city’s remaining green lungs with direct fringe. 53
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref bridge link to the National Park; gateway to wider downland landscape. This green lung has long been protected for future Proposed generations through a series of development plans; a modifications to retreat from this would be a serious betrayal of previous the supporting assurances given to residents of Hove, Portslade, and text to Policy Hangleton. SA4 clarify that Key part of linked historic complex of Benfield further Farmstead and Hangleton Manor. consideration Varied wildlife habitats including badgers and a more Well used for outdoor recreation detailed Developer’s potential plans for 380 homes are assessment of excessive and would require significant infrastructure potential sites (schools, GP Surgeries) will be Roads are already heavily congested and Hangleton undertaken to Lane not a suitable access point. inform site allocations put Bouygues Developments (24/3) forward for Site could provide a significantly higher amount of consultation as development than identified in the 2014 Urban Fringe part of the Assessment. preparation of Part 2 of the Land adjacent to Horsdean Recreation Ground (Site 16) City Plan. Andy Davies (29/1), Jo Graver (65/1, Horsdean Community Sports Association (136/2), Richard and Theresa Pearce (134/1), Wendy Barrett (92/2), Open Spaces Society (27/2), Dave Bangs Left Unity Brighton & Hove Branch (140/1) Concerns regarding impacts on local traffic and local infrastructure (e.g. schools, healthcare) in Patcham.
54
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Concerns regarding water table, water supply and pollution Important for recreational use and gateway to national park. Horsdean Community Sports Association assume that proposals would have no adverse impacts or restrictions on current use of the recreation ground for sports clubs and local community.
Land at Ladies Mile (Site 17) George McAlpine (14/1), Andy Davies (29/1), Jo Graver (65/1), Steve Dunnill (158/2), Jane Moss O’Brien (164/2), Wendy Barrett (92/2), Open Spaces Society (27/2), Dave Bangs Left Unity Brighton & Hove Branch (140/1)
Object to any building on these green open spaces. Concerns regarding adverse impacts on local infrastructure, e.g. schools, GP surgeries and healthcare. Concerns regarding adverse impacts on local road network and traffic levels. Concerns regarding building on old playing field area – does this belong to Patcham School? Archaeologically sensitive area, abuts countryside. Concerns regarding impacts on local nature reserve. Important archaic plateau chalk grassland site.
Hollingbury Park (Site 18) Jo Graver (65/1), Colin Inns (79/1), Gillian Taylor (179/1, Becky
55
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Reynolds (175/1), Richard Leggett (177/1), Celia Leggett (178/1), Friends of Hollingbury and Burstead Woods (129/1), Dr Jo Tulloch (114/1), Ms Brenda Pollack (102/1), Mrs Kate Mullins (124/1), Veronica Atkinson (121/1), Anthony Rogers (131/1), Paul Tibbey (113/1), Edgar Miller (125/1), Mrs Polly Charlton (127/1), Heather Smith (148/1), Christopher Harvey (172/1), WEA John Williams (173/1), Nigel Symington Butterfly Conservation (160/1), Jamie Burston (26/1), Andy Davies (29/2), Dr Lydia Burgess Gamble (66/1), Grenville Nation (70/1), Adrian Peasgood (77/1), Geoff and Jean Harris (141/2), Paula da Luz (156/2), Friends of the Earth Brighton & Hove Branch (174/19), Jacqueline Inns (80/2), Brighton Society (119/8), Anthony L Cooke (115/2), S. Wilkins (138/1)
Objection to any development at Hollingbury Park; important green wedge of open space and should be protected. The housing potential for this site should be deleted from the numerical allowance for the urban fringe. Long established history for recreation North/South views to and from Hollingbury Park to the National Park are valuable and mitigation for any loss is not possible. Open feel of the upper park would be lost. Green Corridor and Gateway to the National Park. Eastern side of Ditchling Road acts as a boundary for open downland. Urban Fringe Assessment is incorrect when it says there is enough open space within the ward; some of the other spaces (Wild Park, Stanmer) are too far to walk. Hollingbury Park serves a much wider area than just the 56
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref ward. It also serves neighbouring wards of Preston Park, Withdean and Patcham where there is a shortage of open space. 90% of Site 18 is proposed Local Nature Reserve and ecologically rich area. Unsound to propose any development; not possible to mitigate for adverse impacts. Valuable greenway linking valued habitats. Essential to wildlife to have some relatively large tracts of open land left undeveloped; this has helped Brighton to achieve designation as Biosphere. Threat to White Letter Hair-streak Butterfly which is identified in the Biodiversity Action Plan. Areas noted for housing development could have significant adverse impacts on ecology of those locations and the areas around them. Areas north and south of reservoir are ecologically rich and there is an ongoing programme of work to improve biodiversity.
Coldean – Site 21 Open Spaces Society (27/2), Dave Bangs Left Unity Brighton & Hove Branch (140/1) Important part of Stanmer Park Historic Park Meadows should be managed for recreation and for wildlife value.
Land at Brighton Racecourse/ Whitehawk Hill (Site 30) Open Spaces Society (27/2), Dave Bangs Left Unity Brighton & Hove Branch (140/1) Land is protected for recreation – part of recreation 57
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref common land. Area is important for wildlife, archaeology and landscape – part of sub-landscape of national importance. Important chalk grassland areas.
Land east of Whitehawk Hill Road (includes part of Craven Vale Allotments) (Site 31) Deborah Malin (19/1), Tessa Pawsey (30/1), Nick Fry (32/1), James Gilderoy, Craven Vale and Whitehawk Hill Allotment Society (90/1), Jenny Embleton (93/1), Mr Andrew Doig (68/1), Graham Levett (157/2), Friends of the Earth Brighton & Hove Branch (174/19), Ian Mallin (171/2), Sara Padhiar Carer’s Garden (28/2), Paul Davey (81/2), Caroline Martin (82/2), Jill Humphrey (107/2). Craven Vale and Whitehawk Hill Society has 352 plot holders; 173 at Craven Vale and 179 at Whitehawk Hill plus a waiting list of 106 across both allotment sites. This is an actively used allotment site and should be protected from development. Urban Fringe Assessment report is flawed; there is no overprovision of open space; the allotments serve a much wider area including many residents coming from the city centre. Any development would contradict other council policy and objectives regarding promotion of healthy lifestyles, local food growing, biodiversity, etc. Allotments are included within the Whitehawk Hill Local Nature Reserve and are adjacent to sites of national archaeological significance. 58
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref There is nowhere to re-locate the allotments; adjacent land is Open Access land which is not recognised in the Urban Fringe Assessment Report. Allotments promote biodiversity and nature conservation. Allotments are important for many of the city’s residents who do not have outside space for food growing. Allotments important for people’s health and well-being. The local roads are unsuitable for any increase in traffic. There should be a brownfield first policy before any consideration of green open spaces.
Land north of Warren Road – Site 33 Brighton Society (119/8), Open Spaces Society (27/2), Dave Bangs Left Unity Brighton & Hove Branch (140/1)
Housing would have a negative impact on landscape here Assessment for this site should be re-considered.
Roedean Miniature Golf Course and land south of A259 (Site 37) Roedean Residents Association (58/1), Open Spaces Society (27/2), Dave Bangs Left Unity Brighton & Hove Branch (140/1) Housing potential should not go forward as it does not conform with objectives of Policy SA4 Bus services are poor Urban Fringe Assessment states that 1ha could support 25 dwellings but no indication of what form these
59
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref dwellings would take. Site important for informal recreation and has potential for archaic grassland restoration.
Land adjacent to Ovingdean and Falmer Road, Ovingdean (Site 42) Deans Preservation Group (96/1, 96/2, 96/3), Ovingdean Residents & Preservation Society (95/1), Heidi Muller (52/1), Dr Philip Denbigh and Denise Denbigh (183/2), Simon Kirby MP (185/1), Open Spaces Society (27/2), Dave Bangs Left Unity Brighton & Hove Branch (140/1) Urban Fringe Assessment is not a sound evidence base; does not take account of detailed ecological information regarding rare plants and animal species. Lack of detailed landscape assessment, lack of recognition that site occupies sensitive location with respect to the National Park; lack of detailed survey regarding archaeology, ecology, landscape, flood risk. PM064 unsound because it is contrary to National Planning Policy Framework, e.g para. 117 re. biodiversity. Development would be contrary to SA5, CP10 and CP16 of City Plan. Adverse impact on countryside and landscape and contrary to NC6 of adopted Local Plan. Lead to coalescence of Rottingdean, Ovingdean, Woodingdean and a weakening of the gap function. Adverse impact on local distinctiveness. Concerns regarding traffic increases and impacts on
60
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref local infrastructure. No immediate necessity for the development; plenty of brownfield sites exist. Delete reference to Urban Fringe Assessment in Policy SA4.
Other Ovingdean Sites – Sites 38, 38a, 39, 41, 43 Simon Kirby MP (185/1), Ovingdean Residents Association and Preservation Society (45/1) Concerns regarding impacts on traffic and local infrastructure (schools, healthcare, etc) Flood risk from development No immediate need for development; plenty of brownfield sites exist
Teale and Brindley Families, Ovingdean Estates Ltd (35/1), Mr D Hunter (75/1) Proposed modifications do not go far enough; Urban Fringe Assessment recommends too low a figure for Site 43. This is not open or accessible land and could accommodate higher number of dwellings
Saltdean Sites generally (Sites 46a, 48, 48a, 48b, 48c, 50) Graeme Forrest (83/3), Saltdean Residents Association (118/1), Chris and Linda Whitby (135/1), Jon Newsom Ray (37/1), Tony Lees (2/1), Mrs C Carruthers (17/2), John Austin Locke (94/2), Cathy Wenger (120/2), Open Spaces Society (27/2), Dave Bangs Left Unity Brighton & Hove Branch (140/1)
61
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Cumulative traffic impacts on local roads and A259 have not been properly considered. Lack of infrastructure to support increased population arising from additional development e.g. schools, healthcare provision. Lack of local demand for the type of housing being proposed; first time buyers will be excluded but second home owners attracted. Potential at Coomb Farm (Site 48) needs to be reduced and further consideration given to wildlife habitats and the protection of the existing woodland. Brownfield sites should be considered before any consideration of green spaces. Important gateway sites to national park. Concerns regarding adverse impacts on setting of the National Park
Objections to Land west of Falmer Avenue - Site 50 Miss Jane Frowde (87/1), Duncan Bassett (34/1), Jon Newsom Ray (37/2), Richard Everest (85/3), Saltdean Countryside Alliance (142/3), Mark Hayes (86/2), Ann R Hayes (84/2).
Query regarding whether there is a mapping error; site appears to be outside City Plan boundary and should be included within the boundary of City Plan. The land is agricultural not urban land; assessment is incorrect. Site should be within the National Park; procedural error by Defra led to the land being excluded.
62
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Could be a significant cost to Defra regarding payment of compensation to nearby residents for loss of value to their homes. There is a significant surface water flood risk; this is not fully acknowledged. No vehicular access to the site. Pressure from additional development on local roads and infrastructure (e.g. schools, healthcare). Site is not suitable and the dwelling potential should be excluded from this site.
PM065 SA5 The South 6 Support: Friends of the Earth Brighton and Hove (174/16); Support Downs, pages 114- representations: South Downs Society (25/7) welcomed. 117, redrafted policy 2 support; 2 and supporting text caveated Support protection of the setting of the National Park (in The council to address support; 2 accord with National Park purposes and duty). Plan would consider the objections by the object be unsound without it. proposed South Downs modifications National Park Caveated support: University of Brighton (167/5); Bouygues adequately Authority (see Development (24/3) address the Statement of Inspector’s Common Ground – No amendments to SA5 sought but directed towards linked concerns and SOCG-01) comments to DA3 and the opportunities at Falmer Campus those of for sustainable growth/development of higher education respondents. sector (eg new academic and sporting facilities). Should recognise these opportunities, within the setting of National Park, to realise Council’s ambitions for a high-quality Academic Corridor/enhance role of higher education provision in City. Support modifications enhancing the protection of National 63
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Park via minimising adverse impacts, however, should not be at the expense of providing the City’s needs particularly housing, employment and transport uses.
Object: R & S Harper (126/3); CPRE Sussex (97/2);
Modification fails to recognise urban fringe acts as gateway to National Park and these routes must be protected. Amend text to protect urban fringe. Potential adverse impacts on National Park must be avoided and, where development benefits override, mitigated.
PM066 SA5 The South 4 Support: South Downs Society (25/11) The council Downs, pages 116- representations: consider the 117 redrafted policy 1 support; 3 Support modification / any development within the setting proposed and supporting text Object of the National Park should be consistent with and not modifications to address prejudice National Park purposes and the duty of the adequately objections by the National Park Authority. address the South Downs Inspector’s National Park Object: R & S Harper (126/4); The National Trust (122/2); concerns. Authority (see CPRE Sussex (97/1); Statement of Text should be expanded to not only include Stanmer Park No further Common Ground – but also protect Benfield Valley from housing. ( amendments SOCG-01) Housing/population increase is likely to impact upon are considered National Trust land and property that provides the City necessary. opportunities for accessible greenspace. Improvements to other facilities (eg accessibility/sustainable transport modes, facilities etc) are likely in order to promote City residents’ 64
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref understanding and access to the National Park. This will require involvement (partnership working) of other major landowners, such as the National Trust. Suggested amended text as follows: para 3.165 at end of first sentence before “as appropriate” insert “and other major landowners”; para 3.166 at end of second sentence after “partnership working” insert “with all key stakeholders to deliver improved interpretation, access and potentially improved visitor facilities.” Para 3.168 should include reference to conserving and enhancing the natural beauty of the South Downs National Park (forms part of first purpose of National Park) and to tranquillity (the absence of artificial light and/or noise) as an important characteristic of the National Park. Priority 4 should also refer to all cultural heritage assets (first purpose of National Parks refers to ‘cultural heritage’)
PM067 SA6 Sustainable No Neighbourhoods, representations Page 119 – amend received footnote 115 PM068 SA6 Sustainable 1 Hove Civic Society (7/6) Support Neighbourhoods, representation, acknowledged page 120 1 support This is one of the modifications we negotiated with the city council and which we would like to see retained. Modification to A.8 to refer to minimum space standards PM069 SA6 Sustainable 3 Hove Civic Society (7/7); The Brighton Society (119/9); North Neighbourhoods, representation; Laine Community Association (13/6) 65
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref page 121 1 support, 2 objections This is one of the modifications we negotiated with the city Support Additional bullet at council and which we would like to see retained. acknowledged 3.172 related to There should be reference space guidelines. The term minimum space minimum space standard means nothing without actual standards guidance. Vital that minimum space standards for all types of Detailed space residential buildings are incorporated into the City Plan. At guidelines will this stage we request that minimum space standards be more subject to public consultation. We have seen recently too appropriately be many instances where the lack of minimum space dealt with in standards has resulted in approval of schemes which we Part Two of the would regard as the slums of the future. City Plan. PM070 SA6 Sustainable No Neighbourhoods, representations page 121 received
Update name of LSP at 3.173 and footnote 118 PM071 SA6 Sustainable No Neighbourhoods, representations page 124 received
Amend footnote 122 PM072 CP1 Housing 77 Support Proposed Modifications Delivery, pages representations; 127-132, 8 support, 69 University of Sussex (116/4), Adur & Worthing Councils amendments to objections (143/1), Brighton & Hove Economic Partnership (57/2), policy and Rottingdean Parish Council (133/3), Kingsway & West 66
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref supporting text to Residents Association (31/6), Hove Civic Society (7/8), Lewes reflect increased District Council (20/1), University of Brighton (167/6) housing target and reassessed role of Welcome the positive approach taken to identifying the urban fringe in additional housing supply and this is supported. response to Impressed with thoroughness of 2014 Urban Fringe Support Inspector’s Initial Assessment. welcomed. Conclusions letter. Accept the need for a more comprehensive planning approach for the urban fringe. Modifications also Recognise that there are only limited development reflect increased opportunities due to tightly drawn boundaries and contribution of significant environmental constraints. windfall supply to Support amended housing target and this needs to be housing target, agreed and pursued through the Plan to avoid planning updated housing in a void without an up to date Plan. land supply and Amended target is realistic and a deliverable amount of trajectory in development for the city. The city will never be able to response to accommodate anticipated housing demand to 2030 and Inspector’s Initial has explored all avenues possible to establish realistic Conclusions letter. supply. Supportive of a collaborative approach to housing supply and student accommodation to ensure needs of local population and students are met.
Plan satisfies Duty to Co-Operate with neighbouring
authorities and this work is being taken forward in a
positive and constructive manner through Greater
Brighton City Region and its Economic Board.
Objections to the Proposed Modifications
67
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref 1. Council has not rigorously assessed all opportunities for The council meeting the city’s objectively assessed housing needs. consider the proposed Council’s approach to housing supply should be reviewed modifications again particularly given the remaining significant shortfall respond to and between the (increased) objectively assessed housing need address the (18,000 – 24,000) and the revised housing target (13,200). Inspector’s concerns as set out in her initial conclusions a. Need to review Policies for Tall Buildings and Housing letter. Densities (CP14)
Colin Brace (152/8,), Westfield Investments (153/1) Hyde Housing (162/1)
Capacity assessment for taller buildings last carried out This issue was 2003 and should be reviewed in light of current housing debated during shortage. the hearing Policies for tall building proposals need to be reviewed sessions and in all parts of the city. the Council has Housing density in CP14 of 50 dwellings per hectare no further outside of Development Areas is too low and should be comments. reviewed in light of housing shortage.
b. Need to review approach to policy protection for employment sites – CP3
La Salle Investment Management (151/5), Colin Brace The council 68
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref (152/1), Westfield Investments (153/1) Hyde Housing (162/1) consider the AEGON UK c/o Kames Capital (169/1) proposed modifications A further review of redundant employment sites is respond to and suggested in light of the planned under-provision of address the housing. Inspector’s Greater flexibility regarding the protection of concerns. employment sites is required. Redevelopment of existing employment sites would make a significant contribution to meeting housing needs of the city. Additional residential units should be encouraged in business parks and industrial estates subject to avoiding adverse impacts on amenity. City’s Article 4 Direction blocks housing supply through permitted development rights for changes of use from offices (B1) to housing (C3).
c. Could be additional potential for housing on existing open spaces in urban area of city
Linden Homes (154/1), Baron Homes Corporation (3/1)
Increase in housing need reinforces the need for a comprehensive review of potential sites that could SA 2011 (Policy contribute to meeting city’s housing need including the Options stage) potential for residential development on existing open assessed spaces in the urban area. options which October 2014 Sustainability Appraisal considers included a more implications of releasing 108 ha of existing open space limited release to help meet shortfall but no attempt to assess the of urban open 69
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref impacts of a more limited release of existing open space space. in the city. Do not consider council’s evidence on open space to be robust; 2011 Open Space Update Study excluded all The evidence school sports facilities and does not follow Sport base informing England’s methodology. The council should commit to and supporting an early review of the 2011 Open Space Study. policy CP16 and Own research and analysis indicates there may be CP17 and some potential for some open space to be released for proposed residential development. modifications is Removal of open space designation at 18 Wellington considered Road to allow whole site for housing. robust. It accords with the NPPF; it is proportionate, adequate / fit for purpose and appropriately up-to-date.
d. Additional housing supply from 2014 Urban Fringe Assessment welcomed but study relies on low densities and does not make efficient use of sites. 2014 Urban Fringe Bouygues Development c/o Vail Williams (24/1), Lightwood Assessment is Strategic (117/2), Westfield Investments Ltd (153/1), Hyde considered a Housing Group (162/1), Ovingdean Estates Ltd, Teale and robust, Brindley Families (35/8), Mr D Hunter (75/4) adequate and up to date 70
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref 2014 Urban Fringe Assessment promotes low evidence base density developments on many of the urban fringe from which to sites and, given city’s housing requirements, the assess the Plan should ensure most efficient use of these sites overall capacity is made. from the city’s Certain locations (e.g. Benfield Valley, Meadow Vale urban fringe. Ovingdean) could support higher amounts of development. Figures in the Urban Fringe Assesment should be recognised as indicative only and not represent an artificial cap on development. Study is not robust; crude assessment of capacity (reference to Site 42). Whilst methodology includes a consideration of potential mitigation, the assessment has been undertaken in an inflexible and inefficient way that has maximised potential constraints and limited opportunities for mitigation. Factual inaccuracies and errors have led to the capacity of some sites being artificially constrained.
e. Relaxation of Visitor Accommodation Policy could boost housing supply Comments noted. Proposed Brighton & Hove Hoteliers Association (21/1) Modifications were editorial. There remains an opportunity for more flexibility in the CP6 provides policy approach to retaining visitor accommodation and sufficient the relaxation of change of use regulations in respect of flexibility for visitor accommodation to help boost housing supply. change of use. 71
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref
f. Underestimate of housing capacity in DA1.
Standard Life Investments (SLI) (159/18) Discussions regarding Proposed number of new homes for the DA1 options for the Development Area is an underestimate of the capacity potential re- of this area to deliver residential development. SLI is location of the currently considering options for development which Brighton Centre could be in the order of 300 units. This should be are at an early recognised in the Plan at Policy CP1. stage. Any additional future residential capacity within DA1 is not prohibited by the housing target in CP1.
g. Higher residential capacity at Inner Harbour – DA2 target should be increased. The policy X-Leisure (103/10) indicates a minimum of Inner Harbour is capable of delivering 1300 units and 1,000 residential this is likely to be required to ensure a viable units. development. Plan should be updated to reflect higher 72
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref capacity.
h. Housing target still too low, more needs to be done to plan for housing particularly given the need to provide more The increased affordable rented housing in the city. housing target Richard Scott (180/5) responds directly to the Inspector’s concerns. i. Query rationale for increased housing target; this has not been properly explained. The increased Steve Parry (16/8) housing target responds directly to the Inspector’s concerns.
2. Objections to residential development on Urban Fringe land and to the inclusion of a numerical allowance for development within the Urban Fringe indicated in Policy CP1. B The 2014 Urban Fringe Richard and Theresa Pearce (134/2), Steve Dunhill (158/1), Assessment is Open Spaces Society (27/1), Sean Flanagan (60/1), (33/1), considered a Chris Todd (174/2) , Roger and Sue Harper (126/5), John robust, Divine (187/1), Councillor Geoffrey Theobald (181/2), Ms adequate and Brenda Pollack (102/2), Friends of Hollingbury & Burstead up to date Woods (77/2), James Gilderoy (90/1), Jill and Paul Corlett evidence base (15/2) , Jenny Embleton (93/2), Friends of the Earth from which to 73 Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Brighton & Hove (174/3), Wendy Barrett (92/1) assess the overall Common to devalue small edge of town green spaces additional when they have value in their own right and links to the residential wider countryside beyond. capacity from Many of these sites are important in terms of the city’s urban archaeology, wildlife and ecology, recreation for all fringe. ages, historic assets, gateways to wider Downland. Significant transport and related air pollution problems in Proposed urban fringe areas which further development would modifications to exacerbate – is Government Inspector aware of these the supporting constraints? text to Policy Should not include the consideration of any allotments SA4 clarify that for housing development – these are important for local further food growing, health and exercise, well-being, wildlife, consideration ecology and nature conservation. and a more Many allotments serve a much wider than local area so detailed cannot say there is a any local surplus of provision. assessment of Query whether the figure of 1,060 for the urban fringe potential sites housing potential is sound given that some sites seem will be to have been put forward using inaccurate or incorrect undertaken to information e.g. Hollingbury Park and Craven Vale inform site Allotments. allocations put Numerical allowance for urban fringe housing should be forward for deleted and the housing target return to 11,300 new consultation as homes. part of the preparation of Open spaces will be even more important as the city’s Part 2 of the population increases with the Plan. Council should City Plan. protect these open green spaces in perpetuity and not
just within the scope of the plan. 74
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Should be brownfield first policy. A sequential approach should be taken to any development in the urban fringe after development in the eight Development Areas have been fully utilised.
2a. Specific objection to the inclusion of particular urban fringe sites in the overall numerical allowance for the Urban Fringe.
Mile Oak Valley Sites (1-6) Open Spaces Society (27/1), Jill and Paul Corlett (15/2) These sites are important for their archaeological, wildlife, recreation roles. Proposed Important gateways to wider countryside and Downland modifications to Provide an important buffering function for wider the supporting Downscape text to Policy Brownfield site opportunities should be used before any SA4 clarify that consideration of these spaces. further consideration and a more Ladies Mile (17) detailed Open Spaces Society (27/2), Steve Dunnill (158/1), Jane Moss assessment of O’Brien (164/1), Andy Davies (29/2), potential sites Site is important in terms of archaeology, wildlife and will be landscape values undertaken to Gateway resource to wider Downland inform site allocations put Rural quality forward for Concerns regarding loss of former sportsfield consultation as Infrastructure concerns regarding local schools, roads, part of the 75
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref etc preparation of Impact on local house prices. Part 2 of the City Plan. Craven Vale (part of Site 31) Jill Humphrey (107/1), Jill and Paul Corlett (15/1), Sara Padhiar-Tutton (28/1), Caroline Martin (82/1), Paul Davey (81/1), Ian Mallin (171/1), James Gilderoy (90/2), Jenny Embleton (93/2), Graham Levett (157/1)
Allotments are valued for health, exercise, well-being, local food growing, wildlife and ecology. It would not be easy for plot owners to re-locate; accessibility and time/effort put in by plot owners mean re-location would be very difficult. Area pointed to in Urban Fringe Study for re-location is open access land and not suitable for allotments. Underutilised brownfield land and buildings should be used first before any consideration of allotment land. Allotments serve a much wider area than just local population so there is no surplus of provision. Represent a green lung within this local area which is heavily populated and where many homes do not have gardens big enough to grow food.
Sensitive location and rich in archaeological interest
and value.
Pressures on local road network already.
Benfield Valley (Sites 10 – 12)
Ian Robertson (108/2), Vivian Robertson (109/2), Ray Tyler
76
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref (145/1), Valerie Axcell (101/1) , Open Spaces Society (27/2) , Linette King (89/2) , Derek Allen (91/2), J Raphael (182/1), Linnette Fellingham (89/1)
One of the city’s remaining ‘green lungs’ with a direct bridge link to the National Park Gateway to wider Downland landscape. Varied wildlife habitats including badgers Well used for outdoor recreation Developer’s potential plans for 380 homes are excessive and would require significant infrastructure (schools, GP Surgeries, roads already congested). Hangleton Lane not suitable access point.
Hollingbury Park (18) Anthony Cooke (115/1), Wendy Barrett (92/2) , Paula de Luz (156/1) , Geoff and Jean Harris (141/1) , Jacqueline Inns (80/1) , Friends of the Earth Brighton & Hove (174/22) , Jamie Burston (26/2) , Dr James O Donnell (184/1) , Friends of Hollingbury and Burstead Wood (77/2), Andy Davies (29/2), Jenny Embleton (93/2)
Areas identified for housing potential are part of the park and should be retained.
This is an important green space for local community
and recreation for all ages and should not be lost for the
sake of 20 houses.
Significant wildlife and ecological value
Building would impact on large water reservoir and 77
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref underground connections to reservoir further up Ditchling Road. The assertion within the Urban Fringe Assessment that there is a surplus of open space in Hollingdean and Stanmer, but the park serves a much wider area including parts of Preston Park ward, Patcham and Withdean where there is a shortage of green space. Therefore question whether the figure of 1,060 dwellings for the urban fringe is sound. Should be a brownfield first approach with a sequential approach to development in the urban fringe.
Land adjacent to Horsdean Recreation Ground (Site 16) Richard and Theresa Pearce (134/1) , Wendy Barrett (92/1) , Sandra Russell (22/1), Horsdean Community Sports Association (136/1) , Open Spaces Society (27/1)
Patcham has already lost many green spaces; Further development will impact on local infrastructure and water table Concerns raised by Horsdean Community Association; assume any proposed development would not impact on current use of recreation ground for sports clubs and local community. Rural quality to this land despite the nearby by-pass.
Whitehawk Hill / Warren Road Sites (Sites 27 – 35) Open Spaces Society (27/1)
These sites are all important in terms of historical, 78
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref archaeological, wildlife, ecology value. Important chalk grasslands Important allotment sites
Falmer Avenue, Saltdean (Site 50) and other Saltdean Sites Mark Hayes (86/1), Graeme Forrest (83/4), Saltdean Countryside Alliance (142/4), Saltdean Residents Association (118/2), Richard Everest (85/4) , Jon Newsom-Ray (37/2), Mrs Curuthers (17/1), John Austin Locke (94/1), Ann R Hayes (84/1), Cathy Wenger (120/1)
Surface water run off and flooding is an issue for Site 50 and development would cause faster run off and flood areas lower down in Saltdean Site 50 should be within the National Park Infrastructure concerns regarding more development in Saltdean area and impacts on local infrastructure and tourism. Site 50 is agricultural and not urban land Concerns regarding transport / roads / air pollution associated with any further development in Saltdean.
Potential amount of housing identified for Coomb Farm
sites is excessive and needs to be reduced in terms of
volume and position.
Further investigation required for Coombe Farm sites
and further consideration given the woodland and
wildlife habitats at back of Coombe Vale and Westfield
Avenue.
79
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref
3. Achievement of Planned Housing Delivery; Housing Trajectory, 5 year housing supply. Linden Homes (154/5), Buoygues Development (24/1), Brighton Society (119/10), Lightwood Strategic (117/2), Mr D Hunter (75/4), AEGON UK (169/1) Housing Housing trajectory implies a step-change in housing trajectory and delivery increasing from 436 in 2013/14 to 655 in council’s 2014/15. The presentation of the trajectory in five-year approach to bands does not make it possible to understand whether housing delivery this step change is actually deliverable. as set out in the Council needs to be more proactive towards housing Housing delivery in order to achieve its housing trajectory, e.g. Implementation greater housing delivery on some of the urban fringe Strategy (Annex sites would boost supply (e.g. Benfield Valley, Meadow 3) is considered Vale Ovingdean). realistic, robust The land supply buffer should be 20% given the city’s and based on land supply problems. up to date and The increased figure for windfall provision is more proportionate realistic than before but probably too conservative. evidence Disagree with the Council’s approach to calculating a including five year supply requirement based on its housing dialogue with trajectory and particular nature of housing supply. developers.
4. Objections re. Duty to Co-Operate Mayfield Market Towns (23/2)
Part of process of leaving no stone left unturned must involve further positive discussions with neighbouring Duty to 80
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref authorities. Little progress appears to have been made cooperate was and co-operation has not led to a positive outcome. debated at the There is a need to consider longer-term strategic examination development options now. There should be joint work hearing between authorities to assess strategic development sessions. Duty options including the potential for a new settlement to to cooperate is north of the National Park. continuous and Brighton & Hove City Council has an obligation to work ongoing as directly with its neighbours and consider whether the evidenced in the Mayfield proposal is a sustainable new settlement update to the option. Duty to Cooperate Paper published along with the proposed modifications [Duty to Cooperate Update Paper - October 2014]
PM073 CP2 Planning for No Sustainable representations Economic received Development, page 133, 136-137
New criterion related to importance of non-B 81
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref use class and consequent modifications to paragraph 4.36 PM074 CP2 Planning for No Sustainable representations Economic received Development, page 136 Update paragraph 4.23 PM075 CP3 Employment 10 Support Modifications Land, pages 138- representations; Brighton & Hove Economic Partnership (57/3); Friends of the 139 modifications to 8 objections, 2 Earth Brighton & Hove (174/17) part 3, 4 and 5 of support Given that the Plan can only identify 85% of the policy to clarify projected requirement for new employment space wording, appropriate concern with any loss of net employment spaces. As Support sui generis uses the national economy gather speed, the need to adopt welcomed. and factors to be the City Plan is becoming increasingly pressing given its considered on implications for the success of the local economy. CP3.4 sites. Strongly support the retention of industrial estates and business parks for business, manufacturing and warehouse use to enable employment land to be retained in the city to retain jobs and reduce transport movements.
Object Modifications
AEGON UK Property Fund Ltd c/o Kames Capital (169/2);
Palace Street Development Ltd (9/1); Cross Stone
Regeneration (100/1); Taylor Wimpey (UK)Ltd (155/1); C. Brace (152/3); Westfield Investments Ltd -C. Brace (153/3); La 82
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Salle Investment Management (151/6)
Given Brighton’s housing shortage, the loss of employment policy approach seems overly restrictive and punitive, and not in line with national guidance. Given historic under-supply of housing and lack of a 20% buffer of housing sites to properly meet identified housing need. The emerging employment land supply policy should be amended to address the historic under-
supply of housing across the district.
Part 4 Amended wording does not far enough in ensuring the As set out in the Plan is positively prepared; wording is still restrictive and matter statement developers and landowners of the five industrial sites (BHCC-11 will still be looking at their sites from the ‘back foot’. Matter Statement Given housing shortfall – barely 50% of OAN, planning 5) the Council policy should be facilitating change and the provision of considers that housing. the proposed Wording is vague, imprecise and relies upon a planning modifications to officers’ subjective opinion as to whether the test has CP3 been met. Employment In reference to former Infinity Foods Site – still a policy Land provide an presumption against the loss of commercial/employment appropriately floorspace. Marketing evidence indicates to owners flexible and since permission for mixed use redevelopment of the responsive policy site that there are barriers to office occupation and there framework is no demand for commercial element and that site is related to an objectively not suitable for employment site (as indicated in the assessed need council’s 2006 ELS and 2009 update). Given significant 83
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref national and local housing land supply deficit and for B Use Class delivery issues, adequacy of employment land employment availability generally in Brighton & Hove and paragraph floorspace over 22 and 47 of NPPF site should be removed from CP3.4 the plan period and allocated for residential. to ensure that Inclusion of viability into policy is broadly welcomed and the City’s a similar test should also be directly applied to CP3 part economy and future potential is 5. But modification does not go far enough. It should also be about whether the redevelopment for other uses not constrained by a lack of brings with it benefits which would outweigh the harm employment caused by the loss of land in B Class use. These sites. benefits could include the delivery of much needed new homes or non-B Class employment generating uses. it
might also include the regeneration of sites with enhancements to the public realm, to the design,
character and visual appearance of the area.
Part 5 The council has not sufficiently re-assessed its
employment sites as an option for residential development as recommended by the Planning
Inspector. In light of housing shortfall; employment sites which are not listed as protected should not have to
demonstrate redundancy but instead should be released to residential or mixed use purposes to accommodate
the additional housing pressures that are being experienced in Brighton & hove.
Amendments to give ‘a priority’ to affordable housing is restrictive; not positively worded and do not go far
enough to answer the criticisms of the Inspector. 84
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Amendments imply that all of the housing would have to
be affordable housing rather than approach of up to 40% and fails to take into account the 10 unit (1,000 sq
m) threshold now set out in the NPPG.
The Brighton and Hove Employment Land Supply Trajectory (June 2013) guides the deliverable supply of
office and industrial accommodation towards the allocated Development Areas and also industrial estates
and business parks. Unallocated sites should not be protected by default in an area where previous under-
supply of housing is ignored. Part 5 should be further modified to allow release where housing need is
identified. Current policy approach will constrain the opportunities
for redevelopment and for maximising the contribution that the Sackville Road Sites could make in meeting
housing needs. Policy CP3 part 5, should be amended to positively facilitate redevelopment for other uses
where the benefits of doing so clearly outweigh any harm through the loss of employment land. Such an
approach would positively acknowledge the pressing land use needs in the City and in particular the shortfall
in the provision of new homes or non-B Class employment generating uses. It might also include the
regeneration of sites with enhancements to the public realm, to the design, character and visual appearance of
the area.
Other Site allocations The Brighton Society (119/11) will be 85
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref CP3 should list sites situated within the Shoreham addressed by Harbour JAAP the Shoreham Harbour JAAP PM076 CP3 Employment 3 La Salle Investment Management (151/7); AEGON UK Land, pages 140- representations, Property Fund Ltd c/o Kames Capital (169/3); Cross Stone 143, update ; 3 objections Regeneration (100/2) paragraphs 4.30- Amended wording does not far enough in ensuring the As set out in the 4.31 to refer to Plan is positively prepared; wording is still restrictive and matter statement Employment Land developers and landowners of the five industrial sites (BHCC-11 Supply Trajectory. will still be looking at their sites from the ‘back foot’. Matter Statement Modifications to Given housing shortfall – barely 50% of OAN, planning 5) the Council supporting text to policy should be facilitating change and the provision of considers that to reflect modifications housing. CP3 Employment to policy (PM075). The Brighton and Hove Employment Land Supply Land together Trajectory (June 2013) guides the deliverable supply of with the office and industrial accommodation towards the proposed allocated Development Areas and also industrial estates modifications and business parks. Unallocated sites should not be provide an protected by default in an area where previous under- appropriately supply of housing is ignored. Part 5 should be further flexible and modified to allow release where housing need is responsive policy identified. framework Current policy approach will constrain the opportunities related to an for redevelopment and for maximising the contribution objectively that the Sackville Road Sites could make in meeting assessed need housing needs. Policy CP3 part 5, should be amended for B Use Class to positively facilitate redevelopment for other uses employment where the benefits of doing so clearly outweigh any floorspace over harm through the loss of employment land. Such an the plan period approach would positively acknowledge the pressing to ensure that 86
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref land use needs in the City and in particular the shortfall the City’s in the provision of new homes or non-B Class economy and employment generating uses. It might also include the future potential is regeneration of sites with enhancements to the public not constrained realm, to the design, character and visual appearance of by a lack of the area. employment sites. PM077 CP3 Employment No Land, page 143, representations clarifies at para. received 4.40 alternative employment generating uses PM078 CP4 Retail 1 Support the deletion of the District Centre Designation at The council Provision, page 144 representation; Policy CP4 of the City Plan, provided that the current consider the – removal of 1 caveated designation is replaced by a strategic allocation which proposed Brighton Marina support includes our site within its boundary. Brunswick modifications from defined centre Developments Group PLC (161/1) adequately address the Inspector’s concerns.
PM079 Policy CP4 Retail 1 Sainsbury's Supermarkets Ltd (123/1) Provision, representation; Given the lack of evidence published by the Council in This was Page 145 1 objection support of the locally set threshold for retail impact debated during assessments, it is unclear as to how a figure of 1,000 sq the hearing Replace gross with m was derived. For Regional centres such as Brighton, sessions and net retail such a low threshold may impact on the viability of the Council has future developments coming forward given the no further substantial difference between the national 'default' and comments. 87
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref the localised threshold. Threshold is arbitrary and without justification or evidence the Council should utilises the default threshold of 2,500 sq m PM080 CP4 Retail No Provision, page 146 representations amend wording received below Table 6 PM081 CP4 Retail No Provision, page 146, representations paragraph 4.44 received
Modification related to removal of District Centre status of Brighton Marina. PM082 CP6 Visitor 2 Brighton & Hove Hotelier Association (21/3) Accommodation, representations Paragraph 4.58 understates the rate of growth in the Page 153, editorial supply of visitor accommodation and growth of short Comments changes at 4.58. term holiday lets since the Plan was submitted. Plan noted. Proposed should relax the change of use of existing B&Bs to modifications family homes as part of the solution to the housing were editorial. shortage on a case by case basis, with the need for CP6 provides quality accommodation outweighing the perceived need sufficient to retain every tourism business in a core zone. flexibility for Changes of use should be welcomed rather a change of use. requirement to prove un-viability as a business before being permitted to exit so long as an overall provision of visitor accommodation continues to meet demand. Would help redress the overcapacity, particularly as the modified City Plan continues to promote expansion of 88
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref that capacity. North Laine Community Association (13/5) Comment Update - Since the study was completed 3 new hotels noted. This can have come into operation (Jury's Inn, MyHotel and Ibis) be altered by and a YHA hostel in the Royal York hotel building. way of minor modification. PM083 CP6 Visitor No Accommodation, representations page 154, editorial received change at 4.64 PM084 CP7 Infrastructure No and Developer representations Contributions, page received 157, additional text at paragraph 4.73 related to timely connection to provision of utilities
PM085 CP8 Sustainable 8 Support Proposed Modifications Buildings, page 160, representations Standard life Investments (159/21) proposed received: 1 Support the reduction in requirements for Code for Support noted. modification to table support; 7 Sustainable Homes standards. set out under CP8.1 objections to address Object to Proposed Modifications and seek reinstatement of Objection Inspector’s Initial higher Code for Sustainable Homes standards acknowledged Conclusions. Friends of the Earth, Chris Todd (174/28); Sussex Wildlife for higher Trust (137/3) standards. This support the aim to deliver high standards of was debated sustainability; during the 89
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref object to the modifications of the table of standards for hearing CP8 and seeks reinstatement of previous higher sessions and standards for sustainability; the Council has concern that modification undermines the aim for no further sustainable development; and comments. support sustainability standards above national standards arguing submission City Plan version of the policy achieved greater consistency with NPPF para 56,57,65.
Object to Proposed Modifications and seek reduction in The policy is sustainability standards for non residential development considered to Westfield Investments, Colin Brace(153/4); Colin Brace (152/8) be drafted on a seek reduction in sustainability standards for non sound evidence residential development in line with the reduction in base consistent sustainability standards for housing; and with government consider the policy will encourage housing and deter policy for non residential development. sustainable development. Object to Proposed Modifications and seek to remove CP8 because housing standards will be covered by other legislation It is considered Mr D Hunter (75/1); and Ovingdean Estates Ltd, Teale and the policy is Brindley Families (35/4) consistent with Question the need to have a policy CP8 indicating its NPPF and requirements are covered by other legislation. government policy for sustainable development.
Objects to reference to Code for Sustainable Homes Level 5 Acknowledge 90
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref post -2016 due to viability and inconsistency with governments that national Housing Standard Review and intentions for the Code. sustainability Trustees of Toad Hole Valley and Pecla Investments (168/1) standards are in acknowledge the modifications reducing Code flux. The policy Standards; is considered to concern over the updated Combined Viability Study be drafted on a undertaken by the council, September 2014. Concerns sound evidence over the inclusion of housing standards because the base consistent governments Housing Standards Review indicates with NPPF and changes in relation to LPA use of standards, noting that government Government stated that a ‘statement of policy’ would be policy for issued in early 2015 on these; sustainable concern that the Plan will not remain ‘relevant, effective development. and consistent’ beyond Autumn 2015; Flexibility is built THV not likely to commence development until post into plan 2016 when Code Level 5 will be required by CP8. policies to PECLA has shown that Level 5 is unviable; address Concern that use of Code Level 5 standard conflicts with viability. governments intended housing standards for energy given Housing Standard Review and argues there is no justification for including a Code rating. Refers to need to pay careful attention to viability and costs; concern that CP8 is not consistent with this, referencing NPPF 95, 173,174. PM086 CP8 Sustainable No Buildings, page 161 representations amend 2.k to refer received to land pollution and groundwater source protection zones. 91
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref PM087 CP8 Sustainable No Buildings, page 162, representations modification to 4.77 received to reflect changes made to standards. PM088 CP8 Sustainable No Buildings, page 162, representations clarification of received footnote 185. PM089 CP8 Sustainable Object to Proposed Modifications and seek reduction in The policy is Buildings, page 164 sustainability standards for non residential development considered to modifications to Cross Stone Regeneration, Ross Barbour (100/2) be drafted on a 4.83 to reflect . seeks reduction in sustainability standards for non sound evidence changes made to residential development in line with the reduction in base consistent standards in sustainability standards for housing, and with government response to . considers the policy will encourage housing and deter policy for Inspector’s Initial non residential development sustainable Conclusions Letter. development.
Object to continued inclusion of Code for Sustainable Homes Acknowledge standards Lightwood Strategic (117/3) that national . notes Govt Housing Standard Review 2013, Statement sustainability March 2014, Queens Speech June 2014, issuing standards are in statements about intentions for Zero Carbon Homes, flux. The policy Code for Sustainable Homes and Building Regulations. is considered to . Notes decision by Planning Inspector for Bath & NES be drafted on a Plan to remove reference to the Code. sound evidence . Seeks removal of reference to the Code base consistent with NPPF and government 92
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref policy for sustainable development.
Objects to inclusion of minimum standard for Code for Acknowledge Sustainable Homes Level 5 post -2016 due to viability and that national inconsistency with national policy. sustainability Trustees of Toad Hole Valley and Pecla Investments (168/1) standards are in acknowledge the modifications reducing Code flux. The policy Standards; is considered to concern over the updated Combined Viability Study be drafted on a undertaken by the council, September 2014. Concerns sound evidence over the inclusion of housing standards because the base consistent governments Housing Standards Review indicates with NPPF and changes in relation to LPA use of standards, noting that government Government stated that a ‘statement of policy’ would be policy for issued in early 2015 on these; sustainable concern that the Plan will not remain ‘relevant, effective development. and consistent’ beyond Autumn 2015; Flexibility is built THV not likely to commence development until post into plan 2016 when Code Level 5 will be required by CP8. policies to PECLA has shown that Level 5 is unviable; address Concerned that use of Code Level 5 standard conflicts viability. with governments intended housing standards for energy given Housing Standard Review and argues there is no justification for including a Code rating. Refers to need to pay careful attention to viability and costs; concern that CP8 is not consistent with this, referencing NPPF 95, 173,174.
93
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Object to Proposed Modification referring to City Plan Part Two The Council Mr D Hunter (75/4) considers the . objects to reference to future policy in City Plan Part Two withdrawal of being different from CP8 proposed . seeks removal of reference to future policy changes in modification City Plan Part Two unnecessary.
PM090 CP9 Sustainable 1 representation Friends of the Earth Brighton & Hove (174/20) Support Transport, page 166 (support) support acknowledged. Modifications to A.2.c travel plan implementation PM091 CP9 Sustainable 2 support - Friends of the Earth Brighton & Hove (174/26) Support Transport, page 167 representations; acknowledged – B.1 inclusion of 1 support, 1 Valley Gardens as objection No reference to providing coach parking in CP9.B.1 Comment priority route whilst plan seems to encourage visitors which will noted. This increase visiting coaches and need parking (J Bryant does not relate (10/1) ) to a specific modification PM092 CP9 Sustainable No Transport, page representations 168, B.4. received Clarification of Brighton Station Gateway area PM093 CP9 Sustainable 4 J Bryant (10/2); Standard Life Investments (159/2);R Scott Transport, page 168 representations; (180/4); FOE B&H (174/12) B.6 parking 3 objections, 1 Coach parking provision in the city insufficient, need to Comment support address shortage – for example at Black Rock noted. This 94
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Editorial does not relate to a specific modification
Maintain previous comments that additional car parking Comments is essential to bring forward viable delivery of DA1. noted the Attempt to ban further city centre car parks is doctrinaire modifications lunacy – other creative solutions available to manage were for clarity. cars Support Support. There is actually a strong case for arguing that any new car parking in the city centre is unjustified and would make the plan unsound as it will impact on bus Support services and increase congestion and pollution. welcome
PM094 CP10 Biodiversity, No page 177, representations paragraph 4.132 received editorial PM095 CP11 Managing No Flood Risk, page representations 181 received update PM096 CP12 Urban No Design, page 185 representations Update footnote 205 received PM097 CP14 Housing 2 Bouygues Development (24/4); The Hove Civic Society (119/3) Density, page 190 representations; Update para. 4.159 1 support Support modification and retention of this density figure as it Support encourages efficient use of land and therefore a movement welcomed. 95
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref towards meeting the housing need. Desirability of carrying out land use studies on a site by site basis to establish suitable densities in relation to provision Comments of open space. This would ideally mean a planning brief for noted. each identified site to ensure that enough open space is left after the housing has been built. As a minimum, each new planning application should include reference to the open spaces that would be provided to serve the development, and the amount of space should vary with the density of the development. Should look at ways in which new housing and open space could be better integrated so that the new houses surround a common area of open space.
PM098 CP16 Open Space, 2 Support: Rottingdean Parish Council (133/4) Support page 194 editorial representations: welcomed. - 1 support; 1 Parish and City Council need to preserve their open spaces objection and sports fields for the use of the public/future The generations. Need sound City policy to direct what is or is representations not acceptable in development terms for such sites (eg. seek to raise wrong to develop a 120 year sports field). new representations Object: Linden Homes (Guildford) & Cothill Educational Trust to policy CP16 (154/2) and do not relate to the Modifications to CP16 principally include the findings of the specified Urban Fringe Assessment. The Council has not sought to Proposed review the potential for housing within all existing open Modification. space. The evidence base informing CP16’s approach is not justified and CP16 1(a-e) should be and supporting 96
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref deleted and replaced with wording consistent with the policy CP16 is NPPF, para 74 . CP16 is more restrictive than NPPF, para considered 74, especially criterion d which requires active marketing of robust. It site before alternatives considered. This is not justified due accords with the to the significant housing need and concerns over the NPPF, it is robustness of the supporting evidence base which (objector proportionate, considers) is not up to date nor complies with current Sport adequate and is England guidance. The Council should commit to early appropriately review of its Open Space Assessment. The Council’s up-to-date. evidence should be updated and in the meantime, the City Plan should follow the approach set out within the NPPF.
PM099 CP16 Open Space, 5 Object: South Downs Society (25/8); Mr Hunter (75/7); R & S The council page 194 representations: Harper (126/6); Ovingdean Estates Limited (35/6); Linden consider the - Homes (Guildford) & Cothill Educational Trust (154/3) proposed Add reference to 5 objections modifications role of Urban Fringe Modification should be deleted. The modifications allow the adequately Assessment as Urban Fringe Assessment’s ‘developable’ sites to be address the material developed without further consultation on suitability of these Inspector’s consideration as sites. Some of these sites would have an everlasting concerns. criterion at end of negative impact on the setting of the National Park. Urban section 1 - e) Fringe Assessment has not been subject to scrutiny so a The evidence mistake to make a decision solely against it. base informing The amount of housing now proposed within urban and supporting fringe/setting of National Park would cause permanent and policy CP16 and irreversible damage. Development in urban fringe should PM099 is only be as a last resort. considered Object to PM099 and the section related to the urban fringe. robust. It The urban fringe needs to be protected from housing accords with the 97
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref development. Re-word to protect urban fringe from housing NPPF, it is development. proportionate, The Urban Fringe Assessment (that informs the revised adequate / fit for housing targets) is not a sufficient robust document to be purpose and used as a planning policy document. It fails to assess full appropriately potential thus recommends too low a housing figure for up-to-date. urban fridge sites. The Modifications do not go far enough to overcome the Inspector’s initial findings. Site 43 in the Urban Fringe Assessment is indicated to be suitable for low density development of just 6 units. Excludes two sites of private residential garden land (albeit overgrown) which should not be restricted as Natural and Semi Natural Urban Green Space and as a Nature Improvements Area. Both sites benefit from direct road access, neither are of high ecological value, one could provide up to 10 dwellings the other up to 25 dwellings and both with development could create publically accessible open space. Modifications to CP16 principally include the findings of the Urban Fringe Assessment. The Council has not reviewed the housing potential within all existing open space. CP16’s approach is not justified and CP16 1(a-e) should be deleted and replaced with wording consistent with the NPPF, para 74. CP16 is more restrictive than NPPF, para 74, especially criterion d which requires active marketing of site before alternatives considered. This is not justified due to the significant housing need and concerns over the robustness of the supporting evidence base which (objector considers) is not up to date nor complies with current Sport England guidance. The Council should commit to early review of its Open Space Assessment. The Council’s 98
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref evidence should be updated and in the meantime, the City Plan should follow the approach set out within the NPPF.
PM100 CP16 Open Space, 1 Object: Linden Homes (Guildford) & Cothill Educational Trust The comments page 195, editorial representations: (154/4) do not relate to amendments to 2.b, - the specified 2d and 2f. 1 objection Respondent 154 submitted same objection to PMO98-101 – it Proposed is not considered to raise anything that specifically relates to Modification. PM100.
PM101 CP16 Open Space, 8 Support: Bouygues Development (24/4) Support pages 196-197 representations: Modification supported as it enables poor quality open acknowledged. amendments to - 1 support; 1 spaces such as Benfield Valley Golf Course to be opened supporting text to caveated for redevelopment in an appropriate manner. reflect PM099 and support; 6 Modification to 4.174 is essential to bring forward the updated open space objections housing numbers required within the City. Client’s view / needs. intention that urban fringe open space sites can be used for housing and provide higher quality managed public open space. Bringing about significant and demonstrable long term enhancements to the City’s public open space offer. Modification to para 4.175 is key as it identifies that the need for housing is more significant than the need for open space. Evidenced through the gap between the additional hectares of open space required in 2030 being increased from 237 hectares to 293 hectares. The change in open space based on population is also based on two bed units which is likely to decrease to one bed units and also the housing target will restrict population growth.
99
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Caveated Support: Sport England (76/3) The council Support subject to suggested minor amendments to provide consider the clarity (removes double negatives) and ensure Policy is suggested sufficiently flexible. Should a Playing Pitch Strategy identify minor a need for additional pitches, the availability of the urban grammatical fringe sites for housing will need to reviewed. amendments provide clarity and are appropriate.
Object: The Brighton Society (119/13); Friends of the Earth The council Brighton & Hove (174/22); Linden Homes (Guildford) & Cothill consider the Educational Trust (154/5); The National Trust (122/13); Abby proposed Hone (150/1); South Down Society (25/10); modifications Remove reference in paragraph 4.174 re moving uses to adequately within the National Park which is outside the remit of this address the Plan and could cause significant harm counter to policy Inspector’s SA5. concerns. Important not to compromise open space standards by rush to meet housing targets and increased densities. The The evidence increase in dwellings and densities make it more important base informing open space standards meet/are more than minimal and supporting standards. Don’t support the calculation of the open space policy CP16 and requirement of 167 hectares using an average size of 2 PM101 is bedroom units - when 62% of the projected housing need is considered for 3-4 bedroom houses. It should be significantly robust. It increased. Since 2006 there’s been a respective under- accords with the provision of open space, so already a considerable shortfall NPPF, it is to be made up. proportionate, 100
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Modifications to CP16 principally include the findings of the adequate / fit for Urban Fringe Assessment. The Council has not reviewed purpose and housing potential of all existing open space. The statement appropriately at para 4.175 that “a significant increase in open space will up-to-date. Any be required by 2030” is misleading because there is a proposal projected surplus of open space in some areas. (e.g. affecting the Patcham, Hollingbury and Stanmer). If the Open Space National Park Assessment were based on need arising from proposed and/or housing target then the (Wards) open space surplus is likely biodiversity will to be greater than identified in the 2011 update. Underlines need to have need for Council’s evidence to be updated, in meantime, regard to the City Plan should follow approach set out within the policies SA5 NPPF. and CP10 Lack of clear evidence that the National Parks’ sensitive respectively. landscapes and ecology, including National Trust’s recently Other than the restored/recreated habitat sites, can cope with additional minor pressures. Concerned that without a strong initial amendments presumption against off-site provision for open space the suggested by important conservation work that is undertaken within the Sport England National Park could be undermined by over-use of sensitive no further sites. Para 4.174 should be amended ( see representations amendments to for suggested amendments) CP16 are Object to inclusion of active allotment sites as having considered housing potential in the Urban Fringe Assessment necessary. Report/City Plan. Creates tension with long established council policies to protect such sites and promote the working of allotment land. Valuable benefits include reducing food miles and encouraging healthy lifestyles, positive physical and mental health benefits, amenity for local community and ecology. Unclear which policy has 101
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref precedence; development plan process should create clarity rather than confusion. Statutory requirement on Local authorities to provide allotments and actively used sites should be protected in local development plans and not identified for other land uses. Urban Fringe Assessment (UFA) site 31 has a waiting list and catchment is wide so shouldn’t assess against local open space supply. UFA appears to be hastily produced desktop study with little local knowledge. It suggests new allotment sites could be created on the lower slopes of [site] 31b to the west. This land is wooded, being developed as a local nature reserve, is designated as open access land under the Countryside and Rights of Way Act 2000 and so could not be used in mitigation. Modification should be deleted. The modifications allow the Urban Fringe Assessment’s ‘housing potential’ sites to be developed without further consultation on suitability of these sites. Some of these sites would have an everlasting negative impact on the setting of the National Park. Urban Fringe Assessment has not been subject to scrutiny so a mistake if decision made solely against it. (NB comments re PM064 : The amount of housing now proposed within urban fringe/setting of National Park would cause permanent and irreversible damage. Development in urban fringe must ONLY be as a last resort.)
PM102 CP17 Sports 5 Support: Rottingdean Parish Council (133/6) Support Provision, page representations: Parish and City Council need to preserve their open spaces welcomed. 200-201 - 1 support; 1 and sports fields for the use of the public/future caveated generations. Need sound City policy to direct what is or is 102
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Add reference to support; 3 not acceptable in development terms for such sites (eg. role of Urban Fringe objections Wrong to develop a 120 year sports field). Assessment as material Caveated Support: Sport England (76/4) The council consideration as Support subject to suggested minor amendments to provide consider the criterion at end of consistent wording and ensure the Policy is sufficiently suggested section 2 and flexible to take into account future Playing Pitch Strategy minor findings. amendments provide clarity and are appropriate.
Object: South Downs Society (25/9); Bouygues Development The council (24/6); Linden Homes (Guildford) & Cothill Educational Trust consider the (154/6) proposed Modification should be deleted. The modifications allow the modifications Urban Fringe Assessment’s ‘housing potential’ sites to be adequately developed without further consultation on suitability of these address the sites. Some of these sites would have an everlasting Inspector’s negative impact on the setting of the National Park. Urban concerns. Fringe Assessment has not been subject to scrutiny so a mistake if decision made solely against it. (The amount of The evidence housing now proposed within urban fringe/setting of base informing National Park would cause permanent and irreversible and supporting damage. Urban fringe development should only be as a last policy CP17 and resort.) PM102 is Whilst the Urban Fringe Assessment (UFA) should be used considered as a helpful guide re locations for residential development, robust. It the housing figures are low and it is not considered accords with the 103
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref appropriate for the UFA to be a material consideration due NPPF, it is to the lack of public consultation undertaken on the proportionate, document. adequate / fit for Delete the bullet points at part 2 of the policy and replace purpose and with wording consistent with paragraph 74 of the NPPF. appropriately PM102 amends policy wording to reflect the Urban Fringe up-to-date. Assessment (2014) (NB comments re CP16 indicate the Other than the Council has not sought to review the housing potential of all minor existing open space). The policy tests are more restrictive amendments than the NPPF. This approach is not justified given the suggested by significant housing need and lack of robust evidence base. Sport England (NB comments re CP16: supporting evidence base is not no further up to date nor complies with current Sport England amendments to guidance. The Council should commit to early review of its CP17 are Open Space Assessment). considered necessary.
PM103 CP18 Healthy City, 1 Friends of the Earth Brighton & Hove (174/23) page 206 representation; Support. Support 1 support welcomed. Modification to part 3 of policy to- minimise negative impacts PM104 CP18 Healthy City, No page 206 representations received Insert footnote reference to lifetime 104
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref neighbourhood principles PM105 CP18 Healthy City, 2 Friends of the Earth Brighton & Hove (174/24) Rottingdean page 207 representations; Parish Council (133/5) 2 support Support, however, there is a question about whether the Support Add reference to air wording on air quality needs to be tightened in light of welcomed and quality issues at the recent Court of Justice of the European Union ruling comment noted 4.197 that there is an obligation to address legal limits as soon See response to as possible. PM014. Support - to comply with UK and EU air-quality standards and avoid prosecution and resident ill health. A clear statement and requirement about air-quality impact upon existing locations and cumulative effects can only help and strengthen the City's drive towards a healthy and more sustainable City and BHCC locations like Rottingdean High-Street PM106 Policy CP19 5 Support Housing Mix, page representations; Hove Civic Society (7/9); North Laine Conservation Area 209, 210 4 support, 1 (13/7); Bouyges Development (24/7), Friends of the Earth Support object. Brighton & Hove (174/25) welcomed. Add new criterion a.iii) in relation to Object The Council minimum dwelling R Scott (180/2) considers the standards The proposed ‘Modification’ appears to need re-wording, re- wording to reflect the applicability of HCA Space Standards proposed required of ‘Registered Providers’. unnecessary.
PM107 CP21 Student 7 Accommodation and representations; University of Sussex (166/8; 116/9) Support Houses in Multiple 3 support No objection to the modification of part (i) A6 or part (ii). welcomed 105
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Occupation, page 1 partially 217, 218, policy support Change to part (i) A7 is understood but considered to Change is wording 3 objection place more restrictions on the potential to deliver further intended to modifications to purpose built student housing which, itself, has the clarify policy clarify A.6 and A.7. potential to free up more housing stock to serve rather than alter resident’s need. Not supported. the approach.
Westfield Investments Ltd/Colin Brace (153/4) The qualification criteria listed are difficult to satisfy and could stymie new student accommodation schemes This was being approved. The requirement to have a formal addressed at agreement with one of the city’s two Universities or the Hearings other existing educational establishments could and as set out in unnecessarily restrict developments being approved. the Matter Firstly, the Universities require developments to comply Statement with their own lower price structures which don’t allow (BHCC -10 for higher spec accommodation (thereby limiting market Matter choice). Secondly, the Universities are themselves Statement 4b) developers of student accommodation and will not the council always support proposals on competitor sites. considers that the City Plan includes If landowners are aware that nominating sites as part of adequate and the SHLAA process would restrict them from being appropriate considered for student accommodation, it may hinder mechanisms to the number of potential housing sites coming forward. enable the Criteria 7 of CP21 does not allow for situations where provision of planning permissions for housing are extant but have student housing not been implemented for reasons such as financial whilst balancing 106
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref viability. this type of The Article 4 Direction is likely to result in a greater need housing with the for purpose built accommodation in the five wards need to provide and/or a wider spread of C4 style student for other types accommodation in neighbouring wards of housing within the city. Select Property Group Ltd (165/1) The potential for SPG does not enter into formal agreements with concentrations universities or other educational establishments. of purpose built Therefore the proposed modification could create a accommodation reason for refusing a development that meets an is noted and the important need for student accommodation. Former Council will wording more appropriate and justified. propose a minor modification clarifying that The additional wording to Criterion 7 "allocated for cumulative housing or" is an unnecessary and unjustified addition to impact is a the policy. The addition of these words duplicates the planning text in footnote 248 that states that sites identified as consideration in potential housing sites "will include those identified in the other City Plan policies and those listed in the SHLAA. determination of In adding these words, Criterion 7 sets a far stronger applications. policy test that is not justified by the need to balance the Change is provision of housing against meeting the needs for intended to student accommodation. clarify policy rather than alter Support the approach. University of Brighton (167/2), Friends of the Earth (174/7) North Laine Community Association (13/3)
107
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Support It is important to be able to provide housing for residents
Support welcomed
PM108 CP21 Student 1 representation No objection. University of Sussex (116/10) Support Accommodation and received, 1 welcomed. Houses in Multiple support Occupation, page 219, updates at paragraph 4.225 and new footnote.
PM109 CP21 Student 1 No objection. University of Sussex (116/11) Support Accommodation and representation; welcomed Houses in Multiple 1 in support Occupation, page 220, clarification of assessment, paragraph 4.234
PM110 CP22 Traveller No Accommodation, representations page 223, update received footnote 254 PM111 Appendix 1 No Glossary of terms, representations 108
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref pages 226, 228, received 229, update glossary PM112 Appendix 2 Key No Diagram, page 233, representations editorial updates to received Key diagram PM113 Annex 1 – No Implementation and representations Monitoring Plan – received modifications and updates to address Inspector’s Concern (July 2013) PM114 Annex 2 – No Infrastructure representations Delivery Plan – received updates related to Flood Defences - Shoreham Harbour Development Area; Waste and Wastewater PM115 Annex 2 – No Infrastructure representations Delivery Plan received addendum reflecting analysis of infrastructure requirements 109
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref relating to urban fringe identified as potential for housing. PM116 Annex 3 – Housing 6 Achievement of Planned Housing Delivery; Housing Trajectory, Implementation representations; 5 year housing supply. Strategy – 6 objections (not Linden Homes (154/5), Buoygues Development (24/1), modifications and all direct to HIS Brighton Society (119/10), Lightwood Strategic (117/2), Mr D update to reflect role but raising Hunter (75/4), AEGON UK (169/1) of urban fringe, issues of Housing increased windfall relevance to the Housing trajectory implies a step-change in housing trajectory and allowance, SHLAA HIS). delivery increasing from 436 in 2013/14 to 655 in council’s updates. 2014/15. The presentation of the trajectory in five-year approach to bands does not make it possible to understand whether housing delivery this step change is actually deliverable. as set out in the Council needs to be more proactive towards housing Housing delivery in order to achieve its housing trajectory, e.g. Implementation greater housing delivery on some of the urban fringe Strategy (Annex sites would boost supply (e.g. Benfield Valley, Meadow 3) is considered Vale Ovingdean). realistic, robust The land supply buffer should be 20% given the city’s and based on land supply problems. up to date The increased figure for windfall provision is more evidence realistic than before but probably too conservative. including Disagree with the Council’s approach to calculating a dialogue with five year supply requirement based on its housing developers. trajectory and particular nature of housing supply.
Sustainability 16 Objections / comments received 110
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref Appraisal representations. 16 representations received linked to Proposed Modifications – PM010, PM019, PM064, PM072 9 directly objecting to the 1) Comments on the actual Sustainability Appraisal SA. a) SA is not legally compliant 7 comments not (Ovingdean Residents & Preservation Society 95/1; Deans SEA/SA of specific to the Preservation Group 96/1; The Vale Residents Society 130/1) individual urban SA, but The supplementary SEA only deals with the fringe sites will submitted under amendments to SA4 in broad terms and fails to assess take place as the SA question. whether the proposed locations and quantum of part of further development at each of the proposed urban fringe sites work as set out in the UFA is justified. SEA/SA of the undertaken at proposed City Plan 1 is defective because it is contrary Site Allocations to Regulation 12(1) of the 2004 Regulations: stage (City Plan (i) It fails to assess alternative urban fringe sites or other Part 2). indeed any combinations of development other than that identified in the UFA; (ii) It fails to describe the likely significant effects of developing each site in the manner identified in the UFA; (iii) It fails to provide reasons for explaining why those sites were identified and why that level of housing was considered for allocation beyond merely pointing-out they were identified within the UFA. Adoption of the City Plan 1 would be in breach of SEA/SA has Regulation 8(1) of the 2004 Regulations, as a key plank assessed of the housing strategy (development of the urban development on fringe) has not been properly assessed. the urban fringe in broad terms. 111
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref b) General comments on SA (Phil Belden 6/1; Phil Belden 6/2; Dave Bangs 140/2; V Del SA 2011 (Policy Federico 146/1; G Del Federico 149/1; Lindon Homes 154/1) Options stage) SA has considered the implications of releasing 108Ha assessed of existing open space within the urban area (32% of options which total supply) but has not assessed a more limited included a more release of open space. limited release of urban open space. Sustainability Appraisal cannot be taken seriously as Local Plan strategy is unsustainable. The City Plan Part 1 has been Cannot see how the SA has been done as the Local subject to an Plan is not sustainable. adequate and robust SA. SA is poorly informed. SA undertaken SA is impenetrable and difficult to navigate for a using available layperson guidance and data. 2) Other Comments (not specific to SA) Nb. PM number in brackets indicates the PM under which the SA included a representation on the SA was submitted. Non Technical Summary. a) General comments on potential impacts of housing: (BH Wildlife Forum 112/1) Concern that the city will become increasingly urbanised Comments having an adverse impact on environment particularly noted. wildlife. (PM064) Further major development will increase pressure on Infrastructure 112
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref existing infrastructure. (PM064) Delivery Plan addresses b) Urban Fringe site specific comments infrastructure (Roedean Residents Society 58/1; John Locke 94/2; Sarah requirements. Wilkinson 138/2; Sean Flanagan 60/1; R&S Harper 126/1) Transport issues in Roedean include poor bus service Comments and all-day car parking. Cycling not an option due to noted. location. (PM064) No recognition of existing biodiversity in the Coombe Comments Vale/Coombe Farm/Westfield Avenue site. (PM064) noted. Inclusion of the site at Hollingbury Park for housing is Comments based on a flawed consultants report. Site should be noted. deleted. (PM064) Housing development on urban fringe sites would lead Comments to isolated communities (includes reference to recent noted planning applications in Saltdean and Ovingdean) (PM072) Additional housing cannot be accommodated in a Comments sustainable way without detrimental impact on the noted. environment (Benfield Valley) (PM010)
c) Other site specific comments (Roedean Residents Society 58/2) Infrastructure Amount of housing planned unsustainable. Additional Delivery Plan infrastructure requirements of additional housing barely addresses addressed (PM019.) infrastructure requirements. d) Making better use of brownfield sites (BH Wildlife Forum 112/1) Critical that better and more imaginative use of Comments 113
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Mod Mod Representations Response Ref brownfield land is made such as: allowing retail high noted. street areas to become residential in recognition of increasing internet shopping; better use of industrial/business park areas such as The Goldstone Retail Park and the Pavilion Retail Park; back-garden development. (PM064) Should re-use brownfield before any Greenfield Comments development takes place. (PM064) noted.
Table 2 – General Comments not related to specific proposed modification
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Response Mod Mod Representations Ref General General comments 14 Support Comme made against Plan/ representations, Support proposed modifications and in particular Support welcomed nts or comments made 3 no comments, increased housing land supply (Lewes District as to whether 1 support, 10 Council (20/1) proposed objections modifications as a No Comments 114
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Response Mod Mod Representations Ref whole have addressed previous Generally the changes do not appear to impact concerns significantly on the natural environment and we have no comment. Clearly the most substantial impacts may arise from the preparation of City Plan Part Two and we look forward to early engagement in the plan making process and the challenge of meeting the needs of the City whilst seeking to protect and enhance the natural environment (Natural England 111/1). Comments noted Reiterate previous comments we made on your submission plan, where we support the inclusion of various policy criterion and reference to the sensitivity of groundwater protection within the Plan Area. It is important to include these criteria, because the Urban Fringe, together with the built up area of the city overlies a principal aquifer. There are also a number of Source Protection Zones present which service public water supplies (Environment Agency 104/1).
No comments to make on legal compliance Trustees of Toads Hole Valley and Pecla Investment (168/1)
No comment (Marine Maritime Organisation (98/1)
Objections
Colin Brace (152/5, 152/6, 152/7); St James Street Community Action Group (170/1); North Laine Arts (12/1); 115
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Response Mod Mod Representations Ref MJH Stimpson (69/1); R Scott (180/1;180;5) National Planning Policy Guidance now states that Comments noted. affordable housing contributions should not be Modifications may required for developments of 10 units or less. Parts b) be required to and c) of Policy CP20 need to be amended to reflect CP20 to reflect the the new guidance set out in the NPPG. new guidance.
Little reference if any to the development of the St Comments noted. James Street area in the City Plan – a growing and This objection vibrant part of the city yet completely ignored whilst does not relate to other areas receive funding and attention. This should a proposed be rectified. modification. Concerns with massive increase of traffic with recent development and how this has been dealt with. Rather than heavy investment in buses a better plan would have been tram and/ trolley bus system. Comments noted Housing stock not keeping with need. Better housing – they do not maintenance and more assistance for older people; relate to a better maintenance and coordination of public proposed buildings. Need for a proper post office on Western modification. Road. Policy CP21 identifies five locations suitable for As set out in the purpose built student accommodation; the number of Matter Statement bed spaces identified for each site would not meet the (BHCC -10 Matter identified student housing need when combined with Statement 4b) the existing accommodation (circa 32,000). council considers that the City Plan includes adequate and appropriate mechanisms to 116
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Response Mod Mod Representations Ref enable the provision of student housing whilst balancing this type of housing with the need to provide for other types of housing within the city. Request that more flexibility is introduced to the appropriate policies in order to avoid onerous financial Issues of viability obligations and impeding the deliverability of new and deliverability housing developments. This dense layering of were discussed at development plan policies in City Plan Part 1 and the examination when prepared, additional policies in Part 2 will form hearing and the the basis for seeking planning obligations during the Council has no development control process including financial further comments contributions towards open space and recreation facilities, highway infrastructure, education facilities, public art, and the local employment scheme. Such contributions are often excessive and result in residential developments becoming unviable and planning consents not being implemented. Whilst the viability of proposed developments is often reviewed by the District Valuer on behalf of the City Council, this is a lengthy process which often adds significant delays to the determination of planning applications. Objection relates to the identification of Land at Fox Way/ Foredown Hill, Portslade in the Submission City This objection 117
Appendix 5 Brighton & Hove City Plan Part One – Proposed Modifications Schedule – Summary of Representations
Prop Summary of Prop Number of Summary of Key Issues expressed in the Representations Officer Response Mod Mod Representations Ref Plan as open space as shown on policies map and does not relate to safeguarded by CP16 Open Space. Site is subject to a proposed a Section 52 Agreement dated 17 June 1990 which modification. requires part of site to be reserved as community site and the majority of site allocated for commercial development albeit no interest has come forward for the later use. Given this agreement and lack of interest for commercial uses the whole site should be allocated for housing. Considers the changes requested to the Plan at submission/ during examination hearings should have been addressed in the proposed modifications: The need to withdraw the city plan from examination and prepare and consult on a single plan Concerned with lack of progress in preparation of Part 2. These issues were Additional policies required. Inadequate dovetailing of debated during the City Plan with current/ emerging plans of adjoining hearing sessions local authorities and county council to address city’s and the Council housing need. Fail to maximise residential has no further development potential in the triangle Lewes- comments. Newhaven-Brighton.
118