Brighton & Hove City Plan Examination 2013 Hearing Session: 23 / 24 October 2013 (AM/PM) STATEMENT IN RESPONSE TO Matter 3a: Development Areas: DA1- DA4 BY BRIGHTON & HOVE CITY COUNCIL Matter 3a: Development Areas Statement by Brighton & Hove City Council 8th October 2013 List of Abbreviations AMEX American Express BACA Brighton Aldridge Community Academy BCEC Bridge Community Education Centre CDIT Creative, Digital and Information Technology CIL Community Infrastructure Levy CPVS Combine Policy Viability Study DA Development Area DPD Development Plan Document DA Development Area ELS Employment Land Study Review 2012 HEIA Health and Equalities Impact Assessment HDtCS Housing Study Duty to Co-Operate May 2013 IDP Infrastructure Delivery Plan LDF Local Development Framework LDS Local Development Scheme LDD Local Development Documents LEP Local Enterprise Partnership NPPF National Planning Policy Framework SA Sustainability Appraisal SDNP South Downs National Park SECAmb South East Ambulance Foundation Trust SHLAA Strategic Housing Land Availability Assessment SO strategic objective SPABDB South Portslade and Aldrington Basin Development Brief StA Strategic Allocation VTBP Viability Technical Background Paper VTSS Viability Testing Strategic Sites 2 Matter 3a: Development Areas Statement by Brighton & Hove City Council 8th October 2013 Index: Page Introduction 4 Matter 3a Questions: Matter 3a question i) 4 Matter 3a question ii) 8 Matter 3a question iii) 11 Appendices: Appendix 1: 13 List of Key Background Documents Appendix 2: 14 Respondents and summary of comments Appendix 3: 19 The Strategic Objectives each Development Area will help to directly meet Appendix 4: 20 Site specific justification for each Strategic Allocations within DA1-DA4 Appendix 5: 23 References Appendix 6: 27 Brighton Marina Inner Harbour Capacity Assessment Appendix 7: English Heritage Statement 3 Matter 3a: Development Areas Statement by Brighton & Hove City Council 8th October 2013 Introduction 1. This statement presents the Council’s evidence in relation to the key issues raised by the Inspector concerning Development Areas; DA1 – DA4. The endnote references are provided in Appendix 5. 2. The council’s evidence regarding the DAs is included fundamentally in all the Core Documents however the most notable documents are listed in appendix 1. 3. A list of respondents and key points/objections raised are provided in appendix 2. Matter 3a.i) Is the scale and mix of development proposed for the Development Areas (DA1 – DA4) appropriate to those areas and will the proposals assist in meeting the strategic objectives of the City Plan? Overview 4. The Area Assessments (June 2008)1 provide the background and initial justification for the approach taken to the DAs. Early considerations included accessibility2, urban character and regeneration. As a result the DAs are located within accessible areas with a potential for additional development/regeneration3. The assessments were informed by other evidence including the Tall Building Study 20034, which identifies the urban DAs as being suitable for taller/higher density development. Though evidence underpinning these studies is pre 2008 or has been updated, the basis for identifying the DAs and key priorities for the areas remain fundamentally unchanged. 5. The Council’s Matter 2 Statement : Overall Spatial Vision addresses the evolution of the DAs in relation to the overall spatial strategy and highlights the key documents5 which justify how the DAs have evolved since the initial area assessments. 6. The scale and mix of development within the DAs has been informed by the evidence/documents outlined above and has taken account of : the existing uses within and key characteristics/priorities of an area (as detailed in the policy); the objectively assessed needs of the city (e.g. Employment6, Retail7, Housing8, Open Space9); development briefs10 which engaged the landowner/development in their preparation; Planning Applications; Urban Characterisation Study11 , capacity12 and viability13 assessments; engagement with land owners, developers, stakeholders and residents; and 4 Matter 3a: Development Areas Statement by Brighton & Hove City Council 8th October 2013 Annual SHLAA14 updates – these have identified sites with housing potential and assessed when they are likely to be delivered over the plan timescale and have informed the overall residential capacity of the DAs. 7. The city wide policies apply to all development proposals including those in the DAs. It is therefore considered a general reference within the DAs to affordable housing, housing mix, flood risk, protection of heritage assets etc is only required if there is a site specific exception. 8. The DA proposals are key to meeting the Plan’s strategic objectives (SOs) directly as outlined in Appendix 3. 9. The Council’s response statement to Matters 4, 5 and 6 provide further evidence in relation to the DAs. The following paragraphs address specific issues relating to the scale and mix proposed for DA1-DA4. DA1 10. DA1 seeks the replacement of the Brighton Conference Centre and allows for the redevelopment of Churchill Square. It is a key priority of the council that this site is redeveloped15. 11. The area is in need of regeneration. The scale and mix of development proposed for the area reflects the considerations/documents detailed above (paragraphs 4-9) and the Retail Studies 200616 and 201117 which identify this area as a focus for directing additional retail capacity. 12. Representations requested a number of detailed wording changes. The council has published modifications to address some of the points made by Standard Life. Representations made in respect of policy CP4 are also relevant (see Council’s Matter Statement 6: Retail). DA2 13. A key objective of DA2 is the comprehensive regeneration of Brighton Marina, with significant improvements in the transport infrastructure and public realm. The development area will make an important contribution towards addressing the city’s assessed housing, employment, retail, leisure and tourism needs18. 14. The scale and mix of proposed development reflects the area masterplan and other background evidence19 which has identified the Marina and wider area as a suitable location for significant mixed-use, higher density development. Additional technical work on the capacity of Brighton Marina Inner Harbour area (see appendix 6) has been undertaken in response to comments made by respondents. It indicates that there is 5 Matter 3a: Development Areas Statement by Brighton & Hove City Council 8th October 2013 sufficient capacity for 1000 residential units below the cliff height within the Inner Harbour Area. A statement of common ground has been prepared by X Leisure and agreed by the City Council and includes some main modifications to DA2 to resolve areas of difference. An area of disagreement remains the restriction of development below the cliff height. The city council considers this should be retained to protect the historic environment of Kemp Town and Kings Cliffe; and to protect views from the SDNP. See the proof of evidence relating to design presented on behalf of the council to the planning inquiry (Sept 2009 ) relating to the proposed development at Brighton Marina (appendix 7, p 29) 15. Whilst two respondents20 concerning the Gas Works site, seek the inclusion of retail within the specified mix for the Gas Works site, this is contrary to the NPPF, would be contrary to the City Plan’s retail strategy (informed by the Retail Study21), has not been justified (in terms of impact on local and district centres) and would undermine the employment role of the area22. 16. One respondent23 has challenged whether the Black Rock site has the capacity to accommodate 7,000 sq m of leisure and recreation related uses within the boundary of the strategic allocation. However, the council has evidence relating to a previous proposal for the site24 which demonstrates that the site does have capacity for the scale and mix of development proposed. 17. Representations on DA2 requested a number of detailed wording changes. The council has published modifications MM7 to address some of these points. Further proposed modifications are summarised in the Statement of Common Ground with X-Leisure. DA3 18. The strategy for DA3 Lewes Road is to consolidate and expand the area’s status as an academic corridor; enable sustainable development that supports the growth of the city’s universities; and improve sustainable transport links and the public realm along Lewes Road. 19. The scale and mix of development proposed for the area reflects the considerations/documents detailed above (paragraphs 4-9), viability work on the Preston Barracks Site (leading to changes), the planning brief for Preston Barracks/University of Brighton25 and student housing reports26. 20. MM8 clarifies the suitability of all B1 uses for Woollards Field, in response to the representation by SECAmb27. 21. Falmer Released Land is suitable for a range of uses, and the policy ensures that redevelopment would provide permanent accommodation for community uses and parking related to the Community Stadium. Representations have been made by The Community Stadium Ltd 6 Matter 3a: Development Areas Statement by Brighton & Hove City Council 8th October 2013 seeking rteference to a hotel use in DA3 and clarification on uses of the Falmer Released Land28. MM78 clarifies that the range of uses does not need to be met in its entirety. CP6 on visitor accommodation