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