We’re urging Brighton & Hove City Council to refuse permission for the Toads Hole Valley development when it is reconsidered on 25 May, 2022, due to it undermining key local and national targets. This is the city’s biggest greenfield site and was meant to be an exemplar of sustainable development. Instead it is a shining example of everything that is wrong with transport planning: the development will unnecessarily increase traffic, congestion and pollution within the city.

The city has the ambition to be net-zero by 2030, supported by both Labour and the Greens, yet this development will undermine that. It will increase emissions from transport, when it is likely we will need to reduce traffic in the city by around 25 – 50% to meet this target.

The proposed bus service is inadequate, even before concerns that the money set aside for it will remain sufficient due to rapidly rising inflation. There are also no safe cycle facilities connecting the development with the city, and their future development is prejudiced by the main junction design.

The Travel Plan for the site is set to lock in polluting travel behaviour. Its level of ambition so poor, that it will undermine the Government target for over a half of all journeys in urban areas to be walked and cycled by 2030. Nearly one quarter of all the homes in the first phase will have no access to public transport or cycle infrastructure except into the National Park. This will lock them into car-based lifestyles. The rest of the development will fare little better.

Chris Todd of BHFOE said:

“The usual obsession with modelling traffic levels, without first aiming to maximise a reduction in car use has resulted in the all too familiar results: rising traffic, increased pollution and congestion, and scarce resources being wasted on building bigger junctions. We need a different approach.

“How can a development in the 21st century have no cycle links into the city and not come with a high frequency bus service? The fact that the highways authority appears to have completely ignored these issues is even more worrying. It provides bland reassurances that further improvements can be sought later on, but the junction design for the main entrance will prejudice links to Nevill Road and elsewhere.

“The Travel Plan, while containing an impressive list of actions, is effectively admitting failure with its very weak targets and expectation of huge car dependency. While it will encourage new residents to reduce car use when they move in, they can only do that if there are safe and attractive options. Nearly a quarter of the residents won’t have access to any cycle or bus links into the city when they move in, while the rest will only have access to an inadequate bus service.

“For people to even consider calling this an exemplary sustainable development is beyond belief. It is a massive wasted opportunity which will cause great harm to the city with more traffic and pollution. What is most shocking is that the lack of scrutiny of transport issues has left the Planning Committee in the dark. This will have skewed their conclusions last time and could skew them again. The development should be rejected until these critical issues are resolved.”


Anyone who knows Hollingbury hill fort knows how the surrounding area is intensively used by walkers, joggers, golfers, dog walkers and children playing around. When it snows, a rarer occurrence nowadays, the valley (part of the golf course) near Burstead Woods is a popular tobogganing spot.

To treat the golf course as somehow separate or different to the surrounding downland is a nonsense as anyone from the nearby local communities will tell you. Yet this is the problem we are faced with within Brighton & Hove City Council. They see the golf course as purely a golf course and therefore the only thing they can do with it is re-let it as a golf course.

While this might not seem to be a problem, after all it works perfectly well now doesn’t it?, is that first impressions can be deceptive. The main issue is the state of the ancient chalk grassland, a rich and diverse and increasingly rare habitat, found few places in the world and now only covering 4% of the South Downs. To manage it properly, it really needs grazing to be reintroduced. The problem is, the hill fort now appears as such a tiny island surrounded by the golf course right up to its edges that to graze it isn’t really viable. It needs the golf course to be reconfigured to enable a viable (large enough) grazing unit to be established.

There is also the issue of creating safer access to the hill fort from the south and west which currently involves having to negotiate flying golf balls. While it’s not normally a problem it does deter people from using the area. And then there’s the fact that the hill fort is one of the city’s most important archaeological sites.

We’ve been working with lots of other groups in the Brighton Downs Alliance and Extinction Rebellion on this. We have asked to appear at the Council’s Policy and Resources Committee on Thursday (23rd) to ask a question about the site. Other groups have also asked to speak. We believe there is a better way forward, if the Council has the will to sort something better out. We’ve sent a briefing to all councillors spelling out our concerns. Given the loss of such important biodiversity and keen public interest, we believe the Council should do the right thing, not just the easiest thing.


Highways England are consulting on six options for a new A27 Arundel Bypass. Unfortunately, they haven’t learnt from their past mistakes. All they have done is tweak their proposals for a highly damaging 70mph dual carriageway.

Demand something better at Arundel.

The Global Climate Strike is happening on 20 September. Young people have been leading the fight against the climate crisis – striking from school to demand the government takes urgent climate action.

We’ll be taking part in the strike here in Brighton. Can you join us on the day? We’ll have placards you can use and (if you’ve worked up an appetite) we’ll go for lunch together afterwards.

Find out more and let us know you’re coming.



Access to Dyke Trail – currently no plans to improve this important link

That’s what developers are saying to people who will live in the new housing at Toads Hole Valley. If you are concerned about climate change and want to reduce your transport carbon emissions then you could find it quite challenging.

Currently, surface transport is responsible for 23% of all the UK’s carbon emissions and is the only sector, along with aviation, whose emissions have risen since 1990. The Committee on Climate Change has said that there should be a 10% shift from cars to more sustainable transport, while others have said there needs to be greater traffic reduction.

Yet for the Toads Hole Valley developers, it’s business as usual. You wouldn’t have thought there was a climate emergency. While they have incorporated some cycle facilities and the site will be served by a bus, their lack of confidence in these measures is demonstrated by the low travel plan target: only 40% of people will walk, cycle, or catch the bus and train in their new development. Little different to what people currently do in the area. Yet with a new development, with the right infrastructure and services, you have a once in a lifetime opportunity to re-frame people’s travel behaviour. They should be aiming for 50 – 60% of people travelling by sustainable means. It’s possible but why the lack of ambition?

As an example of what the developers are proposing, they have come up with a 5 stage crossing over the A27, round a chicane, through a gate, and if you want to cycle on the road out to Devil’s Dyke, you have even more obstacles to negotiate. It would be worthy of a challenge for Indiana Jones himself. Unfortunately, they have designed much of the walking and cycling infrastructure like this while for cars they have made it really easy to drive absolutely everywhere. It doesn’t take a brain surgeon to work out that the car will rule in the new development and carbon emissions will not be reduced by anything like the amount they need to be. We are calling for all concerned to work with us and other stakeholders to come up with something much better, something that can truly be called an exemplar development.

BHFOE 2nd objection to Toads Hole Valley application
Toads Hole Valley – suggested road and access changes

Brighton Kemptown and Peacehaven MP Lloyd Russell-Moyle has now also pledged his support to tackle plastic pollution.

We’re aiming to meet all three of Brighton & Hove’s MPs to share our concerns about environmental damage caused by plastic.

Thank you Lloyd, for your support for a Plastic Pollution Action Plan, backed by legislation to protect wildlife and human health.



Peter Kyle, MP for Hove, has pledged his support for a Plastic Pollution Action Plan, backed by legislation to protect wildlife and human health.


We met with Peter as part of our plan to share our concerns about environmental damage caused by plastic with all three of Brighton & Hove’s MPs.

It’s fantastic to have Peter’s backing for an action plan, which would begin phasing out unneeded plastics now, and look to end pollution from hard-to-replace plastics (like car tyres, paints and clothes) as soon as possible.

Sir David Attenborough’s Blue Planet II has hammered home the tragedy of plastic pollution in our oceans. Up to 12m tonnes  of plastic ends up in the sea each year – not far off the weight of a million London buses.

Sea creatures can get tangled up in plastic – or mistake it for food. The effects can be fatal. Harmful chemicals linked to plastic have been found in species from plankton to dolphins.

It’s time to make a change. Thank you Peter, for your support.

We hope to meet with our other MPs soon. If you’d like to be involved please get in touch or sign our petition – making sure to sign up for our email list.

Toads Hole Valley is the largest greenfield site in Brighton & Hove allocated for development. It was left out of the South Downs National Park after it was severed from the downland when the A27 bypass was constructed. Currently there is an application to build 880 homes, a secondary school, business units, a community centre, doctor’s surgery and local shops.

Whilst not against the development of Toads Hole Valley in principle, we have objected to the current proposals on transport and climate change grounds. In particular, the failure to properly cater for pedestrians and cyclists. The development will encourage car use, even with a bus serving the site, because it is all too easy to drive from one part of the development to another. Therefore, we believe the development fails to conform to the Local Plan and national policy.

This site offers us a once in a generation opportunity to do something really quite special. Unfortunately, while there are some good aspects to this proposal, it is badly let down by its layout. The provision for people who want to walk and cycle is also poor. It will place pedestrians and cyclists in conflict on shared paths deterring people from leaving the car at home.

There is an urgent need to reduce carbon emissions, as we have seen by the recent youth marches and numerous scientific reports. Transport is the one area where we are failing, and failing badly. Yet this development, rather than offering solutions for the future, will lock in the bad habits of the past. This will make it harder for us to tackle climate change, not speed us towards the path we need to take.

The local shopping centre and doctor’s surgery need to be placed, near the community centre, closer to the heart of the community, so that it is easier to walk and cycle there. Pedestrian and cycle facilities need to be segregated to improve comfort, safety and attractiveness. While crossings need to be simplified. Currently the main junction has five separate stages for pedestrians and cyclists to cross to reach the southern side of Goldstone Crescent. Cars only have one. This is hardly prioritising walking and cycling as required by national planning policy.

There is no excuse for not getting this right and we hope the developers will take on board these concerns and amend the application to produce something that is truly groundbreaking.

More reading: BHFOE objection to Toads Hole Valley application

We’re urging Brighton & Hove City Council to approve phase 3 of the Valley Gardens scheme at today’s meeting (7 Feb) of the Environment, Transport and Sustainability Committee. The Council will be asked to approve the plans, which we believe are a vast improvement from those that were consulted on last year. We welcome the way that the Council has listened to residents and altered the scheme quite significantly to address people’s concerns.

We believe the plans offer an exciting glimpse of the changes we could see on the seafront and in the Old Steine. For the first time ever, the seafront cycle lane will connect to Lewes Road, while pedestrians will have direct and attractive crossings and enhanced public spaces. We’re particularly pleased that the promenade west of the Palace Pier will be significantly widened to ease congestion in this area (see picture above taken on a cold winter’s day). Buses will also be better accommodated with a new southbound bus lane and stops. The public consultation showed strong support for the improvements and it’s right that they should now be implemented.

While some people are still unhappy, we believe many of their concerns are unfounded or exaggerated. For the last 30 years Brighton tourism bosses have predicted the demise of the economy every time some minor restriction on cars was made, yet the city remains in rude health. On air quality, the scheme shouldn’t increase pollution overall, while congestion is unlikely to be significantly worse than it currently is.

Quite simply we cannot afford to keep the Aquarium roundabout and current road layout. Other cities are creating new and exciting public spaces and if Brighton doesn’t do the same it will lose out in the longer term. At the same time, health bodies have long called for these sorts of improvements to address the huge impact that obesity is placing on society and the NHS. We need to change the way we move around the city, both for our health and the economy, and this project will help kick-start that change.

Last week West Sussex County Council wrote to a number of objectors to its proposals to dual the A2300 (between the A23 and Burgess Hill).  It has replied to us but provided no real reassurance it knows or cares what it’s doing.  For example, it has claimed in a letter to Bricycles, the Brighton & Hove Cycle Campaign group, that: “Any form of controlled crossings such as toucan or Pegasus crossings will have negative impact of the business case and put funding of the scheme in jeopardy.”  This tells us one of three things:

  1. The business case for the road is so weak it will be undermined if they slow traffic down to allow pedestrians and cyclists safe passage through the area (across the new road and its junctions).
  2. They haven’t a clue as to the needs of pedestrians and cyclists, if they think uncontrolled crossings are any form of benefit to them
  3. They just don’t care

What is worse is that WSCC cannot claim it doesn’t know that walking and cycling are important and bring many benefits.  Late last year, the Government reiterated their importance and said that it wanted to see local highways authorities spending around 15% of their transport infrastructure funding on walking and cycling.

More recently, this year the National Institute for Health and Care Excellence (NICE) published a new draft quality standard where it proposed that: “New and upgraded roads should prioritise pedestrians, cyclists and public transport over motorised vehicles”.  This is out of concern that lack of physical exercise is ruining people’s quality of life and placing an unnecessary and expensive burden on the NHS.

Watch this space for more updates but if you live in West Sussex or use the roads in the area, then we would encourage you to lobby the County Council to start getting serious with its provision for pedestrians and cyclists.

These files are our original objection, WSCC’s response and our reply to their response

bhfoe original a2300 response

wscc a2300 letter to bhfoe

bhfoe a2300 reply to wscc