Archive for the ‘Development’ Category

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.”


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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

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Don’t end up with something like this

Have your say! Respond to the A2300 consultation

Having just experienced West Sussex County Council’s (WSCC) indifference to towards walking and cycling on the New Monks Farm development, we shouldn’t really be surprised to see them at it again.  This time WSCC is proposing to dual the A2300 from the A23 into Burgess Hill to support new development.  They appear to only consider road building as a serious option, while public transport, walking and cycling are seen as add-ons and consequently don’t ever deliver much.  It’s the classic ‘predict and provide’ approach that just fuels traffic growth, congestion and a low quality environment.

What is most shocking, though, is how sub-standard, dangerous and unattractive the proposals are for people who want to walk and cycle.  The shared path alongside the road will do little to alleviate traffic levels in and around Burgess Hill and we suspect that some cyclists will still use the road, even a 70mph road, because it is so bad.  Just producing maps and drawing lines on them showing routes for people to walk and cycle is meaningless unless the infrastructure provided is safe, easy and attractive to use.  This is none of these.

We are urging people to take a few minutes to object to these poor quality and dangerous facilities.

The survey is quite short and you don’t have to fill in all your personal details except for a postcode.  Deadline is midnight, Sunday 28 October.
These are some issues and thoughts on the proposed pedestrian and cycle infrastructure being proposed alongside the A2300:
  1. The scheme does not conform to the National Planning Policy Framework which says that pedestrian and cycle movements should be given priority (para 110) – here they are just an afterthought
  2. The shared path is too narrow (at 2.5m wide) – it should be at least 3 metres wide to meet latest standards
  3. The path is unsafe as it has too many crossings of high speed junctions, made worse by the 70 mph speed limit.  No help is given to people crossing these roads
  4. There are too many sharp bends at crossing points and no slips (easy access points) onto the path near the A23, at Stairbridge Lane or Cuckfield Road – this will cause cyclists to have to swerve into the traffic to get onto and off the shared path
  5. Several quieter roads (good for cycling) would be severed by these proposals with no help given to pedestrians or cyclists to cross the A2300 – Stairbridge Lane to Pookbourne Lane, Bishopstone Lane and Cuckfield Road
  6. The path under the retained overbridge is right next to the 70mph road. This is dangerous – the central reservation should be reduced and or the road moved across to provide the required 3 metre separation between road and path
  7. Some cyclists will be tempted to still use the road (even at 70mph) because the path is so poor (a measure of success in terms of design would be to provide a facility that encourages all cyclists to use it)
  8. The Cuckfield Road roundabout should be redesigned to open up easy access for walking and cycling (from all directions) and with speed limits reduced
  9. The path should have a sealed surface (tarmac)
  10. The proposed new roundabout at the eastern end (not part of this scheme but to be provided for by developers) is not fit for purpose and needs redesigning to properly accommodate cycling.
Feel free to use or adapt these points in your response, or just tell them to go back to the drawing board.  Maybe we can shame them into providing something better!  You can also email your comments to them directly: a2300@westsussex.gov.uk

You can find out more about the proposals here

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We’re disappointed with Adur District Council’s decision to approve the New Monks Farm development, which in turn will see the closure of the Sussex Pad crossing. But our campaign is far from over.

We still have a chance to save the Sussex Pad – or getting a better replacement – by asking the Government to review the council’s decision.

Can you spare 5 minutes to send a letter and help keep the campaign going?

Ask the Government to save the Sussex Pad

At the start

Please share with family, friends and colleagues and encourage them to act to.

Many thanks

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The Sussex Pad is the best, safe road crossing of the A27 for cyclists for miles around. But now it’s under threat from the New Monks Farm development by the airport between Lancing and Shoreham.  The application is being decided by Adur District Council on 3 October, but there is no sign that it is taking the loss of this crossing and indeed other sustainable transport issues seriously.  West Sussex County Council and Highways England appear equally culpable in appearing to go along with these damaging proposals.

Local MPs from Worthing, Shoreham and Brighton & Hove have now joined the campaign to save the Sussex Pad crossing.  We are very grateful to Tim Loughton, Peter Kyle, Caroline Lucas and Lloyd Russell-Moyle who have all written or spoken to Jesse Norman MP, a Transport Minister about the loss of this important crossing and urged him to intervene.

Please sign our petition to save the Sussex Pad.

We have also written a second substantial objection that has been supported by many other local organisations including: Bricycles, Brighton and Hove Cycling UK, Brighton & Hove Friends of the Earth, Brighton Excelsior Cycling Club, Brighton Mitre Cycling Club, CTC local representatives, Horsham District Cycle Forum, Hovelo, Shoreham by Cycle, Sustrans Worthing Co-ordinator, VC Jubilee, West Sussex Cycle Forum, Worthing Cycle Forum.  In addition, Sussex Ramblers and the British Horse Society have also expressed concern at the proposals.

In this objection we dispel many of the myths and misleading statements that were made about the crossing and its proposed replacements.  We also strongly object to the fact that our previous objection was not properly reported to the planning committee and many of the issues we raised were not addressed by the committee reports or at the committee meeting.

Please sign our petition to save the Sussex Pad.

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Containing Waste

Please+pledge_your_support_CRD_containers Cat Fletcher, waste guru, is running a crowdfunding campaign to buy 8 shipping containers to form a creative reuse hub for Brighton and Hove. She is founder and Head of Media for Freegle – UK’s biggest online free reuse community with over 2 million members and runs the Brighton Freegle group which facilitates reuse between 22,000 locals. She’s worked on the multi-award winning Brighton Waste House since 2012 sourcing ‘waste’ materials for its construction – it is now Europe’s only permanent public building built with waste. She’s also worked for the city council redistributing over 100 tonnes of their unwanted goods back into the community. This saved the council money and carbon, while helping residents, charities, artists and businesses in the process.

For the past few years she has benefited from free space at Circus Street old Market via the City Council and Cathedral Developments – allowing her to gather, assess, store and redistribute intercepted ‘waste’ – hundreds of tonnes of reusable materials and goods. However, the Circus Street site is being demolished this summer for redevelopment. So, she’s crowd funding to buy shipping containers to establish a permanent (but potentially mobile!) creative reuse depot.

Having operated pop-up reuse depots in many unused spaces around the city for the past 3 years, she has stacks of evidence about the positive impact this can have. When goods cannot be reused for their intended purposes she’s been able to connect with hundreds of projects, artists and enterprises who can upcycle, reprocess, repair and refurbish all this so called ‘waste’ and keep it in circulation and out of the waste stream. PRBH_CRD Getting a new secure depot would not only allow her good work to continue but it would help accelerate and improve this waste intervention service.  Hence the crowdfunder.

To find out more about the project, the rewards on offer see this very short film.

With just a week to go (the crowdfunder ends on 30th June) the project is already 75% funded, but it still needs that last push to help make it become a reality. Can you help make this happen? Pledges start from just £1 and you will be rewarded with cake. So what’s holding you back? Please back this great project.

Follow the project on Twitter @CityReuseDepot or like on Facebook

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local campaigners at Brighton clock tower

local campaigners at Brighton clock tower

The other week the consultation ended on the City Council’s draft Air Quality Action Plan. This will be an important document what with the recent Supreme Court Judgment (on 29 April) which has ordered the Government to draw up a new national Action Plan to bring air pollution down to within legal limits ‘as soon as possible’. What exactly that means is debatable, but recent rulings in the European Court suggest that difficulty and cost are not reasons for delay.

Yet why would anyone want to delay? The problem is deadly serious with over 29,000 premature deaths every year attributable to air pollution, ten times the number killed in road crashes, and the second deadliest killer in the UK after smoking. Even this is likely to be a serious underestimate as it only looks at the impact from particulates (tiny particles of black soot). It does not include any estimate of the impact of nitrogen oxides and other pollutants. At a local level, that equates to 115 people a year, more than die through alcohol poisoning or drug overdoses where it seems more public funding and effort are spent tackling these issues. Certainly there is greater awareness.  In contrast, little is spent tackling the root causes of air pollution, which in Brighton & Hove is predominantly traffic, with no focus on traffic reduction.

We have responded to the consultation and welcomed much of the analysis in the report and its commentary. However, where we have struggled is with some of the proposed actions. More car parking and road building should be the actions of last resort, yet these are fairly high up on the list. They will only bring short term relief and most likely make the situation worse within a year or two.

The report is big on evidencing the problem and identifying where interventions can be targeted to have most impact. Yet the same rigour is not applied to potential solutions. A park and ride site on greenfield land near Preston Barracks is likely to create more pollution in the Lewes Road corridor. In addition, if we are to build on a green field it should be for housing and in this location could be virtually car-free.

Recently, we also responded to a further consultation on the City Plan modifications (the document which creates the blueprint for development in the city over the next 10-15 years). In our submissions, we requested the Inspector revisited the wording around air pollution to ensure it conforms with the recent Court rulings. We want there to be a requirement that developments do not delay air pollution being brought down to safe levels as soon as possible.

What we want to see is national Government shift funding away from road building into low emission buses, to tackle this issue in many of our cities. At a stroke, that would make a vast improvement and could be done within a few years. Secondly, we want the Council to focus much more on getting more people walking, cycling and using public transport. One reason why the Valley Gardens scheme is so important, but also why action needs to extend further than this. As part of this process we need to see joined up thinking with planning across Government and action taken to promote more car-free development and have development focussed around alternatives to the car. Unfortunately, the Government seems hell bent on removing local autonomy around planning, apart from on wind turbines, despite its so-called localism agenda, which has been anything but.

Alongside all of this, and this is certainly something local government can do, we need some serious awareness raising with the public so that they understand what the issues are and why we need to tackle this invisible killer.

Only then, can we afford to breathe easy.

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Hilary Benn MP with Robin Crane, chairman of the South Downs Campaign holding a signed copy of the Confirmation Order

Hilary Benn with Robin Crane, chairman of the South Downs Campaign holding a signed copy of the Confirmation Order in 2009

After such a long battle to get the South Downs designated a National Park, in which Brighton & Hove Friends of the Earth played a prominent part, it seems almost surreal to realise that the designation is now 5 years old.  The campaign could be said to have started in the 1920s when people started agitating for National Parks to be created in the UK.  However, it wasn’t until after the 2nd World War that the legislation was passed in 1949, by the then Labour Government, to allow National Parks to be established.

The critical moment for the South Downs was in 1947 when the National Parks Committee chaired by Sir Arthur Hobhouse recommended that the South Downs be one of 12 landscapes that should be designated as a National Park. By the 1990s it was the only one that hadn’t.  That was due to lobbying by various vested interests in 1956, when the South Downs was turned down as a National Park on the spurious grounds that due to intensive farming it no longer offered the required recreational opportunities.  Yet this was clearly a trumped up excuse.  The area is simply littered with rights of way and while it might not have as much open access land as other National Parks, it is one of the most visited of all the UK’s National Parks.  People in effect had voted with their feet and its landscape beauty (which was not deemed to have been diminished by farming) was later recognised when it was designated as two Areas of Outstanding Natural Beauty (AONB) in the 1960s.

In the 1980s, as development threats started to intensify and modern agricultural practices were still causing harm to the area, it was people like Paul Millmore and Phil Belden who started pushing the case for a National Park.  However, it wasn’t until 1990 that the South Downs Campaign was formed at Sussex Wildlife Trust headquarters under the chairmanship of Robin Crane, who led the campaign right up to its dissolution in 2010.

Along the way there were many ups and downs and Brighton played a big part in rejuvenating the campaign in 1995 when the Council (then Labour) tried to sell off the downland estate and faced a huge backlash with a 12,000 signature petition opposing the sale.  This was no mean feat before the time of social media and electronic petitions.  The Council backed down and then to its credit got behind the National Park campaign, with full cross party support (Conservative, Green and Labour).

The 1997 General Election was also a key moment, when Farmer Harmer decided to plough up a Site of Special Scientific Interest (SSSI) at Offham Down.  He was well within his rights, but the situation was not helped by a weak and underfunded Government Agency, unable to properly protect these valuable sites.  However, it made great media and resulted in John Gummer (then Secretary of State for the Environment) having to order a Stop Notice to protect the site during the General Election campaign (only the 4th that he had ever issued).

After the election, Michael Meacher became the new Secretary of State and was instrumental in creating the right framework for the National Park to be created.  We received strong support from the city’s MPs, particularly Dave Lepper and Des Turner, and a wealth of other people too numerous to mention.  And despite being almost tripped up by the poor decisions taken on the New Forest National Park, we finally achieved the South Downs National Park in 2009, with the order confirming the designation coming in to effect on 31 March 2010.  It covered a much larger area than could have been anticipated and that was down to the keen interest and enthusiasm shown by the then Secretary of State, Hilary Benn and his minister Huw Irranca-Davies.  They in effect finished the job that the Labour Government had first started some 60 years earlier.

Today, Margaret Paren, a former member of the South Downs Campaign, has chaired the National Park Authority since its establishment and overseen its development and progress.  Already, it is taking a more strategic and consistent approach to planning.  It has supported nearly 200 local community projects, secured funding for research, restoration work and investment in new cycle routes throughout the National Park.  It has produced a Management Plan and this year embarks on its own Local Plan.  There is much to do and the threats to National Parks are increasing as Government slashes the already very small National Parks’ funding and presses ahead with dismantling the planning system and spending money on new roads.

On a day of celebration, it was appropriate to see the Brighton & Hove bus carrying Paul Millmore’s name heading to Lewes and beyond.  But we must also realise that the future of the South Downs is not guaranteed.  It may be in a better place than it was 5, 10 or even 20 years ago, but it faces some very big challenges over the next few years.  If it succeeds in overcoming these, then we will know how successful it has been.


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Group criticises draft planning document

Brighton & Hove Friends of the Earth (BHFOE) has submitted a critical response to Brighton & Hove City Council’s consultation on its draft Parking Supplementary Planning Document (SPD), which ended on 27 March.

BHFOE is concerned that if the SPD is adopted as it is currently drafted it could lead to the long term increase of cars in the city, creating more congestion and pollution, delaying bus services and harming the local economy.  It believes that the SPD may not be lawful if it leads to an increase in air pollution and delays the time that areas already above the legal limits take to become compliant [1].  It is also concerned at the unintended consequences of the standards which could see the loss of front and back gardens for parking when properties are redeveloped and the loss of historic streetscapes.

Chris Todd, planning and transport campaigner for BHFOE said:

“While we fully support the need for local parking standards what is currently proposed could be highly damaging.  It could lead to the loss of green space within the city as front and back gardens are tarmacked over to provide parking.  This would be detrimental for residents and would also harm the city’s historic streetscapes.

“Overall it will increase the number of cars in the city which will only mean more congestion and pollution.  This is at a time when more and more evidence is emerging about the harm that air pollution is causing.  The UK has an obligation to reduce air pollution to below legal limits as soon as possible.

“All new development within the city centre needs to be ‘car-free’ so that it improves the current situation, not makes it worse.  Allowing development which will bring more cars into our strategic bus corridors in the heart of the city is madness.  In the long term it could bring the city to a grinding halt and seriously damage the local economy.”

[1]        Large parts of the city centre are within an Air Quality Management Area and have nitrogen dioxide levels above legal limits.  The worst areas are around North St, Western Road and the Clock Tower.  The UK has already missed the deadline that it was mean to have met to reduce air pollution to safe levels by and recently lost a European Court Case due to its lack of action to tackle this serious issue which leads to at least 29,000 premature deaths every year in the UK.  It is estimated that 115 people a year die prematurely in Brighton & Hove due to particulate pollution, although the number who die prematurely due to all air pollution will be higher.

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We have responded to the consultation on the proposed modifications to the City Plan, which ended at midnight on 16 December. While we support much of what is proposed we have issues with three main areas:

Air pollution:  despite agreeing with the Council to proposed modifications on this issue earlier in the year, recent events (European Court Ruling and emerging research) mean that the proposed wording may be unsound as it does not go far enough to reduce air pollution and act to bring it down below legal limits as fast as possible.  In fact developments could still be approved that will make it worse.

Urban Fringe development:  we have pointed out errors in the Urban Fringe Assessment which undermine the figures for housing in the urban fringe.  We have therefore questioned whether it is justified to have an allocation of 1,060 homes in the urban fringe.

Watering down of energy efficiency:  we have objected to the watering down or energy requirements in new development, not least because as a city we have consistently missed our carbon reduction targets and need urgent action to bring us back on course.  Indeed the fact that we’ve missed our targets year on year, means that we have emitted more carbon than we should and so need to cut our levels even more to compensate.

To see our full comments and links to references, see our submission.

The examiner will now look through all responses to the consultation and see whether any areas warrant further investigation or debate before deciding whether to accept that the City Plan is sound and can be adopted.  The is an important moment for the Council as without a agreed Plan it is in a very weak place to prevent damaging developments.

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