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Archive for the ‘Development’ Category

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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Brighton & Hove Friends of the Earth (BHFOE) is pleased to see that EON is progressing with the Rampion windfarm with the announcement that it will be using 116, 3.5MW turbines, with a tip height of 140.2 metres in a smaller array than originally planned.   The wind farm will provide enough electricity for 290,000 homes and save 600,000 tonnes of carbon dioxide each year.

BHFOE is also welcoming that fact that since the start of the initial consultation, the width of the wind farm has been reduced quite significantly.  In the latest plans, the field of view has reduced from 33 to 10.6 degrees when viewed from the Heritage Coast and the distance of the closest turbine (to the Heritage Coast) has also been increased.  These changes, along with the fact that EON has selected a turbine which is only 140 metres tall, mean that the visual impact from the Heritage Coast and the South Downs National Park is very much reduced.

Chris Todd from BHFOE said:

“This is really good news as it brings us another step closer to reducing our carbon emissions here in Sussex.  We also welcome the fact that EON has altered the size and layout of the wind farm which will dramatically reduce the visual impact from the Heritage Coast and the wider South Downs.

“We look forward to the wind farm producing its first electricity in 2017 and being fully commissioned the following year.  Given the current failure to properly address climate change both in this country and abroad, this is a much needed development.”

Other wind farm facts:

[1]   The wind farm will be built in an area covering 72 square kilometres compared with the 122 square kilometres it was given permission for and the 167 square kilometres that it first proposed.  EON was also given permission to build up to 175 turbines.

[2]   Energy generated in 1 year is estimated to be 1,366 GWh.

[3]   From Devil’s Dyke the field of view has reduced from 58.3 to 28.2 degrees, although the distance to the nearest turbine is about the same as before.

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As threat grows from A27 expansion plans

Hilary Benn MP with Robin Crane, chairman of the South Downs Campaign holding a signed copy of the Confirmation Order, 12 November, 2009

Rt Hon Hilary Benn MP with Robin Crane CBE, chairman of the South Downs Campaign, holding a signed copy of the Confirmation Order, 12 November, 2009

Brighton & Hove Friends of the Earth (BHFOE) is today celebrating the 5th anniversary of the signing of the South Downs National Park Confirmation Order by the Rt Hon Hilary Benn MP in Ditchling, who was the Secretary of State for the Environment, Food and Rural Affairs in 2009.

This was the final hurdle to establishing the South Downs National Park, which came into existence on 31 March 2010.

BHFOE believes that the National Park has been an important development in safeguarding and championing the South Downs landscape.  However, on this important anniversary, it is clear from the Prime Minister’s announcement on Monday that the South Downs National Park is under threat from the Government’s £15 billion new roads programme.  (Incidentally this about equals the amount taken from local government over the past few years).

Chris Todd from BHFOE said:

“Today is the 5th anniversary of an important milestone in the history of the South Downs.  5 years ago we thought the future of the South Downs had been secured when it became England’s newest National Park.  Yet already, this Government, egged on by many local authorities, seems hell bent on road building in the South Downs.

“The impact of individual schemes at Arundel, Worthing and between Lewes and Polegate is bad enough, but the cumulative impact could be devastating.  It is bound to increase pressure for further road expansion on the A27 as the congestion just moves to other places on the network.  It’s a bit like searching for the Holy Grail.  It will require more and more effort and ultimately we risk destroying an iconic landscape in a rather fruitless search for economic prosperity.”

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Brighton & Hove Friends of the Earth (BHFOE) is calling on Brighton & Hove City Council to agree to the revised modifications to the City Plan.  These are due to be considered at Policy & Resources Committee on Thursday.  While BHFOE remains concerned about the threat to the urban fringe, a greater threat would be had by having no City Plan at all.  In addition, the Council is proposing to delete its previous amendment to the urban fringe Policy SA4 which would have allowed development on any proposed housing site listed in the Urban Fringe Assessment.

BHFOE is reassured that this is no longer the case and urban fringe sites will be scrutinised and subject to further consultation before they can be allocated for development.

Chris Todd from BHFOE said:

“While we are not entirely comfortable with the place we are in, the Council is between a rock and a hard place.  Without a City Plan it would find it increasingly difficult to resist unsuitable development right across the city, not just in the urban fringe.  Also it would be more susceptible to losing planning appeals and having costs awarded against it.

“We would much rather the focus be on brownfield development but the time for that debate is over at this stage in the process.  The inspector has specifically asked the Council to review the urban fringe and if they had not done so the Plan would have been found unsound.

“By supporting the adoption of the City Plan, we are not agreeing to sites being developed.  That is a battle which we will need to gear up for on another day to safeguard our parks and allotments from inappropriate development.

“We fully appreciate that some politicians are in an uncomfortable position and are grateful for their support last time round in getting the Council to rethink its policy.  However, we now need them to step up to the plate and agree this Plan for the greater good, just as we have done.”

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News Release, Monday, 21 July, 2014

Bus users left out in the rain

Brighton & Hove Friends of the Earth (BHFOE) is calling on RBS and Brighton & Hove City Council to come up with some innovative designs to give bus passengers proper shelter in North Street, Brighton as part of the RBS financed improvement scheme [1].  The proposed shelters in North Street are far too small for the numbers of people waiting as can be seen by observing the current situation [2].

Despite a few new shelters being proposed as part of this scheme, BHFOE believes they will be overwhelmed by the number of users and consequently many people will continue to block shop doorways as they seek shelter in the rain.  This is one of the issues the scheme is meant to be addressing.

BHFOE is also concerned that moving the eastbound bus stops towards Pavilion Gardens could cause pedestrian congestion as the pavement is quite narrow here where people also congregate for the pedestrian crossing.

Chris Todd from BHFOE said:

“Unfortunately what is a good scheme in many respects, fails abysmally when it comes to providing bus users with shelter.  Given that a large number of shoppers arrive by bus, in an area that RBS wants to see trade boosted, ignoring this issue is a serious mistake.

“Installing bog-standard bus shelters which cater for only a fraction of the people at the bus stops is poor design.  While, ignoring the problem, hoping it will miraculously disappear, is wishful thinking.

“If RBS are unable or unwilling to pay for proper bus or pavement shelters, then it should pay the Council the money to come up with something better.

“Our solution would be to create an attractive pavement shelter which could protect both bus passengers and shoppers when it is raining.  This would stop bus passengers needing to stand in shop doorways for shelter while encouraging shoppers to linger in the area rather than hurry through it.  Unless changes are made to the designs, this will represent a wasted opportunity to put North St on the map, while leaving bus users out in the rain.”

[1]   The initial proposals went to the Environment, Transport and Sustainability Committee on 1 July 2014 after a short consultation a couple of weeks before then.

[2]   There are currently 3 bus shelters in North St for eastbound users.  These are constantly oversubscribed with passengers spreading out all around these shelters which are far too small for the numbers of people using the buses.  RBS are just proposing replacing them like for like. However, in the plans RBS’s consultants have produced, only 2 of these shelters are shown as existing today.  This could create a false impression that RBS is making more improvements than it really is.

Westbound there are currently no bus shelters, although many people waiting at one of the bus stops shelter under the canopy extending out from the buildings there.  RBS is proposing 3 new shelters so there would be a slight gain here but given the numbers of people using the stops they would appear more tokenistic than practical.

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Brighton & Hove Friends of the Earth (BHFOE) has welcomed the City Council’s rejection of a Conservative motion to join the A27 Action Campaign, when both Labour and Greens voted against it.  BHFOE is concerned that dualling the A27 would harm the city’s interests, undermine public transport and increase congestion and pollution as more people would be tempted to drive along the south coast rather than use the train or bus.  See our previous blog for more detail.

A key thrust of the Conservative argument in support of dualling the A27 was that it would allow the space for more sustainable transport to be improved.  However, BHFOE is not convinced by this argument as many of the coastal towns have smaller populations and traffic levels compared to Brighton & Hove and many improvements could be done now.  The reality is that West Sussex County Council has done very little to promote walking, cycling and public transport, other than a few notable exceptions, as it has clung on to the hope that one day an upgrade to the A27 would solve all of its transport problems.  In reality, it is likely to lead to more traffic and pollution and the quality of life in West Sussex will probably fall, while the impact on the South Downs would be severe.

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