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.
Brighton & Hove Friends of the Earth 