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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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News release issued Monday, 7 July, 2014

Council risks making a bad position worse

Urban fringe report being adopted as policy without any public scrutiny

Brighton & Hove Friends of the Earth (BHFOE) is calling on Brighton & Hove City Council to put on hold the consultation on the proposed modifications to the City Plan.  These are due to be considered at Policy & Resources Committee on Friday [1].  BHFOE believes that going ahead with the proposed modifications is premature.  The Urban Fringe Assessment Report has not been subject to any consultation or public scrutiny yet the Council appears to be adopting it as policy [2].

Instead, BHFOE would like to see a public consultation on Urban Fringe Report take place first with modifications to the City Plan coming forward after that.  It is particularly concerned about the proposed amendments to the urban fringe Policy SA4 [see note 1].

Chris Todd from BHFOE said:

“We understand that the Council is between a rock and a hard place because of Government changes to the planning system [3].  However, the proposed modifications to the City Plan will make a bad situation worse.  These changes will give developers the green light to build on any of the sites listed in the urban fringe report, even if the consultants have got their facts wrong.

“Whilst we are not saying no development anywhere, we have serious concerns about loss of green space (which is in short supply across the city) and the impact on the National Park with some of these proposals.  That’s why we need to have this report properly scrutinised now before any changes are made to the City Plan.

“We were also very surprised to see the amount of housing on major development areas fall [4].  This has led to housing being shifted from sustainable locations, where there is good access to services, to the urban fringe where there are not.  This needs reversing.

“We also need our local MPs and councillors to make strong representations to Government about the unfairness of the current planning system and the problems created by London’s distorted housing market [5].”

[1]   BHCC’s Policy & Resources Committee meets at 2pm, Friday, 11 July, 2014 in the Council Chamber at Hove Town Hall, to discuss the proposed modifications to the City Plan, which includes amending the amount of housing across the whole city, not just the urban fringe.  It is also recommending changing the policy on the urban fringe (SA4) to the following:

Development within the urban fringe will be permitted where:

a) a site has been allocated for development in a development plan document; or

b) a site (or part of a site) has been identified in the 2014 Urban Fringe Assessment Study as having potential for residential development; or

c) a countryside location can be justified;

and where it can be clearly demonstrated that:

d) the proposal has had regard to the downland landscape setting of the city;

e) all any adverse impacts of development are minimised and appropriately mitigated and/or compensated for; and

f) where appropriate, the proposal helps to achieve the policy objectives set out above.

BHFOE wants b) above deleted as it believes it is premature and will prejudice which sites will be developed before there has been any scrutiny of the Urban Fringe Assessment or before they are considered in Part 2 of the City Plan.

[2]   The Brighton & Hove Urban Fringe Assessment by consultants LUC has been produced without any stakeholder involvement nor has it been subject to public scrutiny to test whether its recommendations are sound.  For example, the South Downs National Park Authority was not involved in the production of the report, so none of the claims about possible impacts on the South Downs have been tested or assessed by the body charged with safeguarding their future.

[3]   The Government changed the planning system making it easier for developers to do what they want if an area does not have an up to date adopted Local Plan.  Unfortunately, the time given to local planning authorities to draft, consult and adopt a Local Plan were ridiculously short.  See CPRE’s website for an outline of concerns with the new planning system.

[4]   Housing numbers on major development areas is set to fall from 6,155 units to 6,010,a drop of 145 homes, the main drops being in the New England Quarter and London Road area, Hove Station and Shoreham Harbour.  See pages 8/9, Appendix 2, Brighton & Hove City Plan Part One – Proposed Modifications Schedule.

[5]   See article in Planning Resource.  This highlights the housing pressure many local planning authorities are under around London because of the failure to build enough housing in the capital.

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