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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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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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