core strategy preferred options - brighton and hove...core strategy - revised preferred options june...

Brighton & Hove City Council's Local Development Framework

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June 2008

Core Strategy - Revised Preferred Options June 2008

Contents page

Executive Summary 2

Introduction and how to comment 4

Part One – Content, Vision and Objectives 10

Part Two – Spatial Strategy 24

The revised Spatial Strategy 26

DA1 – Brighton Centre and Churchill Square Area 31

DA2 – Brighton Marina and Black Rock 34

DA3 – Lewes Road 38

DA4 – New England Quarter and London Road 43

DA5 – Eastern Road and Edward Street 47

DA6 – Hove Station Area 51

DA7 – Shoreham Harbour and South Portslade 55

SA1 – The Seafront 61

SA2 – Central Brighton 66

SA3 – Valley Gardens 70

SA4 – Urban Fringe 74

SA5 – South Downs 77

SN1- Sustainable Neighbourhoods 80

SN2 - Residential Renewal Areas 84

Part Three – Core Policies 88

CP1 Sustainable Buildings 88


CP2 Urban Design 93

CP3 Public Streets and Spaces 96

CP4 Healthy City 98

CP5 Biodiversity 101

CP6 Open Space 104

CP7 Sports and Recreation 108

CP8 Sustainable Transport 112

CP9 Developer Contributions 115

CP10 Managing Flood Risk 118

CP11 Housing Delivery 121

CP12 Affordable Housing 128

CP13 Housing Densities 132

CP14 Gypsies and Travellers 135

CP15 Retail Provision 138

CP16 Strategic employment sites 142

CP17 Other employment sites 147

CP18 Culture, Tourism and Heritage 150

CP19 Hotel/Guest Accommodation 155

Part Four – Monitoring 158

Annex 1 - Supporting Evidence for Preferred Options 190

- Proposed Changes to Local Plan Proposal Map 249

Glossary of terms 250

Key diagram 264

Brighton & Hove’s Local Development Framework must reflect the role and importance ofthe city in the sub-region and the south east and respond to and provide for the needs ofa growing population and a growing local economy over the next 20 years. Thepopulation is expected to grow to 295,700 by 2026 if current trends continue and 8,000new jobs will be needed over the next ten years to maintain the city’s currentemployment rate.

Therefore the Core Strategy must plan to provide for the 11,000 new homes required bythe draft South East Plan whilst maximising the delivery of affordable housing across thecity to address the city’s housing need (a target is set in the Core Strategy to achieve 230affordable housing units per annum). Employment sites need to be safeguarded to meetthe forecast need for employment land over the next 20 years with a priority ofgenerating more jobs and more high value jobs and there is an identified need for anadditional 20,000 sq m of office floorspace in the city. The creative industries is a growingand dynamic sector in the city, acting as the largest hub of such businesses in the southeast outside London. Forecasts suggest that they will continue to require affordable andappropriate workspace. The city is a primary regional shopping centre and there issignificant capacity for new food and non-food retail floorspace to the period 2016(14,256 sq m and 53,675 sq m respectively) and the priority will be to direct additionalretail firstly to Brighton regional centre but also to maintain and enhance the existingnetwork of shopping centres.

It will also mean working with health providers to help deliver and protect a sub-regionalnetwork of critical care hospitals and a city wide integrated network of health facilities.Sussex University and the University of Brighton play a major role in the economic, socialand cultural life of the city and the sustainable redevelopment and expansion of theircampuses needs to be supported through the Core Strategy. Further Educationestablishments also have plans for refurbishment and consolidation/ expansion of theiractivities and there is the need to ensure parity in the quality of education and access toschools across the city.

The Local Development Framework needs to reflect the role and importance of the majorprojects at various stages of development for key sites around the city including thereplacement of the Brighton Centre, a new arena at Black Rock, a community stadiumand redeveloping the King Alfred sports centre along with proposals for Preston Barracksand the Circus Street site. These developments are expected to bring jobs and prosperityto the city, help to regenerate surrounding areas and reinforce the city’s role as a culturaland tourism and sporting hub.

A number of neighbourhoods in Brighton & Hove have been identified as facing highlevel of disadvantage and major priority of the council and the Local Strategic Partnershipis to reduce inequalities between disadvantaged areas and the rest of the city. Issuesincluding worklessness, long term unemployment and health inequalities need to beaddressed in the Core Strategy.

All this must be achieved within the physical limits of a coastal city, a scarcity ofdevelopable land and a future South Downs National Park which will protect significantareas of the city’s remarkable downland countryside which extends around and into thebuilt up area of the city whilst meeting and integrating the environmental, social andeconomic aims of sustainable development.

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Executive Summary

This means ensuring that new development is a delivered in a way which reduces thecity’s ecological footprint, contributes towards meeting the city’s targets for reduction incarbon emissions and are resilient to the predicted local effects of climate change. It alsomeans ensuring that all major new development in the city supports the regeneration ofthe city and contributes to the creation of high quality, sustainable communities andprovides for the demands that it generates, supported by appropriate physical and socialinfrastructure.

The city is a regional transport hub and although car ownership in the city is one of thelowest nationally congestion remains a significant problem for the city, especially at peaktimes. Approximately 8,000 commuter journeys are made by car every day withinBrighton & Hove, almost half of which are journeys less than 5km. Given the relativeabsence of major industrial processes in the city, transport is the main cause of poor airquality in the city. The Core Strategy must therefore integrate the priorities of the LocalTransport Plan such as the proposed Rapid Transport System to mitigate these impactsand also put forward a strategy for accommodating growth that maximises sustainabletransport opportunities in areas of high accessibility.

The council’s preferred approach is therefore to accommodate future development byoptimising development on brownfield sites throughout the existing built-up area of thecity, in order to preserve the countryside.

The council’s overarching spatial strategy is as a priority to direct significant developmentto seven broad areas of the city where it is possible to make full use of public transport/public transport interchanges and where identified capacity exists to accommodate futuredevelopment.

The development areas are proposed because they contain opportunities for change, theycan deliver development of city wide or regional importance and/or because they are inneed of regeneration. These seven areas are:

l Brighton Centre and Churchill Square areal Brighton Marina and Black Rock l Lewes Road l New England Quarter and London Roadl Eastern Road and Edward Streetl Hove Station areal Shoreham Harbour and South Portslade.

Additional areas of the city are identified as part of the Spatial Strategy as they require aspecial or coordinated approach to managing future change in these areas and these arethe Seafront, Central Brighton, Valley Gardens, the Urban Fringe and the South Downs.Further proposals are set out to improve the sustainability of remaining residential areasof the city with the priority to reduce inequality.

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The Core Strategy is part of Brighton & Hove’s Local Development Framework, a suite ofplanning documents that will guide planning and development of the city over the nexttwenty years. The purpose of the Core Strategy is to provide the overall strategic visionfor the future of Brighton & Hove through to 2026. It will set out how the council willrespond to local priorities and meet the challenges of the future and identify the broadlocations, scale and type of development and supporting infrastructure that will takeplace in the city. It addresses the important city-wide matters such as delivering moresustainable development and neighbourhoods and sets out the council’s strategicapproach to housing, the economy, shopping and transport. Preparation of the CoreStrategy has been informed by extensive consultation, the aims of the city’s SustainableCommunity Strategy, other city-wide plans and strategies, national planning policy andthe draft South East Plan (the regional spatial strategy).

The Local Development Framework documents including the Core Strategy will eventuallyreplace the council’s Local Plan which was adopted on 21st July 2005.

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Introduction

The Local Development Framework

This document is part of the new suite of documents known as the Local DevelopmentFramework (LDF), which has been introduced (under Government legislation) to replace LocalPlans as a more comprehensive means of planning for future sustainable development. Underthe new system there is a regional level of planning, overseen by the South East EnglandRegional Assembly (SEERA), and below that it is the responsibility of each local council toproduce an LDF for its area, within a timescale agreed with the Government.The regional plan produced by SEERA is known as the South East Plan. This Plan will guidedevelopment in the region as a whole through to 2026. The draft Plan was submitted to theGovernment by SEERA in March 2006 and adoption of the Plan is anticipated in 2008.The Local Development Framework for Brighton & Hove will include the following DevelopmentPlan Documents (DPDs):

l A Core Strategy - the strategic policies

l A Development Policies and Site Allocations document - generic policies for all types ofdevelopment and the allocation of land or sites for specific uses

l Area Action Plans - specific proposals for areas of significant change

l A Waste & Minerals Development Framework - prepared jointly with East Sussex CountyCouncil

These will be supported by:l A Proposals Map - showing all policy designations for the city; and

l Supplementary Planning Documents - detailed policy on particular subjectsThe LDF also includes a number of process documents:l A Local Development Scheme - the programme for the LDF as a whole

l The Statement of Community Involvement - setting out how we will involve people in thepreparation of local development documents and the council’s approach to consultationon planning applications

An Annual Monitoring Report - showing how we are meeting the aims of the LDFThe East Sussex and Brighton & Hove Waste Local Plan was adopted in February 2006. LocalPlan and Waste Local Plan policies are automatically ‘saved’ for three years from the date ofadoption but future Annual Monitoring Reports will address the issue of which policies shouldbe saved for longer.

A Revised Preferred Options stage

The council has made good progress in preparing the Core Strategy. The Council initiateda very wide ranging debate, at the Issues and Options stage (October 2005) about thecity’s future. These ideas were developed into the Preferred Options stage which waspublished in October 2006. However, a number of matters have arisen, following thePreferred Options stage, which required us to consider a change in approach to thePreferred Option. The completion of a final Core Strategy has therefore been deferredfor this revised Preferred Options stage to allow:

l further research and evidence gathering required by recently published nationalplanning policy;

l more details to be provided on the location, scale and type of development to bedelivered by the spatial strategy; and

l a more area-based approach to planning to be introduced, setting out how thecouncil will respond to local priorities and meet the challenges of the future (‘place-shaping’) as requested by the Government Office for the South East.

In accordance with the Council’s standards of consultation set out in the adoptedStatement of Community Involvement, the Council is undertaking another stage ofconsultation, before it prepares and submits its Core Strategy to the Secretary of State forpublic examination. This will be a six week period of consultation.

The Government Office for the South East has been consulted on this additional stage ofconsultation and given a positive response to this new area-based approach to the CoreStrategy.

The Revised Preferred Options document

This document sets out the new approach the Council proposes since the original CoreStrategy Preferred Options report was published in October 2006. The document outlinesthe preferred policy directions, indicating if the preferred option has altered and thereasoning for this and highlights alternatives where appropriate.

A substantial number of background documents have been undertaken to inform thepreparation of the Core Strategy. The Council commissioned a number of newbackground studies following the Preferred Options Consultation in 2006. The findingsfrom these studies are published as background documents to this revised preferredoptions stage. The studies are:

l Hotel Futures Study 2007l Urban Characterisation Study 2007l London Road and Lewes Road (LR2) Regeneration Strategy 2007l Public Space Public Life Study 2007l Strategic Flood Risk Assessment 20085


Stage DatesIssues & Options document - early community involvement October 2005 - May 2006Formal public consultation on Preferred Options November - December 2006Revised Preferred Options informal public consultation (thisis the stage we are at now)

June - August 2008

Formal public consultation on Submission document January - February 2009Submission of Core Strategy to the Government May 2009Independent Examination in Public October 2009 (estimated)Adoption of the Core Strategy January 2010 (estimated)

l Open Space, Sport and Recreation Study 2008l Strategic Housing Market Assessment 2008l Creative Industries Workspace Study 2008l Reducing Inequality Review 2008

A Strategic Housing Land Availability Assessment and a Transport Assessment arecurrently underway and interim findings have been published to accompany the revisedCore Strategy Preferred Options document.

Each preferred policy option is now accompanied by a list of its key supportingdocuments and background documents and a full list is set out in separate SupportingEvidence Document.

The Preferred Options document has also been significantly restructured. In taking a morearea-based approach, issues previously set out under the headings of the council’sSustainable Community Strategy have been reorganised. Those that more appropriatelyrelate to a development area, special area or relate generally to neighbourhoods havenow been dealt with in those sections. Where the 2006 Preferred Options would be moreeffective joined together, these have been integrated into a new preferred option in theCore Policies. Other alterations to the preferred options have resulted from the October2006 - December 2006 consultation responses or findings from commissionedbackground studies/ other strategies adopted since October 2006. Further where an issueis better dealt with in another local development document such as a SupplementaryPlanning Document or the Site Allocations DPD or Development Plan DPD this also hasbeen highlighted.

For clarity a section on implementation is included with each preferred option and thesupporting evidence for each preferred option is set out in Annex 1. This provides asummary of the consultation responses, the alternative options considered, theSustainability Appraisal recommendations and the reason for the revised PreferredOptions.

The new structure is explained below:

Part One - Context, vision and objectives. This section sets out the key issues facingthe city over the next twenty years, and summarises the policy context for the CoreStrategy. It also sets out a vision of the city that we are aiming for in 2026 and lists ourstrategic spatial objectives, from which all future planning policies will flow. Theseobjectives have been revised to take account of consultation and the area-basedapproach now being pursued.

Part Two - Spatial Strategy sets out our preferred spatial strategy for accommodatingthe future sustainable development of the city. This is structured as follows:

Proposed development areas - details the type and amount of development withineach area and identifies place-shaping and development priorities. Each developmentarea includes a section on implementation and delivery.

Special areas - those areas in need of a special planning approach or needing effectivepolicy coordination (some of these areas were previously identified as major cross-themeissues and areas set out in Part six of the original Preferred Options Core Strategy).

Sustainable neighbourhoods - a set of proposals to cover the remaining residentialareas of the city with the priority of improving sustainability in neighbourhoods andreducing inequality.

Part Three - Core Policies consists of our preferred approach to strategic policy issues6


such as housing, transport and shopping. Rather than arranged under the headings ofthe council’s Sustainable Community Strategy as previously, these will be listed from CP1-CP19.

Part Four - Monitoring – which sets out in table format all the monitoring indicatorsand targets for the Core Strategy;

Annex 1 - supporting evidence for the preferred options and the proposed changes tothe adopted Local Plan Proposal Map as a result of Core Policies

A glossary of terms.

Key Diagram – illustrating broad locations of future development.

Sustainability Appraisal

In producing this document we have aimed to ensure that our preferred options, whentaken together, will ensure the sustainable development (see definition below) of the cityand the creation of sustainable communities. This is tested by a Sustainability Appraisal.This is a separate document produced alongside the Core Strategy, which criticallyexamines its objectives and options and tests them against the principles of sustainabledevelopment. However, it is a two way process. So in turn, the Sustainability Appraisalcontributes to the reasoning behind, and the refinement of, the Core Strategy.

The first stage of the Sustainability Appraisal process was the production of a ScopingReport (November 2005) setting out the ‘baseline’ against which the Core Strategy wouldbe tested. As the drafting of the various preferred options progressed, the DraftSustainability Appraisal (October 2006) considered each preferred option and all realisticalternatives; its conclusions included suggestions for changes to preferred options and/ormitigation measures in some cases and these were reflected in the 2006 Core StrategyPreferred Options document. The revised preferred options have been reappraised by anupdated draft Sustainability Appraisal (2008) and the response to its suggestions forchanges to the revised preferred options and/or mitigation measures in some cases is setout in Annex 1.

A non-technical executive summary of the updated draft Sustainability Appraisalaccompanies this document. The full Sustainability Appraisal is available on the council’swebsite. The appraisal will itself be subject to the same six week period of consultation.

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Sustainable Development

A widely accepted definition of sustainable development is "development that meets the needs ofthe present without compromising the ability of future generations to meet their own needs".* TheGovernment has set out a national sustainable development strategy with five guiding principles:l Living within environmental limits

l Ensuring a strong, healthy and just society

l Achieving a sustainable economy

l Using sound science responsibly

l Promoting good governance.And four priorities:l Sustainable production and consumption

l Climate change and energy

l Natural resource protection and environmental enhancement

l Sustainable communities. *‘Our Common Future’1987 (the Bruntland Report)

Relationship of the Core Strategy to other documents

The next Development Plan Document (DPD) to follow on from the Core Strategy will bethe Development Policies and Site Allocations DPD. The opportunity to streamline thenumber of DPDs prepared has led to the decision to combine these previously separateDPD topics. This will also ensure that there is a clearer link between the strategicobjectives and policies of the Core Strategy and how they will be implemented throughspecific site allocations or through the development management process. Whilst an‘Issues and Options’ paper for the Site Allocations DPD was published for consultationOctober 2006 - March 2007 the early stage preparation and engagement on thisproposed combined DPD will now commence once the independent examination of theCore Strategy has been completed.

The city council, Adur District Council and West Sussex County Council will be jointlyproducing an Area Action Plan for Shoreham Harbour and South Portslade. Work is dueto start summer 2008 with anticipated adoption March 2011. The Joint Area Action Planwill test and define the regeneration scheme for the Harbour and guide delivery tosupport Brighton & Hove’s Core Strategy.

Waste and Minerals issues will be dealt with in the Waste and Minerals DevelopmentFramework (WMDF) which is being prepared with East Sussex County Council. TheWMDF is being prepared in parallel with the Local Development Framework and will setout the vision and spatial strategy for the sustainable management of minerals resources,the reduction and recycling of waste and its final disposal.

Preliminary work began on the WMDF in 2006, following adoption of the East Sussexand Brighton & Hove Waste Local Plan. Consultation on the Issues and Options for theWaste and Minerals Core Strategy took place February 2008 – April 2008.

The LDF Core Strategy will need to have regard to waste and minerals issues. The savedpolicies and site allocations in the Waste Local Plan will be taken into account in the LDFCore Strategy. There is only one active mineral site in the city, at Shoreham Harbour, andactivity here will need to be safeguarded or replaced in any regeneration proposals forthe area, pending the preparation of the Site Allocations DPD for both minerals andwaste. The LDF Core strategy will also have to take into account the need for suitablesites for reprocessing and recycling aggregates from construction and demolition waste tomeet the targets set out in the draft South East Plan. A supplementary planningdocument on Construction and Demolition Waste has been prepared with East SussexCounty Council in advance of government proposals for managing such wastes becauseof the urgent need to reduce such waste going to landfill in this area. Similarly aPlanning Advice Note: ‘Design guidance for the storage of recyclable materials and waste’has been produced to support increased recycling and waste reduction in order to meetgovernment and draft South East Plan targets.

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How to Comment on the Revised Preferred Options document

This is your chance to let us know what you think about the revised Preferred Options.Your views are important to us and there is a six week period, 27th June - 8th August,during which written comments may be made. To help you do so, a response form hasbeen produced to accompany this document. If you do not have a copy, it can beobtained from the council’s citydirect offices or you can contact us directly. It can also bedownloaded from the council’s website.

Completed response forms must be received by no later than 5.00 pm on 8th August.

Our contact details are as follows:

Post: Local Development Framework Team, City Planning, Room 407 - 410,Hove Town Hall, Norton Road, Hove BN3 3BQ

Fax: 01273 292379

E-mail: [email protected]

Website: www.brighton-hove.gov.uk (go to Planning and then LDF)

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Main Characteristics and key drivers for change in Brighton & Hove (‘spatialportrait’)

1.1 Brighton & Hove is a compact city, situated between the South Downs and the sea.251,9001 people live in the built up area that comprises roughly half of the city’s extent(8,267 ha). With a limited legacy of derelict/ vacant sites these ‘natural boundaries’ defineand limit the outward expansion of the city. In 2004/05 98% of residential developmentsand 100% of new employment floorspace came forward on brownfield land.

1.2 Brighton & Hove is an attractive city of distinct urban and suburban neighbourhoodsgenerally low to medium rise, with some taller buildings in the urban core where netdensity levels range between 60-200 dwellings per hectares. Continuously rising houseprices over the last few years, particularly for smaller properties have put home ownershipout of the reach of many households.

1.3 The natural environment within and surrounding the city is of remarkable quality. Thecity is home to a great variety of common and rare animal and plant species. One sixth ofthe city’s area is covered by a nature conservation designation. The extensive chalkdownlands, currently designated an Area of Outstanding Natural Beauty (AONB), areessential to the health of the city, water supply (aquifer), biodiversity, leisure andrecreation. The city’s network of parks and opens spaces play a wide role for the city as awhole hosting community and cultural events as well as being places of relaxation andrecreation. There has been significant progress in sports-related regeneration andinvestment in sports facilities in schools and colleges.

1.4 Brighton & Hove is a regional cultural ‘city by the sea’ famous for its vibrant,cosmopolitan lifestyle with a strong commitment to the arts and a thriving creativeindustries sector which attracts tourism and new businesses. The city’s cultural heritageencompasses the internationally renowned and iconic Royal Pavilion, regionallyrecognised museum collections, historic parks and gardens but also established culturalactivities such as the Brighton Festival, exhibitions and community based arts and culturalevents. The city is known internationally for its extensive Regency and Victorianarchitecture and has approximately 3,400 listed buildings. The city is also a majorEuropean business conference and tourist destination which attracts around 8m visitorsand brings £408 m into the local economy annually and 15 to 20% of jobs. The 11kmof seafront is the ‘shopfront’ of the city acting as a focus for entertainment, recreationand leisure activities. Substantial public and private investment has transformed theseafront between the Piers. Phased renewal of the coastal defences between Marina andthe city boundary at Saltdean has been undertaken over the past 15 years, part of anongoing programme of coastal defence maintenance.

1.5 The city is a regional centre for shopping and employment and a sub-regional centrefor health services. The economy has performed strongly in recent years, growing by£1.5bn between 1996 and 2004 (2006 prices), with significant falls in unemploymentand rises in average earnings. The city has a strong service sector economy, with publicservices, education and health and financial and business services being rich sources oflocal employment. Brighton & Hove is home to the biggest creative industries cluster inthe south east outside London, currently providing over 10% of employment in the

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Part One - Context, Vision and Objectives

1 Mid year estimate for 2003

economy. The city is known as a profitable place for business with a strongentrepreneurial culture and a large proportion of residents working in higher gradeprofessional occupations and the population as a whole is well-educated compared withthe South East and national averages.

1.6 The city has a well-defined network of shopping centres and contains a significantlygreater number of shops than other cities of similar size, with a strong reputation forspecialist and independent traders. The two growing Universities within the city hostaround 32,000 students and with high graduate/ post-graduate retention they make amajor contribution to the economic, social and cultural life of the city.

1.7 The city is a regional transport hub, with the A23/M23 linking it to London/M25 andthe A27 providing major east-west links. Car ownership in the city is lowest in the SouthEast region and one of lowest nationally and bus patronage and cycling and pedestrianmovements in and out of the city centre have continued to increase since 2000. The city’srail network includes 8 stations over three lines with Brighton Station having the highestdaily passenger volume of all stations along the south coast between Kent andHampshire. Shoreham Harbour on the western side of the city is a regionally significantport.

1.8 Brighton & Hove is a diverse city of neighbourhoods and communities - in the 2001census 94.3% of the city’s population classified themselves as white and 5.7% as blackor from minority ethnic groups. 8.7% of children and young people are from black orminority ethnic (BME) groups. The city’s largest minority group is the lesbian, gay, bisexualand transgender (LGBT) community, estimated to be about 1 in six people in the city.

Drivers for Change

1.9 The Local Development Framework Core Strategy will need to take into account ofthe key drivers for change that will affect the city over the next twenty years, including:

l The population is expected to grow to 295,700 by 2026 if current trends continue2.

l Brighton & Hove has a high proportion of young working age adults and by 2050there will be 90,500 people aged 50 years and above living in Brighton & Hove, anincrease of 20%.

l Population density of the city is over 30 residents per hectare, much greater thanthe South East3 or national average4. The private rented sector has some of theworst overcrowding outside London.

l To address the level of housing need identified in the city 2,520 affordable homeswould have to be provided annually to meet the shortfall.

l Affordability of housing has serious implications for the recruitment and retention ofstaff. It has also resulted in a high number of concealed households.

l Homelessness remains a significant problem; proportionately there are around twiceas many homeless households in priority need within the city in comparison withthe South East and national figures.

l There is an under-supply of housing adaptable to the needs of disabled or ageingresidents.

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2 Office of National Statistics forecast, 20043 South East excludes London4 National means England and Wales

l There is a national trend towards increased car use. Accompanied by theanticipated future development in the city this will lead to severe congestion andpoor air quality by 2026 without a number of positive measures to mitigate theseimpacts.

l Given the relative absence of major industrial polluting processes in Brighton &Hove, transport is the main cause of poor air quality in certain parts of the city. In2008 an extended Air Quality Management Area was designated covering asignificant area of the centre of the city.

l Whilst the creative industries are a growing and vibrant sector (with forecast growthbetween 2.5 and 5% per annum over the next 10 years) creating jobs, prosperity,cultural activity and tourism benefits, this can only be sustained if appropriate andaffordable workspace is available.

l The city has a lack of affordable business premises.

l Set against economic success, the city is a net exporter of commuters, 33,000 wholive in the city work outside whilst 28,000 of the city’s workers live outside the city.

l The working age population is projected to increase by 12,000 over the next 10years. This would mean that in order to maintain the current employment rate of75.6%, more than 8,000 people will need to be moved into work.

l The city’s unemployment rate is still significantly above the South East average andover 22% of adult residents have no qualifications, and school achievement level isbelow the national average.

l Worklessness across the city remains stubbornly high with 13,000 people onincapacity benefits and up to 17,000 on job seekers allowances (2006). Theproportion of young people classed as ‘not in education, employment or training’continues to be a concern and is currently at 10% (against a target of 7%).

l There is evidence that the city is developing a ‘dual economy’ with a largeproportion of highly skilled jobs in knowledge-based occupations supported by agrowing number of lower paid workers in lower skilled, frontline support servicesincluding care work and many of the hospitality and retail trades.

l Within the South East, Brighton & Hove ranks as 2nd most deprived local authorityarea in terms of its average Index of Multiple Deprivation ranking. Particular‘hotspots’ of deprivation are within the East of Brighton (NDC) and there are 10priority deprived neighbourhoods.

l Whilst real progress has been made in reducing the gap between deprivedneighbourhoods in the city and England, there are risks of greater polarisationbetween deprived areas and the rest of the city. Those most affected by inequalityin Brighton (when measured by income, benefit dependency, health and lifeexpectancy, crime and environment) are children living in poverty, but there are alsosignificant groups across the city with multiple needs concentrated in the mostdeprived areas.

l There is a shortfall of primary school places in the centre and west of the city andan oversupply in the north-east of the city.

l Brighton & Hove’s ecological footprint has recently been calculated as 6.5 ha perperson. This eco foot print is not sustainable and the city needs to shift towards amore resource efficient future. 12


l There is an urgent need to move to a low carbon economy and city. The ClimateChange Bill sets out the government’s target to reduce carbon emissions to 60% ofthe 1990 levels by 2050, regional targets are set out in the draft South East Planand the Council’s Sustainable Community Strategy sets a 3.5% per annumreduction target between 2006-2020.

l There is a need to make a significant contribution to low and zero decentralisedenergy production during the lifetime of the Core Strategy and to contribute tomeeting the draft South East Plan regional renewable energy targets and sub-regional targets for land-based renewable energy.

l The city is within a ‘highly water stressed’ region with above regional average percapita water consumption there is therefore a need to secure the sustainablemanagement of water resources and meet the objectives of the Water FrameworkDirective.

l In England and Wales, sea levels have risen by an average 1mm a year over the lastcentury. Current guidance5 is that planning should anticipate sea level rises of 6mma year in South East England and ensure the city is resilient to the predicted impactsof climate change such as warmer, wetter winters, hotter, drier summers, sea levelrise and more frequent extreme weather events.

l Much of the Downland including the ancient woodland at Stanmer will be includedwithin the boundary of the proposed South Downs National Park (expected to beconfirmed in 2008).

l Available evidence suggests a continuing loss of species and habitats.

l In the denser inner core, access to open space is limited, particularly to the east ofthe city. In the west of the city, the seafront lawns and larger urban squares make asignificant contribution to available recreation space.

l Sports and recreation facilities and opportunities are as yet inadequate for a city ofits size and regional importance.

l Brighton & Hove faces increasing competition from home and abroad as a touristdestination both in the leisure and business tourism market.

l Great strides have been made in making the city a healthier place to be, howeverthe health gap between rich and poor continues to grow.

l A young mobile population has implications for range of issues such as a sense oflocal community, potential for crime and disorder, need for suitable employmentopportunities and need to provide a mix of housing units and tenure.

l Whilst community safety is improving in the city, many people are still victims ofcrime.

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5 The United Kingdom Climate Impact Programme (UKCIP) will be published future climate changescenarios for the UK in November 2008 and these will need to be incorporated.

Planning Policy Context

1.10 The Core Strategy must take account of Government planning policy and advice, asset out in Planning Policy Statements (PPS) and must translate this into the local contextwhere appropriate. The Government’s overarching planning policy is set out in PlanningPolicy Statement 1: Delivering Sustainable Development (PPS1). In order to plan forsustainable development, development plans need to carefully consider theinterrelationship between social inclusion, protecting and enhancing the environment, theprudent use of natural resources and economic development.

1.11 The Core Strategy must take account the priorities set out in the RegionalEconomic Strategy 2006-2016 (RES) which identifies the Coastal South East as an areaof untapped economic potential, and the Brighton & Hove (Sussex Coast) Diamond ashaving the potential to stimulate prosperity across a wider area. The overarchingobjectives for the south east set out in the RES are for global competitiveness, smartgrowth and sustainable prosperity. The Core Strategy should also generally conform withthe South East Plan, which will be formally adopted before the Core Strategy. The draftSouth East Plan:

l aims for a healthier region, a more sustainable pattern of development and adynamic and robust regional economy.

l It locates Brighton & Hove at the centre of a Sussex Coast sub-region stretchingfrom Chichester to Rye. This sub-region is designated a ‘regeneration area’ where aparticular need for economic and social regeneration sits alongside extensiveenvironmental designations.

l Gives the city an important role as a catalyst for the renaissance of the wholeSussex coast.

l Additional housing development in Brighton & Hove is expected to take the form ofnew strategic allocations on brownfield sites. Brighton & Hove is currently likely tobe required to provide 11,000 new homes over the plan period to 2026 (550per year).

l The draft Plan also requires, and sets out criteria for, the allocation of sites foremployment use.

l Brighton is identified as part of the regional network of strategic city/town centresand the city is defined as a regional transport hub.

l The coastal strip is regarded as a priority area for tourism and the attraction of thecity is promoted to encourage longer stays through linked trips to surroundingareas.

l Regency Brighton is identified as a regionally significant historic built environment.

Local Strategies and other Plans

1.12 The Core Strategy is expected draw on other plans and strategies produced by thecouncil, or other organisations, that have implications for the development and use ofland, particularly the Sustainable Community Strategy and the Local Transport Plan.

1.13 Every council has been asked by the Government to set up a local strategicpartnership to produce a Sustainable Community Strategy which will co-ordinate effortsto tackle identified priorities for the city. Brighton & Hove’s Sustainable CommunityStrategy sets out a vision for a City of Opportunities by the year 2020. It focuses on eightpriority themes as identified by local residents. The strategy was put together by the 2020

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Community Partnership, made up of 32 representatives of bodies or organisations thatprovide services or whose actions affect quality of life in the city. It was reviewed in early2006 and the priority themes are:

l Promoting Enterprise and Learning

l Reducing Crime and Improving Safety

l Improving Health and Well-Being

l Strengthening Communities and Involving People

l Improving Housing and Affordability

l Promoting Resource Efficiency and Enhancing the Environment

l Promoting Sustainable Transport

l Providing Quality Services

The table below shows how the Core Strategy help delivers the Sustainable CommunityStrategy priorities:

15


Sustainable Community Strategy Priority ThemesCoreStrategyRevisedPreferredOptions

PromotingEnterpriseandLearning

ReducingCrime andImprovingSafety

ImprovingHealthandwell-being

StrengtheningCommunitiesand involvingPeople

ImprovingHousing andAffordability

PromotingResourceEfficiency &EnhancingtheEnvironment

PromotingSustainableTransport

DA1 -BrightonCentreandChurchillSquareArea

4 4 4 4 4

DA2 -BrightonMarinaandBlackRock

4 4 4 4 4 4 4

DA3 -LewesRoad

4 4 4 4 4 4 4

DA4 – NewEnglandQuarterandLondonRoad

4 4 4 4 4 4 4

DA5 –EasternRoad/EdwardStreet

4 4 4 4 4 4 4

DA6 –HoveStationArea

4 4 4 4 4 4

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Sustainable Community Strategy Priority ThemesCoreStrategyRevisedPreferredOptions








DA7 –ShorehamHarbour& SouthPortslade

4 4 4 4 4 4 4

SA1 – TheSeafront 4 4 4 4

SA2 –CentralBrighton

4 4 4 4 4

SA3 –ValleyGardens

4 4 4 4 4

SA4 –UrbanFringe

4 4 4 4

SA5 –SouthDowns

4 4 4 4

SN1 –SustainableNeighbourhoods

4 4 4 4 4 4 4

SN2 –ResidentialRenewalAreas

4 4 4 4 4 4 4

CP1SustainableBuildings

4 4

CP2 UrbanDesign 4 4 4

CP3 PublicStreets &Spaces

4 4 4 4 4

CP4HealthyCity

4 4 4 4 4 4

CP5Biodiversity 4 4 4

CP6 OpenSpace 4 4 4 4

CP7 Sports&Recreation

4 4 4 4

CP8SustainableTransport

4 4 4 4 4

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Sustainable Community Strategy Priority ThemesCore StrategyRevisedPreferredOptions








CP9DeveloperContributions

4 4 4 4 4 4 4

CP10ManagingFlood Risk

4 4

CP11 HousingDelivery 4 4

CP12AffordableHousing

4 4 4

CP13 HousingDensities 4 4 4

CP14 GypsiesandTravellers

4 4 4 4

CP15 RetailProvision 4 4 4 4

CP16 StrategicEmploymentSites

4 4

CP17 OtherEmploymentSites

4 4 4

CP18 CultureTourism andHeritage

4 4 4 4 4 4

CP19Hotel/GuestAccomodation

4

1.14 The second Full Local Transport Plan, covering the period 2006 - 2011, was adoptedby the council in March 2006. Its objectives are to:

l Reduce danger for all road users

l Improve accessibility on sustainable transport modes

l Encourage partnership and innovation

l Seek compatibility between transport and planning policies

l Reduce road traffic, pollution and congestion

l Improve the economic, environmental and social viability of the city

1.15 Tackling congestion includes the implementation of sustainable transport corridors,the promotion of car clubs, walking and cycling initiatives, urban realm improvementsand a major funding bid for a road-based rapid transport scheme. Addressing road safetyincludes safer routes to school and speed management and the council is undertakingmajor city centre road safety schemes at the Clock Tower and Castle Square. The Planfurther includes measures to improve accessibility, and equality of accessibility, to servicesand facilities and specifically identifies measures that have the potential to improve airquality.

1.16 The city council has also produced a Climate Change Action Plan for Brighton &Hove, which is updated regularly. It has been taken into account in drafting all sections ofthis document and, where appropriate, will be developed further at the submission stageof the Core Strategy and within other LDF documents. The council is also working on apreparing a revised Sustainability Strategy and a Climate Change Strategy for the LocalStrategic Partnership which will need to be reflected in the submission Core Strategy.

1.17 A substantial number of other local plans and strategies have been taken intoaccount in producing the Preferred Options document. These are referred to, whereparticularly relevant, in Parts Two and Three of this document.

The Research and Evidence Base

1.18 The studies and documents which form the main research and evidence base for theCore Strategy are specifically referred to where relevant in Parts Two and Three of thisdocument and are summarised in a separate Supporting Evidence Document.

Community and Other Stakeholder Involvement

1.19 The city council carried out extensive community and other stakeholder involvementat the Issues and Options Stage of the Core Strategy, between late October 2005 and theend of May 2006, which involved over one thousand people across a range ofconsultation exercises, workshops and events. The range of methods used to engagepeople is detailed in a Statement of Consultation which was published in October 2006.Consultation on the Preferred Options Core Strategy, between late October 2006 –December 2006 also involved a range of consultation exercises, workshops and eventsand a Statement of Consultation has been prepared and is available separately from thecouncil and on the website. Community involvement has helped inform the revisedPreferred Options and summaries of consultation responses are set out in the SupportingEvidence section in Annex 1 to show how they have helped to shape the revisedpreferred options.

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A Spatial Vision of Brighton & Hove in 2026

1.20 The vision for the city reflects the main characteristics and key drivers for change inBrighton & Hove set out in the start of Part One and takes account of existing plans andstrategies to set out what kind of city Brighton & Hove should be in 2026. It cannotencompass every aspiration for the future but concentrates on the strategic planningaims that could be accomplished within a twenty year timescale. Working closely with allsections and areas of the local community the aim is to achieve the following:

l Work towards becoming a zero carbon6 city with lower carbon emissions supportedby sustainable and renewable decentralised sources of energy and ensure the city isresilient to the predicted impacts of climate change.

l Ensuring new development and change is accommodated in the most appropriateareas of the city; positively addressing local priorities including improving theattractiveness, accessibility and liveability of the city, strengthening the localeconomy and improving the well-being of residents.

l Brighton & Hove will play its full role in the economic growth and development ofthe South East region.

l In partnership, Brighton & Hove will play a lead role in improving the performanceof the Sussex Coast sub-regional economy and help to reduce inter-regionaldisparities.

l Major developments such as the replacement Brighton Centre and Preston Barrackswill act as exemplars of modern design quality and sustainable building practice aswell as support the regeneration of the city.

l To have helped to create more sustainable communities by ensuring a mix of newhousing types, including family homes to match lifetime needs in suitable locations,which offer a good range of community facilities and with good access to jobs, keyservices and infrastructure and thereby reducing the need to travel, building strongcommunities that get involved in influencing decisions.

l By 2026 no one will be seriously disadvantaged by where they live in the city andthe gap between the deprived neighbourhoods and the rest of the city will benarrowed through improvements to infrastructure and support services, by wideningaccess to learning and employment opportunities and by supporting andencouraging community engagement in regeneration and local decisions.

l To have reduced the ecological footprint of the city ahead of draft South East Plantargets.

l Ensure that all new development minimises carbon dioxide emissions, water use,maximises the potential for sustainable construction methods and minimisedemolition and construction waste.

l To have raised the standards of design and architectural quality to ensure that newdevelopment respects and positively enhances the distinctive urban or suburbantownscape of the city’s different neighbourhoods.

l To have secured a high quality public realm which accommodate the needs of allpeople and create public places where people feel safe and at ease with reducedopportunity for crime and reduced fear of crime.

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6 Work towards a city that achieves zero carbon emissions.

l To be a ‘Healthy City’ through promoting the active participation of residents of allage groups in sports and physical activity, healthier living conditions and a city-widenetwork of walk-in polyclinics, health centres, children’s centres and specialistservices providing equality of access to healthcare.

l In 2026 the city will qualify for designation as an UNESCO Biosphere Reserve andwill be an exemplar of new, innovative and optimal practices for integrating theconservation management of the natural environment with urban development

l The downland countryside will be conserved and its links to urban green spacesstrengthened via a green network across the city where biodiversity is enhanced andequality of access to natural open space is achieved.

l To have taken a key role in promoting the city as a gateway to the National Park.

l The city’s open spaces will be well maintained and more accessible to everyone; theValley Gardens in particular will be a more attractive, accessible and usableenvironment.

l To be a ‘Sporting City’ where a wide range of leisure opportunities are providedwhere they are most needed including at Black Rock and King Alfred, and thecommunity stadium will form a focal point for the city’s sporting aspirations.

l In 2026 there will be:

l more people but less traffic and congestion in the city by a reduction in car useof 10-20%;

l less air borne pollution, less traffic noise and far lower carbon emissions;l a flexible transport network incorporating transport interchanges, more

sustainable transport corridors and accommodating peaks of demand;l a Rapid Transport System to move people efficiently to and between major

leisure, retail, tourism and employment sites as well as major residentialdevelopments, and;

l People will be able to move more easily, safely and effectively around the city onfoot, by bicycle on public transport.

l Through an integrated package of long term and short term measures, significantchange and improvement will have been made in local air quality.

l To have addressed the issues of homelessness and overcrowded households andmade substantial progress in meeting the demand for new households by providingsufficient housing that is affordable, accessible and well-designed.

l In conjunction with partners the city’s housing will be brought up to a decentstandard.

l There will parity in the quality of schools across the city giving parents theconfidence to access their local schools.

l To be England’s favourite ‘Creative City’ through an expanded base and support forthe arts and creative industries across the city, drawing on the local workforce, anda thriving creative and cultural quarter in the city centre.

l To be Europe’s best meeting destination and the city’s tourism industry will havegrown significantly but sustainably into a year-round profitable business with 12%more jobs in tourism by 2014.

l The regeneration of the seafront will have continued, with significantly improved 20


seawater quality and ensured that the location and design of development reducesand adapts to the risk of flooding and coastal erosion.

l To continue to bring new life to the city’s built heritage, in recognition of the city’sstatus as a premier historic resort of national significance and international renown,and the contribution such historic areas make to the city’s regeneration.

l The economic performance of the city will continue to improve and GVA will haverisen by 3.2% per year to 2016 and the city’s long-term unemployment rate willhave fallen with an increase in employment rate in the priority identified renewalareas.

l Sustained economic growth will be achieved by:

l Ensuring a range of suitable sites and premises;l Supporting the city’s key and growing employment sectors with a well-trained

and suitably skilled local workforce;l Training and support for local entrepreneurs and start-up businesses.

l In 2026 the city will support a thriving environmental technology sector to supportthe development of renewable and low-carbon energy, recycling initiatives andreduced resource consumption.

l The role of the higher and further education establishments in the city will continueto grow and strengthen and schools will be fit for purpose.

Revised Spatial Objectives

1.21 These objectives derive from the priorities set out in the vision for the city; they willprovide the overall strategic basis for the policies that will be developed from thepreferred options and for the other planning documents that will make up the LDF. Theseobjectives have been revised from the Preferred Options stage in light of consultationcomments and re-ordered (for reference the old spatial objective number is shown inbrackets at the end of the objective).

SO1 Make full and efficient use of previously developed land in recognition of thephysical constraints of the sea and the South Downs on the city’s development and theneed to provide for 11,000 net additional dwellings in the period 2006-2026 and anadditional 20,000sqm of office floor space. [SO4]

SO2 Contribute to a reduction in the ecological footprint of Brighton & Hove andchampion the efficient use of natural resources and environmental sustainability. Ensurethat new development in Brighton & Hove is sustainable in terms of design, constructionand the predicted local impacts of climate change. Promote improvements to thesustainability of existing buildings. [SO1 and SO2 combined]

SO3 Ensure that all major new development in the city supports the regeneration of thecity, is located in sustainable locations, provides for the demands that it generates and issupported by the appropriate physical and social infrastructure. [SO3]

SO4 Address the housing needs of Brighton & Hove by working with partners to providehousing that meets the needs of all communities in the city, that has the right mix oftypes, sizes and tenures, and that is affordable, accessible, designed to a high standardand adaptable to future change. [SO10]

SO5 Ensure design excellence which responds positively to the distinctive character ofthe city’s different neighbourhoods and creates an attractive and accessible well-connected network of streets, spaces and buildings. [SO6]

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SO6 Conserve and enhance the Area of Outstanding Natural Beauty / proposed SouthDowns National Park, including the promotion of an enhanced downland landscape, withgreater biodiversity; more sustainable farming practices and improved public access.Enhance and promote physical and sustainable transport links between the city and theDowns. [SO20]

SO7 To support the creation of an Urban Biosphere Reserve7, a Green InfrastructureNetwork will be established in Brighton & Hove to conserve and enhance the priorityareas for biodiversity and to ensure that everyone has access to natural open space.Nature conservation opportunities in open spaces and in new development should bemaximised to meet Biodiversity Action Plan8 objectives. [SO21]

SO8 Promote new opportunities for sport and recreation through the development ofkey sites such as the Community Stadium and the King Alfred Sports Centre. Protect andenhance the quality and quantity of parks and green spaces in the city, formal andinformal, building on their individual character and landscape to ensure that they arevalued by the whole community and well used throughout the year. [SO22]

SO9 Enhance and maintain the distinctive image and character and vibrant, variedheritage and culture of the city to benefit residents and visitors and support the role ofthe arts, creative industries and tourism sector in creating a range of high qualityinfrastructure support facilities, spaces, events and experiences. [SO18]

SO10 Preserve and enhance the city’s recognised cultural heritage and bring vacantbuildings of national or local architectural or historic interest back into appropriate uses.Ensure new developments contribute positively to their historic surroundings. [SO7]

SO11 Enhance the seafront as a year round place for tourism, leisure, recreation andculture whilst respecting the coastal and marine environment. [SO19]

SO12 Develop Brighton & Hove as a major centre on the South Coast for businessgrowth and innovation, creative industries, retail, tourism and transport. [SO11]

SO13 Support the continued improvement of the economic performance of the city byidentifying and safeguarding an appropriate range of sites and premises to meetdemands of high growth and key employment sectors and ensuring there is a welltrained and suitably skilled local workforce. [SO13, SO12 and SO14 summarised]

SO14 Achieve more parity in the quality of education provided at schools and reduce theimbalance in demand for primary school places in different parts of the city. Assist in thelong term planning of higher and further education establishments, and ensure that theyplay a full part in the city’s economic and social development. [New]

SO15 Maintain and strengthen the role of Brighton city centre, recognising andprotecting its unique cultural, tourism and retail mix and look to diversify the eveningeconomy and leisure function. [SO16]

SO16 Maintain and enhance the distinct character and physical environment of the city’sestablished network of shopping centres to ensure they remain vibrant, attractive andaccessible. [SO17]

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7 Areas nominated by national government and designated under UNESCO’s Man and Biosphere (MAB)programme. They can encompass urban areas, forming sites of excellence to explore and demonstrateinnovative approaches to conservation and sustainable development. They aim to reconcile the conservationof biodiversity with economic development.8 A plan prepared by the city council and nature conservation organisations to reverse the decline in thevariety of species of animals and plants.

SO17 Contribute towards the delivery of more sustainable communities and thereduction of inequalities between neighbourhoods in Brighton & Hove. [SO15]

SO18 Contribute towards reducing inequalities experienced by different groups withinthe city and recognise the special needs of younger people, older people, disabledpeople, lesbian, gay, bisexual and transgender people and black and minority ethnicpeople, refugees and asylum seekers and people of different religions and belief in theprovision and improvement of accessible and appropriate community facilities, healthcare,education, housing, safety and employment. [New]

SO19 Across the city apply the principles of healthy urban planning and work withpartners to achieve an equality of access to community services (health and learning), toopportunities and facilities for sport and recreation and lifelong learning. Ensure pollutionis minimised and actively seek improvements in water, land and air quality and reducenoise pollution. [SO8 and SO23]

SO20 Ensure that Brighton & Hove is a city where all people feel safe in public placesand within their neighbourhoods through working with partners to create a saferenvironment, reduce crime and reduce the fear of crime. [SO9]

SO21 Support a reduction in car use so that there will be less congestion, less air bornepollution, less traffic noise and less greenhouse gas emissions and work with partners todevelop safe and sustainable means of access to and across the city including measuresto improve bus and rail services and consideration of a rapid transport system and sitesfor park and ride. [SO5]

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2.1 Brighton & Hove must respond to and provide for the needs of a growing populationand a growing local economy over the next 20 years. This includes providing for the11,000 new homes required by the draft South East Plan. The city must do this withinthe physical limits of the city, a future South Downs National Park and a scarcity ofdevelopable land, whilst meeting and integrating the environmental, social and economicaims of sustainable development.

2.2 From the start of the preparation of the Core Strategy (the ‘issues and options’ stagein 2005) there has been a reassessment and refinement of the approach toaccommodating development in the city over the next 20 years from the initial 5 possiblebroad approaches, to the original preferred Spatial Strategy and consideration ofalternative approaches set out in the Preferred Options Core Strategy, October 2006 andthis refinement has involved ongoing consultation, sustainability appraisal and evidencegathering. Further details are set out in Annex 1. The original spatial strategy, which setout 10 broad areas for accommodating growth has been re-examined in light ofconsultation responses, further research and evidence gathering and emerging nationalplanning policy and guidance since October 2006.

2.3 The potential of limited development within the urban fringe was re-assessedfollowing publication of the 2007 proposed boundary modifications for the South DownsNational Park and through the Strategic Housing Land Availability Assessment. Thepotential of identifying a strategic development site at Shoreham Harbour was re-examined in light of emerging proposals put forward by the South East EnglandDevelopment Agency.

2.4 The council’s preferred option is still to accommodate future development byoptimising development on brownfield sites throughout the existing built-up area of thecity, in order to preserve the countryside, directing significant growth and development tokey broad areas identified for regeneration or renewal to bring about sustainablecommunities.

2.5 The original 10 broad areas were identified from applying the combined accessibility-led approach and the urban character / urban capacity-led approach to accommodatinggrowth. The opportunities and potential for development within these original 10 areashave been further examined in order to indicate broadly the capacity of the areas to takeadditional development and the type of development that would be most appropriate.

2.6 Local priorities (such as transport improvements, community safety, open space orpublic realm improvements) within these areas and how these could be best addressedthrough the Core Strategy (identified as ‘place-shaping’ priorities) are now set out as partof the proposals for these areas as well as an indication of how the area proposals will beimplemented and delivered. Alternative development options for the areas were alsoidentified and considered and this is set out in Annex 1.

2.7 The revised spatial strategy was informed by an Appropriate Assessment ScopingReport, an interim Transport Assessment, a Strategic Flood Risk Assessment, StrategicHousing Land Availability Assessment (interim findings), Strategic Housing MarketAssessment and through a revised Sustainability Appraisal.

24


Part Two - Spatial Strategy

The council’s overarching spatial strategy for the city to 2026 is to accommodatefuture development within the built up area of the city by optimisingdevelopment on brownfield land and thereby preserving the countryside.

This will be achieved by directing significant development to seven broad areas ofthe city where it is possible to make full use of public transport/ public transportinterchanges and where identified capacity exists to accommodate futuredevelopment.

The development areas are proposed to accommodate a significant amount ofdevelopment because they contain opportunities for change, they can deliverdevelopment of city wide or regional importance and/or because they are in needof regeneration. These seven areas are:

l Brighton Centre and Churchill Square area

l Brighton Marina and Black Rock

l Lewes Road

l New England Quarter and London Road

l Eastern Road and Edward Street

l Hove Station area

l Shoreham Harbour and South Portslade.

Proposals for these areas and indicative amounts of development are set out inDA1- DA7 alongside local priorities. CP11 sets out the full 15 year supply ofhousing sites.

Additional areas of the city are identified as part of the Spatial Strategy as theyrequire a special or coordinated approach to managing future change in theseareas. Proposals are set out in SA1- SA5.

Further proposals are set out to improve the sustainability of remainingresidential areas of the city with the priority to reduce inequality. These are setout in SN1 and SN2.

The indicative amount and type of development to be delivered by theDevelopment Areas is set out in the following table:

25


The revised spatial strategy

Table 1 - Indicative minimum amount of development by type and byDevelopment Area 2006-2026 (as at 1st April 2006)

26


DevelopmentAreas.

Land Uses

DA1BrightonCentreandChurchillSquareArea

DA2BrightonMarinaandBlackRockSite9

DA3LewesRoad

DA4NewEnglandQuarterandLondonRoad10

DA5EasternRoadEdwardStreet

DA6HoveStationArea

DA7ShorehamHarbourandSouthPortslade11

Totals

Offices 500 sq m

24,800sq m

45,000sq m

14,900sq m

20,00012

sq m

105,200sq m

Industrial4,000 sq m13 1,610 sq m

5,610 sq m

Retail 20,000sq m

5,000 sq m

4,446 sq m

29,446 sqm

Hotel317bedrooms14

17,000sq mhotel

2 hotels

Leisure 28,000 sq mconferencecentre and6 screencinema

3,470sq mInternationalArena/icerink

22,374 allpurposeseaterstadium

Residential8 units

2,000units

358 units 795 units 311 units295units

107 units3,874units 15

CommunityUse

1,000 sq m

17,000sq m

GPSurgery

18,000 sqm

Other2,000 sq mteachingandlearningspaceUniversityexpansion16

17,000 –34,000 sqm hospitalspaceUniv.Library,Dancestudio &Creativeworkspace

9 Includes outstanding commitments from Brunswick Scheme as at 1st April 2006.10 Includes outstanding commitments from Brighton Station developments as at 1st April 2006.11 Identified sites with planning permission/ suitable for housing outside Shoreham Harbour. Awaiting

detailed proposals from SEEDA and outcome of further technical studies.12 Exact potential requires further work but includes unimplemented planning permission.13 Indicative minimum for Gas Work Site14 Net gain of 175 bedrooms15 Strategic Housing Land Availability Assessment. Please see Housing Land Supply table in CP11 for full

details on how the 11,000 dwelling requirement set out in the draft South East Plan will be met.16 10% (c.11,000 sq m) over next 5 yrs at University of Brighton and 25% within Sussex University over

next 15 years; 2,500 student units.

Reason for the Revised Spatial Strategy

2.8 The council’s preferred option is still to accommodate future development byoptimising development on brownfield sites throughout the existing built-up area of thecity, in order to preserve the countryside, directing significant growth and development tokey broad areas identified for regeneration or renewal to bring about sustainablecommunities. Following the assessment of the 10 broad areas the following areas are nolonger part of the spatial strategy:

Portland Road - following consultation comments and further assessment whilstopportunities were identified for townscape improvements and improvements to the localshopping centre there was not sufficient capacity to accommodate significantdevelopment to warrant its inclusion as a specific Development Area. The proposedSustainable Neighbourhoods Proposals and general Core Policies were consideredsufficient policy guidance for future development in this area. The EDF site on PortlandRoad is proposed for inclusion in the wider Shoreham Harbour/ South Portslade area.

Old Shoreham Road corridor – following consultation comments and furtherassessment, it is considered that whilst there is the potential for improvements relating tothe sustainable transport corridor and north-south links in the Hove area along thecorridor, the majority of sites along Old Shoreham Road have been identified within theEmployment Land Study as requiring safeguarding for employment uses and therefore donot present significant development opportunity. However links to Old Shoreham Roadhave been made in the Hove Station Area as they relate to that area and in theShoreham Harbour and South Portslade area.

Western Seafront (Kingsway and Wellington Road) - following further investigationof opportunities for additional development beyond existing commitments it was felt thatthis area did not present significant development potential and opportunities regardingtownscape improvements and improved links to the seafront could be better dealt with ina revised Seafront Preferred Option (see SA1).

The following areas were combined to create a larger broad development area:

Brighton Station/ New England area and London Road/ Preston Road Corridorhave been merged as one Development Area because it was considered following furtherinvestigation and the findings of the LR2 Regeneration Strategies (2007) that the closeproximity of the New England area to London Road town centre and the Preston Roadcorridor suggested that these areas were better treated comprehensively and this wouldalso offer greater clarity for investment decisions and coordination of strategies.

Inclusion of Shoreham Harbour in the Spatial Strategy

2.9 The potential for significant regeneration of Shoreham Harbour to create a mixed-usesustainable community around a consolidated, modern port operation has previouslybeen recognised. However, implementation has been frustrated by a number of complexinfrastructure costs.

2.10 In response to concern raised at the ‘issues and options’ stage about the lack ofapparent means to fund infrastructure requirements necessary for development to goahead at the port, Option E – identification of strategic development sites was notpursued as part of the Spatial Strategy in the Preferred Options document and ShorehamHarbour was therefore not included in the list of 10 broad areas where the bulk of thecity’s development was expected to be accommodated. The city council recognised thepotential for the Harbour in the long term and the requirement to take a pro-activeresponse and included a specific policy for Shoreham Harbour.

27


2.11 Since then the South East England Development Agency (SEEDA) has been workingwith Shoreham Port Authority and the three local authorities involved (Brighton & Hove,Adur District Council and West Sussex County Council) to develop a new set of proposalsfor the Harbour with a view to producing a deliverable redevelopment programme.

2.12 The new proposals are considering a redevelopment scheme that is much moresignificant in scale and scope than previously. The scheme that is now emerging looks ata wider area than just the Harbour, comprising South Portslade (plus Southwick andFishergate in Adur District). In order to accommodate the scale of investment ininfrastructure the proposal is likely to involve 5,000 to 10,000 homes (2,000 to 6,000 inBrighton & Hove) and 7,000 to 8,000 jobs in total. The details of the scheme arecurrently under active discussion.

2.13 Discussions have reached the stage where a delivery plan setting out the potentialto implement a scheme in the long term can now be devised. This is likely to include thepreparation of an Area Action Plan by the three authorities with financial support fromSEEDA. For this reason Shoreham Harbour/South Portslade has been added to the list ofDevelopment Areas in the Core Strategy.

2.14 However, there are still a number of significant issues to be addressed. A key area isthat of flood risk. The Strategic Flood Risk Assessments for Brighton & Hove and Adurhave identified parts of the Port as being of high flood risk. Therefore, PPS25 requires theapplication of a sequential/exceptions test to be passed before certain developmentscould be permitted on these sites. The designation of a wider area including SouthPortslade within the Area Action Plan might also assist in this process by allowingflexibility as to the location of the various uses, particular those classified as vulnerableuses in areas identified of lower flood risk.

2.15 Due to the proposals being at an early stage, no contribution from development inthis area to strategic requirements of the Core Strategy has been assumed.

Exclusion of the Urban Fringe from the Spatial Strategy

2.16 Whilst consultation responses suggested a lack of consensus as to the role of theurban fringe, the option of allowing limited development within the urban fringe in thelonger term (beyond 10 years) was reconsidered as part of the overall strategy foraccommodating development and growth in the city. Further assessment suggests that:

l The extent of the urban fringe could be much reduced following the 2007proposed boundary modifications to the South Downs National Park which indicatessome additional areas of the urban fringe to be included in the proposed boundary.

l the opportunities for developing sustainable communities on urban fringe sites arelimited compared with regeneration opportunities within the built up area;

l there is a need for a coordinated approach to the urban fringe rather than allowingpiecemeal development;

l Initial findings of the SHLAA suggest greenfield sites are not required to meet thecity’s housing land supply.

l Housing development on greenfield sites would not be in accordance with theexpectation of the sub-regional strategy of the Draft South East Plan.

It has therefore not been included in the spatial strategy and the approach to the UrbanFringe is therefore addressed in SA4. 28


Conformity with National and Regional Policies

2.17 It is considered that the overarching spatial strategy best articulates nationalplanning policy in the local context. It is considered to be the option that best promotesand integrates environmental, economic and social objectives in the pursuit of sustainablecommunities (meeting PPS 1). It is informed by an initial assessment of Housing LandSupply as required by PPS 3 on Housing. It concentrates on the redevelopment ofpreviously developed land (‘brownfield’ sites) for housing and plans for mixed usedevelopment and aims to reduce car dependence and improve linkages by publictransport, in accordance PPS 3. It also reflects the emerging guidance in draft PPS4Planning for Sustainable Economic Development by proactively encouraging economicprosperity by identifying broad locations for economic development and mixed usedevelopment. It also makes efficient use of land within and around town centres,including higher-density development where appropriate, in accordance with PPS 6 onPlanning for Town Centres. Further, this option articulates advice in PPG 13 on Transportthat Plans should:

l Actively manage the pattern of urban growth to make the fullest use of publictransport and focus major generators of travel demand in city, town and districtcentres and near to public transport interchanges; and

l Accommodate housing principally within existing urban areas, planning forincreased intensity of development for both housing and other uses at locationswhich are highly accessible by public transport, walking and cycling.

2.18 In all these respects the preferred option is also considered to conform with thedraft South East Plan; in particular it conforms with the sub-regional strategy for housingdevelopment on new strategic brownfield allocations. The preferred option also conformswith the Regional Housing Strategy and the Government’s Sustainable Communities Planfor the South East. It is further considered that a focus on mixed use developmentaround major sustainable transport nodes and corridors would help to develop Brighton& Hove’s roles as a regional hub and as a catalyst for growth within the coastal southeast.

Local Priorities

2.19 With regard to local matters, the spatial strategy is considered to be consistent withthe findings of the Urban Characterisation Study (2007). It has regard to the LocalTransport Plan’s long term objectives to improve accessibility at sustainable transportnodes and to reduce road traffic, pollution and congestion. As well as the proposed rapidtransport system, it also takes account of the existing sustainable transport corridors(A270 Vogue Gyratory, Church Road/Western Road, A23 London Road and A259 fromOvingdean eastwards) and traffic management measures proposed for Valley Gardens.The spatial strategy further has regard to strategic priorities 1, 2, 3 and 6 of the EconomicStrategy and strategic objectives 1, 4, 5, 8 and 10 of the Regeneration Strategy, and hasbeen informed by the Employment and Skills Plan and the Reducing Equalities Review. Ithas also taken into account the overarching priorities of the council’s Housing Strategyand the Refreshed Tourism Strategy.

2.20 The revised Spatial Strategy was also informed and appraised through a number ofassessments. Government guidance requires that a Transport Assessment for the CoreStrategy proposals is undertaken to test the potential traffic impacts of developmentproposals and to provide robust evidence for the Highways Agency on the impacts ofgrowth on key road junctions (the A23/A27 interchange at Patcham). Whilst initial

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findings of the study confirms anecdotal evidence that continued and concerted effort isrequired to tackle growing traffic growth and congestion resulting from currentdevelopment trends, the impact of the proposed spatial strategy on top of the underlyinggrowth forecast was found to be very small because the seven development areas wereidentified due to their location in core urban area; they are adjacent to major publictransport corridors; and a large proportion of development is employment-related. TheStrategic Housing Market Assessment has informed the spatial strategy through itsrecommendations on planning for the right ‘mix’ of new housing (in terms of housingtenure, type and size) to ensure that new development meets local housing need anddemand and contributes to the creation of mixed and sustainable communities. The initialassessment of housing land supply in the city (the Strategic Housing Land AvailabilityAssessment) has indicated in broad terms, the major contribution the seven developmentareas will make in accommodating new housing development. At this stage, the ‘interim’results indicate that the city is likely to meet PPS3 requirements for housing delivery overa 15 year period but this will require the inclusion of a realistic allowance for thedevelopment of (small) windfall sites given the significant development constraintsaffecting the city and the lack of opportunity to identify specific sites.

2. 21 Through the Brighton & Hove Strategic Flood Risk Assessment (SFRA), theproposed approach to accommodating growth in the city has been screened against alltypes of flood risk and the SFRA has informed the preferred spatial strategy andidentification of Development Areas, whereby development has been steered to the areasof lowest flood risk first (the sequential test). An exception test has been required forBrighton Marina and Black Rock Development Area as the sequential test indicates that itlies outside Flood Zone 1 (area of low probability of flooding). For Shoreham Harbour thesequential test concluded that the more vulnerable land uses, such as residentialdevelopment, should be directed to the parts of the Development Area that lie in FloodZone 1, whilst water-compatible development may be appropriate in the areas of higherflood risk. Specific requirements to ensure future development is defended and residualrisk is minimised are reflected in the wording for these Development Areas. Article 6 ofDirective 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora(the Habitats Directive) requires an Appropriate Assessment to be undertaken to assessthe impacts of a plan or project against the conservation objectives of a European Siteand to ascertain whether it would adversely affect the integrity of that site. The Brighton& Hove City Council administrative area includes the Castle Hill Special Area ofConservation and a number of other European or Ramsar wildlife sites are located in thewider area. The Core Strategy has been assessed under the provisions of the HabitatRegulations to ensure that it will not have an adverse effect on any European or Ramsarwildlife site and this assessment has been recorded. The Core Strategy does not supportany project proposal where it cannot be demonstrated that the development would nothave an adverse effect on the integrity of any European or Ramsar site. Any subsequentplan following this Core Strategy will similarly adhere to the requirements of the HabitatRegulations. This conclusion was confirmed by Natural England April 2008.

2.22 Further justification is set out alongside the Development Areas, Special Areas andSustainable Neighbourhoods proposals. The full range of council and city strategies andbackground studies used to inform the spatial strategy is indicated with each preferredoptions and further details on these studies can be found in the separately publishedSupporting Evidence Document.

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Context

2.23 The area around the Brighton Centre is in the heart of the cultural, retail andcommercial core of the city and contains the key drivers of the local tourism, leisure andshopping economy. The Brighton Centre was constructed in 1977 and is now thought tobe outdated in terms of its design, specification and appearance when compared withother more modern conference centres located throughout the UK and Europe. The longterm aspiration of the council, set out in the Sustainable Community Strategy and theadopted Brighton Centre SPD is to secure the city’s conference economy by redevelopingthe Brighton Centre as a successful, high profile, sustainable conference centre.

2.24 Churchill Square and Western Road to the north is the principal retail area ofBrighton regional shopping centre and this area contains the larger, more modern retailunits. There is considerable potential to enhance the pedestrian environment, unitconfiguration, appearance and national multiple retailer representation within thisprimary retail area. In order to enable existing retailers to trade up, and to attract majornew retailers to the centre, it is necessary to identify new opportunities for creatingadditional retail space, in addition to the ongoing redevelopment and modernisation ofcurrent stock.

2.25 West Street contains a concentration of bars and large nightclubs and centralBrighton and particularly the West Street area, continues to experience higher incidencesof violent crime. Coordinated work through the Local Public Service Agreement/ViolentCrime Action Plan has sought to manage the area and reduce violent crime. The CentralSeafront area falls within the Brunswick and Regency Neighbourhood Renewal Area, thepriority theme set out in the Neighbourhood Action Plan is to improve community andpublic safety. The 2007 Detailed Air Quality Assessment has indicated that the WestStreet/ A259 junction exceeds the government’s Air Quality Objective for NitrogenDioxide and the area is now included within the declared 2008 Air Quality ManagementArea.

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DA 1 – Brighton Centre and Churchill Square Area

Supporting Documents:Sustainable Community Strategy - 2006Refreshed Local Area Agreement - 2007Brighton Centre: Area Planning and UrbanDesign Framework SPD - 2005Tall Buildings SPG - 2004Retail Study - 2006Brunswick & Regency Neighbourhood ActionPlan 2007-2010Tourism Strategy - 2008Economic Strategy - 2005Community Safety, Crime & Drugs Audit-2004Hotel Futures Study - 2007Public Space Public Life Study - 2007Local Transport Plan - 2006Conservation Strategy - 2003Open Space, Sport and Recreation Study 2008Strategic Flood Risk Assessment - 2008

Local Priorities

2.26 The following local priorities have been identified for the development area:

l The main priority is a redeveloped state of the art conference centre in a landmarknew building to benefit the city and region and to sustain the tourism economy forthe next 30 years, positioning Brighton & Hove as one of Europe’s leadingconference and meeting destinations.

l The redevelopment also provides an opportunity to deliver new retail floorspace onthe edge of Brighton’s shopping centre to enhance and consolidate Brighton’s roleas a primary regional shopping centre within the South East.

l The redevelopment provides an opportunity to address and improve the currentproblem of pedestrian severance between the northern side of the A259 and theseafront;

l Ensure improvements to local air quality at the West Street/ A259 junction.

l Improved pedestrian environment around Churchill Square, a new gateway linkthrough from Churchill Square Shopping Centre to the seafront, enhanced junctionat West Street and Kings Road.

l Fundamental townscape improvement opportunities and improved built form tocreate a new bold iconic landmark building and opportunities for tall building.

l Improve community and public safety including West Street improvements todiversify the evening economy and initiatives to reduce public place violence.

l Explore opportunities for district heating/ combined heat and power technologieslinked to new development.

Preferred Option – DA1 Brighton Centre and Churchill Square Area

To secure a redeveloped state of the art conference centre in a landmark newbuilding to benefit the city and region and to sustain the tourism economy forthe next 30 years, positioning Brighton & Hove as one of Europe’s leadingconference and meeting destinations.

1. To work in partnership with SEEDA and landowners to plan for a replacementfacility for the existing Brighton Centre with a new state of the art conventionfacility incorporating the highest standard of environmental design;

2. To ensure that the redevelopment benefits the surrounding area through highquality building design and townscape, public realm and biodiversityimprovements, in accordance with the adopted Brighton Centre SPD and draftNature Conservation and Development SPD;

3. Support the extension of the Churchill Square shopping centre to provide aminimum 20,000 sq m of new comparison goods floorspace including A2/ A3use floorspace;

4. Ensure replaced/ new leisure and cultural facilities add to the diversity of theevening economy and address community safety concerns, in particular alongWest Street and the lower seafront promenade.

5. To ensure additional movements by car traffic are the minimum necessary andhigh quality public and sustainable transport facilities serve new development;

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6. Improve pedestrian and cycle access through the area and reduce theseverance between the northern side of the A259 and the seafront to accordwith the Public Space Public Life Study;

7. Ensure the redevelopment proposals complement the priorities for theseafront in this area as set out in SA1.

Supporting text

2.27 The Brighton Centre re-development will deliver a sustainable city centreregeneration scheme, over a 30 year timeframe, with an economic impact of some £2billion for the local economy. The objectives for the council are:

l To deliver a world class state of the art convention centre

l To continue to deliver significant positive impact to the local economy

l To protect and enhance Brighton’s position as a leading conference destination

l To increase the target market and to re-establish Brighton & Hove’s position in theinternational association conference market

2.28 The Brighton Centre SPD (adopted January 2005) provides more detailed planningguidance to ensure redevelopment proposals come forward in a co-ordinated, integratedand complementary manner. The Brighton & Hove Retail Study 2006 identified thepotential to extend the rear of Churchill Square as part of the Brighton Centreredevelopment. Proposals should promote strong linkages with the primary shoppingfrontages, along Western Road in particular and connectivity through to the seafront.Any increase in additional car trips generated by large scale retail provision will need tobe mitigated at source.

Implementation

2.29 The council will work with SEEDA, adjacent landowners and other parts of theprivate sector to deliver this priority during the first ten years of the Core Strategy. Theemphasis will be on:

l Partnership working with key private and public sector partners to achieve a sharedvision for the area.

l Maximising the use of other public sector funding opportunities to help deliver thevision.

l Ensuring that any significant expansion of retail should be developed in conjunctionwith strategic transport solutions such as Park & Ride and RTS expansion/improvements.

l Securing community benefits from Section 106 agreements and other mechanisms.The highest priorities will be given to the provision of all necessary transportinfrastructure, townscape and community safety improvements and trainingopportunities to support this significant regeneration opportunity.

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Context

2.30 Brighton Marina is situated at the base of the cliffs to the east of the city centre. Itwas created in the 1970’s and now functions as an independent component of the urbanarea. The Marina contains a mix of housing, shopping, commercial, leisure andrecreational buildings, together with yacht moorings and a working harbour whichcreates a unique marine character. The Marina is identified as a District Centre in the city’sretail hierarchy (See Policy CP15) The majority of retail activity takes place in theMerchant’s Quay and at the Asda superstore. Whilst the District Centre contains a rangeof bars, restaurants and factory outlet stores related to its wider recreation and leisurerole it lacks the full range of shops and services found typically in District Centres.

2.31 The Marina does not benefit from a coherent urban form, the public realm areas ofthe Marina are particularly poor and the buildings do not create a sense of place. Thelong term aspiration of the council, set out in the adopted Brighton Marina SPG20, is toaddress the deficiencies of the Marina by encouraging an improved urban structure whichcreates easier and more attractive access for pedestrians and cyclists, reduces the impactof car-borne visits, extends the “seafront” up to and around the Marina and createsvisual links with the sea from the Marina. The adopted SPG identified opportunities tointroduce additional retail, leisure, office and residential floor space at the Marina andidentified the following priorities:

l make the most efficient use of previously used and underused land

l achieve a truly mixed use location with a critical mass of residents to ensure thatthere is a comprehensive range of viable services and facilities

l reach a scale of development such that key public transport, pedestrian, community,and service improvements can be made

l ensure a highly sustainable location can be created enabling the number and lengthof car journeys to be minimised, and

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DA 2 – Brighton Marina and the Black Rock site

Supporting Documents:Sustainable Community Strategy - 2006Refreshed Local Area Agreement -2007Black Rock Development Brief SPG -2001Brighton Marina SPG - 2003Brighton Marina PAN - 2008Tall Buildings SPG -2004Tourism Strategy - 2008Hotel Futures Study -2007Retail Study - 2006Economic Strategy - 2005Employment Land Study - 2006City Sports Strategy - 2006Public Space Public Life Study - 2007Urban Characterisation Study - 2007Open Space, Sport and Recreation Study - 2008Local Transport Plan - 2006Strategic Flood Risk Assessment - 2008Beachy Head to Selsey Bill ShorelineManagement Plan – First Review 2007

l that the opportunity to utilise the space above the spending beach should beexplored.

2.32 The Marina has a number of different landowners and there is significantdevelopment interest in the Marina. The Outer Harbour (Brunswick Developments)scheme was approved in June 2006. A scheme for the Inner Harbour - the Explore Livingscheme was submitted to the Council in September 2007. Both of these schemes aremixed use which, if they are realised, will entail a significant proportion of residentialdevelopment coming forward in the future. Development should conform with theadopted SPG and the 2008 Brighton Marina masterplan.

2.33 The Black Rock site is situated to the west of the Marina and has been identified inthe Brighton & Hove Local Plan and SPG5 for development of a recreation and leisurefacility. A scheme, which is currently at the pre-application stage, is proposed for a sportsarena and comprises a multi purpose indoor events arena with two Olympic sized icepads, one of which will be for public ice skating. The arena will be able to host a varietyof events including sport (particularly ice hockey and basketball), concerts and shows. Thescheme also includes a residential element. A formal planning application is expected tobe submitted by the developer in the near future. The Gas Works site to the north of theMarina has been identified in the Brighton & Hove Local Plan for housing andemployment uses, and there are potential opportunities to link future mixed usedevelopment on this site to the wider Marina area.

Local Priorities


l To ensure that the regeneration of the Marina is comprehensive and conforms withan updated masterplan approach to avoid piecemeal development.

l To enhance the transport infrastructure at the Marina through the provision of atransport interchange, Rapid Transport System (RTS) and improved emergencyvehicle access.

l To create cohesive sustainable communities by ensuring that new development hasthe necessary social infrastructure in place to support these communities, includinghealth, education (primary school places), youth and community facilities

l To protect and enhance the areas marine character and role for marine-relatedleisure, recreation and employment opportunities.

l To ensure new development accords with the Strategic Flood Risk Assessmentfindings regarding flood risk and Shoreline Management Plan and relevant coastaldefence strategies regarding coastal defences.

l To take advantage of the Marina’s coastal location to maximise opportunities forlarge-scale zero and low-carbon energy technologies, including the potential fordistrict heating/ CHP to serve the Marina and wider city.

l To secure high quality buildings, townscape and public realm.

l To improve legibility, permeability and connectivity within the Marina andsurrounding areas in particularly with the Black Rock development and EastBrighton.

l To encourage a balanced mix of land-uses, and encourage retail and leisure uses atground floor level.35


l To achieve a good mix of housing which reflects housing needs within the city andensure an appropriate level of open space provision.

l To protect and enhance the ecological environment of Brighton Marina and BlackRock site, having particular regard to the RIGs, SSSI and SNCI status of the cliffs andbeach respectively.

l Ensure proposals for the Black Rock site enhance the tourism and leisure function ofthe city and seafront for residents and visitors.

l To investigate potential links and opportunities of the Gas Work Site as an identifiedhousing and employment site close to the Marina.

Preferred Option – DA2 Brighton Marina and Black Rock site

To facilitate the creation of Brighton Marina as a sustainable mixed use district ofthe city, creating a unique, high quality marina environment that will attractresidents and visitors and is well connected to the new leisure and recreationfacility at Black Rock. This will be achieved through:

1. Working in partnership with the different landowners to prepare an updatedmasterplan for the Marina, to ensure a coordinated and comprehensiveapproach to future development;

2. Supporting a more balanced mix of retail, leisure, tourism and commercialuses, that accords with its District Centre status;

3. Safeguarding the existing identified employment site, see CP17;

4. Requiring a good mix of housing which reflects housing needs within the cityand accompanied by an appropriate level of open space provision.

5. Working with developers and the PCT to ensure that necessary socialinfrastructure (health, school places and community facilities) is in place tosupport the new residential communities;

6. All development proposals at Brighton Marina and Black Rock must submit asite specific Flood Risk Assessment in line with requirements andrecommendations for the area set out in the Brighton & Hove Strategic FloodRisk Assessment and guidance set out in PPS25, see CP10.

7. All development proposals at Brighton Marina and Black Rock must provideand maintain appropriate coastal defences to accord with the relevantShoreline Management Plan and coastal strategies;

8. Ensuring a high quality of building design, townscape and public realm;

9. Enhancing the biodiversity of the Marina through the implementation of anecological masterplan;

10. Maximising opportunities for large-scale zero and low-carbon energytechnologies to serve the Marina and wider city, particularly those that thattake advantage of the Marina’s coastal location (see CP1);

11. Enhancing the transport infrastructure at the Marina through the provision ofa transport interchange, Rapid Transport System (RTS) and improvedemergency vehicle access.

12. Promoting improved pedestrian and cycle access within the Marina andbetween the Marina and surrounding areas

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13. Ensuring proposals for the Black Rock site accord with the adopted Black RockDevelopment Brief SPG and provide a leisure and recreation scheme that willprovide an all year attraction for residents and visitors;

14. The area is expected to provide an additional 2,000 residential units* over thePlan period;

* this includes the 853 residential units have been granted planning permission aspart of the Brighton Marina Outer Harbour (Brunswick Developments) scheme

Supporting text

2.35 Following adoption of the Brighton Marina Masterplan SPG in 2003, detaileddevelopment proposals are coming forward on specific sites within the Marina, and onadjacent land. As identified in the SPG the Marina has the potential for significantdevelopment and it is important that future developments help create a more sustainablemixed use district of the city. The council’s Strategic Flood Risk Assessment has identifiedBrighton Marina and Black Rock as falling within an area of higher probability of flooding(Flood Risk Zone 3a). A Sequential Test has been carried out to demonstrate theappropriateness of development in this area and this is available as a background paperto the Core Strategy. Any development proposal will need to demonstrate that the mostvulnerable land uses will be located in areas of lowest flood risk. Detailed guidance andspecifications for addressing flood risk in this area is set out in the Strategic Flood RiskAssessment (section 7.2.9).

Implementation

2.36 An updated SPD is required for Brighton Marina to replace the existing SPG andprovide greater clarity on the form and content of future development and the provisionof adequate social and transport infrastructure. It is recognised that in order to deliver thevision for the Marina set out at the start of the Preferred Option, the following isrequired:

l Greater partnership working with landowners at the Marina and public sectorpartners to produce a shared masterplan for the area;

l Further exploration of the proposed funding and routing of RTS;

l Identification of other public sector funding opportunities to help deliver themasterplan;

l Greater emphasis placed on securing community benefits from S106 agreementsand other mechanisms, through the provision of adequate transport and socialinfrastructure, townscape and community safety improvements and trainingopportunities.

2.37 The Brighton Marina Masterplan PAN04 2008 will be used to guide futuredevelopment proposals at the Marina and will form the basis of the preparation of aSupplementary Planning Document. A Public Arts Strategy has been developed to guideimprovements to the public realm and secure the use of professional artists anddesigners.

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Context

2.38 The Lewes Road development area extends from the Level, in the south, to theUniversities of Sussex and Brighton up to the administrative boundary of the city. LewesRoad is part of Brighton & Hove’s academic corridor and also contains a district shoppingcentre. It is the focal route for the two universities and their students: the SussexUniversity campus at Falmer and the campuses of Brighton University, which are locatedalong the A270 from The Steine to Falmer. There is a city academy proposed at FalmerHigh School and there are a number of primary schools in the area.

2.39 Lewes Road is a busy primary transport route into and out of the city for bothpeople and freight and well served by buses. It has been identified as a sustainabletransport corridor where priority is given to facilitating efficient public transport, cyclingand walking. The area of Lewes Road, south from the Vogue Gyratory is included in the2008 declared Air Quality Management Area due to the exceedence of the government’sAir Quality Objective for annual Nitrogen Dioxides. There are a number ofrecommendations to improve the road in the LR2 Study. The locality is dominated by thedual carriageway, which severs the communities on the eastern and western sides of theroad and presents a barrier to community facilities, parks and shops and there is a highernumber of road accidents along its length.

2.40 The area is characterised by mixed and often poor quality townscape and publicrealm. There are two residential renewal areas on the eastern side of the road. BothMoulsecoomb and Bevendean have been prioritised in neighbourhood renewalprogrammes.

2.41 The two universities make a major contribution to the economic, social and culturallife of Brighton & Hove and the wider region. They have a combined annual revenueexpenditure of around £250 million and employ approximately 5,000 staff. Throughinitiatives such as the Sussex Innovation Centre they also have important links with high

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DA 3 – Lewes Road

Supporting Documents:Sustainable Community Strategy -2006Refreshed Local Area Agreement - 2007Economic Strategy - 2005Tall Buildings SPG - 2004Preston Barracks SPG - 2003London Road/Lewes Road Study (LR2)Regeneration Strategy - 2007Employment Land Study -2006Reducing Inequality Review - 2008LR2 PBA Traffic Study - 2007Local Transport Plan - 2006Urban Characterisation Study - 2007Infrastructure Capacity Study - 2006Retail Study - 2006Public Space Public Life Study - 2007Open Space, Sport and Recreation Study -2008Air Quality Action Plan - 2007Air Quality Detailed Assessment - 2007Bevendean Neighbourhood Action Plan -2007Audit of Community Level Infrastructure -2004Strategic Flood Risk Assessment - 2008

value local businesses. Both universities maintain important links with business and thecommunity, for example the Sussex Innovation Centre at the University of Sussexsupporting start-ups and the University of Brighton ProfitNet programme working withover 500 local small and medium sized enterprises (SMEs). Work with local communitygroups is sustained by the University of Brighton Community University PartnershipProject (CUPP) and its joint project with Sussex University, the Brighton & SussexCommunity Knowledge Exchange (BSCKE). Both universities have proposals to extendand enlarge their campuses.

2.42 There are a number of significant, identified development sites including theCommunity Stadium at Falmer, Woollards Field, and Preston Barracks as well as potentialdevelopment sites like that of the former Moulsecoomb Infants school.

Local Priorities


l Promote the role of the area as a sustainable academic corridor and promote closerlinks between the universities and schools and the wider community.

l Secure high quality redevelopment of the significant sites in the area that willprovide new space for employment, learning and residential development.

l Encourage technology and innovation transfer from the universities to existingbusinesses along the academic corridor and support opportunities for suitable newbusiness accommodation that further develop links.

l Improve the townscape and creation of an attractive, safe and legible public realmthrough the preparation of a comprehensive design guide.

l Enhance the role of the Lewes Road as a district shopping centre and as asustainable transport corridor and implement the priorities in the LR2 Study.

l Ensure improvements to local air quality through implementation of the council’s AirQuality Action Plan and ensure new developments do not increase the number ofpeople exposed to poor air quality.


l Increase training and job opportunities for local people.

l Secure investment in improving the quality of public open spaces in the areaincluding Saunder’s Park and William Clarke Park as well as under used open spacesin residential areas such as Moulsecoomb and Bevendean.

l Improve natural green spaces – better landscaping and biodiversity and streetplanting to enhance the whole route.

l Improve community safety in identified priority areas.

l Seek provision of a community building in Bevendean (identified shortfall in Auditof Community Level Infrastructure 2004) and youth facilities.

Preferred Option – DA3 Lewes Road

Enhance the role of the area as part of the city’s academic corridor throughsupporting proposals which enhance secondary, further and higher educationprovision in the Lewes Road area and facilitate improved sustainable transport39


links, improved air quality and an enhanced townscape and public realm. This willbe achieved through:

1. Working in partnership with the Universities in preparing a SupplementaryPlanning Document to support the sustainable redevelopment and expansionof the campuses and support the need to provide appropriate accommodationfor students and closer links between the Universities and local communitiesthrough sharing facilities and developing local opportunities for training andlearning.

2. Supporting proposals for a city academy at Falmer High School includingimproved access to the site from Lewes Road and appropriate enablingdevelopment;

3. Promoting and investing in improved bus, cycle and pedestrian routes alongLewes Road from The Level to the Universities in partnership with publictransport operators.

4. Preparing design guidance for the area through an Urban Design Frameworkin order to ensure a comprehensive approach that delivers an improvedtownscape, public realm and green approach to the city with more efficientuse of underused sites;

5. Supporting and enhancing the district centre by improved pedestrian linkswith the Sainsbury’s store at the northern boundary and elsewhere in crossingLewes Road itself and overall environmental and physical enhancementsincluding high quality active shop fronts (CP15 Retail Provision).

6. Ensuring that new major development benefits the surrounding area throughhigh quality building design and public realm and through developercontributions, appropriate to the development, to meet priorities in the areaincluding community safety, landscaping and open space improvements,community buildings and sustainable transport and biodiversity.

7. Working in partnership with the South East England Development Agency(SEEDA) and the appointed developer to deliver a genuine mixed use, highquality, sustainable development that successfully focuses on employment(18,600 sq m) use whilst balancing community, residential, research, retail andtraining uses, in accordance with the adopted Preston Barracks SPG.

8. Supporting the delivery of the Community Stadium at Village Way North byBrighton & Hove Albion Football Club including 2,000 sq m teaching andlearning space for courses delivered by City College and others targeted atimproving access to employment;

9. Supporting redevelopment of the former Moulsecoomb Infants’ School toprovide mixed residential and office/community uses.

10. Supporting the development of Woollards Field for academic research oremployment related development with East Sussex County Council and theUniversities amounting to at least 5,000 sq m floorspace.

11. The area is expected to provide an additional 358 residential units over thePlan period

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Supporting text

2.44 This strategy recognises the important role the universities have for Brighton & Hoveand for the wider sub region. Both Universities have plans to expand year on year tomeet national targets. This will require improvement and expansion of their campusesand the need for appropriate new student accommodation on and near the campuses.The council will work with the universities to deliver sustainable expansion through thepreparation of a Supplementary Planning Document for the academic corridor. Theacademic corridor encompasses the Grand Parade campus which lies outside the LewesRoad Development Area boundary. Work on the SPD is due to commence shortly. TheUniversities recognise that they have a role in forging closer links with nearbycommunities. Improved links will be implemented by expanding learning opportunitiesand sharing facilities with local people. There are also opportunities to encouragetechnology and innovation transfer from the universities to existing businesses along theacademic corridor and to support opportunities for suitable new business accommodationthat further develop links.

2.45 Improvement to the sustainable transport corridor, in particular the cycle andpedestrian routes, will be funded through the Local Transport Plan and appropriatedeveloper contributions. These improvements will be closely linked to the other prioritiesfor the area, in particular improving air quality, an improved public realm, greening of thecorridor and improving community safety. A holistic approach to these matters as well astownscape improvements will be delivered through design guidance for the area.

2.46 Lewes Road District centre was identified in the 2006 Retail Study as a potentiallyvulnerable shopping centre. Whilst surrounded by a dense area of residentialdevelopment and containing a good range of everyday services such as a post office,bank and pharmacy there is a poor range and quality of comparison goods retailers.Vacancy rates are high, pedestrian flows are low and the environment and pedestrianmovements hampered by traffic congestion. The study recommended improved shoppingenvironment and pedestrian linkages in order to provide an upgraded shoppingenvironment for the local catchment population.

2.47 There are a number of potential development sites along the Lewes Road Corridor.The Community Stadium on land north of Village Way was approved by the Secretary ofState’s decision letter dated 23 July 2007. The stadium will provide a home for Brighton& Hove Albion FC whilst providing facilities and jobs for the wider community. The club’sintention is to deliver the stadium by 2011. In the event that the stadium is not deliveredthe site will be safeguarded for university (B1 research and development) and university-related uses (not student housing) associated with expansion plans of the universities andthis would be addressed through the Development Policies and Site Allocation DPD.

2.48 Preston Barracks, has been identified for high quality employment, training andacademic floorspace and enabling residential units as well as ancillary retail and leisureuses. Whilst a preferred developer, selected by the city council and SEEDA, will implementa redevelopment scheme, it will be built in accordance with the Supplementary PlanningGuidance.

2.49 The council has been working with Falmer High School, City College and other keypartners to secure the development of a city academy at Falmer High School. The FalmerAcademy project is looking to secure £26m in government funding to build new facilitiesat the site of the current Falmer High School. The development of the Academy willimprove the educational opportunities for pupils drawn from adjacent wards that showhigh levels of deprivation and contribute to improved community facilities and cohesion.

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Potential uses for any surplus land not required for the new academy will be communityand educational development opportunities linked to projects in the Falmer and EastBrighton Area.

2.50 Wider place making priorities identified for the area include the need for significantimprovements to open spaces a number of which are of poor quality and havecommunity safety problems (Saunders Park and William Clarke Park). There are also anumber of open spaces that are underused and in need of investment (Moulsecoomband Bevendean). There are wider community safety concerns around Lewes Road southof the Vogue Gyratory which is identified as a community safety hotspot. Additionally,the shortfall in provision of a community building in Bevendean is identified in theCommunity Infrastructure Audit and is a priority in the Bevendean Neighbourhood ActionPlan.

Implementation

2.51 The development area proposals will be implemented through the following:

l The council will work with the University of Brighton and Sussex University toprepare a SPD for the academic corridor. Work on the SPD has commenced andwill be completed in the next three years.

l Improvement to the sustainable transport corridor, in particular the cycle andpedestrian routes, will be funded through the Local Transport Plan and appropriatedeveloper contributions.

l Townscape improvements will be delivered through design guidance for the area.Priorities for preparing this will be decided through preparation of the Urban DesignFramework (CP2 Urban Design). Where appropriate, new development in the areashould make developer contributions towards delivering the priorities.

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Context

2.52 The current regeneration of New England Quarter is beginning to act as a catalystfor the redevelopment of the surrounding area, some of which currently has a‘backstreet’ character, albeit containing a vibrant residential area with a local school and arange of important small start-up units, creative industry businesses and workshops andbuilder’s merchant units which supply the city’s building trade.

2.53 The area east of Brighton Station provides opportunities for further developmentbeing in close proximity to the retail and commercial core of the city and well placed tocapitalise on excellent transportation links provided by Brighton Station. Trafalgar Streetto the south provides a link to the vibrant North Laine shopping and conservation areaand there is real potential to invigorate this part of the city and create a high qualitypublic realm which improves the arrival experience of those coming to the city by train.

2.54 London Road Town Centre serves as a community hub and key retail centre for thesurrounding residential areas and with the city’s only permanent Open Market, offersaffordable goods for those on lower incomes. However its performance as a town centrehas been in decline. There is a positive outlook for London Road and its future as a localretail area, but there is a great need for regeneration and improvements, with particularattention to the Open Market and refurbishment of retail units to attract prospectivetenants. City College has its main campus in this area and is a key provider of vocationaltraining to meet the rapidly expanding demand for a broad range of workers to supportBrighton & Hove’s economy. In order to meet the operational requirements of the Collegeand the contemporary needs of students and a modern curriculum City College hasidentified the need for redevelopment of current facilities. The proposals would involvethe phased redevelopment of the entire Pelham Street and Wilson Avenue sites.

2.55 London Road is the main entrance and exit route from the city; heavily traffickedand suffers from congestion at peak times, designated a sustainable transport corridor.43


DA4 – New England Quarter and London Road

Supporting Documents:Sustainable Community Strategy - 2006Refreshed Local Area Agreement - 2007Economic Strategy - 2005London Road and Lewes Road (LR2)Regeneration Strategy- 2007Pelham Street Knowledge QuarterDevelopment Brief - 2008Urban Characterisation Study - 2007Tall Buildings SPG - 2004Retail Study - 2006Employment Land Study - 2006Creative Industries Workspace Study -2008Public Space Public Life Study - 2007Brighton Station Site SPG - 2000Air Quality Action Plan - 2007Air Quality Detailed Assessment - 2007Hotel Futures Study - 2007Local Transport Plan - 2006Strategic Flood Risk Assessment - 2008

London Road, south of Preston Circus has been designated as part of the 2008 declaredAir Quality Management Area due to the exceedence of the government’s Air QualityObjective for annual Nitrogen Dioxides. It offers a ‘green approach’ to the city centre –lined by mature trees and punctuated by large open green spaces (Withdean Park,Surrenden Field and Preston Park). Preston Road West is characterised by high rise officeblocks opposite Preston Park’s western boundary and is surrounded by low densityresidential development to the north and tall residential blocks midway along the route.This is a secondary office location providing a range of office floorspace, along with ahotel and new GP practice and pharmacy.

Local Priorities


l Achieve greater integration and accessibility between the London Road shoppingcentre and the Brighton Station/New England Quarter area to the west.

l There is a need to improve health of the Town Centre through managing,enhancing and consolidating the existing retail provision and improve the ‘publicrealm’ and the pedestrian environment of London Road shopping centre.

l Need to secure the redevelopment/refurbishment of key retail sites along LondonRoad including the Open Market which is a prominent feature in the area.

l Safeguard existing employment space in the area and seek intensification/redevelopment to accommodate a net addition of at least 20,000 sq m of officespace over the period 2016-2026.

l Work with City College to secure campus improvements, recognising the role ofCity College in vocational training and further education and as an extension to theAcademic Corridor.

l Acknowledge that workspace affordability, appropriateness and availability is crucialto maintaining the significant creative industries business cluster and arts workshopsand venues in this area and seek to strengthen their presence.

l Maintain and enhance environmental quality along the route of the London RoadCorridor and complete the remaining phases of the Sustainable Transport Corridorwhich is designed to give greater road space/priority to sustainable modes oftransport (buses, cycle lanes and pedestrian access).

l Environmental improvements to create high quality streetscapes through sharedsurface streets and alternative traffic routes to reduce the impact of traffic andcreate better linkages between the Level, Valley Gardens and the seafront.

l Ensure improvements to local air quality through the implementation of thecouncil’s Air Quality Action Plan and ensure developments do not increase thenumber of people exposed to poor air quality.

l Take advantage of the areas central location, sustainable transport links and districtcentre role to ensure new development delivers high quality exemplar sustainableliving and explore opportunities for district heating/ combined heat and powertechnologies linked to new development.

l Opportunities to enhance the appearance of the existing tall building frontage tothe west of Preston Park.

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Preferred Option – DA4 New England Quarter and London Road

To revitalise the London Road retail area and create a major new business quarterfor Brighton & Hove consisting of high quality business accommodationconnecting London Road with the New England Quarter and to maintain andenhance a green gateway to the city at Preston Road West, characterised by ahigh quality employment-led mixed-use park land environment with localamenities. This will be achieved through:

1. Planning for a new business quarter for the city in the New England Streetarea (the area bounded by New England Road to the north, Elder Place to thewest and New England Street to the east) to accommodate the identifiedneed for 20,000 sq m of office floorspace post 2016;

2. Managing, enhancing and consolidating the existing retail provision withinthe defined prime frontage of London Road Town Centre, recognising theimportance of retaining key retail sites to act as ‘anchors’ for the centre;

3. Working with landowners and traders to secure theredevelopment/refurbishment of key retail sites along London Road.

4. Working with City College and the Learning and Skills Council to securePelham Street campus improvements, recognising the role of City College invocational training and further education and as an extension to theAcademic Corridor;

5. Safeguarding existing identified employment sites and recognise Preston RoadWest’s potential for employment led mixed use development;

6. Implementing the Local Transport Plan priorities for London Road Sustainabletransport Corridor;

7. Strengthening links between the New England Quarter, London Roadshopping centre and the North Laine shopping area with high qualitystreetscapes, pedestrian routes, cycle ways, and public realm improvements;

8. Maintaining and strengthening the significant creative industries businesscluster in the area through ensuring that workshops, office space, studios,storage and other premises remain affordable, appropriate and available foruse;

9. The area will provide a minimum of 795 additional residential units over thelife of the plan*

A Supplementary Planning Document will be prepared.

*of which 454 residential units are a commitment at Brighton Station as at 1 April 2007

Supporting text

2.57 The London Road and Lewes Road (LR2) Regeneration Strategy 2007 identifies thepotential of the London Road Corridor to become a strong and attractive gateway to thecity and identified opportunities for regeneration in distinct areas (Preston Road West,London Road Shopping Centre and east of Brighton Station) which would strengthen andenhance the overall character and diversity of the city.

2.58 The Employment Land Study 2006 identified the need to find sites suitable toaccommodate the forecast need for 20,000 sq m of high quality office floorspace post45


2016 and suggested that the New England street area (the area bounded by NewEngland Road to the north, Elder Place to the west and New England Street to the east)appeared to have redevelopment potential.

2.59 The LR2 Regeneration Strategy 2007 further indicates the potential for the creationof a ‘Commercial Quarter’ in this location. The opportunity to create a commercialquarter, offering a range of office space and type, in the heart of the city and close to themain train station would offer allow local businesses to grow, would build on the successof the New England Quarter to create a mixed use area of the city. The greater numbersof people living and working in the area will help to revitalise the shops and market inLondon Road and will reduce the need for people to travel outside of the city for work.This vision also complements the city College’s plans to modernise and expand theirfacilities on their Pelham Street Campus, growing their linkages with businesses throughthe provision of continuous professional development and meeting room and conferencefacilities to the public, together with enhancing and developing their core activities. Adevelopment brief for the Pelham Street site has been prepared (Pelham StreetKnowledge Quarter) to provide a masterplan to guide future development of the site.

2.60 The Retail Study 2006 recommends that the Council should aim to enhance andconsolidate existing retail provision and the overall physical environment in order toimprove the shopping experience and manage its role as a town centre. Key sites for newretail opportunities include the Open Market, former Co-Op Department Store, formerSainsbury’s and Buxton’s. The Retail Study indicates that there is capacity for additionalconvenience and comparison goods floorspace in London Road over the LDF period.These should be of a scale appropriate to the function of the town centre.

2.61 The creative industries sector has been identified as a growing and dynamic sectorwith a shortage of affordable and appropriate workspace, it is important that existingclusters of creative industry workspace are maintained and strengthened. The CreativeIndustries Workspace Study 2008 has highlighted the importance of the existing cluster inthe city centre and New England House as a unique and successful example.

Implementation

2.62 The preparation of a Supplementary Planning Document for New England Road andLondon Road area will ensure a coordinated and more detailed framework for thedelivery of development in the area. The SPD will provide a framework to guidedevelopers and decision makers on the form and content of development and theprovision of infrastructure. The emphasis will be on:

l Positive management of the Council’s land assets to facilitate development whichsupports the policy framework set out above.

l Partnership working with the city College, Open Market Traders, landowners andothers on key development opportunity sites.

l Securing community benefits through Section 106 agreements and othermechanisms, prioritising environmental and shop front improvements.

l Integration with the Local Transport Plan programmes for the sustainable transportcorridor which are designed to give greater road space/priority to sustainable modesof transport (buses, cycle lanes and pedestrian access).

l Potential use by the Council of Compulsory Purchase Order (CPO) powers to deliverthe vision for the area.

l Work on the SPD has commenced.

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Context

2.63 Eastern Road/Edward Street (ER/ES) is the main east-west corridor running fromPavilion Gardens towards Kemp Town. It is parallel to St James Street which is a busydistrict shopping parade. The area extends from Pavilion Gardens in the west to the RoyalSussex County Hospital in the east. It is mixed in character in terms of the scale ofbuildings, uses (civic buildings, employment, residential and hospital buildings) andbuilding types. The area is dominated by a poor quality public realm and builtenvironment and the dual carriageway.

2.64 Edward Street is dominated by the dual carriageway and by the modern civic,community and office buildings on the northern side of the road. The historictownscape, on the southern side remains but is but is affected by the impact of the roadand the poor public realm. The area extends northwards to include the former wholesalemarket at Circus Street. Eastern Road has been identified in the 2007 Air Quality DetailedAssessment as exceeding the government’s Air Quality Objective for Nitrogen Dioxide andis therefore included within the 2008 declared Air Quality Management Area.

2.65 The central part of the corridor is characterised by comprehensive post warresidential redevelopment. The southern side is dominated by a poor quality residentialbuilt environment with a mix of very tall buildings and low rise houses, a poor publicrealm with little provision of open space that is car park dominated and has poorlegibility. On the northern side of the road are the Gala Bingo Hall and the low riseFreshfield Business Park behind.

2.66 To the east, the townscape and public realm markedly improves as the roadcarriageway narrows to the original width with traditional building lines. This area isspecifically identified due to the proposals for ongoing development and consolidation ofregional hospital services at the Royal Sussex County Hospital. 47


DA5 – Eastern Road and Edward Street

Supporting Documents:Sustainable Community Strategy - 2006Refreshed Local Area Agreement - 2007Local Transport Plan - 2006Edward Street Quarter SPD - 2006Circus Street Municipal Market SPD - 2006Audit of Community Level Infrastructure -2004Reducing Inequality Review - 2008Tall Buildings Study - 2004Employment Land Study - 2006Economic Strategy - 2005City Wide Estates Strategy for Health &Social Care - 2007Neighbourhood Action Plans (three local) -2007Urban Characterisation Study - 2007Hotels Futures Study - 2007Public Space Public Life Study - 2007Air Quality Detailed Assessment - 2007Retail Study - 2006Infrastructure Capacity Study - 2006Open Space Study - 2008Strategic Flood Risk Assessment - 2008

Local Priorities


l The main priority is to improve the public realm. This will be carried out via acomprehensive design guide linked to the urban design framework for the city (seepolicy CP2) that would be subject to community and stakeholder consultation. Itwill include Eastern Road and Edward Street extending from Pavilion Gardens toSutherland Road (where the road returns to its original width). Opportunities totransfer road carriageway into the public and pedestrian realm will be explored.

l A further priority will townscape improvement of the Essex Street/Hereford StreetArea which has a discordant mix of low rise residential development and poorlydesigned high rise towers. Other priorities are for clearer movement through thearea and to improve spaces around the buildings. This area will be a priority andhave recommendations in the comprehensive design guide.

l It is important that under-used sites with good public transport access are usedmore efficiently in terms of levels of development. The Gala Bingo Hall and carpark and the Freshfield Business Park are identified as sites that could carry agreater amount of development.

l Main development opportunities in the area are for office and employment uses inthe Edward Street Quarter (Amex site), Circus Street Municipal Market andFreshfield Road Business Park.

l Help deliver health service priorities at the Royal Sussex County Hospital and for amulti-practice GPs’ surgery in conjunction with meeting infrastructure needs.

l Improve sustainable transport access and the ability to move through the areatherefore making it easier to walk cycle and catch the bus along with future plansfor a Rapid Transport System (RTS) and help to improve local air quality.


l The needs of sustainable communities and reducing inequalities betweenneighbourhoods should be addressed by investing in open spaces, improvingcommunity safety, youth facilities, providing school places, improving links andgreen spaces and contributing towards a community building for Queens Park andCraven Vale Neighbourhood area (identified in the Community Infrastructure Audit).

Preferred Option – DA5 Eastern Road and Edward Street

Secure significant improvements to the public realm and townscape making thearea more attractive, accessible and safer for residents, employees and visitorsand contribute towards increased business investment in the area. This will beachieved through:

1. Prioritising improvements to the public realm and poor townscape. This willinvolve the preparation of comprehensive design guidance for the areafocusing on the dual carriageway, under-active frontages and the EssexStreet/Hereford Street Area (see CP2 Urban Design).

2. Contributing towards delivering sustainable transport improvements in thearea by improving the public realm to encourage walking, to transfer roadcarriageway to sustainable transport measures (buses and bicycles) and to helpimplement the Rapid Transport System.

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3. Helping secure additional high quality employment floorspace in the area, toaccord with the Edward Street Quarter Supplementary Planning Guidance.

4. Facilitating a high quality, sustainable mixed-use development, includingemployment, education and housing at the former Municipal Market onCircus Street.

5. Making more efficient use of under-used sites, like Freshfield Road BusinessPark and the Gala Bingo Hall.

6. Working with the health authorities to provide a multi-practice GP’s surgery inthe area and deliver their strategies to enlarge the Royal Sussex CountyHospital whilst balancing the impact on the area in terms of sustainability,infrastructure and transport.

7. Community infrastructure priorities in the area are open space, measures toimprove community safety, provide additional school places, provision of acommunity building and improve legibility.

8. The area will provide a minimum of 311 additional residential units over thelife of the plan.

Supporting Text

2.68 The identified priority for Eastern Road and Edward Street is to improve the publicrealm and address the poor quality built environment. The western end of the road isunder capacity allowing for the opportunity to turn the carriageway over to sustainablemodes and public realm improvements which will make the area a better walking andcycling environment and address community safety and legibility. Options aroundnarrowing the road and enlivening under-active frontages and boundaries will bedeveloped through a comprehensive design guide prepared by the council. Funding forurban realm improvements and implementing the RTS (Edward Street/Eastern Road is thepreferred route) will sought through the Local Transport Plan and developer contributions.Work will be undertaken with Brighton & Hove Bus Company and in consultation withthe local community and stakeholders.

2.69 Future development in the area will be led by three main sites – Circus StreetMunicipal Market, the Edward Street Quarter (Amex site) and the Royal Sussex CountyHospital. Circus Street and the Hospital are anticipated to be redeveloped by 2016 andwill add a significant increase in floorspace on both sites. The Circus Street SPD, adoptedin 2006, sets out a brief for a mixed-use development of residential, employment andeducation uses (including workspace for creative industry businesses, culturalorganisations, artists and community groups, studios for South East Dance) together withsignificant urban realm improvements.

2.70 The role of the strategy will be to facilitate implementation of future plans inpartnership with Amex, Brighton University, the Universities NHS Health Trust and PrimaryCare Trust whilst ensuring that sufficient physical, transport and community infrastructureis in place to serve the new development and surrounding communities. This will beundertaken with partners.

2.71 Making more efficient use of sites relates mainly to the Gala Bingo Site andFreshfield Business Park to provide an increased level of development in an area withgood sustainable transport access and with significant scope to improve townscape. Thiswould be taken forward with occupiers and owners of the site and through the proposedcomprehensive design guide.

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2.72 The main priority area for townscape improvement through the comprehensivedesign guide is the Essex Street and Hereford Street estate. Implementation ofcomprehensive improvements would be subject to two conditions – support of residentsand availability of funding and would be subject to a long term plan. Smaller scaleimprovements around improving the public realm, linkages, community safety andproviding amenity space would be undertaken through close partnership working withHousing, Community Safety Team and local communities and communities of interest.

Implementation

2.73 Development area proposals will be implemented through the following:

l Through preparation of design guidance for the area. Priorities for preparing thiswill be decided through preparation of the Urban Design Framework (CP2 UrbanDesign).

l Funding for urban realm improvements and implementing the RTS (EdwardStreet/Eastern Road is the preferred route) will sought through the Local TransportPlan and developer contributions.

l Development proposals for Edward Street and Circus Street will be implemented inaccordance with adopted Edward Street SPD and Circus Street SPD

l Wider community priorities will be delivered in through developer contributionsfrom major developments in the area.

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Context

2.74 This is an area with a strong industrial past that has been influenced by its proximityto Hove Railway Station and important east-west transport corridors – the railway andOld Shoreham Road.

2.75 Over time industrial uses located on either side of railway have been progressivelyreplaced by employment uses, large-scale out-of-centre retail and some residential uses.The result is an area with a predominance of employment uses, which make up animportant area of employment land provision in the city in particular B1 (offices/lightindustry) and B8 (storage/distribution) uses. They are currently well-used with few vacantunits, and are currently protected by various safeguarding policies in the Local Plan. Theold coalyard site is allocated in the Waste Local Plan for a waste freight transfer facility.

2.76 A key issue identified in various council documents and strategies is the north-southseverance caused by the Old Shoreham Road and the railway line. There is a poor qualityof streetscape in several areas due to lack of defined street frontages, particularly aroundthe large retail sites. The topography of the area may also have contributed to some ofthe poor townscape features, such as paths next to blank walls and lack of streetfrontages. The area also suffers from a poor public realm. The area lacks a high qualityinfrastructure for pedestrian and cyclists partly due to the dominance of cars in manyareas. It has been identified in the Air Quality Detailed Assessment 2007, that theSackville Road and the Old Shoreham Road Junction exceed the government’s Air QualityObjectives for Nitrogen Dioxide and the area is therefore included within the 2008declared Air Quality Management Area.

2.77 The Clarendon area to the west of the station is identified as part of the PortlandRoad and Clarendon Road Neighbourhood Renewal Area and is characterised by postwar high rise residential development adjacent to nearby industrial estate and the busdepot. Part of the area around Conway Street is an identified community safety hotspot. 51


DA6 – Hove Station area

Supporting Documents:Urban Characterisation Study - 2007Public Space Public Life Study - 2007Employment Land Study - 2006Creative Industries Workspace Study - 2008Waste Local Plan - 2006Sustainable Community Strategy - 2006Retail Study - 2006Local Transport Plan - 2006Economic Strategy - 2005Portland Road and ClarendonNeighbourhood Action Plan - 2003Tall Buildings SPG - 2004Refreshed Local Area Agreement - 2007Open Space, Sport and Recreation Study - 2008Air Quality Detailed Assessment - 2007Reducing Inequality Review – 2008Strategic Flood Risk Assessment - 2008

Local Priorities


l There is a need create more active street frontages to improve the environment forpedestrians.

l Public realm improvements generally but also traffic calming measures and in someareas public safety improvements (as identified in the Clarendon NeighbourhoodAction Plan).

l There is scope to increase the efficiency of land use, due in part to the topographyof the area. For example by redevelopment in accordance with the Tall BuildingsSPG to exploit the significant drops in height between sites.

l One priority is to protect and enhance existing employment floorspace provision inthe area to help maintain and strengthen the local economy. Important employmentuses in the area currently include creative industries businesses and workshops (B1),general industrial (B2) and warehousing (B8).

l New residential development could be accommodated via mixed useredevelopments where appropriate on some sites that will not prejudice existing orfuture employment floorspace.

l Several of the junctions in the area are at or near capacity any additional traffic willadd delays. Therefore new development will need to capitalise on its proximity toHove Station, which is a high frequency service. In order to support this, access tothe station, especially from north of the railway line, needs to be improved.

l Priorities for developer contributions in the area are open space improvements,sustainable transport improvements, particularly cycling and enhance the station asa gateway to the city.


l Significant growth of retail warehousing is not anticipated as this could compromisethe viability or vitality of Hove Town Centre and other existing retail centres.

Preferred Option – DA6 Hove Station Area

Recognise the long term regeneration opportunity of the Hove Station area todevelop as an attractive and sustainable employment-led mixed-use area creatinga high quality employment environment that will attract investment and newemployment opportunities for the city and promote efficient use of land throughmixed use developments. This will be achieved through:

1. Preparing a masterplan to promote and coordinate employment-led mixed-use regeneration of under-used land and buildings and consider further thepotential for mid-rise (between six and eight storeys) buildings in thislocation;

2. Through redevelopment secure public realm and townscape improvements inthe area focusing on the Conway Street area, and the industrial/ retailfrontages along Sackville Road, Old Shoreham Road and Goldstone Lane;

3. Ensuring redevelopment supports public safety improvements andopportunities for environmental and open space improvements around theConway Street area;

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4. Enhancing the sustainable transport interchange at Hove Station by improvingthe walking and cycling network in the wider area and strengthening north-south connections;

5. Continuing to protect identified employment sites and encourage moreefficient use of underused sites, see CP16 and;

6. Maintaining and strengthening the creative industries business cluster in thearea through ensuring that workshops, office space, studios, storage andother premises remain affordable, appropriate and available for use;

7. Recognising the need to continue to safeguard the allocated waste site in thearea.

8. The area will provide a minimum of 295 additional residential units over thelife of the plan.

Supporting Text

2.79 The Hove Station area has a number of special characteristics; a sustainabletransport hub with local and regional connections, strong links to Hove Town Centre andthe seafront and proximity to Hove Park. Improving these north south links could unlockfurther potential of the Hove Station area and the council recognises the longer term rolethat this area could provide in terms of new, high quality employment opportunities forthe city.

2.80 Much of the Hove Station area is identified in the Brighton & Hove Local Plan 2005as containing key employment sites and is therefore currently safeguarded byemployment protecting policies. The Employment Land Study 2006 indicates that thesesites remain well used, being relatively modern and still fit for their current purpose withfew vacancies and therefore should continue to be protected. The area also contains arange of out-of-centre bulky goods retail stores. However a number of sites are under-utilised with large areas of car parking and single storey developments. The Tall BuildingSPG identifies potential for mid-rise buildings in this location which are between 6 and 8storeys in height and should be considered as part of wider design considerations for thearea.

2.81 The Employment Land Study also identified the need to find sites suitable toaccommodate the forecast need for 20,000 sq m of high quality office floorspace post2016. An initial capacity analysis of under-utilised sites in this area has suggested thatthere is potential for the 20,000 sq m employment floorspace to be accommodated inthe Hove Station Area. The preferred approach has been to focus this requirement in theNew England Quarter location, see Policy DA4. This approach accords withrecommendations of the Employment Land Study and the LR2 Study and recognises thatthe market is more likely to deliver new office accommodation close to Brighton Stationand the regional centre. The Creative Industries Workspace Study 2008 has highlightedthe shortage of appropriate and affordable workspace to meet the significant forecastdemand for floorspace over the next ten years. To ensure there is a continuing supply ofnew employment floorspace in the city, particularly post 2016, and the potential for newemployment floorspace to meet the needs of the creative industries sector within theHove Station Area existing employment land should be safeguarded, reviewed andmonitored.

2.82 It is anticipated that the majority of the capacity identified in this area would be foroffice uses (Use Class B1) but also for intensification of existing warehouse and

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distribution uses (Use Class B8). It is also recognised that there may be opportunities forhigh quality mixed use development and to strengthen the creative business cluster in thislocation. High quality, employment-led mixed use development would be appropriate onsome sites. Initial SHLAA analysis suggests that this area could accommodate 295residential units by more efficient use of sites. The allocated waste site close to therailway line should continue to be safeguarded to meet the future waste managementneeds of the city.

2.83 The area contains a range of out of centre retail units - Goldstone Retail Park andSackville Road Trading Estate. Whilst redevelopment of large out-of-centre retail sitescould include like-for-like retention of retail, any new retail development would beconsidered against the key tests set out in national guidance, regional and local policiesfor such locations. This is to ensure that the viability and vitality of Hove Town Centre andother existing retail centres is protected and to recognise the defined hierarchy of centresset out in preferred option CP15. The 2006 Retail Study recommends that the councildoes not need to allocate further sites beyond the town centre for food storedevelopment and any proposal in an edge or out-of-centre location must meet the testsset out in PPS6.

Implementation

2.84 The need for additional office development beyond 2016 will be dependant onfurther assessment of the need and the ability of the local economy to support futureoffice growth. The opportunities for new creative industries workspace cluster in this areashould also be explored. The preparation of a masterplan will provide a framework toguide developers and decision makers on the form and content of development and onthe provision of infrastructure. The preparation of a masterplan for this area will also beimportant in ensuring that all issues and necessary improvements such as public realm,townscape, and public safety are fully addressed, including the priorities of the localcommunities as identified in the Neighbourhood Action Plan (for Clarendon).

2.85 A masterplan would also help to ensure that the cumulative impacts ofdevelopment effecting highways and other infrastructure are taken into account and thata co-ordinated approach to development is promoted in light of the fragmentedownership constraints. As one of the gateways to the city, intensification in this areashould be of high quality, employment-led and help address the current dominance ofcars by improvements to cycle and pedestrian routes.

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Context

2.86 Shoreham Harbour/South Portslade is a densely developed, mixed-use area in thewest of the City. Shoreham Port is an industrial and commercial area providing significantemployment. The South Portslade area in this context is defined as the area immediatelynorth of the Port, extending from Old Shoreham Road in the north and as far east as theCarlton Terrace /Boundary Road/Station Road shopping area, and the EDF Energy site inPortland Road and up to the boundary with Adur District in the west. In the south thearea extends east to include the South Portslade Industrial Estate, up to Hove Lagoonlocated by the A259. The A259 provides an important “gateway” into Brighton andHove from the west.

2.87 South Portslade is part of a designated Neighbourhood Renewal Area in view of theneed to address deprivation in the wider Portslade area relative to the rest of Brightonand Hove and the rest of the country.

2.88 The wider area has three schools, a library, other community facilities such as ahealth centre and a new community centre along with a number of industrial sites.

2.89 The Employment Land Study 2006 identifies that the existing allocated employmentsites of Shoreham Harbour, South Portslade, Victoria Road and Franklin Road shouldremain allocated for the next plan period. The Study recognises however that due to thequality of some of these sites, notably South Portslade, where there are a number ofvacant units, wholesale redevelopment would be the only feasible way of makingsignificant changes. The Creative Industries Workspace Study 2008 has highlighted thelack of affordable and appropriate workspace throughout the City to meet the forecastneeds of this growing and dynamic sector.

2.90 On Old Shoreham Road, west towards the boundary with Adur District and mostnotably along Victoria Road there are a number of car showrooms. BoundaryRoad/Station Road District Shopping Centre serves the area. The Retail Study 2006

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DA7 – Shoreham Harbour and South Portslade

Supporting Documents:East Sussex and Brighton & Hove Waste Local PlanRegional Economic Strategy - 2006-2016Local Transport Plan - 2006Sustainable Community Strategy - 2006Portslade Neighbourhood Action Plan - 2007Employment Land Study - 2006Creative Industries Workspace Study - 2008Retail Study - 2006Economic Strategy - 2005Reducing Inequality Review - 2008Public Space Public Life Study - 2006Open Space, Sport and Recreation Study - 2008Urban Characterisation Study - 2007Tall Buildings Study 2003 and SPG 2004Refreshed Local Area Agreement - 2007Shoreham Maritime: Vision to Reality - 1999Air Quality Detailed Assessment - 2007Emerging Adur District Core Strategy - 2008Strategic Flood Risk Assessment - 2008South East Plan Examination Panel Report - 2007Shoreham Maritime Transport Feasibility Study - 2003Sequential Test - 2008

considers Boundary Road/Station Road is a popular shopping destination for the localarea and local workers but could benefit from environmental improvements. The studysuggests that it should continue to be classified as a District Centre but would benefitfrom investment in public spaces. This investment should be a key part of anyregeneration proposals for the area.

2.91 The Port of Shoreham covers about 260 hectares of land (approximately 90 ha areowned by the Shoreham Port Authority). The majority (two-thirds) of the Port area iswithin Adur District’s boundary in West Sussex. The draft South East Plan identifiesShoreham Port as a specific site requiring co-ordinated action to unlock economicdevelopment potential (policies SCT3, SCT6). The Regional Economic Strategy (RES)designates Shoreham as a Regionally Significant Port and as one of the priorities identifiesthe need to “explore future prospects for smaller ports such as Shoreham” The widerPort area could potentially be one of the largest waterfront regeneration areas in thecountry. Whilst this potential has long been recognised, implementation has beenfrustrated by a number of complex infrastructure costs.

2.92 The Port can be characterised as the one of the few “industrial” type areas inBrighton and Hove and thus is a potential location for essential developments requiringthis type of location, such as construction and demolition waste re-cycling. The Port alsocontains Brighton & Hove’s only active mineral site (aggregates wharf) and there are anumber of aggregates wharves within Adur District. Current planning policy for Brightonand Hove (and West Sussex) broadly requires the capacity for aggregates imports to besafeguarded at the Port.

2.93 Given the well-document constraints on Brighton & Hove, the regeneration of thewider Shoreham Harbour area is likely to be the only area offering any significantpotential to meet the long-term (15 to 20 year) demands for housing and employmentdevelopment in the wider Brighton & Hove area.

Local Priorities

2.94 The following local priorities have been identified for the area:

l The inclusion of wider areas adjacent to the port in regeneration proposals isrequired in order to bring benefits to the existing community. This could include, forexample, the provision of training opportunities as identified by the NeighbourhoodAction Plan for the area and environmental improvements to the StationRoad/Boundary Road shopping area.

l There is a need to consolidate and modernise the existing port activity on reclaimedland to allow land released from port use to be more effectively.

l The townscape, streetscape and public realm should be improved, particularly toencourage pedestrians and cyclists to use the area, maximising north-south linkagesand enhancing public safety and crime reduction.

l Leisure/recreation, community and other services including retail should be improvedin conjunction with public spaces, in order to benefit existing communities and toreduce the need for the occupiers of new housing to travel elsewhere for theseservices.

l The area has some potential to be intensified both in terms of housing numbersand refurbished employment areas, thus increasing the efficiency of land use whilstthe potential for tall buildings could be explored. 56


l Existing industrial/employment areas should be improved both to provideemployment for the local population and contribute to the wider needs of the city.Mixed-use development could be appropriate, for example, on car showroom siteswhere the employment floorspace is retained.

l There are a number of environmental issues affecting the area that need be takeninto account. In particular parts of the port area have been identified in theStrategic Flood Risk Assessment for Brighton & Hove as falling within Flood Zone 3b(functional flood plain), such that consideration against Planning Policy Statement25: Development and Flood Risk is needed in terms of demonstrating that thesequential/exception test can be met depending on what uses are proposed on thesites identified at risk. Enhanced flood mitigation and defence measures mayberequired if the Shoreham Harbour and South Portslade area is to accommodate newresidential development.

l Boundary Road/ A259 junction has been identified as exceeding the annualNitrogen Dioxide air quality objective and is included in the 2008 declared AirQuality Management Area. Investigation of the potential for land contaminationarising principally from port associated and other industrial activities is required.

l The Port also has a Site of Nature Conservation Importance (vegetated shingle)below Basin Road.

l Accessibility to the area should be improved. Foremost a package of sustainablepublic transport measures is required including extension of the proposed RapidTransport Scheme (RTS) from Brighton & Hove westwards and improvements tolocal rail stations such as Portslade (and Fishersgate/Southwick). In the longer termthe construction of a new road link from the Port to the A270 is likely to requireconsideration. The opportunity to deliver wider social and economic benefits, e.g.improving the environment of Boundary/Station Road, must be integral toconsidering any highway improvements.

l Developer contributions will be required to address, amongst other things, flooddefences and minimising risk from flooding, open space provision, sustainabletransport and access to services such as community and youth facilities, health careand education.

Preferred Option – DA7 Shoreham Harbour and South Portslade

Currently, the city council believes that the proposal has not reached the stage atwhich the full impacts on the City are able to be assessed accurately.Consequently, whilst Shoreham Harbour and South Portslade can be identified asa broad area for development the full impact of the development must bereserved for a future review of this Core Strategy. However, the issues the citycouncil would expect the development to take are set out below:

Major regeneration is under consideration for Shoreham Harbour and SouthPortslade. The aim will be to create a highly sustainable neighbourhood adheringto the latest standards for sustainable development set out by the Governmentand incorporating best practice. This development is expected to include at leastthe following components, the details of which are still under discussion:

1. New and higher quality jobs including provision for creative industries, tomeet the requirements of the local population/ economy.57


2. New homes including a mixture of tenure and housing types to meet therequirements of the local population/ economy.

3. New retail and leisure facilities and a high quality network of public openspace including a significantly improved public beach. Other supportingcommunity facilities are required. This will include education facilities, forlevels of development at the higher end of those under discussion; this islikely to include at least one new secondary school.

4. Modernisation and consolidation of port activity.

5. Innovative measures to increase use of non car modes of transport. Thisshould include a package of high quality public transport improvementsincluding an extension of the proposed Rapid Transit System (RTS) westwardsfrom Brighton and Hove and upgrades to the existing railway station.

6. Improvements to north-south road links to the wider main road network torelieve/prevent traffic congestion on existing thoroughfares around the area.

7. The need for environmental improvements to the A259 route as a majorgateway into Brighton and Hove.

8. A requirement to provide measures to minimise risk of flooding and toprotect people and property. Any proposals for development in the short-termin the areas identified in the Strategic Flood Risk Assessment as Flood Zone 2or 3 at Shoreham Port will need to demonstrate that the proposal passes thePPS25 Sequential Test and Exception Test requirement depending on the typeof development, in addition to undertaking a site-specific Flood RiskAssessment. In the long term an Area Action Plan covering the Port area willestablish requirements to deal with flooding issues.

9. Appropriate coastal defences to accord with the relevant ShorelineManagement Plan and the forthcoming Brighton Marina to River AdurStrategy Study for coastal defences.

10. Examination of the potential for large-scale zero and low-carbon energytechnologies to serve the new development and wider city, particularly thosethat take advantage of the harbour’s coastal location and existing powerstation and grid connectivity.

11. Developer contributions will be sought towards providing necessary physicaland community infrastructure including the investigation of the potential fora “roof tax”.

12. The production of an Area Action Plan with Adur District Council and WestSussex County Council to guide delivery.

Supporting Text

2.95 Shoreham Port and the wider Harbour area /south Portslade is potentially one of thelargest regeneration areas in the South East of England. In November 2003, the CityCouncil’s Policy and Resources Committee considered that a proposal for theregeneration of the port area (known as Shoreham Maritime) was undeliverable from aneconomic, political and sustainable transport perspective.

2.96 The South East England Development Agency (SEEDA) has initiated revised proposalsfor the wider Harbour area in conjunction with the three local authorities. The PortAuthority and other key organisations with a view to producing a deliverable

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redevelopment programme. The scheme that is now emerging is the result of consideringa wider area comprising south Portslade (plus Southwick and Fishersgate in Adur District)to create greater economic, social and environmental benefits for the surrounding area.

2.97 The new proposals are considering a redevelopment scheme that is much moresignificant in scale and scope than previously. As a result of looking at a larger areasurrounding the Port, this has presented opportunities not only to enhance existing areasbut to create a substantial mixed-use scheme including residential as well as commercialdevelopment alongside new leisure facilities.

2.98 The issues being considered are:

l Flood Protection – The council’s Strategic Flood Risk Assessment has highlightedthat parts of the port area lie in flood risk zone 3b - functional flood plain. PlanningPolicy Statement 25 indicates that only water compatible uses and essentialinfrastructure should be permitted in this zone.

l Sustainability - The project should become established as an international exemplarof sustainable development and to this end consideration of a high quality publictransport network, a balance of employment and residential uses and theincorporation of the latest in low carbon technology are being considered amongstother things. In addition to small-scale schemes the potential for implementinglarge-scale marine, wind and combined heat and power technologies should befully explored as part of the proposals, with access to the grid from the existingpower station being a potential added advantage.

l Economic Development – The new scheme should help stimulate the local and sub-regional economy by providing high quality premises and jobs for all residents andproviding the potential for inward investment as well as business retention.

l Transport –Any new regeneration proposals should maximise the potential for publictransport infrastructure. This includes the extension westwards of the City’sproposed rapid transport system and enhancement of the existing railway stations.There is significant potential to develop a transport network that reducesdependence on private cars and the highway network. Once the sustainabletransport opportunities have been fully explored, it will then be necessary to seewhat highway improvements would be required. A comprehensive cycling andwalking network should also be provided

l Reclamation – Work to facilitate the potential future consolidation of the port onreclaimed land has been reconsidered and redesigned so that it can be delivered ina phased manner that avoids significant costs upfront. Also to investigate thepotential for the reclamation to utilise inert waste, generated by the regenerationproposals themselves and other developments in the wider sub-region.

l Development Mix – Housing density could be increased to improve the efficiency ofland use, and the potential to introduce quality headquarters style offices could alsobe considered. The overall aim should be to establish the potential for a self-sufficient community with a variety of land uses.

l Planning Policy – Discussions have taken place over the most appropriate planningpolicy mechanisms to deliver the scheme. An Area Action Plan (AAP) is to beprepared by the three local authorities (Brighton and Hove City Council, AdurDistrict Council and West Sussex County Council) with support from SEEDA.

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2.99 An evaluation of potential delivery mechanisms will be made over the comingmonths. This will include a joint venture legal agreement between SEEDA and the PortAuthority.

2.100 In order to justify the potential scale of investment under consideration, apreliminary assessment has indicated a possible maximum capacity in the area underconsideration of a total of 5,000 to 10,000 homes and 7,000 to 8,000 jobs, i.e. in AdurDistrict as well as Brighton & Hove. The boundaries of the wider area will be finalisedthrough the production of the Area Action Plan. These proposals are still emerging andthe policy options in the Core Strategy may needed to be amended at the submissionstage to reflect this. Due to the proposals being at an early stage, no contribution fromdevelopment in this area other than from small residential sites already identified hasbeen made in elsewhere in this Core Strategy.

2.101 The preparation of an AAP should ensure that issues such as land ownership,highways, transport, public realm, townscape and public safety are fully addressed.

2.102 There is a need to examine whether the development can be linked to otherstrategic sites in the sub-region (but outside of Brighton and Hove) such as the Shoreham(Upper Beeding Cement Works) and Newhaven Port to accommodate uses relocatedfrom Shoreham Port in potentially more suitable and accessible locations.

Implementation

2.103 Discussions are currently underway with Adur District Council, West Sussex CountyCouncil, SEEDA, the Shoreham Port Authority, the Environment Agency and HighwaysAgency plus a number of other key organisations to consider the potential for a majorregeneration scheme for Shoreham Harbour and South Portslade. The City Council, AdurDistrict Council and West Sussex County Council are to produce an Area Action Plan(AAP). The necessity of producing planning guidance in the interim prior to theemergence of the AAP is under current consideration.

2.104 Significant public investment is required which could be provided by SEEDA andEnglish Partnerships. Details of how the regeneration proposals are implemented arecurrently under discussion and will be added to the submission version of this corestrategy. SEEDA submitted an expression of interest to the Government in October 2007,on behalf of the local authorities, for the next round of New Growth Points and EcoTowns. Shoreham Harbour was not short-listed as one of 15 new Ecotowns. AGovernment decision on New Growth Points is still to be made and is expected at anytime. The submission Core Strategy will need to be amended accordingly. The scheme forthe regeneration of the Harbour will be tested and defined through the preparation ofthe AAP. Once some certainty as to the form of the proposal is established though theAAP, the council will undertake a review of the Core Strategy to reflect amongst otherthings, the impact on the city overall.

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2.105 These are additional areas of the city identified as part of the spatial strategy asthey require a special or coordinated approach to managing future change in these areas(the Urban Fringe and the Seafront were previously covered in Part 6 of the originalPreferred Options Core Strategy, as major cross-theme preferred options).

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Context

2.106 Since the early 1990s the central seafront has been transformed through a mix ofpublic and private investment. The council’s vision for the seafront published in March2003 sets out how the seafront might look by the end of the decade. The council isworking towards achieving a seafront for all, and one integrated process of regenerationalong the coastal strip. Each phase of the regeneration will be designed to protect andenhance the natural environment, achieve quality in planning and urban design and todevelop the recreational potential of the area for both active and passive pursuits. Thereare a number of major schemes coming forward along the seafront:

l Black Rock – a leisure/recreation development, expected to be an ice rink see DA2.

l The International Conference Centre – to replace the existing BrightonCentre, see DA1

l King Alfred leisure centre – to replace the existing swimming pool and leisurefacilities.

Private development schemes have also come forward for Brighton Marina, the i360Observation Tower and Yellowave on the former Peter Pan’s playground site at MadeiraDrive.

Special Area Policies

SA1 - The Seafront

Supporting Documents:Tourism Strategy - 2008King Alfred/RNR Site Planning Brief SPG - 2002Brighton Centre SPD - 2005Brighton Marina SPG - 2003Brighton Marina PAN - 2008Public Space Public Life Study - 2007Urban Characterisation Study - 2007Local Transport Plan - 2006Open Space, Sport and Recreation Study - 2008Beachy Head to Selsey Bill ShorelineManagement Plan First Review - 2007Brighton Marina to Saltdean Strategy Study 2001Strategic Flood Risk Assessment - 2008

2.107 Brighton & Hove’s coastline is characterised by chalk cliffs east of the Marina withassets such as the A259 coast road and residential developments at Rottingdean andSaltdean. The landscape quality of the coastal area of downland countryside atOvingdean Valley and Roedean bottom is such that it has been included in the NationalPark proposed Designation Order. Over the last 15 years, the council has been engaged ina phased renewal of the defences between the Marina and the city boundary atSaltdean. The coastline from the Marina to the city boundary at Shoreham Harbour isheavily urbanised, set against a largely Victorian and Regency townscape which providesa distinctive image and unique character, it is considered by English Heritage to be one ofthe finest urban seafront townscapes in Britain. The seafront has historically beenprotected by concrete walls, timber groyne fields and the shingle beach.

Preferred Option – SA1 The Seafront

The council will work with the public and private sector to continue the on-goingregeneration and maintenance of the seafront in an integrated and coordinatedmanner to accord with council’s vision for the seafront.

Proposals should support the year-round sport, leisure and cultural role of theseafront for residents and visitors whilst complementing its outstanding historicand natural landscape value. Proposals should ensure a good marineenvironment, enhance biodiversity and consider options for small scale renewableenergy provision. Identified priorities are:

Western Seafront (Medina Terrace to Boundary Road/Station Road)

l Opportunities will be sought to improve the flow of traffic along the A259and improve air quality, pedestrian and cyclist crossing opportunities.

l To enhance and improve the public realm and create a more coherenttownscape through greater consistency of scale, height and roofline alongthe north side of Kingsway.

l Opportunities for tree planting north and west of the Lagoon should beexplored to soften the appearance of the A259, improve microclimate andprovide shade and enhance biodiversity.

l The council will work with partners to secure the redevelopment of the KingAlfred/ RNR site to secure new indoor public wet and dry sports facilities onthe site, which both provide for the local Hove communities and contributeto the wider mix of facilities in the city.

l The council will work with DEFRA, the Environment Agency and NaturalEngland to continue to maintain the coastal defences in accordance with theBrighton Marina to River Adur Strategy.

Central Seafront (Medina Terrace to Palace Pier)

l Ongoing improvements and maintenance of the upper and lowerpromenade should accord with the Council’s vision for the seafront andrespecting more tranquil areas west of the Peace Statue.

l Through SEEDA support the council will develop a future vision andlandscaping option for the lower promenade area either side of the WestPier site to complement the i360 Observation Tower proposal.

l Opportunities will be sought to improve the flow of traffic along the A259and improve air quality, pedestrian and cyclist crossing opportunities related

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to the Brighton Centre redevelopment at the A259/East Street junction.

l The council will work with the West Pier Trust and English Heritage to find ahigh quality solution for the West Pier which complements the seafrontregeneration.

l The council will work with DEFRA, the Environment Agency and NaturalEngland to continue to maintain the coastal defences in accordance with arevised Brighton Marina to River Adur Strategy.

East of Brighton Pier to the Marina

The council will:

l develop a future vision, public art and landscaping option for Madeira Drivewhich enhances the historic and nature conservation features in thislocation.

l Safeguard the vibrant event space at Madeira Drive as this presents a uniquelocation for a mix of cultural, sport and leisure activity to take place.

l Improve beach and seafront access for pedestrians and cyclists, linking withaccess improvements at the Marina/Black Rock.

l Ensure new developments respect and enhance the Volks Railway Site ofNature Conservation Importance (SNCI).

East of the Marina

The council will:

l monitor the cliffs in order to understand more fully how the cliffs east ofthe marina will react to changing climate in the next 50 years in order toplan for and take the appropriate measures to safeguard coastalcommunities, important infrastructure (A259 & trunk services) and coastalaccess in the longer term

l adopt a cautious approach to all new cliff top development and examineproposals rigorously in respect of cliff stability, nature conservation andimpact on coastline views and Rottingdean Conservation Area.

l implement in partnership with East Sussex County Council proposals for theA259 (Ovingdean – Telscombe Cliffs) Sustainable Transport Corridor toimprove public transport, pedestrian and cycle facilities between Brightonand Newhaven.

l work with Southern Water to ensure appropriate waste water treatmentinfrastructure.

Supporting text

2.108 One of the unique attractions of the city is its world class seafront. It is the locationof two exceptional groups of historic buildings fronting the sea, east of Palace Pier to theMarina and west of Brighton Centre to Fourth Avenue. The seafront is the city’s mainpublic space and provides an important opportunity for promotion and enhancement ofboth formal and informal recreation. There is a vibrant mix of artist studios, leisure andretail uses in refurbished seafront arches and this unique mix needs to be protected andenhanced. The character of the seafront varies in its intensity of activity with both livelyand tranquil stretches which contribute to its broad appeal to residents and visitors alike.

The need to enhance and improve the public realm along the seafront is recognised bythis preferred option. Opportunities will also be sought to standardise road capacity alongthe length of the A259 to reduce its severance effect with the seafront. The 2007 AirQuality Detailed Assessment identified certain junctions on the A259 as exceeding theannual nitrogen dioxide air quality objectives and the A259 between Arundel Road andthe city boundary with Adur District Council is included within the 2008 declared AirQuality Management Area. New opportunities should be offered to encourage people toextend the amount of time they spend at the seafront as well as opportunities to provideshade and shelter. These opportunities should relate to the emerging Parks and GreenSpaces Strategy and Public Space Public Life Study.

2.109 In addition to recognising the significance of the coastline for leisure andrecreational purposes the importance of conserving coastal habitats and improving themarine environment including sea water quality and coastal zone management is alsorecognised. There are also opportunities to consider small scale renewable energyprovision such as solar and wind energy technologies along the seafront.

2.110 The Strategic Flood Risk Assessment has identified that the coastal frontage of thecity is at risk from tidal flooding. The defence of Brighton & Hove’s coastline over the next50 years is covered by two strategies prepared in partnership with Environment Agencyand adjacent authorities. The reconstruction of the defences between Ovingdean and theMarina, under the Brighton Marina to Saltdean coast protection scheme is now complete.The Brighton Marina to River Adur Strategy recommends the maintenance of existingcoastal defences with some enlargement of groynes and beaches in the King Alfred areaand a scheme to upgrade the defences between the western end of Hove Lagoon andthe River Adur through Shoreham Port. The Strategy will be revised following advice fromDEFRA. The Beachy Head to Selsey Bill Shoreline Management Plan for the coastline westof the marina proposes to continue to ‘hold the line’ in terms of coastal defence.

2.111 To the east of Black Rock and the Marina a chalk cliff line runs all the way toNewhaven. The cliffs (Brighton to Newhaven Cliff) are designated a Site of SpecialScientific Interest (SSSI), a Regionally Important Geological Site (RIGS) and a GeologicalConservation Review site (GCR). How the cliffs will react to changing climate is not yetfully understood. The cliff falls at the Marina in 2000/2001are an indication of what canhappen and a cliff stabilisation scheme was completed in 2005. Adopting a monitoringand management approach to the coastline in this location will increase the longer termunderstanding of the evolution of the cliffs, in the light of climate change. This shouldadvise and enable the council in partnership with Natural England to properly managethis unique and valuable natural feature and plan for the future.

2.112 Southern Water has constructed a storm water storage tunnel along BrightonSeafront as a buffer to control outflows from the combined sewerage system. Stormwater from this tunnel will eventually connect to a new wastewater treatment works atPeacehaven.

2.113 On 23rd March 2007 the council granted planning permission for a mixed usedevelopment on the King Alfred/ RNR site comprising a new public sports centre;751residential units (including affordable housing) in two towers and eight otherbuildings; ground floor commercial uses within classes A1 (retail), A3 (restaurants andcafés) and A4 (drinking establishments); underground car parking; a doctors surgery; apolice office; and public toilets. This was subject to conditions and a Section 106Agreement, the final wording of which was formally approved on 11th July 2007. Thecouncil will ensure that all conditions are discharged and the terms of the Section 106Agreement are fully met.

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Implementation

2.114 Specific priorities such as the West Pier and improvements to other historic andlisted structure along the seafront will be implemented via commercial developments inconjunction with the West Pier Trust or possible future grant schemes with EnglishHeritage and/ or the Heritage Lottery Fund.

l SEEDA money has been identified to fund the scoping study for the area either sideof the West Pier and the council will look to replicate the successful model ofprivate-public investment to implement future visions.

l Future Local Transport Plan programmes/ s.106 contributions will be used toimprove pedestrian and cycling access to and along the seafront.

l The recommendations set out in the Shoreline Management Plan will beimplemented through the coastal defence strategies. The council is working inPartnership with Brighton University on the INFORM study (Information on cliffRecession Management) to monitor the cliffs east of the Marina. More detailedpolicies on coastal defences development in the coastal zone will be set out in theDevelopment Policies and Site Allocations DPD in the meantime the adopted LocalPlan policies SU6 and SU7 will be saved.

l The coastal zone boundary currently identified on the adopted Local Plan ProposalsMap will be updated to take account of the Beachy Head to Selsey Bill ShorelineManagement Plan.

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Context

2.115 Central Brighton is a dense and complex area of quality urban townscape thatstretches south from Brighton station in the north down to the seafront in the south,with North Laine, the Royal Pavilion Estate and Old Steine to the east and the majorseafront hotels and conference centres, Churchill Square shopping centre and major highstreet retailers along Western Road to the west. Its historic form is fundamental part of itsdistinctive character and resulting sense of place. The area contains a unique independentretail sector, restaurants and cafes, a diverse evening economy (clubs, theatres, cinemaand mixed arts entertainment venues) a commercial core and hub for media and creativeindustries as well as some of the city’s key cultural and heritage assets.

Preferred Option – SA2 Central Brighton

To reinforce central Brighton’s role as the city’s vibrant, thriving regional centrefor shopping, tourism, cultural and commercial facilities.

1. The Council will support the viability and long term success of the ‘culturalquarter’, the area centred on Church Street, Jubilee Square, Pavilion andtheatres through ongoing improvements to the attractiveness of the physicalenvironment and public realm, ensuring the historic buildings are maintainedand enhanced and ensure new development supports and maintains thevibrant mix of cultural activities, business, retail, leisure and tourism uses;

2. Brighton Regional Centre will be the focus for significant new retaildevelopment. New retail development should respect the different butinterconnecting shopping identities of the following areas:

l Churchill Square/ Western Road – see DA1

l Western Road 66


SA2 Central Brighton

Supporting Documents:Tourism Strategy - 2008Retail Study - 2006Creative Industries Workspace Study - 2008Sustainable Community Strategy - 2006Refreshed Local Area Agreement - 2007Local Transport Plan - 2006Hotel Futures Study - 2007Conservation Strategy - 2003Public Space Public Life Study - 2007PPS6 Planning for Town Centres -2005Good Practice Guide for Tourism -2006Air Quality Detailed Assessment - 2007Air Quality Action Plan - 2007

l Queens Road/West Street

l Old Town including the Lanes/ Duke Street/ East Street

l The North Laine

l North Street

The council will support proposals to improve and refurbish existing retailunits and shop frontages in order to maintain the Regional Centre’sattractiveness.

3. To accord with licensing, policing and public safety strategies, the Council willpromote a balanced range of complementary evening and night-timeeconomy uses which appeal to a wide range of age and social groups, avoid aspread of large bars/pubs and night clubs and address public safety concerns.

4. Mixed use developments will be promoted which retain active ground flooruses and accord with the range of appropriate city centre uses set out innational policy statement ‘Planning For Town Centres- PPS6’

5. Employment sites and premises will be safeguarded to accord with CP16 andCP17.

6. Ensure that workshops, office space, studios, storage and other premisesremain affordable, appropriate and available for use particularly in the NorthLaine area to maintain and strengthen the significant creative industriesbusiness cluster;

7. The council will secure urban realm improvements to reduce congestion,improve air quality and encourage improved pedestrian and cyclingmovements within the city centre (See CP3 Public Streets and Places);

Preferred Option CP19 Hotel/ Guest Accommodation applies to Central Brightonarea.

Supporting Text

2.116 Within central Brighton, there is a concentration of a range of nationally andinternationally significant cultural businesses, buildings and collections: including theRoyal Pavilion and Gardens, Brighton Museum and Art Gallery, the Brighton Dome,Brighton Festival and the Theatre Royal Brighton, the new Jubilee Library and Komedia allclustered tightly together. At the heart of the area is the iconic and internationallyfamous Royal Pavilion without which, little of the cultural and historic development of thecity centre would have occurred. The wider area is described as the city’s cultural quarter.Cultural and creative industries and the retail, tourism and hospitality sectors continue toinnovate, strengthen and grow within this area and it is important to ensure that thecultural role of the area is promoted and supported.

2.117 As an integral part of the attraction of Brighton as a tourist destination, and inorder to provide residents with the highest quality shopping provision, Brighton RegionalCentre should continue to be the focus for the most significant new retail development.The Retail Study 2006 identified a high demand for new retail space by significant retailoperators, but limited opportunities to meet this demand. The study also indicated that itis important to enhance and consolidate its retail role to maintain its market share.Capacity exists for new convenience and comparison goods floorspace in the regionalshopping centre and this is outlined in CP15.67


2.118 The different but interconnecting shopping areas within the centre are identifiedand described in the Retail Study and there is active support for the protection of existingand provision of new small unit retail space, largely catering for local independenttraders, located within The Lanes and North Laine. The balance and mix of uses in theseareas will be carefully monitored and maintained, see CP15.

2.119 Equally, the need for large format retail units is recognised to retain existing, andattract new, major multiple retailers. New retail development has come forward in recentyears such as the Air Street/North Street Quadrant redevelopment, and as part of theJubilee Street redevelopment. The need to attract further high quality department storerepresentation in order to retain Brighton’s competitive position in the South East Regionis recognised. Whilst there are limited opportunities to find new sites within or on theedge of the Regional Centre, the opportunity to provide new large format floorspace,possibly incorporating a new department store, as part of the Central Seafrontdevelopment area should be investigated (see DA1). Another potential opportunity site isidentified at the former Post Office buildings on Ship Street (this site is currently allocatedin the Local Plan) and this will be considered in the Development Policies and SiteAllocations DPD.

2.120 Environmental improvements and proposals to improve and refurbish existing retailunits and shop frontages in order to maintain the Regional Centre’s attraction to newretailers and shoppers will be supported. Improved connectivity and integration,particularly in terms of clear and improved pedestrian linkages, improved pedestriancirculation and ‘signposting’ between the different shopping ‘quarters’ within theregional centre is a key priority over the plan.

2.121 As well as new retail opportunities, mixed use developments such as the JubileeStreet site and Argus Lofts within the North Laine area and the Air Street/ North StreetQuadrant have also included important employment floorspace from new high qualityoffice accommodation to new creative industries work space. The Creative IndustriesWorkspace Study 2008 identified the attractiveness of central Brighton to creativebusinesses and evidence of a vibrant cluster in the North Laine and Old Steine area.However creative industries clusters are vulnerable to redevelopment pressure and theimportance of the cluster needs to be reinforced and protected. New developmentshould strengthen the mix of uses in central Brighton and retain active ground floor uses.In particular within the North Laine area the valuable contribution of small premises andworkshops in supporting creative arts, IT and media related businesses should besafeguarded, as they support small scale industry and encourage new enterprises to setup and add vitality to the cultural quarter.

2.122 New developments have also contributed towards additional housing in the centralBrighton area. Residential uses as part of mixed use developments or above shops subjectto other planning considerations can also contribute to enhancing the vitality of centralBrighton and improving safety during the daytime and evening. Brighton & Hove’s EmptyProperty Strategy encourages bringing flats above shops back into use.

2.123 The Community Safety, Crime and Drugs Audit 2004, identifies that centralBrighton and particularly the West Street area, continues to be a violent crime hotspot.Through effective coordination of relevant strategies and policy areas (e.g. licensing,policing and public safety) the council will seek to improve safety; through encouraging amore balanced range of complementary evening and night-time economy uses whichappeal to a wide range of age and social groups, and managing existing late night useswithin certain parts of central Brighton. Local work to reduce violent crime is coordinated 68


through the Local Public Service Agreement/Violent Crime Action Plan. Recent work hasincluded: late night dispersal of revellers (through joint work with Police, Council, taxidrivers and local bus companies); Policy Community Support Officers monitoring taxirange area and the introduction of a city-wide Designated Public Place Order whichprohibits the drinking of alcohol on the streets. More recently a Cumulative Impact Zonewithin central Brighton has been adopted by the council’s Licensing Committee in orderto provide greater powers to control the number of licensed premises in the city centre.

2.124 The Air Quality Detailed Assessment 2007 has identified that West Street, NorthStreet, Queens Road and Western Road exceed the government’s Air Quality Objectivesfor Nitrogen Dioxides, the area is therefore included within the declared 2008 Air QualityManagement Area. The Full Local Transport Plan 2006/7-2010/11 has identified aprogramme of Urban Realm Improvements to be undertaken between 2006/7 and2010/11 at Brighton Rail Station (Trafalgar Street); Ship Street/ Old Town area andimprovements to Pool Valley Coach Station, and this programme is likely to be continuedbeyond 2011. These schemes will be developed as part of a consistent vision and basedon the findings of the Public Space Public Life Study (2007), will link to the existing AirQuality Action Plan and will help to improve local air quality.

Implementation

2.125 Opportunities to identify retail and mixed use development sites will be consideredin the Development Policies and Site Allocations DPD.

l Local work to reduce violent crime will be coordinated through the Local PublicService Agreement/Violent Crime Action Plan.

l Urban realm and public safety improvements in central Brighton will primarily be theresponsibility of the council. These works would be funded through the LocalTransport Plan and developer contributions.

l The council will work in partnership with local business and traders groups, the ArtsCommission, Arts Council, English Heritage, Museums, Libraries and Archives SouthEast, The Dome and Festival Co., and the Theatre Royal Brighton to ensure thequarter’s continuing success for residents and businesses.

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Context

2.126 For the purposes of this preferred option, the Valley Gardens area comprises thestreets and open spaces that run in a line from Old Steine in the south to the Level in thenorth, excluding the Pavilion Gardens. This area is of unique strategic significance toBrighton & Hove in the way in which a number of major issues co-exist and, in somecases, conflict. These include: the area’s role as an arrival/departure point for visitors; itsrole as a major traffic route with the A23 sustainable transport corridor; its cultural andheritage significance (including the Royal Pavilion); its provision of open space; itsinclusion within the academic corridor; its wide mix of land uses; and its role as a venuefor major events. However, the area is currently failing to fulfil its potential.

Preferred Option – SA3 Valley Gardens

The council will work with public and private sector partners to enhance andregenerate the Valley Gardens area in an integrated manner that reinforces itsstrategic significance, emphasises its historic and cultural character, reduces theadverse impact of vehicular traffic, improves local air quality and creates acontinuous green boulevard that reconnects the area to the surrounding urbanrealm.

The six overall aims are:

1. Reducing the severance impact of traffic on the enjoyment of the public realmthrough environmental improvements;

2. Creating coherent, safe and useable green spaces;

3. Creating legible links with adjoining areas, particularly for visitors; and

4. Enhancing the appearance and setting of historic buildings. 70


SA3 – Valley Gardens

Supporting Documents:Local Transport Plan - 2006LR2 PBA Transport Study - 2007London Road and Lewes Road (LR2) RegenerationStudy - 2007Public Space Public Life Study 2007Conservation Strategy - 2003Valley Gardens Conservation Area Study andEnhancement Plan -1995Neighbourhood Survey Report - 2006Air Quality Action Plan - 2007

5. Finding appropriate new uses for key buildings.

6. Accommodating provision for high quality outdoor events,

The distinct role and character of each green space will be clarified having regardto the following priorities:

Old Steine - the hub

l Emphasise its role as a visitor destination space.

l Enhance the arrival and departure experience for visitors by ensuring simple,comprehensible links to and from the seafront and the Lanes.

l Ease the movement of pedestrians and cyclists through recapturing road spaceand creating direct crossing points, particularly to re-connect St James’s Streetwith the city centre.

Victoria Gardens - the cultural park

Pursue a comprehensive landscape / townscape scheme to:

a) Improve navigable links for pedestrians both between the two gardens andwith the Cultural Quarter.

b) Redesign the gardens to include new pathways, tree planting and public artand investigate the potential for a café building.

c) Improve the junctions with Kingswood Street, Morley Street and RichmondParade through environmental improvements or redevelopment whereappropriate.

l Encourage a comprehensive solution to the re-use or redevelopment ofbuildings on Gloucester Place for a mix of uses.

l Secure funding for open space improvements from new developments in thevicinity.

l Seek the restoration of groups of buildings on Grand Parade.

St Peter’s - the historic landmark

l Secure the long term future of St Peter’s Church; and enhance its settingthrough public realm improvements.

a) Support proposals for refurbishment/enhancement of the facilities andappearance of the Phoenix Gallery building, possibly through a mixed useredevelopment.

b) Enhance the retail environment through alterations to, or redevelopment of,the supermarket building on the corner of Cheapside and through shop frontimprovements to York Place.

The Level - the recreation and leisure space

l Pursue a comprehensive landscaping scheme for The Level that will distinguishfunctions of spaces, enhance entrances and improve public safety.

l Improve the key links to London Road and the Open Market.

l Improve the public realm to the south of The Level.

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Supporting Text

2.127 The Local Transport Plan includes proposals to transform the area between theseafront and St Peter’s Church into a coherent city park through traffic managementmeasures and urban realm improvements, potentially with a two way traffic on theeastern side. It also includes proposals to improve Pool Valley coach station, as a majorgateway to the city. Valley Gardens is included in the 2008 declared Air QualityManagement Area.

2.128 The council’s Public Space Public Life Study (2007) argues that Valley Gardenscould become the grand route into the city and notes that Victoria Gardens south is amuch under-used green space due to its poor quality. It proposes a more unified ValleyGardens that creates a pleasant, attractive and inviting ‘green lung’, with each greenspace embodying a unique character and offering a different experience. It suggests thatvehicular traffic be re-organised on the west side to reduce traffic volume and that thecouncil blur the boundary between the gardens and the Pavilion Gardens and theCultural Quarter. Further, it makes detailed design suggestions for the Old Steinejunction.

2.129 The LR2 Study (2007) notes that much of the Valley Gardens open space is under-performing and failing to reach its potential to contribute to the character, function andquality of the area. With regard to The Level, it draws attention to the poor layout of itssouthern end, access difficulties and anti-social behaviour after dark. The study notes thatSt Peter’s Church, whilst an important landmark is situated in an area of open spacewhich is rarely used. Accessibility is noted as the major problem affecting this space andVictoria Gardens. The study proposes the creation of a series of connected, high qualitygreen spaces making a grand civic gesture and creating a strong, legible pedestrian route.It states that the success of this vision will also depend on improvements to thesurrounding highways to reduce the impact of traffic.

2.130 The council’s Conservation Strategy (2003) includes a commitment to working withthe church authorities to secure the future of potentially redundant Anglican churchessuch as St Peter’s Church. It also states that the future priority for any historic area grantschemes is likely to be Valley Gardens.

2.131 The Valley Gardens Conservation Area Study and Enhancement Plan (1995)proposed that a new pedestrian pathway be created through Victoria Gardens and thatthey could be used as a sculpture park. This document further proposed: improvementsto Pool Valley; a more attractive link from Old Steine to East Street; improved landscapingto The Level; the restoration of buildings in Grand Parade; and traditional shop frontreinstatement in York Place. Buildings were identified which could be redeveloped toenhance the conservation area.

2.132 The Neighbourhood Survey Report (2006) linked to the Open Space, Sports andRecreation Study revealed that The Level is one of the six most used open spaces in thecity. Improvements requested were: greater formal recreation facilities; more planting;more seating; and better lighting.

2.133 The purpose of this preferred option is to ensure that the strategic importance ofthe Valley Gardens is fully recognised and that disparate proposals for, and pressures on,the area are considered within the context of an overall spatial framework that integratesand balances different or competing demands.

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Implementation

2.134 The primary means of implementation, in the medium term, will be through theLocal Transport Plan scheme to redirect all traffic along the east side of Valley Gardens(south of the Level). Funding is currently set aside for development and implementationof the scheme from 2010. Proposed improvements to the Pool Valley coach station areunderway, funded through the Local Transport Plan in partnership with National Expresswith implementation scheduled for 2007/2008.

2.135 Redevelopment of key sites and buildings will involve working with land ownersand developers. The Circus Street proposals are dealt with in the Eastern Road EdwardStreet Development Area (DA5) where the University of Brighton is a key partner andproposals for the Grand Parade Campus will be dealt with through the proposedUniversities SPD (See DA3). Developer contributions from the redevelopment of siteseither side of Victoria Gardens will be expected for open space and legibilityimprovements and public art in the gardens.

2.136 Repairs and restoration to key groups of historic buildings may be achievedthrough grant schemes in partnership with the Heritage Lottery Fund or English Heritage.Shop front improvements to York Place may be achieved through such a grant schemeand/or through the development control process, utilising the Shop Front Design SPD, incooperation with local businesses.

2.137 Securing the long term future of St. Peter’s Church will be achieved in partnershipwith the church authorities and English Heritage. Urban realm and public safetyimprovements to the Level will primarily be the responsibility of the council.

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Context

2.138 Most of the land surrounding the built up area of the city is managed open spaceor farmed downland and much of this is currently designated as Area of OutstandingNatural Beauty land. Most of the surrounding farmed downland that stretches from thecity’s western boundary with Adur District to the coast between Ovingdean and Roedeanis proposed for inclusion within the proposed South Downs National Park (based on theInspector’s 2007 proposed boundary modifications). In the adopted Local Plan the urbanfringe around the city was defined as a zone of countryside within approximately twokilometres of the built up area boundary but this will change when the National ParkDesignation Order is confirmed and it will be much narrower as in many instances theNational Park boundary will be contiguous with the urban edge. It is likely that there willbe areas of land that are no longer afforded statutory landscape protection and it will beimportant for the council to have a policy in place to address this. However until theNational Park is confirmed the exact extent of the urban fringe will not be known, in theinterim Local Plan policies on the Countryside, AONB and the urban fringe will be saved.

Preferred Option – SA4 Urban Fringe

Land between the built up area boundary and the proposed South DownsNational Park boundary will be protected and enhanced through the following:

1. Development outside the built-up area boundary will not be permitted unless:

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

b) a countryside location can be justified; and

c) there is no significant adverse impact; and

d) enhancement to the countryside/ downland will result 74


SA4 – Urban Fringe

Supporting Documents:PPS9 Biodiversity and Geological Conservation - 2005Draft South East Plan - 2006SDNP - Inspector’s Report on the National ParkBoundary - 2007The South Downs Management Plan -2007Sustainable Community Strategy - 2006Housing Needs Study - 2006Open Space, Sport and Recreation Strategy - 2008The Downland Initiative - 2005Local Transport Plan - 2006

2. Promoting the urban fringe as part of the green network and encouragingopportunities for multi-functional uses such as wildlife, recreation and culturalexperience, new allotments and local food production and biodiversityenhancements (see CP5 Biodiversity)

3. Creating ‘gateway’ facilities and interpretative facilities in connection with theproposed South Downs National Park to support sustainable tourism,

4. Securing better management of the urban fringe, environmentalimprovements and safe public access to the countryside;

5. Protecting sensitive groundwater source protection zones from pollution andencouraging land management practises that reduce rapid surface water run-off and soil erosion.

6. Protecting the wider landscape role of land within the urban fringe, thesetting of the National Park and protection of strategic views into and out ofthe city.

Proposals for farm diversification within the urban fringe should accord with thecouncil’s adopted Planning Advice Note 01 Farm Diversification (October 2005).

Supporting Text

2.139 This preferred option applies to land between the defined built up area boundaryand the proposed boundary of the South Downs National Park. These areas of protectedor residual green space and countryside are not continuous or homogenous entities, insome instances they can be characterised as fingers/ green wedges that come into thebuilt up area others are small pockets of land between the proposed national parkboundary and the urban edge. The careful management of the urban fringe is essentialto retaining the setting of the city in the downland and maintaining the clearly delineatedboundary that exists between urban development and the open countryside. The lack ofurban sprawl is a most attractive and characteristic feature of the city and its setting inthe landscape and should not be eroded on a piecemeal basis by unsightly or harmfuldevelopments or infrastructure.

2.140 The urban fringe is vulnerable to urban pressures such as fly-tipping, vandalism,farm fragmentation leading to abandonment and inappropriate recreational activity suchas illegal motorbiking. Elsewhere there has been piecemeal enclosure both forhorsiculture and garden use. This all contributes to a continuing diminution of thecountryside, in terms of both its extent and its character and quality.

2.141 There are developments or uses for which sites are unlikely to be found within thebuilt up area and sites in the urban fringe may need to be identified. Proposals forfacilities that can not be located in the built up area but are necessary to service theneeds of the city such as new forms of waste or water management, renewable energygeneration (including woody biomass), local food production will be considered provideda sequential test is undertaken to exhaust urban possibilities. Uses appropriate in theurban fringe could include the management of access to the city and the facilitation of agateway to the National Park by sustainable transport modes.

2.142 The city has adopted a sustainable farming strategy for the management of itsfarmland to prevent soil erosion, flooding and pollution of the city’s water supply. TheDraft River Adur Catchment Flood Management Plan prepared by the EnvironmentAgency looks to influence land management to reduce, or ensure no increase in, run-offrates and to encourage activities that may have potential to reduce run-off rates from the

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South Downs and contribute to wider benefits (biodiversity, soil conservation and waterquality improvements).

2.143 The protection of water supply and water quality are key responsibilities in theurban fringe because the chalk under the downland around the city is the aquifer orgroundwater storage that supplies the city. The EU Water Framework Directive introducesa new concept of ‘good status’ that is far more rigorous than current water environmentquality measures and it includes the protection of groundwater. This valuable resourceneeds to be protected from pollution and from land uses with a high risk of pollution.

2.144 The council has adopted a sustainable agriculture policy and signed a managementagreement for the South Downs AONB. The council works with other landowners andDEFRA to seek sustainable management of the Downland not in its ownership andcontrol.

Implementation

2.144 The preferred option would be implemented through the Core Strategy, theProposals Map, generic Development Policies in the Development Policies and SiteAllocations DPD, the development control process and the Local Transport Plan.

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Context

2.145 A National Park is proposed for the chalk landscapes of the South Downsstretching from Hampshire in the west to Beachy Head in East Sussex. National Parks areadministered by a National Park Authority (NPA), which will have the purpose ofconserving and enhancing the natural beauty, wildlife and cultural heritage of the parkand providing opportunities for its understanding and enjoyment by the public and astatutory duty to prepare a Local Development Framework for the National Park.

2.146 For the administrative area of Brighton & Hove the proposed South DownsNational Park boundary includes most of the land currently designated as part of theSussex Downs Area of Outstanding Natural Beauty (AONB) but excludes some parts thatare either developed, proposed for development in adopted development plans or wherethe landscape has been reduced in quality. The proposed park also includes a major tractof land west of Woodingdean and Ovingdean, south of the race course and the cliffs andcoast south of Beacon Hill which do not currently enjoy AONB status.

2.147 The role of the preferred option is to set out the council’s aspirations for thoseparts of the national park within the administrative area of the city to inform futurepartnership working with the National Park Authority. In the interim, until the NationalPark order is confirmed, PPS7, and saved policies in the adopted Local Plan (NC6, NC7and NC8) will continue to give high priority to the protection of AONB land. The SouthEast Plan (Panel Report) reiterated that the purposes of the National Park designationshould be a material consideration in the making of any planning decision that maysignificantly affect the Park.

Preferred Option – SA5 The South Downs

Following confirmation of the National Park order, the council will work inpartnership with the National Park Authority and adjoining authorities andlandowners to protect and enhance the natural beauty of the South DownsNational Park and recognise the following council priorities for National Park

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SA5 – The South Downs

Supporting Documents:PPS7 Sustainable Development in Rural Areas - 2004PPS9 Biodiversity and Geological Conservation - 2005South East Plan Examination Panel Report - 2007SDNP Inspector’s Report on the National ParkBoundary - 2007The South Downs Management Plan - 2007The Downland Initiative - 2005Stanmer Park Historic Landscape Survey andRestoration Management Plan - 2003Sustainable Community Strategy -2006Housing Needs Survey - 2005

land that falls within the city’s administrative area:

1. Promote sustainable land use management systems on the downs withgreater emphasis on local healthy food production, diversification andfarming practises that are sympathetic to wider downland objectives;

2. Conserve and enhance downland habitats and species to meet BAP targetsand recognise the role of the Downs in the city’s green network (see CP5Biodiversity);

3. Protect scheduled ancient monuments and other downland features;

4. Protect sensitive aquifer protection zones and address catchment floodmanagement issues.

5. Increase the amount of access land adjacent to the urban area and enhanceaccess from the urban area to the Downs by sustainable transport including bywalking, cycling, riding and public transport modes (see CP8 SustainableTransport and CP4 Healthy City);

6. Facilitate tourism in the South Downs and the provision of gateway facilitiesto the South Downs National Park, recognising in particular, the role ofStanmer Park (see SA4 Urban Fringe and CP18 Culture, Tourism and Heritage).

Supporting Text

2.148 Until such a time as the South Downs National Park is confirmed by the Secretaryof State of the Department for Farming and Rural Affairs the South Downs AONB isprotected by national and regional planning policies and the adopted Brighton & HoveLocal Plan. The purpose of this preferred option is to set the council’s aspirations forthose parts of the National Park within the administrative area of the city to inform futurepartnership working with the National Park Authority. Through implementation of the2005 Downland Initiative the council is currently working towards a more sustainableapproach to the land management of the South Downs, by improving conservation,public access and recreation whilst maintaining financially viable farm businesses.

2.149 An important role of the National Park Authority will be to promote understandingof the South Downs and to promote access to the Park by sustainable means. A numberof these measures are likely to be implemented within the administrative area of the citycouncil therefore emphasising the need for good partnership working. Stanmer Park is aGrade II registered park of special historic interest, a 485 hectare rural estate withlandscaped park, buildings and gardens, a village, farmland, woodland and amenitygrassland used as public open space within the AONB and proposed to be entirely withinthe National Park. It is covered by a variety of nature conservation and conservationdesignations and is a major recreational resource for residents and visitors. TheSustainable Community Strategy sets out the plan to promote access to the South Downsby developing Stanmer Park as a gateway, promoting open access and improving publictransport.

2.150 The chalk under the downland around the city is the aquifer or groundwaterstorage that supplies the city. It is therefore important that it is protected from anydevelopment or land use that could cause harm by polluting or affecting the watersupply held in the chalk. There are also a number of sites of archaeological andbiodiversity interest designated within the proposed South Downs National Park that aresubject to national and regional protection. 78


Implementation

2.151 In the interim period, prior to designation of the National Park the Sussex DownsAONB continues to be protected by national planning policy set out in PPS7 and savedpolicies NC7 and NC8 in the adopted Brighton & Hove Local Plan (July 2005). Currentstrategies to enhance the South Downs AONB, including the South Downs ManagementPlan and Downland Initiative will continue to be implemented until replaced by a NPAstrategy. The Stanmer Park Historic Landscape Survey and Restoration Management Plan2003 sets out the programme of work to achieve the restoration and management ofStanmer Park.

2.152 Once the National Park is designated the council will seek effective partnershipworking with the SDNPA, adjoining local authorities and landowners to contributetowards protecting the setting of the National Park and providing sustainable access andappropriate gateway facilities. The city council will work towards promoting jointworking structures with the SDNPA, landowners and adjoining local authorities. Thoseareas of AONB land that will fall outside the National Park boundary will be covered bySA4 Urban Fringe.

2.153 Protecting biodiversity will be implemented through core policy CP5 Biodiversity;improving sustainable transport to and from the National Park will be addressed throughCP8 Sustainable Transport and promoted by the Healthy City core policy CP4.

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Context

2.156 The strategy for sustainable neighbourhoods relates to all neighbourhoods of thecity which are primarily residential. The strategy requires joint working with partners,including the health and education sectors, the community and voluntary sector,sustainable transport providers, the police and local communities which will be facilitatedby the Local Area Agreement by the city’s Local Strategic Partnership and ‘family ofpartnerships’. The strategy for sustainable neighbourhoods is underpinned by thefollowing aims (see spatial objectives):

l create balanced communities that meet the needs of all who live there;

l reduce the need to travel by private car and make roads in residential areas feel safer;

l the availability of jobs and training;

DELIVERING SUSTAINABLE NEIGHBOURHOODS

2.154 A sustainable neighbourhood is a place where there are good quality publicservices; mixed and integrated communities with a number of housing choices (including,size, type and for different incomes); places where people feel they can influencedecision-making and have pride in their community; where there is good access to jobs,shops and other local services and where there is a healthy and safe environment(Sustainable Communities: building for the future ODPM 2003).

2.155 The Sustainable Neighbourhoods strategy and Preferred Option SN1 will apply toall residential areas of Brighton & Hove indicated on the key diagram. The aim is tosupport the delivery of sustainable communities across the city. The Residential RenewalAreas Strategy and Preferred Option SN2 take a positive approach to tackling the specificproblems of more deprived areas and reducing inequalities. Specific problems in thesedeprived areas include low levels of qualifications and skills, high rates of unemployment,poor quality of the physical environment, low levels of good health, fears overcommunity safety and community disempowerment.

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SN1 Sustainable Neighbourhoods

Supporting Documents:Sustainable Community Strategy - 2006Reducing Inequality Review - 2008Refreshed Local Area Agreement - 2007Neighbourhood Renewal Strategy - 2002Neighbourhood Action Plans - 2007Retail Study 2006Urban Characterisation Study 2007Local Transport Plan 2006Draft Brighton & Hove Social EnterpriseStrategy - 2008

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l help create communities that work well – with good local facilities (shops, pubs,cafes), opens space and play and community facilities (GPs surgeries, schools,community buildings);

l engage with and listen to local communities;

l encourage environmental sustainability.

Preferred Option – SN1 Sustainable Neighbourhoods

Contribute to creating and maintaining sustainable neighbourhoods by workingwith partners, developers and local communities to:

1. Focus new development in neighbourhoods in local shopping centres andparades where the proposal contributes to the range and viability of localfacilities by maintaining and creating a focal point for community activitiesand encourage investment to improve sustainable transport.

2. Ensure a good balance and mix of uses in existing defined local centres ismaintained and carefully monitored, and opportunities for defining new localcentres in areas currently under-provided for should be explored (see CP15Retail Provision).

3. Facilitate creation of employment opportunities within neighbourhoods.

4. Ensure new or enlarged community facilities (e.g. surgeries, schools, youthfacilities, community buildings) are provided by working with partners toidentify appropriate sites in areas of need or shortfall; ensure newdevelopment contributes to community priorities and needs through planningobligations (see CP9 Developer Contributions); and encourage shared use ofexisting and new community facilities.

5. Contribute to creating balanced communities through the requirement fornew development to provide an appropriate mix of dwelling sizes, tenuretypes and affordable housing (see CP11 Housing Delivery and CP12 AffordableHousing).

6. Promote new development that builds on the positive aspects of the characterof neighbourhoods and protects distinctive and important aspects of character(see CP2 Urban Design and CP13 Housing Densities).

7. Work with local communities to identify priorities for safer streets andpriorities for sustainable transport improvements.

8. Prioritise improvements to open space, sports and recreation facilities in localneighbourhoods where a shortfall has been identified (CP6 Open Space,Sports and Recreation and CP4 Healthy City).

9. Encourage neighbourhood arts projects that improve the environment anddevelop community spirit

10. Encourage existing education and community organisations to forge closerlinks with local communities by providing them with a greater range ofservices and facilities for learning and training.

11. Encourage environmental sustainability improvements to new and existingbuildings (CP1 Sustainable Buildings).

12. Establish mechanisms and processes that give communities the skills,confidence and power to shape and influence public services.

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Supporting Text

2.157 Creating sustainable communities is an ambition of national, regional and localpolicy documents. The preferred option is part of the new area-based approach seekingto direct former topic based policies in the previous version of preferred options into thisintegrated area strategy.

2.158 Promoting development in local shopping centres/hubs in suburban reflects thespatial strategy in the first Preferred Options Core Strategy. Good quality developmentwill be allowed where it helps to strengthen the provision and viability of local servicesincluding shops, community facilities (including public houses) and public transportaccess.

2.159 Local shopping centres and parades provide important local services toneighbourhoods and can often be a focal point for community activities. A sustainablecommunity should have a reasonable range of shops, public houses and cafes that servesday to day needs for local residents particularly for those without access to transport.Parts 1 and 2 of the strategy seek to secure investment in local parades/centres andensure a healthy mix of uses is maintained. The important role of a network of localshopping centres and parades, particularly for walk-in top-up shopping is recognised andsupported. These centres should allow local communities and neighbourhoods to accessfresh, locally produced food and key services for people travelling on foot or by meansother than the car.

2.160 Good quality community facilities within walking distance of all neighbourhoods iscentral to the sustainable neighbourhood strategy. Such facilities may include GPssurgeries, education, training and health centres and community buildings.

2.161 Although there is currently a citywide surplus of school places, demand for placesis unbalanced with schools in the centre and west of the city having significant capacityproblems whilst in the north-east there is an oversupply of places. As primary schools areencouraged to serve their local areas by the government the council will need to addressissues of capacity at these schools and the wider balance of school places across the city.Additionally opportunities to share existing community buildings and facilities, likeschools, churches and universities will be maximised. Through funding by the Learningand Skills Council proposals are coming forward for the refurbishments andimprovements to sixth form colleges in the city.

2.162 Balanced communities should cater for a mix of all household types andaffordability ranging from single households to larger families and including the needs ofdiverse groups such as older people, disabled people, the black and ethnic minoritycommunity and the lesbian, gay, bisexual and transgender community.

2.163 CP2 Urban Design and CP13 Housing Densities set out the urban design prioritiesfor the city. Higher densities are unlikely to be achieved in those suburban and villageneighbourhoods or localities where existing low density development contributes to apositive sense of place. The Urban Characterisation Study provides a comprehensiveunderstanding of the diversity, quality and sensitivity of the city’s neighbourhoods. Thestudy will be used to guide consideration of backland or infill developments and moredetailed policies will be set out in the Development Policies and Site Allocations DPD.

2.164 The preferred option will seek to encourage householders to improve the efficiencyof existing stock by encouraging retrofit of efficiency measures and sustainable energymeasures.

2.165 Part 7 of the preferred option will require securing improvements to residentialareas in terms of road safety and where appropriate opportunities for shared surfaces,safer streets and traffic calming will be implemented. Effective community involvementin implementing this strategy will contribute to strengthening sustainable communities.

2.166 Robust and meaningful community engagement at all levels of participation, and athriving voluntary sector are critical elements for a sustainable community and are apriority for all residential neighbourhoods in the city.

Implementation

2.167 Part 1 would be implemented by developers. A good mix of uses with localshopping centres/parades will monitored through retail health checks and viadevelopment policies that will be updated in the Development Policies and SiteAllocations DPD. In the meantime the current policies in the Brighton & Hove Local Planwill be saved until replaced. Implementation of Part 4 requires close working with publicsector providers, in particular the Primary Care Trust, adult learning, community andvoluntary sector and local communities to identify needs, priorities and sites forcommunity uses and specifying these through the Development Policies and SiteAllocations Document.

2.168 Improving community facilities in neighbourhoods by promoting sharing iscurrently underway through the extended schools programme and provision of children’scentres. It is proposed that this should be widened to include sharing university andfurther education college facilities and appropriate health facilities via effectivecommunity development work. New development proposals impacting onneighbourhoods should contribute towards community facilities through developercontributions.

2.169 Parts 5 (balanced neighbourhoods), 6 (urban design), 8 (open space, sports andrecreation) and 11 (environmental sustainability) will be implemented through corepolicies. Ensuring appropriate densities and good quality of design in new developmentwill also be implemented through applying CP13 Housing Densities and CP2 on Urbandesign.

2.170 Safer street initiatives will be funded and implemented through the Local TransportPlan. Additionally the city council, in partnership with local transport operators, will worktowards improving the quality, number and frequency of services to residential areas withan identified shortfall.

2.171 Priorities for improvements to open space, sports and recreation facilities will beidentified through the city council’s Open Space Strategy and will be primarily fundedthrough developer contributions.

2.172 Improved environmental sustainability to existing buildings will be promotedthrough the Sustainable Building Design SPD and the city council’s Sustainability Teamand through applying high sustainability standards to new development proposals.

2.173 The ability of residents to influence decisions in their areas will be implementedthrough an array of mechanisms including the existing neighbourhood action groups,local action teams, neighbourhood partnerships and community development support aswell as any new opportunities from the emerging Community Engagement Frameworkand the revised Local Area Agreement. Residents and community/neighbourhood groupswill have the opportunity to engage in preparing policy and guidance documents and intheir implementation. Engagement will be carried in accordance with the statement ofcommunity involvement and monitored through the annual monitoring report.

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Context

2.174 A major priority of the current Sustainable Community Strategy and Local AreaAgreement is to reduce inequalities between disadvantaged areas and the rest of the city.A number of neighbourhoods in Brighton & Hove have been identified as facing highlevels of disadvantage (based on national indicators of multiple deprivation). Brighton &Hove has two wards within the top 2% most deprived wards in the country and fourSuper Output Areas in the top 3% most deprived. The city council has secured fundingto improve these areas through the New Deal for Communities initiative, which prioritisedMoulsecoomb and Whitehawk in East Brighton, and Neighbourhood Renewal Fund. Thecity’s Neighbourhood Renewal Strategy 2002-2010 originally identified a further sixteenneighbourhoods, of which, nine have neighbourhood action plans which set out thepriorities for each neighbourhood for the period 2007/8-2009/10 and NeighbourhoodRenewal Fund.

2.175 These programmes are reaching the end of their life and the policy approach isunder review nationally and locally. For example, more detailed statistical analysis allowssmaller pockets of disadvantage to be identified below the neighbourhood level usingSuper Output Area and Lower-layer Super Output Area data17. The role of this strategy isto be flexible enough to implement new approaches, nationally and locally, and tomaintain the momentum of the reducing inequalities which remains a priority in Brighton& Hove. It applies to areas identified as not performing well in relation to establishedagreed indicators – for example high workless levels, lower incomes, poor qualityhousing, high teenage pregnancy rates, poorer health, greater levels of crime and fear ofcrime. The strategy introduces a set of priorities specific to these parts of the city thatgoes beyond the general Sustainable Neighbourhoods strategy (SN1 above).

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SN2 Residential Renewal Areas

Supporting Documents:Sustainable Community Strategy - 2006Reducing Inequality Review - 2008Refreshed Local Area Agreement -2007Neighbourhood Renewal Strategy - 2002Neighbourhood Action Plans - 2007Retail Study - 2006Urban Characterisation Study - 2007Open Spaces Study - 2008Local Transport Plan 2006Community Safety, Crime Reduction and DrugsStrategy - 2005Emerging Community Engagement Framework - 2008Draft Brighton & Hove Social Enterprise Strategy - 2008

17 Super Output Area and Lower-layer Output area data refers to a new geographic hierarchy designed toimprove the reporting of small area statistics in England and Wales

Preferred Option – SN2 Residential Renewal Areas

Contribute to creating a city of opportunities by ensuring a better quality of lifefor the most disadvantaged communities by reducing inequalities and addressingthe factors which exclude people from full engagement with community life.

Work with the Local Strategic Partnership, other partnerships and localcommunities to reduce inequality in the city by helping to implement prioritiesthrough planning policy.

1. Promote sustainable community safety by prioritising improvements toidentified crime hotspots, public realm and open space (see CP3 Public Streetsand Places and CP9 Developer Contributions).

2. Contribute to improving sustainable access to and from the deprived areas inouter locations especially where car ownership levels are low by workingclosely with public transport operators and improving cycle and walking links(see CP8 Sustainable Transport).

3. Address high unemployment levels in deprived areas by increasing goodquality employment opportunities and securing training for local people indisadvantaged areas through planning obligations on major developmentschemes (see CP9 developer contributions).

4. Work with local communities to identify suitable areas for safer streetsmeasures to that give people a greater priority over vehicles, measures toslow vehicles, improve the environment and allow for shared surfaces (see CP8Sustainable Transport).

5. Promote a better balance and choice of housing tenures where there is aconcentration of social rented housing (see CP11 Housing Delivery and CP12Affordable Housing).

6. Prioritise improvements to open space, recreation, cultural and sports facilitiesin areas where there is an identified shortfall in terms of quantity, quality andsafety (see CP4 Healthy City and CP6 Open Space, Sports and Recreation) andto meet the needs of the local community.

7. Ensure that major development adjacent to deprived areas contributes toimproved and integrated community facilities where there is an identifiedshortfall including health, youth facilities, education facilities (early years/primary and extended schools services) and community buildings (see CP9Developer Contributions).

8. Support programmes and strategies which aim to reduce inequalities andpromote healthier lifestyles through working with other agencies to promoterenewal or redevelopment to transform the long term outlook for residentsand the health of neighbourhoods.

9. Improve quality of public services through improved joint working betweenall partners through improved engagement with residents andcommunity/neighbourhood groups and empowering local communities.

Supporting Text

2.176 The strategy for reducing inequality in the city requires close working between thecouncil, other statutory agencies, businesses and community and voluntary sector andeffective engagement with local communities to identify priorities. Research has been

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undertaken to assess the success of previous strategies in the Reducing Inequality Reviewwhich makes recommendations for future approaches and strategies. This will inform thereview of the Sustainable Community Strategy, Local Area Agreements and associatedcitywide strategies. The Core Strategy aims to contribute to delivering these priorities andstrategies. The preferred option has been prepared under a changing policy context andfor this reason the Residential Renewal Areas (RRAs) are not specifically identified. Theareas will be identified through other strategies.

2.177 Community safety is a priority for all residents of Brighton & Hove. In deprivedareas it is a matter of even greater importance as these areas often have a relatively highcrime rates compared to other parts of the city particularly in those adjacent to the citycentre. The Crime and Disorder Reduction Partnership in their three yearly CommunitySafety, Crime Reduction and Drugs Strategy, which identifies environment improvementzones (part of the city identified as hotspots for crime).

2.178 Deprived areas are characterised by high levels of people on Incapacity Benefit andhigh levels of worklessness and long term unemployment. One way to tackle this isthrough providing job and training opportunities for young people and adults withinsustainable travelling distance of residential renewal areas for example by requiring majordevelopment schemes to employ local people in the construction of major developments.

2.179 Close working with the local communities is essential in identifying priorities forsafer streets. Safer streets, including child friendly streets and home zones have beenidentified as a priority in a number of Neighbourhood Action Plans prepared by ten of theneighbourhood renewal areas. Following consultation responses on the first PreferredOptions Core Strategy these priorities have been extended to cover all residential areas ofthe city subject to funding.

2.180 There are marked health inequalities between disadvantaged areas (residentialrenewal areas) and the rest of the city. Improvements to open spaces and recreationfacilities within these areas, including better facilities with good access and communitysafety improvements for all ages, will allow residents to have healthier lifestyles. TheOpen Space, Sport and Recreation Study aims to set out an open space framework thatwill inform the open space, parks and sports strategies and help identify priorities forimprovement.

2.181 Securing balanced communities includes providing a better choice of housing type,size and tenure. In some disadvantaged areas of the city there is a concentration ofsocial rented housing. Introducing a better balance of housing choice to thesecommunities can be addressed, for example, by allowing a higher proportion ofintermediate housing18 as part of the affordable housing element of new developments(see policy CP12 Affordable Housing).

2.182 Part 8 would require effective working with Health, Housing and Adult and SocialCare and other support providers to identify areas of disadvantage where renewal orredevelopment and a package of support measures (e.g. education, trainingopportunities) could transform the long term prospects for families and young people,their health prospects and the overall health of the neighbourhood. A vital way ofimproving how services are delivered in these areas is by working closely with residents,community development workers and community groups.

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18 Intermediate Housing is defined as housing at prices and rents above those of social rent, but belowmarket price or rents. These can include shared equity products (e.g. home buy), other low cost homes forsale and intermediate rent. (PPS3 Housing, 2007)

2.183 A key action to achieve better outcomes for the residential renewal areas isimproving the engagement between services and local communities, this includesempowering communities to achieve better outcomes for themselves.

Implementation

2.184 Planning can contribute to community safety priorities by securing developercontributions from new developments towards improving the public realm. Additionallynew development will be subject to secure by design guidance (through a CommunitySafety Supplementary Planning Document) and there will be a community safety policy inthe Development Policies and Site Allocations DPD.

2.185 Sustainable transport and safer streets priorities are identified through the LocalTransport Plan and may be funded through related developer contributions and the LTP.Improving housing choice will be implemented through policies CP11 Housing Deliveryand CP12 Affordable Housing.

2.186 Prioritising improvements to open spaces and sports facilities within these areasneeds to be part of an overarching open spaces strategy prepared in consultation withlocal communities. It can be implemented through developer contributions, partialrelease for development to fund improvements or by sharing existing facilities (e.g.extended schools programme - see SN1). In terms of allowing release of open space, thiswould only be allowed when identified as part of an open spaces strategy, where theopen space is poor quality, where there is an oversupply within the locality and thedevelopment is minimal to fund improvements (see CP6 Open Space).

2.187 Provision of employment opportunities will reflect priorities in the Brighton & HoveEconomic Strategy, such as through the development of high quality employmentopportunities easily accessible by sustainable transport from these neighbourhoods.Training opportunities will be required as part of major development schemes in closeproximity to disadvantaged areas (see CP9 Developer Contributions).

2.188 Planning can help facilitate contributions towards other priorities for communityfacilities in deprived areas identified, for example, through neighbourhood action plans,will be secured from major developments nearby to renewal areas. Partners including thepublic and voluntary sector will implement measures to achieve more effectiveinvolvement in delivery of services.

2.189 Partners including the public and voluntary sector will implement measures toachieve more effective involvement in the delivery of services.

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Context

3.2 Globally, the rate that we are consuming natural resources and altering theenvironment is unprecedented. Studies have shown that in UK consumption equates onaverage to 5.4 global hectares (gha) per person (a sustainable level is suggested to be1.8gha19). Resources are not only being used more quickly than they can be replenished,but potentially contributing to ecological degradation, loss of species, resource depletionand an increase in greenhouse gas emissions that contribute to climate change. A WWFreport20 on ecological footprinting revealed that Brighton & Hove performs particularlybadly being ranked 57th out of the 60 cities featured in the study. This makes the city’sfootprint one of the worst in the UK requiring 3.47 planets or 6.25gha per person. Aspart of this, activities in Brighton & Hove emit about 1.373 million tonnes of CO2 everyyear, with the domestic sector alone accounting for 48% of emissions (mostly fromenergy use). According to the Environment Agency the city is within a ‘highly waterstressed’ region21 with above regional average per capita consumption22. This is not

3.1 This section of the Revised Preferred Options consists of our preferred approach tostrategic policy issues such as housing, transport and shopping. Rather than arrangedunder the headings of the council’s revised Sustainable Community Strategy as previously,these are listed from CP1- CP19.

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PART THREE – CORE POLICIES

Supporting Documents:Sustainable Community Strategy - 2006Sustainability Strategy - 2002Sustainable Building Design SPD - 2008Draft Nature Conservation in Development SPD - 2008Construction & Demolition Waste SPD - 2006Home Energy Efficiency Strategy - 2001Fuel Poverty Strategy - 2002Waste Local Plan - 2006Housing Strategy - 2004-2007 (being revised)Climate Change Action Plan - 2006Draft South East Plan - 2006PPS 1 (including Supplement - consultation), PPG 3,PPS 9, PPG 10, PPS 22, PPS 23, PPG 24Nottingham Declaration on Climate Change - 2000UK Microgeneration Strategy - 2006Air Quality Action Plan- 2007

CP1 – Sustainable Buildings

19 ‘The Ecological Footprint of Brighton & Hove’ Stockholm Environmental Institute (SEI) January 2006.www.sei.se/reap20 ‘Ecological footprint of British city residents’ http://www.wwf.org.uk/filelibrary/pdf/city_footprint2.pdf.Report commissioned by WWF and based on data collated by the Stockholm Environmental Institute (SEI)November 2007.21 Water stress is related to the amount of water available per person for a given area now and in thefuture. An area of serious water stress is defined as that where the current household demand for water ishigh in relation to current effective rainfall or future household demand is likely to be a high proportion ofthe effective rainfall available to meet demand. In areas of serious water stress, water abstraction is alreadyclose to or above acceptable limits.22 South East average 150 to 160 litres per person per day (l/p/d); Brighton & Hove’s consumption is higheraveraging 169 l/p/d (Audit Commission).

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sustainable, but more relevantly, contrary to the Government’s national commitment tosustainable development in general and cutting CO2 emissions by 20% by 2010 inparticular.

3.3 The production of long-lasting, accessible, healthy, resource-efficient buildings thatare adaptable to changes in climate is a key aspect of Brighton & Hove’s sustainable cityagenda. On the one hand, this reflects the high profile sustainability issues have amongcity residents with 99% of City Views survey respondents having at least some awarenessof the causes and effects of climate change. On the other, it reflects the challenges facinga compact seaside city constrained between the South Downs and the sea that, unlikeother UK cities with a significant industrial legacy, vacant or derelict land, has very littlescope for expansion.

3.4 Current European, national and regional strategies and policies supporting the rise inbuilding standards set ambitious targets for the city to deliver, particular when it comes toCO2 emissions reduction. However, the mechanisms put in place for delivering suchtargets tend to focus on large-scale residential new build. This poses additional challengesto Brighton & Hove as the city’s development profile, while including some large scalenew build, consists mainly of small- and medium-size developments affecting the existingstock.

Preferred Option - CP1 Sustainable Buildings

The council will require all development to deliver levels of building sustainabilityin advance of those set out nationally in order to avoid expansion of the city’secological footprint and to mitigate against and adapt to climate change.

This will include requiring that:

1. all new residential development (including conversions) achieve zero carbonstatus23 and the minimum standards as set out by the council in theSustainable Building Design SPD;

2. all non-residential developments meet minimum BREEAM or equivalentstandards set out in the council’s Sustainable Building Design SPD; and

3. all development proposals (including conversions, extensions and changes ofuse) demonstrate how the development:

a) addresses climate change mitigation and adaptation;

b) avoids contributing to an increase in the city’s current level of carbonemissions by delivering significant reductions in fuel use and greenhouse gasemissions via energy efficiency measures and incorporation of on-site low orzero carbon technologies;

c) aspires towards water neutrality24 by meeting high water efficiency standardsand incorporating new technologies to recycle, harvest and conserve waterresources;

d) makes the most effective use of land;

23 Carbon neutral development is one that achieves zero net carbon CO2) emission from energy use on site,on an annual basis. That is, a development that does not contribute towards an increase in the city’scurrent level of CO2 emissions. 24 According to SEERA’s ‘Sustainability Appraisal Sounding Board’ water neutrality is where ’for every newdevelopment, total water use … after the development [is] equal to or less than total water use … beforethe development’.

e) protects occupant health and the wider environment by making the best ofsite orientation and building form and layout via the use natural light andventilation, landscaping and materials;

f) reduces ‘heat island effect’25 and surface water run-off;

g) uses sustainable materials;

h) enhances biodiversity;

i) minimises waste and facilitates recycling, composting and re-use;

j) reduces air and water pollution;

k) maximises operational efficiency through ongoing evaluation and monitoringof building energy and water systems; and

l) is adaptable to respond to changing needs.

In assessing the achievement of such standards the council will consider:

i) site constraints;

ii) technical viability

iii) financial viability; and

iv) delivery of additional benefits.

To assist developers, the council has produced a Sustainable Building Design SPDand a Sustainability Checklist setting out its aspirations, mechanisms andopportunities for minimum Government standards to be exceeded. Monitoringthe effectiveness of the preferred option through the Annual Monitoring Report(AMR) will be used to inform the council of opportunities to exceed therequirements set out through parts 1 to 4 through the Sustainable BuildingDesign SPD and subsequent revisions.

Supporting Text

3.5 The Local Development Framework for Brighton & Hove has a statutory duty tocontribute towards the achievement of sustainable development. The Government’s 2007Climate Change Bill sets out legally binding targets to reduce carbon dioxide (CO2)emissions by at least 26-32% by 2020 and 60% by 2050 against 1990 levels. PPS1Creating Sustainable Communities urges local planning authorities to deliver sustainabledevelopment via high quality inclusive design and sustainable, durable, adaptable,resource efficient developments. More recent Government publications including theSupplement to PPS1 on Climate Change and Building a Greener Future: Towards ZeroCarbon Development pave the way for the delivery of more resource-efficient buildings ingeneral and ‘zero carbon homes’ by 2016 in particular. To support the delivery of suchtargets and aspirations, the Government introduced the Code for Sustainable Homes,which sets nationwide minimum standards for building design and set progressive rise instandards for Building Regulations26.

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25 On hot days urban areas can have temperatures 20 to 60% higher than the surrounding countryside.This is due to a phenomenon called the urban heat island effect that causes air temperatures in large citiesto be warmer than in neighbouring suburbs and rural areas. Warmer air temperatures can impact on airquality, public health and the demand for energy.26 25% improvement by 2010; 44% by 2013; and zero carbon by 2016; Building a Greener Future

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3.6 However, current national and regional drivers for deliver of sustainable buildings ingeneral and the production of zero carbon homes in particular tend to focus on largescale, new build developments (although some recent documents suggest this ischanging27). The challenges facing the city are significant given it’s compact urban formwith a lack of large brownfield sites and a unique development profile with a largecontribution of new dwellings arising from schemes of 9 units of less, conversions orchanges of uses; the older age private sector housing stock in relation to other cities inthe UK28; the fact that 17.4% of its built up area is within conservation areas; and itslimited capacity to generate energy from renewable sources on a large-scale29.

3.7 In this context, focusing only on new build and the development areas will not beenough for a city seeking to avoid expansion of its ecological footprint in general anddeliver local30, regional31 and national CO2 reduction and low and zero carbon energygeneration targets. Building on Local Plan Policy SU232, Brighton & Hove has alreadyinnovated in this area having delivered since 2002 three ‘zero carbon’, highly resource-efficient developments (Brighton Earthship community centre33, a 16-unit housing and the172-unit One Planet Living residential and mixed-use development34). Additionally, since2006, a standard planning condition has been attached to applications for newdevelopment in the city requiring these to achieve at least BREEAM/EcoHomes ‘verygood’ rating (equivalent to those of level 3 of the Code for Sustainable Homes). Thecouncil is committed to build on this work by promoting, at any point in time, the bestpossible standards of sustainable building design, construction, management anddecommissioning in new and existing developments.

3.8 Despite Brighton & Hove’s achievements, the delivery of zero carbon development by2016 is far from straightforward. Information on technologies and methods ofassessment of building performance as well as minimum UK building standards35 is fastchanging. The council recognises the limitations of setting targets and minimumstandards in a strategic document such as the Core Strategy. Hence, a more flexibleoption that will enable for standards to be more responsive to changing conditions in thecity within the overall commitment to delivering levels of building sustainability inadvance of those set out nationally is proposed. That is, for standards to be set and

27 See Sustainable Buildings: The Challenge of Existing Stock – a technical working paper and Report oncarbon reductions in new non-domestic buildings.28 Since 2001, the share of new build homes coming through the planning system each year is considerablylower (0.3%) than the national average (1%); and roughly half of housing completions involveddevelopments containing 9 residential units or less and/or resulted from conversions and changes of use.The proportion of stock built before 1919 and during the inter-war period is 43% for England and 69% forBrighton & Hove (Brighton & Hove House Condition Survey July 2001using data from the English HouseCondition Survey ‘96).29 An advisory panel for the LDF advising on opportunities for incorporation of LZC technologies in the cityin 2006 concluded that Shoreham Harbour and Brighton Marina were the only areas with potential.30 2020 Community Strategy target is to reduce emissions in the city by 3.5% per annum, 2006 - 2020.31 Draft South East Plan policies EN3 and EN4 set regional targets for energy generation from renewablesources and from land-based renewable energy respectively.32 Efficiency of development in use of energy, water and minerals.33 Planning application number BH2001/00481 - the first zero carbon development in the city34 Planning applications BH2007/00469 and BH2006/01761, respectively.35 Recently the Code for Sustainable Homes has replaced EcoHomes and future developments suggest thisCode might be expanded to include commercial buildings. The Government has already set a path towardsdelivery of zero carbon homes by 2016 and is consulting on ways to reduce water use. Over time otherissues such as materials may rise in priority. Emerging methods of assessing the performance of the builtenvironment, such as BREEAM XB, may also become more prominent over time as policy focus shifts fromnew build to existing stock.

tested via the Sustainable Building Design SPD. The Brighton & Hove SustainabilityChecklist, which supports this SPD, and the council’s housing delivery monitoring enablesfor sustainability features and impact upon economic viability in developments comingthrough the planning system to be monitored and assessed. Together these monitoringtools provide a reliable evidence base to guide future policy revision.

Implementation

3.9 The policy will be implemented through the Sustainable Building Design SPD, NatureConservation and Development SPD, Developers Contributions SPD and other relevantSPDs as well as through DC processes. Monitoring requirements will be set out in Part 4.

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Introduction

3.10 Brighton & Hove is a compact city of distinct urban and suburban neighbourhoodswhere streets are human in scale and buildings are generally low-to-medium rise. It hasan extensive historic core but a poor legacy of later 20th century development and littlederelict or vacant land. The topography of the city, its built form and its location betweenthe sea and the South Downs all contribute to its local distinctiveness, which is readilyapparent and enjoyed from key views along the coast and the sea and from hill tops andridgelines within and beyond the built up area.

Preferred Option - CP2 Urban Design

A city-wide Urban Design Framework will identify and set out areas of the citywhich should generally be preserved; areas of the city suitable for localincremental enhancement; and areas of the city where positive measures arerequired to secure area-wide enhancement. Where appropriate, density will beraised through predominantly low-to-medium rise development but making mosteffective use of those identified areas which have the potential for tallerdevelopments (defined as at least 6 storeys or 18 metres in height). The areaswith such potential are:

l Brighton Marina

l Brighton Station / New England area

l Central Seafront

l Eastern Road / Edward Street

l Hove Station area

l Lewes Road corridor

l London Road / Preston Road corridor93


CP2 – Urban Design

Supporting Documents:Urban Characterisation Study -2007Historic Character Assessment report forBrighton & Hove - 2007Tall Buildings Study -2003Tall Buildings SPG - 2004London Road and Lewes Road (LR2)Regeneration Strategy - 2007PPS1 Delivering Sustainable Development - 2005PPS3 Housing - 2006PPS6 Planning for Town Centres - 2005Draft South East Plan - 2006Design Coding in Practice – an Evaluation - 2006CABE and English Heritage joint guidance onTall Buildings - 2007Accessible Housing and Lifetime Homes PAN - 2008

l Western Seafront / Kingsway

l Shoreham Harbour

All new development will be expected to:

1. Raise the standard of architecture and design in the city;

2. Respect the diverse character and urban grain of the city’s identifiedneighbourhoods;

3. Preserve or enhance the city’s built and archaeological heritage;

4. Protect or enhance key strategic views into, out of and within the city;

5. Provide a legible distinction between public and private realm;

6. Incorporate design features which deter crime and the fear of crime; and

7. Be inclusive, adaptable and accessible;

Supporting Text

3.11 The council’s Urban Characterisation Study (2007) for the city provides an overviewof the visual character, historic development, scale and density, movement patterns andsocio-economic make up of Brighton & Hove. It has identified four distinct landscapecharacter types within the city and, within those, 32 distinct neighbourhoods, in additionto the central conservation areas. Each of the 32 neighbourhoods are studied in detailand this will assist in judging which areas are best able to accommodate, or might merit,positive changes in density and/or built form. The central conservation areas are coveredby the Historic Character Assessment report for Brighton & Hove (2007) carried out aspart of the Sussex Extensive Urban Survey. Both documents will inform the proposedUrban Design Framework.

3.12 The Tall Buildings Study commissioned by the council defines broad areas of the citythat may be suitable for tall buildings, in the form of either nodes or corridors. It alsoidentifies areas of exclusion for tall buildings. The council’s subsequent SupplementaryPlanning Guidance (SPG) on Tall Buildings defines them as being at least 6 storeys or 18metres in height and it refined the potential areas to nine in total. These areas arebroadly defined and the SPG recognises that more detailed appraisal will be required, ineach case, before the prospects of each area for taller development can be concluded.The SPG also sets out detailed criteria that the council will apply when considering tallbuilding proposals.

3.13 The purpose of this preferred option is to provide a statutory basis for the proposedUrban Design Framework and to enable as much certainty and clarity as possible aboutwhere and how the city will most significantly accommodate change, including the broadlocation of any taller development. The preferred option also aims to set out the generalstrategic design criteria expected of new development and to require the higheststandards of design. Innovative contemporary architecture and mixed use schemes whichadd distinctiveness to local neighbourhoods and add to the reputation of the city will beencouraged. An important part of achieving an inclusive society is removing physicalbarriers and exclusions imposed on people by poor design of buildings and otherenvironment. It is also important that the design and layout of all proposals shouldincorporate design features which deter crime and reduce the fear of crime. Thispreferred option requires that all new development should comply with Lifetime HomesStandards and ensure that they are accessible to wheelchair users. Further guidance is setout in the council’s Accessible Housing and Lifetime Homes Planning Advice Note 2008.

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3.14 The Urban Characterisation Study provides a comprehensive understanding of thediversity, quality and sensitivity of the city’s urban character to change and thedevelopment trends and pressures within the city. The study will be used to guideconsideration of backland or infill developments and more detailed policies will be set outin the Development Policies and Site Allocations DPD. The council will aim to ensure thathigh quality is maintained through the rigorous enforcement of planning permission andby taking swift and appropriate action on unauthorised developments. Effective andspeedy enforcement will be given greater emphasis.

3.15 The Urban Design Framework will set out priorities for preparing comprehensivedesign guidance, masterplans and supplementary planning documents for developmentareas and other areas requiring positive enhancement. Detailed measures fordevelopment areas will include the identification of the key strategic views into, out ofand within the city. Key local views will be identified in individual area-based documents,such as those for Development Areas.

Implementation

3.16 The Urban Design Framework will take the form of a Supplementary PlanningDocument (SPD), to be adopted by 2011. It will provide detailed city-wide design criteria,identify key city-wide views, place areas within categories and set out priorities for furtherarea-based policy tools where appropriate. Depending on the nature, size and landownership of an area, such tools may include SPDs, Area Action Plans, non-statutorycomprehensive design guides, masterplans, conservation area appraisals and DesignCodes. Each of these will have a timescale to enable future monitoring.

3.17 The existing Tall Buildings SPG is an up-to-date document and will be saved until2013. More detailed design policies will also be included in the Development Policies andSite Allocations DPD. Until this document is prepared relevant policies in the adoptedBrighton & Hove Local Plan will be saved (QD1-QD5).

3.18 This Preferred Option complements the Spatial Strategy and core policy CP13 onHousing Density. It relates to proposed core policy CP3 on Public Streets and Spaces.

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Introduction

3.19 Brighton & Hove’s streets and public urban spaces (the public realm) do not alwaysdo the city justice. The layout of the city, with a strong east-west pattern of streets andseafront, lends itself to relatively easy navigation, but the links between the areas thatpeople want to get to are not as good as they could be. Streets can be cluttered, theremay be too few places to rest and enjoy life and historic buildings can be obscuredbehind street furniture. An opportunity exists to redress this imbalance by aiming for ahigh quality city environment built around a human scale that accommodates the needsof all people. With more than 8 million people visiting the city each year, the highnumber of people in the city centre makes this imperative.

Preferred Option - CP3 Public Streets and Spaces

The quality, legibility and accessibility of the city’s public realm will be improvedin a comprehensive manner, in conjunction with other partners, though newdevelopment schemes, transport schemes and regeneration schemes. Suchimprovements will be required to produce streets and public spaces that enrichthe quality of life for users by:

1. Positively contributing to the network of public streets and spaces in the city;

2. Enhancing the local distinctiveness of the city’s neighbourhoods;

3. Preserving or enhancing the setting of the city’s built heritage;

4. Utilising high quality, robust and sustainable materials for all elements of thestreet scene;

5. Incorporating street trees and/or other suitable street planting whereverpossible;

6. Providing for the needs of all users and allowing for adaptability;

7. Helping to create safe public spaces;96


CP3- Public Streets and Spaces

Supporting Documents:PPS1 Delivering Sustainable Development - 2005PPS3 Housing - 2006PPS6 Planning for Town Centres - 2005Public Space Public Life Study -2007Local Transport Plan - 2006Manual for Streets - 2007

8. Incorporating an appropriate public art element; and

9. Minimising the adverse impact of vehicular traffic.

New developments will be expected to make an appropriate contribution toachieving these requirements.

Supporting Text

3.20 The council’s Public Space Public Life Study (2007) was commissioned to improvethe legibility but also the quality of the city’s network of streets and urban spaces (thepublic realm) and the ‘liveability’ of Brighton & Hove in general. It draws on extensiveresearch and analysis to make recommendations for improving the city’s network ofstreets and spaces. It reflects local knowledge and experience as well as national andinternational best practice. Legibility refers to our ability to hold an image of the city(sometimes known as a ‘mental map’) in our mind as a means to orientate ourselves andplan our journeys.

3.21 The Public Space Public Life Study introduces to Brighton & Hove the concept of apublic realm network which operates across the city. The principle underpinning this isthat a distinctive hierarchy of routes should be developed and that the experience ofmoving through the city should be continuous and consistent.

3.22 The purpose of this preferred option is to ensure that new developments contributetowards the implementation of public ream improvements proposed by the Public SpacePublic Life Study and that all public realm works (whether publicly or privately funded) aredesigned to achieve consistent aims and standards. This will include ensuring that thepublic realm meets people’s whole lifetime needs: children, parents with pushchairs,people with mobility difficulties or visual impairment, those with temporary or permanentdisabilities, and the elderly making it easier for everyone to move around the city; in thisrespect schemes will be expected to do more than simply meet minimum accessibilitystandards.

3.23 Public art can make important contributions to local distinctiveness and legibility. Itmay take many forms and, in relation to the public urban realm, can include constructiondetails, landscape schemes, water features, street furniture and lighting effects. Public Artcan also be used to provide neighbourhood specific distinctiveness and to address widerissues such as community safety and fear of crime. Public spaces often have a temporaryfunction for outdoor events, and good design can facilitate this use (such as removablestreet furniture).

3.24 Priority for implementation will be given to the Development Areas set out in DA1-7proposals and those urban areas with special area policies under SA 1-3 (the Seafront,Central Brighton and Valley Gardens).

Implementation

3.25 Where new major developments are proposed the council will require developers tocontribute to public realm improvements. This will involve contributing towards achievinga public realm network, as set out in the Public Space Public Life Study. Other schemesmay be implemented and funded through the Local Transport Plan. Detailed proposalsmay be included in Area Action Plans. The policy will also be implemented in partnershipwith businesses in Business Improvement Districts, where appropriate.

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Introduction

3.26 Brighton & Hove is a member of the World Health Organisation’s Healthy CitiesNetwork, whose healthy urban planning principles include:

l human health as a key element of sustainable development;

l co-operation between planning and health agencies;

l Health integrated plans and policies.

3.27 Healthy urban planning aims to positively influence the determinants of healthparticularly by the encouragement of healthy lifestyles and particularly through the designand provision of infrastructure which supports healthy living. This encompasses a need toprovide access to healthy housing, sport facilities, recreation, cultural and communityfacilities, healthy food, care and health facilities.

Preferred Option - CP4 Healthy City

Planning will support programmes and strategies which aim to reduce healthinequalities and promote healthier lifestyles through the following:

1. Carry out health impact assessments (HIA or incorporated into a sustainabilityappraisal) on all planning policy documents.

2. Require HIA on all strategic developments in the city.

3. Require larger developments to demonstrate how they maximise positiveimpacts on health within the development or in adjoining areas (where thebenefits of new development can be maximised).

4. Encourage development that promotes health, safety and active living for allage groups, including healthy living options for older people.

5. Recognise and safeguard the role of allotments, small scale agriculture and98


CP4 Healthy City

Supporting Documents:Draft South East Plan - 2006Sustainable Community Strategy - 2006Refreshed Local Area Agreement -2007Neighbourhood Renewal Strategy - 2002Housing Strategy 2004-2007 (being revised) EconomicStrategy - 2005Sustainability Strategy - 2002Climate Change Action Plan - 2006Local Transport Plan - 2006Food Strategy - 2006Reducing Inequality Review - 2008Active Living Strategy and Action Plan - 2006A Strategy to Reduce Health Inequalities - 2005Local Health Community’s Integrated ServiceImprovement Plan; the ‘Best Care, Best Place’consultation document -2004Fit for the Future-consultation document -2007City Wide Estates Strategy for Health & Social Care - 2007(NICE) Public Health Guidance – Physical Activity andthe Environment - 2008

farmers markets in providing access to healthy, affordable locally producedfood options.

6. Joint working with health providers to help deliver and protect a sub-regionalnetwork of critical care hospitals and a city wide integrated network of healthfacilities that is within reasonable walking distance of public transport.

Supporting Text

3.28 The geographical inequalities in health in Brighton & Hove are such that there aremarked differences in physical and mental health and life expectancy between the mostdeprived and most affluent neighbourhoods in the city. The preferred option aims toreduce these inequalities. It is also recognised that alongside this geographical inequality;health issues affect different communities differently. The determinants of health areclosely linked to factors such as ability to earn a reasonable wage and access to healthyhousing, open space, an active lifestyle, cultural and community facilities, healthy foodand care and health facilities. Environmental factors and constraints in the public realmare increasingly being recognised in national guidance as having a significant impact onhealth.

3.29 Planning can have a real influence on these factors. The preferred option relates toaccess to healthy lifestyles including access to community and cultural facilities that affectmental health especially in older people, ensuring a range of services that are responsiveto the diverse needs of the city’s residents, access to healthy food and an integratednetwork of primary and secondary care.

3.30 The preferred option sets out to ensure that developments and policies are tested toensure that they reduce adverse impacts (through HIA; parts 1and 2) and maximisepositive impacts on health and that developers are asked to demonstrate that they havemade provision for accessing green space, cultural facilities, transport options, exercise,and healthy food (parts 3 and 4). Developments should consider the whole lifetime needsof occupiers and overcome barriers to access to facilities both within and beyond thedevelopment. For the purposes of this preferred option, strategic developments aredefined as all developments requiring an EIA and developments covered by theDevelopment Area proposals in this document or of equivalent size. The type of healthfacilities referred to in part 6 include walk-in polyclinics, health centres, multi-practice GPssurgeries, substance misuse clinics, ambulance facilities and critical care facilities includingextension of the Royal Sussex County Hospital.

Implementation

3.31 It is proposed that the preferred option will be implemented in the following way:

l Parts 1 and 2 will be implemented through the requirement for an HIA on its own, oras part of a sustainability appraisal (Plans) or environmental impact assessment(planning application), for all planning policy documents and major developments (asdefined above).

l Under Part 3 expanding the sustainability checklist to address health impacts, orimpacts on determinants of health will be required for all larger developmentsincluding positive measures to encourage healthier lifestyles. This will be assessed aspart of the planning application process and secured by condition or planningobligation. Guidance will be set out in planning advice notes.

l Part 4 – the preparation of planning advice notes (PANs) will encourage and promotepositive impacts on health.

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l Part 5 will be implemented via the development management process and workingwith Health, Housing and Adult and Social Care services and support providers toidentify areas of deprivation where renewal or redevelopment with other supportmeasures could transform the long term prospects for families and young people,including their health and the impact on health of the wider neighbourhood.

l Part 6 will require joint working with the health services in the city to identifyappropriate sites in the city. Some of these will be identified in the DevelopmentPolicies and Site Allocations Development Plan Document and others through theDevelopment Area proposals.

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Introduction

3.32 Biodiversity is the variety of life on earth, and includes all species of plants andanimals and the natural systems that support them. Through ‘ecosystem services’, such asair and water purification and the amelioration of the effects of Climate Change,biodiversity is a core component of sustainable development, underpinning economicdevelopment and prosperity. It also has an essential role in maintaining and improvingquality of life, particularly in urban areas, and contributes to developing locally distinctiveand sustainable communities.

3.33 All local authorities have a Duty under the Natural Environment and RuralCommunities Act 2006 to have regard to the conservation of biodiversity in exercising alltheir functions. The Duty aims to make biodiversity conservation an integral part of policyand decision making.

Preferred Option – CP5 Biodiversity

The council will develop programmes and strategies which aim to conserve andenhance biodiversity and promote improved access to it through the following:

1. Promote the establishment of a ‘green network’ of nature conservationfeatures as an integral part of the open space framework, which incorporatesthe urban area, urban fringe and surrounding downland. Within the network,a strategic approach to nature conservation enhancement will be taken, withthe objectives of :

l linking and repairing existing habitats and nature conservation sites;

l creating new habitat to achieve Biodiversity Action Plan targets;

l enabling improved access to and understanding of natural green space andnature conservation features.101


CP5 – Biodiversity

Supporting Documents:Draft South East Plan - 2006Draft Nature Conservation and Development SPD - 2008Biodiversity Strategy in England - 2002PPS9 Biodiversity and Geological Conservation - 2005Sussex Biodiversity Action Plan - 1998 onwardsSustainable Community Strategy - 2006Draft Green Networks Study - 2008UK Biodiversity Action Plan - 1994

2. Through detailed guidance within a Supplementary Planning Document on‘Nature Conservation and Development’, ensure that all developmentproposals:

a) Provide adequate up-to-date information about the biodiversity which may beaffected;

b) Maximise opportunities to conserve and enhance biodiversity both on and offsite, taking account of the wider ecological context of the development andof Biodiversity Action Plan objectives;

3. Establish criteria-based policies against which development proposals affectingdesignated sites of international, national and local importance; protectedspecies; and biodiversity in the wider environment will be judged. Suchpolicies will distinguish between the relative importance of each of thesenature conservation features to provide clarity about when development maybe permitted and about any mitigation, conservation and enhancement whichmay be required.

Supporting Text

3.34 Brighton & Hove has a strong foundation for biodiversity conservation, having twoSites of Special Scientific Interest (including one Special Area of Conservation), eight LocalNature Reserves (either proposed or declared) and thirty-two Sites of Nature ConservationImportance. Nevertheless consultation responses, national and regional policy all stronglysupport the need for biodiversity enhancements, including those which extend keyhabitats, reduce the isolation of existing areas of habitat and improve ‘local biodiversity’close to where people can appreciate it on a daily basis. These developments will make avital contribution to the city’s commitment to qualify for UNESCO Biosphere Reservestatus by 2020, which is set out in the Sustainable Community Strategy. Further detailswill be described in a forthcoming City Biodiversity Strategy which will aid future detailedpolicy development.

3.35 Clear objectives for the maintenance, connection and extension of key habitats andspecies have been established through the UK Biodiversity Action Plan. The EnglandBiodiversity Strategy also sets a range of objectives specifically for urban developmentwhich are promoted through Planning Policy Statement 9. The objective of the policy isto ensure an adequate contribution to these objectives is made from development withinBrighton & Hove.

3.36 Working with the Sussex Biodiversity Record Centre, Brighton & Hove Council willcomplete an audit of the biodiversity of the city. This will be used to establish a baselinefor future monitoring from which national and Sussex-wide biodiversity creation targets(promoted through the Sussex Biodiversity Action Plan) can be extrapolated to the locallevel. The audit highlights fragments of isolated habitat and identifies strategicopportunities for their reconnection as part of a city-wide network of natural greenspace.

3.37 A separate study is also being carried out in partnership with the SussexEnvironment partnership and Sussex Wildlife Trust to identify the location of a greennetwork in the city. Taking account of existing natural open space, existing and proposeddevelopment density and national objectives to improve access to natural green space,the study will establish the location of the green network to reconnect the urban area,urban fringe and wider downland. The green network will be an integral component of awider open space framework throughout the city which will incorporate sports provision,

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recreation and children’s play amongst other functions. The framework is beingdeveloped through the emerging Open Spaces Strategy which is discussed in more detailin the CP6 Open Space preferred option.

Implementation

3.38 The location of the Green Network was defined in Spring 2008 and is set out in theDraft Green Networks Study and its implementation will be described in a SupplementaryPlanning Document and defined on the Proposals Map to accompany the SubmissionCore Strategy DPD.

3.39 The draft Supplementary Planning Document ‘Nature Conservation andDevelopment’ includes a clear procedure for identifying existing nature conservationfeatures which may be affected by a development and for quantifying the amount ofnew nature conservation features which should be delivered, either on or off site. TheSPD can also be used to quantify the amount of developer contributions which will berequired from development proposals which do not deliver adequate nature conservationbenefits. These contributions will also be used by the council to deliver pre-definedobjectives within the green network. It is anticipated that the SPD will be adopted inSeptember 2008.

3.40 Designated sites of international, national and local importance are shown on theLocal Plan proposals Map (and remain unchanged).

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Introduction

3.41 Brighton & Hove’s green and open spaces play an essential role in maintaining andimproving quality of life and contribute to developing locally distinctive and sustainablecommunities. They are also important in aiding movement around the city. Green openspaces contribute to physical, mental, and emotional well-being and can offer lastingeconomic, social, cultural and environmental benefits. They act as heat sinks and help tocool urban environments. Parks, recreation grounds, play areas, cemeteries andallotments are all part of this rich matrix.

3.42 An Open Space, Sport and Recreation Study has recently been undertaken. Itrecommends local open space standards which have been applied across the city to helpdemonstrate where there are deficiencies or over-supply. Whilst no surpluses wereidentified in Brighton & Hove there are potential areas where some types of open spacecould be used for another recreational use not currently found in that area. The studydemonstrates that in order to meet the needs of future residents, the city will need toretain and effectively use all existing (both public and private) open space and createmore areas of open space. Whilst the standards are set for different recreational uses(such as children’s play areas or parks) regard will be had to the often multi-use of openspaces, such as the sites existing and potential recreational, historical, visual, biodiversity,cultural, sporting and community value.

Preferred Option – CP6 Open Space

The council will safeguard, enhance, promote access and active living, and wherepossible add to Brighton & Hove’s green/open spaces and beaches through thefollowing:

1. The Council will establish a city wide open space framework to complementthe Green Network. The open space framework will include urban open 104


CP6 Open Space

Supporting Documents:PPG17 Planning for open space, sport andrecreation -2002PPS 9 Biodiversity and Geological Conservation - 2005Draft South East Plan - 2006Sustainable Community Strategy - 2006City Sports Strategy & Action Plan - 2006The Neighbourhood Survey – Brighton & HoveOpen Space - 2006Active Living Action Plan - 2006Parks and Green Spaces Strategy - 2006Urban Characterisation Study - 2007Neighbourhood Action Plans - 2007Public Life Public Spaces Study - 2007Open Space, Sport and Recreation Study -2008

spaces and link the seafront, urban fringe and the countryside to retain andenhance a diverse range of spaces and experiences. All development will beexpected to link to the open space framework and Green Network andcontribute to their establishment and retention. (See also CP5 Biodiversity).

2. Retain all existing open spaces and seek better and more effective use,especially by the general public, in accordance with the Open Space, Sportsand Recreation Study and subsequent revisions, audits and strategies.

3. Help secure investment in poor quality, under-used open spaces, particularly inresidential renewal areas (see SN2) to bring about enhancements in qualityand public use.

4. The loss of small areas of poor quality, under-used, low potential open spacemay be supported where it :

l forms part of an approved strategy and will be replaced by the creation ofgood quality public open space with increased use and an agreedmaintenance plan; or

l can be demonstrated to meet local priorities and needs for open space andwill be replaced by significant sustainable improvements to and enhancedmaintenance of the remaining public open spaces in the area.

5. New development will be required to contribute to the provision of andimprove quality, quantity, variety and accessibility of public open space tomeet the needs it generates in accordance with the local standards set outbelow, or subsequent revisions, and help improve public safety within andaround the space. See also CP9 Developer Contributions.

6. New open spaces including extensions should maximise their accessibility to allusers, including the local community and visitors, and seek to improve thevariety and quality of provision in the city. The opening up for community useof private and school open spaces will be sought when considering proposalsaffecting these sites.

7. Proposals seeking to improve regional or tourist open space provision will beencouraged where they also address the local needs, are of high quality, havean agreed funded maintenance plan and add to Brighton & Hove’s vibrancy.

8. Where it is not practicable or appropriate for a new development to provideall or part of the open space requirements on-site, contributions to theirprovision on a suitable alternative site may be acceptable. Where appropriatea sinking fund should be set up for ongoing maintenance and replacement,contributions should be calculated accordingly. (See also CP7 Indoor andOutdoor Sports Facilities, and, CP9 Developer Contributions).

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* The 2008 Open Space, Sport and Recreation Study contains detailed information onQuality Standards expected.

Supporting Text

3.43 The Council intends to take a proactive approach to open spaces within the city.National and regional policy seeks to protect existing open space and to create new ones.It also requires local planning authorities to plan positively for the provision andenhancement of well-designed green spaces that meet identified local needs.Consultation responses highlight the importance of open spaces to people withinBrighton & Hove including visitors.

3.44 With the need to accommodate the city’s housing within the physical constraints ofthe city and the proposed National Park; the subsequent commercial development andthe move towards increased densities it is important that all new development takes intoaccount and provides appropriate amounts of open space. The maintenance andconsequent funding of all open space is key to providing good quality provision and willbe sought as part of the provision of open space in new development. The Councilcommissioned an ‘Open Space, Sport and Recreation Study’ in accordance with PPG17.This study assessed the quantity of open space, quality and accessibility and its perceivedvalue to local people. The study includes parks and gardens, woodlands and scrubland,green corridors, outdoor sports facilities, teenagers’ and children’s recreation play areas,amenity greenspace within housing developments, allotments, cemeteries, churchyardsand civic spaces. It also took into account the countryside and the seafront. The studyinvestigated current and future demand, shortfalls, quality of provision and recommendedappropriate local standards for different types of open space, sport and recreationfacilities. It provides a sound evidence base for future work and strategies. It should be 106


Open Space Standards

CurrentProvision(hectares)

CurrentProvision(hectare /1,000 pop)

QuantityStandard*(hectare /1,000 pop)

Additionalspace requiredby 2026(hectares)

AccessibilityStandards

Parks andGardens

246.8 0.98 0.98 43 ha 15 minutewalk time(720m)

Natural Semi-Natural

721 2.8 2.8 123 ha 15 minutewalk time(720m)

AmenityGreenspace

148.8 0.59 0.58 25.4 ha 10 minutewalk time(480m)

Allotments 59 (+ 15 hacommunitygarden)

0.23 0.23 10 ha 15 minutewalk time(720m)

Children &Young People(equippedplay)

11.8 0.047 0.055 2.5 ha 15 minutewalk time(720m)

Outdoor Sport See CP7

noted that whilst outdoor sport facilities are included within the term ‘open space’ theyare also covered in more detail by preferred option CP7.

3.45 Within residential renewal areas there appears to be a higher incidence of poorquality, under-used, low potential open spaces. There may also be opportunities toredistribute public open space within the city to make the spread more even e.g. byreleasing poor quality sites and making private sites public. Due to the current and futureneeds, all existing open space should be retained and improved. Only in exceptionalcircumstances will the loss in open space be accepted, for example where developmenton a small part of low value and low quality space will bring about an overall increase inopen space or the development of a small part of a site will bring about significant publicopen space improvements that would otherwise not have occurred. Any developmentproposals on open space should be of public benefit and will need to demonstrate thefollowing sequential approach and, where relevant, submit details to demonstrate whythe preceding preferences are not appropriate. First preference is development ancillaryto the use of the land e.g. a sporting use or interpretation centre etc, second preferenceis a community use, third preference is an employment or café use, fourth preferencewould be other types of commercial use. Only where all other types of developmenthave been considered and demonstrated to be inappropriate should residential beconsidered.

Implementation

3.46 This preferred option will be implemented through the normal planning process andin the following ways:

l Through detailed policies and the identification of sites in the Development Policiesand Site Allocation DPD,

l Through the Developer Contributions SPD new developments will be required toprovide and/or contribute to green open space.

l Other partners will also implement this preferred option through existing and futureParks and Green Spaces/Open Space Strategies and management plans.

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Introduction

3.47 With facilities such as the Brighton Race Course and the Sussex County CricketGround, the city contains sporting facilities of regional and sub-regional importance.Indeed, the Nivea Yellow Wave Beach Volleyball centre has been identified as a potentialpre-games training venue for the London 2012 Olympic Games and Paralympic Games.The city also provides a range of indoor sports facilities both public and private. Theredevelopment of King Alfred, (see SA1), the proposed community stadium at Falmer (seeDA3) and the Brighton International Arena at Black Rock (see DA2) will bring aboutsignificant enhancements to the public sports facilities provided in the city. As well asproviding fun, exercise and a sense of achievement, participation in sport and activerecreation helps to create sustainable communities, health and well being, social inclusionand educational attainment. Strategies to improve physical activity are a key publichealth priority. Benefits of increased participation and more active lifestyles includereduced mortality from cardiovascular disease and cancer and improvements in mentalhealth.

3.48 The 2008 Open Space, Sport and Recreation Study has provided a robust evidencebase for the need for additional sport facilities and sets a standard for outdoor sportprovision. Whilst formal outdoor sport primarily takes place on pitches, wickets, courtsetc, casual and informal recreational activities can take place in virtually all types of openspace and therefore the multi-functional use of such space is and should continue to berecognised.

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CP7 – Sports and Recreation

Supporting Documents:PPG13 Transport - 2001Draft South East Plan - 2006LDF Interim Transport - 2008Sustainable Community Strategy - 2006Reducing Inequality Review -2008Local Transport Plan - 2006Sustainable Transport Strategy - 2000Air Quality Action Plan - 2007

Preferred Option CP7 – Sports and Recreation

To facilitate the council’s aspiration to become a Sporting City and to increaseparticipation in sports and physical activity and to meet forecast demand forindoor and outdoor sports facilities, the council will safeguard, enhance, promoteaccess, and where possible add to Brighton & Hove’s sport facilities through thefollowing:

1. Support the delivery of the proposed community stadium at Falmer (see DA3),the Brighton International Arena at Black Rock (see DA2) and the replacementand enhancement of sports provision at the King Alfred (see SA1).

2. Retain existing indoor and outdoor sport facilities where need is sufficient inaccordance with the Open Space, Sport and Recreation Study and subsequentrevisions, audits and strategies. Where it can be demonstrated there is asurplus of provision, retain the outdoor space for alternative open space usesand the indoor space for alternative community uses.

3. Develop an outdoor sports facilities strategy to guide future provision ofoutdoor sports facilities and to inform the Development Policies and SiteAllocations DPD and investigate potential for an additional indoor multisports wet and dry leisure centre.

4. By helping to secure investment in poor quality, under-used outdoor sportfacilities particularly in residential renewal areas (see SN2) to bring aboutenhancements in quality and public use.

5. New development will be required to make provision for and improve thequality, quantity and accessibility of sport facilities to meet the needs itgenerates in accordance with the local standards set out below or, anysubsequent revisions of the 2008 Open Space, Sport and Recreation Study orresulting from detailed council strategy assessments. (See also CP9 DeveloperContributions).

6. New sport facilities including extensions should meet quality standards,maximise their accessibility and affordability to all users, including the localcommunity and visitors. Proposals should seek to improve the variety ofprovision in the city and increase participation in sport and physical activity,especially from sectors of the community currently under represented, inaccordance with the Open Space, Sport and Recreation Study, Sports Strategyand Action Plan, Sport England toolkits, and subsequent revisions.

7. Proposals seeking to improve regional or tourist sport provision will beencouraged where they also address local needs, are of high quality, have anagreed funded maintenance plan and add to Brighton & Hove’s vibrancy.

8. The opening up for community use of private and school sports facilities willbe sought when considering proposals affecting these sites.

9. The council will work with Sport England and where appropriateneighbouring authorities to develop sports hubs and clusters or centres ofexcellence that benefit the local community and wider public.

10. Where it is not practicable or appropriate for a new development to provideall or part of the sports requirement on-site, contributions to their provisionon a suitable alternative site may be acceptable. A sinking fund should be setup for all new sports facilities for ongoing maintenance and replacement,

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contributions should be calculated accordingly. (See also CP9 DeveloperContributions).

Supporting text

3.49 The city is a major tourist destination and is of regional sporting importance andhelps to support the surrounding villages and towns, offering a wider range of facilitiesthan those that can reasonably be provided within smaller urban areas. The city thereforeneeds to ensure it provides appropriate sports and recreational facilities to reflect itsregional status and aspirations to become a major sporting city by 2020. Existing sub-regional/regionally significant facilities such as the Sussex County Cricket Ground,Brighton Race Course and Withdean Stadium should be retained and where possibleimproved with greater public access and use provided to promote physical activity andsport. The proposed community stadium at Falmer (see DA3), the Brighton InternationalArena at Black Rock (see DA2) and the replacement sports provision at the King Alfred(see SA1) will all help to ensure Brighton & Hove provides the type and quality of facilitiesexpected from a regional centre. The London 2012 Games is likely to generate anincreased interest in sport especially with the identification of the city’s beach volleyballcentre as a pre-games training venue. It is therefore recognised that this generatesopportunities for the city of not just sporting benefit but also cultural, health,educational, tourist, business and economic benefit.

3.50 The interim findings of the Open Space, Sport and Recreation Study (2008) suggeststhat the council should aim to provide an additional multi-sports wet/dry leisure centre toaddress the undersupply of swimming, sports hall and fitness facilities and undertake a

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Standard for Indoor and Outdoor Sports Facilities

IndoorNo local standard setbut modellingundertaken in linewith Sport Englandparameters.

Initial findings indicate a potential need for an additionalmultisports wet/dry leisure centre and a commercially operated icerink (this is being verified with consultants).

Outdoor Sports FacilitiesQuantity (Outdoor sport)CurrentProvision

Current Provision(Ha/1,000 pop)

Proposed Standard(Ha/1,000 pop)

Additional Spacerequired by 2026

Approx 118.5hectares

0.47 0.81 Approx 121hectares

Accessibility (outdoor sport)20 minute walk time (960 metres)Quality (outdoor sport)

Clean, litter-free sports facilities should be provided with appropriate, well-drained,wellmaintained surfaces. Ancillary accommodation should include toilets, changing facilities, dog and litter binsand appropriate amenity and sports lighting.All sites should meet the minimum specifications of the appropriate National GoverningBody of sport and meet Disability Discrimination Act guidance.

needs assessment to address potential sports hall space shortfall. However the increasedoffer from the King Alfred redevelopment may not have been taken into account in theinterim findings so confirmation on the need for a multi-sports centre is awaited. Thecouncil has set out in the Sports Strategy Action Plan for Brighton & Hove 2006-2012 thepriority to work in partnership with sports clubs on the development of new facilities oron the refurbishment of existing venues where clubs are looking to increase participationand make links with the wider community. The concept of sport hubs or centres ofexcellence are also being considered by the council.

3.51 With the demand for additional housing and commercial development and themove towards increased residential densities it is important that all new development isaccompanied by appropriate amounts of sport facilities (both outdoor and indoor). Themaintenance and consequent funding of sport facilities is key to providing good qualityprovision and will be sought as part of the provision of sports facilities in newdevelopment. The Open Space, Sport and Recreation Study (2008) has assessed thequantity, quality and accessibility of sport facilities and their perceived value to localpeople and evaluated indoor sports provision. The study investigated current and futuredemand, shortfalls, and quality of provision and has recommended that the localstandard for outdoor sports should be slightly higher than the current provision. Furtherincreases in capacity can be made by qualitative improvements of existing sites. Furtherprovision will be required over the LDF time period in order to keep up with the expectedfuture increase in population. The study also suggested that the council shouldencourage the provision of additional adrenaline or less conventional sports facilities,building on the success of outdoor basketball and volleyball on the seafront.

3.52 An outdoor sports facilities strategy will be undertaken to provide a more detailedassessment on specific facility types across the city which will inform the DevelopmentPolicies and Site Allocations DPD. It is recognised that the provision of Multi Use GamesAreas (MUGAs) and other flexible sports facilities, including Synthetic Turf Pitches (STPs)can help to increase capacity especially where space is limited, however care needs to betaken that they are appropriately located. The council will also explore partnershiparrangements with schools, through secured community access and the Building Schoolsfor the Future programme, to meet the future demand for outdoor sports. The sportingoffer from the sea will also be explored further.

Implementation

3.53 This preferred option will be implemented through the normal planning process andin the following ways:

l Through detailed policies and the identification of sites in the Development Policiesand Site Allocation DPD,

l Through the Developer Contributions SPD new developments will be required toprovide and/ or contribute if appropriate, to sports facilities.

l Other partners will also implement this preferred option through existing and futureStrategies such as: Sports Strategies, Playing Pitch Strategies, Playground Strategiesand Skate Park Strategies.

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Introduction

3.54 Brighton & Hove is recognised as having a significant role as a regional hub (an areawith a high level of accessibility and interchange) and destination for employment,shopping, tourism and healthcare with the A23/M23 linking the city to London/ M25 andthe A27 providing major east-west links. It is identified as a focus for concentration ofland uses and higher order economic cultural and service activity in the draft South EastPlan. This status corresponds with the major projects and developments proposed in thecity.

3.55 The primary role of the preferred option is to promote sustainable transport in thecity through an integrated sustainable transport system that minimises damage to theenvironment and promotes walking, cycling and public transport use and contributes to asafer, cleaner, quieter city (Chapter 7 Sustainable Community Strategy). It reflects theSustainable Transport Strategy which sets out aspirations for transport in the city and theLocal Transport Plan (a five year plan) which is the main mechanism for delivery and seeksto improve road safety, accessibility, air quality and reduce congestion. Priorities include abus based Rapid Transport System linked to improved Park and Ride and a CoachStrategy. Programmed urban realm, sustainable corridor and road safety improvementswill be incorporated into spatial strategies where appropriate.

3.56 The Revised Preferred Options have been the subject of an interim TransportAssessment (full report due in 2008). It confirms that positive measures will be requiredin order to mitigate the impact of increased traffic levels predicted in the city by 2016and 2026. The interim Transport Assessment will be made available for consultation.

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CP8 Sustainable Transport

Supporting Documents:PPG13 Transport - 2001Draft South East Plan - 2006LDF Interim Transport - 2008Sustainable Community Strategy - 2006Reducing Inequality Review -2008Local Transport Plan - 2006Sustainable Transport Strategy - 2000Air Quality Action Plan - 2007

Preferred Option – CP8 Sustainable Transport

Contribute to creating an integrated sustainable transport system that willaccommodate new development, improve accessibility, promote walking, cyclingand public transport use, and contribute to a safer, cleaner, quieter city.

Support and maintain Brighton & Hove’s role as a regional hub for employment,tourism, shopping, education and healthcare by encouraging the rebalance oftransport to non car modes.

This will be achieved through:

1. Effective working with adjoining authorities, the Highways Agency and publictransport operators to improve sustainable transport links.

2. Working with communities to identify priorities for safer streets (e.g. child-friendly streets and home zones) and sustainable transport improvements (seeSN1 and SN2 on Sustainable Neighbourhoods).

3. Implementing measures to promote choice for people and freight to enabletransfer onto sustainable transport modes by means of strategic capitalschemes, fiscal measures and Smarter Choices.

4. Directing significant development into areas with good sustainable transportlinks (the spatial strategy) or ensuring that major development is located inareas where measures can be taken to secure accessibility improvements forall (see DA1-DA7 Development Areas).

5. Securing developer contributions, where appropriate, towards implementingpriorities in the Local Transport Plan (see CP9 Developer Contributions).

6. Ensuring all new major development schemes respond to the demand fortravel they create through the submission of a transport assessment thatincludes measures to mitigate impacts by reducing car use and makingappropriate contributions towards sustainable transport measures.

7. Preparing guidance on parking and accessibility requirements for newdevelopments.

Supporting Text

3.57 The national and regional policy context is to promote sustainable transport choices,reduce the need to travel and to direct growth into urban areas and regional hubs. Thelocal objectives, outlined in the preferred option, are derived from the Full Local TransportPlan, the findings of the Interim Report of the Core Strategy Transport Assessment(March 2008) and the Sustainable Community Strategy.

3.58 The interim findings of the Transport Assessment (TA) confirm that futuredevelopment in the city will increase pressure on the city’s road network unless positivemeasures are taken to mitigate the impact of car borne travel that will result in a modalshift. The TA goes on to support the approach of the spatial strategy which aims tomaximise development opportunities in sustainable transport locations. It confirms thatall of the measures available to mitigate those impacts and increase choices for travellersshould be considered to address the impact of development on car borne travel. An AirQuality Action Plan was published in June 2007 and expands on the air quality aspects ofproposals in the LTP. It is only through successful transport planning that a significantimprovement in air quality will be achieved. 113


3.59 The city’s role as a regional destination and transport hub within the South East willbe supported and implemented through partnership working with adjacent authorities,Highways Agency and public transport operators (including bus, coach and rail) torebalance the transport system along the spokes (A/M23 and A27) in favour of non carmodes, for example improving bus and rail services and provision of park and ride. Theneed for rail service capacity and line improvements within the sub-region (for examplethe reinstatement of the Lewes- Uckfield line) set out in draft Implementation Plan for theSouth East Plan is supported.

3.60 The overall strategy for the city is to reduce the necessity for car travel by promotingchoice through providing sustainable transport options. Sustainable transport cancontribute directly to health and wellbeing; promoting health by making walking andcycling an attractive option; improving air quality and improving road safety through safepedestrianised areas and cycle lane priority.

3.61 There were positive responses to the first Preferred Options stage of the CoreStrategy around introducing safer streets measures in residential renewal areas andcommentators requested that these measures be extended to other areas of the city. Toreflect this, the introduction of home zones, shared surfaces and child friendly streets willbe considered for all residential areas (see SN1 and 2) subject to funding.

3.62 The spatial strategy aims to concentrate development along sustainable transportcorridors and at nodes where there is good access to public transport. This maximisesthe potential for people to reach these areas by a sustainable transport modes and givesviable alternatives to car use. The Marina and Shoreham Harbour may require additionalaccess improvements as part of future development plans. Increased development insome areas, particularly neighbourhoods, provides the potential to improve access bysustainable nodes.

Implementation

3.63 There are two main funding sources for implementation of sustainable transportimprovements: funding through the Local Transport Plan (LTP) and money securedthrough major planning applications (developer contributions) that must be linked to thedevelopment. This will require close working with Transport Planning and will also beimplemented through preferred option CP9 Developer Contributions.

3.64 Air quality improvement should result from the effective implementation of prioritiesin the LTP and Air Quality Management Plan.

3.65 New major development will be required to submit a transport assessment thatlooks at impacts, mitigation measures and contributions towards sustainable transport.Additionally a Supplementary Planning Document will be prepared on Parking andAccessibility that will set up to date maximum parking standard related to accessibility ofsites.

3.66 Sites required to encourage a modal shift, such as a rail transfer station, will beidentified through the Development Policies and Site Allocations Development PlanDocument.

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Introduction

3.67 In ensuring the best for the city from all development, the council will continuesecuring contributions towards adequate and effective provision of new or upgradedinfrastructure to ensure that development functions in its surroundings. DeveloperContributions ensure for the future that the impact of new development is minimisedand that development provides appropriate contributions for creating sustainablecommunities as a whole as well as improving the quality of our built environment.

Preferred Option CP9 – Developer Contributions

The council will require that all new development is accompanied by thenecessary provision of social and physical infrastructure. Any infrastructurerequired before the development is occupied should be provided on time.

1. Inadequacies in infrastructure arising from proposed development will bemitigated through Developer Contributions, secured through a LegalAgreement/ Planning Obligation that will provide sufficient and appropriateimprovement, through upgrade, enhancement or new infrastructure.

2. Contributions will relate to all aspects of land use, community infrastructureand services that may be affected by development and which accord with thecouncil’s identified local priorities and objectives for delivering sustainablecommunities.

3. Specific infrastructure/service priorities have been identified in Part 2 of theplan related to the Development Areas, Special Areas and SustainableNeighbourhoods proposals.

4. The cumulative impact of all development and differing needs forinfrastructure provision and appropriate community needs will be reflected inthe level and type of developer contributions being sought.

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CP9 Developer Contributions

Supporting Documents:PPS12ODPM Circular 5 - 2005DCLG Planning Obligations Practice Guidance - 2006Audit Commission - Securing Community Benefitsthrough the Planning Process - 2006Draft South East Plan -2006Infrastructure Capacity Study – 2006The emerging Developer Contributions SPD.Reducing Inequality Review 2008

5. Further detailed information on the circumstances and range of contributionsthat may be sought from development will be set out in a DeveloperContributions SPD which will establish a sound basis and methodology foragreeing the level and type of infrastructure requirements necessary fromdevelopment and a method for calculation of costs to deliver that service orprovision.

Supporting Text

3.68 The Preferred Option accords with Government advice in PPS12 and Circular 5/05.This is also reflected the views of the local community and other stakeholders asexpressed in consultation and the priorities set out in the various preferred Core Policies.

3.69 The requirement for developers to contribute towards necessary physical and socialinfrastructure and environmental benefits is highlighted in the majority of theDevelopment Areas detailed proposals and it is important that all priorities in the relevantareas are considered. Priorities will also derive from key strategic objectives or key localneeds identified in strategies, plans and commissioned studies.

3.70 The range of infrastructure and service provision where contributions may be soughtwill include:

l Sports, recreation, youth facilities, play space and amenity space

l Employment and regeneration initiatives including training/apprenticeship

l Health and well being including social services

l Education and learning including schools and libraries

l Biodiversity, countryside and open space including access and interpretation

l Public art, public realm and environmental improvements

l Sustainability measures – construction and sustainable building design

l Affordable housing, including accessibility and life-time homes

l Sustainable transport initiatives including public transport, walking and cycling

l Highways infrastructure and local utility infrastructure

l New/replacement community rooms and mixed use facilities

l Tourism, culture and heritage

l Reducing crime, policing and community safety

l Design & conservation of historic buildings

3.71 The Government’s Planning Policy Statement 12 - Local Spatial Plan (PPS12) statesthat the provision of infrastructure is important in new developments and that thecapacity of existing infrastructure and the need for additional facilities should be takeninto account in the preparation of all local development documents.

3.72 The Government Circular 5/05: Planning Obligations provides guidance on the useof Planning Obligations for ensuring that the planning system delivers sustainabledevelopment, together with greater emphasis on the requirement for obligations to benecessary in order to make the development acceptable in planning terms. Either theinfrastructure should be adequate to meet the needs of new development; ordevelopment proposals must take into account any pressures on infrastructure that may 116


arise from such development; or the need for any such provision by new developmentshould be secured through a Section 106 Agreement for appropriate contributions.

Implementation

3.73 The Circular 5/05 advises that guidance on Planning Obligations, secured thoughDeveloper contributions, should be set out in a Supplementary Planning Document (SPD).Currently a Developer Contributions SPD is being produced that broadens and developsthe current Local Plan policies SU15 Infrastructure, and QD28 Planning Obligations.

3.74 Planning will continue to monitor the implementation of planning obligations in asystematic and transparent way and rigorously enforce compliance with legal agreements/planning obligations. Both the SPD and implementation process will provide a consistentand co-ordinated approach, ensuring delivery of new or improved infrastructure, workingin partnership where necessary with other public and private service providers.

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Introduction

3.75 As a coastal city, the risk of tidal flooding from the sea is a potential constraint tothe location of new development. There are no surface water courses in the city,although the south-western part of the administrative area, around Shoreham Harbour,lies within the flood plain of the River Adur. Ground water flooding, flooding from sewersand flooding from run-off from agricultural land following periods of high rain fall haveall occurred in the city within the last 10 years. The underlying geology of chalk alsopresents risks of groundwater flooding.

Preferred Option – CP10 Managing Flood Risk

The council will seek to manage and reduce flood risk and any potential adverseeffects on people or property in Brighton & Hove, in accordance with the findingsof the Strategic Flood Risk Assessment (SFRA).

The risk of tidal flooding along the coastal frontage and specific requirements tomanage that flood risk is addressed in DA2 Brighton Marina and Black Rock site,DA7 Shoreham Harbour and SA1 The Seafront.

Development proposals in locations that have been subject to previous localisedflooding events (including, surface water/muddy floods, groundwater, or sewerfloods) as identified in the SFRA will need to demonstrate that the issue has beentaken into account and appropriate mitigation measures incorporated, inparticular:

1. Where there has been a previous experience of ground water flooding or apotential risk from this is identified, planning applications should beaccompanied by a site specific flood risk assessment, with appropriatemitigation measures considered, such as avoiding basements, in residentialdwellings or water resilient construction materials.

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CP10 – Managing Flood Risk

Supporting Documents:PPS25 Development and Flood Risk -2006Development and Flood Risk: A Practice GuideCompanion to PPS25 ‘living draft’ (2007)Defra – High Level Target 5 - Development inareas at risk of flooding and coastal erosion - 2005Draft South East Plan - 2006Draft River Adur Catchment Flood ManagementPlan (CFMP) – 2007Climate Change Action Plan - 2006Flood Defence Assessment of Downland Flooding - 2001Strategic Flood Risk Assessment - 2008

2. All development proposals must consider if the site may be affected by orincrease the risk of surface water flooding including ‘muddy flooding’. If a riskis identified, planning applications must be accompanied by a site specificflood risk assessment identifying how the flood risk will be reduced ormitigated.

Where site-specific flood risk assessments are required in accordance with theSFRA, they must be consistent with the latest guidance in PPS25 and anysupplementary information from the Environment Agency.

Supporting Text

3.76 In order to help appraise, manage and reduce flood risk in relation to the location ofnew development in the city the council commissioned a Strategic Flood Risk Assessment(SFRA), April 2008 to assess the nature and extent of the flood risk. The SFRA identifiesthe current and potential future risks from different forms of flooding across the city,including taking into account climate change and likely associated rises in sea levels. TheSFRA will be regularly reviewed to ensure that it contains the latest data and planningpolicy and legislation.

3.77 In the SFRA no areas have been identified in Brighton & Hove as at risk of floodingfrom main rivers or ordinary watercourses, however the SFRA identifies risks from othersources of flooding. As a coastal city, there is a need to consider the risk of tidal floodingbecause areas along the coastal frontage lie within Flood Zones 2 (medium probability)and 3 (high probability/functional floodplain). Surface water flooding is also a particularrisk because of the highly urbanised nature of the city and in particular “muddy”flooding in suburbs of the city when surface water runs off the South Downs.Groundwater flooding is also a potential risk for the whole city due to the highpermeability of the underlying chalk South Downs, and linked to this is the potential forsewer flooding if infrastructure becomes inundated with groundwater. The SFRA indicatesareas that have previously been subject to localised flooding events and examines thepotential future risk taking into account climate change.

3.78 The proposed approach to accommodating growth in the city has been screenedagainst all types of flood risk and the SFRA has informed the preferred spatial strategyand identification of Development Areas, where by development has been steered to theareas of lowest flood risk first (the sequential test).

3.79 It has been found not possible, consistent with wider sustainability objectives for thecity, for all the development areas to be located wholly within Flood Zone 1(lowprobability of flooding). Two of the proposed development areas: DA2 Brighton Marinaand Black Rock and DA7 Shoreham Harbour are both in Flood Risk Zone 3 and weretherefore considered in a more-detailed flood risk assessment (a Level 2 SFRA). Thisprovided consideration of the flood hazards in more detail and for Brighton Marina andBlack Rock this provided a framework for managing flood risk whilst still allowingnecessary development to occur (the ‘exception test’). The Sequential Test for the spatialstrategy and the Exception Test for Brighton Marina are included as a background paperto this Core Strategy. The Exception Test identifies that any proposals for development atBrighton Marina must apply a sequential approach within the development site, carry outa site-specific Flood Risk Assessment, and demonstrate appropriate mitigation measuresin accordance with the recommendations in the SFRA. Regarding Shoreham Harbour, theSequential Test concludes that the more vulnerable land uses, such as residentialdevelopment, should be directed to the parts of the Development Area that lie in Flood119


Zone 1, whilst water-compatible development may be appropriate in the areas of higherflood risk.

Implementation

3.81 Flood risk areas, as identified in the SFRA will be shown on the Proposals Map andthis preferred option will be implemented through DC processes. A detailed developmentpolicy in the Development Policies and Site Allocations DPD will set out the approach tomanaging surface water and sustainable drainage systems.

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Introduction

3.82 One of the spatial objectives of the Core Strategy in terms of making provision fornew housing development is to provide people with a wide choice of decent qualityhousing to meet their needs for a stable home and at a cost they can afford. There is aneed to plan for the volume of new residential development (the overall amount of newhousing) the location of new housing and for a variety or ‘mix’ of new housing (in termsof housing tenure, type and size) to ensure that new development meets local housingneeds and contributes to the creation of mixed and sustainable communities. In doing sothe council will be guided by research that has been carried out into localhousing/accommodation needs. We are specifically required to plan for a 15 year supplyof housing, including a rolling 5 year supply of appropriate land/sites. There is also a needto ensure that there will be sufficient and timely provision of the necessary infrastructureand services that new residential development creates a demand for.

Preferred Option – CP11 Housing Delivery

The council will plan for new housing development in order to help providepeople with a wide choice of decent quality housing to meet their needs for astable home and at a cost they can afford, through:

1. Provision will be made for new housing development in accordance with thetarget set for the city in the draft South East Plan – 570 new homes annuallyto 2026. New housing will be provided as indicated in Table 1 below.

2. Within the regional context, the council will plan to meet the specific localhousing/accommodation needs and aspirations of all communities withinBrighton & Hove. Core Strategy policies SN1and CP12 - CP14 are also relevantin this respect.

The council will seek to ensure that proposals for new residential development121


CP11- Housing Delivery

Supporting Documents:PPS3 Housing - 2006Draft South East Plan - 2006Housing Needs Survey - 2005Housing Strategy 2004-2007 (under review)Strategic Housing Land Availability Assessment – Interim Findings - 2008Strategic Housing MarketAssessment - 2008

(and residential conversions including changes of use) incorporate a mix ofdwelling types and sizes that reflects and responds to Brighton & Hove’s housingneeds. The council’s approach will be informed by up to date assessments of localhousing need and housing demand and will be further developed through thefollowing means:

a. At site level, detailed housing mix requirements will be set out for largestrategic sites36 in the council’s Development Policies and Site AllocationsDevelopment Plan Document, Action Area Plans, Supplementary PlanningDocuments and Site Planning Briefs. ‘Windfall’ sites which come forward of asimilar size will also be required to demonstrate that proposals have had fullregard to a range of housing mix considerations (including housing type,tenure and size) and have been informed by up to date local assessments ofhousing need and housing demand;

b. By safeguarding the existing stock of family-sized dwellings within the city,through including policies designed to resist their loss in the DevelopmentPolicies and Site Allocations DPD; and

c. By requiring all new residential development to have regard to thecharacteristics of existing communities/neighbourhoods to ensure they make apositive contribution to the achievement of mixed and sustainablecommunities; (see preferred options SN1 and CP13).

All proposals for residential development will be required to demonstrate impactson existing physical/social infrastructure and to clearly demonstrate howadditional demand created by the proposal for associated infrastructure and localservices will be met as part of the development proposal. Core Strategy preferredoptions CP13, CP3, CP6, CP9 are particularly relevant in this respect.

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36 In accordance with PPS3, paragraph 24. ‘Large strategic sites’ in Brighton & Hove are defined as thosesites capable of achieving at least 50 net dwellings.

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Table 1 Identified Housing Supply 2007 -2022

A

5 YearSupply

6-10 YearSupply

11-15 YearSupply Total

SupplyDevelopmentAreas 2007-2012 2012-2017 2017-2022

DA1 CentralSeafront 8 0 0 8

DA2 BrightonMarina 100 847 1053 2000

DA3 Lewes Road 31 160 167 358DA4 BrightonStation / LondonRoad

410 300 85 795

DA5 Eastern Road /Edward St 216 30 65 311

DA6 Hove Station 1 228 66 295DA7 ShorehamHarbour 29 72 6 107

Total Supply inDevelopmentAreas

795 1637 1442 3874

B

5 YearSupply

6-10 YearSupply

11-15 YearSupply

TotalSupply

Other IdentifiedSites not inDA'svelopmentAreas

2007-2012 2012-2017 2017-2022

Outstanding LocalPlan Allocations withPP

49 16 0 65

Outstanding LocalPlan Allocationswithout PP

100 645 251 996

OutstandingPlanningConsents>6

781 37 0 818

OutstandingPlanningConsents<6

524 8 0 532

Other IdentifiedSites without PP 205 263 605 1073

Total Supply inDevelopmentAreas

1659 969 856 3484

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C

5 YearSupply

6-10 YearSupply


SupplyTotal Supply A+B 2007-2012 2012-2017 2017-2022Total Supply 2454 2606 2298 7358South East PlanTarget* 2790 2790 2790 8370

Surplus/-Deficit -336 -184 -492 -1012* 20 year requirement (11,400) minus 2006/7 completion figure (797) divided by 19years equals an annual requirement of 558

D

5 YearSupply

6-10 YearSupply


SupplyWindfallAllowance 2007-2012 2012-2017 2017-2022

Small WindfallAllowance <6(discounts applied)

665 665 665 1995

Total Supply fromWindfall Sites 665 665 665 1995

E

5 YearSupply

6-10 YearSupply


SupplyTotal SupplyA+B+D 2007-2012 2012-2017 2017-2022

Total Supply3119 3271 2963 9353

South East PlanTarget 2790 2790 2790 8370

Surplus/-Deficit329 481 173 983

Source: Strategic Housing Land Availability Assessment – interim findings 2008

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Supporting Text

3.83 The overall target for new housing development for Brighton & Hove is set out inthe draft South East Plan and is a requirement providing the appropriate context for theamount of new housing development required over the plan period. Governmentguidance set out in ‘Planning Policy Statement 3: Housing’ (PPS3, November 2006)requires local planning authorities to set out a strategy for the planned location of newhousing which contributes to the achievement of sustainable development. PPS3 alsorequires the expected rate of housing delivery for the plan period to be illustratedthrough a housing trajectory. The Council has recently undertaken a Strategic HousingLand Availability Study37 (SHLAA) the aim of which is to specifically identify land/sitessuitable for new housing and to assess the deliverability and developability of sites. Table1 summarises the results of the SHLAA exercise to date and illustrates, in broad terms,where most development will take place across the city and in what plan period. At thisstage, the ‘interim’ results indicate that the city is likely to meet PPS3 requirements forhousing delivery over a 15 year period but that this will require the inclusion of a realisticallowance for the development of (small) windfall sites given the significant developmentconstraints affecting the city and the lack of opportunity to identify specific sites38. Theresults of the SHLAA will be further tested as part of the consultation process for theRevised Preferred Options.

3.84 Achieving a mix of housing is given high priority in PPS3 which requires localplanning authorities to plan for a mix of housing on the basis of the different types ofhouseholds that are likely to require housing over the plan period. Local planningauthorities are advised to have particular regard to current and future demographictrends and profiles; the accommodation requirements of specific groups, in particularfamilies with children, older and disabled people and the diverse range of requirementsacross the area including the need to accommodate gypsies and travellers (see also CP12and CP14). The need to encourage active living for all age groups including health livingoptions for older people is addressed in CP4 Healthy City and the need for developmentsto be inclusive, adaptable and accessible is addressed in CP2 Urban Design.

3.85 The city council has recently completed its ‘Strategic Housing Market Assessment’(SHMA)39 which will be used to inform both the council’s review of its Housing Strategyand policy development within the Local Development Framework. Specifically, the SHMAprovides an important part of the evidence base to inform policies aimed at providing theright mix of housing across the whole housing market - both market and affordablehousing (see also CP12- Affordable Housing). The study acknowledges that there is a rolefor local planning authorities in influencing the mix of dwellings where there are gaps inthe choice of dwellings available to residents within the market area, or where there areproblems with particular neighbourhoods which might (in part) be tackled throughchanges to the types of dwellings available. The study suggests that the objective shouldbe to identify and address ‘bias and broad imbalances’ in the housing market and theexisting stock of dwellings through new residential development. It also suggests that arange of evidence needs to be considered in addition to projections of future householdtypes40.

37 Brighton & Hove Strategic Housing Land Availability Study, Interim Report April 2008.38 Brighton & Hove Strategic Housing Market Assessment, DTZ April 2008 see para. 11.15.39 Brighton & Hove Strategic Housing Market Assessment, DTZ April 2008.40 See Section 10 ‘Future Housing Provision in Brighton & Hove’, SHMA, April 2008.

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3.86 Of particular relevance to the issue of housing mix are the following findings fromthe 2008 Brighton & Hove SHMA:

l Household growth in Brighton & Hove is likely to increase by 23% from 120,000 in2006 to 148,000 households 2026 (CLG, 2004 based projections). Although much ofthis growth will be driven by smaller and non-traditional household units (eg. Singleadults, single pensioners, cohabiting couples and unrelated households sharing) therewill still be moderate growth in other household types including family typehouseholds,41.

l Brighton & Hove has a housing stock characterised by a high proportion of flats,maisonettes and apartments (46%) and a low proportion of detached (11%) andsemi-detached (20%) housing42 compared to the wider housing market areas withinthe study;

l 52% of the housing stock in the city has four rooms or less (equating to a one ortwo bedroom property); the figure for the Wider Coastal Area is 47% and for theSouth East it is 30%. The city has a smaller proportion of stock with five or morerooms (equating to 2 or more bedrooms) than the wider areas (48% compared to theSouth East figure of 70%)43;

l The recent pattern of residential completions in Brighton & Hove has been dominatedby one and two bedroom flatted development and to a greater extent than the SouthEast as a whole. This is likely to have been driven by a range of factors44 includingdeclining affordability, competition for land, higher density development and thegrowth of the ‘Buy to Let’ market which is highly suited to the development of flats.);

l In Brighton & Hove although 89% of smaller properties (one-two bedroomproperties) are occupied by one and two person households, almost half (45%) oflarger properties (four bedroom plus) are also occupied by one and two personhouseholds45. The SHMA concluded that most households ‘under-occupy’ theirdwellings;

l Over 77% of owner occupied dwellings are under-occupied, i.e. households areoccupying more space than strictly ‘needed’. In the social rented sector theproportion is 36% and in the privately rented sector 31% of properties are under-occupied46. Conversely, in the private rented sector 28% of dwellings areovercrowded. The figure is 20% for the social rented sector and 5% for the owner-occupied sector;

l Analysis of 2005 Housing Needs Survey data regarding households likely to move inthe 2005-2008 period (across all tenures) concluded an even spread of demand for 1,2 and 3 bedroom plus properties.47

3.87 These findings indicate that the relationship between household type and size anddwelling type and size is not straightforward and will, in reality, reflect a range of socio-economic variables. However, there is clear evidence of a ‘bias’ towards smaller dwellingswithin the existing housing stock and also in terms of recent residential development

41 SHMA , Section 10, Figure 10.442 SHMA, Section 6, Key points and Section 10, Figure 10.1143 As footnote 8.44 SHMA, Section 10, paragraphs 10.31 – 10.3445 SHMA, Section 10, Figure 10.946 Based on occupancy standard, SHMA, paras 10.39 – 10.42 and Figure 10.15.47 Section 10, SHMA, paragraphs 10.25 - 10.27.

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which points towards a lack of ‘choice’ across the housing market as a whole in terms ofproperty types and sizes available to current and future households. It is within thiscontext that the council’s policy approach to ‘housing mix’ set out in CP11 has beendeveloped. Where appropriate (in terms of site suitability and with reference to thecharacteristics of existing communities/neighbourhoods), the intention will be to secure,through new development, a wider variety of housing types and sizes particularly onlarger sites where new housing development will make an important contribution toexisting communities in terms of regeneration and/or helping to make them moresustainable places to live. See CP12 for further information regarding housing mixconsiderations for affordable housing.

Implementation

3.88 Implementation of the preferred option will be achieved through a variety ofmechanisms. The Development Policies and Site Allocations Development Plan Document(DPD), Area Action Plans and Supplementary Planning Documents will specifically identifysites where residential development is acceptable in principle. Site proposals may alsospecify the mix of housing required in terms of dwelling type and size, housing tenurebalance and the preferred affordable housing mix. Policy HO9 in the currently adoptedLocal Plan for Brighton & Hove will be ‘saved’ until new policies regarding residentialconversion are developed in the Development Policies and Site Allocations DPD. AnAffordable Housing SPD will assist with more detailed aspects of affordable housingprovision. The ‘Developer Contributions’ preferred option (CP9) and DeveloperContributions SPD will also be key in securing appropriate infrastructure and local servicesrequired by development.

3.89 This preferred option implements the Spatial Strategy by reflecting the approach todirecting development and place-making priorities in different parts of the city. Shouldaspects of Development Area proposals change, then CP11 may also need amending.

3.90 Should monitoring indicate that the city is failing to deliver the required amount ofnew housing, a more proactive approach to site identification and development would benecessary in the latter part of the Core Strategy period.


Introduction

3.91 Housing affordability is a major issue for the city, particularly for families and newlyforming households. The 2005 Housing Needs Survey identified an annual affordablehousing need of 1,456 units, a supply requirement almost six times greater than recentnew build delivery levels48. Given the evidence of the scale of housing need, planningmust ensure that the affordable housing secured as part of new residential developmentacross the city facilitates the matching of local housing/accommodation needs andrequirements of particular groups and communities (e.g. families, key workers, theelderly, gypsies and travellers and those with support needs).

Preferred Option – CP12 Affordable Housing

A plan wide target is set to secure an annual average of 230 units of affordablehousing over the plan period; to be achieved from all available mechanisms.

The Council will negotiate with developers to secure up to a 40% element ofaffordable housing where proposals for residential development are capable ofproducing 10 or more dwellings. The policy will apply to all types of residentialdevelopment including conversions and changes of use.

The proportion and type of affordable housing proposed will be assessed againstthe following criteria:

i. local need in respect of the mix of dwelling types and sizes including the needto provide family-sized affordable housing;

ii. the accessibility of the sites to local services and facilities and public transport;

iii. the particular costs associated with the development of the site;

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CP12 Affordable Housing

Supporting Documents:Sustainable Community Strategy- 2006PPS3 Housing - 2006Draft South East Plan - 2006Housing Needs Survey - 2005Housing Strategy 2004-2007 (under review)Affordable Housing DevelopmentViability Study Update - 2007Strategic Housing Market Assessment - 2008

48 2001/2 – 2006/7: annual average 250 units affordable housing delivered.

iv. the extent to which the provision of affordable housing would prejudice therealisation of other planning objectives; and

v. the need to achieve a successful housing development

Across the city, the required tenure split for affordable housing in terms of totaldelivery will be 55% social rented affordable housing and 45% intermediateforms of affordable housing. For individual development sites, the exact tenuresplit will be guided by up to date assessments of local housing need andsite/neighbourhood characteristics.

The preferred affordable housing mix (in terms of unit size and type of dwelling)on individual schemes will be determined through negotiation and informed byup to date assessments of local housing needs and site/neighbourhoodcharacteristics. For the city as a whole, the preferred affordable housing mix to beachieved from new build is 30% one bedroom units; 45% two bedroom units and25% 3+ bedroom units.

Any enabling residential development on identified employment sites will besubject to the same requirements for affordable housing as set out in the abovepreferred option (see CP16 and CP17).

Affordable housing Definition:

Affordable housing includes social rented and intermediate housing, that isprovided to eligible households whose needs are not met by the market,available at a cost that is genuinely affordable to local people and which includesprovision for the accommodation to remain at an affordable price or for thesubsidy to recycled for alternative affordable housing provision. In Brighton &Hove affordable housing will be managed by a Registered Social Landlord. Lowcost market housing is not considered, for planning purposes, as affordablehousing. (Source: PPS3, Annex B, Adopted Brighton & Hove Local Plan)

Supporting Text

3.92 The 2005 Housing Needs Survey (HNS) found that annually, 2,520 affordablehousing units are needed across the city, 1,456 more than existing re-let supply (1,064net re-lets each year) and a supply requirement almost 6 times recent new build deliverylevels (2005 Housing Needs Survey). Taking account of recent delivery levels49, the HNSidentified a net shortfall of 1200 affordable homes per annum. Despite the evidence ofthe scale of housing need, the 2005 HNS acknowledges that there are a range of issuesto consider when setting targets for the delivery of affordable housing from newdevelopments. There is a need to build viable, sustainable developments and to providefor mixed and balanced communities.

3.93 Underlying the scale of the need for affordable housing is an acute affordabilityproblem. In terms of house price affordability, the 2008 Strategic Housing MarketAssessment (SHMA) notes that housing in the city has become less affordable in recentyears. In the period 1997 – 2007, average house prices in Brighton & Hove have almosttripled50. New households wishing to enter the market face particular difficulties togetherwith family households wishing to move to larger properties. The SHMA estimates that afirst time buyer buying a flat would need a household income of £40-45,000 in order tobe able to buy an entry-level flat/maisonette in the city. To buy a semi-detached or

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49 See Footnote 1.50 Figure 7.4, Strategic Housing Market Assessment, April 2008.

terraced dwelling would require a household income of £60-65,000. The SHMA alsopoints to affordability problems within the private rented sector; results indicate that, atcurrent prices and incomes, approximately 65% of households would be unable to affordto rent a 2 bedroom property.

3.94 With annual levels of housing need currently exceeding annual regional housingrequirements for all new residential development (the draft South East Plan51 requires thecity to provide at least 570 new homes each year), the city council considers that themost pragmatic approach is to require that all new suitable residential developmentprovides a viable and deliverable proportion of affordable housing. In accordance withPPS3, a plan-wide affordable housing target is set which seeks to achieve an annualaverage of 230 units over the plan period from all mechanisms (i.e. not just throughplanning obligations). The target reflects that set in the city council’s SustainableCommunity Strategy and reflects average delivery in the period 2001/2 – 2006/7. Thetarget also reflects that set by the draft South East Plan and accords with the sub-regionaltarget for affordable housing set for the Sussex Coast sub-region. It is expected that thetarget will be monitored annually and assessed over each five-year phase of the planperiod to 2026 and be reviewed accordingly.

3.95 The current adopted Local Plan for the city sets a target proportion of 40% foraffordable housing on all suitable larger development sites (10 or more units). In responseto consultation replies at the Preferred Options Stage (October 2006), the city councilcommissioned new research in the form of an updated Affordable Housing DevelopmentViability Study52 to determine whether higher quotas sought for affordable housing (45%and 50%) would be economically viable in development terms and likely to achievegreater amounts of affordable housing for the city. The study recommends that for onsiteaffordable housing provision the target proportion for negotiation remain at 40% andthat the council might also aim to secure (through a supplementary document or similar)a greater level of local subsidy. Higher targets would be stretching development viabilityand may jeopardise development.

3.96 On the basis of the updated Viability Study, the Council considers that the mostbalanced way forward, in terms of a range of inter-related factors (including site supply,housing market trends, local needs and local affordability, together with wider planningobligations) is to continue to seek onsite provision of affordable housing on suitabledevelopment sites by applying a target quota of up to 40% on larger development sites(up to 10 units or more). The proportion and type of affordable housing will be assessedagainst criteria i-iv set out in preferred option CP12.This approach would accord with thedraft South East Plan presumption in favour of on-site affordable housing provision.

3.97 PPS3 also requires local planning authorities to set out the type and size ofaffordable housing required. In terms of the preferred affordable housing mix (includingunit size mix, dwelling type and tenure balance), ongoing monitoring of local housingneeds together with site and neighbourhood characteristics will continue to inform thepreferred option as it is applied to individual sites. For example, in accordance withpreferred option SN2, it may be appropriate to allow higher proportions of intermediatehousing in Residential Renewal Areas to help facilitate regeneration in those areas andachieve mixed and sustainable communities. Such an approach is supported by the 2008SHMA.

3.98 In terms of the size of affordable housing required, the SHMA indicates thatamongst those households identified as in the highest priority need (Bands A and B of 130


51 Panel Report recommendations52 2007 Affordable Housing Viability Study, Adams Integra, December 2007.

the Housing Register), 41% need a 2 bedroom or larger property53, often because theyare young families with children. The SHMA also identifies that although the greatestneed (numerically) is for smaller (one/two bedroom) properties there are also significantpressures on larger homes and a short term priority for a number of three/four bedroomproperties54. The need for family sized affordable housing will be a specific considerationwhen assessing the overall amount and type of affordable housing that is required to beprovided by suitable development proposals.

3.99 ‘Social rented housing’ is rented housing owned and managed by local authoritiesand registered landlords, for which guideline target rents are determined through thenational rent regime. It may also include rented housing owned or managed by otherpersons and provided under equivalent rental arrangements to the above, as agreed withthe local authority or with the Housing Corporation as a condition of grant (PPS3 AnnexB). Intermediate affordable housing is housing at prices and rents above those of socialrent, but below market price or rents and which meets the requirements set out in thedefinition of affordable housing. These can include shared equity products (eg HomeBuy),or other low cost homes for sale and intermediate rent. The definition does not excludehomes provided by private sector bodies or provided without grant funding. Where suchhomes meet the definitions above, they can be considered for planning purposes asaffordable housing. Whereas, those homes that do not meet the definition for example‘low cost market housing’ may not be considered, for planning purposes as affordablehousing PPS3, Annex B).

3.100 The council is committed to providing high quality housing for people who areunable to access or afford market housing, for example, vulnerable people and keyworkers as well as helping people make the step from social-rented housing to homeownership. The Government’s definition of key workers includes those groups eligible forthe Housing Corporation funded Key Worker Living programme and others employedwithin the public sector (i.e. outside of this programme) identified by the RegionalHousing Board for assistance.

Implementation

3.101 Local assessments of housing needs (for example, the 2005 Housing Needs Surveyand subsequent updates together with ongoing monitoring of local housing needs viathe council’s Housing Strategy and Housing Market Assessment) will guide theimplementation of the Core Strategy preferred option for Affordable Housing. Thisevidence base will be particularly important in terms of helping to determine anappropriate affordable housing mix (unit size mix, dwelling type and tenure balance)required as part of any development scheme. It will be essential to tailor the provision ofaffordable housing to the local housing needs of particular household groups includingfamilies, the elderly, single and multi-person households, families, the elderly and allgroups with particular support needs. The council is also currently reviewing its HousingStrategy and this will specifically identify the housing/accommodation and support needsof particular household types.

3.102 A Supplementary Planning Document for Affordable Housing will also be preparedto assist with detailed aspects of implementation.

3.103 Any enabling residential development on employment sites will be subject to therequirements for affordable housing as set out in the above preferred option (see CP16and CP17).

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53 Figure 10.18, SHMA, April 2008.54 Section 11, SHMA.

Introduction

3.104 In order to make the most efficient use of land, Government policy in PPS3 onHousing (2006) requires local planning authorities to develop housing density policies.Density is a measure of the number of dwellings which can be accommodated on a siteor in an area. In a compact city like Brighton & Hove, tightly constrained between the seaand the Downs, it will be particularly important to make the most efficient use ofbrownfield sites by maximising density levels where appropriate. Good design will be thekey to successfully achieving this.

Preferred Option – CP13 Housing Density

Residential development should be of a density that is appropriate to theidentified positive character of the neighbourhood. Development will bepermitted at higher densities than those typically found in the locality where itcan be adequately demonstrated that the proposal:

1. Would be of high standard of design and would help to maintain or create acoherent townscape;

2. Would respect, reinforce or repair the character of the neighbourhood andcontribute positively to its sense of place;

3. Would include a mix of dwelling types, tenures and sizes that reflectsidentified local needs;

4. Is easily accessible by sustainable transport or has the potential to be easilyaccessible;

5. Is well served by local services and community facilities; and

6. Provides for outdoor recreation space appropriate to the demand it wouldgenerate.

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CP13 – Housing Density

Supporting Documents:Sustainable Community Strategy - 2006PPS3 Housing - 2006Draft South East Plan - 2006Urban Characterisation Study - 2007Annual Monitoring Report -2007Strategic Housing Market Assessment - 2008

To make full and effective use of the land available, new residential developmentin Brighton & Hove will be expected to achieve a net density of at least 50dwellings per hectare (dph), provided it contributes positively to creating ormaintaining sustainable neighbourhoods and that all of the above criteria can besatisfactorily met.

Within the Development Areas covered by policies DA1 to DA7, the density ofnew residential development will be expected to achieve at least 100 dph onmajor development sites, provided that all of the above criteria can besatisfactorily met. Where any site-specific policy is in place for the site, the densitylevel in the policy should be met.

Lower densities will be supported on sites where it can be adequatelydemonstrated that the development would reflect the neighbourhood’s positivecharacter, would meet the housing needs of a particular group or groups withinthe community and would better contribute towards creating a sustainableneighbourhood.

Supporting Text

3.105 PPS3 on Housing (2006) states that net dwelling density means only those siteareas developed for housing and directly associated uses, including access roads withinthe site, private garden space, car parking areas, incidental open space and landscapingand children’s play areas, where provided. PPS3 further states that 30 dwellings perhectare (dph) should be used as a national indicative minimum to guide policydevelopment. The draft South East Plan sets an overall regional target of 40 dph.

3.106 The council’s Urban Characterisation Study (2007) has shown that the 19th centuryterraced development that typifies much of the existing urban core of the city nowsupports net density levels ranging between around 60 and over 200 dph. The upperrange of these figures is comparable to some of the city’s purpose built tall blocks offlats. Semi-detached dwellings in the urban core range between 25 and 80 dph,depending upon size and degree of conversion to flats. In some outer 20th centurysuburbs the figure falls below 20 dph.

3.107 Over the two year period 2004 – 2006, 78% of new dwellings completed in thecity (including conversions and change of use) were built at over 50 dph, with a further13% built at between 30 – 50 dph and 9% at less than 30dph. Densities of at least 100dph were frequently achieved in central areas of the city and over 300 dph in somecases.

3.108 The purpose of this preferred option is to ensure that the city makes the mosteffective use of the limited land available whilst ensuring that sustainableneighbourhoods are achieved. The potential to provide high quality underground parkingfor example should be examined as a means of reducing the impact of car parking on thestreetscape. The preferred option will assist in the implementation of Development Areaproposals (DA1-7) and in creating and maintaining sustainable neighbourhoods (SN1).The council’s preferred approach to achieving the appropriate mix of housing type, tenureand size is set out clearly in preferred option CP11 Housing Delivery.

3.109 The Urban Characterisation Study provides a comprehensive understanding of thediversity, quality and sensitivity of the city’s urban character to change and thedevelopment trends and pressures within the city. The study will be used to guideconsideration of backland or infill developments and more detailed policies will be set out133


in the Development Policies and Site Allocations DPD. Higher densities are unlikely to beachieved in those suburban and village neighbourhoods or localities where existing lowdensity development contributes to a positive sense of place and/or where there is littlepotential to achieve greater accessibility to sustainable transport and/or local services orfacilities.

Implementation

3.110 This proposed preferred option will be implemented through Area Action Plans;planning briefs and/or site-specific SPDs; Design Codes; and the development controlprocess. Implementation will be informed and refined by the results of the updatedUrban Capacity Study, the Open Space, Sport and Recreation Study and schemes agreedthrough the Local Transport Plan which serve to extend or enhance access to sustainabletransport.

3.111 Good design will be a fundamental consideration in achieving higher densityhousing and this preferred option will therefore be closely linked to proposed preferredoption CP2 – Urban Design.

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Introduction

3.112 The 2004 Housing Act requires local authorities to assess the need for gypsy andtraveller accommodation in their areas when they assess the housing requirements of therest of the population. As part of the 2005 Housing Needs Survey, the city council tookpart in a sub-regional Gypsy and Traveller Accommodation Assessment (GTAA) publishedin 2006 as the East Sussex and Brighton & Hove Gypsy and Traveller Study. This studylooked at the accommodation needs and aspirations of gypsies and travellers in the EastSussex and Brighton & Hove study area.

3.113 The Brighton & Hove City Council Traveller Strategy aims to promote communitycohesion and to protect the rights and needs of both the settled and travellingcommunities. The Strategy acknowledges that gypsies and travellers have a right to anomadic lifestyle, to equal access to services (such as education, health andaccommodation) and to protection from discrimination and harassment. The GTAA, theTraveller Strategy and recent government guidance in Circular 1/2006 ‘Planning for Gypsyand Traveller Caravan Sites’ provide the appropriate context for planning to help meetthe accommodation needs of gypsies and travellers living in or passing through the city.

Preferred Option – CP14 Provision for Gypsies and Travellers

Provision will be made to meet the local need for gypsy and traveller55 caravanpitches in accordance with requirements set out in the South East Plan.

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CP14 – Provision for Gypsies and Travellers

Supporting Documents:Housing Act - 2004PPS3 Housing - 2006Circular 1/2006 ‘Planning forGypsy and Traveller CaravanSites’ - 2006Draft South East Plan - 2006Housing Needs Survey - 2005East Sussex and Brighton & HoveGypsy and Traveller Study - 2006

55 Definition(s) of Gypsy and Travellers: Circular 1/2006 defines ‘gypsies and travellers’ as: ‘Persons ofnomadic habit of life, whatever their race or origin, including such persons who on grounds only of theirown or their family’s or dependants’ educational or health needs or old age have ceased to traveltemporarily or permanently, but excluding members of an organised group of travelling show people orcircus people travelling together as such’.

In assessing the suitability of new sites to accommodate gypsies and travellers (orextensions to existing sites), the local planning authority will have regard to thefollowing planning considerations and will need to be satisfied that:

l There is safe and convenient access to the road network;

l There is satisfactory access to local services and facilities (including healthservices, GPs, schools, shops);

l The potential for noise and other disturbance from the movement of vehiclesto and from the site and any on-site business activities is not detrimental tothe character and appearance of surrounding areas;

l There is scope for landscaping and planting to help give structure and privacyand to maintain visual amenity;

l There is capacity to provide the necessary physical and social infrastructure(water, electricity, drainage, sanitation, play areas);

Locating suitable sites within AONBs and other areas with nationally recogniseddesignations (for example Sites of Special Scientific Interest, National Parks,National Nature Reserves and Conservation Areas) will only be acceptable wherethere are no other suitable sites and provided that it can be demonstrated thatthey do not compromise the objectives of their designation.

The following locations should be avoided:

l Sites on or near to significantly contaminated land, industrial processes orother hazards, where there would be a detrimental effect on the generalhealth and well-being of residents; and

l Sites in areas of high flood risk; and

l SACs, SPAs, Ramsar Sites and other areas with internationally recogniseddesignations.

Existing Gypsy/Traveller sites will be safeguarded. Proposals that would result inthe loss of all or part of an existing site will be refused unless:

a. the local planning authority is satisfied that the need for the provision of thesite no longer exists; or

b. the proposal complies with the policies in the development plan and areplacement Gypsy/Traveller site is to be provided in a suitable location.

Supporting text

3.114 Circular 1/2006 establishes a new planning framework to help increase siteprovision to meet the accommodation needs of gypsies and travellers, reduce the numberof unauthorised sites and promote good relations with the settled community.

3.115 Regional Spatial Strategies will now identify the number of pitches required foreach local authority area in the light of local assessments of gypsy and travelleraccommodation needs (the GTAA processes). The South East England Regional Assembly(SEERA) is currently undertaking a partial review of the South East Plan to specificallyconsider the accommodation requirements of gypsies and travellers and the review willset pitch requirements for the South East region. The city council has worked closely withits GTAA partners and has submitted advice to SEERA regarding the need for additionalprovision locally. The city council expects that its allocation for permanent (as in 136


residential) pitch provision could be 14-16 pitches56. This will be additional to the transitprovision that the council currently makes at the Horsdean site just north of the A27.Formal consultation on SEERA’s preferred options will take place during September-November 2008.

3.116 Guidance in Circular 1/2006 also advises that the Core Strategy Development PlanDocument should set out relevant planning considerations and criteria for the location ofgypsy and traveller sites which may be used to guide the formal consideration andallocation of sites in further development plan documents (for example, the DevelopmentPolicies and Site Allocations DPD). These criteria can also be used to meet unexpecteddemand for sites and/or to assist the city council in granting planning consent for suitableapplications in advance of the formal adoption of the Development Policies and SiteAllocations Development Plan Document.

3.117 There is a need to ensure that all sites (whether new or existing/improved):

l are sustainable, easy to manage and maintain;

l are of a decent standard, equitable to that which would be expected for affordablehousing in the settled community; and

l support harmonious relations between gypsies and travellers and the settledcommunity.

All sites considered as options for the Development Policies and Site Allocations DPD willhave their social, environmental and economic impacts assessed in accordance with therequirements of the sustainability appraisal.

Implementation

3.118 This preferred option will be implemented through the Development Policies andSites Allocation DPD and the development control process.

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56 SEERA’s ‘Audit Options A and B’ as at January 2008

Introduction

3.119 Brighton & Hove has a wide variety of shopping centres. In addition to thesedefined centres, there are numerous small local shopping parades and individual ‘corner’shops. It is important that Brighton & Hove’s shopping centres and local neighbourhoodshopping facilities remain vibrant, attractive and accessible. Our larger centres havewider roles than just shopping destinations, functioning also as places to work, live, visit,spend leisure time and access transport services.

3.120 Brighton Regional Centre includes the city’s most significant retail offer. Thecombination of shopping opportunities in both the large stores in Churchill Square andthe small independent units in The Lanes and North Laine give Brighton a uniquecharacter, which is integral to its attraction as a major tourist destination.

Preferred Option – CP15 Retail Provision

Brighton & Hove’s current hierarchy of shopping centres will be maintained andenhanced by encouraging a range of facilities and uses, consistent with the scaleand function of the centre, to meet people’s day-to-day needs, whilst preservingthe predominance of A1 use classes:

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CP15 – Retail Provision

Supporting Documents:Sustainable Community Strategy - 2006Refreshed Local Area Agreement - 2007Retail Study - 2006Tourism Strategy - 2008Food Strategy - 2006Economic Strategy -2005LR2 Regeneration Strategy – 2007Draft South East Plan - 2006PPS6 – Planning for Town Centres 2005White Paper – ‘Planning for a Sustainable Future’ -2005

As the Regional Shopping Centre, Brighton has a key primary retail role andshould be the focus of any future significant retail development, see PreferredOption SA2. Consistent with the ‘Character Areas’ defined in Preferred OptionSA2, floorspace provision in Brighton Regional Centre should provide a mix ofsmall and large unit retail floorspace to cater for both national retail occupiersand the demands of smaller independent/local traders.

Applications for new retail development within the boundaries of Brighton &Hove’s defined shopping centres will be permitted subject to consideration ofscale and mix of uses. Considerations of appropriateness of scale are set out innational planning policy statement, Planning for Town Centres (PPS6).

Applications for new edge and out of centre retail development will be requiredto address the tests set out in PPS6.

Supporting text

3.121 The council intends to take a positive approach to retail development within thecity. The city has an established hierarchy of shopping centres and the council iscommitted to ensuring that these existing shopping centres remain the focus for newretail development, which is appropriate to their role and function. A sustainable mix ofA1 Retail and non-A1 uses will be supported in these shopping centres. A major priorityis to safeguard and enhance Brighton Centre as a primary regional centre and this isaddressed in DA1Brighton Centre and Churchill Square area and SA2 Central Brighton.The Brighton & Hove Retail Study (2006) has reviewed the vitality and viability of each ofthe shopping centres. The Retail Study does not recommend that any new centres need

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Centre Definition Defined Centres Linked PoliciesRegional Centre Brighton DA1, SA2Town Centre Hove

London Road-DA4

District Centre St James’s StreetLewes RoadBoundary Road/Station RoadBrighton Marina

-DA3DA7DA2

Local Centre Mill Lane, PortsladePortland Road, Hove‘The Grenadier’, Hangleton RoadRichardson Road, HoveEldred Avenue, WithdeanOld London Road, PatchamLadies Mile Road, PatchamSeven DialsFivewaysHollingbury Place, HollingdeanBeaconsfield Road, Preston ParkSt George’s Road, KemptownWarren Way, WoodingdeanWhitehawk Road, WhitehawkHigh Street, RottingdeanLustrell’s Vale, SaltdeanLongridge Avenue, Saltdean.

SN1 and SN2(all centres)

to be designated or that their status should change apart from Brighton Marina. Howeverthe Council’s preferred approach for Brighton Marina is to retain its District Centre statusand this is set out in DA2 Brighton Marina and Black Rock Development Area. Theimportance of a balanced network of local centres to allow local communities to accessfresh, locally produced food and key services on foot or by public transport is addressedin the Sustainable Neighbourhoods section, SN1 and SN2.

3.122 The Retail Study identifies significant capacity for new food and non-food retailfloorspace to the period 2016. Whilst it finds that there is a sustainable pattern offoodstores throughout Brighton & Hove, it identifies capacity for further conveniencegoods provision of £97.0m (9,696 sq m) by 2009, £109.9m (10,989 sq m) by 2011 and£142.6m (14,256 sq m) by 2016. Similarly, there is capacity for comparison goodsprovision of £114.9m (17,355 sq m) by 2009, £189.6m (27,250 sq m) by 2011 and£422.6m (53,675 sq m) by 2016.

3.123 There is no recommendation in the Retail Study to identify out of centre sites forfood or non-food retail developments in Brighton & Hove within the timescale of thestudy, to 2016. The council is advised to be cautious towards proposals for new out ofcentre foodstore proposals. The study recommends that any proposal in an edge or outof centre location must demonstrate that it meets the requirements of Planning PolicyStatement 6 – Planning for Town Centres (PPS6). As the Regional Shopping Centre, andin accordance with the draft South East Plan, Brighton has a key primary retail role andshould be the focus of any future significant retail development. Other retail centreswhere retail capacity has been identified have been addressed in the relevantDevelopment Area proposals.

3.124 PPS6 sets out the following tests for new edge and out of centre retaildevelopment:

a) the need for the development;

b) that the development is of an appropriate scale;

c) that there are no more central sites for the development (the ‘sequential approach;

d) that there are no unacceptable impacts on existing centres; and

e) that locations are accessible.

3.125 These tests apply equally, with the exception of the sequential approach (where itis only relevant for applications over 200 sq m): and to applications for the extension ofexisting development in edge and out of centre locations. It is not necessary todemonstrate need, the sequential approach or impact for retail proposals within definedshopping centre boundaries or for other main town centre uses within the town centre.Material considerations to be taken into account in assessing planning applications mayinclude physical regeneration, employment generation, economic growth and socialinclusion.

3.126 As a result of information published in the Barker Review of Land Use Planning(December 2006) and the White Paper – ‘Planning for a Sustainable Future’ (May 2007),the ‘needs’ test set out in PPS6 may change in the future.

3.127 The defined shopping centres will be regularly monitored to ensure that thehierarchy remains balanced, appropriate and representative. Regular monitoring will alsodetermine whether it is appropriate to alter the boundaries of the centre, depending onchanging retail characteristics and demand. Monitoring should include regular updates 140


of the Brighton & Hove Retail Study, and annual audits of the defined shopping centres inaccordance with indicators set out in PPS6.

Implementation

3.128 More detailed wording to support and deliver the objectives of Preferred OptionCP15 and the related Development Area proposals will be included in the DevelopmentPolicies and Site Allocations DPD including policies on the appropriate mix of retail andnon-retail uses. Until this document is prepared, relevant policies in the adopted Brighton& Hove Local Plan will be saved (policies SR4 – SR8). Site-specific retail allocations andany boundary changes to the retail centres will be explored through the DevelopmentPolicies and Site Allocations DPD.

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Introduction

3.129 The Brighton & Hove economy has performed strongly in recent years, growing by£1.5bn between 1996 and 2004 (at 2006 prices), with significant falls in unemploymentand rises in average earnings. The city has a strong service sector economy, with publicservices, education and health, and financial and business services being rich sources oflocal employment. There is also a thriving creative industries sector which accounts forover 10% of the city’s economy. Brighton & Hove has a larger proportion of residentsworking in higher-grade professional occupations. Brighton & Hove was twice identifiedas the most profitable place for businesses in England in the years between 1999 and2003. Proposed economic regeneration projects such as the Brighton Centreredevelopment and the Preston Barracks development have the potential to make asignificant contribution to securing economic prosperity and job retention/creation for thecity. Whilst the city has performed well over recent years, it still lags behind other citieswithin the South East. The need to continue to grow the economic base with highervalue services and to fully utilise the city’s workforce assets are priorities of theSustainable Community Strategy, the Brighton & Hove Economic Strategy (2005-2008),the Employment and Skills Plan (2007) and the Local Area Agreement.

3.130 The draft South East Plan identifies Brighton & Hove as part of the Sussex CoastalTowns regeneration priority area. The emphasis within this sub-region is to promotesustainable economic growth and regeneration to reduce intra-regional disparities. Siteswith good prospect for employment use should be protected and consideration shouldbe given to whether sites need to be upgraded or improved.

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CP16 – Strategic Employment Sites

Supporting Documents:Draft PPS4 Planning for SustainableEconomic Development - 2007Draft South East Plan -2006Employment Land Study -2006Creative Industries Workspace Study - 2008Economic Strategy 2005City Employment & Skills Plan -2007Regional Economic Strategy - 2006 - 2016Refreshed Local Area Agreement - 2007

Preferred Option – CP16 Strategic Employment Sites

Sufficient employment sites and premises will be safeguarded in order to meetthe needs of the city to 2026 to support job creation, the needs of modernbusiness and the attractiveness of city as a business location. This will be achievedthrough:

1. The following sites and premises will be safeguarded and promoted forindustrial and business use (under Use Classes B1and B2);

Bell Tower and Roedean Road (former gasworks site) (see DA2),

Moulescoomb and Fairways Industrial Estate (see DA3),

Home Farm Industrial Estate (see DA3),

Melbourne Street Industrial Area (see DA3),

New England Street Business Area (see DA4),

Freshfield Road Business Park (see DA5),

Conway Street Industrial Area (see DA6),

Newtown Road Industrial Area (see DA6),

Victoria Road Industrial Area (see DA7),

South Portslade Industrial Estate (see DA7),

Franklin Road Industrial Area (see DA7),

Shoreham Harbour (see DA7),

Hove Technology Park,

Centenary Industrial Estate,

School Road Industrial Area,

Portland Road Business Park,

English Close Industrial Area,

Sussex House Industrial Area (including BT depot),

Hollingbury Industrial Estate,

The Hyde Business Park,

Woodingdean Industrial Estate,

Hollingdean Industrial Estate,

Existing Storage and Warehousing uses (Use Class B8) on these sites will beprotected.

2. The following sites will be safeguarded and promoted for office and high-tech business sites (Use Classes B1 (a) and (b));

Woollards Field (see DA3),

Preston Barracks (see DA3),

University of Brighton, Watts site (see DA3),

Preston Road (125-163) (see DA4),

87 Preston Road (see DA4),143


Blackman Street (see DA4),

New England Quarter (see DA4),

Amex House and adjacent land (Mighell Street/Carlton Hill/ John Street) (seeDA5),

Circus Street (see DA5),

Portland Street/ Church Street,

North Street Quadrant/Air Street,

City Park,

Patcham Court Farm,

3. Identifying the New England Street area as the location for 20,000 sq m ofnew office floorspace to meet forecast need post 2016 [see DA4].

4. The council will promote the upgrade and refurbishment of sites and premisesso that they meet modern standards required by business, are more resourceefficient and improve the environment or townscape of the site or premise.Proposals for enabling development will need to fully demonstrate how thiswould provide for reinvestment and refurbishment in the site or premise andas a minimum there should be no net loss in employment floorspace and seekto provide for at least as many jobs.

5. The council will encourage the creation of flexible and affordable businessspace to support the city’s key employment sectors, in particular theknowledge-based economy, creative industries and environmentaltechnologies.

6. The council will develop effective links with partners in neighbouringauthorities in the Gatwick and Brighton & Hove (Sussex Coast) Diamond toensure that there is a sub-regional approach to promoting economicprosperity and creating jobs.

Supporting Text

3.131 The Employment Land Study published in August 2006, provides a robust analysisof the expected employment needs over the next 20 years and made recommendationsto ensure that there is a good supply of appropriate employment land safeguarded tofacilitate a broad range of business types. The study drew on a strong evidence base;using local market information and drew on information from the Regional EconomicStrategy, the draft South East Plan and the Brighton & Hove Economic Strategy 2005-2008 (which is currently under review).

3.132 The Employment Land Study examined the existing stock of industrial estates andoffice sites. The supply of employment land is constrained. However the currentlyprotected employment sites and premises are generally adequate, providing economicalaccommodation for the large number of small local businesses that exist in the city. Theseestablished areas remain popular and there are few which can be said to be entirelyunsuitable for their current purposes, as demonstrated by local vacancy levels. The studyconcluded that there is no significant excess of employment land that needs to bereleased or is unfit for purpose.

3.133 The study indicated that there is a need to invest in these areas if they are to servethe productive needs of the future economy but currently rental levels are not sufficient

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for this to occur on any significant scale. The study suggested that enabling developmentcould help secure new modern employment floorspace. This enabling developmenthowever should not compromise the employment use of the site and be the minimumnecessary to bring the employment floorspace up to modern standard. Proposals willneed to be substantiated on an ‘open book’ basis and to provide the full financial detailsin an independent financial appraisal.

3.134 For the period to 2016, the study concludes that the city has sufficientemployment land identified to meet its needs, based on forecast. This is dependent onthe employment aspects of the major developments identified in some DevelopmentAreas coming forward and this will need careful monitoring through the AMR.

3.135 The study suggests that the city ideally needs a higher quality of officeaccommodation than it currently possesses in order to attract high quality inwardinvestment. Through the LDF, the council needs to address the potential shortfall of officespace in the city post 2016, a shortfall of up to 20,000m2 of office space to meet theprojected growth in the office sector. The longer term potential for additionalemployment floorspace has also been identified in the Spatial Strategy, associated withsignificant development at Shoreham Harbour and following further assessment at theHove Station Area.

3.136 Existing industrial activity in the city plays an important role both in providing forlocal industrial and distribution needs and providing industrial jobs locally that servicewider markets. However, manufacturing employment declined during 1995-2004 andemployment forecasts suggests that manufacturing employment will continue to decline.Over the plan period there is likely to be demand for recycling/ waste processing/reprocessing facilities alongside growth in environmental technology sector and existingindustrial estates (for example Hollingdean depot or Westergate Business Park) are likelytherefore to continue to offer appropriate opportunities for such uses.

3.137 The Creative Industries Workspace Study 2008 has indicated that the creativeindustries sector (defined as including advertising, film and video, architecture, music, artand antiques markets, performing arts, computer and video games, publishing, crafts,software, design, television and radio and designer fashion) has significant unmetdemand for workspace both within and outside the traditional B1-B8 Use Classes. Thesector is set to grow at between 2.5 to 5% over the next ten years, with the modestforecast growth requiring 78,967 square metres of affordable employment space by201757. The lack of affordable and appropriate workspace will be a barrier to the growthof this sector. The opportunities for the creation of flexible and affordable business space/workshop or storage space on the sites listed above will be encouraged as onemechanism to meet the unmet demand. Opportunities are also identified in DevelopmentArea proposals, SA2 Central Brighton, CP17 Other Employment Sites, CP18 Culture,Tourism and Heritage.

3.138 According to the Brighton & Hove City Employment & Skills Plan 2007/8- 2010/11the working age population is projected to increase by 12,000 over the next ten years.This means that the city needs to move more than 8,000 more people into work just tomaintain the current 75.6% employment rate. The city’s major developments (detailed inthe Development Area proposals) provide an opportunity for the city to attract significant

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57 Workspace requirements for creative industries are not homogenous and ranges from high spec officespace for production offices, studio space for design sector or visual arts and crafts, communal facilitiesassociated with performing arts and music industries, retail outlets and workshops for arts and antiquesmarkets and unspecified ‘contingency space’.

inward investment to create high value added jobs that can diversify the city’s economy. Itwill be important for agencies to plan effectively around these developments so that localresidents can take advantage of the new jobs that these developments create. Thenumber of new jobs that are potentially required means that the city will need to workeffectively with neighbouring districts to investigate further opportunities for promotingemployment development.

Implementation

3.139 The sites will be identified on an updated Proposals Map and the policy will beimplemented through the development control process.

l Refurbishment of estates/ premises could be supported by regeneration/ EconomicDevelopment initiatives.

l A Supplementary Planning Document will be prepared for London Road to plan forand ensure delivery of the new office floorspace.

l Detailed policies in the Development Policies and Site Allocations DPD will coverissues relating to Mews, live work units and new warehousing development andtrade counter restrictions.

l The Development Policies and Site Allocations DPD will identify sites suitable formixed use development, where employment uses will be considered.

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3.140 Safeguarding a wider portfolio of employment land maintains the capacity for adiverse economic base in the city and provides jobs locally, reducing the need to travel. Agood supply of land and buildings will offer a range of opportunities for creating newjobs in large and small businesses as well as start-up firms. Smaller business premises/workshops support growing sectors such as environmental technologies and the city’screative and cultural industries often have particular needs which may not be met onconventional industrial/ business sites. This preferred approach also responds to the needset out in SN2 to ensure a supply of smaller employment areas at the neighbourhoodlevel.

In order to maintain a wider portfolio of employment land and to protect smalland expanding local businesses along with major employment generators in thecity:

1. Unallocated sites or premises in employment use (Use Classes B1- B8) will notbe released to other uses unless the site or premise can be demonstrated tobe both redundant and incapable of meeting the needs of modernemployment uses (Use Classes B1-B8);

a) Proposals for enabling development will need to fully demonstrate how thiswould provide for reinvestment and refurbishment in the site or premise andthere should be no net loss in employment floorspace unless there aresignificant and demonstrable gains in number of people employed;

b) Where release is permitted, preference will be given firstly to alternativeemployment generating uses, followed by live/work units or affordablehousing.

2. The council will support appropriate expansion plans of hospitals and higherand further education establishments recognising their role as majoremployment generators (see also DA3 and DA5).

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Preferred Option – CP17 Other Employment Sites

Supporting Documents:Draft PPS4 Planning for SustainableEconomic Development - 2007Draft South East Plan -2006Employment Land Study -2006Creative Industries Workspace Study - 2008Economic Strategy 2005City Employment & Skills Plan - 2007Regional Economic Strategy - 2006-2016Refreshed Local Area Agreement - 2007

3. The council will encourage new employment opportunities for vacant orderelict buildings.

4. The council will recognise the often dual use of community facilities foremployment activities through a policy protecting community facilities to beset out in the Development Policies and Site Allocation DPD.

Supporting Text

3.141 The Employment Land Study 2006 indicates the significant constraints ontraditional employment land supply in the city. The Creative Industries Workspace Study2008 has also indicated the lack of affordable, appropriate and available workspace tosupport the growing creative industries sector both within and outside the traditional B1-B8 Use Classes. The study concluded, that even if the sector were to only grow at amodest 2.5% per annum growth rate (regional and local forecasts suggests 5% couldcontinue to be achieved over the next 10 years) there would need to be 78,967 sq m ofnew workspace. Therefore given the limited amount of land available for development inthe city, it is important that the best use is made of all employment sites and premisesand to avoid the loss of well-located viable employment sites which contributesignificantly to the local economy and new job creation.

3.142 Redundancy and unsuitability for modern employment uses will be determined byconsidering the following criteria:

a) location of the site;b) quality of the buildings;c) site or floor layout;d) accessibility;e) proximity to public transport/ trunk routes;f) other uses in the neighbourhoodg) cost of demolition/ refurbishment sets against its future value for employment uses;h) the length of time the site has been vacanti) documented evidence of the marketing strategy adopted, particularly whether it has

been marketed at a price that reflects local market prices and attempts to make thebuilding attractive to different business or employment uses (the length ofmarketing will need to reflect the size and nature of the site or premise andtherefore whilst a year to eighteen months is considered a reasonable marketingperiod for small sites/ premises but a longer period may be required for larger sites/premises).

j) for office uses the prevailing vacancy rate for the size and type of office in Brighton& Hove should also be considered;

k) for an office building whether change of use is the only practicable way ofpreserving a building of architectural or historic interest.

3.143 Alternative employment generating uses are any uses that generate employmentbut are not classified as an employment use (uses falling outside the Use Class B1- B8).This excludes retail or leisure uses unless they comply with the tests of PPS6 TownCentres.

3.144 Draft PPS4 Planning for Sustainable Economic Development encourages localplanning authorities to take a broader view of economic development that looks beyondthe traditional view of employment activities being only those that fall within the UsesClasses B1- B8 (B1 Business, B2 General Industrial and B8 Storage and Distribution). The

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city contains a number of major employment generators including the two Universities,and the Royal Sussex County Hospital and the council will work with higher and furthereducation sector and the city’s Brighton and Sussex University Hospital NHSTrusts andBrighton & Hove Primary Care Trust to support appropriate expansion (see preferredoptions DA3 and DA5 and CP4). Vacant or derelict buildings such as historic buildingsand buildings in rural areas can often provide opportunities for new employmentfloorspace. The council has set out opportunities for farm diversification in its FarmDiversification Planning Advice Note 01, adopted 2006.The Creative Industries WorkspaceStudy 2008 highlighted that many creative industry businesses make use of communityhalls and performance and exhibition venues that are not traditionally viewed asemployment spaces and a detailed development policy in the Development Policies andSite Allocation Development Plan Document will need to reflect the need to protectcommunity facilities for this employment use as well as their community use function.

Implementation

3.145 Through implementing the Core Strategy, the Development Policies and SiteAllocations Development Plan Document and through the development control process.

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Introduction

3.146 Brighton & Hove has a strong cultural and creative industries sector and serves as acultural hub for the region. The city hosts the largest arts festival in England (which brings£20m into the local economy each year) as well as many other major arts festivals andcommunity festivals. The city is home to several arts and creative industries organisationsof regional and national importance (including South East Dance, Photoworks, WiredSussex, Same Sky, Club Penguin and Linden Labs) and therefore the city has a reputationas a ‘producing’ city where innovative and quality new works and products are exportedworldwide. Culture and creativity are important to the city’s prosperity and to enhancingthe built and natural environment and have been at the heart of many of the city’sregeneration projects such as the Brighton Dome and Museum Complex, Jubilee Streetand the Seafront regeneration.

3.147 Tourism is inextricably linked to the cultural life of the city and Brighton & Hove isone of Britain’s leading and established visitor destinations with almost 8m visitors peryear and an estimated £378 m visitor spend each year. The industry has been successfulin responding to changing markets, taste and style and the city has seen nearly a decadeof steady investment in its tourism product.

3.148 Regency Brighton is identified in the draft South East Plan as a regionallysignificant historic built environment and the Royal Pavilion is recognised internationally.Historic buildings and areas play a major role in the quality of life of residents, of creatinga sense of place and are also are an important cultural asset, providing a positive visitorexperience and tourism revenue, which is important to the wider local economy.

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CP18 Culture, Tourism and Heritage

Supporting Documents:Heritage White Paper -2007Conservation Strategy - 2003Tourism Strategy - 2008Creative Industries Workspace Study - 2008Sustainable Community Strategy - 2006Good Practice Guide on Planning for Tourism - 2006Draft South East Plan - 2006South Downs Management Plan - 2007PPS6 Planning, Building and the Environment – 2006PPS1Delivering Sustainable Development - 2005PPG15 Planning and the Historic Environment -1994PPG16 Archaeology -1990

Preferred Option – CP18 Culture, Tourism and Heritage

To maintain and enhance the historic environment and culture of the city tobenefit residents and visitors and support the role of the arts, creative industriesand tourism sector in creating a modern and exciting visitor destination with arange of high quality facilities, spaces, events and experiences.

1. New visitor attractions, arts and festival events will be expected to:

l be of high environmental standards in terms of design and access;

l complement and build on the city’s distinct tourism offer;

l reduce seasonality;

l promote diversity;

l widen local access;

l support the regeneration of the city; and

l be accessible by public transport.

The council will support the upgrading and enhancement of existing visitorfacilities to meet changing consumer demands and high environmentalstandards in terms of design and access;

2. Recognising the role of the South Downs as a visitor and recreation asset, thecouncil will work with the National Park Authority and adjoining authoritiesand Tourism South East to strengthen physical and sustainable transport linksto the countryside see SA4 Urban Fringe and SA5 South Downs National Park;

3. The provision of affordable and appropriate arts and creative industries workspace, creation, storage performance, showing and rehearsal space will bepromoted in regeneration schemes and in major mixed use developmentsacross the city;

4. The council will support investment in spaces suitable for outdoor events andcultural activities that take place in the public realm;

5. The council will ensure the preservation and enhancement of the historic builtenvironment and archaeological assets and their settings, giving the greatestweight to national designations, and ensure that the city’s built heritageguides local distinctiveness for new development in historic areas; and

6. The Conservation Strategy1 will be taken forward and reviewed as aframework for future conservation area management proposals and toprovide criteria for future conservation area designations and other localdesignations and priorities.

1The Strategy for the Conservation of Brighton & Hove’s Historic Built Environment (2003)(and subsequent revisions)

Supporting Text

3.149 If Brighton & Hove is to compete effectively as a tourism destination, it needs todevelop specific experiences for the visitor, to highlight the things that make the cityunique. The Refreshed Tourism Strategy 2008 has set out a vision that by 2018, Brighton& Hove will be a destination where the needs of visitor, the tourism industry, thecommunity and the environment are in complete balance and consequently will make asignificant contribution to improving the quality of life for local people. A well-planned

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and prosperous tourism industry is a catalyst for improving the environment if the cityand the wellbeing of its people thus making it a better place in which to live and visit.The Tourism Strategy 2008 sets out four guiding principles to take the vision forward:

l investment in infrastructure & physical environment;

l sustainable & responsible tourism;

l improving quality & raising standards and

l partnership & consultation.

3.150 In order to remain competitive and attractive as a tourist destination the TourismStrategy highlights specific products where there is real potential for growth andtherefore increasing the economic value of the visitor economy; these are health &activity; culture & heritage, events & attractions, business conferences; film & televisionand architecture & the built environment. The council will support improvements toexisting facilities and seek the highest standard from new tourism proposals and ensurethey accord with the council’s long-term vision for the city’s tourism industry as set out inthe Tourism Strategy.

3.151 Business tourism is vital for the city’s success. Business events such as conferences,meetings and exhibitions bring Brighton & Hove year-round, higher spending visitors,ensuring the city’s tourism industry invests in quality improvements and staff. As well asenjoying the seafront, leisure visitors come to the city to shop, eat out, and enjoy culture,the built heritage, entertainment and nightlife. The city has tapped into the growingshort break and cultural tourism markets, still mainly at weekends, but this extendsbeyond the summer into the spring and autumn. It is also important to recognise theimportance of the city’s natural environment as a tourism asset. The Tourism Strategyidentifies six tourism places across the city with specific character and role when visitorscome to the city. They are:

l Gateways to the city (in particular railway and coach stations but also the LewesRoad, London Road)

l The Seafront

l Neighbourhoods (Kemptown, central Hove and Brunswick)

l The Downs & Villages (South Downs and Stanmer, Rottingdean)

l Central Brighton Retail areas (The Lanes & North Laine)

l Parks & Open Spaces (Preston Park, The Level, Pavilion Gardens)

3.152 Actions are highlighted in the Strategy for each place in order to allow visitors tomove around the area easily, improve the local environment especially facilities for visitorsand public realm areas, help local people and businesses to share in the benefits oftourism and to develop new experiences or products, building on what there is alreadyfor the visitor. The Core Strategy recognises the tourism role of these places through theSpecial Area preferred options DA1- 5 and SA1- SA5.

3.153 Developing and promoting culture is a key way of attracting valuable off-peakvisitors but also supports regeneration and sustainable communities. Recent investmentby the Arts Council, SEEDA and Lottery funding for venues such as the Brighton Dome,Brighton Museum and Art Gallery have helped to establish a critical mass of culturaldevelopment around the Royal Pavilion and Dome (see also SA1). However the arts andcultural sector can also be found across the city including public art, open studios, retailgalleries and exhibitions, street theatre and free arts events and festivals.

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3.154 It is important that the city’s existing cultural infrastructure is maintained andenhanced and that opportunities for new cultural facilities/ creative industries workspacein regeneration schemes and major mixed use developments are supported to meet thesignificant forecast demands for new creative industries workspace over the next tenyears (Creative Industries Workspace Study 2008) and to fill the gaps that exist in thecultural infrastructure and to increase opportunities for participation across the city. Theadopted Circus Street SPD, for example, has identified the need for creative workspace aspart of the proposed mix of uses and this is likely to be delivered through a dance facilitywhich will bring social, health, cultural and economic benefit.

3.155 The role of iconic buildings such as the Royal Pavilion to the attractiveness of thecity as a visitor destination is recognised and the importance of culture to the city’senvironment, landscape, tourism offer, amenities, identity, image and prosperity isreflected in preferred options CP2 and CP3 relating to high quality design and improvingthe public realm, seafront regeneration proposals (see SA1), regenerating the ValleyGardens (see preferred option SA3), maintaining and enhancing the role of centralBrighton including supporting the Cultural Quarter (see Preferred Option SA2) andthrough the major projects identified at Marina, Black Rock (see Preferred Option DA2)and the Brighton Centre redevelopment (see Preferred Option DA1). The preferredoptions for safeguarding affordable and flexible employment sites and premises willsupport the requirement for work space for artists and creative industries.

3.156 Brighton benefits from a diverse population which brings with it a diversity ofinterests, cultures and history. It is important to recognise opportunities to reinforce andsupport this cultural diversity through appropriate accessible buildings, or other provisionwhen development proposals are being brought forward.

3.157 The city’s architectural heritage encompasses the internationally renowned RoyalPavilion and around 3,400 listed buildings, 15 scheduled ancient monuments and sixregistered parks or gardens of special historic interest. In terms of local designations, thecity has 33 conservation areas, numerous locally listed buildings and 84 archaeologicallysensitive areas. The council’s Conservation Strategy (2003) seeks to manage changewithin the historic built environment and to ensure that the available resources are put tothe best possible use. It will be reviewed and revised as the proposals contained in therecent Heritage White Paper are implemented by the Government. A Historic CharacterAssessment report for Brighton & Hove (2007), carried out as part of the Sussex ExtensiveUrban Survey, provides an up-to-date assessment of the city’s historic core and will informconservation area management plans. The preferred option aims to reflect the wealthand importance of the city’s historic environment and its key relationships with tourismand cultural industries in the city.

153


Implementation

3.158 Part 1 and 2 will be implemented through the Tourism Strategy and through thedevelopment control process, in partnership with Brighton & Hove Economic Partnershipand Tourism South East.

3.159 Part 4 and 5 will be implemented through support of the Arts Council England,Arts Lottery, the Arts Commission, SEEDA funds and through developer contributions.

3.160 Part 6 and 7 will be implemented through the Conservation Strategy, throughConservation Area Studies/Management Plans, through the Heritage PartnershipAgreements to be introduced by the Heritage White Paper, via potential future grantschemes in partnership with English Heritage and/or the Heritage Lottery Fund andthrough detailed policies in the Development Policies and Site Allocations DPD, as well asSPDs where appropriate.

154


Introduction

3.161 It is vital that Brighton & Hove is able to support its tourism and businessconference economy by providing a sufficient and wide ranging type and cost ofaccommodation to cater for visitors. The city’s hotel stock has largely kept pace withchanging customer expectations in response to year round business from conferencedelegates as well as “off-peak” custom from the short break market. The TourismStrategy 2008 recognises that good quality hotels help support a strong conferencebusiness offer for the city.

Preferred Option – CP19 Hotel/ Guest House Accommodation

To support the city’s tourism and business conference economy by providing asufficient and wide ranging type and cost of accommodation to cater for visitors:

1. Proposals for new major hotel facilities will be assessed in line with thepolicies in PPS6 and the sequential approach to site selection with proposalsfor new hotel development directed firstly to central Brighton.

2. Proposals for new major hotel facilities should be accompanied by a marketcase including a demand assessment in order to identify how the proposalwould add to the current supply and offer, whether it has the ability to createnew demand and how it might meet needs currently unsatisfied in thedestination.

3. The council will require new major hotel facilities to provide affordable staffaccommodation.

4. The council will safeguard existing hotel and guest accommodation that fallwithin a defined Hotel Core Zone.

155


CP19 - Hotel/ Guest House Accommodation

Supporting Documents:Hotels Future Study - 2007Tourism Strategy - 2008Draft South East Plan -2006Good Practice Guide on Planning for Tourism - 2006PPS6 Planning for Town Centres -2005‘Here to Stay?’ Tourist AccommodationRetention & Loss, Tourism South East - 2006

5. Applications for change of use of existing hotel and guest accommodationoutside the hotel core zone will need to demonstrate that:

a) the accommodation is poorly located in relation to the main generators ofdemand and is no longer viable; and

b) alternative types of guest accommodation are not viable;

6. Proposed extensions to existing hotels will be supported where this is requiredto up-grade existing accommodation to meet changing consumer demands.

7. Partial conversion of a hotel will be considered where there is adequatedemonstration of the need to enable investment in the remaining hotel.

Supporting text

3.162 The city has a significant stock of hotel and guest accommodation; a total of 160hotels and guest accommodation predominantly located in central Brighton and alongthe seafront. The 2007 Hotel Future Study identified a number of new hotels currentlyunder construction or proposed for the city (such as at the Jubilee Street site and at theBrighton Station site) which, if they all come forward, would represent a 16% increase inthe total supply of serviced accommodation in the city. Much of the demand for theadditional accommodation is likely to relate to a redevelopment of the Brighton Centre.Whilst there remains interest in new hotel development in and around the city, the 2007Hotel Futures Study projections for future requirements for hotel development indicatethat the council does not need to identify additional hotel sites over and above thatwhich is already proposed/ planned to 2016 or to prioritise specific types and standardsof hotel in terms of hotel investment marketing. However ongoing monitoring of theimplementation of these commitments/ proposals will need to be undertaken.

3.163 Given the amount of new hotel development planned, and the constraints inidentifying future sites, a more generic ‘sequential approach’ that directs new hoteldevelopment proposals firstly to the central Brighton area is put forward as the preferredoption. This approach is the most sustainable in planning terms, since it allows greateraccess by public transport and will allow visitors to easily access other facilities andattractions in central Brighton.

3.164 It is recognised that there might be potential to locate new development outsidecentral Brighton either for a destination offer or to permit a hotel to serve a particularmarket, or potentially to help regenerate an area but to accord with PPS6 sequential andaccess tests will need to be fully addressed.

3.165 The availability of staff housing is critical for many operators to attach and retainstaff and the provision for staff accommodation in association with new hotels will berequired.

3.166 A managed approach to existing hotel and guest accommodation follows therecommendations in the 2007 Hotel Futures Study. A redefined hotel core zone will relatemore closely to the main generators of demand and will ensure that key areas of the citycentre are not compromised in their role as accommodation clusters. The redefined hotelcore zone provides a clear and visible sign of the core accommodation areas that supportthe city’s tourism industry.

3.167 It is recognised that outside a redefined hotel core zone there will still beaccommodation of significant scale and character which would be difficult to replace andthe preferred approach therefore requires an evidence-based approach towards 156


determining change of use applications. In line with guidance provided by Tourism SouthEast evidence will need to be provided by the applicant of the efforts to sell the businessas a going concern its business performance related to national average occupancy levels,market analysis of the supply of accommodation in the city and applications for changeof use will need to be accompanied by:

l Proof of marketing for sale – as a going concern for a minimum period of 12-18months at competitive prices;

l Evidence of business performance – details of occupancy and achieved rate data forpast three years along with accounts to explain how the business is performing in linewith levels of occupancy typical of industry/ destination norms

l Evidence of professional management – this includes details of marketing andbusiness plans for the last three years to demonstrate investment plans and attemptsto attract business;

l Attempts to save the business – details of schemes to up-grade and re-position thebusiness, partially convert to an alternative use in return for investment in theremaining rooms, and conversion to self-catering, as appropriate, with costs andperformance forecasts and advice sought from by business support agencies andhotel advisors.

3.168 Support should also be given to the up-grading of existing accommodation,including the addition of appropriate facilities such as spas and health clubs. It is alsorecognised that there may be some circumstances where there may be a case to be madefor partial conversion of a hotel to residential/ apartments, to enable investment in theremaining hotel. Applications will need to be accompanied by a clear evidence of thecase for investment, the need for enabling development and the on-going viability of theaccommodation. As a minimum 50% of the hotel rooms/ floorspace should remain.

Implementation

3.169 Through Development Control. Proposals for new major hotel facilities will beassessed in line with the policies in PPS6 and the sequential approach to site selection.

3.170 The ‘hotel core area’ currently shown in the Local Plan proposals map will beamended and re-defined to focus on the main hotel accommodation clusters along ashorter stretch of seafront and a north-south stretch taking in the station to the seafrontand the parallel A23 and this redefined hotel core area will be used to safeguard existinghotel accommodation.

157


Implementation

The implementation of the Core Strategy will depend on the effective action from arange of different agencies. The city council, as Local Planning Authority, will be a keyplayer through its approach for managing development and through the preparation ofdevelopment briefs, design guidance, masterplans to bring forward development in theDevelopment Areas and through detailed guidance in Supplementary PlanningDocuments. However, other parts of the city council and other agencies will also play animportant role in helping to deliver or support different elements of the Core Strategy –either as a provider or facilitator of new development or through their statutory roles inhelping to manage and control development.

The support of the private sector, whether as an agency for development or in theprovision of services in the local community, will also be important and the city councilwill look to maintain close engagement with them in the coming years, through theforum of the Local Strategic Partnership. Central to this approach is the need to ensurethe involvement of the wider community, whether those who live, or work here. The citycouncil will continue to engage the local community seeking to build on their capacity toengage and influence change to ensure the new plans deliver sustainable developmentand reflect the kind of city residents want to live in.

A number of preferred options will also depend on the production of other documents aspart of the Local Development Framework, for example, the Development Policies andSites Allocation document, Area Action Plans or Supplementary Planning Documents.

Details of how the preferred options will be delivered/ implemented are set out in themain text of the document in Part 2 and Part 3.

Monitoring

A requirement of the new plan making system is that all policies have a robustframework to demonstrate how the objectives will be delivered, and how they will bemonitored to demonstrate their level of effectiveness.

Outlined in the following tables is the monitoring framework for the Core Strategy. Foreach of the preferred options it details:

l the relevant spatial objective;

l what indicators will be employed to monitor the effectiveness;

l any targets that are to be used to measure progress towards the objectives; and

l the data source.

The main delivery agent of this monitoring will be the Annual Monitoring Report (AMR).This is a document that the city council is required to produce on an annual basis whichoutlines both the progress of writing the Local Development Framework documents, andtheir effectiveness in delivering against their objectives. Hence, the indicators and targetswill be reported upon on an annual basis. If it is deemed that adjustments to indicators ortargets are required, or if further appropriate data sources become available, then theywill be introduced through the Annual Monitoring Report. 158


PART 4 – MONITORING

Indicators and Targets

The indicators for each preferred option has been chosen to ensure that they allowcomprehensive monitoring of the performance of the preferred option against itsobjectives, and also provide a contextual setting. The indicators are derived from anumber of sources and include some that are compulsory, nationally set indicators, somethat are from other monitoring regimes, and some that are locally set. Each indicator hasbeen assigned a unique identifier, and part of this prefix identifies its source.

COI/CS Core Output Indicator – a set of common requirements for local authorities; LOI/CS/ Local Indicator – a locally derived indicator deemed to be appropriate for

the needs of LDF monitoring; NIs National Indicator – taken from the National Indicator Set which measures

national priorities that have been agreed by government.The indicators have been selected based not only on their appropriateness, but on theavailability of data. It is deemed that generally, the listed indicators should have data thatis both available at the local level and that is updated on at suitable interval. Where theremay be issues in obtaining the data at present it is expected that it will become availablefor monitoring purposes in the future. Where appropriate National or Regional targetshave been identified they have been included within the framework. Where localcircumstances require specific targets these have been developed and are included withinthe framework.

159


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ble

Com

mun

itySt

rate

gy

LOI/C

S/30

Safe

guar

d A

ON

B N

atio

nal

Park

.fro

m in

appr

opria

tede

velo

pmen

t -

Num

ber

ofpl

anni

ng p

erm

issi

ons

with

inA

ON

B

To b

e de

fined

In-h

ouse

mon

itorin

g

172


Spat

ial

Ob

ject

ive(

s)In

dic

ato

r N

oIn

dic

ato

rTa

rget

(s)

Dat

a So

urc

eN

I

SN1

Sust

ain

able

Nei

gh

bo

urh

oo

ds

SO2,

SO

4,SO

5, S

O8,

SO16

, SO

17,

SO18

, SO

19,

SO20

LOI/C

S/05

Hea

lthin

ess

of d

efin

ed r

etai

lce

ntre

sA

nnua

l Ret

ail H

ealth

Che

cks

show

impr

ovem

ent

from

200

4 ba

selin

e.In

-hou

sem

onito

ring

CO

I/3b

Am

ount

of

new

dev

elop

men

tw

ithin

30

min

utes

of

serv

ices

incl

udin

g G

P su

rger

ies,

prim

ary,

sec

onda

ry h

ealth

serv

ices

, sc

hool

s, e

mpl

oym

ent

and

maj

or r

etai

l cen

tres

100%

In-h

ouse

mon

itorin

g

LOI/L

TP/B

VPI

102

Incr

ease

bus

pat

rona

geIn

crea

se b

us p

atro

nage

by

18%

by

2011

LTP

LOI/L

TP/1

Acc

ess

to f

ront

line

heal

thse

rvic

es10

0% o

f al

l hou

seho

lds

with

in 1

5-30

min

s of

fro

ntlin

e he

alth

ser

vice

sby

pub

lic t

rans

port

LTP

LOI/C

S/31

Exte

nded

sch

ools

pro

gram

me

In-h

ouse

mon

itorin

gLO

I/CS/

32U

rban

Des

ign

Fram

ewor

kA

city

-wid

e U

rban

Des

ign

Fram

ewor

kto

be

adop

ted

by 2

011

In-h

ouse

mon

itorin

g

LOI/C

S/BV

PI99

(y)

Num

ber

of c

hild

ren

kille

d or

serio

usly

inju

red

Redu

ctio

n in

chi

ld (a

ged

less

tha

n 16

)K

SIs

by 4

8% b

y 20

10LT

P

LOI/S

CS/

04/5

Prop

ortio

n of

peo

ple

satis

fied

with

the

ir ne

ighb

ourh

ood

as a

plac

e to

live

Incr

ease

the

pro

port

ion

of p

eopl

ebe

ing

very

or

fairl

y sa

tisfie

d w

ith t

heir

neig

hbou

rhoo

d as

a p

lace

to

live

Com

mun

itySt

rate

gy

173


SN2

Res

iden

tial

Ren

ewal

Are

as

SO2,

SO

4,SO

5, S

O8,

SO16

, SO

17,

SO18

, SO

19,

SO20

LOI/C

S/SA

13

Gap

bet

wee

n th

e hi

ghes

t an

dlo

wes

t sc

orin

g su

per

outp

utar

eas,

IMD

hea

lth,

depr

ivat

ion

and

disa

bilit

y do

mai

n

Redu

ce t

he g

ap y

ear

on y

ear

Sust

aina

bilit

yA

ppra

isal

LOI/C

S/SA

15Ed

ucat

iona

l att

ainm

ent

To r

educ

e th

e ga

p be

twee

n th

e11

9 m

ost

depr

ived

war

ds a

nd t

here

st o

f th

e re

gion

by

10%

as

mea

sure

d by

the

Inde

x of

Loc

alD

epriv

atio

n by

201

0

Sust

aina

bilit

yA

ppra

isal

NI/1

73Pe

ople

fal

ling

out

of w

ork

and

onto

inca

paci

ty b

enef

itTo

cor

resp

ond

with

Loc

al A

rea

Agg

reem

ent

Nat

iona

l Ind

icat

orse

t17

3

NI/1

51O

vera

ll em

ploy

men

t ra

te“

Nat

iona

l Ind

icat

orse

t15

NI/1

53W

orki

ng a

ge p

eopl

e cl

aim

ing

out

of w

ork

bene

fits

in t

hew

orst

per

form

ing

neig

hbou

rhoo

ds D

WP

DSO

“

Nat

iona

l Ind

icat

orse

t15

3

LOI/S

CS/

01/9

Une

mpl

oym

ent

rate

in E

B,H

ollin

gdea

n an

d Ta

rner

Fall

from

4%

to

3.45

by

2009

Sust

aina

ble

Com

mun

itySt

rate

gyLO

I/CS/

LAA

/18

Redu

ce t

he t

otal

num

ber

ofre

cord

ed c

rime

6% re

duct

ion

by 2

007/

8 ci

tyw

ide8

% re

duct

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by 2

007/

8 in

Tarn

er (N

RF A

rea)

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duct

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by20

07/8

in o

ther

NRF

are

as (e

xclu

ding

Tarn

er

Refr

eshe

d Lo

cal

Are

a A

gree

men

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utco

me

18)

LOI/C

S/33

Prio

ritis

ing

open

spa

ceim

prov

emen

ts in

EB4

u an

dN

eigh

bour

hood

Ren

ewal

Are

as

Use

indi

cato

rs a

nd t

arge

ts in

fut

ure

Park

s an

d O

pen

Spac

es S

trat

egy

2009

In-h

ouse

mon

itorin

g

Spat

ial

Ob

ject

ive(

s)In

dic

ato

r N

oIn

dic

ato

rTa

rget

(s)

Dat

a So

urc

eN

I

LOI/C

S/SA

11

How

man

y co

nstr

uctin

gfu

ture

s an

d m

ajor

pro

ject

part

ners

hips

hav

e be

ende

velo

ped

in B

&H

No

targ

etSu

stai

nabi

lity

App

rais

al

LOI/C

S/34

Redu

ce p

rem

atur

e m

orta

lity

rate

s an

d re

duce

ineq

ualit

ies

in p

rem

atur

e m

orta

lity

rate

sbe

twee

n w

ards

/ne

ighb

ourh

oods

with

apa

rtic

ular

foc

us o

n re

duci

ngth

e ris

k fa

ctor

s fo

r he

art

dise

ase,

str

oke

and

rela

ted

dise

ases

(C

VD

) (s

mok

ing,

die

tan

d ph

ysic

al a

ctiv

ity)

Ther

e ar

e na

tiona

l tar

gets

to

redu

ce m

orta

lity

rate

s by

201

0:-

from

hea

rt d

isea

se a

nd s

trok

e an

dre

late

d di

seas

es b

y at

leas

t 40

% in

peop

le u

nder

75,

with

a 4

0%re

duct

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in t

he in

equa

litie

s ga

pbe

twee

n ar

eas

with

the

wor

sthe

alth

and

dep

rivat

ion

and

the

popu

latio

n as

a w

hole

;-fr

omca

ncer

by

at le

ast

20%

in p

eopl

eun

der

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ith a

red

uctio

n in

the

ineq

ualit

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gap

of a

t le

ast

6%be

twee

n ar

eas

with

the

wor

sthe

alth

and

dep

rivat

ion

and

the

popu

latio

n as

a w

hole

;-fr

omsu

icid

e an

d un

dete

rmin

ed in

jury

by

at le

ast

20%

.-A

ctio

n to

red

uce

obes

ity is

a n

ew n

atio

nal t

arge

tw

ith L

ocal

Are

as t

aske

d to

hal

t th

eye

ar-o

n-ye

ar r

ise

in o

besi

ty a

mon

gch

ildre

n un

der

11 b

y 20

10.

All

scho

ols

are

prov

idin

g m

onito

ring

data

for

Yea

rs 1

and

6 b

ySe

ptem

ber

2007

. H

ealth

y di

et a

ndex

erci

se a

re m

ajor

fac

tors

in t

heac

hiev

emen

t of

hea

lthy

lifes

tyle

sfo

r in

divi

dual

s

In-h

ouse

via

LAA

174


175


Spat

ial

Ob

ject

ive(

s)In

dic

ato

r N

oIn

dic

ato

rTa

rget

(s)

Dat

a So

urc

eN

I

NI/1

50

Adu

lts in

con

tact

with

seco

ndar

y m

enta

l hea

lthse

rvic

es in

em

ploy

men

t.

LAA

tar

gets

Nat

iona

l Ind

icat

orse

t15

0

NI/1

16Pr

opor

tion

of c

hild

ren

inpo

vert

yLA

A t

arge

tsN

atio

nal I

ndic

ator

set

116

176


Spat

ial

Ob

ject

ive(

s)In

dic

ato

r N

oIn

dic

ato

rTa

rget

(s)

Dat

a So

urc

eN

I

CP1

Su

stai

nab

le B

uild

ing

s

SO2

Best

pos

sibl

e st

anda

rds

LOI/C

S/35

% o

f ne

w d

evel

opm

ents

and

conv

ersi

ons

appr

oved

via

the

plan

ning

sys

tem

mee

ting

min

imum

bui

ldin

g st

anda

rdre

quire

men

ts f

or B

&H

:(a

) re

side

ntia

l;(b

) m

ixed

-use

invo

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gre

side

ntia

l;(c

) no

n-re

side

ntia

l; an

d(d

) ot

her

90%

In-h

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mon

itorin

g vi

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stai

nabi

lity

Che

cklis

t

Site

orie

ntat

ion

and

build

ing

form

and

layo

ut /

cha

nges

in c

limat

e /

heat

isla

nd e

ffec

ts /

sur

face

wat

er r

un-o

ff

LOI/C

S/36

% o

f to

tal n

ew r

esid

entia

lde

velo

pmen

ts a

ppro

ved

via

the

plan

ning

sys

tem

com

mitt

ing

to in

corp

orat

ion

of s

usta

inab

le u

rban

dra

inag

esy

stem

s

In-h

ouse

mon

itorin

g vi

aSu

stai

nabi

lity

Che

cklis

t

Use

r Li

fest

yle

LOI/C

S/37

% o

f re

side

ntia

l pla

nnin

gap

prov

als

mee

ting

the

Life

time

Hom

e St

anda

rd r

equi

rem

ent

100%

In-h

ouse

mon

itorin

g vi

aSu

stai

nabi

lity

Che

cklis

t

177


Redu

ctio

ns in

fue

l use

and

gre

enho

use

gas

emis

sion

s

LOI/C

S/38

% o

f ne

w d

evel

opm

ents

and

conv

ersi

ons

appr

oved

via

the

plan

ning

sys

tem

com

mitt

ing

to:

(a) z

ero

carb

on d

evel

opm

ent

(b) N

o ad

ditio

nal n

et a

nnua

lC

O2

emis

sion

s fr

om e

nerg

y us

e

100%

In-h

ouse

mon

itorin

g vi

aSu

stai

nabi

lity

Che

cklis

t

Wat

er e

ffic

ienc

y st

anda

rds

LOI/C

S/39

Redu

ctio

n in

per

cap

itado

mes

tic c

onsu

mpt

ion

ofw

ater

acr

oss

the

city

1%A

udit

Com

mis

sion

Reus

e or

rec

yclin

g of

mat

eria

ls a

nd u

se o

f ex

istin

g bu

ildin

gs a

nd in

fras

truc

ture

LOI/C

S/40

% o

f ne

w d

evel

opm

ents

and

conv

ersi

ons

appr

oved

via

the

plan

ning

sys

tem

com

mitt

ing

tost

rate

gy t

o us

e at

leas

t 10

% o

flo

cally

-sou

rced

, re

-use

d or

recy

cled

mat

eria

ls in

the

deve

lopm

ent

100%

In-h

ouse

mon

itorin

g vi

aSu

stai

nabi

lity

Che

cklis

t

178


Spat

ial

Ob

ject

ive(

s)In

dic

ato

r N

oIn

dic

ato

rTa

rget

(s)

Dat

a So

urc

eN

I

Dev

elop

er C

ontr

ibut

ions

LOI/C

S/41

No

of d

evel

opm

ents

req

uirin

gco

ntrib

utio

ns v

ia S

ectio

n 10

6to

war

ds S

usta

inab

le B

uild

ings

Stra

tegy

Targ

et n

ot a

pplic

able

- d

ata

to b

em

onito

red

annu

ally

via

Sec

tion

106

sche

dule

.

In-h

ouse

mon

itorin

g10

0% e

nfor

cem

ent

for

com

plia

nce

onal

l im

plem

ente

dde

velo

pmen

tN

I/186

Per

capi

ta C

O2

emis

sion

s in

the

LA a

rea

Nat

iona

lIn

dica

tor

set

186

CP2

- U

rban

Des

ign

SO5

Plea

se s

ee p

olic

y C

P3 a

nd C

P18

for

othe

r re

late

d in

dica

tors

LOI/C

S/42

All

new

dev

elop

men

t to

dem

onst

rate

a h

igh

stan

dard

of d

esig

n an

d m

ake

a po

sitiv

eco

ntrib

utio

n to

the

bui

lten

viro

nmen

t

A c

ity-w

ide

Urb

an D

esig

nFr

amew

ork

SPD

to

be a

dopt

ed

by 2

011

In-h

ouse

mon

itorin

g

LOI/C

S/43

% o

f re

side

ntia

l pla

nnin

gap

prov

als

mee

ting

the

Life

time

Hom

e St

anda

rd r

equi

rem

ent

100%

In-h

ouse

mon

itorin

g vi

aSu

stai

nabi

lity

Che

cklis

t

179


CP3

- P

ub

lic S

tree

ts a

nd

Sp

aces

LOI/C

S/44

Secu

re p

ublic

rea

lmco

ntrib

utio

nsSe

cure

con

trib

utio

ns f

rom

deve

lope

rs o

f m

ajor

city

cen

tre

sche

mes

tow

ards

ach

ievi

ng a

publ

ic r

ealm

net

wor

k as

set

out

inth

e 'L

egib

ility

Stu

dy -

Pub

lic S

pace

- Pu

blic

Life

' (2

006)

In-h

ouse

mon

itorin

g

LOI/L

TP/3

Num

ber

of p

edes

tria

nm

ovem

ents

10%

incr

ease

in w

alki

ng t

rips

by20

10/1

1Lo

cal T

rans

port

Plan

LOI/C

S/45

Leve

l of

sect

ion

106

agre

emen

ts t

hat

have

sec

ured

prov

isio

n of

Pub

lic A

rt

n/a

100%

enf

orce

men

t fo

r co

mpl

ianc

eon

all

impl

emen

ted

deve

lopm

ent

In-h

ouse

mon

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g

CP4

- H

ealt

hy

Cit

yLO

I/CS/

46M

aint

ain

the

prov

isio

n of

allo

tmen

ts in

Brig

hton

& H

ove

100%

of

allo

tmen

ts t

o be

ret

aine

dIn

-hou

sem

onito

ring

LOI/C

S/47

New

GP

surg

erie

s se

cure

dth

roug

h Se

ctio

n 10

6Ta

rget

not

app

licab

le -

dat

a to

be

mon

itore

d an

nual

ly v

ia S

ectio

n 10

6sc

hedu

le.

100%

enf

orce

men

t fo

r co

mpl

ianc

eon

all

impl

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ted

deve

lopm

ent.

In-h

ouse

mon

itorin

g

NI/5

5O

besi

ty a

mon

g pr

imar

y sc

hool

age

child

ren

in r

ecep

tion

year

LAA

tar

gets

Nat

iona

l ind

icat

orse

tN

18,

55,

56,

57 150

NI/5

6O

besi

ty a

mon

g pr

imar

y sc

hool

age

child

ren

in Y

ear

6LA

A t

arge

tsN

atio

nal i

ndic

ator

set

NI/5

7C

hild

ren

and

youn

g pe

ople

'spa

rtic

ipat

ion

in h

igh-

qual

ity P

Ean

d sp

ort

LAA

tar

gets

Nat

iona

l ind

icat

orse

t

180


Spat

ial

Ob

ject

ive(

s)In

dic

ato

r N

oIn

dic

ato

rTa

rget

(s)

Dat

a So

urc

eN

I

NI/8

Adu

lt pa

rtic

ipat

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in s

port

LAA

tar

gets

Nat

iona

l ind

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NI/1

19se

lf re

port

ed m

easu

re o

fpe

ople

’s ov

eral

l hea

lth a

ndw

ell b

eing

LAA

tar

gets

Nat

iona

l ind

icat

orse

t11

9

CP5

- B

iod

iver

sity

SO7

LOI/C

S/58

Num

ber

of d

evel

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ents

inco

rpor

atin

g bi

odiv

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tym

easu

res

and

enha

ncem

ents

thro

ugh

Sect

ion

106

Targ

et n

ot a

pplic

able

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ata

to b

em

onito

red

annu

ally

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Sec

tion

106

sche

dule

100%

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orce

men

t fo

r co

mpl

ianc

eon

all

impl

emen

ted

deve

lopm

ent

In-h

ouse

mon

itorin

g

CO

I/8(i)

Cha

nge

in im

port

ant

orse

nsiti

ve h

abita

ts a

nd s

peci

esid

entif

ied

in t

he lo

cal

Biod

iver

sity

Act

ion

Plan

(LB

AP)

.

Year

-on-

year

incr

ease

in: a

rea

ofLB

AP

habi

tats

and

nat

ure

cons

erva

tion

feat

ures

for

LBA

Psp

ecie

s

Suss

ex B

iodi

vers

ityRe

cord

Cen

tre

LOI/C

S/59

Prop

ortio

n of

hom

es w

hich

mee

t th

e N

atur

al E

ngla

ndst

anda

rd f

or a

cces

s to

sem

i-na

tura

l gre

en s

pace

All

resid

ents

of

the

city

hav

e ac

cess

to a

n ar

ea o

f na

tura

l gre

en s

pace

of

at le

ast

0.25

ha w

ithin

300

m o

f th

eir

hom

e by

the

end

of

the

plan

per

iod

Cou

ntry

side

Tea

m /

In-h

ouse

mon

itorin

g

181


LOI/C

S/60

Prop

ortio

n of

app

licat

ions

supp

orte

d by

a n

atur

e co

nser

vatio

n su

rvey

whi

chm

eets

pol

icy

requ

irem

ents

(se

eN

atur

e C

onse

rvat

ion

and

Dev

elop

men

t SP

D)

All

elig

ible

app

licat

ions

by

the

end

ofth

e pl

an p

erio

dC

ount

rysi

de T

eam

/In

-hou

sem

onito

ring

CO

I/CS/

8(ii)

Cha

nge

in a

reas

des

igna

ted

for

thei

r in

trin

sic

envi

ronm

enta

l val

ue in

clud

ing

site

s of

inte

rnat

iona

l, na

tiona

l,re

gion

al o

r lo

cal s

igni

fican

ce

Net

incr

ease

in a

rea

of la

ndde

signa

ted

for

its n

atur

eco

nser

vatio

n va

lue

over

the

pla

npe

riod.

Suss

ex B

iodi

vers

ityRe

cord

Cen

tre

NI/1

97Im

prov

ed lo

cal b

iodi

vers

ity -

activ

e m

anag

emen

t of

loca

l site

sN

atio

nal i

ndic

ator

set

197

LO/C

S/29

Gre

en N

etw

ork

Impl

emen

tatio

n of

a G

reen

Net

wor

k by

201

6In

-hou

sem

onito

ring

CP6

- O

pen

Sp

ace

SO8

(SO

9)(S

O11

)

LOI/C

S/61

Leve

l of

deve

lope

r co

ntrib

utio

nsth

roug

h Se

ctio

n 10

6 m

ade

toof

f-sit

e op

en s

pace

/ par

ks

Targ

et n

ot a

pplic

able

- d

ata

to b

em

onito

red

annu

ally

via

Sec

tion

106

sche

dule

100%

enf

orce

men

t fo

r co

mpl

ianc

eon

all

impl

emen

ted

deve

lopm

ent

In-h

ouse

mon

itorin

g

CO

I/4c

Am

ount

of

elig

ible

ope

nsp

aces

man

aged

to

gree

n fla

gaw

ard

stan

dard

-co

mpa

ring

(inpe

rcen

tage

ter

ms)

the

am

ount

of o

pen

spac

e m

anag

ed t

ogr

een

flag

stan

dard

s ag

ains

tto

tal o

pen

spac

e. F

igur

essh

ould

be

give

n in

hec

tare

s

Reta

in s

even

gre

en f

lag

awar

dsan

d en

hanc

e th

e m

aint

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ce o

fal

l oth

er o

pen

spac

e si

tes

so t

hat

mos

t re

side

nts

thin

k th

at f

or t

heir

loca

l are

a th

e pa

rks

and

open

spac

es h

ave

got

bett

er

Cou

ntry

side

Tea

m /

In-h

ouse

mon

itorin

g

182


Spat

ial

Ob

ject

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s)In

dic

ato

r N

oIn

dic

ato

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rget

(s)

Dat

a So

urc

eN

I

LOI/C

S/62

Leve

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r co

ntrib

utio

ns m

ade

to o

ff s

iteop

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pace

/par

ks

Subj

ect

to t

he m

axim

isatio

n of

on-

site

open

spa

ce p

rovi

sion

the

subs

eque

nt le

vel o

f co

ntrib

utio

nsh

ould

resu

lt in

100

% 'p

rovi

sion'

of

gene

rate

d op

en s

pace

dem

and.

In-h

ouse

mon

itorin

g

LOI/C

S/63

%of

peo

ple

satis

fied

with

the

park

s an

d op

en s

pace

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ovid

ed b

y th

e co

unci

l

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yet

def

ined

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006/

7 re

sult

= 8

0)

90%

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Val

uePe

rfor

man

ceIn

dica

tor

119e

CP7

- S

po

rts

and

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reat

ion

SO8

(SO

11)

SO8

(SO

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LOI/C

S/64

Loss

of

play

ing

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sN

o lo

ss o

f pl

ayin

g fie

lds

In-h

ouse

mon

itorin

g

LOI/C

S/65

No

of m

ajor

dev

elop

men

tspr

ovid

ing

recr

eatio

nal s

pace

thro

ugh

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ion

106

n/a

100%

enf

orce

men

t fo

r co

mpl

ianc

eon

all

impl

emen

ted

deve

lopm

ent

In-h

ouse

mon

itorin

g

LOI/C

S/66

Leve

l of

deve

lope

r co

ntrib

utio

ns m

ade

to o

ff s

iteop

en s

pace

/par

ks.

N/A

In-h

ouse

mon

itorin

g

183


NI/8

Civ

ic/

Adu

lt Pa

rtic

ipat

ion

Rate

sin

Spo

rts

Not

yet

def

ined

LA

AN

atio

nal I

ndic

ator

Set

8

LOI/C

S/67

%of

peo

ple

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fied

with

the

spor

ts a

nd le

isur

e fa

cilit

ies

prov

ided

by

the

coun

cil

Not

yet

def

ined

(20

06/7

res

ult

=44

)Be

st V

alue

Perf

orm

ance

Indi

cato

r 11

9a

CP8

- S

ust

ain

able

Tra

nsp

ort

SO1

2SO

19SO

21

LOI/S

CS/

07/0

5Bu

s pa

tron

age

Num

ber

of lo

cal b

us p

asse

nger

jour

neys

ris

es b

y 3%

ann

ually

Sust

aina

ble

Com

mun

itySt

rate

gy

177

LOI/S

CS/

07/0

4N

umbe

r of

peo

ple

kille

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serio

usly

inju

red

in r

oad

acci

dent

s

Num

ber

of p

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e ki

lled

orse

rious

ly in

jure

d in

roa

d ac

cide

nts

cont

inue

s to

fal

l eac

h ye

ar.

Sust

aina

ble

Com

mun

itySt

rate

gy

47

LOI/S

CS/

07/0

2Le

vels

of

car

traf

fic e

nter

ing

and

leav

ing

the

city

cen

tre

Leve

l of

car

traf

fic e

nter

ing

and

leav

ing

the

city

cen

tre

redu

ces

each

yea

r

Sust

aina

ble

Com

mun

itySt

rate

gyLO

I/SC

S/07

/01

Num

ber

of c

ycle

trip

s m

ade

inth

e ci

tyN

umbe

r of

cyc

le t

rips

mad

e in

Brig

hton

& H

ove

cont

inue

s to

incr

ease

eac

h ye

ar

Sust

aina

ble

Com

mun

itySt

rate

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LOI/S

CS/

07/0

3N

umbe

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site

s w

here

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Air

Qua

lity

Obj

ectiv

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r an

nual

mea

n co

ncen

trat

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itrog

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ioxi

de is

not

met

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020

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lity

Obj

ectiv

efo

r an

nual

mea

n co

ncen

trat

ion

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itrog

en D

ioxi

de is

met

thr

ough

out

the

city

Sust

aina

ble

Com

mun

itySt

rate

gy

194

NI/1

67C

onge

stio

n av

erag

e jo

urne

ytim

e pe

r m

ile d

urin

g th

em

orni

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eak

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targ

etN

atio

nal I

ndic

ator

set

167

184


Spat

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Ob

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dic

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NI/1

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d fa

cilit

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by p

ublic

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Nat

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5

LOI/C

S/68

Prep

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n pa

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lann

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TP/1

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pid

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pid

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016

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an

LOI/C

S/69

Dev

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ontr

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ards

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tra

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avel

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annu

ally

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ns t

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usta

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letr

ansp

ort

to e

nsur

e co

ntrib

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ade

and

trav

el p

lans

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mitt

ed

In-h

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mon

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LOI/L

TP/3

Num

ber

of p

edes

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nm

ovem

ents

10%

incr

ease

in w

alki

ng t

rips

by20

10/1

1Lo

cal T

rans

port

Plan

LOI/C

S/70

No

of S

choo

l Tra

vel P

lans

secu

red

thro

ugh

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ion

106

n/a

100%

enf

orce

men

t fo

r co

mpl

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eon

all

impl

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ted

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lopm

ent.

In-h

ouse

mon

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g

198

LOI/C

S/71

aN

o. o

f ad

ditio

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ar c

lubs

secu

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Sect

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106

n/a

In-h

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mon

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I/CS/

71b

No

deve

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of

requ

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ansp

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Ass

essm

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thro

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106

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In-h

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185

CP9

- D

evel

op

er C

on

trib

uti

on

s

Plea

se s

ee in

divi

dual

CP

polic

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tors

for

oth

er D

evel

oper

Con

trib

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n ta

rget

s an

d in

dica

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if n

ot li

sted

her

e

SO2-

4

LOI/C

S/72

Larg

e de

velo

pmen

t re

quiri

ng'F

utur

es'

cons

truc

tion

and

maj

or p

roje

ct

empl

oym

ent

part

ners

hips

mea

sure

s th

roug

h Se

ctio

n 10

6

n/a

100%

enf

orce

men

t fo

r co

mpl

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eon

all

impl

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ted

deve

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ent

In-h

ouse

mon

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g

SO7-

9SO

13-1

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17

LOI/C

S/73

New

sch

ools

or

educ

atio

nfa

cilit

ies

cont

ribut

ion

secu

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thro

ugh

Sect

ion

106

n/a

100%

enf

orce

men

t fo

r co

mpl

ianc

eon

all

impl

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ted

deve

lopm

ent

In-h

ouse

mon

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g

LOI/C

S/74

New

, re

plac

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t or

enha

nced

com

mun

itybu

ildin

gs s

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ed t

hrou

ghSe

ctio

n 10

6

n/a

100%

enf

orce

men

t fo

r co

mpl

ianc

eon

all

impl

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ted

deve

lopm

ent

In-h

ouse

mon

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LOI/C

S/75

Con

trib

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ns t

owar

ds C

CTV

cam

eras

and

oth

er c

omm

unity

safe

ty m

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res

secu

red

thro

ugh

Sect

ion

106

n/a

100%

enf

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men

t fo

r co

mpl

ianc

eon

all

impl

emen

ted

deve

lopm

ent

In-h

ouse

mon

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g

CP1

0 -

Man

agin

g F

loo

d R

isk

SO2

LOI/C

S/76

% o

f ne

w r

esid

entia

lco

mpl

etio

ns o

utsi

de o

f Fl

ood

Zone

1 o

f th

e B7

H S

FRA

n/a

In-h

ouse

mon

itorin

g

CO

I/07

Num

ber

of p

lann

ing

perm

issi

ons

gran

ted

cont

rary

to t

he a

dvis

e of

the

EA

on

eith

er f

lood

def

ence

of

wat

erqu

ality

gro

unds

none

Envi

ronm

ent

Age

ncy

NI/1

89Fl

ood

and

coas

tal e

rosi

on r

isk

man

agem

ent

LAA

Nat

iona

l Ind

icat

orse

t18

9

186


Spat

ial

Ob

ject

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s)In

dic

ato

r N

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dic

ato

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rget

(s)

Dat

a So

urc

eN

I

CP1

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Ho

usi

ng

Del

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SO4

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I/2a

Net

add

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Prov

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in t

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202

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san

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of

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new

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num

200

6 -

2026

In-h

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4

NI/1

59Su

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of

read

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dev

elop

hous

ing

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year

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of d

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Nat

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;(b

) %

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) %

of

affo

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in s

chem

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ith 1

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its

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106

n/a

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all

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ted

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In-h

ouse

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155

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Num

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units

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ver

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In-h

ouse

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5

LOI/C

S/78

Tenu

re s

plit

of a

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f af

ford

able

hou

sing

achi

eved

acr

oss

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City

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% in

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In-h

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187


LOI/C

S/79

Aff

orda

ble

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ing

mix

100%

of

affo

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% 3

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its

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mon

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)

40%

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hous

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in m

ajor

deve

lopm

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ffor

dabl

eIn

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sem

onito

ring

CP1

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Ho

usi

ng

Den

siti

es

SO1

LOI/C

S/81

Net

den

sity

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ls a

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s th

eci

tyA

chie

ve a

net

den

sity

of

at le

ast

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ph in

75%

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ewde

velo

pmen

ts in

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& H

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the

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o 20

26

In-h

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mon

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g

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S/82

Net

den

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ty w

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With

in t

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Are

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DA

2-D

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ach

ieve

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at le

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100

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5%of

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men

ts in

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perio

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In-h

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g

CP1

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an

d T

rave

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Prov

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2006

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1 an

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Hea

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and

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and

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In-h

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Spat

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dic

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Site

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Plea

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or D

A p

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ring

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This section sets out the supporting evidence for the revised Preferred Options. Thepurpose of the preferred options stage is for the council to seek the views of the publicand stakeholders on the proposals it is recommending for the Core Strategy before thefinal version is submitted to the Secretary of State. Where, through consultationresponses and background evidence, other options could be considered to address aparticular issue, the document sets out the option favoured by the Council as the'Preferred Option'. This Annexe sets out the alternative options that were consideredtogether with a brief explanation of why they were discounted along with a summary ofconsultation responses and the recommendations of the Sustainability Appraisal. Furthersupporting information is available in the Statement of Consultation, the full draftSustainability Appraisal and the Supporting Evidence Document.

Part Two - Spatial Strategy

This section sets out how the spatial strategy has been refined since 2005.

The 'Issues and Options' (October 2005)

The 'Issues and Options' document published in October 2005 set out five possible broadapproaches to accommodating the predicted development of the city over the next 20years. It was explained that the preferred option would be likely to consist of acombination of two or more of these broad approaches (or any credible alternativeapproach put forward during community involvement). In summary, the five approacheswere:

A - accessibility-led approach - optimising development within the built up area byidentifying areas of growth opportunity for higher density development based primarilyupon their accessibility to sustainable travel.

B - regeneration-led approach - this would involve optimising developmentopportunities within the built up area by identifying areas of growth opportunity basedupon regeneration needs.

C - urban character /urban capacity-led approach - based on the findings of theUrban Characterisation Study, Urban Capacity monitoring and the Tall Buildings Study toinform opportunities for additional housing to be accommodated in the urban areas ofthe city by identification of potential sites and broad areas.

D - limited development and expansion on the urban fringe - in addition tooptimising development opportunities within the existing built-up area, allow also limitedencroachment into the countryside (on areas of poor quality 'urban fringe, and openareas not included within the proposed South Downs National Park) if this can bejustified in the long term (beyond the next 10-15 years).

E - identification of large strategic development sites - in addition to optimisingdevelopment opportunities within the built up area, this long term approach wouldinclude planning for significant extension such as at the Marina or at Shoreham Harbourto provide at least 1,000 new homes in each case.

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Annex 1 - Supporting evidence for the revised Preferred Options

The Findings of 'Issues and Options' Community Involvement

There was general support for an accessibility-led approach to development, but not iftaken in isolation and that such an approach should not be at the expense of improvingtransport accessibility to other areas of the city. Overall there was a mixed response to theregeneration-led approach. In consultation with some of those directly involved with theneighbourhoods, concerns were raised about the need to ensure that significantimprovements to the physical and social infrastructure are in place before directing anysubstantial new housing development towards them. The urban character/ urbancapacity-led approach was the most difficult approach for people to judge properly as theresearch had not been fully completed at the time of consultation. Nevertheless, thisapproach attracted a significant level of support in principle. It was seen as a pro-activeapproach that could help to identify where investment should best be steered and asuitable approach for incremental change, rather than large-scale redevelopment, wouldhelp to safeguard quality and local distinctiveness and would be best combined withother approaches.

The approach of allowing limited development and expansion on the urban fringereceived a mixed response. It was not a popular approach amongst respondents to theStakeholder Questionnaire. However a very clear majority of the Citizens' Panel, showedsupport for it under certain circumstances. The workshop sessions showed a strongpresumption against any development on the urban fringe. Particular mention was madeof the role of urban fringe greenfield sites as aquifers. The future National Park was seenas sacrosanct. The local business community indicated support for some high-qualityemployment uses on the urban fringe.

There was no overall consensus view on the approach of planning for the identificationof large strategic development sites that could each accommodate 1,000 new homes.The potential of Shoreham Harbour for significant residential and mixed use developmentwas widely recognised and accepted and indeed a significant majority of those consultedwould support this in principle. However, the lack of a new transport link, and concernsover whether any such link could be truly sustainable, were seen by many as a significantbarrier to the inclusion of this approach at the current time. There was no consensus onthe potential of the Marina to be extended to absorb major housing development. Therewere no alternative sites suggested under this approach that received any significant levelof support. Rather there was significant support for the view that no such large sitesexist.

No alternative approach to accommodating future development was suggested thatreceived any widespread support. The most common alternative approach put forwardwas the 'environmentally-led' or 'ecological' approach; one that puts environmentalsustainability to the forefront of decision-making by aiming to ensure that alldevelopments contribute to improving environmental efficiency as a principle objective,combining individual 'quality of life' issues with the better management of naturalresources.

Preferred Option (October 2006)

The council set out as its preferred option for accommodating future development whichwas to preserve the countryside by optimising development on brownfield sitesthroughout the existing built-up area of the city, but with key broad areas identified forregeneration or renewal to bring about sustainable communities. In particular it was tobe a combination of the accessibility-led approach and the urban character / urban191


capacity-led approach. By applying this approach, the following 10 broad areas wereidentified as being suitable to direct significant mixed use higher density development:

l Brighton Marinal Brighton Station / New England areal Central seafront area (Kings Road)l Eastern Road / Edward Street corridorl Hove Station area l Lewes Road corridorl London Road / Preston Road corridorl Old Shoreham Road corridorl Portland Roadl Western seafront (Kingsway and Wellington Road)

To complement the main higher-density development areas, the preferred option wouldalso include some residential or mixed-use development around key suburban centres,where such development could help to strengthen the provision and viability of localservices for those communities and to diversify housing type and tenure within them.Priority would be given to East Brighton New Deal area in particular, as well as to thoseother suburban centres within the identified priority Neighbourhood Renewal Areas.

The discarded options

The regeneration-led approach was not included within the preferred option itself as itwas considered that this approach would not currently meet the social objectives ofachieving sustainable communities. The wider regeneration-led approach will be reviewedin the longer term once the provision of the priority infrastructure requirements, as setout in Neighbourhood Action Plans recently updated for the period 2007-2010, havebeen addressed.

The approach of planning for the identification of large strategic development sites wasnot included in the preferred option as there are serious doubts over the deliverability ofsuch an approach at that time. The only significant identified site where there is supportin principle for such an approach is Shoreham Harbour. However, the lack of thenecessary new transport link in place to enable access, and the likely financial costs andpossible environmental costs of providing it, were considered to be major barriers to theinclusion of this approach in the spatial strategy and Shoreham Harbour was dealt with ina separate Preferred Option.

An alternative approach put forward by some participants during community involvementwas one that puts environmental sustainability ahead of other concerns. Whilst it isaccepted that one of the Government's principles is to respect environmental limits, anyapproach that explicitly prioritises environmental considerations over economic or socialones would not meet national planning policy as set out in PPS1. It was considered thatthe preferred spatial strategy was the best option to integrate all the elements ofsustainable development.

An alternative option for further consideration

Community involvement on the approach of allowing for some limited development andexpansion on the urban fringe did not reveal a clear consensus view on whether, in thelonger term (beyond the next 10 years) this approach should form part of the overallpreferred option. Engagement on this issue was at a very broad level only and was made 192


more difficult by uncertainty over the proposed South Downs National Park and itsboundaries. The Biodiversity Strategy and the Open Space, Sport and Recreation Studywould be necessary to inform further consideration of this option. Natural Englandindicated that it did not oppose all development on the urban fringe in principle,provided that it does not involve any reduction of key habitats or result in the loss of, orreduction in, biodiversity in the area. However, housing development on greenfield siteswould not be in accordance with the expectation of the sub-regional strategy of the draftSouth East Plan.

It was therefore considered that no firm conclusions could be drawn as to whether theapproach should form part of the preferred long-term strategy. In particular, wherecommunity involvement has so far indicated some support for this approach "undercertain circumstances", views are sought on what such circumstances may involve. It wastherefore considered an alternative option to consider whether, in the period 2016-2026,some limited development on the urban fringe should form part of the overall spatialstrategy and, if so, under what circumstances.

The Draft Sustainability Appraisal (October 2006)

The Sustainability Appraisal considered approaches A to D set out at the 'Issues andOptions' stage, together with a 'business as usual' approach based upon continuing withthe policy approach set out in the adopted Local Plan. Approach E, identification of largestrategic development sites, was not appraised as the research and evidence andcommunity involvement showed this to be an unrealistic option at the present time. Theenvironment-led approach suggested by some participants in community involvementwas not appraised either, as it was considered not to be in accordance with nationalpolicy and therefore unrealistic. The main findings of the appraisal were as follows:

None of the proposed approaches should be applied in isolation.l The urban characterisation / urban capacity approach should form part of the

preferred option and should also take into account the findings of the Open Space,Sport and Recreation Study.

l The accessibility-led approach has the greatest potential for reducing car use butcould have wider negative impacts if applied in isolation.

l The identified deprived areas should be included for in any preferred option, but notfor significant higher-density housing development until social and employment issueshave been addressed.

l It may be necessary to allow limited development on the urban fringe to relieve thepressure on the available resources and services (carrying capacity) of the city;however this should be limited and related to high quality sustainable transport andmitigation measures.

l Protection of natural resources and environmental enhancement should be an integralpart of the preferred approach.

l The 'business as usual' approach is not a sustainable one in the longer term.

The Preferred Option took account of the appraisal's conclusions by combining the urbancapacity / urban character-led approach with the accessibility-led approach andincorporating the identified deprived areas in the form of some development aroundsuburban centres, in order to strengthen those centres and make them more viable.

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The findings of the Preferred Options Consultation (October - December 2006)

Of the 57 representations on SS1, in general there was broad support for the principle ofthe approach that was undertaken that led to the identification of the broad areas forfuture development

However consultation responses and views expressed at events questioned whether therewas sufficient information on the likely development expected to come forward in thoseareas to allow a full view to be taken of their acceptability.

In particular at the various workshop events the suitability of the Old Shoreham Road,Portland Road and the Hove Station areas to accommodate significant developmentopportunities was questioned.

The Government Office for the South East raised concerns that the Spatial Strategy didnot provide sufficient detail on the amount and type of development that the 10 areaswere expected to accommodate.

Concern was also expressed at events and through written responses, at the level ofdevelopment anticipated to take place along the seafront.

The Highways Agency and others queried whether there had been sufficient assessmentof the transport implications of the significant development within these broad areas.

The Environment Agency felt that without a strategic flood risk assessment (SFRA) thespatial strategy could risk being found unsound. This would be on the grounds that noSFRA had informed the options and the Sustainability Appraisal; and that the sequentialtest had not been applied to the selection of broad locations.

With regards to the alternative option of allowing development to take place within theurban fringe, the consensus of opinion on the preferred option UF1was that it should besupported. However comments made in relation to the discarded alternative option ofallowing development on the urban fringe as part of the spatial strategy raised a mix ofresponses. Some respondents were very clear that development should not take place inthe urban fringe/ AONB. Others felt that there may be benefits from limiteddevelopments under certain circumstances. Some respondents felt that development ofsome urban fringe must be included as part of the overall spatial strategy for thedevelopment of the city. To exclude this option would unreasonably limit opportunitiesfor a variety of development needs for the wider city and beyond.

Other suggestions were to ensure that the preferred approach made the best use of allrailway stations and potential development opportunities around minor stations; and thatmore development should be directed to selected suburban modes around the city asthese would help to create the demand for public transport between suburban nodes. Inrelation to the discarded approach of directing growth to regeneration/ renewal areas,comments were raised around the need to prioritise all the neighbourhood renewal areasand that residential and mixed use development in the East Brighton area could helpdiversify type and tenure of housing. High density development should also beencouraged outside the broad areas and along the city's main transport routes. Howeveroverall, no alternative approach to the spatial strategy was put forward.

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DA1 - BRIGHTON CENTRE AND CHURCHILL SQUARE

Summary of Preferred Options Consultation

In response to SS1 - Spatial Strategy which included Central Seafront as an areaappropriate for development:

l The area is a focal point along the seafront so development must be of the highestquality.

l Central seafront being mainly a leisure/visitor destination is inappropriate for higherdensity mixed use development.

l The emphasis on 'key seafront sites' puts the future of the whole area at the mercyof large-scale development projects, with all their attendant risks. To enhance theseafront as a sustainable year round tourist attraction a distinction should be madebetween the busy central seafront and the more tranquil wings of the East Cliffstretch and the Hove Lawns/esplanade.

l Reference in the Local Plan to tranquility of the eastern seafront must be preservedand strengthened.

l Comments on CT3 Brighton Centre (7 representations) - were generally supportiveof the proposals but concerns related to the exact proposals of the Brighton Centre(whether the Conference Centre would be replaced within the SPD area) and itsrelationship to proposals for the Black Rock site.

l Concerns were also raised in relation to SR1 Seafront Regeneration around highbuildings and allowing greater density along the seafront; that there should be apresumption against development south of the A259 and that congestion along theA259 should be considered.

At the Economic Partnership - sites and premises event, the need for a state of theart development to provide for international events, conferences etc was raised by oneparticipant and another felt that the Brighton Centre SPD should have been specificabout the uses and limit these to convention centre and retail. At the LSP developmentmorning however one participant questioned whether it was too late to regain the city'sconference centre position through the redevelopment of the Centre. At the Retail andTourism Advisory Panel it was felt that the Brighton Centre redevelopment would helpdraw international events/conferences to the city but that the city needed to do more toattract visitors to the city during the week; other facilities such as ice rinks were needed.The Brighton Centre redevelopment should include potential for retail in conjunction withChurchill Square and concern was raised with the poor links between the centralshopping area and the seafront.

Alternative Options Considered

An alternative option would be to refurbish the Brighton Centre, to focus on improvingthe existing facility to extend its life. This option assumes limited change in the CentralSeafront/ Churchill Square area as there would be less opportunity for new retaildevelopment opportunities to come forward associated with Churchill Square/ WesternRoad. Opportunities for townscape and public realm improvements would need to beaddressed through a general policy requirement in the Local Development Framework.

Also considered was a 'Business as Usual' option relating to a more narrowly definedgeographic area as identified in the adopted Brighton Centre SPD. This SPD was adopted195


in January 2005 and sets out the guidance for a redeveloped conference centre tosupplement policies SR1, SR14 and QD1 of the Brighton & Hove Local Plan. The SPD setsout an Area Planning and Urban Design Framework for a replacement centre andextending this development to benefit the area around the existing Brighton Centre butthe SPD does not examine in detail the wider place-making opportunities on West Street,Western Road and the nearby neighbourhood renewal area.

The Sustainability Appraisal

The Sustainability Appraisal considered all the options and concluded that the preferredoption was deemed to be the most positive approach but suggested that certainmitigation measures would be required. These included area specific points as well asthose of more city wide concern. Area specific points of particular relevance were thepotential for biodiversity gains in the area, the requirements of high environmentalstandards, the need for integrated improvements in public transport through the area,sensitive townscape improvements, environmental improvements along Western Roadand West Street, promoting a more diverse evening economy and the need to considereducation and training opportunities as well as addressing wider community issues. Theseconcerns have been addressed in the wording of the preferred option and city wideconcerns would be secured through the supporting Core Policies.

DA2 - BRIGHTON MARINA AND BLACK ROCK


In response to SS1 - Spatial Strategy which included Brighton Marina as an areaappropriate for development:

l Support is given to the Council's Preferred Option for accommodating significantmixed use, higher density development at the Marina. The policy should specificallyrecognise that this is the most suitable location for significant new retail developmentalong with other uses.

l Appropriate to identify a number of locations within which development is to beconcentrated including Brighton Marina. Support potential of the Marina toaccommodate additional housing and the opportunity, which exists for newdevelopment to deliver the regeneration of this key site in the city.

l Concern about concentration of development being served from one access. Concernabout visual impact on the coastal landscape, especially on views of the cliffs fromfurther east.

l Development should not be visible above the cliff.

l Consider that given the close proximity of the gasholder site to Brighton Marina thissite falls within that broad area.

l The Kemp Town Society deplored the gross overdevelopment of the Marina site andits adverse effect on the neighbouring Grade 1 Listed Kemp Town Estate.

l The PCT wanted to work with the council to identify suitable sites within the newdevelopment area.

l Specific representations regarding the regeneration opportunities for the Gas Workssite and its links to the Brighton Marina area.

l Of those who responded to SR1 Seafront Regeneration, Brighton Marina raised the196


most comments; its shopping status should be clarified, the boundary should bewidened to include the Gas Holder site, there should be better reflection of itsemerging status as a priority regeneration area, the need to maintain and enhancebiodiversity/ nature conservation features and ensure development does not erodeviews of the cliffs.

At the Area-based event, the East area workshop considered that that access to theMarina is a serious concern. There is a poor mix of uses within the Marina, quitedifferent from what was originally intended with a concentration of housingdevelopment. An associated concern was that a lot of the dwellings being built in theMarina and wider city are not meeting the need of residents of Brighton & Hove butproviding second homes. At the Older People's Feedback Session, there was concernraised with the lack of community facilities at the Marina. At the Economic Partnershipsites and premises events, it was suggested at one workshop that the Marina isincreasingly becoming a regeneration area and there is the potential to integrate theMarina more directly with the city. The planned development of Madeira Drive wouldhelp this and this needs to be strategic not ad-hoc. The area's potential is not beingrealised and there should be more tourism attraction for families. Safety at the marinawas raised at the Schools Feedback sessions.


An alternative option for the Brighton Marina area would be not to update the masterplan. This "Business As Usual" option could lead to uncoordinated and piecemealdevelopments at the Marina coming forward which do not adequately address the place-shaping priorities identified as needing to be addressed in order to ensure a moresustainable mixed use environment.


The Sustainability Appraisal considered the preferred option, together with the 'businessas usual' option described above and concluded that the preferred option was deemed tobe the most positive approach but suggested that a range of mitigation measures wouldbe required to be incorporated in the updated masterplan. The mitigation measuressuggested included protecting and enhancing biodiversity, co-ordinated public realmimprovements, sustainable transport provision improvements, safe access, the need for aHIA, requiring high standards of sustainability and opportunities for renewable energyprovision in line with the emerging SPD on Sustainable Building Design, incorporating therequirements of the SFRA, safeguarding the provision of affordable housing andemployment provision and also consideration of the cumulative impact of development.

DA3 - LEWES ROAD


The responses to the consultation on the spatial strategy for Lewes Road were:

l The triangle area (Lewes Road/Upper Lewes Road and Union Road) has a distinctcharacter that new development should respect and there is an identified demand forsmall workshop space.

l Regeneration of Lewes Road is urgently required to include retail/employment units,new housing and refurbishment of good existing office stock.197


l Southern parts of Lewes Road would not be suitable for tall buildings.

l There are some highly sensitive green/parkland areas along the Lewes Road corridornot suitable for development.

l The preparation of the LR2 study and subsequent policy documents and guidancemust have full regard to the current scheme coming forward for Preston Barracks.

l Support policy to direct significant mixed-use, high density development within theLewes Road Corridor.

l here is no scope for development over and above that in the Planning Brief.

l A necklace of sites along Lewes Road could benefit from redevelopment but it shouldnot be high rise, including Preston Barracks.

l For any sites in the 'Lewes Road corridor', would support an appropriate mix ofresidential, retail and office use but not high-density development.

l The Lewes Road corridor should be emphasised as a place in its own right with directand effective transport links.

At the Area based events, the central area workshop suggested that more studenthousing should be concentrated, potentially around the academic corridor (perhaps viaintensification of Pavilion Retail Park) to avoid current conflicts between student lifestyleand that of families in the Coombe Road/Bear Road neighbourhood. Lewes Road areawas the heart of the city's manufacturing economy. Economic functions need to beintensified and the University should attract more economic activity (small business andworkshops) and that more intensive use could be made of Preston Barracks site foremployment uses. The East area workshop supported this growth area and identified anumber of sites along the road. It was agreed that there was some scope for tallerbuildings. It was considered suitable for a mix of use and it would benefit fromcommunity uses. There were issues in the area of student housing concentration.Concern was raised at the BME Elders Forum that safety issues were wider than justcentral Brighton and areas where late night uses were concentrated, for example LewesRoad and at the Universities. At the LSP development morning it was queried by oneparticipant whether more parking would be provided if growth occurs along Lewes Roadand another suggested that the links between the Universities and the regeneration areascould be improved.


A 'business as usual' approach was considered which would allow piecemealdevelopment and improvements along the Lewes Road Corridor to come forward in anuncoordinated manner. This would be contrary to the aims of spatial planning.


The Sustainability Appraisal considered the preferred option, together with the 'businessas usual' option described above and concluded that the preferred option was deemed tobe the most positive approach but suggested that certain mitigation measures would berequired. These include area specific points as well as those of city wide concern. Areaspecific points of particular relevance related to improving air quality, the environmentalquality of parks and open spaces, improving public safety and further analysis ofopportunities for taller buildings. These issues would be best addressed through theproposed design guidance for the area and city wide issues will be secured throughsupporting Core Policies. 198


DA4 - NEW ENGLAND QUARTER AND LONDON ROAD


The responses to the consultation on the spatial strategy for Brighton Station/NewEngland area and for London Road/Preston Road corridor were:

l Brighton Station could form part of a larger regeneration programme in the area. Thestation is close to its pedestrian capacity and without enhancement to cope withgrowth; the station will likely suffer from health and safety problems as well asoperational inefficiency.

l Only support with huge qualification.

l Support the proposals in SS1, which includes the London Road/Preston Road Corridor.London Road is identified elsewhere within the LDF, and within the LR2 study, as anappropriate location for such development and investment.

l Support the principle of Preferred Option SS1which identifies areas including theLondon Road/Preston Road corridor for mixed use, high density development. Alsosupport the objectives of regeneration and renewal to bring about sustainablecommunities in that area.

l Various unsightly vacant and underused sites facing Preston Park could benefit fromwell designed development. The setting of the Park is important and high risebuildings could reduce the apparent size of the Park to its detriment as a majorhistoric and recreational feature in the city. Development at Preston Circus should notexacerbate the already critical traffic congestion.

l Regeneration of London Road urgently required including retail/employment units,new housing and refurbishment of good existing stock.

At the Area-based event, the Anston House strip, Co-op site, Sainsbury's and Somerfieldsites along London Road were seen as having potential for mixed use development,Vantage Point and New England Quarter area for redevelopment and the London Gatearea suitable for more intensification. At the Economic Partnership sites and premisesevent, one workshop considered that Preston Road was not a secondary location andcould see high quality office developments happening there in conjunction with housing.The council needed to take a lead on forcing refurbishment of poor quality/eyesorebuildings to support the regeneration process. Buildings like New England House needurgent external refurbishment (though it was acknowledged that this cheap businessspace was popular with new and growing local businesses.). New England House's role inproviding cheap flexible space for new businesses was also mentioned at anotherworkshop and it was considered impossible to provide 'new' space for same cost.


An alternative approach considered was a 'business as usual' approach which wouldallow piecemeal development of the area in a more reactive, unco-ordinated mannerallowing the 'market' to dictate the mix of land uses.

Another option also considered was to deal with the London Road/Preston Road corridorand the Brighton Station/ New England areas separately as set out in the original CoreStrategy Preferred Option SS1.

199



The Sustainability Appraisal considered the preferred option, together with the alternativeoption of treating the Brighton Station/ New England area separately from London Road/Preston Corridor and the 'business as usual' option described above and concluded thatthe preferred option was deemed to be the most positive approach but suggested thatcertain mitigation measures would be required. These include area specific points as wellas those of city wide concern. Area specific points of particular relevance were theprovision and balance of employment floorspace, environmental improvements and theneeds of the wider community that use the area, further consideration of the scale andmassing of development on surrounding conservation areas and better linkages withinthe area. These issues will be addressed further in the proposed Supplementary PlanningDocument and city wide concerns will be addressed by the supporting Core Policies.

DA5 - EASTERN ROAD AND EDWARD STREET

Summary of Preferred Option Consultation

The following comments were made in response to the preferred options consultation onthe spatial strategy (SS1):

l There is little scope for further development as the corridor is already overloaded withhealth facilities. Tall blocks on the north side, east of Lower Rock Gardens, could beredeveloped to improve the street scene and the skyline from the south.

l The PCT would like to work with the council to identify suitable sites within the newdevelopment area.

l Tree planting to hide 'the horrors', demolition of St James's House, and other towerblocks, replace with small terrace houses.

l The area around Edward Street /Eastern Road could provide a new Civic area. Thetown hall in Hove would then be free for redevelopment.

There was consensus at the Area-based event, east area workshop, that the area isalready overdeveloped and should not be a regeneration and renewal area - there is toomuch traffic particularly around the hospital. Two of the group felt there was potentialto improve the appearance of the area particularly the flats (comprehensivedevelopment). The Brighton & Hove Arts Commission felt the area would benefit frombetter landscaping and public realm improvements that would help to keep businessesthere. It felt the benefits arising from including arts/ culture within mixed usedevelopments and links to regeneration and public realm are established; Circus Street isa good practice example of links with regeneration areas and Bristol Estate an example ofbringing arts out into community.

The Sustainability Advisory Panel suggested that large sites/comprehensive developmentareas, such as the Edward Street Quarter and Hospital sites, should utilise combined heatand power plants

Alternative Options

An alternative option considered was looking at a larger geographic area encompassingSt James Street and the Brighton University site. This priority fits well with the principleof how the development areas have been identified to accommodate higher levels ofdevelopment in areas of good sustainable transport access especially in the way that the 200


buses operate in the area. The resulting benefits arising from development could still gotowards priorities in improving the public realm and community infrastructure. Thedisadvantage of this approach is that it takes the focal point away from Edward Streetand Eastern Road. It reduces the emphasis on the need for a comprehensive approach topublic realm improvements and to positively address the poor townscape and instead torespond to development in a piecemeal way.

Another option considered was the 'business as usual' option, based upon the view thatthe area would generate insufficient development and sites to warrant inclusion as adevelopment area within the spatial strategy.


The Sustainability Appraisal considered the preferred option, together with the alternativeoption and the 'business as usual' option described above and concluded that thepreferred option was deemed to be the most positive approach but suggested thatcertain mitigation measures would be required. These include area specific points as wellas those of city wide concern. Area specific points of particular relevance were the needfor a comprehensive approach to improving the visual appearance of the area includingpublic realm, public art and sustainable transport improvements. In addition,consideration of the renewal areas in the locality, the need for a comprehensive approachto the hospital site, need for a doctor's surgery in the area and more efficient use of land.These concerns have been incorporated into the preferred option. The more generalmitigation measures relating to energy efficiency, biodiversity and addressing the needs ofsmall businesses will be addressed through the core policies.

DA6 - HOVE STATION AREA

Summary of Preferred Option Consultation

The following comments were made in response to the preferred options consultation onthe spatial strategy (SS1):

l Could potentially be in conflict with the East Sussex and Brighton & Hove Waste LocalPlan, which allocates sites for road to rail transfer of waste.

l Any development should ensure an improved interface between modes of transport,particularly between rail and bus connections to the Hove suburbs. Opportunities forimprovements in the conservation area, and the former industrial/railway landadjoining the station.

l Questionned whether there capacity for action in the area near Hove Station (westand north west).

l Only support Hove Station and then not without huge qualification.

l Have severe reservations about the impact of this strategy on the south-side of HoveStation, leading down to Blatchington Road. The road is already a busy thoroughfare.

At the Area Based event - the west area workshop, Hove Station was discussed as anarea with real potential ( Sackville Road, Victoria Road, Goldstone Retail Park and otherretail units on Old Shoreham Road next to Leighton Road). The shortage of healthfacilities in Hove and the difficulty of getting to them was discussed. It was suggestedthat the Hove Station area has potential to house health facility and new school,encouragement to look at co-location of facilities (e.g. Health with the Children's Centre201


on Sackville Road). However the potential for Hove Station area to be a growth area wasqueried at the Older People's Council Feedback session.


An alternative option considered was whether this area should accommodate theadditional 20,000 sq m of new office floorspace requirement for 2016-2026 that isidentified in the Employment Land Study.

An alternative business as usual (or do nothing) approach considered would be to allowpiecemeal development of the area in a more 'reactive' manner allowing the market todictate the mix of land uses.


The Sustainability Appraisal considered the preferred option, together with the alternativeoption of Hove Station area being the new office location and the 'business as usual'option described above and concluded that the preferred option was deemed to be themost positive approach but suggested that certain mitigation measures would berequired. These include area specific points as well as city wide concerns. Area specificpoints of particular relevance were the need for improved linkages between Hove Stationarea and areas to the north and south, consideration of how new employment floorspacecould benefit key employment sectors and the creative and digital industries, therelationship of the area to the Portland Road and Clarendon NRA and the need fortownscape and public safety improvements. These issues would be best addressedthrough the preparation of a masterplan for the area and issues of city wide concerns willbe addressed by the supporting Core Policies.

DA7 - SHOREHAM HARBOUR AND SOUTH PORTSLADE


The following comments were made in response to the preferred options consultation onthe Preferred Option for Shoreham Harbour (SH1):

l Would be better utilised as employment and residential land rather than as a port.Many of its current activities could be transferred to Newhaven.

l The spatial strategy should include reference to Shoreham Harbour as a majorregeneration area. Whilst there are constraints to be overcome for bringing forwarddevelopment at Shoreham Harbour, relevant agencies and bodies, including SEEDAare working together to unlock its regeneration potential.

At the Area-based events, the west workshop felt that the potential of ShorehamHarbour should be looked at more closely. However it was agreed that issues of accessto the site need to be considered carefully and more something for the latter end of theplan period.


An alternative approach considered would not to pursue a strategy for theredevelopment of Shoreham Harbour or the wider South Portslade area and to allowpiecemeal development of the Shoreham Harbour area in a more 'reactive' mannerallowing the 'market' to dictate the mix of land uses. 202



The Sustainability Appraisal considered the preferred option, together with the alternativeoption described above and concluded that the preferred option was deemed to be themost positive approach but suggested that certain mitigation measures would berequired. These include area specific points as well as those of city wide concern. Areaspecific points of particular relevance were the need for sustainable transportinfrastructure and a detailed transport assessment, the need for SFRA and HIA for thearea, protection of coastal vegetation and biodiversity and consideration of the widercommunity needs. These issues will be addressed through the Area Action Plan and citywide concerns would be dealt with through the supporting Core Policies.

SA1 - THE SEAFRONT

Summary of Consultation from the Preferred Options Stage (SR1 SeafrontRegeneration and PRE4 Shoreline Management)

l Of the 16 representations received on SR1, Brighton Marina raised the mostcomments; its shopping status should be clarified, the boundary should be widenedto include the Gas Holder site, better reflect the area's emerging status as a priorityregeneration area, the need to maintain and enhance biodiversity/ natureconservation features and ensure development does not erode views of the cliffs.

l The Brighton & Hove Economic Partnership felt that there should be a seafrontmasterplan whilst those who objected to the policy felt that there should be nofurther development along the seafront.

l It was felt that the status of certain major development sites referred to in thebackground were misrepresented as they did not have planning permission theyshould not be referred to as commitments.

l It was felt by one respondent that the discussion of the preferred option and the 'noalternatives' was misleading. It was felt that several alternatives to certain aspects ofthe major development sites had been put forward and this balance of views shouldbe better reflected in the Core Strategy.

l Need to address chronic congestion along the A259 which should be properlyassessed alongside major development.

l PRE 4 - Shoreline Management Plan: limited comment (5 representations). Onerespondent expressed concern over rising sea levels.

l SS1 - Spatial Strategy also received relevant representations on the seafront:

The area is a focal point along the seafront so development must be of the highestquality.

Central seafront being mainly a leisure/visitor destination is inappropriate for higherdensity mixed use development.

The emphasis on 'key seafront sites' puts the future of the whole area at the mercy oflarge-scale development projects, with all their attendant risks. To enhance the seafrontas a sustainable year round tourist attraction a distinction should be made between thebusy central seafront and the more tranquil wings of the East Cliff stretch and the HoveLawns/esplanade.

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Reference in the Local Plan to tranquility of the eastern seafront must be preserved andstrengthened.

At the Area Based event, the west of the city workshop felt that development pressureneeds to be taken off the seafront/ A259. The Brighton & Hove Arts Commission felt thatthe model of arts and crafts studios/retail outlets on the seafront in the arches is one thathas worked well and is a mix that could be replicated elsewhere in the seafront.


An alternative option considered was a 'do nothing' or 'business as usual' option; whichwould be not to set out a strategy for the seafront but instead to treat issues relating tocoastal protection, nature conservation cultural and built heritage, leisure and recreationrole separately.


The Sustainability Appraisal considered the preferred option, together with a 'business asusual' option, and concluded that the 'business as usual option' was not a sustainablealternative. It suggested that the preferred option should consider the use of SustainableUrban Drainage Systems, if appropriate, to reduce surface water run-off. It suggestedthat renewable energy should be encouraged, that businesses along the seafront shouldbe encouraged to become more resources efficient (e.g. biodegradable waste) andfurther consideration should be given as to how this on-going regeneration will bebeneficial to the communities without direct access to the seafront. Whilst the appraisalrecognised that the preferred option would provide an integrated policy framework forthe seafront the environmental implications of tourism should be addressed. ThePreferred Option has been amended to reflect these issues.

Reasons for the Preferred Option

The original Preferred Option SR1 accorded with the aims of the 2004 Tourism Strategyand reflected key concerns and aspirations raised during earlier stages of communityinvolvement. However this revised preferred option draws together the various issuesrelated to the seafront in a more integrated, spatial approach. It accords with theidentification of Brighton & Hove in the draft South East Plan (TSR7) as a 'tourism hub'and the need for complementary approaches to the development and management oftourism so as to upgrade facilities, promote diversity, reduce seasonality and improveaccess, whilst retaining and enhancing the natural character of the area. This proactivepolicy approach also accords with the government's Good Practice Guide for Tourism andTourism South East's guidance on the need to support and promote tourism.

An increased reference is made to maintenance and regeneration of the seafront andreference to development sites has been removed from the revised preferred option, anddealt with, where appropriate in the Development Area proposals. The revised preferredoption now covers the seafront from Boundary Road/Station Road to the eastern extentof the council's administrative boundary at Saltdean. A change to the Preferred Optionshas also been made to integrate the coastline and coastal defences issues, originallytreated separately by Preferred Option PRE4.

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SA2 - CENTRAL BRIGHTON

Summary of Preferred Options Consultation:

S1: Safer City- 12 responses all broadly support the preferred option subject to goodmanagement and monitoring. 2 objections regarding need to address city wide safety(e.g. also in urban fringe) and access to leisure, sporting and cultural facilities within thecity more generally and provision for the elderly.

At the LSP Development morning - with regards to central Brighton the commentsgenerally supported the approach of S1to better co-ordinate public safety, licensing andplanning policy with the aim of diversifying the night time economy and taking acumulative approach to late night uses.

CT4 Cultural Quarter - 6 responses. Whilst there was general support for the intentionsof the cultural quarter it was thought the option may lead to a view that only a limitedarea of the city was perceived as being important culturally and underplays theimportance of the cultural and creative industries that exist across the city.

R1 Retail Development - 32 responses. Support for larger new shopping units inBrighton Regional Centre, possibly through the expansion of Churchill Square inconjunction with the Brighton Centre redevelopment, with a need for more departmentstore representation. Concerns regarding city centre parking provision associated withfuture new retail development. One respondent queried whether it was appropriate tofocus significant retail development to Brighton regional centre at the expense of othercentres.

The Retail and Tourism Advisory Panel

l Brighton Centre redevelopment does provide potential for retail in conjunction withChurchill Square - there is demand for additional retail space in Churchill Square anda department store.

l Opportunities in regional centre are limited and must not be isolated. Possibleopportunities included West Street, Bartholomew Square, Black Lion Street andWestern Road.

l Independent retail role of North Laine needs to be protected.


An alternative approach, as set out in the Core Strategy Preferred Options would be a'business as usual' option which would deal with those issues that relate to the citycentre: the evening economy and safety, retail, leisure and cultural uses, the public realmand built heritage separately.


The Sustainability Appraisal considered the preferred option, together with the 'businessas usual' option, and concluded that the 'business as usual option' was not a sustainablealternative but suggested that there were also uncertainties with the revised preferredoption when appraised against the sustainability objectives. These uncertainties related tobiodiversity, sustainable urban drainage, water efficiency measures, renewable energy andwaste minimisation. In response it is considered that these uncertainties will be addressedthrough the implementation of preferred options CP1 Sustainable Buildings, CP5Biodiversity and through the requirement of Site Waste Management Plan with

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applications to accord with the Construction and Demolition Waste SPD and the WasteStorage Planning Advice Note.


This preferred option is part of the new area-based approach to the revised CoreStrategy. Following the review of the structure of the Core Strategy Preferred Options itwas considered that an alternative option for dealing with those issues identified asrelating to Brighton regional shopping centre, city centre safety and the cultural quarterwas to draw together these issues in an overarching strategy for the city centre.

SA3 - VALLEY GARDENS


No specific proposed option for the Valley Gardens area was included in the CoreStrategy Preferred Options document in 2006 but it was specifically referred to in theSpatial Vision as a focus for improvements and was mentioned as a priority underPreferred Option UDC2 Urban Design Framework. One formal response on the SpatialVision, from the bus company, made the point that Valley Gardens has an accessibletransport corridor and that greater accessibility there should not be to the detriment ofthis. UDC2 was generally supported during consultation.


No specific proposed option on Valley Gardens was included in the Preferred Optionsdocument. No alternative options are put forward other than a 'do nothing' or 'businessas usual' option.


The Sustainability Appraisal considered the preferred option, together with a 'business asusual' option, and concluded that the 'business as usual option' is not a sustainablealternative. It recognised that as a key gateway to the city, a coordinated approach wouldbe a more sustainable approach to tackle townscape and public realm improvements inthe area. However there were uncertainties with the preferred option when consideredagainst certain sustainability objectives. These related to biodiversity, sustainable urbandrainage, water efficiency measures, renewable energy and waste minimisation. Inresponse it is considered that these uncertainties will be addressed through theimplementation of preferred options CP1 Sustainable Buildings, CP5 Biodiversity andthrough the requirement of Site Waste Management Plan with applications to accordwith the Construction and Demolition Waste SPD and the Waste Storage Planning AdviceNote.


This preferred option is new and is part of the new area-based approach to the CoreStrategy. The evidence base demonstrates a clear need for major intervention at ValleyGardens. The location and potential of this area is clearly of city-wide, strategicimportance and its future needs encompass a wide range of issues that demand an over-arching spatial policy. The proposed policy accords with proposals in the Local TransportPlan, responds to the recommendations of the Public Space Public Life Study and the LR2Study. This preferred option cross-references with a number of other Core Strategy 206


policies, but notably Preferred Options CP3- Public Streets and Spaces and CP18- Culture,Tourism and Heritage

SA4 - URBAN FRINGE


20 individuals and organisations responded to preferred option UF1- Urban Fringe, theconsensus of opinion on the preferred option was that it should be supported. Halfsought no development in the urban fringe. 2 respondents wanted development to beconsidered only 'as a last resort', 2 representations suggested park and ride sites withinthe urban fringe and 3 sought the use of the urban fringe for housing and employmentuses. A number of correspondents only partially supported or objected to the policybecause:

l the policy did not go far enough in protecting the urban fringe and there wereconcerns that the preferred option would lead to inappropriate development,

l the green network should be supported in the urban fringe which should specificallyprotect biodiversity and geology.

When considering what development could be accommodated, there were commentsboth supporting and opposing the use of the urban fringe for a site for travellers.

Other consultation comments related to the urban fringe were raised in relation to theSpatial Strategy (SS1):

l Limited development and expansion on the urban fringe could be included with care.

l Development on the urban fringe is not unacceptable in principle, but emphasise thatany such development should deliver clear improvements for nature conservation.

l Strongly oppose any office development on the urban fringes.

l Should review the outdated AONB boundaries and release land for development thatno longer adheres to the AONB criteria. In addition, there should be bettermanagement of the Greenfield sites on the urban fringe. In some cases, these siteswould be suitable for commercial use and residential developments.

l Very much against the city extending its physical limits into the Sussex DownsAONB/South Downs National Park.

l The South Downs AONB Management Plan should also be taken into account.

l Recognise the potential benefits of urban fringe development 'under certaincircumstances'.

l Notwithstanding the outcome of the South Downs National Park Inquiry,development of some urban fringe must be included as part of the overall spatialstrategy for the development of the city. To exclude this option would unreasonablylimit opportunities for a variety of development needs for the wider city and beyond.

l View the urban fringe as being multifunctional and would expect development to beconsidered only as a last resort and not involve any greenfield sites, i.e. any futuredevelopment on the urban fringe should be restricted to brownfield sites.

l Approach is sound in principle but should not rule out some development ongreenfield sites on the urban fringe that are of poor landscape quality. Some wouldbe enhanced, both in terms of biodiversity and accessibility to the public, by limited

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development in return for better stewardship of the remaining green space andcreation of new parkland. The number of brownfield sites for housing is now limited.Reliance on brownfield sites for a major contribution to Brighton & Hove's strategichousing requirements means that we have to accept intense development at highdensities of the few available sites.

There was a discussion of the role of the urban fringe at one workshop at the LSPDevelopment Morning, one participant felt it should be protected and enhanced whilstanother participant noted that this constraint would result in increased densities withinthe built-up area. At the Area-based event, the west workshop discussed whethercertain uses - such un-neighbourly uses, recycling centres and shopping uses could berelocated to the urban fringe and free up central sites for development a and easingtraffic congestion. At the Economic Partnership sites and premises event, oneworkshop discussing opportunities for new employment floorspace raised the issue ofurban fringe sites.


To have no specific policy approach to the urban fringe but to rely on a combination ofother proposed policies in particular CP5 and CP6.

As a result of consultation comments it was necessary to consider an option which wouldsupport development of some sites on the urban fringe for housing and employmentuses in the period 2016- 2026, as part of the long term strategy for accommodatinggrowth, provided that such development released funding for enhancements elsewhereon the urban fringe.


The Sustainability Appraisal considered the preferred option together with the twoalternative options (outlined above) and a 'business as usual' option. It concludes that thepreferred option was the most sustainable one, compatible overall with the sustainabilityobjectives and in contrast with alternative options considered the wider landscape role ofthe urban fringe. The option of some development post 2016 was found as with itsconsideration at the original preferred option stage to raise too much negativity anduncertainty. The appraisal did not recommend any changes to the revised preferredoption but did suggest ensuring housing and affordable housing in particular is deliveredelsewhere in the city. It is considered that this issue has been explored through theStrategic Housing Land Availability Assessment, interim findings and is sufficiently dealtwith through the Development Areas and CP11 Housing Delivery and CP12 AffordableHousing.


The strategic urban fringe policy in the revised Core Strategy will provide a long termstrategy for those areas of currently in the South Downs AONB and countryside that havenot been included within the proposed South Downs National Park and which otherwisemay come under increasing development. The revised preferred option reflects keypolicies in the draft South East Plan, notably BE4: 'Managing the Urban Rural Fringe'. Itaddresses the key issues where consensus emerged from the research and evidence baseand community involvement findings. It also reflects the preferred spatial strategy set outin Part Two of this document.

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SA5 - SOUTH DOWNS


Preferred Option OS2 - AONB/future South Downs National Park (9 representations) -general support for this preferred option but concerns were raised for the need foradequate protection for areas of AONB that may not fall within proposed National Parkboundary and non-AONB countryside also not included within the proposed NationalPark boundary. Two respondents felt that some areas of AONB could be reconsidered fordevelopment. Comments in relation to the AONB/ National Park were also made inrepresentations to UF 1 Urban Fringe and SS1 Spatial Strategy.


The only alternative option considered was of 'doing nothing' so that the AONB wouldbe protected by national policy and regional policy but this would not reflect the council'saspirations for those parts of the national park within the administrative area of the city.


The Sustainability Appraisal considered the preferred option together with a 'business asusual' option. It concludes that the preferred option is the most sustainable one showingoverall compatibility with the sustainability objectives. The appraisal does not recommendany changes to the preferred option but does suggest ensuring housing and affordablehousing in particular is delivered elsewhere in the city. It is considered that this issue hasbeen explored through the Strategic Housing Land Availability Assessment, interimfindings and will be sufficiently dealt with through the Development Areas and CP11Housing Delivery and CP12 Affordable Housing.


The Core Strategy Preferred Option was drafted at a time of uncertainty as to theoutcome of the National Park Inquiry and no specific preferred option was drafted for thearea of the proposed National Park because the original timetable for designation meantthat it would have been a matter for the National Park Authority before the CoreStrategy was submitted. Although the exact boundaries have yet to be determined, theInspector has recommended the 'in principle' designation of the National Park and maderecommendations for its boundary. However it is considered, in taking an area-basedapproach necessary to set out the council's aspirations for those parts of the proposedNational Park within the administrative area of the city to inform future partnershipworking with the National Park Authority.

SN1- SUSTAINABLE NEIGHBOURHOODS

Summary of Consultation from the preferred options stage:

Consultation comments relevant to the sustainable neighbourhoods' proposals wereraised under a number of preferred options; the following are the most direct comments:

Preferred Options SS1- Spatial Strategy:

l to allow some development at local centres/parades giving priority to deprivedneighbourhoods;209


l development potential around the all minor stations Portslade, Aldrington, LondonRoad, and Moulsecoomb should also be fully explored

l More development should be directed to selected suburban modes around the city asthese would help to create the demand for public transport between suburbannodes.

l Priority should be given to all neighbourhood renewal areas, particularly Central Areassuch as Tarner (South Hanover), which includes the Circus Street market site.

l Should encourage high density development outside of the Broad DevelopmentCorridors/Broad Development Areas where the opportunity arises. This should includethe intensive use of existing brownfield sites on the city's main routes including theA23 and Carden Avenue, Hollingbury.

l Support residential and mixed use development in EB4U area and diversified housingtype and tenure- key worker housing in area.

l Sites in Patcham, Hollingbury and Hollingdean could be used for mixed usedevelopment. These areas are monotonously low density, though they do providecomparatively low-cost family housing.

Relevant comments were also made to Preferred Options L1 and L2 Employmenttraining and wider facilities/learning for local communities:

l Need good bus links to education establishments to increase links to the New Dealfor Communities Area.

l Links between University and deprived areas required limited provision of buildingspredominantly taken form of outreach.

l Wilson Avenue and Community Stadium can become centres of excellence forconstruction training and engineering.

l Provision of student housing and integration with local community is an increasingproblem in East Brighton.

Relevant comments were also made to Preferred Options SC1 Supportingneighbourhood renewal plans/ New Deal Area Delivery Plan and SC2Contributions to community facilities where there is a shortfall:

l All options generally supported strengthening communities and neighbourhoods andcontributing to health improvements and reducing health inequalities. Severalrespondents felt that developer contributions for community facilities should not belimited to NDC and NRA areas. Whilst those areas may need investment, othercommunities in the city should also be given opportunities from developer funding.

l It was suggested that provision of facilities for young people should be emphasised.Also that provision could be linked with Preferred Options OS1-4 Countryside andOpen Space, for example by providing facilities such as open air sports courts, and byimproving access to biodiversity on regeneration sites. This could also help to reducepressure on the South Downs.

l Welcome the references to community safety as this is important part of theregeneration process in renewal areas.

l Whilst the rationale to focus on NRAs is understood, concern was raised by severalrespondents that pockets of deprivation in otherwise prosperous areas could bemarginalised by that Preferred Option. Several respondents commented that the 210


contributions from developers should not be overly onerous on developers as thatcould detract from investment and regeneration in renewal areas. For example, thereis no indication of what is considered 'major' new development. It was alsosuggested that wording in SC2 be amended to clarify that contributions to thecommunity other than built facilities (which require ongoing maintenance) could beacceptable in some circumstances.

Preferred Options S2 Safer streets - main comments were that this was supported butshould be extended to all neighbourhoods not just deprived areas.

At the Local Strategic Partnership Development Morning one workshop felt that theissue for East Brighton is to ensure that the most disadvantaged are included and trained/have access to jobs. There are a number of different ways of achieving the outcomes,focus on the pockets of deprivation/ individuals and be realistic about the cost. The linksbetween the Universities and the regeneration areas can be improved, partly by makingpeople more aware of what is going on at the moment with individual students goingout to the community as part of research or with funded programmes. Need also todispel the myths around students in the local communities in terms of impacts onhousing and local pubs/ shops. At the Economic Partnership Sites and PremisesMeeting it was raised in one workshop that the current local plan makes specificreference to the contribution the universities can make to generating employment andbringing employment to the city and need an equivalent in the new plan. Spectrumopposed SC2 on the basis that LGBT communities are not geographically based. ThePreferred Option should be broadened to include not just geographical communitieswithin areas of social and economic deprivation, but should also seek not to exclude, bydefault, non-geographically based communities of interest within the city by focussingsolely or even primarily on a neighbourhood approach to services. One MOSAICinterviewee felt that there was a lack of reference to the specific needs of minority ethniccommunities. This is seen to be a vital element of any work which will be carried out tostrengthen communities and involve people.

Brighton & Hove Arts Commission - The use of arts and culture can be tremendouslyeffective in the implementation of planning policy in terms of strengthening communitiesand involving people. There are a number of recent projects Brighton & Hove ArtsCommission has been involved with in the city that are excellent examples of this.Participatory, consultative public art projects for example that have been drawn fromneighbourhood action plans help to improve local environments and enable localownership and pride. Public art should have a role to play in enhancing districts/cityneighbourhoods, high quality design, design and integration of sports, conference andrecreation facilities.


No alternative options were put forward during earlier stages of community involvement.An alternative option considered was to identify specific neighbourhoods within the cityto prioritise improvements and also a 'do nothing or 'business as usual' option.


The Sustainability Appraisal considered the preferred option together with the alternativeoption outlined above and a 'business as usual' option. It concludes that the preferredoption was compatible with the sustainability objectives. The area specific alternative wasconsidered less likely to ensure that all neighbourhoods across the city becomesustainable neighbourhoods and the 'business as usual' would not set out an integrated

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approach to creating and maintaining sustainable neighbourhoods. Suggested mitigationrelated to encouraging the integration of biodiversity into all new developments acrossthe city and that sustainable urban drainage should be included where possible in anynew developments. It is considered that these issues would be addressed through citywide policies CP5 Biodiversity and CP10 Managing Flood Risk.


This preferred option is new and is part of the new area-based approach to the CoreStrategy. It directs former topic based preferred options, in the previous version ofpreferred options, into an integrated area strategy to create sustainable neighbourhoodsand reflecting the priorities of the Sustainable Community Strategy. It thereforeincorporates a number of the previous preferred options and will be implementedthrough a number of citywide core policies.

SN2 - RESIDENTIAL RENEWAL AREAS

Summary of Consultation from the Preferred Options stage:

The Strengthening Communities preferred options were generally supported; concernsrelated to widening the application to all communities not just deprived areas andconcern that contributions should be appropriate to the development.

S2 Tackle community safety and road safety in deprived areas - sevenrepresentations supporting child-friendly streets, one representation suggested the corestrategy should go further and champion Living Streets concept. 2 respondents felt theseissues were city wide issues

H5 Community facilities in deprived neighbourhoods - five representation of supportbut sought reference to access to play in all areas lacking access to public open space notjust deprived neighbourhoods.

DC1 Developer Contributions Priorities - general support for the principle thatdevelopers should contribute towards providing the necessary physical, social andcommunity infrastructure.


No alternative options were put forward during earlier stages of community involvement.The alternative is therefore a 'do nothing or 'business as usual' option. It should be notedthat the previous Sustainability Appraisal (2006) had considered the overall approach todirecting development towards regeneration/ renewal areas (Option B regeneration-ledapproach to accommodating growth in the city) but that that Appraisal had concludedthat it was not the most sustainable option.


The Sustainability Appraisal considered the preferred option together with a 'business asusual' option. It concludes that the preferred option was compatible with thesustainability objectives. Mitigation concerns related to any potential new developmentand how these would impact on biodiversity, sustainable urban drainage, water efficiencymeasures, renewable energy and waste management. New development should meet theHigh Level Code for Sustainable Homes/ BREEAM 'Excellent' standard. It is consideredthat these issues would be addressed through the implementation of CP1 SustainableBuildings, CP5 Biodiversity and CP10 Managing Flood Risk.

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This is a new preferred option that has been introduced as part of the area-basedapproach. It is based upon a number of priorities in the Sustainable Community Strategyand identified in the first Preferred Options Core Strategy that focus upon reducinginequalities between deprived areas and the rest of the city. This strategy incorporatesthe relevant topic based preferred options into a single strategy for deprived areas.

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CP1 SUSTAINABILITY

Summary of consultation from the Preferred Options:

Preferred Options PRE 1(need for high sustainability standards) and PRE 2(preparation of more detailed guidance) of the 23 representations to PRE1 and 11representations to PRE2 there was:

l General support given to specify minimum performance standards and targets fordevelopment in the city.

l However some developers expressed need for the 'highest standards' specified to beviable/achievable.

General comments to the PRE section related to:

l the lack of mention of biodiversity/ links to biodiversity

l the need for energy targets to be included in line with the draft South East Plan

l Inclusion of a commitment to minimise pollution and to actively seek improvementsin water and air quality and reduce noise pollution in line with South East Plan.

l In relation to the Construction and Demolition Waste SPD the need for clarification ofits implementation - which DPD will deal with which waste streams.

Event Responses

The area based events did not cover sustainability issues in detail. MOSAIC consulteesfelt there is uneven access to free recycling facilities across the city, the fact some itemsare not accepted for recycling (e.g. hard plastic, containers and batteries) and that thecity need to reduce its environmental footprint. Comments at the LSP event inWhitehawk focused largely around sustainable transport issues. One participantsuggested urban fringe should be maintained and enhanced. Older People's Councilconsultees suggested Lifetime Homes should be promoted but accessibility needs toapply to the wider public realm to provide more for people with disability and olderpeople (transport facilities, provision of seats etc). At the feedback sessions with Schools(Dorothy Stringer and Blatchington Mill) the common feeling was that sustainabilityis high on their agenda. In the Dorothy Stringer session it was suggested that solarpowered public street lighting and wind turbines (on the Downs) are a good idea. In theBlatchington Mill session it was suggested more waste reduction and recycling is needed.

Site Allocation Preferred Options Consultation

Written responses to Spatial Issue 14 - renewable energy included support for theprinciple for renewable energy sources, provided this did not have a detrimental impacton the surrounding housing (both existing and proposed new housing) or stifleregeneration. A number of contributors stressed the need for a flexible approach thatallows for responses to different locations, visual impact of technologies anddevelopment sizes. The need for placing energy efficiency at the forefront and usingS106 to secure sustainable features was also mentioned. Some considered that potentialfor CHP (combined heat and power) units should be further explored. One participant 214


Part Three - Core Policies

suggested the production of policy guidance on micro generation. Shoreham Harbour(CHP), Circus Street regeneration (CHP), Brighton Pier, University of Sussex (CHP),Brighton Marina (marine power) City College, London Road/Lewes Road and BrightonStation were mentioned as sites with potential for renewable energy generationdepending on the kind and use of technologies. National Park (AONB) was not the bestoption for wind turbines.

Responses to Spatial Issue 14 - renewable energy

The Advisory Panel on Renewable Energy indicated that identification of sites forlarge-scale renewable/sustainable energy different parts of the city will depend ongeography, topography, micro-climate, ecology, designated area status and environmentalimpact of technologies upon air quality and neighbourhood amenity. The use of differenttechnologies or combinations of technologies will follow from that. However, in general:

l Brighton Marina and Shoreham Harbour are considered the most promising sites forthe implementation of large-scale marine, wind and CHP technologies;

l existing large-scale buildings with boilers such as hospitals and large office buildings(particularly council offices) as having great potential for incorporating CHPtechnologies;

l the South Downs was not considered a realistic option for large-scale wind resource;and

l off-shore wind farm is an option that could be explored by the local authority.

Other recent/emerging developments

The Environment Agency approached the council to explore possibility of links betweensustainable building requirements and developer contributions to off set carbon emissionsand water efficiency measure not met on site. There is a need to include a link with theDeveloper Contributions policy in the Core Strategy so that this may become possible.


No alternative options emerged from the preferred options consultation. The onlyalternative is therefore to do nothing or 'business as usual' option. This would be to relyon a generic sustainability policy, unsupported by detailed guidance in a SPD, whichwould rely on national and regional targets/ standards and therefore would risk that thespecific local circumstances facing the city would be ignored and the council's targets onsustainability would not be met.


The Sustainability Appraisal considered the preferred option together with a 'business asusual' option. It concluded that the alternative business as usual option was not the mostsustainable as relying on national/ regional targets could risk standards being applied thatdo not adequately reflect the distinctive local environmental circumstances. The preferredoption was found to be compatible with Option 1 but it was indicated in the appraisalthat the potential cost of providing sustainable buildings may conflict with theaffordability of providing affordable housing. However it should be noted that thegovernment sets environmental standards for affordable housing delivered by RegisteredSocial Landlords.

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Preferred options PRE 1and 2 were retained as a city-wide strategic issue but merged toset out in more detail than the original preferred option, the councils approach to deliverlevels of sustainability in advance of those nationally and regionally with further details tobe accompanied by the Sustainable Buildings SPD. The revised preferred option has hadregard to national and regional guidance for the delivery of sustainable buildings andzero carbon homes as set out in the supplement to PPS1 but reflects the city's uniquelocal circumstances and commitments set out in the Sustainable Community Strategy.

CP2 URBAN DESIGN


Written Responses

UDC1 (standard, design and density of development) - There were 27 responses.Overall this proposed option was generally supported to varying degrees. The Lewes Roadand London Road corridors and the Marina were largely supported as suitable for tallerbuildings. Some respondents supported higher densities in the built up area generally butwere opposed to tall buildings whilst some respondents objected to tall buildings inparticular areas, especially along the seafront. Reasons given were the inability of thetransport infrastructure to cope; the adverse impact on pedestrians, cyclists and airquality; and inappropriate visual impact on the landscape. Care was urged if tall buildingsare proposed in the Hove Station area. Three respondents considered the policy toorestrictive in terms of areas and in relying on key strategic views. It was suggested thatShoreham Harbour and Station Road/Boundary Road should also be included as tallbuilding areas. One respondent felt that 6 storeys or 18m is an arbitrary figure. Onerespondent stressed the importance of a vision for the city's skyline and seafront. Onerespondent stressed the importance of tall buildings being mixed use, not just residential.English Heritage drew attention to the revised guidance on tall buildings due to bepublished jointly by English Heritage and CABE.

UDC2 (city wide urban design framework) - There were 11 responses. This proposedpolicy was largely supported. The council was urged to be visionary and not be restrictiveon appropriate uses. The Police urged the addition of areas of improved design toprevent crime and anti-social behaviour. One respondent thought that the priorities listedunder category 2 (c) are too restrictive for a 20 year period. One respondent wished tosee reference to open space in this policy.

Events

The Area based events did not specifically discuss urban design but there wasacknowledgment in the central area event that there is scope for increased height anddensity in the Lewes Road and London Road corridors as part of mixed use development.The east area event also supported tall buildings in the Lewes Road corridor and notedthat Eastern Road needs physical improvements. At the Economic Partnership Sites andPremises Sub Group events, one workshop agreed that there is a need to ensure newdevelopments exhibit a high standard of architecture, with incentives for developers topromote it. At the Spectrum event concern was expressed about high densitydevelopments and impact on light and space.

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Following Issues and Options consultation, the chosen approach was to include thevarious options within a general strategic policy and provide detail in subsequent LDFdocuments. No specific alternative options were put forward at the Issues and Optionsstage or the Preferred Options stage and none emerged from the research evidence,other than a 'do nothing' or 'business as usual' option. However, several respondentssupported higher densities in the built up area generally but opposed tall buildings.Therefore an alternative option would be to delete the reference to potential tallerbuilding areas in the policy, keeping the rest of the policy unchanged.


The Sustainability Appraisal considered the preferred option together with a 'business asusual' option and an option not identify areas for tall buildings but instead to treatapplications on their merit. It concludes that the later option would create manyuncertainties and not reflect the council's adopted Tall Building Guidance that hadconsidered potential locations on sustainable transport nodes or for their lack of visualintrusion. The do nothing option would not adequately capture the particular localcontext for urban design or reflect area specific opportunities for tall buildings. It wastherefore concluded that the preferred option was the most sustainable and compatibleoverall with the sustainability objectives.


It is a priority of the Government, SEERA and CABE to raise design standards andreinforce local distinctiveness. This is reflected in PPS1 (Delivering SustainableDevelopment), PPS3 (Housing) and PPS6 (Planning for Town Centres) and in the relevantpolicies of the draft South East Plan. It was also strongly backed during communityinvolvement and formal consultation on the Core Strategy. This policy would allow thecity to accommodate future development whilst maintaining and enhancing distinctneighbourhoods, by building on the findings of the Urban Characterisation Study andputting them into a policy context.

It is a priority of the Government and SEERA to maximise development on brownfieldsites by raising density where appropriate (PPS1 and PPS3). Tall buildings are one (but onlyone) of the potential ways of achieving this and CABE and English Heritage haveproduced joint guidance on the subject. The study commissioned by the councilconcluded that some areas of the city have potential for taller development. It istherefore considered appropriate to make positive provision for this within the core policy.Ignoring tall building potential may lead to greater development pressure on the historiccore of the city and on the urban fringe. Furthermore, background work for theDevelopment Area proposals (DA1-DA7) has indicated that taller development may havea positive role to play in creating more coherent and legible townscapes.

The original Preferred Options UDC1 and UDC2 have been combined and restructured asCore Policy CP2 - Urban Design. This achieves a preferred option that is truly strategicand spatial and leaves more detailed considerations to other documents. ShorehamHarbour has been added to the list of taller development areas within the policy.Although included within the existing Tall Buildings SPG, this area was omitted from theoriginal Preferred Option UDC1 due to concerns over the deliverability of significantdevelopment at Shoreham Harbour within the plan period. Such concerns are now beingaddressed (See Policy DA7).

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CP3 PUBLIC STREETS AND PLACES


Written Responses

UDC3 (public realm) - There were 11 responses. This proposed policy was largelysupported. Two respondents considered that tall buildings can aid legibility in the publicrealm by acting as landmarks. Brighton & Hove Arts commission stressed the importanceof art and artist led design to the urban realm. One respondent mentioned the need totake account of the Public Space Public Life Study. One would like to see greateremphasis, and clarity, on accessibility for the disabled in the policy. One felt that thepriorities are unduly specific for a 20 year period. One respondent considered thewording ambiguous and therefore objected, but did not explain why.

PST5 (urban realm and transport schemes) - There were 5 responses. Three responsessupported the proposed policy. The other respondents questioned why the proposedpolicy was there and noted that there was no reasoning for it in the preceding pages andthat it had failed to address issues of east-west connectivity and severance.

S1 - S4 (safer city preferred options) - Brighton & Hove Arts Commission referred tothe positive role of culture in creating safer community and public spaces, throughlighting schemes for example, by working with local users.

H4 (healthy food options) - Of the 8 responses, the PCT confirmed that city designmakes a contribution to health outcomes. One respondent commented that thedevelopment of healthy streetscapes is closely linked to the provision of healthy livingoptions and that public spaces should encourage community and human interaction. Onerespondent referred to the need for more benches/seating facilities in public places.

Events

The Area based events did not specifically discuss public realm issues but the OlderPeople's Council event stressed the importance of accessibility and designing for theelderly in the public realm. This was also mentioned in the BME Elders Forum event inrelation to lack of seating around Churchill Square. This forum event further mentionedthe poor appearance of Pool Valley. Children and young people at the schools eventsparticularly commented on the poor appearance, and lack of lighting, of the Marinapublic realm around the cinema/car park area. At the Retail, Culture and TourismAdvisory Panel, the representative from Tourism South East suggested thatenvironmental improvements in St James's Street, linked to pedestrian priority measures,should be considered to enhance the tourism offer.


No alternative options were put forward at the Issues and Options stage or the PreferredOptions stage and none emerged from the research evidence, other than a 'do nothing'or 'business as usual' option.


The Sustainability Appraisal considered the preferred option together with a 'business asusual' option. It concludes that the business as usual option is not deemed to be themost sustainable as it risks loosing opportunities to improve the public ream and to takeforward the recommendations from the Public Life and Public Spaces study. The preferred

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option was compatible with sustainability objectives but it was suggested that the optionincludes the planting of street trees and other suitable street planting as part ofimproving the public realm. This has been included in the wording of the preferredoption.


The important role of the public realm in achieving sustainable communities andattractive places is recognised by the Government in PPS1 (Delivering SustainableDevelopment), PPS3 (Housing), PPS6 (Planning for Town Centres) and, in more detail, theManual for Streets (2007). Enhancement of the public realm is also an objective ofSEERA, CABE and English Heritage. Furthermore, the need for more accessible andinclusive public spaces was a recurring theme during community involvement in the CoreStrategy. A core policy would therefore be appropriate that takes a pro-active approachto these issues and that can take forward the objectives of the Public Space Public LifeStudy and make links with the Local Transport Plan. This proposed policy complementscore policy CP2 on Urban Design and core policy CP8 on Sustainable Transport.

The original Preferred Options UDC3 and PST5 have been combined and restructured asPreferred Option, CP3 - Public Streets and Places. This is to avoid duplication of policyand to ensure that sustainable transport issues are integral to public realm improvements.It also makes the link with health, safety and active living in core policy CP4.

CP4 HEALTHY CITY


Most comments broadly supported the policies but several sought minor amendments towording:

H1 Health Impact Assessments (6 representations): General support

H2 Health and community facilities (11 representations) General support, commentssought reference to accommodating larger GP practices and Poly clinics, ambulanceservice needs, the contribution to healthy lifestyles of cultural facilities (e.g. dance) andBME groups noted the need for appropriate cultural facilities for different culturalcommunities.

H3 Promoting healthy and active living (13 representations) - Majority supportedpolicy, comments sought reference to importance of biodiversity, sports, walking andcycling, and access to countryside and open space contributing to health. Othersrequested amendments emphasising access issues; SPECTRUM sought LGBT healthyliving/support centre.

H4 Allotments and farmers markets (8 representations) - general support butcomments sought strengthening of protection of allotments and possibility of expansion;reference to securing relocation of allotments. One respondent sought reference toredeveloping unused allotments.

H5 Community facilities in deprived neighbourhoods - five representation ofsupport, one respondent sought reference to access to play in all areas lacking access topublic open space not just deprived neighbourhoods, others sought reference to accessto green open space and biodiversity.

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SPECTRUM sought an amendment that developer contributions for community facilitiesfor communities with demonstrable levels of unaddressed need should not exclude, bydefault, non-geographically based communities of interest within the city, also provisionsfor an LGBT Healthy Living centre and accessible meeting/cultural spaces, (e.g. day carecentres and surgeries) in a safe environment relevant to different cultural communitieswith culturally appropriate food, games and reading material. The Area based event(West) noted the shortage of health facilities in Hove and difficulty of getting to them,Hove Station area has potential to house health facility, encouragement to look at co-location of facilities (e.g. Health with the Children's Centre on Sackville Road). Lack of GPsurgeries, the potential for co-location and the need to ensure facilities are providednorth of the railway. The inclusion of health and well-being in the Core Strategy waswelcomed by members of MOSAIC. Some individuals mentioned that there were notenough culturally appropriate facilities in the city and that this needed to be reflected inthe document. Examples mentioned were doctor's surgeries and Day Care Centres, wherethe provision of culturally appropriate food, games and reading materials (e.g.newspapers aimed at minority ethnic people) would contribute to making people feelwelcomed and at home. Some individuals mentioned that Brighton had a big drugproblem that it needed to deal with, both in terms of preventative work and education,and in terms of treatment and advice options available to those addicted to drugs. Freeprovision for the elderly was seen as very important issue, pensioners can't afford entryprices, on top of transport costs. The BME Elders Forum felt that there should be morefree and accessible sports facilities. The older population have contributed a lot to the cityand this should be better recognised. They welcomed the provision of walk-in surgeries.At the LSP Development Morning - one group felt that health inequalities to be asignificant issue for certain areas of the city (East Brighton) and for certain groups -gypsies and travellers. Good to see the LDF's recognition and support in this area. Alsothere was a need for healthy local food, should take into account the specific dietaryneeds of the BME diets. The other group felt that it was important to promote healthylifestyles. Health is a major aspect that should feature specifically in objectives. The roleof walking and cycling should feature as a strategic objective. At the Older People'sCouncil session it was raised that sheltered housing including new developments is notlocated in the easiest places for accessing buses. Nursing homes are closing. Olderpeople are living longer and need support to get out and about. New schemes shoulddeal better with public transport issues.


No credible alternatives resulted from issues and options stage, from the preferredoptions stage or from research evidence other than a do nothing or business as usualoption. Not setting a strategic planning framework for a healthier city would impact onthe ability of the LDF to support the Sustainable Community Strategy's commitment toimproving health and well-being and reducing inequalities in health.


The Sustainability Appraisal considered the preferred option together with a 'business asusual' option. It concludes that the business as usual option is not deemed to be themost sustainable as the Healthy City agenda is importance for the city and is a key themeof the Sustainable Community Strategy. The preferred option was found to be compatibleoverall with the sustainability objectives.

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This preferred option addresses the commitment in the Sustainable Community Strategyto reduce inequalities in health, promote healthy lifestyles and to apply the principles ofhealthy urban planning and the requirement in the draft South East Plan to supporthealthy communities, sustainable health services and an ageing population (S3, S4 andCC11). The evidence base shows marked health inequalities in some neighbourhoods.

The preferred option has primarily changed as a result of amalgamating the originalpreferred options to make a single preferred option. The wording has also been amendedto address comments and to reduce significant overlaps with other preferred options(reference to community facilities is addressed under the Spatial Strategy). Commentsarising from the preferred options consultation include the addition of reference to therequirement for HIA on policy documents. The request to add information on the type ofhealth facilities needed has been added to the supporting text. While the part of theoriginal H3 referring to accessible public domain has been moved to the urban realmpreferred option (CP2). H5 will now be implemented through preferred options SN1 andSN2 relating to delivering sustainable communities.

CP5 BIODIVERSITY


Of the 11 representation, there was general support for Preferred Option OS3 City-wideopen space framework and the promotion of biodiversity conservation, moregeneral comments on open space which related to biodiversity fell into six categories butthe common objection was that biodiversity had not been adequately addressed in thePreferred Options document:

l Development should prevent harm to local biodiversity in accordance with BiodiversityAction Plan objectives and biodiversity policies in the draft South East Plan. Brighton& Hove should be monitoring its contribution towards the national BAP objectives.

l Biodiversity is highly mobile, and cannot be conserved exclusively in predefined areas.Therefore opportunities for biodiversity and habitat enhancements at a range ofscales need to be identified and realised.

l All development should result in net biodiversity increase, not only "major" schemes.

l Biodiversity should be enhanced by actively creating and managing for greaterconnectivity. This should take account of the urban fringe, the council's DownlandInitiative, interconnected urban green spaces and urban fringe land.

l Policies should promote improved access to, enjoyment of, and understanding ofbiodiversity and should recognise the value of urban biodiversity for promotingcommunity cohesion and quality of life.

l Developer contributions are likely to be crucial to the successful delivery of the GreenInfrastructure Network and Local Biodiversity Action Plan.

One respondent felt that the Core Strategy had failed to address the biodiversity policiesin the draft South East Plan, in particular Section D5 and NRM4.

In relation to Preferred Option PRE1 (need for high sustainability standards) it was feltthat more could have been said regarding gains in ecological properties and it wassuggested that the Core Strategy should include a policy that requires all developmentsto conserve and enhance the natural environment and biodiversity, including the delivery

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of a network of accessible, natural green space (Green Infrastructure Network) and LocalBiodiversity Action Plan objectives.

No specific comments relating to biodiversity conservation were made at the consultationevents.


No alternative options were put forward at the Issues and Options stage or the PreferredOptions stage and none emerged from the research evidence, other than a 'do nothing'or 'business as usual' option. It is considered that the previous Local Plan QD19Greenway policy approach did not benefit from a strategic city-wide network approachthat is currently being developed.


The Sustainability Appraisal considered the preferred option together with a 'business asusual' option. It concludes that the business as usual option is not deemed to be themost sustainable as it would not allow for the concept of a green network across the cityto be introduced or reflect the local biodiversity context relevant to the city. The preferredoption was overall found to be compatible with the sustainability objectives.


In the Preferred Options Core Strategy, biodiversity was dealt with through a SpatialObjective and referenced in Preferred Options OS3. However following the consultationresponses it was considered more appropriate to include a separate core policy settingout the strategy for dealing with biodiversity and nature conservation issues locallyspecific which would accord with PPS9 and the draft South East Plan (NRM4) and this isreflected in the wording of the preferred option.

CP6 OPEN SPACECP7 SPORTS AND RECREATION


l There were 11 representations and general support for Preferred Option OS3 City-wide open space framework, key issues related to:

l Lack of a completed open space audit to inform the preferred option

l The need to avoid OS3 becoming a catch all policy to prevent development of anygreenspace regardless of quality or future commercial needs

l The need to make open spaces more existing and interesting, and to minimise anti-social behaviour and promote safety.

l The need to recognise the value of private open space visually, for wildlife and forenjoyment and pride in the city.

l Role of careful management and enhancement of nature space to maintainingecosystems and to meet the aspirations to become an Urban Biosphere Reserve.

There were 11 representations mainly supporting Preferred Option OS4 Enhancingopen space provision through new development. Comments related to:

l The need to complete the open space audit and produce a Developer ContributionsSPD

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l Need for green and open spaces with higher housing density to provide leisure andsport facilities, lack of new provision could increase recreational use of AONB.

l The one objection related to the need for a balance to be sought between the overallbenefit of providing residential development and lack of open space provision.

Other general OS comments were:

l Would welcome the move towards an urban design led approach to assessing theneed for open space requirements and enhancements. Current approach can workagainst the delivery of high quality, high density schemes.

l Important to take into account the links between city open space and thesurrounding countryside, rather than purely focussing on the urban element.

l Support for better public access to the countryside, particularly for disabled andelderly people.

l Whilst important to safeguard environment and open space it is equally important tomeasure potential for economic gain for allocating sites for employment uses incurrent climate of businesses struggling due to lack of sites.

l The open spaces study should take greater account of the intrinsic virtue of theshingle beaches and prevent development encroaching onto them.

l Consider in more detail the areas with inadequate open space and seek to addressthat through planning agreements for the creation of new and enhancement ofexisting green spaces.

l Regard should be to Natural England Guidance and Public Space Public Life Study

Various comments relating to open space, sport and recreation were made at theconsultation events. Some participants at the Area Based Event felt that the centralarea and shopping areas could benefit from additional leisure facilities, others felt careneeded to be taken to ensure facilities were not all centralised so that everyone hadaccess to leisure facilities within their neighbourhood including the elderly, disabled andyoung people. Mixed use development should include open space provision. In the Eastof Brighton participants felt there is need for youth facilities in areas for development.The BME Elders Forum felt that parks do need to be made safer, for everyone, to feelthat they can go there. Elderly people enjoy parks and there needs to be more visiblepatrol in parks. Free leisure provision for the elderly was seen as very important issue,pensioners can't afford entry prices, on top of transport costs with the example of thenew sports centre at Croyden cited. Members of MOSAIC felt that the city has parks thatare generally well-maintained but these are not well-utilised by all sections of thecommunity. An example was given in Hastings (Alexander Park), where the councilorganises events and activities to take place in it every month. In Brighton, such activitiescould include running health eating promotions. It was noted that parks tended to beused by 'middle class' families and that more outreach was needed in order to getfamilies of all backgrounds to see the park as a resource for them also. Finally, it wasnoted that more free toilets were needed in parks. A member of SPECTRUM raisedconcern with high density developments, the need to ensure that light and space ismaintained. At the LSP Development Morning one participant noted that in the outerareas need to make more of access to the Downs and put rural edges to greater use forwalking. Parks and outlying areas need outside space for young people to hang about.At the Older Peoples Council session one participant raised the issue of football pitchavailability, especially for younger teams who are squeezed out by the older players. At223


the Economic Partnership Sites and Premises Sub Group - it was considered by onegroup that there are sites where if development was allowed adjoining green space thespace could be improved as a green park. The city needs to do more to attract visitors tothe city during the week as well as weekends - needs other facilities such as an Ice Rink,etc.

Site Allocations Issues and Option consultation - Open Space Advisory Panel

l The need for open space to be completed to inform approach.

l Mix of views as to whether new/ sites facilities are required or whether people makeuse of access to multi-functional open space.

l Some suburban areas/ deprived areas - many residents are not making full use ofopen space/ proximity to Downs/ countryside.

l Innovative provision should be sought when trying to increase capacity, not just relyon artificial pitches.

l Avoid 'sporting deserts' by natural planting/ features. Natural England standards forresidents to be within 300m of a natural green space.

l Developer contributions could be spent on 'naturalising' sites to increase recreational/sporting capacity of site and also for community play/sports warden to raiseawareness and use of open space.

l Provision for children not necessarily equipped playspace - needs to be safe andwelcoming.


No credible alternative options were put forward at the Issues and Options stage or thePreferred Options stage, other than a 'do nothing' or 'business as usual' option and noneemerged from the community involvement/research evidence.


The Sustainability Appraisal considered the preferred options together with a 'business asusual' option. It concludes that a business as usual option would not be the mostsustainable as it would be contrary to national guidance set out in PPG17 which seeks toensure that open space, sport and recreation facilities are retained/ provided and expectslocal authorities to undertake open space, sports and recreation facility assessment and todevelop local standards and policies. The preferred options were found to be overallcompatible with the sustainability objectives.


In the original Preferred Options Core Strategy, Open Space was covered in PreferredOptions OS3, OS4, and in relation to healthy or active living in H5. The role of allotmentsin providing access to healthy food was also dealt with in H4. Sport and recreation waspartially covered in H2 and indirectly in SC2 and L2. Following the consultationresponses and taking a more strategic approach to the Core Strategy it was felt moreappropriate to combine Preferred Option OS3 and OS4 into one Core Policy on OpenSpace and to include reference to sport and recreation into a separate Core Policy onSports and Recreation. The revised preferred option was informed by PPG17, the draftSouth East Plan (S7) and the recommendations of the draft Open Space, Sports andRecreation Study. Biodiversity and nature conservation is now covered in CP5.

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CP8 SUSTAINABLE TRANSPORT


PST1 Sustainable transport strategy - 18 responses were received and respondentsgenerally supported the sustainable transport policies although there was concern thatover intensification of development could attract more private car journeys and worsenthe environment for pedestrians and cyclists. Developers supported sustainable transportimprovements to serve their development schemes. SEERA sought greater expression ofsupport for Regional draft policy T3 regarding "spokes" to adjacent areas.

PST2 Contributions to sustainable transport facilities - 9 responses received, four ofwhich support the option and sought increased awareness of links outside the city andthe need for financially sustainable transport; two representations of partial supportseeking assurances regarding support for cycling and walking in the urban fringe givingaccess to the AONB/ proposed National Park; and three objections. The objections wereto the current operation of sustainable transport contributions, sought under existingLocal plan policies, rather than to the principle of contributions. The second were from adeveloper seeking reassurance that transport contributions would not prejudice theviability of new developments. The third related to concerns of east-west connectivityand severance across the city.

PST3 Transport assessments - 8 responses were received including 6 of support and twoobjections; from a developer seeking reassurance concerning the scope of contributionsfor sustainable transport and concerns of east-west connectivity and severance across thecity.

PST4 Road safety and air quality measures - 15 responses were received 5 of support,5 of qualified support and five objections. Supporters considered that cycle transfershould be facilitated and that Park and Ride would cut pollution and congestion andreduce C02 emissions thereby improving air quality. The opponent of Park and Rideconsidered that it could lead to congestion and extra traffic in the urban fringe. Partialsupporters were concerned that more than half of visitors/locals still use and need a carwhich could be kept out of the town centre by effective Park & Ride and other transportmodes but that the operation of car parks and parking fines should not be seen as afiscal measure but seen as a way to encourage visitors. The bus operator noted that'essential business traffic' may need regulating and enforcement if it impacts on trafficflow of public transport.

Network Rail considered that the idea of Rail Transfer Station was proactive in its concept,but requested that a greater explanation of rail transfer stations should be provided sinceits primary role is to maintain the railway infrastructure and it might not be in a positionto fund freight transfer.

PST5 Public realm - Five representations were received to preferred option PST5, threeof support and two objections; one felt the option did not relate to transport section, theother raised concerns of east-west connectivity and severance across the city.

At the Area Based events the following comments were made; the rail network couldbe better used, more/moved stations to serve the north of the city more effectively. Citycentre congested and east-west transport links need improving. Too much traffic aroundthe RSCH. Need to take development pressure off seafront and A249. Difficult to getaround Hove by public transport and the railway acts as a north-south barrier. 'Rat runs'and traffic issues around some industrial areas in Portslade were also mentioned.225


Members of MOSAIC viewed sustainable transport as the key priority. Parking is aproblem; buses are expensive with real time information less available in East Brighton.There should be more night time buses and better weekend train services betweenBrighton and London. The BME Elders Forum felt public transport had improved andfree bus travel helped to go shopping in the city centre. There was need for park andride. At the SPECTRUM event it was felt that greater thought should be given to theroute of night time buses - going through unsafe areas e.g. West Street. At theEconomic Partnership Event one group felt that transport was a major issue; needgreater synchronisation between major projects and transport infrastructure; park andride (3 sites north, east and west) is essential to the future success of the city in terms ofbusiness and tourism. Another group felt the city centre office developments still needcar parking provision and development opportunities should be on sustainable transportcorridors. At the LSP Development Morning - transport was the focus of one group'sdiscussion. Several were concerned that increased densities would lead to greater trafficand there is not enough road space or parking space. Others felt that public transportshould therefore be improved, better public transport links to outlying areas rather thanrelying on cars. At the Older People's Council session the need for new developmentschemes to deal better with transport issues was raised. There was concern that in 20years time the city's road would be gridlocked. There was support for park and ride. Atthe Schools Feedback sessions the need for more and cheaper bus services and betterreal time information was raised. An issue of road safety was also raised - betterpedestrian crossing and safer cycling.


To disperse development across the city rather than concentrate it on sustainabletransport corridors to reduce levels of congestion on these corridors.

Business and usual or do nothing approach.


The Sustainability Appraisal considered the preferred option together with an option todisperse development across the city rather than on sustainable transport corridors toreduce levels of congestion and a 'business as usual' option. However it should be notedthat this option would be at odds with the preferred approach to accommodatinggrowth in the city that included an accessible led approach (Option A - Accessibility-ledApproach). It concludes that the dispersal option is unlikely to reduce congestion andimprove air quality.


The revised preferred option is a combination of PST1 to PST 4 in the PromotingSustainable Transport section of the previous Preferred Options Core Strategy. PST5dealing with the public realm is now dealt with by Preferred Option CP3. Additionalcomments were received in relation to the role of Brighton & Hove as a regional transporthub in the draft South East Plan (T1). The city's hub status is now reflected in the revisedpreferred option CP8. The revised preferred option is considered to reflect the localpriorities set out in the council's Sustainable Transport Strategy and Local Transport Planand address the findings of the interim Transport Assessment (May 2008).

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CP9 DEVELOPER CONTRIBUTIONS


DC 1 Developer Contributions Priorities (7 representations) - General support for theprinciple that developers should contribute towards providing the necessary physical,social and community infrastructure:

l Support for links with policies (EQIA), and necessary development across the city.

l Support for evidence base of current sports provision and a Playing Pitch Strategy.

l Support for contributions that will be crucial for the successful delivery of the GreenInfrastructure Network and Local Biodiversity Action Plan, and improved access andinterpretation in the countryside.

l Suggestion for contribution towards strategic transport rail links.

l The need for compliance with government guidance and recognition of the need toachieve a balance between aspirations of investment within regeneration areas andpotential benefits arising from such proposals.

DC 2 Developer Contributions approach (16 representations and 6 more general DCrelated representations) Support generally on ensuring contributions are secured andidentified within an SPD:

l Support for cultural facilities requirements identified in SPD.

l Need for completed open space audit to support developer contributions for openspace and sports facilities.

l Concern that funding for utilities infrastructure from new development should besought from developers rather than burdening existing customers with increase incharges.

l Objection to any blanket approach to developer contributions and that these shouldnot affect viability.

l Network Rail felt that where it has been identified that rail patronage has increasedas a direct result of new developments contributions to transport links includingstation enhancements should be sought. Would also welcome the commitment ofthe council of pooling planning obligations from numerous developments to mitigatetheir combined impact upon the railway.

l The PCT objected, they felt that if would be more effective for health care provision ifin key areas, the council reduces affordable housing requirements and insists onadequate space being made available for a large GP surgery.

l The Brighton & Hove Housing (RSL) Partnership felt a lower tariff should be set foraffordable housing to reflect the lower development values and because it servicesthe needs of existing residents rather than newcomers. To incentivise affordablehousing provision they propose for change of use sites which deliver 100%affordable housing, commuted sums should be waived and for standard projects,tariff set should not undermine the overall development viability.

At the LSP development morning it was suggested that developer contributions shouldbe used to fund these community facilities such as playspace. At the SPECTRUM event itwas felt that when developer contributions are considered for major new developments,space for community facilities be sought for communities with demonstrable levels of227


unaddressed need where a shortfall of such facilities has been identified. This might focuson geographical communities within areas of social and economic deprivation, but shouldalso seek not to exclude, by default, non-geographically based communities of interestwithin the city by focussing solely or even primarily on a neighbourhood approach toservices. Developer contributions should be supported by planning policy development,subject to proper consultation with the communities of interest around their specificneeds, and based on available statutory and community research.


No credible alternative options were put forward at the Issues and Options stage or thePreferred Options stage, other than a 'do nothing' or 'business as usual' option


The Sustainability Appraisal considered the preferred option together with the 'donothing' option. It concludes that the 'do nothing' option is not deemed to be the mostsustainable and would be contrary to government guidance which requires that the LDFcontain an up to date generic policy regarding developer contributions and further detailsof its application set out in a Supplementary Planning Document. Overall the preferredoption is seemed as compatible with the sustainability objectives.


The Preferred Option supports the priorities of the revised spatial strategy and localpriorities set out for the Development Areas, where Developer Contributions should besecured. The Policy supports national and regional policy as well as local objectives forachieving the spatial strategy and visioning for the city.

It was considered appropriate to amalgamate the objectives of the original preferredoptions DC1 and DC2 into one Core Policy as DC 2 set out the intention to prepare aSupplementary Planning Document on Developer Contributions.

CP10 MANAGING FLOOD RISK


PRE3 Managing Flood Risk:

Of the seven representations, 6 supported the preferred option to manage flood risk.

l However the Environment Agency objected to SS1 (spatial Strategy) as it did notdemonstrate how the selection of broad locations has been informed by thesequential test (particularly the location at Brighton Marina) and therefore had majorconcerns regarding the soundness of the Core Strategy and the SustainabilityAppraisal. Their objection was on the grounds that no SFRA has informed the optionsand the sequential test had not been applied to the selection of broad locations. TheSFRA should be used to inform the broad location of development in the CoreStrategy and the location of sites in the site allocations DPD and other LDDs at thepreferred options stage. A flood risk assessment (FRA) should be undertaken prior toany re-development due to the risk of flooding in the Shoreham Harbour area.

l Southern Water suggested that new development tends to extend the area ofimpermeable ground, which can increase the risk of flooding as a result of highertotal and peak run-off. Development must therefore incorporate suitable

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arrangements for surface water drainage to minimise the risk of flooding and toensure that the risk of flooding is not increased elsewhere Also that in locationswhere SUDS are not appropriate all new development should drain surface waterseparately from the foul sewerage system, to provide for more efficient use of thefoul sewer, and reduce the risk of foul water flooding. This is consistent with PPS25,Annex F, and The Interim Code of Practice for Sustainable Drainage Systems,published by the National SUDS Working Group, July 2004. Southern Water wouldwelcome the opportunity to comment on the detailed policy text before thedocument is submitted to the Secretary of State.

l One respondent was concerned about the capability of the infrastructure, such aswater and sewerage; to cope with the increase in development, suggest this may beshould have been addressed in the preferred options.

l SEEDA felt it would be useful if the Core Strategy had a commitment to minimisepollution and to actively seek improvements in water and air quality and to reducenoise pollution, in line with policies NRM1, NRM2, NRM7, T1 and NRM8 of the draftSouth East Plan.

No comments were raised on this issue at the consultation events.


No alternative options were put forward during community involvement at the issues andoptions and preferred options stage or emerged from the research evidence. The onlyalternative is therefore a 'do nothing' or 'business as usual' option.


The business as usual approach would not reflect the new guidance or requirements ofPPS25 Flood Risk or reflect the recommendations of the Strategic Flood Risk Assessmentit was therefore not considered the preferred approach.


The completion of the Brighton & Hove Strategic Flood Risk Assessment has meant thatthe Revised Preferred Options document, and in particular the refreshed spatial strategyhas been informed by the findings of the SFRA and has been reflected in the revisedSustainability Appraisal. The findings of the SFRA have also been reflected in therefreshed preferred option on managing flood risk to accord with PPS25 Developmentand Flood Risk and the draft South East Plan (NRM3) but reflecting the localcircumstances.

CP11 HOUSING DELIVERY


AH1 New housing provision, mix and standard (24 representations) - consultationdemonstrated a wide acceptance that the city should plan to meet its own futurehousing needs. The proposal to provide new housing in accordance with Regional SpatialStrategy requirements was generally well supported at the Preferred Options stage. Therewas a general acceptance and understanding that the overall target for new housingdevelopment for Brighton & Hove as set out in the South East Plan was a requirementproviding the appropriate context for the amount of new housing development over theplan period. The development industry expressed concern that there should be some

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flexibility for the market itself to determine the appropriate mix of housing types andsizes in individual schemes and that PPS3 housing mix and type policies could be toostringent and inflexible. Some specific groups were identified for special consideration, forexample, the housing needs of students and the elderly.

AH2 Necessary facilities to serve new developments (11representations) wasgenerally well supported and people expressed strong concerns regarding the need toprovide/secure physical and social infrastructure that new residential development createsadditional demand for (see also CP9 Developer Contributions).

At the area-based events, those in the central and east areas both raised concerns withstudent housing. The need to ensure there was more provision near the campuses toavoid over-concentration in Lewes Road and to avoid conflicts with families living inCoombe Road/ Bear Road neighbourhood. In the West area workshop there was concernabout the loss of family houses to flats in Hove and that housing sizes were gettingsmaller. SPECTRUM felt that the Core Strategy needed to think about the provision foryoung, old and for LGBT families and also to recognise that elderly men are unhappy inmainstream sheltered housing as they often are excluded and face homophobicbehaviour. At the LSP development morning one workshop discussed the need toimprove housing tenure and type. The Older People's Council response to the CoreStrategy raised the concern of the location of sheltered housing, the need for these to belocated in areas easily accessible by buses. Another suggestion was that families shouldbe encouraged to move to areas with appropriate family housing e.g. Whitehawk to givea better social housing. There was also a concern about the impact of student housingon family housing. At the feedback session with Blatchington Mills School, it was feltthat the city needed more places for homeless people.

Site Allocations Issues and Options Consultation - Advisory Panel Meeting -Housing and Major Mixed Use Site Development

l Mixed use development provides good opportunities for further residentialdevelopment within the city but city centre sites don't often lend themselves tosecuring family-type housing and associated facilities. PPS3 requirements may help tostrengthen negotiations for securing a more diverse mix in residential development.

l Issues regarding the form and mix of housing - matching this to household types andwhat people want. Difficulty regarding the provision of family-sized dwellings in highdensity developments - which are frequently flat/apartment type. Raises the questionof low/medium density development on the urban fringe.

l Issues regarding open space quality and use - consider whether there are situationswhere some open space could be lost and/or reorganised and residentialdevelopment intensified alongside improvements to public open space.

l Flexibility on employment sites may not always be advantageous in terms ofresidential enabling development - all associated policy requirements may renderresidential development not helpful. Need to retain some of the 'not so shiny'employment premises - provide for services/business that help the city to function.

l Issue of student accommodation - needs to be taken account of alongside otherhousing/accommodation demands in the HMA. Providing bespoke studentaccommodation could free up family units within existing housing stock but need toconsider how to encourage provision.

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l Residential development in outlying/neighbourhood areas - in order to change image,raise profile and secure greater mix in terms of tenure balance may need to considera waiver on affordable housing requirements. However, the need for key-workerhousing for young couples/families is also a factor to consider (recruitment issuesfacing health/education organisations).


No alternative options were put forward at the Preferred Options consultation stage. A'do nothing' option would not be acceptable as government guidance and the regionalspatial strategy, the draft South East Plan, set out specific requirements for the delivery ofnew housing within local planning authority areas.


The Sustainability Appraisal considered the preferred approach and found that thedevelopment of new housing across the city raised several uncertainties and negativitiestowards the sustainability objectives and it therefore recommended certain mitigationmeasures. These related to biodiversity, sustainable transport infrastructure, urban design,sustainable urban drainage and water efficiency measures as well as ensuring theprotection of the coastline. New housing should meet BREEAM excellent standard/ a highlevel Code for Sustainable Homes as well as be accessible to health services, education,jobs and locally produced healthy food and waste management. It is considered thatthese issues will be addressed through CP1 Sustainable Buildings, CP5 Biodiversity, CP6Urban Fringe and SN1 Sustainable Neighbourhoods.


The revised preferred option set out above develops the previous preferred options AH1and AH2. It also develops policy in accordance with government guidance in 'PlanningPolicy Statement 3: Housing' which was published after consultation on the PreferredOptions. This specifically refers to the need for policies in local development plandocuments to be more specific about the mix of housing (across all tenures) required andto clearly set out a strategy for the planned location and delivery of new housingdevelopment. The revised preferred option accords with the housing requirements set outin the draft South East Plan (SCT7). The revised Preferred Option has also been informedby the recommendations of the Strategic Housing Market Assessment and the interimfindings of the Strategic Housing Land Availability Assessment.

CP12 AFFORDABLE HOUSING

Summary of Preferred Options consultation:

Preferred Option AH1New housing provision, mix and standard (24 representations)consultation demonstrated a wide acceptance that the city should plan to meet its ownfuture housing needs.

Preferred Option AH3 Allowing 'flexibility' on some employment sites to allowenabling residential development (8 representations) was generally well supported atPreferred Options stage as this would help secure additional affordable housing for thecity. Any enabling residential development on employment sites, like all residentialdevelopment, would be subject to policy requirements for affordable housing. Somegroups felt that if this helped avoid some sites remaining undeveloped for long periods of231


time this would be an advantage. Brighton & Hove Economic Partnership and SussexEnterprise were concerned that there should be no net loss of employment land/space inenabling schemes.

Preferred Option AH4 Increase proportion of affordable housing from new sites(24 representations) - there was strong support for a higher percentage of affordablehousing (higher than the current adopted local plan policy which seeks 40% affordablehousing on appropriate sites) and also support for smaller schemes making provisiontowards affordable housing from many local community groups and individuals. Thedevelopment industry had strong concerns regarding development viability and deliveryissues should a higher percentage be proposed. Other groups were concerned thataffordable housing is not really that affordable and that a lower percentage requirementmight make the affordable housing more affordable. The developing RSLs (RegisteredSocial Landlords) in the city expressed particular support for the current local plan targetof 40% which has enabled the delivery of significant amounts of affordable housing andis now clearly accepted by the development industry in Brighton & Hove. They believe ahigher percentage would undermine viability (and confidence) at individual scheme leveland reduce the overall amounts of affordable housing gained across the city. This groupalso support commuted sums for smaller and have indicated that they would supporthigher levels of affordable housing on employment sites.

At the Area-based Event, the central area workshop felt that the council should gofurther than its 40% requirement for affordable housing. At the East area workshop itwas felt that the Eastern Road area needed more affordable housing and an emptybuildings strategy to bring more buildings back into use. MOSAIC interviewees agreedwith the focus of housing and affordability in the Core Strategy. However they felt notenough was being done to address the housing problem and making cheaper housingaccessible to all. Many families are finding it difficult to access affordable accommodationlarge enough for their needs. The BME Elders had concern with private developersproviding affordable housing, and whether in the long-term they would remainaffordable. There should be flexibility so that families could move to smaller houses ifthey wanted and there should be new council housing. SPECTRUM supported thepreferred option on affordable housing has this has a big impact on LGBT community -particularly young people moving into the city. There is a myth of the pink pound;housing inequality is a problem for the LGBT community. There was also a concern thatnew HMO legislations may result in a decline of provision.


There was strong support at the Preferred Options consultation for measures to increasethe proportion of affordable housing secured from appropriate new development. Oneoption would be to increase the target percentage for affordable housing above thecurrent Local Plan level (40%). Another option considered was to require a contributionto the city's affordable housing from smaller development sites (those of less than 10units). Other consultation responses felt that a lower target for affordable housing wouldencourage more sites to come forward for development and affordable housing could bemaximised as a result.

In response to the range of consultation responses, the city council commissioned an'Affordable Housing Development Viability Study' to test the viability and deliverability ofthe two options set out above. The consultants were also asked to comment on thesuggestion that a lower percentage requirement for affordable housing would encouragemore sites (in overall terms) to come forward for development. The 2007 Viability Study

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updates and builds upon an original development viability study carried out in 2004 toinform the Council's Local Plan at that time. The updated study was also required to testthe 2005 Housing Needs Survey recommendation to increase the percentage ofaffordable housing required on suitable sites to 45%. The results of the 2007 ViabilityStudy have also been reviewed in the 2008 Strategic Housing Market Assessment.


The sustainability appraisal considered that the option of setting a higher proportion ofaffordable housing would not be a viable option as the 2007 Viability Study found thatthis would stretch viability too far and may therefore jeopardise development. Whilst theoption of a 'sliding scale' of contributions to affordable housing (commuted payments)was recommended by the 2007 Viability Study, the Strategic Housing Market Assessment(2008) suggests that the cost and resource implications of negotiations would need to beweighed against the financial contributions to affordable housing of this 'sliding scale'approach. Therefore the appraisal concluded that the preferred option would be the mostappropriate. However mitigation measures would be required. Developments containingaffordable housing must incorporate measures to increase biodiversity, not be situated ondesignated employment sites, be accessible to health services, education, jobs and locallyproduced healthy food and submit a waste management plan. It is considered that theseissues would be addressed by CP1 Sustainable Buildings, CP4 Healthy City, CP5Biodiversity and CP15 Strategic Employment Sites. Uncertainty was expressed as towhether the cost of providing affordable housing may conflict with the cost of providingsustainable homes. It should be noted that the government sets environmental standardsfor affordable housing provided by Registered Social Landlords. The deliverability ofaffordable housing should be kept under review as part of ongoing monitoring of arange of factors such as site supply, housing market trends, needs and local affordability.


The revised preferred option develops the preferred options AH1(b), AH3 and AH4 fromthe original Preferred Options document. It also develops policy in accordance withgovernment guidance in 'Planning Policy Statement 3: Housing' which was publishedafter consultation on the Preferred Options. This specifically refers to the need for policiesin local development plan documents to be more specific about the tenure balance andmix of affordable housing required. It has also been informed by the findings of theHousing Viability Study and the Strategic Housing Market Assessment and has regards tothe need to maximise affordable housing provision in the Sussex Coastal Towns as set outin the draft South East Plan (SCT8).

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CP13 HOUSING DENSITIES


No specific preferred option on housing density was included in the Preferred Optionsdocument but the supporting text to the Spatial Strategy (SS1) and Preferred OptionUDC1 addressed the issue of raising density. Responses to Preferred Option AH1 are alsorelevant.

Written Responses

SS1 Spatial strategy - the general approach of raising density on brownfield land in thencity, and of identifying key areas for significant development at higher density, wasbroadly supported.

UDC1 Standard, design and density of development- the general approach of raisingdensity within the built-up area of the city was largely supported, subject to a mixed-useapproach to major sites.

AH1 Housing provision, mix and standard - planning to provide new housing to meetthe target set for the city in the draft South East Plan was largely supported. Securing anappropriate mix of accommodation in terms of type and size was also largely supported,though the development industry want to ensure that there is some flexibility for themarket itself to determine the appropriate mix of housing types and sizes in individualschemes. Several respondents stressed the need to provide sufficient family homes. Onerespondent referred to the need to reflect Government guidance on housing densitylevels.


An alternative option considered was to set a lower minimum requirement across the cityincluding the Development Areas to the PPS3 minimum of 30 dwellings per hectare(dph). Also a 'do nothing' or 'business as usual' option. This would involve relying onexisting Local Plan policy approach, which is more general and does not set targets.


It was felt that the preferred option would be compatible with the sustainabilityobjectives and would make the best use of previously developed land and prevent theneed to develop on greenfield sites around the city as well as providing specific targetsrelating to residential density in contrast to the 'business as usual' option; although theimpacts were considered to be the same. The lower density option raised uncertainty asto whether the city's housing target could be met and would be a less efficient use ofbrownfield sites. Mitigation measures were indicated related to biodiversity, sustainabletransport infrastructure, urban design, sustainable urban drainage, water efficiencymeasures and ensuring the protection of the coastline. New housing should meetBREEAM excellent standard/ a high level Code for Sustainable Homes and be accessibleto health services, education, jobs and locally produced healthy food and wastemanagement. It is considered that these issues will be addressed through CP1 SustainableBuildings, CP5 Biodiversity, CP6 Urban Fringe and SN1 Sustainable Neighbourhoods.


The preferred option reflects the advice in paragraph 47 of PPS3 and takes into accountthe regional density target in the draft South East Plan (H5) and the recommendations of

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the council's Strategic Housing Market Assessment. The preferred option is considered tobe a positive response to the need to make the best use of the limited amount of landthat is available for housing in Brighton & Hove. Higher density housing in suitablelocations can make a significant contribution towards sustainable neighbourhoods, whilstat the same time reducing pressure for the release of land elsewhere, such as on theurban fringe. This approach was broadly supported during public consultation andinvolvement. It is considered more effective to have target figures within the policy inorder to effectively monitor whether the policy has the intended effect, particularly withinthe Development Areas set out in the Spatial Strategy.

CP14 GYPSIES AND TRAVELLERS

Summary of the Preferred Options consultation:

At the Core Strategy Preferred Options stage (November 2006 - December 2006), the citycouncil approached representative groups for advice regarding appropriate and effectiveways to involve gypsy and traveller groups in the consultation process.

Preferred Option AH1c was supported the national organisation Friends, Families andTravellers (FFT) based in Brighton. FFT advised the council that it would be moremeaningful to engage with gypsies and travellers once potential sites were beingconsidered. FFT also advocate a separate Development Plan Document specifically forgypsies and travellers and a more pragmatic approach to site identification allocation.


An alternative 'do nothing' option is not appropriate as government guidance nowestablishes that local planning authorities must make appropriate provision for gypsy andtraveller accommodation needs. In terms of the Core Strategy DPD, the appropriate policyapproach is to acknowledge that the regional spatial strategy (The draft South East Plan)will set pitch requirements and policy must also clarify the approach to siteselection/location.


The Sustainability Appraisal considered a 'business as usual' option but recognised thatdue to government guidance it was not a viable option. The Preferred Option was foundto be compatible with sustainability objectives.


Consultation at the Preferred Options stage demonstrated wide acceptance that the cityshould plan to meet its own housing/accommodation needs which includes makingappropriate provision for the gypsy and traveller community (AH1c). Representativegroups welcomed the inclusion and specific reference to the need to address theaccommodation needs of gypsy and traveller groups. The revised Preferred Option hasbeen developed in accordance with national and regional planning guidance and thefindings of the sub-regional Gypsy and Traveller Accommodation Assessment (GTAA) -the East Sussex and Brighton & Hove Gypsy and Traveller Study 2006.

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CP15 RETAIL PROVISION


Whilst out of the 32 representations there was support in general for the city's existinghierarchy of shopping centres, with regular monitoring to check their performance andability to serve their purpose and support for new development within the boundaries ofour shopping centres:

l One respondent queried whether it was appropriate to focus significant retaildevelopment to Brighton Regional Centre at the expense of other centres;

l Another respondent queried whether London Road Town Centre should be re-designated as the northern part of Brighton Regional Centre.

l The suggestion of designating a new district centre in the area including andsurrounding the Co-op/ Coral Greyhound Stadium on Neville Road, North Hove wasalso put forward by another respondent.

There was also:

l Support for a sustainable mix of shops and other uses, avoiding major concentrationsof other uses such as restaurants and cafes.

l Support for a sustainable network of local centres and parades to allow localcommunities equal access to fresh food and services.

l Support for larger new shopping units in Brighton Regional Centre, possibly throughthe expansion of Churchill Square in conjunction with the Brighton Centreredevelopment, with a need for more department store representation.

l The need for any new edge or out of centre retail development to be assessed inaccordance with the national guidance on Planning for Town Centres - PPS6.

l One respondent suggested that support should be given to proposals for new retailfloorspace in other locations (including retail parks) that are accompanied byimprovements to public transport and accessibility.

l Concern regarding City Centre parking provision associated with future new retaildevelopment.

The retail issue was not widely discussed at the events. At the Area-based Event, thewest workshop felt that there needed to be better opportunities to serve the people inthe north of Hove, and the potential for shopping areas on the fringe to strengthenneighbourhoods (especially for older people) by providing more accessible local facilities.At the BME Elders Forum discussion it was noted that the BME community had someof the healthiest form of cooking - one member welcomed the commitment to supportlocal food and allotments. At the SPECTRUM event, one attendee felt that the role of StJames Street shopping area should be emphasised and the importance of sustaining itsleisure, retail and business role should be acknowledged and recognised in the CoreStrategy. At the LSP development morning one workshop discussed whether outlyingareas should be more self-contained with local shops for everyday convenience needs orwhether people would use them. There was a similar discussion at the Older People'sCouncil feedback session. At the schools feedback session, children from DorothyStringer School also raised the importance of using local shops but also that ChurchillSquare could be improved with more benches and landscaping.

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Retail and Tourism Advisory panel:

l Brighton Centre redevelopment does provide potential for retail in conjunction withChurchill Square - there is demand for additional retail space in Churchill Square anda department store.

l Opportunities in regional centre are limited and must not be isolated. Possibleopportunities included West Street, Bartholomew Square, Black Lion Street andWestern Road.

l Independent retail role of North Laine needs to be protected.

l Before new retail site opportunities need to have a cohesive transport strategy. Needfor park and ride.

l Recognised linked tourism and retail trips made to the regional centre.

l Need to spread retail growth between Hove, Brighton and Marina with a clearstrategy.

l London Road - opportunities for new retail formats and niche formats.

l Hove Town centre - becoming more attractive - viable for a department storeopportunities limited although unless Hove Town Hall became available.

l Retail warehouse opportunities along Lewes Road e.g. Pavilion Retail Park.

l Seafront - there were seen to be opportunities for retail - arches and redevelopmentof West Pier. However this needs to be balanced with tourism/ leisure opportunitiesand there were considered to be poor links between the seafront and shopping areas.

l St James Street and Portland Road were also seen as having opportunities moreintensified retail development.

Responses to Spatial Issue 13 - finding new sites for retail development

New retail facilities should be focused at the city centre, around ChurchillSquare/Western Road, including consideration of the redevelopment of the BrightonCentre site and Russell Square car park. One respondent (Standard Life) noted thatfocusing major retail development in Brighton City Centre is key to maintaining its role asa primary town centre and regional hub, especially in the face of competition fromcentres such as Crawley. The redevelopment of the Brighton Centre was supported in thisrespect, and should be identified as the preferred location for major new retaildevelopment. Large retail development in other centres in Brighton would be resisted inaccordance with the 'scale' arguments set out in PPS6. The only appropriate locationwould be in the city centre, reinforcing the attraction of Churchill Square.

Potential for London Road, Lewes Road and Hove town centre to increase thedensity of their retail floorspace. One respondent notes that concentrating developmenton the London Road/Lewes Road Corridors could increase pollution, parts of which arealready AQMAs. Support for prioritisation for AAPs for London Rd/Lewes Rd. Severalrespondents would like to see a new department store. One suggested that premisesalready exist, e.g. Co-Op London Road. Many stated that the redevelopment of the Co-Op site with retail-led mixed use should be supported. St James's Investments respondedthat the northern part of London Road centre would be most appropriate for departmentstore or large foodstore to provide regeneration and key attractor, and again suggestedthe potential to re-designate the centre as the northern part of Brighton regional centre.237


Lewes Road - small sites regularly become available in this area, and would welcomeinitiatives to improve the variety and quality of retail in this area.

The Marina is an appropriate place for new retail floorspace. The proposed Asdaredevelopment and other new units will help enhance its district centre role.

There were mixed views on the need for out of town retail opportunities.

Some felt that the council should recognise the role that existing out of centre facilitiesplay in serving local communities, such as the Co-op at Nevill Road, and considerdesignating such areas into the retail hierarchy. Cathedral Group was keen to establishthat Circus Street has the capacity to accommodate an element of retail provision as partof a mixed use regeneration scheme. Legal & General noted that due to high capacityand limited sites, the council should consider well connected edge or out of centre sitessuch as existing retail parks, such as the Gallagher and Carden Avenue Retail Parks,where accessibility could be improved for no-car modes, improvements to the design ofexisting buildings and more retail and other uses intensifying the use of the sites.

Whilst Adur District Council commented that there are a number of retail outlets on theA259, which generate traffic and new retail development should be located withinexisting centres. The Highways Agency felt that large scale out of town developmentwould not be appropriate in terms of sustainable development principles. Others couldnot see the need for further retail park type developments. Preston Barracks wasconsidered as an appropriate location for retail development in order to enable successfulregeneration (Crest Nicholson/Hyde).


Following Issues and Options consultation the preferred approach chosen was to direct allnew retail development to existing defined centres and recognise that Brighton RegionalCentre should be the focus of the most significant retail development. The originalpreferred option did not assume that all identified retail capacity needed to be absorbedin existing centres. No alternative options on the hierarchy of centres or accommodatingnew retail development were put forward at the issues and options consultation or fromthe research evidence.

Through the Preferred Options consultation the hierarchy of centres has been questionedby some respondents seeking to changes to the status of existing centres or the additionof a new centre to the hierarchy. Suggestions were also made as to how the identifiedretail capacity could be absorbed through out-of-centre locations (including retail parks).An alternative option therefore considered was to seek to absorb all identified retailcapacity through existing centres and create new centres and another option consideredwas to absorb new development in out-of-centre locations. A business as usual optionwas also considered.


The alternative option of identifying new retail centres was not considered to be the mostsustainable option as it was not clear that locations for new retail centres would be inaccessible locations. The alternative option of absorbing new development in out-centrelocations was considered to be not be the most sustainable option due to accessibilityissues. Retail development in edge of centre/out of centre will not necessarily be on asustainable transport corridor which may lead increased car use in and out of the city,higher congestion rates and an increase in air pollution. Whilst the preferred option was 238


seen to be the most sustainable option, it was identified that congestion levels are highin central Brighton at the weekends and any increase in retail floorspace is likely to leadto an increase in traffic entering the city, however by keeping the main shopping area ina central location, sustainable modes of transport will be more accessible. Theenhancement of the centre as a shopping location may lead to a further use of resourcesand an increase in waste. Mitigation measures were indicated related to resource useand waste management, sustainable transport infrastructure, any new developmentshould meet BREEAM excellent standard and accessibility to locally produced food. It isconsidered that these issues will be addressed through CP1 Sustainable Buildings, CP8Sustainable Transport and CP4 Healthy City.


It is considered that the preferred option is in accordance with the 2006 Retail Study andthe Sustainable Community Strategy and reflects key concerns and aspirations raisedduring public consultation on the previous preferred options document. It accords withthe Government's aims set out in PPS1 and PPS6 and with the relevant policies of thedraft South East Plan (TC2 and TC3) reflecting Brighton's role as a primary regionalcentre. The alternative options were rejected because:

l In light of the findings of the Retail Study and the LR2 Study for London Road andLewes Road it is not considered necessary to amend the hierarchy and status of theexisting retail centres.

l London Road functions as a Town Centre in its own right and the strategy for thearea as identified in DA4 seeks to consolidate and enhance its town centre status.Other opportunities exist within Brighton Regional Centre to absorb new retaildevelopment.

l There is no recommendation in the Retail Study to identify out of centre sites for foodor non-food retail developments in Brighton & Hove within the timescale of the study,to 2016. The council is advised to be cautious towards proposals for new out ofcentre foodstore proposals.

l The approach and tests set out in PPS6 - Planning for Town Centres - with regard toassessing applications for new retail development outside defined centres, should beobserved.

l It is considered that the proposal for a District Centre at the Co-op/ Corals area doesnot accord with the 2006 Retail Study or PPS6. It does not contain the range of usesand functions identified in PPS6 as appropriate for District Centre status. Further thearea is not located on a sustainable transport corridor.

CP16 STRATEGIC EMPLOYMENT SITES


E1- protecting employment sites (12 responses) - enabling development is criticallyimportant for regeneration sites. Suitable enabling development must be identified in theSite Allocations DPD; Greater flexibility; if it is shown that there is not sufficient financialreturn to invest in poor quality stock or if there is little real demand for occupiers thenalternative uses should be considered; should be more no restrictions on moving betweendifferent use classes relating to employment which allows the city's stock to meet thedemand of employment space uses on a flexible basis. This would prevent market239


restraint and enhance the sub-region. The clause prohibiting enabling developments fromprejudicing other businesses in the vicinity was not supported by the EconomicPartnership.

E2 new office floorspace (11 responses) - of two who objected it was suggested thatthe: preferred option should indicate the broad locations considered for new employmentand regeneration to include Shoreham Harbour, this should provide a clearer policy steer;compared to the issues raised at the issues and options stage the preferred option is lessflexible. Appropriate urban fringe locations can and should serve as a complementaryoption and can assist in delivering long term needs of the city i.e. business park andmixed use proposals. Of those who partly supported they suggested; potential sitesshould not blight the existing property, sequential approach should be adopted andfactors such as the potential for economic regeneration and the level of market demandfor office development in these locations should be considered; should also considermechanisms for encouraging refurbishment of existing buildings.

E4 - encouraging flexible affordable business space (11 responses) there were noobjections but of those that partly supported, the following comments were made: moreshould be done to support creative industries, provide better jobs and less land intensive,greater emphasis should be given to them in policy development, site briefs and planningconditions. Mix of business spaces can have agglomeration benefits which should berecognised in LDF.

Event Responses

The Area-based event raised employment issues. At the Central Area discussion ofopportunities for mixed use development, redevelopment and intensification - manyaround London Road and Lewes Road. Many office spaces in the city were suggested notto meet current flexible/ technological requirements. The Universities should attract moreeconomic activity. Similar sites were raised at the Eastern Area discussion where all useoptions should be explored. At the SPECTRUM event the importance of St. James Streetarea as the city's Gay Village needed to be recognised. A MOSAIC interviewee raisedissues around business support, affordable rates, mentoring and support for first timebusinesses and support for artisans and crafts people. At the LSP developmentmorning, the issues of skills training and access to jobs for local people were discussedin particular for East Brighton. Importance of tourism to the economy was raised in onegroup - making the city an attractive place. It was queried whether there is a role forplanning in directing business investment, and whether this city is more a leader than acatalyst in the wider region. It was agreed in one group that planning can help tosafeguard the employment sites. Need to ensure small, affordable workspace isprotected. At the Dorothy Stringer Schools feedback session, the need for workexperience and job opportunities to be better advertised was raised.

Responses to Site Allocations Issues and Options Spatial Issue 7 - how shouldemployment land and premises be promoted in the LDF?

There was no consensus on which of the three options should be pursued by the 17respondents. 2 respondents felt the third option was the most appropriate.

Generally in terms of specifying employment uses, the need for the flexibility in howemployment land and premises were promoted in the LDF was most often supported.Several respondents commented that employment functions should be considered inmixed use developments and specific sites were suggested. 240


With regards to enabling development there were a variety of suggestions; that themarket should be left to decide how a particular site comes forward; if there was notsufficient financial return to make reinvestment in low quality stock/ low demand thenalternative uses should be considered; that qualitative improvements in employmentfloorspace could in certain circumstances justify a reduction in the quantum ofemployment floorspace. Others were more cautious; adequate employment sites shouldbe protected from conversion; displacement of necessary and existing uses couldundermine mixed communities. ESCC suggested that there did not appear to be anyjustification for allowing enabling development on all allocated sites. There may be soundsite planning reasons why a wider mixed use scheme on a particular site but this wouldbe better achieved by specific allocations on specific sites rather than criteria based policythat might lead to an erosion of employment potential in the city. Adur DC felt that thecity should not rely on neighbouring authorities for any industrial/ warehouse floorspaceneeds.

Economic Partnership Sites and Premises Sub-group:

Flexibility of uses was a common theme; the market should not be constrained by useclasses. Queried whether there would be future demand for B2 space, B8 had beenconstrained by Local Plan policies yet these could employ as many as B2 and areexpanding. Need space that can be used for different uses. There was also support forenabling development. It was felt to have a role by all of the groups: can take risk out ofspeculative development, can help on regeneration and renewal sites to deliver housing,jobs and transport. No consensus as to whether it should apply to all or some sites. Onegroup felt that enabling development didn't necessarily mean housing. Housing couldend up pricing out employment. Opportunities should be considered on a site by sitebasis. Another group suggested that enabling consents should be judged againstspecified criteria.


Two respondents at the issues and options stage suggested that the council shouldprovide additional business stock on the northern edge of the city on urban fringe sitesas an urban expansion of the city for a mix of uses to provide more flexibility for uses ofcity centre office/ industrial areas or to avoid access and congestion problems. Somerespondents also suggested this at the Preferred Options stage. However it should benoted that the revised preferred Spatial Strategy does not include limited developmentand expansion on the urban fringe, see SA4 Urban Fringe.


The option to allocate the new office floorspace in the urban fringe was found to be lesscompatible with the sustainability objectives then the option to allocate new officefloorspace within an existing urban area and would be unnecessary development ongreenfield sites and would not make the most of previously developed land. It would alsobe likely to lead to an increase in private car use, congestion and air pollution. There wereuncertainties with the option to allow more flexibility of employment uses on identifiedemployment sites. Whether it might result in the loss of cheap industrial uses and nothaving defined use classes might result in a lack of balance of types of employment uses.It was recommended that the preferred option required mitigation regarding reducingenergy use, water use and waste production related with employment sites, sustainabletransport provision to these sites to reduce the need for private cares and new241


developments being required to meet BREEAM excellent standards/ a high level Code forSustainable Homes. CP1 Sustainable Building Design and CP8 Sustainable Transport(which requires travel plans) would help meet these issues.


This revised preferred option is an amalgamation of E1 and E2 and E4 as it was felt thatthree issues were closely related and could adequately be dealt with in one preferredpolicy option. The other change is to identify the safeguarded sites in the Core Strategyas strategic employment site allocations rather than in the Site Allocations DPD. It isconsidered that CP16:

l Would help to meet the city's aspirations for growth and productivity and reducingunemployment in deprived areas (targets in the Sustainable Community Strategy andoutcomes 1- 4 of the Local Area Agreement and the recommendations of theBrighton & Hove City Employment and Skills Plan 2007/8- 2010/11).

l Reflect Brighton & Hove's sub-regional role and influence and its location within apriority regeneration area and the Regional Economic Strategies identification of theBrighton & Hove (Sussex Coast) Diamond as an area of untapped economic potential,with the potential to stimulate prosperity across a wider area.

l Accord with policies in the draft South East Plan (RE2) that seek to protectemployment sites those specifically set out for the Sussex Coastal Towns that seek tobalance the demand for housing with employment growth, and to manage existingemployment sites and premises and prioritise delivering employment development(SCT3 and SCT4).

l Reflect consultation concerns of providing flexibility of uses but note that theEmployment Land Study (ELS) which provides an up to date assessment of need foremployment land did not suggest that any of the sites were unfit for purpose.

l Making no additional provision for new office accommodation might mean thatdemand for land is not met and opportunities to provide additional employmentthrough new investment and regeneration are missed, to the detriment of the futureeconomic prosperity of the city.

CP17 OTHER EMPLOYMENT SITES


E3 - other employment sites (9 responses) one respondent objected to this preferredoption: policy should allow the redevelopment of existing employment sites where thebenefits outweigh any harm caused by loss of employment sites particularly where thereare other employment generating uses proposed. Of those that support/ partly support,clarity was sought: it was suggested that policy should indicated length of marketing; testof redundancy must be strong and evidence based; sufficiently flexible to allow a rangeof business modes to be. If E1 is not amended to introduce flexibility then the restrictionto alternative employment generating uses followed by affordable housing is tooprescriptive.


From the Preferred Options consultation an alternative option considered was not toprotect these other employment sites. Another alternative option would be to not specify

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preferences for live work or affordable housing if these sites and premises are found tobe unsuitable for alternative employment generating uses. A 'business as usual option'was also appraised.


The preferred option was considered the most sustainable as the alternative of notprotecting other employment sites was not recommended because these sites would beneeded for sustainable economic development. Not specifying alternative employmentuses could lead to inappropriate development. The business as usual options wasconsidered similar in effects to option 1, however offering less flexibility to upgrade sites.The potential need for private car use to access these sites was raised. Mitigationmeasures were indicated related to energy use, water use and waste production andsustainable transport infrastructure. Any extensions to employment sites/ or newdevelopment should include sustainability features such as green roofs, energy efficiencymeasures, water efficiency measures or meet BREEAM excellent standard incorporatingenergy efficiency designs through low/zero carbon development and be adaptable toclimate change. It is considered that these issues will be addressed through CP1Sustainable Buildings and CP8 Sustainable Transport (which refers to the need for travelplans).


It was considered that the Preferred Option E3 and E4 could usefully be combined andupdated to reflect the recommendations of the findings of the Creative IndustriesWorkspace study and government guidance in draft PPS4 Planning for SustainableEconomic Development, it would also:

l Help to meet the city's aspirations for growth and productivity and reducingunemployment in deprived areas (targets in the Sustainable Community Strategy andoutcomes 1- 4 of the Local Area Agreement and recommendations in the Brighton &Hove City Employment and Skills Plan 2007/8 - 210/11).

l Reflect Brighton & Hove's sub-regional role and influence and its location within apriority regeneration area and the Regional Economic Strategies identification of theBrighton & Hove (Sussex Coast) Diamond as an area of untapped economic potential,with the potential to stimulate prosperity across a wider area.

l Accord with policies in the draft South East Plan (SCT 3 and SCT4) that seek toprotect employment sites and balance the demand for housing with employmentgrowth.

CP18 CULTURE, TOURISM AND HERITAGE

Summary of Preferred Options consultation

Preferred Option CT1 existing tourism facilities (12 representations) - this optionshould be widened as a generic approach to cover new cultural/ tourist facilities.

Preferred Option CT4 the cultural quarter (8 representations)- led to a view that onlya limited area of the city was perceived as being important culturally and underplays theimportance of the cultural and creative industries that exist across the city. PreferredOption needed to reflect role in regeneration projects and strengthen references tocultural/creative industries in the Core Strategy.243


Preferred Option UDC4 historic build environment (16 representations) - theproposed policy was largely strongly supported. There was a wide range of individualcomments, some expressing opposing views: insufficient reference to contemporarydesign; need to be flexible about micro-technologies for renewable energy; conservationshould not be confined to the 'listed stuff'; in principle conservation should take priorityover major development in some areas; and 'conservation creep' should not impede localbusiness enterprise. One respondent felt that the proposed policy does not reflect thepositive impact of conservation areas. Also concerned that loss of corner shops and smallgroups of shops can have very detrimental impact on the character of conservation areas.English Heritage gave detailed comments on refining and clarifying the wording,including the need to reflect the hierarchy of national and local designations.

General - Several respondents felt that the city's potential as a gateway to the proposedSouth Downs National Park had not been adequately reflected in the culture and tourismsection, nor had the need to proactively integrate the city with its rural hinterland andpromote and recognise important archaeological sites such as Hollingbury andWhitehawk Hill. The needs of older people should not be ignored.

Event Responses:

A MOSAIC interviewee raised the need for support for diversity in terms of culturalheritage, skills and capabilities; and ensure more culturally diverse events are accessible tothe wider community. Comments at the Economic Partnership sites and premisesevent suggested that the Marina needs more tourism attractions. Some felt the city wasnot guaranteed to be a tourist destination. It was generally felt that the Brighton Centreredevelopment would help draw international events/conferences to the city but that thecity needed to do more to attract visitors to the city during the week, other facilities suchas ice rinks were needed. Brighton needed to be a balanced community drawing inpeople as tourists, visitors and workers. At the LSP development morning theimportance of tourism to the economy and making the city an attractive place was notedalthough one participant queried whether the city could regain its conference trade.Although difficult to manage tourism, higher value tourism was considered to be better.At the SPECTRUM event, the role of the St James Street area as the city's 'gay village'and the need to sustain its leisure, retail and business role needed to be recognised in theCore Strategy. The Count Me In survey indicated great support from respondents (80%)for the presentation of LGBT community history. At the feedback sessions with Schools(Dorothy Stringer and Blatchington Mill) the common feeling was that there was notmuch for children to do in the city, they needed more sports and leisure opportunities.The area based events did not specifically discuss conservation issues but the BME EldersForum mentioned the need to clean/restore the Indian Gate to the Royal Pavilion.

Site Allocation Issues and Options Consultation

Cultural/ tourism facilities should be encouraged as part of regeneration schemes and inmixed use developments and located both centrally and spread to outlying areas. Oneview expressed was that the city needed a range of venues/locations to host and attractleisure and tourism events if this sector is to grow and develop. Measures should beconsidered that promote and stimulate the cultural and creative economy and theimportance of theatres should be better reflected. The Theatres Trust made theconnections with former cinemas/theatres and the cultural quarter and suggested anentertainment quarter. More direct reference to the role of the South Downs wassuggested alongside the need to ensure more attractive sustainable links to the South 244


Downs and better provision of information and facilities. The idea of adapting existingbuildings such as Foredown Tower and Stanmer House to improve gateway facilities tothe Downs was put forward. The need to ensure widened access and provision for theelderly and disabled was also raised. One individual expressed concern about the amountof modern architecture in the city and the erosion of the city's historic character;considered that new buildings should all be of traditional design and in traditionalmaterials. Brighton & Hove Arts Commission stressed the important link between thecultural facilities/infrastructure of the city and architecture, both old and contemporary.

Arts and Creative Industries Advisory Panel comments:

l Need to build in flexibility in the plan to manage the change in demand for spacefrom the wider creative industries. There is a role for showcase/ exhibition space/higher end creative industry space in the city centre. However there is a lack ofcheap, vacant workspace/ units for arts, production/ rehearsal space in the rest of thecentre.

l Need to consider whether there is a mechanism to allow the temporary uses ofspaces and sites in the city whilst waiting to be developed. Some potential for shareduse of community buildings but not suitable for all arts.

l Need to move away from traditional use class approach to protecting employmentsites that enable opportunities for arts and creative industries.

l The LDF needs to reflect the principles of the benefits of including arts/ culture withinmixed use developments and links to regeneration and public realm.

Retail, Culture and Tourism Advisory Panel comments:

l There is a clear and recognised relationship between retail and tourism in Brighton,trips are often linked.

l Need to be clear about what the city wants to be before thinking about space andsites. For some it was difficult to see the city as a cultural destination, there were notsufficient museum/gallery offer. Others thought there was a lot in the fringes, of thefestival but perhaps this was hidden by the image of the nightclub culture and notwidely known about compared with Edinburgh. It was discussed whether the cityneeds to have a regional art gallery. Need to think about more modern,contemporary offer e.g. film. Need to make the most of who lives in the city andneed to make existing venues more accessible.

l It was noted that the city's historic architecture is a big tourism draw. It wassuggested that environmental improvements in St James's Street, linked to pedestrianpriority measures, should be considered to enhance the tourism offer.


An alternative approach would be the 'do nothing' option, not to include a preferredoption addressing the linked strategic issues relating to culture, tourism and heritage.


A do nothing option was not considered viable as the currently adopted Local Plan doesnot reflect the priorities in the 2008 Refreshed Tourism Strategy or reflect good practiceguidance on planning for tourism development. The role of Brighton & Hove as a creativeindustries cluster is also not recognised in the current Local Plan. The preferred option

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was found to be compatible with the sustainability objectives. However it should beensured that sustainable building design features are included and are compatible withthe historic built environment.


Following the review of the structure of the Core Strategy Preferred Options andconsultation responses it was considered that an alternative approach for dealing withthose issues identified as relating to tourism, culture and the city's built heritage in UDC3,CT1 and CT4 of the original preferred options document was to draw together theseissues in an overarching core policy in the revised version. This would:

l Reflect the role of Brighton & Hove as a tourism hub and a regionally significanthistoric built environment in the draft South East Plan and a creative industries hub inthe Regional Economic Strategy

l Reflect the policies in the draft South East Plan relating to the built environment,tourism and supporting increased participation in cultural activity clusters (BE7, TSR1,TSR4, TSR7 and S7).

l The protection and enhancement of the historic built environment is central toGovernment advice in PPG15 and the Government's Good Practice Guidance onTourism recommends that, in those locations where the future development oftourism is a key issue, it would be appropriate for this to be dealt with in a CoreStrategy.

l Reflect the priorities of the council's Conservation Strategy, Refreshed TourismStrategy 2008 and the findings of the Creative Industries Workspace Study (2008).

CP19 HOTEL/GUEST ACCOMMODATION


In response to the Preferred Option CT2 - Strategy for Hotel Accommodation

Of the 6 representations, the general response was that the preferred option needed toreflect the findings of the Hotel Futures Study (then underway) in order to give people abetter opportunity to comment. However some comments were made suggesting awider spread of hotel accommodation, linked to regeneration schemes.

At the LSP Development morning it was suggested that the impact of new hoteldevelopments on existing stock could be unexpected but positive as existing hotelierswould need to invest or diversify in their offer.

Site Allocations Issues & Options Document - Spatial Issue 6 - areas suitable fornew hotel accommodation

The following suggestions were made:

l Specific sites should not be allocated; a sequential approach should be followed, witheach site identified on its merits which would better reflect and respond to naturalgenerators throughout the city including regeneration areas (Circus Street currentlyexcluded);

l PPS6 guidance should be applied to the selection of all town centre uses includingarts, cultural and tourism facilities; new hotels should be retained in the city centreclose to visitors and public transport;

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l If the provision is well located it could be a resource for visitors to the South Downsand;

l Additional provision to the current Hotel Core Zone e.g. Brighton Station may be amore sustainable solution to parking demand in the Hotel Core Zone;

l Site selection should be informed by up-to-date environmental information, linkedwith sustainable transport and discourage car use and contribute positively to thecity's ecological network.

l One respondent felt that with 4 large hotels proposed/ being development this wassufficient new provision.

l Adur District Council wanted to ensure that Brighton & Hove's hotel strategy takesaccount of development in Adur and sustainable transport links are essential.


Alternative options considered were to identify specific sites for new hotel development;not to have a Hotel Core Zone but instead to rely on policies that put forward apresumption against change of use (unless unviable), judging each case on its own meritsalong with a business as usual option was considered.


The Sustainability Appraisal concluded that the alternative option to identify specific sitesfor new hotel development did not reflect the findings of the Hotel Futures Study thatfound that there was not a strong need for further hotel developments over and abovethat which is already planned up to 2016. The business as usual option would also notreflect the findings of the 2007 Hotel Future Study which indicated that the current hotelaccommodation zone contained a number of anomalies and given limited availability ofsuitable sites a sequential approach and following PPS6 guidance may be moreappropriate. Removing the Hotel Core Zone could lead to uncertainties and would alsonot reflect the findings of the Hotel Futures Study which indicated that the Hotel CoreZone provided a clear sign and certainty around protection of existing accommodationand its removal could leave the council exposed to residential pressures. The preferredoption was therefore seen as the most sustainable. Mitigation measures were indicatedrelated to biodiversity, sustainable transport infrastructure, urban design, sustainableurban drainage, water efficiency measures, meeting BREEAM excellent standard/ a highlevel Code for Sustainable Homes and waste management. It is considered that theseissues will be addressed through CP1 Sustainable Buildings, CP5 Biodiversity and CP8Sustainable Transport.


The Hotel Futures Study was commissioned by the Council in conjunction with TourismSouth East. This study was adopted by the Council in January 2007 as evidence based forthe LDF. The original preferred option CT2 has therefore been revised and updated toreflect the findings. The revised preferred option also reflects the priorities in theRefreshed Tourism Strategy 2008 and policy TSR5 of the draft South East Plan.

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Proposed Changes to the adopted Local Plan Proposal Map

The council must include within its local Development Framework an adopted proposalsmap, which should express geographically the adopted development plan policies of thelocal planning authority. The current adopted proposals map is the Brighton & Hove LocalPlan Proposals Map 2005. The adopted proposals map can only be changed as a result ofa development plan document being adopted. There are a few Core Policies that relate tosite specific issues which will have implications for the adopted proposals map and willrequire at the submission stage of the Core Strategy a submission proposal map toidentify how the adopted proposals map will be amended or added to. The followingchanges are anticipated:

CP5 Biodiversity - makes reference to a 'green network' of nature conservation features.It is proposed that once this network is finalised it will replace the network of Greenwayscurrently identified on the Proposals Map. The proposed green network can be found inthe Interim Green Networks Study 2008 that accompanies the Core Strategy.

CP10 - Managing Flood Risk - the Strategic Flood Risk Assessment identifies areas ofthe city at a higher probability of flood risk (Zone 3). This Flood Risk Zone will be shownon the Local Plan Proposals Map to accord with PPS25.

CP16 Strategic Employment Sites - with a few exceptions, the list of employment sitesand premises outlined in CP16 is the same as the sites currently identified on the LocalPlan Proposals Map under EM1 and EM2 of the Local Plan and therefore the allocatedsite boundaries shown on the proposals map will be unchanged apart from:

Preston Barracks - proposed that the CP16 designation will cover the whole sitecurrently covered by EM2 and EM17.

Brighton Station Site - is not included in CP16 and therefore the EM1 and EM2designations are proposed to be deleted.

Brighton General Hospital Site - is not included in CP16 and therefore the EM1designation is proposed to be deleted.

Woollards Field - the current EM2 site designation for Falmer Business Park will bereduced in extent to cover the Woollards Field site only.

Village Way North - is not included in CP16 and therefore the EM1 designation isproposed to be deleted.

CP19 Hotel/ Guest Accommodation - following the recommendations of the HotelFutures Study 2007, it is proposed in CP19, that the hotel core area currently shown onthe Local Plan Proposal Map will be amended and re-defined. The proposed boundarychanges are shown overleaf.

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This glossary provides a brief explanation of some terms used in this document. Theglossary does not form part of the Preferred Options.

Academic Corridor

Concentration of three major higher and further education institutions (the Universities ofBrighton and Sussex and City College) along the A27/A270 axis in the Brighton area,which together provide enhanced facilities for high-technology and knowledge-basedbusinesses.

Affordable Housing

Residential accommodation that is provided with a subsidy to ensure that rents/pricesremain at a level that is genuinely affordable by local people whose incomes mean thatthey are unable to meet their housing needs via the housing market.

Air Quality Management Area (AQMA)

Local Authorities in the UK have a statutory duty to review and assess air quality againstthe Air Quality Objectives (AQO). Local authorities have to designate those parts of theirareas where the prescribed objectives are not likely to be met by, or at any point beyondthe relevant deadline as Air Quality Management Areas (AQMA's). The declaration placesa legal duty on the council to actively introduce a range of measures, through an AirQuality Action Plan, to improve air quality.

Ancient Woodland

An area which has had continuous woodland cover since at least 1600 AD.

Appropriate Assessment

Appropriate Assessment is a requirement of the European Habitats Directive. Its purposeis to assess the impacts of the plans and projects on internationally designated sites andnature conservation sites.

Aquifer

Rock that provides a natural underground store for water. In Brighton & Hove aquifers areused to provide drinking water.

Archaeologically Sensitive Areas

These are sites that have been compiled by the County Archaeologist as part of the Sitesand Monuments Record on behalf of the local planning authority, as encouraged inPPG16. These areas are judged to have county and city wide importance and are knownto have archaeological remains or features, although the extent and richness of the site isoften unknown. Some might on further detailed investigation merit designation as aScheduled Ancient Monument.

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Glossary of Terms

Area of Outstanding Natural Beauty (AONB)

Area of high visual quality designated by the Countryside Commission (now CountrysideAgency) as being of national importance under the National Parks and Access to theCountryside Act of 1949.

Biodiversity (Biological Diversity)

The range and variety of life (including plants, animals and micro-organisms), ecosystemsand ecological processes.

Biodiversity Action Plan

At UK level these set national objectives and targets which can be delivered through localBAPs (LBAP). Each action plan describes a habitat or species, quantifies the resource anddefines the objectives and time-limited targets required to manage the resourcesustainably and (if necessary) reverse past declines. Specified agreed actions by keyorganisations can then be undertaken and monitored to assist with meeting theobjectives

BME

Black and Minority Ethnic

BREEAM

British Research Establishment Environmental Assessment Method - the most widely usedmeans of reviewing and improving the environmental performance of buildings since itslaunch in 1990.

Brownfield

Previously developed land. Site containing permanent structures and associateddevelopment, such as car-parking, which can be re-developed for other uses.

Built Heritage (or Historic Built Environment)

Buildings and other structures considered to be of a special architectural or historicquality or interest. Includes, but not limited to, Listed Buildings and Conservation Areas.

Built up area

Extent of area identified within which the development of the city has occurred already.The outer limits of the built up area are defined on a proposals map.

Business Improvement District

A Business Improvement District (BID) is a precisely defined geographical area withinwhich the businesses have voted to invest collectively in local improvements to enhancetheir trading environment.

CABE

Commission for Architecture and the Built Environment - a non-departmental public bodyset up by the Government in 1999 to champion the creation of great buildings andpublic spaces.

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Car Club

A Car Club provides its members with flexible access to the 'hire' of a vehicle. Vehiclesare parked in reserved parking spaces close to homes or workplaces and can normally beused, and paid for, on an hourly, daily or weekly basis.

Children's Centres

The main purpose of Children's Centres is to improve outcomes for young children andto reduce inequalities in outcomes between the most disadvantaged children and therest. Each centre must cover a defined catchment area of around 800 children under 5.

Circular

Government advice published to explain or interpret Acts of Parliament.

Citizens' Panel

A consultation technique that consists of a number of residents of Brighton & Hove whotake part in questionnaire surveys about a wide range of issues of importance to the city.

Climate Change

Accounts for long-term changes in temperature, precipitation, wind and all other aspectsof the Earth's climate. Often regarded as a result of human activity and fossil fuelconsumption.

Communities of Interest

In the Brighton & Hove context, these are any one of eleven identified marginalisedcommunities; the homeless and inadequately housed; lesbian, gay, bisexual &transgender (LGBT); black & minority ethnic communities (BME); people with physicaldisabilities; people with learning difficulties; people with metal health problems; women;people with HIV/AIDS; young people; substance/alcohol mis-users; older people; andtravellers.

Community stadium

A stadium that provides high quality sports facilities to meet the needs of top Brighton &Hove sportswomen and men and the wider community.

Comparison goods

Non-food items in shops.

Concealed households

Adults living within another household because they cannot afford to enter the housingmarket (e.g. young adults living with parents).

Conservation Area

An area of special architectural or historic interest, the character or appearance of whichit is desirable to preserve or enhance. In respect of Brighton & Hove they are usuallydesignated by the city council, though the Secretary of State can also designate them.

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Convenience goods

Food items in shops.

Creative Industries

The creative industries include: advertising; architecture; art and antiques markets;computer and video games; crafts; design; designer fashion; film and video; music;performing arts; publishing; software; and television and radio.

Density (dwellings)

Measure used to describe the numbers of housing units associated with a given area. e.g.dwellings per hectare. Net density includes access roads within the site; private gardenspace; car parking areas; incidental open space and landscaping; and local children's playareas where these are to be provided.

Design Code

A design code is an illustrated compendium of the necessary and optional designcomponents of a particular development with instructions and advice about how theserelate together in order to deliver a masterplan or other site-based vision.

District Centre

See Town Centre.

Downland

Usually treeless open land with only a thin covering of soil on the chalk uplands.

Downland Initiative

A programme of action compiled by the city council to deliver a sustainable downlandlandscape by integrating farming, recreation, biodiversity conservation and landscapeobjectives.

Ecosystem services

Essential life support services provided by biodiversity including air and water purification,storm water run off and climate amelioration.

DPD

Development Plan Document.

East Brighton New Deal for Communities initiative

A Government-funded project that aims to bring about positive change within the EastBrighton locality through a partnership of local service deliverers and the community. It isknown by the acronym 'eb4U' (East Brighton for you)

EcoHomes

See BREEAM. The homes version of BREEAM, it provides an authoritative environmentalperformance rating for new and converted or renovated homes, and covers houses,apartments and sheltered accommodation.

Ecological footprint

A tool that works out the amount of land needed to provide a population with all theirresources and to absorb all their waste. This can be compared with the capacity of thearea to provide natural resources and to deal with the waste and pollution created.

Enabling Development

Development which is acceptable in its own right but generates funds to allow theprovision of a strategic development objective of the local planning authority (e.g. therestoration of a building or the construction or renovation of a much needed facility). Thisterm also applies to development of a type or use which is not designated for thatspecific site on the Proposals Map but that would enable the designated use to be viablyimplemented (e.g. some housing development on a designated employment site).

Environment

Includes the 'natural' environment (air, water, land, flora and fauna) and 'built'environment (buildings and other structures built by humans).

Environment Agency

The leading public body for protecting and improving the environment of air, land andwater in England and Wales.

Green network

A series of interlinked natural green spaces and nature conservation features connectingthe urban area, urban fringe and open downland.

Green wedge

A section of undeveloped land that projects into the urban area from surroundingcountryside.

Greenfield

Site that has not been previously been built on (includes areas such as playing fields,allotments and countryside).

Grey water

Grey water is the water from sinks, baths, showers, washing machines etc.

Gypsies and Travellers

Gypsies and Travellers are persons of a nomadic habit of life, whatever their race ororigin, including such persons who on grounds only of their own or their family's ordependants' educational or health needs or old age have ceased to travel temporarily orpermanently, but excluding members of an organised group of travelling show people orcircus people travelling together as such.

GVA

Gross Value Added (GVA) is an indicator of economic prosperity. It measures thecontribution to the economy of each individual producer, industry or sector.

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Health Impact Assessment (HIA)

HIA is a practical approach that determines how a proposal (such as a developmentscheme or a policy) will affect people's health. Recommendations to 'increase thepositive' and 'decrease the negative' aspects of the proposal are produced to informdecision-makers.

Hectare

10,000 m2

Historic Parks and Gardens

Gardens, parks and landscapes whose character reflects the period (or periods) of theirdesign, and sometimes also the style of a particular designer. English Heritage compilesthe list on the Register of Parks and Gardens of Special Historic Interest in England.

Home Zone

A Home Zone is a street or group of streets designed primarily to meet the interests ofpedestrians and cyclists rather than motorists, opening up the street for social use. Itinvolves creating a street design that makes drivers feel it is normal to drive slowly andcarefully. Features often include traffic calming, shared surfaces, trees and planters,benches and play areas.

Hotel Core Zone

An area identified on a Proposals Map within which tourist accommodation would beafforded special protection by planning policy.

Housing Trajectory

The purpose of a housing trajectory is to track the provision of housing supply over theentire lifespan of a development plan and support the plan, monitor and manageapproach to housing delivery by monitoring both past and anticipated completions.

ICT

Information & Communication Technology

Index of Multiple Deprivation (IMD)

The index measures seven different types of deprivation relating to: income, employment,health and disability, education, skills and training, housing and services, livingenvironment, and crime.

Key worker

A worker whose services are essential to local communities, who need to live close tothose communities and the people they serve. Government guidance targets specificworkforce groups such as teachers, nurses, social workers, fire and rescue officers,probation officers and the police.

Legibility

The degree to which a place can be easily understood and traversed.

LGBT

Lesbian, Gay, Bisexual and Transgender.

Lifetime homes

Housing built to standards to cater for various lifestyle stages, e.g. wider corridors tocater for pushchairs and wheelchairs, scope for adaptations for disability needs, needs ofthe elderly, etc.

Listed Building

A building of national importance due to its architectural or historic interest. They arebuildings which have been included in the Statutory List of Buildings of SpecialArchitectural or Historic Interest. The List is compiled by the Secretary of State(Department of Culture, Media and Sport), with advice from English Heritage and otherspecialist organisations, using agreed national criteria.

Local Area Agreement (LAA)

This sets out priorities for Brighton & Hove over a 3 year period, agreed between thepartners of the Local Strategic Partnership and Public Service Board and centralgovernment acting through the Government Office for the South East.

Local Nature Reserves

Local authorities can designate Local Nature Reserves (LNRs) under the National Parks andAccess to the Countryside Act 1949 through a process that requires consultation withNatural England. Such reserves are specifically managed to promote their special localnature conservation value. LNRs usually create opportunities for people to gain access to,appreciate and become actively involved in conserving nature close to where they live.

Local Transport Plan (LTP)

(Also called the Full Local Transport Plan when it has been approved by the Government).It is the document prepared by the city council which sets out its transport policy andproposals and is prepared in order to bid for Government funding for all forms oftransport.

Low Carbon technologies

Technologies that use grid electricity or mains gas to generate heat or power moreefficiently. They are called low carbon because they result in lower CO2 emissions thanusing mains gas or electricity. These include: geothermal and ground sourced heat pumps(which require electricity to operate pumps); fuel cells (which require electricity to createhydrogen); gas fired CHP; or other district heating systems. The latter two are sometimesreferred to as decentralised or localised energy, as they create heat and/or power local towhere they are used. These technologies are sometimes referred to as microgeneration,producing heat or energy locally on a small scale.

LSP

The Local Strategic Partnership, known locally as the 2020 Community Partnership, andmade up of 32 representatives of bodies or organisations that provide services or whoseactions affect quality of life in the city. Responsible for the Sustainable CommunityStrategy.

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Microclimate

Local climatic conditions.

Mitigation measures

Actions to prevent, avoid or minimise the actual or potential adverse effects of a plan,policy, development, project, etc.

Mixed use developments

A development that contains two or more uses e.g. residential, employment, leisure,community uses.

NAP

Neighbourhood Action Plan

National Park

An area designated by the Countryside Agency under the National Parks and Access tothe Countryside Act 1949 (as amended). The statutory purposes of National Parks areconservation of the natural beauty of the countryside and promotion of its publicenjoyment.

National Playing Fields Association

Organisation with specific responsibility for acquiring, protecting and improving playingfields, playgrounds and play space where they are most needed and for those who needthem most.

Natural England

A statutory body formed on 1 October 2006 with the bringing together of EnglishNature, the landscape, access and recreation elements of the Countryside Agency andthe environmental land management functions of the Rural Development Service. Itsremit is to conserve and enhance the natural environment, for its intrinsic value, the well-being and enjoyment of people and the economic prosperity that it brings.

Neighbourhood Renewal

A Government initiative aimed at bridging the gap between the most deprivedneighbourhoods and the rest of England by tackling five key themes of: poor jobprospects; high levels of crime; educational underachievement; poor health; andproblems with housing and the physical environment.

Net Density

See Density.

New Deal

See East Brighton New Deal initiative.

New Media

A generic term for the many different forms of electronic communication that are madepossible through the use of computer technology. The term is in relation to "old" mediaforms, such as newspapers and magazines.

Node

A place where activity and routes are concentrated.

Park and Ride

A facility or facilities that provide parking for cars and an interchange for transferringpassengers onto public transport, particularly at the approaches to the city.

PCT

Primary Care Trust.

Place shaping

Planning can help to create pleasant, thriving places where people want to live and workin safe and good physical environments with a strong community sense of well-being.Local Development Frameworks - and particularly the core strategies should set out avision for the future of places which is locally distinctive, together with the strategy fordelivering it; create the framework for private and public investment that promoteseconomic, environmental and social well-being for the area; and be founded on goodevidence and have a clear programme for delivery.

Planning Obligations/Section 106 Agreements

Planning Obligations, also known as Section 106 Agreements (under the 1990 Town &County Planning Act), are legal agreements that secure measures and/or controls thatcould not be achieved by the imposition of planning conditions.

Planning Policy Guidance Notes (PPGs)

Statements of government planning guidance on a variety of topics that must be takeninto consideration when preparing development plans or when determining planningapplications.

Planning Policy Statements (PPSs)

Statements of government planning policy which are gradually replacing PPGs (seeabove).

Proposals Map

Map that forms an integral part of the LDF and which identifies sites/areas to whichparticular policies apply.

Public Art

Public art includes permanent and temporary work, art facilities and arts training. Publicart can create and enhance local distinctiveness and help develop a desirable sense ofplace. They often provide important opportunities to involve the local community and willoffer work opportunities to local artists. 258


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Public Realm

This is the space between and within buildings that are publicly accessible, includingstreets, squares, forecourts, open spaces and public and civic buildings.

Rapid Transport System

The Rapid Transport System is one of four major transport priorities for Brighton & Hove.It is a bus-based system that will enhance the public transport network to cater forincreasing travel demand around the city. It will work alongside other modes of publicand provide a direct service between key destinations improving access to employment,leisure, housing and economic opportunities for residents and visitors.

Renewable Energy

Term used to describe energy that occurs naturally and repeatedly in the environment -e.g. energy from the sun, wind, water, land, plant material, as opposed to energy derivedfrom non-renewable resources such as that from 'fossil fuels' e.g. coal and oil.Combustible or digestible waste materials are also regarded as renewable sources ofenergy.

Scheduled Ancient Monument

A statutorily protected building, structure or feature of national importance because of itsarchaeological and historic interest.

Secured by Design

Secured by Design is the UK Police flagship initiative supporting the principles of'designing out crime' by use of effective crime prevention and security standards for arange of applications.

SEEDA

South East of England Development Agency. Responsible for producing the RegionalEconomic Strategy.

SEERA

South East of England Regional Assembly. Responsible for producing the South East Plan.

Sequential approach

The Government's required approach (set out in PPG3) for local authorities to identifysuitable land for residential use and buildings for conversion. Re-using brownfield siteswithin urban areas identified in an Urban Housing Capacity Study is the preferred option,followed by urban extensions and new development around public transport nodes.

A sequential approach is also recommended (in PPS6) for the allocation of land for retailuse. The preferred 'retail hierarchy' (in descending order of preference) is: town centresites where suitable sites or buildings suitable for conversion are available, edge-of-centresites, district and local centres and only then out-of-centre sites in locations that areaccessible by a choice of means of transport.

Sheltered housing

Managed housing units, usually for the elderly with wardens/staff on hand.

Shoreline Management Plan (SMP)

Provides a large-scale assessment of the risks associated with coastal processes andpresent a long term policy framework to reduce these risks to people and the developed,historic and natural environment in a sustainable manner. An SMP is a high leveldocument that forms an important element of the strategy for flood and coastal erosionrisk management.

Sites of Nature Conservation Importance

Sites of Nature Conservation Importance (SNCIs) are designated by local authoritiesbecause of their local importance for nature conservation. In addition to the more'scientific' reasons for designation, the SNCIs in Brighton & Hove have been chosen onthe basis of the real benefits they provide to local communities and have been identifiesin partnership with national and local nature conservation organisations and local people.

Sites of Special Scientific Interests

(SSSIs) are designated by Natural England (the government nature conservation agency)under the Wildlife and Countryside Act 1981. Such sites are of special national interest byreason of their flora, fauna, geological features or landforms.

Small business

A business with fewer than 50 employees.

Spatial planning

Spatial planning moves focus from a land-use planning approach based on regulationand control of land, to a wider more far ranging approach that aims to ensure the bestuse of land by assessing competing demands. To this end social, economic andenvironmental factors are taken into account in producing a policy or decision thatpromotes sustainable development. These factors can include health, education,employment, crime prevention, leisure, biodiversity, recycling, energy etc.

Special Area of Conservation

SACs are designated by the EC under the EC Directive on the conservation of habitatsand wild flora and fauna (The Habitats and Species Directive 1992). The HabitatsRegulations 1994 translate the Directive into UK legislation. SACs are outstandingexamples of selected habitat types important for the continuing wellbeing and survival ofselected non-bird species (birds are protected under their own European legislation). TheDirective states that SACs are to be afforded absolute protection subject to 'imperativereasons of overriding public interest'.

SPD

Supplementary Planning Document.

Spectrum

A Lesbian Gay Bisexual and Transgender community forum.

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Sport England

Sport England/ English Sports Council is a non-departmental public body under theDepartment for Culture, Media and Sport. Its role is to provide the strategic lead for sportthrough advising, investing in and promoting community sport in England.

SSSI

Site of Special Scientific Interest. SSSIs are designated by Natural England under theWildlife and Countryside Act 1981. Such sites are of national interest by reason of theirflora, fauna, geological features or landforms.

Statutory Environmental Bodies

Four Government appointed bodies which give advice and must be consulted forcomment upon Sustainability Appraisals. They are: the Countryside Agency; EnglishHeritage; Natural England; and the Environment Agency.

Strategic Flood Risk Assessment (SFRA)

Created to help appraise, manage and reduce flood risk in relation to the location of newdevelopment in the city. The SFRA will assess all forms of flooding for the currentsituation and will also indicate areas that may be at risk in the future taking climatechange into account

Strategic View

The line of sight from a particular point to an important landmark or skyline.

Sustainable Community Strategy

Document that sets out the vision and plans of the agencies, organisations andcommunities who work together through the 2020 Community Partnership to improvethe quality of life in Brighton & Hove.

Topography

Description of the features of the land including height in relation to sea level.

Town Centre

Town and District Centres serve community needs for both comparison and conveniencegoods shopping, together with a range of other services such as banks, building societies,estate agents, cafes and restaurants. The centres are capable of fulfilling an importantfunction as a focus for the community in the area they serve and for public transport.

Townscape

General view, appearance and character of an urban scene/landscape.

Transport Assessment

A process of looking at the impact on transport of a proposed development. Can rangefrom a simple document setting out the movements by different methods likely to arisefrom a development; to a detailed assessment derived from modelling the likely impact ofthe transport needs of a development and setting out the steps proposed to deal with it.

UNESCO Biosphere Reserve

Biosphere reserves are sites recognised under UNESCO's Man and the BiosphereProgrammes, which innovate and demonstrate approaches to conservation andsustainable development. They share their experience and ideas nationally, regionally andinternationally within the World Network of Biosphere Reserves.

Urban Fringe

Area(s) of land on the edge (usually within 2km) of a city or town where urban and ruraldevelopments and uses meet.

Urban Grain

General layout, pattern and footprint of buildings and streets as viewed overhead in planform.

Urban Heat Island Effect

Urban heat island effect is related to higher summer temperatures in urban areas thantheir rural surroundings. Urban heat island studies refer to the 'urban heat islandintensity', which is the maximum temperature difference between the city and thesurrounding area. Studies correlating urban population and maximum difference in urbanand rural temperatures have shown that there is a very strong correlation between thecity size and heat island intensity.

Windfall Site

A site gaining planning permission for a use which was not previously identified for sucha purpose in the Local Plan or Site Allocations DPD. This term is normally applied inrespect of housing developments on unidentified sites.

Zero carbon development

A development that achieves zero net CO2 emissions from energy use on site, on anannual basis.

Zero carbon technologies

Technologies that harness non fossil fuel energy to create heat or generate electricity, i.e.sun, wind, and water. They are called zero carbon because they produce no carbondioxide (CO2) emissions when producing heat or power. These are also referred to as'renewable' energy sources (solar thermal, photovoltaics, wind turbines, hydropower andcombined heat and power using renewable fuels such as biomass, biodiesel or renewablegas). These technologies are sometimes referred to as microgeneration, producing heat orenergy locally on a small scale.

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For further information contact:The Local Development Team, Planning Strategy & Projects,Brighton & Hove City Council, Hove Town Hall, Norton Road,Hove BN3 3BQ.

� 01273 - 292505Email: [email protected] or visit ourLDF website at: www.brighton-hove.gov.uk