Planning strategy

Carbon Reduction 2021 – Our response

During the spring of 2021 the Committee of Hove Civic Society agreed to explore how the Society could contribute to the aim of making the city carbon neutral. We decided to examine our own activities to see how they could be changed or sharpened up. Our proposals, which are set out under the overriding theme Space for People ,can be viewed here.

Supplementary Planning Documents (SPD)

In December 2020 we commented on the draft Urban Design SPD. Our general comments are as follows:

Design needs to recognise the major challenges on the urban environment today. Climate resilience, liveable cities with an attractive public realm are key issues that need to be considered.

The draft SPD in our opinion fails to pay sufficient regard to these considerations in an overarching way. IF Brighton and Hove is to respond to the climate challenge as councils from various administrations have repeatedly stated then a design guide should major on what this means for new development for example by:

Setting our clear expectations on how to deal with developments that need to rely less on fossil fuels. This has repercussions on car use (see more below), on bringing nature into the city for cooling, pollution control, water management, effective use of energy, imaginative use of building materials etc. A reference to the Brighton and Lewes Downs Biosphere and the contribution design can make to bringing the ambitions of that initiative into our built up areas would also be appropriate.
Dealing specifically with the management of traffic, we must recognise that although we may move towards a shift from internal combustion engines to electric with batteries or fuel cells this won’t deal with the fundamentals of too many tins on our roads. Over 40% of households in some parts of our city don’t run a car – we need to plan for those 40% as much as for those that run cars. Car free developments in the central parts of Brighton and Hove are an obvious answer – and the council has started to recognise this in terms of first thoughts and experiments on cycling and walking. Fundamentally reducing car spaces in new developments gives us plenty of additional land to devote to child play, walking, cycling, microparks etc. HCS believes that a car ratio of .25 per new dwelling in the central parts of Brighton and Hove is an appropriate level for the sustainable city that the council wishes to create. A design guide for the city should illustrate the benefits of such lower car parking standards and how land freed up should be put to use for the benefit of the immediate environment within and surrounding new development sites.

Although the draft SPD states at the outset that it helps the city to achieve its ambition of becoming carbon neutral by 2030, we believe that there is substantially more that needs to be done for the guide to come anywhere near meeting that claim.

Hove Station Neighbourhood Plan

In 2019 we commented on the emerging Neighbourhood Plan as part of the Reg 14 consultation.

City plan

We have been closely involved in trying to shape the policies being developed in the City Plan. Below you can see a selection of our submissions – most recently on the Council’s draft of Part II of the City Plan.

September 2020 – formal representation on City Plan Part II

The Society’s comments focuses on 4 areas where we claim that the plan is unsound.:

Public realm: we believe that for the plan to be sustainable the off-site impact of the large amount of new development in the city needs to be recognised and the pressures on the existing fabric of the city dealt with as far as possible. We propose a public realm policy to deal with this.
Arts and Culture: Arts and Culture is a generally recognised key component of city life and is largely ignored in the plan. We propose a substantial strengthening of existing policies or an entirely new policy.
Street Trees: The plan gives insufficient weight to the importance of street trees and their role in an environmentally sustainable townscape that seeks to contribute to efforts to deal with climate change. We propose an addition that seeks to increase our street tree cover not least in order to mitigate CO2 emissions created by new developments.
Conservation Areas: we believe the requirement of taking into account conservation area management plans only has effect if such plans are prepared. This is the role of the local authority and there should be a commitment to ensure that such plans are being prepared.

Our full representation can be found here…

September 2018 – comments on the proposed Part II of the City Plan:

Hove Civic Society’s full response can be downloaded here (PDF document, 193kB)

March 2013 consultation response:

The final, formal stage of consultation ended in April 2013.

Hove Civic Society’s full response can be downloaded here (Word document, 247KB)

Overview:

The committee support a wide range of policies in the plan. In particular we support the overall housing targets and allocation policies and the proposals for the development and special areas in the City.

We challenge the soundness of the plan in two respects:

We believe the plan should include space standards for new housing developments to prevent housing to be built in the City that is not fit for purpose. We believe this requires an addition to an existing policy and a commitment to produce minimum dwelling standards for new housing in the city; we believe such standards should closely follow the standards now set by the Mayor for London in the London Plan as adopted in July 2011 and in the Mayor’s Housing supplementary planning guidance as adopted in November 2012.

Whilst we welcome the references in almost all policies related to the Development areas to decentralised district heating, we believe such reference should also be made in respect of policy for area DA8 specifically referring to the substantial contribution that Shoreham power station could make to district heating for the city.

Earlier response: July 2012

In May 2012 the Council released a further draft plan for public consultation and this closed in July 2012.

Hove Civic Society’s full response can be downloaded here (Word document, 192.5KB).

Overview:

The Committee of Hove Civic Society agreed to pursue representations in the following areas:

Infrastructure, heating and cooling
Housing standards
Transport and Public transport
Biodiversity / street trees
Arts policy

Generally we welcomed much of the draft plan, and we set out specific policies which we welcomed and also those which we believed need improvements.

Infrastructure: The national 80% CO2 reduction target by 2050 poses an extraordinary challenge and we believe that the draft plan seriously underplays the changes needed to de-carbonise the city. We believe that much more emphasis needs to be given to the scope for renewables in the city and that piped heat needs to be recognised as the major potential contributor to reducing the city carbon footprint. We believe that the spatial implications of more renewables need to be recognised and identified rather than just referred to and that the infrastructure ambitions of the plan need to raise the profile of renewable energy and decarbonisation measures, piped heat in particular. We have made a number of proposals for changes to a number of paragraphs accordingly. We believe this aspect requires considerable imagination and vision.

Housing Standards: We reiterate our objection from the previous version of the plan: New dwellings MUST meet minimum dwelling size standards. We believe the Council having set such standards for public sector housing should apply these standards to all new housing. We recognise the built-in inertia of the planning system on this issue but believe that the localism act should allow such policies to emerge. It is simply unacceptable to produce housing year after year that fails in meeting elemental requirements for space including storage. In addition we believe that the housing mix requirements for affordable homes should also apply to all new housing as the needs are not dissimilar. This should allow a more balanced housing mix to emerge during the plan period to counteract the large amount of very small dwellings produced in recent years.

Transport and Public transport: We welcome much of these policies but suggest that they only scratch the surface in terms of achieving sustainable transport policies. We make a number of proposals for improving this section.

Biodiversity / Street Trees: We believe that the role of street trees in the city ecology needs to be explicitly recognised and the need for enhancing the population of street trees should be emphasized.

Public Art: We believe the scope for public art can be strengthened in the policy and the opportunities for public sculpture across the city emphasized.