The four options papers that will form the basis of the review of the city’s blueprint for development for the next 20 years have been published on the Council’s website prior to the cabinet meeting on 13th October. Quite a few surprises.
The Core Strategy was withdrawn by the local authority in July because the Planning Inspector wasn’t convinced by the housing delivery numbers [see earlier story]. Although broadly in agreement with the bulk of the document, the Economic Partnership challenged it on a small but significant number of issues and welcomed its withdrawal [see earlier story].
The strategy deals essentially with the use of land in the city for jobs and homes and the infrastructure that goes with it. The Economic Partnership has long been calling for a more strategic use of our scarce land resources [see earlier stories].
The review of the Core Strategy focuses on four areas:
- Housing numbers and delivery
- Park & Ride
- Employment sites
- Student accommodation
The new coalition government has abolished top-down housing targets but each locality is still under a duty to accommodate projected increases in its population and this will be an important element of a new Core Strategy when it goes back to the Planning Inspectorate for examination in public in 2012. Do we have a robust and deliverable plan to house our population?
The housing figures for Brighton & Hove imposed by the previous Labour government’s South East Plan – 11,400 homes over 20 years – were never really a reflection of the city’s real needs but rather the government’s view of the city’s ability to accommodate and deliver a certain number of homes. The previous city council Conservative administration struggled to allocate sufficient credible sites to satisfy the 15 year delivery plan that the Core Strategy demands; hence the Inspector’s scepticism.
This was partly because they wanted to protect the urban fringe - sites like Hangleton Bottom and Toads Hole Valley - although they did include the latter as a site of last resort, inexplicably only after 2020.
The new Green administration has reviewed the city’s housing needs concluding that, in theory, we will need between 15,800 to 19,400 homes by 2030; well in excess of the South East Plan figures. But they also don’t see how we can get even close to delivering them given the competing demands placed on a very small amount of development land. Working with neighbouring boroughs to contribute to housing solutions for city workers was always part of the mix and it continues to be so.
The preferred option is to deliver more or less the same number of homes as the previous target and put 750 on the urban fringe at Toads Hole Valley.
The inclusion of this part of the urban fringe makes a lot of sense because the 47 hectare valley was deemed “not of sufficient landscape quality” to be included in the South Downs National Park so planning consent still rests with the city council. It is essentially scrubland of limited bio-diversity [except for the southern bank] and access to it is prohibited because it is private property. Anyone who sets foot on it is trespassing; although plenty of people do access it illegally to ride motorbikes and generally cause mischief further degrading the site.
If the bowl of the valley was developed, it could offer the opportunity for properly managed, open green space around the periphery to be brought into public use in a part of the city where the Sports & Recreation Study has highlighted a pressing need.
Rather than lose a green space to development, the city could gain one and provide ultra sustainable homes for some of the 11,000 people on the housing waiting list into the bargain. The site is big enough to accommodate the proposed number of homes and perhaps other development and still leave room for recreation space.
Although the administration has, quite rightly, shied away from trying to deliver over 19,000 homes because the city has no track record of building at this rate, the proposed number of 11,200 is perhaps a little unambitious. At the first hearing with the Planning Inspector [when he advised that the council should have “looked down every rabbit hole” in the search for land] council officers insisted that they could deliver the South East Plan target without recourse to the urban fringe, even citing 50 “secret” development sites that could not be divulged due to commercial sensitivity. Since Toads Hole Valley is now in the mix it is compelling to conclude that 12,000 homes over the 20 year period could be achievable.
The new National Planning Policy Framework [NPPF] adds a complication because its presumption to allow sustainable development [see earlier stories] means that it would be very difficult to deny an application if the owners submitted one for the development of the valley. Including it in the revised Core Strategy gives the local authority some control over how the land is used to the best strategic advantage.
Those that want to protect Toads Hole Valley have to ask themselves who or what they are protecting it for? The odd illegal dog walker, the many illegal motorbikers, the family that owns it? There are many things in the city that are worthy of salvation but in this instance the imperative is to create, not to save.
Park & Ride [P&R]
The Business Forum and the Economic Partnership have spent the best part of a decade lobbying for a significant park & ride facility on the outskirts of the city. But they did not lobby for P&R for its own sake; it was always intended to be part of a viable transport solution to Brighton & Hove’s access problems.
It is perhaps ironic that both organisations might now find themselves agreeing with the Green administration's preferred option on P&R which is to abandon it. The opportunity for a meaningful facility was lost some time ago when Braypool playing fields became part of the National Park and more recently with the sale of Patcham Court Farm [and the latter was always a very, very poor second best without the inclusion of Horsdean allotments and even Horsdean playing fields].
And there was always a question mark over the commercial viability of the series of smaller satellite sites proposed by the previous Conservative administration.
Time, perhaps, to draw a line under P&R and move on. But the details of the still needed alternative solutions to our congestion problems proposed in the options document are vague and woolly. They include the perennial promotion of walking and cycling [no one can argue with that but what does it mean?] and the perhaps ominous control of parking via pricing. Quite apart from its contribution to the wider economy, parking is a source of revenue for the council and the recent tribulations of NCP desperately trying to find a business model that works [see earlier story] are a warning that the right balance can be hard to find. Much, much more detail required.
If possible, trickier even that housing delivery. Ideally a city wants people to live and work in the same place but a quarter of our workforce already leave every day mainly heading north to work in richer pastures.
If we are to avoid becoming a dormitory town for south London we need to protect employment space and identify new sites to accommodate 6,000 to 9,000 extra jobs in the next two years for our young, growing population and move-on space for successful companies that need to expand.
The administration's preferred option is to safeguard the city centre as the primary location for offices. This makes sense and easy access via sustainable transport and good links to London certainly make this where some sectors of the economy prefer to be e.g. digital media and the creative industries. But it might be a mistake to completely rule out a fringe site if it could be shown to demonstrate superior economic, environmental and social benefit.
The revised Core Strategy supports the requirement to develop 20,000 sq metres of new employment space post 2016 and, like the old version, continues to suggest that New England Quarter and the London Road area can accommodate it. This will need closer examination to ensure that the proposed sites are deliverable.
The proposed allocation of key development sites like Hove Station and Brighton Marina is supportable as is the proposal, subject to more detail, to have a hierarchy of industrial estates that can accommodate mixed use development with the caveat that net loss of employment space will need close scrutiny.
Brighton & Hove’s student population is a key element to its economic success that could be exploited further if we can retain more graduates [42% of our workforce has a degree] and generate more graduate level jobs.
With the increase in university fees next year, competition between universities for students will include more than just academic track record. Some 10,000 students are in private sector accommodation because the two universities do not have sufficient on-campus or university-controlled student accommodation.
The revised Core Strategy proposes to devote sites at Preston Barracks and Circus Street at least partly to student housing. It also proposes limits on student housing in places like Bevendean and Hanover where close proximity to the universities or the appropriate bus route makes them attractive to large numbers of students.
Brighton & Hove does not have ghettoised student enclaves like Leeds and this policy will go some way to ensuring that we don’t in the future.
The consultation on the four options papers starts on 17th October and runs until 2nd December. The Economic Partnership will be arranging consultation opportunities.
Click here to download Cabinet Papers of the four Core Strategy options
Read related items on:
Local Development Framework
National Planning Policy Framework
Brighton & Hove Business Forum
Brighton & Hove City Council
Brighton & Hove Economic Partnership