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News - 20 July 2012

Economic Partnership responds to 2012 draft City Plan consultation

The 2012 draft City Plan is immeasurably superior to the previous version which was effectively rejected by the Planning Inspector in May 2010. The Economic Partnership supports 95% of it with just a couple of areas of continuing concern.

The City Plan is the overall strategic and spatial vision for the next 20 years and it attempts the impossible task of providing sufficient space for offices, homes, schools, parks, gardens, roads and infrastructure [physical and digital] in a city that has everything going for it except space.

In addition it must balance economic growth in a time of unprecedented austerity with sustainability at a time of unprecedented danger for the planet and cater for a local population that has increased by 25,000 people over the past decade and shows no sign of slowing down over the next two.

Under these circumstances the city council’s planning officers have done a tremendous job in putting together a superior document involving hundreds of hours of consultation with stakeholders including two separate workshops  with the Economic Partnership in November 2011 and April 2012.

The evidence-based background documents that accompanied the publication of the draft City Plan have revealed in detail the scale of many of the challenges we face. Population projections, which may have to be revisited in the light of the most recent 2011 census results [see earlier story], indicate that we need in excess of 19,000 homes to cater for demand over the next 20 years. But to supply that many would require building on practically every piece of land including employment sites that prevent us from becoming a dormitory town for London and other locations.

Space has been identified for a minimum of 11,300 homes and making up the shortfall of over 7,000 homes is impossible within our unitary authority boundaries. Technically the city is required to work with its neighbours to find suitable sites [see earlier story] but they too will struggle to fufill their housing targets. For this reason the Economic Partnership is urging the council to be much bolder in its housing proposals, building to greater densities and building up in accordance with the Tall Buildings Strategy.

The Partnership supports the vast bulk of the Plan, especially

  • The inclusion of Toads Hole Valley as a development site [see earlier story]
  • Compromising on employment sites by allowing mixed-use schemes to enable sites to be developed in the difficult economic climate [which may last for fully half of the Plan period!]
  • Purpose-built student accommodation to safeguard the strength of the workforce and the contribution of our two universities
  • The sliding scale for affordable housing provision
  • The aspiration for more One Planet Living developments

It has also raised a number of questions;

  • Should Black Rock still be allocated for a major leisure use now that the Ice Arena has failed to come forward?
  • Is it realistic to expect Code 5 housing on the heavily contaminated Gasworks site?
  • Is the expectation for office space at Hove Station reasonable?
  • Is the King Alfred site the best place for a sports centre?
  • Is the local definition of sustainable development in excess of that demanded in the National Planning Policy Framework NPPF]?
  • Apart from the expansion of Churchill Square, do we really need more small shops?

There are only two areas of the Plan that the Partnership finds it cannot support: blanket protection of all remaining urban fringe sites [apart from Toads Hole Valley] and plans to increase visitor accommodation.

There are probably only a couple of urban fringe sites that would lend themselves to development but with 166,000 hectares of national park on the other side of the A27, it is difficult to marry their protection with the pressing need for housing and the scale of the shortfall in supply. The Planning Inspector Roland Punshon said in May 2010 that the local authority should have “gone down every rabbit hole” looking for land for housing [see earlier story]; there are plenty of rabbit holes in privately owned Mile Oak Fields or council owned Hangleton Bottom.

Meanwhile, the proposed increase in visitor accommodation was based on the Hotel Futures Study which was published in 2007 when the world was a very different place. Many of the developments that were guaranteed to increase demand for bed spaces in the city simply never happened and it is clear from talking to those in the industry that a radical reappraisal of current and future provision is needed in the light of possibly another 10 years of austerity. 

The final version of the Plan will be published early in 2013 and go for examination by the Planning Inspectorate in September 2013 for adoption in January 2014 if all goes according to plan [no pun intended].

Click here to download Economic Partnership response to draft City Plan

Read related items on:
Student Accommodation
Local policy
Local Development Framework
Brighton & Hove Economic Partnership

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