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News - 18 April 2017

BHEP responds to Toads Hole Valley consultation

The BHEP was at the forefront of arguing for the exclusion of Toads Hole Valley from the National Park. Brighton & Hove City Council has recently sought responses to their SPD for the strategically important site.

The BHEP submission to the Toads Hole Valley SPD.

The BHEP broadly support the aims and objectives outlined with the SPD for Toad’s Hole Valley.
With Reference to the City Plan Part 1 and the City’s Economic Strategy 2013 – 2018 we have provided the following response as per the headings detailed within Brighton & Hove’s City Council SPD consultation document.

The Site

The Brighton & Hove Economic Strategy states, "The shortage of land within the administrative boundary requires careful allocation use of every potential development site."
With this in mind, the BHEP fully endorses Toad’s Hole Valley as a site which can deliver several objectives as laid out in the City Plan.
Most notably housing, but also schools, communal green space and business space.
These will be discussed more under the headings below.

Planning Policy Context

Policy DA7 Toads Hole Valley is in sync with the City's Economic Strategy Strategic objective SO2 -'To Grow quality jobs and business opportunities in higher value and low carbon sectors.'
There are also overlaps with strategic objective SO1, 'To enhance Brighton & Hove's distinct destination and lifestyle offer.

SO5 of the Brighton & Hove Economic Strategy 2013-18 seeks to establish a strong and influential Greater Brighton City Region.
In that section of the strategy, success is explicitly outlined as:
Key strategic development sites identified in the City Plan are well into the delivery phase including Toads Hole Valley, Preston Barracks and Circus Street, leading to a sharp rise in housing delivery;
The Biosphere Reserve and South Downs National Park stimulate development of the City Region’s offers particularly in terms of a world-class environment, tourism and food.

In this context the BHEP fully supports the Planning Policy context.

Submitting a planning application and Amounts of development

The BHEP fully endorses the City Plan Part One SS1 Presumption in Favour of Sustainable Development.

That section states, “Planning applications that accord with the policies in [the] Local Plan (and, where relevant, with policies in neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise. Where there are no policies relevant to the application or relevant policies are out of date at the time of making the decision then the Council will grant permission unless material considerations indicate otherwise.”

With additional reference to the sustainability of applications, the Economic Strategy also attests that

'there is a robust and real-time evidence base supporting, monitoring and reporting on the City’s key quality of life and sustainability indicator'

The BHEP support the use of the Sustainability Checklist and the Authority Monitoring Report (AMR) as outlined in the city plan part 1 for this purpose.

Master planning and landscape led design

The BHEP wholly concurs with City Plan Part 1 section CP12 (An attractive city) – Urban Design.
The Economic Strategy also refers to this in section SO1 – enhancing Brighton & Hove’s distinct destination and lifestyle offer

Place Making

Strategic Objective SO1 highlights the importance of “Brighton & Hove’s distinctive destination and lifestyle offer as its USP.”
Within this there is an inherent expectation that it is the ’place’ that makes the city. The strategy goes on to say, “Quality of place therefore matters.
Investment in Brighton and Hove’s assets and infrastructure need to continue.” This is also of particular importance in terms of transport as well as sustainable communities as outlined in SA6 of the City Plan part 1.


The City Plan Part 1 highlights the target of 13,200 homes to be built, which still doesn’t meet the total future housing demand.
The minimum target of 700 residential units on the THV site is welcomed, however the BHEP feels that there should be robust measures in place to ensure a good ratio of affordable housing within the housing mix.
This fits well with SO4 of the Economic Strategy which seeks to tackle barriers to employment and creating employment opportunities for all by creating a mix of residents on different incomes within the development.

The strategy outlines that, “The constraint of housing supply also presents real barriers to labour market mobility and restricts the supply of people to take up new job opportunities, driving up the cost base for the city’s workforce and holding back growth in the economy,”

Equally SO5 in the Economic Strategy advises the use of land for a balance of uses, with housing being one.


Strategic Objective SO2 of the Economic Strategy outlines the need to grow quality jobs and business opportunities.
Specifically, the strategy seeks actions that will, “ensure that there is sufficient high quality office space to meet the need identified in the City Plan and the Employment Land Study Review 2012,”

The BHEP supports the mix of use proposed in this SPD.


The BHEP supports the City Plan Policy DA7 that requires that an area of 5 hectares be reserved for a six form-entry secondary school for ages 11-18, or a through school, to meet identified needs.

This fits well with Economic Strategy Objective SO4 – ‘To Tackle barriers to employment.’

Although broadly supportive with the proposals, the Partnership would like to ask what is being done to ensure adequate Primary education provision in the area.

Community and Retail

The BHEP supports the City Plan Policy DA7 that requires the provision of a new multi-use community facility or neighbourhood hub to include a community meeting place, a doctor’s surgery, a resource promoting links with the SDNP as well as shops and cafes.
This fits well with SO1 of the Economic Strategy which seeks to enhance the city’s lifestyle offer.


Strategic Objective SO2 seeks, “To grow quality jobs and business opportunities in higher value and low carbon sectors.”
This objective attests “[that the] economy is driven forward by growth in stronger sectors including specific environmental industries.”

The BHEP also supports the City Plan Policy DA7 which expects the development in THV to be of ‘an exemplar of sustainable development and demonstrate that the city’s UNESCO Biosphere Reserve objectives can be successfully integrated throughout the development scheme subject to viability and deliverability’ (paragraph 3.84). City Plan Policy CP8 Sustainable Buildings lists priorities and sets out minimum standards to inform development design.

The BHEP is also in agreement that robust targets should also be set for:
  • Energy generation
  • Food growing
  • Water use
  • Waste management
  • Transport links
  • Ultra low emission vehicles
  • Reduction of the heat island effect

Transport and Travel

The Brighton & Hove Economic Strategy outlines the need for Smart City management systems that improve the quality and delivery of public services at an affordable cost;

  • Smart systems that reduce transport congestion, pollution and are energy efficient;
  • Technology innovation which reduces the need to travel;

The BHEP supports the City Plan Policy DA7 which, “seeks the development of a fully connected new neighbourhood at THV. The site’s location on the edge of the built-up area, and the physical severance caused by the steep slopes of the SNCI, the A27 and King George VI Avenue pose considerable challenges to achieving this objective.”

Public Realm and blue-green infrastructure

The BHEP supports section 4.58 of the SPD which seeks, “the creation of a new neighbourhood/community to provide an opportunity to design open spaces that are rich in biodiversity, accessible, usable and that help reduce vulnerability to a changing climate.”

Development Phasing and Infrastructure Delivery

The BHEP supports the creation of a phasing programme to alleviate any burden on existing facilities.

In addition, and as outlined in the SPD, the BHEP also supports Policy CP7 Infrastructure & Developer Contributions and the annexe Infrastructure Delivery Plan document.

The BHEP further supports the types of contributions outlined below and which are listed within the SPD:

  • Affordable business accommodation provision and retention;
  • Affordable housing provision including accessibility and retention;
  • Air quality mitigation measures and/or management;
  • Community safety measures and maintenance including appropriate lighting infrastructure;
  • Education and learning facilities provision and/or upgrade;
  • Employment, commercial space provision and retention;
  • Employment training and job opportunities throughout construction phases;
  • Health care facilities including integrated provision for other community needs, retention or replacement, including engagement and support;
  • Highways site-specific connectivity and upgrade to main trunk road and local corridors and sustainable transport accessibility;

Phasing Plan;

  • Project management monitoring contribution;
  • Public Open Space including parks recreation, play space, sports and allotment provision;
  • Public realm, environmental improvements, legibility including site specific artistic components
  • Sustainable development high standard achievement measures and biodiversity landscape enhancement; including SNCI reinstatement and connectivity to SDNP
  • Utilities appropriate connectivity, upgrade and management.



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