Let’s discuss Brighton and Hove’s new City Plan

Policy and planningEconomic developmentEnergyFoodNature

14 Jan

Let’s discuss Brighton and Hove’s new City Plan

Simon Maxwell

(NB This note introduces a discussion. Please see the procedural note at the end (before the Appendix), and perhaps look at comments ‘below the line’ before adding your own.)

Brighton and Hove is preparing an update to its City Plan, covering the years to 2041. There is and has been an extensive consultation process, which we do not want to duplicate. Everyone interested should contribute to formal surveys and meetings. Our purpose is different: to provide an opportunity to explore climate-related issues in more detail, and discuss among ourselves. At present, this is open-ended. We may at a later stage organise a more structured e-discussion.

You can join the discussion by using the comment box below. Comments are moderated, and we ask you to be respectful and constructive.

By way of background, the City Plan is described as follows:

‘The City Plan sets out a framework of planning policies to guide future development in the city over the next 15- 20 year period. It identifies how much new housing and commercial space will be needed to help meet the needs of our residents and businesses. It supports the creation and maintenance of thriving, sustainable communities by encouraging high-quality and well-designed places but also conserving and enhancing the environment, biodiversity and our important heritage assets. The City Plan also helps to ensure that new development is supported by necessary infrastructure. This could include health and community facilities and children’s play areas. It applies to the whole city apart from those parts that fall within the South Downs National Park area (the National Park Authority produces its own plan).’

The timetable is as follows:

Autumn 2024 Key Issues consultation
Winter 2025/26 Draft Plan consultation
Spring/summer 2026 Proposed Submission Consultation
Winter 2026 Submission to government for examination
Autumn 2027 Adoption

The Key Issues Consultation has/had a closing date of 20 January. The next big opportunity to feed in ideas looks like being in Winter 2025/26.

The Key Issues Consultation Paper, published in October 2024, provided a great deal of information, and listed the topics that the consultation will cover:

• Where development should go – our Spatial Strategy

• Homes for Everyone

• Sustainability and Climate Change

• A Diverse and Sustainable City Economy

• Design and Place-Making

• Culture and Tourism

• Healthy City and Communities

• Biodiversity and the Natural Environment

• Transport and Infrastructure

It is obvious, looking at this list, that the City Plan intersects with all the many other strategies and plans that the Council has adopted or is considering, including the overall Council Plan, but also the Economic Plan, the Adaptation Strategy (reviewed here), the Circular Economy Action Plan, the Decarbonisation Pathways Study (discussed here), and many others. One key question is how all these link up.

More specifically, the Key Issues document lists 51 questions, reproduced in Appendix 1. About 20 of these bear on climate change:

· Question 14: How important is it to you that we require new development to reduce the risk of overheating?

· Question 15: Are there any other ways our planning policies could help mitigate climate change impacts?

· Question 16: Are there any more ways our planning policies can support low and zero carbon energy generation and energy infrastructure?

· Question 17: How important is it to you that we encourage new development to incorporate Circular Economy principles?

· Question 18: How important is it to you that we encourage buildings to be designed and built with lower embodied carbon?

· Question 19: Would you support us setting specific targets to limit whole life cycle emissions for larger developments?

· Question 20: How important is it to you that we set carbon emission reduction standards that go further than the national Future Homes and Building Standard for new development?

· Question 21: Should we set a water efficiency target higher than the current optional national standard?

· Question 22: Should we include water efficiency targets for non-residential development?

· Question 28: How important to you are the following elements of high-quality design? • attractive streets and public spaces • innovative and attractive design in new development. • respecting the diverse character of the city’s neighbourhoods • safe, accessible buildings and public spaces that are easy to move through • conserving and enhancing the city’s listed buildings and conservation areas • sustainable buildings that are resilient to climate change by using resources more efficiently • supporting healthier lifestyles by reducing the impact of traffic

· Question 40: How important to you are the following issues in helping residents lead healthy lifestyles? • ensuring the design of new developments and public and green spaces encourage children and adults to be more active • ensuring the design of new development and public and green spaces meets the needs of all ages and abilities • access to healthy food • access to open space for recreation • access to sports facilities • contact with the natural environment, such as trees and wildlife

· Question 41: Under what limited circumstances should we allow the loss of open space or sports facility? • to enable improvements, for example through better access • to provide better facilities, for example a pavilion • to provide wider community benefits, such as a community building • if the open space or sports facility would be replaced elsewhere • if the open space or sports facility is surplus to requirements

· Question 42: Would you support any of the following on areas of open space? • community food growing • community composting area • flood prevention measures, such as rain gardens • measures to improve biodiversity, such as butterfly banks

· Question 43: On larger developments, what types of open space do you think are important to be provided on site? • Children’s equipped play-space • Food growing space • Green space for informal recreation • Natural green space, for example, for wildlife

· Question 44: What types of food growing opportunities would you use if they were available? • Edible planting spaces within landscaping, such as shrubs with berries or fruit trees • Individual food growing space • Communal food growing space • Allotments • Anything else – please tell us.

· Question 45: On larger developments, would you support a requirement to provide food growing space?

· Question 46: Should we be more ambitious with developments that provide mandatory Biodiversity New Gain by requiring more than the 10% minimum requirement? What target would you support? • 10% • 15% • 20%

· Question 47: Please indicate whether you support providing off-site Biodiversity Net Gain on a Registered Site that is: • as close as possible to the development site itself • away from the site but still within the Brighton & Hove area • away from the site in a location where wider ecological benefits can be achieved • across a wider area, for example within the Living Coast Biosphere area within Sussex

· Question 48: Do you think we should use a target to increase the amount of green infrastructure provided by larger developments?

· Question 49: Do you support reviewing parking standards for new developments: • to provide more electric vehicle chargepoints • to provide parking related to levels of public transport • to provide suitable cycle parking • so that new developments do not significantly impact on levels of on-street parking for existing residents • to support the council’s Carbon Neutral ambition and pathways • to provide facilities for safe deliveries and servicing • to provide facilities for disabled drivers • to facilitate businesses to operate effectively

· Question 50: Do you support: • providing more choices for those accessing the city centre by establishing park and ride site(s)? • providing more options for deliveries in the city, for example moving goods to smaller, more suitable and sustainable vehicles as they reach the city centre? • providing more choices by creating local neighbourhood hubs that provide access to public transport, car and cycle hire, and other transport facilities?

· Question 51: Are there any specific requirements for new infrastructure that we should be aware of?

To repeat, specific answers to these questions are best submitted through the Council’s own portal. However, it would be interesting to have additional comments here. Has anything been missed? Are there links to other strategies not yet made? How can Brighton and Hove take a holistic approach to climate compatible development?

Over to you.

_____________

Procedural Note.

Please do not use this site as a substitute for comments via the main BHCC consultation portal (here). For immediate impact, start there, not here.
Comments are moderated. Please be respectful and constructive.
If you have comments on different aspects, please comment separately, so we can distinguish different threads.
Note that there is a ‘Reply’ button in the top right hand corner of published comments. Use this to start or continue conversations.

Appendix 1 - List of Questions

· Question 1: Do you agree or disagree that we should continue to focus new development in the eight existing Development Areas?

· Question 2: Are there any other parts of the city that could be suitable for significant new housing or commercial development?

· Question 3: Are you aware of any specific sites that could be available for development?

· Question 4: Do you have any comments on our proposed Special Areas?

· Question 5: Are there any other means of increasing housing supply that we should consider?

· Question 6: Do you think we should prioritise larger family homes on suitable sites?

· Question 7: Do you agree we should prioritise affordable homes to rent (social rent and affordable rent)?

· Question 8: Do you support the approach of asking for financial contributions to affordable housing from smaller housing sites?

· Question 9: Do you think there is a useful role for ‘co-living’ housing in the city?

· Question 10: Do you agree we should manage the number of new second homes in the city?

· Question 11: Should we be seeking more wheelchair adapted or adaptable housing as part of new housing developments?

· Question 12: Do you think we should prioritise Purpose Built Student Accommodation on suitable sites?

· Question 13: Should we require some accommodation units suitable for families in Purpose Built Student Accommodation developments?