For Official Use: Respondent Number: Rep No: Date Received:

Brighton & Hove City Council Proposed Modifications to the Submitted City Plan Part One Electronic Response Form Consultation Period: Tuesday 4th November until midnight on Tuesday 16th December 2014 The City Council is publishing for consultation post Submission proposed modifications to the City Plan Part One. The City Plan Part One was submitted to Government in July 2013 and is currently under examination by an independent Planning Inspector appointed by the Government to consider the ‘soundness’ of the Plan. The Inspector held a series of hearing sessions in October 2013. In response to the Inspector’s Initial Conclusions Letter the City Council is now proposing a number of changes or ‘main modifications’ to the submitted City Plan Part One to address her concerns. We are only able to accept representations on these proposed modifications. Further guidance on completing this form can be downloaded at www.brightonhove.gov.uk/planning/local-development-framework/consultation This form has two parts:

Part A – Personal Details Part B – Your Representation(s).

Representations should only relate to the Proposed Modifications and not other parts of the City Plan. Part A: Personal Contact Details Please note that you must complete Part A as anonymous forms or those that do not contain an address cannot be accepted. 1. Your Details Title Forename Surname Job Title Organisation Address Postcode Email Address Telephone No. Mobile No.

2. Agent Details (if applicable)

Chairman Brighton & Hove's Wildlife Forum

[email protected]

Data Protection Notice: Personal data given on this form will be used by BHCC (and its agents) in connection with statutory functions. It will not be used for any other purpose.

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Part B: Your Representation Please answer the questions below and clearly explain your comments in the relevant sections. Use one form per representation / comment. You may use as many additional sheets as necessary. (Please note that the text boxes below expand as you type) Q1a. To which Proposed Modification does your comment relate? (Please enter one modification number) Modification Number PMO64 Q1b. To which policy / section of the plan does your comment relate? Policy / Section SA4 Urban Fringe Q2. Do you wish to support or object to this Proposed Modification? (Please tick one box) Support Object Q3a. Do you consider this Proposed Modification Legally Compliant? (Please tick one box) Yes No Q3b. Please use this space to explain your answer above. (Please be as precise as possible and refer to any supporting / background document as you see necessary).

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Q3c. Please set out what change(s) you consider necessary to make the Proposed Modification legally compliant and give your reasons. It will be helpful if you are able to put forward your suggested revised wording of the proposed modifications. (Please be as precise as possible).

Q4a. Do you consider this Proposed Modification is Sound? (Please tick one box) Yes

No

Q4b. If you consider that the proposed modification is unsound, please identify which test of soundness your representation relates to by placing a cross by the appropriate box. Please select

Test of Soundness It is not positively prepared in that it is not prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development. It is not justified in that it is not the most appropriate strategy when considered against the reasonable alternatives, based on proportionate evidence. It is not effective in that it is not deliverable over its period and based on effective joint working on cross boundary strategic priorities. It is not consistent with national policy.

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Q4c. Please use this space to explain your answer to Q4a above (Please be as precise as possible). Brighton and Hove's Wildlife Forum is a non-profit community partnership of representatives from seventeen local wildlife groups with local experts in their field; and over a hundred naturalists, students and professional environmental consultants. BHWF has the commitment to conserve and enhance Biodiversity across the Brighton and Hove area and protect the very rare remaining chalk grassland. Biodiversity is declining in England, and Government Planning policy states that developments should not be permitted if they are likely to cause significant harm in this regard. A net gain in biodiversity should be provided if possible, and, in cases where wildlife is likely to be affected, we would like to see a requirement for planning applications to provide a statement to show how the proposed development would achieve this. The City plan emphasises the fact that the council is fully aware of their Biodiversity duties, and BHWF is pleased to note that it importantly states: • Urban fringe sites will be scrutinised and expect that each individual site will be subject to further public consultation before they can be allocated for development. • Opportunities for development of brownfield sites are to be maximised, 2.19, and the city’s countryside and the South Downs National Park will continue to be protected. • The urban fringe is important in terms of biodiversity. We understand that detailed Environmental Impact Assessments will be provided for every site involving the potential for destruction of wildlife. These should include Ecological Impact Assessment (EcIA) • Public Bodies have a formal Duty to promote biodiversity through the Natural Environment and Rural Communities Act 2006. Section 40 aims “...to raise the profile of biodiversity in England and Wales, so that the conservation of biodiversity becomes properly embedded in all relevant policies and decisions made by public authorities”. • The NPPF contains references to geological and landscape elements in several parts of Section 11 and in the Glossary. We would draw attention in particular to paragraphs 109, 113, 114, 115 and 117. These would appear to provide much needed guidance on useful additions to the LBAP and its importance to the Biosphere Reserve Project application to UNESCO. • The new National Planning Policy Framework (for England) – NPPF - has been published recently by the Department for Communities and Local Government. Although PPS 9 - Biodiversity and Geological Conservation is replaced by the new Framework, the guidance which went with PPS 9 is retained (i.e. Ref 24 in 113 refers to Government Circular 06/2005: Biodiversity and Geological Conservation - Statutory obligations and their impact within the planning system).

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Q4d. If you consider the Proposed Modification unsound, please set out what change(s) you consider necessary to make it sound and give your reasons. It will be helpful if you are able to put forward your suggested revised wording of the Proposed Modification. Please be as precise as possible. RE-INSERT the following without the deletions - paras 3.154 & 3.155. These areas are vulnerable to development pressures./Careful use and management of land within the urban fringe is therefore essential./ SA4 URBAN FRINGE The (Where appropriate, the) council will promote and support the careful use and management of land within the urban fringe to achieve the following objectives "Where appropriate" should be removed. It leaves it too open to abuse.:

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Q5. The Sustainability Appraisal has been updated where appropriate to reflect the proposed modifications. Do you have any comments on this document? It is the strong view of many residents of the City that it is already full to capacity and expansion of the built-up area is in effect prohibited by the South Downs National Park and the sea. Further major development will put even greater pressure on the currently under-pressure hospitals; doctors; dentists; and schools let alone the roads and utility services. It is also of major concern that more and more student accommodation is being provided which puts even greater pressure on the City’s infrastructure and yet makes no contribution to housing numbers and is most unlikely to release currently studentoccupied HMOs back to normal residential use. We fully agree with the statement in 2.12 “Strategy for the future of Brighton & Hove” that the government’s suggested housing target is much higher than the City can realistically accommodate. Our concern as a Wildlife Forum is that the town in which we live will be turned into an increasingly concreted area with adverse impact upon the environment and its wildlife. Whilst we and our wildlife have the much-prized South Downs National Park, there is a world of difference to us and our wildlife in having green spaces actually within the area where we live. Our opening comment above in relation to the pressure on our infrastructure is highly pertinent to wildlife and our open areas. If large-scale development was to proceed, it would lead to even more infrastructure being required and the need for more land to accommodate it. It is critical that more imagination is used to make better use of brown field land. This does not just involve disused sites; it is equally applicable to existing sites still in use. For example: people are changing their shopping habits with use of the internet in particular, which means that our ‘high streets’ will increasingly change thereby offering exciting possibilities for turning them back to residential areas including the flats above leading to regeneration of areas using existing infrastructure. There are several industrial/business park areas where land is not well-used plus large and ugly open car parking in particular. Just two examples would be: The Goldstone Retail Park opposite Hove Park, and the Pavilion Retail Park in Lewes Road. Welldesigned mixed commercial/business and residential development together with building over parking areas would make much better use of substantial areas. The Lewes Road site in particular presents great potential if linked to the adjacent Preston Barracks and Brighton University sites. Yes, it is more difficult than developing green field sites, but surely that is no excuse? In 2010 the Forum published its “Environment, Nature Conservation Agenda”. Item 3 of our 10 point Agenda was:“More could be done to promote private gardens as wildlife habitats. Linking green space in the city, thereby connecting habitats through public land and private gardens, and encouraging people to discover more about their local wildlife will benefit both nature and people. Passing sightings on to the Booth Museum and 'City Wildlife' will highlight the richness in our local ecology.” Whilst we had not seen this as representing a charter for new houses in back gardens or large house extensions to existing properties, we had seen such proposals as inevitable and taking the pressure off the development of our remaining limited green field land. Whilst we would prefer to see such gardens remain as green space, we had seen them 6

as presenting the opportunity for the Planners to adopt a mindset of taking every opportunity to enhance the environment in which we live. This would apply to all privately and publicly owned areas. Adoption of a more imaginative approach to the re-use of brown field land, before the use of any green field land together with the linking of green space, in its broadest sense, throughout the area is essential to the success of our City Plan.

Q6. Do you have any further comments to make?

Q6a. The Inspectorate’s Procedural Guidance states that issues raised on consultation of the Proposed Modifications will be considered through written representations and further hearing sessions will only be scheduled exceptionally. Please could you indicate whether you would like to submit…? i)

Written Representations

Or if required by the Inspector, to ii)

Participate at the Examination in Public

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Q6b. If you wish to participate at the Examination hearing, please outline why you consider this to be necessary:

Q7. Please tick this box if you DO NOT wish to be notified of the publication of the Inspector’s Report, adoption of the City Plan Part One or be involved in the preparation of future plans and policies.

Signed: Dated:

Martin Robinson for Brighton & Hove's Wildlife Forum 15th December 2014

All representations must be received at the email or postal address given on this form by midnight on Tuesday 16th December 2014. Completed forms should be sent to: Email: [email protected] Post: LDF Team, Brighton & Hove City Council, Room 201, Kings House, Grand Avenue Hove, BN3 2LS If you have any further queries please contact us on 01273 292505 or via email [email protected] . Thank you for taking the time to complete your representation(s).

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Consultation on Proposed Modifications to B and H City Plan Part1 ...

Consultation on Proposed Modifications to B and H City Plan Part1 - BHWF Dec 2014.pdf. Consultation on Proposed Modifications to B and H City Plan Part1 ...

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