Hove Civic Society seeks to make representations on major plans affecting our locality.
Over the past two years the Council has been developing draft versions of the City Plan for public consultation and inviting comments.
Following an examination in public in 2013 there have been several rounds of consultation on modifications. The expected date for adoption is now early 2016.
Hove Civic Society has engaged with each stage of the process, and all of our submissions are included below.
March 2013 response:
The final, formal stage of consultation ended in April 2013.
Hove Civic Society's full response can be downloaded here (Word document, 247KB)
The committe support a wide range of policies in the plan. In particular we support the overall housing targets and allocation policies and the proposals for the development and special areas in the City.
We challenge the soundness of the plan in two respects:
- We believe the plan should include space standards for new housing developments to prevent housing to be built in the City that is not fit for purpose. We believe this requires an addition to an existing policy and a commitment to produce minimum dwelling standards for new housing in the city; we believe such standards should closely follow the standards now set by the Mayor for London in the London Plan as adopted in July 2011 and in the Mayor’s Housing supplementary planning guidance as adopted in November 2012.
- Whilst we welcome the references in almost all policies related to the Development areas to decentralised district heating, we believe such reference should also be made in respect of policy for area DA8 specifically referring to the substantial contribution that Shoreham power station could make to district heating for the city.
Earlier response: July 2012
In May 2012 the Council released a further draft plan for public consultation and this closed in July 2012.
Hove Civic Society's full response can be downloaded here (Word document, 192.5KB).
The Committee of Hove Civic Society agreed to pursue representations in the following areas:
- Infrastructure, heating and cooling
- Housing standards
- Transport and Public transport
- Biodiversity / street trees
- Arts policy
Generally we welcomed much of the draft plan, and we set out specific policies which we welcomed and also those which we believed need improvements.
Infrastructure: The national 80% CO2 reduction target by 2050 poses an extraordinary challenge and we believe that the draft plan seriously underplays the changes needed to de-carbonise the city. We believe that much more emphasis needs to be given to the scope for renewables in the city and that piped heat needs to be recognised as the major potential contributor to reducing the city carbon footprint. We believe that the spatial implications of more renewables need to be recognised and identified rather than just referred to and that the infrastructure ambitions of the plan need to raise the profile of renewable energy and decarbonisation measures, piped heat in particular. We have made a number of proposals for changes to a number of paragraphs accordingly. We believe this aspect requires considerable imagination and vision.
Housing Standards: We reiterate our objection from the previous version of the plan: New dwellings MUST meet minimum dwelling size standards. We believe the Council having set such standards for public sector housing should apply these standards to all new housing. We recognise the built-in inertia of the planning system on this issue but believe that the localism act should allow such policies to emerge. It is simply unacceptable to produce housing year after year that fails in meeting elemental requirements for space including storage. In addition we believe that the housing mix requirements for affordable homes should also apply to all new housing as the needs are not dissimilar. This should allow a more balanced housing mix to emerge during the plan period to counteract the large amount of very small dwellings produced in recent years.
Transport and Public transport: We welcome much of these policies but suggest that they only scratch the surface in terms of achieving sustainable transport policies. We make a number of proposals for improving this section.
Biodiversity / Street Trees: We believe that the role of street trees in the city ecology needs to be explicitly recognised and the need for enhancing the population of street trees should be emphasized.
Public Art: We believe the scope for public art can be strengthened in the policy and the opportunities for public sculpture across the city emphasized.
Earlier response: November 2011
On November 24, 2011 we made representations on two of the options papers:
Housing Target Option – We support Option 2, but would like to make the following comments and suggestions: The amount of housing achievable on the land identified is strongly correlated to key policies on densities, housing mix and individual dwelling standards. We believe these are parameters that should be clearly set out as part of the housing figures as they determine unit numbers achievable.
Dwelling mix – In our objection to the LDF Core Strategy we highlighted the need to align new housing to the findings of the housing research in terms of rectifying as far as possible the mismatch between units built (dominance of studio and 1 bedroom units) and units needed (2 + units). We believe this should be clearly set out at this stage as an aspiration – even if details will follow later.
Individual dwelling sizes – We acknowledge the discussions we have had and hope we can find a way forward on this matter. We believe strongly that we need to find a way of setting minimum space standards for new dwellings. We would be content if these were equal to the space standards set for affordable homes in Brighton and Hove. One way of dealing with this would be to include minimum dwelling standards in the Sustainable Appraisal (para 5.4) box, which would automatically elevate the minimum dwelling standard to policy. We also believe that Life Home standards should be met in all cases.
Mixed developments – as more and more people work from home, we believe that new units for home working should be encouraged. This means more space for individual housing units. This is a policy that stretches across both housing and employment.
Reference to District Heating System – We welcome the sustainability appraisal recommendations for Toads Hole valley, which refers to the need to maximise opportunities for a district heating system. We believe this will need to be reflected and anchored in a citywide infrastructure plan for renewable energy. We believe there will be many opportunities for district heating nodes which eventually can connect to an entire network, provided this is planned for. Any larger aggregations of housing should include ‘boiler nodes’ for such an emerging district heating system. The opportunities for connection should certainly be considered for any new development of say above six units. We refer to our existing objection to the Core Strategy relating to the need for planning the renewables infrastructure for the City as part of the infrastructure plan.
We broadly agree with the recommended approach and support:
- The Hove Station designation for employment uses;
- The intensification of Goldstone Road Retail Park;
- The intensification of Sackville Road Trading Estate;
- The intensification of South Portslade Industrial Area;
We would like to draw the attention to district heating opportunities in all cases.
Local Biodiversity Action Plan
From July-September 2012 the Council is consulting on a draft Local Biodiversity Action Plan. It includes descriptions, assessments and action points for 18 groups of species and 15 habitats which occur in the city and are considered to be of particular value. The draft plan will be included in the forthcoming application to UNESCO for designation of Brighton and Hove, parts of Lewes District and surrounding areas as a Biosphere Reserve.
Hove Civic Society's response:
We welcome the draft, its great attention to detail and the many proposals to maintain and improve local biodiversity.
We believe however that the draft plan makes one major omission. We are surprised that there is no reference to our street tree heritage as an important habitat, worth preserving and enhancing. We are also missing any reference to our elm population and the contribution that has been made over the years by the council in maintaining and enhancing our local elm population.
We believe street trees deserve a separate section possibly after section 10, parks and gardens and we believe that their huge importance for biodiversity, acting as habitats for a huge number of species, CO2 absorption, filtering of other emissions, cooling and shading should be recognised in the plan.
We also believe that the scope to substantially extend our street tree population according to biodiversity principles, by choosing appropriate species and densities of planting should be highlighted in a work programme.
We believe that this is an area with one of the potentially largest positive impacts that the biodiversity action plan could achieve and which would be of substantial direct and daily benefit to the people of Brighton and Hove.
Local Development Framework (LDF)
We have made 3 representations challenging the soundness of the core strategy:
We propose that in policy CP1, para 3 a separate bullet-point is added with the words:
n: All new dwellings to meet as a minimum the housing space standards set by the Council for affordable dwellings.
We see this as a strategic issue which should be dealt with at this stage rather than deferred to the Development Policies and Sites Allocations stage
Associated with our first representation but specifically related to policy C11 – Housing Delivery, subsection C, Housing Mix, we believe that the policy should respect the need away from the ‘bias’ towards smaller dwelling units, which do not reflect the local needs.
We propose an additional policy point as follows:
New policy prefacing CP11, C a.: During the first half of the plan period new developments will be expected to provide a substantial proportion of 2 and 3 bed units, with a small proportion only of one bed units, until such time that there is evidence that the housing mix provided by the market corresponds to the local housing demand. To establish when such a level has been reached the Council will carry out further market research and monitoring during the plan period.
The Society believes that policy CP9 Infrastructure and Developer Contributions is unsound in that it does not address the spatial implications of renewable heat and power needs of the city. At this stage we therefore recommend that the following wording is added in para CP9, 1:
The delivery plan will in particular set out a spatial framework for substantially increasing the amount of renewable heat and power available to and used in the city.
Supplementary planning document: Design Guide for Extensions and Alterations
On December 16, 2011 we responded to this draft document with the following observations:
Generally: This is a welcome and well drafted document;
Para 3.1 Single storey rear extensions: Generally supported. The reference to size of garden to be left after development is welcome. Should there not also be a reference to developments where back gardens have been split off for separate development and where the resulting development proposals can result in a near complete cover of previous garden land?
Para 3.2 Extensions on Corner Plots: The first diagram suggests that the extension respects building line of street – as far as we can see the extension could come up to the rear end of pavement if the other houses in the street do so – as suggested on your diagram.
Para 3.4 Replacement windows: Strongly support your suggestions of materials for windows. A link to the need for energy conservation measures and our discussions at CAG re double glazing and insulation would be most appropriate here.
Para 3.5 Solar Panels: Restricting panels on street elevations altogether we believe is too restrictive. We would instead suggest that any arrangements of panels should be such that they form regular blocks, cover entire parts of roofs and are not arranged in a way that leaves jagged edges which provides undesirable contrasts with the underlying roof.
Appendix D – Sustainable Building Design: We repeat our comment from above: Restricting panels on street elevations altogether we believe is too restrictive. We would instead suggest that any arrangements of panels should be such that they form regular blocks, cover entire parts of roofs and are not arranged in a way that leaves jagged edges which provides undesirable contrasts with the underlying roof.
We welcome the reference to Lifetime homes. We would also like to see a reference to minimum dwelling standards saying something like: it is an aspiration of the Council to ensure that all new dwellings built in the City at least reach the minimum sizes required for affordable homes.
We believe there is a place here to refer to choice of more sustainable materials and other issues such as waste and recycling of materials.
Waste and Minerals Development Framework
We have made a number of representations relating to this plan:
Issue W1 There is a need to minimise the amount of waste that is produced: We fully support this and will use our influence with our members to spread the message;
Policy: CS1b Minimising waste during construction and demolition: We welcome the 100% suggested recycling target – however we feel it inappropriate to limit this to major developments only and we would encourage the councils to explore an approach where this target can apply to all but the smallest developments. In particular there is a need to explore how it will be possible to insist on all waste collected in skips to be sorted. Perhaps this requires a careful look at skip licences;
Policy: CS3 Meeting the need for new waste management capacity in line with the waste hierarchy: we welcome sentiment of policy. However we would like to see some indication of direction that helps the move towards the higher level of the hierarchy such as working with industry to increase materials recovery capacity and flows (eg plastics), retailers (return goods) etc.. We feel such additional strategic thought which will have an impact on land use should surface here (and will put W6 into a better context).
Policy: CS4 Distribution and scale of strategic waste recovery facilities. Sets out criteria and a long list of Development Control considerations: The Society’s view is that it is critical with any waste to energy installation that both heat and electricity is extracted – this should not be left as an option.
The programme for preparing the Waste and Minerals Core Strategy (as set out in the Council’s published ‘Local Development Scheme’) is currently being reviewed.