Planning strategy

Hove Civic Society seeks to make representations on major plans affecting our locality. The Council has recently decided to produce a City Plan. This supersedes the work done on the Local Development Framework, which has been abandoned. Our representations below are still relevant and we will seek to influence the Council to meet our objections in the new City Plan. 

City plan

http://www.brighton-hove.gov.uk/index.cfm?request=c1148443

On November 24, 2011 we made representations on two of the options papers:

Housing paper

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.

Employment paper

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 Development Framework (LDF)

http://www.brighton-hove.gov.uk/index.cfm?request=b1150385

We have made 3 representations challenging the soundness of the core strategy:

Representation 1

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

Representation 2

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.

Representation 3

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

http://www.brighton-hove.gov.uk/index.cfm?request=c1147827

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

http://www.brighton-hove.gov.uk/index.cfm?request=b1150385

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.