Brighton and Hove Local Development Framework 2006

Site Allocations

Response of the Regency Society of Brighton and Hove to the Consultation

General
1 We are alarmed to hear that in meeting the imposed regional target of 11,000 new homes by 2026, the Council can no longer make reasonable assumptions based on ‘windfall sites’. In such a heavily constrained urban area, these have always formed part of the provision of new accommodation. They arise from unexpected events; the closure of firms or institutions. Whilst one might expect a gas works to go over time, who would have guessed in the early 1980s that three convents would close in Hove in the next two decades. Identifying sites that might not be available will lead to controversy and even heartache for their owners.

2 We wonder why it should be assumed that all employment sites will be retained. These are not always situated in convenient locations and may be bad neighbours. Planned relocation, freeing land for other development would be a better solution in some cases.

3 We remain opposed to further expansion onto the downland fringe of the conurbation.

4 At the public meeting our concerns about infrastructure capacity were dealt with by referring us to the Infrastructure Capacity Assessment prepared by Baker Associates. In this paragraphs 7.9.15-16 state

“New development also requires sewers and wastewater treatment. SouthernWater has put in an application for a new wastewater treatment works (WTW)and trunk sewers having had its previous application for the expansion of itsexisting Portobello works refused. Improvements to the sewerage system are considered but there is not the same future horizon for the works as there is for water supplies although any sewer works would allow for a certain amount of future development.The new WTW will be sized to allow for all anticipated development until2025. The scheme will include new sewers to transfer flows to the new WTW. Southern Water have found it difficult to comment about sewer capacity as the proposed location and size of a development is required to assess if spare capacity is available. In many parts of Brighton the drainage is a combined sewer and if redevelopment proposed to dispose of surface water via soakaways etc. then spare capacity would be created.”

We do not find these comments at all reassuring.

Eastern Sector

Eastern Road
As this corridor is already severely overloaded by the concentration of health facilities, we do not see much scope for more development. Ideally the tall blocks on the north side east of Lower Rock Gardens would be demolished in favour of lower, high density housing. This would improve the street scene and remove a blot on the Kemp Town/Kingscliffe skyline as viewed from the south.

Brighton Marina
We agree that the area around ASDA and the David Lloyds centre could be radically improved as could the traffic circulation but present indications are that too much new units are being planned and will impact on the cliff line. We remain concerned about the use of only one access into the area on safety grounds.

Lewes Road
Whilst there are a necklace of sites along Lewes Road which could benefit from redevelopment, we are opposed to high rise including Preston Barracks.

Central Sector

Brighton Station
We are not sure that there is any further scope for more development in this area over and above that set out in the Planning Brief. We are disappointed in the standard of development built so far.

Central Seafront Area
This area represents a major opportunity, but also a challenge, to replace the unsightly Kingswest and Brighton Centre and replace them with a stunning modern buildings linked to Churchill Square. The sketches published in The Argus earlier this year were very disappointing. We trust that the setting of St Paul’s, West Street will be carefully considered.

London Road/Preston Road Corridor
There are a number of unsightly vacant and underused sites facing Preston Park which could benefit from new well designed development. However, the setting of the park will be important. If new buildings are high rise, they will reduce the apparent size of the park to its considerable detriment as a major historic and recreational feature in the city. In London Road, the Open Market offers a significant opportunity and we have been impressed by initial sketches put on display in the Jubilee Library. Conversely, we are concerned that the Council’s preferred scheme for Circus Street exceeds the brief by including a tall element which would impinge on views in Valley Gardens.

West Sector

Western Seafront/Kingsway
In the mid-1970s the Hove Borough Council reversed its policies of encouraging comprehensive residential redevelopment on the north side of Kingsway in favour of a conservation-based approach. We feel that this policy should be retained in order to provide for good neighbours to the north-south roads south of New Church Road and to lessen traffic generation on the Kingsway.

Old Shoreham Road Corridor
When the A27 by-pass was proposed, one of the benefits was to be the reduction in east-west (and west-east) traffic flows along this road; the former trunk road. Thus a policy was designed to ensure that it would not become the location for new traffic generating uses. This policy seems to have been undermined in recent year but we feel that it had considerable merit. It is against this background that new development should be proposed. This road also has a domestic, low-rise scale, and taller buildings would be unneighbourly and out of context.

Shoreham Harbour
This harbour is underused and also used in a way which does meet its potential. It represents the best location for urban renaissance in the city . New standards of high design could be set. But the traffic problems will have to be met in an environmentally sustainable way which does not damage residential areas to the North.

Portland Road
The scale of Portland Road precludes much new development but opportunity sites do exist. Recent development centred on the former Portland Gate has shown how these opportunities can be met.

Hove Station
This site could be improved as a transportation interface for different transport modes and offers opportunities for improvement especially in the Conservation Area and former industrial/railway land adjoining the station.

Additional sites
In addition we would continue to resist strongly any proposals for development on the “Falmer site” adjoining Brighton University. We do not feel that this a proper site for a Community Stadium or any other building/s. Conversely , we would recommend the inclusion of Black Rock/Sheepcote Valley as a site for the Stadium.

Brighton City Council has asked for responses to its Local Development Framework proposals: the Society's reponse to Site Allocations follows.