PM010 A SPATIAL STRATEGY FOR BRIGHTON AND HOVE

CPRE Sussex welcomes and supports the Council's recognition, in the proposed new paragraph 2.20, that much of the land within the city's defined urban fringe forms part of the city's green infrastructure either as open space or part of the city's biodiversity resource (although these are not necessarily mutually exclusive). However, this paragraph should also recognise that much of the land within the defined urban fringe is also of high landscape sensitivity.

This recognised in paragraph 7.29 of the Brighton & Hove Local Plan, which states in part, "Countryside areas outside the AONB in Brighton & Hove are felt to be of exceptional quality. It is therefore felt that such areas should be afforded similar protection to other areas of exceptional landscape value which are included in the formally designated AONB. These areas have already enjoyed similar protection for many years by virtue of the policies in previous local plans.” In addition to its inherent sensitivity, the urban fringe forms the setting of the South Downs National Park. Although the National Planning Policy Framework does not specifically protect the setting of National Parks, it is clear that landscape and scenic beauty of the National Park could be adversely affected by inappropriate development within its setting. This was recognised in paragraph 7.41 of the Brighton & Hove Local Plan and in a statement by the then Planning Minister, Nick Boles, in April 2014. The then Minister referred to the Planning Practice Guidance published in March 2014, which explains the duty of local planning authorities to "have regard" to the purpose of national parks ‘in exercising or performing any functions in relation to, or so as to affect, land’ in national parks. The then Minister further explained that the guidance is clear that the duty is relevant in considering development proposals that are situated outside national parks, but which might have an impact on the setting of, and implementation of the statutory purposes of, these protected areas.

It is therefore very important that particular care is taken over the design of any development proposed within the urban fringe, so that potential adverse impacts on the quality of the urban fringe landscape and the National Park are avoided as far as possible and mitigated as far as possible where adverse impacts are unavoidable and outweighed by any benefits of the development. The design of new development should particularly seek to avoid adverse impacts on the tranquillity of the National Park through light or noise pollution. Paragraph 2.20 should highlight this importance.

 PM045 DA7 TOAD'S HOLE VALLEY

CPRE Sussex believes that the proposed development of Toads Hole Valley, as promoted by Policy DA7, will only be acceptable if it the resulting development would create an exemplary suburb that would:

• complement the unique landscape of the site and its surroundings
• safeguard strategic views of the South Downs and the sea.
• create a well-balanced mixed-use sustainable garden suburb following TCPA Garden City Principles
• conserve and enhance the biodiversity of the valley
• bring benefits for the neighbouring communities in Goldstone Valley, Hangleton and Nevill
• mitigate the impact of traffic and traffic noise on the neighbouring areas
• ensure the costs of maintaining the public areas of the valley and serving it with public transport are met by the development

Accordingly, CPRE Sussex objects to the the Proposed Modifications to Policy DA7, which we consider would weaken the Policy's requirements e.g. the proposal to replace "Ensure that" and "is of an" in clause 2 with the weaker "will aim to be an"; the addition of "seeks to" in clause 3; and the replacement of "To secure" with "provide the opportunity to benefit" in clause 4.

We consider that these Proposed Modifications would weaken the Policy's ability to deliver the exemplary suburb that this extremely sensitive site demands.

Potential adverse impacts on the National Park must indeed be avoided as far as possible and mitigated as far as possible where adverse impacts are unavoidable and outweighed by any benefits of the development. 

PM064 SA4 URBAN FRINGE

CPRE Sussex welcomes and supports paragraph 3.154's recognition that much of the city's urban fringe meets the NPPF definition of existing open space and represents a significant proportion of the city's open space resource. We also welcome and support the recognition of the biodiversity importance of the urban fringe.

However, this paragraph should also recognise that much of the land within the defined urban fringe is also of high landscape sensitivity.

This is recognised in paragraph 7.29 of the Brighton & Hove Local Plan, which states in part, "Countryside areas outside the AONB in Brighton & Hove are felt to be of exceptional quality. It is therefore felt that such areas should be afforded similar protection to other areas of exceptional landscape value which are included in the formally designated AONB. These areas have already enjoyed similar protection for many years by virtue of the policies in previous local plans.” In addition to its inherent sensitivity, the urban fringe forms the setting of the South Downs National Park. Although the National Planning Policy Framework does not specifically protect the setting of National Parks, it is clear that landscape and scenic beauty of the National Park could be adversely affected by inappropriate development within its setting. This was recognised in paragraph 7.41 of the Brighton & Hove Local Plan and in a statement by the then Planning Minister, Nick Boles, in April 2014. The then Minister referred to the Planning Practice Guidance published in March 2014, which explains the duty of local planning authorities to "have regard" to the purpose of national parks ‘in exercising or performing any functions in relation to, or so as to affect, land’ in national parks. The then Minister further explained that the guidance is clear that the duty is relevant in considering development proposals that are situated outside national parks, but which might have an impact on the setting of, and implementation of the statutory purposes of, these protected areas. It is therefore very important that particular care is taken over the design of any development proposed within the urban fringe, so that potential adverse impacts on the quality of the urban fringe landscape and the National Park are avoided as far as possible, and mitigated as far as possible where adverse impacts are unavoidable and outweighed by any benefits of the development. The design of new development should particularly seek to avoid adverse impacts on the tranquillity of the National Park through light or noise pollution. Paragraph 3.154 should highlight this importance.

PM065 SA5 THE SOUTH DOWNS

Potential adverse impacts on the National Park must indeed be avoided as far as possible and mitigated as far as possible where adverse impacts are unavoidable and outweighed by any benefits of the development 

PM066 SA5 THE SOUTH DOWNS

Paragraph 3.168 should include a reference to conserving and enhancing the natural beauty of the South Downs National Park, which forms part of the first purpose of National Parks, and to tranquillity (the absence of artificial light and/or noise) as an important characteristic of the National Park. Priority 4 should refer to all cultural heritage assets, not just scheduled monuments - the first purpose of National Parks refers to "cultural heritage" and not all archaeological remains of national importance are scheduled.

Download the Proposed City Plan changes and the objection documents below.