Brighton & Hove City Plan Consultation

Brighton and Hove City Council consulted on Part 2 of their City Plan in Autumn 2020. SWT is now waiting for BHCC to submit the plan to the Planning Inspectorate for examination.

Read the Sussex Wildlife Trust's official response to the consultation here: FINAL Sussex Wildlife Trust response to City Plan Part Two Reg 19 Oct2020

You can read more about the stages of the plan making process on the Brighton and Hove City Council website

Frequently Asked Questions about the Brighton and Hove City Plan consultation

What is a ‘Part 2’ Plan?

Brighton & Hove City Council (BHCC) already have Part 1 of the City Plan which was adopted in March 2016. This sets out the long term vision and strategic objectives for the city until 2030, along with strategic policies and importantly the overall amount of development that should be delivered in the city.

Part 2 of the City Plan has been written to support and compliment the policies in the City Plan Part 1. It adds more detail of what development needs to deliver in the Development Management Policies and importantly allocates more sites to deliver the development set out in Part 1. The policies in Part 2 cannot contradict with what is already agreed in Part 1.

What is Sussex Wildlife Trust saying in their response?

Whilst the Sussex Wildlife Trust is supporting a number of development management policies, we are objecting to policies SA7, H1 and H2. This is because these policies allocate housing on a number of Local Wildlife Sites, including Benfield Valley, and on Whitehawk Hill Local Nature Reserve.

We realise that there is a big need for affordable homes in the city. However, we don’t think that developing these sites will significantly help this need, but it will destroy some really important places for wildlife.

We understand that the City Plan Part 1 has already set a precedent for developing some of the urban fringe in Brighton and Hove, but this doesn’t mean the council have to allocate sites that are supposed to be protected for their biodiversity value. In particular, developing Whitehawk Hill LNR will destroy a big part of the LNR, right at its narrowest point. This is an ancient landscape of huge value for wildlife and local people that should be cherished by the Council.

Some of the allocations in policy H2 are on Local Wildlife Sites, but they already have planning permission as the developers didn’t want to wait for the adoption of the Part 2 Plan. Whilst we are disappointed about this, we have decided not to object to these allocations as development is already happening or about to start. 

What can I say in my comments?

This is a pre-submission consultation, also known as a ‘Regulation 19’ consultation. At this stage, comments have to relate to whether the Plan complies with all the relevant legal requirements and whether it is ‘sound’ in terms of national planning policy. BHCC have provided further information explaining these requirements in their Guidance Note. We strongly recommend that you read this before responding.

It is important that you relate your comments to these requirements, as this is what the Planning Inspector will test the Plan against. All representations submitted during this consultation will be submitted for consideration by a Planning Inspector at the Plan Examination, which is likely to be in 2021. However, the Inspector will only take notice of those comments that are justified in relation to the test of soundness or legal compliance.

For example, a comment that just says ‘I object to this policy’ will have more impact if it is followed with a sound reason for the objection. For example, the Sussex Wildlife Trust is objecting to the housing allocations on locally designated sites of biodiversity value in policy H2 because we don’t think this is consistent with the requirement in paragraph 174 of the National Planning Policy Framework. Paragraph 174 says that locally designated sites should be safeguarded in local plans.

It is also helpful to suggest what changes need to be made to improve the issue. For example, removal or changes to the boundary of a site allocation or perhaps changes to the wording of a policy. We are asking for the deletion of all the housing allocations on Local Wildlife Sites (that do not already have planning permission) and on Whitehawk Hill LNR.

You can support and object to different parts of the Plan and you do not have to comment on every section.

What evidence do I need to provide in my response?

It is important to remember that this is the last opportunity to make submissions on the Plan, so your response needs to include any evidence you want to rely on to make your point. All representations will be passed to the Inspector and then they will decide if an issue warrants further discussion during the Examination.

Whilst you may be able to speak to the Inspector at the Examination hearings, they will expect you to rely on the information you submitted during this consultation. Usually Inspectors don’t allow further evidence to be submitted during the Examination.

Any evidence submitted with your response should be clear and to the point. Additionally, only representors who are seeking a change to the Plan have a right to be heard at the Examination hearings.  

Do I have to respond online?

BHCC would like you to respond via their online Consultation Hub, as this makes it much easier for their planning team to go through all the hundreds of comments that are probably going to receive. It also makes it very clear which section or element of the Plan the comment is about and helps you to justify your comment in relation to legal compliance or the test of soundness.

If you do not want to use an online system, you don’t have to. BHCC will accept responses by paper or email. However, you must make sure you make it very clear which parts of the plan you're talking about, otherwise your comments might be misinterpreted. The easiest way to do this is to fill out the Word version of the Response Form.

You can request a copy of the Response Form by emailing [email protected]  

You can also send in your response form in hard copy to: Proposed Submission CPP2, Policy Projects and Heritage Team, Brighton & Hove City Council, First Floor Hove Town Hall, Norton Road, BN3 3BQ. But remember it must be received on or before the 30 October to be counted.