Boundary of masterplan area

Issue

Options and responses

Comments and actions

Should the boundary be limited to the Conway Street Industrial Area Strategic Allocation, or be expanded to include additional opportunities in the wider area?

· If the area is limited to the strategic allocation alone, opportunity to include and integrate certain potential nearby opportunities will be lost.

· Conversely, if the area of coverage is too extensive, the masterplan could be too complex to deliver.

A	A Strategic Allocation only - Limiting the masterplan area to the Conway Street Industrial Area Strategic Allocation as defined within City Plan Part One Policy DA6	1
B	DA6 land south of the railway - Widening the masterplan area to include additional land south of the railway within the DA6 area.	4
C	All land within DA6 area - Widening the masterplan area even further to include all land within DA6.	8
NB – regardless of where the boundary is determined, the masterplan will examine the wider area context and issues of connectivity (including strengthening north-south connections across the railway).
Total responses		13

Expressions of support for all Options, with strongest support for Option C, followed by Option B and one expression of support for Option A.

Written representations from Hove Station Neighbourhood Forum expressed strong support for Option C, in order to deal with ‘crucial’ issues of north-south (and east-west connectivity). They commented that the Neighbourhood Plan Part 2 sets out indicative long term proposals for Old Shoreham Road frontage to the Trading Estate and the Goldstone Retail Park- areas that are not included in the 3 current major development proposals/projects to the north of the railway within DA6 which could be developed as part of a DA6 Master Plan.

Written representations from Royal Mail (owners of the sorting office located south of the railway within DA6) expressed support for Option C in order to ensure a more comprehensive plan for the area – and a preference for Option B over Option A.

Actions

· Core masterplan area will comprise all DA6 land to the south of the railway.

· Masterplan will also examine opportunities within the DA6 area as a whole (i.e. including that area lying to the north of the railway) to overcome the physical severance caused by the railway and help guide and deliver future development proposals that combine and integrate both with each other and the wider area.

Sustainable transport

Issue

Options and responses

Comments and actions

How can the masterplan best take advantage of the area’s location (close to the train and bus network) to maximise opportunities to support and increase sustainable forms of transport?

A	‘Business as usual’ approach – No further detail or guidance to City Plan policies required.	1
B	Mixed mode approach – Providing a traffic-calmed environment that allows for general car ownership along with sustainable transport modes including walking, cycling and use of public transport.	4
C	Radical approach – Prioritising car-free development and a pedestrian and cycle-focussed environment with integrated sustainable transport service provision.	8
Total responses		13

Expressions of support for all Options, with strongest support for Option C, followed by Option B and one expression of support for Option A.

Written representations from Hove Station Neighbourhood Forum expressed strong support for Option C. Stated that this approach should be used to complement some parts of DA6 with traffic calmed streets and roads . Commented that they supported the traffic calming element of the Hove Gardens Project and strongly advocate the traffic calming of Newtown Road/Wilbury Road/Fonthill Road (in Neighbourhood Plan Part 2).

Written representations from Royal Mail commented that “all development within policy DA6 should maximise opportunities to support the station and the adjacent bus services to promote sustainable travel. In terms of the three options provided, the masterplan must be realistic in what it is seeking to achieve. For this aspect of the SPD, there is an opportunity to go beyond the ‘Business as Usual’ approach, and the ‘Mixed Mode Approach’ is considered appropriate. This does allow car ownership but promotes the sustainable transport modes highlighted allowing for development of sites to be maximised without the challenge of car parking on site. The ‘Radical Approach’ is not considered realistic at present.”

Actions

Masterplan brief will reflect general support for delivering an overall environment where the needs of pedestrians and use of sustainable forms of transport are a guiding principle of future development, while having regard to delivering a viable and successful neighbourhood that integrates well with the wider area.

Public Realm and community facilities

Issue

Options and responses

Comments and actions

How should the masterplan help provide for social inclusion along with a high quality, safe and secure public realm that meets the needs of its communities.

(‘Public realm’ refers to public spaces including public routes and all other open spaces accessed by the public)

A	‘Business as usual’ approach – No further detail or guidance to City Plan policies required.	0
B	Indicative approach – Identifying key opportunities/locations within masterplan area for community uses/ hubs and public open spaces.	3
C	Detailed approach –Identifying locations for community uses/hubs and the type of community facilities required and providing illustrative concept design guidance for public realm and open spaces.	8
Total responses		13

Some support for Option B; stronger support for Option C.

Written representations from Hove Station Neighbourhood Forum expressed strong support for Option C. Commented that the Neighbourhood Plan ‘already delivers much of the indicative approach of Option B by identifying Community Hub 1 Hove Station and Community Hub 2 Sackville Rd/Conway St/Clarendon Rd. as locations for improved/enhanced community facilities in an improved public realm environment, to be funded in part by developer contributions. ‘Moreover, NP Part 2 includes Community Hub Improvement projects which have been developed over two years, through joint workshops with local stakeholders and residents. These projects already provide initial ˜illustrative concept guidance” and are ready to be further developed as an important component of the SPD.

Written representations from Royal Mail commented that “In line with the aims and objectives of the National Planning Policy Framework, developing mixed communities is essential in development proposals. A key part of this is the provision of safe and secure public spaces. The SPD provides the opportunity to commence assessment of areas that may be suitable for community uses and open space. For this reason, the ‘Indicative Approach’ is considered suitable in this instance. A ‘Detailed Approach’ at this stage is considered unnecessary and too prescriptive, particularly given the potential for Royal Mail’s site to either remain in employment use or be redeveloped for residential.

Actions

Masterplan will, where practicable and/or appropriate identify potential locations for community uses/hubs and the type of community facilities required; and provide illustrative concepts to guide the design of public realm and open spaces.

Building heights

Issue

Options and responses

Comments and actions

Hove Station Area has been identified as a ‘node’ suitable for taller development. What types of guidance should the masterplan provide in relation to building heights?

A	‘Business as usual’ approach – No further detail or guidance required to City Plan policies and other relevant planning documents.	1
B	‘Broad brush’ approach - Testing strategic views of the masterplan area and identifying key sensitivities. Providing general advice in establishing a ‘tall buildings cluster’.	2
C	Detailed approach - Providing more specific advice on building heights, densities and massing for each specific development plot within the masterplan area.	9
Total responses		12

Strong overall support for Option C

Written representations from Hove Station Neighbourhood Forum expressed strong support for Option C. Commented that: “the ˜tall buildings cluster” is fully embodied in the NP Part 1 and Part 2. It will be substantially established by the likely approval of the MODA application which aligns high buildings along the north side of the railway line, in parallel with the Clarendon-Ellen Estate 10 storey blocks to the south. In the Conway Street Industrial Area between them the recently approved Hove Gardens project establishes the starting point for ‘…providing more specific advice on building heights, densities and massing for each specific development plot within the Masterplan area.’”

Written representations from Royal Mail commented that “it is essential that guidance for taller buildings within the Conway Street Industrial Area Masterplan SPD retain flexibility given the constant change in circumstances. The Design Document produced pursuant to the Royal Mail site demonstrates that it is capable of providing a ten-storey residential building without impacting identified constraints or neighbouring properties. An allocation for the site within the masterplan should thus reflect this potential with suitably flexible wording should it no longer be required by Royal Mail, ensuring the area can be comprehensively planned. The proposed ‘broad brush’ or ‘detailed’ approach may be a useful barometer for testing potential of areas. However, for reasons such as uncertainty over the availability of land and buildings, the policy should not be restrictive in its nature. In this scenario, a restrictive policy may prevent additional residential development in a sustainable location, where there are no material considerations that would prevent taller development.

Planning applications should be judged on a site by site basis in line with policies within the City Plan One and emerging City Plan Two at the time. The ‘Business as Usual’ approach is therefore preferable in this instance.”

Actions

Masterplan brief will require detailed analysis to be undertaken in order to provide indicative guidance on heights, density and massing of buildings. It should be noted that, in addition to any advice that is formulated via the masterplan, further detailed testing and justification will continue to be a policy requirement in respect of any planning application involving a tall building.

Existing businesses

Issue

Options and responses

Comments and actions

How can the masterplan help address the needs of existing businesses in the Conway Street Industrial Area?

A	‘Business as usual’ approach – No further detail or guidance required to City Plan policies, with the council’s Economic Development team providing assistance where possible to help displaced businesses find new accommodation.	3
B	Relocation approach – As above – and identifying opportunities for wide range of new workspaces with potential to meet needs of both existing and future businesses within the masterplan area.	9
Total responses		12

Some support for Option A, with stronger support for Option B.

Written representations from Hove Station Neighbourhood Forum expressed strong support for Option B. Commented that “the Neighbourhood Plan stresses the importance of providing sufficient affordable work spaces in the redevelopment of DA6 to accommodate the creative enterprises which need low cost premises currently provided in Industrial House. Our Community Hub 2 Improvement Project for the Sackville Road /Conway Street area was developed by a group of community and business stakeholders. The owner of Deacon Labs made it clear that he would be happy to re-locate and enable the site to be redeveloped with some of the developer contributions invested in the Community Hub, but so far been unable to find an alternative location.”

Written representations from Royal Mail commented that, “of the two options provided, the ‘Business as Usual’ Approach is considered the most appropriate at this stage. This is due to the individual circumstances of each of the businesses within the site area. Input from the Council’s Economic Development team is welcome in assisting in the potential relocation of some businesses. It is important to understand the regeneration of the area will provide a mixed use area, with certain areas more likely to be suitable for employment uses than others.

Royal Mail are also open to the potential for relocating within the SPD area should an appropriate opportunity arise. This could release the current Royal Mail site for residential uses that provide greater benefit in terms of, for example, densities. At present it is an under-utilised asset. The SPD also must take account of the emerging Hove Station Neighbourhood Plan, the Regulation 14 consultation for which is currently open. This provides a more local view of the regeneration of the area. Conflict between the two would cause uncertainty to land owners and may hinder regeneration.”

Actions

Masterplan exercise will review range of workspace requirements of existing businesses in the area and will examine opportunities for including new workspaces with potential to meet needs of both existing and future businesses within the masterplan area.

Development phasing and viability

Issue

Options and responses

Comments and actions

If phasing requirements for development are too rigid, there is a danger that investment is not forthcoming; if too relaxed, there is a danger that only the more profitable elements get constructed and vital infrastructure fails to come forward.

How can the masterplan provide helpful guidance on development phasing and viability to help ensure its overall delivery?

‘Business as usual’ approach – No further detail or guidance to City Plan policies required.

Strategic approach - Running a viability check and including an advisory strategy on phasing and funding, to help ensure an ‘equitable’ approach across the masterplan area. Profitable developments would be expected to cross-fund and bring forward less profitable elements, including open spaces and community facilities.

Total responses

Some support for Option A, with stronger support for Option B.

Written representations from Hove Station Neighbourhood Forum expressed strong support for Option B. Commented that: “the Neighbourhood Plan (NP) proposals for the phased, comprehensive redevelopment of DA6 South advocate and provide a framework for this approach and this was the basis of our support for the first phase Hove Garden project. We argued that although 19% - now 10% - is well below the NP policy of 40% ‘affordable’ housing, a higher proportion would be required for the subsequent phases. The NP gives priority for the investment of the 25% Neighbourhood Portion of CIL to the delivery of open spaces and community facilities in DA6 south. The SPD must develop an implementation strategy which delivers this outcome.”

Written representations from Royal Mail commented that “Phasing requirements for development should be determined by the market. This generally brings appropriate sites forward for development at optimum times. Seeking to restrict phasing to certain timeframes will impact upon the availability of sites. Phasing within a scheme is not likely to be a key factor given the potential plot sizes and the number of landowners across the SPD area. The ‘Business as Usual’ option is therefore the most appropriate. Viability will be a key matter in the preparation and consideration of planning applications. All development parcels will have different factors that may affect the viability. The SPD cannot provide a broad-brush approach for each sites given the differences they will all have. As a result, the ‘Business as Usual’ model is essential. Whilst the fine line between too rigid and too relaxed policy is noted, the danger of stopping development from coming forward is considered a much greater risk at the masterplanning stage.

Actions

It should be noted that future planning applications will continue to be considered on their own merits, with regard to adopted planning policy and other material considerations. Masterplan will be informed by a viability check and will include an advisory strategy on phasing and funding, to help guide and ensure delivery of key social and environmental infrastructure, along with the more profitable development opportunities.

Surface water flooding

Issue

Options and responses

Comments and actions

How can the masterplan play a role in ensuring development incorporates appropriate measures to reduce the risk of surface water flooding in the masterplan area and the wider neighbourhood.

A	‘Business as usual’ approach – No further detail or guidance to City Plan policies required.	3
B	‘Broad brush’ approach - Referencing a range of good practice on ‘climate change resilient’ design.	8
C	Detailed approach - Providing specific design guidance and identifying opportunities within the masterplan area to ensure development is both ‘climate change resilient’ and helps alleviate surface water flooding in the wider area.	2
Total responses		13

One respondent noted that while this option included an option C (detailed approach) on the paper version (which they would have chosen) the online version did not offer it. Written representations from Hove Station Neighbourhood Forum expressed strong support for Option C (although they selected Option B on the online form, presumably for the above reason)

This unintended anomaly re. the online form has been noted (and the response table has been amended to take this into account).

Written representations from Royal Mail commented that “The purpose of the SPD is to assist in the interpretation and implementation of planning policies. In terms of flooding, the Council has existing policies relating to flood risk and drainage. Policy CP11 of the City Plan One provides a clear and precise guide to the expectation of what development should deliver. Whilst drainage will be a factor for all sites to consider, the ‘Business as Usual’ approach is considered appropriate in this instance, with reference to those existing policies suitable. Should Approach B be the preferred option, then it should be clearly noted the range of good practices are not mandatory. Again, each site is different and what works at one may be inappropriate at another.”

Actions

The masterplan will be informed by both options ‘B’ and ‘C’. It will identify opportunities for climate change resilient measures to be ‘woven in’ to the built environment and landscaping where appropriate (e.g. within the design of open spaces and roads) while referencing good practice where this may be helpful.

Energy networks

Issue

Options and responses

Comments and actions

The council intends to commission an energy network feasibility study of the wider Hove Station Network. How can this work best be integrated with the masterplan?

A	‘Business as usual’ approach – No further detail or guidance to City Plan policies required.	2
B	Integrated masterplan approach - Ensuring that Masterplan is informed by and integrates with the Energy Network Feasibility Study.	11
Total responses		13

Some support for Option A, with stronger support for Option B.

Written representations from Hove Station Neighbourhood Forum expressed strong support for Option B. Commented that “Issues 7 and 8 are important components of planning for a low carbon Hove Station Quarter. The Neighbourhood Plan has drawn on best practice by reference to the Local Carbon Neighbourhood Planning Guidebook. It will be important that the SPD takes this dimension a stage further to ensure that the new quarter is fit for 21st century purpose.

Written representations from Royal Mail commented that “the Council’s intention to provide a network feasibility study is noted and encouraged. However, there are concerns as to how it could become incorporated within the production of the SPD. The ‘Integrated Masterplan Approach’ will not allow the potential flexibility required in bringing sites forward for development. The ‘Business as Usual’ is more appropriate. The SPD could however explore how development could link into a site-wide network where appropriate.”

Actions

The council will ensure that the masterplan and energy network feasibility study are complementary, with each informing the other. The Invitation to Tender for these work-streams will be suitably structured to achieve this objective.

Equalities

Issue

Responses received

Comments and actions

If you consider the Conway Street Industrial Area Masterplan (Supplementary Planning Document) to have any equalities implications, positive or negative? If so, please provide further details.

· As long as the needs of those with disabilities are met so as to allow them to work, live and enjoy the new development area...potential to be positive if the transport and access arrangements are well thought through

· To not exclude marginalised individuals, the plan must take into account the needs of people who struggle to afford rent in the city. It needs to include provision of social and affordable housing.

· There is a question of social discrimination that needs to be addressed. The argument exists that long term residents feel they will be pushed out or priced out of the area. Social and affordable housing must be adequately spread throughout the redevelopment area and the Master Plan can set a standard for this, i.e. no separate entrances or social housing ghettos.

· Waste management in this location is a waste of good space which should be used for housing, school etc etc

Equalities comments are noted. These issues are covered under existing City Plan policies. They will be integral in informing the masterplan process.

Additional comments and suggestions

Issue

Comments and actions

· Little information on trees/nature and biodiversity opportunities/needs being addressed in the overall masterplan. Lots of trees and green spaces are required (as well as water management) for inclusion in this plan.

· Concern regarding the management of traffic during and following the development of this area, with existing "rat-running" twice a day on Ellen Street becoming even more intense once the area is more densely occupied. What plans are proposed to manage traffic flow?

· Small studio spaces should also be in the area designated for waste management

Noted. Landscaping and biodiversity were always intended to be – and will be - integral elements for inclusion in the masterplan (along with a range of other ‘default’ planning and masterplan considerations that weren’t deemed necessary for inclusion in the issues and options paper).

Traffic flow issues and preventing rat-running will form part of a wider consideration to provide sustainable transport focussed-solutions, a high quality public realm and a safe, pedestrian-friendly environment.

Noted. It is assumed that this comment relates to the coal yard site on the north side of the railway