Adoption of Urban Design Framework Supplementary Planning Document

Date of Meeting:

17 June 2021

Report of:

Executive Director Economy, Environment, & Culture.

Contact Officer:


Paula Goncalves


01273 292352



Ward(s) affected:

All Wards






1.1         This report provides an update on the preparation of the Urban Design Framework Supplementary Planning Document (UDF SPD) and seeks adoption of the final version of the Supplementary Planning Document.


2.         RECOMMENDATIONS:    


That the Tourism, Equality, Communities and Culture Committee:


2.1         Notes the consultation on the Draft Urban Design Framework Supplementary Planning Document (Appendices 2 and 3) and the changes made to the Draft UDF SPD as a result of consultation responses (Appendix 4); and


2.2         Agrees to adopt the Urban Design Framework Supplementary Planning Document (Appendix 1) as part of the city’s suite of planning documents subject to any minor grammatical and non-material text and illustrative alterations agreed by the Head of Planning in consultation with the Chair of the Committee prior to publication.




3.1         The Urban Design Framework (UDF) is specifically referred to in Policy CP12 Urban Design in the adopted City Plan Part One and is signposted in the Spatial Strategy and other city-wide and Development Area policies of this Plan. It is also referred to in the submission City Plan Part Two policies (approved by Council April 2020) that set out criteria for assessing the design quality of places and buildings.


3.2         The aim of the UDF SPD is to illustrate how good urban design can be achieved and why it is vital to the delivery of inclusive, accessible, sustainable and climate resilient development. New development that will help to deliver better buildings, spaces and places for the city, its residents and visitors. As such, it will also help to achieve many of the objectives set out in the Council Plan 2020-23 – A Fairer City with a Sustainable Future.


3.3         The UDF has been prepared in the form of a Supplementary Planning Document (SPD). If adopted, the UDF SPD will be a material consideration to guide decision making on planning applications. It will assist the council in delivering the amounts and types of development proposed in City Plan Part One and Two in more innovative ways and through better quality design (but does not make new or change existing policies).


3.4         The UDF SPD identifies opportunities to support constructive design discussions between applicants, designers, planning officers, councillors and communities by outlining potentially appropriate solutions and illustrating best practice in the city and from elsewhere. The document is structured in three main sections that build on national and local design policy and guidance:

A.    Local priorities

This section focuses on design issues that are particularly important and relevant to Brighton & Hove and sets out design recommendations and principles to illustrate how the council would like to see local policy interpreted. It shows how well-designed new development can help the city to mitigate against and adapt to climate change.  The advice in this section is applicable to all types of development across the city. Local priorities are developed under three key design priorities: context, spaces between buildings and buildings themselves.

B.    Tall buildings

This section sets out additional design considerations that are particularly relevant to development that is 18 metres or more in height and/or significantly taller than its surroundings. It also provides design advice for each of the identified tall building areas in the city as set out in policy CP12 Urban Design in City Plan Part One. If the SPD is adopted, this section will replace guidance currently set out in Supplementary Planning Guidance SPGBH 15 Tall Buildings.

C.    Planning Process

This section describes the council’s preferred approach for engaging with applicants to resolve design issues both prior to the submission of a planning application and during the application process.

D.    Appendices

These provide additional information about some of the issues discussed in the guidance and also provides an extended list of policies and documents that should be read in conjunction with the SPD.


3.5         Each section of the guidance identifies the relevant City Plan policies, sets out key design principles and recommendations to help achieve better planning outcomes. It signposts a range of good practice examples to illustrate how multiple policy objectives can be achieved through high quality and holistic urban design including improving biodiversity and sustainability outcomes.


3.6         The UDF SPD builds upon and responds to the outcomes of earlier stakeholder consultation (undertaken in 2018 as ‘Issues and Options’) and comments received as part of the city-wide consultation on a draft version of the guidance undertaken in Autumn 2020.


3.7         A summary of the 2020 consultation including feedback received and how this feedback has informed changes to the final version of the UDF SPD is given in section 4 with details in the appendices.




4.1         A city-wide public consultation to get feedback on the draft version of the UDF SPD was carried out for over six weeks from 23/10/2020 to 11/12/2020. The public in general and stakeholder organisations and individuals, including residents, developers, landowners, local ward councillors, planning agents and amenity groups registered in the Planning Policy database were invited to comment. The consultation included:

§  5 dedicated online events for stakeholders;

§  12 online briefings for local city partnerships;

§  a survey posted on the council’s online Consultation Portal;

§  opportunities for people without internet access to view consultation documents using computers in council libraries given that the council was unable to make paper copies available due to Covid-19 restrictions; and

§  communication of consultation details via 2 press releases posted on the council’s website and alerts posted in the council’s social media outlets.


4.2         The council received 77 responses in total. The detailed findings and transcript of all responses received as part of this consultation are set out in Appendices 2 and 3 respectively. A table demonstrating how comments informed the changes made to the final version of the UDF SPD is provided in Appendix 4.


4.3         Overall, there was broad support for most aspects of the guidance. Some minor changes made to the wording, graphics and good practice examples have been made in response to comments/suggestions put forward by respondents. The issues that resulted in more significant changes to the final version of the UDF SPD included:


You said

We responded

Section A Local priorities

Recommendations set out in the green boxes are at times overly prescriptive and/or read as policy.

Wording has been revised to clarify that recommendations and principles are advisory and do not constitute new policy.

Request to add new strategic views and landmarks set out in sub-section 1.4 Views and landmarks.

Bevendean Down and Surrenden Road met criteria for strategic views and the Peace Statue for landmarks and have been added to respective lists.

Section B Tall buildings

This section attracted the largest number of responses, including requests to align the guidance for Tall Building Area 9 Shoreham Harbour with the adopted Shoreham Harbour Joint Action Plan (JAAP) and to clarify the boundary for Area 1 Brighton Marina with that set out in City Plan Policy CP12 Urban Design.

Advice on indicative boundary, height ranges and design considerations for Tall Building Area 9 Shoreham Harbour now reference guidance set out in the JAAP.

The indicative boundary for Tall Building Area 1 Brighton Marina has been revised to exclude areas outside the Marina itself.

Section C Planning process

Need to reflect the requirements of different types of application and account for the role of planning conditions in enabling details to be sorted at the later stages of the design process

Wording in sub-sections 7.1 – 7.4 and process diagram indicate how different scales of development and application types can align with the four indicative stages and checkpoints and how these can be agreed in consultation with the Local Planning Authority.

Ensure comprehensive early consultation is carried out and feedback is sought from the local community prior to a planning application being submitted

Sub-section 8.1 has been introduced to provide guidance on community and stakeholder engagement including links to several specialist organisations. Wording updated in sub-sections 7.2 – 7.4 to recommend applicants submit community and stakeholder engagement information.

Cross-reference design stages diagram with RIBA Plan of Work 2020

Diagram amended to cross-reference RIBA Plan of Work 2020.


4.4         This consultation complied with the council’s Statement of Community Involvement (SCI) which sets out policy and standards for engagement in the preparation of planning documents, including supplementary planning documents.


4.5         The UDF SPD was subject to a screening exercise at an early stage of preparation to assess the need for a Strategic Environmental Assessment (SEA). The screening was subject to consultation with statutory environmental; bodies who agreed with the conclusion that the SPD did not require a SEA.





5.1         As part as the Issues & Options consultation, options were put forward ranging from a ‘business as usual’ City Plan policies only approach; a broad brush SPD to identify and summarise existing information available; or a more detailed SPD that provided as much detail as possible were all tested.


5.2         Permission to consult on the Issues & Options was granted by the Tourism, Development and Culture Committee on 21 June 2018. As the early stakeholder consultation report shows, overall, consultation respondents favoured a detailed SPD approach.



6.         CONCLUSION


6.1         The UDF SPD will help to deliver a higher standard of sustainable development and place-making through new development. It will help to contribute to achieving a number of city council priorities and provide clarity for officers, developers, residents and stakeholders.




Financial Implications:


7.1         The cost of officer time, document production and consultation associated with the recommendations in this report will be funded from existing revenue budget within the Planning service. Any significant financial implications arising from the outcome of the consultation and production of the Supplementary Planning Document will be reported in future committee reports.


            Finance Officer Consulted:     Name Jeff Coates                        Date: 18.05.2020


Legal Implications:


7.2         The contents of a SPD are governed by The Town and Country Planning (Local Planning) (England) Regulations 2012. To be lawful, a SPD must be limited to statements regarding “any environmental, social, design and economic objectives which are relevant to the attainment of development and use of land” which “the local planning authority wish to encourage during any specified period” [Regulation 5. (1) (a)].


7.3         Consultation on the draft UDF SPD has been carried out in accordance with the relevant statutory provisions.


Lawyer Consulted:                       Name Hilary Woodward          Date: 25.05.21


            Equalities Implications:


7.4         Equalities issues relevant to this SPD have been considered during the Health & Equalities Impact Assessment (HEQIA) undertaken on City Plan Part 1, particularly those identified for policies CP12 Urban Design and CP13 Public Streets and Spaces. The assessment did not find any particular sensitive groups that were affected by these policies. The Planning and Communities Engagement Teams undertook early engagement with some equality groups and other equality groups were included within the wider public consultation.


            Sustainability Implications:


7.5         Sustainable development is given a very high priority in the SPD. The guidance aims to help planning applicants to meet, and if possible exceed, City Plan sustainable development targets, foster high-density, mixed use development and deliver acceptable development in a way that positively responds to the city’s sensitive landscape, historic built environment and local priorities.


Any Other Significant Implications:


            Crime & Disorder Implications:


7.6         The preparation of the guidance set out in the SPD will allow for more detailed consideration regarding layout and design features which could help deter crime or disorder and the fear of crime. SPD will consider issues of Secured by Design.


            Risk and Opportunity Management Implications:


7.7         The UDF SPD will provide guidance on implementing City Plan Part One Policy CP12 Urban Design and other relevant policies in the Plan and the emerging City Plan Part Two Policies. Responses received as part of the consultation at the Draft SPD stage will help inform the final version of the SPD. The SPD is intended to improve the quality of design in new development and facilitate the successful delivery of higher density and sustainable development. 


Public Health Implications:


7.8         Development across the city is expected to support sustainable and healthy lifestyles. The production of the SPD can help support the timely provision of necessary infrastructure to support sustainable and mixed-use communities across the city. The ways in which good design can facilitate active lifestyles and help minimise noise and other traffic impacts have been considered in the UDF SPD.


            Corporate / Citywide Implications:


7.9         The council is committed to promoting high quality, higher density, mixed-use development. High quality design is the key to achieving acceptable development in a way that respond successfully to the city’s high housing demands, significant spatial constraints and sensitive landscapes. As such, the Draft UDF SPD presents a major opportunity to:

§   Establish constructive dialogue with local communities and those with a stake in the planning system on the key design principles to help deliver development in the city and particularly in more sensitive locations; and

§   Provide greater clarity and confidence for elected members, the council’s Development Management team and the development sector to help unlock investment in and speed up the delivery of housing and other much needed development in the city.


Any Other Significant Implications:


7.10      None identified.






1. Urban Design Framework Supplementary Planning Document (UDF SPD)

2. Draft UDF SPD consultation report

3. Draft UDF SPD consultation report – Appendices

4. You said – We responded table


Documents in Members’ Rooms



Background Documents

City Plan Part One

Submission City Plan Part Two