Appendix 2 Schedules of Additional Modifications

BHCC48 Schedule of Proposed Modifications to the Proposed Submission CPP2 Changes to the Policy Map

1. The Proposed Submission City Plan Part 2 was submitted to the Secretary of State on 13 May 2020. Public hearings were held in November 2021.

2. As part of the examination process a number of proposed Main Modifications (MMs) have been identified. A Main Modification is an amendment which is considered necessary to make the Plan sound or legally compliant, addressing issues raised during the examination process and those set out in Inspector Note 09

3. Some of the MMs will have an impact on the way the CPP2 will be shown on the Policies Map as set out in SD03a - proposed changes to the policies map - West - April 2020, SD03b - proposed changes to the policies map - Central - April 2020 and SD03c - proposed changes to the policies map - East - April 2020

4. This schedule identifies the map changes that are required to as a result of the Main Modifications:

- diagonal line shows strike through of site allocation as shown on the Proposed Submission CPP2 Changes to the Policy Map

- proposed amendments to site boundaries shown as dashed line overlain on the existing site boundary for ease of reading against the Proposed Changes to the Policy Map site boundary line

Proposed Policy Map Change	Policy Reference	Modification Proposed	Reason for Modification
Map1	Policy H1	Policy H1 Housing Sites and Mixed Use Sites Delete the following housing site allocations from the H1 layer as shown on the proposed changes to the policy map: Land between Marine Drive and rear of 2-18 The Cliff, Brighton	To align with proposed changes to Policy H1
Map2	Policy H1	Policy H1 Housing Sites and Mixed Use Sites Delete the following housing site allocation from the H1 layer as shown on the proposed changes to the policy map: 2-16 Coombe Road
Map3	Policy H1	Policy H1 Housing Sites and Mixed Use Sites Delete the following housing site allocation from the H1 layer as shown on the proposed changes to the policy map: 87 Preston Road, Brighton, BN1 4QG
Map4	Policy H1	Policy H1 Housing Sites and Mixed Use Sites Delete the following housing site allocation from the H1 layer as shown on the proposed changes to the policy map: George Cooper House, 20-22 Oxford Street, Brighton	To align with proposed changes to Policy H1
Map5	Policy H1	Policy H1 Housing Sites and Mixed Use Sites Delete the following housing site allocation from the H1 layer as shown on the proposed changes to the policy map Whitehawk Clinic, Whitehawk Road, Brighton#	To align with proposed changes to Policy H1
Map6	Policy H1	Policy H1 Housing Sites and Mixed Use Sites Delete the following housing site allocation from the H1 layer as shown on the proposed changes to the policy map Buckley Close garages, Hangleton	To align with proposed changes to Policy H1
Map7	Policy H1	Policy H1 Housing Sites and Mixed Use Sites Delete the following housing site allocation from the H1 layer as shown on the proposed changes to the policy map: 189 Kingsway, Hove #	To align with proposed changes to Policy H1
Map8	Policy H1	Policy H1 Housing Sites and Mixed Use Sites Delete the following housing site allocation from the H1 layer as shown on the proposed changes to the policy map: Kings House, Grand Avenue, Hove #	To align with proposed changes to Policy H1
Map9	Policy H1	Policy H1 Housing Sites and Mixed Use Sites Add the following site allocation to the H1 layer as shown on the proposed changes to the policy map: Land at Preston Road / Campbell Road, Brighton	To align with proposed changes to Policy H1
Map10	Policy H1	Policy H1 Housing Sites and Mixed Use Sites Add the following site allocation to the H1 layer as shown on the proposed changes to the policy map: 154 Old Shoreham Road, Hove (Furniture Village site and car park, corner of Old Shoreham Road and Sackville Road)	To align with proposed changes to Policy H1
Map11	Policy H2	Policy H2 Urban Fringe Housing Delete the following housing site allocation from the H2 layer as shown on the proposed changes to the policy map: Land at and Adjoining Horsdean Recreation Ground, Patcham	To align with proposed changes to Policy H2
Map12	H2	Policy H2 Urban Fringe Housing Amend the southern and eastern boundaries of the following housing site allocation from the H2 layer as shown on the proposed changes to the policy map Land at former nursery, Saltdean Site allocation before boundary amendment Site allocation following boundary amendment	To align with proposed changes to Policy H2
Map13	Policy H3	Policy H3 – Purpose Built Student Accommodation Amend the site boundary of the site in Hollingdean Road as follows: Site allocation before boundary amendment Site allocation after boundary amendment	To reflect an extant planning permission (BH2019/03700)
Map14	Policy H3	Policy H3 Purposed Built Student Accommodation Delete the following purpose built student accommodation site allocation from the H3 layer as shown on the proposed changes to the policy map: 118–132 London Road, Brighton	To align with proposed change to Policy H3
Map15	Proposed Changes to the Policy Map legend	Proposed Changes to the Policy Map legend Amend the legend to read: Waste & Minerals Sites – SP1 & SP2 (WMSP) Amend to “Waste site allocations and areas of opportunity”	For clarification
Map16	ANA layer on Policy Map	Archaeological Notification Layer update Prior to adoption to update the ANA to reflect the most recent layer as provided by the County Archaeologist.	Factual Update

BHCC49 Schedule of Proposed Additional Modifications, February 2022

1. The Proposed Submission City Plan Part 2 was submitted to the Secretary of State on 13 May 2020. Public hearings were held in November 2021.

2. As part of the examination process a number of proposed Additional (Minor) Modifications have been identified. The Planning and Compulsory Purchase Act 2004 (as amended) allows the Local Planning Authority to make additional (minor) modifications to the plan on adoption, but only if they do not materially affect the Plan’s policies. These additional modifications are not subject to the formal examination and generally address minor issues of clarity.

3. Table 1 identifies the proposed Additional Modifications (AM) the Authority proposes at this stage. These Additional Modifications will only be considered by the Authority and not by the Planning Inspectorate as they do not relate to the soundness of the plan. To view the Main Modifications please refer to the Schedule of Proposed Main Modifications BHCC44.   

4. Table 2 identifies the proposed additional modifications the Authority proposes at this stage in relation to the Implementation and Monitoring Plan (SD04) identified as IMP#. These Additional Modifications will only be considered by the Authority and not by the Planning Inspectorate as they do not relate to the soundness of the plan.   

5. The proposed additional modifications are generally expressed in the form of strikethrough for deletions of text and underlined for additions of text and are set out in the same order as the April 2020 Proposed Submission City Plan Part 2.

Table 1 Schedule of Additional Modifications

Mod. Number

Proposed Submission City Plan Part 2 Reference

Modification Proposed

Reason for Modification

AM01

Introduction paragraph 1.8 page 8

Relationship with other DPDs

Move the following text from paragraph 1.9 to paragraph 1.8 and amend as follows:

“Shoreham Harbour Joint Area Action Plan (JAAP)2 – provides a comprehensive, deliverable plan for the regeneration future revitalization of Shoreham Harbour. The JAAP was prepared jointly with Adur District Council and West Sussex County Council.”

Factual update to reflect adoption of JAAP.

AM02

Introduction paragraph 1.9 page 8

Add the following text to paragraph 1.9

“Review of the Waste and Minerals Local Plan – a focussed review of certain policies in the Waste & Minerals Local Plan”.

And amend the following text at paragraph 1.9 and delete associated footnote:

Community Infrastructure Levy (CIL) – once adopted CIL came into effect on the 5 October 2020. CIL allows local authorities to raise funds from development for the provision of infrastructure in and around their areas.

1. Following an examination in public and consultation on proposed modifications CIL is expected to be adopted in June and introduced in October 2020.

Factual updates.

AM03

Introduction, paragraph 1.10 page 9

Duty to Cooperate

Amend the last sentence at the end of the paragraph to read:

A duty to Cooperate Update Paper is published alongside the Proposed Submission City Plan Part 2 and will include an updated Statement of Common Ground prepared by the West Sussex and Greater Brighton Local Planning Authorities.

Factual update.

AM04

Table 1 page 10

Table 1 Timetable for the Preparation of City Plan Part Two

Delete table and associated footnote:

Table 1 Timetable for the Preparation of City Plan Part Two

City Plan Part Two stage of plan preparation	Date
Scoping Document (Regulation 18)	June 2016
Draft Plan and SA (Regulation 18)	Summer 2018
Publication of Proposed Submission City Plan Part 2	Approved by Council 23 April 2020
Regulation 19 Consultation	Dates to be confirmed after Coronavirus (Covid-19) restrictions are lifted.
Submission to the Secretary of State	The timetable for next stages of the City Plan Part 2 will be published on the council’s City Plan Part 2 webpage once a start date for the consultation has been set1.
Examination in Public
Adoption of City Plan Part Two

Editorial – not required for final version of plan.

AM05

Introduction paragraph 1.14 -1.18, page 11

How to Comment on the Proposed Submission City Plan Part Two

Delete paragraphs 1.14-1.18 and associated footnote as follows:

How to Comment on the Proposed Submission City Plan Part Two

1.14 The public consultation is delayed due to the Coronavirus (Covid-19) restrictions. The timetable for next stages of the City Plan Part 2 will be published on the council’s City Plan Part Two webpage once a start date for the consultation has been set. Paragraphs 1.15 – 1.17 apply once the consultation has commenced.

1.15 The City Council would like your views on the Proposed Submission City Plan Part Two and whether you think it meets the government’s tests of soundness and legally compliant 5 . You do not have to comment on everything in the Proposed Submission City Plan Part Two. We want to hear your views on those aspects that are of most interest to you.

1.16 We recommend you make your comments using the council’s online consultation portal: http://consult.brighton-hove.gov.uk/portal. This will help us handle your comments quickly and efficiently.

1.17 The Proposed Submission City Plan Part Two and supporting documents including the proposed changes to the Policies Map and the Sustainability Appraisal (SA) are available on the Council’s website (https://www.brightonhove.gov.uk/content/planning/planning-policy/city-plan-part-two-proposedsubmission-stage-2020) and once Coronavirus (Covid-19) restrictions are lifted, the council will make them available to be viewed at the customer service centres at Hove Town Hall and Bartholomew House Brighton and the main city Libraries (Jubilee, Hove and Portslade) during normal opening hours. The Proposed Submission CPP2 including the policies map and non-technical SA summary will be available to view at all other libraries during normal opening hours once Coronavirus (Covid-19) restrictions are lifted. Word versions of the Response Form are available on request to planningpolicy@brighton-hove.gov.uk

1.18 The consultation period for the Proposed Submission City Plan Part Two will be set out in a Statement of Representations Procedure published on the council’s City Plan Part Two webpage once a start date has been set. Council’s Consultation Portal: http://consult.brighton-hove.gov.uk/portal

Email: planningpolicy@brighton-hove.gov.uk (please respond using the Response Form) Post: Proposed Submission CPP2, Policy Projects and Heritage Team, Brighton & Hove City Council, First Floor Hove Town Hall, Norton Road, BN3 3BQ

Editorial - no longer required as consultation has occurred.

AM06

footnote 11 Page 15

Policy DM1 Housing Quality, Choice and Mix

Amend footnote 11 to read:

National Planning Policy Framework (NPPF) (2019) (2021) paragraph 61 62

Factual update to paragraph number following updated NPPF 2021

AM07

Policy DM4 page 22

DM4 Housing and Accommodation for Older Persons

Add the following numbering to the second paragraph of policy to read:

 ‘1. Development proposals….’

For clarity to avoid confusion between the two sets of policy criteria.

AM08

Policy DM4 page 22

DM4 Housing and Accommodation for Older Persons

Add the following numbering to the fourth paragraph of policy to read:

‘2. Proposals that….’

For clarity to avoid confusion between the two sets of policy criteria.

AM09

Policy DM5 page 27

DM5 Supported Accommodation (Specialist and Vulnerable Needs)

Add the following numbering to the second paragraph of policy to read:

‘1. Proposals for development ….’

For clarity to avoid confusion between the two sets of policy criteria.

AM10

Policy DM5 page 27

DM5 Supported Accommodation (Specialist and Vulnerable Needs)

Add the following numbering to the third paragraph of policy to read:

‘2. Proposals that….’

For clarity to avoid confusion between the two sets of policy criteria.

AM11

Policy DM6 Page 30, footnote 30

Policy DM6 Build to Rent Housing

Amend footnote 30 to read:

MHCLG National Planning Policy Framework, February 2019 2021

Factual update to paragraph number following updated NPPF 2021

AM12

Supporting text to Policy DM8, paragraph 2.72 page 37

DM8 Purpose Built Student Accommodation

Amend the first sentence of the supporting text at paragraph 2.72 to read:

“However, the number of permitted PBSA bedspaces, currently assessed to be 12,699, remains below the number of students in the city requiring accommodation, particularly for students at the University of Brighton.”

Delete associated footnote 36:

36 3,146 bedspaces managed by University of Brighton, 8,167 managed by University of Sussex, and 1,386 privately managed.

This figure is out-of-date as several large PBSA developments are currently being delivered. The number of bedspaces is changing and any figure in the Plan would rapidly become out-of-date. Stating it remains below the number of students will remain factually correct.

AM13

Supporting text to Policy DM8, para graph 2.73

DM8 Purpose Built Student Accommodation

Amend the first sentence of the supporting text paragraph 2.73 to read:

“The council welcomes the development of new PBSA on appropriate sites. In addition to setting out criteria to guide the suitable location of PBSA, City Plan Part One Policy CP21 allocated five sites for new development, of which Pelham Street remains undeveloped and without an extant permission.”

Factual update.

AM14

Footnote 43

Page 56

Policy DM14 Commercial and Leisure Uses at Brighton Marina

Amend footnote to read:

National Planning Policy Framework (NPPF) (2019) (2021) paragraphs 89-90 90-91

Update to paragraph number following updated NPPF 2021

AM15

Supporting text to Policy DM16 Paras 2.137 and 2.138

DM16 Street Markets

Amend supporting text at the first sentence of paragraph 2.137 and the first sentence of paragraph 2.138 to read:

Street markets and stalls are also important for the establishment of new entrepreneurial business by Brighton & Hove residents.

The council will use conditions and/or obligations to ensure that the operation of markets and stalls do not have harmful impacts, and will require detailed layout plans as part of an application to allow consideration as to whether these matters have been properly addressed.

For clarity

AM16

Policy DM22, Footnote 60 Page 82

DM25 Communications Infrastructure

Amend footnote 60 to read:

National Planning Policy Framework (NPPF), (2021) paragraph 116 118.

Factual update to paragraph number following updated NPPF 2021

AM17

Policy DM33, para 2.250

page 100

Policy DM33 Safe, Sustainable and Active Travel

Amend paragraph 2.250 to read:

Brighton & Hove is already one of the country’s least car-dependent cities outside London, with 38.2% of households not owning a car. A number of high-quality improvements to the public realm have been implemented in recent years. These have taken different forms, for example the award-winning shared space scheme on New Road, and the addition of wayfinding boards and fingerposts throughout the city centre, and with further improvements in the pipeline, notably the redesign of Valley Gardens.

Factual update

AM18

Policy DM37 page 111

Policy DM37 Green Infrastructure and Nature Conservation

Add new section heading at start of section on protected sites to read:

Designated Sites

For clarity

AM19

Supporting text to Policy DM37 paragraph 2.275 page 113

Policy DM37 Green Infrastructure and Nature Conservation

Amend the third sentence in paragraph 2.275 to read:

Applicants must properly assess the harmful effects of their proposals on the natural environment/natural capital73, seek to minimise the impact and give full consideration to achieving biodiversity net gains, in particular to species and habitats of particular principal importance (formerly known as BAP habitats)…

Editorial and typographic corrections

AM20

Supporting text to Policy DM37 paragraph 2.275 page 113

Policy DM37 Green Infrastructure and Nature Conservation

Amend the last sentence of paragraph 2.275 of supporting text to read:

A Natural Capital Investment Strategy for Sussex 2019 74 is being prepared which when adopted will guide the implementation of this policy.

Factual update.

AM21

Supporting text to Policy DM37 paragraph 2.277

Policy DM37 Green Infrastructure and Nature Conservation

Amend the second and third sentences of paragraph 2.277 of supporting text to read:

However, the City’s green infrastructure encompasses more than this ‘spatial backbone’ and includes; street trees, residential gardens, green roofs/walls and landscaped/flood management areas including sustainable drainage systems (SuDS). Cycling/walking routes and manmade features designed to enhance biodiversity/recreation (e.g. bird/bat boxes and bee bricks) are also important to the overarching concept in the City.

Typographical correction

AM22

Policy DM37 Footnote 75 page 113

Policy DM37 Green Infrastructure and Nature Conservation

Delete repeated text from footnote 75 as follows:

The South Downs Way Ahead Nature Improvement Area (NIA) is one of 12 NIAs that were announced by Government in February 2012. It sets a landscape scale approach to biodiversity and focuses on safeguarding endangered chalk grassland, vital for rare and endangered wildlife and the provision of clean drinking water and green space

Editorial correction.

AM23

Supporting text to Policy DM37 paragraph 2.280 page 114

Policy DM37 Green Infrastructure and Nature Conservation

Amend first sentence of paragraph 2.280 to read:

Proposals must assess potential impacts on, nature conservation features (which includes geodiversity) (see paragraph 2.282).

For clarity.

AM24

Policy DM37 footnote 76 page 114

Policy DM37 Green Infrastructure and Nature Conservation

Amend footnote to read:

The Sussex Biodiversity Record Centre (Woods Mill, Henfield) is the principal source of up-to -date desktop biodiversity information. The Booth Museum (Dyke Road, Brighton) may also holds additional data, specifically regarding geodiversity that may be relevant for nature conservation surveys.

Factual correction

AM25

Supporting text to Policy DM37 paragraph 2.282 page 115

Policy DM37 Green Infrastructure and Nature Conservation

Amend second sentence to supporting text at paragraph 2.282 to read:

Ecological reports should be produced in line with the British Standard on biodiversity management in planning and development BS42020:2013 and CIEEM Technical Guidance (and subsequent revisions).

Editorial correction

AM26

Supporting text to Policy DM37 paragraph 2.282 page 115

Policy DM37 Green Infrastructure and Nature Conservation

Amend final sentence to supporting text at paragraph 2.282 to read:

Opportunities to deliver higher carbon dioxide savings through greater passive design, fabric and energy efficiency measures and low and zero carbon technologies will also be required (see CP8 Sustainable Buildings and DM443 Energy Efficiency and Renewables)

Editorial correction

AM27

Supporting text to Policy DM37 paragraph 2.285 page 116

Policy DM37 Green Infrastructure and Nature Conservation

Amend first sentence of paragraph 2.285 to read:

Locally important sites include locally designated wildlife or geological sites; (local geological sites (LGeoS) - (formerly called Regionally Important Geological and Geomorphological Sites (RIGGS)) of regional significance), local wildlife sites (LWS) and local nature reserve (LNRs).

Editorial correction

AM28

Policy DM38, Footnote 81 Page 117

Policy DM38 Local Green Spaces

Amend footnote 81 to read:

National Planning Policy Framework (NPPF) (2018) paragraphs 101 103 and 143-147 147-151.

Factual update to paragraph number following updated NPPF 2021

AM29

Supporting text to DM40, Paragraph 2.308

Page 124

Policy DM40 Protection of the Environment and Health – Pollution and Nuisance

This policy complements the AQAP by ensuring that all new developments adhere to the NPPF guidance that developments should contribute towards national objectives for pollutants (paragraph 181 186 of the NPPF 2021)

Factual update to paragraph number following updated NPPF 2021

AM30

Policy DM40 Footnote 91 Page 125

DM40 Protection of the Environment and Health – Pollution and Nuisance

Amend footnote 91 to read:

National Planning Policy Framework (NPPF) (2021), Paragraph 182 186.

Factual update to paragraph number following updated NPPF 2021

AM31

Policy DM44, footnote 103

Page 135

DM44 Energy Efficiencies and Renewables

Clarify Footnote 103:

103: Carbon neutral recognises that it may not be possible to eliminate all emissions by this date, but that residual emissions can be off-set against carbon-positive measures such as tree planting. The council will consider setting up a carbon offset scheme in the future.

For clarification.

AM32

SA7 Benfield Valley

Page 149

SA7 Benfield Valley

Add footnote to Figure 2 Illustrative Diagram:

^#Please note that this diagram is illustrative. Please view the Policies Map for detailed site allocation boundaries.

For clarification that figure 2 is an illustrative diagram

AM33

Supporting text to Policy SSA4

Page 162

SSA4 Sackville Trading Estate

Amend supporting text at paragraph 3.34 to read:

3.34 The site also falls within the Hove Station Neighbourhood Forum area. A draft Neighbourhood Plan has been produced and was formally consulted on in summer 2018 Spring 2019. The draft Plan sets out aspirations and priorities for the site and wider area (identified in the draft Neighbourhood Plan as the Hove Station Quarter). Once adopted the Neighbourhood Plan, will form part of the Development Plan for the city.

Factual update and to address representation by Hove Station Neighbourhood Forum

AM34

Footnote to SSA7, page 170

SSA7 Land Adjacent to American Express Community Stadium, Village Way

Amend footnote text and weblink to:

¹⁵⁴ https://www.southdowns.gov.uk/planning/planning-advice/landscape/ South Downs Landscape Character Assessment (LCA) 2020

Factual update

AM35

Footnote 152, page 184

Policy H2 Housing Sites – Urban Fringe

Amend Footnote 152 to read:

¹⁵² Brighton & Hove City Council Planning Advice Note 06 Food Growing and Development September 2011 Updated September 2020

Factual update

AM36

Footnote 154 page 185

Policy H2 Housing Sites – Urban Fringe

Amend footnote text and weblink to:

¹⁵⁴ https://www.southdowns.gov.uk/planning/planning-advice/landscape/ South Downs Landscape Character Assessment (LCA) 2020

Factual update

AM37

Appendix 6 pages 221- 223

Appendix 6 Proposed Changes to Policies Map – Tables 1 and 2

Delete Appendix 6

Editorial -description of changes not required for final adopted version of plan.

Table 2 Schedule of Additional Modifications to the CPP2 Implementation and Monitoring Plan (SD04)

Modification Number	Section, paragraph and page number	Additional Modification Proposed	Reason for Additional Modification
IMP1	DM1 Housing Quality, Choice and Mix	Amend the following indicators for DM1 to read: LOI Percentage of residential units permitted^1 meeting nationally described space standardsPercentage of residential units permitted not meeting nationally described space standard LOI Percentage of residential units permitted^1 meeting minimum accessibility and adaptability standards set out in Building Regulation M4(2) Percentage of residential units permitted that do not meet the minimum accessibility and adaptability standards set out in the Building Regulations (M4 (2)).	It is considered easier to monitor exceptions to the policies and allow reasons to be analysed.
IMP2	DM12 Regional, Town, District & Local Centres, page 8	Amend indicator, targets and trigger for Policy DM12 to read: LOI Number and percentage of units in Class A1 use LOI Increase in the number of active commercial units in defined centres Targets: Regional, Town and District Shopping Centres Percentage of Class A1 retail units · Primary frontages 75% · Secondary frontages ‐ Regional centre 35% ‐ Town & District centres 30% Local Shopping Centres 50% of Class A1 units Target: Net gain in number of commercial units Timescale: Ongoing monitoring through retail health checks Timescale: Ongoing monitoring through health checks Trigger: Percentage of Class A1 units falls below target levels    Trigger: increase in vacancies in two successive health checks Action: Review policy approach and Development Management practice	To ensure consistency with changes to the Use Classes Order, as amended pursuant to the Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020 and to reflect proposed Main Modifications to policy.
IMP3	DM13 Important Local Parades, Neighbourhood Parades and Individual shop units, page 9.	Amend indicator, targets and trigger for Policy DM13 to read: LOI Number and percentage of units in Class A1 use in Important Local Parades LOI Increase in the number of active commercial units in Important Local Parades Target: At least 50% units in Important Local Parades to remain in Class A1 use Target: Net gain in number of commercial units Timescale: Ongoing monitoring through retail health checks Timescale: Ongoing monitoring through health checks Trigger: Percentage of Class A1 use units falls below target levels Trigger: Percentage of vacant units increases Action: Review policy approach and Development Management practice	To ensure consistency with changes to the Use Classes Order, as amended pursuant to the Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020 and to reflect proposed Main Modifications to policy.
IMP4	DM25 Communications Infrastructure	Amend indicator and target for DM25 to read: Indicator: LOI Appropriate Implementation and siting of modern communications Infrastructure Appeal success rate for applications where appearance/ impact on setting/ clutter are principal issues. Targets: No specific target70% appeals dismissed where appearance/ impact on setting/reducing clutter are principal issues Timescale: Ongoing Annual monitoring through Plan period	To provide an indicator and target to allow the effectiveness of the policy to be monitored.
IMP5	DM39 Development on the Seafront	Amend indicator, target and trigger for DM39 to read: Indicator: Policy CP11 indicator Policy SA1 indicators Targets: No specific target Targets as per CP11 and SA1 Trigger: Not applicable As for Policy CP11 and SA1	To include reference to relevant targets and triggers referred to for CPP1 Policy SA1 The Seafront
IMP6	DM44 Energy Efficiencies and Renewables, page 27	Amend target for Policy DM44 to read: Target: All developments including conversions and changes of use to New residential created through conversions and changes of uses of existing buildings and for non-residential development (non-major and major) including conversions and changes of use to achieve at least 19% improvement on carbon emission targets set by Part L of Building Regulations until superseded by Future Homes Standards and Future Building Standards or interim uplift in Part L if greater than 19%.	To reflect proposed changes to policy and government announcements and Main Modifications to DM44.
IMP7	SA7 Benfield Valley	Amend indicator, target and trigger for DM39 to read: Indicator: No specific indicator Addressed by Policies DM37, DM38 and H2 Targets: No specific target Trigger: Not applicable Addressed by Policies for Policy DM37, DM38 and H2	To include cross reference to relevant indicators, targets and triggers under DM37, DM38 and H2.
IMP8	SSA1 – Brighton General Hospital Site, Elm Grove	Amend target for Policy SSA1 to read: • 10,000 – 12,000 sq m health and care facility (D1E(e));	To ensure consistency with changes to the Use Classes Order, as amended pursuant to the Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020
IMP9	SSA2 – Combined engineering Depot, New England Road, page 30	Amend target for Policy SSA2 to read: · 1,000 sq m B1 E(g) workspace and managed starter office units.	To ensure consistency with changes to the Use Classes Order, as amended pursuant to the Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020
IMP10	SSA3 Land at Lyon Close, page 31	Amend target for Policy SSA3 to read: · 5,700 sq m net B1a E(g) office · D1 health facilities (GP surgery) and/or	To ensure consistency with changes to the Use Classes Order, as amended pursuant to the Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020
IMP11	SSA4 Sackville Trading Estate and Coal Yard, page 32	Amend target for Policy SSA4 to read: · 6000m2 E(g)B1 employment floorspace	To ensure consistency with changes to the Use Classes Order, as amended pursuant to the Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020
IMP12	E1 – Opportunity Site for Business and Warehouse Uses	Amend target and trigger for Policy E1 to read: Target: No specific target or timescale No consent by 2030 Trigger: Not applicable Review through City Plan Part One	To include a timescale and trigger