Appendix 2 College Conservation Area Character Statement – Consultation Responses

Summary of Consultation Responses

The public consultation received a total of 75 responses which included:

Local residents:                                              59

Visitors:                                                           7

Brighton College                                             1

Brighton and Hove Councillors:                      3

Statutory and County Council Consultees:    5

In responses to the questions:

Do you agree that the draft character statement has captured the special character and appearance of the CA? the following responses were received:

Strongly agree:                                   1

Agree:                                                 11

Neither agree nor disagree:                17

Disagree:                                            21

Strongly disagree:                               25

Should the extent of the conservation area should remain the same:

Those that said it should be enlarged:                                                           7

Those that said it should be reduced:                                                            21

Those that said it should remain as it is:                                                        19

Those that expressed no opinion as to whether it should be changed:        28

Main comments made about the Conservation Area Character Statement

Consultee	Comments by Consultees	Response suggested or amendments
Local Resident	There were objections that the Statement does not identify the area as predominantly residential and that, the Character Statement gives greater powers to Brighton College to develop sites within the conservation area by additions to the school buildings by changing residential use to education uses.	All other conservation areas in the city already have a character statement that clearly sets out the area’s existing character and special interest. This draft Statement sets out what is existing in this conservation area. The Character Statement does recognise those parts of the conservation area which are residential and describes these residential qualities and how they contribute to the character of the of the area.
Local Resident	Some residents wanted the conservation area to be more clearly identified and for it to be associated with Kemp Town Conservation Area.	Kemp Town Conservation Area is half a mile to the east of this area. The nearest conservation area is on the south side of Eastern Road, the East Cliff Conservation Area. This has a denser more urban character than College Conservation Area. It is not considered appropriate for them to be combined. They have different characters and historic significance.
Local Resident & Councillor	Walpole Terrace and College Terrace should be listed.	These are both fine terraces in the conservation area and they are identified in the character statement as making a positive contribution to the historic character of the area. Historic England is the responsible statutory body for listing buildings.
Local Resident	Criticism of the layout of the document.	The layout of the document has been based on recent character statements created for other conservation areas. The intention is that there should be some uniformity to the way these documents can be presented and read.
Local Residents	A number of residents objected to the recently developed Brighton College buildings which they regard as inappropriate and contrary to the historic character of the area	This document cannot influence planning decisions that have already been made. The purpose of the character statement is to provide a description of the existing historic character of the conservation area so that it can be taken into consideration for future development.
Local Residents	There were objections to traffic congestion around the college and parking problems associated with the operation of the school including coach parking.	These comments are not directly relevant to the Conservation Area Character Statement. However, officers have informed the BHCC Parking Strategy team of these comments. That team are aware of the issues and are in liaison with the College to help address the issues
Local Residents	The financial influence of Brighton College should not be allowed to influence the planning process and has had a significant impact on the drafting of the Character Statement.	This statement is an independent heritage assessment of architectural and historic character.
Local Residents	Objection to Brighton College buying property in the conservation area.	The character statement does not enable or prevent the college buying property either in the conservation area or outside of it.
Local Residents	Disagree with the statement that Walpole Road, Walpole Terrace, College Terrace, Canning Street and the Western end of Belle View Gardens are not residential and do not have a residential character.	This statement is inaccurate and does not form part of the character statement. This statement fully recognises that these roads all have a significant and, in some cases, predominantly residential character.
Local Residents	Criticism of the private education system and to the school becoming a multi-national commercial enterprise.	This is not relevant to character statement. The Character Statement is an assessment of the areas historic and architectural character and appearance.
Local Residents	The Character Statement should start from the regency period with development on the seafront. An objector states that there were buildings before the college.	Although there are buildings from the Regency period in the surrounding area including to the south of the conservation area, there is no evidence of any buildings in the conservation area before the school was built. The maps of 1792 and 1851 strongly support this.
Local Residents	Harm and inconvenience caused by building works over the last ten years of development of Brighton College.	The mitigation of negative impact on neighbours during construction is an issue to be resolved through the planning application process by way of appropriate planning conditions.
Local Residents	Local residents should not be prevented from installing uPVC windows within the conservation area	The policies regarding replacement uPVC and double-glazed windows have not changed due to this character statement. Other policy guidance prevents double glazed uPVC windows being installed on the front elevation of conservation areas.
Local Resident	New Brighton College buildings are brightly lit after 5pm and left on too late.	This is not an issue that can addressed through the character statement.
Brighton College	The conservation area character statement should have been drafted with greater use of the Brighton College Archivist and should be redrafted in collaboration between Brighton College and Brighton and Hove Council.	The appropriate approach is for the council to draft the document independently, followed by public consultation to include all interested parties. The statement is then submitted to the relevant council committee for final approval alongside any appropriate amendments made due to consultation responses.
Brighton College	The drafting of the appraisal should have been guided by Historic England’s Conservation Area Appraisal, Designation and Management (2019)	The document was drafted with reference to previous documents for other Conservation Areas as well as the Historic England guidance from 2019.  These documents are well used in the planning application process by both applicants and case officers.
Brighton College	The document exaggerates the importance of the relatively standard C19th-century housing, which owe much of their significance to their setting in relation to the college.	Although unlisted, Walpole Terrace and College Terrace provide an important façade that faces open spaces and the rear facades of the college and they should be regarded as the most significant element in these streets.
Brighton College	There should have been more recognition of the high quality of the new buildings in Brighton College.	It is recognized that some new development is high quality. The document may comment on some negative features but it avoids strong criticism of any building.
Local Residents	Objections to the consultation process: The lack of public participation in preparing for the document and the small number of public notices put up.	There were eight public notices put up as well as information being put on the council web site. This resulted in 64 comments being made via the consultation portal. This is considered a good and proportionate response.
CAG-Conservation Area Advisory Groupe	A comment was made that the character statement did not include any reference to street furniture, especially nineteenth century lampposts.	A paragraph on street furniture has now been added.
Councillor and Historic England	More Photographs in the document and additions to section 5.	More photographs of the area have now been added to be incorporated into section 5.
Historic England	A number of suggestions were made for the amending of the formation of the document.	Minor amendments have been made. However, the format of the document is drafted to follow that of character statements for other conservation areas in Brighton and Hove.
Historic England	Recommendation that the Conservation Area Character Statement include a management plan.	In most cases management plans have not been included in BHCC conservation area character statements. However, a review of the 2015 city-wide Conservation Area Strategy is due to commence next year and this can consider the priorities for any conservation area management plans. It may be that one or more management plans be applicable to a number of conservation areas in the city.
Natural England	No specific comments on this Conservation Area
Environment Agency	No Comment
East Sussex County Archaeologist	No Comment.
Several	Spelling and grammatical corrections.	These comments have been considered and changes including typos have been made.

Responses to whether the extent of the conservation area should remain the same:

Requests were made for the conservation area both to be extended and reduced in size – all responses to this question were from residents.

Comments by Consultees	Response suggested or amendments
It was considered that if the conservation area is not residential then terraced housing should be excluded so that the influence of Brighton College on the character of the area would not be considered.	It is recommended that the residential terraces should not be excluded as they form a significant part of historic character of the area especially along Walpole Terrace and College Terrace.
The conservation area be expanded to include more houses so that the residential element would become more dominant.	The balance between the number of houses and the size of school, if changed, would not change the planning control over either.