Decision - Secretary of State's Proposed Modifications to the Draft South East Plan

To set out the City Council's response to the proposed modifications.

(1) That following response to the South East Plan be approved;

The City Council:-

i). Supports the need  to demonstrate and employ best practice in design and construction for waste minimisation and recycling in Growth Points and Strategic Development Areas including Shoreham Harbour (policy W2).

ii). Welcomes the recognition that policy CC8 gives to the importance of green infrastructure, and the biodiversity, recreational, and cultural benefits it can help to deliver.

iii). Objects to policies RE2 and H2 as failing to give local authorities sufficient guidance in the preparation of their Local Development Documents.

iv). Objects to the housing provision figure for the City of 620 dwellings per annum as the Secretary of State has not demonstrated that this can be accommodated in the City without adverse impact on the quality of life, the character of the urban environment and the economy. The high level of residential completions noted by the Secretary of State has been at the height of the housing market. Amongst other things, the City Council is looking to deliver housing that meets local needs, particularly family housing which is likely to reduce the number of units to be completed on relevant sites. The City Council asks the Secretary of State to take note of the findings Council’s Strategic Housing Land Availability Assessment produced in-line with government guidance. 

v). Is concerned that the emphasis on delivering housing numbers in the wider Shoreham Harbour Strategic Development Area could prejudice broader and longer term economic development objectives. The City Council believes that 10,000 units in the wider Harbour area is likely to be the absolute maximum achievable and that a more realistic figure is 5,000 to 6,000 dwellings to be able to develop a genuine mixed-use sustainable community. The City Council believes that the potential to deliver a significant number of jobs at the Harbour should be identified as part of the Strategic Development Area.

vi). Informs the Secretary of State that not all of the proposed Shoreham Harbour Strategic Development Area lies in Adur District, West Sussex but is also in Brighton & Hove and to provide the scale of development suggested by the Secretary of State will need to encompass a wider area than the operational port (see comments at point v). above).

vii). Requests that the City’s housing provision figure is reduced to reflect that a significant proportion of the Shoreham Harbour Strategic Development Area lies within the City boundaries, as has been done for Adur District Council.

viii). Requests (in view of the points raised at iv to vii above) that the relevant housing provision figures are set at 10,400 (520 pa) for Brighton and Hove and a total of 6000 dwellings for the Shoreham Harbour Strategic Development Area.

ix). Requests that the Secretary of State clarifies that should the Shoreham Harbour Strategic Development Area not deliver the amount of housing ultimately indicated in the South East Plan, that the City Council and it partner authorities will not be required to make up this shortfall elsewhere.

x). Objects to policy W3. The methodology to apportion London’s waste still does not adequately recognise the difficulties of proving sufficient landfill space to meeting’s London need. For Brighton & Hove and East Sussex those difficulties mainly concern the large proportion of Areas of Outstanding Natural Beauty in the Plan area, the distance that waste would have to travel to reach any future landfill and the difficulty of moving that waste. These difficulties are reflected in that there is no historical disposal of London’s waste in Brighton & Hove or East Sussex.

xi). Requests that should the Secretary of State not amend W3 in line with the City Council’s objection (point ix. above), the City Council re-iterates the need for local testing of the apportionment on London’s waste through Waste Development Frameworks to examine the practicalities of the approach.

xii) Objects to policy T3 which encourages the consideration of road charging in regional hubs, and considers that road charging schemes are neither appropriate nor desirable for Brighton & Hove.’