Sustainability Strategy
for the city of Brighton and Hove

How can we influence Council planning policies and decisions?---------

See The Core Strategy for the whole policy context.

  1. Useful information presented at The Council's Sustainability Commission Meetings in 2008
  2. Sustainability and New Governance Arrangements
  3. The Sustainable Communities Act 2007 & Guide 2008
  4. Our Council's Sustainability Strategy - 12 key objectives
  5. Our Council's 12 action plans (PDF format downloads)
  6. A new Sustainability Strategy for Brighton and Hove
  7. The Council’s Climate Change Action Plan
  8. Brighton & Hove Climate Change Strategy Stakeholder Day
  9. The 2020 Community Partnership (also known as The Local Strategic Partnership)
  10. Ways of getting involved
  11. Brighton and Hove Council's Sustainability Team
  12. Brighton and Hove Council's Sustainability Commission
  13. The Planning Applications Sub-Committee and the planning process
  14. Objecting to unsuitable planning applications
  15. Brighton and Hove City Council's Adopted Local Plan
  16. Using The Council's Online Planning Applications Comment Form
  17. Protecting open spaces in your neighbourhood from residential development
  18. Omitting to make it known that a site is 'greenfield'
  19. Omitting to perform neighbourhood-specific open space assessments
  20. Planning Applications likely to be incompatible with Transition Brighton & Hove's objectives
  21. SPG Note 16: Renewable Energy & Energy Efficiency In New Developments - this SPG is the existing requirement imposed on developers
  22. SPG Note 21: Sustainability Checklist - this SPG is the existing requirement imposed on developers
  23. Draft SPD on Sustainable Building Design - expected to replace SPG Note 16 and SPG Note 21

--rss webfeed - to key bodies relevant to Transition Brighton & Hove's Liaison with Local Government Group

Useful information presented at The Council's Sustainability Commission Meetings in 2008

Note that the next and final meeting of The Sustainability Commission (before it is replaced by The Sustainability Partnership is on:
Wednesday, 30 April 2008 at 5.00 PM at Council Chamber Brighton Town Hall.

The TB&H Liaison With Local Government Group has asked the Hub to request that Transition Brighton and Hove is represented within the new Sustainability Partnership, alongside groups such as the Brighton and Hove Food Partnership and the Wildlife Advisory Group, which clearly have been able to influence the Agendas of Sustainability Commission meetings. Please review some recent Agenda items (listed below) if you are in any doubt about the relevance of these meetings to the objectives of Transition Brighton and Hove.

Wednesday, 9 January 2008 at 5.00 PM

Options for reducing Carbon Emissions on Civic Buildings in Brighton and Hove

Options for Reducing Carbon Emissions : Appendix A

Options for Reducing Carbon Emissions : Appendix B

Options for Reducing Carbon Emissions from the Council’s Civic Buildings - report of the Director of Finance & Resources (copy attached).

Scope for reducing energy consumption in street lighting and powering traffic signals in Brighton and Hove

Street Lighting Contract - Presentation by the Assistant Director, Sustainable Transport Powerpoint Presentation

Proposed review of The Council's Sustainability Strategy

Developing a One Planet Living ® Plan for Brighton & Hove - report of the Head of Sustainability & Environmental Policy (copy attached)

Reviewing Brighton and Hove's Climate Change Strategy

City Climate Change Strategy: initial stakeholders’ event - report of the Head of Sustainability & Environmental Policy (copy attached).

City Climate Change Strategy: summary report (copy attached).

Green Architecture and Permaculture in Brighton and Hove

Green Architecture Day 2008 - report of the Head of Sustainability & Environmental Policy (copy attached).

Green Architecture Day 2008 : Report Appendix (copy attached) from Brighton Permaculture Trust.

Meeting Wednesday, 12 March 2008 at 5.00 PM

Home Energy Efficiency and Fuel Poverty in Brighton & Hove - Presentation by the Housing Sustainability Project Manager.

Wildlife Advisory Group - report of the Director of Environment (copy attached)

Eliminating Plastic Bags and Excessive Packaging - report of the Head of Sustainability & Environmental Policy (copy attached)

Eco Open Houses - Presentation by Sustainability Officer.

Call for Restraint on the Issuing and Mass Release of Balloons - report of Head of Sustainability & Environmental Policy (copy attached).

Sustainability and New Governance Arrangements

The Sustainability Commission and New Governance Arrangements - report of the Head of Sustainability & Environmental Policy (copy attached)

New constitution proposed - changing the system for council decisions
Read the proposed new constitution (PDF 217 KB: 7 pages). Take part in the consultation.

The TB&H Liaison With Local Government Group has asked the Hub of Transition Brighton and Hove to request that responsibility for scrutinising sustainability should lie with the Environment Scrutiny Committee. We feel very strongly that, because of the overarching focus of sustainable development and the impact all aspects of the Council’s work have on sustainability, this function would be better placed with the general overview and scrutiny commission.

The TB&H Liaison With Local Government Group has identified a further opportunity for cooperation with the Council's Sustainability Team i.e. strengthening the bridge between Transition Brighton and Hove and the Local Authority. This relates to the proposal that a panel of experts support the new cabinets within the Council. There will be around 20 experts on the panel drawn from Brighton and Hove residents who have national or indeed international expertise to offer. Transition Brighton and Hove has some highly talented and knowledgeable people amongst its membership, and it occurred to us that there may well be TB&H members who may want to offer their expertise &/or who Brighton and Hove City Council may want to approach. When we know the criteria for selecting local experts, we will post the information on TB&H's website, so that willing and suitable experts can come forward.

The Sustainable Communities Act 2007

  1. The Sustainable Communities Act 2007 received Royal Assent on 23 October 2007. It is a significant piece of legislation which begins from the principle that local people know best what needs to be done to promote the economic, social or environmental well-being of their area, but that sometimes they need central government to act to enable them to do so. It provides a channel for local people to ask central government to take such action.
  2. Sustainable Communities Act: A Guide, published by Department for Communities & Local Government (CLG) in February 2008, provides an introduction to the Sustainable Communities Act. The CLG will shortly be publishing a consultation document seeking views on the draft Regulations and Guidance associated with the Act i.e. a public consultation is expected to commence soon.

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Brighton and Hove City Council's Sustainability Strategy

12 KEY OBJECTIVES around which 12 plans of action (2004-2006) have been developed

Brighton and Hove City Council's Sustainability Strategy [PDF 603kb] provides a framework for improving the environment and the quality of life of the residents of Brighton & Hove. It sets out the council's commitment to take action for a more sustainable future:

  1. Improve everyone’s access to ‘basic elements of life’ such as good quality local food;
  2. Reduce air pollutants and improve long-term air quality;
  3. Improve quality of life through leisure, culture and recreational opportunities;
  4. Improve the availability of jobs which improve sustainability and encourage local business to operate more sustainable business practices;
  5. Improve opportunities for people to develop educational and life skills;
  6. Reduce non-renewable energy use in Brighton and Hove, through supporting the use of alternative fuels, and at the same time reduce local fuel poverty;
  7. Improve the overall level of health for all communities in Brighton and Hove and to improve levels of health and safety at work and community safety;
  8. To ensure that everyone has access to decent, affordable housing that meets their needs;
  9. To make the most effective and efficient use of previously developed land (brownfield sites) and promote best sustainable practice in new development;
  10. Maintain and improve the natural environment, habitats and species at Brighton and Hove and to ensure that everyone has access to green space of biodiversity value;
  11. Achieve a reduction in road traffic and progress towards a ‘people friendly’ city with and integrated transport system; and
  12. Reduce, re-use and recycle more of our waste.

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The links below provide THE 12 PLANS OF ACTION (PDF Format) from Brighton and Hove City Council’s website.

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A new strategy for 2008-2009

A refreshed Sustainability Strategy for Brighton and Hove is expected by the end of 2009

Brighton and Hove City Council first launched its Sustainability Strategy (28-page PDF) in 2002 - the year of the 'Rio +10 Earth Summit in Johannesburg'. There followed a series of 2-year Action Plans.

The above plans of action date from the period 2004 to 2006. The Council now recognises that its Sustainability Strategy needs substantial updating.

Bringing in One Planet Living to produce a Sustainability Strategy for Brighton and Hove

Item 37 on the AGENDA of the meeting of The Council's Sustainability Commission on Wed 9th January 2008, was to consider a report by the Council’s Head of Sustainability & Environmental Policy on "Developing a One Planet Living Plan for Brighton & Hove". No decision as to whether to permit One Planet Living to go ahead with the update can be taken until 6th March 2008 at the earliest.

Should the latter be agreed, the process would probably involve: a. collection of planning data (3 months) b. workshops with local stakeholders (6 months) c. production of a report (2 months), and d. launch of the refreshed Sustainability Strategy (1 month). It would therefore take us well into 2009 before such an update could be completed.

The UK branch of One Planet Living have a second a presence in Brighton and Hove, through a separate wing of the organisation known as BioRegional Quintain , responsible for delivering communities in England. BioRegional’s first project in our city is expected to be a development of flats close to the railway station in Brighton. The development will meet the EcoHomes Excellent standard and a Sustainability Action Plan has been drawn up to demonstrate the project's response to each of the One Planet Living Principles:

  1. Zero Carbon
  2. Zero Waste
  3. Sustainable Transport
  4. Local and Sustainable Materials
  5. Local and Sustainable Food
  6. Sustainable Water
  7. Natural Habitats and Wildlife
  8. Culture and Heritage
  9. Equity and Fair Trade
  10. Health and Happiness

The same ten principles are likely to be used in updating The Council’s Sustainability Strategy for the city of Brighton and Hove.

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The Council’s Climate Change Action Plan

The Council’s Climate Change Action Plan is also due to be updated. The need for this was recognised during a themed discussion on Climate Change held on 31st May 2007 by a sub-group of Brighton and Hove's 2020 Community Partnership also known as The Local Strategic Partnership [LSP].

The intention of this sub-group was to develop a Climate Change Strategy which would be 'owned' by the 2020 Community Partnership - and therefore the wider community. The sub-group decided that for the strategy to be truly owned by the 2020 CP its development would have to involve a high level of consultation with local experts and interest groups from the outset.

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Brighton & Hove Climate Change Strategy Stakeholder Day

To achieve this aim, it was decided to hold Brighton & Hove Climate Change Strategy Stakeholder Day on 19th November 2007.

A 13-page PDF report on this day, has been produced by The Environment Council, which helped in the planning of the event.

The Environment Council is a registered charity of 40 years standing, with considerable experience of training, facilitation and providing a forum for dialogue. They were asked by Brighton and Hove City Council, acting on behalf of the 2020 Community Partnership (LSP), to help in the design and facilitation of the meeting in an attempt to get the best outputs from the day and to shape a way forward for the LSP’s Climate Change work.

A cross section of stakeholders met at the University of Sussex on 19th November 2007 to consider and comment on the Council’s Climate Change Strategy. Three members of TB&H’s "Liaison with Local Gov’t Group" were among the stakeholders present. The first talk by John Chesshire, focused on the necessity for a statutory duty on LAs to address climate change, in the light of the IPCC Report findings. The second talk, by Heather Buttivant, addressed the expected effects of climate change impacts on the South East area of the UK in coming years. The third talk, by Thurstan Crockett, was an honest assessment of current work going on in Brighton & Hove i.e. the current Climate Change Strategy i.e. an acknowledgement by the Council that more needed to be done.

The paticipants present compiled a useful list of ‘Visions’ as well as specifying the gaps in policy which would needed to be filled if these visions were to be achieved by 2050. They further produced league tables of Key Strategic Areas that B & H would most benefit from to maximize carbon reduction before 2050. Housing, Resource efficiency & reduction, and integrated transport, were clearly the top three areas.

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The 2020 Community Partnership

The 2020 Community Partnership also known as The Local Strategic Partnership [LSP] is responsible for Brighton & Hove's Sustainable Community Strategy.

The main thing to bear in mind is that the 2020 Community Partnership consists of many interest groups within Brighton and Hove, and is larger than the Council itself.

Although the 8 priority areas identified by The 2020 Partnership cover much of the same ground as the Council's 12 key areas in its own Sustainability Strategy, The 2020 Community Partnership sets out the vision and plans of several different agencies, organisations and communities within our city.

If One Planet Living are given the task of refreshing The Council's Sustainability Strategy one possibility would be to attempt to combine the Council's 12 key areas with The 2020 Community Partnerships 8 priority areas. Since One Planet Living define "sustainability" through 10 Key Principles, accepting their classification system could make understanding of Brighton and Hove's Sustainability Strategy easier for all. The question of "who owns the Strategy?" may arise, but good consultation might allow the many different interest groups to be represented. The Council now has a statutory obligation to have a Sustainability Strategy, though One Planet Living may be able to deliver a document which all parties feel generally belongs to the city of Brighton and Hove.


Ways of getting involved

Perhaps you belong to a local campaign, one of Brighton and Hove's residents' associations, or are working within a NEIGHBOURHOOD or INTEREST GROUP with the newly formed Transition Brighton and Hove.

If you are already meeting with other Brighton and Hove residents,
a good exercise could be to measure your own objectives against those of the city's 2020 Community Partnership.

2020 Community (Local Strategic) Partnership – 8 Priority Areas

  1. Promoting enterprise & learning
    Employment & economic development, Major projects, Learning & Education, Childrens Services, Arts & Creative Industries, Libraries & Museums, Culture & Tourism, Indicators & targets.
  2. Reducing crime & improving safety
    Crime & fear of crime, Alcohol, Children & Young People, Local Issues, Prolific Offenders, Indicators & targets.
  3. Improving health & well-being
    A Healthy City, Suicide, Lifestyle Factors, Healthy Ageing, Indicators & targets.
  4. Strengthening communities & involving people
    Engaging young people, Tackling discrimination, Building community spirit, good relations & celebrating diversity, Getting people involved, Tackling poverty, How people can control their circumstances, Indicators & targets.
  5. Improving housing and affordability
    Housing, Homelessness, Fuel Poverty, Indicators & targets.
  6. Promoting resource efficiency & enhancing the environment Water & Sewage, Climate change, Waste & Recycling, Built Environment, Biodiversity & the natural environment, Energy Efficiency & Renewable Energy, Indicators & targets.
  7. Promoting sustainable transport
    Reduced traffic congestion in central Brighton, Reduced traffic fumes & better air quality, More bus priority measures, More real-time bus information, Better transport links, Promoting the health benefits of walking & cycling, Improving the safety, security and attractiveness of streets, Provision of a Rapid Transport System, Indicators & targets.
  8. Providing quality services
    Providing quality services, Indicators & targets

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What's the point if the strategy is about to be refreshed?

Updating Brighton and Hove's Sustainability Strategy will involve city-wide consultation. It is an ideal opportunity to get involved. It is important to bear in mind that planning policy is part of a process of evolution. New policies do not appear "out of thin air". Notice will be taken of what has gone on before, and familiarity with the strengths and weaknesses of past action plans and policies will help you to make a constructive contribution to future ones.

The 8 priority areas identified by The 2020 Partnership both offer a good familiarization process and reflect the priorities of other interest groups in Brighton and Hove.

Although individuals and groups can make a difference on their own (see the organisations listed in the Green INDEX on this web site), Brighton and Hove City Council holds part of "the public purse" (money which we pay through tax). They already support several initiatives within the city. The Sustainability wing of the Council is also a source of funding, and sometimes they are short of applicants to take up the available support. Reasonable applications which reflect either 12 key areas of the Council's current Sustainability Strategy or the 8 priority areas of the 2020 Community Partnership are likely to be taken seriously.

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Brighton and Hove Council's Sustainability Team

Brighton and Hove Council's Sustainability Team, made up of Council officers, is a small team based within the Strategy & Governance Directorate of the council. The team works across the council and with the community to promote sustainability issues through the development of action plans, supporting local projects and campaigns, and through the delivery of an environmental education programme. The team offer unpaid volunteering, work shadowing and other work experience opportunities. Work can range from general administration and office duties, to research projects and assisting in the organisation of events. Projects which they already support include:

  1. Carbon Management Programme
  2. Climate change action plan
  3. Education for Sustainable Development Conference
  4. Eco-schools programme
  5. Energy performance certificate
  6. Environmental education
  7. Fairtrade
  8. Farmers' markets
  9. Green kids club
  10. Park Art Schools Resource CdRom
  11. Microgeneration
  12. Nuclear Power and Shoreham Harbour
  13. Real nappies
  14. Sustainability commission
  15. Sustainable schools
  16. Sustainability strategy
  17. Water saving
  18. Volunteering
  19. Water Action Plan

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The Council's Sustainability Commission

Those with voting powers on The Sustainability Commission, founded in 2002, are a group of elected Councillors. The composition of the group reflects the political balance on the Council as a whole. The purpose of The Sustainability Commission, which draws its expertise from several interest groups in the city, is to help Brighton & Hove City Council to develop and implement its sustainability policies as part of its activities, including partnership work with other agencies and bodies.

The Sustainability Commission's terms of reference - meetings are approximately every two months at Brighton Town Hall, Bartholomew Square, Brighton and members of the public are very welcome to attend. Forthcoming meetings (Wednesdays): 12th March 2008, 30th April 2008.
Click here for contact officer and Agendas of meetings.

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Why attend the meetings of The Council's Sustainability Commission?

It is perfectly possible for individuals and groups to ignore what the Council is doing and to act to reduce carbon emissions. However, it is also necessary to realise the ways in which the Council spends the money it collects from us, and both uses and wastes vast quantities of energy on our behalf.

A simple example of an area of expenditure and energy-use is street-lighting, item 5 on the AGENDA at the meeting of The Council's Sustainability Commission on 9th January 2008.

Peter Bloxham (standing in for the Council's Assistant Director, Sustainable Transport) gave an intriguing presentation. He disclosed that the city of Brighton and Hove has 21,000 streetlights, 5,000 illuminated bollards and 167 sets of traffic signals including traffic lights, panda and pedestrian crossings. Some of the Councillors present, cited areas of the city where street-lights were of older design. In some Brighton streets (e.g. parts of Coldean) the lights were on all the time - and only by fitting each individual light with photo-electric cells can this problem be resolved.

1. It is through attendance of Sustainability Commission meetings that members of the public can learn about instances of energy wastage.

Peter Bloxham explained that it was not practical to have a meter in each street to measure electricity consumption. Their contract with N Power was therefore for an unmetered supply, estimated at 9820397 Kwatts of energy p.a. The Council's mainetance contract with East Sussex County Council amounted to £642,000 p.a.

2. It is through attendance of Sustainability Commission meetings that members of the public can monitor decisions made by elected Councillors on their behalf..

Faulty street-lights, which are on all day and night, may not add to the Council's electricity bill if the supply is unmetered. So why waste money on fitting each with photo-electric cells or on replacing them with modern CosmoPolis lights (billed as "the next generation in urban public lighting")?

At the meeting on 9th January 2008, Chris Todd highlighted the fact that although these faulty lights were not being metered, the unnecessary consumption of electricity was not in keeping with The Council's Sustainability Strategy. Of course, replacement of inefficient or faulty street-lights could necessitate a higher level of Council Tax, so an administration wanting to keep the Council tax down is faced with a political dilemma. However, if the same administration is pressed by the voting public to take sustainability seriously, they may seek economy (in money terms) in another area of the Council budget or be willing to risk the political consequences of a Council Tax rise.

3. It is through attendance of Sustainability Commission meetings that members of the public are led to the following information:

The newer designs of streetlight, producing a white light (closer to natural daylight) are 'preferable to' and 'more energy-efficient than' the older pinky-orange sodium street-lights. Peter mentioned the manufacturer of these new designs: CosmoPolis.

CosmoPolis - the next generation in urban public lighting

Many town and city authorities are realising the considerable benefits that effective outdoor lighting has to offer in terms of increasing comfort, safety and security, making urban districts more attractive, and enhancing the public's sense of well-being and civic pride. Naturally, the municipalities also expect their lighting systems to be reliable, durable and energy-efficient, and to comply with the latest European lighting regulations. With CosmoPolis, Philips Lighting is introducing a total lighting solution that is highly efficient, sustainable, and offers white and yellow light and superior optical performance in timeless compact designs.

Highly effective natural white light. Enhanced ambience

The bright natural white light of the revolutionary, advanced CosmoPolis lamp helps to create an attractive night-time ambience. Increased sense of safety and security, Offering optimum colour rendering, bright natural white light helps people to identify people and objects, giving them a greater sense of safety and security.

Improved road safety

The bright natural white light improves off-axis/ peripheral visibility, allowing earlier detection of objects at off-axis angles. A high-performance solution - Example: a 3 km road 7 m wide, luminaires mounted at a height of 9 m, 4000 annual burning hours.

A revolutionary system

CosmoPolis is a complete system featuring new lamp technology specially developed for outdoor lighting, driven by the latest generation of electronic gear and incorporated in a brand-new miniaturised optic: the CosmoR.

The proposed wind turbines for Kings House

Another item discussed at the Sustainability Commission meeting on 9th January 2008, was whether to re-submit the application for "six turbines on top of the council building at King's House in Hove" and "one on the lawn outside", which was withdrawn late last year.

As was reported in The Argus on 15th January 2008, the Chair used her casting vote to block re-submission on the basis that there was not enough information available to make a proper decision. This particular vote was very much on party lines, which made members of the public wonder whether the members of The Sustainability Commission were truly applying the Council's Sustainability policies. The absence of the information needed to assess the likely performance of the proposed turbines and the quality of manufacturers' guarantees, was another puzzle, since this main item had been put on the AGENDA several weeks earlier.

One can monitor the performance of Councillors and Council Officers to an extent by reading The Argus report. However, attendance at the meetings puts residents in a better position to hear the arguments for blocking this re-submission and for judging why those in favour of it did not have more information to hand.

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The Planning Applications Sub-Committee and the planning process

Attending the two-monthly meetings of The Sustainability Commission, is the direct route to learning how Local Government consumes energy on the public's behalf, providing an insight into many aspects of city planning.

However, a more influential body and one which is largely responsible for shaping our city environment, is The Planning Applicactions Sub-Committee. Like The Sustainability Commission, this is made up of elected Councillors, reflecting the political balance in the city. Similarly, they are not meant to vote on party-lines, but on the basis as to whether planning applications comply with the policies of the Brighton and Hove Local Plan, soon to be re-named The Local Development Framework.

Newly elected Councillors cannot become experts in planning law overnight, nor do they have time to analyse planning applications in much detail. The latter is the work of Case Officers (i.e. Council employees assigned to each planning proposal), who request reports from all the relevant Council departments (Conservation and Design, Traffic, Environmental Health, The Council's Ecologist etc) before making a recommendation to the Planning Applications Sub-Committee on whether planning permission should be granted or refused. The elected Councillors on the Planning Applications Sub-Committee do not have to follow Case-Officers' recommendations.

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Objecting to unsuitable planning applications

One of Transition Brighton and Hove's priorities must be to influence our local Council's policy-making on sustainability. Note that our Council's concept of Sustainability extends to a wide range of objectives. We need to scrutinize how objectives involving expansion and growth are being applied by planning officers and members of the Council's planning applications sub-committee. Growth in renewables or carbon emissions?

If you are objecting to planning applications, the first thing to do is to attempt to influence the Case Officer's recommendation. Your opportunity to do so is during a three-week period of formal consultation, which usually starts soon after a planning application is registered.

To monitor planning applications, go to the Council's Online Planning Register, tick "I accept" for authorisation to proceed and enter a street name (such as Hollingdean Lane!), or fill in other appropriate fields, in the search box facility. This can return a list of planning applications in any part of the city i.e. wherever you want to look. Any resident of Brighton and Hove has the right to oppose planning proposals in the city, and a powerful objection is that the application is an example of unsustainable development. The more familiar you are with Brighton and Hove's Local Plan or Local Development Framework, the more policies you will be able to quote in support of your objection. Chapter 3 of The Local Plan on Quality and Design has particular weight in deciding the outcome of planning proposals. It is also worth familiarizing oneself with some of the new Supplementary Planning Documents (SPDs). These are replacing older documents known as SPGs or Supplementary Planning Guidance notes. For the time-being, one of the important SPGs which is still be applied (SPGBH note 21) is more commonly referred to as Brighton and Hove City Council's Sustainability Checklist. A list of these older Supplementary Planning Guidance notes is posted here.

The purpose of both the older SPG notes and the new SPDs is to provide guidance on how policies in the saved Local Plan and replacement Development Plan Documents (DPDs) will be implemented.

You will also notice that many Supplementary Planning Documents (SPDs) are now accompanied by their own Sustainability Appraisals.

Policies relating to sustainability and protecting against overdevelopment need to be quoted in residents letters of comment, to ensure that planning officers and the local councillors remember to apply them. Development proposals vary. Some consider local communities, but a proportion of applications are made by private speculators who have their eyes focused on profit at the expense of communities. It is certain that developers will be making their own representations to Case Officers in Council's Development Control and sounding out some of Departmental Managers who supply the Case Officer with their reports. We have to do the same. The Case Officer's final recommendation provides important guidance to members of the Council's planning applications sub-committee. The latter consists of 12 elected City Councillors (reflecting the political balance), who are meant to be guided by planning policies rather than political affiliation.

Meetings of the Planning Applications Sub-Committee are held once or twice a month, and you can see descriptions of the proposals which are being considered within the Planning Register on Brighton and Hove City Council's web site. The best time to lobby the local councillors on the Planning Applications Sub-Committee is about one week before the relevant meeting.

Note that on some occasions (e.g. if planning applications draw fewer than five letters/messages of support or objection during the consultation period) proposals do not reach The Planning Applications Sub-Committee. Instead, the decision to refuse or accept the proposal can be delegated to the planning officers in Development Control.

Developers can appeal to The Secretary of State (the government's Planning inspectorate) against Council refusal. However, objectors do not have the same right to appeal against approval. An Appeal by a developer against refusal, provides objectors with a valuable chance to comment directly to the Secretary of State, an opportunity both to support the Council's reasons for refusal &/or to highlight other grounds for refusal (i.e. policies in the Local Plan) which they feel the Council has failed to apply either deliberately or through accidental omission.

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Brighton and Hove City Council's Adopted Local Plan

Index (PDF 49kb) to the policies: TR, SU, QD, HO, EM, SR, NC, HE

Introduction (PDF 649kb)

TR1-TR21 Chapter 1 Making the connection between land use and transport (PDF 882kb)
SU1-SU16 Chapter 2 Energy, water, pollution and wste (PDF 1.4mb)
QD1-QD28 Chapter 3 Design, safety and the quality of development (PDF 2.1kb)
HO1-H017 Chapter 4 Access to a decent home and community facilities (187kb)
EM1-EM20 Chapter 5 Supporting the local economy and getting people into work (PDF 1.3mb)
SR1-SR26 Chapter 6 Shopping, recreation and leisure - maintaining vitality and viability (PDF 2mb)
NC1-NC12 Chapter 7 An integrated approach to nature conservation and the countryside (PDF 1.2mb)
HE1-HE12 Chapter 8 Managing the change within an historic environment (PDF 852kb)

Glossary (PDF 74kb)

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Using The Council's Online Planning Applications Comment Form

Link to use The Council's Planning Applications Comment Form

The formal consultation period for planning applications is normally 21 days, starting from when the Council agrees to register the proposal. The appropriate entry in the Council's Online Planning Register (you can search by street/area/postcode) will say that the proposal is "under consideration". If the decision goes to The Planning Applications Sub-Committee, the Case Officer will usually accept letters of comment if they arrive before 12 noon on the Friday before the planning meeting.

Click here to see the matters which the Council can and cannot take into account when reviewing your comments. The easiest way to make "valid comments" (in terms of what the Council will consider) is to tie your arguments to policies in Brighton and Hove City Council's Adopted Local Plan.

Areas of comment which can be taken into account

  1. The proposal does not comply with the Council’s planning policies.
  2. The proposed use is not suitable for the area
  3. The appearance and size of a new building is inappropriate.
  4. External alterations to an existing building are not in character.
  5. Adjoining residents will suffer overshadowing, overlooking or loss of privacy.
  6. There will be an increase in noise and disturbance, e.g. from the comings and goings of extra traffic.
  7. New buildings do not have satisfactory access for disabled people.
  8. New roadways and accesses will not be safe for pedestrians and other road users.

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Protecting open spaces and greenfield sites in your neighbourhood
i.e. ensuring that sustainability is high on the agenda in planning decisions:

Constant reminders are needed to ensure that Council Officers and Planning Applications Sub-committee members apply the policies in the Council's Sustainability Strategy, giving them priority over considerations which are detrimental to the environment.


(i) Omitting to make it clear when proposed development sites are 'greenfield'

A common omission, probably my chief source of complaint to Brighton and Hove City Council, is failure to make the planning status of threatened greenfield sites clear to both developers and local residents alike, when registering development proposals. They have never answered me on this. They prefer to keep quiet about the planning status of greenfield sites, pretending on occasions that the status of a plot is "a grey area", when they know all about its planning history.

There is in fact a very clear government definition on what is ‘greenfield’ and what is ‘brownfield’. See Annex Definitions B: of Planning Policy Statement PPS3 (PDF scroll down to page 26)

Even when my residents’ association and individual residents association have dug into their pockets to engage the services of a planning lawyer, who confirms that a proposed development site is "greenfield", the Council does not require developers to correct inaccurate claims in their Design Statements describing the same site as ‘brownfield’.

Consequently, planning officers, the media and even members of the planning applications sub-committee, who decide the outcome of proposals, get fed with misinformation, which I feel its is the case officer’s duty to correct.

We must get involved in the planning process to publicize these gross omissions, which amount to failure by Council Officers &/or Members of the Planning Applications Sub-committee to apply the accepted policies in the Council's Sustainability Strategy. Instances in my own locality (Round Hill), where this has happened, include:

1) The developer Carelet's proposals to locate high-density development on a greenfield site, adjoining a railway corridor and designated greenway.

2) The application to build on a greenfield site, involving the ribbon of land to the east of the Cat Creep steps between Richmond Road and Round Hill Crescent. This greenway is The Round Hill conservation area's "jewel in the crown" and included a wildlife garden which has won national awards.

In each of the above cases, Council Officers have failed to apply the Council’s accepted policies on sustainability and greenfield development, as stated in:

(a) Their action plan on "land use" ( page 6 of this PDF document)

(b) The planning obligation relating to greenfield development in Chapter 3 Section QD 28 (scroll down to 3.118).of the Brighton and Hove Local Plan.

(c) Annex Definitions B: of Planning Policy Statement PPS3 (PDF scroll down to page 26) clarifies what is "brownfield" and what is "greenfield". The Council has failed to make the greenfield planning status clear to these developers.


(ii) Omitting to perform neighbourhood-specific open space assessments

Our Council's failure to apply the Government's Planning Policy Guidance PPG17 on open space assessments

Brighton and Hove Council has also failed to follow the Government Planning Policy Guidance requiring open space assessment before even considering proposals involving the loss of open spaces to the local community.

In relation to the planning applications mentioned above, all threatening the loss of open spaces to the neighbouring community, the Council has omitted to carry out the government's recommended assessment procedures, which involve consulting local residents on the value of the open spaces - See PPG17 Diagram 1 and Paragraph 10 .

A City-wide open space swindle, rather than the NEIGHBOURHOOD-SPECIFIC survey recommended under the Government's Planning Policy Guidance PPG17

The Council's most recent city-wide open space survey has been performed with the help of PMP, a large private consultancy. They have sent a questionnaire to a random selection of Brighton & Hove residents focusing only on publicly accessible open spaces, shared between different suburbs, such as Preston Park, The Level and Stanmer Park.

Both PMP and the Council have ignored the Government's Planning Policy Guidance (PPG17) which requires open space assessment to be both city-wide and NEIGHBOURHOOD-SPECIFIC and values inaccessible open spaces on private land, which can contribute to wildlife habitat, biodiversity, local amenity, offering much needed 'green lungs' in densely-populated areas and a sense of well-being.

PMP's version of open space assessment appears to be designed to provide a license for the Council to do more in-filling on urban land which will be needed for growing food.

The following links will help residents who are interested in the Government's Planning Policy Guidance (PPG17) to Local Councils on Open Spaces. Councils do not have a statutory duty to follow the guidance, but planning inspectors in performing past appraisals (e.g. of The Local Plan) have not refrained from indicating weaknesses in Brighton and Hove City Council's "Open Spaces" policy. Citing the government's expectations is a useful pressure point.

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Planning applications likely to be incompatible with Transition Brighton & Hove's objectives

Supporting the Council when they get it right

We should support Brighton and Hove City Council on the many occasions when Planning Officers make the right recommendations or decisions. Hollingdean Road is already an Air Quality Management Area and to cram this number of residents onto a site which should only take two or three small terraced houses (at the most) is shear madness.

The developer (Southern Primary Housing), responsible for the Holingdean Road proposal, appealed against Council's refusal of their proposal. A Public Inquiry into the Appeal was held on 11 December 2007 at Hove Town Hall.

Developers will pretend to be involved in alleviating the housing shortage, but unsutainable solutions help nobody. The profit motive which encourages people "with the money" to "corner the market in land", which represents land as part of an investment portfolio, is the enemy of people struggling to get onto the housing ladder. The late E. F. Schumacher, author of "Small is Beautiful" explains this in his excellent article, See "THINK ABOUT LAND" written for a housing charity.

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SPG Note 16: Renewable Energy & Energy Efficiency In New Developments

Please note: although this SPG, adopted in July 2004, provides the existing guidance, policies in this area are evolving very rapidly, and this SPG is expected to be incorporated soon in what is currently the Draft SPD on Sustainable Building Design together with the Brighton & Hove Sustainability Checklist SPG Note 21: adopted March 2004, reproduced below.

SPG Note 16: Renewable Energy & Energy Efficiency In New Developments: July 2004 - 1.1 This (adopted) SPG provides the existing guidance on the technologies available and how developers and householders can use renewable energy within new developments and conversions as well as providing guidance on achieving energy efficiency within schemes. It should be read in conjunction with Brighton & Hove Local Plan policies SU2 and SU17.

The Governments Energy White Paper sets a target to reduce carbon dioxide emissions by 60% by 2050. In order to achieve this target, the way buildings are designed and the supply of energy will need to change.

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Brighton & Hove Sustainability Checklist

Adopted SPG Note 21: March 2004

Please note: Supplementary Planning Guidance notes (SPGs) can no longer be produced and are being replaced by Supplementary Planning Documents (SPDs). However, the following checklist still represents the sustainability requirements which development proposals are expected to meet.

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SCORE SHEET | Q=Criteria | FM = fully met | PM= partly met | NM = not met | Comments = |

  1. Does the development protect / maintain and enhance / the biodiversity of the site as per Local Plan Policy QD17?
  2. Has a nature conservation report been submitted as part of the application?
  3. Does the development give rise to an increase in land and water contamination and atmospheric pollution?
  4. Will the design of the development be of a high standard contributing to public safety and crime prevention?
  5. Does the development provide a mix of uses suitable to the area and the development itself? (If major development)
  6. Does the development add a diverse range of employment opportunities for local people, encouraging both start-ups and expanding businesses?
  7. Does the development provide training opportunities for local people?
  8. Does the development provide for expansion in growth areas, as identified in the economic strategy?
  9. Has the development been developed with regard to the principles of policy SU2 and Draft Supplementary Planning Guidance 16 on Renewable Energy and Energy Efficiency?
  10. Does the development incorporate sustainable energy sources such as CHP, Solar and Wind?
  11. Will the development secure the re-use of vacant, derelict and underused sites?
  12. Is the development located in an area with good access to local community facilities?
  13. Will the development achieve a BREEAM / Eco Homes rating of Very Good / Excellent?
  14. Will the development be accessible to all sectors of the community?
  15. Is the development located in an area with a good level of access to public transport?
  16. Will the development promote a sustainable means of transport to all sectors of the community by including e.g. car clubs / car sharing schemes and if a major scheme a Sustainable Travel plan?
  17. Will the development encourage cycle use by providing onsite parking facilities in accordance with TR12 and provide shower and changing facilities if an office development?
  18. Will the development incorporate recycling facilities on site?
  19. Is construction material reused, or recycled from sustainable resources and from a source within 20 km?
  20. Will the development reuse waste water and reduce water consumption?
  21. Will the development provide a mix of unit sizes?
  22. Does the development incorporate the provision of public and private amenity space in accordance with the provisions of policies HO (new policy) and HO5 of the Second Deposit Draft Local Plan?

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Q01 Does the development protect / maintain and enhance / the biodiversity of the site as per Local Plan Policy QD17?

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Q02 Has a nature conservation report been submitted as part of the application?

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Q03 Does the development give rise to an increase in land and water contamination and atmospheric pollution?

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Q04 Will the design of the development be of a high standard contributing to public safety and crime prevention?

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Q05 Does the development provide a mix of uses suitable to the area and the development itself? (If major development)

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Q06 Does the development add a diverse range of employment opportunities for local people, encouraging both start-ups and expanding businesses?

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Q07 Does the development provide training opportunities for local people?

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Q08 Does the development provide for expansion in growth areas, as identified in the economic strategy?

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Q09 Has the development been developed with regard to the principles of policy SU2 and Draft Supplementary Planning Guidance 16 on Renewable Energy and Energy Efficiency?

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Q10 Does the development incorporate sustainable energy sources such as CHP, Solar and Wind?

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Q11 Will the development secure the re-use of vacant, derelict and underused sites?

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Q12 Is the development located in an area with good access to local community facilities?

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Q13 Will the development achieve a BREEAM / Eco Homes rating of Very Good / Excellent?

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Q14 Will the development be accessible to all sectors of the community?

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Q15 Is the development located in an area with a good level of access to public transport?

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Q16 Will the development promote a sustainable means of transport to all sectors of the community by including e.g. car clubs / car sharing schemes and if a major scheme a Sustainable Travel plan?

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Q17 Will the development encourage cycle use by providing onsite parking facilities in accordance with TR12 and provide shower and changing facilities if an office development?

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Q18 Will the development incorporate recycling facilities on site?

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Q19 Is construction material reused, or recycled from sustainable resources and from a source within 20 km?

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Q20 Will the development reuse waste water and reduce water consumption?

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Q21 Will the development provide a mix of unit sizes?

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Q22 Does the development incorporate the provision of public and private amenity space in accordance with the provisions of policies HO (new policy) and HO5 of the Second Deposit Draft Local Plan?

Draft SPD on Sustainable Building Design

Draft SPD on Sustainable Building Design

What are the aims of this SPD?

(a) To provide detailed, up to date, clear advice to various user-groups on relevant sustainable design policies;
(b) to improve the environmental performance of the city’s new build and existing buildings; and
(c) to make sure all developments in Brighton & Hove achieve the highest possible standards of sustainable building design.

This SPD will incorporate current guidance on Energy Efficiency & Renewable Energy (SPGBH 16) and the Brighton & Hove Sustainability Checklist (SPGBH21).

What information can be found in this SPD?

This SPD provides further guidance on:
(1) what the local planning authority requires from developments in the city in terms of sustainable building design, including targets, standards and thresholds;
(2) how to meet these requirements; and
(3) opportunities for owners and occupiers to improve the environmental performance of the city’s buildings even when planning permission is not required.

This SPD is intended for owners and occupiers, communities, developers, builders / contractors, planners and design professionals.

Information on CO2 emissions and climate change, reduction targets and resource saving technologies is fast changing. The speed of change is such that some policy documents become redundant soon after being published.

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