Gasworks development : BHCC Failures Chapter 4 – Failure of both the Council and the Berkeley Group to respond  to the Gasworks Coalition’s concerns about the public consultation 

Gasworks development : BHCC Failures Chapter 4 – Failure of both the Council and the Berkeley Group to respond  to the Gasworks Coalition’s concerns about the public consultation 

This is the fourth article in our series of ten Chapters on BHCC failures relating to the Gasworks development.  Read on……

The first three instalments have already been published on the Brighton Society website. These are:

Chapter 1 : Introduction

Chapter 2 : The attempt to extend the Marina Tall Buildings zone on to the Gasworks site

Chapter 3 : Failure to respond to multiple Freedom of Information requests.  

There were two ‘public consultations’ carried out by the Berkeley Group the first in summer 2020, the second about six months later.  

In response to the second public consultation the Gasworks Coalition of thirteen leading city amenity societies and community groups was established in early January 2021 to campaign against the Gasworks proposals.

On February 17 2021 the Gasworks Coalition issued a statement to the Berkeley Group setting out our concerns about the Gasworks proposals.  A copy was also sent to the Council Planning Dept.

It set out six key issues of concern.

       – We welcomed the use of the site for housing

       – Climate change and the consequences of Covid

       – Density and height

       – Responsible development in the light of Covid

       – Contamination issues

       – Responsible development in the public interest

Berkeley’s very brief reply didn’t address any of the issues we raised; it merely said,

         “….all received and recorded as part of our consultation process”.

That was not a satisfactory response and fails to recognise the Council’s own requirements set out in its Statement of Community Involvement:  “Developers of larger sites will be expected to engage with local communities – residents’ and community associations and relevant interest groups…”  That’s pretty clear.

 Further Questions for Berkeley

On 29 March 2021 as part of the second public consultation process, the Coalition sent fourteen questions to Berkeley – one from each group in the coalition (Another group – The Kingscliffe Society – had joined in the meantime).

Here are the fourteen questions:

1. Alternative design studies – Question from the Brighton Society
What alternative design feasibility studies were carried out?

2. Contamination issues Question from The Kemp Town Society
What do you see as the main risks of formulating detailed design proposals before the contamination issues have been properly researched?

Has the process of monitoring air quality started? If not, when will it start?
When will it be stopped?

3. Health & Safety Question from AGHAST
Southall residents living near the Berkeley Group Gasworks site have experienced health problems that they believe are the result of soil remediation that was not fit for purpose. In the call with AGHAST on Monday 1 March, Dan Wickham (St William) claimed the reported health issues were unrelated to odours emanating from the site or the remediation work.

3a What proof does Berkeley Group have that the incidents of local illnesses are not related to gasworks remediation?

3b How is Berkeley Group proposing to ensure that such problems do not occur in Brighton?

3c Why has the Berkeley Group chosen to use the same specialist company (Atkins) as the remediation consultant for the Brighton Gasworks site?

4. Tall buildings issues – Question from the Amex Area Neighbourhood Action Forum
Will overshadowing diagrams/animations showing the effects of shadows cast by the buildings (at the very least at hourly intervals during daylight hours at the four equinox dates), be published before the planning application?

5. Wind Studies Question from the Kingscliffe Society
What wind studies have been carried out?

What will the wind effects be on the open spaces between buildings (including balconies), from strong north-easterlies and prevailing south-west gales when they hit tall, densely packed buildings?

The following three questions related to the public consultation. process.

6. Question from the Montpellier & Clifton Hill Association
Will the responses to the public consultations (both stages) be published prior to the planning application?

7. Question from the West Hill Community Association
Will you commit to allowing time between your final design and planning application so that residents can be consulted on developed design proposals?

8. Community involvement Question from the Regency Square Area Society
To what degree do you consider you have complied with the Council’s Statement of Community involvement (adopted March 2015), in particular paras 4.10 – 4.14 and Table 4 on p.29?

9. Views and viewpoints Question from the Brighton & Hove Heritage Commission
Why have site sections east/west and north/south, not been issued at consultation stage which show the existing and proposed site ground levels in relation to the surrounding areas, and relate the relative heights of the proposed new buildings to the existing buildings to the east, north and west?

Where will the viewpoints be located (including from the top of Wilson Avenue and from the seafront), which will show the visual impact of the buildings from a variety of directions including from the sea?

Can we be shown a fly-through video?

10. Density Question from the Regency Society
How do you justify more than 700 dwellings on a site of around two hectares (ie a density of >350 dwellings/hectare when the City Plan asks for a minimum of 85 dwellings on the entire site and, as a comparator for another site well outside the city centre, Toads Hole Valley, where the housing planned is 50 to 75 dwellings/hectare on a 26 hectare site? 

What is the confirmed proposed density of this development expressed in dph?


11. Question from the North Laine Community Association
What justification have you for not yet having revealed the extent of affordable homes on the site? How will you define affordable?

12. Question from Rottingdean Heritage
Housing Needs – have you researched the housing needs for this development?

What is the breakdown of accommodation? i.e how many 3-bedroom dwellings, how many 2-bedroom dwellings, how many 1-bedroom dwellings, how many studio apartments?

How do those figures relate to the housing needs for each of those categories set out in the City Plan?

13. Sustainability and zero carbon issues 
Question from the Southdown Rise Residents Association
Why do the proposals fail to include sustainable, eco friendly, and potentially carbon neutral design features so that it aligns with the city’s aim to build sustainably and to become carbon neutral by the year 2030?

Has Berkeley investigated using lightweight engineered timber (CLT) techniques for the new housing? Examples exist in Leamington Spa, East London and Maidstone for buildings between six to ten storeys.

14. Parking issues – Question from Marine Gate Holdings
How many parking spaces on the proposed plan will there be, in relation to the number of proposed dwellings?


On 15 April 2021 we received a reply from Berkeley:

“We have registered your questions as part of our Stage 2 consultation and will consider them alongside the other comments we have received in moving our design proposals forward. We plan to hold our next public event in the Summer to update everyone on our updated design proposals when we have collated the planning application documents, at which point we will be able to provide information on detailed aspects of the proposals such as microclimate, overshadowing and affordable housing. We will also be submitting a Statement of Community Involvement and will be sharing the consultation responses received.”

But there were no responses to our fourteen questions.  It looked as though the planning application would be the next stage.  At the time we anticipated that this would be made at some stage during the summer.

A copy of our responses to the public consultation and covering letter was also sent to Liz Hobden, Head of Planning and Councillor Leo Littman, Chair of the Planning Committee. 

This covering letter was sent by the Brighton Society on behalf of the Coalition:

I attach the Brighton Society’s response to the 2nd public consultation for Berkeley/St William’s proposals for the Gasworks site.

You will have gathered from the recent joint statement signed by 13 community and amenity groups (including both ourselves and the Regency Society), and recent articles in the local press, that there are major concerns in this city about the Berkeley/St William proposals in their current form.

We understand that government housing targets to a certain extent are conditioning the Council’s attitude towards the sort of massive urban conglomeration such as the Gasworks proposal.

But this is a step too far.  It achieves absolutely nothing other than large numbers.  It doesn’t provide affordable housing; it doesn’t relate to the nearby heritage assets in scale or character; it doesn’t relate sympathetically to the adjacent landscape and seascape; it doesn’t provide the sort of housing that the local community needs; it doesn’t aspire in any way to the sustainable building and ecological priorities which the city is trying to achieve in other fields.

In short it is our view that the Council has to insist that this proposal goes back to the drawing board.

We will continue to campaign as hard as we can for this, and will be expanding the campaign to make councillors and our MPs aware of the shortcomings of Berkeley/St.Williams proposals.

We would like to think we could have a dialogue with you over our concerns and those of the other 12 groups, and would welcome any suggestions you might care to make in that direction.

In the meantime here is our response – forwarded to you now because we think it unlikely that the Berkeley Group will divulge its contents publicly prior to making a planning application – even if that.

It is also posted on our website

Yours sincerely,

Jeremy Mustoe

Chairman, Brighton Society”

Despite our suggestion for a dialogue (see above), no reply was received.  The planning application was lodged the following December (2021).


The planning application initially attracted well over 600 objections.  (At the time of writing this article in April 2023, there are almost 1000 objections registered on the Council website).

The Council was under pressure to do something, but for some considerable time there was a vacuum of information.  In subsequent correspondence with the Head of Planning we commented:

We are now in a sort of no-man’s-land where the application is proceeding, the Council are attempting to draw up an as yet undefined list of further issues to discuss with the developer, the results of which will be put out for some form of public consultation, the timescale for which is unknown.”

The story of the Gasworks Coalition’s  post-planning application discussions with the Council is described in detail in our next article in this series: Chapter 5 – Failure to comply with Council’s own rules in validating the planning application

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