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Response of the Brighton Society to the Draft City Plan (3)

CP9 Sustainable Transport
SA6 Sustainable neighbourhoods
SA3 Valley Gardens
CP12 Urban Design

The Brighton Society commented on the City Plan Park and Ride Transport Options Paper in December 2011, expressing our disappointment at the lack of strategic thinking behind the proposal to abandon plans for Park and Ride and to adopt alternative measures to reduce city centre traffic.

We can only reiterate this view and emphasise our strong concerns that a formal Park and Ride Policy is not included in the Draft City Plan.

We consider that past public policies of constructing multi-storey car parks in the central area, in particular the huge car parks associated with the developments around Churchill Square, have been a major cause of the congestion problems currently being experienced in the City.

These problems are only going to get worse in the next 18 year period for which the City Plan is to be the blueprint. Yet there is no realistic alternative being proposed which would provide the majority of residents and visitors to the City any alternative way of moving around easily and inexpensively.

Included in the Draft City Plan are improvements to the city streets and open spaces.  These, though highly desirable in order to create a better and more attractive environment for pedestrians and cyclists, will inevitably reduce the capacity of the road network to accommodate traffic and could also compromise public transport, leading to even more congestion.  So the lack of a coherent and sustainable transport policy could also threaten the viability of future townscape improvements

There comes a point where the problems of congestion and pollution have to be tackled and the emphasis placed on improving and increasing the capability of the public transport system to provide a more effective and cheaper alternative to the private car.  Park and Ride  would play an important part in achieving this aim.

There are highly successful precedents for Park and Ride and several cities of similar size to Brighton have introduced successful Park and Ride schemes – Winchester, Cheltenham, Oxford, Cambridge and Canterbury to name but a few.

In order to achieve a successful Park and Ride scheme a number of things have to happen – and the sooner the better.  The City cannot wait 18 years before they are tackled

Brighton already has many of the components of a successful Park and Ride scheme.

–            It has an excellent Bus Company and an established network of routes and connections to all parts of the City and the surrounding areas

–            the road system has several routes with dedicated bus lanes and the potential for these to be extended and improved further

–            it has a relatively high density of population, and together with the surrounding areas of East and West Sussex District Councils a fairly continuous urban area distributed along the south coastal area;

–            it attracts a high number of tourists – like Oxford and Cambridge.  In these cities, visitors form a high proportion of the users of Park and Ride.  It would certainly make Brighton more attractive as a tourist destination.

There are two main problems.

The first is the shortage of potential sites, because of the city’s restricted location between the sea and the South Downs National Park.  That makes it all the more important and urgent that any possible sites are identified and secured before they become unavailable.  Why for example has part of Toad’s Hole Valley not been suggested as a potential site?  It has good links to the A27 and into the City via Dyke Road.  A large parking area could be created at the top of King George VI Avenue in the area of Court Farm  which could be screened by trees to reduce the visual impact.

Other potential sites in under-utilised areas to the east and west to cater for commuter traffic into Brighton, as well as sites to the north of the City should also be explored.

Nor should sites within the National Park be discounted as long as they were well designed and heavily landscaped and planted with trees. Has any approach along these lines been made to the South Downs National Park?

Cambridge for example has sited some of its Park and Ride facilities within the Green Belt outside the City boundary, and these are not unattractive, being very well designed and landscaped.  If travellers sites are acceptable to the Council within the National Park, why not well designed car parks?

Other potential sites could also be explored – why not encourage parking at railway stations with large commuter car parks north of Brighton particularly at weekends, with either rail or bus services from there into Brighton?

The second main problem is that there are too many City Centre car parks.  A policy to reduce these year by year should be included in the City Plan starting with North Road. The public accept steady incremental change more readily than the shock of radical change.  Such a policy was in fact actually carried out in Cambridge – the largest central car park in the City was demolished as part of a major retail development which included a new John Lewis store.

The omission of Park and Ride from the City Plan is a serious error of policy.

An eminent planner once described one of the main roles of planning as “to avoid the significance of irreversible mistakes”

Park and Ride should be reinstated as an essential part of a Sustainable Transport Policy.
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SA6 Sustainable neighbourhoods

1.   We consider that this section of the City Plan sets out many admirable and desirable objectives, which we would fully support.

We would make two points:

I.          It does not set out in a clear statement what the Council sees as its overall role in creating and maintaining the sustainable neighbourhoods and how it can best play its part in achieving its policy aims.

We think that the role of the Council in relation to sustainable neighbourhoods should be to act as a catalyst and facilitator for individual community organisations to take on and develop with assistance where required – whether advisory, administrative or financial, and to create an environment within which individual or community initiatives are encouraged to grow and resolve the variety of problems which need to be tackled and overcome.

This should be set out clearly as prologue to this section of the City Plan.

ii.          Many of the policies require expenditure, and we are doubtful that all the policies set out in the Plan are affordable.  For example, para 3.159 states that work will be undertaken to…to improve public transport links.  This is at a time when active measures are being taken by the Council to cut many bus services serving outlying areas  – nor was there any community consultation about this beforehand or scope for any discussion with people likely to suffer as a result of the cuts.

So much for encouraging sustainable communities…!
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SA3 Valley Gardens

Context, 3.12

We agree that this area is of  “unique strategic and topographic significance” to the city

Overall aims

The first of these, the notion of a new vibrant park, sets a tone that risks both a promotion of visual and aural loudness, and a skewed topography. Landscape and amenities here certainly need enhancement, but noise and gimmickry should be eschewed. The historic aspects of the area would benefit from being promoted fundamentally as a series of ancient fields, throughout which the basic east-west symmetry of the landscape needs to be preserved.

This essential symmetry and rhythm, along with many priceless mature trees, would be destroyed, for example, by the transfer of traffic to one side of the valley landscape, producing an enormous road along that side, with a bottle neck at the Pavilion and at St Peter’s

The green spaces

The first of these, the notion of a new vibrant park, sets a tone that risks both a promotion of noise and garishness and a skewed topography. Landscape and amenities here certainly need enhancement, but noise and gimmickry should be eschewed. Vibrancy threatens the plan’s stated principle of preserving the special and graceful characteristics of the area. The historic aspects would benefit from the area being promoted fundamentally as a series of ancient fields, throughout which the basic east-west symmetry of the landscape needs to be preserved. We would like to see the addition, and not the loss, of trees.
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CP12 Urban Design              

Without at this stage being able to comment on the proposed Urban Design Framework, our comments are limited to the following points:

1.   Para 1: We would like to see the phrasing of this paragraph re-defined to specifically state a presumption in favour of “low to medium rise development” except in areas where the City Plan has identified taller buildings – ie between 6 storeys (18m) and up to 15 storeys (45m), as being appropriate.  (But see also our comments in para 4 and para 5(ii) below on this topic).

2.   Criteria on which all new development will be expected to comply

Item 2Establish a strong sense of place etc” – will the Urban Design Framework specify how this will be  achieved – ie through a mandatory analysis of the identified neighbourhood concerned and a design statement showing how the proposals have been influenced by that analysis?

Item 4 : We suggest that this aim should be strengthened to read “ Conserve and enhance the city’s built and archaeological heritage”

         Item 5 : We suggest that this aim should be strengthened to read “Protect and enhance strategic views into, out of and within the city”

4.   Para 4.133 : This paragraph is designed to “enable as much certainty and clarity as possible about where the city will broadly accommodate any taller development”.

It is quite unclear to us how this policy clarifies areas where buildings just over 18m high would be acceptable, and where buildings between that height and 45m high (approx 15 storeys), would be unacceptable. As currently defined there appears to be a danger that all new tall buildings developments will take maximum advantage of the Tall Buildings Statement – see Item 5(i) below.

5.   Para 4.134 : This lists areas of the city where increased density could be achieved by permitting tall buildings as defined by the Tall Buildings Statement SPG 15

We have two major reservations over this :

(i)       We consider that the Tall Buildings Statement needs to be revised as part of the current City Plan Review.  We have recently seen two proposals for tall buildings, one on London Road (No.1 Preston Park), and the other in the Hove Station Area where developers have proposed buildings which are at the maximum height (or apparently greater in the case of Hove Station), allowed under the current planning policy, leading to proposals for high buildings which are completely out of scale with their surroundings.   This tendency is obviously going to be repeated in the other areas listed in para 4.134

(ii)       We note that additional areas considered as suitable for tall buildings are now proposed under the draft.

Three areas are included which we consider are certainly not appropriate for future tall building development.  These are all along or adjacent to the seafront, and are the Central Seafront, the Western Seafront / Kingsway, and the Eastern Road / Edward Street areas.

We believe that the appearance of buildings all along the seafront is of vital importance to the character of Brighton and Hove, and the frontage of the city along the seafront should be of a reasonably consistent height and scale.  This strategic aim should take precedence over any perceived need to increase housing or commercial densities.  These should be accommodated in areas further back from the seafront.

Otherwise we run the risk of creating a wall of tall buildings along the seafront which will block views of the sea from other areas of the city, and disguise and run counter to the natural topography of the land which in general rises steadily from sea level towards the north.  The scale of development along the seafront should reflect this and its height be kept relatively low.

a) Central Seafront.  We appreciate that this is a relatively small area which already has some tall buildings.  But it is almost universally considered that the existing tall buildings here (primarily Sussex Heights and the Holiday Inn Hotel), have had a very detrimental effect on the appearance of the seafront, and are quite out of scale with the surrounding older buildings.  Enough is enough.  All new developments here should be in scale with and no higher than the other prominent buildings within this area of the seafront – ie, the Grand and the Hilton Metropolitan hotels.

b)   Western Seafront / Kingsway

                       This area too should maintain a consistent scale and height of new development, generally in sympathy with the existing buildings, to avoid a wall of high buildings separating the city from the sea.  Tall buildings here would be completely inappropriate.

    c)   Eastern Road / Edward Street

                        We appreciate that the proposals for the new buildings on the Sussex County Hospital site are taller than 18m. But we think that hospital uses should be the only exception to that in this area, and should not be used a reason to allow other forms of future development to be built higher than that.

We have commented separately on Policy DA8 – Shoreham Harbour – and our concern about the detrimental effect that tall buildings would have on views towards the sea and the effect on existing housing to the north of Kingsway in this area.

6.       Para 4.135  – SPG 15 : we have already noted above our concerns that the Tall Buildings Statement should be revised as part of the Draft City Plan.  It would have to be anyway to include any area considered suitable for tall buildings which is not included in the current SPG15

7.       Para 4.136 Strategic Design criteria.

Two comments – firstly, that we think it might be worth including a ‘health warning’ about the desirability of avoiding pastiche design solutions for developments in or close to historic environments and conservation areas

Secondly, that Design and Access Statements and Building for Life criteria are matters of detail not strategic design, and if they are to be mentioned at all under the category of urban design, should given a separate paragraph or included under para 4.139, and not mixed up with matters relating to the wider strategic issues of appearance, scale and townscape.