Response of the Brighton Society to the Draft City Plan (1)

DA1 Brighton Centre and Churchill Square Area
DA2 Brighton Marina and Black Rock Site
DA6 Hove Station Area
DA5 Eastern Road and Edward Street Area
SA1 The Seafront

DA1 Brighton Centre and Churchill Square Area

The Brighton Society recognises the need for a new conference centre to compete with facilities elsewhere in the country, and we welcome the Plan’s commitment to “high quality building design and townscape”.

We would also welcome a pedestrian link between the Churchill Square shopping mall and the seafront; however such a link has failed to work in the past so plans for a new one would need to be convincing.

We strongly question the need for additional shopping floor space. High street retailers are struggling to hold their own against online competitors and there are empty shops in the existing mall and nearby. It is true that there is currently a recession, but we believe that the proposed extension to the Mall would result in the permanent loss of shops in nearby streets.

We are also strongly opposed to the creation of any further closed off areas in the city centre, that is areas which cease to be public spaces once the shops close in the evening.

We welcome the commitment to improved public safety in and around West Street.

We consider that a policy should be specifically included in section DA1 to improve the appearance and visual quality of the urban environment and townscape in Cannon Place and Russell Road as part of any redevelopment proposals in this area. Both streets are urban disaster areas.

We do not think any more tall buildings are appropriate in this area. Refer to our response to Section CP12 – Urban Design.

Finally, we are concerned that the planned development of the area seems to rely on an agreement between a number of different landowners. Such agreement has not been achieved in the past and there is a risk that continuing failure will result in ongoing blight for the area. For this reason we believe that the Plan should be drafted to allow clear flexibility for the independent development of different parts of the Seafront and Churchill Square sites, if necessary.
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DA2 Brighton Marina and Black Rock Site

Marina
A priority for the Marina should be that it remains essentially and literally a marina, and the presentation of its position in the city plan (3.8, 3.9) ought to state this, instead of referring to the moorings and harbour as if a secondary feature. The poor public realm is attributed to the piecemeal process of developments, but the culprits are actually poor building design, over-development and inappropriate usage. The target for housing units will result in substandard development.

The most important principle in the stated strategy (page 33) is that any proposed schemes “do not breach the cliff height within the marina”. We support the local priority A10 (page 34) to conserve biodiversity and geodiversity.

Black Rock
The policy for the Black Rock Site includes a commitment to the provision of a single recreational facility (3a). But we see no overriding necessity for a large-scale dominant development here, and would prefer an emphasis on a development criterion of sympathy with the historic architecture and natural setting. We regret the past decision to reject the proposal submitted by the architects R H Partnership in December 2002 for the design, build, finance and operation of a Spa and Hotel.

We welcome the plan (in Supporting text) to replace existing SPDs on the marina, and we particularly support paragraph 3.21 regarding the natural environment of the area.
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DA6 Hove Station Area

We consider that a policy which permits high buildings of between 18m (6 storeys) up to 45m (15 storeys) in this area which is quite inappropriate here. Refer to our response to Section CP12 Urban Design in which our reservations regarding the Tall Buildings policy are discussed further.

Tall buildings do not mean higher density.

Respect for the listed (grade II) station, the surrounding late Victorian buildings and small scale shops in the Hove Station conservation area should influence the scale of new residential units. At the same time there are several single storey commercial buildings which could be replaced with more substantial buildings. The factory buildings along the railway line could set the scale for any new industrial buildings.

High buildings in Conway Street would be a disaster – it is hard to count how high the proposed buildings are, but about 20-22 storeys. In housing unit terms, it is the equivalent of 9 or 10 x PortZEDs, and even Sussex Heights has only about 100 flats.
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DA5 Eastern Road and Edward Street Area

We suggest an acknowledgement in the introduction that the area is surrounded by, and variously adjacent to, six conservation areas and a number of listed buildings.

Although a number of tall buildings have been unfortunately permitted in this area in the past, this is not a mistake which should be repeated in the future. We take the view that there should be no further tall buildings permitted in this area other than for further Hospital uses – refer to our response to Section CP12 – Urban Design.

We support the general objective (3.49) to secure a better public realm here and the strategy (A1) to improve the townscape through the adoption of design guidance. We welcome the specific proposal (A9) for green infrastructure including substantial tree planting and soft landscaping.

Edward Street
The Edward Street Quarter may well benefit from high quality employment-led redevelopment, but the precedent set by the Amex development is excessive in scale and aggressive in massing, and we hope lessons will be learned from this for the Planning Brief (2e).

Circus Street
The Circus Street Site should be developed with maximum pedestrian through-routes including some public east-west steps, views of and from its steep slope, and the preservation or reapplication of some locally historic materials and built forms. Historic architecture and listed buildings of Grand Parade should be respected and complemented by neighbouring redevelopment.

In the supporting text the development area is said to lie within a tall buildings area with two large potential development sites. This should be qualified by an undertaking that developments should be proportionate and sensitive to the wider context.
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SA1 The Seafront

Overall
The scene-setting and contextual paragraphs, and the statements of overall priority, correctly stress the “outstanding historic setting and natural landscape value” of the seafront; and the reference to ensuring maintenance is welcomed. We particularly support the second of the listed priorities under A.

We believe that the sea front is one of the city’s greatest assets. For this reason we strongly recommend that the Plan should indicate an intention not to allow general development on the south side of the seafront roadways between Black Rock and the Hove Lagoon. There may of course need to be some exceptions to this policy. For example on the King Alfred site is already developed and there are proposals for re-development. In other places small scale, low rise development may be permitted to enhance the use of the beach for recreation.

Central Seafront
We question the wisdom, in a long-term city plan, of committing the Council to finding a “solution” for the West Pier. The West Pier site is owned by the Brighton West Pier Trust as a charitable asset for the public good. The Trust has a long history of failure in its attempts to develop the site. This has resulted in local blight.

We believe that the City Plan should recognise that while the public interest may be well served by a new development on the site (such as a new pier), it may equally be served by leaving the site (or part of it, if the i360 is built) undeveloped. The Plan should leave both of these possibilities open.

We approve of the respect for tranquillity west of the Peace Statue, and would like to see the same for aspects of the area between the Palace Pier and Black Rock.

East of Palace Pier
Owing to the beauty and character of the ornamental ironwork, we would want

• avoid, in a “public art strategy” for Madeira Drive, a perpetuation of the low standard of some precedents in this area, and
• seek public consultation on the strategy and on individual items of art.

We recommend demolition of the worst of the Aquarium development and major restoration of the former listed terraces; and we recommend endeavours to fund an extension of the iconic line of lamp-standards beyond Peter Pan to Black Rock.