Principal Planning Officer
Shoreham Harbour Regeneration Partnership
Brighton Society comments – Public Consultation on Revised Draft JAAP for Shoreham Harbour
Thank you for meeting us last Monday to discuss aspects of the Draft JAAP, and for giving us a a slightly extended deadline in order for us to complete our comments on the Revised Draft following our meeting.
In general terms we strongly support the intentions of the Plan to create a development framework for an important stretch of the south coast between Brighton and Shoreham. In many ways this is currently an unattractive section of coastline, but with imaginative and sympathetic development of its beachfront and harbour areas could be an extremely attractive area in which to live and work. We consider that it could also make a major contribution to the improvement of the harbour and seafront – not only in terms of its development potential – but also to improve the public access and amenities to its harbour and beachfront areas. This would benefit not only those who will live and work there but also the many people who live near and visit this part of the south coast.
1. General comment – Vision Statement
Section 2 sets out the vision for Shoreham Harbour. Objective 8 sets out the vision for Recreation and Leisure and Objective 9 is to promote high design quality and improve townscape.
We would like to see these important objectives carried through into the sections dealing with the seven character areas. When it comes to dealing with these areas these objective headings have not been mentioned. Specific suggestions for these are set out in the following paragraphs:
2. Aldrington Basin
2.1 Relationship between Hove Lagoon and Western end of Aldrington Basin
Paras 4.2.12 – 4.2.16 propose ways in which the connections with Hove Lagoon and Hove seafront could be improved, and this is indicated in very general terms on Map 7.
We agree with the general intentions of these paragraphs but consider that they need to include more “vision” if any real improvements to the relationship between Hove Lagoon and the eastern end of the harbour are to be achieved.
In our previous responses in 2013 and 2014 to the Shoreham Harbour Development Brief and Draft JAAP, we suggested that the small strip of land between Hove Lagoon and Aldrington Basin could be opened up to form a public open space with views both towards Hove Lagoon to the east and the harbour to the west, and act as a transitional area between the recreational use of Hove Lagoon and and the more commercial uses associated with Aldrington Basin.
We are aware that in order to achieve this there are two main obstacles:
(i) Basin Road South which intersects the two areas;
(ii) The land between the two areas is privately owned and not owned by the Harbour
The first of these problems could well be solved in ways set out in para 4.2.15 – “this connection could be achieved through the development of pathways and crossings to achieve direct, safe access.” We agree that a safe crossing point on Basin Road South could be achieved by a combination of adequate signage and sensitive road landscaping design.
The second problem is more difficult and would have to be resolved in the longer term, but since this Plan is intended to set out the desired form of Harbour development up to 2031, we think it should be included in the Plan at this stage.
Fig 1.View looking west into Aldrington Basin Fig.2 Existing view from Hove Lagoon
We understand that the area between the Basin and Hove Lagoon will provide “Employment priority redevelopment opportunities”, and para 4.2.28 states, “Opportunities to develop the under-used sites to the north of Newhaven & Brighton Fish Sales for modern fit-for-purpose employment space will be encouraged” . We do not disagree with this – the question is, “what form of employment opportunities would be the most suitable?” Part of the area concerned (which is only the relatively small area shown Map 7), is currently used as a builder’s and scaffolder’s yard, and access for the public between Basin Road South and the harbour edge is not currently possible.
We think there is an opportunity here to define a future public open space overlooking the harbour and all its visual interest to the west and Hove Lagoon to the east. It could be defined on its northern and southern sides by commercial uses such as cafes and small scale retail uses. Small Stuio type offices, and perhaps some residential uses too could be accommodated on the upper levels to bring life and trade to the area. The existing Fish Sales building immediately to the south could also form an integral part of the scheme.
The important element which we strongly feel should be specifically mentioned in the Plan is for ”an open space” as the essential component of the policy set out in para 4.2.28.
The new public space would need to be attractively landscaped and paved, with seats overlooking the harbour and Hove Lagoon, as well as outdoor seating areas associated with the café/restaurant uses.
The whole area could then be strongly linked via a safe and prominent crossing point on Basin Road South with the recreational uses associated with Hove Lagoon.
Some soft landscaping improvements to remove part of the existing hedge on the east side of Basin Road together with improvements to the adjacent pathways and pedestrian and cycle routes would also be required on the Hove Lagoon side.
This public open space should be defined as such on Map 7.
In order to facilitate the development of this area, the existing commercial uses could be encouraged to re-locate, by including measures in the Plan to provide alternative sites elsewhere in Harbour area for the organisations concerned.
We believe that the potential attractions of this proposal – were it to be clearly defined in the Harbour Development Plan – would encourage private enterprise to develop the area along the lines described. There are countless examples throughout the world of former derelict or run down port waterside areas being transformed into attractive public spaces incorporating a wide range of popular and sustainable public facilities.
This represents a real opportunity to create a strong physical and visual link between the western end of the Brighton and Hove seafront with the eastern part of Shoreham Harbour.
2.2 Northern side of Aldrington Basin and the harbour
The JAAP lists the main objectives for land use around Aldrington Basin but they are very specific and do not consider the long term potential for developing the northern side for residential and recreational use. We note that the Port Authority has concerns with residential quayside developments but the Development Plan should be considering the long term potential for this valuable stretch of the harbour.
It is disappointing that the north side of the Aldrington Basin is to remain as commercial/industrial use but we would still encourage you to consider the possibility that some residential uses could be included in this area on the upper levels of suitable commercial floor space in this specific area.
It seems to us that as much potential residential uses should be provided for in
the JAAP, given the limited land available for housing south of the South Downs National Park and more imaginative thinking could achieve this in some situations. CPRE has advocated that residential uses could be created on upper floors above car parks, retail parks and brownfield commercial sites. Why could this not be provided above single-storey commercial premises along this stretch of prime harbourfront with prime views overlooking the harbour?
here would appear to be opportunities to develop this sheltered south facing side of the Aldrington Basin. Residential properties with adjacent marinas in this situation would have high values which could subsidise much needed social housing. The Lady Bee and Nicholson Marinas are already in place which suggests that residential developments with quayside access could successfully be located along the northern side of the basin without any interference to the work of the Port Authority.
Further to the west, the western end beyond the Texaco depot is undeveloped and the natural line of the cliff face is clearly apparent. The area has potential for recreational use although access from the A259 will need to be improved. This stretch of the A259 coast road has spectacular views across the harbour which would need to be preserved in any future development. (Fig 3)
Currently most of the heavy industry is concentrated on the southern side of the basin where there is good road access. The northern side has poor access with only narrow roads and restricted parking. There are three major users, the Texaco fuel depot, Travis Perkins Builders merchants and the Cemex ready mixed concrete depot. Travis Perkins and Cemex are concentrated in one area at Britannia Wharf and the Texaco depot is located at an isolated location at the far end of the developed northern side. The remaining areas along the northern side have industrial units of varying size and condition interspersed by small marinas. Many of the industrial units are located on the quayside but do not use any form of shipping or any harbour facilities. Some of these industrial areas have car parks along the quay with access to the water cut off by wire fencing. See Figs 4 and 5 below.
Even the small marinas cannot be accessed as they again have high security fencing. (Fig 6). This side of the harbour would be ideal for residential and public access along the harbour side but currently most of the quayside is lined by barbed wire fencing.
This area could provide high value residential developments and could provide spectacular quayside public areas yet this part of the harbour is occupied by many users that have no relationship with the harbour.
We consider that this area could be improved by providing some access along the waterfront for pedestrians and perhaps cycles. Even a narrow path along the edge of the north side of the harbour would bring a significant improvement in the environment. A continuation of the cycle and pedestrian access routes (which are proposed in areas further west), into this area would bring significant improvements to its appearance as well as providing a safe and pleasant way for people to see the harbour. This idea appears to be supported by Map 7 where a potential viewpoint is shown on the north side of the basin.
3. Portslade and Southwick Beaches (Section 4.4)
We strongly support the general policies to improve the pedestrian and cycleways of Monarch’s Way and the National Cycle Network as set out in this section. However we feel that as currently expressed, it merely pays lip service to improving these nationally important pedestrian and cycle routes, and the adjacent beachfront areas.
3.1 Basin Road South and the beachfront The currently appallingly unfriendly and unsightly pedestrian and cycle route behind the Esplanade housing to the western end of Basin Road South, could be much improved to allow both better views of the harbour to the north and the beach to the south, and the recreational value of whole of the seafront between Hove Lagoon andCarat’s café at the western end of Basin Road South could be vastly improved.
In combination with much needed improvements to the interface between Basin Road south and the beachfront, improvements to the whole of Basin Road South could effectively extend the public realm of Brighton and Hove seafront much further to the west, which, by incorporating links across the harbour like the existing pedestrian and cycle bridge, would in turn benefit the occupants of the new housing developments proposed along the northern edge of the harbour by providing better access to the beachfront.
Para 4.4.6 of the Plan admits “Despite the industrial feel of this route, it remains popular and the beaches are frequented by local families, swimmers, surfers and artists, particularly during the summer months.”
In fact the whole area is visually disastrous, being unkempt, scruffy and unattractive, and access to most of the beach and sea along this stretch of Basin Road South is cut off by an array of rusting metal and concrete walls and wire mesh fencing.
The roadway and pavements are unattractive and unsafe for both pedestrians and cyclists. The potentially attractive views and access to the beachfront from Basin Road South are concealed behind a high concrete wall or separated from it by high and unsightly metal fencing for much of the length of the roadway.
The whole area is scruffy and unkempt, with no attempt at any landscaping or softening of the industrial character of the area. It is also very unfriendly towards pedestrians and cyclists.
The Plan states “Linkages to existing open space assets such as Hove Lagoon, West Hove and Portslade / Southwick Beaches will also be encouraged”.
We cannot find any evidence elsewhere in the proposals which shows how this will be achieved and accordingly conclude that it is not a serious policy aim. It should be.
How are the vaguely expressed policies set out in the Plan going to be realised? How much will be carried out by the local authorities? How much commitment will there be from the Port Authority to improving the whole area? How much will have to be done by private enterprise? How much done by Natural England?
And if there are convincing answers to these questions, in what form will the required improvements be carried out?
We were dismayed when we discussed this with you, to discover that the Port Authority currently owns the beach and apparently had no intention of improving access to it (access to which is completely cut off by the scruffy walls and fences along the this stretch of Basin Road South). Nor were you to able to confirm to us how far on to the beach towards the sea the Port Authority’s ownership extends.
The Harbour Development Plan will vastly increase the development potential of the whole area and create thousands of new homes and employment opportunities, leading to a much increased demand for the recreational opportunities offered by the coastal beachfront and harbour areas.
There should be a stated policy contained within the Development Plan to ensure that a proportion of the profits from the development of the Harbour should be used to carry out the much needed improvements to the public domain and facilities in this area.
4. Improvement of the Lock crossing
The current environment for public access across and around the locks is appalling with pathways hemmed in and surrounded by high ugly wire fencing. Access to the impressive scale and engineering qualities of the locks should be encouraged so we would strongly support improvements to the environment of this critical part of the harbour.
The harbour has many important historic assets besides those mentioned in the Plan, and we feel that the JAAP should include a list of all the important buildings.
The northern edge of the basin includes most of the historic assets of the harbour. The old coast road between Brighton and Shoreham runs beneath the natural
cliff face. The line of the road remains intact for most of its length, made up of various access roads and track. Important historical assets that should be noted in the JAAP are:
Substantial Victorian Warehouses on the Travis Perkins site. Used for storage of substantial quantities of Imported ice during the 19th Century.(Fig 12)
Early 19th Century coastguard cottages and a group of Victorian buildings above Nicholson Wharf.
The Port Authority buildings and the numerous industrial buildings at the locks.
Views across the harbour
Preservation of the open view across the harbour Southwick/Portslade.
The cliff top view across the harbour from the Portslade/Southwick border to the Lady Bee Marina is an asset that will require tight planning controls. This stretch of the A259 corridor is on relatively high ground and it will be essential to ensure that the open view across the harbour are kept intact. The aim to improve the amenity value of adjacent areas along the north side of the harbour would complement this aim.
Other potential viewpoints are shown on the Maps dealing with individual areas of the harbour, but these appear to be indicative only, are not generally discussed in the text, nor appear to have any apparent constraints on any development proposals in the area which might affect them. Definition and protection of important views both down the length of the harbour and across it at key points, need to be considerably strengthened.
7. Definition of Port associated uses and general industrial/employment uses
There does not appear to be any differentiation in the JAAP between uses which have a strong relationship with the Harbour and the Port – in terms of needing to be located where they are – and land occupied by general commercial and industrial uses which could operate anywhere within the West and East Sussex and Brighton and Hove areas.
In order to be able to make intelligent decisions about priorities for land uses within the harbour area it would seem to us that it would be essential to have this information available.
For example the strip of land between Hove Lagoon and Aldrington Basin discussed in para 2.1 above is occupied by a scaffolders yard – there would appear to be no reason for this to be situated where it is if an alternative location could be found.
There are many other firms situated on harbour land with no apparent direct links to Port activities where this situation also applies.
8. Height, form and scale of new developments
We generally support the proposals included in the JAAP, particularly in relation to building heights and townscape considerations. We consider it very important that the built up areas of the seafront have a consistent height and are not compromised by tall blocks as have been areas of the seafront near the central part of Brighton seafront.
We are opposed to policies included in BHCC’s Policy SPG 15 (Tall Buildings) that propose areas where tall buildings are deemed to be acceptable on the seafront. The lack of any Urban Design studies to clarify constraints on tall buildings in other areas of Brighton and Hove has led to problems both for developers who are left to work out their own interpretations of what is acceptable, and for campaigners against tall buildings in inappropriate locations.
We think reference to SPG15 in para 11 on p.93 should be deleted – in its current form SPG15 is a discredited policy and it should not form part of the Shoreham Harbour JAAP.
We do however support the Development form and typology studies set out in para 4.7.69 of the Draft JAAP, and would like to suggest that similar studies should be included for other potential housing sites within the harbour area.
These could be extended to include studies on the proposals for the housing densities envisaged for particular areas, heights of buildings as well as indicative housing mix proposals, all of which would give essential guidance for potential developers.
There is no mention of the potential role the railway line between Shoreham and Southwick stations where it runs close to the northern boundary of the Harbour area could play in promoting development near these stations. Transport hubs can generate higher residential densities and concentrations of employment opportunities because of their accessibility.
In conclusion we think the Draft JAAP will be a very useful planning tool and sets out clear and much required planning guidance which should assist in creating major improvements to the Shoreham Harbour area. The port has enormous potential to make a vital contribution to an important and up to now neglected stretch of coastline between Brighton and Shoreham, in terms of opportunities for commercial, residential and recreational uses.
The comments we have made in this letter are intended to strengthen the planning guidance in areas where we think it needs further work and we hope you will consider the points we have made in that light.
Jeremy Mustoe MA (Cantab), Dip Arch
Chairman, Brighton Society
Malcom Dawes BSc, MSc, CEng, MICE, MIStructE
Trustees, Brighton Society