KTS’ response to the Draft City Plan

The Draft City plan went out for consultation over the Summer months, with July 20th the final day for submissions from interest parties to comment on it.

Rather than duplicate the lengthy document here, please click on the link below:


KTS responded with the following letter to BHCC, which outlines our major comments going forward with respect to the Heritage and other issues affecting the Estate, Black Rock, the Gasworks and the Marina.

TO: Mr R Frazer and Mr J Bennet

Local development Framework team

Planning Strategy and Projects

Brighton & Hove City Council

Hove BN3  3BQ

ldf@brighton-hove.gov.uk                                                                  19th July 2012

Dear Sirs

Brighton & Hove Draft City Plan Part One

We are writing principally in relation to section DA2 of the Brighton & Hove Draft City Plan Part One.  However before turning to this section in detail we would like to comment on section SA1, CP12 and CP 15  both of which affect the Kemp Town Estate, the conservation of which is our charge..

SA1 The Seafront


3.99     We feel this section is open to misinterpretation and that while improvement and enhancement within this area are desirable and well protected by the requirement  ‘ to complement the outstanding historic setting and natural landscape value of the seafront’,  there should be a general prohibition of development south of the  Coast Road.  We understand that this was recommended  as a firm policy by the Conservation Advisory Group of the City.

We would question whether there are any development opportunities, save in areas previously identified, and within the “East of palace Pier to the Marina” section should certainly be limited to the DA2 area and should be required to do nothing to prejudice surrounding conservation areas, their setting, or diminish the use and enjoyment of the beach.

CP12 Urban Design

In points 2 and 4  there should be a clear statement ‘where these adjoin any potential development’ after each point

4.134  add to the end of the reference to Brighton Marina as a node ‘and further limited by the restriction on building above the cliff height.

 CP15 Heritage

1          Historic areas are affected not only by development within their designated areas (usually a Conservation Area) but also by development within their setting.  We would suggest amending this section to read at the end ‘for new development in and within the setting of historic areas’.

4.156   the Kemp Town Estate is one of only four Grade I listed Estates recognised by English Heritage in England and the only Grade 1 listed Estate by the Sea.  As such it is an almost unique feature in Brighton and should be mentioned as such in this paragraph, after the Royal Pavilion.  We are disappointed that the Sussex Extensive Urban Survey failed to mention this.  We also suggest the words ‘up to date’ with reference to this Survey be removed as it is already 5 years old.

DA2 Brighton Marina, Gas Works and Black Rock Area

Strategy Statement

In view of  its origin and the reason for the Marina’s existence as the only safe harbour of any size between Dover and the Solent there should be priority given to the provision of a safe harbour for yachting and all other uses should be subject to this.

Given the fluctuation in the cliff height throughout the Marina we would suggest  adding to the end of  the second bullet point ‘in order to protect the historic environment and the setting of the Grade 1 listed Kemp Town Estate’

In the fifth bullet point we would suggest reference should be made to the SSSI status of the cliffs and preserving public access to them

We do feel the description of the Marina as a District Centre is misleading and should be abandoned in favour of the words ‘a sustainable mixed use district of the City’ as used elsewhere in this section and throughout the document.  Due to its geography it cannot fulfil the functions of a Centre, as it protrudes out into the sea, with cliffs on the one side where it is attached to the land.  As a result of this, access is limited to one road and pedestrian and cycle users and of course boats.  It cannot expand its area as it is limited by the sea on three sides and the cliffs on the other.  To call it a District Centre implies an expanding function and influence, which if it were to be achieved could only be in an upwards direction and so conflict with the strategic objects in Bullet points 2 and 5

A Local priorities

4          It is important CP15 be included here.  Most of the Marina’s surrounding areas are either historically important or the Southdown  National Park which should perhaps also be specifically mentioned

6          Marine uses, such as boating, surfing, fishing leisure and recreation should be given priority rather than mere emphasis in the provision of retail activity and services dedicated to this use as well as support to the increased population.

B. This section should be made specifically subject to the Strategy set out at the beginning of Section DA2 and include a requirement to ensure that density does not exceed the capacity of the surrounding area to withstand it

Whilst the target for completion of the additional development in the DA2 site  is some 17 years distant the Royal Sussex County Hospital , which has planning permission and is scheduled to commence in late 2013 and continue for 10 years, is another very substantial development in the area.  We are concerned that the effect of such an immense amount of construction in such a small area over such a long period cannot but have a detrimental effect on the Kingscliffe and Kemp Town Conservation areas.  We also doubt that the only A road, the coast road, will be able to carry all construction traffic thus forcing heavy vehicles onto unsuitable roads and forcing heavy lorries, vans and other traffic into the mainly narrow Conservation Area side streets.


1  Brighton Marina Inner harbour

a)         Design – the sentence should end ‘and reflect the unique location and surroundings of the Marina, ‘ so as to ensure it  is clear that the design as well as the durable materials must reflect the unique location. Ending the sentence with  ‘to reflect’ could be interpreted as relating only to the materials.


2. Gas Works site

If it is desirable to increase the quality and quantity of retail  in the DA2  area we wonder why the Gas works site only has ancillary retail use projected.  If, as is required in (d) links between the Gas works, the Marina, and Black Rock are improved this seems an ideal location for a retail outlet that would attract shoppers to the DA2 area.  We would not have thought retail use is subject to the problems with the site which limit residential development here.

3. Black Rock Site

The use of this area needs to be expanded beyond exclusively leisure and recreation.

a)      To include other tourism uses, such as a hotel, destination restaurant or bar and cafe uses which it is recognised would create jobs underpinning general leisure use at this end of the Seafront, drawing  visitors to the area and linking the Marina area with the beach and seafront up to the Pier.

b)      This section should make it clear that there is an absolute prohibition on development protruding in any way above Cliff on this site.  This should ideally be a separate section c) with existing c) becoming d) and so on.

The concluding un-numbered paragraph of this section should be removed

Supporting Text

We are unclear on the merit of a section so labelled.  Would it be clearer to label these points ‘Further Factors affecting the area comprised in DA2′?

3.13     This section needs to make it clear that the restriction on building above the cliff height overrides that the inclusion of the Marina in CP12 as an area suitable for tall buildings

3.15     We cannot see why, given the physical limitations of the Marina as a District Centre, if it has to be such, the Centre cannot include all 3 sites.  This at least would remove the nucleus from the sea and provide a possibility of more of the usual features such as banks, post offices and doctors’ surgery.

3.16     The concept of a transport interchange in the Marina is flawed as all buses servicing the Marina terminate there and there is no other form of transport such as tram of railway to interchange with.  There is also no area within the Marina suitable for a collection of large stationary vehicles that is not also used for providing access either to residential areas or commercial deliveries.

3.17     It is recognised that development of the Black Rock site may envisage other uses to recreation and leisure, so the words “The Black Rock site……….in this part of the City” should be deleted.

In conclusion, while welcoming the vision and wide scope of the City Plan, the Kemp Town Society is concerned that in various places the aspirations for dense development and high buildings conflict with the aspirations for the preservation of the City’s s many nationally important historic buildings and set pieces.  Developers will always seize on the wording of policies that grant maximum height and density and therefore  profit.  They will ignore sections such as CP15 where the City has limited the scope for such developments.  There must be absolute clarity in the City Plan that where there is a conflict between policies encouraging development of a density and/or height which conflict with the conservation policies and/or exceed the capacity of the surrounding area, then the conservation and capacity policies must prevail. We cannot see any such statement anywhere in the City Plan.

Yours Faithfully

Jill Sewell

Hon.Sec Kemp Town Society




Local Interest, Outside the Estate, Planning Issues

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