The Localism Act 2011 and the National Planning Policy Framework (NPPF July 2018, paragraphs 24-27) place a duty on local planning authorities and other prescribed bodies to cooperate with each other to address strategic planning issues relevant to their areas. The city council has been engaging in ongoing collaborative working with neighbouring planning authorities and other bodies in order to address relevant strategic planning issues and comply with the Duty. The key areas of engagement are summarised below.
In preparing City Plan Part One, the city council engaged with a comprehensive list of stakeholders and adjoining authorities, details of which are set out in the LDF Duty to Cooperate Compliance Statement June 2013 and the LDF Duty to Cooperate Update Paper October 2014. Since adoption of City Plan Part One, the council has continued to work with neighbouring local authorities and other relevant organisations to address identified strategic cross-boundary issues.
Most cross-boundary issues affecting the city were dealt with in the adopted City Plan Part 1. An outstanding strategic issue addressed during the preparation of the City Plan Part 2 was the provision of permanent pitches for the Gypsy and Traveller accommodation and the outcomes of this process are set out in the Duty to Cooperate Statement November 2019 which was published in November 2019 with the Proposed Submission City Plan Part 2.
The council is a member of the West Sussex & Greater Brighton (WS&GB) Strategic Planning Board (SPB) together with Adur District, Arun District, Mid Sussex District, Horsham District, Chichester District, Lewes District, Worthing Borough, Crawley Borough Councils and East Sussex and West Sussex County Councils and the South Downs National Park. The constituent authorities have prepared a Local Strategic Statement (LSS) which sets out long term Strategic Objectives and Spatial Priorities for delivering these in the short to medium term. In 2013 an initial LSS for Coastal West Sussex & Greater Brighton was agreed by the Board and endorsed by each of the constituent authorities. In 2015 the LSS was updated through a focused ‘refresh’ taking account of the expansion of the Board to include Mid Sussex and Horsham districts and the implementation of the Greater Brighton City Deal. LSS2 includes updated Strategic Objectives covering the period 2015 to 2031 and Spatial Priorities for the period 2015-2025.
The WS&GB authorities recognise that a full review is required to address the longer term issues facing the area, in particular the continuing gap between housing needs and housing delivery, and the continuing challenges around supporting sustainable economic growth and infrastructure investment. The SPB is therefore working towards preparation of a new Local Strategic Statement (to be known as LSS3) which will robustly and creatively explore options for meeting the area’s unmet needs for housing, employment and infrastructure.
The new LSS will cover Brighton & Hove, together with Lewes District and the whole of West Sussex including Crawley.
To inform the future preparation of LSS3 a study was commissioned in 2017 to provide a detailed review of the Housing Market Areas (HMAs) and Functional Economic Market Areas (FEMAs) operating within and across the WS&GB authorities. Proposals to commence the preparation of LSS3 were further discussed by the West Sussex and Greater Brighton Strategic Planning Board in February 2019 and were further endorsed at the 12th September 2019 Board meeting where it was agreed that a work programme to commission the evidence base for the LSS3 and work to produce a Statement of Common Ground would commence.
In late 2020 early 2021, a draft LSS3 Studies Programme was produced along with an indicative 2021-23 LSS3 Timetable and Work Programme:
- Statement of Common Ground - March 2021
- LSS3 Studies Procured and Supplied - 2021/2022
- LSS3 Strategy, Consultation and Final Strategy Agreed - March 2023
The LSS3 Indicative Timeline dovetails, so far as possible, into the next round of Local Plan Reviews of all ten WS&GB Local Planning Authorities (LPAs). As Local Plan Reviews become adopted, LSS3 will be producing a collaborative sub regional planning framework for further reviews, taking into account 2050 Net Zero Carbon and the results of the 2020 Planning White Paper.
The city council, Adur & Worthing Councils, West Sussex County Council, the Environment Agency and Shoreham Port Authority, have adopted a Joint Area Action Plan for the Shoreham Harbour area. The councils submitted the plan to the Secretary of State for Housing, Communities and Local Government for independent examination on 31st May 2018; examination hearing sessions took place in September 2018. A consultation on the Proposed Main Modifications took place between 18th January 2019 and 1st March 2019. Following the receipt of the Inspector’s report confirming that the plan is sound and able to be adopted, subject to the incorporation of the modifications, the councils jointly adopted the plan in October 2019.
Waste & Minerals
The city council is a Waste and Minerals Planning Authority. The Waste & Minerals Local Plan (WMLP), comprising the Waste & Minerals Plan (WMP; adopted 2013) and Waste and Minerals Sites Plan (WMSP; adopted 2017) was produced jointly with East Sussex County Council and the South Downs National Park Authority.
Compliance with the Duty to Cooperate was considered by the appointed Inspectors during the public examinations of the WMP and WMSP. Cooperation occurred with West Sussex County Council (WSCC) regarding mineral wharves at Shoreham Harbour during the preparation of the WMP and joint working was ongoing while WSCC’s own waste and minerals plans were prepared. This issue links to work on the Shoreham Harbour JAAP, as described in the previous paragraph, as the need to safeguard mineral wharves at the Harbour is a key strategic issue. Cross-boundary working is ongoing with a number of authorities to address strategic waste and minerals issues, notably the need to ensure a steady supply of soft sand to support the development industry. Statements of Common Ground have been agreed with Surrey County Council with regard to waste management and Kent County Council regarding soft sand supply. The city council is a member of the South East Waste Planning Advisory Group which address cross-boundary waste planning issues in the south-east.
A review of the WMLP is now underway, primarily intended to address concerns over the future supply of minerals that were raised by the WMSP Inspector. A consultation on the scope of the review took place in autumn 2017 and a consultation on Draft Revised Policies took place in summer 2020. A consultation on Proposed Submission versions of the revised policies is expected in Spring 2021.