Supplementary Regulation 16 representation, December 2022
Brighton & Hove Council officer response
Brighton & Hove City Council (BHCC) notes the amendments that have been made to the Basic Conditions Statement (BCS) in response to the concerns raised by the Neighbourhood Plan examiner.
The amended BCS now includes an additional section setting out that the legal requirements in paragraph 8 of Schedule 4B to the Town and Country Planning Act 1990 (as amended) have been met.
In addition, it includes two tables which set out in detail each of the Neighbourhood Plan policies has had regard to the National Planning Policy Framework (NPPF) and how the policies are in general conformity with policies in the Brighton & Hove City Plan Parts 1 and 2.
Under the terms of the relevant legislation, the council is not required to reach a formal view on whether the draft Neighbourhood Plan meets the basic conditions until after it has received the Neighbourhood Plan examiner’s report. However, in general terms officers consider that the information added to the BCS seeks to address the Examiner’s concerns and that the amended document now provides more comprehensive evidence to enable him to complete the Neighbourhood Plan examination.
15 December 2022
Summary of external representations received
The following is a summary of external representations received in response to the Hove Station Neighbourhood Plan Supplementary Regulation 16 consultation on the amended Basic Conditions Statement between 3 November and 15 December 2022. Copies of all representations have been submitted to the Independent Examiner pursuant to paragraph 9 of Schedule 4B to the 1990 Act.
The table below presents a summary of representations received so may not always be verbatim. All original representation documents have been submitted to the Independent Examiner.
All representations submitted in response to the original Regulation 16 publication of the Neighbourhood Plan between 20 May and 15 July 2021 are set out in a separate document.
1. Sport England
Received 7 November 2022 by email.
Summary of representation
The response includes no comments on the amended Basic Conditions Statement or the Hove Station Neighbourhood Plan. It provides general information (including weblinks) on the role of Sport England and planning policy and guidance for the provision of sports facilities in plan-making and in response to housing and other development proposals).
2. West Sussex County Council
Received 10 November by email
Summary of representation
Do not have any comments to make on the amended Basic Conditions Statement.
3. Environment Agency
Received 25 November 2022 by email.
Summary of representation
Having reviewed the information, do not wish to make any further comments.
4. Southern Water
Received 7 December 2022 by email.
Summary of representation
Do not wish to make further comments at this stage.
5. Natural England
Received 8 December 2022 by email and letter.
Summary of representation
Do not have any specific comments on the Hove Station Neighbourhood Plan Supplementary Regulation 16.
6. Historic England
Received 12 December 2022 by email and letter.
Summary of representation
On the basis of information currently available do not wish to provide detailed comments at this stage.
(The response includes additional comments setting out requirements for heritage impact assessments to accompany future development proposals).
7. National Grid (Avison Young)
Received 13 December 2022 by email and letter.
Summary of representation
National Grid has identified that no assets are currently affected by proposed allocations within the Neighbourhood Plan area.
(The response provides additional information on the role of National Grid including weblinks for further information and advice).
8. National Highways
Received 16 December 2022 (late response) by email
Summary of representation
Have no further comment to make regarding the general content of the Basic Conditions Statement.
(The response restates representations made in the Highways England response to the Regulation 16 consultation in July 2021 regarding the need to consider the potential impacts of development within the Neighbourhood Plan area on the A27/ Devil’s Dyke Interchange.
This included a request that the Neighbourhood Plan clearly state that all planning applications for development within the Plan area should be accompanied by information regarding forecast impacts of vehicular trips on the operation of the SRN; and that the Plan set out how it will work alongside the City Plan to ensure that the individual and cumulative impacts of development on the A27 will be appropriately mitigated.
It was requested that reference to the assessment of impacts on the SRN be included within the text supporting Policy 1)