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***Please note that we will be adding in another objection focused on sustainable and social housing next week. Below is our response to the council. Remember that you can still object via email after Sunday 29th September. Email planning.applications@brighton-hove.gov.uk and quote the application number. Remember to add in your address too!***
Dear Ms Seale,
Planning Application Reference: BH2024/01720
Description: Development of a total of 101 dwellings (C3 use) of 2-4 storeys in height to include change of use of part of footgolf course and car park (F2 use) and demolition of derelict cottages and erection of new dwellings. Works to Benfield Barn to create a community hub facility including café and footgolf use (F2 use).
Erection of 4 new workshops of 1-2 storeys within footprints of Barn outbuilding ruins (E(g)/F2 use).
Community use on ground floor of new residential marker building (F2 use). Landscaping works including
allotments/orchards. Ecological works. Creation of and upgrades to pedestrian and cycle routes. Associated alterations to existing vehicular access off Hangleton Lane and provision of car and cycle parking. Associated off-site landscaping and ecological works to wider Valley including provision of parkland south of Hangleton Lane for community use.
Location: Land And Part Of Foot Golf Course And Benfield Barn At Benfield Valley Hangleton Lane Hove
BN3 8EB
The Benfield Valley Project committee and its members strongly object to the application for the development of 101 dwellings on Benfield Valley as detailed in planning application BH2024/01720. We believe that it should be rejected by Brighton & Hove Council for the following reasons:
Ecology:
Benfield Valley is one of the last remaining fragments of chalk grassland, of which there is only 4% remaining in the South Downs National Park. Mitigation for this alone would not be possible and the pressure that this would place on what remains of the site will be permanent. Chalk downlands are one of our most diverse plant communities, once a section of chalk downland is covered, it cannot be replaced, and much of the wildlife supported by chalk grasslands cannot withstand the devastation of development. Chalk download is rich in a range of species of plants and wildlife, many of which cannot thrive in any other habitat; it is also an excellent carbon store therefore it stands to reason that building on top of a habitat such as this will significantly reduce this potential. Correct management of the Benfield Valley would see its current level of biodiversity increase. Developing any area of it will only have a negative impact. We note that on the Landscape General Arrangement drawings (North Downland), there are labels which propose planting scrub for dormice on chalk grassland. It is hugely inappropriate to replace chalk grassland with scrub. The Benfield Valley Biodiversity Opportunity Area has a target of chalk grassland restoration and therefore the proposal to do this will be both harmful and negligent.
The Benfield Valley is unique in that it is a mosaic habitat consisting of chalk downland, deciduous and evergreen woodland, hedgerow and grassland. Due to this it is suitable for a wide variety of wildlife and plant life. Building on a section of this will remove a large chunk of this habitat that cannot be replaced - whatever mitigation is proposed - and the development will place pressure on the wider area e.g. waste, groundwater and the city’s aquifer, increased footfall and traffic, which will further push species such as Dormice and Common Lizards out of the area.
“...small-scale but acute disturbance events can have significant effects on plant community composition, and can have wider reaching impacts on other aspects of site management.” (https://besjournals.onlinelibrary.wiley.com/doi/full/10.1046/j.1365-2664.2003.00800.x) This study, based on the use of military vehicle disturbance on chalk grassland habitat, demonstrated that “such compaction can alter local hydrology, soil nutrient status and decomposition of litter (Voorhees et al. 1989; Alakukku & Elonen 1995), in addition to restricting root penetration and growth (Agnew & Carrow 1985; Braunack & Williams 1993). Modified site conditions caused by soil compaction, altered hydrology and the availability of propagules all affect grassland re-establishment (Shaw & Diersing 1990; Jones & Bagley 1998).”
Surveys completed by the Benfield Valley Project and entered into the Sussex Biodiversity Records indicate the existence of a number of species of mammals, reptiles, invertebrates and birds, many of which are on red or amber conservation lists. Such species include Badgers, European Hedgehogs, Dormice, Brown Hairstreak Butterflies, Buzzards, Kestrels, the Songthrush, Common Lizards, Slow Worms and the nationally rare True Fox-Sedge.
Dormice, one of the most threatened species in the UK, live in the valley - both north and south of the Hangleton Lane. Brighton & Hove is a stronghold for them and their habitats must be under the highest possible protections. The fragmentation that the development will create will be devastating to these mammals, and we do not believe that the application outlines the irreversible damage that will occur in the building phase of the development. As outlined in section 4.2 of the dormouse survey, ‘much of (‘the habitat suitable to support dormice within the allocation’) will be cleared as part of the proposed development.’ Dormice are arboreal so are highly exposed to disturbances in the ecosystem. They have relatively small dispersion abilities, which in turn prevents them from repopulating areas they have been displaced from and urbanisation and socioeconomic development make it difficult to improve habitats for Dormice.
Introducing a housing development into the middle of a nature reserve will also introduce predatory species such as cats into the area which has been isolated from such threats. The introduction of pets to the area will have a detrimental impact on the local wildlife, like dormice, reptiles and birds. The British Trust for Ornithology (BTO) estimates that cats kill around 55 million birds in the UK each year alone.
Reducing the size of the foraging and nesting areas available to mammals and reptiles, means that they will be pushed to the perimeter which will lead to increased predation. The number of predators in this significantly reduced area will increase, which will, in turn, negatively impact the prey population and therefore we will likely see a decrease in predators such as reptiles and Dormice. As discussed further in point ‘h’, this restriction to the outer edges of the site also increases the risk of such prey being predated by common predators such as domestic cats and brown rats (of which there is a later population in the South due to recreation and human dwellings), Crows, Magpies and Foxes.
Although wildlife corridors have been proposed, the fragmentation of the site will interrupt the connectivity of the valley, which is a requirement of Policy SA7 and will have irreversible consequences such as increased predation, as outlined above. Narrowing of Benfield Valley as a wildlife corridor increases the edge effect leading to the reduction of biodiversity and limiting species that are able to tolerate the new environment. This can lead to increased risk of parasitism/disease, increase risk of predation, adverse microclimate conditions and competition from invasive species. It can also lead to reduced soil moisture, increased climate stress, such as elevated temperatures, increased wind speeds and lower humidity. Growth of trees have been seen to decline faster than that of the interior wood as a result of stressors like elevated heat stress. Creating narrow wildlife corridors limits necessary movement of species, reducing biodiversity. It can also cause species to behave differently, narrow corridors become bottlenecks that predators can take advantage of as the prey species migrate between habitats.
Reducing wildlife’s ability to move freely through habitats can result in genetic stagnation. By reducing a species ability to move freely and safely through habitats, individuals can become isolated from the rest of the population, reducing genetic diversity and leaving them vulnerable to disease and increasing the chances of local extinction. Despite the promise to ‘enhance’ the existing hedgerow and what might be left of the woodland to the south of the development, this aspect has not been adequately acknowledged in any of the surveys. We do not believe it is possible to mitigate this. The lack of established vegetation as cover will result in increased vulnerability for the Hazel Dormice. The enhanced remnant hedgerow will not be enough to replace the overall loss of an important section of a mosaic habitat.
Wildlife relocation is ineffective as a long term solution and often results in harmful consequences for the wildlife involved, which have to fight for new territories, find new sources of food, water and shelter and may even spread disease or become infected when entering a new community. All of which reduces the animals chances of survival. The young may be orphaned if adults are relocated without them, or if family groups are relocated, adults may abandon or kill their young in order to survive. There is a serious lack of authoritative research on the success of translocation projects and subsequent monitoring is shown to be at best inconsistent, at worst negligent. Translocating populations can also have an inadvertent negative effect on nearby populations.
Climate and Biodiversity Crisis: In 2018, BHCC declared a climate ‘and’ a biodiversity emergency and promised to take action to become a carbon neutral city by 2030 and to strengthen local protection and enhancement of species, habitats and ecosystems services under available powers. Developing any section of the valley flies in the face of this commitment. Moreover, the 2021 Environment Act strengthened the ‘biodiversity duty’ for all. This duty ‘requires all public authorities in England to consider what they can do to conserve and enhance biodiversity’ (https://www.brighton-hove.gov.uk/climate-action/strengthened-biodiversity-duty#tab--background ) with the key goal being to "(improve) nature and (halt) the decline in our biodiversity to achieve thriving plants and wildlife". Part of this is the requirement to halt the decline in species abundance. Any development of the Benfield Valley will prevent the city from meeting this target by 2042, and certainly by 2030, due to the key species it contains and the impacts that this development will have on the site. Had this requirement been released prior to the City Plan, we believe that no section of the Benfield Valley would not have been included in any allocations.
Pressure on our already fragile aquifer: Brighton & Hove sits on a chalk block, or aquifer, which holds the groundwater that provides the city’s drinking water. This groundwater comes from rainfall that falls into the ground and is therefore very vulnerable to becoming polluted from human activity such as highways, developments and agriculture. The proposed development in Benfield Valley will inevitably increase pollutants entering into the city’s chalk aquifer. Climate change is also increasing extreme rainfall events that further exacerbates pollutants entering into the chalk aquifer. The City Council is working in collaboration with SDNP, Southern Water and the Environment Agency in prioritising protection of our chalk aquifer and increasing the use of sustainable drainage, green infrastructure and nature based solutions across the city to support this (https://www.brighton-hove.gov.uk/environment/how-we-protect-our-environment/what-sustainable-drainage#:~:text=Sustainable%20Drainage%20Systems%20(SuDS)%20are,and%20release%20it%20slowly%20(attenuation) ). The City Council also has a commitment to adapting the city to climate change which includes protecting existing green infrastructure that can help reduce the pressure of flood events ‘and’ for preventing pollution of our chalk aquifer. The proposed development will only exacerbate these impacts of climate changes upon the city as it will mean the replacement of important green infrastructure with hard, impermeable surfaces. We at the Benfield Valley Project regularly receive reports from local residents concerned about localised flooding events during times of heavy rain, particularly along Hangleton Valley Drive. Any development will only compound this further. Additionally, this will put further pressure on the sewer system, resulting in more pollutants leaking into groundwater.
Inaccurate recording of the nature of the valley and ‘shifting baseline syndrome’: Sections of the valley have been historically and repeatedly ill-managed which has caused the slow erosion of the quality of the landscape. This has included, but is not limited to, the overlooking of years of fly-tipping in woodland areas to the north and south of the Hangleton Lane. We at the Benfield Valley Project estimate that we have removed around two tonnes of rubbish from the valley, which has been ignored by the council as the freeholders, and has been permitted by them without consequences for the leaseholders. Additionally, the removal of trees, shrub and low lying vegetation to the rear of the barn and along the pathway to the east of the north site, along with the fact that the existing leaseholders permitted the depositing of tonnes of waste chalk from a nearby construction site, has caused significant damage to this area of the valley. Consequently, the ecology surveys performed by any group, be that the Benfield Valley Project or Phlorum, will always be skewed - for example, the destruction of existing badger setts as a result of the chalk piles dumped on top of them - and risks undervaluing the valley as a whole. This is a clear case of ‘shifting baseline syndrome’ and means that any mitigation proposed is only considering the nature of the valley as it is now, not how it was ten years ago, or previous to any fly-tipping, for example, which has resulted in further ecological decline and diminishing habitats. We do not have an accurate picture of the extent of the damage done to the valley throughout the years and therefore cannot say for sure what might have flourished there had it been correctly managed from the moment the lease was gifted to the then Hove Council by Sir Tim Sainsbury.
Biodiversity Net Gain (BNG): the application states that there will be a 34% increase in BNG, just 13.68% with the Dormouse ‘mitigation’ excluded. Due to reasons already stated, we believe that this is unlikely given the amount of housing that is being proposed (41 more than that which is stated on CPP2) and the long term impact that this will have on the valley as a whole. Part of the proposed BNG is planting trees outside of the proposed houses but, following objections from the refuse collection department as a result of restricted access to houses, these have been taken away to make space for refuse vehicles. Furthermore, and as previously discussed, it is not possible to mitigate the loss of chalk downland, a priority habitat. The proposed BNG credits to be purchased on other sites does further damage to the valley by distracting from the harm that has been caused and greenwashing over it by claiming to replace the loss of biodiversity by putting it somewhere else.
UNESCO Biosphere: Brighton & Hove is recognised as a UNESCO Biosphere, which is a global designation in recognition of our unique ecology and habitats. The entirety of the Benfield Valley is an important part of this designation and building on any part of it would at best belittle this designation, at worst, threaten it. https://thelivingcoast.org.uk/about
Traffic and air quality monitoring: 101 homes will produce at least a minimum of 143 vehicles - not the suggested 123 - according to the National Transport for South-East, which equates to 1.42 vehicles per household. The Transport Assessment sets out that the proposed development is likely to generate additional vehicle movements of 58 two-way trips in the morning peak (between 8am and 9am) and 48 two-way trips in the evening peak (between 5pm and 6pm). These traffic movements will be distributed across a number of junctions and routes in the vicinity. The plan does not have enough parking for the footgolf, community hub and 4 to 5 workshop businesses. A traffic survey was done when the children were on school holidays so does not show the volume of traffic in real time. Furthermore, the assumption that residents will have the option of purchasing electric vehicles or to travel via cycling are just that, an assumption. Unless the plans set aside a budget for helping residents to purchase such transport options, we do not believe that this is a realistic assumption to make.
Local infrastructure:
Parking: the developers have outlined that the housing would be a mixture of flats and family homes. Parking facilities would only be available to those in the houses, as each house would have a parking space outside. All residents of the flats would need to park ‘in surrounding roads.’ This will put pressure on an already congested residential area.
Increased flooding risk: chalk downland is a natural ‘rain garden’ and one that should be preserved to help allay the increased flooding risks that will come with a warming planet. See points 2 and 3 for further information.
Public transport links: though there are bus stops close to the proposed development, no improvements have been stated for the nearby roundabout crossing points. Each point would be required in order for residents to reach these stops, which are west of the very busy roundabout.
Ineffective tree planting: Paragraph 4.12 details orchard planting, which is not in keeping with the biodiversity of the area and will not support the wildlife that lives there. Disease-resistant elm should also be replanted for the rare white-letter hairstreak butterfly along with broad leaf native woodland trees.
The limitation of future opportunities: the application states no clear management plan to ensure ‘good stewardship’ of the remaining land, nor does it make clear what funding would be available nor for how long. The developers are assuming that this land would be cared for by local volunteers but without a clear - at the very least - ten-year plan with assurances for continued funding, none of this is a given.
For the past four years, the Benfield Valley Project has led many community engagement events at the site. These include, but are not limited to, path clearance and ecological management mornings, educational school field trips with all schools and youth groups local to the valley e.g. Portslade Aldridge Community Academy (PACA), Blatchington Mill Secondary School, Goldstone Primary, Aldrington Primary, Peter Gladwin Primary, Hill Park Primary, St Nicholas Primary, Benfield Primary, various Brownies/Guides and Beavers/Cubs groups; monthly litter picks, annual community nature days, dawn chorus walks, dog walks, ecology site visits and surveys with local university students, Duke of Edinburgh volunteering activities, John Muir Award ecological tasks and many more. All of these would need to be immediately halted upon approval of the application. Schools and groups commitment to these visits will be impacted or their focus may get redirected to other activities so the valuable relationships and progress established over recent years with schools and community groups will be damaged. Engagement with nature is an important part of the council’s priorities to connect people with nature through their commitment the UNESCO Biosphere designation and the nationally recognised Our City, Our World schools climate programme; but also in support of the city’s priorities around public health, particularly in supporting mental health & well-being and in the role this engagement & interaction with nature has in reducing costs on the NHS and health services. So with this in mind, this would ultimately disadvantage local children and groups who have had their education and wellbeing enriched by the site and these events. Furthermore, any development of the valley would severely limit such activities for a number of years and would forever restrict any site-specific educational work on or around the proposed area. As discussed previously, there are no guarantees that specific aspects of the ecology would ever fully recover from this development especially given that, once work is complete, there will be increased pressure on the site as a whole, which will then need to support the residents of 101 dwellings.
BVP are actively exploring various options for gaining greater ownership powers of BV such as buying the lease and fundraising options for enabling this - the five-year plan that BVP has created would see all ecological enhancements, including the renovation of the barn and its garden, suggested by the developers fulfilled through public and lottery funding grants - including crowdfunding - and the creation of a Community Interest Company (CIC). This CIC would work with local residents, including the Footgolf business, but also with relevant council departments, local community and environmental groups & experts, The Living Coast Biosphere partnership, and others in increasing and enhancing the ecological and community value of the site and make it a centre of excellence for environmental and nature education and wellbeing - all of which would support city priorities around public health and nature education. Any development of the valley would not support such priorities. Any housing priorities could be fulfilled, and likely exceeded, by placing the designated 100 dwellings on true brownfield sites such as the new vacant local school sites. This would obviously also have significantly less ecological and environmental impact than developing on the Benfield Valley site.
The Benfield Valley is an impressive example of what can happen when the local community takes over the management of a site of ecological and community value. Maintaining the whole valley as such would lead the way nationally in creating an exciting new precedent of community-led nature reserves and what these can achieve. Building on any section of this would severely limit potential as, not only would this be delayed by years, it would likely mean that opportunities for further ecological growth would be suppressed by the new development.
Whatever vision the developers have for the housing estate and the long-term management of the valley pales in significance to what BVP and other community groups could deliver not just to the site but to the city as a whole if given stewardship of the land. Sir Tim Sainsbury had this vision when he originally gifted the lease to the council for community use and preventing any development of the valley would see this vision fulfilled.
We will be submitting a detailed response with regard to the development of the barn and its surrounding garden in due course.
Yours sincerely,
Helen Forester
On behalf of the Committee and Members of the Benfield Valley Project
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