Coalition Archives: Whitehawk Hill Development Briefing by Steve Parry


Hyde/BHCC property development: Whitehawk

Whitehawk Hill (

On Brighton’s Whitehawk Hill lie traces of an ancient ritual monument known as Whitehawk Camp. 
Older than Stonehenge, 5,500 years ago this Neolithic enclosure was a spectacular landmark: four white chalk walls encircling the summit of the hill, a place for community gatherings, feasting and burial. Today the site is dominated by a mobile phone mast and cut by road and racecourse.

Excavations in the early 20th century revealed pottery, flint tools, animal bones, chalk carvings and four poignant human burials: a 40 year old man, a young boy and two women in their twenties – one buried with her unborn baby, a carved chalk pendant and fossilised sea urchins laid by her side. 
Most of the hill remains unexcavated.

WHITE HAWK HILL was filmed over one year from autumn to summer in collaboration with archaeologist Matt Pope, who grew up next to the hill and ‘abandofbrothers’, a rites of passage based mentoring organisation for young men, founded in Whitehawk.

In the Neolithic period the average life expectancy was around thirty. The young men and women who gathered here would have been skilled and respected members of their community. A twenty-year-old today can feel alienated and marginalised; excluded rather than included. With ‘abandofbrothers’ we explored this contrast through on-site experiential events and investigation of the Neolithic finds collection at Brighton Museum & Art Gallery.

WHITE HAWK HILL is an evocation of a forgotten hinterland and its people, connecting archaeology, myth and contemporary life to reveal a landscape shared by two communities over 5,000 years apart.

Artists: Caitlin Easterby, Simon Pascoe (Red Earth), Anna Lucas

Participants: Andrew and Louis Drake, Richard Hawley, Lucas Pyke, Rex Brangwyn and the men and families from ‘abandofbrothers’
Dr Matt Pope (UCL), Andy Maxted (Curator BM&AG), Paola Ponce (ASE) Rosie Harding, Tanushka Marah, Orlando Tyr
The people of Whitehawk Hill
Live music Dirk Campbell
Second camera Simon Hipkins
Additional thanks to Donna Close and Paul Gorringe (Whitehawk Hill Park Ranger)

ANNA LUCAS is a film and video artist whose work develops from observations of social networks and individuals in response to specific geographic and architectural locations.

‘abandofbrothers’ is a charity established by men committed to positive social change. Central to their work are experiences that have come to be termed ‘rites of passage.’

NB: file:///C:/Users/Owner/Documents/UP%20TO%20DATE/H%20+%20G/WORKING%20DOCUMENTS/BHHC/1822%20Indenture%20Brighton%20Racecourse.pdf

  • Copies of the deeds relating to the division of the tenantry lands in the parish of Brighthelmston in the year 1822, together with extracts from the minutes of the proceedings of, and copies of reports to, the late Town Commissioners and the Town Council, with reference to the portions of the same lands dedicated to public uses. Printed by order of the Town Council, 1878


25.9.17: Special Housing Committee

  • With regard to the Whitehawk Road site access, the project was at very early stage and detailed work had not been carried out yet. Officers were looking at the best way to gain road access, while engaging with the community throughout the process. The details of site access would eventually be taken to the Living Wage Joint Venture Board.

It was confirmed that with regard to site costs, in valuing the sites, road access was one of the main elements which would help to depress the value of the site. Although the cost of site acquisition had been increased in the business plan, that would include site abnormal costs.  

12.10.17: Policy & Resources

  • Living Wage Joint Venture Business Plan 

14.11.18: Housing Committee

  •  Question: Hyde/BHCC Contract

“As a result of the Budget announcement regarding the HRA cap and the response by Councillor Meadows to Councillor Mears at the last meeting of full Council could the Chairperson confirm the withdrawal of the Council from this contract?”

Chair’s response

“Thank you for your question.  Working in partnership with Hyde the joint venture will deliver 1,000 new lower cost homes for rent and sale. The first three sites have been identified to deliver up to 570 new homes. These are Coldean Urban Fringe, the former Belgrave Centre, Portslade and Whitehawk Urban Fringe. Public consultation has taken place on all three sites with planning applications due by the end of this year.

Our plans for maximising new housing supply via the Housing Revenue Account are outlined in our Housing Supply report to be considered at today’s meeting.”

6.12.18: BHCC Policy & Resources Committee

  • “Disposal of Land north west of Whitehawk, Brighton by way of long leasehold”
  • Deputation:

JOINT DEPUTATION from ‘Save Whitehawk Hill Local Nature Reserve’ 

& ‘Brighton & Hove Housing Coalition’


“Joint Venture Project” for a high rise estate in the middle of the Whitehawk Hill Local Nature Reserve and the Race Ground recreational common

Whitehawk Hill is Brighton’s senior and most important public Downland site. It is a statutory Local Nature Reserve, and was voted for inclusion in the new South Downs National Park by full council in 2002. Its status as a common, now known as ‘The Race Ground’, is perhaps a thousand years old. It is mostly statutory Access Land. It has the earliest statutory Scheduled Ancient Monument in Sussex protecting one of the ten best Neolithic Causewayed Camps in Britain. Its wildlife includes many rare or scarce animals and plants and rare ecosystems such as species-rich chalk grassland and furze field.

The Joint Venture proposal for a new high-rise estate of 217 properties in five blocks with 110 parking spaces on the Hill will smash our Local Nature Reserve and this treasured landscape in two. It comes in addition to 103 recent new homes in the Valley and a planned 38 more on Swanborough Drive playground, and will hugely cram the already crowded north end of the Whitehawk Valley.

The site is a sacrosanct public space, the local infrastructure and amenities are already at breaking point, and the needs of local residents have not been properly considered.

The Council is not even attempting to use the resources that are available to build houses for Social Rent.

We call upon Brighton and Hove City Council to put an end to this development and find other sites for much needed social housing, preferably council housing at social rents.

The signatories to this deputation represent communities from throughout the City and in particular Whitehawk and East Brighton. We include community groups working for a better quality of life for the people of our City, for the conservation of the natural environment, for benefit to the health and wellbeing of all and for housing that is truly affordable and secure. 

Eileen McNamara Amanda Bishop, Anne Glow, Maria Garrett – Gotch 

Dave Bangs, Sharon Scaife, Charmaine Evans 

Richard Bickers, Kim Turner, Judith Watson, Nichole Brennan, Steve Parry

  • Background Document:

‘Save Whitehawk Hill’ & ‘Brighton and Hove Housing Coalition’

Notes to accompany our Delegation to PR&G Committee 06/12/18


The atrocious proposals to build a city-centre-type high rise housing estate on Whitehawk Hill are breathtaking in their audacity and ignorance. 

Though Whitehawk Hill is the most visible landscape feature of Brighton along the entire sweeping Bay of Sussex from Worthing to Seaford, and Chanctonbury to Ditchling Beacon, the housing site which smashes its unity in two is merely described in the BHCC City Plan Part Two as “Land at and adjoining Brighton Race Course”, as though it exists only as a valueless adjunct to that commercial enterprise. 

At one stroke the multiple statutory designations which load the Hill like the medals on a veteran’s dress uniform are dismissed. 

Though the Hill and the housing site have been protected by their status as common land for a thousand years and probably more (mostly as Brighton’s ‘Eastern Tenantry Down’ and in the last two centuries as ‘The Race Ground’ recreational common) and though many of its species have official recognition as being of conservation importance, and though it is largely statutory Access Land, and largely within the statutory Local Nature Reserve, it is just seen as being fit for a totally arbitrary excision (like a dog’s bite from a carcass) for a major urban development.

Though the full Council voted support for the inclusion of the whole of the Hill in the South Downs National Park only 16 years ago, their aesthetic and cultural assessment of the Hill now flips to a valuation that sees it as a mere disposable adjunct to an existing housing estate.

Though the Council  (admirably) thrice turned down developers’ applications for housing development at Meadow Vale, Ovingdean (which they had similarly voted to include in the National Park) in a middle class area with very low housing densities and very privileged access to private garden space, they think it appropriate to build an estate of  8 story towers right next to a crowded working class community with high levels of deprivation, and right in the middle of Brighton’s premier and senior public Downland site, thinking that this would not be contested. 

Hyde Housing’s Joint Venture eco-expert tells us that “there are no badgers there”, though local residents have loved and watched over them for 50 years. Their expert has not seen the pleasure that watching the Dartford warblers and foxes, the stonechats and whitethroats, the lizards and slow worms, the minibeasts – and even, remarkably, perhaps still adders – the bats, the skylarks, the meadow pipits and house martins has given us.

They draw up a programme which anticipates their bulldozers being on site by next spring (2019) as though they expect no possible delays – nothing except meek gratitude and acceptance from us, and urging on to do their good work – as though we must share the same dismissive evaluation of this neglected nature reserve as they do.  

Though they would readily accept (or perhaps not, in some cases) that a high rise housing estate at Cuckmere Haven or Ovingdean, Rottingdean or Alfrsiton would be an outrage they think that Whitehawk is another case.

They judge our ‘fish and chip Downland’ as being altogether without worth, though they readily accept the worth of Alfriston’s ‘cream tea Downland’.

In a City in which street after street, estate after estate of the finest family council housing – of garden city standard – and whole areas of erstwhile private rented modest housing is lost to gentrification and HMOs for ripped-off students; and in which whole suburbs of luxurious private housing at low densities, low levels of occupation and very privileged access to private garden space make no contribution to the housing needs of those on our waiting list and those dismissed from our waiting list – in this City we are asked to accept that there is no alternative to further pillage of our urban fringe Downland to meet our housing needs, though many of our urban fringe Downland sites are of greater public value than those more remotely sited within the National Park. 

We watch the architecture of the rich at the Marina rise up match the height of the ancient causewayed enclosure made by our first farming ancestors on Whitehawk Hill. We watch the architecture of our competing University corporations rise up in the Lewes Road valley to home 700 temporary student residents, when it could have provided an unbeatable opportunity for homing those most in need of secure and affordable housing in our City. 

We urge councillors to use your audacity and your bravery to reach new solutions for our homeless and poorly housed, which really take on the vested interests which leave so many people without homes or in homes subject to insecurity and super-exploitation.

We urge councillors to remember that their responsibility for the protection of nature is a categorical imperative that sits alongside and co-equally with the categorical imperative to provide each and every one of us with a decent, affordable and secure home. 

We must find our solutions in ways that equally recognise the epochal crisis of the extinction of nature, and the crisis of human misery caused by a failing housing supply, and seek solutions at the expense of those who can most afford to contribute. 

In a world in which some 60% of the global biomass of wild animals has been lost in just 47 years, we must recognise our local, domestic, particular responsibility to stop and reverse that process, and the concomitant need to protect all those places which still retain reservoirs of wild nature.

The slogan of the National Trust – “forever, for everyone” – is one which is applicable to the responsibilities of our Council too. Our specially recognised and protected places for nature are a resource to be preserved in perpetuity, not to be used as a contingency fund for future trading for other purposes. We all need homes, but Nature is our home, too. We need both homes.


Hyde Housing and BHCC


  • These heads of terms represent the commercial agreement of the parties at the current stage of1.3 negotiations. Whilst this document therefore reflects a reasonably advanced agreed position on the fundamental features of the joint venture, these heads of terms are not exhaustive or intended to be legally binding2. The parties only intend to be legally bound to one another when they enter into formal contracts for that purpose.

Accommodation costs (approximate):
·1 Bedroom Flat BHCC £69.50 per week (Social Rent)Same flat in proposed development: £147.66 – 113% higher
·2 bedroom Flat BHCC £80.14 per week (Social Rent)Same flat in proposed development £177.19 – 121% higher )That is before you include service charge of £15.49 per week). 

The sale of land to the ‘Joint Venture’ is thought to be based upon a250 year lease The sale is described in council meeting minutes as:“disposal” of Land north west of Whitehawk, Brighton by way of long leasehold and that delegated authority be given to the Executive Director Economy, Environment and Culture, Assistant Director of Property & Design and Executive Lead Officer Strategy, Governance & Law to agree terms and execute all legal documentation necessary to dispose of the site to the LWJV’ 29.11.18: Correspondence with HydeRichard Bickers


I have received this response from someone at Hyde regarding my query about ecological surveys and EIA etc. basically it appears they have done very little (though they avoid telling me what they have done) which means the programme stated on their consultation boards is cloud cuckoo land. I shall be going back to him to see if I can find out more.

From: Colin Harnor <[email protected]>
Sent: 29 November 2018 
Subject: RE: Proposed JVP development Whitehawk Hill – ecological surveys etc

Dear Mr Bickers,

Many thanks for your email in relation to Homes for Brighton & Hove’s development proposal in Whitehawk Urban Fringe Site.

The proposal is at an early design stage and we are currently reviewing all feedback from the public consultation events held on 10 and 11th October. Once this review has been completed we aim to update our proposals and carry out further survey work. At the start of the project we appointed an ecology consultant to our design team so please be assured a full suite of required ecological surveys will be conducted to inform the design. This will include an Ecological Impact Assessment to determine and quantify impacts to significant receptors. Mitigation measures will be incorporated to ensure all impacts are properly addressed and any habitat loss fully compensated. At this stage we have not engaged with third 3rd parties such as Natural England but it is something we will consider once the proposal is developed further.

 We will provide further updates in the New Year.

Colin Harnor, Lead Land and Planning ManagerT: 020 7346 6544 (Ext. 6544)
M: 0791 876 8529
E: [email protected]

From: Richard Bickers 
sent: 23 November 2018 
To: Colin Harnor
Subject: Proposed JVP development Whitehawk Hill – ecological surveys etc

 Dear Colin Harnor,

I am seeking information regarding this proposed development.  I would be grateful if I could be provided with a full list of ecology surveys that have been carried out, as well as surveys that are planned. In addition, for those already carried out I would be grateful if the survey reports could be made available. I am aware of the Urban Fringe Assessments (UFAs) that were carried out by Land Use Consultants in 2014 and 2015 and which are available on Brighton and Hove City Council’s web-site. I am interested in any additional surveys. I was told at the consultation exhibition in October that a Preliminary Ecological Appraisal (PEA) had been carried out. Was this in addition to the UFAs, i.e. a new survey?

 The UFAs made recommendations in regard to the following to inform the development of detailed proposals at this site –

 Extended Phase 1 Habitat Survey (equivalent to PEA) 

  • Plant species 
  • Birds 
  • Reptiles 
  • Badgers 
  • Invertebrates 

 Can you confirm if any of these have been carried out or are planned?

I would also be grateful if any mitigation strategies/plans that may have been prepared, based on the results of baseline surveys, could also be made available.

The proposed development is stated to comprise 217 dwellings. This would exceed the threshold of 150 dwellings set out in Schedule 2 of the The Town and Country Planning (Environmental Impact Assessment) Regulations 2017, above which a screening opinion regarding the need for an Environmental Impact Assessment should be sought from the relevant Local Authority. Can you confirm whether a screening opinion has been sought from the Local Authority (BHCC) and if so what the outcome of this was?

 I would also be grateful if you could confirm if any consultations or other discussions have taken place regarding the proposed development with Natural England, the East Sussex County Ecologist or other relevant third parties regarding the proposed development and the status of the site as a Local Nature Reserve and issues relating to habitats and wildlife species.



  • Argus 11.12.18

  • WordPress 28.10.18

  • Sussex Wildlife Trust, Severing their own green finger, 23 October 2018 

By Jess Price
Conservation Officer

Brighton and Hove City Council’s (BHCC) own website states: ‘Whitehawk Hill is an ancient habitat designated a Local Nature Reserve (LNR) with areas of species-rich chalk grassland supporting colonies of Adonis and Chalkhill Blue butterflies. From the top there are panoramic views over the city to the downs and the sea, including the Isle of Wight on a clear day… Ancient chalk grassland is internationally important – it is one of Britain’s rarest and richest habitats, with threatened species including Adonis Blue butterfly and orchids.

So why do BHCC plan to damage this vital green space by building five huge tower blocks on it in partnership with the Hyde Group?

The Sussex Wildlife Trust completely accepts the need for affordable housing, especially in an area with such a high disparity between wages and living costs[1]. But this should not be at the expense of one of the City’s most valuable wild spaces. 

Whitehawk Hill LNR links the city with the South Downs National Park and acts as a green lung, delivering services that we all rely on including filtering our drinking water, absorbing carbon, feeding our pollinators and providing a much loved recreational space. With so little space protected for wildlife in the City, we can’t let a precedent for developing Local Nature Reserves be set.

The Homes for Brighton and Hove partnership wants local people to let them know what they think about the proposal – to help guide their planning application to BHCC – but the deadline is tomorrow 24thOctober.  Please fill out their survey and let them know that a Local Nature Reserve is not an appropriate location for new housing.

Areas designated for their wildlife value should be cherished, not degraded.

[1] Lloyds Bank’s Affordable Cities Review.


  • Judy chard:

23 Oct 2018 18:57:00

This is a beautiful area… WHY would you WANT to desecrate it…. Be wise choose somewhere more appropriate

  • Yvonne:

23 Oct 2018 19:11:00

Please don’t build in the area of special interest on Whitehawk Hill.

For the sake of our planet, wildlife, countryside, and people in Brighton and in this country.

I find it surprising Brighton and Hove City councils are allowing building on this site.

Hoping that you see how vital it is, and listen to nature conservationists like the Sussex Wildlife Trust.

Thank you for reading this,

Mrs Yvonne Habkirk

  • Isobel Grant:

23 Oct 2018 20:01:00

No no no. Leave the wildlife alone.

  • Jane Durnford:

23 Oct 2018 21:56:00

It would be very wrong to build houses on this nature reserve. It is a valuable link to provide a ‘green corridor’ in our landscape that has already lost so many natural areas. It is an asset for local people to enjoy unspoiled beauty and experience their connection with nature. While people need homes it should not be at the cost of this irreplaceable reserve.

  • Amanda Bishop:

24 Oct 2018 08:13:00

A local nature reserve is not the place to be building tower blocks. We need to protect this space.

  • Helen Smith:

24 Oct 2018 08:24:00

Really important to preserve these special fragments of wildlife in a city.

  • Elaine Tiffin:

24 Oct 2018 08:36:00

It is unacceptable & downright inappropriate to build on this land! Please cease & desist!

  • Nichole Brennan:

24 Oct 2018 08:41:00

This needs to be looked at again, This is not the place for 5 high rise flats, it will not even serve the community

  • Amanda Sherratt:

24 Oct 2018 08:44:00

Our natural spaces are so valuable. They should build in brown field sites if at all possible.

  • Robert Morris:

24 Oct 2018 08:50:00

LNRs should not be sacrificed for housing developments. Alternative sites for housing should be identified and developed.

  • Richard Amey:

24 Oct 2018 09:48:00

A reserve is what it says it is: an area kept because of its value and importance to us all. Build on this space and what is left of value for the new residents on their doorstep, or of importance for them to preserve?

  • paul weston:

24 Oct 2018 16:19:00

This is not right and typical of BHCC not to think things through properly

  • Margaret Hammond:

24 Oct 2018 16:23:00

For goodness sake haven’t we destroyed enough wildlife habitat as it is? Leave us something, please!I have lived within sight of Whitehawk Hill all of my 71 years, please allow my great grandchildren the pleasure of doing the same.

  • Billy:

26 Oct 2018 04:17:00

I once lived in Brighton before the toxicity of the city got to me.One of the few places to escape to was Whitehawk Hill ,the air was clear and there were few people around.Brighton is already overpopulated with very few natural spaces within reach.Building there will be like putting a noose around your neck.



Thank you for allowing me to come to the meeting on Monday to hear your concerns. As a result of what I heard at that meeting, I wrote to the Leader of the Council outlining those concerns about this development. Today I have sent this statement to him along with the other members of the Labour Group and the press.

Councillor Nancy Platts – statement on the proposed Joint Venture development on Whitehawk Hill

As an East Brighton Ward Councillor, I attended the public meeting on Monday to listen to the views of residents in Whitehawk about the proposed build on Whitehawk Nature Reserve.

I saw how upset and angry local people were about the proposals and heard some very powerful and well-reasoned arguments against the development of this site.

I have carefully considered everything said at the meeting and I understand and acknowledge the very real concerns and practical reasons why this land should not be opened up to development either now or in the future.

The existing plans are over development of the site in an already densely populated area. There is one route in and one route out of Whitehawk. We already have a problem with parking and congestion, especially during major events in the City, making it difficult for buses to pass on Whitehawk Road and Whitehawk Way and for traffic to flow smoothly.

This development would take away a much-loved nature reserve from residents, the majority of whom have no gardens. Access to green space and being able to enjoy the natural environment is good for people’s physical and mental well-being and this area brings the community together.

As the Council’s website says, “Whitehawk Hill is an ancient habitat designated a Local Nature Reserve with areas of species-rich chalk grassland supporting colonies of Adonis and Chalkhill Blue butterflies.” Development will damage the environment and the biodiversity of the area.

We are campaigning hard to get a decent playground in Whitehawk and the excellent public consultations undertaken by the Parklife campaign highlighted the value placed on green spaces by local people.

I recognise that we have a need for properly affordable housing and council housing in Brighton but I remain concerned that too many new developments in Brighton and Hove have not met our 40% affordable housing target. Developers are being let off the hook by saying their schemes are not financially viable if they allocate 40% of their space to affordable housing.

Clearly, the more land that is built on for developers to maximise their profits, the more the space is reduced for affordable housing. The result has been to open up our urban fringe for development, adversely impacting on one of the most deprived areas of our City. It should not be the case that residents in Whitehawk should be expected to have even more people packed into the area, cheek by jowl, putting a strain on roads, schools and GP services.

In my view, the consultation process carried out by Hyde Housing Association was poor. So much more care and community involvement needs to be put in to the shape and placement of these projects. We should recognise that the old days when major developments can be foisted upon working class communities without meaningful consultation and involvement are over.

The voices of Whitehawk are important and East Brighton has been left out of the debate in the City for way too long. We now need to develop a neighbourhood plan that allows residents to have greater control over what happens next in their local area.

On these grounds, and as a local Ward Councillor, I will be opposing any proposals for this site to be developed and I will be supporting the residents in their campaign to stop this build.

Nancy Platts
Labour Councillor for East Brighton Ward


“The Sussex Wildlife Trust and CPRE Sussex are writing to you as Council Leader and Chair of the Policy, Resources & Growth Committee to urge you to do whatever you can to halt the Council’s dangerous plans to develop housing on Whitehawk Hill Local Nature Reserve.

Brighton and Hove City Council’s (BHCC) own website recognises that Whitehawk Hill is an ancient habitat of huge value to the local community, but this seems to have had little impact on the decisions of the Homes for Brighton & Hove partnership.

Whitehawk Hill LNR links the city with the South Downs National Park and acts as a green lung, delivering services that we all rely on, including filtering our drinking water, absorbing carbon, feeding our pollinators and providing a much loved recreational space. 

The Sussex Wildlife Trust and CPRE Sussex completely accept the need for affordable housing, especially in an area with such a high disparity between wages and living costs, but this should not be at the expense of one of the City’s most valuable wild spaces. It is completely unacceptable to develop it.
Large amounts of research demonstrate how valuable access to nature is in terms of health and wellbeingi. However at time of high levels of obesity and poor mental health, BHCC are showing little regard for the recreational value of Whitehawk Hill LNR to local residents.

The City Plan Part 1 is clear that BHCC wants to ensure that the city’s natural environment is protected and enhanced, with the vision stating that ‘The downland countryside will be conserved and its links to urban green spaces strengthened via a green network across the city where biodiversity is enhanced and equality of access to natural open space is achieved’. Similarly Policy CP10 requires BHCC to link and
repair habitats and nature conservation sites within the South Downs Way Ahead NIA, whilst conserving, restoring, recreating and managing priority habitats. Developing on Whitehawk Hill LNR is contrary to these requirements and conflicts with the three objectives of the Living Coast Biosphere, of which BHCC is a lead partner.

We remind you that BHCC have a duty under the NERC Act 2006 to have regard for biodiversity and in particular priority habitat, such as lowland calcareous grassland. This duty is further supported by the requirements of paragraph 174 of the National Planning Policy Framework. To push ahead with this proposal goes directly against the principles of sustainable development and the Council’s desire to provide strong civic leadership for the wellbeing and aspiration of Brighton & Hove.

The need to act now and stop this scheme from going any further is imperative. The proposal to build five tower blocks on a designated site sets a dangerous precedent of damage and degradation of the City’s ecological network, against a background of alarming declines in biodiversity. We must all recognise our responsibility to stop and reverse this loss of biodiversity and the need to protect all those places which
still retain reservoirs of wild nature and deliver the essential environmental benefits we all rely on. 
We ask you to recognise your responsibilities and act now to ensure that this important site is not destroyed.



19.11.18: Nature Conservation Designations

Freedom of Information Act 2000: Please see our response to your Freedom of Information request below.

 We are pleased to provide some of the information you have requested. I have detailed below the information.

 We can confirm that the remainder of the information you have requested is held by Brighton & Hove City Council. However, this information is exempt as follows;

  Under section 21 (1) of the Freedom of Information Act (FoIA), we are not required to provide information in response to a request if it is already reasonably available by other means.

 Some of the information you requested is available using the links below. If you do not have access to the internet at home, you may be able to use facilities at your local library.

 Whitehawk Hill Nature Reserve Protection Can u advise me on any info you have on Whitehawk hill nature reserve. Including the 3 protection status’s on this land, including being part of the biosphere and a local nature reserve. I’m particularly worried about the proposed development on chalk, and wish to see any consultations, surveys or work carried out on the safety of building on this rare Chalk grasslands Designations Nature Conservation Designations: 

The Whitehawk Hill Nature Reserve is a Local Nature Reserve (LNR) declared in 2004 for calcareous grassland habitats which support notable butterflies.  Further information on the LNR including consultation on the management of the LNR can be found on the council’s website. The site is within the Nature Improvement Area (NIA). The entire city is within the Brighton and Lewes Downs Biosphere. 

 Open Space Designations: The site is designated open space and includes various typologies including natural/semi-natural, allotments and outdoor sports. 

 Historic Designations: The site is within an Archaeological Notification Area (ANA). 

 The boundaries of the various designations can be seen on the draft City Plan Part 2 interactive policies map. 

 Development: As part of the Examination in Public of the City Plan Part 1, the council was instructed to look more positively for opportunities for housing development within the city’s urban fringe and in 2014 commissioned the Urban Fringe Assessment (UFA 2014). The UFA 2014 identified that an area of land (1.5ha) at the northern end of Whitehawk to the west of the existing tower blocks on Albourne Close and Lodsworth Close had potential for approximately 150 units of higher density housing. The 2014 UFA study acknowledged that development would sit on land registered as part of the LNR but considered that there was potential to mitigate any significant negative effects. 

 In 2015, the council commissioned further landscape, ecological and archaeological assessments for some of the urban fringe sites. This included a Phase 1 Habitat Survey and included consideration of protected/notable species. The UFA 2015 study suggested that, for landscape impact mitigation reasons, the identified potential development area for this urban fringe site (site 30 ‘ Land at and Adjoining Brighton Race Course) be adjusted southwards to avoid areas of higher land. In terms of ecology, the assessment concluded that impacts on the LNR, including partial loss, would require appropriate mitigation and outlines a series of mitigation measures including the enhancement of retained habitats, measures to restore and recreate calcareous grassland and improved habitat management. The 2015 Study does indicate that detailed development proposals must be informed by an updated Extended Phase 1 Habitat Survey and species surveys to ensure potential impacts are identified and appropriate mitigation developed. 

 Consultation: The site has been proposed as an urban fringe allocation in draft City Plan Part 2 in policy H2.  City Plan Part 2 was subject to a period of consultation between July and September this year and consultation responses are currently being analysed. A draft consultation statement, including a summary of responses should be available early in the New Year. 

 Please quote the reference number 2532468 in any future communications.

Possible further Requests

  • Air quality impact study?


Historic England

From: Historic England Southeast [[email protected]]
Sent: 06 December 2018 12:11
Subject: RE: Advice on development near Neolithic causewayed camp

I have taken a look at the proposal and the site location. There is the Scheduled Ancient Monument, Whitehawk Camp causewayed enclosure, approx. 500m away from the site. As the site boundary does not appear to border or fall into the monument boundary this would not require Scheduled Monument Consent. It is possible the local authority may consult Historic England on the proposed development because of the monument.

Apart from the monument, there are no other heritage assets for which Historic England would be consulted on. I have included a list below of what we are consulted on for your reference.

We should be formally consulted by the local authority on the following criteria:

•        Listed building consent applications relating to works to a Grade I or II* building, or demolition (or part) of a Grade II building.

•        Planning applications which affects the setting of a Grade I or II* listed building, or a Grade I or II* registered park or garden, a scheduled monument or a registered battlefield.

•        Development which affects the character or appearance of a conservation area and which involves the erection of a new building, or the extension of an existing building where the area of land in respect of which the application is made is more than 1,000 square metres.

•        Local authorities’ own applications for planning permission for relevant demolition in conservation areas.

•        Care of Cathedrals Measure 2011: applications for certain classes of works to Anglican cathedrals.

•        Ecclesiastical Exemption: for works that affect listed ecclesiastical buildings or archaeological remains.

•        Listed Building Heritage Partnership Agreements proposals, where these would cover Grade I or Grade II* listed buildings or listed buildings owned by local planning authorities.

•        Local Listed Building Consent Orders proposals, where these would cover Grade I or Grade II* listed buildings or listed buildings owned by local planning authorities.

•        Nationally Significant Infrastructure Projects (NSIP).

•        Applications for Scheduled Monument Consent.

I hope this information is useful to you. Please do not hesitate to contact me if you have any other questions.

Kind Regards,

Sarah Garcia


Warren Morgan

From: Warren Morgan <[email protected]>
Sent: 07 December 2018 14:25
To: Richard Bickers
Subject: Re: Proposed JVP development at Whitehawk Hill in Local Nature Reserve

 Dear Mr Bickers,

Thank you for your email. I have asked senior officers at the city council to clarify the status of the site in question, and what protection it has. Their response was as follows:

“The site is part of the Local Nature Reserve which covers most of the hillside surrounding that side of Whitehawk. This is designated locally by the council rather than Natural England (although it is then registered with Natural England).However it was identified in the Urban Fringe assessment as suitable for residential development and is proposed to be allocated as such in City Plan Part 2. 

There is an expectation in the Urban Fringe Assessment that any development would include measures to mitigate environmental impact and enhance the area. The development plans have had specialist input from an ecologist and landscape architect and will include measures to mitigate and enhance in line with these requirements.”

As far as I am aware as a ward councillor, there are no immediate plans to bring forward a planning application for the site, it is certainly not being sold, and any proposals to build there would be subject to all the usual and statutory consultations as part of the Planning process.


Councillor Warren Morgan 

From: Richard Bickers <[email protected]>
Sent: Thursday, December 6, 2018 9:57:31 AM
To: Warren Morgan
Subject: Proposed JVP development at Whitehawk Hill in Local Nature Reserve

 Dear Warren Morgan,

I am writing to you regarding statements you have made about the location of the Proposed JVP development at Whitehawk Hill. In the article on this in the Brighton and Hove News on the 17th of November you are quoted as saying –

It isn’t in the part of Whitehawk Hill that has special designation.’

I understand you have made similar statements to people who have written to you on this subject, such as –

The site does not encroach upon the scheduled nature reserve…’

This is factually incorrect, the proposed site lies fully within the boundary of the statutory Whitehawk Hill Local Nature Reserve. I have attached a plan showing the boundary of the LNR (taken from the governments Magic Map application) in the relevant area as well as a similar plan with my sketch of the proposed development site (as at the time of the consultation in October) boundary. It clearly shows the proposed development site within the LNR boundary. Indeed the fact that it lies within the LNR is identified in the Urban Fringe Assessments of 2014 and 2015 and even on Hyde’s consultation exhibition boards (also attached, see the aerial plan on board 1 for example), prepared for the consultation in October.

In addition to lying within the LNR the proposed development site also lies within statutory access land designated under the CROW Act as well as the 1822 Race Ground recreational common.

Can you confirm that you will not be making the same or similar misleading statements regarding the location of the proposed development site within the LNR in future?


Dr Richard Bickers (Member of the Chartered Institute of Ecology and Environmental Management)

Local Green Space Designation


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