June 2014 UPDATE: Brighton and Hove City Council currently has a Green Party led administration. They are undoubtedly skilled in political rhetoric and self-promotion. But they have significant gaps in their ability to manage the ‘Green’ elements in the local natural environment.

For example:


Result: Awarded ‘Biosphere Reserve’ status by UNESCO(UK) in June 2014. Such status is awarded to 'sites of excellence' to explore and demonstrate conservation and sustainable development in practice.



An Example of Brighton and Hove City Council failing to respond adequately to representations on the Local Biodiversity Action Plan (LBAP)

Formal Comments on the Local BAP

On 3 September 2012 Eco-Logically submitted a formal representation on the Draft LBAP. No response or feedback was received from the council.

Having checked both the main e-mail 'inbox', 'cc box' and backup archive for all e-mails (including 'spam') it was clear that no response had ever arrived.

The first opportunity we had to comment on the post-consultation version of the LBAP was as a visitor to the City Sustainability Partnership (evening of 6 March 2013). Despite a clear concern about the council failing to address the points raised by ecologists, the verbal response from the CSP chair was " ...there were issues about the way the consultation took place... people around the table are happy with where we are at... " This is just no way to undertake a formal consultation, nor to treat those responding to a formal consultation. Indeed, it may breach recommended local government procedures for undertaking consultation.

This appears to be a case of 'Maladministration' in terms of this consultation procedure.

Recommendations from a qualified ecologist and member of the National Biodiversity Network should be afforded due attention by the local authority. The representation submitted followed detailed discussions with qualified colleagues who provided considerable weight to the input on local Biodiversity. Most of the concerns about the LBAP structure, and stakeholder engagement were ignored. So too were many of the detailed comments formally submitted.

Example of areas not addressed are provide below ( Numbering corresponds to Representation submitted on 3 September 2012)

RECOMMENDATION: 1. Input from local businesses, organizations and knowledgeable individuals could had been built into preparing this Local BAP.

One of the main functions of producing a Local BAP is to engage with a wide range of sectors. More than a quarter of a million people live in Brighton and Hove yet only thirteen responses were obtained (13 out of 250,000!). Involvement by wide cross-section of stakeholders was minimal. Main activities seemed to focus on Dorothy Stringer and Moulsecoomb Schools. This is the easiest sector to include as children are interested in nature. There was no attempt to promote the discussion board which had been produced at www.citywildlife.org.uk/forum/viewtopic.php?f=5&t=34&p=51#p51. In fact comments on this board were not attended to by the council, apart from some brief responses occasionally, that still failed to address the point raised.

IGNORED: Comments received from Eco-Logically were ignored. This appears to have been the way other respondents were treated.

RECOMMENDATION: ...we would have a clear action plan to set the future direction. Instead the Draft Local BAP is a shambolic mixture of phrases and unclear direction.

Apart from some rearrangement of the paragraphs, the unstructured layout of the document remains unhelpful as a usable Action Plan. It is now 99 pages long(!) with no Appendix and an initial 'contents' list that does not list the content accurately.

RECOMMENDATION: 4. Insufficient effort has been made to link the proposed Actions across Brighton & Hove with the wider framework in which a Biodiversity Action Plan sits.

IGNORED: It still remains unclear where the listed objectives and actions were derived from. Were they national objectives, or Sussex BAP ones? Were they suggested by those responding to the draft LBAP or added by the council ecologist based on his interests and priorities? An obvious example is using Matthiola incana as a local Biodiversity indicator species. It is not mentioned on Section 41 ( Natural Environment and Rural Communities Act (2006 ). This is a non-native plant, found across the south coast, southwest peninsula and west coast up into Wales. It is a bizarre choice as a biodiversity indicator and totally inappropriate in ecological terms.

RECOMMENDATION: 15. The Local BAP should go to the heart of nature and life itself being vitally important to everybody. At the very least it should raise this point and refer to the 'intrinsic value' in nature.

IGNORED: This LBAP still fails to capture the very essence of biodiversity, as being essential to life itself; all life. There is no mention of 'intrinsic value' in nature. The LBAP still remains restricted to just the utilitarian 'how will it service local people' demand.

In other words: "It is not INSPIRING"

This LBAP still fails to capture the very essence of biodiversity, as being essential to life itself; all life. There is no mention of 'intrinsic value' in nature. The LBAP still remains restricted to just the utilitarian ' how will it service local people? ' demand.

It is shocking how this element is absent.




They are all covered (deliberately and with foresight) in the National guidelines on biodiversity and wider literature on producing BAPs. The council has done a great disservice to local people (and to nature, in my opinion) by just ignoring these guidelines and formal comments.

RECOMMENDATION: 29. The biggest failing in this LBAP is there is no clear aim. What is it aiming to achieve?

IGNORED: The overall aim should be loud and clear near the beginning of the LBAP. It should clearly explain why it is important to everybody (which it is), and why it should start immediately. The nearest thing to a statement of the aim is in lacklustre bureaucratic Paragraph 6:

"The overall aim (or ‘vision') for biodiversity in Brighton and Hove is that by 2020, ...

...biodiversity will be integrated into decision-making by the Brighton and Hove Strategic Partnership and its member organisations."

It is stated: “This LBAP also contributes to the over-arching objective of achieving designation of Brighton and Hove as part of a UNESCO Biosphere Reserve ” and elsewhere the LBAP has been demoted to a ' technical document informing the biosphere bid"'

NO! This is wrong. BHCC has a formal Duty to promote biodiversity now, not wait until 2020. The LBAP is the key action plan to provide the strategic aims, objectives and agreed actions now.

A few years ago Eco-Logically commented on the City Plan how unfortunate it was that BHCC devoted all its resources to the one ambition – ' City Biosphere Status '. This biosphere bid has truly diverted all attention away from the existing Biodiversity Duty. If only a quarter of the money, member and staff time and effort had been allocated to Local Biodiversity Action over the past decade we would already be enjoying the rewards from the biodiversity investment.

The continuing waste of resources on an unrequired and uncertain ' biosphere bid' in these economically challenging times remains exorbitant in our opinion.

RECOMMENDATION: 33. It is recommended that at least 20% of the land area south of the NP boundary is managed with biodiversity as a key objective.

IGNORED: Nowhere is an explicit figure provided for the area of land defined above. We know the National Park is in 'safe hands', it is the rest of Brighton and Hove which needs biodiversity objectives integrated into the LDF. Also...

RECOMMENDATION: 34. It is recommended that the LBAP should explicitly state there are sustainability constraints on levels of consumption by the local population living here, without harming environmental features, environment resources or the local biodiversity.

IGNORED: As in 33 above, an explicit figure should form the basis of the LDF. The UN Millennium Development Goals and the Royal Society's ' People and the planet ' report (April 2012) should be referenced. Both of these documents, and the recommendation, were ignored.

Further detailed comments

RECOMMENDATION: Refer to England Biodiversity Strategy Objectives and Actions. These are available and should clearly stated.

IGNORED: Although three of the four priority actions are partially addressed through the five 'Key Principles' in the LBAP the EBS priority area ' Reducing environmental pressures ' has been completely ignored. The recommended actions and 'England Delivery Plan' have all been totally ignored!

It would appear that the LBAP for Brighton and Hove was written without any reference to the EBS and only subsequently were a few vague phrases 'shoe-horned in' to ensure the EBS was at least mentioned. The LBAP certainly does NOT “ ...take full account ” of the EBS and can be considered disingenuous to give that impression in this council document. This point is expanded upon in recommendations on 'Geodiversity' below.

RECOMMENDATION: Reference to 'Urban Commons' (toward the end of the LBAP and elsewhere) is not a useful term.

RETAINED, EVEN MORE STRONGLY: The 'urban common' idea was first proposed in Sheffield nearly twenty years ago. For a former industrial, heavily urbanized city it may be considered a useful concept to encourage residents to appreciate the areas being recolonized by pioneer invasive plants. Normally such areas are called 'wasteland' and usually ignored. In Brighton and Hove there are no such areas. Any such 'brownfield' site is quickly grabbed for building on!

'Common' also has a specific legal meaning and referring to land as an 'Urban Common' creates legal complexity which clouds the intention of the LBAP. It is an unhelpful term, and for our local urban area which has an intricate framework of interconnected green spaces and potential habitat corridors, will merely provide ammunition for barristers with a vexatious objection to the LBAP's status in future planning proposals.

RECOMMENDATION: Link the LBAP to the Sussex BAP objectives and targets. They are vague at the moment. This should be referenced at the very least, or use hyperlinks on the on-line version of the LBAP.

IGNORED: Why is the council unable to be transparent in linking the LBAP objectives and targets to the Sussex or National ones? Even if the higher category objectives cannot be applied locally, this should be explicit. For example, expanding the area of broadleaved woodland by 5ha is trivial. The recommendations clearly given were;

“2. Achieve favourable or recovering condition of all native broadleaved woodlands larger than 0.1ha by 2015.

3. Expand the current native woodland resource in Brighton and Hove by 38 ha by 2015.”

Why not respond in a transparent way to these recommendations?

RECOMMENDATION: Refer to Sussex Parkland HAP objectives and targets

IGNORED: Similarly, the Sussex Parkland HAP was ignored despite objectives and targets being clearly available. It is bizarre to state that Hollingbury Park and Stanmer Park fall within 'The Urban Area' when they clearly link to the surrounding countryside, National Park and former AONB.

Veteran Trees: It is symptomatic of a local authority disinterested in collaborating transparently with all local stakeholders that there is no reference to 'Veteran Trees' within the Parkland objectives for the LBAP. These were clearly given as recommendations, but then:

IGNORED: 'Map all veteran trees in the city jurisdiction by 2015 and establish programme to plant new trees as needed to ensure no loss of continuity between veteran trees in the long-term'

RECOMMENDATION: 'INCLUDE: BSBI 'Axiophytes' relevant to Brighton / Hove' was

IGNORED: The council's 'City Parks' Team have an unnatural interest in promoting inappropriate species (Virginia creeper Parthenocissus quinquefolia and hybrid bluebell Hyacinthoides x massertiana are two recent examples). The prime recommendation by most ecologists and naturalists across the UK is to favour locally-appropriate native species . Hence the 'Axiophyte' list of plants was provided, which could have been included as an Appendix at the very least, to inform future planning consultations.

RECOMMENDATION: Include Locally important Geomorphological Features such as coastal shingle and four Local Geological Sites:

TQ20/121 The Goldstone, Hove Park

TQ30/135 Stanmer Village

TQ30/236 Black Rock, Brighton Marina

TQ40/174b Coastal section: Friar's Bay to Brighton Marina


113. Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife or geodiversity sites or landscape areas will be judged.

IGNORED: All references to earth science or geodiversity were ignored. The word 'Geology' does not appear once in the LBAP!

In addition to conflicting with the EBS and the National Guidelines detailed in the formal representation, it is simply wrong for an Action Plan supposedly promoting biodiversity to ignore the underlying landscape, rocks and soil. Detailed recommendation were provided by Eco-Logically and the council have an expert geologist within their existing staff. There was simply no good reason provided for ignoring the Geodiversity which supports the whole of Brighton and Hove in this LBAP.


These are a few examples to illustrate how the council has chosen to ignore the representation provided by Eco-Logically in responding to a formal consultation. This may be considered to be 'Maladministration' and a formal complaint will be registered under the Regulations applying to Local Authorities.

In addition to showing a lack of respect for experienced and knowledgeable local stakeholders it is noted that other responses were also ignored. For example the Botanical Society's recorder expressed concern about the species chosen. For example the continuing use of non-native plants in areas with biodiversity management objectives, and the fact Matthiola incana has no nature conservation merit.

Seagulls may be the moniker of the local football team but using these as a biodiversity indicator makes no sense in sustainability terms. If populism was desired then it would make far more sense to include the house sparrow Passer domesticus , as recommended by Brighton and Hove's Wildlife Forum. Whilst it is mentioned just once, in the gardens section, so much more could have been usefully included. This bird has suffered a more than 75% population decline recently, yet many local people are still fondly aware of this most urban 'biodiversity bird'. The opportunity to create suitable local habitat and engage in 'citizen science' has been lost in the Local Biodiversity Action Plan for Brighton and Hove. Who is going to monitor herring gulls?!

Our local wildlife deserves so much more from the council. Our local people deserve so much more from the Local BAP being produced on their behalf by their council too.

We urge Brighton and Hove City Council to make the changes needed for the LBAP to be truly ' Fit for Purpose ' before it is formally published.

John M Patmore
Eco-Logically .com

18 March 2013


Click here for the FULL RESPONSE from Eco-Logically (.pdf document)

We have been recommending the production of a Local BAP which fully engages local stakeholder, groups and interested individuals since 2001. Detailed advice has been provided over the past decade to the council.

National guidelines have been published and updated over the decade, yet Brighton and Hove Council has given these little attention. A conference held at Dorothy Stringer school failed to refer to the Formal Biodiversity Duty even once, as attention was diverted to the ambition of obtaining a 'Biosphere Reserve' label from UNESCO.

This web-page provides an example from the previous 'England Biodiversity Strategy' of key areas to address. The council paid insufficient attention to this national strategy, as with the current version published in 2011. The 'checklist' is retained below for information.


Brighton and Hove Local BAP: a Checklist

1. Introduction and background

2. Philosophical reasons for caring about nature - not always 'shopping' and consuming

3. General BAP recommendations

4. Documents

5. Habitat objectives

6. Species objectives

   ...Eco-Logically comments on LBAP draft..pdf, March 2011 [ 12 pages, 61 kB, click to download]

10 March 2011: Eco-Logically has just received the LBAP 1st Draft! Comments required within a fortnight... so please pass this link on to colleagues also interested in an input to this rather opaque collaboration:

   ...Copy of Brighton & Hove LBAP draft 1.doc [ 616 kB, click to download]

   ...Copy of Comments Paper - LBAP draft1.doc [ 43 kB, click to download]





2010 ‘International Year of Biodiversity' may nearly be over but despite Falmer Stadium, lack of Downland grazing and a ‘slash and burn' approach by the council near Wild Park our biodiversity will still survive into 2011. It is a fact that Brighton & Hove still does not have a plan for conserving and enhancing its biodiversity resource. Indeed, there is not even a project proposed within the council to address this glaring gap.

For a whole series of reasons it has taken over a decade for Brighton & Hove City Council to even start drafting a Local Biodiversity Action Plan (LBAP) following ‘ Biodiversity: the UK Action Plan ' (published in 1994). This was discussed in 2001 at the ‘Wildlife Advisory Group' (WAG) established by the council. A report with recommendations on the essential components for producing a LBAP, detailed habitat and species lists were published (Ref: Local Biodiversity Action Plan for Brighton & Hove, May 2003, WAG). This was not progressed and the WAG folded, after receiving no further support from the council from 2009 onward.

Confusing stuff!
   Despite attempts to progress biodiversity using the existing guidelines the council has been reluctant to follow these; indeed, a council document discussed on 13 July 2010 stated ‘ The national BAP process has been complicated and rather confusing, '.

There was a suggestion to keep the habitat and species lists as short as possible. This is totally opposite to the concept of diversity! Brighton and Hove's Local Biodiversity is a source of inspiration and joy, to be cherished and nurtured, not kept 'as short as possible'.

Consultation stuffed!
   There is a ‘consultation' on a draft LBAP planned for 2011. Below is a table of the main documents, policies, habitats and species which a LBAP should address for Brighton & Hove. This can be used as a CHECKLIST to help compile an intelligent response to the apparently ‘rather confusing' consultation draft.

  Checklists appear like this  
Example item Further details, references, web-links

[please note: the check-box does not link to other servers, but is just a simple way for tracking items]

Incidentally, the previous consultation over the Nature Conservation SPD was not used as an opportunity to open discussions with local stakeholders. Instead a ‘Statement of Representations' (August 2009) was presented at an Environment Cabinet Members meeting with the simple ‘No Change' recommended and seemingly ‘rubber-stamped'. An objection to the recommended species planting list was ignored (= ‘No Change') and many plants originating from Asia, United States and central Europe totally unsuited to the Sussex native biodiversity were formally recommended. This includes Virginia creeper Parthenocissus quinquefolia , which is a ‘Schedule 9' species that is both unlawful to plant outside the most urbanized areas and a highly invasive creeper unsuitable for new developments.

What community?
   So, please use the checklist below to see if the important biodiversity issues have been addressed. However, it will take a lot more to ensure biodiversity is being progressed with full involvement from local residents, groups and businesses.

Local community involvement should be at the core of drafting, producing and implementing a Local Biodiversity Plan. A ‘Community Engagement Framework' (2009) has been produced by the LSP which could help guide the council in engaging with the community. Unfortunately, all the evidence so far indicates the LBAP will be just another document published, box ticked and then left to languish.


How about an Urban Biosphere?
   Biosphere reserves are designated by UNESCO and the council has expended many resources seeking to obtain the ‘Biosphere Reserve' label for Brighton and Hove. A two day conference was devoted to this in 2008. However this will be hard to justify if there is not even a functioning Local BAP network and action plan in place.

At a recent conference on the biosphere reserve application the intention to shortly consult on the LBAP was not mentioned (10 November 2010 ). Also the formal Biodiversity Duty was not covered in any of the talks.

If the Urban Biosphere Reserve accolade is to have a genuine purpose there needs to be clear objectives, targets and action under a Local Biodiversity Action Plan. So far this connection has not been made.


2.Beyond the merely prosaic : Nature is intrinsically valuable

Apart from looking after Local Biodiversity because of the formal Duty there is another reason for caring about nature; its sheer beauty and excitement. Most children know this.

We can reconnect with the pleasure and joy that nature has. But beyond the anthropocentric ‘human-centred me…me…me…' need to possess and consume there is also an intrinsic value within nature.

Whilst the LBAP is the core mechanism which can inspire us all in enhancing our local biodiversity, it must not become just another grey dull council document.


“Through wise stewardship of the natural world we both improve our environment and nurture ourselves too. By caring about nature we can enhance our own health and freedom; and through this we can access the world in which the human spirit was first born”

We can be bold in providing advice and clearly show that the council has responsibilities to manage its biodiversity, and our natural inheritence, wisely.

This responsibility is stated in both ‘Biodiversity and your duty of care: A guide for Local Authority Elected Members' [South East England Biodiversity Forum, 2009] and ‘Conserving Biodiversity – The UK Approach' which explicitly mentions the intrinsic ethical and philosophical value within nature:

Box 2 – Why conserve biodiversity?

Because it is wrong to treat nature as if it has been designed for our convenience and abuse.

Because it inspires and enriches our lives (aesthetic/spiritual/cultural services). It enriches many people's lives every day. We are uplifted by nature and our spirit is renewed by contact with it. It provides endless motivation for enquiry, from schoolchildren to scientists.

[Source: DEFRA, October 2007]


3. General Biodiversity Planning recommendations

There is still no overall project plan for local biodiversity. If a professional project plan is ever drawn up it should include:

This is such basic preparation to managing any project. But it has been almost surreal to experience the difficulties in raising the need for clear project management with the council.

Obviously community involvement will be critically important for planning, action and reporting, so ensure:


4. Documents

Whilst the Council has published virtually nothing on Local Biodiversity there are many published resources available elsewhere. Biodiversity Action Plans operate with a framework which contributes to the international objectives and actions through to local ones. Information, objectives and action 'cascades' across these levels. Monitoring the action progress flows into the reporting at UKBAP level, and ultimately allows us to see the global changes from sustainable development.

Does the draft LBAP refer to the following essential resources setting out national, regional and Sussex biodiversity objectives?

  Checklist : Refers to other objectives?  
The UKBAP http://www.ukbap.org.uk/
SE Regional BAP http://www.sebiodiversity.org.uk/
Sussex BAP http://www.biodiversitysussex.org/


Does it mention the International Dimension?

  Checklist : Refers to international aspects?  
The Convention on Biological Diversity which identified the critical link between sustainable development and the natural environment: http://www.cbd.int/2010/welcome/
Millennium Development Goals - especially #7, 'Goal 7: Ensure Environmental Sustainability' http://www.unmillenniumproject.org


Does it mention National Guidance?

  Checklist : Refers to national guidance?  
Formal status of the Biodiversity Duty for public agencies Guidance for Local Authorities on Implementing the Biodiversity Duty ' (DEFRA, 2007)
Planning Policy Statement 9: ‘Biodiversity and Geological Conservation' [PPS9] Planning Policy Statement 9 states that plan policies and planning decisions should be based on up-to-date information.
Guide to Good Practice for PPS9, describes a number of reasons why this information is needed, including to:  
  • Provide the evidence base needed to prepare and measure the implementation of local development frameworks and sustainable community strategies;
  • Ensure a spatial planning approach to the development of local Biodiversity Action Plans;
  • Appraise environmental impacts of development proposals and
  • Inform a strategic and spatially planned approach to the conservation, enhancement and restoration of biodiversity.
England Biodiversity Strategy (plus see below for relevant objectives) 'Working with the Grain of Nature: A Biodiversity Strategy for England'. England Biodiversity Group, 2002.


Does it refer to the England Biodiversity Strategy?


Checklist : England Biodiversity Strategy,

Delivery of local and regional biodiversity objectives by strong, inclusive partnerships with a long term vision and stability for the future. Links to sustainable partnerships
Local activity takes place and is complementary to national plans and programmes.
Local priorities and targets are informed by national BAP priorities and targets and vice versa. Information exchange
Widespread exchange of easily-accessible information, good practice and guidance about local biodiversity activities.
An effective means of reporting and monitoring progress. Reporting mechanism
A set of local biodiversity indicators produced to track progress on delivery of the action plan.
Biodiversity objectives and targets integrated into Council activities, particularly LDF, Sustainable Community Strategy and recognition of local biodiversity objectives in planning policies. Council core activities
Development of the contribution of local partnerships to the improved communication and understanding of biodiversity.
Better understanding of the economic drivers which are causing biodiversity loss. Economic links
Correction of failures in the local economic free-market and implementation of the ‘polluter pays' principle.
Recognition of biodiversity as a public good.
Decisions reflect the full costs and benefits of biodiversity.
Role of biodiversity in local development planning and applications is widely understood and recognised, in a way which contributes to nature conservation and environmental protection. Development plans
A financial and cultural climate in which funding for biodiversity is encouraged.
Increased Board-level recognition of biodiversity as a material business issue. Businesses involved
Increase in the number of companies and businesses with biodiversity objectives included in their Corporate Social Responsibility plan.
Biodiversity objectives integrated with business management systems to consider all aspects of its activities, products and services, including effects on biodiversity.
Increase in the number of local company site-related BAPs making measurable contributions to Local BAP objectives.
Identification and promotion of good practice at sectoral and company level.
Increase in the number of companies involved in the LBAP partnership, and involved in habitat and species schemes.
Widespread adoption of biodiversity reporting mechanism to contribute to Local BAP monitoring and reporting.


Does it refer to other Sectors which contribute to Biodiversity?

  Checklist : England Biodiversity Strategy,
The retention and good condition of semi-natural habitats within farming systems.
The promotion and reward of appropriate land management techniques that benefit semi-natural habitas.
Conservation, management, restoration and creation of habitats to allow biodiversity to thrive.
Reverse the losses of farmland biodiversity and the positive management of all farmland features beneficial to biodiversity.
A sustained increase in the biodiversity value of agriculturally productive land.
Water quality targets developed and met for priority BAP habitats.
Water quantity requirements developed and met for condition assessment of relevant SSSIs esp. abstraction impacts on Downland aquifer.
Water and wetland habitat conservation is promoted in all policies, plans and projects controlling water level and flood management activities. esp. local flood impacts.
A programme for prevention and management measures for non-native invasive species established and funded. NOTE: this is also relevant to urban areas, covered below...
Pest issues addressed. esp. Dutch elm disease and Oak dieback
Provision of more advice to Council Development Control and better monitoring of changes resulting from developments and planning applications. Ancient woodland and planning appliations
Reduced damaging impacts on woodland from surrounding agricultural practices.
Improved consideration of pollution and other indirect impacts on woodland biodiversity.
Improved information on state of woodlands, including parkland and pasture-woodland. esp. Stanmer Park, Preston Park and Hove Park
Increased proportion of woodland under approved management and protection.
Guidance on habitat management for woodland, parkland and pasture-woodland.
Woodlands and trees complementing other habitats, at a landscape scale, and providing for non-woodland species (eg: rides and glades).
Increased high-quality public access to woodland.
Increased local involvement in woodlands and biodiversity.
Biodiversity protection, conservation and enhancement objectives in regeneration guidance esp. Shoreham Harbour development which involves western sections of Hove and Portslade.
New planning legislation and guidance underpinned by sustainable development objectives.
Planning obligations linked to positive biodiversity objectives.
New developments build in biodiversity and disseminate good practice.
Biodiversity conservation and enhancement as an element of brownfield development.
Key brownfield biodiversity species conserved through site protection, mitigation and habitat creation.
Understanding and acceptance of how brownfields can make a positive contribution to the ‘green' elements of urban regeneration.
Biodiversity conservation and enhancement objectives are included in planning applications.
Natural green spaces and wildlife features are provided as part of planning applications.
Biodiversity targets incorporated in house-building and other development schemes.
The use of ‘Sustainable Urban Drainage Systems' (SUDS) as standard practice for all ‘new-build' developments.
Green buildings designed and constructed as standard practice for all new-build.
  MARINE AND COAST note: Brighton's legal jurisdiction extends beyond the Marina wall
Development of an ecosystem-based approach to maritime and coastal environmental management.
Incorporation of biodiversity objectives in flood and coastal defence policy.
Delivery of maritime habitat and species action plans.
A coherent legal and administrative framework for nature conservation in the marine and coastal environment.
Management of alien/invasive species. in marine/coastal areas, also see below.
Targeted research, survey and monitoring to provide the knowledge required for an ecosystem-based approach to management of the marine environment.
Increased understanding of climate change impacts on maritime habitats and species.
Improved monitoring of water quality on maritime areas.
Increased understanding of biodiversity impact from offshore developments. esp. 'Rampion' project


Does it clearly include Urban aspects which contribute to Biodiversity?

  Checklist : Urban aspects contributing to Biodiversity:  
Parks to be managed with biodiversity conservation as a core principle. Potentially applies to all parks and green spaces.
Large urban parks progress LBAP objectives.
Relevant parks and urban green spaces protected and managed as local wildlife sites.
Peat-based compost phased out in horticultural departments and use.
Pesticide use significantly reduced.
Water conservation measures are in place.
Ecological skills employed in all LPA parks and landscape teams.
Performance indicators for parks linked to biodiversity targets.
Residents can access natural greenspace within 300m wherever possible.
Cemetary and churchyard management linked to LBAP objectives.
Increase in woodland and appropriate environment habitats for burial practices.
New cemetary allocation not leading to a loss or damage to important wildlife sites.
Transport corridor management linked to BAP objectives. esp. rail routes to Lewes and Hassocks
Development along transport corridors does not lead to loss or damage to important wildlife sites.
Continued increase in wildlife gardening and consequent enhancement of biodiversity in urban and suburban areas.
Sustainable gardening approaches adopted. esp. gardening for local wildlife species
Increased participation by local residents . esp. in ‘citizen science' for biodiversity record centre and LBAP monitoring.
Key gardens and allotments contributing to habitat mosaic protected through planning policy. esp. adjacent areas recognized in the LDF
Sale of problem exotic plants controlled. mainly though monitoring and advice at garden centres.
Greater understanding of the value of gardens for biodiversity at the landscape scale. esp. gardens contributing to the wider habitat mosaic.
Schools to be encouraged to develop their grounds for biodiversity objectives.
Schools encouraged to make use of their grounds as ‘outdoor classrooms'.
Implementation of ‘School Grounds BAP'. note: BAP published by the Council, 2004
Better local environments for people suffering from deprivation.
Local renewal schemes for residential areas and estates to include biodiversity components.
Increased provision of trees and greenspace in built environments.
Environmental and biodiversity proofing within SEU and NRU remits relevant to Brighton & Hove

'Social Exclusion Unit' and 'Neighbourhood Renewal Unit' link with ‘Accessible Natural Greenspace Standards' (published by Natural England).

Local GPs prescribing walks and conservation activities in local greenspaces.
Local biodiversity areas linked to Local Health Trust and Health Action Zone programmes.
Better information and understanding of managing non-native species.
Promotion of locally appropriate species based on biodiversity objectives.
Greater understanding of positive biodiversity benefits from non locally-ecological species which are appropriate to local biodiversity objectives.


Does it mention other General Guidance for Local Authorities?

  Checklist : Other general guidance  
Association of Local Government Ecologists guidance on Biodiversity and the LDF. Integrating Biodiversity Into Local Development Frameworks (ALGE, 2005).
  This states key documents to inform the LDF or DPD relating to biodiversity should lead in:  
  • Providing leadership in the community – increasing the profile of biodiversity across the authority's functions.
  • Examining opportunities to integrate biodiversity considerations into all relevant service areas and functions, and taking steps to implement the opportunities identified.
  • Management of local authority land holdings. A compliant authority will manage its own sites in a way that is sensitive to biodiversity.
  • Making efforts to raise awareness of all staff, managers and elected members with regard to biodiversity issues.
  • Demonstrating a commitment and contribution to key local biodiversity initiatives, such as LBAPS and contributing to delivery of outcomes, for BAP listed priority species and habitats and LBAP listed species and habitats, where appropriate.
  • Use of information and data and demonstrating progress against key biodiversity indicators.
  • Progress against any biodiversity indicator included in the local government performance framework.
The Local Government Association's Position Statement on Biodiversity The Local Government Association Position Statement, welcomes the “…identification of local authorities…to provide a lead for the Local Biodiversity Action Plan (LBAP) process”


Does it mention the Council's earlier Sustainability objective?

  Checklist : Council Strategy objective  

Sustainability Strategy, 2002 , states the objective: published by Brighton & Hove City Council (2002)

'To achieve our local targets set out in the Sussex Biodiversity Action Plan'  


Does it refer to the other Sussex BAPs?

  Checklist : Sussex Biodiveristy Action Plans  
Sussex Urban Habitat Action Plan, objectives include: The Sussex Urban HAP, 2001, Biodiversity Partnership
  • All householders to enhance the biodiversity of their own gardens.
  • Identify all habitats and species in urban areas that require action…
  • All people to have access to advice, information and training on biodiversity in urban areas…
Sussex Biodiversity Opportunity Areas, our area includes: Objectives highlighted in Biodiversity Opportunity Areas, 2009, produced by the Biodiversity Partnership.
  # 32: Brighton and Hove urban green network  
  # 33: Benfield to Hangleton  
  # 42: Stanmer and Ditchling Downs  
  # 43: East Brighton Downs  


5. Habitat objectives

Ensure Habitat Objectives include relevant habitats across the whole jurisdiction, not just the easy areas such as ‘School Grounds'. Recently the ' Brighton and Hove Habitat Audit 2007- 2009' identified:

Habitat Feature (arranged by total area size)
Area (Ha)
1. Arable and horticulture
2. Built-up areas and gardens
3. Broadleaved woodland
4. Transport corridor associated verges only
5. Scrub woodland
6. Semi-natural dry grasslands and scrubland
7. Littoral chalk
8. Transport corridor with natural land surface
9. Other littoral sediment
10. Mixed woodland (broadleaved and yew)
11. Chalk grassland
12. Grassland, possibly unimproved
13. Brackish standing water with no sea connection
14. Neutral grassland
15. Maritime cliff and slopes
16. Saline lagoons
17. Other littoral rock
18. Mudflats and sandflats not covered by sea water at low tide
19. Other standing open water and canals
20. Open water (standing/running not specified)
21. Coastal vegetated shingle
22. Standing open water and canals
23. Boulders and rock above the high tide mark
24. Estuary saline water


Are the following ‘Habitats' included?
Particularly 'Urban areas' as this is THE key area which must not be omitted from the LBAP. About 25% of land is currently within the 'urban area boundary', this will increase once building on the countryside (now termed 'urban fringe') starts.

There is tremendous connectivity between private gardens and opportunities to achieve biodiversity objectives, encourage local awareness of wildlife and to engage residents in raising the status of Brighton's biodiversity. Local awareness and understanding is one of the key objectives of the UKBAP.

  Checklist : Habitats to include  
Wood-pasture and parkland  
Chalk grassland Internationally important
Mesotrophic Grassland Areas of grassland that are not strictly calcareous; examples, Hove Lagoon, Spiranthes spiralis grassland near Roedean.
Open standing water Larger than garden 'ponds'
Ponds Typically in private gardens
Coastal vegetated shingle Globally restricted habitat
Maritime cliff and slope  
Brighton Marina Including maritime and intertidal areas; eg: for sea horse, sponges, ringed plover, former Polygonum maritimum.
Urban areas, particularly important are: This is THE key area which must not be omitted from the LBAP.
Geologically and Geomorphologically important areas Specifically included in PPS 9, but often missed out.


Regarding Gardens: from 'No Nettles Required: The truth about wildlife gardening'

Ken Thompson, 2006. Eden Project Books , ISBN: 978 1 905 081114 4

This is an interesting non-technical book, Dr Thompson writes:

"….gardens tend to be forgotten. ...since gardens are outside any form of statutory control and it's impossible to know what lives in them. Gardens are a vast resource, but if you don't know what's in them, and you couldn't do anything about it even if you did, you're likely to pretend they don't exist, and that's what the official attitude has been.

Gardens are good wildlife habitat in themselves, and they join up to form a giant, interlinked network that clearly doesn't need much help from railways or canals. This emphasis on corridors not only distracts attention from the gardens that surround them but also makes wildlife gardeners who don't have a corridor at the bottom of the garden feel as if they are wasting their time.

To sum up, up to a third of the entire UK invertebrate fauna occurred in [...an urban Sheffield] garden. Although it's clear that gardens are already extremely rich in wildlife, and that they can provide a home for perhaps half of Britain's native invertebrates, we also know that much of the potential of gardens as wildlife habitats remains untapped.

p.170   Reconnecting with nature

Half the world's population lives in towns and cities. In Britain the proportion is more like 90%. For most of us food comes shrink-wrapped from the supermarket and the closest we get to wildlife is a David Attenborough documentary. We are all born with an innate affection for living things ['biophilia'], an instinctive biophilia, which can be either stifled or nurtured by our early experiences.

...many children now grow up without forging any close personal bond with their local flora and fauna.

What can be done to reconnect people with the natural world? In fact anyone with a garden has their own nature reserve, literally on the doorstep. You can develop a close personal relationship with your wildlife and observe its changing with the seasons."

6. Species objectives

It is usually stated that species conservation depends upon successful habitat conservation. However a closely grazed downland turf which suits adonis blue butterflies presents a desert to crickets and grasshoppers, including the wartbiter.

Last century there were many species sharing the land across Brighton and Hove with us (refer to the species listed in Local Biodiversity Action Plan for Brighton & Hove, May 2003). Many of these are now locally extinct, or perilously close to extinction. Locally, important biodiversity species hanging on include:

  Checklist : Species  
All bat species, especially Found in buildings, churches and trees
  • Long-eared bats
  • Pipistrelle
  • Serotine
Wartbiter cricket Decticus verrucivorus Found on the Downs
Dormouse Muscardinus avellanarius     
Adonis blue butterfly Polyommatus bellargus  
pheasants-eye Adonis annua                       
red star-thistle Centaurea calcitrapa     
cornflower Centaurea cyanus  
white helleborine Cephalanthera damasonium a woodland orchid
narrow-leaved helleborine Cephalanthera longifolia      a woodland orchid
basil thyme Clinopodium acinos  
frog orchid Coeloglossum viride a downland orchid
chalk eyebright Euphrasia pseudokerneri  
red hemp-nettle Galeopsis angustifolia  
early gentian Gentianella amarella ssp. anglica only found in England
juniper Juniperus communis  small colony remains on the Downs
pennyroyal Mentha pulegium on the edge of ponds
fly orchid Ophrys insectifera   
early spider orchid Ophrys sphegodes  
burnt orchid Orchis ustulata      
corn buttercup Ranunculus arvensis  
shepherd's needle Scandix pecten-veneris grows on old walls
field fleawort Tephroseris integrifolia  
spreading hedge parsley Torilis arvensis  
round-headed rampion Phyteuma orbiculare also called 'Pride of Sussex'



John Patmore  
Preston Park
December 2010

Update: 22 May 2014