We understand that after 15th July 2020, due to the status of the Local Plan and the apparent lack of a 5 year housing supply, the District may be vulnerable to planning applications for housing in inappropriate locations. Approvals may lie outside the District Council’s control due to appeals determined by Central Government. We are disappointed that the District Council should find itself in this position and struggle to accept the damage that this situation is likely to cause. However, we are realistic enough to recognise that an effort has to be made to exert some control over the location of new housing development. We note the safeguards proposed in the Interim Housing Policy Statement but have concerns about their application.

We suggest three alterations.

POINT 1
Para 6.2 - The role of Settlement Hubs and Neighbourhood Plans
The Policy steers development towards Settlement Hubs, and to a lesser extent Service Villages, and will allow development on land adjoining but outside the approved settlement boundaries (Criteria 1, 2 and 3). This will remove the certainty fundamental to Neighbourhood Plans which aim to contain development within settlement boundaries. As a result Neighbourhood Plans will lose their credibility. Local residents and the volunteers who have put so much work into preparing both “made” Plans and the current reviews, are likely to be very disillusioned. The supporting text (paragraph 3.3) acknowledges that Neighbourhood Plans are part of the Development Plan but we consider that, at the very least, the Policy should do the same and require that they be taken into account on a par with the Local Plan.

Recommend The supporting text in paragraph 6.2 requires reference to be made to “adopted and emerging Local Plan policy and evidence” but we consider that it should read “ adopted and emerging Local and Neighbourhood Plan Policy and evidence”.


POINT 2
Para 6.2 Criteria 1 – Settlement Boundaries
If approval is granted for a site “contiguous with an identified settlement boundary” it is not clear whether that boundary is automatically re-defined to include the permitted site. If it is, this could lead to creeping incrementalism with a series of adjoining sites being permitted extending ever further into the surrounding rural area. Presumably extensions to settlement boundaries must stop somewhere. We suggest :-

Recommend (Para 6.2 Criteria 1) “The site boundary in whole or in part is contiguous with an identified settlement boundary as approved in the relevant made Neighbourhood Plan or the Site Allocations Development Plan Document (ie at least one boundary must adjoin the settlement boundary or be immediately adjacent to it)”


POINT 3
Para 6.2 Criteria 5 - Chichester Harbour Area of Outstanding Natural Beauty

We understand that National Parks and Areas of Outstanding Natural Beauty enjoy the same level of protection in national planning policy. The difference in the context of this proposed Interim Policy is that while the SDNP is its own Planning Authority, Chichester District is the Planning Authority for the Harbour AONB and determines proposals for development within the AONB boundary. The Interim Policy should recognise this. While development within the Harbour AONB cannot be ruled out, applicants should be made aware that the AONB is distinguished from the rest of the District due to international, national and local designations and is also accorded the highest status of protection In relation to landscape and scenic beauty (NPPF paragraphs 171 & 172).

We recall the last CDC Interim Policy “Facilitating Appropriate Development: 2012 - 2014”. It was similar in many respects to this one, and in practice encouraged development on some small high value sites within the AONB, which would not normally have been permitted, and which provided small numbers of expensive private housing without any affordable housing contribution. We would not wish to see this outcome repeated.

Recommend (Para 5 – last line) “……..……….and the Chichester Harbour AONB. Land within the Chichester Harbour AONB has the highest status of landscape protection, and proposals must also be shown to contribute to and enhance the quality of its biodiversity that has been recognised by international, national and local designations.”