Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Representation ID: 4321

Received: 14/03/2023

Respondent: Mr Matthew Rees

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Para 5 of page 256 it is not legally compliant in reference to "community orchard". The policy deprives residents of amenity value of the wildflower meadow and is incompatible with para 629 and it does not promote health and wellbeing (sustainability requirement), it is not sound nor justified because it could become a source of anti-social behaviour causing detriment to Saxon Meadow residents. It is not justified because there are no private gardens for the 28 dwellings and a more appropriate plan is to support allotment holders to cultivate fruit trees in the proposed site for allotments if they so desire.

The plan is not justified or legally compliant because there are missing references to Policy P11, in relation to the protection of the setting and views into and out of the area, and there are not sufficient provisions to ensure sufficient separation distances between Saxon Meadow and the new homes, or how the site plan will protect existing views to Chichester, Oving and the South Downs.

Change suggested by respondent:

Text below should be added and policies adjusted or implemented accordingly
Policy A14
Subject to an evaluation of the economic, social and environmental benefits of safeguarding 73 hectares of land to the west of Tangmere to provide agriculture and / or viticulture / hotticulture, the residual parcel of land to the west of Tangmere is allocated for residential development of not more than 1,000 dwellings, community facilities and open space If development were to proceed in this location it will be expected to address the following site-specific requirements:

1. Be planned as an extension to Tangmere village, that is well integrated with the existing village and provides good access to existing facilities

2. A range of types, sizes and tenures of residential accommodation to include specific provision to meet specialised housing needs, including accommodation for older people;

3. Incorporate new or expanded community facilities, including transforming the existing village centre into a new local centre providing new village centre amenities and not reduce any of the existing amenities enjoyed by existing residents including the right of way to their properties and their meadow;

4. Make provision to accommodate a new two-form entry primary school and associated development, including provision for an early years setting and a special support centre. Further land shall be safeguarded to facilitate the potential expansion of the two-form entry primary school to three-form entry;

5. Incorporate open space and green infrastructure, including parks, playing pitches, sports pavilion and new allotments and community orchard located adjacent to the allotments and, for the avoidance of doubt, not on the land owned by Saxon Meadow Tangmere Ltd, enabling the relocation of the existing allotments at the Tangmere Military Aviation Museum.

6. Make provision for green links to Tangmere village, and the South Downs National Park and Chichester city. Opportunities should be explored for provision of integrated green infrastructure in conjunction with the other strategic sites to the east of the city;

7. Respect important existing views of Chichester Cathedral spire and reduce any impact on views from within the South Downs National Park, particularly sensitive locations such as the Tangmere conservation area itself, views of St Andrews Church Oving from Saxon Meadow, the Trundle and Halnaker Hill and protect the setting, including views into and out of the Tangmere conservation area, consistent with policy P11.

8. Subject to detailed transport assessment, provide primary road access to the site from the slip-road roundabout at the A27/A285 junction to the west of Tangmere providing a road link with no direct link to Tangmere Road to respect policies NE23, NE20, P16. Development will be required to provide or fund mitigation for potential off-site traffic impacts through a package of measures in conformity with Policy Tl (Transport Infrastructure) and T2 (Transport and Development);

9. Make provision for improved sustainable travel modes between Tangmere and Chichester city, in partnership with relevant authorities, including improved and additional cycle routes linking Tangmere with Chichester city, Shopwhyke and Westhampnett. Opportunities should also be explored for improving transport links with the 'Five Villages' area and Barnham rail station in Arun District; and CDC work with relevant authorities to deliver the reinstatement of a train stop to serve Tangmere and Oving on the existing rail line.
10. Conserve or enhance the heritage and archaeological interest of the site, the historic village and its setting (particularly that of the Conservation Area which includes a meadow that will not be divided into smaller lots) and the World War Il airfield, Commonwealth War Graves and other commemorative structures, including making provision for the relocation of existing allotment space to facilitate the potential expansion or relocation of the Tangmere Military Aviation Museum;
11. Occupation of development will be phased to address the existing issues of flooding at Church Lane, and requirements of existing dwellings, particularly in relation to drainage infrastructure at Saxon Meadow which must be improved by the developer given that these dwellings rely on soakaway across agricultural land for run-off. Strategic infrastructure will also include full adoption by Southern Water of the wastewater infrastructure at Saxon Meadow, and align with the delivay of infrastructure for adequate wastewater conveyance and treatment to meet strict environmental standards;
12. Proposals for the development should have regard to the West Sussex County Council Minerals Safeguarding Area and associated guidance.

Full text:

There is much to commend in this document and the supporting technical documents that accompany it, and I have listed in the appendix to this letter 26 such paragraphs and policies. I am happy for my support to be registered against these sections of your consultation document. There is also much upon which I must represent a concern, so I attach representations relating to 22 paragraphs or policies.

I am happy to participate in a hearing session, and I would flag at this stage that the common theme that links all of these representations is the need to safeguard the natural and built environment in and around Saxon Meadow, Tangmere from the risks of unsustainable development, I consider that the independent examiner should focus their review on the aspects of the local plan that relate to this matter.

Appendix 1: list of policies that I support
1. P14, 1.23, 1.24: Duty to cooperate
2. P24, para 2.30 "the council declared a climate emergency in July 2019"
3. P24, para 2.32 — "all proposal for new development should be considered in the context of a climate emergencV'
4, P30: Objective 2: natural environment: "development will achieve net gains in biodiversity'
5. P43, 4.1 "National policy promotes increasing energy efficiency, the minimisation of energy consumption and the development of renewable energy sources"
6. P43, 4.3: "Some renewable energy projects provide significant opportunities to enhance biodiversitV'
7. P53, Policy NE5: Biodiversity and Biodiversity Net Gain
8. P62, Para 4.42: Hedgerows and some types of woodlands are identified as a priority habitat
9, P62, Policy NE8: Proposals should have a minimum buffer zone of 15 metres from the boundary of ancient woodland or veteran trees to avoid rood damage (known as the root protection area)
10. P68, Policy NEIO: Criteria for Development in the Countryside - Does not prejudice viable agricultural operations or other viable uses
11. P80, Para 4.91: There are serious concerns about the impact of flooding, both in respect of current properties at risk but also the long-term management of the area.
12. 4.92: any development in the plan area must therefore have regard to flood and erosion risk.
13. 4.94: built development can lead to increased surface water run-off; therefore, new development should include SuDS to help cope with intense rainfall events
14. P81, Para 4.96: Environment Agency consent is required for any works within 16 m of tidal waters and 8m of fluvial watercourses in line with the Environmental Permitting Regulations 2016. This strip is required for access. The policy includes a setback requirement to ensure this access strip is not obstructed.
15. P80, 4.92, Any development in the plan area must therefore have regard to flood and erosion risk, now and in the future, by way of location and specific measures, such as additional flood alleviation, which will protect people, properties and vulnerable habitats from flooding. Recent changes to national guidance highlight the importance of considering flood risk from all sources, and this is particularly significant for the plan area as large parts of it are at risk from groundwater flooding, which needs to be recognised in development decisions alongside the well-established risks in relation to tidal, fluvial and surface water flooding. Appropriate mapping of all sources of flood risks is still evolving, and is likely to develop further over the plan period
16. P93, Policy NE20 Pollution: Development proposals must be designed to protect, and where possible, improve upon the amenities of existing and future residents, occupiers of buildings and the environment generally. Development proposals will need to address the criteria contained in, but not limited to, the policies concerning water quality; flood risk and water management; nutrient mitigation; lighting; air quality; noise; and contaminated land. Where development is likely to generate significant adverse impacts by reason of pollution, the council will require that the impacts are minimised and/or mitigated to an acceptable level within appropriate local/national standards, guidance, legislation and/or objectives.
17, P94, 4.127, Light pollution caused by excessive brightness can lead to annoyance, disturbance and impact wildlife, notably nocturnal animals. The design of lighting schemes should be carefully considered in development proposals to prevent light spillage and glare.
18. P94, 4.128, Dark skies are important for the conservation of natural habitats, cultural heritage and astronomy. The plan area includes three 'Dark Sky Discovery Site' designations, all located within the Chichester Harbour AONB; Eames Farm on Thorney Island, Maybush Copse in Chidham; and north of the John Q Davis footpath in West Itchenor. Development within or directly impacting these areas will be subject to particular scrutiny in terms of their impact on dark skies. The entire SDNPA area is also declared as an International Dark Sky Reserve. Development directly impacting this area will be subject to similar scrutiny.
19. P96, Policy NE22 Air Quality
20. P97, Policy NE-23 Noise
21. P142, Para 6.29, Amenity: Private space, shared space and the design quality and construction of communal spaces all contribute to amenity
22. P155-6, Policy P11:Conservation Areas "protecting the setting (including views into and out of the area)"
23, P55, Para 4.26 - The council is under a legal duty to protect designated habitats, by ensuring that new development does not have an adverse impact on important areas of nature conservation, and by requiring mitigation to negate the harm caused.
24. P58, Para 4.33 The council is under a legal duty to protect their designated bird populations and supporting habitats
25. P95, Para 4.129 The council has a duty to review and assess air quality within the district
26. P301, Conservation Area: An area of special architectural or historic interest, designated under the Planning (Listed Buildings & Conservation Areas) Act 1990. There is a statutory duty to preserve or enhance the character, appearance, or setting of these areas.

Attachments: