Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Representation ID: 4596

Received: 16/03/2023

Respondent: Chichester Harbour Trust

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Chichester Harbour Trust objects to the proposed housing allocations, in particular with reference to the allocations below which principally affect Chichester Harbour AONB:
A11 Land at Highgrove Farm, Bosham
A13 Southbourne Broad Location for Development
A12 Nutbourne and Hambrook (Chidham and Hambrook Parish)

Change suggested by respondent:

The housing allocation for the east-west corridor should be reduced, with particular reference to:
A11 Land at Highgrove Farm, Bosham
A13 Southbourne Broad Location for Development
A12 Nutbourne and Hambrook (Chidham and Hambrook Parish)

Full text:

The Chichester Harbour Trust objects to the proposed housing allocations, in particular with reference to the allocations below which principally affect Chichester Harbour AONB:
A11 Land at Highgrove Farm, Bosham
A13 Southbourne Broad Location for Development
A12 Nutbourne and Hambrook (Chidham and Hambrook Parish)

The combined allocation for these sites is 1,595, and should be considered in combination with the 1,600 houses allocated in A6 West of Chichester, and 30 at Fishbourne Parish leading to a total of 3,225. Taking into consideration the 2,100 houses planned at Havant Borough Council's strategic site at Southleigh, this gives a total figure of 5,325 houses between Chichester and Havant in the gap between the AONB and National Park. This represents major development within the 5.6km zone of influence for Chichester Harbour SSSI.

It is our observation that these proposed allocations represent a conflict with the policies outlined in the Plan chapter 4 on the natural environment, which makes it hard to justify the soundness of the Plan, particularly:
Policy NE2 Natural Landscape
Policy NE3 Landscape Gaps between settlements
Policy NE6 Chichester’s Internationally and Nationally Designated Habitats
Policy NE7 Development and Disturbance of Birds in Chichester and Langstone Harbours, Pagham Harbour, Solent and Dorset Coast Special Protection Areas and Medmerry Compensatory Habitat
Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty
Policy NE16 Water Management and Water Quality

Our specific objections to the allocations at A11,12 and 13 relate to:
- the impact on the sensitive landscape setting of the AONB and loss of open views to the South Downs
- the over-reliance on developing greenfield sites, mostly on grade 1 & 2 agricultural land leading to concerns about unsustainable loss of countryside and impact on food production and food security
- the inadequate waste water treatment infrastructure and lack of funded improvements in the timescales required
- the additional flood risk and ground water issues raised by construction on low lying coastal plain sites
- the impact on biodiversity and species that rely on the interconnectivity between the protected landscapes
- the additional recreational pressure of over 5,000 homes (potentially over 10,000 people) within the SSSI zone of influence
- the inevitable increase in air, noise, and soil pollution

It is noted that in the case of A12 and A13, the location of the development is not yet clear as the sites will be determined through the neighbourhood planning process, however it is hard to see how the concerns raised above would not be relevant.

Overall, we feel that the Plan does not reflect emerging government rhetoric (soon to translate to policy through the NPPF) about overdevelopment of countryside in the South East of England, and that the timescale is not compatible with the NPPF review which may lead to an alternative method of determining housing allocations in the district. For this reason we find the plan to be unsound.

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