The level of development anticipated
Comment
A27 Chichester Bypass Mitigation Supplementary Planning Document - August 2023
Representation ID: 6346
Received: 17/10/2023
Respondent: Fishbourne Parish Council
Pleased to see the commitment that all new dwellings, whether planned or unplanned, will count towards the cap on new homes
Pleased to see the commitment that all new dwellings, whether plannned or unplanned, will count towards the cap on new homes
Object
A27 Chichester Bypass Mitigation Supplementary Planning Document - August 2023
Representation ID: 6409
Received: 01/11/2023
Respondent: Obsidian Strategic AC Limited, DC Heaver and Eurequity IC Ltd
Agent: Quod
With regards to paras 4.9 and 4.10:
The Local Plan Evidence base used to inform the SPD considered assessment of development at 535dpa which forms the draft Local Plan. However, the evidence that is presented also considered a sensitivity test of 700dpa, concluding that the same A27 mitigation package could accommodate this higher level of growth in a similar
manner.
To base the SPD on evidence that has not been properly examined (through EIP) is premature and risks disproportionately loading infrastructure requirements on development that comes ahead of the adoption of the Plan and as such is premature. The A27 contribution
formula is intrinsically linked to the level of growth promoted in the draft Local Plan, and so if this increases, the contribution calculation would need to be amended to reflect this. This approach is contrary to the PPG which states that SPDs should build on advice and guidance
in the Local Plan. Coming ahead of the Local Plan but basing its assessment on the emerging strategy is unsound on this basis.
We write on behalf of Obsidian Strategic Asset Management Limited, DC Heaver and Eurequity Ltd
in response to the consultation on the Chichester District Council A27 Chichester Bypass Mitigation Supplementary Planning Document.
We are concerned that Chichester District Council (CDC) is preparing and attempting to adopt a Supplementary Planning Document (SPD) before the emerging Chichester Local Plan has been examined by a planning Inspector. For this reason, we object to the draft SPD.
In attempting to adopt an SPD before the draft Local Plan has been examined, CDC are relying upon an evidence base that has yet to be tested or considered sound by an Inspector. Given this, CDC are failing to act in accordance with the Planning Practice Guidance that requires SPDs to “build upon and provide more detailed advice or guidance on policies in an adopted plan [our underlining].”
In addition to this, we object to the draft SPD’s methodology for calculating planning contributions.
This methodology is flawed, disproportionate and not supported by evidence. The proposed
methodology for calculating planning contributions only focusses on residential uses within the district
and fails to reflect the impact of other forms of development.