Interim Policy Statement for Housing Development

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Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3619

Received: 09/07/2020

Respondent: Mr Nicholas Pyke

Representation:

1. Government's standard methodology is not based on local need - the figure is too high
2. Sustainable locations should take account of flood risk/climate change.
3. Highgrove Farm allocation does not provide for gradual growth of Bosham, nor is appropriate in scale to Bosham
4. Development causing coalescence along A259
5. Highgrove Farm will compromise Chichester Harbour and the National Park
6. 200m buffer zone around wildlife corridors not sufficient - should be 500m. Undeveloped land west of Chichester should be safeguarded.
7. Support criteria 9 but should be enforced

Full text:

My comments on the Draft Interim Policy Statement for Housing are as follows.
1.3 The CLPKP will continue to form part of the statutory development plan until the LPR is adopted, however Planning Practice Guidance1 makes clear that where local plans have been adopted more than 5 years ago, the housing target against which the housing supply and delivery will be assessed should be derived from the Government’s standard methodology for assessing housing need. From the 15 July 2020 (five years from the date of adoption of the CLPKP), the Council’s housing supply and housing delivery will be assessed against the figure of 628 dwellings per annum, rather than the previously adopted housing target of 435 dwellings per annum.

Comment 1 - The Government's standard methodology for assessing housing need is a centralised method of assessment, which is neither based on an actual local assessment of need, nor on the amount of land available, nor the suitability of development in respect of harm to environment and wildlife it supports. This is particularly pertinent to the situation in Chichester where so much of the District is either AONB or National Park. I believe that some 67% of the District is occupied by the SDNP (South Downs National Park), and a further 3.5% is occupied by the CHAONB (Chichester Harbour Area of Outstanding Natural Beauty). This leaves some 30% for all the housing and much of this land lies between the two designations creating the setting for them. This is especially true of the ‘land to the west of Chichester’ and should mean that any proposed development in this area is very limited. I believe that the figure for the District is far too high given the above constraints and every effort should be made to seek to reduce these.

2.3 This statement aims to provide interim guidance which will apply until the Council considers it has a five-year supply of housing in line with Government guidance. The intention is for the Council to be able to guide development to appropriate and sustainable locations using this document to assist in the consideration of planning applications.

Comment 1 – Sustainable locations needs to take account of the long term and in this regard the potential effects of climate change and rising sea levels should be taken into account. The Environment Agency advises Councils to plan for floods and coastal risk up to 2065. The NPPF states that development in areas of risk is INAPPROPRIATE and should be avoided. This would further reduce the area which is available for new housing.

4.6 Sites should be of a scale and density appropriate to the adjoining settlement. Smaller scale sites, that provide for the gradual growth of settlements, are more likely to be suitable than sites that would significantly change the character of a place. Developments adjoining smaller settlements will be expected to be smaller in scale than those that might be suitable for the extension of Chichester or the Settlement Hubs, with their larger sizes and range of facilities. The Council may support higher density development in settlements with greater facilities and accessibility.

Comment 1 – this should apply to the possible allocation at Highgrove Farm (policy AL7) which would be increasing the scale of Broadbridge by over 75%. This clearly is not appropriate in scale to the adjoining settlement and does not provide for the “gradual growth of settlements” and would significantly change its character.

6.2 To provide clarity for applicants and other parties, the following criteria set out what the Council considers good quality development in the Chichester Local Plan area, with reference to adopted and emerging Local Plan policy and evidence.
2. The scale of development proposed is appropriate having regard to the settlement’s location in the settlement hierarchy.

Comment 1 – this should apply to the possible allocation at Highgrove Farm (policy AL7) which would be increasing the scale of Broadbridge by over 75%. This clearly is not appropriate in scale to the adjoining settlement

6.2 (3) The impact of development on the edge of settlements, or in areas identified as the locations for potential landscape gaps, individually or cumulatively does not result in the actual or perceived coalescence of settlements, as demonstrated through the submission of a Landscape and Visual Impact Assessment.

Comment 1 - The concentration of development along the A259 west of Chichester has already compromised the distinctiveness of the villages along there and the development proposed along this road further closes the gaps between villages.

6.2 (4) Development proposals make best and most efficient use of the land , whilst respecting the character and appearance of the settlement.

Comment 1 – the best use of grade 1 and grade 2 farmland should be to keep it in productive agricultural use.

6.2 (5) Proposals should demonstrate consideration of the impact of development on the surrounding townscape and landscape character, including the South Downs National Park and the Chichester Harbour AONB and their settings. Development should be designed to protect long-distance views and intervisibility between the South Downs National Park and the Chichester Harbour AONB.

Comment 1: Bosham and the proposed Highgrove Site (AL7) lie in a narrow gap between the SDNP and CHAONB. From the Downs you can look out towards the Harbour and from the AONB you can see the Downs and Kingley Vale. Development on this site would greatly compromise this landscape. Any development in this area will compromise the setting of the AONB and the intervisibility between the CHAONB and the SDNP. This is supported in the report prepared for the Chichester Harbour Conservancy entitled ‘A Study of the Views connecting the Protected Landscapes of Chichester Harbour and the South Downs and the AONB views towards Chichester Cathedral’.

6.2 (6). Development proposals in or adjacent to areas identified as potential Strategic Wildlife Corridors as identified in the Strategic Wildlife Corridors Background Paper should demonstrate that they will not affect the potential or value of the wildlife corridor.

Comment 1: Wildlife connectivity between the SDNP and CHAONB is both historic and essential for the survival of species. Wildlife corridors need to be wide enough and connect with both streams and hedgerows. The proposal for only a 200m buffer zone around the proposed wildlife corridors is not enough. Given that the SDNP and the CHAONB have nationally significant status for environmental protection, linking these sites is of national significance (Glover Review). The scale of protection therefore should be on the Regional Scale of 500m and not the local scale of 200m. Effectively this means that undeveloped land west of Chichester should be safeguarded from further development.

I support your aspirations in Para 9 Development proposals shall be of high quality design that respects and enhances the existing character of settlements and contributes to creating places of high architectural and built quality. Proposals should conserve and enhance the special interest and settings of designated and non-designated heritage assets, as demonstrated through the submission of a Design and Access Statement but despair of the ability of volume builders to achieve this and the ability of the Planning Departments to enforce this.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3620

Received: 10/07/2020

Respondent: Caroline Tilbury

Representation:

Criteria 6 - mature trees should also be given top priority regardless of in a corridor or not
Criteria 8 - the standards are too low. Should include the facilitation of renewable community supplies and banning home boilers. Solar sources to be included, and trees.
Use constructed reed beds for local water treatment.

Full text:

6. Wildlife corridors: Value of mature trees should be given top priority whether they are within recognised corridor or not since they will represent a corridor centre where there is no other evidence.
8. Minimising energy consumption to achieve 19% improvement and maximising energy supplied renewables to 10% is very irresponsibly low. They are disgracefully low improvement targets in view of the climate emergency and the huge advances of renewable energy. The statement should include the facilitation of renewable community supplies and banning of individual home boilers for heating. This alone would reduce energy consumption and personal energy costs. Solar panels, Solar tiles and or Solar glass in windows should be mandatory now as they are in many parts of France. Trees should also be included as much as possible in every development to boost CO2 sequestering cooling effects for residence and support the rapidly diminishing wildlife.
I would also like to suggest making small communities more individually resilient and include more encouragement to have local water treatment by constructed reed beds, which are exceptionally low tech, low energy but are a highly efficient system for treating local black water now. They produce clean water to EU bathing water standards.”

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3621

Received: 08/07/2020

Respondent: Clive and Christine Grinyer

Number of people: 2

Representation:

No further development in Birdham - impact on infrastructure, character and wildlife

Full text:

As residents on Bridham Village for 20 years, we are shocked and appalled by the recent building developments in Bell Lane and Old Common Close off the A286. This feeder road itself is already inadequate for the type and volume of traffic experienced in the summer months. The sewage and other infrastructures are already overburdened.
This lovely village cannot host any more large building projects without losing something of it's character which sits so well in this AONB and harbour setting.
We have just recently had close encounters with a shellduck family with seven ducklings, deer, foxes, field mice and pigmy shrews. There are frequent visits here from the Great spotted Woodpecker and Green Woodpecker (sometimes together) and a variety of other birds.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3622

Received: 08/07/2020

Respondent: Mr Daniel Penfold

Representation:

Concerned at development in Birdham - impact on infrastructure and risk of flooding

Full text:

I am writing to express my concern with the draft Local Plan.

As a resident and home-owner residing in Bridhm I am distressed to see that areas of the surrounding farmland are being considered for large scale development.

As I am sure you are aware, the local infrastructure is already under strain with volumes of traffic far above those sustainable on the panisual and regular flooding / drainage issues prevalent across the village. Any development in or around the Birdham would only serve to exacerbate these problems.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3623

Received: 10/07/2020

Respondent: Mr Martin Windebank

Number of people: 2

Representation:

Object to proposals:
1. loss of agricultural land
2. flood risk
3. no improvements to local infrastructure

Full text:

Whilst we support the building of new houses we object strongly to the ill thought out proposals as presently advised.

1. Some of the proposed developments eg: Highgrove, Bosham are on prime agricultural land. With an increasing population and ever greater demands to become self sufficient this is in our view madness.

2. Many of the proposed developments are on the Chichester flood plain. The line that major flooding is a one in two hundred year event is delusional and will be made worse by any further development.

3. There seem to be no firm proposals for improving/increasing local infrastructure. Schools and surgeries are generally over subscribed and had any of the bureaucrats and developers who proposed these developments had to take themselves or their children to A and E in St Richard’s they would not dream of building new homes without providing adequate hospital facilities for the existing population.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3624

Received: 06/07/2020

Respondent: Mr Nicholas Boyd

Representation:

Enlarge the A286 before building more houses. Upgrade sewerage infrastructure.

Full text:

• The A286 road, between West Wittering etc and Chichester, is so narrow that anyone cycling holds up Cars, Lorries and Emergency Vehicles indefinitely when there are cars coming in the other direction.

• Due to the popularity of cycling; stimulated by British success at the Olympics and Tour de France; there are many more colourful Cyclists on the road.

• When there are young children of 4 or so, are on the road on their tiny bikes; cycling in convoy with their protective parents; they actually slow the slew of cars behind them almost to crawl.

• PROPOSAL: Surely no more building should take place on the Manhood Peninsular until the A287 has been widened, to allow (at the very least) both one footpath and two dedicated cycle-lanes?

• Due to the popularity of the beach at West Wittering in the Summer, barely moving cars queue all the way back to, and actually onto the A27.

• That queue of cars only moves at the speed that the two WW Car Park barriers raise and lower to allow cars entry. How can this density of crawling cars and vans safely allow access by Emergency Vehicles?

• SUMMARY: First enlarge the A286, and then allow more house building. Then, while you allow more houses and therefore people, the existing (appalling) sewerage infrastructure is in real need of upgrading.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3625

Received: 09/07/2020

Respondent: Janis Tilling

Representation:

- No new housing until existing stock has been protected from floodrisk. Only consider sites above a safe level.
- Only consider brownfield land for development.
- Infrastructure should be in place before development.

Full text:

I am writing to comment on the Council's Draft Statement for the following reasons:

• Flooding issues must be front and centre of all of this. New houses cannot be built until existing stock has been
protected. This is one of the highest risk areas in the country and it is ridiculous to even consider building here
before sea defences have been put in place. Building houses that will be unable to get house insurance, and
are likely to be inundated within 40 years is immoral. Only sites above a safe level should be considered and
Chichester’s harbour area and coastal plain are too vulnerable already.

• Once the land of the South Downs National Park and the AONB has been subtracted from the equation there
is insufficient space left to provide building land for all this development. This will lead to calls to build on farm
land, which would be completely bonkers as we are heading for food shortages soon and need more farming
space not less. We need to become more self-sufficient, not be increasing the food-miles. Filling in the strategic
gaps between villages along the A259, for example, is a terrible prospect along with compromising the landscape
and view from and to the South Downs. Only brown field sites should be considered for development.

• 'First things first' should also be the plan for dealing with the waste water from all this development. The pollution
in the harbour is dreadful already without having extra from all these potential new houses. Proper infrastructure
needs to be in place before any new building takes place.

Essentially the proposed new development of 12,500 house by 2035 is inappropriate, unsustainable and unrealistic
without large infrastructure investment. This needs to be sorted first before rushed, back of the envelope plans are
pushed through.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3626

Received: 09/07/2020

Respondent: Mr Brian Wort

Representation:

Object to further development in Birdham - poor infrastructure and impact on wildlife and AONB

Full text:

As a resident of Birdham village I must strongly object to any further proposed housing development in the area.
Birdham is a quintessential English village of a design that is fast disappearing from our landscape. I believe the Council and indeed all of us have a moral duty to protect it and others like It, to preserve our culture and heritage not just for now but for future generations.
Apart from the moral aspect there are other important issues to consider. The infrastructure in all aspects is woefully inadequate to support further development. The damage to wildlife and Areas of Outstanding Natural Beauty would be immeasurable and lost for ever.
When reviewing the Local Plan I would urge Chichester District Council to consider the serious impact any further development would have on Birdham village.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3627

Received: 10/07/2020

Respondent: Mr Graham Salmon

Representation:

Object to development at Pottery Fields - impact on infrastructure, wildlife and quality of life.

Full text:

I continue to be increasingly concerned regarding the proposal by the parish council to include Pottery Fields at NUTBOURNE in their suggested development proposal.

Chidham and Hambrook parish council are quite open that this area cannot sustain further development,it being a narrow strip of land ,sandwiched between the A27 and the coast.

They however feel blackmailed by Planning regulations to offer what is a completely unsustainable local plan...which will lead to further overcrowding,traffic pollution loss of green open spaces of which there are few left, and serIous deterioration of quality of life for existing residents and tax payers.

Pottery Fields was rejected on appeal in 2014 by the government planners,and I and my neighbours were led to believe that this decision woUld be upheld until at least 2025.
We now find the the rules have been changed,and feel this is a completely unjust decision,having invested considerable sums in purchasing property adjacent to what is now proposed as a major development.
Financially,we will all lose considerable equity,but even worse,the quality of life for us ,and all residents locally will be severely affected.

The original refusal by the council and the Government Inspector, was made on the basis of “impact regarding proximity to the Harbour and South Downs AONB” and the connecting views between same.
Also, the need to keep a defined undeveloped space between NUTBOURNE and Southbourne.
Neither of those criteria have changed,and the “pareing down” by 50% of the undeveloped space is entirely cynical....no doubt next year it will be infilled on the basis of pressing need.

Traffic pollution is already a serious problem with long delays both at the “Tesco roundabout “ and at Southbourne . Water quality and nitrates into Chichester Harbour is already a concern.
Simply handing green field sites To Developers is akin to selling off the family silver.
Very soon the quality of life for all residents will be so affected that all the reasons people want to live here will be void
Pottery Fields,is a “natural wildlife corridor” linking the downs and the harbour. It is home to an abundance of wildlife including kestrels and deer. Numerous geese and ducks overfly the area daily and have done probably for hundreds of years. They cannot navigate by maps setting out wildlife corridors by local authorities,no matter how well (or cynically)intentioned.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3628

Received: 08/07/2020

Respondent: Mr David Gibbons

Representation:

Object to development in Birdham - impact on infrastructure and flood risk

Full text:

The proposed development for 250 houses on the land opposite Birdham Store should not go ahead for the following reasons:

The entire field was under water during and for many days after prolonged rainfall earlier in the year and in previous years.

The pumping station in Pinks Lane is failing to cope with heavy rainfall since the Tawny Close and The Pines developments were built. Adding more housing could cause serious problems.

Additional pressure on GP surgeries and St Richards.

Increased traffic congestion and subsequent increased pollution levels.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3629

Received: 06/07/2020

Respondent: Mrs Nikki Miller

Representation:

Document unsustainable:
1. does not account for climate change/ flood risk
2. proposes unsustainable construction
3. impact on ecosystems
4. ignores need for development to be nutrient neutral
5. ignores need for effective placemaking

Full text:

The Draft Interim Housing Policy Statement is unsustainable in these respects:
1. It takes no account of climate change and the Environmental Agency’s own prediction as to flooding levels in our area. Indeed, The National Policy Planning Framework states that “development in areas of risk is inappropriate and should be avoided”.
2. It proposes construction of houses in an unsustainable manner. Building must get much closer to being carbon neutral. It must be much more energy efficient than units currently being built.
3. It will impact on precious eco systems; of most significance our five chalk streams (to remind: there are only 210 of these worldwide). All must be included in the CDC’s plan. One, Newells Lane, has been omitted entirely. There is only a 200m buffer zone around the others. They are essential to continue the historic connectivity of the SDNP and CHAONB and the concomitant species survival on which, in turn, depends human existence.
4. It largely ignores that in this area all future development must be nutrient neutral. A recent study by Natural England into the condition of Chichester Harbour Site of Special Scientific Interest reports 80% of the area is classed as “unfavourable declining” with consequential disturbance to habitat and species, increased nitrates and coastal squeeze.
5. It currently ignores the need for effective place making. It does not plan, as it must, for the necessary infrastructure to be in place before development begins.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3630

Received: 13/07/2020

Respondent: Mr Peter Lansley

Representation:

Bewildered by Whitehouse Farm development demonstrating lack of regard for wildlife and environment and contradicts the Council's declaration of a Climate Change emergency.

Full text:

I share key areas of concern identified in the Local Plan Review as cited below:
Development proposals in or adjacent to areas identified as potential Strategic Wildlife Corridors as identified in the Strategic Wildlife Corridors Background Paper should demonstrate that they will not affect the potential or value of the wildlife corridor or compromise on environmental quality, and ensure high standards of construction in accordance with the Council’s declaration of a Climate Change Emergency.
I am, therefore, bewildered by the White House Farm housing development having received planning approval on a highly valued greenfield site opposed by many concerned residents reported in the local press demonstrating a complete disregard for the value of wildlife and environmental quality and contradicting the Council’s declaration of a Climate Change Emergency.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3631

Received: 09/07/2020

Respondent: Mr R S de Chair

Representation:

Development in Birdham should be in consonance with the existing village. Additional infrastructure capacity required.

Full text:

It seems particularly important for Birdham that developments receiving approval should be genuinely in consonance with the existing character of this particular environment. Infrastructure in the area is already under strain, and account has to taken of this, by ensuring that needed additional capacity is added commensurately with such approvals as are to be given.
It needs to be borne in mind that even relatively small sites - say with space foe 2 or 3 dwellings, could, in aggregate ,contribute significantly to the housing stock in the area, without becoming intrusive, and, just because they are not of the stature of sites offering 6 or more dwellings, should nevertheless be regarded as contributing towards the numbers required, and not ignored (as is understood to have been the case in the past) when assessing the degree of need for more housing.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3632

Received: 08/07/2020

Respondent: Mr Ron Green

Representation:

No further housing south of A27 until northern bypass.
Object to additional development in Birdham.

Full text:

Any increase in housing south of the A27 is absolutely unacceptable until the A27 Northern Bi-pass is approved.
Birdham
To consider increasing the size of Birdham by one third in a single development would completely change the character of this village and exacerbate the continued drainage and communication problems.
I object most strongly to any further large scale development in this village.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3633

Received: 10/07/2020

Respondent: Rosellen Mates

Representation:

1. No provision for basic infrastructure development
2. No accentuation on realistically affordable housing
3. There is inadequate provision of wildlife corridors
4. It takes no account of rise in sea level and climate change
5. No commitment to carbon neutral development.
6. Loss of agricultural land.
7. Damage to South Downs National Park and the Chichester Harbour
8. Suggest Council makes use of existing brownfield sites, empty commercial properties, and recognise the changing habits in shopping

Full text:

I do not believe this policy to be sustainable for these reasons:

• No provision for basic infrastructure development (that which exists is already at breaking point), most particularly provision for sewerage infrastructure/concentration on water quality. There would seem to be no plan to make this resilient and sustainable.
• No accentuation on realistically affordable housing
• There is inadequate provision of wildlife corridors ,inadequate protection of the very precious chalk streams - indeed one, Newells, is not in the plan at all.
• It takes no account of the continuing rise in sea level and climate change which will have a major impact on this area of the south coast which is at special risk of sustained flooding as well as adverse weather events
• There seems to be no commitment to sustainable or carbon neutral houses, contrary to national policy to be carbon neutral by 2030
• Destruction of agricultural land when the country needs to produce more of its own food.
• It would require excessive building between the South Downs National Park and the Chichester Harbour SSSI/RAMSAR site to the huge detriment of both

I would also urge the Council to make full use of all existing brown field sites, empty commercial properties, and recognise the changing habits in shopping and thus use of the centre of Chichester.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3634

Received: 05/07/2020

Respondent: Mr and Mrs Liney

Representation:

Housing target should be reduced to reflect loss of land to be built on in National Park

Full text:

Living East of Chichester city centre,like many of us not protected by being in The South Downs National Park ,I live in a constant state of fear ,over what pretty and pleasant area you will allow to be spoilt with mass building next, everyday I pass yet another place,that had trees fields ,hedging and wildlife gone forever.
Surely if a large part of our area is protected from being built on and quite rightly, logic should suggest that the target housing numbers should be reduced,for the smaller areas left not kept the same and ruthlessly packed into every space no matter the cost to our wildlife, or which villages are spoilt. I’m no expert just another person who loves this lovely area we live in but judging by the amount of traffic jams and the ridiculous amount of people all trying to cram themselves onto our beaches recently, should we really be encouraging thousands more people to come and live in this really very small city and mainly small village area.
I had hoped that the new faces in control of CDC would be different, and perhaps even stand up to the government with their unreasonable demands for more and more house building in every space they can be crammed in but it seems it will only stop when every once charming village is a mass of concrete.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3635

Received: 10/07/2020

Respondent: Shelley Gibbons

Representation:

Concerns about building 250 houses in Birdham - impact on infrastructure and drainage

Full text:

As a resident of Birdham I am concerned about some of the suggestions in the local plan.
Birdham is classified by CDC as a settlement village which should mean only modest development.
It appears that CDC feels the most likely site for development within Birdham, is an area that has the capacity for 250 houses. This plot of land has poor drainage and spends many months water logged. Drainage is a significant problem in Birdham, particularly on new developments. I live in Tawny Close and we have problems whenever there is heavy rain.
Historically in Birdham the majority of development has been small pockets of around 30 houses which I feel is acceptable but a big development will cause infrastructure problems, roads/traffic ( already a nightmare in the Summer months) plus the aforementioned drainage, both surface and sewage,

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3636

Received: 10/07/2020

Respondent: Mr and Mrs Sue and Geoff Talbot

Number of people: 2

Representation:

1. Para 6.2 - include reference to neighbourhood plans.
2. criteria 1 - amend wording to “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)”
3. criteria 5 - amend wording to "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.”

Full text:

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.”

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3637

Received: 09/07/2020

Respondent: Susie Alexander

Representation:

Object to additional development in Birdham - impact on infrastructure, and floodrisk

Full text:

I understand that you are considering permitting further large scale development in Birdham village.

You accepted our recent Neighbourhood Plan which, I think, covered our obligations as a village until 2021
with ongoing development in the village as I write.

There have been no improvements in the local infrastructure since our plan was delivered to accommodate
the expansion of the village which has already happened much less the proposed future expansion.

The village school is still full, traffic on the road still backs up behind a single cyclist and comes to a halt in
a long queue where the Selsey road joins the Birdham road & again at the Stockbridge roundabout, never
mind the summer traffic to & fro from the beach.

We still have flooding locally including at Whitehouse farm where, I understand, you may consider a major
housing development and sewage still bubbles up from manholes in the village after heavy rain.

You classify Birdham as a Settlement village, therefore not suitable for large scale development such as you
threaten and I agree with that classification. I object to your proposal for all the reasons I have listed.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3638

Received: 08/07/2020

Respondent: Mr Timothy Firmston

Representation:

Paragraph 2.3 - brownfield sites are most appropriate for development.
Paragraph 3.4 - test of IPS will be at planning inquiry
Paragraph 4.2 - provision of infrastructure should be in parallel with new development
Paragraph 4.5 - building where land is available may not result in sustainably located sites
Paragraph 4.6 - only allow sites that do not significantly change the character of a place
Paragraph 4.7 - infrastructure required in line with building development
Paragraph 6.2 pt 4 - agree this criteria.

Full text:

paragraph 1.3 Planning to build 628 houses / units peer annum for many years is dependent on people purchasing these houses in what will become a more difficult money supply period as the UK recovers in part from the loss of employment and the pandemic. Developers will not build houses unless there is every prospect of them being bought.

paragraph 2.3 The most appropriate development comes from the most suitable locations and this should include brownfield sites rather than greenfield sites. There seems to be a in-built system discounting brownfield sites. A redundant commercial horticultural nursery site with no employment and no food production would still be discounted for development in favour of building on greenfield agricultural land.

paragraph 3.1 The Framework needs to protect areas such as the Area of Outstanding Natural Beauty (AONB) as particularly important. In an area such as the AONB any planning applications need to follow the principle of disproving the adverse impacts would demonstrably outweigh the benefits.

paragraph 3.4 Although the IPS should be helpful until the Local Plan Review is completed the acid test of its importance will be whether can it stand up to scrutiny at a Planning Inquiry?

paragraph 4.2 The provision of additional infrastructure needs to be in parallel with housing development to provide the community assets required rather than possibly follow on years later.

paragraph 4.5 Build new houses where sites are available which may mean they are not located in relation to existing settlements with access to facilities and services. There are several examples within Birdham where building has taken place such as at the Westlands Estate and the Greenacres Estate that are far from facilities and services. Also the new affordable housing at Piggery Hall Lane / Church Lane in East Wittering is another example.

paragraph 4.6 Only agree to suitable sites for building that do not significantly change the character of a place.


paragraph 4.7 Agree that infrastructure is required in line with building development, not following on years later or not at all.

paragraph 6.2 point 4 Agree that one of the criteria that the Council considers good quality development is that development proposals need to make best and most efficient use of land, for example building on brownfield sites.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3639

Received: 08/07/2020

Respondent: Mr Michael Class

Number of people: 2

Representation:

Object to new development in Birdham - impact on infrastructure

Full text:

We are objecting to the two new developments ...1 off Bell Lane of 70 houses and 2 on the land opposite the Birdham Store of 250 houses....... This area is served by ONE road which on many occasions is completely congested...on many occasions it has taken us between 1and 2 hours to return from Chichester, 4 miles away!........ Also Doctors and Schools are full to capacity......
Birdham is classified by CDC as a settlement village which should only mean modest development....... Historically in Birdham the majority of building is of 30 properties or less... Plus all the infrastructure problems Drainage both surface and sewage, Roads, Traffic, School and Doctors.......... Please do not ruin this lovely village and cause those of us who live here yet more problems on this already over used country, unlit Road.........

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3640

Received: 10/07/2020

Respondent: Mr Peter Mitchell-Heggs

Representation:

Not sustainable - does not account for internationally designated sites, impact on wildlife, loss of agricultural land, construction is not sustainable, no provision for basic infrastructure. Brownfield land should be prioritised.

Full text:

This policy in not sustainable. It does not take into account Chi harbour is SSSI status and a RAMSAR site with recognised international wetlands SPA with 5kmZone of influence Ancient woodlands are linked to this flood plain area of Chi harbour. Threat to wildlife in the linking corridors is intense and increased by the plan Destruction of agricultural land when the nation is crying out for more is clearly counterproductive House construction plans are far from carbon neutral No provision for basic infrastructure development, either building eg sewer, water,gas rods ,cycle lanes, or social eg shops, surgeries, schools, buses village halls, chapels,playgrounds, No effort to accentuate access for first time buyers or really affordable housing Use all available brownfield sites of all types before destroying for ever the Special ( not just a local and my proud delineation) Area which you on our behalf have the duty to protect for now and the future.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3641

Received: 08/07/2020

Respondent: Mr and Mrs A Newton

Number of people: 2

Representation:

We object to the plan to build the quantity of housing in Birdham. It will swamp the small community and the infrastructure is not good enough.

Full text:

We object to the plan to build the quantity of housing in Birdham , we understood that we had a plan in place we agreed that would last for the next 25 years.

The proposed planning is too large it will swamp the small community and the infrastructure is not good enough now, particularly the A27.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3642

Received: 25/06/2020

Respondent: Mr Colin Hamilton

Representation:

Energy efficiency criteria does not go far enough. Solar panels should be fitted as standard

Full text:

I am appalled by the fact that with respect to Climate Change, at para 8 you are still demanding that developers supply on site from renewable sources only 10% of the predicted energy usage of the development. At the moment, that demand is qualified by a statement ‘if viable’ which it apparently never is. That is why in recent years and months you have approved swathes on new housing (and continue to do so) without a single solar panel in evidence and no doubt no ground source heat pumps, underfloor heating etc. It is an absolute disgrace. You are condoning the next generation of housing, thousands of them, which make NO contribution to the zero carbon targets.
Why can you not, in this policy, demand that builders fit solar panels as a minimum, as norm?

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3643

Received: 09/07/2020

Respondent: Mr David Owen

Representation:

Whitestone Farm inappropriate for development:

1. out of character
2. flood risk
3. inadequate facilities and infrastructure
4. Birdham is defined as a ‘Settlement Village’

Full text:

I understand that a greenfield site to the south east of Birdham Straight opposite the Birdham Store has been proposed as a suitable site for the development of up to 250 houses. This is wholly inappropriate for a number of reasons:

1. A development of this number of houses is completely out of character with the village as it stands today. There has never in the past been a proposed development so disproportionate to the existing size of the village as previous Planning Officials have recognised the folly of such plans. I hope that you will display the same sense.

2. In 2012 the village suffered extensive flooding to numerous properties. The proposed site acts as an extensive sink for excess water every Winter. This Winter was no exception, with a significant proportion of the field flooded for an extended period of time. Where would all this water lay if the field was built on.

3. The facilities and infrastructure of the village will not be able to cope with such overload.

4. Birdham is defined by your organisation as a ‘Settlement Village’ NOT a ‘Settlement Hub‘ and as such it should not be subjected to such overload.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3644

Received: 08/07/2020

Respondent: Jenny Currell

Representation:

Prioritise development on brownfield land.
Plans ignore flood risk.
Development will exacerbate traffic.

Full text:

I would like to state my objections to this housing development plan for the following reasons:

Brown field, derelict or abandoned sites, or small developments in city or village centres should be the building plan options not farm land. This land should be kept and used for food supplies particularly now that society as a whole is looking to greener resources. Two of Chichester District Council’s land allocation proposals breach the principle of reducing ‘food miles’, namely, Highgrove Farm and Apuldram/Donnington.

Flooding in this area is a constant threat and The National Policy Planning Framework acknowledges this saying ‘development in areas of risk is inappropriate and should be avoided’ yet these proposed plans totally ignore this.

As a regular walker along the A259, I observe frequent build up of traffic which will only be exacerbated by housing development.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3645

Received: 21/06/2020

Respondent: Mr Jon Llewellyn

Representation:

1. Parish councils should have more power.
2. Housing should be evenly distributed across parishes
3. building on greenfields diminishes food production and ability to have wind /solar farms

Full text:

1. There doesn’t seem to be much in the policy about the role of the parish council planning committees. I think they should have more power, as otherwise developments are imposed on communities rather than having their support.
2. There are details relating to the distribution of housing developments, but I would like to see a system whereby if we need for example an increase of 10% of housing, that should be evenly distributed across villages/towns/communities and not just located in one development. Communities are much more willing to accept new developments if they know neighbouring communities are also taking their share.
3. You mention sustainability, but with every field that gets built upon, a community’s ability to sustain itself by growing it’s own produce/maintaining it’s own livestock, is diminished. We should also take into account the fact that it lessens our ability to install solar/wind farms etc. We need to take greater account of this in my opinion; the greater the population the more land we need to dedicate to these uses within a specified distance. If we are not doing this we may as well forget referring to sustainability at all.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3646

Received: 24/06/2020

Respondent: Dr & Mrs Ervine A & Shelley Ellis

Number of people: 2

Representation:

Concerns over flood risk increase from new development. Flood risk assessment is required. Support request for infrastructure

Full text:

(4.2) flooding downstream
We have considerable personal concern regarding flooding from adjacent and above ground into our garden. last year for the first time this occurred when there had been no rain. We have lived here for 40 years and as this has not happened before we wonder who else is now discharging the water in our direction. Whilst recent developments such as the field in Claypit lane opposite us was converted into a car park for Rolls Royce last year and the Grange Estate next to it and now a large estate in progress east of Madgewick lane to our west side.
(4.9) suggests a flood Risk assessment which we think is important and applicable at this stage of the local development in this area and is certainly relevant for some of us West of Claypit Lane which was flooded this year with the March School ourselves and Hadley House effected. In fact the school had to have their water pumped out by a tanker.
We note the development proposals should include necessary infrastructure for waste water conveyance, open spaces and highway improvements to avoid flooding elsewhere.
We thought the Draft Interim Policy Statement for Housing was correct to emphasise this and now requires to be carefully followed in this locality.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3647

Received: 13/07/2020

Respondent: Mrs Sarah Headlam

Representation:

Solar panels should be fitted as standard to all new developments.
Numbers of market housing should be restricted to rebalance the population.

Full text:

In general agreement with the draft statement and in particular with paras 6.1 and 6.2 of the draft with reference to local context:
Para 4.1 deliverability, paras 4.2 and 4.3 and locational sustainability, para 4.6
Para 8 includes the need to maximise energy supplies and this should be met by making the provision of solar roof panels obligatory for all new developments and for which government funding towards the cost may be available.
In my earlier representations to the Local Plan made in February 2019 I stressed the need to rebalance the population mix to nearer the national average, and therefore to achieve this, to restrict for the time being the percentage of market housing provided.
The government has just announced that it is providing an infrastructure fund which includes money for housing. At the same time the Local Government Association has proposed that Local Authorities should be allowed to be directly responsible for providing affordable accommodation and this could help to cut the Housing Benefit bill.
I recommend that this could be a way forward using these initiatives; for the Chichester District Council to
assume that the numbers of additional housing [unclear text] demanded could be provided within the time [unclear text] required.

Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3648

Received: 22/06/2020

Respondent: Dr Carolyn Cobbold

Representation:

1. coastal settlements will face flood risk by 2065 - adjust settlement hierarchy
2. use high climate change allowances when considering planning applications and most recent scientific research into floodrisk
3. density should reflect capacity of site to drain floodwater
4. settlements with low employment and no higher education facilities should be considered remote
5. take into account climate change emergency declaration
6. infrastructure should be required for lifetime of development
7. flood risk assessments should be informed by most recent climate change allowances and sea level rises from the Environment Agency

Full text:

See attachment

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