Interim Policy Statement for Housing Development

Comment

Representation ID: 3679

Received: 28/06/2020

Respondent: Fishbourne Parish Council

- Support document
- para 2.4 - delete reference to prioritising known sites as this conflicts with criterion 5 of IPS
- sites within Fishbourne are not appropriate as not deliverable without highway improvements
- support criteria 1 - 5 and 7 - 12
- amend criterion 6 to include data to show 'value' of corridor

Comment

Representation ID: 3680

Received: 10/07/2020

Respondent: Gleeson Strategic Land

- Prioritise sites that can deliver homes quickly over other approaches
- applications for small sites that are deliverable now should be granted planning permission
- use of restrictive time condition should be justified for each development
- need for off site infrastructure should not be used to refuse development
- criterion 3 - the Landscape Gap Assessment should not be afforded weight as it has not been tested at examination
- criterion 6 - corridors cannot be afforded any weight at present
- criterion 8 - these standards are not adopted policy
- Promote Land at Clay Lane, Fishbourne

Comment

Representation ID: 3681

Received: 09/07/2020

Respondent: Heaver Homes Ltd

Agent: King & Co c/o ATP

- unlikely that approaches will be enough to achieve yield, so more homes should be delivered through windfall
- consider need to amend LPR timetable
- clarify that 628 is minimum figure
- encourage development on brownfield sites
- suggest specific paragraph wording for paras 2.3, 3.4, 4.3, 4.5, 4.6, 4.9, 5.2, 6.2 and criteria 2, 3, 4, 5, 7, 8, 11 and 12, include new criteria 13 and 14

Comment

Representation ID: 3682

Received: 10/07/2020

Respondent: Gleeson Strategic Land

- Priority to sites that can deliver quickly
- use of restrictive time condition should be justified for each development
- reliance on off-site infrastructure should not be a reason for refusal
- 6.2.3 Landscape Gap Assessment should not be given weight as untested at examination
- 6.2.6 corridors are not adopted policy so cannot be given weight
- 6.2.8 - new environmental standards are not adopted policy so should not be a reason for refusal
- Promoting Land West Clay Lane, Fishbourne

Comment

Representation ID: 3683

Received: 29/06/2020

Respondent: Goodwood Estate Company Limited

Agent: HMPC Ltd

- support approach, however wording not sufficiently robust to safeguard direction of strategy in emerging local plan
- suggest wording amendments to paragraphs and criteria
- reference NPPF as a whole
- clarify IPS relates to all settlements
- reference protection of important countryside, which may run contiguous with urban edges
- protect integrity of National Park boundaries
- protect views of cathedral and historic city centre and setting in relation to National Park
- clarify that lack of housing supply does not mean all sites are suitable
- clarify points to ensure early delivery of housing

Comment

Representation ID: 3684

Received: 03/07/2020

Respondent: Home Builders Federation

- urge Council to speed up preparation of local plan
- clarify calculation of housing figures
- criterion 8 - introduces new policies and should be removed
- remove references to policies in Local Plan Review

Comment

Representation ID: 3685

Received: 13/07/2020

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

- IPS should be accompanied by Annual Position Statement
- clarify calculation of housing figure
- IPS disregards implications of Brexit and Covid
- question location of Kirdford in settlement hierarchy
- question whether intensification is appropriate - NPPF does not reference 'intensify'
- refer to LPR Policy S5 in list of relevant policies
- 6.6.2 not clear on what is good quality development
- request further consultation on IPS

Comment

Representation ID: 3686

Received: 17/08/2020

Respondent: Lewis & Co Planning

- support approach
- para 4.6 - clarify small sites to be no larger than 1 hectare
- support criteria 4 and 5
- further clarity should be given to the weight of the IPS in decision-making process

Comment

Representation ID: 3687

Received: 08/07/2020

Respondent: Hallam Land Management Limited

Agent: LRM Planning Ltd

- Support approach
- clarify calculation of housing figure
- clarify what size of development is considered to be 'small'
- support allowance of outline applications at this stage
- consider criteria to be appropriate although important to recognise presumption in favour of development is engaged due to land supply shortfall

Comment

Representation ID: 3688

Received: 26/06/2020

Respondent: National Grid

Identified National Grid asset in area (see map attachment) - overhead transmission line Bolney-Lovedean (through north of plan area and National Park)

Comment

Representation ID: 3689

Received: 10/07/2020

Respondent: Sunley Estates and Castle Properties

Agent: Neame Sutton Limited

- Support approach
- Issue revised housing land supply position statement
- criterion 3 - LVIA are costly and technical reports, clarify sought whether LVIA are required or whether this should be Landscape and Visual Appraisal as a more proportionate approach
- delete criterion 6 - introduces new policy
- criterion 8 - standards are new and at odds with Deregulation Bill 2015 - should not replicate building standards - consider amending the criterion

Comment

Representation ID: 3690

Received: 10/06/2020

Respondent: Persimmon Homes

- housing figure should be 691dpa
- if IPS uses emerging policy, should be a recognition that not all criteria will carry equal weight in decision-making
- concern that the Council is seeking to introduce new policies - clarify if IPS is being drafted as SPD or DPD
- criterion 8 - introducing new standards which have not been through examination - delete criteria
- amend criteria 1 to suggest at least one boundary adjoins settlement boundary, and combine with criteria 2

Comment

Representation ID: 3691

Received: 10/07/2020

Respondent: Pilkington Town Planning

- Support approach
- Criterion 1 - amend to include land that is not contiguous but abuts development adjacent to settlement boundary
- criterion 3 - LVIA may be disproportionate for sites less sensitive - criterion should be more flexible
- reintroduce infill policy similar to RE16 of 1999 Local Plan

Comment

Representation ID: 3692

Received: 02/07/2020

Respondent: Portsmouth Water Ltd

Representation pertains to the representation previously submitted to the consultation on LPR Preferred Approach

Comment

Representation ID: 3693

Received: 10/07/2020

Respondent: Thawscroft Limited

Agent: Quod

- Supports approach to boosting housing supply
- Promote Land west of the Paddocks, Selsey

Comment

Representation ID: 3694

Received: 10/07/2020

Respondent: Redrow Homes

Agent: Pegasus Planning Group

- Support approach
- concerned that IPS introduces new policy requirements, particularly criterion 8 - suggest deletion of criterion 8 and technical specification to be left to building regulations
- suggest wording changes for criterion 9
- no need to raise nitrate neutrality as this is a material consideration in planning applications already

Comment

Representation ID: 3695

Received: 09/07/2020

Respondent: Thakeham Homes

Agent: RPS Planning & Development

- Concern that IPS introduces new policies - should be removed and reserved for Local Plan Review
- IPS creates unnecessary additional layer of policy-making
- Criterion 8 gives rise to viability concerns, lacks robust evidence base and scrutiny and examination
- fail to understand why CDC is using this approach

Comment

Representation ID: 3696

Received: 06/07/2020

Respondent: Save our South Coast Alliance

- Comments made on paragraphs of IPS include seeking clarification of wording and suggested changes to wording
- reiterate importance of consideration of climate change allowances and risk of flooding
- suggest amendments of criteria wording

Comment

Representation ID: 3697

Received: 09/07/2020

Respondent: South Downs National Park Authority

- Add reference to Section 62 of Environment Act 1995 to section 6
- Support criteria 5 and 6 and suggest minor wording changes to criterion 6

Comment

Representation ID: 3698

Received: 09/07/2020

Respondent: Sidlesham Parish Council

- Clarify whether IPS will recognise Neighbourhood Plans that are at an advanced stage but not yet made due to delay in referendums
- Clarify whether parishes with no proposed housing figure in Local Plan Review will remain without a figure
- Chichester has restricted land to accommodate new development due to environmental constraints - this should be made clear in the IPS

Comment

Representation ID: 3699

Received: 10/07/2020

Respondent: Seaward Properties Ltd

Agent: Smith Simmons Partners

- Support approach
- amend para 3.4 to make clear that out of date policies for housing do not apply to applications for housing
- suggest clarifying that policy applies to greenfield and brownfield land and prioritise reuse of brownfield land
- include reference to encouragement of 'hybrid applications'
- criterion 1 - clarify 'adjacent'
- criterion 5 - clarify that some housing within the AONB may be appropriate
- amend wording of criterion 12 to refer specifically to Chichester Harbour

Comment

Representation ID: 3700

Received: 20/07/2020

Respondent: Southbourne Parish Neighbourhood Plan Steering Group

- Amend paragraph 6.2 to refer to emerging neighbourhood plans
- criterion 1 - refer to settlement boundaries as defined by neighbourhood plans
- criterion 5 - make clear that development is not supported in the AONB

Comment

Representation ID: 3701

Received: 10/07/2020

Respondent: Sussex Ornithological Society

- support inclusion of criterion 6 wildlife corridors
- make reference to need for proposals to deliver net gain in biodiversity

Comment

Representation ID: 3703

Received: 09/07/2020

Respondent: Taylor Wimpey

Agent: Turley

- Support approach
- Clarify role of IPS in determination of applications
- Criterion 3 - landscape gaps is new policy and therefore inappropriate
- Criterion 6 - wildlife corridors is a new policy and should be deleted
- Criterion 8 - environmental standards are new policy
- Promote Chantry Farm Westbourne

Comment

Representation ID: 3704

Received: 10/07/2020

Respondent: West Wittering Parish Council

- parish boundaries should be used instead of settlement boundaries
- Manhood Peninsula cannot take more development due to infrastructure constraints
- account should be taken of climate change flood risk impacts

Comment

Representation ID: 3705

Received: 10/07/2020

Respondent: Linden Homes & Miller Homes

Agent: WYG

- Support approach to prioritising progress on known sites
- Support criterion 4 for higher densities
- Some elements of criterion 8 are new policy and should be deleted
- Clarify how criteria will be applied to existing allocations in the Local Plan

Comment

Representation ID: 3706

Received: 10/07/2020

Respondent: Seaward Properties Ltd

Agent: WYG

- Paragraph 4.5 relies too heavily on the settlement hierarchy in the Local Plan
- Clarify how IPS will be used for determing applications e.g. what level of compliance is acceptable
- Criterion 8 - introduces new policy and should be deleted
- Promote Land south of Clappers Lane, East Wittering

Comment

Representation ID: 3707

Received: 09/07/2020

Respondent: Mr and Mrs Tearall

Agent: Genesis Town Planning Ltd

- Include policy on fill development
- Promote Yeoman's Field, Hambrook

Comment

Representation ID: 3708

Received: 10/07/2020

Respondent: Deerhyde Limited

Agent: Quod

- Support IPS
- Promote Northcommon Farm, Selsey