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Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2290

Received: 01/02/2019

Respondent: Historic England

Representation Summary:

Historic England welcomes and supports the reference to the historic environment of Chichester district, and the heritage assets therein, in paragraphs 2.27 and 2.28 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Full text:

Paragraph 1.5 of the Local Plan Review states "This Plan seeks to balance the economic, social and environmental dimensions of sustainable development". "Balance" implies some gains and some losses. However, this does not reflect the four bullet points that follow this sentence.
In addition, Paragraph 8 of the National Planning Policy Framework explains that;
"Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives)".

We therefore suggest that "balance" is not the most appropriate word.

The three overarching objectives include; "c) an environmental objective - to contribute to protecting and enhancing our natural, built and historic environment......". We therefore welcome the fourth bullet point of paragraph 1.5; "Protecting and enhancing the unique and special qualities of our environment".

Reword the first sentence of paragraph 1.5 as; "This Plan seeks to deliver the economic, social and environmental dimensions of sustainable development in mutually supportive ways".

Paragraph 1.16 explains that the National Planning Policy Framework reiterates the importance of significantly boosting the supply of new dwellings, whilst ensuring provision for other development needs including economic growth.
Whilst not untrue, we consider that this does not fully represent the Government's objectives and policies as set out in the Framework and therefore gives the misleading impression that the Framework is only about housing supply and economic development.
In fact, the protection and enhancement of the natural, built and historic environment is also identified as important in the Framework e.g. in the environmental overarching objective for the planning system as set out in paragraphs 8, 11b)i and 20 d).
Reword the final sentence of paragraph 1.16 as:
"The importance of significantly boosting the supply of new dwellings is reiterated, whilst ensuring provision for other development needs including economic growth and protecting and enhancing the natural, built and historic environment".
Paragraph 31 of the National Planning Policy Framework requires "The preparation and review of all policies should be underpinned by relevant and up-to-date evidence". We previously expressed our concerns about the historic evidence base for the policy framework for the district when commenting on the Issues and Options stage of the Local Plan Review;
"We are aware of the Council's series of Conservation Area Character Appraisals, The Future Growth of Chichester Study and the Landscape Capacity Studies. However, the Council's "Supporting documents" webpage has no historic environment documents and we are not clear if the Council has other historic environment evidence e.g. is there an extensive urban survey of Chichester or other townscape or characterisation study ? Is there an urban archaeological database ? Is there a list of locally important heritage assets ? Has the Council undertaken a survey of grade II buildings at risk ?".
However, looking at the Council's Local Plan Review Preferred Approach Plan - Evidence Base - December 2018 webpage, the only specific historic environment evidence base document identified is the Chichester Historic Environment Strategy and Action Plan. Whilst we welcome the Strategy, we have previously expressed the view that we do not consider that it forms, by itself, an adequate historic environment evidence base for the Local Plan Review.
We are aware that the Council has a list of locally important buildings, but that Chichester was not covered by the West Sussex Extensive Historic Town Surveys - perhaps as it was thought a candidate for the more intensive approach of an Urban Archaeological Database (UAD). However, we are not aware that such a UAD exists, and whilst we are aware of the Council's Historic Environment Record (the availability of which accords with paragraph 187 of the National Planning Policy Framework), we do wonder if the archaeological evidence and significance of the city is fully understood and readily available. We suggested that the Historic Environment Strategy could set out actions to enhance understanding and management of the archaeological resource of the historic city and we would be pleased to discuss how we might be able to assist with this.
We will expect the Council to have an adequate, up-to-date and relevant historic environment evidence base and to demonstrate in the Pre-Submission Local Plan how that historic evidence base has informed and influenced the Plan's policies and site allocations.
The historic environment evidence base for the Local Plan Review should be set out on the Council's Evidence Base webpage. If there are indeed gaps in that evidence base, then these should be filled and that evidence taken on board in preparing the Pre-Submission Local Plan Review document.
Historic England welcomes and supports the reference to the historic environment of Chichester district, and the heritage assets therein, in paragraphs 2.27 and 2.28 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Historic England welcomes and supports, in principle, the identification of "Protect the area's valuable heritage and historic assets" as one of the challenges faced by the Plan.
However, the National Planning Policy Framework requires local plans to deliver an environmental overarching objective which includes "to contribute to conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and to include strategic policies to make sufficient provision for "conservation and enhancement of the natural, built and historic environment" (our underlining).
The Framework therefore requires local planning authorities, through their local plans, to do more than just conserve the historic environment i.e. to enhance it as well. This should be identified as a challenge (although it is also an opportunity).
Reword the last bullet point of paragraph 2.28 as; "Protect and enhance the area's valuable heritage and historic assets".
Historic England welcomes, in principle, as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework, the reference to the historic environment in paragraph 3.1;

"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while supporting the historic and natural environment".

However, the National Planning Policy Framework refers to "conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and the "conservation and enhancement of the natural, built and historic environment". We therefore suggest that "supporting" should be "conserving and enhancing" as terminology more consistent with the Framework and possibly ambiguous than "supporting".

Reword the first sentence of paragraph 3.1 as;
"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while conserving and enhancing the historic, built and natural environment".
Historic England welcomes the inclusion of "Have a quality of life that is enriched through opportunities to enjoy our local culture, arts and a conserved and enhanced heritage;" in the Vision as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes "As an historic walled cathedral city, its rich cultural and architectural heritage will be conserved, enhanced and promoted together with the views and landscape value afforded by its setting" in paragraph 3.4 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "The conservation and enhancement of the historic environment, the high quality landscapes and the agricultural and other rural activities that support it will remain paramount" in paragraph 3.14 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports, in principle, the Strategic Objective "Conserve and enhance landscape and heritage" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. However, we suggest that it could be rather more ambitious e.g. "Conserve, enhance, increase appreciation and enjoyment of and access to heritage"
Paragraph 4.2 states that; "New development must achieve sustainable development principles and must not adversely affect the character, quality, amenity or safety of the built environment, wherever it occurs". The implication is that this is a requirement of the National Planning Policy Framework, but we cannot find this exact wording in the Framework.

However, paragraph 127 of the Framework does set out what planning policies and decisions should ensure of developments, including "are sympathetic to local character and history" and "establish or maintain a strong sense of place". In addition, paragraph 185 of the Framework requires plans to set out a positive strategy for the conservation and enjoyment of the historic environment, which should take into account "the desirability of new development making a positive contribution to local character and distinctiveness".

We therefore consider that the final sentence of paragraph 4.2 should be revised to more closely reflect the requirements of the National Planning Policy Framework.

Reword the final sentence of paragraph 4.2 as ""New development must achieve sustainable development principles, must not adversely affect the history, quality, amenity or safety of the natural, built and historic environment and should make a positive contribution to local character and distinctiveness and establish or maintain a sense of place". (Alternatively, these could be set out as bullet points for clarity).
Historic England welcomes and supports "enhance the quality of the built, natural, historic, social and cultural environments" in Policy S2 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Although the historic environment is not identified as a constraint or as an opportunity for enhancement in paragraph 4.12 as a factor in the definition of the Settlement Hierarchy, we note that paragraph 4.14 does explain that consideration has been given to other factors in determining whether a settlement is a suitable location for additional housing growth. We would like to think that these other factors include the potential effects on the historic environment.
Historic England welcomes and supports "where possible enhances the character, significance and setting of heritage assets" as one of the considerations to guide potential discussions on a possible site for a new settlement in paragraph 4.33 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessments" in paragraph 4.90 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we suggest that reference should also be made to heritage impact assessments to underpin the planning of new development.
Reword paragraph 4.90 to read;
"it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessment and heritage impact assessments".
Historic England welcomes and supports "such development will need to be sensitive to the
historic character of the city" in paragraph 4.91 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "conserve and enhance the city's historic character and heritage", "Enhance the city's existing heritage, arts and cultural facilities", "Protect views of the cathedral" and "All development will be required to have special regard to the city's historic character and heritage. Development proposals should be underpinned by historic characterisation assessments and make a positive contribution to the city's unique character and distinctiveness" in Policy S13 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we would like to see a reference to heritage impact assessments to underpin development proposals.
We also wonder if it would be helpful to have a specific policy to protect important views, allied to or combined with a policy for tall buildings in the historic city ?
Reword Policy SP13 to read "Development proposals should be underpinned by historic characterisation assessment and a heritage impact assessment......".
Historic England welcomes and supports "Any development proposals within the vicinity of the site must clearly demonstrate how the development would protect, and where possible enhance, the operation and heritage of the site as a motor-circuit and airfield" in Policy S15 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site" in Policy S17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would prefer "significant archaeological assets" to be retained in situ.
Reword Policy S17 as;
"All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site, with any significant archaeological assets retained in situ".
Paragraph 2.2 of the Plan notes that the North of the Plan Area has "rich cultural and heritage assets". We are surprised, therefore, that paragraph 4.128 has no mention of these assets.
Reword paragraph 4.128 "This part of the plan area is predominantly rural with few sizeable settlements, characterised by undulating countryside with a high proportion of woodland, typical of the Low Weald landscape. Conserving the rural character of the area, with its high quality landscape and natural and historic environment, is a key objective".
Historic England welcomes and supports "Conserve and enhance the rural character of the area, the quality of its landscape and the natural and historic environment;" in Policy S19 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes paragraph 5.1 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Strictly-speaking, historic parks and gardens are registered for their special historic interest rather than their protection per se, but one of the purposes of Registration is to encourage appropriate protection and inclusion on the Register is a material consideration in the determination of planning applications.
Historic England welcomes paragraph 5.5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports Policy S20, particularly the references to history, historic character and local identity in clause 1, sense of place in clause 2, character in clause 8 and high quality public realm in clause 11 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would also like to see a specific clause relating to heritage assets.
Add a new clause; "conserves or enhances the significance, special interest, character and appearance of heritage assets".
Historic England welcomes and supports paragraph 5.12 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, paragraph 5.13 states that "Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and seek to avoid or minimise any conflict between the conservation of the heritage asset and any aspect of the proposal" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
This very largely reflects paragraph 190 of the National Planning Policy Framework, but the Framework requires local planning authorities to take the particular significance of any heritage asset that might be affected by a proposal into account when considering the impact of a proposal on a heritage asset, "to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal". The requirement is clear - any conflict should be avoided or minimised; it is not sufficient to merely "seek to" avoid or minimise that conflict.

In addition, paragraph 189 of the Framework states;

"In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting......Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.

There is, therefore, a clear onus to be placed upon the applicant/developer to identify and describe the significance of any heritage assets affected.

Paragraphs 193, 194, 195 and 196 of the Framework set out how local planning authorities should consider the impact of a proposed development on the significance of a designated heritage asset. We believe that this could usefully be summarised in the Plan.

Reword paragraph 5.13;
"Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and take that significance into account when considering the impact of a proposal on a heritage asset, to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal".
Add new paragraphs;
"For applications which affect, or have the potential to affect, heritage assets the applicant will be expected to describe the significance of the asset and its setting, using appropriate expertise; at a level of detail proportionate to its significance and sufficient to understand the potential impact of the proposal; using appropriate references such as the Historic Environment Record and, if necessary, original survey (including, for assets of archaeological interest, an appropriate desk-based assessment and, where necessary, a field evaluation)";
"When considering the impact of a proposed development on the significance of a designated heritage asset, the Council will give great weight to the asset's conservation. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), will require clear and convincing justification"; and

"The Council will refuse proposals that would lead to substantial harm to (or total loss of significance of) a designated heritage asset unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply. For proposals that would lead to less than substantial harm to the significance of a designated heritage asset, the Council will weigh this harm against the public benefits of the proposal".

Historic England welcomes and supports Policy S22, which we consider complies with the requirements of paragraphs 17 and 20 of the National Planning Policy Framework to contain strategic policies and for those strategic policies to make sufficient provision for the conservation and enhancement of the historic environment.

We also consider that the policy forms part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the word "positive" is significant, and we believe that the Plan (and Council) should be proactive in the conservation and enhancement of the historic environment. National Planning Practice Guidance states "Such a [positive] strategy should recognise that conservation is not a passive exercise".
We therefore consider that the positive strategy for the conservation and enjoyment of the historic environment is not a passive exercise but requires a plan for the maintenance and use of heritage assets and for the delivery of development including within their setting that will afford appropriate protection for the asset(s) and make a positive contribution to local character and distinctiveness. We therefore look to local plans to contain commitments to positive measures for the historic environment. We therefore welcome the commitments within Policy S22 to positive actions, including heritage at risk, which paragraph 185 requires to be part of that positive strategy for the conservation and enjoyment of the historic environment. However, we do feel that the supporting text could helpfully explain a little more about the Council's approach to heritage at risk, perhaps borrowing some text from the Chichester Historic Environment Strategy and Action Plan.
We also consider that the positive strategy should comprise recognition throughout the Plan of the importance of the historic environment, of the historic environment's role in delivering the Plan's vision and the wider economic, social and environmental objectives for the Plan area, and of the potential impacts of the Plan's policies and proposals on the historic environment.
We are pleased to have identified a number of references throughout the Plan to the historic environment and we therefore consider that the Plan sets out an adequate positive strategy for the conservation and enjoyment of that historic environment as required by paragraph 185 of the National Planning Policy Framework and that the Plan is therefore compliant with that paragraph.

Add a new paragraph explaining what "heritage at risk" is and the Council's approach to assets at risk e.g.

"Unfortunately, heritage assets can be at risk from neglect, decay or other threats. Designated assets at risk, with the exception of Grade II secular buildings and Grade II places of worship used less than six times a year, are identified on the Historic England Heritage at Risk Register. Within the district outside the South Downs National Park, six assets are on the Register (February 2018): three scheduled monuments, two listed buildings and one conservation area. The Council will actively seek to address threats to heritage assets by recording and monitoring Heritage at Risk in Chichester District, publishing it on our website and working with the owners of heritage assets at risk to find solutions and secure repairs to bring them back into active use, including where appropriate viable new uses and/or proposals for enabling development so they are preserved for future generations."

Historic England suggests that paragraph 5.37 could also refer to the range of heritage assets to be found in the countryside of the Plan area.
Reword paragraph 5.37 as;

"It is valued for many reasons, including agriculture and community food production, its landscape qualities including the special characteristics of Chichester Harbour and Pagham Harbour, the setting it provides for Chichester City and other towns and villages, its range of heritage assets, including historic landscapes, and the opportunities it provides for recreation and biodiversity".
Historic England welcomes and supports clause d of Policy S32; "integrate with the surrounding built, historic and natural environments" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
As noted in paragraph 6.12, the Chichester Entrenchments Scheduled Monument lies partly within and partly immediately to the north of the site. Paragraph 194 of the National Planning Policy Framework identifies Scheduled Monuments as being assets "of the highest significance", substantial harm to or loss of which should be wholly exceptional.

We have previously commented (as English Heritage) on the allocation of this site during the consultation on the Key Policies. We explained that development close to the earthworks might harm the historical value of the heritage asset by interrupting views between its parts and introducing incongruous land-use in its immediate surroundings. This in turn would make it difficult to appreciate the asset's open rural setting, its extensive linear nature and its purpose of enclosing large areas of open land.

Accordingly, we initially objected to the form of the allocation in the Key Policies, but subsequently withdrew that objection following amendments to the boundary of the Strategic Development Location on its northern side so that the boundary ran along the south edge of the belt of woodland in which the scheduled monument sits, thereby entirely excluding the monument from the SDL, and the allocation of the northern area of the amended site as open space.
We are therefore pleased to see that the Strategic Site Allocation still excludes the scheduled monument. We also welcome and support the following requirements of Policy AL1, which we consider provide, in principle, adequate protection for the Scheduled Monument in accordance with the National Planning Policy Framework:
6. Landscaped to protect priority views of Chichester Cathedral spire;
7. Keep land north of the B2178 in open use, free from built development, to protect the natural history interest of both Brandy Hole Copse, and the setting of the Chichester Entrenchments Scheduled Monument;
8. Conserve, enhance and better reveal the significance of the Chichester Entrenchments Scheduled Monument and other non-designated heritage assets and their settings and to record and advance understanding of the significance of any heritage assets to be harmed or lost;
However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Shopwyke Strategic Site Allocation, which we note is an existing allocation.
However, the Grade II listed barn at Greenway Farm is located to the south-west of the site and the Grade II listed Shopwyke Grange and the Grade II* listed Shopwyke Hall are located to the south-east. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL2, which we consider provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework:
7. Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm and the cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan.
However, we consider that reference should also be made to the Grade II listed Shopwyke Grange. This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 7;"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm, the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
According to our records there are no designated heritage assets on this site, although the Grade II listed Shopwyke Grange and Grade II* listed Shopwyke Hall lie to the north-east of the allocated area, Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

We note that criterion 7 of Policy AL2 requires the development of the Shopwyke Strategic Site Allocation to ".......conserve and enhance the historic significance of the......cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan. We have suggested in our comments on this policy that it include reference to the listed Shopwyke Grange, and we consider that this requirement should also be included in Policy AL3 to provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework.

Historic England welcomes and supports criterion 8 of Policy AL2; "Existing views of Chichester Cathedral spire are to be protected". However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as;
"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
Historic England makes no comment on the principle of the two sites at Land at Westhampnett/North East Chichester Strategic Site Allocation, which we note were part of a broad strategic development location in the adopted Local Plan.
However, the site abuts the Graylingwell Hospital Conservation Area, the buildings of the former 'pauper lunatic asylum' (including the Grade II listed chapel), the Grade II listed Summersdale Farmhouse and a Grade II registered park and garden. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".
Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL4, which we consider provide, in principle, adequate protection for these designated assets in accordance with the National Planning Policy Framework:
9. Development should be designed with special regard to the Graylingwell Hospital
Conservation Area, the buildings of the former 'pauper lunatic asylum' and the Grade II registered park and garden in which they sit, and to other listed buildings in the vicinity of the site and their settings. Important views of Chichester Cathedral spire from the area should be protected;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Southern Gateway Strategic Site Allocation.
However, the site includes a row of Grade II listed buildings on Southgate and a number of non-designated heritage assets (the southern gateway of the city had Roman roads converging upon it and this is likely to result in enhanced archaeological potential in this part of the city. The development of suburbs in the medieval and later periods is a further factor with both the canal and railway as examples of later uses of the area. There are a number of buildings of interest, including the former Law Courts and Bus Garage). Part of the site lies within the Chichester Conservation Area and there are listed buildings adjacent to the site.
Paragraph 184 of the National Planning Policy Framework states heritage assets "are an irreplaceable resource, and should be conserved in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of existing and future generations". Paragraph 194 of the Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".

Historic England therefore welcomes and supports, in principle, the following requirements of Policy AL5;

3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals, as appropriate;
However, we consider that these requirements should be strengthened to ensure that they provide adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we consider that Policy AL5 should promote more strongly the opportunity to use the heritage of the area to help define its character and the desirability of new development making a positive contribution to local character and distinctiveness as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
These comments are without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword clause 2 as follows;
Proposals should include a high quality distinctive design response appropriate to this gateway location and based on the character and heritage of the area, which establishes a clear hierarchy of streets and spaces, active frontages of buildings which front streets and spaces with clearly defined building lines;
Reword clause 3 as follows;
3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area, including the Conservation Area, listed buildings (both on and adjacent to the site), non-designated buildings of historic interest and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
Reword clause 9 as follows;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals;
According to our records, the site Land South-West of Chichester (Apuldram and Donnington Parishes) contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
Historic England welcomes and supports clause 3:
3. Protect existing views of Chichester Cathedral spire and the setting of the Chichester Harbour Area of Outstanding Natural Beauty which should be analysed at an early stage of the masterplan;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
According to our records, the site at Highgrove Farm, Bosham, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.

Historic England has no comments on the principle of land being allocated in the revised Fishbourne Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Fishbourne identified in paragraph 6.65 of the Plan is "Protecting the heritage assets of Fishbourne and their setting".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL9, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL9;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings and the Fishbourne Roman site Scheduled Monument, or the character or appearance of the Fishbourne Conservation Area".
Historic England has no comments on the principle of land being allocated in the revised Chidham and Hambrook Neighbourhood Plan for a minimum of 500 dwellings.
However, we consider that Policy AL10 should include a specific requirement to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL10;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets.
Historic England has no comments on the principle of land being allocated in the revised Hunston Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Hunston identified in paragraph 6.77 of the Plan is "Respecting the setting of listed buildings and the Hunston conservation area".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL11, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL11;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Hunston Conservation Area."
According to our records, the site Land north of Park Farm, Selsey, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.

This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England has no comments on the principle of land being allocated in the revised Southbourne Neighbourhood Plan for a minimum of 1,250 dwellings.
However, we consider that a specific requirement should be included in Policy AL13 to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL13;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Prinsted Conservation Area."
Historic England has no comments on the principle of the allocation Land West of Tangmere.

However, the site is close to the Tangmere Conservation Area and a number of listed buildings, including the Grade I listed Church of St Andrew. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade I buildings as assets of the "highest significance".

Historic England therefore welcomes, in principle, clauses 5 and 8 of Policy AL14

5. Protect existing views of Chichester Cathedral spire and reduce any impact on views from within the National Park;
8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, including the expansion or relocation of the Tangmere Military Aviation Museum.
However, we consider that clause 8 should be strengthened to ensure that it provides adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we note that paragraph 6.95 of the Plan identifies, as one of the specific issues need to be taken into account in planning the development and site layout at Tangmere, "Conserving and enhancing the setting of the historic village (particularly the Conservation Area"). We consider that this should be included within Policy AL14.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as follows:

8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, particularly the Conservation Area and the Grade I listed Church of St Andrew and including the expansion or relocation of the Tangmere Military Aviation Museum.
Add a new criterion as follows:
""Conserve and enhancie the setting of the historic village, particularly of the Conservation Area".
Historic England welcomes and supports clause b of Policy DM3 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clauses 1 c and 2 e of Policy DM5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, clause 2 of Policy DM13 but considers that the policy should be, in the first instance, to avoid adverse impact on the historic environment as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the wording used in Policies DM3 and DM5 would be appropriate.
Reword clause 2 of Policy DM13 as:
"Is located so as not compromise the essential features of nationally designated areas of landscape, historic environment or nature conservation protection".
Historic England welcomes and supports clause 1 of Policy DM17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clause b of Policy DM20 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports paragraph 7.129 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Many farm buildings that are now redundant for modern farming needs are likely to be of historic interest - it is acknowledged that farm buildings are generally under-represented on the National Heritage List for England. Historic England considers that Policy DM21 should include stronger protection for such buildings as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Add a new criterion to Policy DM21 as follows:

"Features of architectural or historic significance are retained and, where the building forms part of a historically significant complex of buildings, consideration is given to the future use(s) of those buildings and the impact of the proposal on the integrity and character of the complex".
Historic England welcomes and supports, in principle, paragraphs 7.154 - 7.161.
However, we consider that paragraph 7.154 should be reworded to clarify the distinction between designated and non-designated heritage assets (the latter including buildings on the Local Buildings List for Chichester).
Reword paragraph 7.154 as follows:
"There are a large number of "Heritage Assets" (as defined in the National Planning Policy Framework), both designated and non-designated, in the plan area. Designated assets are Listed Buildings, Scheduled Monuments, Conservation Areas and Registered Historic Parks and Gardens. Non-designated assets include archaeological sites (although the remains may be of national significance equivalent to scheduled monuments, and which should be considered subject to the policies for scheduled monuments) and non-listed buildings which have been identified as locally important, such as those on the Local Buildings List for Chichester City and 'positive' buildings within Conservation Areas."
Historic England welcomes and supports in principle, Policy DM27 both as part of the positive strategy for the conservation and enjoyment of the historic environment as required by paragraph 185 of the National Planning Policy Framework and also as a non-strategic policy for the conservation and enhancement of the historic environment as suggested by paragraph 28 of the Framework.
However, we consider that clause e. should specify the (wholly) exceptional circumstances in which permission for a proposed development that would lead to substantial harm to (or total loss of significance of) a designated heritage asset would be granted i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

We would also welcome the policy being more detailed in terms of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset, as do, for example, Policies EH10, EH11, EH14 and EH15 of the West Oxfordshire Local Plan 2031. These policies were developed with Historic England and the Inspector that examined the Local Plan 2031 shared our concern that the historic environment policy in the Local Plan 2031 provided inadequate locally specific detailed policy guidance and considered the more detailed policies necessary for the Plan to be sound.

(However, we do acknowledge that the Inspector that examined the Key Policies development plan document considered the modified historic environment policy (Policy 47) put forward by the Council with our support was sufficient for the Plan to be sound, and that Policy DM27 in the Local Plan Review very largely repeats Policy 47).

Reword clause e. of Policy DM27 as follows;
"Development involving substantial harm to or loss of designated heritage assets will
only be granted in exceptional circumstances (wholly exceptional circumstances for
designated assets of the highest significance) i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

More details of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset. We would be pleased to work with the Council on a revised policy or policies.

Paragraph 7.195 of the Plan notes that the remnants of canals "are important early 19th Century historic features in the landscape of the coastal plain and warrant protection".
Historic England agrees with this statement, but Policy DM33 makes no mention of protecting the historic significance of the remaining canal sections.
Reword the first paragraph of Policy DM33 as follows;
"Development that makes provision of through navigation or enhancement of the Chichester Ship Canal and the Wey and Arun Canal will be supported where it meets environmental, ecological, historical and transport considerations."
Historic England welcomes and supports clause 3 of Policy DM34 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2291

Received: 01/02/2019

Respondent: Historic England

Representation Summary:

Historic England welcomes and supports, in principle, the identification of "Protect the area's valuable heritage and historic assets" as one of the challenges faced by the Plan.

The Framework therefore requires local planning authorities, through their local plans, to do more than just conserve the historic environment i.e. to enhance it as well. This should be identified as a challenge (although it is also an opportunity).

Full text:

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2420

Received: 07/02/2019

Respondent: South Downs National Park Authority

Representation Summary:

Para 2.29 (challenges and opportunities facing the Plan Area): We suggest that the 7th bullet point should say 'Protect and enhance the character of the area including the Chichester Harbour AONB and the setting of the SDNP'.

Full text:

The SDNPA and all relevant authorities are required to have regard to the purposes of the South Downs National Park (SDNP) as set out in Section 62 of the Evironment Act 1995. The purposes are 'to conserve and enhance the natural beauty, wildlife and cultural heritage of the area' and 'to promote opportunities for the understanding and enjoyment of the special qualities of the national park by the public.' The Authority would appreciate reference to Section 62 being added to
paragraph 1.31 of the draft Plan.

Duty to Cooperate

As set out in our previous response, the SDNPA has a set of six strategic cross-boundary priorities.
I would like to take the opportunity to again highlight these which provide a framework for ongoing Duty to Cooperate discussions:
* Conserving and enhancing the natural beauty of the area.
* Conserving and enhancing the region's biodiversity (including green infrastructure issues).
* The delivery of new homes, including affordable homes and pitches for Gypsies, Travellers and Travelling Showpeople.
* The promotion of sustainable tourism.
* Development of the local economy.
* Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel.

Conserving and enhancing the natural beauty

We welcome the requirement in policies S26 (Natural Environment) and DM28 (Natural Environment) to ensure that development proposals have no adverse impact on the openness of views and setting of the SDNP. It is noted that a substantial amount of new homes are proposed on the A259 corridor between Emsworth and Chichester. This is a sensitive stretch of land in the coastal
plain between the coast, the south coast railway and the A27. This corridor provides the connection, including intervisibility, between the protected landscapes of the South Downs National Park and Chichester Harbour AONB, for example views of the channels within the Harbour from the Trundle and Stoke Clump.
We note the intention of identifying settlement gaps and look forward to seeing the evidence base and the proposed gaps in the Regulation 19 iteration of Chichester Local Plan Review 2035, particularly as to how they will contribute to safeguarding the relationship between the SDNP and Chichester Harbour AONB. We would welcome the opportunity to work with CDC on this matter.

Locations identified for development

Development in the CDC Local Plan Review 2035, particularly along the A259 (policies AL7 Highgrove Farm Bosham, AL9 Fishbourne Parish, AL10 Chidham and Hambrook Parish, AL13 Southbourne Parish) corridor, have the potential to deliver a significant cumulative adverse impact on the setting of the National Park and its important relationship with the Chichester Harbour AONB.
We consider that the policy wording for the A259 corridor Strategic Site Allocations could be more robust and proactive with regard to conserving and enhancing the National Park. In particular, it could provide more active direction to applicants in order to ensure adverse impacts are minimised locally, and in relation to the National Park. For example, with regard to green infrastructure, each of the
A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) include a criteria requiring the provision of green infrastructure, and we would suggest this could be re-worded as follows: 'Identify opportunities are taken for and secure the expansion and provision of multifunctional green infrastructure into the wider countryside and protected landscapes of the South Downs National Park, and Chichester Harbour AONB, including between settlements and facilities.'

Reference to considering and minimising impact on the SDNP in each of the A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) is welcomed, for example criterion 5 of policy AL9:
Fishbourne Parish. However, this could be usefully re-worded to ensure that developers do not create a scheme and only consider the impact afterwards. Wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design' avoids the risk of relying upon ill-informed and inappropriate mitigation measures This matter could also be usefully
addressed in relevant Strategic and Development Management policies elsewhere in the Local Plan concerning design, landscape, and the South Downs National Park. We would be happy to work with CDC on this matter.

We note Strategic Policy S32, which requires proposals for housing allocations and major development sites to be accompanied by a site-wide design strategy. We would strongly encourage masterplans and development briefs for each allocation (or settlement where the sites are to be allocated through a Neighbourhood Plan) to come ahead of applications and demonstrate positive design interventions which respond directly to landscape/SDNP sensitivities. We would be happy to be involved in shaping these as consultees in order to achieve the best quality scheme. These interventions could be written in to the policy wording.

There is an opportunity for allocation policies to seek to deliver the joining up of existing, and/or improvements to, the network of RoW (Equestrians, Cyclists and Pedestrians) to enable and encourage access into the National Park in accordance with the National Park's Second Purpose.
Further comments on specific allocations:
* Policy AL1 (Land West of Chichester) - We welcome the consideration of the Centurion Way in criteria 10. However, we would ask for stronger policy wording to explicitly state that development must not adversely affect, and preferably enhance usability of, Centurion Way connecting Chichester with the SDNP.
* We note that Policy AL4 (Land at Westhampnett/NE Chichester) still refers to Lavant Valley greenspace but we query if this is likely to be secured now based on planning applications submitted. We would suggest that criteria 12, last sentence, could also refer to securing offsite improvements/upgrades for cycleway links
* Policy AL6 (Land South-West of Chichester (Apuldram and Donnington Parishes)) should address the important opportunity to secure a safe off-road connection between the Centurion Way and Salterns Way as the two flagship and largely safe off-road multi-user trails linking Chichester with (respectively) SDNP and Chichester Harbour AONB. We would welcome the opportunity for further dialogue and joint working on this matter with CDC.
* We welcome criterion 5 of policy AL14 (Land West of Tangmere). It is a sensitive site due to the impact on clear views of the site from important locations in the SDNP such as the Trundle and Halnaker Hill. We therefore ask that criterion 5 is expanded to emphasise and address the sensitivity of the site
Specific wording comments on other policies/paragraphs:

We have the following comments on the following specific paragraphs:
* Para 2.29 (challenges and opportunities facing the Plan Area): We suggest that the 7th bullet point should say 'Protect and enhance the character of the area including the Chichester Harbour AONB and the setting of the SDNP'.
* Policy S20 (Design): As mentioned above regarding the A259 Strategic Site Allocation policies, we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy S25 (The Coast): Paragraph 5.44: We suggest adding 'serves to provide important scenic views from the water across to the SDNP which should be conserved'.
* Policy S26 (Natural Environment): We suggest deleting reference to 'openness' and to include reference to views from and to the National Park.
* Policy S32 (Design Strategies for Strategic and Major Development Sites): We suggest that the policy requires such design strategies to be informed by landscape character and the sites landscape context. We also suggest that criteria h. includes a requirement to state maximum building heights.
* Policy DM17 (Stand-alone Renewable Energy): The policy requirement for demonstrating no significant adverse impact upon landscape or townscape character is welcomed. We request reference is also made specifically of views of the SDNP.
* Policy DM19 (Chichester Harbour AONB): We request criterion three also identifies the relationship by way of intervisibility between the AONB and SDNP.
* Policy DM22 (Development in the Countryside): Further to comments on the A259 Strategic Site Allocation policies and S20 (Design), we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy DM23 (Lighting): The reference to the South Downs International Dark Skies Reserve is welcomed. However, proposals that aren't immediately adjacent to the Reserve may have significant adverse impact, for example due to the site's particular visibility within the landscape or sky glow; we suggest that wording is amended to reflect this.
* Policy DM32 (Green Infrastructure): We suggest that this policy could benefit from specifically citing that green infrastructure should be 'multifunctional'. We also recommend reference to opportunities to make better green infrastructure connections in line with Lawton Principles of 'bigger, better, more joined up', to ensure these spaces can function and therefore deliver benefits.

Conserving and enhancing the region's biodiversity (including green infrastructure).

The SDNPA welcomes the approach taken by CDC to identify green infrastructure and habitats networks as cross boundary issues in paragraph 1.26 of the Plan. The SDNPA looks forward to continuing to work with CDC on green infrastructure matters particularly as your Plan is progressed to pre-submission.

We note that an open space study has been prepared and this could be linked up with other work into a wider green infrastructure approach incorporating the identified strategic wildlife corridors, areas for natural flood management, PROW and connections between the settlements, protected landscapes and the stations, landscape views/settlement gaps and some land management guidelines
for these really important areas. This would be particularly useful to inform development proposals in the A259 corridor.

Policy SD30 - Strategic wildlife corridors

The SDNPA very much welcomes and supports the inclusion into policy of wildlife corridors which traverse the district connecting the two protected landscapes of the Chichester Harbour AONB and the SDNPA.

It is important to note that there is no corresponding policy within South Downs Local Plan, currently at examination, to continue protection of the wildlife corridors within the SDNP. We have concerns that it is unlikely to be sufficient for the corridors just to reach the SDNP boundary. We also note that several of the corridors appear to be quite narrow, especially to the east of the City, and we query whether they are substantial enough to perform the intended function.

We note the detailed evidence outlined in the background paper and the SDNPA would like to work with CDC on the continued development of the strategic wildlife corridors, in particular with regard to their connection points with the National Park and how we can work together on robustly delivering this strategic cross boundary objective.

Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation

The SDNPA has been working together on technical advice to facilitate sustainable development within proximity Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation, which are designated for their populations of Bechstein and barbastelle bats. The draft Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol was published in 2018 in the Core Document Library as part of the South Downs Local Plan Examination. The Protocol is based on published data which identifies key impact zones, one of 6.5km and one of 12km, around each of the three SACs. It also sets out avoidance, mitigation, compensation and enhancement measures to inform and be addressed by development proposals. Parts of the Chichester District Local Plan area are within these key impact zones. These zones have been incorporated into policy SD10 of the South Downs Local Plan and the policy has not been modified by the Inspector as a result of the examination in public. The SDNPA would welcome the opportunity for further discuss with CDC and Natural England on this work.
Solent Recreation Mitigation Partnership

Both CDC and the SDNPA are members of the Solent Recreation Mitigation Partnership (SRMP) (also known as Bird Aware Solent) which has provided a strategic mitigation solution to address potential harm to the protected habitat at Chichester Harbour and ensuring compliance with the Habitats Regulations. We note that the SRMP mitigation solution is reflected in Policy DM30 and we look forward to continuing to work with CDC and other members of the SRMP on this matter.
With regard to paragraph 7.185 we suggest reference to the Medmerry Realignment be a new bullet point: 'Medmerry realignment, which is intertidal habitat created in 2013 to compensate for historic losses across the Solent to SSSI and Natura 2000 sites'.
We also suggest the following wording amendment to paragraph 7.187: '...This is particularly relevant to Chichester and Langstone Harbour and Pagham Harbour and the impact of recreational pressure on the birds that use these Special Protection Areas. Any negative impacts that the development may have should will be weighed against the benefits of the proposal. This may include looking at whether the assets are surplus to requirements, if the proposal impacts on a small area or corridor or if a wider need exists for the development and there is no alternative location....'

The delivery of new homes, including affordable homes and pitches for Gypsies,
Travellers and Travelling Showpeople

Policy S4: Meeting Housing Needs
The SDNPA welcomes the uplift to the housing target to address unmet need arising in that part of the SDNP within Chichester District (estimated at 44 dpa at the time the last Statement of Common Ground was agreed in April 2018). The provision of 41 dpa broadly meets this need.
We note that the Objectively Assessed Need is calculated only for the area outside the SDNP using the 'capping' method set out in the Government's standard methodology (the currently adopted target of 435 dwellings per annum plus 40% = 609) - this is helpful as it makes a clear distinction between the assessed need for Chichester District Local Plan area and that for the SDNPA, notwithstanding
the Duty to Cooperate.

Policy S5: Parish Housing Requirements 2016-35
We support identification of parish specific housing requirements providing certainty to local communities. This is the same approach as we have taken in the South Downs Local Plan.

Affordable housing
We note that there is a need for 285 affordable homes per annum (source: HEDNA) which underlines the need for a strong policy which seeks to maximise affordable housing delivery. This high level of need is common to the wider sub-region and is an issue relevant to the wider housing market area.
The SDNPA supports CDC's approach of taking opportunities arising from new residential development to contribute to the supply of affordable housing, to meet local needs in terms of type and tenure (paragraph 4.35). In this respect, it is important that the whole plan viability testing currently being undertaken should fully reflect Planning Practice Guidance on viability, such that as high as possible a percentage of affordable housing is sought. We also support the positive approach to Community Land Trusts (CLTs) as a mechanism for delivering affordable housing (paragraph 4.45). Chichester District Council may also wish to note that SDNPA has, subject to main modifications consultation, received the go-ahead from its Local Plan Inspector for unmodified inclusion of Strategic Policy SD28: Affordable Housing in the South Downs Local Plan. This includes a lower threshold than that advised in Government policy, and also seeks on-site affordable housing from small sites below the 11 threshold stipulated in Government policy.

Policy S7: Meeting Gypsies, Travellers, Travelling Showpeoples' Needs
The SDNPA supports the principle of the policy and whilst noting the significant need arising. It is not clear whether the intention is to allocate sites to meet the need in a separate DPD. Paragraph 4.49
refers to 'the forthcoming DPD' and policy S7 to sites being allocated in a Site Allocation DPD 'where there is a shortfall in provision'. Has this work already been triggered by the scale of need? The policy and associated text could be clearer on this matter.
We would like to highlight that there is limited capacity within the National Park to allocate sites for Gypsies and Travellers through DtC, given significant landscape constraints. We suggest that the coastal authorities and SDNPA continue to work closely with regards addressing the need.

Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel
The SDNPA supports in principle Policy S23 (Transport and Accessibility). In particular, we support emphasis on encouragement of use of sustainable modes. We suggest explicit support in the text for improving links into the National Park, particularly by sustainable and active transport modes.
Allocation policies should also should seek to deliver the joining up of existing, and/or improvements to, the network of Public Rights of Way.

SDNPA notes reference in the policy to a coordinated package of improvements to the A27 Chichester Bypass, as well as to a new road from the Fishbourne roundabout. The SDNPA would urge that any such schemes be fully assessed, including streetlighting, for potential adverse impacts on landscape where there is a relationship with the National Park and its setting. Any such impact will
need to be mitigated, and opportunities taken to enhance green infrastructure networks and public rights of way networks. CDC may wish to consider whether the Policy S23 should include additional wording to reflect these principles.

Centurion Way
The SDNPA supports the reference to Centurion Way in paragraph 7.185 in relation to Green Infrastructure & resistance to dissection of green movement corridors. There are opportunities to improve these links, for example, suggest explicit reference to protecting and enhancing the Centurion Way. The reference to Salterns Way is also supported. Centurion Way and Salterns Way are two flagship off-road routes for the SDNP and AONB respectively and do not currently benefit
from safe off-road connection. The SDNPA would strongly support policy to secure this connection and would welcome opportunities to discuss this further and work jointly with CDC on this strategic issue.

With regard to Strategic Policy S14 (Chichester City Transport Strategy) we request that the SDNP is included in the penultimate bullet point as a destination for strategic cycle routes.

Transport evidence
We would highlight that the transport assessment carried out to inform the South Downs Local Plan.
This indicated a potential severe impact on the Petersfield Road / Bepton Road / Rumbolds Hill junction in Midhurst of additional development in the town, in the context of junctions already becoming overcapacity due to background traffic growth, for example, . arising from strategic development in neighbouring planning authorities.
A review of the CDC Transport Study of Strategic Development indicates significant traffic growth arising from Scenario 1 (the preferred strategy). It is not clear from the study how this will impact on the A286 towards Midhurst, which in turn could have a critical impact on junction capacity at Midhurst.
SDNPA may seek further assurance that such potential impacts have been looked at, and appropriate mitigation sought.
Other comments
Page 16 - Local Plan area map: Request clarification whether the Local Plan area includes the following two properties, as not clear from the Local Plan Area map: Stedlands Farm, and The Stable/Little Stedlands, Haslemere GU273DJ
We would like to wish you well in the progression of your Local Plan and would welcome further discussion and joint working on the strategic cross boundary matters raised.

Attachments:

South Downs National Park [1292].pdf (297.77 KB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2444

Received: 07/02/2019

Respondent: South Downs National Park Authority

Representation Summary:

Map page 16 - request clarification whether LP area includes Stedlands Farm and the Stable/Little Stedlands, Haslemere GU27 3DJ

Full text:

Attachments:

South Downs National Park [1292].pdf (297.77 KB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2489

Received: 07/02/2019

Respondent: Chidham & Hambrook Parish Council

Representation Summary:

The term East-West Corridor used with in regard to west of the City of Chichester is ill defined and the use of this term implies the focus of policy is on transport and through movement to the detriment of a more balanced focus on local settlement, existing residential, local countryside and amenity issues.
There is a lack of vision, clarity and coherence of planning policy towards the Bourne Villages, their character and the surrounding countryside that lies between the South Downs AONB and Chichester Harbour AONB

Full text:

Characteristics of the Plan Area: a spatial portrait
The term East-West Corridor used with in regard to west of the City of Chichester is ill defined and the use of this term implies the focus of policy is on transport and through movement to the detriment of a more balanced focus on local settlement, existing residential, local countryside and amenity issues.
There is a lack of vision, clarity and coherence of planning policy towards the Bourne Villages, their
character and the surrounding countryside that lies between the South Downs AONB and Chichester
Harbour AONB

Policy S2 Settlement Hierarchy
Object
Chidham & Hambrook, among the other Bourne villages, is characterised as a 'service village' with no definition or explanation of what this means. This term does not reflect the special and unique character of any of these areas, it designates them as no more than utilitarian dormitory communities.
"The largest level of growth is expected in the service villages and settlement hubs, able to accommodate higher levels of growth without adversely impacting the character of the settlement". An increase in growth of housing stock by 55% will undoubtedly negatively impact Chidham & Hambrook.

Policy S3 development Strategy
We believe the rationale for how the number of 500 dwellings for Chidham & Hambrook was arrived at to be wanting and the supplementary evidence to be inconsistent and contradictory. Figures in the 2018 HELAA report suggest that there is available land from achievable sites for 565 new dwellings. This is a completely unrealistic expectation. If these are assessed against the suggested CDC figure of 30- 35 per hectare and 80% developable this gives a total of 360 - 420. The figures seem to be almost entirely based on projections put forward by promoters. Consequently, we were told to put a call out for additional sites. Several of those that have come forward are on sites previously rejected by CDC on the grounds of impact on the AONB, significant access constraints, adverse impact on the landscape and detachment from the settlement boundary.
The Sustainability Appraisal sets out to select numbers in the Potential Distribution Strategies. Assuming a figure of 650 pa, across Chichester District, the predicted numbers for Chidham & Hambrook stay within a narrow range of 500-750, whereas other Parishes fluctuate widely eg Fishbourne 250-1000, Hunston 0-1000.Unlike other parishes, it did not consider a figure of less than 500 for Hambrook.
The Strategic Development Location Assessments seek to assess each district against sustainability criteria. Chidham & Hambrook has been scored with 11 negative and 7 neutral with only 12 positive.
We agree with your judgements with the following additions:
1a in addition to the bat population North of Priors Leaze Lane the Ham Brook is home to water voles.
4b This is a significant constraint. Without adequate public transport and no local facilities or services this will put considerable strain on both the A259 and A27 at both Emsworth and Fishbourne.
5a There is considerable risk of surface water flooding on a number of identified sites.
6a This should be a negative score. To speculate that Southern Rail might increase the service is no justification for assuming a shift to sustainable transport. The hourly service east and west is not adequate for commuters.
9 This should be a negative. There are no local shops apart from a very small and poorly stocked Post Office, which has erratic opening hours, and a charity shop. This doesn't constitute some shops. There are no medical facilities, sports facilities or recreation ground.
10a-12b There are extremely limited employment opportunities in Chidham & Hambrook so difficult to see how any of these would apply.
13a The Local Plan diminishes our rural economy by taking farmland and nurseries for development
13b We have high quality Grade 1 and Grade 2 agricultural land .
We believe these judgements demonstrate that Chidham & Hambrook is less suitable for large scale housing numbers than other areas.

Policy S12 Infrastructure Provision
Infrastructure Delivery Plan
This gives us no confidence that the development of 500 homes in Chidham & Hambrook will give us the infrastructure we need at the time it is required.
Despite the rapid growth in housing numbers over the last five years there has been little infrastructure development. We have no medical centre, local convenience store, employment opportunities, early years or child care provision ,sports or recreational facilities.
Transport: there is no mention of any upgrades to any of the roads or junctions serving the Parish to alleviate congestion and to improve safety. There is no mention of cycling routes and walking provision to provide safe routes. This will be exacerbated by the 1,110+ homes proposed in the Southbourne Parish which will have a coalescent impact on Chidham & Hambrook, particularly Priors Lease Lane and Broad Road.
Education: the suggestion here is that Chidham & Hambrook will be contributing funding to a new school in Southbourne rather than a replacement school in Policy AL10. This represents yet another contradiction. It is unclear where or at which development Early Years and Child Care places would be accommodated.
Health: The nearest provision would be Southbourne

Policy S8 Employment
Object
7.1 Part Two Development Management states " place housing in locations which are accessible by public transport to jobs, shopping, leisure, education and health facilities."
There are limited employment opportunities in Chidham & Hambrook and it appears there is no demand for commercial premises in the area. Industrial units built by Taylor Wimpey on the Lion Park development were not taken up and consequently converted to housing. In the last few years three employment opportunities have closed down to be replaced by housing - two garages which sold, serviced and repaired vehicles, one of which sold petrol and a small stock of essentials, and a plant nursery. This will put an added pressure on traffic as more people drive to their areas of employment west or east using the A259. Public transport is limited and expensive.

Policy S23 Transport /DM8
Object
In Chidham & Hambrook the vast majority (80%) of the proposed new dwellings would be built off Broad Road and some sited on the adjoining Main Road, the A259. There is no provision for the road infrastructure impact of 2250 new homes along this road between Southbourne and Fishbourne. And this will impact the travel survey.
Currently Broad Road has significant safety issues for pedestrians, drivers and cyclists. There is limited visibility due to lack of off-road parking facilities for current residents which has resulted in a number of near accidents. Where it meets the A 259 there is a staggered junction with Cot Lane which, even at present, is difficult to negotiate. The combination of new housing leading to increased traffic in Broad Road and the potential significant volume of increased traffic coming from the 1100+ new dwellings in Southbourne will make this junction dangerous and untenable.
To the North of the Parish there will be increased traffic on the Common Road to Funtington and then the B2178 as a route into the city. Opportunities for any access to housing developments without using Broad Road or Main Road are extremely limited. All other roads in the Parish are essentially lanes, mostly restricted to single lane traffic and could not be used as access to developments.
Pedestrian access in Broad Road is very poor with footways in places too narrow to accommodate buggies, wheel chairs or motorised disabled scooters. As a consequence residents are heavily reliant on cars.

The added volume of traffic will cause significant congestion and decreased air quality. Accessing the A27 at Fishbourne will be further exacerbated by the lack of plans to introduce an additional junction and slip roads onto the A27 between Emsworth and Fishbourne, and for no right turns from the Stockbridge and Whyke roundabouts. The only suggested mitigation is to create a hamburger junction. The increased commuter traffic combined with beach traffic in good weather, will cause gridlock at this roundabout at every junction.
We object to the proposal to build a link road to Birdham which would go straight through a flood plain and a site of environmental significance and would have a negative impact on the views from the coast to the City and SDNP.
Public transport is limited to one bus service along the A259 and an hourly train in either direction from Nutbourne station. The bus is very expensive and the vast majority of passengers are those with bus passes. There is no bus service south to north. The train frequency is too limited as a viable alternative to car travel. We would like to see a more robust policy focussing on public transport links.

We support the creation of an integrated and sustainable transport plan for the District, or at the very least for the area west of Chichester. This plan should draw upon the ongoing work of the ChEmRoute group's investigations and proposals and be coordinated with WSCC with the goal of introducing high quality and separated cycle links between the villages along the A259 and Chichester.

CDC together with WSCC Highways should undertake to provide specialist advice to those Parish Councils chosen to implement proposed strategic housing allocations through Neighbourhood Plans along the A259 in order to assess the impacts of the scale of such allocations on the local highway network. Such advice should be provided in order to aid site selection prior to any master planning of the subsequent development proposal and to help find solutions to potential traffic problems

Policy S6 Affordable Housing
Support
There is a disproportionate number of detached and 4 bed houses currently in our housing stock. We would like to see a commitment for Social Housing in addition to Affordable Housing, which many local people cannot afford to rent or buy. This means many young people leave the area. There is too much flexibility given to developers here in delivering the housing need for the area. They must deliver their "affordable" requirement if sufficient housing to meet local needs is to be provided.

Policy DM 2 Housing Mix
Support
As above we have a high number of 4+ bed and detached homes. Young, low income and single households are being priced out of their neighbourhoods.

Policy DM3 Housing Density
Support
Specialist housing and housing for the elderly will require a lower density as it will be single story. It is essential that there are robust measures that will enable high quality homes to be built to enable elderly people to remain in their community should they need to move into adapted housing more appropriate to their needs. Similarly, life long homes for those with a disability who need specialist housing.

Policy S26 / DM19 Natural Environment
Object
The Spatial Vision and Strategic Objectives 3.6 states that any development west of the city will
" conserve and enhance the local distinctiveness, character and cohesion of existing settlements".
The Sustainability Appraisal states, in relation to Chidham and Hambrook " The scale of the development will completely alter the existing development and there will be significant impact to the existing historic village" These two statements are contradictory .
The magnitude of an additional 500 homes {growth of 55%) will patently alter the local distinctiveness and character of Chidham & Hambrook and risk coalescence with Southbourne. The landscape is characterised by extensive arable land with some nurseries and pasture. Hedges, bushes, orchards and groups of trees contribute to the landscape, as do streams which pass through the Parish. The South Downs National Park is to the North and the AONB of Chichester Harbour to the South.
The CDC Landscape Capability Study reinforces the detrimental effect development will have on the landscape and character in all areas within the Parish
Nutbourne East - Ham Brook Mosaic
Potential development is said to impact on:
valued views, visual corridor for views from Nutbourne Channel towards the SDNP, separation of Southbourne, Hambrook, Nutbourne East, the rural landscape setting, existing pattern of low density settlement.
It will also contribute to the loss of:
Pasture, arable fields, hedgerows, trees, woodland (ancient and semi natural) copses. The area is constrained by its remaining rural character.
Nutbourne West-Nutbourne East Coastal Plain
Potential development will impact on:
valued views, characteristics views to the harbour and the SDNP, views from the AONB and nearby peninsulas: wider separation between Nutbourne West and Nutbourne East, the rural landscape setting,of the AONB, the existing pattern of low density settlement, the well treed landscape setting.
It will also contribute to the loss of:
Pasture, arable fields, hedgerows, trees, woodland copses, characteristic landscape field patterns. The area is constrained by its rural and treed character which contributes to the open setting and character of the AONB.
Upper Chidham Coastal Plain
Potential development will impact on:
Valued views- to the harbour, hills of the SDNP, Bosham Church, setting of Nutbourne Channel and Bosham Harbour, setting of listed buildings, strong rural and tranquil character, views from the SDNP.
Contribute to the loss of:
Arable and paddock fields, hedgerows, trees, tree belts, patches of coastal grassland and wetland, characteristic landscape field patterns.
The area is constrained by its rural and tranquil character, the visually sensitive open large scale fields, its contribution to the open, rural setting of the settlements of Chidham, Nutbourne East and West and their wider separation and its contribution to the wider AONB landscape, including the setting of Nutbourne Channel and Bosham.
Nutbourne East North - Eastern Coastal Plain
Potential development will impact on:
Valued views, rural character, separation between Hambrook and Nutbourne East, semi enclosed and more open character,
Contribute to the loss of: pasture and arable fields, hedgerows, trees, and characteristic field patterns
Nutbourne East Nurseries
Potential development will impact on:
Valued views, characteristic views to the Harbour and SDNP, rural character, separation between Bosham and Nutbourne East, semi enclosed and more open character, the pockets of orchards and small copses.
Contribute to the loss of: pasture and arable fields, hedgerows, trees, and characteristic field patterns

There are clearly significant constraints on the landscape and character if large scale development were to take place in Chidham & Hambrook. The principles in the AONB Management Plan must be rigorously applied to any new developments.

Policy S29, S30, DM 32 Wildlife Corridor
Support
We welcome a specific Policy on wild life corridors located between the SDNP, the Chidham peninsula and Chichester Harbour. The Chidham / East Nutbourne wild life corridor linking important Green Infrastructure, is of special sensitivity.
A variety of species commute or forage between the harbour area and the SDNP including mammals, both deer and bats, of which 10 or more species have been recorded. Badgers, while not normally found on the peninsula, have been seen. Smaller species like Hedgehogs, stoats, weasel, moles, and small prey species, including tawny and barn owls, grey heron and migrant species such as Fieldfare and Redwing use these corridors .
The Ham Brook follows a natural environmental course from the AONB to the SDNP. This natural water course is home to water voles (seen by CDC Wildlife Officer and local environmental volunteers as recently
as January 2019) and the land north of Priors Leaze Lane is a Barn Owl Habitat.There is ancient woodland either side of the railway line next to the trout farm and this is a dormouse habitat too. Development in this area should be constrained by proximity to the wildlife corridor identified by CDC.

AL10/SA10 Chidham & Hambrook
Object
In 2014 at the last iteration of the Neighbourhood Plan there were 850 households in the Parish of Chidham and Hambrook. By the time the new Local Plan is published there will have been an increase in the number of properties in the region of 150 to a total of 1003 in the Parish, an 18% increase. The previous Local Plan had set a target increase of 25 houses. Whilst absorbing this number of properties there have been no changes to the infrastructure and services in the area to support the additional population apart from a charity shop and expansion of the Primary School which is now at capacity and has been for the last year. The new Local Plan requires us to accept a further minimum of 500 properties. This will increase our local housing stock by 50% and will undoubtedly increase the population area by a greater percentage given the age demographic of the area.
6.68 states that" opportunities to relocate and expand the school to two form entry will be sought.". We note that there are similar plans for a relocated and expanded school in Bosham with a site allocated for that purpose, in addition to a new school in Southbourne. Discussions with WSCC have made it clear they would not support the creation of two new schools in such close proximity. It is therefore nonsensical to suggest these two schools could be realised. WSCC data does not support it. Their calculations for schools are based on 210 Primary children for 1000 homes so patently 750 homes would not meet support for two 2 form entry schools. However, the current school is at capacity and cannot on its current site be expanded. If a school project is not forwarded in Chidham & Hambrook the additional children coming from 500 homes would need to travel to Bosham or Southbourne to attend school, along with children from 1100+ homes proposed in Southbourne. There needs to be some clarity and certainty on which of these proposed schools can be achieved and how they would be funded. We find it extraordinary that there is no policy statement on Education.

The Parish Council fully acknowledges that it has a responsibility to contribute to the need for more new housing in the District. However, in view of the above, and having carefully scrutinised the evidence, we believe that 500 homes for Chidham & Hambrook is excessive and is not supported by the documentation. The low provision of amenities, the absence of planned sustainable transport, the proximity of the AONB, the sensitive nature of the landscape and the density of housing proposed, limits the development capacity of the land.
For the reasons given we would like this number significantly reduced by at least 50% in line with Bosham and Fishbourne.

Attachments:

Chidham & Hambrook Parish Council [6650].pdf (430.54 KB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2586

Received: 07/02/2019

Respondent: Countryside Properties

Agent: Turley

Representation Summary:

Final bullet 2.4 not consistent with para 6.91

Full text:

See attachment

Attachments:

Turley obo Countryside Properties [7291].pdf (497.73 KB)

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2622

Received: 04/02/2019

Respondent: Mr Mike Dicker

Representation Summary:

The data in this plan should reflect the demographic data of the local plan area only.
In particular the social and economic characteristics must reflect the plan area and not the district as a whole.

See attached for full detail.

Full text:

Full detailed submission for the Local Plan and supporting evidence is attached.

The representations attached to this submission reflect a high level summary of the detailed submission and do not contain the full level of detail received.

High level comments received:

a. The transport study conducted by Peter Brett Associates (PBA) is not fit for purpose and needs to be rewritten. The scope set for PBA is far too constraining and counters the democratic process agreed by the council to seek alternative routes.

b. Many of the documents are inconsistent and in their current form smack of inconsistency and bias. Reasons for excluding some strategic sites are not consistently used for other sites.

c. Many of the evidence documents are not present or are not complete for this consultation. These will need to be re consulted when they are complete.

d. CDC should not be accepting the unmet housing need from the South Downs National Park (SDNP). They should also be going back to government to insist that until certainty is provided on the A27 this area can not accommodate future housing and or employment space.

e. The proposed link road was resoundly rejected last time it was proposed by Highways England. CDC need to respect the voices that rejected what is option 2 by stealth. Particularly as the PBA report states that the building of the link road will offer other "strategic options". This will not be tolerated locally.

Attachments:

Michael Brian Dicker Redacted.pdf (12.62 MB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2804

Received: 07/02/2019

Respondent: MR William Sharp

Representation Summary:

Issues of rural setting and green access need to be better acknowledged and protected. Current accesses are fragile and easily disrupted or downgraded by new developments (a notable example being the downgrading of the southern end of Centurion Way).

Full text:

See attachment

Attachments:

William Sharp [7072].pdf (1.11 MB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2806

Received: 07/02/2019

Respondent: MR William Sharp

Representation Summary:

Section 2.13
Insert Tourism as a significant employer.

Full text:

See attachment

Attachments:

William Sharp [7072].pdf (1.11 MB)

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2809

Received: 07/02/2019

Respondent: MR William Sharp

Representation Summary:

Section 2.18 The end phrase "offers the best potential for attracting inward investment" is not substantiated. New jobs could drive out some of the existing "self employed" and some of the existing "micro, small and medium sized businesses". OBJECT To the phrasing "However, there is also a need to support and diversify economic activity in the rural parts of the plan area" on grounds that original wording is too unfocussed allowing any form of diversification. Only diversification that complements the area should be contemplated.

Full text:

See attachment

Attachments:

William Sharp [7072].pdf (1.11 MB)

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2813

Received: 07/02/2019

Respondent: MR William Sharp

Representation Summary:

Section 2.28
OBJECT To the phrase "... whilst recognising the need to accommodate new development" on grounds that this kind of phrase is too often used by developers to shoe-horn in inappropriate developments.

Full text:

See attachment

Attachments:

William Sharp [7072].pdf (1.11 MB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2838

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Representation Summary:

Section 2.24 of the PAP references Sites of Nature Conservation Importance, we recommend that this is updated to reflect that sites are now referred to as Local Wildlife Sites (LWS). This is a national move to ensure that all locally designated sites are consistently referenced, especially within the planning system.

In section 2.29 SWT recommends that the penultimate bullet point is revised both to include geodiversity and locally designated sites. Paragraphs 171 and 174 of the NPPF are clear that locally designated sites must be safeguarded in plans in order to protect and enhance biodiversity.

Full text:

See attachment

Attachments:

Sussex Wildlife Trust [1790].pdf (1.32 MB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2887

Received: 05/02/2019

Respondent: Councillor Christopher Page

Representation Summary:

Para 2.2, 2nd bullet: the accessibility from the Manhood peninsula to the north is much worse than the Plan records.

Para 2.5: The A27 is operating at more than double its original capacity. Improvements have not satisfactorily kept up with traffic increases. it is now one of the most dangerous, busiest, mot polluting major road in the country.

Full text:

See attachment

Attachments:

Christopher Page [7337].pdf (83.56 KB)

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2974

Received: 04/02/2019

Respondent: Mrs Sarah Sharp

Representation Summary:

2.29 OBJECT due to omission
Climate change is missing from this list.

Full text:

See attachment

Attachments:

Sarah Sharp [6629].pdf (1.12 MB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3060

Received: 06/02/2019

Respondent: Chichester Harbour Conservancy

Representation Summary:

Local Plan Map does not show Chichester Harbour AONB. If it did, it would help Chichester District Council, as the Local Planning Authority (LPA), to demonstrate the protected landscape constraints they are under when trying to identify land for new developments.

Full text:

See attachment

Attachments:

Chichester Harbour Conservancy [1372].pdf (1.53 MB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3061

Received: 06/02/2019

Respondent: Chichester Harbour Conservancy

Representation Summary:

Page 20, 2.23 Environment Characteristics:
Chichester Harbour is important for its landscape value, as well as biodiversity, land and water-based recreation, and tourism. Furthermore, Chichester Harbour AONB should get a special mention and its own reference number under Environment Characteristics, especially considering that Medmerry is afforded this recognition, which does not have the same level of protection as Chichester Harbour.

Full text:

See attachment

Attachments:

Chichester Harbour Conservancy [1372].pdf (1.53 MB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3062

Received: 06/02/2019

Respondent: Chichester Harbour Conservancy

Representation Summary:

Page 21, 2.24 SNCIs:
The Conservancy was led to believe that Sites of Nature Conservation Importance had been renamed Local Wildlife Sites since the last Local Plan.

Full text:

See attachment

Attachments:

Chichester Harbour Conservancy [1372].pdf (1.53 MB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3063

Received: 06/02/2019

Respondent: Chichester Harbour Conservancy

Representation Summary:

Page 21, 2.27 Environmental Characteristics:
"Landscapes - the district has 86 conservation areas (of which 61 are in the National Park and 2 are shared between the District and the National Park), and 17 registered parks and gardens (2 of which are within the plan area)."

The reference to 61 in the National Park is now irrelevant to this Local Plan and should be deleted.

Full text:

See attachment

Attachments:

Chichester Harbour Conservancy [1372].pdf (1.53 MB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3064

Received: 06/02/2019

Respondent: Chichester Harbour Conservancy

Representation Summary:

Page 22, 2.29 Challenges and Opportunities:
The LPA should state whether the list is in an order of importance. Nevertheless, it is felt that that the order should start by protecting the environmental and historic assets that are in Chichester District, i.e. the last bullet points, then those bullet points that support economic and social development, and then finally provision for new housing and business sites. This order would be more logical: (1) protect what is here; (2) support local people; (3) plan ahead.

Full text:

See attachment

Attachments:

Chichester Harbour Conservancy [1372].pdf (1.53 MB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3108

Received: 06/02/2019

Respondent: Chichester Harbour Conservancy

Representation Summary:

Page 166, 7.100 Sustainable Design and Construction:
"A key issue for the plan area is accommodating the development needs within environmental and landscape limitations, whilst promoting more sustainable patterns of
development through enabling improved accessibility to key services and facilities, public
transport nodes and employment opportunities."

This is central to the Local Plan and should be reproduced in 2.29 as a key challenge.

Full text:

See attachment

Attachments:

Chichester Harbour Conservancy [1372].pdf (1.53 MB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3146

Received: 07/02/2019

Respondent: Rolls-Royce Motor Cars Limited

Agent: David Lock Associates Ltd

Representation Summary:

The LPR does not recognise requirements of the District's established businesses for expansion and to build in resilience. RR factory will need to expand in future.

No discussion of automotive sector/advanced manufacturing in this section.

Full text:

See attachment

Attachments:

David Lock obo Rolls Royce [1764] AL6.pdf (230.35 KB)
David Lock obo Rolls Royce [1764] Characteristics of Plan Area.pdf (185.38 KB)
David Lock obo Rolls Royce [1764] DM9.pdf (187.53 KB)
David Lock obo Rolls Royce [1764] HELAA.pdf (74.58 KB)
David Lock obo Rolls Royce [1764] S3.pdf (181.48 KB)
David Lock obo Rolls Royce [1764] S8.pdf (250.69 KB)
David Lock obo Rolls Royce [1764].pdf (134.18 KB)
David Lock obo Rolls Royce [1764] Strategic Objectives.pdf (191.55 KB)
David Lock obo Rolls Royce [1764] Site 3.pdf (410.89 KB)
David Lock obo Rolls Royce [1764] Site 2.pdf (375.10 KB)
David Lock obo Rolls Royce [1764] Site.pdf (1.13 MB)