Policy H12 Intensification sites

Object

Representation ID: 4371

Received: 16/03/2023

Respondent: Mr Stephen Jupp

Legally compliant? No

Sound? No

Duty to co-operate? No

For sites on this list why do any additional caravans have to meet an identified need only on that site to be acceptable - that is unreasonable bearing in mind the overwhelming need identified.

Why is the land to the north and south of the proposed allocation at Five Paddocks excluded?

Object

Representation ID: 4472

Received: 16/03/2023

Respondent: Mr Stephen Jupp

Legally compliant? No

Sound? No

Duty to co-operate? No

Inconsistency in approach to the sites.

You say the 2 show person sites would be temporary due to flood risk but at the same time an additional traveller pitch is propped immediately to the south at The Stables and that is not to be temporary

Al the recent permissions at Five Paddocks Farm have been permanent and the allocation should also be permanent.

Support

Representation ID: 4854

Received: 17/03/2023

Respondent: Environment Agency

We note that no sites are within any medium to high risk flood zones, which we are supportive of. Some sites may need to consider wastewater infrastructure availability, bearing in mind the hierarchy set out in paragraph 020 of the Planning Practice Guidance for Water supply, wastewater and water quality (i.e. “the first presumption is to provide a system of foul drainage discharging into a public sewer to be treated at a public sewage treatment works”).

We note that Policy H14 specifies that suitable services are needed for sites.

Support

Representation ID: 5142

Received: 16/03/2023

Respondent: South Downs National Park Authority

We note the findings of the latest GTAA (2022) which is for the area of Chichester district outside the SDNP. The additional pitch provision needs set out in Table 5.1 and 5.2 are for Chichester outside the SDNP only.

We would highlight that there is limited capacity in the National Park to allocate sites for Gypsies and Travellers through duty to cooperate, given significant landscape constraints. Indeed, the protection afforded to National Parks is such that unmet need in the South Downs National Park may be displaced to other (non-designated) authorities outside the National Park.
Policies H11, H12 and H13 are supported, including the mechanisms for making provision for travellers accommodation, i.e. provision of pitches on new strategic allocations and appropriate intensification of existing authorised sites.

We’d welcome continued joint working between the coastal authorities and the South Downs National Park Authority in regard to addressing the need.

Object

Representation ID: 5248

Received: 16/03/2023

Respondent: Southbourne Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Legal Compliance – The Parish Council was not consulted about Policy H12 (or Policy H11 or Policy A13/2) until now. Parish Councils are listed as one of the bodies the District Council must consult under the Town and Country Planning (Local Planning) (England) Regulations 2012. (See also Para. 3.4 of the Local Plan Statement of Community Involvement).

Soundness – Proposed intensification of the site at Sunrise in Southbourne is not deliverable (Policy H12 – Proposed 1 additional pitch at Sunrise as shown in Local Plan Appendix I). The site identified as Sunrise in the Local Plan is already fully occupied and includes the controversial encroachment over a significant length of a Public Right of Way (Footpath 212). An unauthorised park-home dwelling has been recently located over the original route of the PRoW. The site does not have its own access to fresh water or the sewer system and its permission was granted WITHOUT the requirement for this. It would seem that the District Council is attempting to use this proposed intensification to regularise this unauthorised development. This is not acceptable.

Object

Representation ID: 5983

Received: 23/03/2023

Respondent: Westbourne Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The Plan indicates that there is a high level of unmet need generally for Gypsy’s Travellers and Show People. The high levels of existing and unauthorised pitches in Westbourne is also mentioned in the Plan. The neighbouring parish of Southbourne is also mentioned as a location with high levels of pitches and unmet need. The relevant extract on the approach to meeting this need is as follows. “the council has had to utilise a wide range of options for meeting this need. This entails providing pitches on the strategic housing allocation sites, supporting increases in the density of pitches on existing authorised sites which have been assessed as being acceptable in principle for additional pitches, and allowing pitches to come forward on a case-by-case basis. The council will also consider allocating additional pitches via the forthcoming Allocations DPD.”

Westbourne Parish Council is concerned to avoid intensification of the authorised and unauthorised Gypsy and Traveller and Showman’s Pitches located within the Parish. Westbourne already has one of the highest concentrations of such uses anywhere in the District and further intensification will have an adverse impact on the balanced and cohesive community that we seek to protect. We would argue that other locations with lower intensities of such use should be sought to meet this need.

The site in Cemetery Lane at Greenacre is identified as a location for an additional four pitches. There have been many enforcement issues in this area with unauthorised pitches and unauthorised industrial and commercial development, and further increases in the quantity of pitches will exacerbate the situation to the detriment of the balanced and cohesive community that the Parish Council seeks to protect and enhance.