Policy P6 Amenity

Assessment of amenity in any development clearly requires a great deal of attention during the pre-application process and Parish Councils and local residents should be consulted on the detail at this stage.

The separation distances proposed in the masterplan are not sufficient and need to be increased materially.

Local plan should also be changed as follows:

Separation distances

Development shall maintain suitable separation distances between the windows of habitable rooms in dwellings (principal living rooms, principal dining areas, bedrooms and kitchens where there is not separate dining room) and the windows and walls of other properties to ensure that an appropriate level of amenity is provided and retained for all residential occupiers. It will generally be expected that no less than 21 metres is proposed between facing principal windows of habitable residential rooms and windows of other uses that could result in significant overlooking. Appropriate distances will be considered on an individual site and design basis considering aspects such as density, scale, height differences and site levels. In circumstances where land levels vary or the difference in building heights is greater than one storey or new development is proposed next to a conservation area longer separation distances will be ordinarily required to support the delivery of policy PI 1. Shorter distances will be permitted where they are necessary to secure the positive reuse of a historic building or are consistent with the character of the local area subject to it being demonstrated that an appropriate level of amenity for existing and future occupiers would be achieved.

There is much to commend in this document and the supporting technical documents that accompany it, and I have listed in the appendix to this letter 26 such paragraphs and policies. I am happy for my support to be registered against these sections of your consultation document. There is also much upon which I must represent a concern, so I attach representations relating to 22 paragraphs or policies.

I am happy to participate in a hearing session, and I would flag at this stage that the common theme that links all of these representations is the need to safeguard the natural and built environment in and around Saxon Meadow, Tangmere from the risks of unsustainable development, I consider that the independent examiner should focus their review on the aspects of the local plan that relate to this matter.

Appendix 1: list of policies that I support
1. P14, 1.23, 1.24: Duty to cooperate
2. P24, para 2.30 "the council declared a climate emergency in July 2019"
3. P24, para 2.32 — "all proposal for new development should be considered in the context of a climate emergencV'
4, P30: Objective 2: natural environment: "development will achieve net gains in biodiversity'
5. P43, 4.1 "National policy promotes increasing energy efficiency, the minimisation of energy consumption and the development of renewable energy sources"
6. P43, 4.3: "Some renewable energy projects provide significant opportunities to enhance biodiversitV'
7. P53, Policy NE5: Biodiversity and Biodiversity Net Gain
8. P62, Para 4.42: Hedgerows and some types of woodlands are identified as a priority habitat
9, P62, Policy NE8: Proposals should have a minimum buffer zone of 15 metres from the boundary of ancient woodland or veteran trees to avoid rood damage (known as the root protection area)
10. P68, Policy NEIO: Criteria for Development in the Countryside - Does not prejudice viable agricultural operations or other viable uses
11. P80, Para 4.91: There are serious concerns about the impact of flooding, both in respect of current properties at risk but also the long-term management of the area.
12. 4.92: any development in the plan area must therefore have regard to flood and erosion risk.
13. 4.94: built development can lead to increased surface water run-off; therefore, new development should include SuDS to help cope with intense rainfall events
14. P81, Para 4.96: Environment Agency consent is required for any works within 16 m of tidal waters and 8m of fluvial watercourses in line with the Environmental Permitting Regulations 2016. This strip is required for access. The policy includes a setback requirement to ensure this access strip is not obstructed.
15. P80, 4.92, Any development in the plan area must therefore have regard to flood and erosion risk, now and in the future, by way of location and specific measures, such as additional flood alleviation, which will protect people, properties and vulnerable habitats from flooding. Recent changes to national guidance highlight the importance of considering flood risk from all sources, and this is particularly significant for the plan area as large parts of it are at risk from groundwater flooding, which needs to be recognised in development decisions alongside the well-established risks in relation to tidal, fluvial and surface water flooding. Appropriate mapping of all sources of flood risks is still evolving, and is likely to develop further over the plan period
16. P93, Policy NE20 Pollution: Development proposals must be designed to protect, and where possible, improve upon the amenities of existing and future residents, occupiers of buildings and the environment generally. Development proposals will need to address the criteria contained in, but not limited to, the policies concerning water quality; flood risk and water management; nutrient mitigation; lighting; air quality; noise; and contaminated land. Where development is likely to generate significant adverse impacts by reason of pollution, the council will require that the impacts are minimised and/or mitigated to an acceptable level within appropriate local/national standards, guidance, legislation and/or objectives.
17, P94, 4.127, Light pollution caused by excessive brightness can lead to annoyance, disturbance and impact wildlife, notably nocturnal animals. The design of lighting schemes should be carefully considered in development proposals to prevent light spillage and glare.
18. P94, 4.128, Dark skies are important for the conservation of natural habitats, cultural heritage and astronomy. The plan area includes three 'Dark Sky Discovery Site' designations, all located within the Chichester Harbour AONB; Eames Farm on Thorney Island, Maybush Copse in Chidham; and north of the John Q Davis footpath in West Itchenor. Development within or directly impacting these areas will be subject to particular scrutiny in terms of their impact on dark skies. The entire SDNPA area is also declared as an International Dark Sky Reserve. Development directly impacting this area will be subject to similar scrutiny.
19. P96, Policy NE22 Air Quality
20. P97, Policy NE-23 Noise
21. P142, Para 6.29, Amenity: Private space, shared space and the design quality and construction of communal spaces all contribute to amenity
22. P155-6, Policy P11:Conservation Areas "protecting the setting (including views into and out of the area)"
23, P55, Para 4.26 - The council is under a legal duty to protect designated habitats, by ensuring that new development does not have an adverse impact on important areas of nature conservation, and by requiring mitigation to negate the harm caused.
24. P58, Para 4.33 The council is under a legal duty to protect their designated bird populations and supporting habitats
25. P95, Para 4.129 The council has a duty to review and assess air quality within the district
26. P301, Conservation Area: An area of special architectural or historic interest, designated under the Planning (Listed Buildings & Conservation Areas) Act 1990. There is a statutory duty to preserve or enhance the character, appearance, or setting of these areas.

WGPC supports this policy intent.

In respect of Space Standards, whilst the phase 2 of Chichester is intending to meet NDSS standards, any such policy requirement needs appropriate justification as set out in footnote 49 of the NPPF.
In respect of separation distances, it is suggested that the 21 meter back to back distance be clarified that this is between first floor windows. Lower separation distances may be acceptable between single storey dwellings such as bungalows.

We agree with the need to provide suitable amenity standards for residents. However, a number of the policy points are replicated elsewhere, for example in relation to noise and lighting requirements.

If the Council cannot provide sufficient evidence to support the adoption of these standards, then this policy should be deleted.

See attachment.

See attachment.

See attachment.

- Reduce and or alter the housing density of the propose plan in the south/south east area of the [Tangmere] development so to enable more green space to be created.
- Shift the proposed housing in the south/south-east area further south towards the Tangmere Road and this increase the greenspace border between the housing and Saxon Meadow.

The above would all help to reduce the detrimental amenity impact and help redress the damage to outlook and views to and from Saxon Meadow residences, health and well being and sense of enclosure. It would extend and expand the greenspace/corridors around the Conservation Area this help reducing the negative effects to wildlife/biodiversity.

See representation

Suggest wording of Point 1 is amended. suggest further clarity is provided re; (g). Separation Distances paragraph 2 needs reviewing and clarifying to ensure it's consistent with wider aspirations of the Local Plan.

See attached representation.

See attachment.

See attachment.

A clear distinction between the Residential areas of the City Centre. Zoning of Bar/Club night time economy should be sought for the protection of the Conservation Area and Residents

RADAR objects to this on the grounds of Soundness. CDC has a dismal track record on Planning Enforcement. What confidence can any Inspector have that the CDC will implement or enforce proposed Policies given what has happened at a Premises in West Street recently.
(Address can be supplied, if requested but withheld for Legal reasons) Past performance undermines the Soundness of the Plan and possibly the Legality.

The Historic City should already be protected by the CDC but the Planning Department have not implemented or enforced policies with any effect or Confidence nor taken account of the sensitivity of the area next to the Cathedral and Boarding School and has left the Conservation Area and Residents and RISK.

Parish Councils and local residents should be consulted on the detail at this stage.

Assessment of amenity in any development clearly requires a great deal of attention during the pre-application process and Parish Councils and local residents should be consulted on the detail at this stage.