Policy S3: Development Strategy

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Flawed plan. It is a local plan why is the North repeatedly excluded.Does not preserve the biodiversity or conservation of Chichester harbour AONB. No concrete information on infrastructure or protection of AONB from pollution, light pollution , flooding etc. Does not mention transport infrastructure or costings. Not enough information to give an educated response. Unless this is adequately addressed in future iterations of the plan I will raise this with the examiner at the appropriate time.

The Goodwood Estates Ltd welcomes the opportunity to again participating in shaping the future of the District through this review of the local plan. The authority will be well aware of the Estate's firm view on the future scale, shape and form of Chichester to ensure that it retains the very special characteristics that underlie its economic success.

Development to meet the growing needs of the City and its environs must be accommodated if the District is to prosper and grow, but this should not mean a "free-hand" for developers on each and every undeveloped 'greenfield' around the City. Development of the next area of undeveloped land adjacent to the city's existing boundaries does not mean it is the most sustainable approach for the community as a whole. It is all too easy for landowners, at a time of acute housing demand, to promote sites as the next closest to available services (often 'as the crow flies') providing housing quickly to meet that undeniable need. The north and north-eastern edges of the city are vulnerable in this regard, an area for which the maintenance of openness is essential for the sustainable and sound interrelationship of Chichester with the neighbouring national park.

Up and down the country, the negative effects of suburban housing growth promoted on that basis are experienced; often without a true recognition of infrastructure needs and a consequential increase in car borne journeys and loss of greenspace. Equally the often, bland design and over-developed sub-urban layouts, tacked on to urban edges, may mathematically meet local needs and offer people an opportunity to own or rent a home, but consequentially erode the community and character of locations to the long-term detriment of its economic base, identity and community distinctiveness; this is particularly true of cities such as Chichester, where the overall character and ambience underpins much of its economic success.

The authority will be well aware of the "Cathedral Cities Initiative", which seeks to recognise the economic and heritage importance of protecting the form and context of the country's important cathedral cities and historic market towns. By providing clear, precise and 'joined up' planning policy protection, that directs new development and associated infrastructure appropriately to sites best able to accommodate it in terms of benefits to the community as a whole (offering benefits in excess of the provision of additional homes and not just the individual interests of the landowner 'dressed up' as offering wider local benefit) it will prevent inappropriate inner-urban and sub-urban development that will cumulatively destroy the true character and distinctiveness of the city.

Chichester is used as an exemplar in the Cathedral Cities initiative, promoted initially at the time of formulating the last local plan for the District, where there was a real threat unchecked urban expansion would undermine the very essence of the District's local economy. That threat has been reduced through this local plan by changes to strategic allocations, but the threat remains from unscrupulous developers and landowners who will continue to exploit the 'loop hole' provided by a lack of housing supply or incomplete planning policy position (potentially an acute situation until this plan is adopted). It is essential this plan not only makes provision to meet objectively assessed housing and employment needs but equally ensures that essential open areas, around and within the city, which contribute positively to its setting, character and economic vitality are given long-term protection through specific policy designation.

The NPPF is explicit that sustainability is a true balance of social, economic and environmental considerations. This means the plan must represent a true reflection of the suitability of a location to accommodate additional growth in a meaningful way. It must not apply the over simplified, developer led approach that the next piece of available land nearest the centre must be sustainable and developed for housing. A robust strategy will look at all sites within the district making use of all appropriate and available land within urban areas, surrounding settlements and along transport corridors, as well as the "easy pickings" on the urban edges. Development sites further from the city centre ,can often prove more sustainable in terms of the NPPF sustainability balance than sites that comprise the next undeveloped site on the urban edge. Any development promoted must, as a minimum, ensure that it demonstrates a positive response to the sustainability balance, not just meeting a mathematical housing need, and provide appropriately, not only for the infrastructure needs of the housing to be provided , but also for the community as a whole; too many development proposals focus simply on the needs of the individual site giving rise to the many real concerns of local people that the community does not have the capacity to absorb additional housing.

The Estate is therefore heartened to see the council taking a bold step through this Local Plan Review to reconsider previous development scenarios, while ensuring that a true level of housing need is accommodated. Paragraphs 4.30 to 4.33 recognise it is not sustainable to continue to rely on past sources of supply. We support this stance fully and encourage the council to take the initiative forward even at this early stage. As stated in the draft plan, there is a long lead in time to such a fundamental and complex change of direction in strategic development, but without a meaningful start now old habits will continue, resulting in an increasing unsustainable City and loss of the very factors that undermine its economic success. There is an inevitability that developers and landowners affected by the changes, will, through planning applications and appeals, do their utmost to ensure their individual interests are protected, over and above the long-term impacts of inappropriate developments on the community as a whole. To counter such proposals in the short term, this plan must set out a logical, precise and robust strategy that follows all up to date Government advice in a positive and sustainable manner

The Estate believes a sound planning strategy set out in this local plan review can deliver ample development land within the district in a manner that will meet housing and employment needs while protecting the very important transitional relationship offered by land between the urban edge and the SDNP boundary. This will involve a step change from past trends of allocating the next area of land as development locations, to be focussed more on evolving settlement hubs on good transport routes, such as around Tangmere, and allowing appropriate scales of development to sustain rural settlements that have to date be excluded from growth considerations. This will involve an on-going dialogue with adjoining authorities under the duty to co-operate to ensure future development is located in sustainable locations where it is most appropriate and not simply in locations of least (often political or subjective) resistance. The Estate will support the council in its emerging strategy and looks forward to working alongside it in the pursuit of a sustainable social, economic and environmental future.

The district is both fortunate but equally unfortunate to have a large part of its area within the National Park, a similarity it shares with the Estate. The purpose and objectives of the Park are acknowledged and supported, and the Estate continues to work with SDNP to establish a planning regime that recognises the true role of landed estates in establishing the character and form of the National Park. This includes the generation of planning policy and proposals through the emerging National Park Local Plan, that recognise the importance of allowing estates to continue to evolve such that the character of the National Park can be sustained. This includes an appropriate planning approach that allows justified estate development, which may at times appear 'at odds' with general national park objectives.

It is the Estate's belief the Park has not considered the true development capacity of its area and this will have unintended consequences on communities, not only within the Park itself, but also within surrounding districts. If the Park is to avoid development up to its boundary, in part a response to its own displaced needs, it is important the District retains existing open land to the north and north east of the city, permitting only new development and activity that are appropriate to a rural area, complement existing land uses and or which maintain the essential openness of the area.

Land between the city and National Park is an area that must be governed by landscape priorities that provide a crucial open, and where deliverable, accessible green space to the city community, but equally provides
(a) clear linkages to the national park,
(b) protects the integrity of the National Park boundary, and
(c) protects the important relationship and setting of city and Park.
Definition of the City Boundary (Plan SB1) should not simply be a red line on a plan, but supported by clear policies and proposals to encourage the boundary to be enhanced and defended.

The Estate owns a significant "buffer" area between the National Park and City (Goodwood Estate Plan 1) and will continue to work closely with both the Council and the SDNPA to achieve such an objective; to establish an appropriate planning policy regime for land between the city edge and National Park. A sound planning approach to the use of land south of Lavant Straight, between the A285 and A286, will ensure policy objectives within that area are complementary, and do not detract from the setting of either the historic city or national park. The land should be kept open primarily with the exception of appropriate development around the settlements of Westhampnett, Westerton, Strettington, and at Goodwood Aerodrome and Motor Circuit (as more specifically controlled through other policies of the plan). The land should be used for agriculture, countryside, forestry, public access and other landscape purposes.

Through representations to this local plan, set out in individual comments to policies and sections, the Estate seeks to demonstrate its commitment to the future sustainability of Chichester and its community through appropriate use of this "buffer area."

New policies proposed through the Local Plan, such as those proposed for the Goodwood Motor Circuit and Aerodrome, provide a positive response to the above objectives and are to be supported. Provision of a "Whole Estate Plan" for Goodwood as required by policies contained in the emerging National Park Local Plan, will provide a planning policy context that straddles the District/National Park boundary. The District Local Plan should acknowledge this approach and ensure that its policies do not conflict.

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We wish to support this policy.

The Berkeley Group is the sole owner of Lawrence Farm which forms part of the land that is allocated for development by Policy AL6. Lawrence Farm is extends to 3.67 hectares and is located adjacent to the Fishbourne roundabout. The site is referred to in the Strategic Housing Land Availability Assessment as CC08209A and it remains both available and deliverable.

We support the principle of improving the Fishbourne roundabout and the provision of a new link road connecting the A27/A259 Fishbourne roundabout and A286 Birdham Road. Lawrence Farm can help to facilitate and deliver the roundabout improvements and the northernmost part of the link road. We would therefore like to work collaboratively with the Council and the adjoining landowners to support the allocation of the site as the Local Plan progresses.

We believe that the land to the South-West of Chichester is a sustainable location for development. It is located adjacent to the built-up area of Chichester, the largest and most sustainable settlement in the District, and benefits from being approximately one mile from the train station and the high street.

Policy S8: Meeting Local Employment Needs includes 145,835m2 floorspace as identified in the Housing and Economic Development Needs Assessment (HEDNA) and an additional 86,000m2 of floorspace as an allowance for future losses. The HEDNA includes four scenarios for employment need which results in a wide range of floorspace requirements. We believe that total floorspace provision in Policy S8 might be overly ambitious for a couple of reasons. Firstly because the rate of future loss of employment is likely to slow down compared to the rate experienced by the Council when permitted development rights first came into effect and secondly, given the current and emerging economic uncertainties.

It will be important for the Local Plan to contain sufficient flexibility and to be able to react to economic changes during the Plan period. We would therefore recommend removing the reference to the acreage of employment land and number of new homes and including an additional sentence added at the end of the first paragraph to say:

"The final quantum of employment space and number of dwellings will be determined by an up-to-date market assessment to determine the viability of the proposals, the need for additional commercial floorspace and the demand for more housing at the time of submission."

We would like to work with the Council and the adjoining owners of land within Policy AL6 to understand if there is scope for Al6 to provide a greater number of new homes.

AL6 also represents a great opportunity to deliver a new country park and green infrastructure. The provision of strategic open space can not only assist with protecting the Chichester Harbour Area of Outstanding Natural Beauty, the Solent Special Area of Conservation and the views of Chichester Cathedral spire, it can also help to achieve a net biodiversity gain.

As set out in Policy AL6, proposals will need to demonstrate that sufficient capacity will be available within the sewer network. We are happy to work with the adjoining landowners, Council, Southern Water, and other stakeholders to ensure that the Apuldram waste water treatment works can accommodate the development.

We anticipate that strategic highway improvements, new strategic open spaces and potential improvements to the Apuldram wastewater treatment are likely to have an impact on the viability of the allocation. The viability of AL6 will need to be considered in greater detail as the Local Plan progresses. A further advantage of AL6 providing more than 100 new homes is the potential to improvement to the viability of the allocation.

In order to enable and deliver the most suitable improvements to the Fishbourne roundabout, we recommend that the full extent of the land at Lawrence Farm is included in the Proposed Strategic Site Allocation AL6. The amendment of the accompanying plan for AL6 to include all of our client's land around the Fishbourne roundabout will not only maximise opportunities for the road to be provided within the red edge of the site, but also help to avoid complications later in the process.


1. We believe the text of the policy should be amended to have an additional sentence added at the end of the first paragraph to say:

"The final quantum of employment space and number of dwellings will be determined by an up-to-date market assessment to determine the viability of the proposals, the need for additional commercial floorspace and the demand for more housing at the time of submission."

2. The plan in the policy map for AL6 should be altered to include all of the land outlined in red in the allocation:

5.18 No mention of use of gray water, design,. Overall appearance should not be red brick boxes with small windows. Lets get modern, architectural that is designed to resist flooding, not just raise houses by 1m which can then cause problems to existing lower houses. But preferably, keep all developments in the North, where catastrophic coastal flooding is much less likely to occur. Why build south of the A27, which could all be flooded in 50 years because of rising sea levels? Please lobby the government to restrict housing applications in National Parks.