1.17

Insert additional text after the first sentence: Working with parish councils, in compliance with the principles set out in the statement of community involvement is a legal requirement for the council and it would be inappropriate for the council to override existing neighbourhood plans with material increases in house building targets ( e.g. increase around 30%) unless there is strong local support evidences by a local referendum with representative participation rates.

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.

Update the plan and re submit.

The plan is out of date and incomplete with reference to the revisions made in the plan

Support – with qualification
WGPC agree that Chichester District requires an effective adopted Local Plan to protect the district, and especially villages, from speculative development. However, WGPC has concerns about the methodology for the housing allocation.
Wisborough Green cannot take further (significant in percentage terms) housing allocation without a detrimental impact on its rural and historic character - contrary to Local Plan objectives.

See attachment.

[RECEIVED LATE]

Statement from Chidham & Hambrook Parish Council
concerning the Chichester Local Plan 2021-2029 Proposed Submission Consultation


The current Local Plan was made in 2016. It would be reviewed within five years. Consultation on the Preferred Approach Plan was undertaken between December 2018 and February 2019. Our residents profoundly disagreed with the change in the proposed housing allocation for the Parish which had risen from 25 (Objective Assessment indicative housing number) in the previous Local Plan (2014-2029) to 500 (2024-2039) Since then, despite our arguments, the number has only been reduced to 300 i.e. 12 times our previous housing allocation. There has been no explanation from Chichester District Council about what has been changed/retained as a result of the consultation or for what reasons. The figure of 300 has not been justified. Our arguments have not been addressed. Furthermore, there is a Southbourne planning application for 63 houses on the immediate north-west border of the parish with the only access through Chidham & Hambrook, but this, if approved, would be in addition to the allocation determined by CDC. This application would impact a protected chalk stream destroy the rural edge of the village and landscape and exacerbate local concerns about development levels. Despite these issues, this development would have little if any practical connection with Southbourne.

We have been asked to comment on the Regulation 19 Submission Plan which includes brand new Policies which have been introduced apparently without any local consultation. The response submission process is on-line only, complicated and time-consuming. Residents are limited to three reasons for objecting – legal compliance, soundness and duty to cooperate. They are restricted to a comment of only 100 words. Only four supporting documents can be attached. This consultation process seems undemocratic. We realise that the government makes the rules, and the Council has to keep to the rules, but this is not an acceptable or democratic form of Consultation.

In the period 2014 - 2017 of the previous Local Plan there was a substantial amount of development in Chidham & Hambrook: the 25 properties increased to 144 new properties permitted by the end of 2019, many ‘on appeal’, and a further 148 in the period to 2022 of which 144 count towards the new Local Plan. This means a further 156 houses are required.

Currently a further 239 houses are the subject of planning applications which have gone to appeal.

The Council’s original assertion of the status of the parish as a relatively high ranking service village was only justified by the theoretical ranking system, but not in our view, as expressed to the council, by practical, comparative, qualitative reality. Although this ranking has disappeared from the current draft it must have contributed to the appeal decision in 2021 for 118 houses in Hambrook which was not contested by the Council, and allowed at a time when the Council could not demonstrate a 5 year housing land supply.

Our residents are understandably incensed. It is difficult to present an argument for a Neighbourhood Plan that requires so many houses, and any new plan will be required to get residents approval in a referendum. Our current experience is of increasing housing numbers for a parish where travel by car is necessary because of the distances, infrequency, inconvenience and cost of buses or trains.

How can CDC expect support from local communities for their Local Plan involving future development if they disregard concerns about the current situation in terms of the limitations of the infrastructure? Just as importantly the parish is midway between the SDNP and the Chichester Harbour AONB. Building in the parish degrades the links between, and therefore the habitats themselves, of these two important and legally protected environmental areas. This is economically counterproductive because of the importance of tourism and leisure, and farming to the area, and the historic and chronic underinvestment in basic wastewater treatment capacity locally.

Support – with qualification
WGPC agree that Chichester District requires an effective adopted Local Plan to protect the district, and especially villages, from speculative development. However, WGPC has concerns about the methodology for the housing allocation.
Wisborough Green cannot take further (significant in percentage terms) housing allocation without a detrimental impact on its rural and historic character - contrary to Local Plan objectives.