Policy S8: Meeting Employment Land Needs

Showing comments and forms 1 to 20 of 20

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 431

Received: 28/01/2019

Respondent: Mr Graeme Barrett

Representation Summary:

As mentioned on an earlier comment sheet there has been a loss of some 700 jobs on the Peninsula:
Southern Yachts Itchenor
Cobham Microwave East Wittering
Earnley Concourse Earnley
South Down Holiday Park Bracklesham
Check-a-Trade Selsey.
Thereare no plan to regenerate employment on the Peninsula

Full text:

Resident of West Wittering
As mentioned on an earlier comment sheet there has been a loss of some 700 jobs on the Peninsula:
Southern Yachts Itchenor
Cobham Microwave East Wittering
Earnley Concourse Earnley
South Down Holiday Park Bracklesham
Check-a-Trade Selsey.
Thereare no plan to regenerate employment on the Peninsula

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 458

Received: 28/01/2019

Respondent: Mr Robin Kidd

Representation Summary:

Why restrict this policy to employment in classes B1-B8? Why not include retailing and leisure and other institutions as sources of employment? This has led to unnecessary inflexibility (e.g. in turning down gym applications), and has encouraged employers to move out of the district e.g. to Portsmouth.

Full text:

Why restrict this policy to employment in classes B1-B8? Why not include retailing and leisure and other institutions as sources of employment? This has led to unnecessary inflexibility (e.g. in turning down gym applications), and has encouraged employers to move out of the district e.g. to Portsmouth.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 602

Received: 07/02/2019

Respondent: Mrs Zoe Neal

Representation Summary:

Land allocation under AL6 of 33 hectares is 3 times the HEDNA requirement when added to the three other sites identified in 4.57. By redistribution of the shortfall, business site AL6 can be removed alongside the need for developers to spend exorbitant funds on a raised link road which impedes into the AONB, over 2 and 3 Flood plains (parts are covenanted to National Trust) destroying prized landscape views of the Cathedral. AL4 within the noise buffer zone not in a zone 2 or 3 flood plain, with 5 easy road access points and is in the current area plan.

Full text:

Ref Policy S8
4.56 Identifies the total additional employment land required at approximately 231,835 sq.m equating to 23.2 hectares as identified in the HEDNA.

4.57 gives the four suggested additional employment sites, these are made up of:
AL1 -6 hectares
AL2 -4 hectares
AL15 -2.4 hectares
This totals 12.4 hectares which leaves 10.8 hectares remaining to be identified.

Policy AL6 is proposed to have 33 hectares for employment development space. This is 3 times the requirement, which additionally requires a raised road over a flood plain, obliterating views of the Cathedral from the coast to be built for access. The other 3 either already have access or it is already planned for.

Policy AL6 conflicts with 4.54 which states that the local plan review seek to maintain an attractive environment through protecting the landscape and heritage assets which will encourage tourism.

Policy AL4 easily accommodates at least 10.8 hectares of employment land and is included in the current CDC Local Plan.
Compared to AL6 it is not on a flood plain zones 2&3
Has 5 obvious road access points without the need to spend developers money on £63M worth of road improvements.
No increase to noise or light pollution as is within the 400m noise buffer zone in the vicinity of the aerodrome.
Location is near to percieved prestigious Rolls Royce and Goodwood so is attractive to businesses and in line with 4.52 approach "....supporting businesses with high growth potential that reflect local characteristics."
This is also an opportunity to offer easy accessible employment to those resident in the SDNP area and unemployed due to the loss of local infrastructure within SDNP, which many residents speak of.
AL4 has only very recently been withdrawn from the HELLA; CDC should consider using compulsory purchase powers to acquire this site for industrial use. The majority of airports / airfields in Britain have industrial business developments on their boundaries as only residential dwelling cannot be built within noise buffer zones.
Or
The additional 10.8 hectares of space should be distributed over other employment areas which already have access to the road network.

I wish to raise this with the examiner.

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 725

Received: 01/02/2019

Respondent: St Pancras church

Representation Summary:

Support the flexibility embodied in the penultimate paragraph regarding retention of existing employment sites, which states that "exceptionally, other leisure or community uses may be supported on employment sites. "
This would not only provide opportunities to create diversity for church and community uses but also facilities such as gyms. It is better to have buildings occupied than left vacant.

Full text:

Support the flexibility embodied in the penultimate paragraph regarding retention of existing employment sites, which states that "exceptionally, other leisure or community uses may be supported on employment sites. "
This would not only provide opportunities to create diversity for church and community uses but also facilities such as gyms. It is better to have buildings occupied than left vacant.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 814

Received: 02/02/2019

Respondent: Mr Graeme Barrett

Representation Summary:

Propose Goodwood as an alternative employment location to AL6 as less conflict with DM25 Noise.

Full text:

Resident of West Wittering
Now is the obvious opportunity to buffer the noise around Goodwood by developing an industrial facility between the track/airfield and housing. Thiswould be by far more appropriate the A286 Southern Link Road development.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1203

Received: 07/02/2019

Respondent: Nova Planning

Representation Summary:

Policy S8 needs to be updated to reflect the Council's viability evidence, particularly in relation alternative uses.

Full text:

We acknowledge the importance of balancing the planned housing delivery with employment provision in the interests of overall sustainable development. However, the blanket protection of existing employment sites outlined in this policy does not serve that purpose. The policy limits its support to 1) the intensification of existing employment uses and 2) in exceptional circumstances the reuse of these sites for leisure and community uses.

Based on the evidence contained within the Council's CIL Viability Assessment (2014) neither scenario is likely to be viable. In relation to office use, the Assessment states that "speculative office development produces a negative land value...We therefore recommend that a CIL Charge should not be set for office floorspace". The assessment provides similar commentary in relation to industrial and storage uses, stating that "industrial/warehouse development in Chichester is generally not viable. There is therefore no potential for sustaining a CIL charge". It is also important to note that these comments are made in the context of Greenfield Development and without the negative implications of existing use values and demolition/clearance costs.

The viability of standalone community or leisure uses (the only alternative uses considered acceptable) is also questionable given the limited economic value in these uses. The Assessment states that "some development may occur on traditional employment sites but this will be linked to specific user requirements, or through mixed use developments which incorporate office accommodation alongside other more viable uses such as residential or retail". Policy S8 ignores this evidence and provides no support for mixed use development as a means of retaining and increasing employment on existing sites that are in need of investment and regeneration.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1513

Received: 07/02/2019

Respondent: Linden Homes & Miller Homes

Agent: WYG

Representation Summary:

It is recommended that added flexibility is provided in both policy S8 and in the allocation of 6 hectares of employment space at West of Chichester via policy AL1 to recognise the uncertainty associated with employment provision. It is recommended that instead the allocation of employment space at West Chichester be made more flexible by allocating the areas for mixed use employment and residential uses, with the final amount of employment to be determined by market evidence submitted at the time of the application.

Full text:

Linden Homes and Miller Homes recognise and support the need for an adequate supply of employment land to help provide jobs and services to the residents of the local area and help meet economic goals within the district. In this respect, the provision of some employment land on the West of Chichester allocation is accepted to create a sustainable, mixed-use, community.

However, the Council's planned need for new employment space is add odds with the evidence provided by the Council's own HEDNA. The HEDNA identifies a need for 145,835m2 of new employment floor space where as the plan provides for a supply of 235,182m2 of floor space, an oversupply of over 60%. It is recognised that the difference is to make up for forecast losses in employment space over the plan period, however, the reasons for these forecast losses are not made clear. Reference is made to 'no longer suitable sites for employment' but it is not clear where these sites are or why they may no longer be suitable. In any case, the retention and/or redevelopment of existing employment sites (which would normally be classified as brownfield sites) should take precedent over new allocations, which is endorsed by draft policy DM9 of the draft plan.

Furthermore, if the Council has particular concerns in regards the loss of employment space through
Permitted Development rights allowing Change of Use to Residential (C3) use then, if they can provide suitable evidence, the Council could explore use of an Article 4 direction to help better control the loss of employment space, rather than rely on new, less certain, employment allocations.

Finally, the policy, and allocation policies which provide for new employment space, do not provide sufficient flexibility to allow the plan to adapt to changing local, national and international economic circumstances, which can change quickly and sometimes unexpectedly. Whilst recognition is given to the need for close monitoring and potentially early review of the policy, it is considered that instead flexibility should be built into the policy now to allow developers to show local need.

Therefore, given the above, it is recommended that added flexibility is provided in both policy S8 and in the allocation of 6 hectares of employment space at West of Chichester via policy AL1 to recognise the uncertainty associated with employment provision. It is recommended that instead the allocation of employment space at West Chichester be made more flexible by allocating the areas for mixed use employment and residential uses, with the final amount of employment to be determined by market evidence submitted at the time of the application. This will help ensure that the employment provision provided meets local needs at the time of development and the land is put to its most economically and socially valuable use.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1636

Received: 07/02/2019

Respondent: Mr Dominic Stratton

Representation Summary:

Section 4.24 states "These include new strategic allocations made in this Plan, retained allocations from the adopted Local Plan 2014-2029, existing commitments," in the adopted plan there is a strategic site to the South of Goodwood aerodrome. This has been removed from the strategic site list and no consideration has been made for its adoption as an employment site which would have the benefit of "place" and interaction with a high tech business (Rolls Royce) good transport links and un-affected by the noise issue (Goodwood buffer) for residential housing. The site must be included in the employment site allocation.

Full text:

Section 4.24 states "These include new strategic allocations made in this Plan, retained allocations from the adopted Local Plan 2014-2029, existing commitments," in the adopted plan there is a strategic site to the South of Goodwood aerodrome. This has been removed from the strategic site list and no consideration has been made for its adoption as an employment site which would have the benefit of "place" and interaction with a high tech business (Rolls Royce) good transport links and un-affected by the noise issue (Goodwood buffer) for residential housing. The site must be included in the employment site allocation.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1666

Received: 07/02/2019

Respondent: Mrs Claire Stratton

Representation Summary:

The plan states "These include new strategic allocations made in this Plan, retained allocations from the adopted Local Plan 2014-2029, existing commitments," in the adopted plan there is a strategic site to the South of Goodwood aerodrome. This has been removed from the strategic site list and no consideration has been made for its adoption as an employment site which would have the benefit of "place" and interaction with a high tech business (Rolls Royce) good transport links and un-affected by the noise issue (Goodwood buffer) for residential housing. The site must be included in the employment site allocation.

Full text:

The plan states "These include new strategic allocations made in this Plan, retained allocations from the adopted Local Plan 2014-2029, existing commitments," in the adopted plan there is a strategic site to the South of Goodwood aerodrome. This has been removed from the strategic site list and no consideration has been made for its adoption as an employment site which would have the benefit of "place" and interaction with a high tech business (Rolls Royce) good transport links and un-affected by the noise issue (Goodwood buffer) for residential housing. The site must be included in the employment site allocation.

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2448

Received: 05/02/2019

Respondent: Horsham District Council

Representation Summary:

Horsham Council notes and supports Policy S8, which sets out the identified employment floorspace requirement for 2016-2035 (231,835 sqm) and which seeks to meet it through an identified supply of 235,182 sqm.

Full text:

Horsham District Council welcomes the opportunity to comment on the Regulation 18 Draft "Preferred Approach" version of the Chichester Local Plan. Our comments focus on Policy S3 "Development Strategy"; Policy S4 "Meeting Housing Needs"; Policy S5 "Parish Housing Requirements 2016-2035"; Policy S7 "Meeting Gypsies, Travellers and Travelling Showpeople Needs"; Policy S8 "Meeting Employment Land Needs" and "Strategic Site Allocations".

Policy S3 Development Strategy/ Policy S4: Meeting Housing Needs
Policy S4 deals with meeting housing needs in Chichester District between 2016 and 2035. Policy S4 states that Chichester will provide for at least 12,350 dwellings between 2016 and 2035. This equates to an annual target of 650 dwellings per year, which is slightly in excess of the current identified housing target of 609 dwellings per year, as set by the Government. Horsham District Council therefore supports strategic policy S4, as it seeks to meet the full identified housing need in Chichester District.

We do, however, have concerns over the "Proposed Strategic Locations/Allocations" target of 4,400, which is set set out in the table in Policy S4. Policy S3 "Development Strategy" sets out the 14 proposed strategic development locations for Chichester District, which would make up the total strategic allocations target of 4,400 dwellings from Policy S4. Further detail on these individual sites is provided in the "Strategic Site Allocations" section of the draft plan (pages 95-133). First, the total number of dwellings identified in the strategic development
locations in Policy S3 is 8,085. This number is significantly in excess of the 4,400 identified in Policy S4 and no explanation is given as to why the numbers differ. Second, the 14 strategic development locations identified in Policy S3 include 5 neighbourhood plan 'housing allocations' (totalling 2,550 dwellings). These are Policy AL8 East Wittering (350 dwellings); Policy AL9 Fishbourne (250 dwellings); Policy AL10 Hambrook (500 dwellings); Policy AL11 Hunston (200 dwellings) and Policy AL13 Southbourne (1,250 dwellings). Horsham Council would like to see further evidence that this number of neighbourhood plan sites can realistically be delivered within the identified timescales, given the inherent difficulties of both "making" neighbourhood plans and bringing forward development sites within these neighbourhood plans.

In addition to meeting Chichester's identified needs, Horsham Council notes and welcomes the reference in paragraph 4.23 to the West Sussex and Greater Brighton Strategic Planning Board, and attempting to address the objectively assessed housing and other development needs within the wider West Sussex and Greater Brighton area. Horsham District Council considers it important that all districts and boroughs within the Strategic Planning Board area work together to aim to meet as much of the longer term and unmet development needs of the wider sub-region as possible, through an accelerated work programme of Local Strategic Statement 3.

Policy S5 "Parish Housing Requirements"
Horsham Council notes and supports Policy S5, which allocates parish housing requirements for small sites between 2016 and 2035.

Policy S7 "Meeting Gypsies, Traveller and Travelling Showpeople Needs"
Horsham Council notes and supports Policy S7, which identifies a need for 91 additional permanent residential Gypsy & Traveller pitches and 28 additional plots for Travelling Showpeople, and states that where there is a shortfall in provision, a Site Allocation DPD will be prepared to allocate sites.

Policy S8 "Meeting Employment Land Needs"
Horsham Council notes and supports Policy S8, which sets out the identified employment floorspace requirement for 2016-2035 (231,835 sqm) and which seeks to meet it through an identified supply of 235,182 sqm.
I trust these comments are helpful. Horsham Council is keen to work with Chichester District Council in taking the Chichester Local Plan through to adoption.

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2494

Received: 07/02/2019

Respondent: Chidham & Hambrook Parish Council

Representation Summary:

Limited employment opportunities and no demand for existing premises in parish.

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.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2633

Received: 05/02/2019

Respondent: Barton Willmore

Representation Summary:

Concerns that no clear vision as to type of place being created/where employment fits in - should be overall vision.

More flexible approach to employment (like retail) should be taken.

Need for updated Employment Land Review.

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Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2700

Received: 07/02/2019

Respondent: Artemis Land and Agriculture Ltd

Agent: Dominic Lawson Bespoke Planning

Representation Summary:

Support employment land policy - land at Crouchlands Farm could contribute to provision of floorspace and should be allocated for mixed-use development

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Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2709

Received: 07/02/2019

Respondent: Gladman

Representation Summary:

CDC need to consider interrelationship of housing and employment and whether planned employment provision will require uplift in housing requirement

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Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2852

Received: 07/02/2019

Respondent: MR William Sharp

Representation Summary:

Object on grounds that; failure to acknowedge need for only low-carbon growth; failure to resist loss of green fields; transport links can be damaging; failure to acknowledge inherent values of landscape and heritage assets; no evidence that new office develoopment can be compatible with other existing commitments ie; protecting historic assets.

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Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3150

Received: 07/02/2019

Respondent: Rolls-Royce Motor Cars Limited

Agent: David Lock Associates Ltd

Representation Summary:

Object to omission of proposed RR strategic expansion land at Goodwood.

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Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3244

Received: 07/02/2019

Respondent: WSCC (Estates)

Agent: Henry Adams LLP

Representation Summary:

Amount of floorspace proposed feels optimistic given lead in times and economics.

Policy should reflect flexibility on differing opportunities for employment floorspace beyond B use classes

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Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3316

Received: 05/02/2019

Respondent: West Sussex County Council

Agent: Savills Plc

Representation Summary:

Policy wording is overly rigorous and could prevent appropriate development from coming forward.

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Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3477

Received: 06/02/2019

Respondent: Mr Colin Hammerton

Representation Summary:

Para 4.24 Site to the south of Goodwood airfield has been removed from the strategic site list for housing but there is no reason why it should not be considered for an employment site.

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Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3553

Received: 07/02/2019

Respondent: Berkeley Strategic Land Ltd.

Agent: WYG

Representation Summary:

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.

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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: