Policy S19: North of the Plan Area

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Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 95

Received: 10/01/2019

Respondent: Dr Carolyn Cobbold

Representation Summary:

The North of the district is probably more accessible to other areas than much of the southern part of the district. There is a need for more affordable housing throughout the SDNP and in villages and communities on its periphery

Full text:

The North of the district is probably more accessible to other areas than much of the southern part of the district. There is a need for more affordable housing throughout the SDNP and in villages and communities on its periphery

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 111

Received: 12/01/2019

Respondent: Mrs Alice Smith

Representation Summary:

The north of chichester should take a larger share of the required housing, instead of stuffing it all in Southbourne and Tangmere. These were once rural areas too.

Full text:

The north of chichester should take a larger share of the required housing, instead of stuffing it all in Southbourne and Tangmere. These were once rural areas too.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 694

Received: 31/01/2019

Respondent: Mrs Fiona Horn

Representation Summary:

If the north is generally excluded from development. Is it right that councillors who have no real insight into the uniqueness of the south have undue influence when voting on issues that are not going to affect their area? Seems very unfair.

Full text:

If the north is generally excluded from development. Is it right that councillors who have no real insight into the uniqueness of the south have undue influence when voting on issues that are not going to affect their area? Seems very unfair.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 786

Received: 02/02/2019

Respondent: Mrs C. Pierce

Representation Summary:

Plaistow village should have a defined settlement boundary that takes into its conservation area and with consideration of the many other housing development sites brought forward by Plaistow landowners.

Full text:

Para: 4.130 Given the present constraints on development in the area, the Local Plan Review provides for only limited growth focused on enabling these communities to continue to sustain its local facilities and contribute towards meeting locally generated housing needs, and support for the rural economy, in line with the overall Plan strategy and settlement hierarchy.

The current CDC CLPKP defines Plaistow and Ifold villages as a combined 'Service Village', the definition is as follows:
"Service Villages (local centre for services providing for villages and parishes): Villages that either provide a reasonable range of basic facilities (e.g. primary school, convenience store and post office) to meet the everyday needs of local residents, or villages that provide fewer of these facilities but that have reasonable access to them in nearby settlements." (CLPKP)

The settlement of Ifold is defined by a Settlement Boundary.

In the Settlement of Ifold there is no shop, pub, school, medical facilities or recreational facilities to meet the everyday needs of local residents, other than a village hall and a Scout & Girl Guide Hut both run by and reliant on volunteers.

Plaistow village is outside a settlement boundary, and therefore in the countryside (or "Rest of Plan Area" as defined in the current CLPKP Policy 2 - Development and Settlement Hierarchy).

In Plaistow village there is a primary school; village shop; Church; pub; village hall with youth club (with its own multi-use outdoor games area) and preschool (with its own dedicated outdoor play area); weekly Royal Mail Post Office outreach service; village green; outdoor, fenced children's playground; cricket pitch with practice nets and pavilion; and a football field with pavilion.

The notional link of the two settlements being classified as a combined 'service village' is, in reality, 'not reasonable', as householders in the Ifold settlement do not have comparable ease of access to facilities and services. Therefore, when evaluating sites for housing development across the entire Parish and with reference to the NPPF, a site in Plaistow village is more sustainably located than any site in Ifold, even within the limits of the 'service village' designation.

The service village notation in the Local Plan CLPKP revolves around reasonable access to services and facilities. In the case of Ifold 'reasonable access' can only be achieved by the use of a car or taxi service, whereas for Plaistow, village services and facilities may be accessed by residents on foot. Within the Service Village notation all potential housing sites are therefore not equal in terms of access to facilities and services.

Out of all the villages in the North of the District area, Plaistow village does not have a Settlement Boundary, yet it is a village that has the most number of facilities and services. All other villages have sustained considerable levels of new housing development over the past 15-20 years yet Plaistow village has not absorbed any of that housing.

The planning consultancy AECOM, appointed by Locality a partner organization of the Ministry of Housing, Communities and Local Government (MHCLG), conducted a Site Options and Assessment (August 2016) of the proposed housing sites to be considered for inclusion in the Plaistow and Ifold Parish Neighbourhood Plan. Their study concluded that the CDC Site Allocations DPD site had a high probability of being considered less sustainable in terms of national planning policy at Examination, than the alternative sites in Plaistow, given that the Ifold settlement currently has no services and few facilities - following the closure of its village store.
In the AECOM report (dated August 2016), under conclusions and recommendations (page 25) the following comments are drawn to the attention of Chichester District Council planning department:
'Ifold is fundamentally a less sustainable location than Plaistow.'
'The NPPF...would not support any further residential development at Ifold due to the lack of services and facilities within walking distance.'
'It would be virtually impossible for any party, including for CDC, to argue that development at Ifold would be justified for as long as there is no shop, school or pub in the village but there is a range of suitable and available sites at nearby Plaistow.'
* Importantly, this conclusion should be used in the case against the current allocation of Site 4 (Land to the North of Little Springfield Farm by CDC in their current Site Allocations Development Plan Document (SA DPD).
* The second bullet point on page 26 of the AECOM Report (August 2016) sets out that:
"The approach to sustainable development in the English planning system as set out in the NPPF and reiterated in both Chichester's adopted Local Plan and in the Little Springfield Farm appeal decision means that Plaistow is effectively the only settlement in the Parish that could be considered suitable for new housing development."

Plaistow village should have a defined settlement boundary that takes into its conservation area and with consideration of the many other housing development sites brought forward by Plaistow landowners. They are sites that were not discounted by the Parish Council in its neighbourhood planning activities but not brought forward as the housing allocation in the previous Local Plan had been accounted for in a suitable site Land opposite the village green, Common House Road, Plaistow. Defining a settlement boundary in Plaistow would manage any housing development to be brought forward by those landowners.

Further evidence in support of this is set out as follows:
* Ifold is approximately 2.4km from the centre of Plaistow village, which has the most facilities and services: a school, shop, Church, hall, post office services, village green, children's playground, other recreational facilities and a pub;
* Facilities and services in Ifold are limited to a village hall and a Scout Girl Guide HQ (which rely on volunteers);
* There are no public open spaces or a children's playground in Ifold;
* Plaistow Road, Ifold is a 40 mph speed zone up to the boundary and then becomes a 60 mph speed zone up to Plaistow village. There are no pavements. pedestrian crossings or street lighting to permit safe pedestrian access to the limited Ifold facilities or the facilities in Plaistow.
* The Local Education Authority (West Sussex County Council) 'Home to School and College Transport Policy' applied walking distances are: 3.218688 kilometres (two miles) in relation to a child who is under the age of eight; and 4.828032 kilometres (three miles) in relation to a child who has attained the age of eight. However, in approximately 1997/1998 West Sussex County Council made arrangements for the provision of bus transport for Ifold school children to and from Plaistow and Kirdford Primary School. This is because the Plaistow Road route is regarded by the County Council as too hazardous for a child to walk. The County Council were going to withdraw the free service that had been provided for a number years or withdraw the service entirely as they were not required to provide a bus. The only grounds to have a free service retained was safety, which the Parish Council proved and the County Council agreed.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1331

Received: 06/02/2019

Respondent: Mr Simon Davenport

Representation Summary:

This policy does not go far enough to ensure that housing provision is balanced for various parts of the city and to include the provision for limited development within national park villages where housing is needed for those working locally and requiring affordable housing.

Full text:

This policy does not go far enough to ensure that housing provision is balanced for various parts of the city and to include the provision for limited development within national park villages where housing is needed for those working locally and requiring affordable housing.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1877

Received: 06/02/2019

Respondent: Jennie Horn

Representation Summary:

Unequal distribution of housing between north of Chichester and along the A259

Full text:

Having trawled through the CDC Local Plan, which I have to say at the outset is the least user friendly document I have had the misfortune to read in a long time. The sceptic amongst me , would claim that CDC has deliberately done its best to make it as inaccessible as possible and these points go to explain my reasons for coming to that conclusion.

:- It was released just before Christmas, when CDC knows that people are busy.
:- It was released with very little advertising and only now has there been a little more effort but still not enough..
:- Very few public exhibitions have been put on or advertised , many actually put on by local communities horrified at what has been included.
:- Only available really to those who have access to the internet as there is a charge of £15 for a paper copy so excluding many of the older generation who do not have access to the internet.
:- the fact that the software being used only allows one response from an email address. Any others are not acknowledged.

I would like these issued raised and acknowledged. For such an important Consultation to be conducted in this matter is harmful and actually against a democratic process.

I have commented electronically but because of the constraint of 100 words this makes commenting properly very restrictive , I am therefore submitting this email as well and insist that both my electronic comments/objections are taken together and that neither is excluded.
I welcome a need for a Local Plan to safe guard the uniqueness and sustainability of our beautiful city, but this plan is wholly unfit for purpose. In places it is so biased and contradictory , it has actually made me laugh ! This is a Local Plan so why has there only been development in the South , East and West. For some reason Goodwood and the North has either been included and then removed or excluded completely. This is not a LOCAL PLAN, this is a biased and incomplete plan because of this exclusion.

The Southern and western areas that border Chichester Harbour AONB have been repeatedly included in the plan for significant development despite having the a same or greater criteria for exclusion than Goodwood and the area to the south SDNP which have been excluded. This invalidates the Plan as it contradicts all the criteria used and makes a mockery of the Plans integrity.

TRANSPORT

The transport study done by Peter Brett Assoc (PBA) is completely unfit for purpose. The study has only explored short term transport infrastructure which is completely unacceptable for this Plan which specifically states that is should be looking at short, medium and long term transport models especially the considering the Plan is supposed to last until 2035. It has included a link road in AL6 which was roundly opposed in the democratic Highways England (HE) consultation of 2016 along with hybrids of Options 2 and 3 also rejected, so it should not have been included unless all other options including the preferred Mitigated Northern route had also been included.

There has been no detail of how these large housing developments (over 2000 homes) along the A259 are going to access the A27 which is already at full capacity at the Fishbourne Roundabout. There is also no evidence that the required consultations between CDC, PBA and HE have taken place so any inclusion of link roads and junction upgrades are invalidate and should be removed and if not adequately addressed in future iterations of this plan , I will raise it with the examiner at the appropriate time .The PBA actually claims that there will not be an increase in air/noise/pollution by the building of a link road. REALLY ! You are proposing to build an elevated road (due to it being on a floodplain 3 zone !) which would have to be 4 metres high in an open flat topography, bordering the highly sensitive Chichester Harbour AONB with dark skies and noise/air pollution protection and restricting right turns only, necessitating Stockbridge and Whyke roundanabout traffic to travel twice as far and the report states that there would be no increase in air pollution.Absolutely ridiculous and totally unrealistic.They also state that there will be no further increase in air pollution despite traffic volume increasing year on year. Chichester, especially Stockbridge Roundabout has frequently breached air quality limits in recent years and continues to do so. So this part of the report is just nonsense.(DM24/SP28)
There is also no mention of any realistic funding. Again you cannot include junction upgrades which come under the jurisdiction of HE and for which no consultation evidence has been shown in the report. CDC Local Plan should not include any upgrades that they do not have confirmed funding for when the plan is produced. Anyone can produce a plan with a nice wish list but this does not make a professional /viable document .
CDC said itself that "any highways improvements should mitigate congestion on the A27"....the limited detail in this plan actually adds to the congestion it does not mitigate it and it again hugely disadvantages local traffic.

All the proposed developments along the A259, at Chidham/Hambrook, Bosham, Southbourne and Fishbourne all claim that they are sustainable because they have good transport links in the form of bus and rail links. They do not and these transport link viabilty and frequency cannot be influenced by CDC as they are run by independent companies. At present the bus service is fairly frequent at peak times but other times is not so cannot be relied upon. It is also not a very cheap option for many people. Rail links have been cut significantly in recent years with timetable rearrangements and places like Bosham and Southbourne have one train stopping once an hour at peak times, to and from Chichester. Not what I would call good links. and again is expensive..£2.80 for a single from Fishbourne...a journey of 5 minutes !! So these developments would realistically rely on cars again so increasing the burden on the Fishbourne of Emsworth junctions that are already running at full capacity.

Unless these issues are adequately addressed in future iterations of this plan, i will raise it with the examiner at the appropriate time.

HOUSING

( including 3.17,S3,S5,S19,4.3 )

Why is CDC not insisting that SDNP take back responsibility for the allocation of 41 houses a year . It would remove the need for CDC to find areas for another 200+ houses within their local plan and SDNP should be promoting small scale house building within the Park in order to sustain local services such as schools and local services which will die if more families are not encouraged.

Why has the north of Chichester ,been removed from the plan...houses along the A259 amount to well over 2000 houses with the same environmental sensitivities and yet houses south of the SDNP to Chichester NONE. There is no justification for this as there is suitable land around Goodwood airfield and Rolls Royce that could be used and was originally included in the plan but again was removed for no justifiable reason. Why can large villages like Lavant and Boxgrove not have any housing allocation ? They are classed as local service hubs as they have shops and schools and yet are excluded. Unless this is adequately addressed in future iterations of the plan, I will raise this with the examiner at the appropriate time.

New housing need to be smaller less intrusive developments so that they don't overwhelm and swamp existing residential areas. They also need to be a majority of affordable housing for people with local connections. These local connections should actually mean people born in the city or whose parents have lived in the area for the majority of their lives. Local young adults don't stand a hope of buying or even renting in Chichester as the prices are so high compared to wages of most ordinary people.There should be a ban on second homes and but if they do slip though and are rented out, then rents should be capped to make it less attractive to landlords.

New developments should not include 'executive' 4 and 5 bedroomed houses. There are enough of these in Chichester and so developments should consist of 1, 2 and 3 bedroomed properties only with a few 4 bedroomed houses to satisfy housing association demand.

Why are brownfield sites like the one bordering Swanfield Drive / Portfield near Sainsburys not being used for housing if demand is so crucial. We do not need anymore out of town entertainment which is killing the town centre.It should be reclassified for housing , as it would have less impact, is within walking distance of services and already borders residential areas..

Unless these issues are adequately addressed in future iterations of the plan, I will raise it with examiner at the appropriate time.

SCHOOLS/SERVICE INFRASTRUCTURES

(including 4.85)

Although there is lip service paid to providing schools, it is all very vague. If you are building developments of 250 + then you are going to need school provision. Most schools in places like Bosham are already at full capacity from local children so expansion or new schools need to be built very early on in any development. The threshold should be very low , for example when the 50th house of 250 is built, that way the services will already be in place before the houses are occupied. Most primary schools within Chichester city and surrounding villages are now already at full capacity necessitating parents to have to travel in cars to get their children to less local schools. The schools like Parklands Primary that have been expanded recently to take two form entry have suffered from substandard design and building. Stairs out of action for months. Disabled toilet out of use and worst of all classrooms too hot in summer due to lack of air conditioning which meant children had to be sent home for several days. This particular issue has still not been addressed so will occur next year when the temperature rises.

Although the Free School has recently been completed( but because of its site requires most children to access by car at least some if not all of the way,) relieving pressures on primary and secondary school places, no provision has been made for future developments around the southern peninsula of Witterings/ Bracklesham etc which necessitates huge transport movement twice a day as there is no secondary school provision within a 6 mile radius.

Funding for such new schools are not funded by CDC and therefore these should have been properly costed and funded before they could be legitimately included in the Local Plan...again a fictitious wish list !!

No mention of where people are going to find other services such as doctors and dentist, many of which are already running at full or near full capacity.If there are no services available locally then people will be forced to travel. No mention of increased travel because of this and lack of local school places in the Local Plan.

Unless these issues are adequately addressed in future iterations of this plan, I will raise it with the examiner at the appropriate time.

AIR QUALITY

DM24/SP28 There is no acknowledgement of the fact that the air quality levels especially at Stockbridge Roundabout exceeds quite substantially acceptable levels set by the Government. Such an omission is significant and has a huge influence on future planned developments and unless it is adequately addressed in future iterations of the plan, I will raise this with examiner at the appropriate time

AL6.

Well where do I start on such an utter inaccurate piece of wilful destruction and vandalism. AL6 contradicts everything that the Local plan states .
It does not protect the biodiversity of the area...It DESTROYS it
It does not protect the historic views of the only Cathedral visible from the sea...It DESTROYS it.
It does not enhance the natural environment (S26)... It DESTROYS it
It does has an adverse impact on the openness of views in and around the coast. (S26)..It DESTROYS them.
It does not have regard to flood and erosion policy (S27)...It WILL increase the likelyhood of flooding and contamination of Chichester Harbour water.
It does not protect the area from light/air/noise pollution(DM23/24 etc)....it would DESTROY the dark skies policy and hugely increase air pollution.

I could continue. AL6 should be removed completely. The Plan itself states that no proper study has been done into the impact of AL6 and so that very admission should have been enough to exclude it from the plan.How can you include a destructive option like this without doing any sort of environmental study or impact study first. Unprofessional and disgraceful AL6 comes within 100 metres of Chichester Harbour which has AONB status which holds the same protection as the SDNP but does not have the same 5km exclusion that the SDNP has been given....strange that !! Unfortunately Chichester Harbour does not have a landed Estate as its neighbour !!

AL6 is on a category 3 Floodplain , which under Governments own rational means that it should not be developed for housing or industry at all because of the unacceptable flood risk and only then developed if ALL other less risky sites have been developed first and only then for suitable light use. Land to the south of the SDNP has been removed due to it being under risk of flooding and yet it is mainly classed as Flood zone 2 , a lesser risk. So why was it removed for this reason and AL6 left in place ?
INCONSISTENCY and BIAS. REMOVE AL6.

Under CDC own data, a link road would need to be elevated to 4 metres in order to be safe from flooding.How on earth are you going to mitigate a road that high which is on a flat topography with historic views of Chichester and the Cathedral ? .This would then contravene Government policy on pollution and housing , as the toxic fumes from the road would reach higher into the air.REMOVE AL6.

This link road and Options 2/3 were hugely unpopular in the 2016 Highways England Democratic Consultation and were emphatically rejected by the vast majority of Chichester residents as they knew it would be short term and ineffectual and that along with the no right turns at junctions would hugely hinder the movement of local traffic. CDC were seen to accept that and Cllr Dignum said that "any Highways improvement should mitigate congestion on the A27". Clearly this scheme would not and so why is the link road included. If you want an unbiased complete Plan then surely the mitigated Northern route should have been included in this plan as the criteria are the same...no funding and no HE acceptance, or exclude both proposals. Again double standards to the detriment of the south.No roads should have been included as they do not come under CDC remit or funding and the protection under Para 3 AL6 is unachievable. Total betrayal under Cllr Dignum leadership.REMOVE AL6

In order to instigate a link road , junction upgrades are also mentioned...(but not funded by CDC and no consultation evidence with HE in the Local Plan S23 and PBA report) Each junction is estimated to take a minimum of 3 yrs to complete, that's 15 years of gridlock, air pollution and misery. Seriously. Chichester city and tourist industry would be destroyed. REMOVE AL6

There is no mention of only a 100 metre border with the Chichester Harbour AONB and yet frequent reference is made to the SDNP 1km border. Double standards and inconsistency again.REMOVE AL6

There is no mention that the land earmarked in AL6 is floodplain 3 category. Frequent reference to SDNP/Goodwood being in Flood zone 2 and a small amount in Flood plain 3. Again double standards and inconsistency. REMOVE AL6

No mention to the destruction of the views and yet time and again SDNP/Goodwood views of the Cathedral are mentioned and pushed. The views from SDNP/Goodwood are far less prominent and actually are invisible because of the topography of the land in many places. Not the case for views in AL6 where uninterrupted views of the Cathedral can be seen from the coast in almost any position looking north. Double standards and inconsistency again.REMOVE AL6

No amount of mitigation could protect Chichester Harbours unique ecology. It has status as an AONB, SPA,SAC,SSSI and is a Ramsar site. There is no detail of how a successful buffer zone would be applied.There appears to be no room for a proper successful wildlife buffer zone, with proposed building up to 100 meters of the harbour.There would be significant adverse ecological damage done, from light, noise and especially air pollution,which already breaches Government and EU safe levels. There is no mention of waste water management and the capacity for any further waste water to be processed at Apuldram Water Treatment plant is not an option as it has reached capacity so the risk of polluted water entering Chichester Harbour is incredibly high and an unacceptable risk.(Policy S18) REMOVE AL6

There are other much more suitable areas already identified around Goodwood Airfield and Rolls Royce which meet the criteria set out in the plan for housing and light industrial employment and already have suitable infrastructure but have been unjustifiably removed. These should be reinstated and AL6 REMOVED.

Any development of AL6 would necessitate movement by car due to its proximity to the A27 .This is against CDC Local plan policy of encouraging any new developments to either be well served with public transport or sustainable transport ie cycling and walking. The position of this site will not meet this criteria. REMOVE AL6.

There is no mention of the fact that this site is part of the River Lavant floodplain. Those of us who remember the 1990's , remember the hugely damaging flooding that affected Chichester partly because the water courses and natural drainage had been allowed to deteriorate. AL6 covers a significant part of the River Lavant natural drainage basin. It would be insane to build on this land. It could well result in renewed flooding in the city centre as we get wetter winters and the rain water has no where to go.REMOVE AL6.

The plan is totally inconsistent as to numbers in the development. How can we possibly comment on a plan that in one place states there would be 100 houses and industrial units in AL6 and yet elsewhere it says 200 + homes and industrial units. Ridiculous inconsistency and very unprofessional. REMOVE AL6.

Unless all these issues are adequately addressed in future iterations of the plan, I will raise these with the examiner at the appropriate time.

In summary, The CDC Local Plan in its form at present should be rejected and rewritten with the inconsistency and bias removed. Any development site should only be include when a proper and realistic viability study has been commissioned by independent consultants who will have been given a complete and unbiased brief (unlike the PBA study which is incomplete ,short term and does not reach the brief that was supposedly set). This is hugely important to the Chichester area and its residents. We want and deserve a fair ,complete and transparent plan and this version is not.

CDC along with WSCC should go to central Government and insist that until proper funding is put in places to sort the transport/A27 and services (Schools etc) infrastructure out then although the Plan can be written, no housing will be built until funding has been secured and work started on this vital infrastructure. We cannot sustain this level of development without serious investment on infrastructure and the addressing of dangerous pollution levels because of the lack of it.

Until this Plan has been fairly and properly amended so it provides a properly informed, fair and complete document it should not be adopted and should then be rewritten and only then reissued for full public consultation again. Unless this is adequately addressed in future iterations, I will raise it with the examiner at the appropriate time.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1890

Received: 07/02/2019

Respondent: William Fleming

Representation Summary:

The SDNP (Policy S3, Policy S5 and Policy S19) should share some of the development or have a northern route around Chichester.

Full text:

Policy S23 is not acceptable as this is similar to the Highways England Option 2 which was comprehensively rejected by the public. If S23 were to be implemented according to the Peter Brett consultation then The South Downs National Park (SDNP) should have to take more housing and trade development to relieve the pressure that would be put on the Manhood Peninsula.
The Manhood cannot cope with any more development without having a complete upgrade of the A27, not the Peter Brett S23 option.
The SDNP (Policy S3, Policy S5 and Policy S19) should share some of the development or have a northern route around Chichester.
Site AL6 Land South West of Chichester (Apuldram and Donnington Parishes) is within a flood plain with the River Lavant running directly through the middle of the area.
This area should remain a strategic gap between the two parishes and efforts concentrated on the area being more gainfully used as a green wildlife corridor.
This area should be removed and use the alternative land near Goodwood; Policy AL6, S15, S16.

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2251

Received: 01/02/2019

Respondent: Historic England

Representation Summary:

Historic England welcomes and supports "Conserve and enhance the rural character of the area, the quality of its landscape and the natural and historic environment;" in Policy S19 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Full text:

Paragraph 1.5 of the Local Plan Review states "This Plan seeks to balance the economic, social and environmental dimensions of sustainable development". "Balance" implies some gains and some losses. However, this does not reflect the four bullet points that follow this sentence.
In addition, Paragraph 8 of the National Planning Policy Framework explains that;
"Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives)".

We therefore suggest that "balance" is not the most appropriate word.

The three overarching objectives include; "c) an environmental objective - to contribute to protecting and enhancing our natural, built and historic environment......". We therefore welcome the fourth bullet point of paragraph 1.5; "Protecting and enhancing the unique and special qualities of our environment".

Reword the first sentence of paragraph 1.5 as; "This Plan seeks to deliver the economic, social and environmental dimensions of sustainable development in mutually supportive ways".

Paragraph 1.16 explains that the National Planning Policy Framework reiterates the importance of significantly boosting the supply of new dwellings, whilst ensuring provision for other development needs including economic growth.
Whilst not untrue, we consider that this does not fully represent the Government's objectives and policies as set out in the Framework and therefore gives the misleading impression that the Framework is only about housing supply and economic development.
In fact, the protection and enhancement of the natural, built and historic environment is also identified as important in the Framework e.g. in the environmental overarching objective for the planning system as set out in paragraphs 8, 11b)i and 20 d).
Reword the final sentence of paragraph 1.16 as:
"The importance of significantly boosting the supply of new dwellings is reiterated, whilst ensuring provision for other development needs including economic growth and protecting and enhancing the natural, built and historic environment".
Paragraph 31 of the National Planning Policy Framework requires "The preparation and review of all policies should be underpinned by relevant and up-to-date evidence". We previously expressed our concerns about the historic evidence base for the policy framework for the district when commenting on the Issues and Options stage of the Local Plan Review;
"We are aware of the Council's series of Conservation Area Character Appraisals, The Future Growth of Chichester Study and the Landscape Capacity Studies. However, the Council's "Supporting documents" webpage has no historic environment documents and we are not clear if the Council has other historic environment evidence e.g. is there an extensive urban survey of Chichester or other townscape or characterisation study ? Is there an urban archaeological database ? Is there a list of locally important heritage assets ? Has the Council undertaken a survey of grade II buildings at risk ?".
However, looking at the Council's Local Plan Review Preferred Approach Plan - Evidence Base - December 2018 webpage, the only specific historic environment evidence base document identified is the Chichester Historic Environment Strategy and Action Plan. Whilst we welcome the Strategy, we have previously expressed the view that we do not consider that it forms, by itself, an adequate historic environment evidence base for the Local Plan Review.
We are aware that the Council has a list of locally important buildings, but that Chichester was not covered by the West Sussex Extensive Historic Town Surveys - perhaps as it was thought a candidate for the more intensive approach of an Urban Archaeological Database (UAD). However, we are not aware that such a UAD exists, and whilst we are aware of the Council's Historic Environment Record (the availability of which accords with paragraph 187 of the National Planning Policy Framework), we do wonder if the archaeological evidence and significance of the city is fully understood and readily available. We suggested that the Historic Environment Strategy could set out actions to enhance understanding and management of the archaeological resource of the historic city and we would be pleased to discuss how we might be able to assist with this.
We will expect the Council to have an adequate, up-to-date and relevant historic environment evidence base and to demonstrate in the Pre-Submission Local Plan how that historic evidence base has informed and influenced the Plan's policies and site allocations.
The historic environment evidence base for the Local Plan Review should be set out on the Council's Evidence Base webpage. If there are indeed gaps in that evidence base, then these should be filled and that evidence taken on board in preparing the Pre-Submission Local Plan Review document.
Historic England welcomes and supports the reference to the historic environment of Chichester district, and the heritage assets therein, in paragraphs 2.27 and 2.28 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Historic England welcomes and supports, in principle, the identification of "Protect the area's valuable heritage and historic assets" as one of the challenges faced by the Plan.
However, the National Planning Policy Framework requires local plans to deliver an environmental overarching objective which includes "to contribute to conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and to include strategic policies to make sufficient provision for "conservation and enhancement of the natural, built and historic environment" (our underlining).
The Framework therefore requires local planning authorities, through their local plans, to do more than just conserve the historic environment i.e. to enhance it as well. This should be identified as a challenge (although it is also an opportunity).
Reword the last bullet point of paragraph 2.28 as; "Protect and enhance the area's valuable heritage and historic assets".
Historic England welcomes, in principle, as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework, the reference to the historic environment in paragraph 3.1;

"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while supporting the historic and natural environment".

However, the National Planning Policy Framework refers to "conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and the "conservation and enhancement of the natural, built and historic environment". We therefore suggest that "supporting" should be "conserving and enhancing" as terminology more consistent with the Framework and possibly ambiguous than "supporting".

Reword the first sentence of paragraph 3.1 as;
"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while conserving and enhancing the historic, built and natural environment".
Historic England welcomes the inclusion of "Have a quality of life that is enriched through opportunities to enjoy our local culture, arts and a conserved and enhanced heritage;" in the Vision as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes "As an historic walled cathedral city, its rich cultural and architectural heritage will be conserved, enhanced and promoted together with the views and landscape value afforded by its setting" in paragraph 3.4 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "The conservation and enhancement of the historic environment, the high quality landscapes and the agricultural and other rural activities that support it will remain paramount" in paragraph 3.14 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports, in principle, the Strategic Objective "Conserve and enhance landscape and heritage" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. However, we suggest that it could be rather more ambitious e.g. "Conserve, enhance, increase appreciation and enjoyment of and access to heritage"
Paragraph 4.2 states that; "New development must achieve sustainable development principles and must not adversely affect the character, quality, amenity or safety of the built environment, wherever it occurs". The implication is that this is a requirement of the National Planning Policy Framework, but we cannot find this exact wording in the Framework.

However, paragraph 127 of the Framework does set out what planning policies and decisions should ensure of developments, including "are sympathetic to local character and history" and "establish or maintain a strong sense of place". In addition, paragraph 185 of the Framework requires plans to set out a positive strategy for the conservation and enjoyment of the historic environment, which should take into account "the desirability of new development making a positive contribution to local character and distinctiveness".

We therefore consider that the final sentence of paragraph 4.2 should be revised to more closely reflect the requirements of the National Planning Policy Framework.

Reword the final sentence of paragraph 4.2 as ""New development must achieve sustainable development principles, must not adversely affect the history, quality, amenity or safety of the natural, built and historic environment and should make a positive contribution to local character and distinctiveness and establish or maintain a sense of place". (Alternatively, these could be set out as bullet points for clarity).
Historic England welcomes and supports "enhance the quality of the built, natural, historic, social and cultural environments" in Policy S2 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Although the historic environment is not identified as a constraint or as an opportunity for enhancement in paragraph 4.12 as a factor in the definition of the Settlement Hierarchy, we note that paragraph 4.14 does explain that consideration has been given to other factors in determining whether a settlement is a suitable location for additional housing growth. We would like to think that these other factors include the potential effects on the historic environment.
Historic England welcomes and supports "where possible enhances the character, significance and setting of heritage assets" as one of the considerations to guide potential discussions on a possible site for a new settlement in paragraph 4.33 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessments" in paragraph 4.90 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we suggest that reference should also be made to heritage impact assessments to underpin the planning of new development.
Reword paragraph 4.90 to read;
"it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessment and heritage impact assessments".
Historic England welcomes and supports "such development will need to be sensitive to the
historic character of the city" in paragraph 4.91 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "conserve and enhance the city's historic character and heritage", "Enhance the city's existing heritage, arts and cultural facilities", "Protect views of the cathedral" and "All development will be required to have special regard to the city's historic character and heritage. Development proposals should be underpinned by historic characterisation assessments and make a positive contribution to the city's unique character and distinctiveness" in Policy S13 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we would like to see a reference to heritage impact assessments to underpin development proposals.
We also wonder if it would be helpful to have a specific policy to protect important views, allied to or combined with a policy for tall buildings in the historic city ?
Reword Policy SP13 to read "Development proposals should be underpinned by historic characterisation assessment and a heritage impact assessment......".
Historic England welcomes and supports "Any development proposals within the vicinity of the site must clearly demonstrate how the development would protect, and where possible enhance, the operation and heritage of the site as a motor-circuit and airfield" in Policy S15 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site" in Policy S17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would prefer "significant archaeological assets" to be retained in situ.
Reword Policy S17 as;
"All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site, with any significant archaeological assets retained in situ".
Paragraph 2.2 of the Plan notes that the North of the Plan Area has "rich cultural and heritage assets". We are surprised, therefore, that paragraph 4.128 has no mention of these assets.
Reword paragraph 4.128 "This part of the plan area is predominantly rural with few sizeable settlements, characterised by undulating countryside with a high proportion of woodland, typical of the Low Weald landscape. Conserving the rural character of the area, with its high quality landscape and natural and historic environment, is a key objective".
Historic England welcomes and supports "Conserve and enhance the rural character of the area, the quality of its landscape and the natural and historic environment;" in Policy S19 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes paragraph 5.1 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Strictly-speaking, historic parks and gardens are registered for their special historic interest rather than their protection per se, but one of the purposes of Registration is to encourage appropriate protection and inclusion on the Register is a material consideration in the determination of planning applications.
Historic England welcomes paragraph 5.5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports Policy S20, particularly the references to history, historic character and local identity in clause 1, sense of place in clause 2, character in clause 8 and high quality public realm in clause 11 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would also like to see a specific clause relating to heritage assets.
Add a new clause; "conserves or enhances the significance, special interest, character and appearance of heritage assets".
Historic England welcomes and supports paragraph 5.12 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, paragraph 5.13 states that "Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and seek to avoid or minimise any conflict between the conservation of the heritage asset and any aspect of the proposal" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
This very largely reflects paragraph 190 of the National Planning Policy Framework, but the Framework requires local planning authorities to take the particular significance of any heritage asset that might be affected by a proposal into account when considering the impact of a proposal on a heritage asset, "to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal". The requirement is clear - any conflict should be avoided or minimised; it is not sufficient to merely "seek to" avoid or minimise that conflict.

In addition, paragraph 189 of the Framework states;

"In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting......Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.

There is, therefore, a clear onus to be placed upon the applicant/developer to identify and describe the significance of any heritage assets affected.

Paragraphs 193, 194, 195 and 196 of the Framework set out how local planning authorities should consider the impact of a proposed development on the significance of a designated heritage asset. We believe that this could usefully be summarised in the Plan.

Reword paragraph 5.13;
"Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and take that significance into account when considering the impact of a proposal on a heritage asset, to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal".
Add new paragraphs;
"For applications which affect, or have the potential to affect, heritage assets the applicant will be expected to describe the significance of the asset and its setting, using appropriate expertise; at a level of detail proportionate to its significance and sufficient to understand the potential impact of the proposal; using appropriate references such as the Historic Environment Record and, if necessary, original survey (including, for assets of archaeological interest, an appropriate desk-based assessment and, where necessary, a field evaluation)";
"When considering the impact of a proposed development on the significance of a designated heritage asset, the Council will give great weight to the asset's conservation. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), will require clear and convincing justification"; and

"The Council will refuse proposals that would lead to substantial harm to (or total loss of significance of) a designated heritage asset unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply. For proposals that would lead to less than substantial harm to the significance of a designated heritage asset, the Council will weigh this harm against the public benefits of the proposal".

Historic England welcomes and supports Policy S22, which we consider complies with the requirements of paragraphs 17 and 20 of the National Planning Policy Framework to contain strategic policies and for those strategic policies to make sufficient provision for the conservation and enhancement of the historic environment.

We also consider that the policy forms part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the word "positive" is significant, and we believe that the Plan (and Council) should be proactive in the conservation and enhancement of the historic environment. National Planning Practice Guidance states "Such a [positive] strategy should recognise that conservation is not a passive exercise".
We therefore consider that the positive strategy for the conservation and enjoyment of the historic environment is not a passive exercise but requires a plan for the maintenance and use of heritage assets and for the delivery of development including within their setting that will afford appropriate protection for the asset(s) and make a positive contribution to local character and distinctiveness. We therefore look to local plans to contain commitments to positive measures for the historic environment. We therefore welcome the commitments within Policy S22 to positive actions, including heritage at risk, which paragraph 185 requires to be part of that positive strategy for the conservation and enjoyment of the historic environment. However, we do feel that the supporting text could helpfully explain a little more about the Council's approach to heritage at risk, perhaps borrowing some text from the Chichester Historic Environment Strategy and Action Plan.
We also consider that the positive strategy should comprise recognition throughout the Plan of the importance of the historic environment, of the historic environment's role in delivering the Plan's vision and the wider economic, social and environmental objectives for the Plan area, and of the potential impacts of the Plan's policies and proposals on the historic environment.
We are pleased to have identified a number of references throughout the Plan to the historic environment and we therefore consider that the Plan sets out an adequate positive strategy for the conservation and enjoyment of that historic environment as required by paragraph 185 of the National Planning Policy Framework and that the Plan is therefore compliant with that paragraph.

Add a new paragraph explaining what "heritage at risk" is and the Council's approach to assets at risk e.g.

"Unfortunately, heritage assets can be at risk from neglect, decay or other threats. Designated assets at risk, with the exception of Grade II secular buildings and Grade II places of worship used less than six times a year, are identified on the Historic England Heritage at Risk Register. Within the district outside the South Downs National Park, six assets are on the Register (February 2018): three scheduled monuments, two listed buildings and one conservation area. The Council will actively seek to address threats to heritage assets by recording and monitoring Heritage at Risk in Chichester District, publishing it on our website and working with the owners of heritage assets at risk to find solutions and secure repairs to bring them back into active use, including where appropriate viable new uses and/or proposals for enabling development so they are preserved for future generations."

Historic England suggests that paragraph 5.37 could also refer to the range of heritage assets to be found in the countryside of the Plan area.
Reword paragraph 5.37 as;

"It is valued for many reasons, including agriculture and community food production, its landscape qualities including the special characteristics of Chichester Harbour and Pagham Harbour, the setting it provides for Chichester City and other towns and villages, its range of heritage assets, including historic landscapes, and the opportunities it provides for recreation and biodiversity".
Historic England welcomes and supports clause d of Policy S32; "integrate with the surrounding built, historic and natural environments" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
As noted in paragraph 6.12, the Chichester Entrenchments Scheduled Monument lies partly within and partly immediately to the north of the site. Paragraph 194 of the National Planning Policy Framework identifies Scheduled Monuments as being assets "of the highest significance", substantial harm to or loss of which should be wholly exceptional.

We have previously commented (as English Heritage) on the allocation of this site during the consultation on the Key Policies. We explained that development close to the earthworks might harm the historical value of the heritage asset by interrupting views between its parts and introducing incongruous land-use in its immediate surroundings. This in turn would make it difficult to appreciate the asset's open rural setting, its extensive linear nature and its purpose of enclosing large areas of open land.

Accordingly, we initially objected to the form of the allocation in the Key Policies, but subsequently withdrew that objection following amendments to the boundary of the Strategic Development Location on its northern side so that the boundary ran along the south edge of the belt of woodland in which the scheduled monument sits, thereby entirely excluding the monument from the SDL, and the allocation of the northern area of the amended site as open space.
We are therefore pleased to see that the Strategic Site Allocation still excludes the scheduled monument. We also welcome and support the following requirements of Policy AL1, which we consider provide, in principle, adequate protection for the Scheduled Monument in accordance with the National Planning Policy Framework:
6. Landscaped to protect priority views of Chichester Cathedral spire;
7. Keep land north of the B2178 in open use, free from built development, to protect the natural history interest of both Brandy Hole Copse, and the setting of the Chichester Entrenchments Scheduled Monument;
8. Conserve, enhance and better reveal the significance of the Chichester Entrenchments Scheduled Monument and other non-designated heritage assets and their settings and to record and advance understanding of the significance of any heritage assets to be harmed or lost;
However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Shopwyke Strategic Site Allocation, which we note is an existing allocation.
However, the Grade II listed barn at Greenway Farm is located to the south-west of the site and the Grade II listed Shopwyke Grange and the Grade II* listed Shopwyke Hall are located to the south-east. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL2, which we consider provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework:
7. Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm and the cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan.
However, we consider that reference should also be made to the Grade II listed Shopwyke Grange. This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 7;"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm, the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
According to our records there are no designated heritage assets on this site, although the Grade II listed Shopwyke Grange and Grade II* listed Shopwyke Hall lie to the north-east of the allocated area, Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

We note that criterion 7 of Policy AL2 requires the development of the Shopwyke Strategic Site Allocation to ".......conserve and enhance the historic significance of the......cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan. We have suggested in our comments on this policy that it include reference to the listed Shopwyke Grange, and we consider that this requirement should also be included in Policy AL3 to provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework.

Historic England welcomes and supports criterion 8 of Policy AL2; "Existing views of Chichester Cathedral spire are to be protected". However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as;
"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
Historic England makes no comment on the principle of the two sites at Land at Westhampnett/North East Chichester Strategic Site Allocation, which we note were part of a broad strategic development location in the adopted Local Plan.
However, the site abuts the Graylingwell Hospital Conservation Area, the buildings of the former 'pauper lunatic asylum' (including the Grade II listed chapel), the Grade II listed Summersdale Farmhouse and a Grade II registered park and garden. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".
Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL4, which we consider provide, in principle, adequate protection for these designated assets in accordance with the National Planning Policy Framework:
9. Development should be designed with special regard to the Graylingwell Hospital
Conservation Area, the buildings of the former 'pauper lunatic asylum' and the Grade II registered park and garden in which they sit, and to other listed buildings in the vicinity of the site and their settings. Important views of Chichester Cathedral spire from the area should be protected;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Southern Gateway Strategic Site Allocation.
However, the site includes a row of Grade II listed buildings on Southgate and a number of non-designated heritage assets (the southern gateway of the city had Roman roads converging upon it and this is likely to result in enhanced archaeological potential in this part of the city. The development of suburbs in the medieval and later periods is a further factor with both the canal and railway as examples of later uses of the area. There are a number of buildings of interest, including the former Law Courts and Bus Garage). Part of the site lies within the Chichester Conservation Area and there are listed buildings adjacent to the site.
Paragraph 184 of the National Planning Policy Framework states heritage assets "are an irreplaceable resource, and should be conserved in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of existing and future generations". Paragraph 194 of the Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".

Historic England therefore welcomes and supports, in principle, the following requirements of Policy AL5;

3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals, as appropriate;
However, we consider that these requirements should be strengthened to ensure that they provide adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we consider that Policy AL5 should promote more strongly the opportunity to use the heritage of the area to help define its character and the desirability of new development making a positive contribution to local character and distinctiveness as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
These comments are without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword clause 2 as follows;
Proposals should include a high quality distinctive design response appropriate to this gateway location and based on the character and heritage of the area, which establishes a clear hierarchy of streets and spaces, active frontages of buildings which front streets and spaces with clearly defined building lines;
Reword clause 3 as follows;
3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area, including the Conservation Area, listed buildings (both on and adjacent to the site), non-designated buildings of historic interest and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
Reword clause 9 as follows;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals;
According to our records, the site Land South-West of Chichester (Apuldram and Donnington Parishes) contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
Historic England welcomes and supports clause 3:
3. Protect existing views of Chichester Cathedral spire and the setting of the Chichester Harbour Area of Outstanding Natural Beauty which should be analysed at an early stage of the masterplan;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
According to our records, the site at Highgrove Farm, Bosham, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.

Historic England has no comments on the principle of land being allocated in the revised Fishbourne Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Fishbourne identified in paragraph 6.65 of the Plan is "Protecting the heritage assets of Fishbourne and their setting".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL9, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL9;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings and the Fishbourne Roman site Scheduled Monument, or the character or appearance of the Fishbourne Conservation Area".
Historic England has no comments on the principle of land being allocated in the revised Chidham and Hambrook Neighbourhood Plan for a minimum of 500 dwellings.
However, we consider that Policy AL10 should include a specific requirement to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL10;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets.
Historic England has no comments on the principle of land being allocated in the revised Hunston Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Hunston identified in paragraph 6.77 of the Plan is "Respecting the setting of listed buildings and the Hunston conservation area".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL11, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL11;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Hunston Conservation Area."
According to our records, the site Land north of Park Farm, Selsey, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.

This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England has no comments on the principle of land being allocated in the revised Southbourne Neighbourhood Plan for a minimum of 1,250 dwellings.
However, we consider that a specific requirement should be included in Policy AL13 to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL13;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Prinsted Conservation Area."
Historic England has no comments on the principle of the allocation Land West of Tangmere.

However, the site is close to the Tangmere Conservation Area and a number of listed buildings, including the Grade I listed Church of St Andrew. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade I buildings as assets of the "highest significance".

Historic England therefore welcomes, in principle, clauses 5 and 8 of Policy AL14

5. Protect existing views of Chichester Cathedral spire and reduce any impact on views from within the National Park;
8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, including the expansion or relocation of the Tangmere Military Aviation Museum.
However, we consider that clause 8 should be strengthened to ensure that it provides adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we note that paragraph 6.95 of the Plan identifies, as one of the specific issues need to be taken into account in planning the development and site layout at Tangmere, "Conserving and enhancing the setting of the historic village (particularly the Conservation Area"). We consider that this should be included within Policy AL14.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as follows:

8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, particularly the Conservation Area and the Grade I listed Church of St Andrew and including the expansion or relocation of the Tangmere Military Aviation Museum.
Add a new criterion as follows:
""Conserve and enhancie the setting of the historic village, particularly of the Conservation Area".
Historic England welcomes and supports clause b of Policy DM3 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clauses 1 c and 2 e of Policy DM5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, clause 2 of Policy DM13 but considers that the policy should be, in the first instance, to avoid adverse impact on the historic environment as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the wording used in Policies DM3 and DM5 would be appropriate.
Reword clause 2 of Policy DM13 as:
"Is located so as not compromise the essential features of nationally designated areas of landscape, historic environment or nature conservation protection".
Historic England welcomes and supports clause 1 of Policy DM17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clause b of Policy DM20 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports paragraph 7.129 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Many farm buildings that are now redundant for modern farming needs are likely to be of historic interest - it is acknowledged that farm buildings are generally under-represented on the National Heritage List for England. Historic England considers that Policy DM21 should include stronger protection for such buildings as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Add a new criterion to Policy DM21 as follows:

"Features of architectural or historic significance are retained and, where the building forms part of a historically significant complex of buildings, consideration is given to the future use(s) of those buildings and the impact of the proposal on the integrity and character of the complex".
Historic England welcomes and supports, in principle, paragraphs 7.154 - 7.161.
However, we consider that paragraph 7.154 should be reworded to clarify the distinction between designated and non-designated heritage assets (the latter including buildings on the Local Buildings List for Chichester).
Reword paragraph 7.154 as follows:
"There are a large number of "Heritage Assets" (as defined in the National Planning Policy Framework), both designated and non-designated, in the plan area. Designated assets are Listed Buildings, Scheduled Monuments, Conservation Areas and Registered Historic Parks and Gardens. Non-designated assets include archaeological sites (although the remains may be of national significance equivalent to scheduled monuments, and which should be considered subject to the policies for scheduled monuments) and non-listed buildings which have been identified as locally important, such as those on the Local Buildings List for Chichester City and 'positive' buildings within Conservation Areas."
Historic England welcomes and supports in principle, Policy DM27 both as part of the positive strategy for the conservation and enjoyment of the historic environment as required by paragraph 185 of the National Planning Policy Framework and also as a non-strategic policy for the conservation and enhancement of the historic environment as suggested by paragraph 28 of the Framework.
However, we consider that clause e. should specify the (wholly) exceptional circumstances in which permission for a proposed development that would lead to substantial harm to (or total loss of significance of) a designated heritage asset would be granted i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

We would also welcome the policy being more detailed in terms of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset, as do, for example, Policies EH10, EH11, EH14 and EH15 of the West Oxfordshire Local Plan 2031. These policies were developed with Historic England and the Inspector that examined the Local Plan 2031 shared our concern that the historic environment policy in the Local Plan 2031 provided inadequate locally specific detailed policy guidance and considered the more detailed policies necessary for the Plan to be sound.

(However, we do acknowledge that the Inspector that examined the Key Policies development plan document considered the modified historic environment policy (Policy 47) put forward by the Council with our support was sufficient for the Plan to be sound, and that Policy DM27 in the Local Plan Review very largely repeats Policy 47).

Reword clause e. of Policy DM27 as follows;
"Development involving substantial harm to or loss of designated heritage assets will
only be granted in exceptional circumstances (wholly exceptional circumstances for
designated assets of the highest significance) i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

More details of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset. We would be pleased to work with the Council on a revised policy or policies.

Paragraph 7.195 of the Plan notes that the remnants of canals "are important early 19th Century historic features in the landscape of the coastal plain and warrant protection".
Historic England agrees with this statement, but Policy DM33 makes no mention of protecting the historic significance of the remaining canal sections.
Reword the first paragraph of Policy DM33 as follows;
"Development that makes provision of through navigation or enhancement of the Chichester Ship Canal and the Wey and Arun Canal will be supported where it meets environmental, ecological, historical and transport considerations."
Historic England welcomes and supports clause 3 of Policy DM34 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2837

Received: 06/02/2019

Respondent: Casa Coevo

Agent: Verve Planning

Representation Summary:

The policy wording is too restrictive and does not allow flexibility for small scale housing that is not included in policies S3 and S5.

Full text:

See attachment

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3132

Received: 04/02/2019

Respondent: Mrs Sarah Sharp

Representation Summary:

Last bullet point isn't compatible with WSCC's decision to cut bus services.

Full text:

See attachment

Attachments: