Chichester Local Plan 2021 - 2039: Proposed Submission

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Object

Chichester Local Plan 2021 - 2039: Proposed Submission

1.25

Representation ID: 4076

Received: 14/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Council has not engaged constructively with Chichester Harbour Conservancy. In the run-up to this consultation, there has been no dialogue to address the key strategic matters of housing provision, biodiversity, the landscape and setting of the AONB, etc. The Conservancy has not yet been asked to agree a Statement of Common Ground. This is all disappointing since the Conservancy is the Statutory Joint Advisory Committee for the AONB, yet we are not part of the plan-making process.

Change suggested by respondent:

1. List the local authorities and organisations that are being actively engaged.
2. Make an effort to come and speak to the Conservancy about the Local Plan, the value of the AONB, the Wildlife Corridors, etc.
3. Seek a Statement of Common Ground with the Conservancy.

Full text:

The Council has not engaged constructively with Chichester Harbour Conservancy. In the run-up to this consultation, there has been no dialogue to address the key strategic matters of housing provision, biodiversity, the landscape and setting of the AONB, etc. The Conservancy has not yet been asked to agree a Statement of Common Ground. This is all disappointing since the Conservancy is the Statutory Joint Advisory Committee for the AONB, yet we are not part of the plan-making process.


Our response:

For clarification, the Chichester Harbour Conservancy are not one of the prescribed duty to cooperate bodies. They have been consulted at all stages of plan making.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

2.1

Representation ID: 4077

Received: 14/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

"There are 33 parish councils located within the Local Plan area, including six parishes which are also partly located within the South Downs National Park." Since this is a section on characteristics, why is the AONB not acknowledged?

Change suggested by respondent:

"There are 33 parish councils located within the Local Plan area, including six parishes which are also partly located within the South Downs National Park, 7 parishes which are partly located within the Chichester Harbour Area of Outstanding Natural Beauty (AONB), and 1 parish located entirely within the AONB."

~ Every time the South Downs National Park is cited, you need to think, 'Should we also cite Chichester Harbour AONB, since they are both protected landscapes?' I understand parishes that cross the boundary in the Park will be subject to two Local Plans, but that is not the point. If the Plan is written such as way so as to not give equal status to the South Downs and Chichester Harbour, then the policies and their interpretation will be affected - Chichester Harbour will be seen as second class to the National Park.

Full text:

"There are 33 parish councils located within the Local Plan area, including six parishes which are also partly located within the South Downs National Park." Since this is a section on characteristics, why is the AONB not acknowledged?


Our response:

Noted. It is considered appropriate to acknowledge the split of the district between two planning authorities. However, this does not in any way detract from the status of the AONB or the way in which the Plan responds to the AONB designation.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

2.23

Representation ID: 4079

Received: 14/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

"The coastal and harbour areas are important for biodiversity, recreation and tourism." This is a simplification. Are marine businesses not important to Chichester Harbour? Is the cultural heritage and gentle way of life not important? Is the landscape of the AONB not nationally important?

Change suggested by respondent:

"All the coastal and harbour areas are important for biodiversity, recreation, tourism, and marine businesses, with Chichester Harbour also recognised as a nationally important landscape. The cultural heritage and gentle way of life on the coast is an intrinsic value that needs to be protected."

Full text:

"The coastal and harbour areas are important for biodiversity, recreation and tourism." This is a simplification. Are marine businesses not important to Chichester Harbour? Is the cultural heritage and gentle way of life not important? Is the landscape of the AONB not nationally important?


Our response:

It is considered that read as a whole the spatial portrait (including the proposed additional wording to paragraph 2.21) reflects the matters referenced by the respondent.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

3.3

Representation ID: 4332

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

"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 Council achieve sustainable development and deliver Policy A11. The proposed A11 will adversely affect the character, quality, and amenity of Bosham and Chichester Harbour AONB. The text in Section 3.3 is inconsistent with Policy A11.

Change suggested by respondent:

Delete Policy A11.

Full text:

"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 Council achieve sustainable development and deliver Policy A11. The proposed A11 will adversely affect the character, quality, and amenity of Bosham and Chichester Harbour AONB. The text in Section 3.3 is inconsistent with Policy A11.


Our response:

The housing distribution seeks to reconcile a range of factors in order to achieve the most sustainable approach to the distribution of development. This is set out in more detail in the Sustainability Appraisal and Housing Distribution Background Paper.

Where potential adverse impacts of development have been identified, it is considered that these are not insurmountable and could potentially be mitigated. Development proposals will be subject to the requirements of the natural environment policies and site specific requirements set out in the site allocations policies.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

3.3

Representation ID: 4333

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

"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 Council cannot achieve sustainable development and deliver Policy A11. The proposed A11 will adversely affect the character, quality, and amenity of Bosham and Chichester Harbour AONB. The text in Section 3.3 is inconsistent with Policy A11.

Change suggested by respondent:

Delete Policy A11.

Full text:

"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 Council cannot achieve sustainable development and deliver Policy A11. The proposed A11 will adversely affect the character, quality, and amenity of Bosham and Chichester Harbour AONB. The text in Section 3.3 is inconsistent with Policy A11.


Our response:

The housing distribution seeks to reconcile a range of factors in order to achieve the most sustainable approach to the distribution of development. This is set out in more detail in the Sustainability Appraisal and Housing Distribution Background Paper.

Where potential adverse impacts of development have been identified, it is considered that these are not insurmountable and could potentially be mitigated. Development proposals will be subject to the requirements of the natural environment policies and site specific requirements set out in the site allocations policies.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

3.18

Representation ID: 4334

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

"Land at Highgrove Farm, east of Broadbridge, Bosham is allocated in the Site Allocation DPD 2014 - 2029 for 50 dwellings." This planning application has lapsed. Shouldn't the allocation of 50 dwellings be deleted, to be replaced by a proposed allocation for 295 dwellings?

Change suggested by respondent:

Policy A11 to allocate 295 dwellings to Bosham - as much as I disagree with the Policy, let's at least make sure we're talking about the same thing here.

Full text:

"Land at Highgrove Farm, east of Broadbridge, Bosham is allocated in the Site Allocation DPD 2014 - 2029 for 50 dwellings." This planning application has lapsed. Shouldn't the allocation of 50 dwellings be deleted, to be replaced by a proposed allocation for 295 dwellings?


Our response:

As set out in the Local Plan Appendix H, the allocation (Policy BO1) made in the Site Allocation DPD has been ‘saved’ for continued use.

The reasoned justification to Policy A11 (Highgrove Farm) makes clear that development of the larger allocation will need to take account of and seek to integrate with this extant allocation.

However, it should be noted that permission has now been granted on appeal (21/00571/FUL) for 300 dwellings and supporting infrastructure on the land comprising site allocations A11 and BO1.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy S1 Spatial Development Strategy

Representation ID: 4336

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Chichester Harbour Conservancy Objects to Policy A11, A12 and A13, for reasons that will be explained in response to each individual policy. It is difficult to accept this is sustainable development.

Change suggested by respondent:

Delete A11, revised A12 and A13.

Full text:

Chichester Harbour Conservancy Objects to Policy A11, A12 and A13, for reasons that will be explained in response to each individual policy. It is difficult to accept this is sustainable development.


Our response:

The housing distribution seeks to reconcile a range of factors in order to achieve the most sustainable approach to the distribution of development. This is set out in more detail in the Sustainability Appraisal and Housing Distribution Background Paper.

See also responses to the respondent’s representations to the individual site allocations.

Support

Chichester Local Plan 2021 - 2039: Proposed Submission

4.2

Representation ID: 4337

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Representation Summary:

Chichester Harbour Conservancy recognises climate change as one of the biggest threats to the AONB. Where the Conservancy may have objected to previous schemes in terms of the landscape impact, it is recognised that such a position is no longer sustainable. The Conservancy would broadly favour the installation of renewable energy measures along the east-west corridor (within a 25 year time frame), rather than turn existing farmland into housing.

Full text:

Chichester Harbour Conservancy recognises climate change as one of the biggest threats to the AONB. Where the Conservancy may have objected to previous schemes in terms of the landscape impact, it is recognised that such a position is no longer sustainable. The Conservancy would broadly favour the installation of renewable energy measures along the east-west corridor (within a 25 year time frame), rather than turn existing farmland into housing.


Our response:

Support and comment noted

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.7

Representation ID: 4340

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

"Chichester Harbour Conservancy's Chichester Harbour AONB Management Plan (the Management Plan)." This factually incorrect. It is not the Conservancy's AONB Management Plan. We prepare it on behalf of the Local Authorities, and is therefore Chichester District Council's Management Plan for Chichester Harbour. The other LAs are WSCC, HCC and HBC.

Change suggested by respondent:

Correct references to the Chichester Harbour AONB Management Plan to clarify that it is prepared on behalf of Local Authorities.

Full text:

"Chichester Harbour Conservancy's Chichester Harbour AONB Management Plan (the Management Plan)." This factually incorrect. It is not the Conservancy's AONB Management Plan. We prepare it on behalf of the Local Authorities, and is therefore Chichester District Council's Management Plan for Chichester Harbour. The other LAs are WSCC, HCC and HBC.


Our response:

Suggested change to reference to the AONB Management Plan agreed. Amendment also proposed in relation to paragraph 4.9 to include reference to character and setting of AONB.

Support

Chichester Local Plan 2021 - 2039: Proposed Submission

4.8

Representation ID: 4368

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Representation Summary:

This is a well written section. I am slightly concerned that it conflicts with A11.

Full text:

This is a well written section. I am slightly concerned that it conflicts with A11.


Our response:

Support and comment noted

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