Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5128

Received: 16/03/2023

Respondent: South Downs National Park Authority

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We are pleased to see the South Downs National Park reference alongside the Chichester Harbour AONB in the ‘Issues and opportunities facing the plan area’ section. We note that the strategic objectives of the Plan do not address the National Park designation.

Add wording.

Object

Representation ID: 5129

Received: 16/03/2023

Respondent: South Downs National Park Authority

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We are pleased to see the South Downs National Park referenced in paragraph 3.19 and 3.21, particularly highlighting the area north of the A27 in provide a transition to the South Downs National Park.

Agree that reference could be made to setting of the National Park and amendments to paragraphs 3.19 and 3.21 are proposed.

Object

Representation ID: 5131

Received: 16/03/2023

Respondent: South Downs National Park Authority

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Term ‘Natural Landscapes’ is unclear, and is inconsistent with the European Landscape Convention (2004) definition of landscape. For clarity in language, we recommend the references to ‘natural landscapes’ and ‘rural character’ (both in this policy and elsewhere in the Plan) be replaced with ‘landscape character’. Welcome criteria 1 of Policy NE2. Note criteria 5 of this policy for the setting of the AONB and lack of an equivalent policy criteria for South Downs National Park and its setting - this is an important omission, strongly advise that an equivalent criterion is added to this policy. Second unnumbered paragraph in policy NE2 refers to identified character areas - unclear what ‘identified character areas’ are and where these are set out for applicants. Need for LVIA should not be limited to larger schemes, it would be appropriate for ‘smaller’ developments in the setting of the National Park.

On the basis that the ELC Article I Definition of Landscape is “an area as perceived by people whose character is the result of the action and interaction of natural and/or human factors”, it is not considered that the policy name is inconsistent with the European Landscape Convention Guidance. Criterion 5 has been removed as it is considered this is already reflected within the Chichester Harbour AONB policy. Whilst the SDNP is not within the Local Plan area, reference to views and the setting of the SDNP is made at criterion 1 of the policy. Landscape character areas are referred to at paragraph 4.7 and these areas are further sub-divided and identified in the Landscape Capacity Study appearing at Figure 4 of Appendix A. Wording has been added to the policy providing that LVIAs may be required for small-scale development proposals within the setting of the SDNP/ Chichester Harbour AONB.

Support

Representation ID: 5132

Received: 16/03/2023

Respondent: South Downs National Park Authority

Reference to intervisibility (into and from the South Downs National Park) is welcomed and supported.

Support noted

Support

Representation ID: 5133

Received: 16/03/2023

Respondent: South Downs National Park Authority

We very much welcome and support the inclusion into policy of the strategic wildlife corridors which traverse the district connecting the two protected landscapes of the Chichester Harbour AONB and the South Downs National Park. The wording of this policy seeking to protect the integrity, function, connectivity and ecological value of the corridor are important for the effectiveness of the policy and are strongly supported. The final criteria regarding taking opportunities to extend and enhance the corridors is positive and will help support nature recovery.

Support noted

Support

Representation ID: 5134

Received: 16/03/2023

Respondent: South Downs National Park Authority

We particularly welcome and support the reference to the Mens SAC, Ebernoe Common SAC and Singleton & Cocking Tunnels SAC conservation area zones and the Sussex Bat SAC Planning and Landscape Scale Enhancement Protocol.

Support and comment noted.

Support

Representation ID: 5135

Received: 16/03/2023

Respondent: South Downs National Park Authority

The policy for water neutrality is noted and the South Downs National Park Authority welcomes the continued joint work with CDC and with the other affected Local Planning Authorities.

Support noted

Object

Representation ID: 5136

Received: 16/03/2023

Respondent: South Downs National Park Authority

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The policy requirement for demonstrating no significant adverse impact upon landscape or townscape character is welcomed in Policy NE1 (Stand-alone Renewable Energy).

Reference to views into and from South Downs National Park as well as the Chichester Harbour AONB will be incorporated into criterion 1 of the policy

Support

Representation ID: 5137

Received: 16/03/2023

Respondent: South Downs National Park Authority

We note that policy H1 (Meeting Housing Needs) sets out a housing target of 10,350 up to 2039 and the supply figure identified is 10,359 dwellings (9 over the target figure). We also note the introductory paragraphs 5.1-5.4 that explain that due to constraints the Chichester District Council Plan area is now unable to accommodate any unmet need from the South Downs National Park part of Chichester
District.
The South Downs National Park Authority has commissioned an evidence study of development need, and this will assess housing need using a methodology consistent with the standard method, incorporating demographic change and affordability levels based on the best available data at geographies appropriate for creating local population estimates for the National Park area.

Support noted.

Object

Representation ID: 5138

Received: 16/03/2023

Respondent: South Downs National Park Authority

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is noted that a substantial number of new homes are proposed on the A259 corridor between Emsworth and Chichester. This is a sensitive stretch of land in the coastal plain between the coast, the south coast railway and the A27. This corridor provides the connection, including intervisibility, between the protected landscapes of the South Downs National Park and Chichester Harbour AONB, for example views of the channels within the Harbour from the Trundle and Stoke Clump. The amendments to policy set out earlier in this consultation response will help to ensure that development coming forward in this sensitive area positively addresses the South Downs National Park and its setting.
It is noted that several settlements around the South Downs National Park have been given a figure to be identified through either Neighbourhood Development Plans or through a potential future Site Allocations DPD. We particularly note Southbourne (1,050 homes), Wisborough Green (75 homes), (Kirdford (50 homes) and Boxgrove (50 homes). We raise concern about these figures and the challenge neighbourhood planning groups may have as many potential sites in these areas are likely to be in the setting of the South Downs National Park. It will be important that attempts to meet these target figures address the requirements of NPPF paragraph 176 on setting.

Comments noted. Amendments to other policies set out under relevant representations.