Chichester Local Plan 2021 - 2039: Proposed Submission

Support

Representation ID: 5364

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Council may well have fulfilled Duty to Co-operate, (Bellway recognise that West Sussex and Greater Brighton Strategic Planning Board comprises representatives of local planning authorities across West Sussex) however a Local Strategic Statement 3 has not yet been agreed / adopted. Statements of Common Ground are not available on the website at this point. We respectfully reserve our position on this, however Bellway believe that the Local Planning Authority has followed the letter and spirit of the Duty to Cooperate in arriving at the pre-submission plan.

The Statement of Compliance published at the time of the Regulation 19 consultation set out the key cross boundary strategic issues and engagement undertaken by the Council with neighbouring authorities and other relevant bodies on these issues.

It is acknowledged that preparation of LSS3 has not advanced as quickly as the Council and others would have wished. However, in the absence of progress on the LSS3 update the Council is, as referenced above, preparing statements of common ground with individual authorities.

Support

Representation ID: 5365

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Bellway supports spatial priority 2 setting out that Chichester City / Tangmere / Bognor Regis gives priority to the infrastructure improvements needed to support delivery of strategic employment and housing sites identified in Chichester and Arun Local Plans. There is a need for significant investment in Chichester’s infrastructure to enable housing targets to be met. Bellway therefore consider it vital that strategic infrastructure improvements are delivered. New development offers the best means of securing investment in the area including through contributions towards such improvements albeit there is a fine balance to achieve in ensuring development is viable, particularly in regeneration areas such as Southern Gateway.

Support noted

Support

Representation ID: 5366

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Support intent of Policy S1 and wording but for one minor clarification (see below). Focus on Chichester City is appropriate and welcome. Wide dispersal of allocations is testimony to Council’s relentless exploration of opportunities throughout plan area. Following minor amendments the section titled ‘Spatial Strategy’ has been positive prepared, is fully justified, effective and consistent with the NPPF. As set out in monitoring section, distribution of new homes throughout plan area throughout duration of plan period will need to be assessed in line with development strategy and kept under review, so that if delivery departs from the spatial strategy, interventions can be made.

Point 7 is applicable to the whole policy and it is agreed this could be made clearer

Object

Representation ID: 5368

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Purpose of draft Policy S2 to reaffirm full settlement hierarchy and function of each tier, insofar as this might guide all forms of development, windfall and speculative applications not explicit in the wording of the draft policy. Recommend minor amendments for sake of clarity. Welcome spatial depiction set out in key diagram. Agree with Councils' stance on development within settlement boundaries and welcome approach that settlement boundaries must respect setting form and character of settlement.

1. As Policy S1 sets out the expected scale/type of development in each settlement tier the amendments suggest by the respondent are considered unnecessary.

2. Agree with respondent’s suggested amendment

Object

Representation ID: 5371

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Not specified

Duty to co-operate? Not specified

It is unfortunate that paragraph 4.18 of the proposed plan does not read clearly.

Comment noted. The wording of the policy will be amended to reflect the removal of the sequential test.

Object

Representation ID: 5374

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Not specified

Duty to co-operate? Yes

Bellway commend Chichester Council for already publishing a strategic wildlife corridors background paper (consulted on in 2018). Bellway do not consider that draft Policy NE4 (Strategic Wildlife Corridors) accords with paragraph 180 of the NPPF. Whilst Bellway has reservations about consistency with the NPPF, minor modifications could render it consistent and sound.

Comment noted. Paragraph 179(a) of the NPPF is clear that plans should identify and safeguard corridors. Paragraph 180 does not then refer to how this may be achieved. It would be hard to argue how you could compensate for the loss of a corridor. It is not considered that the wording is inconsistent with paragraph 180, however modifications to the policy are being proposed.

Object

Representation ID: 5377

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Policy should retain some degree of flexibility.

Objection and proposed change noted. i)Points 1.c) and d) within Policy NE5 state the proposed on-site and off-site interventions within the Plan Area, as part of the mitigation hierarchy. While the biodiversity metric (both 3.1 and 4.0) considers the interventions in terms of spatial risk multiplier score, the policy specifies local parameters, including requirements to contribute towards strategically significant networks. These requirements enable CDC to target offsite BNG delivery to ensure the right habitats in the right places. As the criteria are not directly comparable they are not considered duplicative and the proposed change is not necessary.
ii)We will consider a minor amendment to Policy NE5 that enhances its flexibility by allowing for off-site provision outside of but neighbouring the Local Plan Area, recognising that BNG can contribute to wider nature recovery plans as well as local objectives. This will be caveated by the need to ensure land is deliverable in areas of strategic importance for biodiversity in accordance with future Local Nature Recovery Strategies.

Support

Representation ID: 5380

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Bellway supports draft Policy NE6 which has regard to Internationally and Nationally designated sites. Bellway understand that development is only permitted where it can be demonstrated that it would not lead to an adverse effect on the integrity, either alone or in combination, directly or indirectly, to internationally, European and nationally important habitat sites. Explicit reference to the designation and features provides helpful clarification.

Support and comment noted

Support

Representation ID: 5381

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Bellway support draft Policy NE7, acknowledging the Council’s duty to protect internationally important wildlife sites.

Support noted

Object

Representation ID: 5383

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Concerned that absolute nature of first sentence highly likely to result in policy conflicts that will require degree of pragmatism and professional judgement. Whilst explanation in paragraphs 4.41-4.42 of supporting text is welcome, definition of a hedgerow in so far as it applies to criteria 2 of the policy is unclear – different approach to hedgerows as defined under the Hedgerows Regulations for short section in domestic garden is required. Believe that latter would fall to criteria 3, but differentiation not entirely clear. Following minor amendments, contend that draft policy and supporting text has been positively prepared, is fully justified, effective and consistent with the NPPF.

Criterion 2 will be amended to reflect the definition of irreplaceable habitats in the NPPF and reference to hedgerows will be removed. Criterion 6 will be expanded to reflect the NPPF and provide further clarity.