Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5385

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Consider policy provisions pragmatic and broadly consistent with national government guidance. Fifth paragraph - no objection in principle but prescribed distances (8m and 16m) should be regarded as a guide, that allows for flexibility depending on site circumstances. Welcome clear steer on drainage / build requirements (nos.1-4), support intent for sustainable drainage systems to be designed into landscape of all major development and for use of construction materials with low permeability up to at least same height as finished floor levels. Commend Council for commissioning Level 2 SFRA.

Reference to 8m and 16m relates back to legislative requirements, and hence will need to be applied in accordance with that legislation.
The Council can see the point made about ‘where relevant’ in terms of the application of the sequential approach, and would have no objection to making such an amendment.

Object

Representation ID: 5390

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Bellway are concerned that several of the criteria (f-g) require ‘compliance’ with as yet unpublished position statements. There is no surety that they would be subject to prior consultation. Under ‘Residential development within the catchment of the Apuldram Waste Water Treatment Works’, it is unclear how allocations are reconciled with the need to negate any net increase in flows to the treatment works (criteria c). Whilst Bellway has reservations about the limitations of the draft Policy, it is considered that subject to modifications, it is capable of being made effective and found sound.

The Position Statement for Apuldram was published in 2018 and that for Thornham in 2021.

Allocated sites need to achieve no net increase in flow where relevant.

Object

Representation ID: 5392

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Bellway note the contents of draft Policy NE17. Given that this draft Policy wouldn’t impact upon the deliverability of the Police Field site, no further comments are proffered.

Comments noted. However, it is not considered necessary to amend the title as it is clear what area is relevant in the policy.

Object

Representation ID: 5393

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Bellway note the contents of draft Policy NE19, the supporting text of which cross-references Policy NE16 and largely replicates draft Policy NE6(b). As such, the need for draft Policy NE19 is unclear. It certainly presents an opportunity for consolidation. Bellway acknowledge that nutrient neutrality is an evolving issue and would encourage Chichester Council to consider the implications of the LURB through the SHRA. The lack of identification of either Council led, or third party, solutions to deliver credits is disappointing.

A nutrient mitigation plan will need to be agreed in line with requirements for any relevant development. This is usually done through the planning application process as the mitigation available will evolve over the plan period. The policy is not intended to identify particular schemes.

Object

Representation ID: 5394

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Bellway note the contents of draft Policy NE20 but query whether it is necessary to include; ‘Development proposals will need to address the criteria contained in, but not limited to, the policies concerning water quality; flood risk and water management; nutrient mitigation; lighting; air quality; noise; and contaminated land’ when all are policies in their own right, noting that the plan needs to be read as a whole.

Many policies within the plan cross-reference other relevant policies. NE20 Pollution is an over-arching policy for all the other pollution policies contained within the plan

Object

Representation ID: 5395

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Bellway note the contents of draft Policy NE21. Bellway has no objection to the criteria therein, albeit consider that in many cases (beyond AONB’s) such matters are capable of being addressed by means of an appropriately worded condition. This observation is perhaps more pertinent to the validation list than the draft Plan.

Comment noted

Support

Representation ID: 5396

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Bellway welcome the inclusion to maximise the provision of pedestrian and cycle networks to minimise traffic generation and congestions. The sustainable location of the Police Fields provides significant opportunity to maximise the use of the site, being a walkable development in terms of access to the city centre. Bellway contend that the proposed draft policy ‘Air Quality’ as conveyed in the draft Plan has been positively prepared, is fully justified, effective and consistent with the NPPF.

Support noted

Object

Representation ID: 5397

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Bellway agree with the sentiment of draft Policy NE23, acknowledging that noise can have an impact on the living conditions of future occupiers in residentials developments. Bellway has no objection to the criteria therein, albeit consider that in many cases (beyond AONB’s) such matters are capable of being addressed by means of an appropriately worded condition. This observation is perhaps more pertinent to the validation list than the draft Plan. Bellway contend that the draft Policy ‘Noise’ as conveyed in the draft Plan has been positively prepared, is fully justified, effective and consistent with the NPPF.

Comment noted

Object

Representation ID: 5398

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Bellway note the contents of draft Policy NE24. Bellway has no objection to the criteria therein, albeit consider that in many cases (beyond AONB’s) such matters are capable of being addressed by means of an appropriately worded condition. This observation is perhaps more pertinent to the validation list than the draft Plan. Bellway contend that the draft Policy ‘Contaminated Land’ as conveyed in the draft Plan has been positively prepared, is fully justified, effective and consistent with the NPPF.

Comment noted

Support

Representation ID: 5399

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Support Policy H1 although concerns over 10,350 meeting local housing needs/doesn't allow for supply buffer. Sympathetic to constraints/capacity of A27 - evident Council undertaken exhaustive search for suitable sites. Agree with SA concerns over development being subject to tilted balance. Understand permanent solution some way-off for A27. Commend Council for seeking to plan positively. Understand rationale behind spatial strategy. Encourage higher density and regard housing numbers on allocations as minimum. Where affordability currently worsening, lack certainty housing need for area will be achieved - recognised shortfall of housing projected despite assurance may be resolved via LSS3. Additional infrastructure required to ensure timely delivery of allocated sites. Reserve position in absence of published trajectory.

Support noted