Chichester Local Plan 2021 - 2039: Proposed Submission

Support

Representation ID: 5400

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Bellway welcome the inclusion of the Southern Gateway as an allocation for 180 dwellings, albeit for the reasons set out in relation to draft Policy H1 above, the anticipated numbers should be prefixed by at least or approximately. Consideration should be given to the timing of any intervention, should the Neighbourhood Plans not progress in a timely manner. This would provide clarity for all concerned. Subject to these modifications, Bellway contend that policy H2 has been positively prepared, is fully justified and effective.

Support noted.
Para 10.1 of the Plan makes it clear that the strategic site allocation policies include an anticipated number of dwellings to come forward on each site and that any variation to this through the development management process would need to be justified with up to date evidence, for example, through a Transport Assessment. A modification is proposed to Policy A13 and other relevant strategic allocation policies to include ‘approximately’ to reflect this flexibility.
There is a track record of allocations successfully being made through Neighbourhood Plans and there is no evidence to suggest that this will not continue over the plan period. The council would use a further DPD as a mechanism for ensuring that site allocations can be made should Neighbourhood Plans not progress within a reasonable timeframe following adoption of the Local Plan.

Object

Representation ID: 5401

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Express concern over apparent disparity in year-on-year affordable housing needs, as flagged in the ICENI HEDNA (see attachment for detail). Given scale of affordability challenge, aspiration to optimise proportion of affordable homes is commended. Support delivery of affordable homes. Strategic allocation A5 and wider Southern Gateway could, subject to viability
considerations, ensure timely provision of affordable housing within Chichester City. Great care should be taken to avoid prejudicing delivery by ensuring suitable flexibility is ‘built in’ to the local plan.

Iceni have confirmed that the fall in year-on-year affordable housing needs) is primarily due to the reduced levels of newly forming households (from 280 to 225 per annum). The main reason for this is a move away from using the standard method towards using published population and household projections. This is justified on the basis that the additional households linked to the uplift in the standard method will only come to the plan area if it is affordable to do so it would be inconsistent to then provide additional affordable housing to address their need.
The Council is aware of the level of affordable housing need and is seeking to maximise the level of provision, balanced against the constraints to delivery and significant viability considerations. The Council agrees that the Southern Gateway site provides an important opportunity to bring forward affordable housing in a sustainable location. The policy is informed by viability evidence and does allow for some flexibility.

Support

Representation ID: 5402

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Bellway supports draft Policy H5, which requires the delivery of an appropriate type and size, consistent with the most up to date HEDNA. Bellway welcome that planning permission can be granted for an alternative mix subject to a robust evidencing that the proposal addresses any housing imbalance that exists or that it addresses need and demand for affordable housing, self-build housing, older person and specialised housing. Bellway contend that the draft Policy ‘Housing Mix’ as conveyed in the Pre-submission Plan has been positively prepared, is fully justified, effective and consistent with the NPPF.

Paragraph 5.26 supports a different housing mix where appropriate with regard to the nature of the development site and the character of the area

Object

Representation ID: 5403

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Not specified

Duty to co-operate? Yes

Limited supporting text referring to Self Build and Custom Housing Act 2015. Support requirement for all residential schemes of 200+ homes to provide self and custom build service plots. Concern over requirement for 2% of market units provided on strategic scale housing sites (ambiguity on what is meant by strategic scale housing sites). Difficult to integrate self / custom build products on more modest sites (particularly higher densities), as opportunity to introduce self / builders / specialist custom build developers problematic. May result in lower density housing. Requirement for self / custom build products on sites of less than 200 homes might only serve to hamper delivery.

Paragraph 5.29 does specify that strategic-scale entails those which are larger than 200 units. While the call to remove the reference to smaller sites is noted, it is considered that the relevant part of the policy strikes the right balance between encouraging self-build provision, while noting the practical difficulties with achieving delivery as part of smaller housing sites. Furthermore, the part of the policy in question does not impose any specific requirement in this regard and hence suitably flexible. Ultimately, requiring a proportion of self/custom build within mainstream housing sites is an increasingly common policy requirement and hence there is no reason it should be a significant impediment to delivery.

Object

Representation ID: 5414

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Not specified

Duty to co-operate? Yes

Have significant reservations in terms of policy's practicality - compliance with M4(2) typically results in a 10% increase in floorspace over and above standard market house types, with a commensurate increase in build costs - seldom reciprocated in an increase in GDV. Will be important to test implications of requirement on whole plan viability, isn’t clear whether this has been modelled. Consider would be more appropriate for only a proportion of dwellings to be M4(2) see draft Gosport Local Plan and Havant Housing Delivery Position Statement. Should M4(2) compliance be enforced through Part M of building regulations, would be inappropriate to duplicate matters covered (paragraph 16f of the NPPF) in National Policy.

Whilst the building regulations are due to be updated to include M4(2) as standard, this has not yet taken place. The policy was drafted to reflect the needs of the local population and therefore has remained as drafted to ensure delivery of M4(2) dwellings should there be a delay or change to the building regs update.
The policy has been viability tested alongside all other policy requirements

Support

Representation ID: 5416

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Intent of Policy P1 is supported. Welcome emphasis upon a design led approach to all development and consistency with National Design Guide. Welcome requirement of Sustainability Statement, although question whether this should be required for ‘all development proposals’ (this is perhaps best elaborated upon in the validation checklist). Point A is welcomed, albeit a proportionate and flexible approach is required, particularly given challenges in sourcing materials. Will be important to allow some freedom and avoid making mechanism for assessment too prescriptive and cumbersome. Considered policy strikes right balance. Contend draft Policy ‘P1’ has been positively prepared, is fully justified, effective and consistent with the NPPF.

Support and comments noted. The Council agrees that it isn’t reasonable to expect all proposals to submit a sustainability statement, and hence proposes an amendment to revert to the same criteria which currently apply to sustainable construction and design statements. The issue raised concerning the need for some flexibility regarding the sourcing of materials is considered to be addressed by the proposed amendment in relation to representation 5151

Object

Representation ID: 5417

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 supports the draft Policy P2. Bellway welcome the in-built flexibility of the policy which enables justification of non-compliant areas to allow for alternative design styles. Bellway contend that the draft Policy ‘P2’ as conveyed in the draft Plan has been positively prepared, is fully justified, effective and consistent with the NPPF.

Proposed changes noted. i) it is not considered necessary to remove references to building typologies and silhouettes to ensure the soundness of the Plan. Indeed the National Design Guidance makes reference to typologies in relation to consideration of the local vernacular; ii) It is not considered necessary to remove bullet 5 as its inclusion reinforces the need to consider the heritage of the area as part of local character considerations; iii) it is not considered necessary to alter bullet 6 as the wording ensures the retention of only boundary treatments that contribute positively iv) it is not considered necessary to alter bullet 8 as suggested as this may weaken regard for the importance of protecting landscapes.

Support

Representation ID: 5418

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Bellway support the requirement for ‘Development proposals to make efficient use of land’, broadly mirroring paragraph 119 of the NPPF. Bellway also support the restraint in avoiding arbitrary targets that pay little attention to the form of buildings, instead placing emphasis on a design led approach.

The Council welcomes the support in relation to the P3 Density Policy. We consider it appropriate to separate the policy from P2, which considers character and distinctiveness more broadly. This is to ensure sufficient attention is given to the range of constraints to be considered in relation to optimisation of sites, not limited to surrounding context and character.

Object

Representation ID: 5419

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 welcome the intent, but recommend that flexibility be built into this policy to enable sites to be able to respond to specific site opportunities and constraints. Subject to this modification, Bellway contend that the draft Policy ‘P4’ as conveyed in the draft Plan has been positively prepared, is fully justified, effective and consistent with the NPPF.

Objection and comments noted. It is considered that the design requirements within Policy P4 can be broadly applied and reflect general principles to be complied with rather than specific or overly rigid criteria. The need to provide further flexibility is therefore considered not to be necessary.

Support

Representation ID: 5420

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Support intent of Policy and emphasis placed on multi-functional spaces although surprised by assertion that all open space should be lit. Might need clarification.

Support and comments noted. We will consider a minor amendment to the policy to avoid any assertion that all open space should be lit.