Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5423

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Not specified

Duty to co-operate? Yes

Support intent of Policy albeit many criteria (a-g) overlap with other policies. Scope for consolidation. Requirement for new homes to meet NDSS acknowledged, important to test implications of requirement on whole plan viability. Should be recognised that requirement to meet NDSS in combination with M4(2) will influence overall density achieved on a site and could serve to limit overall number of homes delivered. Approach to external amenity space welcomed, cross over with earlier policies re; noise pollution/odour. Rigid adherence to 21m separation distance between directly facing principal windows of habitable rooms can result in unintended consequences and jar with creation of distinctive places exhibiting a tighter grain. Pleased to see flexibility afforded.

Objection and comments noted. i) While the policy does address some issues covered in other policies, it seeks to address the design and amenity angle in relation to these issues and how those issues can be considered holistically as part of the design process. ii) Our Residential Space Standards Evidence Study addresses the matter of NDSS and M4(2) adoption, noting that whilst the combined impacts cannot be fully assessed until the technical requirements of M4(2) are determined, it is anticipated that the standards will be complementary, NDSS having been recognised as a potential common baseline within the Government’s consultation. Furthermore, there is provision for flexibility, with the Government proposing for exceptional circumstances to be considered if the application of M4(2) is justified as being impractical and unachievable on specific sites . The conclusion of the Local Plan Viability Assessment was that the proposed requirement for NDSS compliance is viable. The study provides evidence that NDSS adoption will not prompt developers to increase dwelling footprints. Site densities are therefore unlikely to be affected. This evidence will be submitted as part of the examination documents. We will consider a modification to the policy to ensure clarity in interpretation and implementation of this requirement iii) In terms of the issue of back-to-back distances referred to, the Council agrees that some flexibility is required in relation to this issue. It considers this is offered within the policy but will consider a modification to the policy and its supporting text to provide clarity

Object

Representation ID: 5425

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Not specified

Duty to co-operate? Yes

Query whether there is a need to have an entire policy dedicated to materials and detailing, when this could be incorporated within draft Policy P1 (design). Some aspects are prescriptive such as requirement to ‘avoid UPVC products’. Alternatives might well be available but will add significant cost. Unclear whether such policy requirements have fed into whole plan viability assessment.

Materials and detailing are key to successful design and are often not given sufficient attention, and this policy will clearly address that problem. Moreover, paragraph 126/131 in the NPPF states that being clear about design expectations is essential for achieving a high standard of design and creating better places. The policy is framed is a flexible manner, and hence isn’t considered overly prescriptive. The policy has been incorporated into the viability work, as referenced in Stage 2 Appendix I, Table D.

Object

Representation ID: 5495

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 positive stance under criteria 3 and 4, albeit the remaining criteria merely repeat large tracts of national policy. It is unclear what criteria 1, 2 and 5 add.

Objection and comments noted. It is considered that the specification of the five high-level criteria within Policy P9 helps to establish the local policy requirements in the context of national policy and legal obligations, and enables more detailed policy requirements relating to listed buildings and conservation area to be derived and defined. Consequently, no change is required.

Object

Representation ID: 5496

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 positive stance to alterations to mitigate climate change and allow for reuse and positive attitude adopted by the Council in relation to Listed Buildings. However, policy merely repeats large tracts of national policy. It is unclear what it adds.

Objection and comments noted. It is considered that Policy P10 establishes the local policy requirements relating to listed buildings in the context of national policy and legal obligations, and relative to broader requirements regarding the historic environment. Consequently, no change is required

Object

Representation ID: 5497

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 fact that the policy is tailored to local circumstances but is concerned that draft Policy P11 won’t be regarded as positively prepared and consistent with the NPPF owing to criteria A2 requiring development to ‘protect the setting’.

Objection and comment noted. We will consider a minor modification to the policy to ensure consistency with the NPPF and statutory requirements in terms of the protection of the settings of heritage assets

Object

Representation ID: 5498

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Not specified

Duty to co-operate? Yes

Support intent of Policy 12 - consider it aids interpretation of national planning policies recognising importance of historic environment. Surprised by first section of criteria 2(c) in so far as implies non-designated heritage assets could be designated solely based on their contribution towards their surroundings. Would appear to be more a matter of townscape / character than heritage per-se. Note inclusion of archaeology in policy but would be surprised if criteria 4(a-c) need apply to all developments (even minor applications) that involve excavation and ground works. Perhaps more appropriately addressed through validation checklist.

Objection and comments noted. i) Neither the NPPF nor PPG specifies criteria for the identification of non-designated heritage assets (NDHAs), although the latter signposts Historic England advice, which suggests examples including a ‘Landmark’ criterion, where an asset may be selected on the basis of its contribution to the local scene. It is considered that the proposed criteria at 2 c) is aligned with this sentiment and therefore appropriate in principle. We will, however, consider amendments to the policy and its supporting text to clarify the broad categories assessed during the identification process. ii) We will consider modifications to criteria 4 a)-c) to clarify the policy, requiring a proportionate response to development proposed on sites which include or have the potential to include heritage assets with archaeological interest, in accordance with the NPPF.

Object

Representation ID: 5499

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 fact that the policy is tailored to local circumstances but is concerned that the policy won’t be regarded as positively prepared and consistent with the NPPF owing to criteria 4 requiring development to ‘preserve the setting’.

Objection and comment noted. We will consider a minor modification to the policy to ensure consistency with the NPPF and statutory requirements in terms of the protection of the settings of heritage assets

Object

Representation ID: 5500

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Not specified

Duty to co-operate? Yes

Support spirit of Policy P15. Bellway welcome opportunity to improve quality and accessibility of open space at the Police Fields. Bellway note that following the guidance in the preceding text c.0.168ha on on-site amenity and natural greenspace is likely to be required alongside an Equipped Play Space (children).

Objection noted.

Existing open space is defined in paragraph 6.84

Object

Representation ID: 5501

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Not specified

Duty to co-operate? Yes

Support Policy P16, note need for planning applications for 50 or more dwellings to be accompanied by a Health Impact Assessment. Unclear where this threshold has come from – no explanation in supporting text, feels a little arbitrary. Some overlap, most notably in respect of allotments (under criteria 2) with preceding Policy P15, albeit this needn’t detract from the fact that the policy has been positively prepared and is broadly consistent with the NPPF.

The inclusion of thresholds is considered to be reasonable and appropriate given the nature of the plan area. However, in order to maximise the beneficial opportunities a modification is proposed to also include a threshold of 1000sqm floorspace.

Object

Representation ID: 5502

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Legally compliant? Yes

Sound? Not specified

Duty to co-operate? Yes

Not clear how developments are to mitigate impacts of travel by car, albeit assumed that encouragement for car sharing (through travel plans) and electric vehicles (through the provision of charging points) are two means. Agree there is need for new transport infrastructure to come forward alongside new development but consider phasing of development of sites that serve to minimise impacts upon the A27 (notably Southern Gateway) need not be impaired owing to City Centre location and proximity to travel interchanges. Concur it is beholden upon strategic development to promote delivery of sustainable forms of travel and deliver new transport infrastructure, must be proportionate to potential effects of development.

Policy T1 sets out a strategy based on an expectation that all new development will support and embody the four objectives set out in the policy text. These focus on reducing the need to travel by car, improving access to sustainable modes of travel, managing travel demand and mitigating the impacts of car use. Although development located within Chichester city will more easily be able to meet some of these objectives, that does not mean it will not contribute to the adverse impacts on the A27 Chichester Bypass. There is no intention within the Plan to delay any developments within the city from coming forward as soon as practicable.