Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5717

Received: 17/03/2023

Respondent: Metis Homes

Agent: Nova Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Add new paragraph.

Due to the limited availability of deliverable and/or developable brownfield sites within the plan area, relative to the level of housing need, greenfield sites are always going to be have to be the main focus for development within the Local Plan in order to meet the Plan Area’s housing needs. Nevertheless, the council has still sought to allocate brownfield sites where it can, such as Southern Gateway.

Object

Representation ID: 5718

Received: 17/03/2023

Respondent: Metis Homes

Agent: Nova Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Distribution of housing to Northern Plan Area (Kirdford and Wisborough Green) is based on flawed assumptions regarding capacity of the A27. These locations are not well served by existing facilities and amenities and are sequentially less sustainable than locations in Southern Plan Area where A27 capacity is presented as only relevant constraint to increased/additional allocations. The additional numbers that have been added to Northern Plan Area at this late stage are unnecessary given the comments at paragraphs 5.6.5 and 11.2.3 of Stantec Transport Study, which confirm that capacity exists for up to 700 dwellings per annum in the Southern Plan Area. Proposed approach does not deliver the most sustainable distribution of development.

Reflecting the spatial strategy the majority of the growth proposed in the Local Plan is located within or around Chichester city and in the east west corridor. However, as set out in paragraph 3.24 (and explained more fully in the Housing Distribution and Transport Background Papers (July 2024)) the Council has had to look at increasing the supply of dwellings from the north of the north east of the plan area.

Object

Representation ID: 5719

Received: 17/03/2023

Respondent: Metis Homes

Agent: Nova Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Distribution of housing to Northern Plan Area (Loxwood) is based on flawed assumptions regarding capacity of the A27. These locations are not well served by existing facilities and amenities and are sequentially less sustainable than locations in the Southern Plan Area, where A27 capacity is being presented as only relevant constraint to increased/additional allocations. This is unnecessary given additional capacity in the A27 as outlined at paragraphs 5.6.5 and 11.2.3 of the report. For this reason, Spatial Strategy is not properly ‘justified’ and consequently the draft Plan is unsound.

Reflecting the spatial strategy the majority of the growth proposed in the Local Plan is located within or around Chichester city and in the east west corridor. However, as set out in paragraph 3.24 (and explained more fully in the Housing Distribution and Transport Background Papers (July 2024)) the Council has had to look at increasing the supply of dwellings from the north of the north east of the plan area.

Object

Representation ID: 5720

Received: 17/03/2023

Respondent: Metis Homes

Agent: Nova Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Land at Maudlin Farm not featured at Regulation 18 stage. SA stated Southbourne development unlikely to be deliverable in first 5 years. Planning Ref. SB/22/01283/FULEIA for ‘Land at Harris Scrapyard & Oaks Farm’, would provide at least 50 dwellings in period to 2026 and 103 dwellings by 2027. Southern Water have confirmed suitable foul drainage can be accommodated. SA therefore incorrect as proposed development can provide early housing delivery as part of BLD. Loxwood also identified as SDL, results in less sustainable distribution of housing than if transport evidence had been properly applied. Loxwood is sequentially less sustainable than a number of other Service Villages in South.

The site at Maudlin Farm was promoted to the Preferred Approach consultation (under Regulation 18) and subsequently assessed through the HELAA and SA.

It is acknowledged that there is currently headroom available at Thornham WwTW but this serves development not only in the Plan Area but also from Havant Borough. In addition available headroom can, depending on weather conditions, fluctuate year on year. As such, there is no certainty that capacity would be available to serve development. Southern Water’s DWMP identifies the need for capacity improvements at Thornham WwTW to serve future development, which are planned for the next AMP period (2025-2030).

It should also be noted that there is a difference between Southern Water’s legal obligation to provide developers with the right to connect to a public sewer regardless of capacity issues at the time a planning application is determined and which may be managed through the imposition of a planning condition and delivering strategic infrastructure capacity through the AMP to accommodate future Local Plan growth.

Loxwood is one of the larger settlements in the north of the Plan Area with a good range of existing services and facilities. The Council’s updated facilities research in the Settlement Hierarchy Update Background Paper (May 2024) concludes that it is appropriately classified in the Local Plan Settlement Hierarchy as a service village.

Object

Representation ID: 5721

Received: 17/03/2023

Respondent: Metis Homes

Agent: Nova Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy seeks to limit and control development in areas designated as proposed Wildlife Corridors. It assumes that land within the designation is already in a natural state and therefore protection is the only relevant consideration. This is not the case, as part of the proposed Strategic Wildlife Corridor to the east of Southbourne comprises an operational Breakers Yard known as Harris Scrapyard. The existing Breakers Yard occupies an important area within the proposed Strategic Wildlife Corridor. See proposed amendment.

Comment noted. It is acknowledged that not all land within the corridors is within a natural state. The corridors link known high quality habitat; there will not be a continuous connection of high quality habitat but it is likely that species are moving through these areas to reach the higher quality habitat. Agree that where possible, any development within a corridor should be in a form that supports the delivery of the corridor. The policy has proposed amendments.

Object

Representation ID: 5722

Received: 17/03/2023

Respondent: Metis Homes

Agent: Nova Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy needs to reflect extended timetable being given to small sites to ease burden on small developers and LPAs. Government’s response to the consultation on the regulations for and implementation of BNG outlines that implementation of BNG on small sites will be extended to
April 2024.

Objection and proposed change noted. The anticipated timescale for adoption of the Proposed Local Plan is such that reference to the small sites extension period (until April 2024) is considered not to be necessary as it will have concluded prior to Plan’s adoption. The proposed change is therefore resisted

Object

Representation ID: 5723

Received: 17/03/2023

Respondent: Metis Homes

Agent: Nova Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Criteria 5 stipulates a minimum 15m buffer to Ancient Woodland and Veteran Trees to protect Root Protection Zones. This is too specific and presumptive. Planning applications for development on sites with existing trees are required to submit a Tree Survey and Arboricultural Impact Assessment (AIA). These documents provide a site-specific analysis of tree constraints, including the
identification of root protection zones. As currently drafted, the policy assumes a standard constraint and would unnecessarily limit development.

Paragraph 035 of the PPG Natural Environment Guidance refers to the Forestry Commission and Natural England advice which is a material consideration in appropriate circumstances. Criterion 5 reflects the buffer zone recommendation

Object

Representation ID: 5724

Received: 17/03/2023

Respondent: Metis Homes

Agent: Nova Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object on grounds that Portfield Roundabout and Oving Junction have capacity issues in both 535 and 700 dwellings per annum scenarios; Council’s own highways evidence show an additional 2,970 dwellings could be accommodated in Southern Plan Area; delivery of entirety of 2,970 dwellings should be considered in context of 1) affordable housing need identified in HEDNA and 2) meeting unmet housing needs in South Downs National Park under Duty to Cooperate; evidence used to justify lower housing requirement explicitly states higher objectively assessed needs can be met; additional development in North contradicted by Transport Study; additional numbers in North unnecessary given additional capacity in A27 and lack of facilities and amenities.

The justification for not meeting the housing needs in full is set out in the Housing Need and Transport Background Papers (May 2024). The latest Duty to Cooperate evidence is set out in the updated Statement of Compliance

Object

Representation ID: 5726

Received: 17/03/2023

Respondent: Metis Homes

Agent: Nova Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Unrealistic to suggest delivery will occur as early as 2028 therefore Council cannot demonstrate delivery of 1,050 dwellings over Plan period; issue could be addressed by bringing forward development within BLD earlier without undermining BLD objectives; two land parcels in area promoted: Land at ‘Harris Scrapyard & Oaks Farm’ (HSOF) and ‘Land East of Inlands Road’ (LEOIR). Extent of BLD should be expanded to include wildlife corridors - delivery and management of wildlife corridors can only be secured if they become an integral part of BLD alongside planned development.

The housing trajectory has been reviewed and delivery is now expected to commence from 2030/31 onwards.

To be consistent with Policy NE4 (Strategic Wildlife Corridors) regarding development proposals within the corridors, it is considered appropriate that land that falls within the boundaries of the identified corridors should be excluded from the extent of the BLD.

It is considered the policy criterion as drafted provide an appropriate approach and level of detail.

It should be noted that planning permission for the development of the site being promoted was granted on appeal (18 September 2023) for 103 dwellings and associated infrastructure.

Object

Representation ID: 5728

Received: 17/03/2023

Respondent: Metis Homes

Agent: Nova Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to Land at Maudlin Farm, Westhampnett’ - did not feature at Regulation 18 stage. SA stated Southbourne development unlikely to be deliverable in first 5 years. Planning Ref. SB/22/01283/FULEIA for ‘Land at Harris Scrapyard & Oaks Farm’, (discrete land parcel of proposed BLD) would provide delivery of at least 50 dwellings in period to 2026 and 103 dwellings by 2027. Southern Water have confirmed suitable foul drainage can be accommodated for the development. SA therefore incorrect as proposed development can provide early housing delivery as part of BLD. If this is the reason for introducing an allocation at Maudlin Farm, and altering spatial strategy, at this late stage in the plan-making process, then Spatial Strategy is flawed.

There is considerable flexibility open to LPAs in how the initial stages of local plan production are carried out and there is no requirement to have a further Regulation 18 consultation.

The Housing Distribution Background Paper (May 2024) sets out the justification for the site allocations and strategic parish numbers set out in Policy H2.
It is noted that the alterative site promoted has since granted planning permission at appeal.
The justification and evidence to support the latest housing trajectory is set out in the Housing Supply Background Paper (May 2024).