Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
2.37
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.
Add new paragraph relevant to all locations – “Policies will seek to prioritise the redevelopment of brownfield or previously developed land in sustainable locations” in accordance with Paragraph 119 of the NPPF.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
3.25
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.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
3.27
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.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy S1 Spatial Development Strategy
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.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE4 Strategic Wildlife Corridors
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.
Policy should be amended to support and facilitate necessary change of land to enable delivery of wildlife corridor.
Development proposals within strategic wildlife corridors will only be granted where it can be demonstrated that:
1. The development is in a form that supports the delivery of the wildlife corridor;
2. There are no sequentially preferable sites available outside the wildlife corridor; and
3. The development will not have an adverse impact on the integrity and function of the wildlife corridor and protects and enhances its features and habitats.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE5 Biodiversity and Biodiversity Net Gain
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.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE8 Trees, Hedgerows and Woodlands
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.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H1 Meeting Housing Needs
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.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A13 Southbourne Broad Location for Development
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.
Propose changes to following paragraphs:
"Provision will be made for a mixed use development within the broad location for development at Southbourne, as shown on the Key Diagram. Development proposals for Land within the broad location
will ensure that the comprehensive development of the area and the delivery of 1,050 dwellings, local employment opportunities and supporting community uses and facilities is not prejudiced."
"Development should ensure that comprehensive development is achieved, including high-quality design and layout that integrates well with the surrounding built and natural environments to enable a high degree of connectivity with them, particularly for pedestrians and cyclists, and provides good access to facilities and sustainable forms of transport."
"6. Ensure the provision of supporting infrastructure made necessary by development within the broad location, including education provision, community facilities and transport in accordance with the most up to date evidence of need;"
"9. Demonstrate that development would not have an adverse impact on the nature conservation interest of identified sites and habitats including, where possible, the delivery of strategic wildlife corridors and provision for long-term management to maximise wildlife protection and enhancement;"
"Development proposals which prejudice the delivery
of infrastructure provision required for the area will not be permitted."
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H2 Strategic Locations/ Allocations 2021 - 2039
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.
See attachments.
