Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
2.30
Representation ID: 5352
Received: 17/03/2023
Respondent: Landlink Estates Ltd
Agent: Jackson Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The Council position does not comply with Section 19(1A) of the PCPA 2004, which requires Local Plan policies to be designed to secure that the development and use of land in the LPA's area contribute to the mitigation of, and adaptation to, climate change.
The plan has failed to demonstrate a vision of how to achieve net zero by 2050,or decarbonise power systems by 2035 in line with the Climate Change Act 2008 and ongoing ambitions towards Net Zero.
The 2008 Climate Change Act sets a legally binding target to reduce net greenhouse gas emissions from their 1990 level by 100% by 2050. The plan does not demonstrate how this is achieved and is not legally compliant.
Withdraw plan and rework to ensure priority given to climate change, especially in relation to land use implications and climate mitigations. Propose an additional strategic overarching policy to deliver Net Zero and secure sustainable development to make the Plan sound. Suggested wording as follows:
Additional Strategic Policy 01 - Delivering Net Zero.
The Council will support growth and change that delivers a more sustainable, low carbon future for Chichester District, reflecting the Government’s legal Net Zero targets and the Council’s declared climate emergency (July 2019). The ambition is to reduce levels of carbon emissions by X%* at the end of the plan period.
Climate change mitigation is required in all relevant policy areas, including sustainable travel, net zero buildings, energy and water efficiency, renewable energy production and energy storage, and also supporting the circular economy and green infrastructure through the protection of carbon sinks and opportunities for
carbon sequestration.
Development and change will be planned for and managed in accordance with the following principles of sustainable development:
1. All development will contribute to achieving net zero by 2050 as follows (demonstrated through an energy calculation):
• No on-site fossil fuel combustion;
• Energy use is minimised, demonstrated through space heating demand of less than 15kWh/m2 /year and operational energy use of less than 35kWh/m2 /year for dwellings; or demonstrated by using BREEAM Excellent level accreditation, with outstanding level for energy use (Credit Ene01) or equivalent for non-residential
development;
• On-site renewable generation is maximised, equivalent to at least the on-site energy demand.
• Where the above criteria cannot be met, due to exceptional circumstances set out in support of the development, the proposal must deliver equivalent carbon reductions through off-site
measures;
2. The effective use of land is made for development through optimising reuse of previously developed sites and buildings, therefore reducing the need for greenfield development and retaining embedded carbon where viable;
3. Supporting embedded and free-standing renewable energy development and de-carbonisation of the District as set out in policy NE1 and as defined in the site allocations DPD which will identify the necessary range of suitable sites for renewable energy to meet the legal climate obligations.
*The percentage reduction in carbon emissions to 2039 (end of the plan period) needs to be calculated by CDC from the 1990 baseline. CDC's current Climate Change Action Plan targets stop at 2025.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy S1 Spatial Development Strategy
Representation ID: 5353
Received: 17/03/2023
Respondent: Landlink Estates Ltd
Agent: Jackson Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Objection on grounds that policy does not address net zero and climate change adaptation and mitigation; positive strategy must expressly achieve net zero including renewable energy and carbon sequestration; must address strategic allocation of climate change management area and issue of coastal retreat, including strategy for replacement homes lost to climate change; Para 4.76 inconsistent with SA that excludes strategic development on MP due to climate change; nothing in evidence base in terms of re-provision of homes and infrastructure required for climate adaptation; removal of strategic site at Selsey unsound as not justified, nor supported by evidence because:
1. Does not respect the settlement hierarchy;
2. SFRA confirms the site passes the sequential test;
3. Does not mitigate impacts on B2145
The suggested changes to the policy includes achieving net zero by positive strategy for development of energy from renewable sources and carbon sequestration, climate change and adaptation for coastal change management, and adding detail about resilience on the Manhood Peninsula including tidal flooding.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE1 Stand-alone Renewable Energy
Representation ID: 5354
Received: 17/03/2023
Respondent: Landlink Estates Ltd
Agent: Jackson Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy does not comply with national policy in respect of climate change, including NPPF para 155 a) and b); Policy is negatively worded with barriers to RE development rather than positive provision proposals that recognise the significant scale of RE development required to meet net zero, or land use implications for the commitment to carbon reduction now set out in law.
There is no evidence in the totality of the published evidence base to consider renewable energy production and how this intersects with other land use policies in the plan. The plan does not identify the quantum of additional renewable energy development requirements in the plan period and how this intersects with NE3 and NE4.
NE1 Standalone Renewable and low carbon energy (including heat) revised policy wording in attached submission written representation document. Proposed wording includes a requirement to identify the increase in renewable energy required to meet net zero by the end of the plan period, and support for battery energy storage systems and green hydrogen.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE2 Natural Landscape
Representation ID: 5355
Received: 17/03/2023
Respondent: Landlink Estates Ltd
Agent: Jackson Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Object on grounds that strategic policy must reflect the NPPF to move to a low carbon economy; the extent of what is considered a significant loss of BMV Land is not quantified; policy should refer to 20ha limit imposed by Schedule 4 paragraph (y) of the Development Management Procedure Order 2015 where Natural England are consulted; temporary loss of agricultural land for temporary uses, for example ground mounted solar farms, should be treated differently as land not lost to agriculture permanently.
Revised policy proposed in attached written representation and includes considerations of climate change, mitigation and adaptation to achieve net zero.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE3 Landscape Gaps between settlements
Representation ID: 5356
Received: 17/03/2023
Respondent: Landlink Estates Ltd
Agent: Jackson Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Object on grounds that policy not justified in relation to delivering net zero; proposed gaps not identified in plan; needs to be examination of reasonable alternatives so that plan reflects sustainability objectives; proposed landscape gaps may contain important sites for delivery of renewable energy to allow Council to reach binding net zero targets such as solar farms; no examination in the SA of the impacts of gap designations in preventing development of critical climate adaptation development.
Policy should not proceed to Regulation 20 until the compatibility with the ability of the District to achieve net zero has been demonstrated, and this is tested through the SA process.
Remove the policy from the plan as it has not been assessed in terms of reasonable alternatives in the sustainability appraisal and has therefore not met the requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 -Regulation 12(2)b.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE4 Strategic Wildlife Corridors
Representation ID: 5357
Received: 17/03/2023
Respondent: Landlink Estates Ltd
Agent: Jackson Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Objection on grounds that wildlife corridors have not been assessed for their impact on delivering net zero; wildlife corridors may contain important sites for delivery of renewable energy; requiring unjustified sequential testing is contrary to NPPF 158 a) where renewable energy applicants do not need to demonstrate the overall need for the development; SA not considered impact of removing BMV land within the proposed wildlife corridors which exceeds NE threshold; policy not assessed in terms of reasonable alternatives in sustainability appraisal.
Remove the policy from the plan as it has not been assessed in terms of reasonable alternatives in the sustainability appraisal and has therefore not met the requirements of The Environmental Assessment of Plans and Programmes Regulations 2004 -Regulation 12(2)b.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE14 Integrated Coastal Zone Management for the Manhood Peninsula
Representation ID: 5358
Received: 17/03/2023
Respondent: Landlink Estates Ltd
Agent: Jackson Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Objection to policy on grounds that ‘Resilience and Adaptation – ICZM 2021 and beyond’ and ICZM 2011 not included in evidence base; policy should include an allocation of area of coastal change management consistent with the area of coastal retreat; SA assessment dismisses linked pathways and impacts of relocating current settlement areas; should provide vision reflecting accelerating climate change; acknowledge potential sites needed now for relocation of communities in vulnerable areas; address vulnerability of B2145; Selsey site in Preferred Approach could act as phase 1 of managed retreat and relocation of settlement with part of allocation ring fenced for occupation by relocated inhabitants.
Revised NE14 proposed - see attached written representation doc for full wording. Proposed revisions include climate change adaptation and mitigation including designating an area of coastal change management and supporting development that is capable of long term defence by recognising managed retreat.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H1 Meeting Housing Needs
Representation ID: 5359
Received: 17/03/2023
Respondent: Landlink Estates Ltd
Agent: Jackson Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy has not included housing allocations to deal with climate adaptation and managed coastal retreat. Council must identify an area of coastal change management to properly plan for climate adaptation and identify a quantum of development required to meet the managed coastal retreat. As housing will be permanently lost to coastal retreat this must be replaced. Local Plan must identify broad spatial and land use requirements for this important component of housing supply. Interaction of supply of replacement housing as a result of climate adaptation and more traditional housing need as well as timeframe for replacement housing, should be considered as part of supply side calculations.
The housing requirement for replacement housing lost to coastal retreat must be calculated andadded to overall housing requirement for the plan period.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H2 Strategic Locations/ Allocations 2021 - 2039
Representation ID: 5360
Received: 17/03/2023
Respondent: Landlink Estates Ltd
Agent: Jackson Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Objection to policy on grounds that it has failed to be properly assessed in line with The Environmental Assessment of Plans and Programmes Regulations 2004 - Regulation 12; unjustified removal of strategic housing site at Selsey - removing site from plan condemns population of Selsey relying on B2145 to effective abandonment; reasonable alternatives not tested in SA. Supporting evidence for Selsey site attached.
To make the plan sound the strategic site at Selsey needs to be reinstated in the plan with commensurate testing in the SA. The allocation would need to ensure that the development deals with flood resilience for access and egress to the B2145 in a proportionate way, working with the relevant agencies. The significant benefits of providing (partial) flood resilience to the wider community of Selsey needs to be recognised as part of the planning policy balance.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H3 Non-Strategic Parish Housing Requirements 2021 - 2039
Representation ID: 5361
Received: 17/03/2023
Respondent: Landlink Estates Ltd
Agent: Jackson Planning Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Object on grounds that policy does not include sites in Parishes to seek to meet the Council’s OAN where there are acceptable sites capable of accommodating housing to meet those needs; evidence of suitable sites has been provided in HEELA assessment; a reasonable alternative would have been to look at parishes considering allocations in Neighbourhood Development Plans (Hunston) and where planning application are well advanced (North Mundham); reasonable alternative site Charmans Field, Runcton should have been tested in SA.
Add additional capacity at North Mundham and Hunston villages:
Hunston – Figure 100
North Mundham Figure 100
See attachments.
