Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5604

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Needs to be more focus on non-strategic housing provision, even at service village level. Encouraging moderate growth and new infrastructure will benefit service villages and in turn, assist with creating sustainable communities and reducing the need to travel.

Development that supports services in the identified Service Villages will be supported where this is consistent with the development strategy.

Object

Representation ID: 5605

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy suggests landscape gaps are required to prevent coalescence between built up areas however, this is not always the case. There may well be other designations preventing development in these locations, therefore imposing a landscape gap is unnecessary. If landscape gaps are considered to be necessary, it is recommended these are clearly established and shown on a proposals map for clarity. The suggestion of boundaries being shown in a Site Allocations DPD would not be practical unless the document were to be made alongside the emerging Local Plan.

The detailed location and boundaries of landscape gaps will be considered and assessed through either the subsequent Site Allocations DPD that will follow on from the Local Plan or be undertaken as part of a relevant neighbourhood plan. The need for any gap will be taken into account in relation to delivering required and identified development.

Object

Representation ID: 5606

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Whilst it would be a preference to purchase any off-site units within CDC, there is limited availability of units. It is expected that there is the ability to source units, still meeting the DEFRA trading rules, in a neighbouring area or even further afield before using the statutory credit scheme as a last resort.

Objection and comment noted. We will consider a minor amendment to Policy NE5 that enhances its flexibility by allowing for off-site provision outside but neighbouring the Local Plan Area, recognising that BNG can contribute to wider nature recovery plans as well as local objectives. This will be caveated by the need to ensure land is deliverable in areas of strategic significance in accordance with future Local Nature Recovery Strategies

Object

Representation ID: 5607

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Unrealistic to set finished floor levels (FFL’s) to an offset from ‘average site level’. Setting minimum FFL’s to 300mm above an average site level would challenge viability of any larger site or smaller site on a considerable gradient and restrict master planning and placemaking (due to earthworks required to achieve FFL offset from ‘average site level’) at no benefit to flood risk. Exceedance event flow routes can be protected with no increased flood risk to properties without having lift plot FFL’s in lower areas of development sites to such a level. It is recommended wording looks to protect exceedance flow routes ensuring property FFL’s are 300mm above exceedance flood level. Additionally, ‘vulnerable’ development is not clearly defined – is this specific to dwellings in Flood Zones 2 or 3? Should be clarified.

This is essentially the same point made by the Environment Agency and the Council agrees that the policy should be amended accordingly.
In terms of the reference to needing to be more specific in relation to what is defined as vulnerable development, this is not considered to be strictly necessary, as this relates back to national policy, and presumably all forms of vulnerable development encompassed by national policy should be protected from the impacts of flood risk.

Object

Representation ID: 5608

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Question legality of position placing responsibility on developers for Southern Water’s short comings in ensuring sufficient (and suitable – not at detriment to Arun Valley SAC/SPA) supply of potable water for proposed development.

Challenge legality of Apuldram and Thornham sections of policy - under Water Industry Act, developer has an absolute right to connect to the existing sewer whether or not this overloads the system - responsibility for all downstream treatment and discharge is that of the WaSC. Re; point d, policy looks to place emphasis and programme on the developer rather than the WaSC (see Water Industry Act 1991 s94) and should therefore be removed. Suggest Policy is reviewed and re-worded to avoid conflict with Water Industry Act.

We recognise SW’s role and responsibilities but cannot grant permissions that would contravene HRA requirements

Object

Representation ID: 5610

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Suggest revisions to policy.

Comments noted

Object

Representation ID: 5611

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

CDC has reduced housing number to 535 dpa in the south and 40dpa in the north of the District, a shortfall of 1,134 dwellings from the OAN (10%). Do not believe reducing the OAN by this much is necessary or justified, believe more could be allocated to north of Plan area still, in order to accommodate the full OAN.

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

The housing distribution seeks to reconcile a range of factors in order to achieve the most sustainable approach to the distribution of development. This is set out in the more detail within the Sustainability Appraisal and Housing Distribution Background Paper. Higher options for the north of the plan area have already been considered and deemed inappropriate through the SA process.

As set out in the SA and Housing Distribution Background Paper a range of scenarios were considered in the north plan area and the final scenarios are the most appropriate for each settlement when assessed against the SA topic areas.

Object

Representation ID: 5613

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Concern where Neighbourhood Plans are delayed, knock-on delay in provision of housing - suggest CDC use this opportunity to allocate sites to ensure delivery as these are strategic allocations.

The justification and evidence to support the latest housing trajectory is set out in the Housing Supply Background Paper (May 2024).

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: 5614

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Concerned Loxwood Neighbourhood Plan currently being delayed due to water neutrality and if Plan continues to be delayed, there will be knock-on delay in provision of housing in north of the District - suggest CDC allocate sites to ensure delivery.
Question legality of Policy placing responsibility on developers for Southern Water’s short comings in ensuring sufficient capacity for new development.

The council is committed to working with neighbourhood plan groups to take forward housing numbers and allocate sites through the NP process. The Plan, at Policy H2, includes a commitment by the council to allocate sites through a subsequent development plan document in the eventuality that demonstrable progress is not made towards making provision for the housing numbers through NPs.
We recognise SW’s role and responsibilities but cannot grant permissions or allocate sites that would contravene HRA requirements

Object

Representation ID: 5615

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is argued that over the 18-year Plan period there should be some growth within all Parishes, even at a low level and that any without growth is suitably justified.

The Housing Distribution Background Paper (May 2024) sets out the justification for the spatial strategy and distribution of housing across the plan area. It would not be appropriate for all parishes to have planned growth, although this does not prevent suitable rural exception sites coming forward for affordable housing in accordance with Policy H7.