Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5616

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Re; desired tenure of affordable housing, in Thakeham’s experience with working with Registered Providers, there is difficulty in providing both affordable and social rent on the same site.

This point is understood, however, it is considered to be largely a management issue rather than a policy issue. Moreover, there is a need for both tenures

Object

Representation ID: 5617

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Thakeham objects to the requirement for: “2% of market units provided on strategic scale housing sites should be self/custom build”. Requirements on relatively small sites creates undesirable piecemeal provision with potential feasibility and deliverability issues at implementation stage. Would suggest a focussed provision on sites of 500 or more dwellings represents a more acceptable approach, ensuring effective and comprehensive delivery. To ensure Policy is suitably justified, CDC should consider alternative approaches to increasing supply of self-build plots as referenced in PPG.

It is not clear why there is a concern with ‘piecemeal provision’ for this type of housing. This would be understandable for affordable housing, as that requires management, but it isn’t clear why there would be any difficulty in self/custom build coming forward in small clusters.
There are also plenty of policies at other authorities which involve small amounts of self-build provision, with provision on much smaller sites than is proposed in this instance, such as Mid-Devon (5% on sites of 20 or more dwellings). Finally, other sources are also supported in the Local Plan, such as via neighbourhood planning.

Support

Representation ID: 5618

Received: 17/03/2023

Respondent: Thakeham Homes

Thakeham does not object to the content of the policy, however in order to be robust we believe Policy NE10 (Development in the Countryside) should reflect Policy H7. If a site is within the countryside it is often considered rural and therefore Policy NE10 should acknowledge the requirements within Policy H7 (see also rep no 5619 on Policy NE10).

Support noted.

Support

Representation ID: 5619

Received: 17/03/2023

Respondent: Thakeham Homes

In order to be robust we believe Policy NE10 (Development in the Countryside) should reflect Policy H7. If a site is within the countryside it is often considered rural and therefore Policy NE10 should acknowledge the requirements within Policy H7.

As pointed out at paragraph 1.12, the plan should be read as a ‘whole’ and policies will not be applied in isolation

Object

Representation ID: 5620

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Part b is too onerous for developers. Majority of other Local Planning Authorities in the South only require a percentage of the development to be to M4(2) standards and this is commonly over a threshold for development size for example on developments larger than 20 or 50 dwellings. Requiring dwellings to be constructed to M4(2) standards requires plots to have a larger footprint and therefore impacts the number of houses and the viability of developments.

The policy was drafted to reflect the needs of the local population.
The policy has been viability tested alongside all other policy requirements

Support

Representation ID: 5621

Received: 17/03/2023

Respondent: Thakeham Homes

Whilst Thakeham does not object to the general direction of the policy, with plots to be included on larger strategic sites, we believe there should be a caveat within the policy to make sure they are carefully designed, for example they have separate entrances.

The Council agree that it is important that the pitches and plots in question are carefully designed. However, there is already a specific policy within the plan which addresses site design. It would indeed be expected that each pitch/plot would have its own access. However, if the representation means that the pitches should be separated off from the rest of the housing with a separate vehicular access then that is likely to be an unreasonable requirement, as no such requirement would generally be applied to other forms of housing.

Object

Representation ID: 5622

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy P1 requires all Design & Access Statements (DAS) to explain how the proposed development delivers all 10 characteristics as set out in the National Design Guide. This is not something Thakeham feel is necessary as it has the potential to over complicate the DAS.

The Council agree that some further clarification in this regard would be helpful in terms ensuring that this requirement can be met in a manner which works efficiently in practice. Ultimately, this part of the policy will need to be applied in a pragmatic manner via the development management process.

Object

Representation ID: 5623

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Thakeham believes Paragraph 6.9 is ambiguous and clarity should be provided to understand what would be deemed ‘too many similar house types’, as ultimately all large developments utilise a small range of basic house types.

Objection and comment noted. It is considered that the supporting text sufficiently describes the potential harm to local character associated with repetition in larger schemes. To attempt to further define would hinder flexibility in its applicability to a variety on contexts

Object

Representation ID: 5624

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Thakeham query the wording of paragraph 6.11 as it suggests that CDC require developments to be at a minimum of 35dph to meet their 5YHLS. We would question how this can be applied to sites that would fall below this density, for example where there might be site constraints that mean a lower density is more appropriate to create a well-designed scheme. More clarity should be provided in this paragraph to make it clear and robust.

Objection noted. Paragraph 6.11 of the supporting text is focused on ensuring the efficient use of land, setting an expectation of a minimum density of 35 dph, continued from the adopted Local Plan approach, and explained within the Housing Density Evidence Study. P3 is flexibly worded, however, requiring a design-led approach where site capacity is determined once relevant constraints are considered. It is therefore suggested that this approach as currently drafted does not prevent lower density schemes on constrained sites.

Object

Representation ID: 5625

Received: 17/03/2023

Respondent: Thakeham Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Paragraph 6.20 appears to be asking for brick walls on boundaries that face the public realm or shared parking areas. These are not only costly and often quite a hard, engineered approach that can often be more sensitively designed with a fence and/or planting. In Thakeham’s view planting should be encouraged over brick walls, not only for aesthetic reasons, but for wildlife and Biodiversity Net Gain benefits.

The Council would agree that brick walls are not always the best form of boundary treatment, for the reasons set out. However, it is contended that the policy does not explicitly require the use of brick walls and other forms of boundary treatment would appear to fit the description set out in the policy, such as estate railings for example. However, some clarification in this regard is proposed in response to the concern raised.