Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
Policy P6 Amenity
Representation ID: 5626
Received: 17/03/2023
Respondent: Thakeham Homes
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Re; Point 1, needs to be clear if this relates to private amenity space, or just public. If it refers to private amenity space, will require setting aside specific space for flats, often difficult to achieve.
Re; (g), not clear if this would relate to air source heat pumps (ASHP). Commonly ASHPs do not have enclosures around them as they restrict the air flow.
Re; "separation distances" section, 21 metres not achievable on front-front or front-side scenarios, would significantly impact ability to design sites to the target density of 35dph.
Suggest wording of Point 1 is amended. suggest further clarity is provided re; (g). Separation Distances paragraph 2 needs reviewing and clarifying to ensure it's consistent with wider aspirations of the Local Plan.
See attached representation.
Objection and proposed changes noted. i) The Council considers the supporting text for policy 6 to sufficiently clarify that private, shared and communal spaces all contribute to amenity. ii) It is considered that point g) is sufficiently flexible to allow service equipment, such as air source heat pumps, to be fully integrated or inconspicuously located. Provision of an alternative ensures function need not be impeded. iii) The Council considers that the policy offers flexibility by allowing separation distances to be considered on an individual basis. It will consider modifications to the policy and its supporting text to ensure that the range of potential scenarios are reflected. It should be stressed, however, that the 35 dph figure quoted in the supporting text of policy P3 is not a density target, but a guideline and hence shouldn’t form a basis for any inappropriate spatial relationships between buildings.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy P8 Materials and Detailing
Representation ID: 5627
Received: 17/03/2023
Respondent: Thakeham Homes
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Point 6 - If features such as chimneys are desired to be incorporated into a scheme, then they need to be GRP. GRP chimneys can be in keeping with existing character of an area and should not be dismissed with a blanket policy such as this.
Point 9 - fibre cement boarding can be a visually attractive design within a development. If cladding is to be used it is preferred to be fibre cement due to safety benefits. Timber is combustible and even if it has been treated poses a fire risk. Timber is not recommended by Building Regulations, further support of this is within The Building Safety Act.
Point 10 - would recommend this is assessed on a case-by-case basis depending on what blocks are put forward at design stage.
Point 11 - uPVC provides a robust and reliable material at a reasonable price which is highly popular in the housing market. It is also a product that house buyers would commonly expect to find on a new-build and are familiar with.
Reconsider wording of point 6 of Policy P8. Either remove point 11 or amend as follows: “The use of uPVC will not be unsupported, however the use of alternative materials with environmental benefits will be encouraged”.
See attached representation.
The policy does not impose a wholesale prohibition on ornamental chimneys. However, in design terms it would be far more appropriate for such design elements to be utilised as an integral part of the overall design and function of buildings, rather than superficial, ornamental additions. In relation to point 9, again, from a design perspective, materials should be authentic to the overall design concept, not based on imitation materials. The policy does not presume to override or contradict legislation or building regulations. In relation to the comment concerning point 10, the Council consider that the wording of the policy achieves the appropriate balance in terms of not entirely preventing the use of flint blocks, but emphasising a preference for a traditional approach, as that will maximise the chances of achieving a high quality outcome.
In relation to point 11, UPVC is not considered to be attractive in design terms and is highly unsustainable. Consequently, it is considered that the policy strikes a reasonable balance in this regard in terms of discouraging it, but not ruling it out completely.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy I1 Infrastructure Provision
Representation ID: 5628
Received: 17/03/2023
Respondent: Thakeham Homes
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Would recommend amendment to wording of penultimate point (vii).
Amend (vii) to read as follows:
Ensure new development benefits from gigabit-capable broadband infrastructure (where such facilities are locally available) at the point of occupation;
See attached representation.
The NPPF says:
10. Supporting high quality communications infrastructure
Paragraph 114:
Advanced, high quality and reliable communications infrastructure is essential for economic growth and social well-being. Planning policies and decisions should support the expansion of electronic communications networks, including next generation mobile technology (such as 5G) and full fibre broadband connections. Policies should set out how high quality digital infrastructure, providing access to services from a range of providers, is expected to be delivered and upgraded over time; and should prioritise full fibre connections to existing and new developments (as these connections will, in almost all cases, provide the optimum solution).
The policy at vi is in accordance with the building regulations Section 1 RA1
Approved Document R Volume 1: Physical infrastructure and network connection for new dwellings (publishing.service.gov.uk)
The requirement for a functioning connection to a gigabit-capable public electronic communications network is set out in the Building Regulations 2010 (amended 2022) in section 1 requirement RA2 (at the same link above).
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
1.37
Representation ID: 5629
Received: 17/03/2023
Respondent: Thakeham Homes
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Concerns with length of delay between Regulation 18 and 19 consultations. Regulation 19 consultation only allows for comments relating to soundness of Plan, not its content, and there are a number of new policies. Since Regulation 18 consultation in 2018 a number of large events/changes have taken place including Covid and NPPF changes, as well as new constraints such as water and nutrient neutrality.
Main concern is how up to date the evidence base remains and if Plan will stand up to Examination and be considered sound. Concerned that five years between Regulation 18 and 19 is too long without fully updated evidence base.
See attached representation.
Key evidence documents have been updated e.g. HEDNA, flood risk, retailing, transport assessment since the Regulation 18 consultation and the Council in conjunction with other affected local authorities has completed a water neutrality strategy.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy S1 Spatial Development Strategy
Representation ID: 6255
Received: 17/03/2023
Respondent: Thakeham Homes
Aspiration of policy generally supported.
See attached representation.
Noted.