Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5785

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Object on grounds that CDC cannot demonstrate that Local Plan policies have been developed through effective, ongoing and constructive engagement with Prescribed Bodies; there are no up to date, published and agreed SOCGs with any Prescribed Bodies to support Pre-Submission Local Plan; KPC had issued multiple FOIs to CDC to determine the state of the SOCGs regarding Water Neutrality yet were rejected each time by CDC.

The Statement of Compliance published at the time of the Regulation 19 consultation set out the key cross boundary strategic issues and the engagement undertaken by the Council with relevant bodies on these issues and the outcomes of that at that stage.

The latest position is set out in the updated Statement of Compliance (April 2024) and Statements of Common Ground.

Freedom of Information requests received will have been responded to in accordance with the council’s published FOI procedures.

Object

Representation ID: 5795

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Object on grounds that needs to be locally distinctive to give a greater 'sense of place'; leaves out important designations; says nothing about water quality, water neutrality, nutrient neutrality or source protection zones; unrealistic - should recognise sustainable and active travel not possible in some areas, ie; Kirdford.

The 3rd bullet refers to protecting, managing and enhancing the natural environment which encompasses protecting water quality. The supporting text below gives additional information about each sub area. It is intended to be an ambitious Vision.

Object

Representation ID: 5796

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Object on grounds that no explanation or heading for three plan areas - unclear of purpose; unclear what is meant by local communities becoming more self-reliant - Kirdford has virtually no local infrastructure; locating 50 dwellings will not conserve and enhance Kirdford.

Each of the plan areas has a heading in bold above the relevant paragraphs.

The next para 2.50 explains more about opportunities to maintain or enhance local services.

Policy I1 requires infrastructure and its timing to be secured by way of condition or legal requirement

Object

Representation ID: 5797

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Object on grounds that cannot be achieved by consciously locating development in rural inaccessible locations with no local facilities (Kirdford).

The Climate Emergency Action Plan is monitored and reported on separately to the Local Plan, in regular Progress reports published on the council website Climate change - Chichester District Council

It sets an area wide target to reduce emissions across the District by 10% year on year to 2025 – which is referred to in para 2.31 of the plan. Targets beyond that are still to be set.

The objective as currently worded refers to being in line with the council’s Climate Emergency Action Plan which allows flexibility as the targets in that evolve.

Object

Representation ID: 5799

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Objective needs to be clear that there are more designated sites than those listed - should include Ebernoe SAC and The Mens SAC. Inclusion of 'landscape character' at end reads as an afterthought, ineffective. Quantum of biodiversity net gains Plan is seeking to achieve should be set out here - query how protection and enhancement of natural environment, nature recovery, tree cover can be measured?

1. “including” indicates the list is not exhaustive.

2.The requirement for biodiversity net gain is set out in policy NE5.
3. Landscape is covered by Objective 2 – the text underneath is intended to be read with the objective rather than repeat. Policy NE2 and its supporting text set out more detail.

Object

Representation ID: 5807

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

This Objective which states that housing should be located in ‘accessible neighbourhoods’ cannot be met in rural locations such as Kirdford. This objective clearly cannot be achieved by the Local Plan allocating 50 dwellings to Kirdford. The Housing Objective includes no mention of the amount of housing it is seeking to deliver, what tenure, what location and when. This should be clearly set out. The inclusion of a section on Design in this section makes it unclear and confusing compared with Objective 6 (Design and Heritage – Ensuring Beautiful Places).

Accessibility standards are covered in Policy H10 and space standards in P6.

It is not considered that they need to be specifically referred to in strategic objectives.

Agree the design references overlap with Objective 6.

Object

Representation ID: 5808

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

This Objective should state the amount of jobs / employment floorspace the Local Plan is seeking to achieve, and it should be much clearer about the objectives for employment in villages and rural areas.

Employment floorspace targets are set out in the monitoring framework at Appendix F., and in Policy E1. Employment growth forecasts on which the employment requirement is based are only available at District level. Whilst an adjustment has been made to convert this to a requirement for the Plan Area (i.e. minus the SDNPA) we do not have information to disaggregate this further to particular villages or areas

Object

Representation ID: 5809

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

A key aspect of this Objective is improving ‘health indicators’ and ‘life expectancy’ yet the Objective does not say what these indicators are or what the goal is for increasing life expectancy. The objective should be much clearer about these.

Life expectancy rates are set out in para 2.11 and are currently above the national average.

Other health indicators set out in the Health Impact Assessment accompanying the plan also show a healthy population compared to the England average.

In this context a specific target rather than ongoing improvement is not considered necessary.

Object

Representation ID: 5810

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

This objective states that the National Design Code will be supplemented by local design codes. Yet the Local
Plan’s Policy D1 (Design Principles) says nothing about Design Codes being used. Although the title of this Objective includes ‘Heritage’ the actual text provides no further detail about what the Local Plan’s Objectives are in relation to Heritage – this is a clear omission and needs to be rectified through modifications.

1.Heritage is in the first line of the objective.

2. An amendment is proposed to policy P1 which will address the issue concerning local design codes (please see response to representation 5859).

Object

Representation ID: 5811

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Whilst working with infrastructure providers is clearly important this should not be the overall objective – the overall objective should be to identify and deliver the infrastructure required to deliver the spatial strategy. What are the key measurable deliverables for infrastructure, when will they be delivered and for what purpose?

The objective does say “to ensure the timely delivery of key infrastructure to support delivery of new development”. The council is not the infrastructure provider so cannot deliver the infrastructure itself