Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5812

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

The Objectives only mention Water Neutrality in passing and it comes across as an ‘add on’ or ‘afterthought’ by CDC despite it being a very important issue for the Local Plan. There is no mention of the Sussex North Water Resource Zone or the Arun Valley SPA / SAC.

Water neutrality will be added to Objective 2

Object

Representation ID: 5813

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Notably missing from the Council’s list of factors that informed the spatial strategy are:
• Sustainable access to facilities and services; and
• Water neutrality and specifically the Sussex North Water Resource Zone.

Comments noted, however, the bullet point list is not exhaustive and the issues identified by the respondent are addressed in relevant sections of the Plan.

Object

Representation ID: 5814

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

In relation to supporting text, Kirdford is not an area that is well located to other uses and nor is it serviced by any choice of transport modes apart from the private automobile and a poor bus service.

Noted.

Object

Representation ID: 5815

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Justification provided by CDC for the selected Spatial Strategy in relation to the North of the Plan Area (NAP) is difficult to follow and it fails to effectively justify CDC’s decision to look to Kirdford for additional housing. It states that “Conserving the rural character of the area, with its high quality landscape and environment is a key objective” yet this is not the actual Strategic Objective of the Local Plan, therefore what exactly is the Local Plan referring to here? Do not see where there is an "identified need" set out in evidence for additional housing need in Kirdford.

As set out in the SA and Housing Distribution Background Paper (July 2024) a range of growth scenarios were considered across the north Plan Area. The Landscape Capacity Study identifies that the landscape around Kirdford is generally of high sensitivity but with some opportunities for small scale development. To avoid landscape or visual harm, therefore, the lower growth scenario is considered appropriate for Kirdford.

Object

Representation ID: 5816

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

The suggestion that Kirdford should access its services and facilities from Dunsfold Park which is over 10 miles away and a 20 minute drive away and not yet built is a very considerable stretch by CDC to attempt to justify proposing development at Kirdford.

This is not the case. Rather it recognises that new development can provide the opportunity to improve accessibility, including by sustainable modes of travel, in accordance with Policies T1 and T2.

Object

Representation ID: 5817

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Attempts to explain that the due to the constraints on the A27 in the south of the plan area, that a “moderate level of growth in the north to help make up the overall shortfall of dwellings”. However it does not state what the “constraints on the A27” actually are. It does not set explain what the “overall shortfall of dwellings” is due to the “constraints on the A27”.

The Plan should be read as a whole. Section 3 (Housing) and 8 (Transport and Accessibility) of the Local Plan provide more detail on the matters referred to.

Object

Representation ID: 5819

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy confusing, does not state quantum of housing, employment or critical infrastructure required for each area or when development will come forward including need for Water Neutrality solution in North of Plan Area. First sentence: dispersing development inconsistent with principle of sustainable development and concept of place-making. Point 1: Does Plan make provision for unplanned sustainable growth or planned growth that is not sustainable? Point 2: Meaning unclear; Point 3: Why does Policy make out North of Plan Area villages should wait for opportunities to arise? Point 6: What is definition of small-scale housing? Define local community facilities and define (c); Point 7: In Kirdford, will all development be handled through NP? Final paragraph: does not actually state what the distribution of development is.

1. The Plan needs to be read as a whole. Policy H1 sets out the overall quantum of housing and how that breaks down by sub-area, E1 quantum of employment land and the IDP the infrastructure required to support development. In terms of housing, the trajectory sets out the expected delivery of sites taking into account known infrastructure constraints. In north of plan area, the updated trajectory forecasts delivery from 2032/33 onwards. However, there is no restriction on when sites can come forward if it can be demonstrated that the requirements of Policy NE17 are met in full.

2. This needs to be read in the context of the wording that follows it i.e. the type of development proposed by the Local Plan for each of the sub-areas.

3. This refers to the making of specific allocations or parish housing numbers.

4. This reflects that development on the Manhood Peninsula will be more limited and focused on supporting the Vision for the area

5. It is agreed that Point 3 should be amended to reflect that this Local Plan is proposing more planned development in the North of the Plan Area.

6. ‘Small scale’ need not necessarily exclude major development provided it was consistent with the size and character of the settlement and local area and will also be subject to the requirements of other relevant policies. Community facilities is defined in the glossary (Appendix J).

7. As set out in Policy H3, the intention is that suitable sites to deliver the Parish housing number will be identified through a Neighbourhood Plan or, in the event that this does not progress, a DPD.

8. Policy S1 sets out the overall strategy but, as set out in 1 above the Plan should be read as a whole. The Council consider the policy is robust.

Object

Representation ID: 5823

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Key Diagram has a number of deficiencies: Key Diagram map titled “North East of Plan Area” is referred to in Local Plan as ‘North of the Plan Area’ (the area that includes Kirdford, Wisborough Green, Plaistow & Ifold, and Loxwood) which creates confusion to the reader when comparing with Paragraph 1.9 of the Local Plan (‘How to Use the Plan). The Legend includes SAC yet neither the Ebernoe Common SAC or the Mens SAC are not indicated in the North of the District. Very messy Diagram for South of Plan Area - not possible to make out what is being proposed. Most users not aware of what acronyms stand for.

1. It is agreed that for consistency with the wording of paragraph 1.9 and Map A3 in Appendix A, the Key Diagram should be amended.
2. Although the boundary of the Ebernoe Common and Mens SACs abut the northern plan area they lie outside of the plan area (within the South Downs National Park) and, as such, it would not be appropriate to illustrate them on the Key Diagram.
3. Paragraph 1.11 in the section on ‘How to use the Plan’, indicates that an explanation of acronyms used can be found in the Glossary. However, to easily understand the Key Diagram it would be beneficial for acronyms in the legend to be written in full.

Object

Representation ID: 5825

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Simply no justification with any substance to explain of how the Council has arrived at the policy or hierarchy.

The Council’s approach to the classification of settlements in the hierarchy is based on the availability of community facilities, key public services, retail and leisure opportunities. The Settlement Hierarchy Background Paper (May 2024) concludes that Kirdford has the range of services and facilities to be classified

Object

Representation ID: 5828

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

No definition in Policy or supporting text of what each tier of hierarchy actually means; no reference to an evidence base used to justify the Policy. Extensive discussion in attachment regarding Background Paper.

Policy S1 sets out the expected scale/type of development in each settlement tier. The Council’s approach to the classification of settlements in the hierarchy is based on the availability of community facilities, key public services, retail and leisure opportunities as set out in the Settlement Hierarchy Background Paper (May 2024).