Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5853

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Supporting text does not set out how CDC’s viability evidence base has (or has not) informed Policy - serious omission given fundamental role viability evidence plays in preparing affordable housing policy. Unclear what calculation will be for commuted sums for sites 6 to 9 dwellings in designated rural areas. Commuted sums only accepted in exceptional circumstances does not exclude homes in designated rural areas from requirement for ‘exceptional circumstances’ - unclear what policy approach is in this respect.

There is no need for the viability evidence to be explicitly referred to in the supporting text. The important thing is that the Council has produced viability evidence and this supports the position taken in the Local Plan.
In terms of greater clarity being required with respect to commuted sums, this is already set out in the Council’s Affordable Housing SPD. With regard to the assertion that paragraph 5.19 should be in the policy, the Council would have no objection to that, though it is not considered necessary to make the plan sound, as any neighbourhood plan would have the option of doing that in any case, provided this could be justified with suitable evidence

Object

Representation ID: 5854

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy does not include reference to the ability of neighbourhood plans to be supported by Housing Needs Assessments to provide neighbourhood area / parish level evidence base to inform the housing mix for the neighbourhood area.

Criteria 1 contains a footnote on the word HEDNA that states ‘Or additionally, a specific parish local housing need study’. This is to reflect where additional/or updated studies have been done to inform both applications and neighbourhood plans

Object

Representation ID: 5855

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

What does the policy define as local? What is CDC’s
justification for 30 dwellings? How has 30 dwellings been decided as the upper threshold? This seems like a large scheme for small settlements. Unclear what CDC considers to be a ‘local connection’? Also unclear what Policy refers to in terms of a connection to the host parish “in the first instance” but then refers to a “second instance” where immediately surrounding parishes can then be considered. Unclear as to how this would work in practice. Not possible to determine what is “adjacent” or “as close as possible to the settlement boundary”.

The local connection test is set by Housing at CDC and is available to view on their webpage. Paragraph 5.31 to be updated to clarify.

The threshold of 30 dwellings was drafted to be in line with the average number of dwellings built within the limit of 1 hectare for previous entry level exception sites. Planning practice guidance has been updated to first homes and no longer includes a size limit, however should be proportionate in size to the settlement.

Criteria 4 requires occupiers to meet the local connection test, as set by Housing. Wording to be simplified.

The nature of exception sites means it is not possible to restrict them to only adjacent to the settlement boundary. Criteria 6 was drafted to allow some flexibility to allow sites to come forward further from an existing settlement boundary where suitable, but to ensure development is still delivered in suitable locations.

Object

Representation ID: 5859

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Considered to be a ‘non-event’ of a design policy. Does not go beyond what is already provided in national policy and guidance. Together, P1 and P2 should point to the ability for communities to prepare local design codes through neighbourhood plans and which would then represent a more specific version of the design policies. Policy currently unclear about need for ‘major development’ to provide a detailed masterplan or design codes or development briefs. Policy focusses solely on Design and Access Statement requirements.
Policy hooks for specific design tools and documents are important for effectiveness and clarity for communities,
developers and decision-takers about design process expected from CDC.

The point in relation to reliance on national policy is noted, but reliance on national policy in this regard is appropriate in the interim while a plan area design code is being prepared. The Council agree that it is important for the policy to reflect the importance of the neighbourhood/local level in relation to the production of design codes, this is addressed via the amendment proposed in relation to representation 4291. In relation to masterplans, these requirements are set out in relation to the site-specific allocation policies. There will also be opportunities to add masterplans to any site-specific design codes.

Object

Representation ID: 5864

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Addresses character and distinctiveness but is more about general principles rather than policies specific to Chichester District and its individual places. Together, P1 and P2 should point to the ability for communities to prepare local design codes through neighbourhood plans which would represent a more specific version of the design policies. Policies currently unclear about need for ‘major development’ to provide a detailed masterplan or design codes or development briefs. Policies focus solely on Design and Access Statement requirements. Policy hooks for specific design tools and documents are important for effectiveness and clarity for communities,
developers and decision-takers about design process expected from CDC.

The Council considers that policy P2 is actually quite clear and specific rather than general. The respondent requests that both this policy and policy P1 highlight the ability to produce local design codes. It should be stressed that the ability to produce local level design codes exists independently of the Local Plan and hence technically these doesn’t need to be mentioned at all in order for local communities to utilise that opportunity. Nevertheless, it is considered worth highlighting them in the Local Plan, as clearly they can be an important design tool and helpful with respect to local distinctiveness, and an amendment to policy P1 in order to make reference to them is proposed.
In terms of the reference to policies focusing solely on the requirements of design and access statements, this certainly isn’t the case with respect to policy P2, which contains a number of specific requirements with respect to the design of new development and doesn’t even mention design and access statements.

Object

Representation ID: 5866

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

States at paragraph 2 that non-designated heritage assets will be identified and conserved and enhanced in accordance with their significance and contribution to the historic environment, yet it does not state how they will be identified and what the Council’s approach will be to this.

Objection and comments noted. This issue is addressed with Policy P12 and its supporting text, specifically paragraphs 6.71 and 6.72. Consequently, no change is considered to be required.

Object

Representation ID: 5869

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Legally compliant? No

Sound? No

Duty to co-operate? No

Lack of attention and detail given to Monitoring Framework; no introduction to Framework or how it intends to work with authorities and organisations it identifies in Framework; entirely unclear which ‘Target to be achieved’, ‘Monitoring Indicators’ and ‘Responsible Agency / Partner’ relates to each policy; 'Delivery’ refers to policy documents, not what would expect when defining how policies will be delivered; for its WRZ monitoring indicator, targets and indicators will not provide an accurate, on-going and up to date assessment of total water usage in the WRZ region after development takes place compared to water usage in the region before development took place; no mention of joint mitigation strategy to ensure water neutrality in WRZ.

An introduction to the Monitoring Framework will be added. The framework layout reflects that many of the targets in the monitoring framework are applicable to several policies within each Chapter. The Sussex North Water Neutrality Mitigation Strategy will be added to the Delivery column for Chapter 4. The indicators for the Water Resource Zone are considered sufficient to measure the target of achieving water neutrality and will be part of the wider monitoring of the overall joint local planning authority mitigation strategy.