Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 4044

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

"Outside of the settlement boundaries" development in the rest of the plan is restricted to that which requires a countryside location. However, much of the proposed development has been allocated to locations outside the settlement boundaries where there is no evidence of an essential local rural need, whilst being in the countryside.

Environmental and infrastructure constraints, and whether they can be mitigated, have been considered in determining whether a figure less than the standard method can be justified.

A revised NPPF was published in December 2023. The NPPF contains transitional arrangements whereby Local Plans that have reached Regulation 19 stage before 19 March 2024 will be examined under the relevant previous version of the NPFF. These transitional arrangements, therefore, apply to the Chichester Local Plan as it reached Regulation 19 stage in January 2023

Object

Representation ID: 4045

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

CDC commissioned a Landscape Capacity Study to provide evidence where the landscape and visual impacts of development would be greatest, therefore to identify which areas have the greatest capacity to accommodate change without causing significant and detrimental damage to the landscapes within the plan area.
There is no reference or recognition of this in the policy or the proposed allocation of sites especially in the East/West corridor. There is land around Chichester where the landscape and visual impacts would be lower. In landscape and visual terms these sites should be selected before the release of lower capacity sites.

The Landscape Capacity Study which informed the preparation of the Local Plan is referred to at paragraph 4.7 of the policy background text

Object

Representation ID: 4047

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This policy states that development will only be permitted within gaps provided that it would not diminish the physical, visual and/or perceived gaps between settlements. However, proposed allocations within the East/West corridor would not comply with this policy.

Comments noted. The detailed location and boundaries of landscape gaps will be considered and assessed through either the subsequent Site Allocations DPD that will follow on from the Local Plan or be undertaken as part of a relevant neighbourhood plan. No development has therefore been allocated in a landscape gap.

Object

Representation ID: 4050

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Allocations in the East/West corridor are outside the existing settlement boundary and in the countryside contrary to this policy.

The spatial strategy seeks to locate the majority of development in locations which have access to a range of services and facilities, informed by the settlement hierarchy evidence. This has also been influenced by site availability and suitability, environmental and other constraints

Object

Representation ID: 4051

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The proposed allocations within the East/West corridor, would not comply with this policy and would damage the visual relief to the built up areas and the views between the AONB and the SDNP.

Comment noted

Object

Representation ID: 4054

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Bosham Parish Council contends that the plan is not sound as regards policy NE16 because adequate SAFE water supplies will not exist and the provision of water supplies will be detrimental to water the quality.
There is no evidence in the LPlan to show how lower water usage will be encouraged
There is no evidence of upgrades to waste water infrastructure which the IDP categorises as a critical issue.

The EA has identified areas supplied by PW and SW as at serious water stress. A new reservoir "Havant Thicket" is planned for 2029 in Havant to support future water supply needs. There are serious public concerns about using recycled wastewater as a portable water source for public consumption. This is the first use of such untried technology in the UK.
Para 4.102 states “ it is clear that upgrades to wastewater infrastructure will be necessary to manage the increased wastewater from housing growth over the plan period whilst maintaining and improving the water quality of receiving waters”. Therefore it is incumbent on CDC to explain such upgrades. This they have not done. Para 4.103 states SW is preparing a DMWP to consider the options… The Southern Water DWMP is no more that a conditional proposal , predicated on obtaining financing from a number of sources. In addition, the timeline of the DWMP does not run parallel with that of the LPlan as its vague proposals for enhancement run until 2050. There is no clear strategy of improvements and any proposed development is reliant upon a concrete DWMP. The current wastewater system at Bosham and other treatment works is at capacity (as illustrated in SWater document Chichester Harbour and growth in Bosham) and Chichester Harbour, into which storm flows drain, is deemed by Natural England to be “declining”. The Waste Water Infrastructure requirements for much of the plan’s proposed is not based on a clear strategy of deliverable improvements despite the Infrastructure Development Plan categorising potable and wastewater infrastructure improvements as CRITICAL ISSUES
Thus any additional housing with put an intolerable strain on an already overloaded system.

1. The first part of the policy sets out that development would only be allowed where safe water can be provided without such harm.
2. The policy encourages applicants to build to facilitate a lower water use.
3. Southern Water are the statutory undertaker with responsibility for identifying and delivering upgrades to meet the needs of new development. This is done through their business planning process, including the DWMP.

Object

Representation ID: 4063

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Over capacity at the Fishbourne roundabout was identified in 2014, there has been a massive increase in housing west of Chichester between 2014 and 2023 but no improvement to the roundabouts have been implemented to date. There is no guarantee that funding to improve the A27 or Fishbourne roundabout will be available within the timescale of the Plan.
Congestion has been a problem since 2014 and this strategy does not offer a solution. There is a clear omission here that funding is not available to facilitate the improvements required to address the current and worsening congestion caused by future development.

The strategy set out in Policy T1 will support the level of development that is proposed by the Plan. Therefore, there is no justification for reducing planned housing numbers below what is proposed. Following adoption of the new Local Plan, a new Supplementary Planning Document (SPD) will be prepared to set out guidance on how the proposed contribution for A27 Bypass improvements secured.

Object

Representation ID: 4067

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There is no evidence of any currently available offsetting scheme for much of the proposed development The South Downs National Park has confirmed in writing that they do not intend to enter any s106 mitigation agreements for nitrate offsets at Chilgrove Farm on a piecemeal basis. The plan makes no reference to any alternative scheme or approach.

A nutrient mitigation plan will need to be agreed in line with requirements for any relevant development. This is usually done through the planning application process as the mitigation available will evolve over the plan period.

Object

Representation ID: 4068

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There appears to be no evidence of a district wide strategic approach to achieving appropriate mitigation measures.

The various pollution policies point to the relevant guidance, standards and/or action plan. Appropriate mitigation measures will be determined at planning application stage and considered on a case-by-case basis

Object

Representation ID: 4071

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This policy is not sound as it does not accord with the following policies:
NPPF para 176,
NE2, NE3, NE10, NE13, NE16, NE19 & NE20
P2, I1, T1

Objection noted. The policy as drafted includes a number of criteria which are intended to ensure the development comes forward in the most sustainable way, including ensuring protection of the natural environment and landscape, the delivery of infrastructure in line with the IDP and Policy I1 and to ensure any highways issues and sustainable transport options are dealt with as part of a planning application.