Chichester Local Plan 2021 - 2039: Proposed Submission

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Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy S2 Settlement Hierarchy

Representation ID: 4044

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

"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.

Change suggested by respondent:

The scale of the development proposed should be reduced in order to reflect there is no longer a requirement to meet mandatory target numbers set by government. Some 80% if the district falls within CHONAB & SDNP landscape, which is protected against development, this suggests that CDC would be justified in further reducing the government allocated figure for housing by a proportionate amount.

Full text:

"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.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE2 Natural Landscape

Representation ID: 4045

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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.

Change suggested by respondent:

As a results of the conclusions in the Landscape Capacity Study of Sub-area 91 between Bosham and Fishbourne, the proposed allocations should avoid areas of medium / low capacity, which are constrained by its rural character.

Full text:

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.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE3 Landscape Gaps between settlements

Representation ID: 4047

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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.

Change suggested by respondent:

Remove proposed development allocated to landscape gaps between existing settlements.

Full text:

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.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE10 Development in the Countryside

Representation ID: 4050

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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

Change suggested by respondent:

Remove these proposed allocations and identify more suitable locations.

Full text:

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

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty

Representation ID: 4051

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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.

Change suggested by respondent:

Proposed allocations adjacent to the AONB and impacting on its setting, including views into and from the SDNP should be removed.

Full text:

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.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE16 Water Management and Water Quality

Representation ID: 4054

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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.

Full text:

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.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy T1: Transport Infrastructure

Representation ID: 4063

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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.

Change suggested by respondent:

Public transport is not in the control of CDC and therefore it is not possible to guarantee improved and expanded services. The proposed the £7,728 charge per unit towards infrastructure is yet to be confirmed as legally compliant. Thus an even greater reduction in housing numbers to the Chichester area is required.

Full text:

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.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE19 Nutrient Neutrality

Representation ID: 4067

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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.

Change suggested by respondent:

There should be an overall district wide strategy for dealing with mitigation, and mitigation measures must be in in evidence prior to the adoption of the plan, to ensure the plan is sound.

Full text:

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.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE20 Pollution

Representation ID: 4068

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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

Change suggested by respondent:

Both a reduction in housing numbers to reduce the pollution and a district wide strategic approach to achieving appropriate mitigation measures, to ensure soundness of the plan.

Full text:

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

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy A11 Highgrove Farm, Bosham

Representation ID: 4071

Received: 14/03/2023

Respondent: Bosham Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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

Change suggested by respondent:

Removal of the proposed allocation from this site and identify a less sensitive, policy compliant site.

Full text:

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

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