Chichester Local Plan 2021 - 2039: Proposed Submission

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Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H3 Non-Strategic Parish Housing Requirements 2021 - 2039

Representation ID: 6500

Received: 28/05/2024

Respondent: CPRE Sussex

Agent: CPRE Sussex

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

RECEIVED LATE: Wisborough Green 75 additional houses is unacceptable – see CDC Capacity Study sub sections 166+167. There are limitations: ancient woodland; wildlife – rare habitats and species, river floodplain; and water neutrality. See HRA with reference to Mens Ancient Woodland and presence of European Protected Species, Barbastelle Bats flight paths and foraging across the parish. Also, see Natural England report Site Improvement Report and reports by Frank Greenway, 2008 et al..

Attachments:


Our response:

The housing distribution seeks to reconcile a range of factors in order to achieve the most sustainable approach to the distribution of development. This is set out in the more detail within the Sustainability Appraisal and Housing Distribution Background Paper.
Since the publication of the Preferred Approach Local Plan, work has had to be undertaken to look at the capacity of the north east of the plan area to accommodate more dwellings, due to the constraints on growth in the south of the plan area (to demonstrate that the council has left ‘no stone unturned’ in seeking to reach the full local housing need figure).
As set out in the SA and Housing Distribution Background Paper a range of scenarios were considered in the north plan area and the final scenarios are the most appropriate for each settlement when taking into account the factors above.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.105

Representation ID: 6501

Received: 28/05/2024

Respondent: CPRE Sussex

Agent: CPRE Sussex

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

RECEIVED LATE: In relation to Portsmouth Water and Southern Water targets to reduce water consumption to 100 litres per person per day (lppd) by 2040, it is noted that the target is not the level which could be required for water neutrality.

Attachments:


Our response:

Comment noted – these targets are set by the respective water companies and do not override any plan requirements.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy E9 Caravan and Camping Sites

Representation ID: 6502

Received: 28/05/2024

Respondent: CPRE Sussex

Agent: CPRE Sussex

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

RECEIVED LATE: The Local Plan is weak on impacts especially from the largest concentration of caravans at Selsey on Medmerry.

Attachments:


Our response:

The criterion for policy E9 seeks to deal with impacts from existing caravan sites with its set of policy criteria which is also applied to proposals seeking intensification/alterations of existing sites. This criteria includes the requirements for proposals to demonstrate a demonstrable need; be of an appropriate scale in relation to setting and local amenity as well as be sensitively sited so as not to be visually obtrusive whilst maintaining the tranquility of the area.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE19 Nutrient Neutrality

Representation ID: 6503

Received: 28/05/2024

Respondent: CPRE Sussex

Agent: CPRE Sussex

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

RECEIVED LATE: Nutrient neutrality exclusion of large area of the Peninsula from the protection zone is illogical as same conditions exhibited in Chichester harbour exist at Pagham.
Nutrient budget calculator March, 2022 version gives an “n” factor for discharges from WWTW - no direct mention of its use at Chichester harbour and as data on Pagham Harbour has yet to be made public, the role of Sidlesham WWTW has not been referred to. The “N” factor would probably be more restrictive on outflows from WWTW than the total discharge permits and shows a lack of coordinated approach between the Environment Agency and Natural England.

Attachments:


Our response:

The area affected by the requirement for nutrient neutrality is defined by Natural England. The notice of designation of sensitive catchment areas published by government on 25 January 2024 confirmed Chichester and Langstone Harbours as part of the wider Solent nutrient sensitive catchment.
If the catchment is extended to include Pagham Harbour in future then the same requirement would apply. Policy NE16 also ensures that effects on water quality are considered in all parts of the plan area.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE16 Water Management and Water Quality

Representation ID: 6504

Received: 28/05/2024

Respondent: CPRE Sussex

Agent: CPRE Sussex

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

RECEIVED LATE: There are two reports due to be published - the West Sussex Coast and Gt Brighton Board and Southern Water overall plan for drainage and waste water. The timing of the LP is thus unable to take these two influential inputs into account and may have implications for the ‘Soundness ‘ of the plan as it moves forward.
No mention is included of Sidlesham WSTW which is operating at and beyond capacity resulting in new housing on the Manhood Peninsula dealing with waste water in gardens, in houses etc.

Attachments:


Our response:

We worked with Southern Water as the Drainage and Wastewater Management Plan (DWMP) was being prepared and consulted upon but the DWMP was not yet published in final form before the Reg 19 consultation. Suggest wording is amended for clarity.

The situation in relation to Sidlesham WWTW is acknowledged and is for Southern Water to address. The Local Plan does not propose any housing allocations in the Sidlesham catchment.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.112

Representation ID: 6505

Received: 28/05/2024

Respondent: CPRE Sussex

Agent: CPRE Sussex

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

RECEIVED LATE: Paragraphs 4.112 and 4.113 are contradictory.

Attachments:


Our response:

Paragraph 4.112 sets out that the Water Neutrality Strategy provides overall evidence that Local Plan development will not negatively impact on the Arun Valley sites; paragraph 4.113 sets out the details of how applicants will need to demonstrate their scheme is water neutral in its own right.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Appendix F: Monitoring framework

Representation ID: 6506

Received: 28/05/2024

Respondent: CPRE Sussex

Agent: CPRE Sussex

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

RECEIVED LATE: This section requires a firm commitment to monitoring and reporting back, not just a paper one.

Attachments:


Our response:

The monitoring, to assess whether the policies of the new local plan are achieving the objectives and intended policy outcomes, will continue to be reported annually within the council’s Authorities Monitoring Report which is published on the council’s website.

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