Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
1.14
Representation ID: 4091
Received: 15/03/2023
Respondent: Chichester Harbour Trust
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The NPPF is currently under review and may result in a shift in Government Policy on development - particularly on housing targets. We feel that the publication of the Chichester Local Plan pre-empts the outcome of the consultation and potential change in national planning policy.
The timescale of the plan submission should be amended to allow for the confirmation of national planning policy. In the meantime, to guard against speculative development, there should be a moratorium on building in the district.
The NPPF is currently under review and may result in a shift in Government Policy on development - particularly on housing targets. We feel that the publication of the Chichester Local Plan pre-empts the outcome of the consultation and potential change in national planning policy.
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
Chichester Local Plan 2021 - 2039: Proposed Submission
1.37
Representation ID: 4093
Received: 15/03/2023
Respondent: Chichester Harbour Trust
Legally compliant? No
Sound? No
Duty to co-operate? No
There has been no further public consultation on the preferred approach since 2018/19, four years have passed since this time. The issues that were raised during that consultation are still relevant today, and have not been addressed within the new proposed Plan.
This is a comment only
There has been no further public consultation on the preferred approach since 2018/19, four years have passed since this time. The issues that were raised during that consultation are still relevant today, and have not been addressed within the new proposed Plan. The reduction in housing numbers in the revised plan does not adequately reflect the challenges and constraints of the infrastructure issues, particularly waste water treatment and the A27. The impact on sensitive landscapes has not been properly addressed, with 1,600 houses proposed on the Chichester Harbour AONB boundary without active engagement with Chichester Harbour Conservancy over the impact (particularly the allocated site A11 at Highgrove Farm, Bosham.
There is considerable flexibility open to LPAs in how the initial stages of local plan production are carried out and there is no requirement to have a further Regulation 18 consultation.
The Statement of Consultation (January 2023) together with the Summary of Responses reports, set out how the Local Plan has been changed to respond to the main issues raised in responses to the Preferred Approach Local Plan.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
2.21
Representation ID: 4095
Received: 15/03/2023
Respondent: Chichester Harbour Trust
Chichester Harbour provides a significant economic benefit to the district's economy. Although dated now (2009, UE Associates) the Valuing Chichester Harbour study found that there were 455 businesses in the Harbour, and that the contribution to the local economy was £2.78 billion.
This cumulative figure is made up of individual valuation information from maritime businesses (£524M), residential property (£2,151M), tourism (£44M), land values (£52M) and recreation (£1.2M). This document is available on Chichester District Council's website: https://www.chichester.gov.uk/media/7890/Valuing-Chichester-Harbour-2009---Part--1/pdf/Valuing_chichester_harbour_part_1.pdf
Chichester Harbour provides a significant economic benefit to the district's economy. Although dated now (2009, UE Associates) the Valuing Chichester Harbour study found that there were 455 businesses in the Harbour, and that the contribution to the local economy was £2.78 billion.
This cumulative figure is made up of individual valuation information from maritime businesses (£524M), residential property (£2,151M), tourism (£44M), land values (£52M) and recreation (£1.2M). This document is available on Chichester District Council's website: https://www.chichester.gov.uk/media/7890/Valuing-Chichester-Harbour-2009---Part--1/pdf/Valuing_chichester_harbour_part_1.pdf
Noted.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
2.41
Representation ID: 4096
Received: 15/03/2023
Respondent: Chichester Harbour Trust
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The over-reliance of development in the east-west corridor risks delivering unsustainable levels of housing on unwilling communities - particularly between Chichester and Emsworth to the west of the city.
Reduction in the housing allocation, particularly the distribution along the boundary of the Chichester Harbour AONB.
The over-reliance of development in the east-west corridor risks delivering unsustainable levels of housing on unwilling communities - particularly between Chichester and Emsworth to the west of the city. The proposed delivery of 3,225 houses in this area (1,600 west of Chichester, 1,050 Southbourne, 245 Bosham, 300 Chidham & Hambrook, 30 Fishbourne) cannot be reconciled with the objectives of conserving local distinctiveness, character and cohesion of settlements. The infrastructure to support this level of development is simply not in place, and is unlikely to be through the Plan duration (particularly waste water treatment, roads, doctors, schools). The proposed levels of development are disproportionate to the size of the existing settlements, and therefore will be default alter their character immeasurably.
The change proposed does not relate to this paragraph. The suggested change has also been recorded against the relevant policies – S1, H2, H3 and responded to there.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Objective 1: Climate Change
Representation ID: 4099
Received: 15/03/2023
Respondent: Chichester Harbour Trust
We absolutely support this aspiration; however by default the Plan fails to deliver this in any meaningful way. The levels of housing development proposed are incompatible with the aspirations outlined.
We absolutely support this aspiration; however by default the Plan fails to deliver this in any meaningful way. The levels of housing development proposed are incompatible with the aspirations outlined. The south of the district occupies low-lying coastal plain, which is highly vulnerable to coastal change and sea level rise. Ground water levels are high, leading to frequent flooding. Conversely, the region also suffers from water scarcity issues due to climate change. As a matter of course, most new developments in the area are highly car-reliant, as the public transport and cycling infrastructure is not able to provide a viable alternative.
Comment noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Objective 2: Natural Environment
Representation ID: 4105
Received: 15/03/2023
Respondent: Chichester Harbour Trust
We support these ambitions. However in reality it is unlikely that the proposed plan will be able to deliver these aspirations.
We support these ambitions. However in reality it is unlikely that the proposed plan will be able to deliver these aspirations. The volume of housing proposed between Chichester and Emsworth (3,225), especially when combined with Havant Borough Council's strategic site at Southleigh (2,100 homes) will lead to an unprecedented level of development pressure on the AONB, SSSI/SPA designated site at Chichester Harbour. Inevitably the repercussions for waste water treatment (already at full capacity and storm discharging regularly) and additional recreational disturbance will further compound the challenges affecting the protected site, meaning that it is unable to recover from the current "Unfavourable Declining" condition assessment.
Comment noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Objective 7: Strategic Infrastructure
Representation ID: 4107
Received: 15/03/2023
Respondent: Chichester Harbour Trust
We support the reference to the need for waste water service providers to work with regulators to ensure adequate provision for the delivery of the plan. However we fear that in reality the required infrastructure will not be deliverable in the timescale of the Plan delivery which will lead to the continued discharging of untreated effluent into Chichester Harbour and other water bodies, including the Lavant, which flows into the Harbour. This will lead to the continued ecological decline of the harbour and work directly against the ambitions to restore it to favourable condition.
We support the reference to the need for waste water service providers to work with regulators to ensure adequate provision for the delivery of the plan. However we fear that in reality the required infrastructure will not be deliverable in the timescale of the Plan delivery which will lead to the continued discharging of untreated effluent into Chichester Harbour and other water bodies, including the Lavant, which flows into the Harbour. This will lead to the continued ecological decline of the harbour and work directly against the ambitions to restore it to favourable condition.
Support noted
Policy I1 requires infrastructure and its timing to be secured by way of condition or legal requirement. It is those conditions or legal agreements that will set out the detailed phasing and housing triggers.
It would not be practical to prevent all development from being provided until all accompanying infrastructure is completed as that would not be economically viable.
S106 has to meet the requirements set out in Regulation 122 of The Community Infrastructure Levy Regulations 2010 (as amended) meaning that its use is limited to addressing the impacts of its development. CIL is to be used to address the cumulative impacts of new development, and cannot be used to address underlying infrastructure deficits unless these are also required to support the new development.
The intention is that infrastructure providers take responsibility to ensure that the infrastructure it provides is maintained into the future. It is up to the developer to make such arrangements to ensure this happens. This often happens by the developer after the first year or so setting up a management company, whereby the residents pay a management fee to maintain the up-keep of communal facilities.
As much information as the Council has at present is included within the Infrastructure Delivery Plan which accompanies this Local Plan.
Critical infrastructure would have to be delivered in advance, but all other infrastructure would be delivered in tandem with development, particularly that infrastructure to be delivered through S106 linked to triggers in the S106 agreement.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy S1 Spatial Development Strategy
Representation ID: 4108
Received: 15/03/2023
Respondent: Chichester Harbour Trust
Legally compliant? No
Sound? No
Duty to co-operate? No
The Plan promotes an over-reliance on developing the east-west corridor, with unsustainable levels of development between Chichester and Havant. Combined with the Havant Borough strategic site at Southleigh (2,100 homes) this leads to a delivery of 5,300 new houses in the narrow corridor between Chichester Harbour AONB/SSSI and the South Downs National Park. The ecological and landscape implications of this over-development are huge; both for biodiversity and for local communities.
A significant reduction in the housing allocation in the east-west corridor is required.
The Plan promotes an over-reliance on developing the east-west corridor, with unsustainable levels of development between Chichester and Havant. Combined with the Havant Borough strategic site at Southleigh (2,100 homes) this leads to a delivery of 5,300 new houses in the narrow corridor between Chichester Harbour AONB/SSSI and the South Downs National Park. The ecological and landscape implications of this over-development are huge; both for biodiversity and for local communities. Just some of the impacts include inadequate waste water infrastructure; lack of transport infrastructure; inadequate community facilities including schools and doctors services. Potential ramnifications are increased congestion, light and noise pollution; waste water discharges; recreational disturbance, to name just a few.
The additional burden of this increased population will further compound and render irreversible the ecological decline of Chichester Harbour SSSI.
As a general comment, the plan in this area is overly reliant on the delivery of green-field sites, raising important concerns over sustainability; agricultural production, food security, groundwater and surface water drainage and flooding.
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 more detail in the Sustainability Appraisal and Housing Distribution Background Paper.
Development of the strategic allocations will be subject to the requirements of the Local Plan natural environment policies, particularly Policy NE2 (Natural Landscape), NE5 (Biodiversity) and NE13 (Chichester Harbour AONB) and the site specific requirements set out in the strategic allocation policies.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
4.8
Representation ID: 4110
Received: 15/03/2023
Respondent: Chichester Harbour Trust
We welcome the ambitions of this statement. However we note that it does seem directly at odds with the delivery of 3,225 houses on greenfield sites in the east-west corridor.
We welcome the ambitions of this statement. However we note that it does seem directly at odds with the delivery of 3,225 houses on greenfield sites in the east-west corridor.
Support and comment noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
4.9
Representation ID: 4111
Received: 15/03/2023
Respondent: Chichester Harbour Trust
We welcome the inclusion of this paragraph. However it is important to recognise that it is not only development control within the AONB itself but the landscape context and over-development around the boundary of the AONB that cumulatively leads to threats to the integrity of the AONB landscape, setting and ecological condition. The development of 3,225 additional properties in close proximity to the AONB will have indirect impacts in terms of water quality and recreational pressure particularly.
We welcome the inclusion of this paragraph. However it is important to recognise that it is not only development control within the AONB itself but the landscape context and over-development around the boundary of the AONB that cumulatively leads to threats to the integrity of the AONB landscape, setting and ecological condition. The development of 3,225 additional properties in close proximity to the AONB will have indirect impacts in terms of water quality and recreational pressure particularly.
Support and comment noted
