Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
5.3
Representation ID: 5642
Received: 17/03/2023
Respondent: Countryside Properties
Agent: Turley
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Lack of reference to latest transport study conclusions in CDC Duty to Cooperate Statement of Compliance, and how this was accounted for in duty to cooperate discussions with adjoining LPAs; along with a lack of progress with adjoining LPAs SoCG, makes it difficult in the interim to conclude whether Council’s legal duty has been met. Would respectfully wish to reserve the right to comment further on this once such evidence is available.
See attachment.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE5 Biodiversity and Biodiversity Net Gain
Representation ID: 5643
Received: 17/03/2023
Respondent: Countryside Properties
Agent: Turley
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Whilst support overall objective of policy, first paragraph is insufficiently flexible to discharge the remaining criteria of policy. For example, in instances where ‘protection’ or ‘adverse impact’ cannot be avoided, but can be reduced in accordance with the mitigation hierarchy, and / or the benefits clearly outweigh the likely impact. Wording of first paragraph neither ‘justified’ nor likely to be ‘effective’ in its current form. It is assumed reading the remainder of the policy that this may be an unintended consequence. Second paragraph also duplicates provisions in remaining criteria of policy.
Delete introductory paragraph including A to H.
Remaining policy text addresses elements omitted and is therefore sufficient to deliver policy objectives in their own right.
See attachment.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE15 Flood Risk and Water Management
Representation ID: 5644
Received: 17/03/2023
Respondent: Countryside Properties
Agent: Turley
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The wording ‘exceed the normal design standards’ in first criterion of policy is somewhat ambiguous, and as a consequence is unlikely to be ‘effective’ in its application. Requirement in criterion 2 that, ‘There is no increase in either the volume or rate of surface water run-off leaving the site’ is also unlikely to be justified on all sites, particularly where ground conditions do not permit infiltration.
Would suggest first criterion is revised to define ‘normal design standards’ Council will expect to see as a minimum when determining planning applications, either in words, or by reference to specific guidance outlined in remainder of policy.
Would recommend first sentence of criterion 2 be amended to: ‘There is no increase in the rate of surface water run-off leaving the site’.
See attachment.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE23 Noise
Representation ID: 5652
Received: 17/03/2023
Respondent: Countryside Properties
Agent: Turley
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The words ‘an absence of significant noise disturbance or annoyance’ in criterion 1 are sufficiently ambiguous to compromise effectiveness of policy. Similarly, in criterion 2 the wording ‘by reason of noise disturbance and annoyance on the surrounding area or environment,’ is sufficiently ambiguous to compromise effectiveness of policy.
Suggest wording that aligns better to NPPG4:
‘…by seeking to ensure noise exposure likely to give rise to significant adverse effects on health and quality of life is avoided….’
We would suggest criterion 2 be reworded to be more specific to the noise sensitive uses and users this criterion is aimed toward.
See attachment.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H1 Meeting Housing Needs
Representation ID: 5654
Received: 17/03/2023
Respondent: Countryside Properties
Agent: Turley
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The SA asserts it would be unreasonable to test growth scenarios above LHN figure of 638dpa. However, if transport study conclusions are correct, this may not prove to be the case. As a consequence, these matters may need to be revisited through an update or addendum to the SA to ensure the SA process is found to be legally compliant, with further revisions and consultation on Policy H1 as necessary to ensure it meets the ‘positively prepared’ and ‘justified’ tests of soundness. This should be progressed prior to formal submission of Local Plan, with outcomes and actions (including any necessary revisions to the Local Plan) discussed with adjoining LPAs as part of Council’s legal Duty to Cooperate on strategic matters.
See attachment.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A14 Land West of Tangmere
Representation ID: 5655
Received: 17/03/2023
Respondent: Countryside Properties
Agent: Turley
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Support re-allocation under policy A14. Confirm site remains suitable for mixed-use, no known overriding constraints to delivery. Further evidence in support can be found under 20/02893/OUT. Criterion 2 - would welcome agreement over specific type/amount of accommodation required. Would welcome confirmation that specialist needs required will be limited to C3. Criterion 3 - wording ‘transforming the existing village centre into a new local centre’ does not take into account outcome of engagement, consultation, and outline permission. Recommend cross checks undertaken prior to formal submission to ensure black line extent of site on Map 10.8 aligns with that progressing towards grant of permission.
Recommend criterion 2 is amended to:
‘A range of types, sizes and tenures of residential accommodation to include specific provision to meet specialised housing needs within Use Class C3, including accommodation for older people;’
Suggest criterion 3 is revised to ‘expanding and enhancing the existing local centre’.
Suggest reference in criterion 10 to conserving or enhancing the WWII airfield should be deleted. In addition, reference to relocation of allotment space is addressed in criterion 5, so could be deleted at 10 to avoid duplication.
See attachment.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H5 Housing Mix
Representation ID: 5656
Received: 17/03/2023
Respondent: Countryside Properties
Agent: Turley
Support inclusion of criterion 3. In addition to evidenced local need, may be other site-specific factors that justify need to provide a different mix of housing for a particular site. This could include for example, viability considerations.
Suggest following revision to criterion 3:
‘robust evidence demonstrates that a different mix of dwellings is justified to address particular site-specific factors, or to meet local needs and demand for specific types, tenures and sizes of housing to contribute to the diversity of housing in the local area and help to redress any housing imbalance that exists;'
See attachment.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H8 Specialist accommodation for older people and those with specialised needs
Representation ID: 5658
Received: 17/03/2023
Respondent: Countryside Properties
Agent: Turley
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
To be consistent with the approach outlined in the first paragraph of Policy H6/H8, it is suggested requirements are set out and justified in relevant site-specific allocation policies. Any specific requirements for non-allocated sites should also be clarified, with appropriate flexibility built in to ensure this can account for specific site circumstances.
Suggest first paragraph be amended to:
‘All New housing sites over 200 units, which are allocated in the Local Plan, will provide specialist accommodation for older people as set out in the relevant site-specific allocation policies. The specific type and amount of accommodation required will depend on the size and location of the site.’
See attachment.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H10 Accessible and Adaptable Homes
Representation ID: 5660
Received: 17/03/2023
Respondent: Countryside Properties
Agent: Turley
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
We note the Government has published its response to the consultation on the building regulations governing accessibility - Part M . This response states that the Government will make part M4(2) the mandatory standard. Whilst this is still to be introduced, given the likelihood that the Government will make M4(2) the mandatory standard we would recommend that the Council amend its policy accordingly to ensure no unnecessary repetition of building regulations within planning policy.
See attachment.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy P1 Design Principles
Representation ID: 5663
Received: 17/03/2023
Respondent: Countryside Properties
Agent: Turley
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Part A - extent to which such materials can be applied is likely to vary on a site by site basis.
Part B - inclusion of elements listed are unlikely to be appropriate for all developments and site circumstances, particularly elements such as green and blue roofs and green walls. Policy as worded, unlikely to be effective over plan period.
Suggest Part A is amended to read ‘….including, where possible, the use of materials …’
Would suggest the following revision to Part B: ‘The proposals include measures to adapt to climate change, such as the provision where possible of green infrastructure, sustainable urban drainage systems (SuDS), suitable shading of pedestrian routes and open spaces, a mixture of drought and rain tolerant native planting and the incorporation of green or blue roofs or green walls;'
See attachment.
