Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5664

Received: 17/03/2023

Respondent: Countryside Properties

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is unclear if PV, EV and ASHP’s are defined as ‘service’ equipment. These elements are often difficult to be fully integrated all of the time, and would make this element of the policy ineffective for the duration of the plan period. We would suggest this is defined in a footnote for avoidance of doubt.

Objection and proposed change noted. It is considered that bullet g) is sufficiently flexible and clear as it does not require full integration (location in visually inconspicuous locations is presented as an alternative).

Object

Representation ID: 5665

Received: 17/03/2023

Respondent: Countryside Properties

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Criteria 9 and 11 are considered overly prescriptive and insufficiently flexible to effectively address site specific circumstances.
Penultimate paragraph sufficiently ambiguous to compromise effectiveness of policy as may be justifiable reasons why alternative materials may have to be sought on approved schemes to address particular site-specific factors.

Objection and comments noted. In relation to points 9 and 11, it is considered that the policy wording achieves the appropriate balance in terms of discouraging the use of less appropriate materials but not preventing their use outright. The reference to value engineering is considered to be very important as it is a significant problem within the planning system for schemes to be consented on the basis of a certain standard of design and materials, and for this to then be diluted through the details and compliance process or subsequent applications. This issue is also highlighted in paragraph 140 of the NPPF.

Object

Representation ID: 5667

Received: 17/03/2023

Respondent: Countryside Properties

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The wording ‘and beyond the site boundaries’ in Criterion 2 is sufficiently ambiguous to compromise its effectiveness. Could imply a requirement to meet needs beyond that required to satisfy the statutory tests in regulation 122 (as amended by the 2011 and 2019 Regulations) and policy tests in the National Planning Policy Framework.

Objection and proposed change noted. A fundamental characteristic and importance of Green Infrastructure is the broad social, economic and environmental benefits it brings, which by nature extend beyond the boundaries of an individual development site to the wider community. We will, however, consider a modification to the policy to recognise that the expectations on development to create new GI must be proportionate.

Object

Representation ID: 5669

Received: 17/03/2023

Respondent: Countryside Properties

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Re; criterion 1 - no development threshold requirement listed in Table 6.1 for indoor facilities.

Objection noted.

It is agreed to add to Table 6.1 a threshold requirement for the provision of on-site community and sports halls and to add a table note to clarify that such provision will depend on local circumstance.

Object

Representation ID: 5671

Received: 17/03/2023

Respondent: Countryside Properties

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Use of term ‘reducing’ in first bullet point implies that this is from a baseline. Where a development has been designed in a way that achieves this objective, the promotion of sustainable modes of transport is inherent as an outcome.

i) The suggested change is appropriate and would improve the sense of the first objective.
ii) The suggested change is appropriate and would improve the sense of the first objective.

Object

Representation ID: 5676

Received: 17/03/2023

Respondent: Countryside Properties

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

(1)(i) should be expressed as preference of council, not binary requirement -may be subject to design considerations on site-by-site basis. Term ‘accessing’ is ambiguous, could refer to other modes of transport. Point 2. mentions adoption of a specific threshold of impact which is not defined for either Transport Statements or Assessments. Further clarification required. In 3. Should also be recognised that monitoring would offer an opportunity for Travel Plan targets to be reviewed regularly to ensure they remain relevant or can respond to exogenous factors/external influences. Conditions at time of production of Travel Plan may change in the future.

i) The suggested replacement would impose a higher bar compared to the proposed term ‘reduce’ and it is considered that not all development across the plan area would be able to ‘minimise’ the need to travel by car, but all can play a role in reducing this.
ii) The suggestion is accepted to assist clarity.
iii) The suggestion is accepted to ensure that the policy is flexible.
iv) The suggestion is accepted to ensure that the policy is effective.

Object

Representation ID: 5680

Received: 17/03/2023

Respondent: Countryside Properties

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Sub-point (iv) can only require ‘future-proofing’ to be secured through the application of reasonable allowances, rather than be treated as an absolute term, and hence is ineffective in its current form.
In Sub-point (v), if the intention is to ensure that appropriate fixed commuted sums are identified to cover a period of maintenance for infrastructure, this should be stated.

Objection noted.

Suggestion to reword (iv) will be taken on board.

(v) the suggestion is not to collect commuted sums for the council to maintain infrastructure that it does not own. 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 infrastructure providers 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.

No change will be made to (vii) as this will weaken the policy and make it ineffective.

Support

Representation ID: 6094

Received: 17/03/2023

Respondent: Countryside Properties

Agent: Turley

Support in principle.

Support in principle noted

Support

Representation ID: 6096

Received: 17/03/2023

Respondent: Countryside Properties

Agent: Turley

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.

Support noted