Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5145

Received: 16/03/2023

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst the Council have set out their activities with regard to the duty to co-operate within the compliance statement this document also notes that a none of the required Statements of Common Ground have been agreed, with many are still being drafted. Given that paragraph 26 of the NPPF expects these to be in place throughout the plan making process it is concerning that these are not available for this consultation providing clarity between Chichester District Council (CDC) and relevant parties as to the key issues and the co-operation that has taken place to address these issues.

What is disappointing is that whilst the West Sussex authorities have established mechanism for joint working through the West Sussex and Greater Brighton Planning Board no progress has been made in actually addressing the unmet needs of this area. The Local Strategic Statement (LSS) includes an objective of meeting housing needs for a growing population, yet little has been achieved with the Council suggesting that these matters will be considered in next LSS for 2030 to 2050. The HBF recognises that the area is constrained by the national park and its coastal location but seemingly nothing has been achieved in seeking to move forward. As such we would question whether the mechanisms established in this area have maximised the effectiveness of the preparation of this local plan in addressing the issue of unmet housing needs. The expectation is that cross boundary issues are not pushed forward to future plans or plan reviews, yet this is clearly what is being done in the West Sussex and Greater Brighton area.

Object

Representation ID: 5146

Received: 16/03/2023

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is unsound as not consistent with transition requirements being proposed. The Government’s response to the consultation on the regulations for and implementation of BNG outlines that implementation of BNG on small sites will be extended to April 2024.

Object

Representation ID: 5147

Received: 16/03/2023

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is unsound as it is not justified or consistent with national policy.

It would appear from the Council’s evidence that there may be highway capacity to meet housing needs in full. Without further evidence to support the position put forward in policy H1 the Council will need to allocate additional sites to ensure that housing needs are met in full, and the plan is sound. The Council will also need to review their approach to sites in the AONB to ensure that proper consideration is given to these sites and provide evidence as to whether or not they will ensure at least 10% of all homes will come forward on small sites.

Object

Representation ID: 5148

Received: 16/03/2023

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Object on grounds that: Council has not presented evidence on how HEDNA identified need will be met from windfall development; Council should examine whether there are opportunities to meet demand for self-build plots through the disposal of its own sites or by working with landowners to bring forward specific sites that will be able to provide plots; Council to recognise within policy that it is not always feasible for large sites deliver self-build plots - development of single plots by individuals operating on sites poses both practical and health & safety concerns, plots could be left empty or unfinished detrimental to other homeowners on site; whilst some sites may be able to locate self-build plots to reduce risks, on others it will not be possible.

Object

Representation ID: 5149

Received: 16/03/2023

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is unsound as it is not effective. Only through site allocations can the Council be certain the needs of older people be met. Important that policy provides: effective mechanism through which decisions on accommodation can be made on basis of need for and supply of such development; sets out how many specialist homes for older people are required in Chichester; commitment is made to monitoring supply against level of need across plan period; presumption in favour of development be applied if supply of land for such development falls below identified annual needs. Needs to be clear as to what is required and how a decision maker should react to ensure those needs are met. By including level of need in policy or supporting text, greater weight will be given to this in decision making, leading to the more positive approach that is required to meet housing the needs of older people.

Object

Representation ID: 5150

Received: 16/03/2023

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy should be amended to reflect changes to Building Regulations

19. Last year the Government 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.

Object

Representation ID: 5151

Received: 16/03/2023

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Part A requires proposals apply sound suitable design including the use of materials that reduce embodied carbon and make use of re-used or recycled materials. The HBF recognises the importance of reducing the embodied carbon in new homes but the extent to which such materials can be used will vary from development to development. As such we would suggest that the policy is amended to read “… including, where possible, the use of materials …”

Object

Representation ID: 5152

Received: 16/03/2023

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is unsound as it has not been justified.

21. This policy will require all new residential development to meet the nationally described space standards. As the Council will be aware in order to adopt these standards the Council must show that there is a need for such homes within the District, but we could not find the evidence referred to in paragraph 11.105 of the Local Plan. If the Council cannot provide sufficient evidence to support the adoption of these standards, then this policy should be deleted.

Object

Representation ID: 5153

Received: 16/03/2023

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Lack of clarity within supporting text and policy with regard to what is required in terms of indoor sports facilities. Table 6.4 does not provide any reference to development thresholds nor hectares per 1,000 population. The requirements appear to be general standards for all communities rather than relating to specific development. Unclear to a decision maker or applicant as to what is required in terms of built sport and recreation facilities. Provision of on-site built sport and recreation facilities will only be relevant in very few circumstances with improvements in provision largely being provided by the Council using the Community Infrastructure Levy or other financial contributions.

Object

Representation ID: 5154

Received: 16/03/2023

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Part (iii) of the policy is unsound as it is inconsistent with national policy and is unjustified.

The policy requires all residential development to ensure new development benefits from gigabit-capable broadband infrastructure at first occupation. However, the delivery of super-fast broadband connections is often not in the gift of the developer. The HBF agrees that such infrastructure is important, however, its provision is not essential and should not be considered a barrier to the occupation of new homes as indicated in this policy. Whilst the HBF supports the Council’s desire for such infrastructure it is their responsibility to work with the infrastructure provider to ensure its delivery and enable developments to be connected. Given that the type of connection required of development is also set out in Part R of the Building Regulations we consider it unnecessary to set this out in local plan policy. Paragraph relating to Fibre to the Premises should therefore be deleted.