Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5683

Received: 17/03/2023

Respondent: Barratt David Wilson Homes

Agent: Henry Adams LLP

Legally compliant? Not specified

Sound? Yes

Duty to co-operate? Not specified

Supports the principle of the allocation, but requests further consideration of the following requirements:

- older persons accommodation
- allocation of gypsy and traveller pitches

[see attached representation for further information]

Objection noted.

The Council has an identified need for housing for older people (as set out in the Housing and Economic Development Needs Assessment 2022). Strategic sites of over 200 dwellings are required to provide accommodation for older people. Discussions can be held with the relevant Council departments regarding provision.

As set out in the Gypsy and Traveller and Travelling Showpeople Background Paper, the Council have explored a number of options for pitch delivery. This has included a ‘Call for Sites’ and an assessment of the potential for intensification on existing Gypsy and Traveller sites but the likely provision arising from these sources does not meet the assessed level of pitch need, requiring provision to be made on the proposed strategic housing sites. The Planning Policy for Traveller Sites indicates that pitches should be well integrated into the local community thereby providing good access to essential services. The good practice guidance for designing Gypsy and Traveller sites (2008), although withdrawn still provides useful guidance for the design of Gypsy and Traveller sites, stated that where possible sites should be developed near to the settled community as part of mainstream residential developments.

Object

Representation ID: 5684

Received: 17/03/2023

Respondent: Barratt David Wilson Homes

Agent: Henry Adams LLP

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

BDW object to the Strategic Wildlife Corridor (SWC) locations for the following reasons:
- The Council has not published its evidence base in the Reg 19 consultation for applying this new constraint layer;
- The current use of the corridors is not stated, no considered sustainability of future development potential;
- Blanket policy designations are not required
- Locations adjacent to existing settlements appear unjustified and inappropriate in current form.

[see attached representation for further information]

Comment noted. A background paper and corresponding appendices containing evidence and the methodology for identifying habitat will be available upon submission of the Plan.
The Council has undertaken three separate rounds of consultation on the strategic wildlife corridors, as proposed in their various forms, since 2018. Landowners who had submitted sites to the Council for the HELAA were targeted through a technical consultation in 2021.
It is acknowledged that the District (and Plan area) is highly constrained; this has concentrated development pressures in the least constrained areas, including the east-west corridor, and has increased the need for wildlife corridors to be established in order to protect those routes of highest quality habitat for protected species.

Object

Representation ID: 5685

Received: 17/03/2023

Respondent: Barratt David Wilson Homes

Agent: Henry Adams LLP

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Wording of criteria 7. (use of permeable materials) is inconsistent with the drainage hierarchy as set out in national Planning Practice Guidance (PPG). Accordingly the policy is unreasonably restrictive.
[see attached representation for further information]

Objection and comment noted. We recognise that bullet 7 has the potential to be narrowly interpreted as inconsistent with PPG and will therefore consider a minor amendment to remove this reference to permeable materials and drainage matters more comprehensively addressed within Policy NE15

Object

Representation ID: 5751

Received: 17/03/2023

Respondent: Barratt David Wilson Homes

Agent: Henry Adams LLP

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The wording of criterion 7 is inconsistent with the drainage hierarchy set out in national Planning Practice Guidance (PPG) paragraph 056. Policy is unreasonably restrictive and fails to recognise the guidance which allows for a hierarchy of options for the management of surface water drainage. The reason being is that it will not be possible to achieve infiltration drainage solutions on all sites, which Policy P5 would currently require. It is recommended that this be addressed with an amendment to follow the recommendations of the PPG.

As above.

Object

Representation ID: 5752

Received: 17/03/2023

Respondent: Barratt David Wilson Homes

Agent: Henry Adams LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Consider Plan area capable of accommodating greater housing quantum. Council have failed to provide sufficient justification for not meeting its housing need in full and have not suitably considered unmet need from adjoining authorities. Evidence base (Transport Study 2023) contradicts Council's position. Council should consider allocation of additional housing sites to meet full or higher housing provision within plan area. Land at Stubcroft Farm, East Wittering promoted.

The justification for not meeting the housing needs in full is set out in the Housing Need and Transport Background Papers (May 2024). The latest Duty to Cooperate evidence is set out in the updated Statement of Compliance.
Promotion of alternative site noted.

Object

Representation ID: 5753

Received: 17/03/2023

Respondent: Barratt David Wilson Homes

Agent: Henry Adams LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Object on grounds that evidence base in Reg 19 consultation not published; current use of Corridors not stated - could have sustainable future development potential; blanket policy designation not required, built environment and nature can work in unison; those affected by SWC and other stakeholders not consulted; District already highly constrained.

This rep appears to be a duplication of 5684 (see row above). The above response remains relevant

Object

Representation ID: 5754

Received: 17/03/2023

Respondent: Barratt David Wilson Homes

Agent: Henry Adams LLP

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy sets out support for new employment development and sets out criteria for expansion of existing employment sites and for new sites. Policy sets out that new provision will be allowed for in existing settlements but it is silent in relation to new build development outside of settlement boundary.

Development outside of settlement boundaries follows the Council’s spatial strategy with new employment development to be distributed in line with the settlement hierarchy. Policy S2 Settlement Hierarchy provides that development outside of the settlement boundaries must be in accordance with policy NE10 Development in the Countryside.

Object

Representation ID: 5755

Received: 17/03/2023

Respondent: Barratt David Wilson Homes

Agent: Henry Adams LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Paragraphs 2.43 – 2.45 of the draft Plan set out the reasoning, which relates to the need to protect the semi-rural nature of ‘some’ settlements and in recognition of the important wildlife habitats such as Pagham Harbour and Medmerry. These highlighted areas are subject to international wildlife designations and are very different to say our clients land at Stubcroft Farm, which has
no heightened landscape or wildlife designations. On the contrary, land at Stubcroft Farm comprises relatively ordinary open arable land, which is intensively farmed. It is not extraordinary in any form and a blanket approach suggested by the Council, highlighting landscapes or habitats of national or international importance is not reflective of the entirety of the Manhood Peninsula.
This should not be taken as a reason for not allowing further development, which is suitably located, on the Manhood Peninsula.

Comments noted. There is not a blanket approach to development. Para 3.20 of the Publication Plan sets out why no strategic allocations are proposed on the Manhood Peninsula. Add reference to additional constraints for clarity.

Object

Representation ID: 5756

Received: 17/03/2023

Respondent: Barratt David Wilson Homes

Agent: Henry Adams LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Object to policy requirement for schemes exceeding 200 homes on grounds that proposed allocations would not accommodate overall need; no clear quantifiable policy requirement to deliver need; plots available in other areas that have not been taken up for allocation (HBI0028); absence of information regarding requirements for pitch provision and site specific needs; no evidence on engagement with gypsy traveller community regarding desire to be located on suburban residential sites (contradicts typical locations on rural sites/periphery of rural settlements); specific access for larger HGVs for static homes and touring caravans makes it difficult to design suitable access within residential housing estate - no consideration given to how this can be accommodated.

The gypsy and traveller site design guidance from 2008 encourages provision as part of mainstream residential development. The reasons for not allocating the Pinks Four are clearly explained in the background paper. In terms the reference to large vehicles, it is not clear why the respondent thinks pitches will be utilising large vehicles, and in any case all residential development has to be designed to accommodate large vehicles such as refuse vehicles. Also, if that argument is valid then presumably this policy requirement would always be rejected, but it clearly hasn’t as there are numerous examples now of this approach being found sound.

Object

Representation ID: 5757

Received: 17/03/2023

Respondent: Barratt David Wilson Homes

Agent: Henry Adams LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Policy sets out onerous restriction on water use per person per household per day. Potentially achievable, however, it is restrictive and not attractive to future residents. Accordingly, its introduction without flexibility, may limit desirability of future properties. Policy should therefore allow housebuilder flexibility to allow high water usage, set against greater off-site water saving measures. Knock on effect could be an increase in housing values for existing stock not subject to restrictive water use. Also consider there to be a need for a strategic mitigation to be provided alongside the Plan. At present, there is no evidence of this being prepared.

Comments noted

A joint LPA offsetting mitigation scheme is being developed (SNOWS) to sit alongside local plans of affected authorities.