Chichester Local Plan 2021 - 2039: Proposed Submission

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Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H4 Affordable Housing

Representation ID: 4182

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Why is there a more generous % of affordable homes in the North of the District than the South? Housing in the South is very expensive and dominated by high value larger properties.
This is clearly an inadequate number of social and affordable rented properties that will not meet the need of 200pa as identified in the HEDNA 2022.
Of the annual figure of 535, 160 homes will be affordable. Of that 91 will be for social and affordable rent. This is less than half the number required. This policy will only serve to increase the gap between market housing and affordable and will result in fewer people being able to afford a home.

Change suggested by respondent:

The tenure mix changed to allow for 200 affordable and social rented homes pa.

Full text:

Why is there a more generous % of affordable homes in the North of the District than the South? Housing in the South is very expensive and dominated by high value larger properties.
This is clearly an inadequate number of social and affordable rented properties that will not meet the need of 200pa as identified in the HEDNA 2022.
Of the annual figure of 535, 160 homes will be affordable. Of that 91 will be for social and affordable rent. This is less than half the number required. This policy will only serve to increase the gap between market housing and affordable and will result in fewer people being able to afford a home.


Our response:

The HEDNA clearly states that the highest house prices are in the north of the plan area (para 2.2 and 2.23). When this is combined with the lower financial contributions with respect to infrastructure, it means that there is a more favourable viability position, meaning that a higher affordable housing threshold can be achieved in that area.
The Council is certainly seeking to maximise the delivery of social and affordable rented accommodation. However, this is hampered by the significant constraints which are faced in terms of viability and delivery. Consequently, while this is clearly a very difficult situation, and the Council would obviously prefer to increase the level of social and afforded rented accommodation, this is not considered to be achievable in reality

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

5.17

Representation ID: 4183

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

This cannot be achieved through the mix of housing as set out in H4. Less than half of this identified need will be met. The Council should be aspiring to meet this need to enable people to afford homes. The vision as described will not be reached unless it is.

Change suggested by respondent:

Change the tenure mix so the identified need is met.

Full text:

This cannot be achieved through the mix of housing as set out in H4. Less than half of this identified need will be met. The Council should be aspiring to meet this need to enable people to afford homes. The vision as described will not be reached unless it is.


Our response:

The Council is seeking to maximise the delivery of affordable forms of rented housing, however, significant viability constraints limit what can be achieved in practice. Moreover, national policy also requires the provision of other forms of affordable housing such as First Homes. Furthermore, focusing solely on social and affordable rented accommodated would have significant viability implications and could actually reduce the total amount of affordable housing delivered

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

5.10

Representation ID: 4184

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Housing developments of any size should be counted against parish allocations. There is no justification for not doing so.

Change suggested by respondent:

Include all size of developments against the housing allocation number.

Full text:

Housing developments of any size should be counted against parish allocations. There is no justification for not doing so.


Our response:

Any size sites can be allocated but these would still be in addition to any windfall sites (that are under 5 dwellings) that may come forward (to avoid double counting).

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H2 Strategic Locations/ Allocations 2021 - 2039

Representation ID: 4185

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

The housing numbers are too high. 2000 houses are planned from Fishbourne to Southbourne along one transport route. This is not sustainable and will result in coalescence, suburbanisation, traffic congestion, decrease in air quality, substantial impacts on landscape, green infrastructure, the AONB and the environment.

Change suggested by respondent:

Reduce the housing allocation number.

Full text:

The housing numbers are too high. 2000 houses are planned from Fishbourne to Southbourne along one transport route. This is not sustainable and will result in coalescence, suburbanisation, traffic congestion, decrease in air quality, substantial impacts on landscape, the AONB and the environment.


Our response:

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 the more detail within 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.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H1 Meeting Housing Needs

Representation ID: 4186

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

If the recommendations within the policies are to be adhered to the 10,300 number is not viable or deliverable The danger, therefore, is that these recommendations will be superseded by ‘exceptional circumstances’ and the policies will be overridden. 87% of the housing is in the East/West corridor which will impact on Chichester Harbour AONB, already in decline.

Change suggested by respondent:

Reduce the housing numbers.

Full text:

If the recommendations within the policies are to be adhered to the 10,300 number is not viable or deliverable The danger, therefore, is that these recommendations will be superseded by ‘exceptional circumstances’ and the policies will be overridden. 87% of the housing is in the East/West corridor which will impact on Chichester Harbour AONB, already in decline.


Our response:

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 the more detail within 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.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

5.2

Representation ID: 4187

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Given the significant constraints on the plan area and the fact that the standard methodology need no longer apply when there are exceptional circumstances we feel this number is too high. It represents a reduction of only 100 houses a year. The number should be reduced to a figure reflecting the fact that only 30% of the plan area is developable. It is not possible to squeeze that amount of housing into this area without considerable detrimental impact on local residents and our environment.

Change suggested by respondent:

Reduce the housing number from 10,350 and plead exceptional circumstances for Chichester District and its residents.

Full text:

Given the significant constraints on the plan area and the fact that the standard methodology need no longer apply when there are exceptional circumstances we feel this number is too high. It represents a reduction of only 100 houses a year. The number should be reduced to a figure reflecting the fact that only 30% of the plan area is developable. It is not possible to squeeze that amount of housing into this area without considerable detrimental impact on local residents and our environment.


Our response:

The Council is not meeting the standard methodology figure (see Housing Need Background Paper for further detail)
The Local Plan housing requirement of 535 (south of the plan area) is a constrained annual requirement figure, based on the constraint of the A27. Other constraints are taken into account when developing the spatial strategy to meet the requirement and through the Sustainability Appraisal (SA) and Habitats Regulations Assessment (HRA). This issue is also covered in more detail in the Housing Need, Housing Distribution and Transport Background Papers.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.107

Representation ID: 4188

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Southern Water are preparing a Drainage and Wastewater Management Plan which will not be complete until sometime in 2023. There is at present no certainty of a deliverable solution for the Thornham catchment and any solution will take time and substantial investment to deliver. For this reason, there should be additional restrictions in this catchment as there are for Apuldram. This should be stated here.

Change suggested by respondent:

.Refer to additional restrictions in the Thornham catchment .

Full text:

Southern Water are preparing a Drainage and Wastewater Management Plan which will not be complete until sometime in 2023. There is at present no certainty of a deliverable solution for the Thornham catchment and any solution will take time and substantial investment to deliver. For this reason, there should be additional restrictions in this catchment as there are for Apuldram. This should be stated here.


Our response:

This para refers to the Position Statement for Thornham which sets out when restrictions will be needed.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.98

Representation ID: 4189

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

We understand that supply of water across the whole of the south of England is now reaching critical levels As the EA have identified the plan area as being under serious water stress, this should be the very reason not to build 10,350 homes. The long-term impact would be very severe, particularly in prolonged periods of high temperatures and minimal rainfall. Relying on a reduction of water use of 15l per person is not enough to allay serious consequences. A much broader water strategy across the whole of the south of England is urgently required.

Change suggested by respondent:

Reduce the housing number to a level where water supply is not at risk

Full text:

We understand that supply of water across the whole of the south of England is now reaching critical levels As the EA have identified the plan area as being under serious water stress, this should be the very reason not to build 10,350 homes. The long-term impact would be very severe, particularly in prolonged periods of high temperatures and minimal rainfall. Relying on a reduction of water use of 15l per person is not enough to allay serious consequences. A much broader water strategy across the whole of the south of England is urgently required.


Our response:

Policy NE16 requires sufficient water supply prior to occupation.

The suggested change is not a change to this paragraph. The suggested change has also been recorded against policy H1 and responded to there.

Support

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE4 Strategic Wildlife Corridors

Representation ID: 4190

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Representation Summary:

We wholeheartedly support this but wildlife corridors MUST be adhered to and protected. ANY development would have an adverse effect and undermine connectivity and the ecological value of the corridor. We cannot support any significant development.

Full text:

We wholeheartedly support this but wildlife corridors MUST be adhered to and protected. ANY development would have an adverse effect and undermine connectivity and the ecological value of the corridor. We cannot support any significant development.


Our response:

Support noted

Support

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE3 Landscape Gaps between settlements

Representation ID: 4191

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Representation Summary:

The Landscape Gap Assessment should be routinely referred to when considering planning applications. Gaps need to be defined and protected.

Full text:

The Landscape Gap Assessment should be routinely referred to when considering planning applications. Gaps need to be defined and protected.


Our response:

Comments noted.
Landscape gaps, will be designated as part of a subsequent Site Allocations DPD or through relevant neighbourhood plans.

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