Chichester Local Plan 2021 - 2039: Proposed Submission

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Object

Chichester Local Plan 2021 - 2039: Proposed Submission

6.29

Representation ID: 4213

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Definition of amenity is required.

Change suggested by respondent:

Definition of amenity is required.

Full text:

Definition of amenity is required.


Our response:

Objection and proposed change noted. Definitions for amenity and amenity space are provided within Appendix J: Glossary

Support

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy P2 Local Character and Distinctiveness

Representation ID: 4214

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Representation Summary:

Point 7 and 8 are critical and we have seem many examples of this being flouted by developers. Much tighter control during the construction phase is essential.

Full text:

Point 7 and 8 are critical and we have seem many examples of this being flouted by developers. Much tighter control during the construction phase is essential.


Our response:

Support and comments noted

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.10

Representation ID: 4215

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Situations like this should be considered as a separate issue. We would advocate that any planning application which will trigger such coalensence is refused. Particularly relevant if a gap is preserved between Southbourne Parish and Hambrook Parish this will automatically provide much better protection for the wioldlife corridor and the unique Hambrook chalk stream.

Change suggested by respondent:

.

Full text:

Situations like this should be considered as a separate issue. We would advocate that any planning application which will trigger such coalensence is refused. Particularly relevant if a gap is preserved between Southbourne Parish and Hambrook Parish this will automatically provide much better protection for the wioldlife corridor and the unique Hambrook chalk stream.


Our response:

Comments noted. The detailed location and boundaries of landscape gaps will be considered and assessed through either the subsequent Site Allocations DPD that will follow on from the Local Plan or be undertaken as part of a relevant neighbourhood plan.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

3.24

Representation ID: 4216

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

There should be an equal commitment to conserving the special character of those sites close to Chichester Harbour. The area between the SDNP and AONB is very special and needs conserving too. Not to do so is contrary to Climate Change and Environment policies.

Full text:

There should be an equal commitment to conserving the special character of those sites close to Chichester Harbour. The area between the SDNP and AONB is very special and needs conserving too. Not to do so is contrary to Climate Change and Environment policies.


Our response:

The special character of the area is recognised in the Local Plan. Development will be subject to the requirements of the Local Plan natural environment and place making 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

4.103

Representation ID: 4217

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

How can a Plan that has not yet been written inform the Local Plan?

Change suggested by respondent:

.

Full text:

How can a Plan that has not yet been written inform the Local Plan?


Our response:

Agree this is unclear – we worked with Southern Water as the DWMP was being prepared and consulted upon but the DWMP was not yet published in final form before the Reg 19 consultation. Suggest wording is amended.

Support

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE5 Biodiversity and Biodiversity Net Gain

Representation ID: 4218

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Representation Summary:

Support in principle

Full text:

Offsite provision and biodiversity credits should be resisted as it will not result in any bio diversity gain for the development site and could lead to a significant loss.

a. Where an adverse impact on biodiversity is unavoidable, and no other option is available, this will only be supported where it has been demonstrated that the impact has been minimised as far as possible and, as a last resort, appropriate compensation provided for any remaining adverse impacts;
There can be no compensation for any adverse impact on biodiversity. If that is the case planning permission should be refused at the outset.


Our response:

Support in principle noted.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H1 Meeting Housing Needs

Representation ID: 4254

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

We support every effort to improve air quality. Include Ultra Low Emission Zones. Use of car pooling.
Air quality will be reduced by the increased volume of traffic on the A27 before any upgrades can be implemented because engine idling will be increased.
The siting of 2000 new homes along the A259 corridor and the increase in traffic will impact in air quality. This cannot be mitigated. It will deter those who wish to walk or cycle if they are breathing in fumes from cars. The only way this policy can be achieved is if there is a decrease in cars using our roads. And without frequent bus and train services at affordable levels of cost, this will not happen.

Change suggested by respondent:

Reduce the housing numbers from 10,350.

Full text:

We support every effort to improve air quality. Include Ultra Low Emission Zones. Use of car pooling.
Air quality will be reduced by the increased volume of traffic on the A27 before any upgrades can be implemented because engine idling will be increased.
The siting of 2000 new homes along the A259 corridor and the increase in traffic will impact in air quality. This cannot be mitigated. It will deter those who wish to walk or cycle if they are breathing in fumes from cars. The only way this policy can be achieved is if there is a decrease in cars using our roads. And without frequent bus and train services at affordable levels of cost, this will not happen.


Our response:

Impacts from planned development were considered as part of the Sustainability Appraisal and through the Air Quality Assessment – Annex D of the Transport Study. The suite of transport policies include a number of measures to mitigate/reduce car travel and the Air Quality Policy NE22 requires an air quality assessment where proposals are likely to impact upon air quality.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

1.17

Representation ID: 6020

Received: 11/04/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

[RECEIVED LATE]

- Concerns raised regarding consultation process in relation to Parish Council, neighbourhood planning and local community support.

See full representation/statement within attachment.

Full text:

[RECEIVED LATE]

Statement from Chidham & Hambrook Parish Council
concerning the Chichester Local Plan 2021-2029 Proposed Submission Consultation


The current Local Plan was made in 2016. It would be reviewed within five years. Consultation on the Preferred Approach Plan was undertaken between December 2018 and February 2019. Our residents profoundly disagreed with the change in the proposed housing allocation for the Parish which had risen from 25 (Objective Assessment indicative housing number) in the previous Local Plan (2014-2029) to 500 (2024-2039) Since then, despite our arguments, the number has only been reduced to 300 i.e. 12 times our previous housing allocation. There has been no explanation from Chichester District Council about what has been changed/retained as a result of the consultation or for what reasons. The figure of 300 has not been justified. Our arguments have not been addressed. Furthermore, there is a Southbourne planning application for 63 houses on the immediate north-west border of the parish with the only access through Chidham & Hambrook, but this, if approved, would be in addition to the allocation determined by CDC. This application would impact a protected chalk stream destroy the rural edge of the village and landscape and exacerbate local concerns about development levels. Despite these issues, this development would have little if any practical connection with Southbourne.

We have been asked to comment on the Regulation 19 Submission Plan which includes brand new Policies which have been introduced apparently without any local consultation. The response submission process is on-line only, complicated and time-consuming. Residents are limited to three reasons for objecting – legal compliance, soundness and duty to cooperate. They are restricted to a comment of only 100 words. Only four supporting documents can be attached. This consultation process seems undemocratic. We realise that the government makes the rules, and the Council has to keep to the rules, but this is not an acceptable or democratic form of Consultation.

In the period 2014 - 2017 of the previous Local Plan there was a substantial amount of development in Chidham & Hambrook: the 25 properties increased to 144 new properties permitted by the end of 2019, many ‘on appeal’, and a further 148 in the period to 2022 of which 144 count towards the new Local Plan. This means a further 156 houses are required.

Currently a further 239 houses are the subject of planning applications which have gone to appeal.

The Council’s original assertion of the status of the parish as a relatively high ranking service village was only justified by the theoretical ranking system, but not in our view, as expressed to the council, by practical, comparative, qualitative reality. Although this ranking has disappeared from the current draft it must have contributed to the appeal decision in 2021 for 118 houses in Hambrook which was not contested by the Council, and allowed at a time when the Council could not demonstrate a 5 year housing land supply.

Our residents are understandably incensed. It is difficult to present an argument for a Neighbourhood Plan that requires so many houses, and any new plan will be required to get residents approval in a referendum. Our current experience is of increasing housing numbers for a parish where travel by car is necessary because of the distances, infrequency, inconvenience and cost of buses or trains.

How can CDC expect support from local communities for their Local Plan involving future development if they disregard concerns about the current situation in terms of the limitations of the infrastructure? Just as importantly the parish is midway between the SDNP and the Chichester Harbour AONB. Building in the parish degrades the links between, and therefore the habitats themselves, of these two important and legally protected environmental areas. This is economically counterproductive because of the importance of tourism and leisure, and farming to the area, and the historic and chronic underinvestment in basic wastewater treatment capacity locally.


Our response:

There is considerable flexibility open to LPAs in how the initial stages of local plan production are carried out and there is no requirement to have a further Regulation 18 consultation.

It must be recognised that the Local Plan is the primary development plan document for the Plan Area and will establish the strategic policies for the Plan Area for the next 15 years. Its preparation may render some policies within made neighbourhood plans out of date.

The consultation undertaken accorded with the Council’s adopted Statement of Community Involvement and with the statutory requirements for Local Plans at this stage of their preparation. Whilst the on-line consultation portal was the preferred means of submitting a response, representations could also be made via email and letter.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.23

Representation ID: 6025

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

A baseline needs to be established to prevent sites being cleared and evidence lost. This has happened in Chidham where sites have been stripped of vegetation before an application has been submitted. What would constitute evidence that this has happened? What would the penalties be? CDC Ecologists and Enforcement should be present when such works are scheduled. We have examples of where this has happened – planning application for Chaswood. This site was completely stripped before a planning application was sought. Planning application CALA Homes stripped out 80% of an entire hedge to make a temporary entrance which has now been superceded by the main entrance.

Change suggested by respondent:

A baseline for biodiversity gain should be reclarified and redefined.

Full text:

A baseline needs to be established to prevent sites being cleared and evidence lost. This has happened in Chidham where sites have been stripped of vegetation before an application has been submitted. What would constitute evidence that this has happened? What would the penalties be? CDC Ecologists and Enforcement should be present when such works are scheduled. We have examples of where this has happened – planning application for Chaswood. This site was completely stripped before a planning application was sought. Planning application CALA Homes stripped out 80% of an entire hedge to make a temporary entrance which has now been superceded by the main entrance.


Our response:

Proposed change noted. The issue of pre-emptive clearance is addressed by the Biodiversity Metric, referenced in Policy NE5 Point 1 a). It is therefore considered unnecessary to duplicate the Metric’s detail within the Local Plan policy.

Support

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty

Representation ID: 6085

Received: 15/03/2023

Respondent: Chidham and Hambrook Parish Council

Representation Summary:

Support in principle

Full text:

This policy is of the utmost importance. Chichester Harbour is in decline and the AONB needs to be conserved. How is the setting of the AONB defined? What would exceptional circumstances be? We feel that this is too loose an expression and provides a get out for developers?


Our response:

Support noted

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