Chichester Local Plan 2021 - 2039: Proposed Submission

The Highgrove site at policy A11 needs to be removed from the local plan as it contradicts the statement in paragraph 4.8.

The threshold of twenty hectares is exceedingly low in proportion to the scale of most field sizes in the coastal plain. A vast swathe of the best and most versatile agricultural land could be lost without recourse to more series specialised and detailed assessment.
There is a logical inconsistency between this statement and the policy advanced for Highgrove Farm, Bosham (A11) which straddles grade 1 and grade 2 agricultural land and is capable of yielding between 126 and 144 tonnes of cereal per year that’s 244,800 loaves of bread according to a local seed merchant.

The site proposed at Policy A11 needs to be removed from the plan.

Stipulations are insufficiently clear to prevent the coalescence of settlements especially in the east-west corridor. They allow crowding out of open fields, margins and hedgerows that provide invaluable connections for wildlife between the South Downs National Park and the Chichester Harbour AONB.
Point 4 under policy NE2 would prohibit the change of use of the area designated under policy A11 which straddles grade 1 and grade 2 agricultural land and is capable of yielding between 126-144 tonnes of cereal per year that’s 244,800 loaves of bread according to a local seed merchant.
SDNPA has been consulted but not co-operated with.

The site proposed at Policy A11 for Highgrove should be removed from the local plan.

There is a logical inconsistency between this statement and the policy advanced for Highgrove Farm, Bosham (A11) as the historic separation of Fishbourne and Bosham Settlement Areas is compromised and whilst the emerging Local Plan proposes the site for development, the Bosham Parish Neighbourhood Plan specifically rejects it. Again, I think Chichester District Council are confusing the duty to consult with a duty to co-operate. As the Neighbourhood Plan has not been co-operated with, nor has the advice from SDNPA or Chichester Harbour been taken into account.

The proposed site at Highgrove in policy A11 needs to be removed from the local plan.

The ’strategic wildlife corridors’ referred to are in fact small scale local ones that connect along very small chalk streams of undoubted ecological value including millstreams, but their width and length touching upon the boundaries of SDNP and CHAONB but not interpenetrating them suggests a minimalist approach. When neighbouring Arun are contemplating a wildlife corridor stretching from Clymping Beach to the Ashdown Forest (“Weald to Waves”), the ambition of the CDC plan appears paltry. On one site (Highgrove) the Sussex Biodiversity Record lists in excess of one hundred bird species records alone.

The wildlife corridor stepping-stones referred to need to be defined clearly so that the public knows what this means.
Policy A11 Highgrove needs to be removed from the local plan

Whilst the wildlife corridors receive a set of maps with outlines of their modest proportions, ‘stepping stones’ are neither defined, nor delimited spatially. It appears therefore as a piece of rhetorical padding.
Building on farmland is not going to produce a measurable net gain in biodiversity. In the site proposed at A11 there are mature hedgerows which will be disturbed.

The site allocated in Policy A11 at Highgrove needs to be removed from the Local Plan.

The phrase ‘biodiversity net gain’ has great importance in the NPPF, yet at least one site proposed for development (Highgrove Farm, Bosham) has an established database maintained by Sussex Biodiversity Record of over 100 species of birds alone. Yet the policy A11 does not refer to how this would be boosted by 10% either insitu or by offset.

There should be a moratorium on any further house building until Southern Water have a concrete plan in place and have provided clear details of how they plan to deal with the overflows into the harbour.
The plan contradicts itself saying that development will only be permitted if it does not have an adverse impact on the quality of water bodies because the development proposed is guaranteed to adversely impact the harbour and there is no detail in the plan of how sewage overflows are going to be stopped or the damage that has already been done mitigated.

Last year, Southern Water polluted Chichester Harbour with 1700.37 hours of wastewater overflows. This is 70.85 days or 19.41% of the year. CDC are aware of this and recognises that wastewater infrastructure needs improvement but there is no guaranteed improvement promised in the plan. The plan states that development proposals will only be permitted if the development has no adverse impact on the quality of water bodies. However, if the system is at capacity at the moment which it is clear from the data above it is, then CDC have a duty to residents not to exacerbate the problem.

The wording needs looking at as it implies you have used a document that may not have been written to inform the writing of the local plan. The document, if it exists, needs to be available to the public so that we can see how Southern Water are going to accommodate the extra wastewater developed by the proposed housing in the local plan.

If Southern Water are in the process of preparing a plan, this would imply it has not been written and published yet. If this is the case and it has not been written, how has it been used to inform the local plan?
If the DWMP has been written already, why has the DWMP not been provided for the public?

Remove policy A11 from the local plan.
Cut the number of houses allocated in the plan to from the 10,354 proposed to 2,699.

Chichester District Council are under a statutory duty to protect Chichester Harbour. The housing proposed in this plan will have an adverse effect on the quality of the water bodies. Southern Water are not able to cope with the level of wastewater generated in the district. For Policy A11 Southern Water have stated they do not have the capacity for the number of houses proposed. The water quality and wastewater part of this policy will not be complied with if these houses are built.

Change the allocated number of houses in the plan to 2,699 (23.5% of the government allocation)
Use neighbourhood plans to decide on which developments will be used.

The government document online relating to the change in mandatory house building targets states, 'The Bill will strengthen opportunities for people to influence planning decisions that affect their immediate area. We will give increased weight to neighbourhood plans to ensure the efforts of local communities to produce them bear fruit, introduce Neighbourhood Priorities Statements as a means for communities to formally input into the preparation of local plans, and allow residents to bring forward the development they want to see on their street through innovative new ‘street votes.’ The wider review of the Framework next year will support this.’
https://www.gov.uk/government/consultations/levelling-up-and-regeneration-bill-reforms-to-nationalplanning-policy/levelling-up-and-regeneration-bill-reforms-to-national-planning-policy

There is large scale opposition to the continued development in the area and the squeezing of houses allocated into a small space. Local people's views need to be taken into account.

There is no longer a requirement to meet mandatory housing targets set by the government. 73% of the Chichester District is classified as SDNP, a further 3.5% occupied by the AONB. This land is protected against development. Chichester District Council would be justified in taking the government-allocated figure for housing and reducing it by 76.5%. building 23.5% of the housing allocation to equate to the percentage of land available. The government target was 638 houses per year from 2021-2039 or 11,484 houses. This would equate to 2,699 houses, not the 10,354 proposed. Neighbourhood Plans seem to have been ignored.