Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 3813

Received: 22/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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 threshold of 20 hectares follows the requirements of Natural England’s Guidance on assessing development proposals on agricultural land and as referred to at paragraph 001 of the National Planning Practice Guidance: Natural Environment. Policy NE3 Landscape Gaps Between Settlements seeks to prevent coalescence of settlements. The Sustainability Appraisal considers the loss of best and most versatile land

Object

Representation ID: 3814

Received: 22/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

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 threshold of 20 hectares follows the requirements of Natural England’s Guidance on assessing development proposals on agricultural land and as referred to at paragraph 001 of the National Planning Practice Guidance: Natural Environment. Policy NE3 Landscape Gaps Between Settlements seeks to prevent coalescence of settlements. The Sustainability Appraisal considers the loss of best and most versatile land

Object

Representation ID: 3815

Received: 22/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

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 new Local Plan will update policy and where there is a conflict of existing policy the most recent up to date version will apply. However, the parish may choose to give future consideration as to whether or not it wishes to review the neighbourhood plan to consider, assess and identify landscape gaps within the parish once the new Local Plan is adopted. Alternatively, this process could be undertaken by CDC.

Object

Representation ID: 3816

Received: 22/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

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.

Comment noted. The width of the corridors has been based on technical information relating to location and presence of species

Object

Representation ID: 3817

Received: 22/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

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.

Objection noted.
i)Stepping stones are defined within the proposed Glossary (Appendix J). Proposed policy NE5 specifically requires their consideration by development at H. The identification and mapping of stepping stones, where recognised as an area of particular importance for biodiversity, is an iterative process which will be further addressed by the mandatory development of a Local Nature Recovery Strategy;
ii) It is recognised that the strategic significance of agricultural land in terms of existing biodiversity may be low. Proposed policy NE5 requires a minimum of 10% biodiversity net gain against a pre-development baseline, calculated using the national Biodiversity Metric. The Metric enables consideration of land parcels containing multiple habitats, such as hedgerows surrounding cropland, ensuring the site and proposed BNG is accurately measured;
iii) The conservation of trees and hedgerow is specifically addressed by Policy NE8. The changes proposed do not relate to this policy (objections have also been recorded against Policy A11).

Object

Representation ID: 3818

Received: 22/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

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.

Objection noted. The change proposed (removal of Policy A11) does not relate to this policy (objections have also been recorded against Policy A11).

Object

Representation ID: 3836

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? No

Sound? No

Duty to co-operate? No

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.

Policy NE16 requires that development is phased to align with delivery of new or improved wastewater infrastructure where this is needed.

Object

Representation ID: 3837

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

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?

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.

Object

Representation ID: 3838

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? No

Sound? No

Duty to co-operate? No

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.

The suggested change is not a change to this policy. The suggested change has also been recorded against policy A11 and responded to there.

Object

Representation ID: 3839

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

There is no longer a requirement to meet mandatory housing targets set by the government. 73% of the District is classified as SDNP, a further 3.5% occupied by the AONB. This land is protected against development. Housing proposed will have an adverse effect on the water quality of Chichester Harbour. The strategic road network has no capacity. CDC 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.

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. This issue is also covered in more detail in the Housing Need, Housing Distribution and Transport Background Papers.
Where the Local Plan makes a parish housing requirement it will be for a Neighbourhood Plan to identify potential development sites.

Policy I1 requires infrastructure and its timing to be secured by way of condition or legal requirement. It is those conditions or legal agreements that will set out the detailed phasing and housing triggers.

It would not be practical to prevent all development from being provided until all accompanying infrastructure is completed as that would not be economically viable.

The proposed modifications to Policy T1 Transport Infrastructure set out the council’s approach to securing transport mitigation to support the planned growth.