Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 3855

Received: 28/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The SDNPA have raised concerns about the connectivity between the SDNP and Chichester Harbour AONB being lost through the development proposed at Policy A11. It seems that the duty to consult and the duty to cooperate have been confused during this process as the SDNPA are not in favour of policy A11 but their concerns appear not to have been considered.

The spatial strategy seeks to locate the majority of development in locations which have access to a range of services and facilities, informed by the settlement hierarchy evidence. This has also been influenced by site availability, suitability, environmental and other constraints.
Assessment of traffic impacts from planned strategic development forms part of the transport evidence base. NE2 Landscape Policy and NE13 Chichester Harbour AONB provide specific protection in relation to the AONB and the SDNP

Object

Representation ID: 3856

Received: 28/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

There are currently no plans in place or guaranteed for nitrate neutrality required Policy A11. SDNPA have stated that they are not going to be in a position to sign further section 106 agreements to offset nitrates at Chilgrove. Without a guaranteed plan to offset nitrates, sites requiring nitrate offsetting should not be included in the plan.

A nutrient mitigation plan will need to be agreed in line with requirements. This is usually done through the planning application process as the mitigation available will evolve over the plan period.

The change sought is not a change to this policy.

Object

Representation ID: 3857

Received: 28/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The word used in paragraph 4.29 is ‘essential’ which does not imply that this condition is an optional requirement but a mandatory one. The development proposed in Policy A11 needs to have a plan in place to offset nitrates but cannot demonstrate it will be nutrient neutral. The lack of provision for offsetting nitrates would bring Policy A11 into conflict with this paragraph of the local plan. The plan cannot be sound if it is inconflict with itself.

Objection and proposed change noted. Policy NE19 (with supporting text) requires all relevant developments within the Solent catchment to demonstrate nutrient neutrality. This is considered to be consistent with the wording of paragraph 4.29. ii) The change proposed (removal of Policy A11) does not relate to this policy (objections have also been recorded against Policy A11)
iii) The change proposed (removal of relevant site allocations without nutrient mitigation) does not relate to this policy (objections have also been recorded against Policy NE19 (rep 6256 refers).

Object

Representation ID: 3858

Received: 28/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The site proposed for policy A11 is grade 1 and 2 agricultural land and productive farmland. It has been in production until last year and includes mature hedgerow at the rear boundary. Although the site is less that 20 hectares in size, it is capable of producing a variety of cereal crops.

Policy NE10 refers to development in the countryside. It states that proposals to build should be complementary to or compatible with its countryside location and does not prejudice any viable agricultural operations or other existing viable uses.

This again brings policy A11 into contradiction with the local plan.

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: 3891

Received: 06/03/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

It is questionable if the bus and rail links could be described as good. There is a bus every half hour until early evening when it switches to one bus an hour to Chichester on the 700 route.
There is one train per hour in each direction which actually stops at Bosham Station.
The primary school is at capacity with no space for expansion. The GP surgery is only open part-time and again, is working at capacity.
The village currently has only one small shop.
We currently have 4 community halls within walking distance but another is being proposed here.

Objection noted. It is accepted that new development may affect existing infrastructure and local services and may require new or enhanced provision to meet needs. Therefore, all relevant service providers are consulted to identify if the services they provide have existing capacity or if additional capacity is needed to accommodate the proposed development. This is outlined in the Infrastructure Delivery Plan (IDP) that supports the Local Plan. It is the responsibility of service providers and stakeholders to identify and ensure delivery of the infrastructure that is required. The Local Plan plays a supporting role in helping to deliver infrastructure by requiring developers to make financial contributions through the developer obligation process (as set out in Policy I1) or by the phasing of development in line with the expected delivery of required infrastructure. The Council will continue to work with service providers to understand the Plan Area’s infrastructure needs and to regularly update the IDP.

Object

Representation ID: 3892

Received: 06/03/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

This site is outside of the Bosham settlement boundary and is farmland. It was deemed the least suitable place for development and there are hundreds of local objections to developing this site. 245 houses is a massive increase in the size of the village with very few extra facilities provided for this scale of development. The site has only one entrance and exit by road onto the A259 and this will result in an increase in air pollution as vehicles queue to get into and out of the development at peak times.

Objection noted. The spatial strategy seeks to locate development in locations which have access to a range of services and facilities, informed by the settlement hierarchy evidence. This has also been influenced by site availability and suitability, environmental and other constraints.

Object

Representation ID: 3893

Received: 06/03/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The site is wholly outside the settlement boundary and is therefore defined as 'countryside'. This brings the site's inclusion into conflict with the plan (points 4.50 and 4.52) which suggests that building outside settlement boundaries will be 'limited'.
There is brownfield land within the settlement boundary at Burns Shipyard which could be developed to build more houses than the three multi-million pound houses currently proposed and awaiting a planning decision.
The inclusion of this site will have a detrimental impact on the A259 and on congestion at the already well-over-capacity A27 Fishbourne Roundabout.

Objection and alternative site proposal noted. The Council is required to identify sites to meet its housing need; Due to the limited availability of deliverable and/or developable brownfield sites within the plan area, relative to the level of housing need, greenfield sites are always going to be have to be the main focus for development within the Local Plan in order to meet the Plan Area’s housing needs. Nevertheless, the council has still sought to allocate brownfield sites where it can, such as Southern Gateway.
This site has been selected as it is adjacent to the boundary, and has been deemed to be suitable to bring forward new sustainable development.
CDC have and continue to work with both National Highways and WSCC to assess the impact of development, and the potential for cumulative effects, on the highway network. Where site specific mitigation is required, this is identified in the site specific policies and IDP. As part of a planning application, developers will be required to submit a Transport Assessment and/or Travel Plan to detail any highway issues and sustainable travel options, which will need to address issues identified in the Local Plan policies and IDP.

Object

Representation ID: 3894

Received: 07/03/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

This paragraph makes no reference to protecting the existing settlement at Broadbridge from flooding. The flood risk data is not conclusive that the site will not flood and the assessment is arguably out of date with many of the tests carried out in 2014 and groundwater tests carried out in 2016/2017. The site is prone to flooding at the western boundary which adjoins Brooks Lane. Brooks Lane is already prone to flooding.

Comment noted. The entirety of the site is located within Flood Zone 1, although it is understood that there are local concerns about flooding from groundwater. This site has planning permission (reference 21/00571/FUL). As part of the application, the report to Planning Committee considered the proposed approach to surface water drainage and considered it acceptable subject to the imposition of a planning condition. The Council is therefore satisfied that the site can be acceptably drained.

Object

Representation ID: 3905

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Objection grounds similar to other strategic allocations proposed within east-west corridor (i.e. A11 and A12), including:

i) insufficient wastewater treatment capacity for housing proposed, and adverse impact on water quality of Chichester Harbour; no guarantee or timetabled plan for upgrades;

ii) lack of road network capacity (esp. Fishbourne roundabout), associated impacts on congestion and air quality, and no guaranteed major improvements.

The overall spatial strategy seeks to locate the majority of development in locations which have access to a range of services and facilities, informed by the settlement hierarchy evidence. This has also been influenced by site availability and suitability, environmental and other constraints.

In terms of infrastructure, it is accepted that new development may affect existing infrastructure and local services and may require new or enhanced provision to meet needs. Therefore, all relevant service providers are consulted to identify if the services they provide have existing capacity or if additional capacity is needed to accommodate the proposed development. This is outlined in the Infrastructure Delivery Plan (IDP) that supports the Local Plan. It is the responsibility of service providers and stakeholders to identify and ensure delivery of the infrastructure that is required. The Local Plan plays a supporting role in helping to deliver infrastructure by requiring developers to make financial contributions through the developer obligation process (as set out in policy I1) or by the phasing of development in line with the expected delivery of required infrastructure. CDC will continue to work with service providers to understand the Plan Area’s infrastructure needs and to regularly update the IDP.

In relation to wastewater infrastructure the current position is set out in the Statement of Common Ground with Southern Water and the Environment Agency (April 2024). In relation to the highway network, CDC have worked with both National Highways and WSCC to assess the impact of development, and the potential for cumulative effects, on the highway network. Where site specific mitigation is required, this is identified in the site specific policies and IDP. As part of a planning application, developers will be required to submit a Transport Assessment and/or Travel Plan to detail any highway issues and sustainable travel options, which will need to address issues identified in the Local Plan policies and the IDP.

Object

Representation ID: 3928

Received: 08/03/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Objection on grounds of:
i) inconsistency with NE2 and NE10 due to loss of high-quality agricultural land and prejudice of viable agricultural operations;
ii) inconsistency with NE2 and NE3 regarding coalescence of Fishbourne and Bosham Settlement Areas and loss of open landscape gap;
iii) failure to comply with duty to cooperate; non-compliance with Bosham Neighbourhood Plan, and lack of consideration of SDNPA and Chichester Harbour Conservancy advice;
iv) adverse impact on character of Bosham village;
v) non-compliance with S2 as proposed development outside settlement boundary;
vi) inadequacy of strategic wildlife corridors;
vii) low likelihood of farmland development producing measurable biodiversity net gain; lack of biodiversity plan clarifying how site hedgerows and bird species will be protected;
viii) non-compliance with NE16 due to insufficient wastewater treatment capacity for housing proposed, and adverse impact on water quality of Chichester Harbour; no guarantee or timetabled plan for upgrades;
ix) lack of road network capacity (esp. Fishbourne roundabout) and associated impacts on congestion and air quality; no guaranteed major improvements; inadequate sustainable transport links;
x) lack of primary education capacity; schools inaccessible via walking/public transport;
xi) significant public and local opposition to proposal;
xii) inappropriate proposed community facilities (village hall and allotments) and inadequate existing rural amenities (shop, GP surgery);
xiii) loss of connectivity between SDNP and Chichester Harbour AONB (biodiversity, recreation, landscape);
xiv) lack of plans or guarantees for nutrient neutrality;
xv) out-of-date flood risk assessments; untested SuDS proposals

Objection noted. It is accepted that new development may affect existing infrastructure and local services and may require new or enhanced provision to meet needs. Therefore, all relevant service providers are consulted to identify if the services they provide have existing capacity or if additional capacity is needed to accommodate the proposed development. This is outlined in the Infrastructure Delivery Plan (IDP) that supports the Local Plan. It is the responsibility of service providers and stakeholders to identify and ensure delivery of the infrastructure that is required. The Local Plan plays a supporting role in helping to deliver infrastructure by requiring developers to make financial contributions through the developer obligation process (as set out in Policy I1) or by the phasing of development in line with the expected delivery of required infrastructure. The Council will continue to work with service providers to understand the Plan Area’s infrastructure needs and to regularly update the IDP. In relation to wastewater infrastructure the current position is set out in the Statement of Common Ground with Southern Water. In relation to the highway network, CDC have worked with both National Highways and WSCC to assess the impact of development, and the potential for cumulative effects, on the highway network. Where site specific mitigation is required, this is identified in the site specific policies and IDP. As part of a planning application, developers will be required to submit a Transport Assessment and/or Travel Plan to detail any highway issues and sustainable travel options, which will need to address issues identified in the Local Plan policies and the IDP.
The policy criteria, in combination with other policies in the Natural Environment chapter of the plan, is intended to ensure the development proposals come forward in a way that are sustainable and suitable.