Chichester Local Plan 2021 - 2039: Proposed Submission

We endorse the strategic approach to housing allocation and the proposal that Plaistow and Ifold should accommodate a maximum of 25 new dwellings on sites to be identified in a neighbourhood planning exercise. We consider this number to be properly assessed, given the capacity of this isolated rural community. In anticipation that responses to the Regulation 19 consultation may raise alternatives to the strategy, we wish to make further points to explain why we consider its approach to be justified.

THIS IS A SUMMARY OF THE PARISH COUNCIL'S COMMENT - PLEASE REFER TO THE SUPPORTING DOCUMENTS FOR FULL DETAILS THANKYOU

Plaistow and Ifold Parish Council respectfully suggests that the policy should include the requirement that the development needs a countryside location and meets an essential, small scale, and local need, which cannot be met elsewhere.

Suggested wording (from Policy 45 of adopted Local Plan):

“Within the countryside, outside Settlement Boundaries, development will be granted where it requires a countryside location and meets the essential, small scale, and local need which cannot be met within or immediately adjacent to existing settlements.”

Plaistow and Ifold Parish Council is supportive of Policy NE10, Development in the Countryside; however, respectfully draws attention to its concern that the Plan does not unambiguously set out, in a strategic policy, that development in the countryside - and especially in the North of the Plan Area -will only be sustainable at the level of development proposed and where development “requires a countryside location”.

Policy 45, ‘Development in the Countryside’ within Chichester’s currently adopted Local Plan 2014 – 2029 includes the overarching proviso that development proposed in the countryside “requires a countryside location”, before proceeding to recite the other criteria that apply.

Policy NE10 does not include this requirement.

In Policy 45 of the currently adopted Local Plan, development within the countryside would not be considered unless a justification for a countryside location (or this location, which happens to be in the countryside) is made out.

The Council notes that within other policies of the draft Plan e.g., policy E2, ‘Employment Development’ a requirement for a countryside location is included.

Were it to be included in NE10, it would reinforce the spatial distribution policy for new housing, by providing an additional clear indication that residential development, to ‘grow’ rural settlements, is unacceptable unless it has unambiguous community support and benefits.

There is supporting text to this effect, but in our view it is not fully reflected in policy wording. In particular, Policy NE10 should make clear that residential development in the countryside is unsustainable and will therefore be resisted except in the very limited circumstances allowed by the Plan and national planning policy.

Plaistow and Ifold Parish Council respectfully suggests that the policy should include the requirement that the development needs a countryside location and meets an essential, small scale, and local need, which cannot be met elsewhere.

The Parish Council suggests that the wording within Policy 45, Development in the Countryside of the current adopted Local Plan 2014-2029 should be inserted into emerging Policy NE10: -

“Within the countryside, outside Settlement Boundaries, development will be granted where it requires a countryside location and meets the essential, small scale, and local need which cannot be met within or immediately adjacent to existing settlements.”

Propose a distinctive policy for development in the North of the Plan, which would more explicitly link the nature and capacity of the spatial areas with the proposed housing allocations. This was achieved in Policy 25 of the current adopted Local Plan.

Plaistow and Ifold Parish Council notes that there is no like-for-like replacement of Chichester’s current Local Plan 2014 – 2029 Policy 25, ‘Development in the North of the Plan’ in the emerging plan; but there is a substantial amount of explanation about the area strategy in the supporting text for Chapter 2 and in the supporting text for Policy S1, which is the spatial development strategy.

The Council would have liked to see a policy more explicitly linking the nature and capacity of the spatial areas with the proposed housing allocations. This was achieved in Policy 25 of the current adopted Local Plan.

The Spatial Strategy and recognition of different landscapes is supported by Plaistow and Ifold Parish Council; however, the distinctive differences of the landscapes within the District are not adequately followed through and protected within policy. As drafted, NE10 does not help to conserve the distinctive qualities of the landscapes as it is not specific. The separate/distinctive Policy 25, ‘Development in the North of the Plan’ within Chichester’s current Local Plan 2014 – 2029 helps to underline and support Chichester’s aspiration to conserve and enhance the distinctive landscape in the North of the Plan Area, which is currently significantly weakened by the omission of a distinctive policy in the current draft version of the Plan.

To meet the Plan’s ambition to maintain landscape quality, the policies and supporting text must be consistent and refer to landscape character.

Plaistow and Ifold Parish Council seeks to act in the capacity of critical friend to ensure that the Local Plan is fit for purposes and expertly drafted to avoid confusion in its future application.

It is the Council’s view that the following matter(s) should be addressed to ensure the Plan is sound i.e., justified, effective and consistent with national policy.

In general terms (strategic matters) the Plan, as worded, risks confusion and unsoundness in terms of its use of language for ‘landscape’ and how it applies ‘landscape’.

• The Plan should adhere to the European Landscape Convention definition of Landscape. This is adhered to by Landscape professionals and Protected Landscapes, and is required in terms of plan-making (https://www.gov.uk/government/publications/european-landscape-convention-guidelines-for-managing-landscapes).

• This definition is even more important because policy and supporting text appears to switch between terms such as ‘rural setting’, ‘countryside’ and ‘natural landscape’. Whilst countryside is defined in planning terms, the others are not, and their use within the Plan is inconsistent. The foundation of the Plan and its understanding of the different areas is ‘landscape character’ and so it is this which the policies are seeking to conserve and enhance. The landscape evidence upon which the Plan relies (the Capacity Study 2019) is all about landscape character, which is how landscape is understood in planning terms. Therefore, the Plan should refer to “conserving and enhancing landscape character”, or “ensuring no adverse effects upon landscape character”. This will ensure the Plan links directly back to its evidence base and avoids confusing terminology in the policies themselves.

• The relationship between landscape character and other areas of policymaking is not yet joined-up.

• The Plan’s evidence for landscape uses the Landscape Character Assessment method. This is the accepted way to understand landscape for planning (Policy and DM). However, the Capacity Study (2019), does not cover the whole District. Yet assumptions about landscape appear to be made in areas where there is no evidence. For example, in the Sustainability Appraisal’s (SA) assessment of the site at Crouchlands Farm, there is no landscape evidence to support the finding that the landscape would be benefitted by a development. Indeed, the opposite is considered to be the case. This calls into question other aspects of the SA, which might also be founded upon an incomplete landscape evidence-base.

Given the Plan’s aspiration to maintain the landscape quality, particularly in the North of the Plan Area, this quality is found through landscape character assessment, which is the evidence-base. In order to meet the Plan’s own ambition, the policies, and supporting text, must be consistent and refer to landscape character too, which, in the North of the Plan Area happens to be rural.

Please amend to match the evidence base: insert "a number of small-scale dispersed settlements..."

The North of the Plan Area is primarily rural in character with diverse landscapes, rich cultural and heritage assets and a number of SMALL-SCALE dispersed settlements, some of which are relatively isolated and served by narrow lanes with limited public transport.

The Plan does not currently recognise that the scale of settlements in the North of the Plan Area is materially different from the rest of the District.

Settlements are 'small and dispersed’. It is the small scale and dispersed pattern of the settlements within the North of the Plan Area that give this part of the District its landscape character.

The nuance of this point should not be underestimated, and the drafting should be tighter to ensure sensitive, landscape led planning decisions within the North of the Plan Area.

Incorrect use of the word 'landscapes'. Change to 'designated historic landscapes'.

The Plan is currently unclear in its use of the term ‘Landscape’ for Conservation Areas and Designed Landscapes (parks and gardens). This is not the correct use of the word ‘landscape’. A change to 'designated historic landscapes' would be better. The term landscape is defined by the European Landscape Convention and this definition should be applied in Local Plan making. Landscape is everything, it includes settlements as well as perceived natural environments. As currently drafted, this paragraph does not comply with the European Landscape Convention.

Suggested re-wording of the first part of 2.23: -

"In the North of the plan area, the "Low Weald" IS A HIGH QUALITY, VALUED landscape characterised by a mix of pasture and medium to small-scale arable fields AND PADDOCKS. IT FORMS A CHARACTERISTIC SETTING TO THE SOUTH DOWNS NATIONAL PARK. Further south, the...."

Poor reference to the Plan's evidence-base.

2.23 as currently drafted does not refer to the 'high quality' landscapes in the North of the Plan Area, in line with the evidence-base and fails to acknowledge its role in forming the setting to the South Downs National Park.

Suggest tighter drafting is required to ensure that all development in the area is driven by evidenced existing local need – rather than a potential ‘local need’ once development has been delivered.

The Council supports the main messages as drafted; however, it has some concerns about the implications of ‘enhancement’ of local services and facilities.

Enhancement is normally required to enable existing modest services and facilities – which support local need only - to cope with greater numbers of people. As drafted, this part of the Plan offers the potential for confusing and conflicting decision making.

If the primary emphasis in the North of the Plan Area is to maintain “the rural character of the existing villages, whilst enabling the local communities to become more self-reliant in meeting their local needs…” then tighter drafting is required to ensure that all development in the area is driven by evidenced existing local need – rather than a potential ‘local need’ once development has been delivered.

Re-title policy 'NE2 Landscape';

Amend criteria #3 to 'Development proposals maintain the [insert distinctive character] of settlements and...' to ensure policy links to evidence base;

Addition of criteria #6 to state 'Development proposals within the setting of the South Downs National Park should recognise its status as a landscape of the highest quality and should be landscape-led in their design; sensitively located and designed to reflect this with scale and extent of development limited and designed to avoid or minimise adverse effects upon the National Park and its Purposes. Proposals must comply with the South Downs Local Plan and Management Plan which are material planning considerations';

Suggest all applications are supported by either an LVIA or LVA (Landscape Visual Appraisal - a 'light touch' LVIA) to avoid the need to specifically refer to identified character areas.

Suggest key perceptual qualities of dark night skies and tranquility are explicitly referenced.

Concerns that the soundness of the Plan is compromised, due to unclear drafting. Suggested amendments below.

Natural landscape is a misnomer. Landscape is defined (European Landscape Convention) and it includes settlements, roads and infrastructure and the policy itself rightly refers to settlements. We consider this policy heading is confusing and the term 'landscape is already often misused within the Plan. Given Chichester's significant areas of Protected Landscapes and their settings, the terminology used should match those Protected Landscapes. Suggest this policy is re-worded to 'NE2 Landscape'. Point #3 "Development proposals maintain the [insert DISTINCTIVE CHARACTER] of settlements and...' This links the policy back to the evidence base.

The policy need to equally cover the setting of the AONB and National Park. The North of Plan Area includes a significant area of landscape which contributes to the setting of the National Park. Not just visually but in terms of landscape character and perceptual qualities such as dark night skies and tranquility. It is suggested that a criteria #6 is added to state: "Development proposals within the setting of the South Downs National Park should recognise its status as a landscape of the highest quality and should be landscape-led in design; sensitively located and designed to reflect this with scale and extent of development limited and designed to avoid or minimise adverse effects upon the National Park and its purposes. Proposals must comply with the South Downs Local Plan and Management Plan which are material planning considerations.

"For larger schemes in identified character areas..." - it is unclear what the 'identified character areas' are and when this part of the Policy might apply. Suggest all applications are supported by either an LVIA or LVA (Landscape Visual Appraisal - a 'light touch' LVIA). This avoids the need to specifically refer.

This policy missed reference to key perceptual qualities, highly valued aspects of landscape (See NPPF 174), particularly in the North of the Plan Area and those landscapes which contribute positively to the setting of the National Park. Suggest dark night skies and tranquility are explicitly referenced - as Policy NE21 fails to provide equal weight to lighting between the two Protected Landscapes.

The policy should make reference to 'landscape character'.

As landscape is referenced in the title of this policy, it should make reference to 'landscape character', as this should be where the 'gap evidence' is derived from. By referencing 'landscape character' it links back to Chichester's own evidence base and avoid spurious gaps being created - ensuring all gaps are identified using the same robust methodology.