Chichester Local Plan 2021 - 2039: Proposed Submission

Include the characteristics identified in paras 2.2 and 2.3 in the Vision

The Vision does not refer to conserving the different characteristics identified across the District established in paragraphs 2.2. and 2.3. It is recommended that these identified characteristics needs to form part of the Local Plan Vision to ensure the Plan is coherent and not fighting against itself.

Include reference to landscape character.

The explanatory text is all about the low-lying land. The Council suggest that this text needs to reflect the whole objective and refer to 'landscape character'. Ideally this should be first, as it is the landscape character (geology, soils etc.) that underpins the important natural environment and designated sites being referenced.

Include reference to landscape character

The Council suggests that this objective should refer to 'landscape character', as understanding landscape character is at the heart of achieving the ‘integration’ of new development referred to.

The suggested alternative wording is:

“The north of the plan area covers those parts of Chichester District which lie north AND EAST of the South Downs National Park boundary. This includes Loxwood Parish and most of the parishes of Kirdford, Plaistow and Ifold, and Wisborough Green, together with a small part of Lynchmere Parish close to the Surrey border around the villages of Camelsdale and Hammer.”

This paragraph, as currently drafted, does not correctly orientate The North of the Plan Area with the South Downs National Park (SDNP) and should therefore be corrected. The SDNP is both North and East of the SDNP boundary.

These smaller villages [specifically Plaistow Ifold and Kirdford] should be reclassified as “Rest of Plan Area: Includes the countryside and other small villages and hamlets which have poor access to facilities.”

The drafting of this section of the Plan does not match the landscape character evidence in relation to settlement character. The ambition to support landscape quality in the North of the Plan Area is supported by the Council, but it is undermined by identifying all the settlements as ‘Service Villages’. Plaistow, Ifold and Kirdford in particular are all small villages in comparison with Loxwood and Wisborough Green, which are larger scale settlements and different in character terms. By labelling them all as ‘Service Villages’ will risk these smaller villages becoming treated as larger ‘Service Villages’ in time, which will risk them losing their character and settlement hierarchy within this area. These smaller villages should be reclassified as “Rest of Plan Area: Includes the countryside and other small villages and hamlets which have poor access to facilities.”

The Plan identifies that there are few large settlements North of the Plan Area. To ensure this distinctive area of the District is correctly conserved and, where appropriate, enhanced in keeping with the aspirations set out in Chapter 2: Vision and Strategic Objectives, North of the Plan Area, paragraphs 2.49 – 2.51 it is important that the various settlements within the area are correctly identified. Compared to Fishbourne, Boxgrove, and Westhampnett* Wisborough Green is an isolated exceptionally rural village; however, when you compare Wisborough Green to Plaistow, Ifold or Kirdford, Wisborough Green appears more akin to a true ‘Service Village’.

*proximity to A27, public transport, Chichester city and other higher order settlement hubs, services and facilities

Therefore, it is incorrect to list Plaistow, Ifold, Kirdford, Wisborough Green and Loxwood in the same ‘Service Village’ category as Fishbourne, Boxgrove, and Westhampnett etc as this does not correctly recognise the true scale of the settlements in the North of the Plan Area, which are materially different from the rest of the District.
Settlements are 'small and dispersed’ with poor connectivity either to each other or to other settlement hubs. To do so, is contrary to the Plan’s aspiration to maintain landscape quality. The Plan’s policies need to correctly reflect the characteristics of each landscape. If settlements are incorrectly identified any growth will be unsustainable and will change the character of the whole landscape. The ambitions should be constrained by an area’s landscape capacity.

Chichester's landscape evidence remains the Capacity Study 2019. The results of this study should be correctly reflected within Plan policies.

Whilst the Council understands that some small-scale development is required within the North of the Plan area and supports this, it wishes to act as a critical friend to ensure that the nuances of the proposed small scale development is fully appreciated.

All housing numbers advocated for the North of the Plan Area are large-scale for the current size of the settlements in this area and will increase their population sizes, without providing any services / facilities to manage this increase. In truth, the Plan cannot / does not deliver the required services / facilities the current settlements need, irrespective of any additional growth. The Plan cannot alter the proximity of the SDNP; the areas dark skies; its rare ecology; the poor rural road networks; the proximity of key services to these northern settlements e.g., secondary schools / higher education / transport links - many of which are situated outside of the District itself; the lack of supermarkets; the lack of other services which are necessary to support a diverse population i.e., libraries, children’s centres, job centres etc and the dependence on private vehicles.

The various services / facilities required to support bigger population sizes are outside of the control of CDC and the Local Plan – medical services / school placements (primary, secondary, and higher education) / public transport services / leisure / retail. Therefore, whilst 25, 50, 75, 220 are very small housing numbers when compared to the rest of the District, if the local services upon which these additional residents will rely upon are already oversubscribed – which they are - and there is no prospect of delivering the requires support services in the area – which there is not - then any housing number above that which the current local area can reasonably accommodate is unsustainable development.

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.”

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.

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.

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.

The Vision does not refer to conserving the different characteristics identified across the District established in paragraphs 2.2. and 2.3. It is recommended that these identified characteristics needs to form part of the Local Plan Vision to ensure the Plan is coherent and not fighting against itself.