Chichester Local Plan 2021 - 2039: Proposed Submission

Consider the inclusion of ‘small-scale’ wording is superfluous, and should be deleted.

We support the inclusion of Hambrook and Nutbourne as a service village within the district's settlement hierarchy. However, we question the need for the inclusion of the wording ‘small-scale’ when referring to housing developments consistent with the indicative housing numbers set out in Policy H3. No definition is provided over what does, or does not constitute ‘small-scale’. There is a risk that small-scale could be inferred as excluding ‘major development’ as defined within the NPPF glossary. To avoid any confusion, we therefore consider the inclusion of ‘small-scale’ wording is superfluous, and should be deleted.

We support the inclusion of Hambrook and Nutbourne as a service village within the district's settlement hierarchy. Indeed, the Council’s Settlement Hierarchy Background Paper confirms Hambrook and Nutbourne has a broad range of key local facilities and services as well as local employment opportunities. The village also has a railway station with frequent services to Chichester and Portsmouth, as well as bus services to Chichester and Petersfield, collectively providing a wider range of facilities, services and employment opportunities.

Policy NE4 should be amended to reflect the objectives and role of the Strategic Wildlife Corridor:

Development will only be permitted where it would not lead to a significant adverse effect upon the ecological value, function and connectivity of the strategic wildlife corridors.

Development proposals within strategic wildlife corridors will only be granted where it can be demonstrated that:

1. The development will not have a significant adverse impact on the function of the wildlife corridor and protects and enhances its features and habitats.
2. The proposal will not undermine the connectivity and ecological value of the corridor.

Development proposals outside, but in close proximity to the strategic wildlife corridor will be acceptable where it can be demonstrated that:
a) The development will not have a significant adverse impact on the integrity and function of the wildlife corridor; and
b) The proposal will not undermine the connectivity and ecological value of the corridor.

All proposals for new development (with the exception of householder applications) within or in close proximity to wildlife corridors should take opportunities available in order to extend or enhance those corridors.

The wording as drafted fails the NPPF soundness tests, on the basis that: (a) Ecology-led masterplannning can ensure development is accommodated within the SWCs while fully maintaining the functional elements of the corridors; (2) The policy as drafted is also wholly inconsistent within NPPF paragraph 180, it that it only provides for development avoidance measures within the SWCs; and (3) The ‘integrity’ test element of the policy relates to undertaking Appropriate Assessments. The protection afforded within the policy wording must be proportionate to the locally important status of the designation.

The Plan should meet at least its full identified need of 638dpa, plus an additional buffer to accommodate unmet needs from SDNP(40 dpa), plus a 5% flexibility buffer. The resulting housing figure being 712 dpa. Based on the currently identified supply of 10,359 dwellings, a further circa. 2,500 homes (rounded) would need to be identified. Sustainable and suitable locations for growth, such as Chidham and Hambrook parish, should be revisited to help need the housing supply shortfall. The Council should also critically review the robustness of the ‘Category b Known commitments’ supply components.

The Plan should meet at least its full identified need of 638dpa, plus an additional buffer to accommodate unmet needs from SDNP(40 dpa), plus a 5% flexibility buffer. The resulting housing figure being 712 dpa. Based on the currently identified supply of 10,359 dwellings, a further circa. 2,500 homes (rounded) would need to be identified. In view of the shortfall the housing figure apportioned to Chidham and Hambrook parish, should be increased to at least 500 dwellings over the plan period.

Replace 300 with 500 dwellings. Add 'significant' to clause 5 (Ensure that development avoids significant harm to protected species and existing important habitats features and facilitates the achievement of biodiversity net gain, and facilitates the creation of high levels of habitat connectivity within the site and to the wider green infrastructure network and identified strategic wildlife corridors within the parish. This includes the provision of appropriate buffers as necessary in relation to important habitats which are being retained and/or created.

The Plan should meet at least its full identified need of 638dpa, plus an additional buffer to accommodate unmet needs from SDNP(40 dpa), plus a 5% flexibility buffer. The resulting housing figure being 712 dpa. Based on the currently identified supply of 10,359 dwellings, a further circa. 2,500 homes (rounded) would need to be identified. In view of the shortfall the housing figure apportioned to Chidham and Hambrook parish, should be increased to at least 500 dwellings over the plan period.

Text change to paragraph 4.18:

The Council will apply an additional layer of planning restraint to the countryside protection policies within these strategic wildlife corridors to ensure that connectivity between the South Downs National Park and the Chichester Harbour AONB and Pagham Harbour is maintain in the long term. If a significant
adverse impact on the function of the corridor resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then it will not be permitted.

The wording as drafted fails the NPPF soundness tests, on the basis that: (a) Ecology-led masterplannning can ensure development is accommodated within the SWCs while fully maintaining the functional elements of the corridors; (2) The policy as drafted is also wholly inconsistent within NPPF paragraph 180, it that it only provides for development avoidance measures within the SWCs; and (3) The ‘integrity’ test element of the policy relates to undertaking Appropriate Assessments. The protection afforded within the policy wording must be proportionate to the locally important status of the designation.