Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
The Vision is that by 2039,
Representation ID: 4109
Received: 15/03/2023
Respondent: The Goodwood Estates Company Limited
Agent: HMPC Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The LP is supported. The district has been subject to inappropriate speculative developments without corresponding infrastructure and service improvements. Developments have been self-centred, failing to acknowledge consequences on the long-term attractiveness, viability and sustainability of the District. Each development has impacted the ability to provide enhancements and much-needed infrastructure.
To be sound the plan must meet NPPF tests and we find the plan sound in terms of it being reasonable and capable of being delivered. However it lacks soundness in terms of its vision and protection and enhancement of economic, heritage and environmental assets.
We believe the changes we suggest will allow the plan to explain more clearly a joined-up approach between its strategic vision, development allocations, infrastructure provision and environmental enhancement, that will serve as robust evidence for (a) the safeguarding and enhancement of its important economic and environmental assets, (b) the promotion and support of its development proposals, and (c) improved defence against inappropriate and harmful speculative development.
The LP is supported. The district has been subject to inappropriate speculative developments without corresponding infrastructure and service improvements. Developments have been self-centred, failing to acknowledge consequences on the long-term attractiveness, viability and sustainability of the District. Each development has impacted the ability to provide enhancements and much-needed infrastructure.
To be sound the plan must meet NPPF tests and we find the plan sound in terms of it being reasonable and capable of being delivered. However it lacks soundness in terms of its vision and protection and enhancement of economic, heritage and environmental assets.
No specific changes have been proposed in this representation so the change sought is unclear.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Objective 4: Employment and Economy
Representation ID: 4130
Received: 15/03/2023
Respondent: The Goodwood Estates Company Limited
Agent: HMPC Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Within the plan are policies or supporting information deficient on key matters affecting the economic sustainability of the district. The plan fails to recognise the full extent of th eimportant roles of Goodwood Estate and Rolls-Royce to the District economic vitality.
The plan seeks to accommodate Goodwood needs through its policies but continues to present major challenges threatening Estate sustainability.
The plan should identify and protect economic assets robustly, appropriate provision made or their sustainability and enhancement and clarity that interests will not be impacted adversely by developments on adjoining land, or which adversely affect infrastructure essential to its well-being.
The Estate has shared with the planning authority an independent report prepared by LSE as to the very significant contribution made by Goodwood and Rolls-Royce locally (this report is in the process of being updated and it is understood Rolls-Royce has commissioned a similar study – it is intended such evidence will be available for the local plan examination). The REport and its findings should be reflected in the Plan.
The local plan is a major step forward in terms of protecting the Estate’s interests and allowing it to evolve and continue to contribute significantly to the local and regional economy. However, for the plan to be truly sound and provide a true basis for forward investment, we ask that changes are made to the plan as we identify through our representations.
Within the plan are policies or supporting information deficient on key matters affecting the economic sustainability of the district. The plan fails to recognise the full extent of th eimportant roles of Goodwood Estate and Rolls-Royce to the District economic vitality.
The plan seeks to accommodate Goodwood needs through its policies but continues to present major challenges threatening Estate sustainability.
The plan should identify and protect economic assets robustly, appropriate provision made or their sustainability and enhancement and clarity that interests will not be impacted adversely by developments on adjoining land, or which adversely affect infrastructure essential to its well-being.
This objective is to support a diverse economy, including the sectors mentioned but a more explicit reference to hospitality and vehicle manufacture can be added.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
2.5
Representation ID: 4135
Received: 15/03/2023
Respondent: The Goodwood Estates Company Limited
Agent: HMPC Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The plan must acknowledge and plan for the long-term management and sustainability of the important transportation links identified. This acknowledgement is absent.
The plan must acknowledge and plan for the long-term management and sustainability of the important transportation links identified
The plan must acknowledge and plan for the long-term management and sustainability of the important transportation links identified. This acknowledgement is absent.
The Local Plan Transport and Accessibility section provides detail on how the Council will work with partners to deliver transport proposals, including sustainable modes of travel, to support growth over the plan period.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
1.28
Representation ID: 4139
Received: 15/03/2023
Respondent: The Goodwood Estates Company Limited
Agent: HMPC Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The plan does not explain sufficiently how key strategic and cross-boundary issues are being addressed through the plan and across the plan area. One crucial area missing from the list of examples of effective outcomes is economic impact, and its role in protecting and enhancing the physical and environmental objectives of the plan (and wider) area. Authorities should jointly promote a vibrant and sustainable economy, which recognises and enhances the assets which contribute to and comprise that economic activity.
Explain in detail how key strategic and cross-boundary issues are being addressed through the plan and across the plan area
The plan does not explain sufficiently how key strategic and cross-boundary issues are being addressed through the plan and across the plan area. One crucial area missing from the list of examples of effective outcomes is economic impact, and its role in protecting and enhancing the physical and environmental objectives of the plan (and wider) area. Authorities should jointly promote a vibrant and sustainable economy, which recognises and enhances the assets which contribute to and comprise that economic activity.
The list of outcomes is not exhaustive and the Employment and Economy Chapter introductory text references the links to the County economic priorities. The Duty to Cooperate Statement of Compliance (April 2024) also provides details of the engagement and joint working with neighbouring authorities.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
8.3
Representation ID: 4141
Received: 15/03/2023
Respondent: The Goodwood Estates Company Limited
Agent: HMPC Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Principal causes of A27 congestion are local traffic movements from and to an inadequate local highway network, made worse by poorly integrated new developments, and conflicted priorities between through and crossing traffic.
The solution is not a very costly “by-pass” of limited economic or environmental benefit. Past by-pass proposals failed to correctly assess the true economic cost of options promoted, the cost and benefits of tackling the issues at a local level of on-line improvements, lack of co-ordinated improvements in the local highway network and a failure to engage appropriately and positively to solve a common problem.
Neither the local plan nor its strategies should be based on any A27 by-pass premise and should not make provision for any A27 by-pass proposal.
Principal causes of A27 congestion are local traffic movements from and to an inadequate local highway network, made worse by poorly integrated new developments, and conflicted priorities between through and crossing traffic.
The solution is not a very costly “by-pass” of limited economic or environmental benefit. Past by-pass proposals failed to correctly assess the true economic cost of options promoted, the cost and benefits of tackling the issues at a local level of on-line improvements, lack of co-ordinated improvements in the local highway network and a failure to engage appropriately and positively to solve a common problem.
The strategy set out in Policy T1 will support the level of development that is proposed by the Plan
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
1.39
Representation ID: 4142
Received: 15/03/2023
Respondent: The Goodwood Estates Company Limited
Agent: HMPC Ltd
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Identification and protection of important environmental sites is supported, but we request that similar identification is made of other important areas that contribute positively to the economic and environmental well-being of the district; including landscape, economic and heritage assets. Policies to protect and enhance these areas as an essential component of a sustainable strategy is vital.
Identification and protection of important environmental sites is supported, but we request that similar identification is made of other important areas that contribute positively to the economic and environmental well-being of the district; including landscape, economic and heritage assets. Policies to protect and enhance these areas as an essential component of a sustainable strategy is vital.
Identification and protection of important environmental sites is supported, but we request that similar identification is made of other important areas that contribute positively to the economic and environmental well-being of the district; including landscape, economic and heritage assets. Policies to protect and enhance these areas as an essential component of a sustainable strategy is vital.
Comments noted, however, it is considered that the existing plan policies, particularly those related to natural environment and place making, address the points made by the respondent.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A21 Land east of Rolls Royce
Representation ID: 4219
Received: 15/03/2023
Respondent: The Goodwood Estates Company Limited
Agent: HMPC Ltd
Policy A21 The Estate supports the policy, providing the resultant development offers an equally high standard of building and landscape design, site density and use, an without harm or adverse impact on surrounding land and land uses and the local road network.
Policy A21 The Estate supports the policy, providing the resultant development offers an equally high standard of building and landscape design, site density and use, an without harm or adverse impact on surrounding land and land uses and the local road network.
Support noted
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A10 Land at Maudlin Farm
Representation ID: 4220
Received: 15/03/2023
Respondent: The Goodwood Estates Company Limited
Agent: HMPC Ltd
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Policy A10 Land at Maudlin Farm Supported. The Estate welcomes criterion 10 and will offer to work with the developer to ensure noise mitigation measures are appropriate.
Map 10.6 A small strip of land fronting Dairy Lane and to the west of the site boundary is excluded from the allocation. The land is owned by the Goodwood Estate. The land could be used as an extension to the Maudlin Farm allocation or treated as a windfall site.
Policy A10 Land at Maudlin Farm Supported. The Estate welcomes criterion 10 and will offer to work with the developer to ensure noise mitigation measures are appropriate.
Map 10.6 A small strip of land fronting Dairy Lane and to the west of the site boundary is excluded from the allocation. The land is owned by the Goodwood Estate. The land could be used as an extension to the Maudlin Farm allocation or treated as a windfall site.
1. Noted.
2. The site east of Dairy Lane is assessed in the HELAA (HWH0005a) as being deliverable and the HELAA also recognises the potential for the site to come forward in conjunction with the larger adjoining site (proposed for allocation in the Local Plan under Policy A10).
Whilst there may be some technical and place making advantages if the two sites were developed together, the Council are not proposing any amendments to sites allocated in the Local Plan or to allocate any additional sites
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
2.3
Representation ID: 4223
Received: 15/03/2023
Respondent: The Goodwood Estates Company Limited
Agent: HMPC Ltd
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Chichester is the main settlement and centre for the district’s economic well-being and growth and it is correct it should be the focus for new sustainable development. When identifying the city and its environs as such, the plan must be equally confident all elements which make the city special and which contribute its character, wealth, quality of life and attractiveness, are not lost or damaged through inappropriately located, densities and forms of new development.
The plan should identify and support specific policies that protect and enhance these key elements to sustain Chichester as a key economic and historic centre.
Chichester is the main settlement and centre for the district’s economic well-being and growth and it is correct it should be the focus for new sustainable development. When identifying the city and its environs as such, the plan must be equally confident all elements which make the city special and which contribute its character, wealth, quality of life and attractiveness, are not lost or damaged through inappropriately located, densities and forms of new development. The plan should identify and support specific policies that protect and enhance these key elements to sustain Chichester as a key economic and historic centre.
Noted. It is considered that Policy A1 (Chichester City Development Principles), together with relevant design policies, effectively address the matters referred to by the respondent.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H4 Affordable Housing
Representation ID: 4224
Received: 15/03/2023
Respondent: The Goodwood Estates Company Limited
Agent: HMPC Ltd
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The local plan should lead the provision of affordable housing through specific policy requirements that reflect local need and ensure delivery on suitably located sites. Consequently the plan should introduce additional local Policies to clearly identify the need for affordable housing on most sites, to limit the ability of developers to challenge affordable housing provision through generic viability statements, or allow a default position of contributions towards developments elsewhere.
The plan’s primacy should identify sites (or parts of sites) best located to meet identifiable need for affordable housing and require a demonstration of delivery.
The local plan should lead the provision of affordable housing through specific policy requirements that reflect local need and ensure delivery on suitably located sites. Consequently the plan should introduce additional local Policies to clearly identify the need for affordable housing on most sites, to limit the ability of developers to challenge affordable housing provision through generic viability statements, or allow a default position of contributions towards developments elsewhere. The plan’s primacy should identify sites (or parts of sites) best located to meet identifiable need for affordable housing and require a demonstration of delivery.
The level of specificity envisaged by this response is considered to be out of step with the conventions of such policies. Policy H4 is considered to be appropriate in terms of following the traditional approach of setting out general affordable housing requirements, and is informed by local evidence, particularly that set out in the HEDNA 2022 and the viability appraisal. The policy also seeks to prevent the reduction in those requirements unless it is absolutely necessary, but does allow for some flexibility where it can be demonstrated on a case-by-case basis that the requirements cannot be met. The policy is considered to be consistent with national policy and the conventions for how such policies are drafted
