Chichester Local Plan 2021 - 2039: Proposed Submission

Criterion 4 Reference to Westhampnett (Policy A9 and Policy A10) should be cross referenced to the relevant policy pages at this point – possibly through a footnote – to indicate the removal of land previously allocated.

Criterion 5b this should be expanded to not only reflect ‘characteristics of the area’ but also to address the need for the development promoted, its contribution to wider benefits and to the evolution and sustainability of existing employment, and include tourism and leisure proposals. Heritage interests should be added to the list of proposals.

Cross referencing and further explanation is required

The 3 lines of approach should be explained further in supporting text. For example, what is to be included in identifying setting, form and character, and what is meant by ‘good accessibility’. These requirements are open to differing interpretation, unintentionally or intentionally and the plan should offer guidance as to a minimum status to be applied. Character for example will be made up of differing elements, built and undeveloped, the quality and maintenance of the public realm, existing trees or landscape structure etc.

Policy S2 Generally supported but further detail is required

Issues arising from inadequacies of the A27 and its local and national importance are acknowledged. Proposals to improve connectivity to and upgrading of that route are supported. Route improvement through the Government’s RIS3 programme is to be welcomed. It is not for the local plan to make proposal for this national route but it can examine and make proposals for the local network connecting to it. Failure to invest in the local road network gives rise to many examples of movement restriction and capacity limitations, that in turn are manifest in added congestion on and around the existing A27.

Chapter 8 should make reference to the role of aviation in transportation. The NPPF (paragraph 106f) requires local planning policies to: “recognise the importance of maintaining a national network of general aviation airfields, and their need to adapt and change over time – taking into account their economic value in serving business, leisure, training and emergency service needs, and the Government’s General Aviation Strategy.”

Chapter 8 should make reference to the role of aviation in transportation. The NPPF (paragraph 106f) requires local planning policies to: “recognise the importance of maintaining a national network of general aviation airfields, and their need to adapt and change over time – taking into account their economic value in serving business, leisure, training and emergency service needs, and the Government’s General Aviation Strategy.” The plan does not make such references and is therefore not compliant with the NPPF and consequently is unsound.

Goodwood Aerodrome is a general aviation airfield.

Moreover, the plan should make provision for how aviation is likely to change in the future, with technological advances, not only in terms of being more accessible to the public for sport and recreation, but also the impact of STEM activities and their important role in future aviation and the advance of drone and similar technologies. Goodwood Airfield is closely and actively engaged with developers of such technology and this is likely to become an increasing sector of the Estate’s business.

General aviation airfields, such as Goodwood, frequently have sufficient land available for new aviation-related facilities (unlike constrained commercial airfields) and provide a major infrastructure resource. Unfortunately, this benefit is often overlooked in planning policies, and many airfields are subjected to threats of redevelopment – for reasons of viability fuelled by a high demand for housing land- and increasing resistance to developments supporting aerodrome business (such as potential noise and disturbance to adjoining residential areas)

Local political reaction to activities at many general aviation airfields has led to the introduction of restrictive planning policies, many related to noise and disturbance and a fear of expansion. Goodwood airfield is no exception, but it has worked with the local community over many years to reach an operational position that provides a balance between continued operation and protection of local amenities. Unfortunately in recent years, particularly as a result of an ill-founded strategic development allocation in the previous local plan, that operational balance is coming under further strain and cannot be further adjusted.

A position is fast approaching where operations at the airfield and motor circuit could be compromised unacceptably by the encroachment of new development, in particular housing development. This was ably demonstrated by the speculative housing proposal north of Madgwick Lane to which both the Estate and planning authority objected for reason, amongst many others, potential noise disturbance, safety concerns and operational constraints which contributed to an unacceptable ‘agent of change’ situation.

The proposal was subject to public inquiry and a finely balanced decision was granted in favour of development by the inspector for reason of the benefits of new housing outweighing the potential harm to Goodwood operations, on grounds that the (unproven) mitigation offered by the developer will be both provided and be effective, and we suggest, a misunderstanding of the true impacts of existing operations.

The Estate will continue to oppose the development for sound planning reasons that the mitigation offered and based on inaccurate evidence, will be inadequate and ineffective in addressing the concerns raise by the Estate and planning authority.

The safeguarding of land for Rolls-Royce expansion is welcomed providing the resultant development offers an equally high standard of building and landscape design, site density and use, and without harm or adverse impact on surrounding land and land uses and the local road network.

The plan must encourage each Parish neighbourhood plan to actively pursue the long-term growth and sustainability of its area, not only planning for a minimum growth, but through further, on the ground, analysis of the sustainability appraisal (AECOM January 2023) to identify additional opportunities that plan for a true and sustainable balance between growth and protection/enhancement.

The plan should confirm that planning for ‘no change’ in a Parish is not acceptable.

The plan must examine strategic infrastructure needs and ensure that enhancement opportunities are identified and protected through appropriate policy designations to ensure new developments do not compromise the ability to deliver. Further development of housing sites immediately adjacent to the A27 should be resisted unless provision is made within the application for appropriate upgrading of that route (this is most important in locations close to existing or potential junctions.)

Local Parishes can assist the supply of land for development needs, “in the right place and of the right kind.”

Development needs should not be confined to housing, although this is expected to be the more significant development form that must be planned and not left to speculation.

All change within a Parish should result in positive enhancement of economic assets, including local need, its sense of place, heritage and environment.

We acknowledge the work done through the sustainability appraisal (AECOM January 2023) and while its general methodology and aim is supported (including the consideration of all HELAA sites) we encourage the Council to work with all Parishes to take that appraisal to a finer grained level to identify short and longer term additional development opportunities, and to firmly identify and plan for areas of little or no change, and environmental and general enhancement that adds positively to the district’s sustainability.

Growth priority in Parishes to the west of Chichester and along the A27 corridor is supported as a strategic priority, providing such growth is supported by deliverable infrastructure to not only meet its direct need, but provide enhancement to the wider community, and should not exacerbate existing issues and infrastructure deficiencies.

Growth generally, and new developments individually, should not be located where future infrastructure improvements will be compromised; this is particularly important in Parishes and on development sites adjoining key strategic routes such as the A27.

Despite important environmental designations, there is greater capacity available within Parishes to the south of the city, that can be identified through a finer grain assessment in Neighbourhood Plans. Many constraints are ‘jumped upon’ and applied too freely in the south to resist even appropriate developments, forcing other areas to accommodate ‘displaced developments’ in less than appropriate locations.

To the north, opportunities exist but are constrained by the proximity of the National Park, and the over-arching landscape and environmental need to protect and enhance its boundaries and environs.

The value of the National Park and its importance Nationally (economically and environmentally) extends further than its physical boundaries. The plan should introduce specific policies that seek to protect land within Parishes adjoining the National Park from inappropriate development which will undermine the importance and significance of the National Park. These peripheral areas of protection and enhancement should be defined through neighbourhood plans.

The plan should explain in greater detail the findings of co-operative working with neighbouring authorities to achieve a more sustainable spatial strategy, that provides a “joined up” spatial vision.

We support generally the work the planning authority has undertaken in co-operation with neighbouring authorities, but consider weaknesses remain in the sustainable distribution of housing and other development needs that reduces the need for commuting and unnecessary travel.

The plan should explain in greater detail the findings of co-operative working with neighbouring authorities to achieve a more sustainable spatial strategy, that provides a “joined up” spatial vision and does not follow a ‘silo-mentality’ of providing only for district needs.

The growth of suburbia, beloved by volume housebuilders, and exacerbated by the Government’s unduly simplistic approach to meeting local housing need quickly, serves only to exacerbate many of the problems the local plan seeks to address.

Evidence of co-operative working and a step-change from ‘more of the same’ in terms of housing provision, will make the Plan more sound. It is essential if the plan area is to be protected from inappropriate speculative housing promoted solely on grounds of housing numbers.

The ability of neighbouring authorities, including the National Park, to provide for appropriate, further growth, including that generated within Chichester District but using employment and service opportunities beyond district boundaries, should be explained and reflected in policies and allocations.

Introduce policy protection for key views.

While Policy NE2 is supported in general we believe there is a need to introduce policies to protect key views, within and across the District. Development should not be permitted in areas where important views will be lost or degraded.

Views of the Cathedral are of particular importance, as are views to and from the Downs.

Long range views from the Downs towards the sea (and vice versa) and views to the Cathedral spire contribute positively to the character and sense of place within the District, whether views are close or distant.

Development should not be permitted in areas where important views will be lost or degraded, or where a new development will intrude an appreciation of the Cathedral (and heart of the city) as being close to and linked to the surrounding countryside.

The form of the city and those links between the countryside and city centre that remain, should be protected from amorphous housing development that degrades Chichester’s special form and character.

The role of Goodwood Estate businesses in transcending many business sectors should be reflected through the Plan and suitable provision for its sustainability made through Plan policies.

Goodwood does not sit easily within the Plan’s definition (and therefore policy provision) of tourism and hospitality as set out in Chapter 7: Employment and Economy. It is a hybrid situation attracting elements of many sectors of the Employment and Economy Chapter, and we request this position is more visibly acknowledged and provided for through the Plan.

There are references within Chapter 10 (policies A9 and A16) but this is focussed on the Goodwood Airfield and Motor Circuit.

The majority of the Goodwood Estate is within the National Park rather than CDC and it is understandable policy should focus on the airfield and circuit. However, it is important the Plan acknowledges and makes provision for the inter-connection of the airfield and motor circuit with the rest of the Estate, and the significant benefits of a "combined Goodwood" to Chichester District and the region.

The Estate welcomes a continuing dialogue with the planning authority to ensure the local plan is an appropriate vehicle to support and enhance the Estate through future years.

Representations we make to earlier parts of the Plan illustrate the economic contribution made by the Estate to the District and this should be reflected in Chapter 7.

The policy should require the adherence to the National Design Guide as a minimum and to local (including specific site) design guides where they exist. Where no design guidance exists or where developments wish to introduce a differing design approach, they must be required to demonstrate why guidance nationally or locally should be set aside.

Policies should require developments to demonstrate with evidence how compliance with guidance is met - it will not be sufficient to rely on generic wording that a development meets the set criteria

Recognition of design principles is supported strongly and the requirements of Policy P1 is welcomed. However, with design and especially good design, be subjective, it is important for the plan to demonstrate how such objectives are to be measured and achieved. The policy references the National Design Guide, but the policy should also reference the role more specific, local design guides can play in delivering high quality local neighbourhoods.