Chichester Local Plan 2021 - 2039: Proposed Submission

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Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy P2 Local Character and Distinctiveness

Representation ID: 4293

Received: 15/03/2023

Respondent: The Goodwood Estates Company Limited

Agent: HMPC Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Criteria listed should go further to reference design guides that indicate the key elements of an area that define its character and which are desirable to maintain and enhance

Change suggested by respondent:

In addition to the generic requirements set out in criteria 1 – 9, the policy should reference design guides that indicate the key elements of an area that define its character and which are desirable to maintain and enhance.

This policy should correlate with Policies P3 Density, P4 layout and Access, P5 Spaces, P6 Amenity, P7 Extensions, and P8 Materials and detail. All are interconnected and the plan should indicate that a policy cannot be applied in isolation, but as a whole.

Full text:

Policies supporting local character and distinctiveness is supported but the criteria listed should go further to reference design guides that indicate the key elements of an area that define its character and which are desirable to maintain and enhance


Our response:

Objection and proposed changes noted. The Council agree that it would be helpful to make reference to other design guidance, but not in multiple design policies, and hence it is considered that this point will be addressed by making reference to local level design guides/codes via proposed amendments to Policy P1.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy P9 The Historic Environment

Representation ID: 4295

Received: 15/03/2023

Respondent: The Goodwood Estates Company Limited

Agent: HMPC Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The plan should acknowledge the role the historic environment plays in the economic vitality of the District. It should require through any heritage assessment accompanying a development proposal affecting a heritage asset, an analysis of the contribution of that asset individually and collectively to the local economy.

Heritage assessments frequently focus on the design and fabric of the asset and its immediate setting. Less frequent is an assessment considering the individual role of the asset in the distinctiveness of a settlement which makes it attractive to visitors and encourages visitor spend.

Change suggested by respondent:

The plan should require through any heritage assessment accompanying a development proposal affecting a heritage asset, an analysis of the contribution of that asset individually and collectively to the local economy; assessing contribution before and after the development proposed .

Full text:

The plan should acknowledge the role the historic environment plays in the economic vitality of the District. It should require through any heritage assessment accompanying a development proposal affecting a heritage asset, an analysis of the contribution of that asset individually and collectively to the local economy.

Heritage assessments frequently focus on the design and fabric of the asset and its immediate setting. Less frequent is an assessment considering the individual role of the asset in the distinctiveness of a settlement which makes it attractive to visitors and encourages visitor spend.


Our response:

The plan does acknowledge the important role that the historic environment plays in relation to the local economy, as is clearly set out in paragraph 6.48. However, it is considered that the requested requirement in relation to appraising the economic aspects of development affecting a heritage asset would be inconsistent with national policy, as the NPPF specifically states in paragraph 194 that with respect to the information which can be required in relation to such applications:
“The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance.”
Consequently, it appears clear that the level of information needs to be focused on the issue of significance and it would be unreasonable to require a more extensive assessment.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy P13 Registered Parks and Gardens

Representation ID: 4296

Received: 15/03/2023

Respondent: The Goodwood Estates Company Limited

Agent: HMPC Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Recognition of the importance of Goodwood House and Park is welcomed, but the value of the Estate to the District (and indeed the National Park) goes well beyond the designated parkland. The Estate is an inter-linked body, where individual elements rely on other parts, activities or events to be sustainable. The Estate is embarked on a long-term strategy to both restore original features and to introduce new, that will continue the evolution of one of the Nation’s significant parklands.

Change suggested by respondent:

This policy is welcomed but we request the supporting paragraphs are revised to reflect the principles set out in the accompanying letter.

Full text:

Recognition of the importance of Goodwood House and Park is welcomed, but the value of the Estate to the District (and indeed the National Park) goes well beyond the designated parkland. The Estate is an inter-linked body, where individual elements rely on other parts, activities or events to be sustainable. The Estate is embarked on a long-term strategy to both restore original features and to introduce new, that will continue the evolution of one of the Nation’s significant parklands.

Attachments:


Our response:

Objection and comments noted. The Council certainly respects the importance of Goodwood House as well as the parkland. However, this policy is specifically focused on Registered Parks and Gardens, and hence the policy and supporting text needs to be focused on that issue, rather than encompassing the wider issues referred to in the representation.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

6.83

Representation ID: 4297

Received: 15/03/2023

Respondent: The Goodwood Estates Company Limited

Agent: HMPC Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Goodwood Airfield and Motor Circuit offer a large open area close to Chichester City that is a valuable local recreation source. In line with Chapter 8 of the NPPF we request that the role of the circuit, airfield and the open space and recreation opportunities it offers is reflected in the local plan.

Change suggested by respondent:

In line with Chapter 8 of the NPPF we request that the role of the circuit, airfield and the open space and recreation opportunities it offers is reflected in the local plan.

Full text:

Goodwood Airfield and Motor Circuit offer a large open area close to Chichester City that is a valuable local recreation source. In line with Chapter 8 of the NPPF we request that the role of the circuit, airfield and the open space and recreation opportunities it offers is reflected in the local plan.

Chapter 6 focusses on “traditional sport, recreation and open space provision,” but other important recreation sources, equally important for place-making, health and well-being should also be acknowledged and provisioned through Chapter 6. Both aviation and motor activities are recognised as sport and recreation by Sport England and the large open areas used can, and do, offer opportunities to host a variety of non-aviation and motor community and sporting activities and access to open space and landscape, whether actual or perceived, free or controlled.


Our response:

No specific open spaces are mentioned by name in paragraph 6.83. If Goodwood were to be mentioned then all would need to be mentioned and this is unnecessary.

Paragraph 8 of the NPPF does not state that open spaces need to be named in the Local Plan.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

5.11

Representation ID: 4298

Received: 15/03/2023

Respondent: The Goodwood Estates Company Limited

Agent: HMPC Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The recognition of longer-term growth requirements is welcomed although it should be stated that there exist significant material constraints that are unlikely to be removed through subsequent plans, but are not identified. These constraints should be identified now to provide confidence for investment going forward, and to local communities. A review of the plan could be in as little as 5 years. For example, areas designated for open green or blue space and well used, key view lines, or areas preventing coalescence, should have a degree of permanency attached, to offer a presumption against their early release in subsequent plans.

Change suggested by respondent:

Long term environmental, economic and social constraints to development, should be identified and protected through policies that can be rolled-forward through subsequent reviews of the local plan.

Full text:

The recognition of longer-term growth requirements is welcomed although it should be stated that there exist significant material constraints that are unlikely to be removed through subsequent plans, but are not identified. These constraints should be identified now to provide confidence for investment going forward, and to local communities. A review of the plan could be in as little as 5 years. For example, areas designated for open green or blue space and well used, key view lines, or areas preventing coalescence, should have a degree of permanency attached, to offer a presumption against their early release in subsequent plans.


Our response:

The bullet points in para 5.14 set out the potential considerations that will influence longer term growth options, which includes consideration of constraints.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H4 Affordable Housing

Representation ID: 4299

Received: 15/03/2023

Respondent: The Goodwood Estates Company Limited

Agent: HMPC Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The policy indicates commuted sums will be acceptable only in exceptional circumstances, and is supported. However, it would be helpful if the plan offers guidance on the circumstances where a site might be considered unsuitable for affordable housing. This is not a decision which should be left to the developer. Where commuted sums are obtained it will be helpful to the community to understand where those sums will be spent and in what timescale, to avoid the potential for all sites suitable for affordable housing in the areas where they are needed, being used in preference for open market housing.

Change suggested by respondent:

The plan should offer guidance on those circumstances which might dictate a site being considered unsuitable for affordable housing provision.

Where commuted sums are obtained it will be helpful to the community to understand where those sums will be spent and in what timescale.

Full text:

The policy indicates commuted sums will be acceptable only in exceptional circumstances, and is supported. However, it would be helpful if the plan offers guidance on the circumstances where a site might be considered unsuitable for affordable housing. This is not a decision which should be left to the developer. Where commuted sums are obtained it will be helpful to the community to understand where those sums will be spent and in what timescale, to avoid the potential for all sites suitable for affordable housing in the areas where they are needed, being used in preference for open market housing.


Our response:

While such an amendment could provide greater clarity, it is not considered necessary to render the plan sound; the plan should provide a framework for decision making, rather than a precise set of prescriptions akin to legislation. In addition, it could actually increase the likelihood of such exceptions being utilised if they were clearly spelled out, which would be counterproductive. In addition, it is not possible to provide greater clarity at this stage in terms of when and where those contributions will be spent, as this depends on the size and timing of contributions. The council also does not have a housebuilding arm like some councils, and so does not have a pipeline of sites already identified which it is looking to develop for affordable housing schemes

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H7 Rural and First Homes Exception Sites

Representation ID: 4300

Received: 15/03/2023

Respondent: The Goodwood Estates Company Limited

Agent: HMPC Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Goodwood Estate has traditionally provided housing for its workers to run estates traditionally and its associated farming practices.

With a change of role and practice, the Estate would like to explore the possibility of providing new housing for staff employed in its hospitality and non agricultural and forestry ventures. Such an initiative is frustrated by general rural housing policies.

Change suggested by respondent:

Criterion 1 should acknowledge local need as including the needs of large estates seeking to provide for staff accommodation, as these are different generally from the provision made through Policy H9.

Full text:

The Goodwood Estate has traditionally provided housing for its workers. Like many other estates as fewer staff were employed to run estates and its farming practices, Goodwood sold off properties for welcome income used to sustain and maintain the Estate as a whole.

With income generated by its wide-range of world-renowned activities, the Estate has in recent years (Covid excepted) been able to reinvest and buy back land and buildings previously sold off (the former sculpture park being a recent example, and the Goodwood Hotel previously). In the same vein the Estate would like to explore the possibility of providing new housing for staff, particularly those employed in its hospitality and non agricultural and forestry ventures. Such an initiative is frustrated by general rural housing policies.


Our response:

Accommodation for employees of the Goodwood Estate would best sit under policy H9 as occupation would be linked to the location of employment. The policy supports provision of employment for ‘rural based enterprise’, of which the Goodwood Estate could be considered. Applications for accommodation in this area would be considered on a case by case basis and a needs study required.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.10

Representation ID: 4301

Received: 15/03/2023

Respondent: The Goodwood Estates Company Limited

Agent: HMPC Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

A previous strategic development allocation has potentially eroded the physical separation of Chichester and Westhampnett, but opportunity remains to ensure some separation or sense of place to be retained or re-established. Removal of land from the former allocation (Policy A9) is welcomed and supported fully but the land should be offered long term protection through a specific designation.

Change suggested by respondent:

Land removed from the former strategic allocation as identified through Policy A9 should be formally designated as land unsuitable for housing development due to the material constraints applicable to it. The land should be identified as an important open area

Full text:

A previous strategic development allocation has potentially eroded the physical separation of Chichester and Westhampnett, but opportunity remains to ensure some separation or sense of place to be retained or re-established. Removal of land from the former allocation (Policy A9) is welcomed and supported fully but the land should be offered long term protection through a specific designation.


Our response:

Designation of areas as either landscape gaps and/or potentially important open space, including local green space, will be designated as part of a subsequent Site Allocations DPD or through a relevant neighbourhood plan.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.11

Representation ID: 4302

Received: 15/03/2023

Respondent: The Goodwood Estates Company Limited

Agent: HMPC Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The plan does not provide sufficient long term protection for open areas that perform strategic gap functions or represent important open areas

Change suggested by respondent:

The strategic gap Assessment should be revisited as a matter of urgency and key gaps identified through the local plan and protected by robust policy. Land north of Madgwick Lane, Westhampnett should be so identified and included. The land is unsuitable for housing and the removal of land from allocation is supported.

Full text:

The plan does not provide sufficient long term protection for open areas that perform strategic gap functions or represent important open areas


Our response:

The assessment considered a small range of potential areas for future local landscape gaps rather than seeking to define strategic gaps.

Designation of areas as either landscape gaps and/or potentially important open space, including local green space, will be designated as part of a subsequent Site Allocations DPD or through relevant neighbourhood plan.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE3 Landscape Gaps between settlements

Representation ID: 4303

Received: 15/03/2023

Respondent: The Goodwood Estates Company Limited

Agent: HMPC Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

While it is acknowledged that precise boundaries of gaps will be defined through a Site Allocations DPD or Neighbourhood Plans, the Plan should provide guidance on strategically important areas that should be included within any such designation. Land North of Madgwick Lane is a strategic gap which should be protected.

Change suggested by respondent:

The Plan should provide guidance on strategically important areas that should be included within landscape gap designations

Full text:

While it is acknowledged that precise boundaries of gaps will be defined through a Site Allocations DPD or Neighbourhood Plans, the Plan should provide guidance on strategically important areas that should be included within any such designation. Land North of Madgwick Lane is a strategic gap which should be protected.


Our response:

No areas have been identified as being of strategic importance but landscape gaps will be designated as part of a subsequent Site Allocations DPD or through relevant neighbourhood plans.

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