Chichester Local Plan 2021 - 2039: Proposed Submission

Development proposals within or adjacent to defined corridors should not be determined by a strict interpretation of corridor boundaries as shown on the proposals map, but by detailed assessment ‘on the ground’ both of the development site itself and that immediately adjoining, to avoid undermining connectivity and ecological value. The Estate will work with CDC and SDNPA to ensure the delivery of beneficial wildlife corridors and welcomes the opportunity to define their precise location, width and alignment. Corridors defined in principle on Map NE4b are supported subject to detailed discussion around boundary definition as it appears ‘on the ground’

Care should be taken with developer claims of highly increased bio-diversity gains where the starting calculation is a site devoid of or having limited biodiversity due to its former function (e.g intensive agriculture) – the plan should set a minimum standard of gain for all sites reflecting their size and past development form.

The Goodwood Estate relies heavily upon its managed woodland for its business enterprises and for renewable energy. The Estate is progressing a strategy of new woodland planting and a move from ‘cash-crop’ to native woodland, for amenity and environmental benefits. Woodland management is a balance of business and environmental objectives which the Estate has successfully maintained for many years. This regime follows the broad principles set out in this policy, but must be modified to ensure the balanced objectives across the Estate of economic sustainability and environmental enhancement can be evolving in coming years. The Estate has a number of areas designated as “ancient woodland” although these were felled and or replanted during the last war. Development decisions affecting such locations should be considered on the basis of on the ground assessment rather than a reliance on out-dated map designations. The plan should recognise changing woodland practices.

The plan must include policies that add an additional layer of protection to important areas, confirming that open countryside and land outside settlement boundaries (particularly that identified as playing an additional function) does not carry with it a presumption in favour of any development; the new local plan being applied as a whole.

The definition of land as Countryside or land located beyond the settlement edge or boundary, while offering a level of protection, is an insufficient policy constraint to speculative housing justified only by local housing demand. The plan must include policies that add an additional layer of protection to important areas, confirming that open countryside and land outside settlement boundaries (particularly that identified as playing an additional function such as gap or coalescence avoidance) does not carry with it a presumption in favour of any development; the new local plan being applied as a whole.

The fact settlement boundaries have been reviewed through this local plan and further encouraged through the Site Alocation DPD and Neighbourhood Plans is supported.

As set out in the accompanying letter, we ask that the particular needs and character of the Goodwood Estate, particularly the husbandry over centuries which has created the landscape which the plan seeks to protect, are recognised, ideally as a specific policy, through the local plan and its need to evolve for the wider public good of economic growth and environmental protection, is maintained and enhanced. Areas subject to policies A16 and A17 should not be viewed in isolation from other parts of the Estate

The Goodwood Estate lies beyond any settlement boundary although it is close to the settlement of Westhampnett and the northern edge of Chichester. It is a major economic driver in the district as well as being a large, rural business. The special characteristics and role which the Goodwood Estate exhibits should be reflected in the local plan.

Much of the Estate lies within the National Park, but that part remaining in Chichester District has the greatest potential for economic growth as well as decline through ill-placed adjoining development (see Policy A9 and Map 9a).

There is often misplaced conflict between development proposals and other policies of the local plan which seek to protect the environment. We acknowledge and welcome the policies introduced to assist the Estate (policies A16 and A17) but there is a risk those policy areas will be viewed in isolation form the rest of the Estate with which it should be integrated if the plan is to truly assist and protect the Estate and its economic value to the District (and beyond).

We look to the plan to facilitate the delivery of such an initiative, and those which may be similarly proposed elsewhere in the district, by providing supportive policies for necessary infrastructure, additional to Policy NE18 Source Protection Zones.

The Goodwood Estate has its own borehole water supply but suffers from potential water shortages due to a variable water table affected by climatic change. The Estate has embarked on an estate-wide study to improve water supply and distribution across its land holding and to remain ‘water neutral.’ We look to the plan to facilitate the delivery of such an initiative, and those which may be similarly proposed elsewhere in the district, by providing supportive policies for necessary infrastructure, additional to Policy NE18 Source Protection Zones.

The plan should set out clearly the minimum evidence required to demonstrate the lack of noise disturbance and a resultant high-quality of living environment for individual sites.

Policy should acknowledge the impact of new development on existing uses, with reference to the ‘agent of change’ principle (NPPF paragraph 186) being a policy requirement.

The policy is supported, particularly reference to Goodwood Airfield and Goodwood Motor Circuit. We request the Plan ensures all demonstrations of policy compliance are robust. Developers when presenting evidence, are often selective or apply a generic approach to noise assessment not truly representative of existing situations.

The plan should set out clearly the minimum evidence required to demonstrate the lack of noise disturbance and a resultant high-quality of living environment for individual sites.

Policy should acknowledge the impact of new development on existing uses, with reference to the ‘agent of change’ principle (NPPF paragraph 186) being a policy requirement.

A revised housing strategy responsive to constraints is supported. Recently development was promoted in inappropriate locations, without a true acknowledgement of the impacts of the development. The Estate will continue to oppose developments (including proposals north of Madgwick Lane) that harm the estate’s ability to contribute strongly to the local economy, and to ensure the reasonable living conditions of prospective house occupiers are not harmed.

The plan should clarify that a zero figure in Policy H3 does not mean all development opportunities, including windfalls, must be resisted. The zero figure is offered as a strategic guide to housing locations but is not an indication that all forms of housing will be inappropriate.

It is inappropriate to require villages to provide a zero-housing figure. Villages may not be strategic locations for significant additional housing, but it is not unreasonable, through neighbouring planning or individual promotions to support some limited development subject to material considerations and individual merit.

At Lavant for example the Estate has land interests where a small contribution to housing supply could be made – not necessarily as open market housing, but specific quality housing to meet identified needs. In other villages in-fill development might be appropriate.

It will be helpful for the plan to acknowledge the two distinct business areas, which have different requirements in terms of local plan policy.

Accompanying Footnote 51 should be changed to more appropriately reflect the contribution of the Goodwood Estate to the local, regional and National economy.

Local Plan Paragraphs 10.71 – 10.75 The Estate supports the local plan in recognising the importance to the district of the Goodwood Motor Circuit and Airfield. The Estate similarly supports Policies A16 and A17 and changes to Local Plan Maps, A9a, and both A16a. While the airfield and motor circuit occupy the same area of land (Map A16a) it will be helpful for the plan to acknowledge the two distinct business areas, which have different requirements in terms of local plan policy.

Accompanying Footnote 51 should be changed to more appropriately reflect the contribution of the Goodwood Estate to the local, regional and National economy. The Estate has shared with the planning authority the LSE report commissioned to research the contribution of Goodwood (LSE “The Goodwood Estate: Estimating Socioeconomic Contribution January 2020”).

This document providing evidence from all Good businesses over a period of time, should be referenced in paragraph 10.71, rather than the one-off event mentioned. It will be appreciated that if a single event generates a significant local and National turnover of some £60M in 2014, the combined turnover from all Goodwood businesses will be of far greater significance. It is this most important and significant contribution to local, regional and National economics, that must be protected, enhanced and sustained through policies of the local plan. The report is being updated and will be shared with the planning authority when available (expected before the Local Plan Examination)