Chichester Local Plan 2021 - 2039: Proposed Submission

Propose that section 6 of the policy is reworded accordingly in accordance with paragraph 35(c) of the NPPF:

b. “Local community facilities, including village shops, that meet identified needs both within the village, neighbouring villages and surrounding smaller communities, and also the wider needs of the District in relation to the strategic aims of the Plan, and will help make the settlement more self-sufficient in the immediate and long-term; and

c. Small scale employment, tourism or leisure proposals related to sustaining and enhancing existing sites and communities”.

The draft policy makes provision for non-strategic growth beyond the site allocation identified, including small-scale employment, tourism or leisure proposals. We would propose that the wording ‘small-scale’ is not effective as it is not specific, and therefore propose that the policy is reworded accordingly in accordance with paragraph 35(c) of the NPPF:
b. “Local community facilities, including village shops, that meet identified needs both within the village, neighbouring villages and surrounding smaller communities, and also the wider needs of the District in relation to the strategic aims of the Plan, and will help make the settlement more self-sufficient in the immediate and long-term; and
c. Small scale employment, tourism or leisure proposals related to sustaining and enhancing existing sites and communities”.
It should be recognised that whilst clearly the majority of major development will be directed towards main settlement hubs, that the unique characteristics of the District should be considered in terms of offering further specific development opportunities to sustain the economic viability and housing capacity required.
The Plan sets out a requirement to consider in the next review, the allocation of a strategic new settlement, in order to meet housing need. As such, development which is sustainable and capable of contributing towards development needs in the shorter term should be considered favourably in line the NPPG.

Premier suggests Draft Policy NE5 is amended to make specific reference to the completion of the ‘relevant Defra Biodiversity Metric 3.1 (or equivalent)’ as part of the Biodiversity Appraisa

Premier agree with the premise of Draft Policy NE5 and the acknowledge the 10% biodiversity net gain requirement is consistent with the Environment Bill 2021 which requires developments to achieve a minimum 10% biodiversity net gain from November 2023 (exact date TBC).
Premier recognise the unique qualities of the Chichester Marina’s location and rural countryside setting, and considers that the protection of the environmental and landscape quality is extremely important. Premier acts as the long-term manager and steward of the Site and seeks to actively and appropriately manage users and the environmental setting for the benefit of existing wildlife and in in the interests of protecting key tidal habits and enhancing biodiversity.
Premier suggests Draft Policy NE5 is amended to make specific reference to the completion of the ‘relevant Defra Biodiversity Metric 3.1 (or equivalent)’ as part of the Biodiversity Appraisal requirement in the interests of soundness to ensure the policy wording is effective and measurable, and also consistent with national policy in line with paragraph 35 (c and d) of the NPPF.

Suggest that the policy wording is amended as follows to include employment uses which are not prescriptive to marine uses only:
“The council will continue to work with partner organisations and authorities to protect and enhance the Plan's coastal areas, including around Chichester Harbour, Pagham Harbour, Medmerry Compensatory Habitat and the open coast, whilst ensuring they continue to provide an important recreational, economic and environmental resource.
The council will support:
• ongoing habitat protection, restoration, enhancement and creation, including both compensatory and new coastal and wetland habitats; and opportunities to connect coastal and freshwater habitats and floodplain habitats at a catchment scale to facilitate wider nature recovery;
• careful location, design and review of flood defences to adapt to climate change and sea level rise, to reduce coastal squeeze and support natural processes;
• appropriate leisure and recreational uses, including water-based activities, and marine and non-marine related employment uses which meet local needs, complement existing employment, tourism and leisure uses and or provide a public benefit, including those which require direct access to water; where these uses avoid adverse environmental impacts”

Premier is pleased to see a recognition within the Plan for support for leisure and recreational use and water-based activities in the coastal areas, and marine employment uses.
Noting the challenges Marinas now face, as mentioned above, we would suggest that the policy wording is amended as follows to include employment uses which are not prescriptive to marine uses only:
“The council will continue to work with partner organisations and authorities to protect and enhance the P’an's coastal areas, including around Chichester Harbour, Pagham Harbour, Medmerry Compensatory Habitat and the open coast, whilst ensuring they continue to provide an important recreational, economic and environmental resource.
The council will support:
• ongoing habitat protection, restoration, enhancement and creation, including both compensatory and new coastal and wetland habitats; and opportunities to connect coastal and freshwater habitats and floodplain habitats at a catchment scale to facilitate wider nature recovery;
• careful location, design and review of flood defences to adapt to climate change and sea level rise, to reduce coastal squeeze and support natural processes;
• appropriate leisure and recreational uses, including water-based activities, and marine and non-marine related employment uses which meet local needs, complement existing employment, tourism and leisure uses and or provide a public benefit, including those which require direct access to water; where these uses avoid adverse environmental impacts”.

Premier welcome the Council’s housing target for the plan area is to provide for at least 10,350 dwellings (equivalent to 575 dwellings per annum) to be delivered in the period 2021-2039 including 310 non-strategic Parish housing requirements and 657 windfall site allowances. However this is below the housing requirement of 13,734 (equivalent to 763 dwellings per annum) derived from the Governments Standard Method for the same period, resulting in a significant shortfall of 3,384 dwellings, notwithstanding the fact that the Council are “now unable to accommodate any unmet need from the part of the South Downs National Park within Chichester District” (as stated at supporting paragraph 5.1 to Policy H1) which has potential Duty to Co-operate implications.

In respect to five year housing land supply (5YHLS) considerations, it is noted CDC’s ‘Chichester Local Plan Area – Five Year Housing Land Supply 2022-2027 (Updated Position at 1 April 2022) statement identifies a potential housing supply of 3,174 net dwellings over the period 2022-2027. This compares with an identified housing requirement of 3,350 net dwellings. This results in a shortfall of 176 net dwellings, equivalent to 4.74 years of housing supply. The Council can therefore not demonstrate a 5YHLS as confirmed by recent appeal decisions , .

In the interests of maximising housing delivery and satisfying the Council’s objectively assessed housing needs, Policy H1 should be revised to state the housing requirement figure derived by the Government’s Standard Method so as to ensure the policy is “effective” and the new Local Plan has been “positively prepared” in accordance with paragraph 35 (a and c) of the NPPF.

The draft policy makes provision for non-strategic growth beyond the site allocation identified, including small-scale employment, tourism or leisure proposals. We would propose that the wording ‘small-scale’ is not effective as it is not specific, and therefore propose that the policy is reworded accordingly in accordance with paragraph 35(c) of the NPPF:
b. “Local community facilities, including village shops, that meet identified needs both within the village, neighbouring villages and surrounding smaller communities, and also the wider needs of the District in relation to the strategic aims of the Plan, and will help make the settlement more self-sufficient in the immediate and long-term; and
c. Small scale employment, tourism or leisure proposals related to sustaining and enhancing existing sites and communities”.
It should be recognised that whilst clearly the majority of major development will be directed towards main settlement hubs, that the unique characteristics of the District should be considered in terms of offering further specific development opportunities to sustain the economic viability and housing capacity required.
The Plan sets out a requirement to consider in the next review, the allocation of a strategic new settlement, in order to meet housing need. As such, development which is sustainable and capable of contributing towards development needs in the shorter term should be considered favourably in line the NPPG.

Premier agree with the premise of Draft Policy NE5 and the acknowledge the 10% biodiversity net gain requirement is consistent with the Environment Bill 2021 which requires developments to achieve a minimum 10% biodiversity net gain from November 2023 (exact date TBC).
Premier recognise the unique qualities of the Chichester Marina’s location and rural countryside setting, and considers that the protection of the environmental and landscape quality is extremely important. Premier acts as the long-term manager and steward of the Site and seeks to actively and appropriately manage users and the environmental setting for the benefit of existing wildlife and in in the interests of protecting key tidal habits and enhancing biodiversity.
Premier suggests Draft Policy NE5 is amended to make specific reference to the completion of the ‘relevant Defra Biodiversity Metric 3.1 (or equivalent)’ as part of the Biodiversity Appraisal requirement in the interests of soundness to ensure the policy wording is effective and measurable, and also consistent with national policy in line with paragraph 35 (c and d) of the NPPF.