Chichester Local Plan 2021 - 2039: Proposed Submission

Premier understands and supports the need to protect employment land for the wider viability and economic success of the district. Indeed the objectives of maintaining “a flexible supply of employment land and premises” and the retention of “suitable employment sites and encouraging their refurbishment, upgrading and intensification to meet modern business needs” are supported by Premier.
Premier would however stress the importance of recognising leisure and community uses in employment areas which is not currently acknowledged. Diversification for leisure uses is particularly relevant to waterside locations, as set out below in respect to Policy NE11, relating to suitable development at the Coastal area.
Supporting paragraph (7.17) states:
“Given the limited opportunities for employment uses with direct access to the coast, and reflecting the Chichester Harbour Conservancy Management Plan’s planning principles, particular scrutiny will be given to the marketing evidence for marine related employment sites with the aim of preserving these uses”.
The Chichester Harbour Conservancy Management Plan is not a statutory Development Plan Document, and nor is it considered to be a robust policy approach. Indeed, Premier made representations to a number of elements in this Plan through the consultation period (see appended to these representations). Fundamentally, this Plan should not be cross-referenced as it is not in compliance with national policy, and therefore is not a sound policy basis.
The definition of ‘marine-related employment sites’ could be interpreted so as to prevent the flexibility that is promoted by much of the supporting text to Policy E2 and which is required in a changing marine industry. Interpreted too narrowly, this paragraph will have the opposite effect to that intended. Lengthy marketing periods risk leaving a property empty and creating no employment when a change of use would create employment and further economic benefits.
Paragraph 7.17 should recognise the relevance of complimentary uses which support the economic viability of marinas. These include not only leisure and tourism and but also other uses to be able to “accommodate needs not anticipated in the plan, allow for new and flexible working practices (such as live-work accommodation), and to enable a rapid response to changes in economic circumstances” as per paragraph 81 of the NPPF.
Paragraph 83 of the NPPF requires that “Planning policies and decisions should recognise and address the specific locational requirements of different sectors”. Chichester Marina can also be argued to form part of the rural economy, and the NPPF (paragraph 84) supports “the development of and diversification of… land-based rural businesses… sustainable rural tourism and leisure developments which respect the character of the countryside”.
The policy supporting text wording for paragraph 7.17 should therefore be amended to “marine related and supporting and ancillary uses” in recognition of this, and in accordance with the NPPF, Policy NE11 and paragraph 7.17 of the Plan.
Dealing with the Policy text, Premier considers that it is only appropriate for changes from employment to residential use to require demonstration that properties are no longer suitable for employment uses. Changes of use which retain or enhance employment should be encouraged as this will provide employment sites with the flexibility they require to respond to market changes and prevent loss of employment.
In the interest of diversifying employment uses and making the policy more effective in accordance with paragraph 35© of the NPPF, the policy should therefore be amended accordingly:
“Existing employment sites will be retained to safeguard their contribution to the local economy. Changes of use which retain or increase employment will be supported. Employment uses other than those in use classes E(g), B2 or B8 which require planning permission, will be permitted on existing employment sites provided they are of a similar character in terms of providing jobs, the skills they require and their contribution to long-term economic growth. Where the proposed alternative use is a main town centre use, the sequential test set out in national policy must be met.
Where planning permission is required for alternative non-employment uses on land or floorspace currently in or last used for employment generating uses, it must be demonstrated (in terms of the evidence requirements in Appendix C) that the site is no longer required and is unlikely to be re-used or redeveloped for employment uses to meet future demand”.

Premier understands and supports the need to protect employment land for the wider viability and economic success of the district. Indeed the objectives of maintaining “a flexible supply of employment land and premises” and the retention of “suitable employment sites and encouraging their refurbishment, upgrading and intensification to meet modern business needs” are supported by Premier.
Premier would however stress the importance of recognising leisure and community uses in employment areas which is not currently acknowledged. Diversification for leisure uses is particularly relevant to waterside locations, as set out below in respect to Policy NE11, relating to suitable development at the Coastal area.
Supporting paragraph (7.17) states:
“Given the limited opportunities for employment uses with direct access to the coast, and reflecting the Chichester Harbour Conservancy Management Plan’s planning principles, particular scrutiny will be given to the marketing evidence for marine related employment sites with the aim of preserving these uses”.
The Chichester Harbour Conservancy Management Plan is not a statutory Development Plan Document, and nor is it considered to be a robust policy approach. Indeed, Premier made representations to a number of elements in this Plan through the consultation period (see appended to these representations). Fundamentally, this Plan should not be cross-referenced as it is not in compliance with national policy, and therefore is not a sound policy basis.
The definition of ‘marine-related employment sites’ could be interpreted so as to prevent the flexibility that is promoted by much of the supporting text to Policy E2 and which is required in a changing marine industry. Interpreted too narrowly, this paragraph will have the opposite effect to that intended. Lengthy marketing periods risk leaving a property empty and creating no employment when a change of use would create employment and further economic benefits.
Paragraph 7.17 should recognise the relevance of complimentary uses which support the economic viability of marinas. These include not only leisure and tourism and but also other uses to be able to “accommodate needs not anticipated in the plan, allow for new and flexible working practices (such as live-work accommodation), and to enable a rapid response to changes in economic circumstances” as per paragraph 81 of the NPPF.
Paragraph 83 of the NPPF requires that “Planning policies and decisions should recognise and address the specific locational requirements of different sectors”. Chichester Marina can also be argued to form part of the rural economy, and the NPPF (paragraph 84) supports “the development of and diversification of… land-based rural businesses… sustainable rural tourism and leisure developments which respect the character of the countryside”.
The policy supporting text wording for paragraph 7.17 should therefore be amended to “marine related and supporting and ancillary uses” in recognition of this, and in accordance with the NPPF, Policy NE11 and paragraph 7.17 of the Plan.
Dealing with the Policy text, Premier considers that it is only appropriate for changes from employment to residential use to require demonstration that properties are no longer suitable for employment uses. Changes of use which retain or enhance employment should be encouraged as this will provide employment sites with the flexibility they require to respond to market changes and prevent loss of employment.
In the interest of diversifying employment uses and making the policy more effective in accordance with paragraph 35© of the NPPF, the policy should therefore be amended accordingly:
“Existing employment sites will be retained to safeguard their contribution to the local economy. Changes of use which retain or increase employment will be supported. Employment uses other than those in use classes E(g), B2 or B8 which require planning permission, will be permitted on existing employment sites provided they are of a similar character in terms of providing jobs, the skills they require and their contribution to long-term economic growth. Where the proposed alternative use is a main town centre use, the sequential test set out in national policy must be met.
Where planning permission is required for alternative non-employment uses on land or floorspace currently in or last used for employment generating uses, it must be demonstrated (in terms of the evidence requirements in Appendix C) that the site is no longer required and is unlikely to be re-used or redeveloped for employment uses to meet future demand”.

Proposes ‘appropriate mitigation’ [as per policy NE6] has regard for existing residents and the commercial viability of businesses, and is proportionate to the scale of development proposed to ensure it doesn’t render development unviable or overburden.

Premier agree with the premise of Draft Policy NE6 and recognise the need to address water and nutrient neutrality issues. That said, Premier acknowledge the practical difficulties in guaranteeing nutrient neutral position for the lifetime of the development and suggest the ‘appropriate mitigation’ has regard for existing residents and the commercial viability of businesses and is proportionate to the scale of development proposed to ensure this doesn’t not render development unviable and to avoid overburdening local residents and businesses.
Premier recognise the unique qualities of the Chichester Marina’s location and the areas’ international and national designated habitats. With this is mind and factoring in Premier’s responsibilities as the long-term manager and steward of the Site, Premier is committed to protecting Chichester Marina’s sensitive habitats in the interests of protecting local wildlife.