Chichester Local Plan 2021 - 2039: Proposed Submission

Suggests policy is improved and made clearer by replacing 'safeguard' with 'allocate' the land for employment development.

Rolls-Royce Motor Cars (R-RMC) is highly supportive of the inclusion of Land East of Rolls-Royce (Policy A21) as a site for R-RMC to deliver its vision for the strategic expansion of the existing headquarters of R-RMC at Goodwood (R-RMC Goodwood). R-RMC considers the policy is sound in principle, but one minor modification is suggested to provide greater clarity.

Justification for Policy A21

As a prestigious global manufacturer of luxury motor cars and a major employer within Chichester District, R-RMC’s proposed expansion would signify a considerable investment into the local, district and wider UK economy.

Since its arrival in 2003, the Goodwood facility has expanded incrementally and now fully utilises the capacity of the existing site for its manufacturing needs. As part of its continued operations, and to improve its logistics processes, R-RMC requires an increase in manufacturing space to meet manufacturing needs and remain responsive to an evolving market. The proposed expansion would potentially generate additional employment opportunities and further contribute to the local and wider economy, thus helping to strengthen Chichester’s economic outlook at a time of national economic uncertainty. R-RMC has made previous representations through the Local Plan process seeking recognition of the importance of this expansion and is pleased that the Council acknowledges these needs through the inclusion of draft Policy A21.

The National Planning Policy Framework (NPPF) has sustainable development at its heart, including economic components. Moreover, paragraph 81-85 make it clear that supporting economic growth and competitiveness is of great importance in the planning system.

As part of these representations, R-RMC has prepared a report demonstrating the suitability, availability and achievability of the proposed expansion site. The report highlights R-RMC’s commitment to delivering an expansion within the Plan period, with a suite of technical assessments already undertaken and progress being made towards submission of a planning application later this year. The report, which should be read in conjunction with these representations, demonstrates that the site is in a suitable and sustainable location for development and that there are no significant constraints that would preclude development. R-RMC is confident that, through its emerging proposals, there exists an opportunity to provide development sensitively and with an enhanced landscape setting to satisfy the requirements of the draft policy.

Notwithstanding the above, R-RMC suggest the Policy is improved and made clearer by replacing ‘safeguard’ with ‘allocate’ the land for employment development. It is acknowledged that, at earlier stages of the Local Plan process, there was more limited detail available regarding the scope, extent and timescales for delivering an expansion, and it was appropriate at the time to consider the site for safeguarding for future needs. However, as outlined above and in the submitted report, R-RMC is developing its emerging proposals, has undertaken a series of technical assessments and intends to submit a planning application in 2023 (and certainly prior to the adoption of the new Local Plan). The Council can therefore be satisfied that there is more certainty regarding the intention to progress with an expansion of R-RMC Goodwood, certainly within the next five years.

Based on this, we suggest that there is an opportunity to reflect this position through an amendment to draft Policy A21. It is understood that the employment development is ‘not included in the [Plan’s] employment figures as it relates specifically to future operational needs for Rolls-Royce rather than to the broader employment requirement identified in the HEDNA’. However, the site has been tested through the Local Plan process and is considered through the HELAA and the wider Local Plan evidence base (e.g., the SA the Chichester Transport Study). It has been tested the same as an allocation and it would provide greater clarity and consistency to describe it as such. Notwithstanding this, it is also recognised that the policy as set out does not prevent R-RMC coming forward with its proposals subject to meeting the stated criteria.

In summary R-RMC supports draft Policy A21 but suggests it is amended to ‘allocate’ the site to ensure that the policy is fully effective and sound.

Rolls-Royce Motor Cars (R-RMC) acknowledges the proposed allocation of land bounded by Old Arundel Road and the A27 Westhampnett Bypass for the delivery of 265 homes. The site is located just south of the existing and proposed expanded R-RMC Goodwood site, which indicates that there may be interrelationships between the two sites as they come forward for development. R-RMC is committed to working with the Council to ensure that any cumulative impact is assessed appropriately, and any required mitigation reasonably and proportionately shared, reflecting any such cumulative impact.

Rolls-Royce Motor Cars (R-RMC) acknowledges the updated allocation of the Tangmere Strategic Development Location (SDL). The site is located just south of the existing and proposed expanded R-RMC Goodwood site, which indicates that there may be interrelationships between the two sites as they come forward for development. R-RMC is committed to working with the Council to ensure that any cumulative impact is assessed appropriately, and any required mitigation reasonably and proportionately shared, reflecting any such cumulative impact.

Further clarity could be provided to highlight where this requirement will not apply. This could include employment development on bespoke sites where provision is for a single party and in connection with specific and bespoke employment activities.

Whilst Rolls-Royce Motor Cars (R-RMC) broadly supports the principle of Policy E2 as drafted, R-RMC objects regarding the justification and effectiveness of the requirement for new employment development to ‘provide for an appropriate range of unit types and sizes to accommodate the needs of start-up and move on businesses within the plan area’. While the draft policy states that this will only be sought ‘where feasible’, R-RMC considers that further clarity could be provided to highlight where this requirement will not apply. This could include employment development on bespoke sites where provision is for a single party and in connection with specific and bespoke employment activities.

Rolls-Royce Motor Cars (R-RMC) supports the Council’s commitment to securing safe, sustainable, connected and accessible transport options in the district. This reflects national objectives and ensures that development is designed to consider and mitigate its transport impacts. R-RMC wishes to encourage the Council to ensure that transport mitigation sought from development is proportionate, reasonable and directly related to the development. While cumulative impact is an important consideration, individual sites should not be burdened with a requirement to mitigate all cumulative impact singlehandedly. This would be inconsistent with national policy and the planning obligations tests set out in Regulation 122 of the Community Infrastructure Levy Regulations 2010.

Amend policy to more clearly support flexibility in individual circumstances where the adopted parking standards may not be the most appropriate solution.

Rolls-Royce Motor Cars (R-RMC) supports the Council’s commitment to securing adequate car and cycle parking provision from development in the district. Draft Policy T4 (Parking Provision) requires development to deliver parking in accordance with the West Sussex Parking Standards Guidance (2020) or any subsequent standards.

While the principle of this approach is recognised, it is important that the Local Plan clearly sets out that the adopted Parking Standards should be seen as a starting point for assessing parking needs in a development. It is acknowledged that the Parking Standards guidance sets out they are an “initial guide for developers (paragraph 6.3 West Sussex Guidance on Parking at New Developments September 2020) and the Local plan policy should align with this approach. It is also important that the policy retains some flexibility to account for individual circumstances and nature of operations where a different approach is more appropriate. This may include circumstances such as the delivery of the bespoke R-RMC expansion site, where parking provision for specific employment needs may differ. This would not negate the requirement to prepare and provide a Travel Plan as appropriate.

R-RMC suggests that the draft policy is amended to more clearly support flexibility in individual circumstances where the adopted Parking Standards may not be the most appropriate solution. This would make the draft policy effective and sound.

Rolls-Royce Motor Cars (R-RMC) supports the principle of draft Policy P7 which supports alterations and extensions where this does not result in over-intensification or cause harm to the character of the local area. R-RMC consider this draft policy a positive approach to delivering Section 11 (Making effective use of land) of the National Planning Policy Framework (NPPF). Paragraph 120 of the NPPF encourages local authorities to ‘promote and support the development of under-utilised land and buildings’. This policy is therefore considered justified, effective and sound.

The policy and/or supplementary text could acknowledge that some green infrastructure (including public rights of way) may need to be rerouted or re-provided to facilitate development to meet the area’s needs. This flexibility is provided in certain site-specific policies (such as Goodwood expansion site policy A21) but could be reflected in this policy to apply to relevant sites, subject to appropriate consents and sensitive design considerations.

Rolls-Royce Motor Cars (R-RMC) supports the principle of draft Policy P14 which sets out the green infrastructure requirements and expectations from new development. R-RMC recognises the positive impact that green infrastructure provides with respect to health and wellbeing, biodiversity, climate change resilience and other social, economic and environmental factors.

However, as part of this policy, proposals must demonstrate that a stringent list of criteria have been addressed, including but not limited to ensuring that proposals ‘do not lead to the dissection of the linear network of cycle ways, public rights of way, bridleways and ecological corridors’.

While the principle of this position is understood and supported, R-RMC considers that the policy and/or supplementary text could acknowledge that some green infrastructure (including public rights of way) may need to be rerouted or re-provided to facilitate development to meet the area’s needs. This flexibility is provided in certain site-specific policies (such as Goodwood expansion site policy A21) but could be reflected in this policy to apply to relevant sites, subject to appropriate consents and sensitive design considerations.

The policy should be updated to reflect and be consistent with national policy, specifically paragraph 180(a) of the NPPF. This should be set out as a hierarchy, where development will be permitted where there is no adverse impact to Strategic Wildlife Corridors. However, where this is not possible, proposals will be expected to mitigate or, as a last resort, compensate for any adverse impact.

R-RMC supports the principle of this draft policy, which seeks to protect the district’s network of Strategic Wildlife Corridors. R-RMC recognises the important role these corridors play in facilitating wildlife connectivity and movement.

However, draft Policy NE4 specifically states that ‘development will only be permitted where it would not lead to an adverse effect upon the ecological value, function, integrity and connectivity’ of these corridors. Rolls-Royce Motor Cars (R-RMC) supports the principle and overall aim of this policy, but considers the Council’s approach to be rigid, unjustified and inconsistent with national policy.

Paragraph 180(a) of the National Planning Policy Framework (NPPF) indicates that planning permission should be refused where ‘significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for’ (emphasis added). This highlights the NPPF’s resolve to provide a mechanism for mitigating against or compensating for any assessed adverse impact. R-RMC is concerned that Policy NE4, as currently drafted, does not reflect the sentiment of the NPPF.

To make the policy justified, effective and sound, R-RMC suggests that the policy is updated to reflect and be consistent with national policy. This should be set out as a hierarchy, where development will be permitted where there is no adverse impact. However, where this is not possible, proposals will be expected to mitigate or, as a last resort, compensate for any adverse impact.

Clarify criterion six to make clear that tree planting should be sought 'unless, in specific cases, there are clear, justifiable and compelling reasons why this would be inappropriate'.

Draft Policy NE8 sets out the Local Plan’s requirements relating to trees and woodlands. While Rolls-Royce Motor Cars (R-RMC) broadly supports the principle of the draft policy, we suggest that there is an opportunity to provide some clarity regarding criterion six: ‘all major development proposals will be required to provide street tree planting’.

While the principle of street tree planting is recognised, this may not always be appropriate or practical. It is acknowledged that Paragraph 131 of the National Planning Policy Framework (NPPF) encourages local authorities to ensure that new streets are tree-lined. However, this position is supported by footnote 50 which provides the caveat that street tree planting should be sought ‘unless, in specific cases, there are clear, justifiable and compelling reasons why this would be inappropriate’.

R-RMC suggests that the draft policy is updated to reflect national policy to make it effective and sound.