Chichester Local Plan 2021 - 2039: Proposed Submission

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Object

Chichester Local Plan 2021 - 2039: Proposed Submission

1.23

Representation ID: 4780

Received: 17/03/2023

Respondent: Reside Developments Ltd

Agent: Tetra Tech

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Concern that Local Plan not seeking to address unmet need agreed by West Sussex and Greater Brighton Strategic Planning Board, and cannot meet own need.

Concern no progress following 2016 LSS2

Change suggested by respondent:

See submitted letter
The housing number should be increased as there appears to be additional capacity on the A27 beyond that stated
Additional sites that are currently in the planning system without technical problems and recommended by officers for planning permission should be allocated in the Local Plan to meet the housing need
There needs to be more certainty on what happens if Neighbourhood Plans and the District Council do not deliver the housing numbers expected in a timely manner
Policies NE3 and NE4 need to be amended

Full text:

Please see submitted letter but we do not believe the housing number has been robustly evidenced as we believe the housing requirement could be higher and more sites should be allocated and provided for and we do not believe the Duty to Cooperate has been met.


Our response:

The Council have sought to address unmet needs during the preparation of this Local Plan and have engaged with both neighbouring authorities and those in the wider region but, as set out in the updated Statement of Compliance (April 2024), no authority has confirmed that it is in a position to accommodate any of the Plan Area’s unmet need.

It is acknowledged that preparation of LSS3 has not advanced as quickly as the Council and others would have wished. However, in the absence of progress on the LSS3 update the Council is, as referenced above, preparing statements of common ground with individual authorities.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy S1 Spatial Development Strategy

Representation ID: 4783

Received: 17/03/2023

Respondent: Reside Developments Ltd

Agent: Tetra Tech

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Recognises large parts of the district are subject to constraints;

Concerned justification for constrained 535 dpa figure due to the A27 is not correct interpretation of Transport Study evidence. Suggests appears to be additional capacity;

Considers that any site that can be developed sustainably should be allocated in the plan and supported, to address large unmet housing need.

Concerned that proposed Site Allocations DPD does not give certainty over delivery.

Change suggested by respondent:

The housing number should be increased as there appears to be additional capacity on the A27 beyond that stated.

Additional sites that are currently in the planning system without technical problems and recommended by officers for planning permission should be allocated in the Local Plan to meet the housing need.

There needs to be more certainty on what happens if Neighbourhood Plans and the District Council do not deliver the housing numbers expected in a timely manner.

Full text:

See submitted letter


Our response:

The justification for not meeting the housing needs in full is set out in the Housing Need and Transport Background Papers (July 2024).

There is a track record of allocations successfully being made through Neighbourhood Plans and there is no evidence to suggest that this will not continue over the plan period.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE3 Landscape Gaps between settlements

Representation ID: 4786

Received: 17/03/2023

Respondent: Reside Developments Ltd

Agent: Tetra Tech

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

See attached letter. Policy NE3 “Landscape Gaps between Settlements” is too broad and should be caveated that the gaps will only be protected if there is demonstrable harm. As currently written, there could be a long distance between settlements that technically diminishes the physical gap and strictly speaking could be argued to result in the perceived coalescence of settlements.

Change suggested by respondent:

Policy NE3 “Landscape Gaps between Settlements” is too broad and should be caveated that the gaps will only be protected if there is demonstrable harm.

Full text:

See attached letter


Our response:

Comments noted.
The detailed location and boundaries of landscape gaps will be considered and assessed through either the subsequent Site Allocations DPD that will follow on from the Local Plan or be undertaken as part of a relevant neighbourhood plan.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE4 Strategic Wildlife Corridors

Representation ID: 4789

Received: 17/03/2023

Respondent: Reside Developments Ltd

Agent: Tetra Tech

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

See submitted letter. Policy NE4 “Strategic Wildlife Corridors” needs to be rewritten as the policy starts off correctly with saying development will only be permitted if it does not have an adverse effect on the wildlife corridor. It therefore makes no sense to then caveat that with the two points that follow which adds in a sequential test (point 1) and largely repeats the first statement (point 2).

Change suggested by respondent:

Policy NE4 “Strategic Wildlife Corridors” needs to be rewritten. Point 1 should be deleted as there is no need for a sequential test if there is no harm. The first part of Point 2 should be deleted as it is repetition, and the second half should just be added to the policy and seek the enhancement that it is fair to ask for.

Full text:

See submitted letter


Our response:

Comment noted. The policy wording will be modified.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H3 Non-Strategic Parish Housing Requirements 2021 - 2039

Representation ID: 6161

Received: 17/03/2023

Respondent: Reside Developments Ltd

Agent: Tetra Tech

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Concerned that delivery through Neighbourhood Plans and/or subsequent DPD does not provide certainty or ensure timeliness.

Considers Southbourne (as well as other parishes with zero housing figure due to strategic site allocations) should also have a parish figure.

Change suggested by respondent:

Allocation of proposed housing site (Willowbrook Riding Stables, Hambrook) within Plan to ensure timely delivery.

Full text:

See submitted letter


Our response:

The Housing Distribution Background Paper (May 2024) sets out the justification for the non- strategic parish numbers set out in Policy H3.
The housing distribution seeks to reconcile a range of factors in order to achieve the most sustainable approach to the distribution of development. This is set out in the more detail within the Sustainability Appraisal and Housing Distribution Background Paper. This has also been influenced by site availability and suitability, environmental and other constraints.
The justification and evidence to support the latest housing trajectory is set out in the Housing Supply Background Paper (May 2024).
There is a track record of allocations successfully being made through Neighbourhood Plans and there is no evidence to suggest that this will not continue over the plan period. The Site Allocations DPD provides a mechanism for ensuring that site allocations can be made should Neighbourhood Plans not progress within a reasonable timeframe following adoption of the Local Plan.

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