Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 4815

Received: 17/03/2023

Respondent: Willowfield Farm

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Some of my comments from the Preferred Approach consultation were deleted by the planning authority without warning. I only spotted this when I went back to see what I had written to help someone else with another matter. Their reason being that they 'thought they were a duplication' of comments written in another section. This was not the case - related points were linked by reference to each other but each was individually written and included proposed modifications to the wording.

The Council received over 3200 responses to the Preferred Approach consultation and in some cases the published comments were summarised but all the representations received were taken into account in deciding whether changes to the draft Local Plan should be made.

There is considerable flexibility open to LPAs in how the initial stages of local plan production are carried out and there is no requirement to have a further Regulation 18 consultation. The Regulation 19 consultation provides a further opportunity for making representations.

Object

Representation ID: 4817

Received: 17/03/2023

Respondent: Willowfield Farm

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This plan appears to contradict the DPD. It should be noted that where a new DPD is adopted it will take precedence over this document. My comment is generated in response to Bosham site Allocation which is not sound.

The Local Plan currently being prepared is a DPD. It will replace the adopted Local Plan Key Policies and set the strategic framework for the preparation of future Neighbourhood Plans and any subsequent DPD. As set out in Local Plan Appendix H, the policies in the currently adopted Site Allocation DPD have been ‘saved’ for continued use.

See also the respondent’s representations to Policy H2 – Rep 4882.

Object

Representation ID: 4826

Received: 17/03/2023

Respondent: Willowfield Farm

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The SA's that have been undertaken appear to be have been done to fit the proposed site allocations not vice versa. Sites that seem to have a better sustainability appraisal seem to have been ignored/modified/rejected for no apparent reasons or wighting has not been given to sustainable items such as distance fromt transport hubs and ability and proposensity to offset/mitigate environmental factors have been ignored. I refer specifically to the HIghGrove and French Gardens sites in the Bosham section.

A Sustainability Appraisal has been undertaken at all stages of the Local Plan preparation. However, the outcome of the SA is only one of a number of factors that needs to be weighed up in determining whether a site is suitable for allocation.

Object

Representation ID: 4834

Received: 17/03/2023

Respondent: Willowfield Farm

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The plan does not provide adequate provision for self build or for people who would like to live in Passivhaus or similar standard buildings.

The Council considers that the policy approach set out within Policy H6 (Custom and/or Self Build Homes) will ensure that demand on the register can be met. The Council have recently undergone a process of updating the Custom and Self-Build Register and this, combined with additional data on the level of self/custom build need in the Plan Area, has indicated a strong demand for self-build/custom plots. To address this, the Council are proposing to increase the level of self-build/custom provision on strategic sites.
In addition to the requirement for plots to be made available on strategic housing sites a proportion of self builds will also come forward on smaller sites and infill (windfall) sites. The policy also encourages provision to be made via Neighbourhood Plans.

Object

Representation ID: 4844

Received: 17/03/2023

Respondent: Willowfield Farm

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The way of registering for self build is too onerous and makes it difficult to register.

The Council has now updated the self-build register and has taken appropriate steps to ensure that it is not overly onerous to join. Additional data has also been sought from the right to build register in order to augment the Council’s understanding of the level of demand for self-build plots within the plan area. This suggests that there is a strong demand for self/custom build plots within the plan area and the Council proposes to reflect that via an amendment to the plan in order to increase the level of self/custom build provision.

Object

Representation ID: 4859

Received: 17/03/2023

Respondent: Willowfield Farm

Legally compliant? No

Sound? No

Duty to co-operate? Yes

I believe that this policy rules out exception sites from coming forward. The local plan is supposed to cater for both existing and future need across the whole district, but if there is existing need within a Parish that is not being built either due to future loading of district houses or because applications are not being built out or even coming forward then exception sites should be allowed. I do not believe this is how the NPPF is intended to be interpreted.

Criteria 1 to be updated to include the word allocated to clarify this only includes allocated sites and not undetermined permissions.

Due to need for affordable homes in the plan area it is not expected that criteria 9 will be a barrier to development. However it has been included in the policy to ensure that should a higher number of First Homes be delivered and a need can no longer be demonstrated, a site will not be developed and remain empty or changed to market homes in a location which would not ordinarily be supported.

Object

Representation ID: 4882

Received: 17/03/2023

Respondent: Willowfield Farm

Legally compliant? No

Sound? No

Duty to co-operate? Yes

I object to the increased allocation at Highgrove Farm and the evidence submitted that has arrived at this allocation. I represent The French Gardens (TFG) site which has been incorrectly coloured red on the HELAA and incorrectly assessed on the Sustainability Assessment. These errors have been blindly carried forward reulting in a gross lack of soundness. Briefly 1.TFG is lower grade soil. 2. TFG was preferred by locals in the Village consultation. 3. TFG no impact on East-West coalescence, SDNP and AONB. 4. TFG would result in reinvestment into dilapdated rural business. 5. TFG mitigation available onsite etc.

The Housing Distribution Background Paper sets out the justification for the site allocations and strategic parish numbers set out in Policy H2.
Promotion of site noted.

Object

Representation ID: 4895

Received: 17/03/2023

Respondent: Willowfield Farm

Legally compliant? No

Sound? No

Duty to co-operate? No

The Examiner of Bosham's plan suggested that residents would still have a say in where housing was allocated within the village. That has bot happened with no consultation with landowners or residents other than to propose one single site. Residents voted to accept the modifications based on teh inspectors comments which to date have not been upheld.

There is considerable flexibility open to LPAs in how the initial stages of local plan production are carried out and there is no requirement to have a further Regulation 18 consultation

Object

Representation ID: 4916

Received: 17/03/2023

Respondent: Willowfield Farm

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Allocating an additional 245 houses to Highgrove is at odds with the Village Plan. It coalesces unnecessarily East-West, it isnt the lowest grade soil, it doesnt respect residents wishes as consulted in the Neighbourhood Plan. It incorrectly draws on erroneous HELAA data.

Promotion of alternative site noted

Object

Representation ID: 4919

Received: 17/03/2023

Respondent: Willowfield Farm

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The allocation does not give due weight to the setting of the AONB and SDNP. The permanent loss of views from one to the other cannot be mitigated against and is a permament loss to the local community and nation as a whole. If housing is allocated to this site it should be the minimum possible.

Promotion of alternative site noted