Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 4812

Received: 17/03/2023

Respondent: Miller Homes and Vistry Group

Agent: Tetra Tech

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As with Policy P2, whilst the principle of providing inclusive, accessible layouts and prioritizing walking and cycling is advocated, the policy is overly detailed and prescriptive, relating to matters more appropriately included in a design guide rather than planning policy. It is also considered the policy replicates points made in policies 2 and 5 in particular.
See representation report for more detail and context.

Objection noted. Paragraph 126 in the NPPF states that being clear about design expectations is essential for achieving a high standard of design and creating better places. In addition, the detailed policies naturally follow on from the policies which focus on more high-level design principles, meaning there is an inevitable degree of repetition necessary. Furthermore, policy is clearly a more effective mechanism for achieving these important objectives when compared with relying solely on SPDs or other guidance such as the National Design Guide. Therefore, it is considered that this detailed policy framework is the clearest and most effective way of achieving these important design objectives.

Object

Representation ID: 4814

Received: 17/03/2023

Respondent: Miller Homes and Vistry Group

Agent: Tetra Tech

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As with Policies P2 and P4, whilst the principles of providing attractive, well landscaped space is supported, the policy is overly detailed and prescriptive, relating to matters more appropriately included in a design guide rather than planning policy. It is also considered the policy replicates points made in policies 2 and 4 in particular.
See representation report

Paragraph 126 in the NPPF states that being clear about design expectations is essential for achieving a high standard of design and creating better places. In addition, the detailed policies naturally follow on from the policies which focus on more high-level design principles, meaning there is an inevitable degree of repetition necessary. In addition, policy is clearly a more effective mechanism for achieving these important objectives when compared with relying solely on SPDs or other guidance such as the National Design Guide. Therefore, it is considered that this detailed policy framework is the clearest and most effective way of achieving these important design objectives

Object

Representation ID: 4818

Received: 17/03/2023

Respondent: Miller Homes and Vistry Group

Agent: Tetra Tech

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We agree with the need to provide suitable amenity standards for residents. However, a number of the policy points are replicated elsewhere, for example in relation to noise and lighting requirements.

Objection and proposed changes noted. i) While the policy does address some issues covered in other policies, it seeks to address the design and amenity angle in relation to these issues and how those issues can be considered holistically as part of the design process.
ii) Our Residential Space Standards Evidence Study provides evidence to justify adoption of the NDSS within the Plan Area and will be submitted as part of the examination documents. We will consider a modification to the policy to ensure clarity in interpretation and implementation of this requirement. iii) In terms of the issue of back-to-back distances referred to, the Council agrees that some clarification is required in relation to this issue. It will consider a modification to the policy and supporting text to provide this.

Object

Representation ID: 4820

Received: 17/03/2023

Respondent: Miller Homes and Vistry Group

Agent: Tetra Tech

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Whilst Miller and Vistry are committed to using high quality, sustainable materials, we have concerns about policy P8. Policy P8 is particularly prescriptive in regards to what materials and detailing should be used, for example on the types of cladding that can be used (point 9) or suggesting the avoidance of commonly used upvc windows (point 11). Such prescription within planning policy is likely to stifle innovation and is not justified and any such points should be removed. The reference to ‘value engineering approaches’ is also not required or justified. Each application should be assessed on its own merits.

Paragraph 131 within the NPPF emphasises the important of high quality, beautiful and sustainable design and the need to be clear about the design expectations in order to achieve this. Building materials are a key aspect of this, as emphasised in the National Design Guide, and hence need to be addressed robustly in policy. The Council would suggest that the requirement to use high-quality, sustainable materials is likely to encourage innovation rather than discourage it. In addition, the policy is framed is a flexible manner, and hence isn’t considered overly prescriptive.
The reference to value engineering is considered to be very important as it is a significant problem within the planning system for schemes to be consented on the basis of a certain standard of design and materials, and for this to then be diluted through the details and compliance process or subsequent applications. This issue is also highlighted in paragraph 140 of the NPPF.

Support

Representation ID: 4821

Received: 17/03/2023

Respondent: Miller Homes and Vistry Group

Agent: Tetra Tech

Miller and Vistry are broadly supportive of this policy, having incorporated a range of measures within the west of Chichester development to enhance the Green Infrastructure Network.

Support noted.

Support

Representation ID: 4823

Received: 17/03/2023

Respondent: Miller Homes and Vistry Group

Agent: Tetra Tech

Miller and Vistry are broadly supportive of this policy, having committed to deliver significant levels of new public open space on site.

Support Noted.

Support

Representation ID: 4824

Received: 17/03/2023

Respondent: Miller Homes and Vistry Group

Agent: Tetra Tech

Vistry and Miller support the principle of this policy having allowed for land within the local center for a healthcare facility.

Support noted.

Object

Representation ID: 4827

Received: 17/03/2023

Respondent: Miller Homes and Vistry Group

Agent: Tetra Tech

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We have no in principle comment on the continued allocation of employment space at the West of Chichester SDL but the policy and supporting text should recognize the ever-evolving nature of the employment market and provide sufficient flexibility within the policy to allow for alternative uses to come forward should marketing of employment space generate no viable market interest.

This policy is framed in floorspace as the calculations of additional employment land to be allocated are based on floorspace figures. The figure used for Land West of Chichester is taken from a planning application. However assuming a 40% plot ratio on 5.2ha (the part of the 6ha which does not already have permission) gives an indicative floorspace of 20,800 rather than the 22,000 used. This would be more consistent with the way other figures have been calculated.

Support

Representation ID: 4829

Received: 17/03/2023

Respondent: Miller Homes and Vistry Group

Agent: Tetra Tech

In respect of contributions towards the A27, Miller and Vistry support the confirmation in the table beneath paragraph 8.20 that the contribution to be sought from the West of Chichester development towards A27 improvements will be £1,803 per dwelling.

N/A

Object

Representation ID: 4831

Received: 17/03/2023

Respondent: Miller Homes and Vistry Group

Agent: Tetra Tech

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Miller and Vistry support the implementation of infrastructure required as a result of development where it is justified and proportionate, including maintenance of infrastructure where it remains the responsibility of the developer.

Agree that this should be clarified