Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
1.25
Representation ID: 5773
Received: 17/03/2023
Respondent: Beechcroft Developments Limited
Agent: Genesis Town Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
Procedure set out in NPPF and PPG has not been followed; overwhelming unmet need for housing not addressed in evidence for plan; no statement of common ground demonstrating how A27 cross-boundary issues has or will be resolved.
Statements of common ground will need to be prepared and published, in accordance with procedural requirements. These will then need to be considered and reflected in the emerging Local Plan which need to be consulted upon again in light of this evidence.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
The Vision is that by 2039,
Representation ID: 5774
Received: 17/03/2023
Respondent: Beechcroft Developments Limited
Agent: Genesis Town Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
Vision suggests people will be able to choose from a variety of homes to suit their incomes, needs, lifestyle and stage of life in accessible locations close to existing or new services, meeting the needs of young people, families and older people. However, Plan does not propose to meet housing needs and as a result, there will be an insufficient supply to meet housing needs let alone provide choice. Households on a lower income will find it increasingly difficult to find suitable housing, households generally will find it increasingly difficult to access suitable housing regardless of needs, lifestyle and stage of life, housing needs of young people, families and older people will not be met.
Proposed policies are directly at odds with proposed Vision - either the Vision will need to be amended to recognise that housing needs will not be met and choice will not be provided, or policies will need to be amended to provide for housing needs and choice.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
2.52
Representation ID: 5775
Received: 17/03/2023
Respondent: Beechcroft Developments Limited
Agent: Genesis Town Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
Paragraph 2.52 suggests that strategic objectives align with the objectives of LSS2, one of which is meeting strategic housing needs. However, paragraph 5.2 of the proposed submission draft explicitly identifies that not only will the housing needs of the plan-area not be met, but also that no contribution will be made to the unmet needs of the South Downs or the sub-area more widely.
Proposed policies directly undermine objectives of LSS2 - either paragraph 2.52 will need to be amended to recognise that there is some conflict between policies of Plan and objectives of LSS2, or policies will need to be amended to provide for strategic housing needs.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy S1 Spatial Development Strategy
Representation ID: 5776
Received: 17/03/2023
Respondent: Beechcroft Developments Limited
Agent: Genesis Town Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
An increased dwelling requirement could be accommodated without the need to significantly alter the proposed spatial strategy. Additional development could be accommodated at less constrained Service Villages in northern parts of Manhood Peninsula. Not all of Manhood Peninsula is affected by challenges. Hunston is relatively unconstrained compared to other parts of Manhood Peninsula. Hunston has good accessibility to road network. Additional development at Hunston would be consistent with Policy T1. Hunston has been, and continues to be, a sustainable location for new development. Previous work on emerging Local Plan and now withdrawn Neighbourhood Plan demonstrate that it is capable of delivering at least 200 homes during Plan period. Site promoted at Land at Hunston Village Dairy.
Make a strategic scale allocation as part of Policy H2; set a housing figure of at least 200 homes for Hunston in Policy H3 which could be delivered as part of Neighbourhood Plan process.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H2 Strategic Locations/ Allocations 2021 - 2039
Representation ID: 5777
Received: 17/03/2023
Respondent: Beechcroft Developments Limited
Agent: Genesis Town Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
An increased dwelling requirement could be accommodated without the need to significantly alter the proposed spatial strategy. Additional development could be accommodated at less constrained Service Villages in northern parts of Manhood Peninsula. Not all of Manhood Peninsula is affected by challenges. Hunston is relatively unconstrained compared to other parts of Manhood Peninsula. Hunston has good accessibility to road network. Additional development at Hunston would be consistent with Policy T1. Hunston has been, and continues to be, a sustainable location for new development. Previous work on emerging Local Plan and now withdrawn Neighbourhood Plan demonstrate that it is capable of delivering at least 200 homes during Plan period. Site promoted at Land at Hunston Village Dairy.
Make a strategic scale allocation as part of Policy H2; set a housing figure of at least 200 homes for Hunston in Policy H3 which could be delivered as part of Neighbourhood Plan process.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H3 Non-Strategic Parish Housing Requirements 2021 - 2039
Representation ID: 5778
Received: 17/03/2023
Respondent: Beechcroft Developments Limited
Agent: Genesis Town Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
An increased dwelling requirement could be accommodated without the need to significantly alter the proposed spatial strategy. Additional development could be accommodated at less constrained Service Villages in northern parts of Manhood Peninsula. Not all of Manhood Peninsula is affected by challenges. Hunston is relatively unconstrained compared to other parts of Manhood Peninsula. Hunston has good accessibility to road network. Additional development at Hunston would be consistent with Policy T1. Hunston has been, and continues to be, a sustainable location for new development. Previous work on emerging Local Plan and now withdrawn Neighbourhood Plan demonstrate that it is capable of delivering at least 200 homes during Plan period. Site promoted at Land at Hunston Village Dairy.
Make a strategic scale allocation as part of Policy H2; set a housing figure of at least 200 homes for Hunston in Policy H3 which could be delivered as part of Neighbourhood Plan process.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H1 Meeting Housing Needs
Representation ID: 5779
Received: 17/03/2023
Respondent: Beechcroft Developments Limited
Agent: Genesis Town Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
Object on grounds that no exception circumstances for alternative approach to housing need; there is a need for at at least 666 homes per annum in plan area equating to a need for 11,988 homes over plan period; also need for at least 1,083 homes per annum if affordable housing needs are to be met equating to 19,485 homes; unmet need in excess of 10,000 homes in related authorities; capacity constraints on A27 should not limit amount of development, inconsistent with objectives of national policy.
Full need for housing will need to be assessed taking account of needs of particular groups; engage with prescribed bodes to investigate capacity to accommodate unmet need in excess of 10,000 homes, demonstrate through statements of common ground; meet full need unless able to demonstrate adverse effects of additional traffic flows on A27 outweigh benefits; retitle H1 to recognise will not meet need or amend to meet housing need.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy T1: Transport Infrastructure
Representation ID: 5780
Received: 17/03/2023
Respondent: Beechcroft Developments Limited
Agent: Genesis Town Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
Object on grounds that proposed “monitor and manage” approach as opposed to “plan, monitor and manage” approach inherently acknowledges that Council is failing to plan to address infrastructure or housing needs; approach not consistent with national policy and will actively constrain delivery of infrastructure and housing needed; modelling data provided in Chichester Capacity Study does not provide justification for how figure of 535 dpa was arrived at, SATURN modelling shows that 700 dpa could be accommodated; requested financial contributions are for improvements on the SRN which is the responsibility of National Highways, funding received from the Department of Transport; method by which financial contributions have been calculated is flawed.
Adopt a “plan, monitor and manage” approach which plans to meet housing needs in full through committing to delivery of infrastructure improvements and if necessary, phasing housing requirement towards end of plan period with progress towards infrastructure funding being monitored and delivery of sites being managed such that they will only be brought forward providing appropriate infrastructure improvements to A27 as is necessary to support each development, is provided. Chichester Capacity Study needs to be updated and use latest traffic growth modelling (Ver 8.0 SATURN modelling) to establish capacity of roundabout junction improvements and extent of funding required to carry out necessary improvements. Take into account other types of use for financial contributions in addition to residential.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H4 Affordable Housing
Representation ID: 5782
Received: 17/03/2023
Respondent: Beechcroft Developments Limited
Agent: Genesis Town Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
Object on grounds that HEDNA identifies need for 225 affordable ownership homes, disregarded within Plan; unclear how tenure mix has been identified - disproportionately large share of social and affordable rental homes compared to that needed; policy does not align with evidence.
As the tenure mix sought by Policy H4 does not align with the evidence, additional work will need to be undertaken to demonstrate that this is justified and that it will be effective.
See attachments.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
8.21
Representation ID: 5783
Received: 17/03/2023
Respondent: Beechcroft Developments Limited
Agent: Genesis Town Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
Object on grounds that developer contributions sought for improvements exclude contributions from other development types such as industrial, retail, leisure, education which all generate traffic movements but don't appear in assessments - approach to securing financial contributions towards improvements to A27 is flawed.
See attachments.
