Chichester Local Plan 2021-2039 - Main Modifications consultation

Not specified

Main Modification MM5

Objective 1
The proposed additions strengthen alignment with the NPPF in relation to sustainable transport (paras 105–106). This is a step in the right direction in aligning with NPPF paragraphs 104–106, which require plans to promote sustainable transport modes and reduce car dependency. However, in rural parishes like Kirdford, these aspirations are not realistically achievable without significant infrastructure investment.
MM5 fails to resolve this spatial disparity. Without targeted rural transport strategies or investment commitments, this objective cannot be effective or deliverable in the North of the Plan Area. Consequently, Objective 1 is unsound.

Objective 2
Our Regulation 19 Representations raised concerns about the clarity, effectiveness, and measurability of Objective 2. Unfortunately, the MM has not addressed this, and Kirdford Parish Council (KPC) considers that the objective needs to be clear that there are more designated sites than those listed and that Ebernoe SAC and The Mens SAC should be included, as important designated sites in the District. The text refers to designated sites, but it should refer to the above two sites as they are important at the Local Plan level.
Furthermore, we consider that the Objective is not sufficiently measurable. What are the quantum of biodiversity net gains the Plan is seeking to achieve – this should be clearly set out here. How will it measure the protection and enhancement of the natural environment, nature recovery, tree cover?
We also requested, given the importance of landscape in the District, and being located partly within the South Downs National Park (SDNP) and part within its setting, that a landscape objective should be included in the Local Plan. Whilst an objective has not been added, MM5 includes a requirement to protect landscape character and conserving and enhancing the SDNP and its setting. We are satisfied with the above inclusion, although we raise questions about the measurability of the landscape element of Objective 2.
There is no supporting strategy or delivery framework included in MM5 to explain how Objective 2 will be achieved or funded. This undermines its effectiveness and, therefore, we consider it partly unsound.

Objective 4
This Objective is better aligned with the NPPF paras 88-89 on supporting economic growth and diversification. However, it continues to present an urban-centric view of employment without recognising the constraints and opportunities in rural parishes.
This Objective should state the amount of jobs / employment floorspace the Local Plan is seeking to achieve across the District and should specify the goals of the Local Plan in terms of employment and jobs in villages and rural areas / Parishes, where the local economy differs from employment typology and scale in Chichester City and the A27 corridor area.
There is no commitment to enhance digital infrastructure or improve transport connections for rural employment zones, which limits the effectiveness of this policy for the north of the District.
The additions to Objective in MM5 (marine-related leisure, hospitality, bespoke vehicle manufacturing) are not relevant in Kirdford and most rural areas, and the Local Plan should set out measurable objectives in terms of the economy, including specific measurements for the rural economy.
Objective 4 is partially sound and legally compliant, but it is undermined by a lack of delivery mechanisms for rural enterprises.

Objective 5
This Objective aims to contribute towards improving ‘health indicators’ and ‘life expectancy’, yet the Objective does not say what these indicators are or what the goal is for increasing life expectancy. The objective should be much clearer about these and should aim to be effective for the North of the Plan Area, where there are few formal recreation areas and limited connectivity between settlements, green spaces and health facilities.
The Local Plan fails to recognise that the North of the Plan Area is environmentally constrained and lacks the infrastructure found in the south. Furthermore, there is no new implementation mechanism proposed to improve the provision or accessibility of green infrastructure and sport and health facilities in small rural parishes.
In light of the above, we consider that Objective 5 is not effective with regards to rural parishes, especially those in the North of the Plan Area, therefore the objective is still unsound.

Objective 6
We are satisfied that MM5 has introduced the special qualities of protected landscapes in the design objective, as it indirectly includes cultural heritage (an important special quality of the SNDP) in the objective. However, Objective 6 fails to refer to heritage outside of designated landscapes. Although the title of this Objective includes ‘Heritage’, the actual text provides no further detail about what the Local Plan’s Objectives are in relation to Heritage, in the whole District, and not within designated landscapes.
Moreover, we are concerned that the National Design Code will be supplemented by local design codes, yet Local Plan Policy D1 (Design Principles) says nothing about Design Codes being used. This objective does not translate into policy and therefore it is not effective and unsound.

Objective 7
The revised Objective introduces language about nature-based solutions, integrated transport, and a monitor-and-manage strategy for the A27 and it also clarifies infrastructure priorities. However, while the language is improved, this objective still lacks clarity regarding the infrastructure delivery mechanisms for the North of the Plan Area.
The MM-revised Objective 7 does not commit to funding, phasing, or define a strategic delivery body. It refers to monitoring but not to how monitoring outcomes will affect the phasing of development. The only area-specific transport/infrastructure measures refer to mitigation of impacts on the A27, which illustrates the urban-centric and South of the Plan Area focus of the Local Plan and the lack of identified infrastructure requirements to deliver the spatial strategy (including the North of the Plan Area).
Furthermore, there are no measurable deliverables for infrastructure.
Considering the above, Objective 7 is not effective, especially with regards to the North of the Plan Area and would be unsound.

Final paragraph of the policy should refer to a maximum scale of new development to be allocated via a Site Allocation DPD as well as an identified area. Exclude North East from further allocations via the Site Allocation DPD.

Main Modification MM6

Policy S1 Spatial Development Strategy
The revised Policy S1 and supporting paragraphs attempt to clarify the approach to distributing development across the District. However, the policy remains unsound for the following reasons:

1. Unjustified spatial distribution (especially in the North East of the Plan Area). The Plan continues to promote a disproportionate housing target of approximately 1,800 dwellings in the North of the Plan Area without clearly evidencing how this figure was derived, or how it takes account of the constraints in the area. As mentioned in our previous representations, Chichester District Council (CDC) has sought to fulfil an artificial housing capacity/target of 1,800 dwellings rather than approaching this exercise with an open mind. There is no reference to updated landscape capacity assessments, ecological surveys, or infrastructure feasibility work that would justify this quantum of growth in parishes such as Kirdford and the wider North East of the Plan Area.

2. Reliance on Neighbourhood Plans for delivery without support. The MM6 revision of Policy S1 continues to rely on Neighbourhood Plans to allocate development in rural parishes, without providing evidence of their ability to do so. KPC raised concerns with the SA determining locations for growth if the allocations are to be determined through the NDP. This approach lacks justification and risks non-delivery, which undermines the Plan’s effectiveness.

3. Lack of consideration for environmental constraints. The Spatial Strategy and its modification still fail to adequately account for the presence of Ebernoe Common SAC, The Mens SAC, and the Sussex North Water Resource Zone — all of which impact Kirdford Parish and its ability to accommodate additional housing.

4. Lack of integration with transport and accessibility evidence. There is undoubtedly limited potential to travel by walking / cycling or public transport in comparison to the southern plan area and there are no settlement hubs in this North East of Plan Area, and the spatial strategy still contradicts Objective 1 of the Local Plan and undermines the delivery of a truly sustainable spatial strategy.

KPC is satisfied that point 3 of Policy S1 has been amended and it has removed the sentence “where opportunities arise”, as it was ambiguous language and inefficient to support rural communities.

We are, however, concerned with the proposed last paragraph to the policy text: “Additional housing allocations, if required, will be made through the Site Allocation DPD (or review of the Local Plan)”. This text leaves the door open to new allocations beyond the Local Plan allocations and Parish housing numbers, and it does not provide any framework for the potential allocation of new sites. We consider that the text, if it remains, should refer to a maximum scale or development to be allocated via a Site Allocation DPD (and not identified in the Local Plan), as well as an identified area. The North East of the Plan Area should be discarded from any potential allocation via a Site Allocation DPD, and this should be reflected in the text of Policy S1.

The Sustainability Appraisal (SA) Addendum supports the removal of the explicit North/South spatial split, arguing it gives the plan more flexibility. However, KPC is
concerned that this obscures where growth is intended and downplays constraints in the North.

In light of the above, KPC considers Policy S1 (as amended by MM6) to be unsound due it not being justified, effective or consistent with national policy.

Main Modification MM7

Key Diagram
KPC remains concerned that the Key Diagram map refers to the “North East of Plan Area” but the Local Plan text refers to ‘North of the Plan Area’ (the area that includes Kirdford, Wisborough Green, Plaistow & Ifold, and Loxwood). This creates confusion for the reader when compared with paragraph 1.9 of the Local Plan (‘How to Use the Plan), which refers to the North of the Plan Area (the northeast of the District and Hammer / Camelsdale).

Main Modification MM10

Policy NE3 Landscape Gaps between settlements

KPC is very concerned with the revised wording of Policy NE3. Not only has MM10 not addressed the concerns raised previously by KPC with regard to the lack of assessment of the North East of the Plan Area, but also it leads to the ineffectiveness of the policy in this area.

The revised policy text states that development will be permitted within landscape gaps, where these have been defined. The definition of landscape gaps is left to either a Site Allocation DPD or a Neighbourhood Plan. Whilst KPC is supportive of the principle of defining the landscape gaps within the Neighbourhood Plan Area, we are very concerned that the amended policy seems to only apply once landscape gaps have been defined and leaves no opportunity to apply the policy and apply a broad landscape gap protection unless and until there is a formal designation in the Neighbourhood Plan. This could lead to landscape gaps not being effective until a Neighbourhood Plan defines them, which could take a significant time since the adoption of the Local Plan. Whilst KPC expects to review and update the Kirdford Neighbourhood Plan shortly, we are concerned with the lost effectiveness of the policy in the absence of a Neighbourhood Plan or a Site Allocation DPD defining landscape gaps.

We remain concerned that the policy, even as amended, lacks the clarity and enforceability required to be considered sound. MM10 does not define any specific landscape gaps at this stage, nor does it map them. Instead, it defers this critical task to future plan-making processes, including neighbourhood plans. Whilst KPC welcomes this approach, it may also lead to increased risks, creating inconsistency and uncertainty in how landscape gaps are protected across Chichester District. It also places a disproportionate burden on parish councils to carry out technical landscape assessments without the resources or support that should be provided at the strategic level, especially to parishes within the North East of the Plan Area, which, as we mentioned above, have not been assessed by CDC.

Moreover, the policy’s language, though improved, still allows for considerable flexibility in interpreting what constitutes "diminishing openness" or "perceived coalescence." In areas such as Kirdford, where the landscape is predominantly rural, these judgments are often subjective and contested. Without clear criteria, the policy will be difficult to implement consistently. This undermines its effectiveness and fails to provide a justified approach to safeguarding rural character.

In conclusion, MM10 does not go far enough to make the policy sound and may be inapplicable unless and until landscape gaps are designated in future planning documents. The absence of defined landscape gaps, measurable criteria for assessing proposals, and supporting spatial evidence means that the policy is not effective and not justified. Therefore, this policy remains unsound. KPC considers that MM10 requires further strengthening and evidence before it can be found sound

Main Modification MM5

Objective 1
The proposed additions strengthen alignment with the NPPF in relation to sustainable transport (paras 105–106). This is a step in the right direction in aligning with NPPF paragraphs 104–106, which require plans to promote sustainable transport modes and reduce car dependency. However, in rural parishes like Kirdford, these aspirations are not realistically achievable without significant infrastructure investment.
MM5 fails to resolve this spatial disparity. Without targeted rural transport strategies or investment commitments, this objective cannot be effective or deliverable in the North of the Plan Area. Consequently, Objective 1 is unsound.

Objective 2
Our Regulation 19 Representations raised concerns about the clarity, effectiveness, and measurability of Objective 2. Unfortunately, the MM has not addressed this, and Kirdford Parish Council (KPC) considers that the objective needs to be clear that there are more designated sites than those listed and that Ebernoe SAC and The Mens SAC should be included, as important designated sites in the District. The text refers to designated sites, but it should refer to the above two sites as they are important at the Local Plan level.
Furthermore, we consider that the Objective is not sufficiently measurable. What are the quantum of biodiversity net gains the Plan is seeking to achieve – this should be clearly set out here. How will it measure the protection and enhancement of the natural environment, nature recovery, tree cover?
We also requested, given the importance of landscape in the District, and being located partly within the South Downs National Park (SDNP) and part within its setting, that a landscape objective should be included in the Local Plan. Whilst an objective has not been added, MM5 includes a requirement to protect landscape character and conserving and enhancing the SDNP and its setting. We are satisfied with the above inclusion, although we raise questions about the measurability of the landscape element of Objective 2.
There is no supporting strategy or delivery framework included in MM5 to explain how Objective 2 will be achieved or funded. This undermines its effectiveness and, therefore, we consider it partly unsound.

Objective 4
This Objective is better aligned with the NPPF paras 88-89 on supporting economic growth and diversification. However, it continues to present an urban-centric view of employment without recognising the constraints and opportunities in rural parishes.
This Objective should state the amount of jobs / employment floorspace the Local Plan is seeking to achieve across the District and should specify the goals of the Local Plan in terms of employment and jobs in villages and rural areas / Parishes, where the local economy differs from employment typology and scale in Chichester City and the A27 corridor area.
There is no commitment to enhance digital infrastructure or improve transport connections for rural employment zones, which limits the effectiveness of this policy for the north of the District.
The additions to Objective in MM5 (marine-related leisure, hospitality, bespoke vehicle manufacturing) are not relevant in Kirdford and most rural areas, and the Local Plan should set out measurable objectives in terms of the economy, including specific measurements for the rural economy.
Objective 4 is partially sound and legally compliant, but it is undermined by a lack of delivery mechanisms for rural enterprises.

Objective 5
This Objective aims to contribute towards improving ‘health indicators’ and ‘life expectancy’, yet the Objective does not say what these indicators are or what the goal is for increasing life expectancy. The objective should be much clearer about these and should aim to be effective for the North of the Plan Area, where there are few formal recreation areas and limited connectivity between settlements, green spaces and health facilities.
The Local Plan fails to recognise that the North of the Plan Area is environmentally constrained and lacks the infrastructure found in the south. Furthermore, there is no new implementation mechanism proposed to improve the provision or accessibility of green infrastructure and sport and health facilities in small rural parishes.
In light of the above, we consider that Objective 5 is not effective with regards to rural parishes, especially those in the North of the Plan Area, therefore the objective is still unsound.

Objective 6
We are satisfied that MM5 has introduced the special qualities of protected landscapes in the design objective, as it indirectly includes cultural heritage (an important special quality of the SNDP) in the objective. However, Objective 6 fails to refer to heritage outside of designated landscapes. Although the title of this Objective includes ‘Heritage’, the actual text provides no further detail about what the Local Plan’s Objectives are in relation to Heritage, in the whole District, and not within designated landscapes.
Moreover, we are concerned that the National Design Code will be supplemented by local design codes, yet Local Plan Policy D1 (Design Principles) says nothing about Design Codes being used. This objective does not translate into policy and therefore it is not effective and unsound.

Objective 7
The revised Objective introduces language about nature-based solutions, integrated transport, and a monitor-and-manage strategy for the A27 and it also clarifies infrastructure priorities. However, while the language is improved, this objective still lacks clarity regarding the infrastructure delivery mechanisms for the North of the Plan Area.
The MM-revised Objective 7 does not commit to funding, phasing, or define a strategic delivery body. It refers to monitoring but not to how monitoring outcomes will affect the phasing of development. The only area-specific transport/infrastructure measures refer to mitigation of impacts on the A27, which illustrates the urban-centric and South of the Plan Area focus of the Local Plan and the lack of identified infrastructure requirements to deliver the spatial strategy (including the North of the Plan Area).
Furthermore, there are no measurable deliverables for infrastructure.
Considering the above, Objective 7 is not effective, especially with regards to the North of the Plan Area and would be unsound.

Main Modification MM5

Objective 1
The proposed additions strengthen alignment with the NPPF in relation to sustainable transport (paras 105–106). This is a step in the right direction in aligning with NPPF paragraphs 104–106, which require plans to promote sustainable transport modes and reduce car dependency. However, in rural parishes like Kirdford, these aspirations are not realistically achievable without significant infrastructure investment.
MM5 fails to resolve this spatial disparity. Without targeted rural transport strategies or investment commitments, this objective cannot be effective or deliverable in the North of the Plan Area. Consequently, Objective 1 is unsound.

Objective 2
Our Regulation 19 Representations raised concerns about the clarity, effectiveness, and measurability of Objective 2. Unfortunately, the MM has not addressed this, and Kirdford Parish Council (KPC) considers that the objective needs to be clear that there are more designated sites than those listed and that Ebernoe SAC and The Mens SAC should be included, as important designated sites in the District. The text refers to designated sites, but it should refer to the above two sites as they are important at the Local Plan level.
Furthermore, we consider that the Objective is not sufficiently measurable. What are the quantum of biodiversity net gains the Plan is seeking to achieve – this should be clearly set out here. How will it measure the protection and enhancement of the natural environment, nature recovery, tree cover?
We also requested, given the importance of landscape in the District, and being located partly within the South Downs National Park (SDNP) and part within its setting, that a landscape objective should be included in the Local Plan. Whilst an objective has not been added, MM5 includes a requirement to protect landscape character and conserving and enhancing the SDNP and its setting. We are satisfied with the above inclusion, although we raise questions about the measurability of the landscape element of Objective 2.
There is no supporting strategy or delivery framework included in MM5 to explain how Objective 2 will be achieved or funded. This undermines its effectiveness and, therefore, we consider it partly unsound.

Objective 4
This Objective is better aligned with the NPPF paras 88-89 on supporting economic growth and diversification. However, it continues to present an urban-centric view of employment without recognising the constraints and opportunities in rural parishes.
This Objective should state the amount of jobs / employment floorspace the Local Plan is seeking to achieve across the District and should specify the goals of the Local Plan in terms of employment and jobs in villages and rural areas / Parishes, where the local economy differs from employment typology and scale in Chichester City and the A27 corridor area.
There is no commitment to enhance digital infrastructure or improve transport connections for rural employment zones, which limits the effectiveness of this policy for the north of the District.
The additions to Objective in MM5 (marine-related leisure, hospitality, bespoke vehicle manufacturing) are not relevant in Kirdford and most rural areas, and the Local Plan should set out measurable objectives in terms of the economy, including specific measurements for the rural economy.
Objective 4 is partially sound and legally compliant, but it is undermined by a lack of delivery mechanisms for rural enterprises.

Objective 5
This Objective aims to contribute towards improving ‘health indicators’ and ‘life expectancy’, yet the Objective does not say what these indicators are or what the goal is for increasing life expectancy. The objective should be much clearer about these and should aim to be effective for the North of the Plan Area, where there are few formal recreation areas and limited connectivity between settlements, green spaces and health facilities.
The Local Plan fails to recognise that the North of the Plan Area is environmentally constrained and lacks the infrastructure found in the south. Furthermore, there is no new implementation mechanism proposed to improve the provision or accessibility of green infrastructure and sport and health facilities in small rural parishes.
In light of the above, we consider that Objective 5 is not effective with regards to rural parishes, especially those in the North of the Plan Area, therefore the objective is still unsound.

Objective 6
We are satisfied that MM5 has introduced the special qualities of protected landscapes in the design objective, as it indirectly includes cultural heritage (an important special quality of the SNDP) in the objective. However, Objective 6 fails to refer to heritage outside of designated landscapes. Although the title of this Objective includes ‘Heritage’, the actual text provides no further detail about what the Local Plan’s Objectives are in relation to Heritage, in the whole District, and not within designated landscapes.
Moreover, we are concerned that the National Design Code will be supplemented by local design codes, yet Local Plan Policy D1 (Design Principles) says nothing about Design Codes being used. This objective does not translate into policy and therefore it is not effective and unsound.

Objective 7
The revised Objective introduces language about nature-based solutions, integrated transport, and a monitor-and-manage strategy for the A27 and it also clarifies infrastructure priorities. However, while the language is improved, this objective still lacks clarity regarding the infrastructure delivery mechanisms for the North of the Plan Area.
The MM-revised Objective 7 does not commit to funding, phasing, or define a strategic delivery body. It refers to monitoring but not to how monitoring outcomes will affect the phasing of development. The only area-specific transport/infrastructure measures refer to mitigation of impacts on the A27, which illustrates the urban-centric and South of the Plan Area focus of the Local Plan and the lack of identified infrastructure requirements to deliver the spatial strategy (including the North of the Plan Area).
Furthermore, there are no measurable deliverables for infrastructure.
Considering the above, Objective 7 is not effective, especially with regards to the North of the Plan Area and would be unsound.

Main Modification MM5

Objective 1
The proposed additions strengthen alignment with the NPPF in relation to sustainable transport (paras 105–106). This is a step in the right direction in aligning with NPPF paragraphs 104–106, which require plans to promote sustainable transport modes and reduce car dependency. However, in rural parishes like Kirdford, these aspirations are not realistically achievable without significant infrastructure investment.
MM5 fails to resolve this spatial disparity. Without targeted rural transport strategies or investment commitments, this objective cannot be effective or deliverable in the North of the Plan Area. Consequently, Objective 1 is unsound.

Objective 2
Our Regulation 19 Representations raised concerns about the clarity, effectiveness, and measurability of Objective 2. Unfortunately, the MM has not addressed this, and Kirdford Parish Council (KPC) considers that the objective needs to be clear that there are more designated sites than those listed and that Ebernoe SAC and The Mens SAC should be included, as important designated sites in the District. The text refers to designated sites, but it should refer to the above two sites as they are important at the Local Plan level.
Furthermore, we consider that the Objective is not sufficiently measurable. What are the quantum of biodiversity net gains the Plan is seeking to achieve – this should be clearly set out here. How will it measure the protection and enhancement of the natural environment, nature recovery, tree cover?
We also requested, given the importance of landscape in the District, and being located partly within the South Downs National Park (SDNP) and part within its setting, that a landscape objective should be included in the Local Plan. Whilst an objective has not been added, MM5 includes a requirement to protect landscape character and conserving and enhancing the SDNP and its setting. We are satisfied with the above inclusion, although we raise questions about the measurability of the landscape element of Objective 2.
There is no supporting strategy or delivery framework included in MM5 to explain how Objective 2 will be achieved or funded. This undermines its effectiveness and, therefore, we consider it partly unsound.

Objective 4
This Objective is better aligned with the NPPF paras 88-89 on supporting economic growth and diversification. However, it continues to present an urban-centric view of employment without recognising the constraints and opportunities in rural parishes.
This Objective should state the amount of jobs / employment floorspace the Local Plan is seeking to achieve across the District and should specify the goals of the Local Plan in terms of employment and jobs in villages and rural areas / Parishes, where the local economy differs from employment typology and scale in Chichester City and the A27 corridor area.
There is no commitment to enhance digital infrastructure or improve transport connections for rural employment zones, which limits the effectiveness of this policy for the north of the District.
The additions to Objective in MM5 (marine-related leisure, hospitality, bespoke vehicle manufacturing) are not relevant in Kirdford and most rural areas, and the Local Plan should set out measurable objectives in terms of the economy, including specific measurements for the rural economy.
Objective 4 is partially sound and legally compliant, but it is undermined by a lack of delivery mechanisms for rural enterprises.

Objective 5
This Objective aims to contribute towards improving ‘health indicators’ and ‘life expectancy’, yet the Objective does not say what these indicators are or what the goal is for increasing life expectancy. The objective should be much clearer about these and should aim to be effective for the North of the Plan Area, where there are few formal recreation areas and limited connectivity between settlements, green spaces and health facilities.
The Local Plan fails to recognise that the North of the Plan Area is environmentally constrained and lacks the infrastructure found in the south. Furthermore, there is no new implementation mechanism proposed to improve the provision or accessibility of green infrastructure and sport and health facilities in small rural parishes.
In light of the above, we consider that Objective 5 is not effective with regards to rural parishes, especially those in the North of the Plan Area, therefore the objective is still unsound.

Objective 6
We are satisfied that MM5 has introduced the special qualities of protected landscapes in the design objective, as it indirectly includes cultural heritage (an important special quality of the SNDP) in the objective. However, Objective 6 fails to refer to heritage outside of designated landscapes. Although the title of this Objective includes ‘Heritage’, the actual text provides no further detail about what the Local Plan’s Objectives are in relation to Heritage, in the whole District, and not within designated landscapes.
Moreover, we are concerned that the National Design Code will be supplemented by local design codes, yet Local Plan Policy D1 (Design Principles) says nothing about Design Codes being used. This objective does not translate into policy and therefore it is not effective and unsound.

Objective 7
The revised Objective introduces language about nature-based solutions, integrated transport, and a monitor-and-manage strategy for the A27 and it also clarifies infrastructure priorities. However, while the language is improved, this objective still lacks clarity regarding the infrastructure delivery mechanisms for the North of the Plan Area.
The MM-revised Objective 7 does not commit to funding, phasing, or define a strategic delivery body. It refers to monitoring but not to how monitoring outcomes will affect the phasing of development. The only area-specific transport/infrastructure measures refer to mitigation of impacts on the A27, which illustrates the urban-centric and South of the Plan Area focus of the Local Plan and the lack of identified infrastructure requirements to deliver the spatial strategy (including the North of the Plan Area).
Furthermore, there are no measurable deliverables for infrastructure.
Considering the above, Objective 7 is not effective, especially with regards to the North of the Plan Area and would be unsound.

Main Modification MM5

Objective 1
The proposed additions strengthen alignment with the NPPF in relation to sustainable transport (paras 105–106). This is a step in the right direction in aligning with NPPF paragraphs 104–106, which require plans to promote sustainable transport modes and reduce car dependency. However, in rural parishes like Kirdford, these aspirations are not realistically achievable without significant infrastructure investment.
MM5 fails to resolve this spatial disparity. Without targeted rural transport strategies or investment commitments, this objective cannot be effective or deliverable in the North of the Plan Area. Consequently, Objective 1 is unsound.

Objective 2
Our Regulation 19 Representations raised concerns about the clarity, effectiveness, and measurability of Objective 2. Unfortunately, the MM has not addressed this, and Kirdford Parish Council (KPC) considers that the objective needs to be clear that there are more designated sites than those listed and that Ebernoe SAC and The Mens SAC should be included, as important designated sites in the District. The text refers to designated sites, but it should refer to the above two sites as they are important at the Local Plan level.
Furthermore, we consider that the Objective is not sufficiently measurable. What are the quantum of biodiversity net gains the Plan is seeking to achieve – this should be clearly set out here. How will it measure the protection and enhancement of the natural environment, nature recovery, tree cover?
We also requested, given the importance of landscape in the District, and being located partly within the South Downs National Park (SDNP) and part within its setting, that a landscape objective should be included in the Local Plan. Whilst an objective has not been added, MM5 includes a requirement to protect landscape character and conserving and enhancing the SDNP and its setting. We are satisfied with the above inclusion, although we raise questions about the measurability of the landscape element of Objective 2.
There is no supporting strategy or delivery framework included in MM5 to explain how Objective 2 will be achieved or funded. This undermines its effectiveness and, therefore, we consider it partly unsound.

Objective 4
This Objective is better aligned with the NPPF paras 88-89 on supporting economic growth and diversification. However, it continues to present an urban-centric view of employment without recognising the constraints and opportunities in rural parishes.
This Objective should state the amount of jobs / employment floorspace the Local Plan is seeking to achieve across the District and should specify the goals of the Local Plan in terms of employment and jobs in villages and rural areas / Parishes, where the local economy differs from employment typology and scale in Chichester City and the A27 corridor area.
There is no commitment to enhance digital infrastructure or improve transport connections for rural employment zones, which limits the effectiveness of this policy for the north of the District.
The additions to Objective in MM5 (marine-related leisure, hospitality, bespoke vehicle manufacturing) are not relevant in Kirdford and most rural areas, and the Local Plan should set out measurable objectives in terms of the economy, including specific measurements for the rural economy.
Objective 4 is partially sound and legally compliant, but it is undermined by a lack of delivery mechanisms for rural enterprises.

Objective 5
This Objective aims to contribute towards improving ‘health indicators’ and ‘life expectancy’, yet the Objective does not say what these indicators are or what the goal is for increasing life expectancy. The objective should be much clearer about these and should aim to be effective for the North of the Plan Area, where there are few formal recreation areas and limited connectivity between settlements, green spaces and health facilities.
The Local Plan fails to recognise that the North of the Plan Area is environmentally constrained and lacks the infrastructure found in the south. Furthermore, there is no new implementation mechanism proposed to improve the provision or accessibility of green infrastructure and sport and health facilities in small rural parishes.
In light of the above, we consider that Objective 5 is not effective with regards to rural parishes, especially those in the North of the Plan Area, therefore the objective is still unsound.

Objective 6
We are satisfied that MM5 has introduced the special qualities of protected landscapes in the design objective, as it indirectly includes cultural heritage (an important special quality of the SNDP) in the objective. However, Objective 6 fails to refer to heritage outside of designated landscapes. Although the title of this Objective includes ‘Heritage’, the actual text provides no further detail about what the Local Plan’s Objectives are in relation to Heritage, in the whole District, and not within designated landscapes.
Moreover, we are concerned that the National Design Code will be supplemented by local design codes, yet Local Plan Policy D1 (Design Principles) says nothing about Design Codes being used. This objective does not translate into policy and therefore it is not effective and unsound.

Objective 7
The revised Objective introduces language about nature-based solutions, integrated transport, and a monitor-and-manage strategy for the A27 and it also clarifies infrastructure priorities. However, while the language is improved, this objective still lacks clarity regarding the infrastructure delivery mechanisms for the North of the Plan Area.
The MM-revised Objective 7 does not commit to funding, phasing, or define a strategic delivery body. It refers to monitoring but not to how monitoring outcomes will affect the phasing of development. The only area-specific transport/infrastructure measures refer to mitigation of impacts on the A27, which illustrates the urban-centric and South of the Plan Area focus of the Local Plan and the lack of identified infrastructure requirements to deliver the spatial strategy (including the North of the Plan Area).
Furthermore, there are no measurable deliverables for infrastructure.
Considering the above, Objective 7 is not effective, especially with regards to the North of the Plan Area and would be unsound.

Further revision, supported by ecological evidence and spatially defined corridor mapping, including the North East of the Plan Area, before it can be adopted.

Main Modification MM11

Policy NE4 Strategic Wildlife Corridors
Main Modification MM11 introduces substantial changes to Policy NE4, which relates to the protection and enhancement of strategic wildlife corridors. The revised policy removes the original multi-criteria structure and replaces it with a more concise framework. It states that development proposals will only be permitted where they do not lead to an adverse effect on the ecological value, function, integrity, and connectivity of corridors. It also introduces new supporting paragraphs requiring applicants to assess habitat features on their sites and consider how these connect to the broader ecological network.

While the clearer wording and additional context are welcome improvements, the modified policy still falls short of being sound. The simplification of the criteria has removed important safeguards and procedural steps that would have ensured more robust ecological protection. The policy now relies heavily on the applicant to demonstrate that their proposal will not undermine corridor integrity. However, KPC has previously raised concerns that there is no evidence of how the integrity and function of these wildlife corridors have been assessed and how they should be assessed by applicants, particularly in rural areas where ecological assets are complex and sensitive. We are particularly concerned with the proposed corridors, which should be planned and delivered in the North East of the Plan Area as well, and not only limited to the South of the Plan Area with no compelling justification.

Furthermore, although the supporting text refers to the need to retain and enhance features such as treelines, hedgerows, and watercourses, the policy itself does not require these features to be protected, only that their “value” be considered. This is a significant weakening of the original intent of the policy and does not reflect the level of protection that is necessary under national policy and legislation.

Additionally, the policy creates potential conflicts with Neighbourhood Plans. The supporting text suggests that in cases where a wildlife corridor overlaps with a local green infrastructure designation in a made neighbourhood plan, Strategic Policy NE4 will take precedence. This may undermine the principle of subsidiarity in neighbourhood planning and create ambiguity if local evidence has taken a different approach to identifying or managing biodiversity assets. The concern increases by the fact that neighbourhood plan groups are unlikely to have had access to the full ecological data that should have informed the district-level corridors in the first place.

In conclusion, MM11 represents an improvement in structure and clarity but fails to address core concerns previously raised by KPC regarding the protection of strategic wildlife corridors in ecologically sensitive rural areas. The policy is not effective because it delegates too much responsibility to applicants without clear standards or enforcement tools. It is not justified as it leaves behind the North East of the Plan Area. As such, we consider MM11 to be unsound and in need of further revision, supported by ecological evidence and spatially defined corridor mapping, including the North East of the Plan Area, before it can be adopted.

Main Modification MM5

Objective 1
The proposed additions strengthen alignment with the NPPF in relation to sustainable transport (paras 105–106). This is a step in the right direction in aligning with NPPF paragraphs 104–106, which require plans to promote sustainable transport modes and reduce car dependency. However, in rural parishes like Kirdford, these aspirations are not realistically achievable without significant infrastructure investment.
MM5 fails to resolve this spatial disparity. Without targeted rural transport strategies or investment commitments, this objective cannot be effective or deliverable in the North of the Plan Area. Consequently, Objective 1 is unsound.

Objective 2
Our Regulation 19 Representations raised concerns about the clarity, effectiveness, and measurability of Objective 2. Unfortunately, the MM has not addressed this, and Kirdford Parish Council (KPC) considers that the objective needs to be clear that there are more designated sites than those listed and that Ebernoe SAC and The Mens SAC should be included, as important designated sites in the District. The text refers to designated sites, but it should refer to the above two sites as they are important at the Local Plan level.
Furthermore, we consider that the Objective is not sufficiently measurable. What are the quantum of biodiversity net gains the Plan is seeking to achieve – this should be clearly set out here. How will it measure the protection and enhancement of the natural environment, nature recovery, tree cover?
We also requested, given the importance of landscape in the District, and being located partly within the South Downs National Park (SDNP) and part within its setting, that a landscape objective should be included in the Local Plan. Whilst an objective has not been added, MM5 includes a requirement to protect landscape character and conserving and enhancing the SDNP and its setting. We are satisfied with the above inclusion, although we raise questions about the measurability of the landscape element of Objective 2.
There is no supporting strategy or delivery framework included in MM5 to explain how Objective 2 will be achieved or funded. This undermines its effectiveness and, therefore, we consider it partly unsound.

Objective 4
This Objective is better aligned with the NPPF paras 88-89 on supporting economic growth and diversification. However, it continues to present an urban-centric view of employment without recognising the constraints and opportunities in rural parishes.
This Objective should state the amount of jobs / employment floorspace the Local Plan is seeking to achieve across the District and should specify the goals of the Local Plan in terms of employment and jobs in villages and rural areas / Parishes, where the local economy differs from employment typology and scale in Chichester City and the A27 corridor area.
There is no commitment to enhance digital infrastructure or improve transport connections for rural employment zones, which limits the effectiveness of this policy for the north of the District.
The additions to Objective in MM5 (marine-related leisure, hospitality, bespoke vehicle manufacturing) are not relevant in Kirdford and most rural areas, and the Local Plan should set out measurable objectives in terms of the economy, including specific measurements for the rural economy.
Objective 4 is partially sound and legally compliant, but it is undermined by a lack of delivery mechanisms for rural enterprises.

Objective 5
This Objective aims to contribute towards improving ‘health indicators’ and ‘life expectancy’, yet the Objective does not say what these indicators are or what the goal is for increasing life expectancy. The objective should be much clearer about these and should aim to be effective for the North of the Plan Area, where there are few formal recreation areas and limited connectivity between settlements, green spaces and health facilities.
The Local Plan fails to recognise that the North of the Plan Area is environmentally constrained and lacks the infrastructure found in the south. Furthermore, there is no new implementation mechanism proposed to improve the provision or accessibility of green infrastructure and sport and health facilities in small rural parishes.
In light of the above, we consider that Objective 5 is not effective with regards to rural parishes, especially those in the North of the Plan Area, therefore the objective is still unsound.

Objective 6
We are satisfied that MM5 has introduced the special qualities of protected landscapes in the design objective, as it indirectly includes cultural heritage (an important special quality of the SNDP) in the objective. However, Objective 6 fails to refer to heritage outside of designated landscapes. Although the title of this Objective includes ‘Heritage’, the actual text provides no further detail about what the Local Plan’s Objectives are in relation to Heritage, in the whole District, and not within designated landscapes.
Moreover, we are concerned that the National Design Code will be supplemented by local design codes, yet Local Plan Policy D1 (Design Principles) says nothing about Design Codes being used. This objective does not translate into policy and therefore it is not effective and unsound.

Objective 7
The revised Objective introduces language about nature-based solutions, integrated transport, and a monitor-and-manage strategy for the A27 and it also clarifies infrastructure priorities. However, while the language is improved, this objective still lacks clarity regarding the infrastructure delivery mechanisms for the North of the Plan Area.
The MM-revised Objective 7 does not commit to funding, phasing, or define a strategic delivery body. It refers to monitoring but not to how monitoring outcomes will affect the phasing of development. The only area-specific transport/infrastructure measures refer to mitigation of impacts on the A27, which illustrates the urban-centric and South of the Plan Area focus of the Local Plan and the lack of identified infrastructure requirements to deliver the spatial strategy (including the North of the Plan Area).
Furthermore, there are no measurable deliverables for infrastructure.
Considering the above, Objective 7 is not effective, especially with regards to the North of the Plan Area and would be unsound.