Category Archives: Local Plan

An old style development plan prepared by district or other local planning authorities. These plans will continue to exist for a while after the introduction of the new development system .

Vote on options for the City’s local road network

The Chichester City Council, together with the residents of Chichester, are in the process of preparing a Chichester Neighbourhood Plan. The Plan can include planning policies,
infrastructure projects, and aspirations. They have produced a document Southern Gateway: Road opportunities  Chichester Neighbourhood Plan – Background document which examines how the local road network could be improved in the vicinity of the Southern Gateway redevelopment area. It follows on from public consultation through which residents expressed support for a bridge or underpass across the Basin Road level crossing and for re-routing cars out of the city centre.

The document sets out the existing situation with city centre highway routing and four options: Firstly, the two preferred options for highways changes that CDC is considering making, namely

  • – reducing the southern gyratory to one lane (option 10)
  • – building a new link road through the city centre (option 11)

Secondly, the City Council’s new options

  • – redirecting cars out of the city centre, pedestrianizing Southgate (option 12), and
  • – as above with an underpass at Basin Road level crossing (option 13)

There is also the option to stay as we are (options 0)

The options are out for consultation – to express  a choice or add a comment go to here.

Voting will close on 15 December 2020

The Society’s formal response to Government on planned changes to the planning system

The Society has previously made a response to the proposals via Civic Voice as noted in an earlier post available hereIt has now filed a formal response with the Ministry of Housing, Communities & Local Government (GCLG) as noted below. (If you wish to view the Government’s consultation document it can be viewed here; the ensuing white paper can be viewed here)

Below is the Chichester Society view on the two planning consultations published by DCLG in August 2020 entitled: Changes to current Planning System and Planning for the Future.  We begin with an introduction which provides some context to our circumstances here in Chichester.

Introduction

Local planning policy is governed by the National Planning Policy Framework (NPPF). This places upon local planning authorities (LPAs) a duty to deliver sustainable development in their area based upon nationally directed Objectively Assessed Need targets for housing (OAN). The NPPF places what is called a ‘presumption in favour of development’ on all planning applications unless it can be demonstrated that the development would be detrimental based on defined policies.

Development in any LPA area is identified by the production of a Local Plan (LP). This must be a robust and clear document that outlines the planning framework and long-term strategy over a 15-year lifespan. The LP in Chichester was adopted in 2015 with a housing allocation of 435 dwellings per annum.  It needed review before July 2020 for it to have remained valid. The LP must be regularly monitored and updated in order to show that the planning authority have a five-year supply of land to meet the centrally allocated Objectively Assessed Need.

Chichester District Council (CDC) began a Review of the Adopted LP in 2016 in order to demonstrate that they had the land supply to meet the OAN of 12,350 dwellings for the remaining period (2016-2035). This means that the council had to be able to demonstrate that it had sufficient sites allocated to deliver 628 dwellings per year and this became the adopted level in the Review.

CDC is tightly constrained in the area that it can allocate for housing development because the majority of the district is located within the South Downs National Park (SDNP) which is its own LPA and is therefore excluded from the Chichester Local Plan Area. Our District also includes the Chichester Harbour AONB, Pagham Harbour Special Protection Area and Medmerry Compensatory Habitat.  All these are excluded from development. This leaves a very limited area of land for housing allocation and inevitably squeezes development into a limited number of areas within the City, on the East-West corridor from Tangmere to Southbourne and on the Manhood Peninsula which is in the Southern Coastal Plain and is very fertile.

Suitable sites for development are assessed via a Housing and Economic Land Availability Assessment (HELAA). Sites from the HELAA are selected and identified for potential future development.

Local opposition to Highways England proposals for the A27 road improvement resulted in cancellation of their proposals.  This has hindered the Local Plan Review as many of the assumptions around road capacity that informed the initial site allocations and transport capacity work had to be abandoned following the scrapping of the scheme by central government. New rules on nutrient neutrality in the waters of the Solent introduced by Natural England in June 2019 have further added to the delay of the Review.

The LP has now become out of date. Its Review is now behind schedule and as of July 2020, CDC can no longer demonstrate a five-year land supply to deliver housing. This leaves our communities vulnerable to speculative applications to bring forward sites within the HELAA assessment, which are by definition regarded as sustainable.  We now live with an Interim Policy Statement aimed at limiting ‘planning by appeal’.

In August the government proposed changes to existing planning law to come into effect later this autumn.

The first was called Changes to current Planning System. It does not need primary legislation. Of particular concern are the changes to the formula used to establish the OAN.  It is calculated that the new formula will result in an increase in the OAN for the CDC area from 628 to 995 dwellings per annum, a large increase.

Secondly and at the same time, the Government published a Planning White Paper called Planning for the Future the object of which is to ensure that at least 300,000 new dwellings are built in England each year. This does need primary legislation and is the biggest change to planning policy since 1947. It is to be achieved by zoning areas for ‘growth’, ‘renewal’ or ‘protection’.  It proposes public participation at the consultation stage when Local Plans are drafted but reduced public consultation later on when development in ‘growth’ areas comes forward – in fact leading to abandoning the need for outline planning applications altogether in many cases. The proposal is that automatic outline permission is given for new development in “growth” areas and for “beautiful” schemes.

At present it can take 5 to 10 years to create a LP and the White Paper aims to reduce this to just 30 months. LPs will be much shorter (a reduction of 2/3rds in size is envisaged).  The new style LP will be just a ‘core set of standards and requirements for development’.  All this will be achieved by making new LPs subject only to the NPPF ‘sustainability’ test, by abolishing the test of ‘soundness’, abolishing ‘sustainability appraisals’ and abolishing the ‘duty to cooperate’.

Once new style LPs are in place it is proposed to limit the time it takes to determine planning applications to just 8 or 13 weeks and to achieve this, the White Paper is suggesting that LPAs must refund application fees if they exceed these periods.

We have made comments on both consultations.

Comments on ‘Changes to current Planning System’.

Below are the views of the Chichester Society on the first consultation Changes to current Planning System:

“Because of the amount of protected landscape (SDNP & AONB) within the Chichester District so little is left that is capable of development and almost all that there is comprises high grade agricultural land in farming production mainly within the southern coastal plain.  With the need to increase food production, this area has some of the most fertile land in England with long sunshine hours capable of high levels of agricultural output.  To destroy this natural resource and instead to build houses upon it makes no economic sense.

 The housing numbers imposed on any Local Planning Authority area should not be determined by the actual size of the authority area but on the size of those parts which have no physical or environmental limits to development. Therefore, we consider that assessment of housing numbers in any District area should be reduced by the omission of those parts:

  • within a National Park,
  • an AONB,
  • of land liable to flood,
  • of grade 1 & 2 agricultural land,
  • of wildlife corridors
  • and of greenfield land important to the setting of the National Park, AONB or City.

In addition, in Chichester, so much of the demand for housing comes from completely outside the area by the insatiable demand from those elsewhere in England seeking to relocate, many for early retirement. Priority in the allocation of new housing should be given to local residents and young people

Comments on the White Paper ‘Planning for the Future’

The Chichester Society has made comment on the second consultation which is the planning White Paper called Planning for the Future set out below:

  • The White Paper proposes the encouragement of public participation at the consultation stage of Local Plan preparation so as to reduce consultation later on when development in comes forward.

Comment: We oppose the limiting of public engagement. Our experience has been that the standard of design falls once development is applied for. We believe that all development should continue to be the subject of individual planning applications. Public engagement is considered essential if the planning process is to be seen as trusted. Paragraph 2.48 of the White Paper states that peoples’ right to be heard in person will be changed at local plan inquiries. Planning Inspectors will be given the discretion over the form that an objector’s representation might take with the ‘right to be heard’ during a public forum removed. The right to appear and be heard could be replaced with the opportunity for an Inspector to call objectors over the phone or ask for further written comments at the Inspector’s discretion. The issue of limited public involvement  becomes even more important when one considers that the opportunity to engage in the planning application process is also being diminished by the new proposals.

  • Making Local Plans subject only to the NPPF ‘sustainability’ test. Abolishing the test of ‘soundness’, abolishing ‘sustainability appraisals’ and abolishing the ‘duty to cooperate’.

Comment: These tests are seen as essential. We are concerned about funding for essential infrastructure.  The White paper is largely silent on effective mechanisms for achieving infrastructure, housing or flood risk.  The removal of the ‘Duty to Cooperate’ raises concern as how consideration will be given to resolving strategic cross boundary issues such as major infrastructure. 

  • Involve communities in setting design codes in their area for Local Plans.

Comment: The planning system was previously reformed to address concerns that it was not sensitive enough to local needs and this brought about Neighbourhood Plans.  It is particularly unclear how Neighbourhood Plans will fit into the proposed new zonal planning system.  There is no clarity about the scope and power of Neighbourhood Plans in the new system. The current proposals would appear to reduce the role of Neighbourhood Plans to local design guides. 

  • Altering the system such that all land falls within one of 3 planning zones– a ‘growth area’ suitable for substantial development’, a ‘renewal area’ which means an existing built up area which is considered suitable for development or ‘densification’ and finally a ‘protected area’ where more stringent development controls apply.

Comment: We have concern that public support to agree where ‘growth’ is to take place will be difficult, perhaps impossible.

  • Limit the time to determine planning applications to 8 or 13 weeks and to achieve this, to consider making LPAs refund application fees if they exceed these periods.

Comment: Such pressure is only likely to reduce public confidence in the planning system. 

  • Increase land owner / developer contributions when land is given planning permission for development

Comment: Support

  • Replace paper with digital code: interactive maps, modelling and text messaging.

Comment: Support

ChiSoc responds to UK Government Consultation on changes to the planning system

The Chichester Society has submitted a response to two Government documents relating to the planning system.

First the Government has published a consultation document on changes to the planning system a copy of which can be viewed here. The consultation ends at 11:45pm on 1 October 2020. Ways for members of the public to respond can be found here.

Second the Government has also issued a White PaperPlanning for the Future’ which can be found here.

The Chichester Society Executive Committee has submitted the following response:

To Civic Voice

The Chichester Society is making the representations set out below to Government on the two planning Consultations.

  • Changes to current Planning Systems, a consultation paper with proposals to improve the effectiveness of the current system. It will be found on this link:

Our comment:

Whereas under current policies the assessment of how many new dwellings are to be planned for in any given district is subject to a cap, which applies as a limit to the number, the new method will remove that cap. In addition, statistical sources for determining the starting number of new homes will now involve the use of the ‘higher of’ of various statistics. The Chichester District Local Plan 2015 which expired in July this year contained a requirement for 435 dwellings per annum. We understand that the number will increase to 995 dpa or thereabouts as a result of the changes now proposed which we consider excessive.

These changes pay no regard to local circumstance. They treat all parts of England in the same way.  We believe that the individual character of our District areas should be assessed rather than our being handed a formula of “one size fits all”.

Because of the amount of protected landscape (SDNP & AONB) within the Chichester District so little is left that is capable of development and almost all that there is comprises high grade agricultural land in farming production mainly within the southern coastal plain.  With the need to increase food production, this area has some of the most fertile land in England with long sunshine hours capable of high levels of agricultural output.  To destroy this natural resource and instead to build houses upon it makes no economic sense.

The housing numbers imposed on any Local Planning Authority area should not be determined by the actual size of the authority area but on the size of those parts which have no physical or environmental limits to development. Therefore, we consider that assessment of housing number in any District area should be reduced by the omission of  those parts:

  • within a National Park,
  • an AONB,
  • land liable to flood,
  • grade 1 & 2 agricultural land,
  • wildlife corridors
  • and greenfield land important to the setting of the any National Park, AONB or City.

In addition, in Chichester, so much of the demand for housing comes from completely outside the area by the insatiable demand from those elsewhere in England seeking to relocate, many for early retirement. Priority in the allocation of new housing should be given to local residents and young people

 

2          Planning for the Future (The White Paper) will be found on this link:

Our Comment

  • It is proposed to reduce the content of Local Plans. The changes envisage reducing the size of LPs by ‘at least 2/3rds’ by cutting out all lists of ‘policies’ and instead producing a ‘core set of standards and requirements for development’.

Comment: This is a huge task for Local Planning Authorities with limited staff and expertise to create what will need to be site specific sets of ‘standards and requirements for development’ on all areas where ‘growth’ or ‘renewal’ is to be zoned.

  • Encouraging greater public participation at the consultation stage of LPs so as to reduce consultation later on when development in ‘growth’ areas comes forward – in fact leading to abandoning the need for outline planning applications altogether in many cases. The proposal is that automatic outline permission is given for new development in “growth” areas and for “beautiful” schemes.

Comment: We oppose the limiting of public engagement on where new development is to be allocated to that period during the Local Plan preparation. Our experience has been that the standard of design falls once development is applied for. We believe that all development should continue to be the subject of individual planning applications.

  • Making LPs subject only to the NPPF ‘sustainability’ test, abolishing the test of ‘soundness’, abolishing ‘sustainability appraisals’ and abolishing the ‘duty to cooperate’.

Comment: These tests are seen as essential in preventing a ’developers’ charter.

  • Limit content of LPs to that of setting out site or area specific parameters.

Comment: This is a huge task beyond the capacity of most District PLA’s and would need major public engagement to be seen as trusted.

  • Involve communities in setting design codes in their area for LPs.

Comment: Looking at the National Design Guide published in Oct 2019, it says almost nothing about community involvement in setting local design codes which we think it should have done. Communities will want involvement provided they believe they will be listened to.

  • Nationally to set a new infrastructure levy for infrastructure and affordable housing.

Comment: no comment

  • Alter Local Planning Authority (LPA) planning roles to that of appointing a chief officer for ‘design and place making’. The indication is that this may become a ‘statutory appointment’.

Comment: no comment

  • Altering the system such that all land falls within one of 3 planning zones– a ‘growth area’ suitable for substantial development’, a ‘renewal area’ which means an existing built up area which is considered suitable for development or ‘densification’ and finally a ‘protected area’ where more stringent development controls apply.

Comment: We have concern that public support to agree where ‘growth’ is to take place will be difficult, perhaps impossible. We consider allocating land for ‘renewal’ and ‘protection’ will be easier.

  • Limit the time to determine planning applications to 8 or 13 weeks and to achieve this, to consider making LPAs refund application fees if they exceed these periods.

Comment: Such pressure is only likely to reduce public confidence in the planning system.

  • Reduce the time to produce a LP to just 30 months, with the threat of government intervention if exceeded. Give Planning Inspectors holding LP examinations the right to decide who is called to give evidence, the intention being to shorten the process.

Comment: This is a huge task for LPA’s with limited staff and expertise to create what will need to be site specific sets of ‘standards and requirements for development’ on all areas where ‘growth’ or ‘renewal’ is to be zoned.

  • Increase ‘permitted development’ rules

Comment: still under discussion

  • Increase land owner / developer contributions when land is given pp for development

Comment: Support

  • Replace paper with digital code: interactive maps, modelling and text messaging.

Comment: Support

 

Planning application responses – 29 May 2020

The following submissions were approved by the Society’s Executive Committee.
The entries below comprise the planning application number, brief details of the address and the subject of the application and the Society’s response.

You can view the planning application and any associated documents by quoting the application number at the District Council’s website here

20/01082/PLD
4 Alexandra Road, Chichester. Removal of front wall
Requested that this application is disallowed and an enforcement notice served on the applicant

20/01120/DOM
43 Bisopsgate Walk, Chichester. Part 2 storey and part single storey rear extension.
Requested that this application is refused pending a sensible rethink of the roof form.

20/01155/DOM
5 Tregarth Road, Chichester. Single storey rear and side extenson and loft extension and front porch.
Requested that this application is refused

Good by Design – The view of the Horsham Society – so what is ours?

‘Good by Design’ is the Horsham Society’s views on what constitutes good design in Horsham. It combines and expands content from the Horsham Town Design Statement adopted by Horsham District Council in December 2008 and from the Design Protocol of Chichester District Council, December 2013. Click here to view their document.

The notes are intended as guidance as to what the Horsham Society is looking for and are  intended as starting point and the employment of judgement and evaluation are very much matters for the observers themselves.

So what are our views on such matters for Chichester?

The Chichester Society, through its Executive Committee, recently made known its views on the Chichester District Council’s Local Plan Review (the Review is available here).

In particular in relation to ‘ Section S20 – Design’ (reproduced below from the Review)  ‘ChiSoc welcomed this additional policy and supported its purpose in the Plan

Policy S20: Design

All proposals for new development will be required to be of high quality design that:

  1. responds positively to the site and its surroundings, cultural diversity and history, conserves and enhances historic character and reinforces local identity or establishes a distinct identity whilst not preventing innovative responses to context;
  2. creates a distinctive sense of place through high quality townscape and landscaping that physically and visually integrates with its surroundings;
  3. provides a clear and permeable structure of streets, routes and spaces that are legible and easy to navigate through because of the use of street typology, views, landmarks, public art and focal points;
  4. is well connected to provide safe and convenient ease of movement by all users, prioritising pedestrian and cycle movements both within the scheme and neighbouring areas and ensuring that the needs of vehicular traffic does not dominate at the expense of other modes of transport, or undermine the resulting quality of places;
  5. incorporates and/or links to high quality Green Infrastructure and landscaping to enhance biodiversity and meet recreational needs, including public rights of way
  6. is built to last, functions well and is flexible to changing requirements of occupants and other circumstances;
  7. addresses the needs of all in society by incorporating mixed uses and facilities as appropriate with good access to public transport and a wide range of house types and tenures
  8. is visually attractive and respects and where possible enhances the character of the surrounding area in terms of its scale, height, density, layout, massing, type, details, materials,
  9. provides a high standard of amenity for existing and future neighbours, occupiers and users of the development;
  10. creates safe communities and reduces the likelihood and fear of crime;
  11. secures a high quality public realm with well managed and maintained public areas that are overlooked to promote greater community safety, with clearly defined private spaces;
  12. ensures a sufficient level of well-integrated car and bicycle parking and external storage;
  13. is sustainable and resilient to climate change by taking into account landform, layout, building orientation, massing and landscaping to minimise energy consumption and mitigate water run-off and flood risks.
Now it’s your turn!

We would welcome your views on such design issues whether on major developments or ones that affect a particular locality. You may do so via our contact page. However before doing so you might like to consult the full Local Plan Review here

ChiSoc responds to the Local Plan Review

Having considered the content of the Review document the Society has filed the following comments and suggested changes on development principles, transport strategy, design, the Southern Gateway and land allocation.

Please refer to the original document here for background to the comments

On Policy S13: Chichester City Development Principles

  • ChiSoc welcome the minor changes proposed which include the protection of views of the cathedral. Please note the duplication of the policy on the city’s existing heritage, arts and culture

On Policy S14: Chichester City Transport Strategy

  • ChiSoc propose the following additional measures are included:
  • Replacement of the level crossings in Basin Road and Stockbridge Road by an underpass or bridge
  • Safeguarding of land to enable the expansion of the Chichester railway Station, its tracks and platforms, from 2 to 4 to enable a fast train service
  • Safeguarding of land close to the A27 for a future “park and ride”
  • Safeguarding of land close to the A27 for a “consolidation centre” for break bulk delivery to city retail units.

On Policy S20: Design

  • ChiSoc welcome this additional policy and support its purpose in the Plan

On Policy S23: Transport and Accessibility

  • ChiSoc welcome this additional policy and support its purpose in the Plan.
  • It especially welcomes the proposed New road connecting Birdham Road to A27 Fishbourne roundabout (see Policy AL6), known as the Stockbridge Link Road when first proposed by Highways England as part of Option 2b in the 2016 Consultation.

On Policy AL5: Southern Gateway

  • ChiSoc propose the following changes are made:
  • In site specific requirement number 3 we propose “3. Respect for the historic context, have regard to that part of Southern Gateway that lies within the Conservation Area and to the Listed Buildings and Heritage Assets, and make a positive contribution towards protecting and enhancing the local character and special heritage of the area and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
  • We propose to add as site specific requirement number 4 “provision of a bridge or underpass to allow the removal of the level crossings on Stockbridge Road and Basin Road”
  • We propose the removal of paragraph 7

On Policy AL6: Land South-West of Chichester (Apuldram and Donnington Parishes)

  • ChiSoc supports this new policy, and its land allocation.

Local Plan – The Final Chapter

Chichester’s Draft Local Plan

Following protracted hearings during the autumn of 2014, dissecting and reviewing the District Council’s draft Local Plan, Sue Turner, the Planning Inspector for the Examination in Public (EiP), delivered her report which is available on the CDC website.

She has approved CDC’s Plan on condition that numerous amendments are added.

Here is the Society’s take on the result:

  1. Overview The Local Plan has to sit within the bounds set down by the National Planning Policy Framework (NPPF)[1] which is created by central Government and underlies the entire plan-making process. Subject to the amendments mentioned above, the Inspector found that the Local Plan is indeed aligned with the NPPF.
  1. ‘Duty to Co-operate’ Draft Local Plans fail if they are not created as a result of co-operation and consultation between adjoining councils, public agencies and other stakeholders[2]. The Society argued at the EiP hearings that CDC had not met this requirement. The Inspector disagreed. She decided: ‘in preparing the Plan the Council has … engaged effectively with prescribed bodies to address strategic matters. It has therefore met the duty set out in section 33A of the 2004 Act’ (page 5, paragraph 11)
  1. ‘Soundness’: ‘Soundness’ is fundamental when assessing whether a Draft Local Plan is fit for purpose[3].In assessing soundness, the Inspector framed the EiP hearings around nine ‘issues’, asking whether the Plan:
    • Is a ‘robust strategy’
    • Is supported by ‘robust infrastructure planning’
    • Identifies ‘objectively’ the need for market and affordable housing
    • Maximises housing delivery
    • Provides for a ‘thriving local economy’
    • Allocates strategic development sites based on ‘robust evidence’
    • Identifies development sites through Neighbourhood Plans
    • Has environmental policies that are ‘soundly based’
    • Has effective built-in monitoring and delivery

Sue Turner concluded(page 27, paragraph 132) ‘that with the recommended main modifications set out in the Appendix the Chichester Local Plan satisfies the requirements of Section 20(5) of the 2004 act and meets the criteria for soundness in the National Planning Policy Framework’.

  1. A closer look at the Inspector’s opinions: the following comments focus on a few of the EiP report’s themes likely to be of interest to the Society’s members. The abbreviation “MM” signifies “Main Modification” (as listed in the appendix to the Inspector’s Report).
  • A ‘robust strategy’: the Inspector accepted the Plan’s intention to focus new development in an ‘East-West Corridor’ (para 15) after receiving CDC amendments which include:

‘The East-West Corridor is the main focus for new development proposed in the Local Plan…The Plan seeks to accommodate new growth within and around the city and to enhance its role as a sub-regional centre and visitor destination. However it is recognised that new development needs to be planned sensitively with special regard to the city’s historic environment and setting, whilst also addressing key infrastructure constraints, particularly in terms of wastewater treatment capacity and transport….’ (MM26).

  • Infrastructure planning: this technical section includes CDC amendments (MM22) about cycling and pedestrian infrastructure design; and about Apuldram Wastewater Catchment Area (MM 35). The Inspector observes ‘the Plan takes account of the need for strategic infrastructure and demonstrates that it can realistically be provided to ensure that the level of development that is proposed can be delivered’ (para 37).
  • Housing need estimates: CDC has increased its estimates for new homes required each year (MM7) to 505, excluding the National Park. The Inspector concurs (para 42).
  • Maximising housing delivery: the report identifies a mismatch between data on new homes needed, averaging 505 a year, and supply averaging 415. The reason relates to constraints in infrastructure such as A27 road works and wastewater drainage. This conundrum has been resolved for the present by CDC submitting an amendment (MM9) that acknowledges the supply gap:

‘For this reason the Council will review the Local Plan within five years to ensure that OAN (Objectively Assessed Need) is met…’.

The Inspector: ‘For these reasons I conclude that the Plan should be adopted now, subject to a commitment to a review to be completed within five years….(para 56).

  • Four strategic development sites:
    • West of Chi: target numbers during the Plan period increased from 1,000 to 1,250 (para 83). The Inspector notes local concern and uncertainty about sewerage treatment routes to Tangmere WwTW and proposals for an on-site treatment facility; but because the Plan is a strategic document detailed proposals are ‘not appropriate’ at this stage. ‘In these circumstances the provision of wastewater treatment facilities does not prevent a barrier to developing the West of Chichester’ (para 85).
    • Westhampnett/NE Chi: ‘I am satisfied that the Plan’s flexible and pragmatic approach to addressing the buffer between Goodwood and new housing development is appropriate and effective’ (para 93).
    • Shopwyke Lakes & Tangmere: are ’soundly based and deliverable.’ (paras 89 & 102).
  • Environment policies – protecting heritage assets: English Heritage was concerned and the outcome is six amendments to the Plan (MM100-105). The Inspector is satisfied ‘that the Plan includes an effective strategy to ensure the District’s heritage assets can be protected and which is consistent with the NPPF’.
  1. The ChiSoc view: The inspector’s conclusions are disappointing. On a number of points we felt that the evidence demonstrated failure of the Local Plan. The inspector concluded otherwise. On the issue of the duty to co-operate, we felt we had provided evidence of inadequate co-operation with Havant BC. The inspector concluded that there had been sufficient co-operation. On West of Chichester Strategic Development Location (SDL), despite numerous objections concerning inadequate transport infrastructure and wastewater treatment, which would make the site an unsuitable SDL, the inspector decided that these major difficulties were not a matter for the Local Plan but for resolution during the detailed planning process.

[1] The NPPF can be viewed at www. gov.uk  Plan-making processes and policies are described from page 37

[2] NPPF, pages 42-43, paragraphs 178-181

[3] NPPF, page 43, paragraph 182

Local Plan – What’s been happening?

Local Plan – What’s been happening?

The Examination in Public (EIP) of Chichester District Council’s Local Plan took a break during the latter half of November while the District Council, on the recommendation of the Planning Inspector, reviewed its original housing target figure of 6,973 new homes to be built during the plan period (to 2029).

When the EIP resumed on 2 December, the Council outlined how it had reviewed its figures and proposed new, increased figures. The total number of new homes proposed would rise to 7,388 homes during the plan period, an increase from 410 per annum to 435. Of this increased number the overwhelming proportion, 250 homes were to be located at the West of Chichester Strategic Development Location, viz., Whitehouse Farm.

Notwithstanding the ‘encouragement’ from the Planning Inspector to review their methodology and maximise the number of homes to meet the objectively assessed need (OAN) for housing, there remains considerable doubt that the Council has come up with a satisfactory figure – anyway certainly not in the eyes of the developers.

The EIP sat for two days at the beginning of December before taking another break.

During the break the Council compiled its Draft Modifications to the Local Plan, which had arisen during and as a result of the Examination In Public. These modifications were approved by the District Council on 22 December.

On 8 January 2015 the modifications were put out for public consultation for a six week period ending on 19 February.

It is anticipated, though not certain, that the following will happen over the next weeks and months. First the Planning Inspector will consider the responses to the consultation on the modifications. A reconvening of the EIP may happen in late March. Sometime later the Inspector’s report will appear. The report may or may not approve the Local Plan.

Meanwhile there is the little matter of District Council elections, not to mention a General Election. The District Council will go into ‘purdah’ in April.

So one thing is for certain, it will be a different District Council, indeed a different Government that will be picking up the loose ends from the long-running saga of the Chichester Local Plan.

Local Plan – ChiSoc Submissions

The Society has written two submissions for the Examination in Public of the Chichester District Local Plan.

For our thoughts about the Council’s “Duty to Cooperate” click here (PDF document*).

For our thoughts about housing numbers and where new houses should go, click here (PDF document*).

And for an earlier posting giving our (somewhat jaundiced) thoughts about the whole Local Plan process, click here.

*If the term “PDF” means little to you, click here.

The Draft Local Plan

 

The Draft Local Plan from October 2013 to September 2014

Chichester District Council compiled a new Local Plan and, as of October 2013 it arranged two substantial Public Consultations to seek the views of residents, businesses, and the wider community about the proposals. To consult the original draft Plan open this pdf file here

The first round of consultation lasted from March to early May, the majority of responses being via the District Council’s website. A copy of the Society’s formal response is available in this pdf file here.

During this first Consultation the Society briefed its members about the draft Plan and to view a copy of this four-page advice note see this pdf file here. – note the page-turning facility by placing your mouse-pointer on the page edges. This feature is made possible by software offered to charities free of charge although there may be a few adverts.

The Chichester Society opposed proposals to develop on greenfield sites on the city’s western and eastern margins as being hugely detrimental to Chichester’s unique character. We believed that more emphasis must be put on developing ‘brownfield’ sites such as Shopwhyke Lakes to the south east. We also questioned the methodology for calculating the number of new homes required. We also questioned whether the Council’s development aspirations can be fulfilled while there are notable infrastructure problems – principally roads and drainage. The Society explained its position in a memorandum mailed in July to each District Councillor in person, and later published in the September edition of the Newsletter. To view this briefing, see this pdf file here – note the page-turning facility by placing your mouse-pointer on the page edges. This feature is made possible by software offered to charities free of charge although there may be a few adverts.

Local Plan and Planning Concept Statements

Chichester residents will be increasingly aware that the Draft Local Plan proposes extensive new areas of housing plus a small amount of employment on what the District Council calls ‘strategic sites’ around Chichester.

As the Society reviews the developing Local Plan, these sites feel very far short of real strategic planning. Rather they have come to the fore simply as a result of developers proposing patches of land that they own (or have options on). And the Council has not had the resources – or the foresight – to do much more than acquiesce.

Be that as it may, the approval or otherwise of the sites now rests with an Examination in Public in September, when the Plan will be scrutinised by an Inspector appointed by Whitehall. Somehow, this process again seems to fall short of the much-vaunted idea of Localism!

Further, despite this official timetable, the developers are now doing their best to jump the gun. They are preparing plans (as at Whitehouse Farm) and submitting planning applications (as at Westhampnett) in advance of any approval under the incoming Local Plan. Presumably, they see an advantage in being ready to go as soon as the Local Plan is approved, rather than starting from scratch when – or rather if – it is.

Another incentive for developers to push the pace is that, if development begins early, they are likely to be liable for much smaller contributions to local communities, in terms of playing fields, village halls, road improvements and the like.

This is because, at present, developers give back to the community through “Planning Gain” in the form of ‘Section 106’ agreements, which are widely seen as less onerous than the system of Planning Gain through the ‘Community Infrastructure Levy’ (CIL) that will come in with the Local Plan.

To oppose this juggernaut, the District Council has invested some effort in erecting defensive screens called ‘Concept Statements’. These are intended to be indications of how the council would like the site to be developed, formulated by ‘community planning’. Which is admirable, you may say, and in principle that is true.

But in practice, the community meetings have been squeezed into a foreshortened timetable. The Tangmere one was brought forward from September to June without due notice, and the Westhampnett one happened before anyone in Chichester City had heard about it!

Local parish councils did know; but the developments are on a district-wide scale and would weld the new strategic sites irrevocably to Chichester itself. This is an extension of the problem of pitting under-resourced local councils against over-resourced developers backed by central government.

Worse, it now appears that these Concept Statements may be worth little more than the paper they are written on. They are apparently only a ‘material consideration’ which effectively means that a developer can ignore them if they can find any reason for doing so.

To illustrate the point, the developers who want to build on the corner of Stane Street and Madgwick Lane managed to get through a 2-hour presentation and question session without mentioning concept statements once; and the developers for Whitehouse Farm mounted an exhibition of their plans for the site before the concept statement for that area has even been published.

We will look back in 20 years’ time and wonder how Local Government ever deserved that name.

Development east of Chichester “may damage the future of Rolls Royce”

So says Mr. Torsten Müller-Ötvös,  the chief executive of Rolls Royce Cars, about plans to build on the green fields between Chichester and Rolls Royce’s “Telly Tubby” (sedum roofed) factory at Westhampnett.

In a report in the Chichester Observer, he explains “Rolls Royce will effectively be located within a housing estate that is indistinguishable from any UK urban location; exactly the situation we sought so hard to avoid” when they planned their move into the area.

The Society has its own reservations about this planning application, which is just the latest instance of growing piecemeal destruction of the rural surroundings of the city and the wider district.

In fact, we have rather a lot to say. In our response to planning application 14/01159/OUTEIA, we have commented that this development:

would meet none of the three dimensions to sustainable development as required under the Government’s National Planning Policy Framework: Economic, Social or Environmental;

would adversely impact on the Economy of the Goodwood Estate and the Rolls Royce plant, both of which derive major benefits from the ambience of their settings;

would fail to integrate with, and would indeed overwhelm, the social character of Westhampnett village; and

would destroy the rural environs of Chichester, Westhampnett and Goodwood, and harm the setting of the South Downs National Park.”

We also noted that the Draft Local Plan identifes no need for extra housing at Westhampnett. But permission has nevertheless been given for 100 houses on another nearby site. So Westhampnett is already delivering more than is being asked of it.

For a longer summary, see here. Or to read our submission in full, see here.

Objection to Westhampnett housing development

The Society objected to the large scale housing at Westhampnett. The following is a summary of its submission to the Chichester District Council.

1) This site conflicts with ‘saved policies’ to “protect the rural area” (Policy RE1), protect the identity of settlements (RE6), and to protect the local environment and setting in the landscape (BE11).

2) Any outline planning application here is premature.

3) The site is well beyond the Settlement Policy Area … and can’t even be integrated with the existing village.

4) The site failes no less than six of the criteria set out in Interim Policy Statement on Housing (FAD) of July 2012. Sadly this statement no longer has force, but it’s reasoning remains sound.

5) Any housing here would intrude into views from and into the South Downs National park, and hence would detract from the experience of visitors to the National Park, not to mention local events including the horseracing at the top of the hill and the festivals at the bottom of the hill at Goodwood.

6) The prosed link road into the development would detract from the rural quality of the lane and would also destroy a section of mature hedgerow identified as part of a Bat network.

7) The Draft Local Plan identifes no need for extra housing at Westhampnett. Even so, planning permission has been permitted for 100 houses on another nearby site. So Westhampnett is already delivering more than is being asked of it.