Category Archives: Neighbourhood Plan

Proposed land swap involving Bishop Luffa School – give the Council your views

The City Council say there is the potential to swap some parcels of land between the Bishop Luffa School and the West of Chichester development site. This would enable a new extended school for ages 4-18 to be delivered on the West of Chichester Site, adjacent to the newly permitted sports pitches, and the existing school site would then be developed for housing, which would fund the building of the school. Bishop Luffa School are keen for such a land swap to go ahead. The proposal document can be viewed here.

The Council wants to know the views of locals – voting can be done online here or by indicating a preference via the last page in the document – returning it to the Council.

Voting will close on 15 December 2020

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

 

Neighbourhood Plan launch to seek views

Public Launch for the Plan

A public consultation launch for the Neighbourhood Plan was made by Cllr. Richard Plowman, Mayor of Chichester on 14 October 2019 in the City’s Assembly Rooms, attended by over 100 including residents, members of the public and representatives from a number of local organisations. The presentation can be viewed here and the notes from the meeting here. The boundary of our Parish is viewable here.

Ten fundamental principles were laid down:
  1. The City declared a climate change emergency in June 2019 which must be backed by real and effective action.
  2. The City will be carbon neutral by 2030.
  3. The City Centre to be free of all fossil fuelled powered vehicles, the use of electrical vehicles to be encouraged and all deliveries to be made by electrical vehicle transport.
  4. The City to remain small and compact essentially a large historic market town in a rural setting and to position it to be a Unesco World Heritage site by 2032
  5. The City parks and green open spaces to be protected and enhanced. Re-wilding of derelict areas and use of more trees in the urban areas to produce natural wildlife corridors and public spaces such as squares throughout the City with zoning of areas with different characteristics eg retail, restaurant and evening economy.
  6. The City views are determined by the Cathedral and these views respected and all buildings to be subservient and generally no more than four stories high.
  7. The City economy needs revitalising particularly the City Centre and attracting more visitors to the City
    through Tourism, and the Meetings, Incentive and Conference industry (MICE).
  8. The City to maintain, enforce and expand areas of Conservation and preserve buildings of both historic, social cultural and architecturally.
  9. The plan to be holistic and inclusive for all people of Chichester (elderly, families, young, students, disabled and disadvantaged).
  10. The Neighbourhood Plan will be made by the People for the People of Chichester and will be part of Planning Legislation.
Aims to be achieved

The following were cited:

  1. Large international hotel of 200-250 beds (needs meeting and conference facilities)
  2. Large multi-use events/ performance/ exhibition/ conference hall
  3. Removal of level crossings and replacement with low level underpass
  4. More train and bus services to and from Chichester and metro line to Bognor Regis
    and coast
  5. Concert/ Theatre Hall up to 550 capacity (possibly the Court Building)
  6. Large Nightclub
  7. Central Medical centre
  8. New Crematorium
  9. HiTec village for graduates/millenniums near Station
  10. Zoning of areas in the City for better navigation eg North Street, East Street for Retail
    and service, Central Cross area for banks and jewellers. West Street – Cathedral and
    cultural. South street restaurant, bars and evening economy. Eastgate square and St
    Pancras village
  11. Improved public realm increased pedestrian areas and signage. Cathedral square
  12. Public square for Farmers and special markets e g Christmas/ Ice rink.
  13. Cultural trail linking Galleries and Theatre

 

GET INVOLVED

To elicit views of residents and the public an online survey is being used and can be viewed here. The survey closes at 5pm on Monday 9th December 2019

The City Council has a dedicated website page and a Facebook account to enable progress on the Plan to be followed and views to be expressed.

 

You can also add your comments to this post below