Goodwood Estate Matter 7: Strategic Development Locations (SDLs)
Chichester Local Plan: Key Policies 2014 - 2029 Matter 7: Strategic Development Locations (SDLs)
Supplementary Statement submitted on behalf of the Goodwood Estate
Contents
Statement 2
Appendix 1 Flood Map for Planning (Environment Agency, 2014) 8
Terence O’Rourke Ltd. Page 1 of 8 August 2014
Goodwood Estate Matter 7: Strategic Development Locations (SDLs)
Statement
Scale, Location and Quantum of Development
We believe that the scale of housing proposed for the district is inappropriate, (as we believe the assessment has treated the District in isolation, without a true assessment of the impacts of the travel to work area and desire over need). If the level of housing proposed is found to be correct, The Estate believes that if all constraints are taken into account appropriately and objectively the strategic allocation of development in and around the city should follow a different pattern. It is documented that the Estate objects most strongly to the allocation of land to the north-east of the city (Old Place Farm) as a strategic housing location; its reasons are set out fully in representations and has been discussed with the local planning authority, but to summarise the strategic allocation at Old Place Farm ignores the very special circumstances and character of the city and its environs that should temper and qualify its objectives. The approach is one of standardisation, following a process that ignores key elements that make Chichester special and underpins its economic base, and has not taken account of all environmental and infrastructure constraints.
The boundary of the Old Place Farm allocation is not justified by robust evidence. The allocation boundary does not take account of environmental constraints, and the scale of development proposed is greater than the capacity of the site. Additionally the impact of the strategy on key economic drivers has been ignored; Goodwood and Rolls-Royce, individually or collectively represent a major source of inward investment and employment and it is imperative that the local plan ensures that the ability of both enterprises to grow and flourish is not impeded by inappropriate policies and proposals. In a recent radio discussion chief secretary to the Treasury Danny Alexander outlined the Government’s view that despite its many initiatives and the undoubted growth in the economy, businesses are still showing signs of a lack of investment, due in part from a lack of confidence. The planning process plays an important role in that confidence base and it is vital local plan are correctly prepared and make proper provision for economic growth through setting an appropriate framework for investment.
Rolls-Royce and Goodwood are part of the UK automotive industry, one of the Government’s key sectors for investment to lead the country on the road to recovery. The deficiencies of the plan, and its potential negative effect on the sustained growth of the businesses have been brought to the attention of the planning authority repeatedly since the plan was published, including through our representations. However, no change or modification to the plan has been proposed in the headlong pursuit of a document and five-year land supply at all costs. This is a clear example of what the minister was referring to, where further investment in key economic drivers is frustrated by a lack of confidence brought about by poor planning decisions. A local plan evidence base which ignores key economic drivers and the affects of new strategic development upon them is clearly deficient, and the conclusions reached that manifest themselves in those strategic allocations must be similarly flawed.
The strategic allocation at Old Place Farm is a threat to the economic survival of the estate and we question if it is imperative at this time to proceed with it, as the risks to growth are significant compared to the limited benefit of meeting a housing need. We believe the housing target can be met in other ways, and, as the site cannot be brought forward until later in the plan period in any event due to significant constraints that apply – such as foul drainage and, we believe highways (A27 improvements – supplies to
Terence O’Rourke Ltd. Page 2 of 8 August 2014
Goodwood Estate Matter 7: Strategic Development Locations (SDLs)
Rolls-Royce are already frustrated by poor traffic links and congestion), to remove this allocation now would provide certainty for investment and time to find an alternative strategy. Immediate housing need, and that required for the next five years or more, can be met by other allocations not so constrained. The Old Place Farm allocation is not a popular one locally, as it cuts across many of the factors deemed important to the community, including landscape, heritage setting and character, as well as the significant local concern of A27 traffic.
A major impediment to the development of the allocation at Old Place Farm is the issue of noise. Since our representations were submitted there have been a number of documented planning cases where noise, particularly from motor circuits, is cited as giving rise to unacceptable (even intolerable) living conditions. Goodwood motor circuit, and the associated aerodrome, is a long-standing, lawful use, which is strictly controlled by planning approval. However, even with the strict management regime imposed on circuit and aerodrome activities, complaints against noise generated have become commonplace over many years. Complaints have been raised by residents in the Summersdale area of Chichester, even though the levels of noise generated are within permitted levels. The Estate does everything it can to minimise noise disturbance, but the fact that complaints continue to arise demonstrates most clearly that it is unsound planning to allocate further housing within earshot of the circuit. To do so will inevitably lead to more complaints – which can be avoided if the allocation is distributed differently.
Since we raised the issue through representations, those with interest in the Old Place Farm allocation have sought to demonstrate that their studies show that noise levels do not affect all of the site, are low across parts of the allocation, or can be mitigated through design and physical barriers. However, evidence suggests that this is not the case. Noise readings within existing residential areas on the edge of Chichester fall within stated limits of toleration, yet the Estate continually receives complaints, and not only from those closest to the circuit, that noise levels are unacceptable. It is suggested that sales of new properties at the Greylingwell hospital, a recent redevelopment to the west of the circuit, are slow due to the proximity to the circuit and potential noise disturbance. When that application was proposed the Estate raised the matter with the council and developer, but it was considered that a suitable layout and appropriate glazing would be sufficient to mitigate any potential disturbance. This is proving not to be the case and to allocate more housing immediately south of the circuit will expose more residents to potential noise disturbance and is an unsound and unsustainable proposal.
The local plan must be about delivery. The Government sees development as a key element of growth in the country and has for a number of years been stripping away unnecessary planning impediments that frustrate development coming forward. A key objective of this plan must be to provide strategic development opportunities that can be delivered quickly and certainly within the timeframe of the local plan. This is not the case at Old Place Farm, the strategic allocation to the north-east of the city, where the Estate hold a number of covenants over the land which restrict development. While covenants in themselves are not a planning matter, it is material in this case as the covenants restrict the delivery of development at the site, even if approved. The Estate brought this matter to the attention of the council, to indicate that there is an impediment to the delivery of the strategy, but this has not been acted upon and the allocation remains unchanged.
Terence O’Rourke Ltd. Page 3 of 8 August 2014
Goodwood Estate Matter 7: Strategic Development Locations (SDLs)
The landowner / developer believes the covenants do not preclude development and therefore there is likely to be a protracted legal case before the site is or is not available for development. Even in the unlikely situation that the landowner is proven correct, this will be many years in the future, potentially in excess of five years and possibly well beyond the plan period. We submit that there is sufficient uncertainty over the early deliverability of this allocation that its continued inclusion in the plan will result in the plan being unsound in terms of delivery. We do not therefore believe that the evidence demonstrate that the timing and phasing of development in each of the SDLs is viable and deliverable as set out in the housing trajectory. For the Old Place Farm allocation we suggest this fact is recognised by the submission of an application for housing on that part of the allocation only, which is not subject to the covenants.
This current planning application on part of the site is reliant upon the allocation being carried forward, yet, as set out in our representation, any reasonable person considering where new housing should be located at Chichester would instinctively avoid land on which there is a significant flooding issue and immediately adjacent to a known noise generator. Add to this the matter of significant infrastructure problems and there can be no conclusion other than to find the allocation unsound, particularly when alternative strategies are available to meet known housing demand.
The definition of the flood plain in the allocation and the suggestion this is kept free of development is acknowledged, but its position in relation to developable areas, (recent evidence from last winter shows that flooding can extend beyond the defined area, including regular flooding of the A27 and approach roads) results in a development that will be separated from the built up area and often with constrained accessibility. Flood maps from the environment agency confirm that the access roads are within flood zone 2 and 31. Contrary to the objectives of the plan, this barrier removes any direct links to the city centre resulting, in many non-sustainable journeys and a strategic development area that does not integrate easily with the existing community.
As set out above, overall we do not believe that all environmental and infrastructure constraints have been taken account of in the Westhampnett/North East Chichester allocation. The scale of development in the Westhampnett/North East Chichester Allocation also does not appear to be based on rigorous assessment of capacity. Finally we do not believe the timing/phasing of development is viable/deliverable. This is further explored in the next section, relating to highways.
Highways Infrastructure
The issue of the A27 is not simply a local concern. Issues surrounding the A27 have been recognised nationally, particularly the Chichester Bypass section recognised as requiring improvements. Government policy and its approach to sound planning is focused on growth. In the Treasury report, “Investing in Britain’s Future” (July 2013) which underlies many of the Government’s changes to the planning system, six major road schemes are identified as impediments to growth. The A27, along with the A303, are the only two routes in the south of England so identified2 – the A27 being the more significant. The inclusion of the A27 in this report sends a very clear message, and states explicitly that the A27 at Chichester is “one of the most notorious and
1 Appendix 1 – Flood Map for Planning 2 Paragraph 2.2
Terence O’Rourke Ltd. Page 4 of 8 August 2014
Goodwood Estate Matter 7: Strategic Development Locations (SDLs) longstanding road hot spots in the country”. Adding to existing problems when a solution is not agreed cannot be considered sound planning.
Initial recommendations for improving the A27 at Chichester were made over a decade ago in 2002, with the publication of the South Coast Multi Modal Study, which contained various recommendations for the A27 at Chichester. All of the proposed improvements were rejected by the secretary of state for transport as they were considered too damaging for the environment3. The Highways Agency then progressed with local stakeholders less environmentally damaging options, and public consultation took place in early 2005. However in 2009 the government, following a cost review, dropped these proposals.
The problems remained, and in 2012 West Sussex County Council started working on a short term action plan that would enable the planned development that met local need to be brought forward. The work was completed in 2013, with various short-term ‘affordable’ proposals for key junctions. Again these proposals never progressed to public consultation as the government once again recognised the importance of this road, and the severe problems that were faced. Therefore the council halted work on progressing the short term improvements necessary for additional development.
Today proposals for upgrading the A27 are at feasibility stage by the Highways Agency. Whilst central government have made clear they understand the major issues with the road, and therefore commissioned a feasibility study, it has already been stated that the ability to fund improvements will be subject to value for money and deliverability. There is a very real risk that the government will come to the conclusion that the improvements are not affordable, and therefore will not progress with them. In addition with the potential change in government in 2015 there is a very real risk that funding could be withdrawn as occurred in 2009. If the improvements are made there is no current timescale for implementation. Further information will be available with the Autumn Statement in December.
Even if central government were to commit to fund improvements, development should not proceed in the knowledge that improvements are proposed. Improvements should be planned and delivered before additional development is proposed – there is no quick fix or interim arrangement that is acceptable. History has shown that funding being withdrawn for improvements to the A27 is a very real possibility, and impact on the environment is going to be a big issue. Yet the route has reached that threshold where action must be taken. Developer contributions are very unlikely to be able to make acceptable the impact on the A27, with the Highway Agency consultation response to the local plan stating, “the cost of delivering [a suitable mitigation package for the A27 so that impacts do not become severe] is likely to be substantial”. These improvements would be required to enable development at Old Place Farm, and that brings into question whether the development would be viable, with the scale of highways improvements required.
The positive Highways Agency consultation response to the Local Plan is reliant on the A27 improvements being made by central government, yet the local plan makes no reference to these, instead relying on the improvements previously worked on by West Sussex County Council, which appear to have not been progressed since 2013 - there
3 Highways Agency http://www.highways.gov.uk/roads/road-projects/a27- chichester-improvement
Terence O’Rourke Ltd. Page 5 of 8 August 2014
Goodwood Estate Matter 7: Strategic Development Locations (SDLs) are no contingency measures in place if Central Government funding is not forthcoming. Issues surrounding the A27 could be a ‘showstopper’.
It is unsound for the plan to proceed in the light of this advice, particularly with those allocations, such as that at Old Place Farm, which are directly dependent upon this route. To proceed with the housing targets set by the council on the basis of an unsuitable strategic transport situation suggests that the council’s basic housing assumptions are unfounded. To proceed with allocations where there are clear infrastructure inadequacies, simply to meet a technical housing land supply deficit is premature and unsound – planning must ensure development is sustainable and that means having the infrastructure to support it. There is little benefit to be gained from more strategic housing adding to the pressures of an already over used strategic route. The plan is unsound in failing to make proper provision for the timing of strategic road improvements. It should accommodate and make provision for housing phased alongside the A27 improvements and seek to work with other authorities in the short term to meet immediate housing need through cooperation within the journey to work area.
Wastewater Treatment Facilities
The upgrading of the WWTW at Tangmere is long overdue. It is an essential element of infrastructure to enable the plan’s objectives to be delivered sustainably and soundly. To bring forward any part of the allocation in advance of this provision (scheduled for 2019) simply adds to the strain on existing infrastructure with a ‘make do and mend’ approach to an acute problem for individual sites, as demonstrated by the submission of the application for part of the allocation since the plan was published. There is no benefit to the local community derived from bringing forward development sites reliant on Tangmere WWTW (even in part) in advance of the upgrade being available. To do so, simply results in an ad hoc, and un-coordinated development, which the plan is seeking to avoid. Arguments from landowners / developers that there is some limited capacity, transient arrangement or suggestion that this is the first phase of a comprehensive scheme, serves only to promote individual interests and does not represent sound sustainable plan making.
We acknowledge that Chichester is in a very difficult position. It is a very attractive town where people wish to live and is therefore subject to a considerable level of in migration from those able to meet the high housing costs. Providing additional housing will simply perpetuate the issue and will not guarantee local homes for locally generated need. The city’s attractiveness, linked to the need to ensure economic prosperity, has resulted in growth over many years, but without the necessary complementary investment in infrastructure. There is a limit to the growth of settlements informed by constraints that will from time to time change. Chichester is at one of those thresholds and development allocations are now conflicting significant constraints on its eastern side. Those constraints are fundamentally important to the city’s future but we submit that the balance used by the council in making those allocations is unsound, where too much weight is given to the need to meet a theoretical housing need, without proper weight being given to other material considerations.
Terence O’Rourke Ltd. Page 6 of 8 August 2014
Goodwood Estate Matter 7: Strategic Development Locations (SDLs)
We submit that the plan should not be providing for the number of dwellings identified. However if this number is proved to be correct, allocations to the east of the city should be reconsidered to ensure that these are balanced against other plan objectives and are timed and located to benefit from planned infrastructure improvements. Overall we believe that there are ‘showstopper’ issues with highways and the tangmere wastewater works.
Terence O’Rourke Ltd. Page 7 of 8 August 2014
Goodwood Estate Matter 7: Strategic Development Locations (SDLs)
Appendix 1 – Flood Map for Planning (Environment Agency, 2014)
Terence O’Rourke Ltd. Page 8 of 8 August 2014