West Itchenor Parish Council

6 Locksash Close, , PO20 8QP Parish Clerk – Mrs Carol Smith MILCM Tel: 01243 204204 Email: [email protected]

POLICY 1 PRESUMTION IN FAVOUR OF SUSTAINABLE DEVELOPMENT

The approach as defined in Policy 1, namely to “work proactively with applicants…to find solutions…. wherever possible” is, in our view, unsound. It is almost always ‘possible’ to grant permission. It is in the nature of Local Plans to contain a wide range of policies which could almost always both support an approval or justify a refusal. This policy 1 appears to derive from the National Planning Policy Framework (NPPF) paragraph 14 but the NPPF 14 does not include the words “wherever possible”. The Parish Council believes they should be omitted from Policy 1.

NPPF does however refer to a restriction on the ‘presumption in favour of sustainable development’ where the application is on land within an AONB but Policy 1 makes no such reference and the Parish Council is of the view that it should. This restriction is in footnote 9 to NPPF paragraph 14 and this should be carried over into Policy 1.

The Parish Council also notes a letter from Bob Neill MP in which he states that “The National Planning Policy Framework does not require Councils to provide more houses than are needed” He also states that “we want to see housing development in a properly planned, strategic way and not just at any cost”

The Parish Council would like the words “wherever possible” be omitted from Policy 1 and the Policy should refer to a restriction on the ‘presumption in favour of sustainable development’ where the application is on land within the AONB.

West Itchenor Parish Council

6 Locksash Close, West Wittering, Chichester PO20 8QP Parish Clerk – Mrs Carol Smith MILCM Tel: 05600 793843 Email: [email protected]

POLICY 43 AREA OF OUTSTANDING NATURAL BEAUTY (AONB).

The policy has 5 criteria to be met before planning permission is granted. However the 5th criteria only requires that: “Consideration has been given to the requirements of the Chichester Harbour AONB Management Plan”.

In the view of the Parish Council this wording is insufficient to protect the Harbour and the AONB. We propose the words “consideration has been given to” are omitted and the word ‘meets’ inserted so that applications ‘meet’ the requirements of the Chichester Harbour Management Plan.

Reasons In the current Local Plan 1999 ‘Saved Policies’ the District addressed the need to protect the area of the Harbour and the AONB by a series of individual policies including RE4 (Rural Environment – Areas of Outstanding Beauty …… Protection of Landscape and Character), C1(Coastal Environment – Waterside Development) and H12 (Replacement Dwellings). The draft Local Plan covering the period up to 2029 omits these policies. However, the thrust of these policies have been incorporated in the Chichester Harbour Conservancy Management Plan 2009 – 2014. This document was the product of the partnership between Local Authorities in West and Hampshire, Natural and the Chichester Harbour Conservancy.

The Parish Council believes that the Draft Local Plan is unsound by the use of the words “Consideration has been given” which gives insufficient weight to the importance of the AONB Management Plan in Policy 43.

The Parish Council also understands that a view has been expressed that the AONB Management Plan may incorporate future changes that might not be acceptable to Council resulting from the ability of the Conservancy to carry out 5 yearly reviews of its Plan and that this may be the reason given for adopting the words “Consideration has been given”. The Parish Council is of the opinion that this shows a lack of confidence in the process and that it is unfounded. A review of the Plan will need to comply with the Countryside and Rights of Way Act 2000 within which cooperation among the partners is a requirement. The Parish Council believe that it is unsound to reduce the strength given to the plan because of fears of future amendments.

Additionally the policy for that part of Chichester Harbour Area of Outstanding Natural Beauty that lies within Hampshire and which is within the Havant Borough Core Strategy Local Plan (HBCSLP) adopted in March 2011, contains no such constraint upon the strength of the policies within the AONB Management Plan.

We set out policy below HBCSLP’s policy: West Itchenor Parish Council

6 Locksash Close, West Wittering, Chichester PO20 8QP Parish Clerk – Mrs Carol Smith MILCM Tel: 05600 793843 Email: [email protected]

Policy CS12 Chichester Harbour Area of Outstanding Natural Beauty (AONB) Development will be permitted where it:

1. Carefully assesses the impact of individual proposals, and their cumulative effect, on the Chichester Harbour AONB and its setting. 2. Is appropriate to the economic, social and environmental wellbeing of the area or is desirable for the understanding and enjoyment of the area. 3. Conserves and enhances the special qualities of the Chichester Harbour AONB (as defined in the Chichester Harbour AONB Management Plan) 4. Meets the policy aims of the Chichester Harbour AONB Management Plan and 5. Provides mitigation of any detrimental effects including where appropriate the improvement of existing damaged landscapes relating to the proposal.

West Itchenor Parish Council

6 Locksash Close, West Wittering, Chichester PO20 8QP Parish Clerk – Mrs Carol Smith MILCM Tel: 05600 793843 Email: [email protected]

POLICY 43 - Addendum to written statement submitted on the 30 August 2014

Proposal

This comment concerns Policy 43 Chichester Harbour Area of Outstanding Natural Beauty (AONB). The policy has 5 criteria to be met before planning permission is granted. However the 5th criteria only requires that:

Consideration has been given to the requirements of the Chichester Harbour AONB Management Plan.

In the view of the Parish Council this wording is not sufficiently strong to protect the Harbour and the AONB. It is proposed that the words underlined are omitted so that planning applications must ‘meet’ the requirements of the Chichester Harbour Management Plan.

Reasons

In our written Statement of 30 August 2014 and already submitted, It emphasised that the wording of Policy 43 needed amendment in order to give weight to the Chichester Harbour Conservancy Management Plan (CHCMP) “Planning Guidelines”. We are aware that these guidelines do not form part of the CHCMP at the present time.

Nevertheless, the CHCMP Policies in part 2 of that document help to cover areas that the old Local Plan coastal policies (1999) used to cover and which are no longer covered in the Chichester District Local Plan: Key Policies. For example, without the CHCMP policy EG4 on page 37, the new Local Plan would give no safeguarding to marine-related industries in the Harbour. The CHCMP 2014-19 has become the more important instrument for the AONB and will in due course be supplemented with further partnership coordinated policies for protection and sustainability. It therefore needs to have its status raised by the amendment of Policy 43 as outlined above.