Appendix 1 Chichester District Local Plan Preferred Approach November 2019 Summary of responses - Part One Introduction The Local Plan Review Preferred Approach was the subject of public consultation between 13 December 2018 and 7 February 2019. Part One of the Preferred Approach Plan contained 32 Strategic Policies and 15 Strategic Allocations. Part Two set out 35 detailed Development Management Policies. In addition, a document set out proposed changes to the policies map and a Sustainability Appraisal and Habitats Regulations Assessment were also published. Just over 3,200 representations were made by 729 respondents. These can be broken down as follows – Representations Support Object Comment Part 1 2742 389 1444 909 Part 2 401 92 136 173 Appendices to 25 1 12 12 document Sustainability 17 0 2 15 Appraisal Policies Map 20 4 6 10 Habitats 3 0 0 3 Regulations Assessment All the consultation responses are available in full via the consultation portal which can be accessed via the council’s website at https://www.chichester.gov.uk/article/30923/Preferred- approach---consultation-December-2018 . In addition, summary reports of the representations have been prepared and are also available on the same web page. This report sets out a further summary of the responses received to Part One of the Plan. It focuses on the issues raised, and for that reason individual respondents are not named. However, where organisations have submitted responses, to help legibility, the organisation is stated in bold. All respondents have been advised of their respondent and representation numbers but if further guidance is sought please contact the Planning Policy team at [email protected] Page 1 of 125 It has not been possible to provide a unique reply to each representation received during the consultation. However, the document does set out an initial response to the issues raised based on all representations received. Whilst this does not represent the Council’s final view, it indicates how further work to be undertaken for the new Local Plan is intended to proceed at this time, and how consultation comments influence the development of the Plan. A second supplementary document will set out the consultation responses to Part 2 (Development Management Policies) and accompanying documents. We would like to thank everyone who took the time to respond to this consultation. Page 2 of 125 Introduction Respondents Representations Support Object Comment 7 13 1 4 8 Representation numbers 1295, 2289 (Historic England), 2395 (South Downs National Park Authority), 2585, 2616, 2620, 2621, 2797, 2800, 2803, 3057, 3058, 3059. Summary of issues and key comments raised by residents and other respondents South Downs National Park • Unclear why National Park is given high level of prominence in the Local Plan Review, when unlike the AONB, it is not part of the Plan area. • Why is CDC not integrating planning process with area of SDNP within CDC area? • CDC need to understand where unmet need from SDNP is generated from. Evidence Base • Not known if effectiveness of current Local Plan has been evaluated, with findings used to inform Preferred Approach. • Evidence seen under FOI does not show appropriate and effective cooperation has occurred, particularly with Highways England for development of transport infrastructure. • Statements of Common Ground not available as part of consultation. These must be re-consulted on at the next stage. • Suggest amendments to specific wording - para 1.5 and 1.16. Historic Environment Strategy does not form adequate evidence base. Should consider if archaeological evidence and significance of city is understood and available. (Historic England) • Commercial Development Plan absent as part of the consultation. Amendments to wording • Reference to Section 62 of the Environment Act 1995 should be added to paragraph 1.31. (SDNPA) Other • Section 1.7 – Poor local community involvement under existing plan. • Section 1.10 - cannot be sustained. Developments under existing Plan have not respected character of Chichester. • Many errors, CDC accountable for supplying incorrect & out of date information. • Section 1.26 - Support specific mention of need for cross-boundary cooperation over dark skies policy. Initial Council response to issues raised and way forward for the Local Plan Review Overall, it is considered the South Downs National Park is a critical part of the context for this Local Plan and the review document does not give it undue prominence. The National Park Authority works closely with the District Council and arrangements are in place for the District Council to deliver planning services on applications within the national park area. With regards to housing need, further detail is set out in the Housing Background Paper which will need to be updated. The effectiveness of the current Local Plan has been assessed in Authority Monitoring Reports published each year. Work is ongoing with Highways England and others on the necessary transport evidence to support the Local Plan, and progress on this and other matters will be documented in Statements of Common Ground which will inform the next stage of the Plan and be placed on the Council’s website. Finally, work is underway to consider the detailed submission by Historic England and any necessary further work will be Page 3 of 125 reflected in the Plan as it develops. Ultimately, the final draft version of the Plan will be supported by all necessary evidence. Reference to Section 62 of the Environment Act 1995 is not considered necessary – other legal requirements (for instance, relevant legislation for minerals and waste planning) are not detailed in this section. Other comments are noted. The Plan will be subject to significant updating prior to the next public consultation. Page 4 of 125 Characteristics of Plan Area Respondents Representations Support Object Comment 11 21 1 5 15 Representation numbers 2290 (Historic England), 2291 (Historic England), 2420 (South Downs National Park Authority), 2444 (South Downs National Park Authority), 2489 (Chidham & Hambrook Parish Council), 2586, 2622, 2804, 2806, 2809, 2813, 2838, 2887, 2974, 3060, 3061, 3062, 3063, 3064, 3108, 3146. Summary of issues and key comments raised by residents and other respondents Amendments to wording • Para 2.13 - Insert Tourism as a significant employer. • Para 2.29 should reflect para 7.100 (balance of development needs within environmental and landscape limitations) as a key challenge. • Para 2.27 - reference to 61 in National Park is irrelevant and should be deleted. • Para 2.23 - Chichester Harbour is important for its landscape value, as well as biodiversity, land and water-based recreation, and tourism. Chichester Harbour AONB should get its own reference under Environment Characteristics. • Para 2.29 - List in order of importance. Start by protecting environmental and historic assets, then support economic and social development, then provision for new housing and business sites. • Para 2.29 - Suggest 7th bullet point is 'Protect and enhance the character of the area including the Chichester Harbour AONB and the setting of the SDNP'. (SDNPA) • Para 2.29 - Climate change missing from list. • No recognition of requirements of established businesses for expansion and to build in resilience. No discussion of automotive sector/advanced manufacturing. • Final bullet 2.4 not consistent with para 6.91. • Para 2.28 – Object to "whilst recognising the need to accommodate new development" - used by developers to shoe-horn in inappropriate developments. • Para 2.18 - Phrase "offers the best potential for attracting inward investment" not substantiated. New jobs could drive out some existing businesses. • Para 2.18 – Object to "However, there is also a need to support and diversify economic activity in the rural parts of the plan area" original wording too unfocussed allowing any form of diversification. Only diversification that complements the area should be contemplated. Changes to Maps • Local Plan Map does not show Chichester Harbour AONB. Would help CDC demonstrate protected landscape constraints when identifying land for development. • Map page 16 - request clarification whether LP area includes Stedlands Farm and the Stable/Little Stedlands, Haslemere. (SDNPA) Transport • Para 2.2, 2nd bullet: accessibility from Manhood peninsula worse than recorded. • Para 2.5: A27 operating at more than double original capacity. Improvements have not satisfactorily kept up with traffic increases. East-West Corridor • Term East-West Corridor is ill defined and use of this term implies the focus of policy is on transport and through movement, to detriment of a more balanced focus on Page 5 of 125 local settlement, existing residential, local countryside and amenity issues. (Chidham & Hambrook Parish Council) • Lack of vision, clarity and coherence of policy to Bourne Villages, character and surrounding countryside between the South Downs and Chichester Harbour AONB. Wildlife/Conservation • Para 2.24 - references to SNCIs; update to reflect sites now Local Wildlife Sites. • Para 2.29 - recommend penultimate bullet point is revised to include geodiversity and locally designated sites. Paras 171 and 174 of NPPF are clear locally designated sites must be safeguarded in plans in order to protect and enhance biodiversity. • Rural setting and green access need better acknowledgement and protection. Accesses are fragile, easily disrupted or downgraded by new developments. Historic Environment • Support reference