Name Organisation Date Acknowledged
Comment Received
Subsequent Changes to
R&RNDP
Resident 03.07.17 yes
Support
Resident 06.07.17 n/a
Objects to Renault Garage site No change
Resident 11.07.17 yes
Support
Owner New River Retail 13.07.17 yes
Supports Rake development site
Resident 31.07.17 yes
Suggested 'special case' amendment to
Policy H4
No change
Consultee
Receipt
acknowle dged
Date of Response
Comment Received Subsequent Changes to R&RNDP
Bowling Club none
BT Open Reach none
C2C LEP none
Chichester DC 21.06.17 none
Chichester DC 15.08.17
Policy H5: Local Housing Needs - The local ‘Rural Housing Enabler’ is employed by the CDC (the Housing
Authority). Policy H6: it is advised that the words ‘subject
to viability and deliverability’ be inserted after the mix requirements.
Policy H5 amended to reflect both comments. Also additional text added to Policy H2 and
Para 4.5.6
East Hants DC none
English Heritage none
Environment Agency 23.06.17 01.08.17 & 10.08.17
Policy H6: include NPPG on watersupply, wastewater and water quality Policy NE1 amended
Forestry Commission 14.07.17 31.07.17
No comments but provided summary of relevant planning guidance
Harting PC 18.09.17
No comments
Highways Agency 28.07.17
No comments
Historic England 18.08.17
1 Refer to number of heritage assests. 2 Add date of Conservation Area. 3 More detail on heritag assests
requested. 4 Vision to include “heritage assets will be conserved and
enhanced” 5 Defi ne what is i mportant in the protected views. 6 Change Policy BE1 headi ng or content.
7 More detail on design characteristics. 8 Suggested changes to Policy BE2. 9 Request additional policy
on unsoecified 'other heritage assets'. 10 Changes to Policies H3, H4 and E1 to protect hi stori c
dwelling. 11 Policy H6 Renault Garage site shoul d refer to Conservati on Area
1 Para 2.4.5 amended. 2 para 2.4.4 amended. 3 Figure 2.3 added. 4 No change as Vision
already includes 'character of natural and built environments' which is sufficient in a Vision.
5 No change as to pick out some aspects of a view would ignore the other supporting
elements. 6 No change necessary. 7 No change as design issues covered in the objectives and
policies of the SDNPA . 8 Most included in BE1. 9 No change as existing policies and SDNPA
Local Plan fulfil requirement. 10 Policies amended. 11 Policy H6 amended.
Homes & Communities Agency none
Liss PC 21.06.17 16.08.17
Support
Little Angels none
Lunch Club none
Marine Management Org 14.08.17
No comments
Milland Church none
Milland PC none
National Grid none
National Trust none
Natural England 05.07.17
Support Policy NE1 No action needed
Network Rail 25.08.17
No comments
NHS Coastal West Sussex CCG 08.08.17
No Comments
NHS South Eastern Hampshire CCG none
R&T News none
Rake School none
Rogate PCC none
Rogate School none
Rogate Society none
Rogate Tennis Club 14.08.17
No comments
Rogate Village Hall 22.06.17 none
SDNPA 21.06.17 18.09.17
22 comments and suggestions All deal t with - see separate document in App 10
Sheet PC 14.08/17
No comments
South East Water none
Southern Gas Networks 15.08.17
No comments
Southern Water 03.08.17
1 Amendments to Policy CH3 to al low for special circumstances. 2 Proposed addi ti onal poli c y new
utility infrastructure
1 Policy CH3 amended. 2 Policy NE1 amended to include suggested wording.
SSE 18.08.17
No comments
Sussex Wildlife Trust 14.08.17
No comments
Thursday Club none
Trotton & Chithurst PC 02.07.17 06.08.17
Textural suggestions Undertaken
Woodland Trust none
WSCC 29.06.17 16.08.17
No comments
Youth Club 11.09.17
No comments
Totals 8 44
21
245
SDNPA response to the pre submission Rogate & Rake Neighbourhood Plan
Page
number
Section
Comments
SDNPA Recommendation
6
1.1.1
We note that the plan period stretches beyond that of the South
Downs Local Plan (SDLP). In order for there to be consistency it is
recommended that the plan period for the Rogate & Rake NDP
(RRNDP) extends to 2033 rather than 2035.
Reconsider plan period.
Done
8
1.4.5
There are 7 identified special qualities to the SDNP, the following are
missing from this paragraph:
•
An environment shaped by centuries of farming and embracing
new enterprise
•
Well-conserved historical features and a rich cultural heritage
•
Distinctive towns and villages, and communities with real pride
in their area
Include full list of SDNP special qualities
Done
7
1.4 Planning
Policy
The South Downs Local Plan: Preferred Options was consulted on in
the Autumn of 2015, since then revisions have been made to the
emerging Local Plan and the National Park Authority agreed to consult
on a pre-submission version of the South Downs Local Plan in the
Autumn of 2017.
Update references to the South Downs Local Plan
throughout the RRNDP
Done
10
2.1.8
Missing population figure for hamlets.
Include population figure where available.
Done
10
2.3.1
SINCs were known as Sites of Nature Conservation Importance (SNCI)
in West Sussex, but they are now called Local Wildlife Sites.
Reference to areas of Ancient Woodland could also be included here
Amend terminology
Done
Include reference to areas of ancient woodland
within the neighbourhood area Done
246
Page
number
Section
Comments
SDNPA Recommendation
13
2.5.2
The plan states the SDNPA, using data from CDC’s affordable housing
needs register, identifies an appropriate level of development in Rogate
over the plan period would be 11-25 homes. This is not accurate as the
emerging South Downs Local Plan (SDLP) has set a requirement for
Rogate of just 11 homes. The housing figure for Rogate, as with other
settlements in the National Park is landscape-led and in line with the
first purpose of the National Park to ensure that any housing
development does not detract from the natural beauty, wildlife or
cultural heritage of the National Park. We have used a wide ranging
evidence base in support of this including Viewshed, Tranquillity and
Habitat Connectivity. These all fed into the Strategic Housing Land
Availability Assessment (SHLAA) along with other evidence for example
on highways and flooding.
The emerging SDLP Policy SD26 states NDPs may accommodate higher
levels of housing than is set out in the Local Plan, providing they meet
local housing need and are in general conformity with the strategic
policies of the development plan.
Reference is made in the Plan to a 2011 Housing Needs Survey – this
should be included in the Evidence Base. The plan states that the
Housing Needs Survey identified a need for 14-26 affordable homes. It
would be useful to understand these figures better as we’re aware that
in 2014 Chichester Housing Register recorded 12 households with a
local connection to the parish, of which 7 (58%) are in bands A-C and
considered to have a priority need for housing.
Provide and clarify evidence base for local housing
Need
Text revised to take account of the findings of
the June 2017 RPC/CDC Housing Needs
Survey
247
Page
number
Section
Comments
SDNPA Recommendation
We note and welcome that there is community support for at least 50%
of the new homes to be affordable housing. The current adopted
affordable housing requirement for Chichester District is 40% on sites
of 10 or more and 20% on smaller sites. The emerging SDLP policy is
for a minimum of 50% affordable homes on sites of 11 or more homes.
On smaller sites, a proportion of affordable homes will be sought on the
following sliding scale:
3 homes - Meaningful financial contribution, to be negotiated case-by-
case
4-5 homes - 1 affordable home
6-7 homes - 2 affordable homes
8 -9 homes - 3 affordable homes
10 homes - 4 affordable homes
These levels are subject to the SDLP policy being adopted following
Examination in Public.
Amended Para 4.5.4
14
2.5.3
The plan refers to a need for new housing to provide one, two or three
bedroom homes to meet local needs. The evidence base for this
statement should be included – are the results of the Housing Needs
Survey being referred to here or another source of information in
a
dd
it
io
n
t
o
t
h
is
?
Provide details of evidence base
Text revised to take account of the findings of
the June 2017 RPC/CDC Housing Needs
Survey
16
Objective 2
Natural
Environment
You may wish to expand this objective to also cover water systems
(river, ponds, etc.) which are also key elements of the natural
environment and characteristic features of the landscape.
Include water systems in Natural Environment
Objective
Done
248
Page
number
Section
Comments
SDNPA Recommendation
19
Policy NE1:
Conserve,
Protect and
Enhance the
Natural
Environment
Policies H1, H2, H3 and H4 have the potential to increase
population in existing properties or through windfall development of
new dwellings. These polices are restrictive policies and the scale of
development which may come forward is expected to be small. In light
of the conclusion in the HRA for the Preferred Options Local Plan, the
following wording is recommended to be included in Policy NE1 (new
wording underlined):
‘Development proposals resulting in a net increase in residential units
within 5km if the boundary of the Wealden Heath Phase II SPA will
require a project-specific Habitats Regulations Assessment screening to
determine whether a likely significant effect on the integrity of the site
will result and any requirements for mitigation are identified.’
We note and welcome that views of special local significance have been
identified in the Plan.
Bullet point (a) would better read as “conserve and enhance the natural
beauty…” which is in line with national and local policy regarding the
natural environment.
For clarity bullet point (d) should refer to new development.
It would be helpful to also refer to the SDNPA Dark Sky Quality Map in
addition to the Tranquillity Study to assess proposals.
Recommended addition to Policy NE1:
‘Development proposals resulting in a net increase
in residential units within 5km if the boundary of
the Wealden Heath Phase II SPA will require a
project-specific Habitats Regulations Assessment
screening to determine whether a likely significant
effect on the integrity of the site will result and
any requirements for mitigation are identified.’
Done
Clarify policy wording
Done
22
Policy BE1:
Locally
distinctive
First sentence refers to ‘good quality’ design – surely reference should
be made to ‘high quality’. Also it would be good to see reference to
design being informed by the landscape i.e. a landscape-led approach.
Revise policy wording Done
249
Page
number
Section
Comments
SDNPA Recommendation
design within
the Parish
The word ‘innovative' refers to function, more than architectural style.
I
s
t
h
e
ai
m
h
e
r
e
n
o
t
t
o
p
r
e
c
l
ud
e
'co
n
t
e
m
p
o
r
ar
y'
ar
ch
i
t
e
ct
u
r
e
?
W
e
wo
u
l
d
recommend the wording is revised to clarify the policy’s intention.
The word 'design' is quite generic. If the real meaning here is
architectural style then it should be defined. The spaces between
buildings should also be considered: orientation of built form on plot,
boundary treatments etc. The 'character' of the context and settlement
patterns should inform this.
Given the quality of dark night skies in the neighbourhood area, it would
be appropriate to avoid the use of modern style high powered lighting
designs and external security lighting that would reduce the quality of
the locally distinctive character, particularly within the Conservation
Area. In addition, discouraging the use of excessive amounts of glazing,
particularly towards or in the open the countryside would help
conserve the quality of dark night skies.
Done
Done
Include additional policy criteria to ensure locally
distinctive design and design which conserves the
quality of dark night skies.
Done
23
Policy BE2:
Conservation
Area
Development proposals within the setting of the Conservation Area can
also have an impact on the character of the Conservation Area. We
therefore recommend the policy also refers to proposals within the
setting of the Conservation Area.
We would recommend use of the term ‘conserve’ rather than
‘preserve’ which is more active but would still relate to actively retaining
a façade in its historic form for example.
Refer to proposals within the setting of the
Conservation Area.
Done
Amend policy wording.
Done
Include reference to materials which contribute to
the character of the conservation area. Done
250
Page
number
Section
Comments
SDNPA Recommendation
There is no specific mention of materials in this policy although we note
para. 2.3.4 refers to local stone.
24
Housing
Paragraph 4.5.4 includes the emerging SDLP draft thresholds for
affordable housing provision. These figures are subject to change, and
have been revised since the Neighbourhood Plan has been drafted. We
would therefore recommend that the Plan simply cross-refers to the
SDLP which then ensures the information in the submission NDP is
correct and confirms with the SDLP.
Remove affordable housing thresholds. Kept
for now Include
reference that affordable housing will be sought in
line with the adopted Local Plan policy. Done
24
Policy H1:
Settlement
Boundary
Proposals will need to be consistent with the Development Plan in
addition to the policies in the Neighbourhood Plan.
Include reference to compliance with the
Development Plan. Done
25
Policy H2:
Residential
Development
in the Open
Countryside
The RRNDP sits within the context of national and local planning
policies. As currently drafted, policy H2 re-emphasises much of the
protection already afforded by national policy and emerging Local Plan
policy. This additional layer may be unnecessary, risks creating
significant confusion and may in places be in conflict with higher level
policy, thereby undermining the level of protection afforded. The policy
omits the exception for proposals where the innovative nature of the
design of the dwelling would meet NPPF paragraph 55. This potentially
creates a conflict with national policy.
It would be helpful to acknowledge in the supporting text of this policy
the SDNPA’s approach towards Whole Estate Plans, which supports
proposals outside settlement boundaries where these are part of a
Reconsider whether policy is necessary and if so
reword policy to ensure conformity with national
policy. Not done – need to see exactly what
the relevant national policy is – ask Amy.
Included reference to NPPF Policy 55
dwellings
Provide reference to Whole Estate Plans in the
supporting text. Done
251
Page
number
Section
Comments
SDNPA Recommendation
Whole Estate Plan or Large Farm Plan that has been endorsed by the
Authority.
26
Policy H3:
Conversion
of Existing
Residential
Properties
Where conversions are made to historic buildings, reference should
also be made to conserving the historic fabric of the building.
Criteria (b) for sufficient off-street parking should be without adverse
landscape or visual impact.
Include additional criteria regarding the conversion
of historic buildings. Done
Ensure parking provision does not have an adverse
landscape or visual impact. Done
27
Policy H4:
Replacement
Dwellings,
Extensions
and Annexes
See comments made on Policy BE1 which covers some of the same
issues.
Reconsider policy wording. Done
29-32
Policy H6:
Allocation of
Sites Suitable
for
Development
Supporting evidence is needed to provide detail on all the sites
considered and the rationale for selecting particular sites. Some of this
is covered in the Potential Development Sites Background Paper,
although this needs to be updated as the Plan now allocates sites.
A map showing the location of both of the site allocations would be
helpful. Also the site boundary of the site allocations needs to be
provided.
As the South Downs Local Plan affordable housing requirements have
yet to be adopted we would advise removing reference to these in the
allocation policies.
Provide supporting information on the site
selection process This will be provided in the
Evidence Pack
Include map showing both site allocations To
be done – requires SDNPA resources
Remove un-adopted South Downs Local Plan
affordable housing requirements from policy
wording. Kept for now
252
Page
number
Section
Comments
SDNPA Recommendation
Figures 4.4-6 show site layouts which we understand have been
prepared to establish the capacity at each site. It may be that there are
other appropriate layouts and we would advise that the Plan makes
clear these are only indicative layouts and not mandatory.
(b)
Renault Garage and bungalow south of A272, Rogate
Confirmation on the availability of this site is required. It is currently in
active use. We would also query whether the garage provides services
(i.e. servicing/repairs) other than car sales? If so, then should the loss of
t
h
e
s
er
v
i
c
es
b
e
t
a
ken
i
n
t
o
a
cc
o
un
t
?
P
r
ef
er
enc
e
s
h
o
u
l
d
b
e
m
a
d
e
f
o
r
t
h
e
two sites being developed as one to ensure they relate well to one
another and allow for space within the development for mitigation
measures. The site is adjacent to the Conservation Area and Rogate
Lodge – a locally important historic parkland, is on the opposite side of
the A272. The rear boundary of the site is a historic landscape feature
and should be conserved. Locally important viewpoint 15 could be
improved by development at this site. Additional criteria to the
allocation should ensure pedestrian access to the village is provided as
well as the wider countryside.
(c) Land on north side of B2070 London Road west of Flying Bull PH,
Rake
We have a number of concerns about this site - it will possibly result in
loss of trees, it is at a higher level than the adjacent road, and the layout
plan in Figure 4.6 shows garden land outside of the Parish/Designated
NDP area, and thus beyond the remit of the NDP to allocate. There is
potential for landscape archaeology to be present along the historic
administrative boundary (ditches/banks/mature marker trees etc.) which
Emphasise that layouts are indicative. Done
Confirm availability of site. Done
State preference for sites to be developed as one.
Done
Reference the Conservation Area, nearby historic
parkland, locally important viewpoint and historic
field boundary Done by referring to BE1 and
BE2.
Include criteria for pedestrian access into the
village and the wider countryside Existing
east and west path along s side of A272
Address concerns raised with site allocation.
Done
253
Page
number
Section
Comments
SDNPA Recommendation
should be conserved. Any rear boundary should not be walls but
instead trees and the design of the plots should be driven by the
wooded character or the area.
Development of this site could be considered if a case was being made
for the housing being essential in order to “enable” retention/continued
viability of the pub (which is identified as a Community Facility on Policy
CH1 and which the NDP Group intend to register as an Asset of
Community Value) – but no such justification appears to have been
given.
It should be noted that the site is located close to the boundary of the
parish with Liss. The housing provision figures set out in draft policy
SD26 relate to settlements rather than parishes. The draft allocation is
in Rake and not the village of Rogate. The allocation would not
therefore contribute to meeting the housing provision figures set in
SD26 for Rogate. It is recommended that Rogate Parish discuss this
emerging allocations with Liss Parish.
34
Policy T1:
Encouraging
Sustainable
Travel
This policy requires that, where practical, new development to connect
to the nearest point of the public right of way network and that
opportunities to enhance existing links should be taken wherever
possible. There could therefore be an increase in access to international
designations and recreational disturbance of protected species.
In order to ensure that there are no adverse effects on the integrity of
international designations, it is recommended that the following wording
is added to policy T1 (new text underlined):
the following wording is added to policy T1 (new
text underlined):
‘Planning permission will not be granted for
development that would have an adverse impact
on international nature conservation designations,
or on to the amenity value…’ Done
254
Page
number
Section
Comments
SDNPA Recommendation
‘Planning permission will not be granted for development that would
have an adverse impact on international nature conservation
designations, or on to the amenity value…’
n/a
CIL
There is no mention in the Plan of Community Infrastructure Levy
(CIL), or any explicit indication of how CIL money collected from
development in the area might be prioritised, or indeed what any
projects within the area that might be considered suitable for funding
through the CIL money that will be collected by the Parish Council.
There are potentially some of the key projects and actions from the
Plan that could be drawn out as a starting point for this, for example the
Community Projects list. There are also some good hooks for where
reference or consideration could be made (paragraphs 3.4 and 6.1.7, for
example)
There is no set way of how to address CIL in NDP’s, although the
Wisborough Green NDP
(http://www.chichester.gov.uk/neighbourhoodplan#wisborough) is a
good example of how consideration has been given to various projects
and how they might be funded, as well as how these might be prioritised
by the Council (see the community action plan towards the end of the
document).
Include details in the Plan on how CIL will be
prioritised and whether any projects within the
neighbourhood area might be considered suitable
for funding through CIL money.
33
Policy EW1:
Supporting
the rural
economy
The second bullet point of the policy ends “or” – it appears that an
important section of this policy is missing. This second bullet point also
appears to allow for a wide range of development which may not be
appropriate in a rural location. The use of the word “redevelopment” is
Clarify wording
Done
255
Page
number
Section
Comments
SDNPA Recommendation
unclear – e.g. does this support demolition of redundant farm buildings
and erection of newbuild in their place?
It would be helpful to acknowledge in the supporting text of this policy
the SDNPA’s approach towards Whole Estate Plans, which supports
proposals outside settlement boundaries where these are part of a
Whole Estate Plan or Large Farm Plan that has been endorsed by the
Authority.
Provide reference to Whole Estate Plans in the
supporting text. Done
37
Policy CH3:
Public Open
Spaces,
Village
Greens and
Local Green
Space
Experience at the Petersfield NDP Examination and others highlights the
need to evidence how Local Green Spaces have been selected and
justify how they meet the requirements as set out in the NPPF
paragraph 77. How are they demonstrably special? Are they in close
proximity to the proximity they serve?
It would be useful to include details of the village greens which are
shown on Fig 4.7.
Provide further evidence in support of the Local
Green Space designations Will
be provided in the Evidence pack
Include village green details
Already included in Policy CH3 –
see reference to VG24 and VG26
42
7. Monitoring
and Review
Since the last iteration of the R&RNDP guidance has become available
on how a NDP might be reviewed and what the requirements will be to
do so. These include a streamlined process for minor amendments to
NDPs. The details of 7.1.2 are subsequently inaccurate and we would
recommend removing this section or the level of detail reduced so that
the Parish Council does not become tied to a certain course of action in
the future.
Remove wording or reduce level of detail.
done