Chichester Local Plan 2021 - 2039: Proposed Submission

Ended on the 17 March 2023

Chapter 5: Housing

Meeting Housing Needs


(3)5.1. The Preferred Approach consultation on the Local Plan was based on meeting the identified objectively assessed housing needs of the plan area of 638 dwellings per annum[27] (dpa) plus an allowance for accommodating unmet need arising from the Chichester District part of the South Downs National Park.

(10)5.2. However, constraints, particularly the capacity of the A27 has led to the council planning for a housing requirement below the need derived from the standard method, of 535 dpa in the southern plan area and a further 40 dpa in the northern plan area, a total supply of 10,350 dwellings over the plan period from 2021 – 2039. As a result of not meeting the identified housing needs, the council is now unable to accommodate any unmet need from the part of the South Downs National Park within Chichester District.

(1)5.3. In order to meet the requirements of the duty to cooperate the council have approached neighbouring and other authorities to see whether they may be able to meet any of Chichester's unmet needs. Most of the neighbouring authorities are faced with similar constraints and are unable to assist. The latest position will be set out in the Duty to Cooperate Statement of Compliance.

5.4. The council will continue to work with other local authorities in the West Sussex and Greater Brighton Strategic Planning Board to address the objectively assessed housing need for housing and other development needs arising in this area. As discussed in paragraph 1.27, this duty to cooperate includes the commissioning of new evidence to understand the potential longer term development needs, including housing, arising within the area, before considering spatial options for addressing this need - taking into account the opportunities available, the potential infrastructure and constraints. These issues are not for the council to consider in isolation, with the joint strategic planning partnership being the agreed mechanism to address such matters in a timely way.

5.5. The Plan period runs from 2021 – 2039. To ensure a continuous supply of housing over the plan period, a number of sources of supply have been identified. These include new strategic allocations made in this Plan, retained allocations from the adopted Local Plan 2014-2029 (brought forward into this Plan), existing commitments, sites to be identified at a parish level through neighbourhood plans (or DPD) and sites not yet identified that are likely to come forward through the development management process in accordance with the policies of this Plan ('windfalls').

(91)Policy H1 Meeting Housing Needs

The housing target for the plan area is to provide for at least 10,350 dwellings to be delivered in the period 2021-2039. The broad sources of supply anticipated in this Plan are as follows:



Number of dwellings

Housing requirement for the full Plan Period (1 April 2021 to 31 March 2039)


Housing supply

(1 April 2021 to 31 March 2039)

a. Completions 1 April 2021 - 31st March 2022


b. Known commitments (comprising)


Outstanding 2015 Local Plan [1] and Site Allocation DPD 2014 – 2029 allocations[2] without planning permission


Outstanding 'made' Neighbourhood Plan allocations without planning permission


Planning permissions as of 1 January 2023[3]

New Strategic Locations/Broad Location for Development and Allocations


c. Remaining figure without planning permission


Non-strategic Parish Housing Requirements


d. Remaining figure without planning permission


e. Windfall (small site allowance)


Total supply for the full Plan period (1 April 2021 to 31 March 2039) (=a+b+c+d+e)


The broad spatial distribution of this supply of housing across the different plan areas is indicated in the table below:


Housing provision 2021-2039

East-West Corridor


Manhood Peninsula


North of Plan Area


Plan Area Total


[1] Carried forward in this Local Plan (see Policy H2 Strategic Locations/ Allocations 2021 – 2039)

[2]Carried forward in this Local Plan (see Policy H2 Strategic Locations/ Allocations 2021 – 2039) Site Allocations DPD 2014-2029)

[3] Does not include planning permissions on small sites (1-4 dwellings) permitted after 1st April 2022 as these are included in the windfall allowance.

Strategic Locations/Allocations

(2)5.6. In order to achieve the levels of housing supply required to meet identified needs, it is necessary to make provision for larger scale development in the plan area. In total the Plan provides for at least 7,000 dwellings to come forward from such sites, including allocations carried forward from the 2015 Local Plan. Details of the strategic locations and allocations expected to deliver this source of supply are set below with the detail for each site in Chapter 10. Note: some large-scale strategic development is currently expected to be provided for through neighbourhood plans.

(78)Policy H2 Strategic Locations/ Allocations 2021 - 2039

The following strategic site allocations are carried forward from the 2015 Local Plan:





Land at Shopwyke



Land at Westhampnett/ North East Chichester



Tangmere Strategic Development Location



West of Chichester


The following new strategic sites are allocated:





Land at Highgrove Farm, Bosham



Land East of Chichester



Land at Maudlin Farm, Westhampnett


A4 and A5

Southern Gateway


A broad location for development (BLD) is identified as follows, with the allocation of a site within the BLD to be identified through either the neighbourhood planning process or subsequent Site Allocation DPD:





Southbourne Broad Location for Development


The following strategic locations have been identified where neighbourhood plans are anticipated to be prepared to identify the sites required:





Chichester city



Nutbourne and Hambrook (Chidham and Hambrook Parish)





If draft neighbourhood plans making provision for at least the minimum housing numbers of the relevant area have not made demonstrable progress, the council will allocate sites within a development plan document in order to meet the requirements of this Local Plan.

Non-strategic Parish Housing Requirements

(2)5.7. Following a similar approach to the 2015 Local Plan, it is proposed that responsibility for identifying sites suitable for small-scale housing is assumed at a parish level in order to address the needs of local communities. In accordance with the Local Plan settlement hierarchy, it is intended that such new housing should generally be directed primarily towards the larger, more sustainable settlements.

5.8. Indicative housing numbers to be planned for each parish are set out in the policy below.

(88)Policy H3 Non-Strategic Parish Housing Requirements 2021 - 2039

Small-scale housing sites will be identified to help provide for the needs of local communities in accordance with the parish housing requirements set out below. Suitable sites will be identified either through neighbourhood plans or subsequent development plan document. Note that a '*' against a parish name indicates that a strategic allocation/ broad location for development is identified or strategic location for development is made as set out in Policy H2.


Housing Figure


Housing Figure









Chichester City*


Chidham and Hambrook*






East Wittering


















North Mundham




Plaistow and Ifold










West Wittering






Wisborough Green




If draft neighbourhood plans making provision for at least the minimum housing numbers of the relevant area have not made demonstrable progress the council will allocate sites for development within a development plan document in order to meet the requirements of this Local Plan.

(1)5.9. Suitable sites and locations for development will be identified meeting the criteria set in Policy S1 and Policy S2 (Spatial Development Strategy and Settlement Hierarchy) and other policies in the Plan. It is intended that the identification of sites and phasing of delivery will be determined by local communities through neighbourhood planning in consultation with the council. In areas where parish councils do not wish to prepare their own neighbourhood plan, the council will work with the parishes to identify sites in a subsequent development plan document. Housing sites for Chichester city will be allocated through the preparation of the development plan document and may include sites adjoining the Chichester city settlement boundary in neighbouring parishes (including sites separated from the settlement boundary by the A27).

(3)5.10. Some flexibility may be allowed for minor amendments to housing numbers for individual parishes subject to the detailed investigation and assessment of potential sites through neighbourhood plans and in the subsequent Site Allocation DPD. Developments of 6 or more dwellings will be counted against the parish housing requirements. Developments of less than 6 dwellings will not count against the parish housing requirements as they are already taken into consideration in an allowance made for future delivery from windfall small sites.

Longer Term Growth Requirements

(2)5.11. This Plan considers the development needs of the plan area up to 2039. Beyond the Plan period additional planned provision for housing will be required. During the course of preparing this Plan, it has become apparent that it may not be appropriate in the longer term to continue to rely completely on similar sources of supply such as urban extensions and urban intensification given their cumulative environmental, infrastructure, landscape and historic character impacts.

(2)5.12. In order to be in a position to update this Local Plan within the next five years the Council will need to consider future population and household growth. At the same time, the requirement for sufficient homes to house a local workforce without relying on excessive in-commuting to the District’s workplaces will need to be considered. The continual evolution of National Planning Policy also presents challenges as in what national, regional, sub-regional and plan area strategic planning context any future reviews of this plan maybe undertaken.

5.13. As indicated at paragraph 5.4, the West Sussex and Greater Brighton Strategic Planning Board has been commissioned to prepare the evidence base for the Local Strategic Statement 3 (LSS) for the longer term period 2030-2050. This work will involve neighbouring authorities, which may provide a strategic context in which to plan for the district’s future after 2039 and present one option for dealing with future housing growth. Similarly, the Council will continue to work bilaterally with neighbouring authorities in seeking to find cross boundary strategic solutions to future growth requirements.

5.14. In addition to the investigation of strategic solutions to address the longer-term development needs, in order to facilitate the identification of possible new development specifically within the Chichester plan area, the following considerations are set out to guide potential discussions leading up to the preparation of a future review of this Plan:

  • Sufficient scale to support potential long-term development needs arising and support the provision of key infrastructure and community facilities;
  • Comprehensively planned in consultation with existing communities and key stakeholders;
  • Sustainable, inclusive and cohesive communities promoting self-sufficiency and with high levels of sustainable transport connectivity;
  • Inclusion of on-site measures to avoid and mitigate any significant adverse impacts on nearby protected habitats;
  • Provision of a mix of uses to meet longer term development needs
  • Maintain the plan area’s distinctive identity;
  • A layout and form of development that avoids coalescence with existing settlements within and adjacent to the plan area and does not undermine their separate identity; and
  • Respects the historic and landscape character and conserves and where possible enhances the character, significance and setting of heritage assets

Affordable Housing


(1)5.15. Improving the provision of and access to suitable housing is one of five key priorities identified in the council's Corporate Plan. The council is the strategic housing authority for the whole of the district and through its Housing Strategy, seeks to address a range of statutory responsibilities, including the prevention of homelessness and the management of housing need.

(1)5.16. House prices and rents in the plan area continue to grow and remain high compared to average household incomes – the Housing and Economic Development Needs Assessment (HEDNA) 2022 confirms that house prices are 14 times average earnings for those working in the district. Rental costs are slightly lower than the regional average but notably higher than the national average. This means housing is unaffordable to many people in the plan area.

(1)5.17. The HEDNA 2022 identifies a need for approximately 200 social and affordable rented houses per annum for the plan area (to 2039). To help meet this need, the provision of affordable housing will be required as set out in in Policy H4.

(1)5.18. Affordable housing should be indistinguishable from market housing in terms of the location, external appearance, design, standards and build quality and should meet all requirements of the design policies and national design guidance.

5.19. Neighbourhood Plans can set out higher requirements for affordable housing provision (in terms of the amount of units to be delivered on sites), where local evidence of need and viability supports this.


5.20. In accordance with national policy, 25% of the affordable housing provision will be made up of first homes. First homes must be discounted by a minimum of 30% against market value, the first sale price must be no higher than £250,000 and the First Home must be sold to a person who meets the eligibility criteria. A S106 agreement will be entered into to secure the necessary restrictions on the use and sale of the property.

5.21. The remaining 75% of affordable housing provision will be made up of an appropriate mix of affordable rent/social rent and shared ownership. Other forms of affordable home ownership products will also be considered, although this should not be at the expense of social rent. The HEDNA demonstrates the importance of providing affordable rented properties, especially social rent. In order to provide clarity, the required tenure mix has been set out in the policy. However, this can be negotiated on a case-by-case basis where necessary, subject to appropriate justification, in liaison with the council's Housing Department.

(25)Policy H4 Affordable Housing

Provision of affordable housing will be required as set out in criteria 1 to 4 below and in accordance with the type, mix and tenure requirements set out in Policy H5 (Housing Mix).

  1. On-site affordable housing provision will be required on sites of 10 dwellings or more, or sites of 0.5 hectares or more at the following percentages:
    1. North of the Plan Area – 40% on greenfield sites, 30% on previously developed land.
    2. South of the Plan Area – 30% on greenfield sites, 20% on previously developed land.

Strategic Locations/Allocations will make provision as per the requirements set out above unless otherwise stated in the site-specific allocation policy.

  1. On sites of 6 to 9 dwellings, in areas designated as rural areas as shown in Appendix B, the council will seek a financial contribution for the provision of affordable dwellings as a commuted sum.[33]
  2. Where the affordable housing calculation results in fractions of homes, the fraction will be sought as a commuted sum, using the calculation set out in Appendix I.
  3. Where the affordable housing requirement causes a proposal to be financially unviable, developers must assess the below options in order of preference:
    1. Establish if any public subsidy is available to deliver a policy compliant mix;
    2. Alter the tenure mix within the affordable housing percentage required by the policy;
    3. Reduce the overall percentage of housing provided as affordable units;
    4. Provide a financial contribution for affordable housing to be delivered off-site

Commuted sums will only be accepted in very exceptional circumstances if supported by evidence, including, where appropriate, viability evidence. If it can be demonstrated that affordable housing on site is not appropriate, development of affordable dwellings on another site may be considered. If this is not achievable, the council will seek a financial contribution to enable provision of affordable homes elsewhere in the plan area, this is to be calculated in accordance with the latest information on the council's website. The council will expect the requirements of criterion 4 to be demonstrated through an 'open book' process. An independent valuer appointed by the council, at the developer's cost, will provide an independent viability assessment.


25% of the affordable housing provision will be made up of first homes, which will be available to first-time buyers at a minimum of 30% discount from market value and accord with other national policy requirements concerning first homes.

The tenure split of affordable housing should be as follows:

  • 25% first homes
  • 35% social rent,
  • 22% affordable rent
  • 18% shared ownership

Planning permission can be granted for an alternative tenure split provided that robust evidence demonstrates that a different split is more suitable, for example where it is appropriate in order to meet local needs.

Opportunities should be taken to include a proportion of affordable older persons accommodation as part of the affordable housing provision, particularly involving care provision.

Other forms of affordable home ownership will be considered if a suitable justification can be provided, though this should not be at the expense of the social rented component of the tenure mix set out above.

Sub-division of sites

Where a site has been sub-divided or is not being developed to its full potential so as to fall under the affordable housing threshold, the council will seek a level of affordable housing to reflect the provision that would have been achieved on the site as a whole had it come forward as a single scheme for the allocated or identified site.

Housing Mix


5.22. The council will seek to ensure that new housing reflects the need and demand of the plan area's existing and future communities and provides an improvement to the quality and mix of new market and affordable housing in the plan area.

5.23. The mix of dwellings on all development sites is expected to reflect the recommendations of the most recent Chichester Housing and Economic Development Needs Assessment (HEDNA). The HEDNA provides a detailed assessment of housing need; referring to housing size and type by tenure, for the long-term needs of the plan area, although it is recognised that these may change over time.

(2)5.24. In relation to market dwellings, the HEDNA (2022) sets out that the parameters for housing mix should be as follows:

  • 1-bedroom: 5-10%
  • 2-bedrooms: 30-40%
  • 3-bedrooms: 35-45%
  • 4+-bedrooms: 15-20%

5.25. In terms of affordable housing, the HEDNA provides important background information and should heavily inform the size and type of the affordable units provided. However, it will also be important to have due regard to the housing register, especially as this is particularly pertinent in relation to the current affordable housing need, and at the time of the adoption of the plan the greatest need pertains to 1-bedroom units. The specific mix of affordable units should be agreed with the council's Housing Department, who can also provide details of the current level of affordable housing need.

5.26. It is acknowledged that in applying the recommended housing mix to individual development sites, regard should be had to the nature of the development site, the character of the area, and to up-to-date evidence of need as well as the existing mix and turnover of properties at the local level. The figures in the HEDNA should therefore be used as a monitoring tool to ensure that future delivery is not unbalanced. Where an alternative mix is proposed, applicants will be expected to provide justification as part of the planning application process.

5.27. Changing demographics are expected to be a key influence over the plan period. Occupancy patterns show that a high percentage of owner-occupied properties have more bedrooms than they require. There are likely to be opportunities to provide types and sizes of dwellings which will be attractive to older residents and encourage downsizing, consequently enabling some larger homes to be potentially released for families to occupy.

(17)Policy H5 Housing Mix

  1. For new market and affordable residential development, homes must be delivered of an appropriate type and size, consistent with the most up to date HEDNA[34], to address identified local needs and market demand.
  2. The mix of affordable units provided should also pay due regard to the current Housing Register.
  3. Planning permission can be granted for an alternative mix provided that:
    1. robust evidence of local housing need demonstrates that a different mix of dwellings is required to meet local needs and demand for specific types, tenures and sizes of housing to contribute to the diversity of housing in the local area and help to redress any housing imbalance that exists; or
    2. it addresses need and demand for affordable, market housing including self-build and custom-build housing, older person and specialised housing.

Where a development site has been divided into parts, or is being delivered in phases, the area to be used for determining whether this policy applies will be the whole original site.

Self Build and Custom Homes


5.28. The Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016) requires the council to keep a register of individuals and associations of individuals who are seeking to acquire serviced plots of land in the authority's area. The council must grant permission for enough suitable serviced plots of land in order to meet the demand within 3 years of the end of each base period.

(1)5.29. In order to ensure that needs are met a variety of approaches will be pursued:

  • Provision of plots at new Strategic Allocations (Policies A8, A10, A11 and A13), this will make provision for current need which focuses on Chichester and the surrounding parishes.
  • Requiring future strategic scale housing sites (200 dwellings or more) not included above to make provision for self and custom build dwellings in order to ensure a pipeline of future supply. The scale of the requirement in such instances is reflective of the current level of need in order to ensure a consistent approach.
  • By encouraging provision through the neighbourhood plan process, as it is considered that the neighbourhood planning process is well placed to identify needs at the local level and respond to that either via specific allocations or bespoke local level policies.
  • There will also be opportunities for future provision via the future Site Allocations DPD, which will be underpinned by a call for sites process.

(12)Policy H6 Custom and/or Self Build Homes

New sites over 200 units which are allocated in the Local Plan will be required to provide self and custom build serviced plots [35]as set out in the relevant site-specific allocation policies.

In all other instances 2% of market units provided on strategic scale housing sites should be self/custom build.

Self and custom build serviced plots will also be encouraged as part of other residential development sites, though there is no requirement for a specific number of plots.

Plots/units must be extensively marketed at a reasonable value for at least 12 months. For the first two months of this marketing period, the plots will be prioritised to individuals and associations of individuals on the council's self-build register. Where the council agrees that the plots have been appropriately marketed (for a period of not less than 12 months) and have not sold within this time period these plots may be built out as conventional market housing (this option is not available for plots granted via the exception sites criteria referred to below).

The provision of custom and self-build plots via the neighbourhood planning process is encouraged, particularly where a need can be demonstrated via the council's Custom and Self-Build Register, or via evidence gathered as part of the neighbourhood planning process.

Affordable Housing on Exception Sites


5.30. Exception sites allow homes to be built on sites which are not allocated for development in the Local Plan. Exception sites meet a specific, local need and are located outside the existing settlement boundary. Policy H7 applies to first homes exception sites and rural exception sites, and each element of the policy addresses the specific issues and requirements pertaining to such sites.

5.31. Exception sites are offered at below market value to provide affordable homes for local people. Proposals for exception sites (as defined in the NPPF) must meet an identified local housing need in the parish in which they are proposed. For both first homes and rural exception sites, occupiers will need to demonstrate a local connection, which may be as a result of residency, having family or employment in the local area. For the purposes of this policy a 'local connection' is set out in the rural allocations policy contained in the council's allocations scheme.

5.32. Applications must be accompanied by appropriate evidence to demonstrate that the scale and mix of housing proposed will meet a local need. This should be based on information from the council's housing register or up-to-date parish housing needs survey (that has been approved by the council as housing authority).

5.33. Homes built on exception sites must remain available for their intended use in perpetuity. This requirement will be secured through a legal agreement as part of the planning application process.

5.34. First homes exception sites can come forward on unallocated land outside of a local or neighbourhood plan. First homes exception sites will not be permitted in 'designated rural areas', this means Areas of Outstanding Natural Beauty and National Parks and other areas designated as 'rural' under Section 157 of the Housing Act 1985 (as shown at Appendix B). In contrast, rural exception sites can be located in a National Park or an AONB. National policy sets out that First homes exception sites only need to be 'primarily' for First homes and hence can include a small market housing component. However, the inclusion of a market housing component will need to be robustly justified, taking into account the requirements set out in this regard in national policy and guidance.

5.35. To ensure deliverability, applicants must also demonstrate that the proposal is economically viable. Due to their location, rural exception sites must be owned and managed by an approved Registered Provider or incorporated Community Land Trust. Rural exception sites must provide affordable housing for local households in perpetuity; consequently, the homes must be secured through a s106 agreement with an accompanying Nomination Agreement with the Registered Provider that provides the nomination criteria for the homes.

5.36. In assessing the suitability of proposed affordable housing exception sites, consideration will be given to the existing and potential supply of affordable housing from other sites within the settlement. Where the area has a defined settlement boundary, proposals must demonstrate that there are no alternative sites available within the settlement. Priority should be given to sites located adjacent to the settlement boundary and in all circumstances, sites should be well related to the settlement, local services and facilities. Where suitable sites are unavailable, the local housing need may be met in another settlement within 5 miles or their local sub-area.

5.37. Outside settlement boundaries, schemes will only be permitted if the council is satisfied that the existing affordable housing stock will not meet the current local housing need, and where the scheme can be considered to be well-integrated with the settlement. Proposals for affordable housing exception sites will not be permitted in scattered or isolated locations, or for large scale development of over 30 homes.

5.38. The scale of the development should be appropriate to the size of the settlement, defined in the NPPF as not larger than one hectare, or exceeding 5% of the size of the existing settlement. In assessing this, account will also be taken of extant unimplemented permissions in the settlement. Proposals should be of a high standard of design and environmental sustainability, and respect the form, scale and character of the surrounding settlements and countryside.

5.39. The council's Planning Obligations and Affordable Housing SPD provides further information on the provision of exception site housing.

(9)Policy H7 Rural and First Homes Exception Sites

Proposals for affordable housing on rural exception sites will be supported where all of the following criteria are met:

  1. There is an identified local housing need which cannot be met by existing or future affordable housing provision;
  2. Proposals for rural exception sites are for up to 30 dwellings;
  3. The number, size, type and tenure of affordable homes should be based on robust and up to date evidence of local need;
  4. Occupiers can demonstrate a local connection to the parish in the first instance, and the immediately surrounding parishes in the second instance;
  5. The homes will remain affordable in perpetuity;
  6. The site is located adjacent or as close as possible to the existing settlement boundary and does not result in scattered or isolated development in rural areas; and
  7. The scale of the proposal is proportionate to the existing settlement, reflects the landscape character of the area, and would be well related to the existing settlement.

In addition to the requirements above, proposals for first homes exception sites, except in designated rural areas, will be supported where all of the following criteria are met:

  1. The site delivers primarily first homes;
  2. There is a need for first homes which is not being met elsewhere in the plan area;
  3. The homes will remain first homes in perpetuity;
  4. The first homes provided are occupied by first-time buyers who meet the local connection test; and
  5. The size of the site is proportionate to the size of the existing settlement to which it is adajcent, reflects the landscape character of the area and would be well related to the settlement.

Applications for first homes exception sites that propose the inclusion of a small proportion of market housing will be expected to provide robust evidence that the site would be unviable without such housing being included.

Specialist accommodation for older people and those with specialised needs


5.40. Specialist housing caters for people with specific accommodation needs. Specialist housing includes homes for older people, such as extra care housing, homes for those with disabilities or specialist support needs, residential institutions, houses of multiple occupation and hostels. The council will work with partners to identify and secure provision of suitable sites for specialist housing.

Housing for older people

(5)5.41. The Housing and Economic Development Needs Assessment (HEDNA) 2022 estimates the greatest population increase in the district by 2039 to be those in age groups 75 and over. To support an ageing population there should be provision of suitable housing options for the differing needs of individuals, including:

  • Sufficient adaptable and/or accessible market housing stock so that those wishing to remain in their own homes can do so as their needs change.
  • Smaller homes, for those wishing to downsize, and bungalows.
  • Extra care housing, for those able to live relatively independently but requiring on-site support.
  • Care homes, for those needing additional support.

(1)5.42. Policy H10 (Accessible and Adaptable Homes) requires development to deliver adaptable and accessible dwellings, supporting delivery of more accessible long-term housing options.

5.43. West Sussex County Council supports the provision of extra-care housing rather than traditional care homes. The provision of extra-care accommodation on a mixed tenure basis will be encouraged, in Chichester city and settlement hubs (as defined in the Local Plan settlement hierarchy) to meet the needs of extra-care housing in the Chichester plan area.


5.44. The student population of Chichester University was recorded at 4,400 full-time students in 2020[36]. Students live at home, in purpose-built accommodation on campus, rent rooms in private shared houses or have alternative accommodation arrangements. Whilst students should have a choice of accommodation, this should be balanced with the housing needs of the general population.

5.45. The growth of students living in the private rented sector in Chichester has influenced the dynamics of the housing market in the City and the supply of entry-level market housing, increasing pressure on the private rented sector. To minimise the pressure on the existing housing stock it is desirable that any significant increase in full time student numbers is matched by the provision of purpose-built student accommodation, in appropriate and sustainable locations.

Houses in multiple occupation

5.46. Houses in multiple occupation (HMOs) are dwellings lived in by more than one family or groups of individuals who share facilities such as a kitchen or bathroom. They provide a valuable source of accommodation to meet the needs of some of our local population. They can offer a more affordable way to live, particularly for students, low paid workers and key workers who cannot afford to access housing on the open market.

Retention of specialist residential accommodation

5.47. It is evident that, alongside the need for additional specialist residential accommodation to be provided, the plan area experiences significant demands on its existing stock of specialist residential accommodation, for example the change of use of care homes to open market residential development. This can be attributed to a number of different factors including changes in the demographic profile of the plan area and increasing demands being placed on operators of specialised accommodation.

5.48. Taking account of the need to create and retain a mix of residential accommodation to provide for the different needs of communities within the plan area, the Local Plan sets out a presumption in favour of retaining this residential accommodation. However, there may be circumstances where an alternative use is acceptable. Further guidance is set out in Appendix C.

(14)Policy H8 Specialist accommodation for older people and those with specialised needs

All housing sites over 200 units, including those allocated in this plan, will be required to provide specialist accommodation for older people to include a support or care component. The specific type and amount of accommodation required will depend on the size and location of the site.

Proposals for specialist housing, such as homes for older people, student, HMOs or essential worker accommodation[37], and other groups requiring specifically designed accommodation will be supported where the following criteria are met:

  1. There is an identified need;
  2. It will not lead to a concentration of similar uses in an area that would be detrimental to the character or function of an area and / or residential amenity;
  3. It is in close proximity to everyday services, connecting by safe and suitable walking / cycling routes or public transport for the intended occupier;
  4. It can be demonstrated that the development is designed to provide the most appropriate types of support for the target resident;
  5. It can be demonstrated that revenue funding can be secured to maintain the long-term viability of the scheme (if relevant to the type of accommodation proposed); and
  6. The scheme is supported by the relevant agencies (if relevant to the accommodation type to be provided).

Proposals which may result in the loss of specialist needs accommodation will not be permitted unless it can be demonstrated that there is no longer a need for such accommodation in the plan area, or alternative provision is being made available locally through replacement or new facilities.

Accommodation for Agricultural, Horticultural and other Rural Workers


5.49. As a largely rural area there is often a need for accommodation for workers related to agriculture, horticulture, forestry, equestrian activities or other rural based enterprise. This accommodation may require a location in the countryside or within a Horticultural Development Area (HDA) where new residential development would not otherwise be permitted. In such cases, applications for new residential development, 'replacement dwellings', or the conversion of an existing building will be required to demonstrate an essential need for the accommodation. Whether this is essential in any particular case will depend on the needs of the enterprise concerned and not on the personal preferences or circumstances of any of the individuals involved. It must be proven that there is a clear need for the rural worker to live near or at their place of work in the countryside or HDA in order to perform their employment role.

5.50. Planning permission for new temporary, seasonal or permanent occupational accommodation in the countryside or HDA will be assessed thoroughly with the aim of detecting attempts to abuse (e.g. through speculative proposals) the concession that the planning system makes for such accommodation. In particular, it is important to establish whether the stated intentions to engage in farming, horticulture, forestry or any other rural based enterprise are genuine, are reasonably likely to materialise and are capable of being sustained for a reasonable period of time. The evidence required to be included is outlined in Appendix C.

5.51. The council will investigate the history of the holding to establish the recent pattern of land use and whether any dwellings or buildings suitable for conversion or occupation have recently been sold separately from the farmland. In order to retain the property for its intended use, a restrictive condition will be included on any such planning approval limiting its occupation to a person solely or mainly, or last working in agriculture, horticulture, forestry or a rural enterprise.

5.52. There may be circumstances where housing currently restricted to occupation by agricultural, horticultural or other rural workers is no longer required for its original purpose. In such circumstances, any application to remove a restrictive occupancy condition for any dwelling in the countryside will need to demonstrate that the need for which the dwelling was approved originally, no longer exists. Evidence as specified in Appendix C will be needed to support any application to vary or remove a restrictive occupancy condition.

(4)Policy H9 Accommodation for Agricultural, Horticultural and other Rural Workers

New Accommodation

Development proposals which are necessary to meet the temporary, seasonal or permanent accommodation needs of persons working solely or mainly in agriculture, horticulture, forestry or other businesses requiring a countryside or Horticultural Development Area location, will be granted where all the following criteria have been addressed:

  1. Provision of accommodation on-site or in the immediate vicinity of the rural business is essential for its effective operation;
  2. No suitable accommodation exists, could be made available in established buildings on the site or in the immediate vicinity or has been disposed of within a reasonable period of time prior to the submission of the development proposal;
  3. Clear evidence is provided of the economic viability of the rural enterprise and the accommodation is essential for the continued viability of the business;
  4. The accommodation is of a size commensurate with the operational requirements of the business;
  5. The siting and landscaping of any new accommodation is well-related to the existing business building/s or other on-site dwellings and minimises the impact to the character and appearance of the countryside, ensuring no adverse impact on designated sites; and
  6. The supporting information as set out in Appendix C has been provided.

Where new accommodation is granted, this will be the subject of a condition ensuring that the occupation is restricted to a person solely or mainly working, or last working in the locality in agriculture, horticulture, forestry or other rural business and required to live locally in order to perform their role.

Existing Accommodation

Planning permission for the removal of a restrictive occupancy condition on accommodation for agricultural, horticultural or other rural workers will only be granted where it can be demonstrated that:

  1. That there is no longer a continued need for the accommodation or for the rural business; and
  2. The property has been marketed for an appropriate period at an appropriate price for its use as accommodation tied to a rural business and evidence of marketing can be produced in accordance with Appendix C.

Accessible and Adaptable Homes


5.53. Housing should be adaptable to meet the needs of the population within the plan area. The Housing and Economic Development Needs Assessment (HEDNA) 2022 estimates a significant increase in the number of households containing someone with a long-term health problem or disability, living with dementia or with mobility problems. The council is seeking to maximise the provision of suitable housing in order to address this need. However, this does have viability implications, which moderates the level of provision which can be made. The Government have confirmed that following the consultation 'Raising accessibility standards in new homes' there will be a requirement for all new homes to meet Part M4(2) (Accessible and Adaptable dwellings) of the Building Regulations, to ensure they are suitable for a wide range of occupants.

5.54. The HEDNA 2022 estimates an increased need for wheelchair adapted housing. Again, viability consideration place limits on the extent to which this need can be met. To help meet this need, 5% of affordable dwellings will be required to meet Part M4(3) ((2)(b)) (Wheelchair Accessible) of the Building Regulations.

5.55. Wheelchair accessible homes to be delivered through affordable housing must only be provided where the council is able to nominate a person to live in the dwelling. This should be discussed with the council during the pre-application/application process.

5.56. It is recognised there may be applications with site-specific considerations such as site topography, which make the provision of homes designed to meet the enhanced accessible standards not feasible. In these cases, applicants are advised to seek pre-application advice in order to ascertain whether additional information is likely to be required as part of their application submission.

5.57. Applications for major development must include a schedule of accommodation identifying the specific standard under M4 of the Building Regulations that each dwelling will meet.

(1)5.58. To ensure compliance with the standards, the council must be provided with plans certified for compliance and/or written confirmation from an appointed building control body that the specifications for each dwelling meet the relevant standard. Where necessary, this will be secured through a performance-based condition prior to occupation.

(9)Policy H10 Accessible and Adaptable Homes

On all residential development sites:

  1. 5% of affordable housing must meet wheelchair accessibility standards M4(3)((2)(b)) where there is an identified need on the Housing Register.
  2. all remaining dwellings must meet accessibility and adaptability standards M4(2)[38]

Where it is not possible to provide dwellings at M4(3) Building Standards on site, an equivalent off-site contribution should be provided[39].

Meeting Gypsies, Travellers and Travelling Showpeople's Needs


5.59. Gypsies, travellers and travelling showpeople have specific accommodation needs. There are a large number of gypsies and travellers within the plan area, some of which constitute well established communities with extensive family ties within the plan area. However, the council has also experienced considerable amounts of in-migration. Traveller pitches have tended to become clustered in particular parishes, namely Birdham, Funtington, Sidlesham and Westbourne (including a considerable number of unauthorised pitches). There are also two large public sites located within the plan area at Easthampnett and Westbourne. There is also a large travelling showpeople site in Southbourne parish.

(1)5.60. TheGovernment's Planning Policy for Traveller Sites (PPTS 2015) requires councils to assess and meet gypsy, traveller and travelling showpeople's accommodation needs. Meeting this need has the same level of importance as every other housing need within the plan area. PPTS 2015 updated the definition of travellers for planning purposes to no longer include those who have ceased to travel permanently. However, the needs of all travellers still have to be met in an appropriate manner.

Meeting the Needs of Gypsies, Travellers and Travelling Showpeople

5.61. A new Gypsy and Traveller and Travelling Showpeople Accommodation Assessment was completed in 2022 (GTAA) in order to inform the new Local Plan, which builds on the previous joint study undertaken in 2018/19, which was produced on behalf of a group of Coastal West Sussex Authorities. The need requirement, as per the new GTAA is set out below.

Table 5.1 Additional pitch provision required in the plan area to accommodate gypsies and travellers

2024 - 29[40]

2029 – 34

2034 – 2039


Households who meet the PPTS definition[41]





Households whose status is unknown but may meet the definition





People living in caravans but established in the GTAA as not meeting the definition.





Table 5.2 Additional plot provision required in the plan area to accommodate travelling showpeople

2024 – 29

2029 – 34

2034 – 2039


Households who meet the PPTS definition





Households whose status is unknown but may meet the definition





Travelling showpeople established in the GTAA as not meeting the definition.





5.62. Given the high level of need within the plan area the council has had to utilise a wide range of options for meeting this need. This entails providing pitches on the strategic housing allocation sites, supporting increases in the density of pitches on existing authorised sites which have been assessed as being acceptable in principle for additional pitches, and allowing pitches to come forward on a case-by-case basis. The council will also consider allocating additional pitches via the forthcoming Allocations DPD.

5.63. While a wide range of sites have been promoted for new allocations, and also considered for intensification, only a limited number have been considered to be acceptable. These sites are considered in the section below and assessed in detail as part of the evidence base.

5.64. The provision of pitches on the strategic housing allocations is considered to be an effective and sustainable mechanism for providing pitches, as it will ensure that the occupants will have good access to facilities and will ensure integration with the settled community. However, the council cannot rely heavily on that approach, as it is will be less effective at meeting the short-term needs. The policy below sets out the framework for the delivery of traveller pitches on the strategic housing allocations. Traveller pitches should be planned for at the outset of the development, and must not be provided on public open space or other parts of the site safeguarded for other purposes. Pitches should be provided in small clusters of 3 – 4 pitches in order to ensure that travellers can live together as family units. However, larger clusters could be considered if they are provided as part of a high-quality, well-managed scheme, for example provided by a housing association.

5.65. In addition, sites for mixed residential and business uses will be considered where appropriate, and will be important for ensuring suitable provision is made for travelling showpeople (for example in order to ensure that space is afforded to store equipment). In particular, the Southbourne BLD is considered to be the main opportunity for providing additional travelling showpeople plots as it is in close proximity to the main showpeople site within the plan area. The BLD is also of a scale whereby incorporating travelling showpeople accommodation is most appropriate, as this is likely to require a relatively large area and will be mixed use in nature, as there is a need to incorporate a notable amount of storage space. The employment allocation at Bognor Road also includes a requirement to provide travelling showpeople plots, as there is need for more accommodation at a nearby site within an existing employment area.

5.66. To maintain a supply of land and associated accommodation, the council considers it important to ensure that existing permanent authorised sites for Gypsies and Travellers are retained. Permitted accommodation for sites within the rural area will not set a precedent for permanent built dwellings. In order to protect existing permitted sites from other forms of development, sites will be safeguarded.

(8)Policy H11 Meeting Gypsies, Travellers and Travelling Showpeoples' Needs

The Gypsy, Traveller and Travelling Showpeople Accommodation Assessment identifies the potential need for permanent pitches and plots for the period 2024 to 2039 as:

  • 124 additional permanent residential gypsy and traveller pitches (for those who meet the definition) of which 90 pitches are required before 2029;
  • 34 additional pitches will be needed for those who don't meet the definition; and
  • 40 additional plots for travelling showpeople, of which 26 are required before 2029.

The Local Plan provides for a range of mechanisms for making provision for gypsy and traveller and travelling showpeople accommodation including:

  • Allocating pitches on suitable sites, including provision of pitches on new strategic housing allocations, as set out in the site-specific policies;
  • Appropriate intensification of suitable existing authorised sites as set out in Policy H12; and
  • Flexible release of sites on a case-by-case basis as per Policy H13.

All gypsy and traveller pitches provided must comply with the site design policy (Policy H14).

Pitches consented in the plan area should be marketed initially[42] for travellers with a local connection.

Offsite accommodation in lieu of pitches required on strategic sites will only be acceptable where all of the following criteria are met:

  1. The alternative site provides for at least the same quantity of provision as required by the relevant allocation policy (unless it can be demonstrated that the need level for the district has been reduced);
  2. The alternative site is considered as sustainable with regards to access to services when compared with the site allocation for which it is a substitute; and
  3. The site can be developed within the same timeframe (or faster) as the housing allocation site being replaced.

In addition to the site allocations within this Local Plan, in the event of any non-allocated housing sites coming forward for development, accommodation for Gypsies and travellers (whether they meet the Planning Policy for Traveller Sites definition or not) should be provided on development sites of 200 homes or more whilst there remains an identified need in the plan area. 3 pitches should be provided for every 200 dwellings proposed. Off-site provision in lieu of the required pitches can be provided as an alternative, subject to compliance with the criteria set out above.

Where there is a shortfall in provision, sites will be allocated within a Site Allocation DPD. The council's annual monitoring process will help ensure provision is provided at the appropriate time.

Proposals for the loss of existing sites approved for gypsies, travellers and travelling showpeople, or sites last used for that purpose within the last two years, will be required to demonstrate that there is no longer a need for this type of accommodation in the plan area or that the site is no longer suitable for that use.

Intensification of existing authorised pitches

5.66. An important opportunity for providing additional pitches is by increasing the density of existing authorised sites. This is often an appropriate approach for addressing identified needs as it allows existing family units to stay together on the same site.

5.67. However, intensification needs to be approached very carefully in order to ensure that sites do not become excessively large or become overly dense and hence undermine the standard of accommodation provided. In particular, the district contains a number of sites which are already very large, and generally these are likely to only be suitable for limited intensification. In addition, some sites are already used as efficiently as is considered suitable and hence it would not be appropriate to further raise the density of those sites.

5.68. The council has commissioned and produced extensive evidence in relation to existing sites, and the process has also been informed by a call for sites. Where sites have been established as being suitable for intensification, then the policy below establishes the principle of development in those instances, subject to meeting the requirements of the site design policy and other relevant policies within the Local Plan generally.

5.69. The sites and numbers of pitches considered acceptable on those sites is set out in the policy below, and supplemented by location plans within the Local Plan Appendix I.

(6)Policy H12 Intensification sites

To meet the accommodation needs of gypsies and travellers, proposals for additional pitches on the sites, and for the numbers of pitches, set out in the list below, and shown on the inset maps in Appendix I will be permitted, subject to meeting the requirements set out in the traveller site design policy. The number of additional pitches specified is in addition to the number of pitches on the site which have been granted planning permission at the time of the adoption of the Local Plan.

  • Land at Cherry West, 1 pitch
  • Land at Lakeside Barn, 4 additional pitches
  • Tower View Nurseries: North/South, 1 pitch, Connors/Scant Road East 1 pitch
  • Greenacre, 4 pitches
  • Sunrise, Southbourne, 1 pitch
  • The Stables on Bracklesham Lane, 1 additional pitch
  • Five Paddocks Farm, Bracklesham, 2 additional travelling showpeople plots (temporary consent/s owing to future flood risk).

Additional caravans on existing authorised sites which have adequate facilities will also be supported where it meets identified accommodation needs associated with that site, provided this does not lead to overcrowding of sites and the infrastructure is available to meet the additional demand.

Windfall provision of new gypsy and traveller pitches

5.70. This policy sets out a criteria-based approach to assessing proposals which come forward on an ad-hoc basis for the provision of accommodation to meet the needs of gypsies, travellers and travelling showpeople. The policy provides flexibility to meet such needs on a case-by-case basis, and seeks to ensure that sites are provided in appropriate and sustainable locations, and which respect both the interests and cultures of both settled and traveller communities to promote a sustainable, balanced and integrated community.

5.71. As has been set out above, there are well-established gypsy, traveller and travelling showpeople communities with extensive family ties within the Local Plan area, particularly settled in a small number of the more rural parishes. The high concentration of pitches and plots in some of these parishes has led to local concerns that there is a dominance of this type of development in certain areas, which is resulting in perceived unbalanced communities. The council wishes to ensure that the development of communities is mixed and sustainable.

5.72. Sites should not be identified for gypsy, traveller and travelling showpeople use in locations that are inappropriate for bricks and mortar residential dwellings, unless exceptional circumstances apply.

(6)Policy H13 Accommodation for Gypsies, Travellers and Travelling Showpeople

Proposals for new sites, or for the intensification or expansion of existing authorised sites[43], will be supported where it can be demonstrated that all of the following criteria have been met:

  1. The site and proposal is well-related and appropriate in scale to the nearest settled community, having regard to factors such as the scale and form of existing gypsy and traveller sites/pitches and travelling showpeople plots in the area. It must be demonstrated that the number of pitches proposed, considered in relation to both the individual proposal, and the cumulative impact in relation to other existing encampments in the area, will not dominate the local settled community;
  2. The site is suitable in terms of topography, and avoid locations where there are significant constraints to development including flood risk, or which are in the vicinity of incompatible uses such as sewage treatment works or contaminated land;
  3. The proposal would avoid unacceptable harm to the character of the local area and amenity of neighbouring properties;
  4. The site is not in a location whereby it would be in conflict with nationally designated areas of landscape, historic environment or nature conservation protection;
  5. The site has safe access to the highway and public transport services and will not result in an unacceptable impact on the highway network;
  6. For travelling showpeople sites, a site suitability assessment should be submitted with the proposal which takes account of the nature and scale of the showpeople's business in terms of the land required for storage and/or the exercising of animals; and
  7. For proposals outside of settlement policy boundaries, it should be demonstrated that there is a need for the pitch or plot provision within the plan area, and that the proposal will help to meet the identified need for the plan area.

Site design requirements for gypsy, traveller and travelling showpeople sites

5.73. The plan area contains a number of traveller sites which entail a very poor standard of amenity and have a detrimental impact on the character of the area. Conversely, there are a number of more attractive and/or spacious sites, which have a much more successful relationship with the character of the area, and create a much better environment for the site occupants.

5.74. In order to prevent the repetition of the unsatisfactory sites referred to above, and to ensure that the standards of the better sites are reflected in the additional pitches to be provided as part of the Local Plan, a site design policy is considered to be essential. This is especially important given the high number of pitches which are required to be provided.

5.75. It is difficult to set specific size requirements for traveller pitches, as this can often depend upon multiple factors, such as the shape of the site, and on issues such as whether on-site turning is required in order to make the site acceptable in highways terms. However, in order to meet the requirements set out in this policy it is considered likely that a pitch size of at least approximately 320 square metres will be required, this has been established as an appropriate size through the council's site assessment work.

5.76. The Designing Gypsy and Traveller Sites: good practice guide (2008), while noting that it is withdrawn, is still considered to constitute a useful document for informing design considerations as part of the development management process. However, given that this is no longer an adopted policy document it is considered vital to ensure that traveller site design requirements are clearly set out in policy as per the requirements below.

5.77. Likewise, it is considered that it remains best practice, as set out in the guide, to ensure that any new sites (including sites that are proposed for sub-division, intensification or expansion) are up to a maximum of 15 pitches in size. Applying this limit would seek to help provide a well-balanced site where amenity, security and management are achievable.

(2)Policy H14 Gypsy and Traveller, and Travelling Showpeople site design policy

New gypsy and traveller and travelling showpeople sites/pitches must meet the following requirements:

  1. The site and all the accommodation provided benefits from suitable provision of essential services including water, power, sewerage, drainage and waste disposal, or it can be demonstrated that these will be successfully provided prior to the occupation of the site (and maintained as such thereafter). For drainage, this is to be demonstrated by a Drainage Strategy compliant with the council's adopted Surface Water and Foul Drainage SPD, and the West Sussex Lead Local Flood Authority Policy for the Management of Surface Water;
  2. The site must be well landscaped, including through the provision of high-quality boundary treatments, such as timber post and rail fencing and native planting. Incongruous and/or imposing boundary treatment such as metal fencing will not be acceptable;
  3. Proposals should ensure efficient use of land, whilst ensuring that a good standard of amenity is provided for the occupiers, and ensure that the site is not overcrowded;
  4. Pitches will need to contain: sufficient amenity space, including an amenity building (which utilises sustainable design principles as set out in Policy P1 Design Principles), space for a static caravan, touring caravan and car parking;
  5. The site layout must respond positively to the relevant site constraints and should have regard to how the layout can contribute to the promotion of health and well-being such as ensuring adequate landscaping and play areas for children and achieve a reasonable level of visual and acoustic privacy and amenity for people living on the site and for those living nearby;
  6. The design should ensure that the site appears as an open community integrated with its surroundings; and
  7. Any storage areas provided need to be designed and located in a manner which ensures that they are not visually prominent and do not have an unacceptable impact on the character of the area or neighbouring properties.

A site layout plan should be submitted as part of any planning application which demonstrates that the site is able to accommodate the number of pitches and/or plots sought in a manner which will accord with the requirements set out above.

[27] Housing and Economic Development Needs Assessment (April 2022)

[28] Carried forward in this Local Plan (see Policy H2 Strategic Locations/ Allocations 2021 – 2039)

[29]Carried forward in this Local Plan (see Policy H2 Strategic Locations/ Allocations 2021 – 2039) Site Allocations DPD 2014-2029)

[30] Does not include planning permissions on small sites (1-4 dwellings) permitted after 1st April 2022 as these are included in the windfall allowance.

[31] Additional 300 over previous allocation of 1,000.

[32] An additional 245 to the 50 allocated in the Policy BO1 Site Allocation DPD 2014 – 2029 (total of 295)

[33] See website for information about calculation of commuted sum.

[34] Or additionally, a specific parish local housing need study.

[35] As defined in the Planning Practice Guidance

[36] Source: Chichester HEDNA April 2022

[37] Those meeting the essential local worker definition as set out in the NPPF

[39] See website for information about calculation of commuted sum.

[40] This includes the figure from the base date of the GTAA, which is 2022, so this period is effectively a 7 year period.

[41] This category includes a proportion of the undetermined need (30%), as per the methodology used by the consultants who produced the GTAA.

[42] For at least 12 months

[43] Sites covered by Policy H12 above are not required to comply with these requirements as they have already been deemed to meet the criteria in question.

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