Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1316

Received: 06/02/2019

Respondent: Seaward Properties Ltd

Agent: Mrs Rebecca Humble

Representation Summary:

Housing should be better distributed across the District. The Plan places an over-reliance on Neighbourhood Plans to deliver housing.

Full text:

Policy S3 (Development Strategy) sets out the Council's proposed approach to general development across the District through the Plan period. The first objective is to focus development around Chichester and the east-west corridor. Whilst is it accepted that this is the most sustainable location in the District, this strategy will result in a.) an excessive burden on an already challenged infrastructure network (the A27 and poor quality rail services) and b.) mean that other more remote areas across the District will not keep pace with the development of services and facilities in proportion with the amount focused in Chichester itself. Furthermore, it is commonly the case that the complexities around strategic allocations can result in delays to development which can have a consequential impact for housing delivery across the District and consequently the objectives of Policy S4 (Meeting Housing Needs). To address these issues the Council should give consideration to better dispersing development across the District on a higher number of smaller sites. These types of sites should be located towards the periphery of the District whereby settlements can sustain the prospective occupants of new developments. There are a number of benefits to this approach. In the first instance, smaller sites are more likely to come forwards early in the Plan period and ensure that Chichester can deliver the amount of housing required. Delays in land negotiations are less likely to affect the deliverability of sites of this type. Secondly, by locating those sites on the periphery of the District, a proportion of the residents would use local facilities on a daily basis thereby supporting the sustainability of these settlements. Furthermore, the use of local facilities would lessen any immediate burden on infrastructure in the vicinity of Chichester and allow time for it to be developed and improved over the longer term which would avoid compounding an existing problematic situation. Thirdly, the development of smaller sites at the edge of the District would better encourage more widespread infrastructure improvements across the District rather than focusing solely on Chichester. Finally, this approach is fundamentally more sustainable. The focus of a District's housing requirement in a central area will not lead to sustainable patterns of growth over the longer term.

With regard to Policy S4 (Meeting Housing Needs) the Plan is heavily reliant on Neighbourhood Plans delivering large-scale housing allocations which are considered to be disproportionate to the Neighbourhood Plan (NP) process. For example, the plan anticipates Southbourne NP accommodating 1,250 dwellings, Chidham and Hambrook NP accommodating 500, East Wittering NP 350 and Fishbourne 250. To ensure the Plan delivers in terms of its housing requirement, this will require Neighbourhood Planning Groups to have made significant progress on their respective Plan and Plan reviews by May 2019. This is a complex and time-consuming task and the timescales involved may result in a rushed NP process with the alternative of Chichester District Council taking back control and allocating sites contrary to an emerging NP. This is reflected in the minutes of the Chidham and Hambrook NP Group meeting minutes of November 2018 where it is minuted that one of five volunteer residents 'expressed surprise' at the 'tight timescale indicated for the (review) project'. In respect of Fishbourne NP, the Parish Council met on 15th January 2019 where the Groups response to the current consultation was discussed. The minutes are awaited and are likely to provide a steer on the NP groups views on the extent of development proposed within the NP area. Each of the NP groups involved are at various stages in the preparation and review process of their respective Plans making it difficult to predict how quickly each will progress. This will require Council Officers to allocate a significant proportion of their time to support NP groups which may delay work on other Policy work with a consequential impact on progress and delivery of sites across the District. Furthermore, whilst Southbourne NP group have identified land to accommodate their portion of housing development, it is a single site, north of the railway line and therefore, require a bridge. This level of infrastructure improvement is likely to render this scale of development undeliverable in the context of the NPPF. The improvements will be required to facilitate this scale of development and, as such, are likely to be unviable which again, conflicts with the NPPF.