Firstly, Linden Homes and Miller Homes fully support the continued allocation of the site for a new mixed-use community. Linden Homes and Miller Homes are committed to delivering much needed, high quality, homes on site along with the supporting infrastructure to create a diverse, sustainable new community to the west of Chichester. This is demonstrated by the continued work currently being undertaken to obtain Reserved Matters consents and discharge all pre-commencement conditions to facilitate commencement on site as soon as is legally possible.

It is noted that, in the main, the draft policy AL1 and its supporting text replicates Policy 15 of the adopted plan, whilst taking account of the fact that outline permission has been granted for the first 750 homes and associated infrastructure. Linden Homes and Miller Homes are generally supportive of this replication and have no comments on most of the allocation policy.

However, in the context of the national objective of 'significantly boosting the supply of homes (para. 59, NPPF 2018)' it is considered that a less rigid approach to the allocation of new homes on the site should be adopted to allow the flexibility for more than 1,600 homes to be delivered on site if technical evidence, at planning application stage, can demonstrate this can be sustainably accommodated. The rest of this section sets out why a more flexible approach to allocating homes on the West of Chichester site should be adopted to make it clear that 1,600 is only the minimum number of homes to be delivered on site.

The land west of Chichester has been masterplanned as a new, sustainable community which will have a range of services and facilities to support residents of the site. This includes a new school, healthcare facility, local shops, employment space and country park. Furthermore, the site is masterplanned to maximise sustainable links to the city centre by bicycle and public transport which further improve residents' access to the many facilities, services and employment opportunities Chichester has to offer. This is further evidenced by the recently approved Reserved Matters application for the primary infrastructure and SANGs, which includes enhanced cycle and pedestrian links to routes into Chichester Centre.

It is therefore considered that housing could sustainably be accommodated on site beyond the 1,600 currently allocated by marginally increasing the density across the site, particularly in areas identified for lower density development. This is supported by draft Policy DM3, which supports densities of at least 35dph per hectare, and higher in locations with good transport links and access to services. Furthermore, government policy also supports development that makes efficient use of land, which includes ensuring that 'decisions avoid homes being built at low densities, and ensure that development make optimal use of the potential of each site (paragraph 123 of the NPPF)'.

Considering this, and in line with emerging policy DM3 and the national emphasis on boosting housing supply, it seems appropriate to explore increasing the average density of the site from the current site wide average of 34dph to an average closer to 40dph due to the planned transport links and good access to services, facilities and job opportunities that the site will enjoy. This could be achieved through a slight increase in the density of housing proposed in the outer areas of the site from the current low level envisaged of 25dph to a range of 30 - 35dph. This has the potential to increase the number of new homes achievable on site from 1600 to circa 1750 without increasing the development area of the site.

Maximising the use of the site supports CDC's strategy set out at draft Policy S3. Policy S3 sets out the broad approach to development within the district. It states that sustainable planned development across the district will be focused on Chichester and within the east-west corridor. Chichester is recognised as a sub-regional centre, with access to the best range of services, facilities and employment opportunities in the district. Therefore, rather than artificially limiting growth around Chichester, allocated sites around Chichester should be given the flexibility to deliver as many houses as environmental and technical constraints allow.

'Significantly boosting the supply of housing' is a critical objective of the Government's approach to overcoming the national housing crisis (Paragraph 59 NPPF). To do this paragraph 60 requires that LPA's 'determine the minimum number of homes needed [our own emphasis added]'. It follows therefore, that policies that allocate sites for new housing should also adopt an approach that only sets a minimum number of houses, particularly in those most sustainable locations that have the potential to support higher growth. Indeed, this is an approach adopted by the Council to all but one of the other allocation policies. Removing the artificial cap of 1,600 homes allocated at the West of Chichester site would allow more homes to be delivered in the plan period and hence help provide the Council and Local Plan Examiner additional reassurance that there is sufficient flexibility within the allocation policy for more housing to be supplied should there be difficulties with delivery on other sites. This is particularly important in the context of the low level of oversupply identified by the Council of 128 homes, equating to a buffer of only 1% of the total housing requirement. Therefore, as the above has demonstrated, there is no reason why the same wording should not be used within draft policy AL1.

Any outline or full planning application which is required will be supported by a full suite of technical documents and evidence, including any additional environmental evidence required under the EIA regulations, to demonstrate how additional housing could be accommodated on the site in such a way that adverse environmental impacts could be avoided. Any changes to density on site would also still have careful regard to the character of the area and any specific environmental constraints, which may mean that some areas of lower density would still be appropriate where circumstances require. Suitable contributions (either financial or in kind) towards additional infrastructure would also be provided to support additional housing where required by relevant planning policies and an identified need is demonstrated and justified.

Taking the above together therefore, we propose that point 1 of draft policy AL1 be amended to make clear that 1,600 is the minimum to be delivered on site. This alteration has the benefit of providing consistency with the adopted masterplan for the site, previous adopted allocation policy and other draft allocation policies, whilst providing flexibility for the site to deliver additional housing in a highly sustainable location where detailed assessment at the planning application stage demonstrates this is environmentally feasible.

We also wish to correct an error within the supporting text to the policy at paragraph 6.13. The paragraph states that the outline application delivers a connection to Tangmere Waste Water Treatment Works. This is incorrect on two accounts. Firstly, the actual connection and pipeline is being delivered separately by Southern Water and is detailed in their planning application for the pipeline with reference WSCC/004/18/WH. Secondly, the outline permission actually allows not only for a connection to the Tangmere facility, but also allows for an onsite foul drainage facility. Whilst the preference is for a connection to the Tangmere facility, the actual foul drainage solution for the site, to date, has not been formally selected yet and both options remain open. We therefore recommend the text is amended to reflect this situation.