The Chichester Local Plan Review identifies a total housing requirement of at least 12,350 dwellings over the period 2016 to 2035. This equates to an average supply of 650dpa and relates solely to the area outside of the SDNP.

The proposed housing requirement is based upon a requirement of 609 dwellings, derived using the standard method identified in the PPG (para. 2.35, 2018 HEDNA). A further 41 dwellings are added to accommodate unmet need arising from the Chichester District part of the SDNP (para. 2.22, Local Plan Review).

Whilst it is agreed that the standard method should be used to identify the housing needs of the area, it is considered it has been incorrectly applied. Furthermore, the inclusion of 41 dwellings for the SDNP is not sufficient to meet the unmet needs from this area.
The PPG places a limit on the amount of increase in the minimum annual housing need figure an individual local authority can face. Where there is an up to date local plan, i.e. less than 5-years old, this is set at 40% above the average plan requirement. If there is no up to date local plan it is set at the higher of 40% above step 1 or the most recent plan requirement, whichever is the greater.
In terms of Chichester the extant local plan is less than 5-years old, being adopted in December 2016. This identified an average annual housing requirement of just 435 dwellings. The 2018 HEDNA utilises this requirement to identify a need for 609dpa over the period of the Local Plan Review, which has been capped at 40%.

However, the extant Local Plan did not provide for the full need of 505dpa due to several constraints including infrastructure capacity and the quantification of need within the SDNP (para. 7.9). The Plan states that 'For this reason the Council will review the Local Plan within five years to aim to ensure that OAN is me' (para. 7.9).

However, the PPG is clear that the cap is applied 'to help ensure that the minimum local housing need figure calculated using the standard method is as deliverable as possible. The cap reduces the minimum number generated by the standard method, but does not reduce housing need itself. Therefore strategic policies adopted with a cap applied may require an early review and updating to ensure that any housing need above the capped level is planned for as soon as is reasonably possible'. (PPG ID 2a-007).

Given that the Council is already not meeting its previously identified needs it appears contrary to the ethos of the NPPF and PPG to use the artificially low annual housing requirement of 435 dpa as the base figure and then final capped figure of 609 dpa to limit future need. There is also further unmet need in the neighbouring South Downs National Park. Therefore, it is proposed that the Council review their Housing Need figures.