Comment

Sustainability Appraisal - Local Plan Preferred Approach

Representation ID: 1922

Received: 06/02/2019

Respondent: Mr Andrew Kerry-Bedell

Representation Summary:

The Sustainability Appraisal and Spatial Vision and Strategic Objectives are contradictory in respect of Chidham and Hambrook and particularly relating to the natural environment. Refer to Parish Council's response on Policy S26/DM19.

Full text:

The allocation of 500 homes in the Chidham and Hambrook area is excessive and is not supported by the Council's Sustainability Appraisal.

I object because:
1. The Local Plan promotes the joining of settlements between Chichester to Emsworth, which will adversely impact the special and unique character of these villages. This is in line with the Parish Council's response to Policy S2 Settlement Hierarchy.
2. The Local Plan Review has failed to make a proper distribution of housing in the Parish. The so-called comprehensive selection process undertaken by the planners in their Strategic Site Allocation exercise, and subsequently approval by the District Councillors, is woeful, as it is simply based upon developers' estimates, which have not followed the density benchmarks as per Policy DM3, and also have not been moderated for locations adjacent to sensitive locations. (as Parish Council's response to Policy S2 Settlement Hierarchy.)
3. The Infrastructure Delivery Plan -http://www.chichester.gov.uk/CHttpHandler.ashx?id=31025 (Pages 106-111 for our Parish) which supports the Local Plan is not fit for purpose. It does not adequately address the transportation, educational, medical and general amenities needs of the area that will take a long time to put in place, and not in time for a community which is expected to grow by over 50% in the plan period. This also includes the ongoing debacle about plans for the future of the A27, while in the meantime the A259 takes an ever increasing volume of local traffic. See Parish Council's response AL10/SA10 S23.
4. The Spatial Vision and Strategic Objectives (section 3.6 of the Local Plan) and the Sustainability Appraisal in relation to Chidham and Hambrook are contradictory. See Parish Council's response Policy S26/DM19 Natural Environment. If the latter prevails we will see the loss of key landscape views, the loss of high quality grade 1 and 2 farmland, a further deterioration in water quality, and further increased disruption to internally important migrating birds.

Whilst everyone in the parish fully acknowledges it has a responsibility to contribute to the need for more new housing in the District, there is no justification for the 500 homes slated for Chidham & Hambrook, a number which is excessive and not supported by any documentation.

Most importantly, it is also at odds with the standard method for assessing local housing need, based on the recently reduced ONS estimates of local housing requirements which, In September 2018, revised down its previous 2014 estimate of 210,000 new households per year to 159,000 per year in England, a huge reduction of 25%

It is also highly likely that there are reduced affordability ratios in the Chidham and Hambrook area compared to Bosham and Fishbourne which are closer to Chichester (this area is likely closer to the Havant figure of a 9.2 price to earnings ratio rather than the Chichester one of 13.5)

Adjustment factor equation to take account of affordability

There is also no account taken of the release of properties from landlords for sales in the area. As the affordability factor on new houses is 9.7, and existing houses 7.6, there should be a focused campaign on driving landlords to sell more houses already in the area, rather than building new ones.

For all the reasons given above the allocated number of houses it was stated should be significantly reduced by at least 50%, to 250 houses
Maximum

Finally, dealing with two specific local proposals by landowners:
1. Orchard Farm, Drift Lane - this campsite and caravan site has been offered for development. This single track road is already blocked by construction traffic for a single house currently being built. It is not conceivable that access for any construction traffic would be practicable to build any future house in Drift Lane.
2. Baileys fields - Pallant homes. Based on all of the considerations given above, this development is too large altogether at 500 homes.

Developer viability assessments

It is also notable that, when houses are built, developers do not make the most of the land that they own. Many housebuilders hide behind the viability assessment in not building a suitable number of affordable homes. The government has said that "this assessment should only be used when circumstances have made the council's requirements literally impossible." In all case developers trying to hide behind viability assessment should be made to publish their reasoning so that the local public can scrutinize it and, if the developers refuse to do this, their plans should also be refused.