Although I am a parish councillor, I am writing as a private resident of Loxwood within Chichester District.
Whereas I fully understand the need for additional housing within the district as imposed by Government under their new Objectively Assessed Need (OAN) formula, I must strongly object to the allocation of 125 additional houses within Loxwood parish as detailed in policy S5 of the CDC Local Plan Review 2035 - Preferred Approach document for the following reasons:-

1. The process of allocation within the designated Service Villages is flawed due to the lack of consultation in advance of this determination with any of the local parishes, contrary to best practice and the NPPF. It is also contrary to CDC's own policies on Community Involvement and the CDC Local Plan Review 2035 - Preferred Approach document which states that "an essential part of the process has been community engagement". NO such engagement has taken place with Loxwood nor do I suspect with any of the other parishes prior to the determination of allocated housing numbers. The NPPF states that Planning Authorities should "Work with the support of their communities and with other authorities if appropriate" and "should identify suitable locations for such development where this can meet identified needs in a sustainable way". The omission of any such engagement and involvement is therefore contrary to national and local policy.

2. The allocation of 125 houses to Loxwood in the North of Plan Area is disproportionate and unfair. Within the current "Made" CDC Local plan effective for 2015-2029 the three designated Service Villages in the North of Plan Area were allocated new housing targets equally at 60 per village, without any reference to the HELAA current at that time. Loxwood decided which sites were viable and achievable to accommodate this number through the formulation and making of a Neighbourhood Plan.

Under the CDC draft Local Plan Review 2035 - Preferred Approach document, CDC has accepted all the sites submitted under their recent call for sites exercise within Loxwood. These were submitted not by the Parish Council, but by local land owners and developers who have significant financial self interest in putting forward sites which have not been reviewed or assessed by the Parish Council in any way. Other Service Villages in the North of Plan Area have been allocated either zero additional housing in the case of Kirdford or only 25 in the case of Wisborough green on the same premise, as CDC claim that Kirdford submitted no sites under the call for sites exercise and Wisborough Green only one site. This is clearly a case of developer led planning which is contrary to National and locally stated policy.

All the service villages within the North of Plan Area should have been challenged to provide a proportionate number of houses under this proposal irrespective of the HELAA or call for sites exercise, as was the practice before. This would have resulted in 50 additional houses per village and would be a fairer and more policy compliant methodology. I am also somewhat distressed to see that the Land South of Loxwood Farm Place has been re-submitted by the developer despite being the subject of 3 judicial reviews and a resounding success for CDC in winning their case in the High Court supported by a number of hard working local residents from Loxwood who put in a considerable amount of time and effort into ensuring that their Neighbourhood Plan was robust enough to resist inappropriate development within the parish. CDC will effectively have wasted their own and these residents' time, effort and money if they continue to allow this site to be put forward for development let alone CDC costs involved in defending the High Court challenge.

3. The whole premise for additional housing development within the NPPF and also the CDC Local Plan Review 2035 - Preferred Approach document is that of sustainability. In Paragraph 4 of the Local plan review document CDC defines sustainable development as:-
 The pattern of need and demand for housing and employment across the area;
 Infrastructure capacity and constraints, in particular relating to wastewater treatment, roads and transport;
 Environmental constraints - avoiding flood risk areas, protecting environmental designations, landscape quality, the historic environment and settlement character;
 The availability of potential housing sites, their deliverability and phasing

Loxwood has few if any employment opportunities, so the demand for housing in the parish is not driven by local employment needs. Indeed most of the residents of Loxwood who work need to travel outside of the parish and use private transport to do so. Loxwood is a popular location not because of need, but because people want to move into what is a delightful rural country location with the benefits that this can bestow. Indeed according to CDC's Landscape Capacity Study document referred to in the draft Local Plan Review - 2035 document, Loxwood has low, or low to medium capacity for development. Despite this CDC has described Loxwood as a "larger Village with the potential for development". These are contradictory statements and demonstrate the lack of detailed attention given to the allocation of housing, relying more instead on what developers put forward than their own analysis of need or capacity.

The public transport situation within Loxwood parish is laughable. There are no sustainable services which would allow workers to travel at peak times to their places of work. There are no bus services that are available more than once per day or only on two days per week. This is hardly sustainable transport.

It is well known by CDC that Loxwood has a fragile and failing waste water sewage system. It is regularly at maximum capacity due to the inundation of surface and ground based water. Southern Water themselves say that there is insufficient capacity for further connections to the system without significant infrastructure renewal or improvement The Nursery Site development in Loxwood has been the subject of an enforcement order due to the Antler Homes connecting illegally to the system and they have had to provide attenuation tanks to allow a trickle discharge into the system as a temporary measure until Southern Water can improve the overall infrastructure. Temporary in this case means a relatively permanent solution as Southern Water have no plans for upgrading the sewage infrastructure in Loxwood in their current or next five year capital spending plans. There is no promise that the following period will include an upgrade to the Loxwood system either. Therefore, in terms of sustainability, how can CDC require Loxwood to accommodate a further 125 houses plus windfall developments of less than 6 houses to go ahead given the state of the sewage system? This is clearly unsustainable.

In addition to sewage, Loxwood Village had the highest number of flooded houses (16) of any village in Chichester District in the 2013/14 storms. This was in the main due to the bursting of the banks of the Loxwood Stream. Further urbanisation of the village will place greater pressure on the surface water disposal most of which relies on ditches feeding into the Loxwood stream.

Finally on sustainability, under the proposed plan with windfall developments, Loxwood will see around 200 new dwellings in the plan period out of a total current stock of around 650 dwellings. This is a 30% increase in this essentially rural village (CDC's description). This level of urbanisation will without doubt change the historic nature and settlement character of the village putting excessive pressure on the local School, which is already near to capacity, and the other services such as the medical practice. This is contrary to the Sustainability statements in both the NPPF and the proposed local plan.

In conclusion I would urge CDC to take into account all of the above arguments and to review its housing allocations for the Villages in the North of Plan Area so that they are more equitable and realistic given the nature of this village and its inability to provide any significant number of sustainable dwellings now or in the near to medium future. Other villages should be challenged to come up with additional housing sites to take up any short fall in required housing allocations in a fair and plan led approach to housing numbers.