Comment

Draft Interim Policy Statement for Housing Development

Representation ID: 3597

Received: 12/06/2020

Respondent: Mr Alistair Impey

Representation Summary:

Document inadequate and there should be a moratorium on housing development other than affordable/starter housing. Proposed boost in housing is at odds with ideas of sustainability, and will have negative impacts on existing settlements with existing infrastructure and the environment.
IPS does not consider impacts on development caused by Brexit or COVID19.

Full text:

I live on the Manhood Peninsula and am increasingly distressed by the inability of Chichester District Council and the Government to develop housing to match the requirement for affordable housing for local families and provision for starter homes for younger people (in particular key workers) rather than the huge developments of 4 bedroom houses - presumably aimed, primarily, at those from outside the local area - that seems to be the major focus of development promoted by the local planners. There appears to be little recognition that, given the constraints limiting most development to areas in Chichester District Council that are outside the South Downs National Park and the Chichester Harbour AONB, there is simply no room for any major development in the limited remaining spaces (mostly high quality agricultural land or more limited areas of important environmental value) and that any permitted development should focus on the needs of local families and residents.

I believe that the Interim Policy Statement for Housing Development (IPSHD) is an inadequate document to address development in the Chichester area and that the suggestion in Paragraph 2.1 that housing supply in the area be boosted is unsustainable. Personally I believe that there should be a complete moratorium on housing development (other than plans that have already received planning permission) in the area, other than for affordable housing for local families and development of starter homes for key workers and local young people on brownfield sites (e.g Southern Gateway - para 2.4.2 of the IPSHD), until there is a sustainable environment for any such development. Such an environment would require the following steps to be taken and completed prior to any new major development being considered.

• Completion of proposed improvements to the A27 round Chichester to ensure a proper separation of local and through traffic to ensure sustainable access to Chichester and Bognor centres for surrounding communities.
• Completion of drainage and sewerage works so that there is adequate capacity to fully treat all storm and foul drainage for existing and future users and reduce flows of nitrates and other partially treated waste into Chichester Harbour or the entry to the Eastern Solent.
• Completed increases in the number and capacity of schools and medical facilities and improved public transport to match already poorly served existing needs and to be available to service any future housing for which planning permission might be contemplated, prior to any such permission being contemplated.
• Prioritising the development of small scale buildings of one bed /studio flats - to address the need to provide housing for younger people, rather than dismal estates of three/ four bedroom houses, of little architectural merit, that are inappropriate to the character of the settlements upon which they are imposed.
• Ensuring full protection of the wildlife corridors between Chichester AONB and the SDNP and wild life corridors between Pagham Harbour and Medmerry Reserves themselves and from them to the Chichester Harbour AONB and with the SDNP.
• That Planning policies be revised to formally limit developments on the boundaries of Chichester Harbour AONB and SDNP that might negatively impact these important resources. Issues might include noise, light pollution, unsustainable vehicle movements, etc.

Obviously such works would require significant funding, much from Central Government or its agencies. Since, however, it is Central Government that is insisting on unsustainable development in our communities, surely they should first fund the infrastructure development that might make such development sustainable.

Paragraph 3.1 of the IPSHD states that developments should be sustainable and in paragraph 3.3 states that developments should be in accordance with the development plan (as noted the Chichester Plan is now out of date) and considered for planning permission in accordance with this development plan unless material considerations indicate otherwise. The IPSHD describes a number of criteria that should be considered when assessing any potential development. Presumably such criteria are to be considered as material to the overall objective of sustainable development, in the context of Paragraph 3.3. I believe that consideration of these matters clearly indicate that there are material considerations that prevent any further development in the area. In particular:

• Sites should be sustainable located in relation to existing settlements. (Paragraph 4.5)
• Sites should be of a scale and density appropriate to adjoining settlement (Paragraph 4.6)
• Sites should be acceptable in all other respects (e.g highway access, flood risk, affordable housing, open space and reflect the needs of local communities (Paragraph 4.7)
• Impact on the SDNP and Chichester Harbour AONB (Paragraph 5)
• Risk of flooding should not increase (Paragraph 11)

It would appear from the IPSHD that Chichester District Council and Central Government are committed to sustainable development. Sustainability focuses on meeting the needs of the present without compromising the ability of future generations to meet their needs. The concept of sustainability is composed of three pillars: economic, environmental, and social. The proposed boost in development as envisaged in the IPSHD runs in complete contradiction with the goal of sustainability. Large developments have little positive economic impact on existing settlements; such developments have highly negative consequences on the social structures of local communities by imposing significant pressure on existing resources and infrastructure and development of the scale envisaged by the IPSHD will have a very negative impact on the environments of the affected communities with significant knock-on effectives of the very sensitive environments of Chichester Harbour, the SDNP, Pagham Harbour, Medmerry and the wildlife corridors that connect these areas with each other.


The IPSHD does not appear to have considered how development needs (compared to the previous Local Plan) might be impacted by the major economic changes that are likely to impact our area due to COVID 19 or the uncertainties of the United Kingdom leaving the European Union nor the rapid increase in the impact of climate change. The absence of such consideration may lead to flawed conclusions as to what if any new major development is required in our area and as to whether or not such development might be considered sustainable.


Thank you for giving me the opportunity to comment on the Interim Policy for Housing Development and I trust my comments will be helpful in the preparation of an improved document that can address the issues faced by our local communities in the face of pressures to promote unsustainable development.