My comments on the Draft Interim Policy Statement for Housing are as follows.
1.3 The CLPKP will continue to form part of the statutory development plan until the LPR is adopted, however Planning Practice Guidance1 makes clear that where local plans have been adopted more than 5 years ago, the housing target against which the housing supply and delivery will be assessed should be derived from the Government’s standard methodology for assessing housing need. From the 15 July 2020 (five years from the date of adoption of the CLPKP), the Council’s housing supply and housing delivery will be assessed against the figure of 628 dwellings per annum, rather than the previously adopted housing target of 435 dwellings per annum.

Comment 1 - The Government's standard methodology for assessing housing need is a centralised method of assessment, which is neither based on an actual local assessment of need, nor on the amount of land available, nor the suitability of development in respect of harm to environment and wildlife it supports. This is particularly pertinent to the situation in Chichester where so much of the District is either AONB or National Park. I believe that some 67% of the District is occupied by the SDNP (South Downs National Park), and a further 3.5% is occupied by the CHAONB (Chichester Harbour Area of Outstanding Natural Beauty). This leaves some 30% for all the housing and much of this land lies between the two designations creating the setting for them. This is especially true of the ‘land to the west of Chichester’ and should mean that any proposed development in this area is very limited. I believe that the figure for the District is far too high given the above constraints and every effort should be made to seek to reduce these.

2.3 This statement aims to provide interim guidance which will apply until the Council considers it has a five-year supply of housing in line with Government guidance. The intention is for the Council to be able to guide development to appropriate and sustainable locations using this document to assist in the consideration of planning applications.

Comment 1 – Sustainable locations needs to take account of the long term and in this regard the potential effects of climate change and rising sea levels should be taken into account. The Environment Agency advises Councils to plan for floods and coastal risk up to 2065. The NPPF states that development in areas of risk is INAPPROPRIATE and should be avoided. This would further reduce the area which is available for new housing.

4.6 Sites should be of a scale and density appropriate to the adjoining settlement. Smaller scale sites, that provide for the gradual growth of settlements, are more likely to be suitable than sites that would significantly change the character of a place. Developments adjoining smaller settlements will be expected to be smaller in scale than those that might be suitable for the extension of Chichester or the Settlement Hubs, with their larger sizes and range of facilities. The Council may support higher density development in settlements with greater facilities and accessibility.

Comment 1 – this should apply to the possible allocation at Highgrove Farm (policy AL7) which would be increasing the scale of Broadbridge by over 75%. This clearly is not appropriate in scale to the adjoining settlement and does not provide for the “gradual growth of settlements” and would significantly change its character.

6.2 To provide clarity for applicants and other parties, the following criteria set out what the Council considers good quality development in the Chichester Local Plan area, with reference to adopted and emerging Local Plan policy and evidence.
2. The scale of development proposed is appropriate having regard to the settlement’s location in the settlement hierarchy.

Comment 1 – this should apply to the possible allocation at Highgrove Farm (policy AL7) which would be increasing the scale of Broadbridge by over 75%. This clearly is not appropriate in scale to the adjoining settlement

6.2 (3) The impact of development on the edge of settlements, or in areas identified as the locations for potential landscape gaps, individually or cumulatively does not result in the actual or perceived coalescence of settlements, as demonstrated through the submission of a Landscape and Visual Impact Assessment.

Comment 1 - The concentration of development along the A259 west of Chichester has already compromised the distinctiveness of the villages along there and the development proposed along this road further closes the gaps between villages.

6.2 (4) Development proposals make best and most efficient use of the land , whilst respecting the character and appearance of the settlement.

Comment 1 – the best use of grade 1 and grade 2 farmland should be to keep it in productive agricultural use.

6.2 (5) Proposals should demonstrate consideration of the impact of development on the surrounding townscape and landscape character, including the South Downs National Park and the Chichester Harbour AONB and their settings. Development should be designed to protect long-distance views and intervisibility between the South Downs National Park and the Chichester Harbour AONB.

Comment 1: Bosham and the proposed Highgrove Site (AL7) lie in a narrow gap between the SDNP and CHAONB. From the Downs you can look out towards the Harbour and from the AONB you can see the Downs and Kingley Vale. Development on this site would greatly compromise this landscape. Any development in this area will compromise the setting of the AONB and the intervisibility between the CHAONB and the SDNP. This is supported in the report prepared for the Chichester Harbour Conservancy entitled ‘A Study of the Views connecting the Protected Landscapes of Chichester Harbour and the South Downs and the AONB views towards Chichester Cathedral’.

6.2 (6). Development proposals in or adjacent to areas identified as potential Strategic Wildlife Corridors as identified in the Strategic Wildlife Corridors Background Paper should demonstrate that they will not affect the potential or value of the wildlife corridor.

Comment 1: Wildlife connectivity between the SDNP and CHAONB is both historic and essential for the survival of species. Wildlife corridors need to be wide enough and connect with both streams and hedgerows. The proposal for only a 200m buffer zone around the proposed wildlife corridors is not enough. Given that the SDNP and the CHAONB have nationally significant status for environmental protection, linking these sites is of national significance (Glover Review). The scale of protection therefore should be on the Regional Scale of 500m and not the local scale of 200m. Effectively this means that undeveloped land west of Chichester should be safeguarded from further development.

I support your aspirations in Para 9 Development proposals shall be of high quality design that respects and enhances the existing character of settlements and contributes to creating places of high architectural and built quality. Proposals should conserve and enhance the special interest and settings of designated and non-designated heritage assets, as demonstrated through the submission of a Design and Access Statement but despair of the ability of volume builders to achieve this and the ability of the Planning Departments to enforce this.