To assist in providing the necessary additional level of growth in the district, there is a need to recognise the suitability of additional sites on the edge of Chichester City, through the allocation of additional housing sites such as land at Raughmere Farm in Lavant Parish.

Paragraph 11b of the National Planning Policy Framework indicates that policies should, as a minimum, provide for objectively assessed needs for housing, unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

Paragraph 60 of the NPPF sets out that in order to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.

To establish the minimum number of homes needed, paragraph 61 sets out that strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance.

Paragraph 66 goes on to set out that strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need can be met over the plan period.

Berkeley supports the identified housing need of 11,484 homes over the plan period, which equates to 638 per annum, calculated using the Standard Method and referenced in paragraph 5.1 of the Local Plan. However, it should be noted that this does not include any allowance for assisting with unmet need from the part of the South Downs National Park within Chichester District.

Policy H1 sets a housing requirement of 10,350 homes during the plan period, equating to 575 dwellings per annum.

As such, a shortfall of 1,134 dwellings exists against the calculated housing need. The plan seeks to justify this shortfall at paragraph 5.2 as a result of perceived constraints across the district, including the capacity of the A27.

The draft plan and evidence base provides limited justification for this shortfall. Berkeley therefore considers that, having regard to paragraph 11(b) of the NPPF, the draft plan fails to provide a strong reason for restricting the overall scale, type or distribution of development based on the application of policies in the Framework that protect areas or assets of particular importance.

Chichester Council have produced a Duty to Cooperate Statement of Compliance as part of their Local Plan evidence base. Whilst it has been demonstrated that the Council have attempted to establish if any neighbouring authorities can accommodate the Council’s unmet need, no local authorities have indicated that they are able to accommodate some of the unmet need, as referred to in paragraph 5.21.

As a result, the responsibility falls back to Chichester District Council to fulfil the unmet need within its own boundaries.

Fundamental to the soundness of the local plan and the future environmental, social and economic sustainability of the district is the need for the local plan to plan positively to meet the housing needs of the district in full.

Berkeley does not support this lower housing requirement than the identified need on the basis that the Local Plan has failed to identify sufficient grounds upon which to diverge from the District’s housing need. Additionally, Berkeley believes there is greater capacity for suitable housing growth at Chichester City than has been identified in the draft plan.

The housing requirement of 10,350 is capacity led and has been reached given constraints such as the capacity of the A27. Additional capacity for development can be identified in the HELAA that is well located in relation to Chichester City which can assist the Council in delivering a housing supply closer to the identified need of the District and continue to accord with the spatial strategy of Policy S1.

It is important to note that the Inspectors Report for the Worthing Local Plan (October 2022) emphasises meeting housing needs as the ‘most important and pressing of all strategic issues’. Chichester Council should therefore utilise as much available capacity as possible to contribute to meeting their housing need.

Berkeley does not consider that the evidence provided to suggest this additional capacity cannot be brought forward demonstrates strong reasons why the overall scale of growth in the district should be restricted.