An Allocation should be made within Policy H2 for 150 – 160 dwellings at Land West of Church Road (Northern Parcel). By not including an allocation at the settlement of East Wittering, and specifically Land West of Church Road (Northern Parcel), the Draft Local Plan is not ‘justified’ and ‘effective’

Following on from objections to Policies S1 and H1, a further objection is raised to the absence of strategic allocations at the Settlement Hub of East Wittering, which had been supported under the Preferred Approach of the Local Plan by Policy AL8 (350 dwellings to be delivered by the Neighbourhood Plan). However, a strategic allocation should be made at the Settlement Hub of East Wittering. It should not be deferred to the neighbourhood planning process as proposed in the Preferred Approach of the Local Plan as this would not be ‘positively prepared’.

As set out under objections to Policy S1, the Sustainability Appraisal has incorrectly not tested growth scenarios which includes development at the Settlement Hub of East Wittering. It is noted within the SA that the 2022 SFRA shows extensive tidal flood risk under climate change scenarios, affecting all the sites reasonably in contention for allocation. This includes Site HWW0002a, Land to the West of Church Road.

However, Chichester District Council published another SFRA back in 2018, identifying Land to the West of Church Road, in the ‘climate change risk zone in 2115’ catchment. The 2018 SFRA was utilised to assess sites in the 2020 HELAA. Land to the West of Church Road was originally discounted in the 2020 HELAA, due to being in the subject catchment. This was challenged and it was argued this is an extreme tidal event and should not be confused with identified flood zones. The EA subsequently advised that the model had been superseded and that the site is not considered to be at risk of coastal flooding. The reason for the difference was found to be which of the various flood risk scenarios were used in the 2018 SFRA. Chichester District Council then produced a revision to the 2018 SFRA in April 2021.

Upon review of the 2022 SFRA, the Council claims the assessments have an updated harbour costal model. Appendix E of the 2022 SFRA outlines how climate change may influence the tidal and coastal flood risk. However, from reading the 2022 SFRA, our interpretation is that the update is based on the original 2018 SFRA, instead of the revised 2018 SFRA and therefore, it appears that the modelling is believed to be inaccurate once again.

Land West of Church Lane is therefore considered available for development within the HELAA. The Sustainability Appraisal also considers the site under reference HWW0002a and has a ‘green’ response on the RAG scale indicated and supporting the findings that the site is suitable for development on these grounds.

It is therefore considered that the exclusion of the settlement of East Wittering from consideration for development is fundamentally flawed and based on incorrect data.

Specifically, Land to the West of Church Road (Northern Parcel) is identified within the SHLAA as developable (See Appendix A) and should be subject to a strategic allocation for 150 - 160 dwellings. Development on the site (Phase 1) is already part committed through the 2022 permission for 70 dwellings (Appeal Ref: APP/L3815/W/21/3286315), demonstrating the unconstrained nature of the overall site.

Representations were submitted via Chichester’s Call for Sites exercise in 2020, and the Site was positively assessed in the HELAA 2021and considered developable. Therefore, in total the Site could accommodate 220 to 230 dwellings, which accords with the HELAA assessment of 226 dwellings.

Notwithstanding this positive HELAA assessment in 2021, the assessment within the SA differs and refers to a relatively poor performance with specific reference to a low level of landscape performance within the 2019 Landscape Capacity Study. The 2019 Study predates the HELAA (and is arguably more out of date in comparison) and covers a more significantly larger area than site HWW0002a. The conclusions of the 2019 Landscape Capacity Study also recognise that there could be very limited development adjacent to the settlement edge if carefully integrated into the landscape and with care given to heritage assets. Given the findings of the Appeal Inspector (see below) it is considered that more significant development can be accommodated through the introduction of an appropriate landscaped setting and the conclusions of the SA are over played in this regard.

Notwithstanding the findings of the 2019 Landscape Capacity Study, during the consideration of the Appeal for the Southern Parcel in 2022, development was found to have a limited impact upon the wider landscape and whilst it would have a significant but localised effect on the character of the countryside, it was concluded this would lessen over time. It is considered that the development of the Northern Parcel could also be integrated into the landscape in a similar manner without significant, wider landscape harm.

Please also see Site Specific Representation Attached