We continue to recommend that the land east of Southbourne (Policy A13 in emerging LP) is identified for mixed use development as the most sustainable and appropriate location for development at Southbourne, as was acknowledged within the draft submitted Neighbourhood Plan previously. . We feel that suitable and sufficient justification and rationale has been presented to bring forward the land east of Southbourne as a specific allocation in this local plan and we would question why a site that has been comprehensively masterplanned, is available, suitable, and deliverable, has not been given specificity within the emerging plan and is instead vulnerable to the delays and changes likely to be experienced with the drafting of a DPD or NP.

We note that within Policy H1, there is a larger than average reliance on windfall sites to meet the overall total supply for the plan period. We would question whether sufficiently compelling evidence has informed a figure that equates to over 20% of the figure applied to strategic allocations has been set aside for a windfall allowance.

Further, we would also question the reliance on 2,210 dwellings that are currently allocated in the adopted plan/Site Allocations DPD but do not yet benefit from planning permission. Even with both of these assumptions included, there does not appear to a significant headroom within the housing supply in the event of a delay to a strategic development or reduced levels of windfalls or sites delivered from existing applications. The delays experienced at the strategic developments at Tangmere and West of Chichester (totalling 2,900 dwellings from the 2015 adopted plan), it is clear that there is a need for sufficient housing allocations so as to not plunge the Council once again into a housing supply shortfall in the event of unexpected events. We would encourage the emerging plan to be prepared with a degree of hindsight to inform those future scenarios in which these two large strategic sites are not delivered at the rates envisaged when they first benefitted from allocation.

We acknowledge the difficulties experienced in Chichester District in meeting their historic housing need; based on a number of constraints, infrastructure delivery and the Duty to Cooperate. In particular, the Council has removed the estimated need within the area of the District within the South Downs National Park Authority. An acceptance of a lack of delivery within the National Park inevitably increases the pressure on the areas outside the National Park.

We would therefore encourage the Council to undertake a review of the district’s housing needs immediately following adoption of the 2021-2039 Local Plan, which takes into account forthcoming census-based household and population projections and is subject to the current proposed changes to the National Planning Policy Framework.

The emerging Local Plan proposes 535 dwellings per annum (dpa) set against an objectively assessed need of 638dpa, which in itself is a reduction on the standard method calculation due to the portion of the District within the SDNP. The deficit between OAN and the 535 adjusted figure equates to a shortfall of more than 1,000 dwellings. It cannot be argued that the plan has been positively prepared when it proposes both an unjustified reduction in its own housing delivery and a failure to accommodate unmet need from SDNP, based on the transport evidenced outlined in the accompanying note it is apparent that there is significant headroom in the strategy to accommodate an increase in dwellings per annum to at least allow CDC to meet their OAN with an appropriate buffer.

This DPA reduction has been justified by the Council based primarily on operational capacity constraints of A27. However, the accompanying transport response from i-Transport demonstrates the Councils justification for reducing their housing delivery per annum has in fact been based on out-of-date traffic modelling, overestimates background traffic growth, utilises ineffective parameters for traffic generation in the face of sustainable travel, fails to seek other funding sources for transport improvements and does not provide modelling data of the proposed mitigation package within the constraints level of housing delivery proposed by the plan. Sensitivity testing within the Council’s LPRTA (Jan 2023) demonstrates that a delivery of 700 dwellings per annum could be accommodated, a figure significantly higher than the adjusted figure from CDC. The unevidenced assertions regarding the constraints posed by the A27 results in the justification for constraining housing delivery being undermined; the plan risks being found not sound as a result of this, and we propose that additional capacity is found within appropriate sites such land east of Southbourne to help address this risk.
CDC has struggled with a precarious housing land supply, with the most recent assessment resulting in a shortfall of 176 dwellings. Within the housing supply for the upcoming plan period, over 20% of these are sites without the benefit of planning permission that have been carried forward with no recent evidence of deliverability or suitability. The risks, based on historic underdelivery, result in this strategy not being positively prepared and failing to be supported by robust and recent evidence. Further, based on recent appeal decisions overturned on the grounds of an unstable housing supply, it is apparent that the reliance of Chichester District Council’s on interim housing policies is not a long-term or sustainable solution. The likely need during the upcoming plan period for interim housing policies is an approach that is wholly unsustainable and would be inappropriate and ineffective to maintain throughout the plan period.


Policy H2 allocates 1,050 dwellings at Southbourne with the allocation of the site to be identified through either the neighbourhood planning process or subsequent Site Allocation DPD. We recommend that the plan be prepared with sufficient flexibility to allow for this (and potentially other) broad locations of development to provide additional housing than prescribed within the current emerging plan.

The Southbourne Neighbourhood Plan had initially allocated 1,250 dwellings on land east of Southbourne, prior to concerns being raised by the Examiner (based on a pre-emption of the emerging local plan). The Examiner did not conclude that the proposed allocation was unsustainable for growth or inappropriate in size, but simply that the timing of the Neighbourhood Plan was too early against the emerging Local Plan timetable which had unfortunately been delayed. Indeed, the draft policy A13 includes a wide range of facilities and requirements that can be more comprehensively and fully met with some flexibility over the final quantum of development. Furthermore, through a masterplanning design-led approach, it may be that a higher quantum of development is deemed appropriate in any event.

We continue to recommend that the land east of Southbourne (Policy A13 in emerging LP) is identified for mixed use development as the most sustainable and appropriate location for development at Southbourne, as was acknowledged within the draft submitted Neighbourhood Plan previously.

One aspect of the delivery in Southbourne that will need some further consideration is the follow-up process, post-adoption of the Local Plan. The draft policy identifies the need to formally allocate a site within a either the neighbourhood planning process or subsequent Site Allocation DPD. It is worth noting that despite valid attempts by the Southbourne Neighbourhood Plan to allocate land East of Southbourne, they were prevented from doing so by the recommendations of the Examiner. In order to protect their community from speculative allocations (and in direct response to the recommendations of the Examiner), the NPG has proceeded with a plan with zero allocations. If a new NP is to be prepared to inform which areas of Southbourne will be subject to the overarching BLD policy, it will be the neighbourhood planning group’s fourth attempt at doing so. Whilst we are confident that the NPG will be proactive in their efforts to secure a comprehensively masterplanned residential scheme in Southbourne, this community has gone far beyond what many others have in seeking to plan for their community. There is therefore a risk that they will decide to not prepare a new NP. In this instance, Chichester District should provide timescales for the preparation of the Site Allocations DPD post-local plan adoption and also assess the impact of this on the overall housing trajectory. In the event the NPG once again proactively seek to plan for this new allocation, they should be given every support by the District Council. Alternatively, we recommend that a specific site in Southbourne should be identified at this stage, reducing any reliance on a secondary policy mechanism. Given the level of detail within the draft wording for the BLD policy within Southbourne it is unclear whether there are any benefits to leaving allocation to a DPD or NP document. We feel that suitable and sufficient justification and rationale has been presented to bring forward the land east of Southbourne as a specific allocation in this local plan and we would question why a site that has been comprehensively masterplanned, is available, suitable, and deliverable, has not been given specificity within the emerging plan and is instead vulnerable to the delays and changes likely to be experienced with the drafting of a DPD or NP.


We broadly support the Council’s emerging policies regarding affordable housing, housing mix and tenure, design and sustainability.