15% above the housing requirement should be identified to safeguard against the non-implementation and delivery of housing proposals and to ensure the Plan is effective and positively prepared.
Higher number of homes should be allocated to the Manhood Peninsula.

The table included within Policy H1 shows an overall housing supply of 10,359 dwellings over the 2021-2039 plan period. This equates to a flexibility allowance of just 0.087%. Further flexibility needs to be built into the housing supply to allow for any phasing issues and an element of non-delivery of sites. The Levelling-up and Regeneration Bill: reforms to national planning policy consultation noted that their analysis suggests 15% of planning permissions are not progressed or are revised.

In this regard, Gladman consider that an additional supply flexibility of 15% above the housing requirement should be identified to safeguard against the non-implementation and delivery of housing proposals and to ensure the Plan is effective and positively prepared in line with paragraph 35 of the NPPF. This would result in the Council needing to identify a further 1,550 homes over the plan period.

Gladman strongly disagree with the no. of homes allocated to the Manhood Peninsula. The 963 dwellings figure over the plan period comprises of existing housing completions and commitments in the area and it does not include any new strategic housing allocations. The Council maintain that is due to recognition of the recently permitted growth and the on-going constraints in the area such as groundwater flood risk. The reason why there is a high no. of commitments in the area in recent years is due to Chichester District Council currently being unable to demonstrate a robust five-year housing land supply.

A small amount of allocated housing growth has been allocated to the Manhood Peninsula area of the district due to the uncertainty surrounding the impact of groundwater flood risk in the area, following the publication of the revised PPG guidance on flood risk and coastal change (August 2022). A high-level data map was produced by JBA Consulting which indicates likely groundwater levels across the district taking into account factors such as topography, groundwater recharge volumes and spatial variations in aquifer storage and transmission properties. Whilst this provides a useful starting point for any assessment of groundwater flood risk, it does not necessarily assess the risk of groundwater flood risk.

Gladman’s land interest at land off Main Road, Birdham lies in the Manhood Peninsula area. An outline planning application was submitted by Gladman in June 2021 and is currently under determination by the Council (application ref: 21/01830/OUT). Gladman have recently submitted a Groundwater Flood Risk Assessment (GFRA) which concludes that the site is at negligible risk of groundwater flooding at ground level and low to moderate risk below ground level with appropriate mitigation where required. The GFRA is currently subject to review by the Lead Local Flood Authority and if a no objection response is submitted, the application will be reported to Chichester’s Planning Committee with no outstanding technical issues likely to be in April 2023.

Furthermore, Gladman have concerns that progressing with the proposed housing requirement in its current form will further exacerbate the significant shortage of affordable homes within Chichester and increase affordability issues in the district. The ratio of house prices to earnings in 2021 for Chichester is 14.61 and is therefore one of highest in the country.