Address the housing need. Housing figures should be assigned to settlements which need growth to sustain existing services and which have public transport options.

A key objective of the Government is to significantly boost the supply of housing. Paragraph 60 of the NPPF states that to support this aim it is important that a sufficient amount and variety of land can come forward where it is needed.

In addition, paragraph 11 of the NPPF states:

Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area;

or

ii. 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 26 of the NPPF further states:

Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, joint working should help to determine where additional infrastructure is necessary, and whether development needs that cannot be met wholly within a particular plan area could be met elsewhere.

Section 33a of the Planning and Compulsory Purchase Act 2004 also requires planning authorities to co-operate with other local planning authorities and to engage constructively, actively and on an ongoing basis in the preparation of the Plan, in so far as it relates to a strategic matter. A strategic matter includes the sustainable development and use of land that has or would have a significant impact on at least two planning areas.

Policy H1 of the Draft Local Plan sets out a housing target of at least 10,350 dwellings to be delivered in the period 2021-2039. This equates to an annual provision of 575 dwellings per year, 63 dwellings per year less than the housing target set by Government. Provision for accommodating unmet need arising from the Chichester District part of the South Downs National Park is now no longer proposed. Over the plan period this equates to 1,134 fewer dwellings provided, and potentially 340 fewer affordable homes (based on 30% provision).

The reason for the reduced housing target is cited as being ‘constraints’, in particular the capacity of the A27.

However, the Local Plan fails to consider how housing growth can help to sustain and expand existing public transport provision to make it a more attractive and viable option for existing and future residents. Further housing can also help to support existing shops and services in a settlement which can be accessed without the need to use the A27.

In particular, Birdham has a range of services and facilities suitable for serving the day to day needs of residents, including a primary school, shop and outdoor community facilities. Regular use of the A27 is not therefore inevitable if living in a settlement where a good range of facilities exists.

In addition, the Local Plan is proposing to deliver 114,652sqm of new employment space up to 2039. If the Local Plan fails to provide sufficient homes to house a local workforce it is in effect relying on in-commuting which will worsen the identified A27 capacity issues.