We proposed the following changes:

1) Increase the Policy H1 housing figure to at least 712 dpa (12,816 dwellings over the plan period) to meet the standard method figure in full; to help meet unmet needs arsing within the South Downs National Park; and to provide a 5% delivery buffer:
2) Increase the Policy H1 East-West Corridor sub-area housing provision figure from 8,717 dwellings to 11,174 dwellings between 2021 to 2039.
3) Update the Policy H1 components of housing supply figures, in particular the ‘Category b Known commitments’ following a critical review of the deliverability of the respective supply sites.
4) Re-consideration locations previously identified in the Preferred Approaches consultation as sustainable / suitable locations for growth, such as Fishbourne.

c) Meeting Housing Needs

i) The Housing Requirement

2.22 Para 5.2 of the draft Local Plan identifies a constrained supply figure of 575dpa is proposed, below the identified housing needs for the District which is calculated at 638dpa (through the Standard Method). This equates to a shortfall of 1,134 dwellings against identified housing needs across the Plan period of 2021 – 2039 or circa. 10% of the identified housing needs.

2.23 Moreover, the draft Plan no longer seeks to provide an additional allowance for accommodating unmet need arising from the South Downs National Park. The draft Plan notes that this is due to constraints arising from transport capacity, in particular, the operational capacity of the A27 Chichester by-pass which forms part of the Strategic Road Network governed by National Highways.

2.24 However, we consider this position is not positively prepared and is unjustified, and therefore results in a Plan which is not “sound”.

2.25 This is because on a review of the Local Plan Transport Study (January 2023) (LPTS) there appear to be significant matters which have not been considered by the Council which would allow identified housing needs to be achieved in full. This includes:

• The LPTS and draft Local Plan makes no allowance for the RIS 3 funding review, which is due to be concluded in 2023/24. The A27 has previously been identified as a location for government investment (circa. £100m), with the funding only withdrawn as it was not possible to get consensus between local authorities. However, it is reasonable to assume that an award of funds is likely through RIS 3. An award of fund through RIS3 would significantly increase network capacity on the A27, which in turn would enable greater levels of growth to be realised – it is noted that the LPTS sensitivity testing demonstrates an additional 165dpa can be achieved with the delivery of the full mitigation package.;

• The modelling underpinning the LPTS may overestimate the amount of traffic that is likely to be generated by the planned growth strategy. A blanket trip rate may not be reflective of the nature and location of identified developments, and no allowance has been made for the internalisation of trips within strategic sites, and the allowance made for sustainable travel (5%) does not correspond with WSCC Travel Plan targets (10%);

• The baseline traffic flows informing the modelling has a 2014 base, with further validation undertaken in 2018. Changes to traffic flows as a result of behavioural change since the Covid-19 pandemic will therefore not be reflected in the assessment;

• In the period since the modelling informing the LPTS has been undertaken, future traffic growth has been reforecast by the Department for Transport and subsequently released in December 2022. The forecast growth is considerably lower than that used to inform the LPTS, and thus the assessment overestimates future year base line flows;

• No additional modelling of a 700 dpa strategy with the reduced mitigation package has been undertaken. It has not been demonstrated that the proposed package of measures cannot accommodate an uplift in dpa;

• The mitigation strategy appears to goes beyond mitigation of the development impacts and result in an improvement of conditions beyond the baseline flows. This would suggest that there is headroom in the strategy to accommodate an uplift in dpa, even without improvements at Stockbridge;

• There is a significant difference in the costing outputs of the mitigation strategy prepared by Stantec, as authors of the LTPS, and the CDC-WSCC revisions. It is not unreasonable to assume that the Stantec costings are accurate, given its experience of such infrastructure and that the exercise was informed by National Highways, who govern the A27 as part of the Strategic Road Network. Further consideration should be given as to whether the uplifted costs presented by CDC-WSCC are accurate.

2.26 We therefore consider that the CDC should be looking to meet at least its full identified need of 638dpa, plus an additional buffer to accommodate unmet need from South Downs National Park, which was identified as circa. 40dpa in the Preferred Approaches consultation (December 2018). In addition, an appropriate buffer (i.e. 5%) should also be applied to ensure there is a realistic prospect of meeting housing needs.

2.27 If CDC was to adopt this approach, it would result in an increased requirement of 712 dpa, or 12,816 dwellings over the course of the Plan period. Based on the currently identified supply of 10,359 dwellings, a further circa. 2,500 homes would need to be identified and allocated through the Plan to address this uplift.

2.28 In meeting this additional need, re-consideration of locations previously identified in the Preferred Approaches consultation as sustainable / suitable locations for growth, such as Fishbourne, would clearly be required.

ii) Components of Supply

2.29 Policy H1 (Meeting Housing Needs) identifies that the total supply across the Plan Period (of 10,359 dwellings) is comprised of:

• Completions 2021/22 – 712 dwellings;
• Known commitments:
o Outstanding 2015 Local Plan and Site Allocations DPD 2014 – 2029 allocations without permission – 2,210 dwellings;
o Outstanding ‘made’ Neighbourhood Plan allocations without planning permission – 100 dwellings; and
o Planning permission as of 01 January 2023 – 3,364 dwellings.
• New Strategic Locations / Broad Locations for Development and Allocations without planning permission – 3,056 dwellings;
• Non-Strategic Parish Housing Requirements without planning permission – 260 dwellings; and
• Windfall (small site allowance) – 657 dwellings.

2.30 A significant proportion of the above ‘known commitments’ (circa. 21%) comprise outstanding allocation from the 2015 Local Plan and 2014 Site Allocations DPD. These allocations, that do not benefit from planning permission, have simply been ‘carried forward’ from previous Plan-making exercises. Given the time which has elapsed since these allocations were previously considered and adopted, and the lack of progress being made in delivering homes at these allocations, the Council should satisfy itself that these allocated sites remain suitable and deliverable locations for re-allocation in the draft Plan. It is considered that the approach of carrying these allocations forward and re—allocating them within the draft Local Plan without evidence to confirm they remain deliverable or developable renders these allocations as unjustified. Clearly, if there is insufficient evidence to confirm these sites are deliverable or developable, then this brings into question whether re-allocating these sites in the draft Plan is an effective strategy for addressing growth requirements.

2.31 Further, of the above components of supply in Policy H2 (Strategic Locations / Allocations) 2,150 dwellings (circa. 21%) are attributed to broad locations (in the case of 1,050 dwellings in Southbourne) or neighbourhood planning areas (for the locations of Chichester City, Nutbourne and Hambrook, Loxwood, Boxgrove, Fishbourne, Kirdford, North Mundham, Plaistow and Ifold, Westbourne, and Wisborough Green) where specific sites will be allocated through Neighbourhood Plans or a subsequent Development Plan Document.

2.32 As indicated by the Housing Trajectory at Appendix E of the draft Local Plan there is a clear need for new allocation sites to come forward quickly, especially as existing sites under construction are scheduled to (in the main) conclude within the next 3 – 5 years.

2.33 We consider there is a significant risk from the current strategy which effectively postpones identifying site specific allocations for over 1/5 of the current housing requirements until further Plan-making exercises are completed. As currently drafted, we consider the strategy is not positively prepared, nor would it be effective in addressing housing needs over the Plan period.

2.34 We consider this could be rectified through the identification and allocation (through the emerging Plan itself) of additional suitable sites, such as Gleeson’s site in Fishbourne as detailed in Section 3.

Recommended Change
2.35 In view of the above, we proposed the following changes:

1) Increase the Policy H1 housing figure to at least 712 dpa (12,816 dwellings over the plan period) to meet the standard method figure in full; to help meet unmet needs arsing within the South Downs National Park; and to provide a 5% delivery buffer:

Housing Figure Element Dwellings Per Annum Dwellings between 2021 and 2039
Standard Method 638 11,484
South Downs National Park Unmet needs Allowance 40 720
5% Delivery Buffer 34 612
Total Housing Figure 712 12,816

2) Increase the Policy H1 East-West Corridor sub-area housing provision figure from 8,717 dwellings to 11,174 dwellings between 2021 to 2039.
3) Update the Policy H1 components of housing supply figures, in particular the ‘Category b Known commitments’ following a critical review of the deliverability of the respective supply sites.