2.11 Chapter 3 of the draft Local Plan defines how housing and other needs will be met spatially across the District, in accordance with a defined settlement hierarchy.

2.12 Paragraphs 3.5 through 3.28 of the Draft Local Plan summarise the rationale for the proposed distribution of growth, including noting:

• That growth is required in both urban and rural areas to meeting needs;
• The focus remains on Chichester city as a main sub-regional centre and the most sustainable location;
• Outside of Chichester, development will be focused on ‘settlement hubs’ within the east-west corridor at Tangmere and Southbourne;
• Outside of these locations land for new development will be identified and allocated through the Local Plan or a neighbourhood plan at Service Villages where there are suitable locations to do so; and
• The Local Plan aims to continue to protect the countryside.

2.13 Draft Policy S1 (Spatial Development Strategy) broadly reflects the above, and states that “new residential and employment development is [to be] distributed in line with the settlement hierarchy, with a greater proportion of development in the larger and more sustainable settlements”. The corresponding table identifies a range of ‘Strategic Development Locations’ which are considered to be the ‘more sustainable settlements’ including the service villages of Bosham, Hambrook / Nutbourne (combined) and Loxwood.

2.14 Draft Policy S2 (Settlement Hierarchy) expands this list to include a wider range of settlements where development will be delivered through site allocations as well as windfall development in accordance with other policies in the draft Plan.

2.15 Whilst we have no objection to the principle of distributing the majority of growth to the most sustainable location, subject to consideration of constraints, it is our view the Council has not sufficiently justified the rationale behind its settlement hierarchy.

2.16 This is because a key settlement, Fishbourne, has been overlooked in the settlement hierarchies set out in draft Policies S1 and S2 without good reason. Fishbourne, has not been identified as a more sustainable settlement and ‘Strategic Development Location’ in the table at draft Policy S1, and has instead only been identified in draft Policy S2 as a ‘Service Village’, and a location for the non-strategic provision of only 30 homes. This is despite Fishbourne being a highly sustainable location with suitable and deliverable locations for growth (including Gleeson’s site as detailed in Section 3).

2.17 No evidence is provided which considers the sustainability of Service Centres that provides justification for Hambrook / Nutbourne, Loxwood and Bosham being elevated over Fishbourne.

2.18 From our own review, it is clear there is no rationale for this, as shown below:

Current population Sustainable transport options Existing services / facilities Draft Local Plan proposals
Fishbourne 2,666 Train Station and bus services Primary School
Medical Practice
Public Houses
Community Hall
Supermarket (Tesco Extra)
Roman Palace (inc. coffee shop) 30 homes
Hambrook / Nutbourne Hambrook: 1,908
Nutborne: 1,962

Combined total: 3,870 Train Station (Nutbourne) and bus services Post office
Public House 300 homes
Loxwood 1,026 Bus services Primary School
Medical Practice
Post Office
Community Hall 220 homes
Bosham 1,578 Train Station and bus services Primary School
Medical Practice
Post office
Co-op shop
Churches
Public Houses 245 homes


2.19 We consider that Fishbourne should instead be recognised as a ‘more sustainable’ location where additional strategic-scale growth can and should occur. It has a commensurate number of services and facilities compared to other Service Villages. The proximity to Chichester compared to the other Service Centres and the multitude of employment opportunities and facilities there is also a unique strength of Fishbourne. It also benefits from a nearby Tesco Extra.

2.20 This would be consistent with the Regulation 18 Preferred Approach (December 2018) consultation which identified (through the previous version of draft Policy S1 – at that stage identified as Policy S3 Development Strategy) Fishbourne as a “larger and more sustainable settlement”, alongside Bosham, Hambrook / Nutbourne and Hunston, with an allocation of a “minimum of 250 dwellings”. Loxwood was not recognised as a more sustainable settlement at that time, albeit was still identified to accommodate 125 homes.

2.21 No information has been provided to justify this change in approach between the Regulation 18 and Regulation 19 consultation. We therefore consider the current approach to the Spatial Strategy is not justified and consider draft Policy S1 not “sound”.