Reduction to only 2.6 Ha per 1000 population represents a considerable erosion of open space standards on the present 3.55/3.65Ha/1000 overall provision. This will lead to inadequate levels of Green Infrastructure, particularly on large strategic sites, to support new populations and improve the health and well being of residents as well as the natural environment. The new standards appear to be mainly based on comparisons with what is currently available as opposed to what is needed and no viability or practical issues have been raised during the course of determining planning applications under the present standards. New developments do not have the same size gardens as much of the existing stock and therefore rely more heavily on public open space and allotments.

There appears to be an inconsistency between the population product in Table 7.1a (which appears to produce an average person per dwelling figure of about 2.16 - based on the dwelling size spread in Policy DM2) and the multiplier used by WSCC in relation to assessing education facility needs (2.28 persons per dwelling - see IDP p25). Note also the precautionary 2.4 persons per dwelling figure used in the HRA doc. para 6.22.

Other factors that should be taken into account with regards person per dwelling figures are that Strategic Developments along the A27 corridor will not have the same proportions of second/holiday homes as elsewhere in the Plan Area, which has done so much to reduce average person per dwelling figures. It should also be noted that there has been a significant rise in houses in multiple occupation since 2011 which does not appear to have been taken into account. There is also a need to take a precautionary approach with regards limiting off site recreation pressures to minimise impacts on the Chichester and Pagham Harbour SPAs.

Given the importance of open space and need for consistent methodologies for determining infrastructure provision, it would appear appropriate to use the higher WSCC figure unless there are clear reasons otherwise.