Policy H1 Meeting Housing Needs

Make Southern Water a statutory commenter/stakeholder/approver to ALL planning applications.

I would like to understand from where the figure of 10,350 comes. There is no national Government target for housing. Per Michael Gove: “…the standard method [for assessing local housing need] does not provide a housing target. […] it is used by councils to inform the preparation of their local plans, which local authorities are required to have. Councils decide their own housing requirement once they have considered their ability to meet their own needs in their area. This includes taking local circumstances and constraints, such as Green Belt and Areas of Outstanding Natural Beauty, into account […] This recognises that not everywhere will be able to meet their housing need in full.”

Fewer houses should be built in the area until there is a plan in place to stop sewage outflows which are having an adverse impact on Chichester Harbour.
Building houses on greenfield agricultural land sites should not be permitted whilst brownfield land is available.
building outside of designated settlement areas should not be permitted.

"Protecting and enhancing the unique and special qualities of our environment."

The special qualities of our environment are not being protected or enhanced by building on greenfield land when there are brownfield sites available. Chichester Harbour has already been adversely impacted by sewage outflows and there seems to be no detail in this plan for how the problem that already exists will be dealt with. Building 10,000 homes will exacerbate the impact of sewage outflows on Chichester Harbour, an AONB site of special scientific interest.

A cycle route for commuters between Wittering and Chichester needs to be included.

New flood works to keep the sea out and rainwater away needs to be included.

The plan puts more than nine hundred houses in the manhood peninsula.

However the plan fails to make provision for a cycle route alongside the a286.

Such a cycle route is needed if any more housing in the witterings is allowed, to reduce car travel at peak times.

Also there is nothing in the plan to stop more flooding in the manhood, without which no more hosing should be allowed.

The plan document should open by clearly explaining that no dwellings can be consented and until all the critical infrastructure imperatives are in place or are guaranteed to implemented in an aligned manner.

Are you serious? Provision of fresh water?? Wastewater and sewage?? Environmental impact? Highways congestion? What part of West Sussex in 30 years won't be under water? Medical health and care capability? You have heard this all before. Enough is enough!

Change the allocated number of houses in the plan to 2,699 (23.5% of the government allocation)
Use neighbourhood plans to decide on which developments will be used.

The government document online relating to the change in mandatory house building targets states, 'The Bill will strengthen opportunities for people to influence planning decisions that affect their immediate area. We will give increased weight to neighbourhood plans to ensure the efforts of local communities to produce them bear fruit, introduce Neighbourhood Priorities Statements as a means for communities to formally input into the preparation of local plans, and allow residents to bring forward the development they want to see on their street through innovative new ‘street votes.’ The wider review of the Framework next year will support this.’
https://www.gov.uk/government/consultations/levelling-up-and-regeneration-bill-reforms-to-nationalplanning-policy/levelling-up-and-regeneration-bill-reforms-to-national-planning-policy

There is large scale opposition to the continued development in the area and the squeezing of houses allocated into a small space. Local people's views need to be taken into account.

There is no longer a requirement to meet mandatory housing targets set by the government. 73% of the Chichester District is classified as SDNP, a further 3.5% occupied by the AONB. This land is protected against development. Chichester District Council would be justified in taking the government-allocated figure for housing and reducing it by 76.5%. building 23.5% of the housing allocation to equate to the percentage of land available. The government target was 638 houses per year from 2021-2039 or 11,484 houses. This would equate to 2,699 houses, not the 10,354 proposed. Neighbourhood Plans seem to have been ignored.

Please refer to attached supporting document. Policy H1 is discussed on page 11.

Meet OAN
Allocate more sites in North of the Plan area.

We acknowledge that Chichester District Council is positively attempting to address housing need within the District. However, we object to the proposed plan area total of 10,359 and seek to point out that this figure is too low when compared to the data provided within the HEDNA (April 2022). Ultimately, the Council should be meeting the objectively assessed housing need of 638 dwellings per annum.
The supporting text for Policy H1 reads:
‘constraints, particularly the capacity of the A27 has led to the council planning for a housing requirement below the need derived from the standard method, of 535 dpa in the southern plan area and a further 40 dpa in the northern plan area, a total supply of 10,350 dwellings over the plan period from 2021 – 2039.’
Whilst we acknowledge the constraints of the A27 to the Southern Plan Area, these constraints are not as limiting in the North of the Plan Area, to justify a housing supply of 40 dwellings per annum (679 total).
It is therefore considered that a higher number of dwellings should be allocated to the North of the Plan Area, by increasing the settlement boundary of sustainable settlements such as Loxwood and Kirdford, in order to help the District achieve the objectively assessed housing need of the district.
Loxwood, in particular, is a highly sustainable settlement that the Draft Local Plan has allocated a minimum of 220 dwellings (Policy H2 – Strategic Locations / Allocations) over the plan period. Loxwood is a ‘service village’ that has been recognised by the Council to be a highly sustainable, with sufficient services and facilities, including a school, GP surgery and is well served by public transport. Within the Sustainability Appraisal (January 2023), the highest growth scenario allowed for 1,050 dwellings in Loxwood, with the middle scenario allowing 450 dwellings.
As such, there is significant capacity for allocations within Loxwood and a greater housing provision of a minimum of 300 dwellings, should be provided, based on the findings of the Sustaianbility Appraisal, in order for Chichester to meet the objectively assessed housing need (OAHN).
We argue that to prepare a ‘justified’, ‘effective’ and ‘consistent’ Local Plan, the District needs to increase the housing provision of the North of the Plan Area, through the specific allocation of sites at a District level.

A moratorium on house building until wastewater and A27 road infrastructure upgrades are guaranteed and carried
out.
A reduction in overall house building numbers in the district to reflect the 23.5% of land which is available for
development bringing the proposed number of dwellings to 2699.
Removal of policy A11 from the proposed plan for the reasons listed.
Removal of policy A12 from the proposed plan for similar reasons listed as policy A11.

I am emailing as a member of the public who has been invited to make comments on the proposed new Chichester District Council Local Plan.
Firstly, I have been invited to comment on whether the plan is legally compliant. With this in mind, I would question whether it is. I am aware that there is legislation which is designed to protect Chichester Harbour, namely, I believe, the Chichester Harbour Conservancy Act 1971. This legislation gives the Harbour Conservancy a duty to conserve, maintain and improve the harbour. In the proposed local plan it states:
“4.120. In February 2018 the Chichester Harbour designated Site of Special Scientific Interest (SSSI) was downgraded from ‘Unfavourable – recovering’ to ‘Unfavourable – no change’. Further assessment during 2019/20 found that more than 3000ha of the intertidal parts of Chichester Harbour were now ‘Unfavourable – declining’. A specific policy is therefore required to address this issue. Nitrates finding their way into the Harbour (from a variety of sources) cause algal growth which is harmful to wildlife. Although the proportion of total nitrogen originating from new development is very small, it is important that this source is addressed whilst other measures, such as catchment management, are undertaken to reduce other inputs and recover wildlife.”
Concerning nitrate mitigation, I note that the South Downs National Park Authority (SDNPA) are not able to
guarantee any further land to offset nitrates and this will impact the number of houses which can be built in the
area. The SDNPA has made this clear in the letter they have submitted in consultation regarding Policy A11
(attached). There are, I believe, several proposed sites in the local plan which will need to be able to show they have nutrient neutrality and at present, they cannot do this. With this in mind, I suggest that it would be wrong to
propose the site referred to in Policy A11 and any other sites where this matter applies.
In addition to the issue of nitrates, there is also the issue of water pollution which is blighting the harbour. Building
over 10,000 new houses in the district is going to exacerbate both nitrate and wastewater pollution. A study by Chichester Clean Harbours Partnership (attached) shows that at five sites which were tested within Chichester Harbour, all failed tests for E.coli and Feral Streptococci levels which suggests water quality in the harbour is being impacted by the constant outflows of sewage which are happening across the thirteen outlets which Southern Water control and discharge directly into the harbour. Last year’s data shows that Southern Water spent over 19% of the year releasing untreated sewage into the Chichester Harbour waters. This is evidence that Southern Water is either unable or unwilling to cope with treating the wastewater generated by the housing in the district so to propose 10,000 further houses with no guaranteed upgrades to the wastewater treatment seems ludicrous and a dereliction of the statutory legislation designed to protect the harbour. For these reasons I would question whether the plan can be judged as legally compliant.
The second area I have been invited to consider is whether the proposed plan is ‘sound’. To this, I would suggest that there are so many contradictions between what the plan proposes and what is found in the National Planning Policy Framework (NPPF), other consultation documentation and the plan itself that I believe the plan cannot be found to be sound. As an example two examples referred to above:
Allowing building to go ahead on land without being able to guarantee nitrate offset brings the plan into conflict
with itself. (Policies NE12, NE13, NE19)
To allow building to go ahead which is guaranteed to increase sewage outflow into the harbour brings the plan into conflict with itself. (Policies NE12, NE13, NE16, NE17)
The focus of most of the plan seems to be on providing housing. However, the NPPF makes it clear that house
building needs to be sustainable and include infrastructure in order to meet the economic objective and that there is an environmental objective to be considered both of which I do not believe this plan is meeting.
The proposed local plan does not include any guaranteed upgrades to the strategic road network but does refer to
the fact that the congestion on the roads is a major concern for the residents of the Chichester District. (Proposed Local Plan Point 8.3) I am aware that the strategic road network is an issue outside of the Council’s control but again, to propose adding 10,000 plus housing to the area when they are aware of the serious congestion problem seems nonsensical, especially now in the light of the government removing mandatory house building targets.
The main issue the Chichester District seems to have is that within the boundary, there is a large percentage of land which is protected from development as SDNP and AONB land. What this plan seems to be doing is trying to cram 90% of the original government-proposed allocation of housing into 23% of the land in the district. It stands to
reason that this will have a detrimental impact on the road network. In addition, Chichester District Council are
aware that the major junctions on the A27 have been operating at capacity since the last local plan was written and in their transport assessment published in January 2023, they have made reference to the major junctions now all operating well over capacity (CDC Local Plan Transport Assessment 2039 Point 11.2.1) and have made reference to the fact that there has been no mitigation which was proposed in the previous local plan to most of the junctions (CDC Local Plan Transport Assessment 2039 Point 1.3.2). Therefore building more housing without guaranteed upgrades to the road network would seem both unfair to the residents and businesses who are already suffering the daily challenge of congestion and unethical in the light of the plan which contains several policies referring to minimising the climate crisis, reducing pollution and only allowing development which does not exacerbate congestion and road use. Once again this brings the plan into conflict with itself because the additional congestion is
going to impact both pollution in general and air pollution specifically (Policies NE20, NE22)
The NPPF suggests that there is a presumption in favour of sustainable development but I would argue that trying to fit too many houses into a small, already over-congested area, is not sustainable and does nothing to enhance the lives of people who already live in the area. Of the three objectives in the NPPF (economic, social and environmental) this plan only seems to address the social objective of providing more housing. It does not address the economic objective because of the strain building 10,000 further houses will create on already weak infrastructure. More importantly, it does nothing to address the environmental objective because it will increase pollution and exacerbate problems with the sewage network and the road network which already exist.
In conclusion, with reference to whether the plan is sound, I do not believe it can be judged as sound because, aside from contradicting itself and not fulfilling the objectives outlined in the NPPF as I have highlighted above, the plan is not taking into account local people’s wishes. There have been several action groups set up and demonstrations against further building in the area on the large-scale proposed here. Neighbourhood Plans have been completely disregarded and people in the area have genuine concerns about the impact of pollution on the harbour, the relentless building with no additional infrastructure and the detrimental impact of building on farmland and the implications for biodiversity and agricultural security as well as coalescence of our villages and strain on already overburdened resources such as doctors, schools and village shops.
I can speak concerning Policy A11 because this directly affects where I live but I will also try to highlight below other policies where I know the proposed sites conflict with what is in the neighbourhood plan and conflict with
statements in the local plan.
Our neighbourhood plan has been ignored and the site proposed was the site deemed least suitable for
development and conflicts with the statements in the local plan in the following ways:
1) The site is greenfield land and there is brownfield land available capable of being used for smaller-scale
development (Burns Shipyard). This would appear to be the case with most of the proposed sites being
greenfield land. (Policies A6, A10, A11, A12 A13 and A14). The NPPF states that where possible preference
should be given to using brownfield land for development before allowing development on Greenfield or
agricultural land.
2) The site is wholly outside of the Bosham settlement boundary which in the plan would define this as the
countryside. The local plan states in Chapter 3, that development in the countryside should be ‘restricted’ to
what is essential and meets the proposed needs as defined by policy NE10. The site chosen does not meet the criteria set in policy NE10 and proposing the site, therefore, puts it into contradiction with the plan.
3) The site proposed for Policy A11 is grade 1 and 2 productive agricultural land. The local plan states that it will seek to protect the best and most versatile agricultural land from large-scale, inappropriate or unsustainable non-agricultural development proposals that are not in accordance with the Development Plan. (Local Plan Point 4.8) However for the sites A1, A12 and A14 this does not seem to be the case. In the case of some of the land proposed from Policy A14, I believe the land has been compulsorily purchased from farmers. A large majority of the land proposed for development in the local plan is viable and productive agricultural land.
4) The site’s overflow wastewater discharges from the Bosham outlet into the Bosham channel. This outlet has
been the most compromised in 2022 and has discharged for the largest amount of hours out of all 13 outlets
that discharge into Chichester Harbour.
5) The site proposed for Policy A11 has no proposed primary school provision. The local village school is at
capacity and is unable to be expanded on its current site because there is no land available. Instead, the children from this proposed development will be expected to go to school outside of the village and this will inevitably lead to more cars on the roads as the proposed schools with places are not accessible by public transport or within walking/cycling distance. Again, this is a theme common to Policy A12.
6) The site proposed in Policy A11 suggests that the land is likely to suffer from groundwater and surface runoff
flooding. The likelihood of flooding is greatest along the western boundary of the site which abuts the existing
development of Brooks Lane. Brooks Lane already suffers periods of flooding. The NPPF says that new
development should not increase the likelihood of flooding at existing developments.
7) The vehicle access to the A259 is via one vehicle access point only, which is likely to exacerbate air pollution at peak times with cars idling to access the A259.
8) The proposed additions to the village will be a fourth community hall, which there is no desire or need for and
no end-user has been identified to maintain, allotments which were specifically proposed at the initial consultation and rejected as the least popular choice of an additional community facility and a mini football
pitch which has been hastily added and squeezed onto the site of inadequate size and with inadequate parking
provision to make it a usable asset.
For all of these reasons, I believe that the proposed local plan cannot be judged to be sound. There were several
hundred objections to Policy A11 and I believe there would be true for most of the sites proposed. Our local
neighbourhood plans have not been taken into account when producing this plan and this is against what is stated in the NPPF which suggests that Neighbourhood Plans give communities the power to develop a shared vision for their area. (NPPF Point 29)
The last area I have been invited to consider is if the proposed local plan meets the duty to co-operate. In this
respect, I feel that the duty to co-operate seems to have been viewed as more a ‘duty to consult’ Whilst there has
arguably been consultation between appropriate bodies and other local authorities, I do not believe the plan
reflects the advice that has been given. Again, coming back to Policy A11 as an example the SDNPA, Chichester Harbour Conservancy, Southern Water and National Highways have all raised reservations about the proposed scale of development and the impact it will have on the Bosham area and local infrastructure. However, the reservations have not been heeded and the proposed development is still much the same as it was at the outset. Again, local plans have been ignored and local voices have not been heard. Whilst I am aware that the duty to co-operate is not a duty to agree, if every aspect of a consultation is ignored, I would argue this can hardly equate to co-operation.
In conclusion, I understand the importance of having a local plan and I understand the constraints that Chichester District Council is under due to the available land infrastructure constraints it faces which are largely outside of its control. However, because of the above, and that they have now been given the freedom to deviate from mandatory government house building targets, I would ask you to pay scrutiny to the number of houses in the proposed plan and recommend to Chichester District Council that they need to go back and rewrite the plan to reduce house building to a sustainable level of 23.5% of the government proposed allocation to reflect the percentage of land which is available in the district for development. I also recommend that there be a moratorium on further development in the district until the issues of water pollution by nitrates and sewage can be addressed and until there are the mitigation measures proposed in the transport assessment to allow for further house building.

Modify the plan to a fewer number of houses.

I have read the plan, all of it, and the biggest thought that comes into my mind is that there appears to be very little promised...
What appears to be guaranteed/promised
Ten thousand odd dwellings squeezed into approximately 20% of the available land space.
What is not guaranteed/promised
No new roads or traffic congestion mitigation. The roads around Chichester and the surrounding areas are at capacity already and have been for some time, (Transport assessment Jan 2023) with the exception of the Covid lockdown period. My business involves engineers driving to visit customers in and around this area are a considerable amount of the working day is wasted in traffic congestion. At not an inconsiderable cost. For example, one of my engineers lives in Bognor Regis and what was a 35-minute journey to work - in Bosham - now takes 60 minutes. 60 minutes. More frequent flooding and closures of roads exacerbate this and the new Free school sited on Hunston Road, has compounded the misery. Of course, these delays that everyone experiences only compound the pollution issue as well. This can only get worse with the additional promised housing in the area. Working in and around the area will be chaos.
No new sewage infrastructure is guaranteed for the foreseeable future.
Chichester Harbour and the streets of Bosham are regularly filled with sewage that overflows whenever there is rain. According to Southern Waters’ own Beach Boy App data, there are regular non-stop discharges of Sewage into Chichester Harbour. There is nothing in the plan to stop this and Southern Water themselves say that they don't have the capacity to deal with the wastewater at present, let alone with another Ten Thousand houses built in the medium term. All the E.Cioli levels in the Harbour are already above acceptable levels as advised by the Environment Agency. Table enclosed - figures supplied by the Clean Harbour Partnership.
Attached is the document that explains this testing
No doctor surgeries
None planned
No new schools for the majority of these new housing developments
So despite the positive language of the Plan, there are no plans to provide any new schools for that area, except for the Tangmere proposed development. So in the absence of such plans, I have to ask where in the area are. I don't know about the availability of school places around the area except for Bosham and Chidham where there are none.
General observations
There don’t appear to be many proposed developments for this housing on Brownfield sites. All the major developments in the area appear to be on Grade 1 and 2 agricultural land. Some of which, i.e. Highgrove Farm, which is outside the settlement boundary, appears against National Planning Policy Guidance and local opinion.
So in conclusion, this Plan appears to be solely a cash-generating exercise by Chichester District Council, with income derived from Section 106/CIL levies and forecasted Council Tax receipts, which gives no apparent regard, or only Lip Service, to the quality of life and areas of natural beauty for the existing residents and proposed new residents. It is not a really well thought out plan, not joined up at all with the needs and requirements of the local and separate Utilities and Government agencies such as Transport.
I am not against new housing generally. I'm sure there is a need for future generations and increased population in the County, But this cannot be allowed without all the other facilities that should come along with new housing. This Plan does not plan for that. If there is no funding available to upgrade these facilities, then I can’t see how it is sensible to allow more new housing on this scale.
Yours sincerely Roger Weymouth
Dear all (Sent local councillors, responses removed)
I’ve looked at some possible “road improvements” notably one just outside Tesco which looks like there will be a possibility of multiway lights and a new junction but removing an existing one coming onto the roundabout from the industrial site. Just makes me wonder how much busier this junction will be if they feel the need to re-do the junction. I cannot see how a traffic light system will
improve anything and this strikes me as a case of trying to polish a turd. There will just be too much traffic because of ill-thought-out planning and too many new houses but minus the traffic network improvements required. I also read somewhere that a model or
something shows that if there are no improvements to this area, it will result in a 29-minute wait time at the Tesco roundabout for traffic coming from Bosham way at AM and PM peak times. 29 minutes! Are the planners trying to destroy the quality of life around these parts?
I do not hold much hope for real improvements to the road network, if, after any housing gets the go-ahead in this plan. I quote a paragraph from the Chichester District Council Duty to Co-operate Statement (May 2014). Item 3.10 it states “ The Highways Agency is confident that the works on the A27 Chichester Bypass required to support development set out in the Local Plan can be delivered.
The Stantec Chichester District Council Local Plan Transport Assessment (Jan 2023) states:
• "The adopted Chichester Local Plan (LP) 2014-2029, included a set of mitigation measures at the 6 principal
junctions along the A27 corridor. Although there have been works at the Portfield Roundabout in this timeline, no other mitigation schemes have been completed along the A27 corridor, as such the mitigation schemes defined in this report will also be required to consider the development from this plan period."
So it seems that all this was promised back then and then shelved and the road network is now pretty much unusable on a daily basis, despite the promises of the Highways Agency. So we have a situation where we all try and bypass the Bypass
I would have thought that any new developments, roadworks etc are meant to be progress, or progressive. Not regressive to the local community and those of us who work in the area.
Perhaps there needs to be a moratorium on all new housing in the district until guaranteed measures are in place to improve the road network. This is not guaranteed in the plan. (Point 8.5)

The sites which are uncommitted should only be released conditional on infrastructure being in place commensurate with development.

This policy does not pass the test of soundness as it does not PHASE the release of the uncommitted housing sites. Despite 62% of the overall allocation already being built or committed, equating to 10 years land supply, the remaining 3300 are not constrained. As a consequence such sites could be granted Permission without the necessary infrastructure being in place.

i have conducted my veterinary practice from the current site which is located in Priors Leaze Lane Nutbourne, for the last 40years. Obviously, if the surrounding fields are made available for housing this would greatly enhance my business apart from providing affordable homes for local residents.

Policy H1 allows for 657 housing units to be provided via windfall. This is quite a high number, where do you anticipate these will be provided? Will there be a basis for these to be provided outside settlement boundaries? This is particularly relevant when you consider the numbers being accounted for in the existing locations elsewhere.

To assist in providing the necessary additional level of growth in the district, there is a need to recognise the suitability of additional sites on the edge of Chichester City, through the allocation of additional housing sites such as land at Lawrence Farm in Fishbourne Parish.

Paragraph 11b of the National Planning Policy Framework indicates that policies should, as a minimum, provide for objectively assessed needs for housing, unless 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 60 of the NPPF sets out that in order to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.

To establish the minimum number of homes needed, paragraph 61 sets out that strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance.

Paragraph 66 goes on to set out that strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need can be met over the plan period.

Berkeley supports the identified housing need of 11,484 homes over the plan period, which equates to 638 per annum, calculated using the Standard Method and referenced in paragraph 5.1 of the Local Plan. However, it should be noted that this does not include any allowance for assisting with unmet need from the part of the South Downs National Park within Chichester District.

Policy H1 sets a housing requirement of 10,350 homes during the plan period, equating to 575 dwellings per annum.

As such, a shortfall of 1,134 dwellings exists against the calculated housing need. The plan seeks to justify this shortfall at paragraph 5.2 as a result of perceived constraints across the district, including the capacity of the A27.

The draft plan and evidence base provides limited justification for this shortfall. Berkeley therefore considers that, having regard to paragraph 11(b) of the NPPF, the draft plan fails to provide a strong reason for restricting the overall scale, type or distribution of development based on the application of policies in the Framework that protect areas or assets of particular importance.

Chichester Council have produced a Duty to Cooperate Statement of Compliance as part of their Local Plan evidence base. Whilst it has been demonstrated that the Council have attempted to establish if any neighbouring authorities can accommodate the Council’s unmet need, no local authorities have indicated that they are able to accommodate some of the unmet need, as referred to in paragraph 5.21.

As a result, the responsibility falls back to Chichester District Council to fulfil the unmet need within its own boundaries.

Fundamental to the soundness of the local plan and the future environmental, social and economic sustainability of the district is the need for the local plan to plan positively to meet the housing needs of the district in full.

Berkeley does not support this lower housing requirement than the identified need on the basis that the Local Plan has failed to identify sufficient grounds upon which to diverge from the District’s housing need. Additionally, Berkeley believes there is greater capacity for suitable housing growth at Chichester City than has been identified in the draft plan.

The housing requirement of 10,350 is capacity led and has been reached given constraints such as the capacity of the A27. Additional capacity for development can be identified in the HELAA that is well located in relation to Chichester City which can assist the Council in delivering a housing supply closer to the identified need of the District and continue to accord with the spatial strategy of Policy S1.

It is important to note that the Inspectors Report for the Worthing Local Plan (October 2022) emphasises meeting housing needs as the ‘most important and pressing of all strategic issues’. Chichester Council should therefore utilise as much available capacity as possible to contribute to meeting their housing need.

Berkeley does not consider that the evidence provided to suggest this additional capacity cannot be brought forward demonstrates strong reasons why the overall scale of growth in the district should be restricted.

The Sustainability Appraisal and supporting evidence provide insufficient evidence to demonstrate that strong reasons exist for restricting the level of housing provision. Additionally, it is not demonstrated that the adverse impacts of delivering the housing need in full would significantly and demonstrably outweigh the benefits.

Reduce the housing number

I do not consider the location of most of the development to be well located. Both Tangmere and Southbourne are outside the city, Southbourne by a distance of 6 miles. There is insufficient evidence to show that there will be any modal shift to alternative forms of transport than the car. Transport links are poor and the distances too great for most people to walk or cycle. Cycling links to the city from both Tangmere and Southbourne are poor. Public transport is irregular, infrequent and expensive.

Reduce overall housing number

1) Development is patently not located or designed to minimise traffic generation. Unless there is a fully integrated and planned modal shift requiring substantial investment car use will rise exponentially. Locating so much housing out of the city in areas which have minimal facilities will lead to many more car journeys. If your nearest shop or pharmacy is 2/3 miles away are you going to wait for a bus scheduled every 30 mims, walk 40 mims each way or get in the car?

Housing number should be further challenged on this basis.

CATM model calibrated and validated using 2014 data not taking account of developments such as Chichester Free School adjacent to A27 Whyke roundabout. Transport assessment states "all junctions on the A27 Bypass are over capacity in one or both modelled peak hours". Only 28% of traffic growth due to Local Plan development. Improvements only to Fishbourne and Bognor Roundabouts so over capacity issues still remain at other roundabouts. Plan does not effectively mitigate the impact of additional growth and is adding further demand.

Reduce the housing numbers.

If the recommendations within the policies are to be adhered to the 10,300 number is not viable or deliverable The danger, therefore, is that these recommendations will be superseded by ‘exceptional circumstances’ and the policies will be overridden. 87% of the housing is in the East/West corridor which will impact on Chichester Harbour AONB, already in decline.

Over capacity at the Fishbourne roundabout was identified in 2014, there has been a massive increase in housing west of Chichester between 2014 and 2023 but no improvement to the roundabouts have been implemented to date. There is no guarantee that funding to improve the A27 or Fishbourne roundabout will be available within the timescale of the Plan.
Congestion has been a problem since 2014 and this strategy does not offer a solution. There is a clear omission here that funding is not available to facilitate the improvements required to address the current and worsening congestion caused by future development.

Both a reduction in housing numbers to reduce the pollution and a district wide strategic approach to achieving appropriate mitigation measures, to ensure soundness of the plan.

There appears to be no evidence of a district wide strategic approach to achieving appropriate mitigation measures.

Reduce the housing numbers from 10,350.

We support every effort to improve air quality. Include Ultra Low Emission Zones. Use of car pooling.
Air quality will be reduced by the increased volume of traffic on the A27 before any upgrades can be implemented because engine idling will be increased.
The siting of 2000 new homes along the A259 corridor and the increase in traffic will impact in air quality. This cannot be mitigated. It will deter those who wish to walk or cycle if they are breathing in fumes from cars. The only way this policy can be achieved is if there is a decrease in cars using our roads. And without frequent bus and train services at affordable levels of cost, this will not happen.

To assist in providing the necessary additional level of growth in the district, there is a need to recognise the suitability of additional sites on the edge of Chichester City, through the allocation of additional housing sites such as land at Raughmere Farm in Lavant Parish.

Paragraph 11b of the National Planning Policy Framework indicates that policies should, as a minimum, provide for objectively assessed needs for housing, unless 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 60 of the NPPF sets out that in order to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.

To establish the minimum number of homes needed, paragraph 61 sets out that strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance.

Paragraph 66 goes on to set out that strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need can be met over the plan period.

Berkeley supports the identified housing need of 11,484 homes over the plan period, which equates to 638 per annum, calculated using the Standard Method and referenced in paragraph 5.1 of the Local Plan. However, it should be noted that this does not include any allowance for assisting with unmet need from the part of the South Downs National Park within Chichester District.

Policy H1 sets a housing requirement of 10,350 homes during the plan period, equating to 575 dwellings per annum.

As such, a shortfall of 1,134 dwellings exists against the calculated housing need. The plan seeks to justify this shortfall at paragraph 5.2 as a result of perceived constraints across the district, including the capacity of the A27.

The draft plan and evidence base provides limited justification for this shortfall. Berkeley therefore considers that, having regard to paragraph 11(b) of the NPPF, the draft plan fails to provide a strong reason for restricting the overall scale, type or distribution of development based on the application of policies in the Framework that protect areas or assets of particular importance.

Chichester Council have produced a Duty to Cooperate Statement of Compliance as part of their Local Plan evidence base. Whilst it has been demonstrated that the Council have attempted to establish if any neighbouring authorities can accommodate the Council’s unmet need, no local authorities have indicated that they are able to accommodate some of the unmet need, as referred to in paragraph 5.21.

As a result, the responsibility falls back to Chichester District Council to fulfil the unmet need within its own boundaries.

Fundamental to the soundness of the local plan and the future environmental, social and economic sustainability of the district is the need for the local plan to plan positively to meet the housing needs of the district in full.

Berkeley does not support this lower housing requirement than the identified need on the basis that the Local Plan has failed to identify sufficient grounds upon which to diverge from the District’s housing need. Additionally, Berkeley believes there is greater capacity for suitable housing growth at Chichester City than has been identified in the draft plan.

The housing requirement of 10,350 is capacity led and has been reached given constraints such as the capacity of the A27. Additional capacity for development can be identified in the HELAA that is well located in relation to Chichester City which can assist the Council in delivering a housing supply closer to the identified need of the District and continue to accord with the spatial strategy of Policy S1.

It is important to note that the Inspectors Report for the Worthing Local Plan (October 2022) emphasises meeting housing needs as the ‘most important and pressing of all strategic issues’. Chichester Council should therefore utilise as much available capacity as possible to contribute to meeting their housing need.

Berkeley does not consider that the evidence provided to suggest this additional capacity cannot be brought forward demonstrates strong reasons why the overall scale of growth in the district should be restricted.

A revised housing strategy responsive to constraints is supported. Recently development was promoted in inappropriate locations, without a true acknowledgement of the impacts of the development. The Estate will continue to oppose developments (including proposals north of Madgwick Lane) that harm the estate’s ability to contribute strongly to the local economy, and to ensure the reasonable living conditions of prospective house occupiers are not harmed.

Commit to early review, exploring higher growth options.

See supporting statement.

The Council should look to optimise housing delivery in parts of the district which are not affected by the constraints of the A27 and have the ability to assist in addressing other issues (e.g. meeting unmet need from the part of the district that falls within the South Downs National Park). As such, we consider it essential for the North of Plan Area to make a more significant contribution towards housing supply.

Policy H1 identifies a housing requirement of 10,350 new homes across the plan period. Based on the components part of this policy, it is expected that a total of 10,359 new homes will be delivered. We consider that this buffer provides a lack of flexibility especially as the overall housing requirement is expressed as a minimum within Policy H1.

Meet the required figure of 638 spa along with the unmet need within the SDNPA of 40 dpa

Increase provision in the east - west corridor where there is a good bus service and railway stations.

No sound basis for the lower figure now suggested which has arisen from political pressure and is not supported through previous evdiecen provided by the council and earlier consultation stages.

The Plan needs to address the needs of all groups

There appears to be no assessment of the need for those people who are not travellers but cannot afford to live in a permanent dwelling but need to live in a caravan or those who may live on houseboats. The Housing and Planning Bill 2016 contains a to consider the needs of people residing in or resorting to a district with respect to sites for caravans and the mooring of houseboats as part of that requirement.
How this their need addressed in the Plan?

See attached representation.

WGPC objects to this policy as it includes parish housing allocations. Please refer to response for Policy H3.

WGPC objects to this policy as it includes parish housing allocations. Please refer to response for Policy H3.

The housing allocation for the District needs to be significantly reduced, with less reliance on bringing forward greenfield sites.

We feel that the proposed volume of housing delivery is too high for the capacity of the district to deliver it sustainably, without causing significant harm to protected sites, landscapes and communities. The proposed development is squeezed into a small geographic area along the east-west corridor especially, sandwiched between the Chichester Harbour AONB and South Downs National Park, harming both through the loss of interconnectivity both in terms of biodiversity and landscape views. This concentrated development places an undue burden on the available infrastructure (particularly water treatment and road transport) and is an unsustainable use of highly productive farmland on the south coast plain. We believe this approach is incompatible with wider government ambitions around environmental and climate change management.

Premier welcome the Council’s housing target for the plan area is to provide for at least 10,350 dwellings (equivalent to 575 dwellings per annum) to be delivered in the period 2021-2039 including 310 non-strategic Parish housing requirements and 657 windfall site allowances. However this is below the housing requirement of 13,734 (equivalent to 763 dwellings per annum) derived from the Governments Standard Method for the same period, resulting in a significant shortfall of 3,384 dwellings, notwithstanding the fact that the Council are “now unable to accommodate any unmet need from the part of the South Downs National Park within Chichester District” (as stated at supporting paragraph 5.1 to Policy H1) which has potential Duty to Co-operate implications.

In respect to five year housing land supply (5YHLS) considerations, it is noted CDC’s ‘Chichester Local Plan Area – Five Year Housing Land Supply 2022-2027 (Updated Position at 1 April 2022) statement identifies a potential housing supply of 3,174 net dwellings over the period 2022-2027. This compares with an identified housing requirement of 3,350 net dwellings. This results in a shortfall of 176 net dwellings, equivalent to 4.74 years of housing supply. The Council can therefore not demonstrate a 5YHLS as confirmed by recent appeal decisions , .

In the interests of maximising housing delivery and satisfying the Council’s objectively assessed housing needs, Policy H1 should be revised to state the housing requirement figure derived by the Government’s Standard Method so as to ensure the policy is “effective” and the new Local Plan has been “positively prepared” in accordance with paragraph 35 (a and c) of the NPPF.