Interim Policy Statement for Housing Development

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We support the principle of an Interim Policy Statement to guide development in the Local Plan area until the Local Plan Review is adopted.

From the 15 July 2020 (five years from the date of adoption of the CLPKP), the Council’s housing supply and housing delivery will be assessed against the figure of 628 dwellings per Annum and the Council will no longer have a five year housing land supply as required by the NPPF.

This Interim Policy Statement for Housing will help achieve the planning system's requirements for a five year supply of land.

The Parish Council is supportive of the aims of this document, as it attempts to control development in the hiatus between the old local plan being out of date and the new plan being adopted. It is important that the tests of suitabilty in terms of sustainability, flooding, environmental and heritage concerns are robustly applied to ensure only appropriate development takes place.

Section 6.2 -
Point 6 - We would recommend that the opportunity is taken here to be more aspirational and encourage developments now to deliver biodiversity net gain and improvements in the Strategic Wildlife Corridors that have been identified as part of the proposals for the Local Plan Review. This would send a clear message of the Council’s intentions to deliver biodiversity net gain. By setting this aspiration at the outset gives the best opportunity for developers to achieve by planning the design of their site at the outset.

Point 7 – We would wish to see further detail here with regard to wastewater treatment. Whilst reference is made to the current Local Plan policy on wastewater treatment this has also since been supplemented by the Surface Water and Foul Drainage SPD which should be referenced and also the Council endorsed joint EA/SWS statement for Apuldram catchment. We would recommend that there is more specific reference to these constraints as overcoming these issues can slow down development.

Point 8 – We support the requirements for high standards of construction and that the statement asserts to aspirations beyond the requirements set out in policies of the current Local Plan.

Point 11 – This section is comprehensive to ensure that flood risk is fully considered at a site specific level with a lot of detail included in the first sentence. However, the opportunity could be taken to set out locations where development would not be supported due to high flood risk and impacts of climate change on the flood zones as being considered through the Local Plan review. The section does not distinguish between sources of flood risk and whilst it is important all sources are fully considered on a site there will be areas with tidal or fluvial risk where the depths and velocities of flood risk are more hazardous than surface or groundwater flood risk. We note that reference to EA Climate Change allowances is made in relation to an FRA, however, we would recommend that this is extended to refer applicants to your Strategic Flood Risk Assessment where all sources of flood risk are considered as well as then highlighting the need to look at the most recent Climate Change allowances which may supercede some of the SFRA information.

In relation to paragraph 6.2, criteria 7 - we suggest that you consider including a statement to alert housing developers to Chichester District Council’s SPD ‘Approach for securing development contributions to mitigate additional traffic impacts on the A27 Chichester Bypass’. This SPD requires contributions from developments across the district and not just those in close proximity to A27 Chichester Bypass junctions.

We have no comments on the points of detail, for what seems to be a logical and structured working document. However members commented that, for those not familiar with the subject and the issues involved, they would have found the document more accessible if it had been provided with an Executive Summary explaining its purpose and the general concept of the policy that it describes.

We have reviewed the document, and support the provision of Section 6.2 (7), which references the need for developers to consider wastewater requirements as part of their development proposals, as this should help to ensure early engagement with service providers.

Waverley Borough Council has no major concerns regarding the Draft Interim Policy Statement for Housing Development. We wish to ensure that Chichester DC can achieve your housing target without the need to seek assistance from Waverley Borough Council.

West Itchenor Parish Council supports the District Council’s Interim Policy Statement and has no suggestions for amendment

Paragraph 6.2 (11) Under Relevant policies include: please add: West Sussex LLFA Policy for the Management of Surface Water: https://www.westsussex.gov.uk/media/12230/ws_llfa_policy_for_management_of_surface_water.pdf

2.3 With regards to sustainable locations, I would urge the Council to simply rule-out any new developments in Flood Zone 3.

https://flood-map-for-planning.service.gov.uk

I know that a site being in Flood Zone 3 does not necessary mean that no development is possible, but given the climate projections arguments will be made time and again that it is unsustainable.

4.5 In a similar point to the above, future housing development sites should be located well away from the water, to allow the rollback of the coast over the next 80 years. This will allow the creation of new saltmarsh habitat, which has been in severe international decline since records began.

Historic Extent of Saltmarsh at Chichester Harbour (source: Natural England)

1946 717.3 hectares

2016 295.5 hectares

Loss = 59%

Globally, saltmarsh is declining at a rate of about 50%, so it is actually doing worse at Chichester Harbour. That is mainly due to: i) water quality; ii) coastal squeeze, and; iii) climate change / sea level rise.

So in conclusion, sites shouldn’t just be located in relation to existing settlements, but also located with conservation and flood risk in mind.

4.6 The Conservancy has some concerns about density, with regards to the character or the area, flood risk, etc.

6.2 (5) The Conservancy absolutely welcomes the recognition of the importance of protecting long distance views between the AONB and the National Park. Whilst CDC has not cited the Priority Views Study, it could be added as relevant evidence.

6.2 (6) There is a reference to development “in or adjacent” to the Strategic Wildlife Corridors. It is a concern that this is being contemplated. The Conservancy would prefer to blanket protection within the Strategic Wildlife Corridors, and a commitment to a strong buffer zone around them. We would also draw your attention to the emergence of a wider and emerging Chichester Coastal Plan Nature Recovery Area, which will likely include the Strategic Wildlife Corridors, further embedding the good work that the Council started in this regard.

6.2(7) The Conservancy was disappointed that 17/03148/FUL (50 dwellings at Highgrove Farm) was approved in early 2019. This was because the determination relied on assurances from Southern Water about the capacity of waste water provision. Following a subsequent investigation into their practices, Southern Water then pleaded guilty to all 51 charges brought by the Environment Agency in March 2020. Furthermore, it was felt that the impact of the development on the landscape in this case was not given enough weight. Finally, and with a further 250 dwellings now proposed adjacent to the initial 50, there was a sense that the developers should have prepared a plan for the whole site in the first instance, rather than this piecemeal approach.

We would therefore urge the Council to prepare the emerging Local Plan to ensure such issues do happen again.

6.2 (8) There should be recognition that increased insulation in well-designed buildings can reduce overheating. It’s not just about renewable energy, there’s energy conservation to consider as well.

6.2 (9) The Conservancy would welcome Design and Access Statements that account for the needs of less mobile / disabled people.

6.2 (12)It would be a good idea to define what “Where appropriate” means.

I have lived in this village for 50+ years, obviously there has been development on this peninsula and we are all aware of the tremendous traffic flow and over-congestion of the A286. This is the only main road serving the areas of Birdham, Bracklesham Bay down to the Witterings, East and West, and specifically the only main road that serves all of the housing in Birdham.

Flooding and Drainage
Birdham is a low-lying land area in relation to the sea-level. As you are aware the area proposed for development is subject to flooding. After an exceptional wet winter, which we understand will be normal climate going forwards, due to climate change, ditches and drainage are very important. The existing drainage is inadequate in these very wet winters, and although extra drainage was installed in the fields just behind Walwyn Close, tremendous flooding still resulted in Crooked Lane, at the bottom of Pescotts Close, very near Birdham Village School. When the roads flood, this causes severe potholes, of which there were many this year. Further building will result in more traffic, on roads which are unable to cope with the existing level of traffic. There is no alternative route. Building more houses and more traffic will compound the problems associated with poor drainage.
There are also problems with the drainage system which results in flooding, and the appearance of raw sewage escaping and settling in some ditches in the area.

Traffic and Related Incidents
As the road is the only main access route from the A27 to the beaches, this road becomes severely congested, to the point where emergency vehicles struggle to use the road, in an emergency.
This road has been shut on more than 2 occasions, over the years, due to fatalities and serious accidents. This means that the residents are unable to leave their locality.
It would be unsuitable to encourage any building or development that would increase the traffic volume on this road at any time.
On a congested day it can take up to 2 hours to get through a traffic jam on this road.

An Area of Outstanding Natural Beauty
I oppose the building or development of land in Birdham, which is unquestionably an area of outstanding natural beauty and it was designated as such by parliament. Please see the attached document:
"Chichester Harbour AONB was designated in 1964 under the National Parks and Access to the Countryside Act 1949. Since its formation in 1971 under the Chichester Harbour Act, Chichester Harbour Conservancy has had the primary role in managing Chichester Harbour and the surrounding land identified by Parliament as being significant to the integrated management of the land and water."

The general infrastructure of the area is already severely stretched, and is not able to cope with any further increase in traffic or persons. The area should also be conserved as it is an area of outstanding natural beauty, which is needed to protect our future environment.

The geography of the Chichester District makes the realisation of the housing numbers in our Local Plan Review nigh unachievable. As the north of the District is now within the SDNP the land available for development is greatly reduced. Therefore the Coastal Plain has become the target for excessive development and must be restrained.
The threat of a Climate Change Emergency, which the Council have agreed to, and the threat of rising water levels in areas close to the sea do nothing for future development in the Plain.
This should be a exceptional circumstance where the NPPF can be challenged. In fact the whole of the NPPF is in need of a review regarding the housing numbers determined for Chichester District. The methodology for fixing housing needs is flawed and the same applies to the requirements for Gypsy and Travellers sites.
The infrastructure for the Plan Area is also in need of serious attention. The A 27 situation worsens almost daily with no hint of when, if ever, this will be remedied, the availability of Doctors and appointments at the too few surgeries and, to a slightly lesser degree, hospital spaces and of course, becoming even more serious is the capability of Southern Water to manage the treatment of waste water and sewage. So let’s consider Southern Waters’ inadequacies. They have been courting trouble for some years now for discharging effluent into the harbour from their Appledram WWTW, and they are still discharging raw untreated sewage into the River Lavant from properties in the Villages within the Valley. And this is 2020! It is a disgrace. The system in Westhampnett still requires the attendance of tankers to relieve the overflowing of the drains in the Village.
The works carried out by Southern Water at their Easthampnett (Tangmere) WWTW two years ago was to increase the capacity by a additional 3,000 new homes. To facilitate the transport of effluent from the west of Chichester they are currently building a Trans Chichester Pipeline to Easthampnett. This because there will never be any additional capacity at Appledram. This is all very well but the current proposals for sites around Chichester have already swallowed this increased 3,000 capacity. Many of these are already well underway. Whitehouse Farm has approximately 1,500 dwellings, Madgewick Park 350 houses, New Fields, off the Oving Road, an unknown number yet, more planning permissions required but in the region of 150 houses and a new proposal for 200 homes at Old Place Farm, yet to be lodged and finally the SDL site at Tangmere which will produce 1,200 new houses.
What will Southern Water pull out of the hat when these are all connected. And of course these numbers take no account of the “Windfall” developments of which in Chichester District there are many.
So, looking at the Big Picture, Chichester District cannot possibly be expected to fulfil a five year supply of 620 new homes per annum. The infrastructure struggles with the requirement of 425 new homes under our existing Local Plan which is currently under review.

1. Sewerage System capacity requirements to be taken into consideration prior to any further housing development.
It is well known that Westhampnett has a severe issue with foul drainage, in fact the system in Stane Street is past capacity resulting in pumping / tankering having to be undertaken on a regular basis. Given that Southern Water cannot provide adequate capacity for Westhampnett at present Westhampnett Parish Council would seek to have an Upgrade to the Sewerage System completed as a prerequisite to any further development. Ie Southern Water must actually sort out the current problems and provide suitable additional capacity before anything further is built. It is imperative that strong requirements are laid at the door of developers and Southern Water to provide this urgently, or the housing growth required throughout the District cannot take place, as this is also a matter of concern in other areas of the district - the infrastructure for sewage disposal is now inadequate, and needs upgrading.

Not being highly knowledgeable on all the Policies the Parish Council believe that there are 2 areas within the document that pertain to this issue, namely:

On page 4 of 10, Item 4.5
Locational Sustainability
4.5 Sites should be sustainably located in relation to existing settlements, with access to the facilities and services that are generally likely to be required by new residents. Policy 2 of the CLPKP, and emerging policy S2 of the LPR, sets out the settlement hierarchy which will inform consideration of any proposed site.

On page 7 of 10, Item 6.2 sub item 7 and on page 9 of 10 Item 6.2 sub item 11
7. Development proposals should set out how necessary infrastructure will be secured, including, for example: wastewater conveyance and treatment,
affordable housing, open space, and highways improvements. Relevant policies include:

• CLPKP Policy 9 Development and Infrastructure Provision
• CLPKP Policy 12 Water Management in the Apuldram Wastewater Treatment Catchment
• CLPKP Policy 34 Affordable Housing
• CLPKP Policy 54 Open Space, Sport and Recreation
• LPR Policy S6 Affordable Housing
• LPR Policy S12 Infrastructure Provision
• LPR Policy S31 Wastewater Management and Water Quality
11. Development must be located, designed and laid out to ensure that it is safe, that the risk from flooding is minimised whilst not increasing the risk of flooding
elsewhere, and that residual risks are safely managed. This includes, where relevant, provision of the necessary information for the LPA to undertake a
sequential test, and where necessary the exception test, incorporation of flood mitigation measures into the design (including evidence of independent
verification of SUDs designs and ongoing maintenance) and evidence that development would not constrain the natural function of the flood plain, either by
impeding flood flow or reducing storage capacity. All flood risk assessments should be informed by the most recent climate change allowances published by
the Environment Agency. Relevant policies include:

• CLPKP Policy 42 Flood Risk and Water Management
• LPR Policy S27 Flood Risk Management
• LPR Policy DM18 Flood Risk and Water Management

Relevant evidence includes:
• Strategic Flood Risk Assessment Level 1
• Chichester Surface Water and Foul Drainage SPD (Supplementary Planning Document)

2. Overdevelopment of any one area

Westhampnett Parish Council are acutely aware of the housing requirements laid down by Government, and passed down to Local councils. The proposed increase to 628 dwellings per annum, from 435 dwellings per annum is too large an increase.

It is simply not acceptable to continually build more housing in a Parish where new housing will have already increased by nearly 600 in the last few years, with 400 of those in the last 2 years, to the next 18 months. The Parish needs to settle as a community, and there is great concern as to the intentions for the large brown area marked HWH0001b, denoted as Site Allocation, on the attached HELAA map. This area was surrounded with a blue line in the previous Local Plan and at that time linked with the Madgwick Lane development and N.E.Chichester. Whilst more land is obviously needed if the housing objectives are to be met, developing this area would result in a completely changed Chichester with no divide between the City and the Parish of Westhampnett, and the Parish Council consider this to be overdevelopment of any one area.

The Parish Council would like to see a Policy within the Interim Policy Statement that acknowledges this and fully considers the issue. The aim needs to be for smaller sites providing settlement growth, rather than larger sites which significantly alter the character of the place, definitely not resulting in actual or perceived coalescence with other settlements, or affecting potential value or existing value of wildlife corridors.

The Parish Council very much hopes that these 2 very important points are noted, and suitable constraints included within the Interim Policy Statement.

1. Bosham Parish Council considers that the statistics underpinning this policy statement should now be reviewed in the light of the current circumstance brought about by the Covid-19 pandemic, which will affect the employment opportunities and the logistics of residents.

2. We request the dates of all relevant policies and evidence documents are noted for reasons of clarity.

3. Implementation of the latest information and recommendations in respect of climate change is of great importance and a vital critical element of Sustainable Development.

4. Chichester Harbour villages are particularly susceptible to coastal erosion and flooding. All development must be sustainable in the long term and not just for the plan period.

5. We expect CDC to robustly respect the protected, both national and international, status of Chichester Harbour Area of outstanding Natural Beauty.

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1. Background

3. Request that a guarantee is given that 628 is the maximum figure for dwellings per annum.

Hunston Parish Council understands that only approved Neighbourhood Plans can be included. We wonder whether consideration can be given to Plans that have reached Regulation 14 status?

2. Approach to boost housing supply

2.4.1 Support prioritising delivery of known sites

3. Planning Policy context

3.1 Strongly support the need for sustainable development. This should be limited to areas that are not at risk of flooding due to rising temperatures, up to 2065. With a rise of 1.5°, the Manhood Peninsula will be under water as far north as Hunston. (https://choices.climatecentral.org/#10/50.8675/-0.5836?compare=temperatures&carbon-end-yr=2100&scenario-a=warming-4&scenario-b=warming-1.5)

Strongly support the need to protect areas or assets of particular importance, such as Pagham Harbour, Medmerry and the Chichester AONB

Recognise the need to protect Pagham Harbour and Chichester Harbour from the adverse impact of nitrate pollution

Strongly support protecting Strategic Wildlife Corridors

Would suggest that no development should take place until there is an updated Strategic Flood Risk Assessment for Chichester District

3. Local Context

4.2 This is critical, and strongly supported that development should not take place that is dependent on the delivery of significant offsite infrastructure. For example, there are no plans for the road infrastructure and all Water and Treatment Centres are at capacity. This means that no development can take place that is fully within the applicant's control.

4.7 The impact of housing development on existing villages in relation to size is supported.

6. Interim Housing Policy Statement

6.2.1 Support being in “accessible locations”
6.2.2 Support the protection of long-distance views
6.2.11 Strongly support that development should not have an impact on flooding or be at risk of flooding.
6.2.12 Strongly support that Nitrate neutrality has to be an absolute requirement