Policy H2 Strategic Locations/ Allocations 2021 - 2039

The allocated housing for Bosham should be 0 not 245

The capacity at Bosham sewage works is zero, therefore the housing allocation must be zero not 245.
The Q90 Dry Weather Flow rate limit set by the Environment agency is 1221 m3 per day for Bosham wwtw.
The latest actual Q90 Dry Weather Flow rate for 2021 for Bosham was 1339 m3 per day which is above the limit.
Therefore no new housing can be allocated until Southern Water bring forward their plans for upgrading the Bosham sewage works. They have not done this as at Feb 2023. There is simply no capacity at the sewage works for new housing.

Fewer houses for Loxwood. They need to go nearer to Urbanisation such as Chichester, where there is retail, transport, roads, services.

I object to 220 homes in Loxwood on the following basis:
Your document states that Loxwood 'benefits from services and facilities, including healthcase'. This is absolutely untrue,

We have one bus per day to Guildford, which returns an hour later so is useless.
We have no general shop or Post Office any more
We have tiny sewers than cannot cope with the water we have now
We have water neutrality issues that prevent even the new shop from starting up
The school is full and turning away children - and has no room to expand
The Doctors Surgery is bursting and cannot take more patients, it is next to impossible to get an appointment now
We only have one through road
We have flooding issues

The number of houses need to be drastically reduced otherwise this will be to the detriment of all residents and the current eBay of life. There is no shop in place either to serve the community so how do you expect the expansion of the community to be successful?

220 houses in LOxwood when there is still no water neutrality really does not make sense. I would also like to ask if Chichester Council are trying to end life in rural villages. Please note that Loxwood is a village and not a town!

Policy A11 needs to be removed from the local plan.
Policy A12 needs to be removed from the plan.
Policy A13 should be limited to 300 houses.
The housing numbers allocated in the plan should be cut to 2,699 and should be allocated based on provision identified in neighbourhood plans.

Building 84% (8717 houses) of the allocated housing along the east-west corridor is not justifiable. There are no guaranteed upgrades to the sewage network or the strategic road network in this area. The areas proposed rely on wastewater treatment facilities which are already over capacity. The road network cannot cope and there are modelled peak time delays of 29 minutes to access the Fishbourne roundabout if this scale of development goes ahead. The Fishbourne roundabout has been over-capacity since 2014 and no measures have been taken to improve the situation. There is nothing guaranteed in the plan to address this.

Loxwood removed from Strategic Site status

On what basis has Loxwood been considered a strategic site? What evidence makes this a sound conclusion?

Allocate a minimum of 300 dwellings to Loxwood. Remove the reliance on the delivery of housing via
Neighbourhood Plans and parish allocations.

Please refer to attached supporting document. Policy H2 is discussed on page 12.

I think brown field sites should be found. Development should take place on the outskirts of larger settlements not in small villages that do not have the infrastructure and capacity to cope. North of Chichester council is being unfairly targeted. You have to take into account the problem of sewage disposal and the impact of water usage which will damage the RSPB nature reserves and the rivers. Therefore south of the A27 would be the obvious choice for development/re-development.

I object to 220 new houses to be built in Loxwood. It does not take into account the number of houses that have already been given planning permission. So it will be more than 220 and this Plan is not being honest. There will be too many houses that will be built on green fields. They will totally overwhelm the village which has a very limited bus service and no amenities. What about the Crouchlands development? No mention of the 600 houses and new primary school which is only a short distance from Loxwood.

The wishes of the residents of Loxwood and their local council should be given consideration . 220 new houses in Loxwood should be revoked on the grounds of unlawful urban sprawl.

I can only speak for Loxwood. We have a current approved village plan and have submitted another which due to water problems you have sat on. Loxwood is a rural village: residents treasure their rural environment. We have complied to building requests in the past and literally hundreds of hours of work, planning and local discussion has gone into the preparation of village plans, all, it appears, to no avail. We have no shop, the school is full and 50 years out of date; there is one ridiculous bus. we are not and never have been a 'Service' village.

In line with our comments on Policy H1 – Meeting Housing Needs, we propose a greater allocation of dwellings to the sustainable settlement of Loxwood, with a minimum of 300 dwellings, based on the findings of the Sustainability Appraisal (Jan 2023).
In addition to this, we do not support the strategic allocation of housing at a Parish/Neighbourhood Plan level, and strongly object to proposed provision of 220 dwellings via parish allocations. This is based on the proposed settlement boundary within the Revised Neighbourhood Plan for Loxwood, not adopting appropriate sites for housing.

Policy H2 – Strategic Locations/Allocations should be remove the reliance on the delivery of housing via Neighbourhood Plans and parish allocations, and amend to allowed proposed dwelling allocations to be allocated at a District level, in order to ensure the uptake of appropriate deliverable sites.

We acknowledge that the figure of 220 dwellings for Loxwood has been assessed through an approximate blend of scenarios within the Sustainability Appraisal, however the higher growth scenarios allow between 450-1050 dwellings.
While we support the proposed growth of Loxwood, we wish to highlight that this proposed figure of 220 will not sufficiently meet the objectively assessed need for housing within the District, and should be increased to allow greater housing provision in the North of the Plan Area. In line with our comments on Policy H1 – Meeting Housing Needs, we propose a greater allocation of dwellings to the sustainable settlement of Loxwood, with a minimum of 300 dwellings, based on the findings of the Sustainability Appraisal (Jan 2023).
In addition to this, we do not support the strategic allocation of housing at a Parish/Neighbourhood Plan level, and strongly object to proposed provision of 220 dwellings via parish allocations. This is based on the proposed settlement boundary within the Revised Neighbourhood Plan for Loxwood, not adopting appropriate sites for housing.
The Sustainability Appraisal discusses the 10 unit site, HLX0006, and outlines that the site is considered to be suitable, available and achievable within the HELAA. As such, the SA has included the site within the calculated sum of anticipated future dwellings across Loxwood (220). However, the site has been disregarded within the Neighbourhood Plan and sits outside of the proposed settlement boundary, despite being a highly suitable location for housing allocation.
This Policy can therefore, not be considered ‘effective’ within the Draft Local Plan as the housing provision of 220 can be increased to better satisfy the objectively assessed housing need in of the District. Further to this, the Parish Council’s failure to include and allocate appropriate sites at a Neighbourhood Plan level will mean that the housing target of 220 dwellings will not likely be deliverable across the plan period.
The Draft Local Plan is therefore considered to be ‘ineffective’ and ‘unjustified' by failing to provide sufficient housing provision or ensure the delivery of housing in an effective manner. Policy H2 – Strategic Locations/Allocations should be remove the reliance on the delivery of housing via Neighbourhood Plans and parish allocations, and amend to allowed proposed dwelling allocations to be allocated at a District level, in order to ensure the uptake of appropriate deliverable sites.

Thames Water are the statutory sewerage undertaker for a small part of the northern area of the District around Haslemere and are hence a “specific consultation body” in accordance with the Town & Country Planning (Local Planning) Regulations 2012

None of the strategic sites are located within the Thames Water region.
If any sites were to be located within the Thames Water region, a consideration to the potential impact on water and wastewater infrastructure should be included when promoting a development and provision for upgrades should be made, where required.
The time to deliver water/wastewater infrastructure should not be underestimated. It can take 18 months – 3 years for local upgrades and 3 – 5 years plus for more strategic solutions to be delivered. It is therefore vital that the Council and Developers work alongside Thames Water so that we can build up a detailed picture what is being built where, get confidence of when that development is going to start and what the phasing of that development will be.
To support this Thames Water offers a Free pre planning service where developer can engage Thames water to understand what if any upgrades will be needed to serve the development where and when.
Link here > https://www.thameswater.co.uk/developers/larger-scale-developments/planning-your-development/water-and-wastewater-capacity
We recommend developers attach the information we provide to their planning applications so that the Council and the wider public are assured water and waste matters for the development are being addressed.

Amend allocation policies to include conditions that a site may only come forward after specific infrastructure requirements have been met.

As an example, site A11, Highgrove farm, subject to a current application should only be released when Transport and Wastewater infrastructure is at least committed.

It would be better to build near to major roads. Our little B roads are not suitable and it would render the current village unsafe to add more new traffic, with cars, delivery vans and supply vehicles.

We are on a junction of two B-roads, not big enough for big housing development
The school is full, with a waiting list and no room to expand
Loxwood floods badly
The sewers are too small to cope with the village as it now is
Fresh water supplies are stretched to the maximum as it now is
Water neutrality is an ongoing issue in Loxwood
There is no gas
There is no shop
There is no public transport
We are car-dependent and building 220 new homes would bring huge air and traffic pollution

Brownfield sites are available in abundance.

Lack of infrastructure, ie schools and medical facilities. Children are already having to go out of the village to school which is totally unacceptable and not in line with travel policy, ie virtually no public transport which means excessive use of cars, and thus detrimental to the environment. Loxwood medical practice is not going to cope with the additional population as it is stretched to breaking already. Loxwood and Dunsfold development will make the problem even more disastrous.

Policy A15 should be removed and Policies H2 and H3 amended to reflect a realistic allocation of 125
houses which is still generous compared to other local area with better services.
Loxwood should not be deemed to be a strategic location-it is a small rural village

CDC have not consulted on revised housing numbers in North of the district-it quotes the restrictions of the A27 which prevents the southern development however the A281 is a bigger constraint which will also have Dunsfold adding pressure.
Allocation of 220 houses plus a further 91 houses on already allocated sites is not
sustainable in rural Loxwood-it a huge Percentage increase and will destroy the village
CDC Sustainability Appraisal is weak in its justification for allocation of 220 houses
There is no viable bus, lack of sewerage capacity, a village school, shops
to support large increase in housing

A greater level of housing needs to be included around Chichester City, given the additional capacity.

Policy H2 the local plan suggests a further 1,125 homes could be delivered through the allocation of three new sites around Chichester City.

Inclusive of the three proposed site allocations, the total proposed level of housing around Chichester City stands at 4,080 dwellings. Given the length of the plan period, and the strategic importance of Chichester City, as outlined above, Berkeley considers there is greater capacity for development surrounding Chichester City, which can contribute towards the current shortfall, such as land at Lawrence Farm.

Reduce the allocation for Chidham and Hambrook

Chidham & Hambrook has been misrepresented as a service village. The criteria used is flawed. There is no convenience store, medical services, recreation ground, sports facilities unlike Fishbourne and Bosham. 300 houses is not moderate growth. It increases the population by 30% there are minimal existing facilities to expand and there is no provision in this plan for increased public transport options. Its just left to the private sector to provide, a sector whose aim is to make a profit. There is no bus service north to south and the east/west bus service has been cut to 2 an hour.

Remove these proposed allocations and identify more suitable locations.

Allocations in the East/West corridor are outside the existing settlement boundary and in the countryside contrary to this policy.

Reduce the housing allocation number.

The housing numbers are too high. 2000 houses are planned from Fishbourne to Southbourne along one transport route. This is not sustainable and will result in coalescence, suburbanisation, traffic congestion, decrease in air quality, substantial impacts on landscape, the AONB and the environment.

Berkeley does not believe the Local Plan provides a suitable level of development around Chichester City and wishes to provide evidence that there is a greater number of suitable sites than is being proposed.

Evidence of this is provided in the relevant comments and the attached representation in full.

Please see the attached document which provides Berkeley Strategic's representation to the emerging Local Plan in full.

Given there is now an identified shortfall in housing provision arising from the draft local plan, the suitability of the site must be reconsidered having regard to the housing shortfall. In doing so, it is evident that the development of this site would not result in adverse impacts that would significantly or demonstrably outweigh the benefits. The site should there be allocated in the local plan to assist in more fully meeting the identified housing need of the district.

The site is located adjacent to the edge Chichester City, which as discussed above, is the most sustainable settlement in the district. The site therefore represents a suitable location for development, in accordance with the spatial strategy and is close to key services.

As clarified at the recent application and appeal, the development of the site would have no impact on the capacity of the A27 or wastewater treatment that cannot be mitigated. The site is not in an area constrained by water neutrality. The site is not constrained by any of the reasons given at paragraph 5.2.11 of the Sustainability Appraisal as to why housing needs cannot be met in full.

The only constraint referred to in the latest HELAA assessment of the site is noise as a result of proximity to Goodwood Airfield. During the appeal, the inspector did not dispute that an average 55dB noise level over a 16 hour period would not be exceeded in external amenity areas. This noise exposure standard is referred to in national guidance and as the benchmark noise threshold for external amenity areas in adopted local planning policies, such as Royal Borough of Windsor and Maidenhead. Satisfactory internal noise levels can be achieved through detailed building design. As a result, it is considered that this site is suitable for development, having regard to noise constraints.

Additionally, Policy A17 of the emerging Local Plan refers to development being unacceptable within a 400m buffer of Goodwood Aerodrome. The eastern edge of Raughmere Farm is not within this buffer.

The recent appeal decision relating to the site refers to a deterioration of the rural character of the site and a diminution of the gap separating Chichester and Lavant. Berkeley considers that through an amended scheme design, the rural character and gap can be preserved. The HELAA raised no landscape objections to the site.

The appeal inspector concluded that the proposed development of the site was not acceptable in landscape and noise terms and that the Council were able to demonstrate a 5 year land housing supply, meaning that the harm identified was not outweighed by the housing delivery and other benefits of the development at that time. However, it is evident now that the Council are unable to meet their housing need and so the benefit of development in this respect should be given more weight than the harm caused by any perceived landscape or other impacts.

As such, the perceived impacts of development at Raughmere Farm can be mitigated and are therefore not considered to outweigh the need for increased housing delivery in the District. The site is therefore suitable and available for development and should be allocated in the local plan to more fully meet the district housing need.

The housing allocation for Loxwood should be moved to locations better served by services, employment, public transport and available utilities.

I object to the significant allocation of housing to Loxwood as development is in an area remote from employment and services, not well served by public transport, not within cycling distance of services and employment and will increase pressure on already overloaded utilities, particularly sewage.

Plan for a range of new housing that meets the needs of local people, that does not overburden any one place, including taking into account changing requirements at different stages of life, affordable housing and specialist accommodation; helping young people and families to stay in the area; Plan to provide local infrastructure to support new development before approving such, and seek opportunities to address existing infrastructure problems, such as those relating to the A27 and wastewater treatment

Westhampnett Parish Council would like to point out that the current local plan was adopted in July 2015, and under Regulation 18 of the Town and Country Planning (Local Planning) Regulations 2012 various bodies and stakeholders were notified in June 2017 that the council was preparing a plan, and invited to comment about what that plan ought to contain: consultation on the preferred approach closed in February 2019.

Since that time, there has been a marked shift in local authority obligations on housing requirements; feedback received on the Regulation 18 consultation is outdated, and we would question whether the plan is procedurally sound; there is a need to return to the Regulation 18 stage.

On that basis, we have the right to make representation in person to the individual appointed as the planning inspector.

There needs to be reduction in the number of houses required in Loxwood back to the numbers stated in the neighbourhood plan which is currently held up in CDC.

The plan for Loxwood is unsustainable given the local lack of employment, public transport and waste water disposal. There will be a total reliance on car journeys for work, leisure and living needs. For these reasons the increase of 220 houses is fundamentally flawed and unsustainable. This local plan demonstrates a lack of understanding of the environment in the far north of the district and needs revisiting for Loxwood and surrounding villages.

Increase Hambrook and Nutbourne to 500 as previously suggested in the consultation documents which were sent to the Parishes.

Reduce Loxwood allocation.

Increase provision as per objection to H1 but reduce in Loxwood as per previous comments

It needs to be revisited and this madness stop!

A15 - Loxwood. The number of proposed additional houses for Loxwood is incredible! The village has already taken it's overloaded unfair share already and to want to add and develop a further 220 is abhorrent. There are NO facilities to support this influx of houses/people and is detrimental to the current residents.

Portsmouth Water support this policy.

Replace the single large site allocation for Loxwood with a dispersed approach comprising small / medium sized sites with a focus on self build housing provision.

The policy approach for Loxwood is for inappropriate homogeneous large scale housing estate development.

This does little to broaden housing choice in the local area because similar developments are evident at larger nearby centres such as at Billingshurst in Horsham District.

Communities in Loxwood and the north of the district are ready to embrace more dispersed smaller site opportunities and growth of a proportionate scale that serves to organically evolve and grow the settlements maximising support for local businesses, facilities and self reliant strong sustainable communities.

Local insights and available information on local growth and self build housing are not reflected.

The policy approach lets the northern part of the district down because it does not reflect an understanding and appreciation of the particular potential of the local area and its distinct social, environmental, economic and settlement characteristics including demographics.

The housing allocation for the east-west corridor should be reduced, with particular reference to:
A11 Land at Highgrove Farm, Bosham
A13 Southbourne Broad Location for Development
A12 Nutbourne and Hambrook (Chidham and Hambrook Parish)

The Chichester Harbour Trust objects to the proposed housing allocations, in particular with reference to the allocations below which principally affect Chichester Harbour AONB:
A11 Land at Highgrove Farm, Bosham
A13 Southbourne Broad Location for Development
A12 Nutbourne and Hambrook (Chidham and Hambrook Parish)

The combined allocation for these sites is 1,595, and should be considered in combination with the 1,600 houses allocated in A6 West of Chichester, and 30 at Fishbourne Parish leading to a total of 3,225. Taking into consideration the 2,100 houses planned at Havant Borough Council's strategic site at Southleigh, this gives a total figure of 5,325 houses between Chichester and Havant in the gap between the AONB and National Park. This represents major development within the 5.6km zone of influence for Chichester Harbour SSSI.

It is our observation that these proposed allocations represent a conflict with the policies outlined in the Plan chapter 4 on the natural environment, which makes it hard to justify the soundness of the Plan, particularly:
Policy NE2 Natural Landscape
Policy NE3 Landscape Gaps between settlements
Policy NE6 Chichester’s Internationally and Nationally Designated Habitats
Policy NE7 Development and Disturbance of Birds in Chichester and Langstone Harbours, Pagham Harbour, Solent and Dorset Coast Special Protection Areas and Medmerry Compensatory Habitat
Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty
Policy NE16 Water Management and Water Quality

Our specific objections to the allocations at A11,12 and 13 relate to:
- the impact on the sensitive landscape setting of the AONB and loss of open views to the South Downs
- the over-reliance on developing greenfield sites, mostly on grade 1 & 2 agricultural land leading to concerns about unsustainable loss of countryside and impact on food production and food security
- the inadequate waste water treatment infrastructure and lack of funded improvements in the timescales required
- the additional flood risk and ground water issues raised by construction on low lying coastal plain sites
- the impact on biodiversity and species that rely on the interconnectivity between the protected landscapes
- the additional recreational pressure of over 5,000 homes (potentially over 10,000 people) within the SSSI zone of influence
- the inevitable increase in air, noise, and soil pollution

It is noted that in the case of A12 and A13, the location of the development is not yet clear as the sites will be determined through the neighbourhood planning process, however it is hard to see how the concerns raised above would not be relevant.

Overall, we feel that the Plan does not reflect emerging government rhetoric (soon to translate to policy through the NPPF) about overdevelopment of countryside in the South East of England, and that the timescale is not compatible with the NPPF review which may lead to an alternative method of determining housing allocations in the district. For this reason we find the plan to be unsound.

Housing to be built in urban areas and not on green belt/green fields

Far too many homes in unsuitable locations such as Loxwood. There is not enough infrastructure to support the volume of housing proposed. No allowance appears to have been made for the already disproportionate development already dumped on the area already.

Plan is totally unsuitable for Loxwood and should not expand the existing planned sites in the LDP.

Plan does not comply with current and future government strategies, bear no relation to infrastructure of Loxwood ignoring lack of transport via public services, one bus per day, four days per week, limited employment, resulting in increase in car transport to work either to Guildford, Billingshurst, Horsham. 1 village school, GP practice at capacity no room for expansion. Lack of sewage capacity already resulting in private sewage for 2 new housing estates. Environment totally ignored, wildlife corridors destroyed, no protection of current wildlife habitats and degradation of existing bridleways and footpaths