Policy H2 Strategic Locations/ Allocations 2021 - 2039

Remove Loxwood allocation.

Loxwood is not a service village. The Post Office has closed, the village shop has closed, there is one bus a day on four days a week. The nearest railway is 6 miles away with no bus connection. The local roads are incapable of taking the increased traffic being considered and the sewage system is inadequate for the recently increased volume of houses built so is the water system with no possibility of improvement for years. You would be destroying our village/rural life and beautiful surroundings,

The number of houses needs to be reduced.

Looking at Loxwood. There is insufficient infrastructure for drainage, sewage, transport, retail, roads, schools, doctors etc.
Southern Water is already spilling sewage into the river Lox.
This area simply cannot support more housing.

Loxwood Plans need to return to and adopt those proposed by the Parish Council. CDC should be working with the Parish Council to develop Loxwood in context to its current setting as an attraction and of benefit to the future not only for residents but in national and world terms for nature and wildlife. Currently has a wide range of wildlife covering the proposed area including bird life such as kites, buzzards, gold crest to protected species such as bats, badgers, dormice, amphibians to name but a few. CDC should be working with recognised groups such as CPRE, Woodland Trust, Wildlife Trusts, the Wey and Arun Canal to ensure the historical, physical and mental benefits can be appreciated and valued by residents and visitors alike for the future, not destroyed. the footpaths and bridleways are well used by individuals, walking groups, dog walkers, cyclists on a strong daily basis. The proposed housing would destroy this completely.

Plan totally ignores CDC's own comments re Loxwood with reference to impact on area if housing is increased including infrastructure, environment and site. Fails to address very limited - transport links, no shops/PO, employment opportunities requiring increased travel by car putting extra pressure upon one B road; 1 primary school with no room for expansion, as with a full Medical Practice. Serious current problems include no capacity for disposal of sewage and waste water for new housing. Totally ignores government legislation re preservation and development of environment for nature, wildlife and benefit to community and visitors.

Cancel the plan completely

My wife and I strongly object to the building of 220 more houses in Loxwood due to the incapacity of the drainage system in the village
which would be totally inadequate to cope with any more building houses. We have had numerous drainage problems since the existing new houses have been built in Loxwood.
We are currently dealing with a serious raw sewage situation which flowed and covered our garden, causing yet more distress.
Please check if you need to with Southern Water who constantly tell us that the sewers and drainage are not fit for any more housing.

An Allocation should be made within Policy H2 for 150 – 160 dwellings at Land West of Church Road (Northern Parcel). By not including an allocation at the settlement of East Wittering, and specifically Land West of Church Road (Northern Parcel), the Draft Local Plan is not ‘justified’ and ‘effective’

Following on from objections to Policies S1 and H1, a further objection is raised to the absence of strategic allocations at the Settlement Hub of East Wittering, which had been supported under the Preferred Approach of the Local Plan by Policy AL8 (350 dwellings to be delivered by the Neighbourhood Plan). However, a strategic allocation should be made at the Settlement Hub of East Wittering. It should not be deferred to the neighbourhood planning process as proposed in the Preferred Approach of the Local Plan as this would not be ‘positively prepared’.

As set out under objections to Policy S1, the Sustainability Appraisal has incorrectly not tested growth scenarios which includes development at the Settlement Hub of East Wittering. It is noted within the SA that the 2022 SFRA shows extensive tidal flood risk under climate change scenarios, affecting all the sites reasonably in contention for allocation. This includes Site HWW0002a, Land to the West of Church Road.

However, Chichester District Council published another SFRA back in 2018, identifying Land to the West of Church Road, in the ‘climate change risk zone in 2115’ catchment. The 2018 SFRA was utilised to assess sites in the 2020 HELAA. Land to the West of Church Road was originally discounted in the 2020 HELAA, due to being in the subject catchment. This was challenged and it was argued this is an extreme tidal event and should not be confused with identified flood zones. The EA subsequently advised that the model had been superseded and that the site is not considered to be at risk of coastal flooding. The reason for the difference was found to be which of the various flood risk scenarios were used in the 2018 SFRA. Chichester District Council then produced a revision to the 2018 SFRA in April 2021.

Upon review of the 2022 SFRA, the Council claims the assessments have an updated harbour costal model. Appendix E of the 2022 SFRA outlines how climate change may influence the tidal and coastal flood risk. However, from reading the 2022 SFRA, our interpretation is that the update is based on the original 2018 SFRA, instead of the revised 2018 SFRA and therefore, it appears that the modelling is believed to be inaccurate once again.

Land West of Church Lane is therefore considered available for development within the HELAA. The Sustainability Appraisal also considers the site under reference HWW0002a and has a ‘green’ response on the RAG scale indicated and supporting the findings that the site is suitable for development on these grounds.

It is therefore considered that the exclusion of the settlement of East Wittering from consideration for development is fundamentally flawed and based on incorrect data.

Specifically, Land to the West of Church Road (Northern Parcel) is identified within the SHLAA as developable (See Appendix A) and should be subject to a strategic allocation for 150 - 160 dwellings. Development on the site (Phase 1) is already part committed through the 2022 permission for 70 dwellings (Appeal Ref: APP/L3815/W/21/3286315), demonstrating the unconstrained nature of the overall site.

Representations were submitted via Chichester’s Call for Sites exercise in 2020, and the Site was positively assessed in the HELAA 2021and considered developable. Therefore, in total the Site could accommodate 220 to 230 dwellings, which accords with the HELAA assessment of 226 dwellings.

Notwithstanding this positive HELAA assessment in 2021, the assessment within the SA differs and refers to a relatively poor performance with specific reference to a low level of landscape performance within the 2019 Landscape Capacity Study. The 2019 Study predates the HELAA (and is arguably more out of date in comparison) and covers a more significantly larger area than site HWW0002a. The conclusions of the 2019 Landscape Capacity Study also recognise that there could be very limited development adjacent to the settlement edge if carefully integrated into the landscape and with care given to heritage assets. Given the findings of the Appeal Inspector (see below) it is considered that more significant development can be accommodated through the introduction of an appropriate landscaped setting and the conclusions of the SA are over played in this regard.

Notwithstanding the findings of the 2019 Landscape Capacity Study, during the consideration of the Appeal for the Southern Parcel in 2022, development was found to have a limited impact upon the wider landscape and whilst it would have a significant but localised effect on the character of the countryside, it was concluded this would lessen over time. It is considered that the development of the Northern Parcel could also be integrated into the landscape in a similar manner without significant, wider landscape harm.

Please also see Site Specific Representation Attached

Reduce the allocated numbers of proposed dwellings in this rural, isolated area to prevent permanent disfigurement of the area.

The proposed allocation of dwellings for the Loxwood Ward are disproportionate in scale to the other larger areas mentioned. ie: 220 dwellings for Loxwood and 270 for Chichester City ??
The infrastructure here in the Loxwood ward is barely able to cope with the existing houses requirements in relation to public transport, schools places, doctors surgeries etc... Further development in the area is unsustainable and therefore should be reconsidered. There are other applications too for large scale housing developments at Crouchlands Farm with 600 dwellings.

Currently the Plan proposes 10,354 total new homes over the Plan period (575.2 homes p.a). However, using the Standard methodology, the actual housing needed in the District is 11,484 homes. The 11,484 figure is calculated using data from the ICENI Chichester Housing and Economic Development Needs Assessment (HEDNA) Report from April, 2022. Indeed, using this data, CDC is currently 1,131 homes short of it’s need over the 18-year period.

Nutbourne/ Hambrook and Loxwood are both defined as ‘Services Villages’ under Policy S2 (Settlement Hierarchy). The Boxgrove settlement is within same settlement category (Service Village) as Nutbourne/ Loxwood and Hambrook. The 2021 CDC HELAA assessed the 9 submitted sites as available, suitable and deliverable for Boxgrove Parish (with 6 suitable sites adjacent to the Boxgrove settlement boundary) and 3 further sites at settlements within Boxgrove Parish, totalling 610 potential plots, as outlined earlier in this document. This should be reflected in a revised policy.

In regards to Plan Policy H2 relating to Strategic Locations/ Allocations 2021 – 2039, we object to the exclusion of Boxgrove Parish from Policy H2. Boxgrove Parish should be listed as a Parish with the potential to accommodate strategic locations for residential development, where Neighbourhood Plans are anticipated to be prepared to identify the site(s) required, alongside the 3 strategic locations currently listed in draft Policy H2 (namely Chichester City, Nutbourne and Hambrook and Loxwood).

Miller and Vistry support the inclusion of West of Chichester (A6) as a Strategic Allocation under policy H2.

We note that a significant proportion of the housing numbers proposed through the Local Plan will be delivered by Neighbourhood Plans. We have highlighted key criteria for individual locations that we would wish to see considered by those Plans when allocating sites. Where possible we would wish to see these included within the Local Plan policy but as you will be aware we have produced a checklist for Neighbourhood Plan groups in your district which will guide the identification of sites and other key issues and opportunities to be addressed in the future.

If we accept the proposed 295-300 homes I proposed that this is split more in line with the Village Plan and consultation and which is more sustainable, viable and robust in terms of actual delivery. I suggest that an additional 220 houses are allocated to HighGrove Farm (270 in total) and 25-30 to HBO0003 which adjoins Bosham Station. HBO0003 is considered 'developable' in the HELAA although the map incorrectly colours it red.

I object to the increased allocation at Highgrove Farm and the evidence submitted that has arrived at this allocation. I represent The French Gardens (TFG) site which has been incorrectly coloured red on the HELAA and incorrectly assessed on the Sustainability Assessment. These errors have been blindly carried forward reulting in a gross lack of soundness. Briefly 1.TFG is lower grade soil. 2. TFG was preferred by locals in the Village consultation. 3. TFG no impact on East-West coalescence, SDNP and AONB. 4. TFG would result in reinvestment into dilapdated rural business. 5. TFG mitigation available onsite etc.

The Plan should meet at least its full identified need of 638dpa, plus an additional buffer to accommodate unmet needs from SDNP(40 dpa), plus a 5% flexibility buffer. The resulting housing figure being 712 dpa. Based on the currently identified supply of 10,359 dwellings, a further circa. 2,500 homes (rounded) would need to be identified. In view of the shortfall the housing figure apportioned to Chidham and Hambrook parish, should be increased to at least 500 dwellings over the plan period.

Remove Policy A11. Amend Policies A12 and A13.

Chichester Harbour Conservancy hereby Objects to Policies A11, A12 and A13, for the reasons that will be set-out later in the consultation response.

The ‘tests of soundness’ for Local Plan preparation are set out in paragraph 35 of the July 2021 NPPF. They require the 2021-39 Local Plan to have been:

• Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.
Local Plan reviews are a legal requirement every 5 years in accordance with Regulation 10A of the 2012 Town and Country Planning (Local Planning) (England) Regulations. The Regulation 19 Plan is not legally compliant as it has not been reviewed within 5 years of the last Plan adopted in July 2015. It is also disappointing that the failure of the current Regulation 19 Local Plan to meet objectively assessed need (OAN) of 638 dpa outside the national park has not been properly evidenced in any up to date statement of common ground with neighbouring authorities with regards to the ‘duty to cooperate’.

At this stage we believe the Plan as drafted therefore fails the ‘positively prepared’, ‘effective’, and ‘consistent with national policy’ tests.

In addition, with regard to the longer term growth requirements and the singular issue of a potential new settlement the plan also fails the ‘justified’ and ‘consistent with national policy’ tests of soundness.

Duty to Cooperate
The 2014-2029 Local Plan adopted in 2015 does not meet the full objectively assessed housing needs for the area. But it did recognise that future proposals to improve the capacity of the A27 and wastewater treatment works could facilitate additional housing growth. For this reason, it committed the Council to a review of the Plan within five years to ensure that housing needs could be met. That undertaking to review within 5 years was not met.

In 2021 the Council invited an advisory visit from PINS to advise on how the present Local Plan should be prepared. The inspector advised that if the Plan was prepared which did not meet the full housing needs of the area, it would have to show that it had followed the duty to co-operate with neighbouring authorities in maximising the effectiveness of plan preparation.

The inspector said the Duty to Cooperate was therefore critical in the preparation of the Local Plan Review. At the time of the meeting, the council said discussions with neighbouring authorities had been carried out on the basis that the Local Plan Review would meet the full objectively assessed housing needs (OAN) for the area. However if this was not the case, the inspector said evidence of constructive, active, and on-going engagement to determine whether or not development needs could be met elsewhere would need to be shown. Importantly, the inspector said,1) ‘a failure to meet the Duty to Cooperate cannot be remedied during the examination process because it applies to the preparation of the Plan, which ends upon submission’, and 2) local planning authorities should make every effort to secure the necessary cooperation on strategic cross boundary matters before submitting plans for examination.

The Duty to Cooperate Statement of Compliance (January 2023) forms part of the evidence base for the Submission Local Plan. In the event, the Local Plan excluding the national park only provides for 575 dpa against an OAN of 638 dpa. However this under provision against need has not been justified anywhere in discussions with neighbouring authorities before the Plan was submitted. Appendix 1 of the Statement of Compliance lists those authorities that were consulted during the earlier Regulation 18 Preferred Approach consultation. Appendix 2 lists those authorities where Statements of Common Ground have been agreed with Chichester DC for the Regulation Submission 19 Plan. No statements have produced or agreed. Therefore as it stands the under provision of housing against OAN in the Plan has not been justified. The failure to meet the duty to cooperate cannot be remedied because it has already ended with the Submission Plan. The plan therefore fails the positively prepared and justified tests. It also fails to comply with national policy in the NPPF paragraph 24-27 which advises on the duty to cooperate approach.

Local Plan Policies
The remainder of these comments deal with the Settlement Hierarchy policy S2, H1, H2 H3 and H8.

Policy S2 – Settlement Hierarchy
The Settlement Hierarchy background paper prepared for the Regulation 18 draft Local Plan provides the justification for the hierarchy in Policy S2 of the Regulation 19 Local Plan. We agree that the hierarchy prioritising development at Chichester as the sub regional centre, followed by development at the settlement hubs, service villages and the rest of the plan area is reasonable. However, although the distribution of housing amongst the settlements in the current Regulation 19 plan has been updated compared to the last Regulation 18 plan, the background paper itself has not been updated. Nor is there any justification or explanation for the change in the quantum of strategic and non-strategic housing to the different categories of settlement in the background paper or the Local Plan itself.

Policy H1 – Meeting Housing Needs
The identified housing need has been informed by the 2022 Housing and Economic Development Needs Assessment (HEDNA). It explains that based on the standard methodology, since the last HEDNA in 2020, the district wide housing need has increased from 746 dpa to 763 dpa (621 dpa in the Plan Area to 638 dpa) with the balance to be found in the national park. The proposed 638 dpa for the area of the district outside the national park is the figure that will be tested at the forthcoming Examination.
We have already explained why the failure of the Council to plan for the 638 dpa in the Regulation 19 Local Plan has not been justified in connection with the duty to cooperate and no evidence has been presented in any statement of common ground with neighbouring authorities to show how development needs could be met elsewhere.
Policy H2 – Strategic Site Allocations and Policy H3 – Non-Strategic Parish Allocations
Policy H2 identifies strategic scale and policy H3, non-strategic allocations. We have explained above that the Settlement Hierarchy Background Paper was prepared for the 2018 Preferred Options Regulation 18 Local Plan but has not been updated to provide any justification for the revised housing distribution and quantum of development for the named locations and settlements in the Regulation 19 Local Plan.
Policy H8 – Specialist accommodation for Older People
National policy in the online planning practice guidance (PPG) is clear that the need to provide housing for older people is critical. The guidance on the provision of this type of housing states:
• Plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people. These policies can set out how the plan-making authority will consider proposals for the different types of housing that these groups are likely to require.
• They could provide indicative figures or a range for the number of units of specialist housing for older people needed across the plan area throughout the plan period.
• It includes the following within the general definition of specialist housing - age-restricted general market housing, retirement living or sheltered housing, extra care housing or housing-with-care, residential care homes and nursing homes, and senior co-housing communities.
• LPA’s can identify sites for co -housing communities and other specialist housing types for older people, because,
• Allocating sites can provide greater certainty for developers and encourage the provision of sites in suitable locations. This may be appropriate where there is an identified unmet need for specialist housing. The location of housing is a key consideration for older people who may be considering whether to move (including moving to more suitable forms of accommodation).

Factors to consider include the proximity of sites to good public transport, local amenities, health services and town centres.
In our view however, draft Policy H8 doesn’t reflect the guidance in the PPG. For instance, although the policy sets out a threshold of provision for specialist housing of housing sites of 200 or more units, there is no guidance on the actual % provision as there is for example, on affordable housing. All it says is the specific type and amount of accommodation required will depend on the size and location of the site.
The supply of specialist housing should not just be focused on large scale housing schemes. The landscape and environmental constraints across the district even outside the national park would not necessarily allow for large 200 plus unit schemes in all locations. To support an ageing population policy should support the provision of suitable specialist housing to meet the differing needs of individuals across a range of options and in a range of locations.
The second part of H8 should therefore confirm that proposals for specialist housing, such as homes for older people will be supported without any policy qualification for a site’s location within or outside a settlement boundary or within an AONB where a proposal in its local context is not deemed to represent major development.
Rather than rely on the criteria based approach, the policy should also allow for the allocation of sites for specialist accommodation for older people in a Neighbourhood Plan where a site has the support of local people.

The ‘tests of soundness’ for Local Plan preparation are set out in paragraph 35 of the July 2021 NPPF. They require the 2021-39 Local Plan to have been:

• Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.
Local Plan reviews are a legal requirement every 5 years in accordance with Regulation 10A of the 2012 Town and Country Planning (Local Planning) (England) Regulations. A question could be raised over the legality of the Regulation 19 Plan as it has not been reviewed within 5 years of the last Plan, which was adopted in July 2015. On the Council’s own admission the current Regulation 19 Local Plan fails to meet objectively assessed need (OAN) of 638 dpa outside the national park. However, without any properly evidenced ‘duty to cooperate’ statement of common ground with neighbouring authorities, it is unclear whether this under provision is justified.

We support the local authority in its attempts to navigate what is a challenging situation in relation to housing delivery within the district, however at this stage we believe the Plan, as drafted, fails to meet the ‘positively prepared’, ‘effective’, and ‘consistent with national policy’ tests and therefore could be interpreted as unsound.

In a bid to assist the process, we have collated our thoughts on how the Regulation 19 Local Plan could be improved below.

Local Plan Policies
These comments deal with the proposed Spatial Strategy (Policy S1) Settlement Hierarchy (S2), policies H1, H2 H3 and NE4. We also propose a new policy H4.

Policy S1- Spatial Strategy
Policy S1 deals with the spatial strategy of the plan. It has been informed by the role of each settlement within a hierarchy based on its facilities and services.

We agree that the spatial strategy for delivering growth and development should focus on Chichester
city as the main sub-regional centre and most sustainable location with a wide range of services and facilities. However, there are self-evident constraints to further strategic scale development at the settlement itself because of its historic setting, the A27 to the south and east, the harbour AONB to the west and the national park in the north. Focusing growth close to the city would however still reinforce its role as a sub-regional centre and locating a significant proportion of development in or around
Chichester city ahead of the second tier settlement hubs would reduce the need to travel to facilities and deliver sustainable development.

Policy S2 – Settlement Hierarchy
The Settlement Hierarchy background paper prepared for the Regulation 18 draft Local Plan provides the justification for the hierarchy in Policy S2 of the Regulation 19 Local Plan. We agree that the hierarchy prioritising development at Chichester as the sub regional centre, followed by development at the settlement hubs, service villages and the rest of the plan area is reasonable. However, although the distribution of housing amongst the settlements in the current Regulation 19 plan has been updated compared to the last Regulation 18 plan, the background paper itself has not been updated. Nor is there any justification or explanation for the change in the quantum of strategic and non-strategic housing to the different categories of settlement in the background paper or the Local Plan itself.

Policy H1 – Meeting Housing Needs
The identified housing need has been informed by the 2022 Housing and Economic Development Needs Assessment (HEDNA). It explains that based on the standard methodology, since the last HEDNA in 2020, the district wide housing need has increased from 746 dpa to 763 dpa (621 dpa in the Plan Area to 638 dpa) with the balance to be found in the national park. The proposed 638 dpa for the area of the district outside the national park is the figure that will be tested at the forthcoming Examination.
As indicated earlier, without any properly evidenced ‘duty to cooperate’ statement of common ground with neighbouring authorities, it is unclear whether this under provision is justified.

Policy H2 – Strategic Site Allocations and Policy H3 – Non-Strategic Parish Allocations
Policy H2 identifies strategic scale and policy H3, non-strategic allocations. We have explained above that the Settlement Hierarchy Background Paper was prepared for the 2018 Preferred Options Regulation 18 Local Plan but has not been updated to provide any justification for the revised housing distribution and quantum of development for the named locations and settlements in the Regulation 19 Local Plan.
Longer Term Growth Requirements
Paragraph 22 of the NPPF says strategic policies should look ahead over a minimum 15-year period from the date of the adoption of a plan to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. This justifies the proposed end date of the Plan of 2039. However, the NPPF goes on to state that where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.
Paragraphs 5.11-5.14 of the draft Plan says although its focus is on the development needs of the plan area up to 2039, some initial consideration has been given to the concept of a new settlement to accommodate potential longer term growth needs. This arises from some reservations about whether it will be appropriate in the longer term to continue to rely on existing sources of supply (e.g. urban extensions and urban intensification).
We agree that a new settlement would have a valuable role to play in meeting future housing need of the district and support the lower-case policy text of the Plan at paragraphs 5.11-14. However, bearing in mind the national policy guidance for a 30 year or so vision to allow for the planning and site identification for a new settlement, we see no reason why that part of the lower-case text at paragraph 5.14 of the Regulation 19 Plan should not be elevated into actual Plan policy. Such an approach would deliver benefits to the plan anyway in offering a ‘land supply reserve’ in the event the Examiner for the Local Plan finds that it should meet OAN in accordance with the ‘positively prepared’ test. If a new settlement is needed to contribute to OAN, it would then form part of the development strategy of the Plan and justify the policy in principle.
We therefore propose a new Policy H4 – A New Settlement as set out in section 6 below.
Policy NE4 – Strategic Wildlife Corridors
The Council produced a Strategic Wildlife Corridor background paper in December 2018 and another technical consultation document in July 2021. Neither document has been updated for the present Regulation 19 Local Plan. It is unclear therefore whether the ecological interest has changed and whether it can still inform the extent and location of the defined wildlife corridors in the current Plan. We say this on the basis that standard habitat surveys are usually required to be reviewed and updated after 18 months.

Paragraph 179(a) of the NPPF sets out policy to protect and enhance biodiversity and geodiversity and states that Plans should identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national, and locally designated sites of importance for biodiversity; wildlife corridors and stepping stones that connect them.
We therefore agree that the identification of wildlife corridors in the emerging Plan is consistent with national policy but without any up to date proportionate evidence of biodiversity interest we would question whether their extent and location as shown on the relevant proposals maps have been justified.
As it stands, the wording of Policy NE4 also goes beyond the purpose of the policy which is the ‘safeguarding of wildlife rich habitats and wider ecological networks’.
Policy NE4 states development will only be permitted where it would not lead to an adverse effect upon the ecological value, function, integrity, and connectivity of the strategic wildlife corridors. It does not resist development in principle and so long as impacts can be adequately mitigated it should be granted.
This policy principle therefore makes redundant policy test 1 which introduces a sequential test for preferable sites outside a corridor. The test is in conflict with the underlying purpose of the policy which is to safeguard wildlife corridors from adverse harmful impacts that cannot be mitigated. Test 1 should therefore be deleted.
Development outside or in close proximity to a wildlife corridor should not be subject to the policy requirements of NE4 either and the designation should end at its boundary. ‘Close proximity’ is vague and would introduce uncertainty to the policy. If development does not undermine the connectivity and ecological value of the corridor, then there is no proper basis for the policy restriction on such development. We therefore propose the deletion of the second part of the policy as well.

The role and impact of existing commitments in the housing land supply on the proposed strategic and non-strategic allocations in H2 requires further clarification in lower case policy text.

See attached representation.

I write in response to the regulation 19 consultation version of the Chichester Local Plan 2021-2039 in our capacity as promoters of Ansells Yard, Kirdford Road, Wisborough Green.

Conclusions
There are several concerns on the soundness of the plan in terms of whether it is effective, justified, positively prepared or consistent with national policy in accordance with paragraph 35 of the NPPF.
It is not considered that the Council has justified the extent of the under supply of housing against the established housing need. There are significant concerns over the delivery of housing from the strategic allocations within the unjustified timescales as set out within the trajectory contained in the plan.

Levanter will continue to make further representations on the deliverability of the site as part of the plan making progress.

See attached representation.

It is suggested that Policy H2 includes the wording “at least” before the quantum of development for any strategic location or allocation. For example, Policy A13 would instead state “at least”.

1 Introduction
1.1 These Representations have been prepared on behalf of Hallam Land Management Limited (hereafter ‘Hallam’), in response to the Chichester Local Plan Review Proposed Submission Plan consultation.

1.2 Hallam is a strategic land promotion company operating throughout England, Wales and Scotland delivering land for new employment and commercial premises, housing, including specialist elderly housing, and mixed-use developments. Hallam has been acquiring, promoting, developing and trading in land since 1990. During that time, the company has established an outstanding record in resolving complex planning and associated technical problems in order to secure planning permissions for a whole range of different land uses to facilitate the delivery of new development.

1.3 Hallam control land to the west of Southbourne, to the north of the A259 and south of the railway line. Development of this land for new housing including specialist elderly accommodation, as shown in the accompanying Vision Document, would be consistent with the established Spatial Strategy; which is rightly retained in the consultation document. Similarly, development would contribute towards meeting the future housing needs of the District within the proposed Broad Location for Development (BLD) at Southbourne.

1.4 These Representations set out our support for the BLD drawn on the key diagram to the west and east of Southbourne. However, Hallam are seeking amendments to Policies S1, H1, H2, H8 and A13 to ensure that: the overall housing needs are met across the District, including early delivery and specialist accommodation; the flexibility sought early in the Submission Plan, at Policy S2 and H1, is carried through to the strategic allocations and locations; and, the BLD is distributed to the west and east of Southbourne.

1.5 Moreover, Hallam are proposing the allocation of small and medium scale sites at Southbourne within the Local Plan, to enable early delivery of housing and infrastructure, with the land under their control a suitable site for this allocation. Should the Council not allocate these sites, then the strategic allocations/locations policies need to be updated to reflect the requirement for the delivery of small and medium scale parcels which could form part of the larger sites.

1.6 In the context of the above, it is instructive to note that Chichester District has an older population than national average, which has been predicted to increase by 42% between 2021- 2039. The increasing need for specialist accommodation should be addressed through specific allocations within the Local Plan, rather than the proposed approach of Policy H8.

1.7 Our response is focused on the following matters:

• The Spatial Strategy, settlement hierarchy and the distribution of development across the District;
• The overall amount of new housing required within the new plan period;
• The need for specialist accommodation;
• The status of Southbourne and the role and function it plays; and
• The strategic allocation proposed at Southbourne in Policy AL13.

1.8 In preparing the Local Plan Review, the Council will need to ensure that it complies with paragraph 35 of the National Planning Policy Framework (NPPF) (2021) which sets out four tests to ensure the plan is ‘sound’. These are as follows:

• Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet needs from neighbouring areas are accommodated where it is practical to do so and is consistent with achieving sustainable development;
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross- boundary strategic matters that have been dealt with rather than deferred, as evidenced by statements of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.

1.9 We are mindful that the Government has recently published a consultation concerning potential amendments to the NPPF. Paragraph 1 of that consultation document indicates that the government is committed to “building more homes” whilst Paragraph 6 explains that the government “remains committed to delivering 300,000 homes a year by the mid-2020s”.

1.10 In the proposed revisions, paragraph 1 makes clear that the NPPF provides “a framework within which locally-prepared plans can provide for sufficient housing and other development in a sustainable manner.” At paragraph 60 the overall aim of a Local Plan is identified as meet[ing] as much housing need as possible with an appropriate mix of housing types to meet the needs of communities.

1.11 It is clear therefore that the potential amendments to the NPPF firmly intend that Local Plans, including this one, continue to provide a sufficient supply of housing land to meet identified needs.

2 Objectives and Spatial Strategy

Objectives of the Local Plan
2.1 The Submission Plan has identified key challenges and opportunities that influence future planning, across the three areas of the District, and how it aims to address these through planning policies and proposals.

2.2 Within the consultation document, the strategic objectives presented by the Council are structured into specific categories, ensuring housing and neighbourhood objectives are clearly set out for the plan period.

2.3 Amongst these is the objective to increase housing supply; increase provision of affordable housing; and promote the development of mixed, balanced and well-integrated communities. These are consistent with the NPPF’s policy objective to significantly boost the supply of housing in paragraph 60. In this context, it is right that the Local Plan’s development strategy is founded on this objective, ensuring sustainable development which responds to social, economic and environmental considerations that meets the needs of the plan area.

2.4 These objectives frame the policies and proposals for future development across the plan area to create sustainable neighbourhoods; this demonstrates, as a matter of principle, that the Local Plan intends to be positively prepared and justified, albeit there are limitations on how this is achieved in practice when the policies and proposals are considered.

2.5 The NPPF states at paragraph 22 that strategic policies should look ahead over a minimum 15 year period from the date of the Plan’s adoption. The Local Plan aims to cover the period of 2021- 2039, which is 18 years. However, this plan has not been adopted yet and it is considered unlikely that this Local Plan will be adopted before 2024-25. Therefore, the Plan may not cover the required plan period of 15 years and the Council should extend the plan period to at least 2040 to ensure this requirement is met.
Policy S1: Spatial Strategy
2.6 The Spatial Strategy is accompanied by the Key Diagram (Map 3.1), identifying the distribution of development and infrastructure provision across the plan area.

2.7 The strategy aims to build on the existing Local Plan, focusing growth at Chichester city, as the main sub-regional centre, and at two settlement hubs along the east-west corridor at Tangmere and Southbourne.

2.8 Policy S1 specifically identifies the broad approach to providing sustainable development, in accordance with the Local Plan Objectives, ensuring development is focused principally along the east-west corridor. It aims to distribute development in line with the settlement hierarchy, ensuring development is located in the larger and more sustainable settlements.

2.9 This accords with paragraph 20 of the NPPF which requires strategic policies to set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for housing, infrastructure, community facilities along with policies that seek to conserve and enhance the environment.

2.10 Paragraph 105 of the NPPF states that the planning system should actively manage patterns of growth in support of these objectives. With significant development being focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.

2.11 Paragraph 69 of the NPPF sets out how small and medium scale sites can make an important contribution to meeting the housing requirement. Part d) identifies how working with developers to encourage the sub division of large sites could help to speed up the delivery of homes.

2.12 In this context, Policy S1 (6) outlines how non-strategic provision is made for small scale housing developments consistent with the indicative housing numbers set out in Policy H3, however this does not identify an approach to medium scale sites. Consequently, the Local Plan should allocate small and medium scale sites for residential development.

2.13 Should the Local Plan not allocate these scale sites, then there should be parcels within the BLDs identified as medium scale sites for early delivery in the plan period without prejudicing the BLDs. Policy S1 should be amended to include medium scale sites and to require flexibility to the housing target. This is discussed further in respect of Policy A13.

2.14 Policy S1 (7) states that strategic allocations and locations will be made through either this emerging Local Plan, the extant Site Allocation Development Plan 2014-2019 (or subsequent Site Allocation Development Plan Document (DPD)) and through Neighbourhood Plans. Notwithstanding the allocations in the emerging Local Plan, the most appropriate future mechanism is the Site Allocations DPD, which has to meet the ‘tests of soundness’ rather than ‘basic conditions’. This more rigorous approach to plan making is better able to address the site selection process and assessment of delivery requirements that a strategic allocation will need to demonstrate, particularly when taking account of the scale of growth proposed at Southbourne.

2.15 Lastly, the final paragraph of Policy S1 states that to ensure that the Plan’s housing requirement is delivered, “the distribution of development may need to be flexibly applied, within the overall context of seeking to ensure that the majority of new housing is developed in accordance with this Strategy”. The wording of this should be amended to state flexibility will be needed rather than may be needed, to ensure there is the ability to mitigate delays on allocations being brought forward by alternative proposals in order to meet the housing requirement over the plan period.

2.16 The use of the Authority Monitoring Report to control this is considered an acceptable approach, and policies A6 to A15 should reflect this requirement for flexibility. In practical terms, the LPA will need to consider performance in bringing forward and delivering large-scale development and enable alternative solutions where the required outcomes are not being achieved. This is discussed later in relation to Policy A13 specifically.
Policy S2: Settlement Hierarchy
2.17 The consultation document sets out a Settlement Hierarchy which is to serve as the framework for the Council to achieve its vision for the plan area, meet the scale of development required and enhance the quality of the built natural, historic, social and cultural environments, whilst sustaining the vitality of communities. This hierarchy seeks to deliver sustainable development that will support the role and function of different places within the plan area.

2.18 In this regard, Policy S2 is consistent with the NPPF acknowledging how “significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, improve air quality and public health.” (paragraph 105 refers). The Settlement Hierarchy ensures that new development is located in areas where residents have access to facilities and services and a range of public transport networks.

2.19 Chichester city is identified as the Sub-Regional Centre, with four Settlement Hubs being identified at East Wittering/Bracklesham; Selsey; Southbourne and Tangmere. This is a continuation of the existing spatial strategy in the Adopted Local Plan and consistent with the principle of locating new development at the most sustainable locations.

2.20 Southbourne is rightly identified as a Settlement Hub due to its range of local services and facilities, key public transport connections and employment/educational opportunities accessible via non vehicular methods of travel. The approach to Southbourne is discussed later at Section 4 and at Policy A13.

2.21 Accordingly, this strategic policy is positively prepared and justified, and is consistent with national policy promoting sustainable patterns of development.

3 Overall amount of Housing

Policy H1 Meeting Housing Needs
Housing Need

3.1 Paragraphs 60 and 61 of the NPPF state that to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance.

3.2 Only in exceptional circumstances could an alternative approach be justified. But even then, that alternative approach will also need to reflect current and future demographic trends and market signals.

3.3 Policy H1 identifies the need for the Plan to make provision for at least 10,350 dwellings within the plan period, amounting to 575dpa.

3.4 This is lower than both a. the standard method figure of 638 dpa; and, b. the Preferred Approach figure in the previous consultation, of 650 dpa which included accommodating some unmet need arising from the South Downs National Park (SDNP) area. This shortfall will amount to over 1,100 dwellings across the plan period. Without any Statements of Common Ground being published by the Council or evidence of the shortfall being accommodated elsewhere, this remains unaddressed.

3.5 It is highly germane that the current Local Plan adopted a lower housing figure than the identified need of 505dpa, proposing instead to deliver 435dpa.

Affordability in Chichester

3.6 The affordability ratios have risen from 12.38 in 2015, when the current Local Plan was adopted, to 14.61 in 2021 for Chichester, which is significantly higher than the current 9.1 national average, increasing the need for affordable housing within Chichester.

3.7 Between the 2011 and 2021 census, the number of people ages 50 to 64 years rose by over 3,100 (an increase of 13.4%), while the number of residents between 35 and 49 years fell by approximately 1,900 (8.5% decrease).

3.8 Chichester’s worsening affordability ratios and aging population, which typically occurs in line with house price increases, demonstrate the clear need to increase the housing delivery to meet current and future needs (in line with the NPPF), and maximise the potential for housing in this District. The current strategy to supress housing provision will only exacerbate these problems.

3.9 With the Submission Plan proposing to not meet the identified need, this once again will be an issue which moves onto the next Local Plan, failing to tackle key issues across the District such as affordability and lack of housing land supply. These issues cannot simply be moved onto the next Local Plan, they should be addressed now.

Constraints for development

3.10 The lower figure of 575dpa reflects both the infrastructure constraints along the A27 and at the


Waste Water Treatment Works, but also no longer accommodating unmet need from SDNP.

3.11 The Transport Study (January 2023) assesses the capacity levels, with particular focus on the A27. Although the Council state that 535dpa is the highest level of development per year achievable, the conclusions of this latest Study state, at paragraphs 5.6.5 and 11.2.3, that development of 700 dpa could be accommodated (in the southern plan area) through the mitigation proposed in the previous scenario of 535dpa with some additional mitigation at the Portfield and Oving roundabout.

3.12 This Transport Study (2023) was published following the preparation of the Sustainability Appraisal which refers to the 2018 study, therefore the latest evidence on highways matters has not be considered within the preparation of this Local Plan.

3.13 This is fundamental to the Plan’s approach – increasing the housing requirement could assist with funding those additional highway improvements, in line with the recommendations of the Transport Study at Section 9.3 to prioritise junctions to avoid delays to housing delivery. This should be further reviewed by the Council to ensure the District’s need is not being understated. It is recommended the housing need figure is reviewed in line with this evidence and the need to meet the minimum of the standard method figure of 638dpa, and aim to return to the 650dpa previously proposed.

Duty to Co-Operate

3.14 Paragraph 24 of the NPPF outlines the need for co-operation between local planning authorities on strategic matters that cross administrative boundaries.

3.15 The East Hampshire Local Plan Review has identified 100dpa for the SDNP area of the District, below the identified need of 112dpa for the District’s area and the overall requirement of 447dpa for the SDNP (Housing and Economic Development Needs Assessment 2017). In effect, in combination with Chichester, the National Park is needing to accommodate some 30 more dwellings per annum without any assessment as yet as to whether this can be achieved given the statutory protection that is afforded to it.

3.16 Whilst a Statement of Common Ground is referred to, it has not been published and therefore it is not possible to determine whether the decision not to make a provision for the National Park area is soundly based.

3.17 Previous evidence for the Preferred Approach demonstrated how the figure of 650dpa was achievable and necessary to help with the worsening affordability ratios across Chichester and the neighbouring authorities. Having removed provision for unmet need it is considered this plan has not been positively prepared.

Summary

3.18 Policy H1 clearly sets out how the majority of housing is to be delivered along the east-west corridor, with 535dpa in the southern plan area and 40dpa in the northern plan area. This is consistent with the Spatial Strategy and the Settlement Hierarchy, Policies S1 and S2, and the overarching objective of locating new housing at the most sustainable locations in the plan area.

3.19 By limiting the amount of housing there will be fewer schemes contributing to the required infrastructure improvements. Without developer contributions to fund wholescale upgrades to this infrastructure there is a risk of pushing the problem down the line for the next Local Plan to address, whilst problems with affordability and an aging population are further exacerbated.

3.20 All future schemes will be required to mitigate their impact on infrastructure including highways and utilities, and there is an opportunity for small to medium scale sites to be delivered in the short term whilst the larger allocations and/or the majority of the larger allocations await the upgrading of these works.

3.21 Currently, the proposal to reduce the overall housing supply for the new plan period is not supported, and the Council should review the Transport Study with the intention of meeting the assessed level of local housing need in full. Without the identified housing requirement being met in full the problem of the younger population being unable to afford to remain in Chichester will continue, further growing the gap in workforce and an increasingly aging population.

3.22 Therefore, this policy is not positively prepared, justified or consistent with the NPPF.

Policy H2 Strategic Locations/Allocations 2021-2039
3.23 The wording of ‘at least’ within Policy H1 provides flexibility on the ability to achieve the minimum amount of housing considered necessary by the Council, in line with Policy S2. Although this quantum is not agreed, the approach using ‘at least’ is considered a sensible approach to allow the achievement rather than under delivery of much needed open and market housing.

3.24 The strategic locations/allocations set out in Policy H2 do not reflect this flexible approach. Instead, the sites are fixed as exact number of dwellings for those locations.

3.25 Paragraph 119 of the NPPF requires planning policies to promote an effective use of land in meeting the need for homes, while safeguarding and improving the environment and ensuring safe and healthy living conditions.

3.26 Policy A13 is a BLD and is fixed at 1,050 dwellings within Policy H2, this does not allow for the masterplanning approach to further assess the actual capacity and the best use of this land.

3.27 As such flexibility should embedded into the wording of Policy H2 to ensure that the intention of Policy S2 is achieved; the housing target of at least 10,350 dwellings across the plan period (Policy H1) is met; and the land identified for development is most effectively used.

3.28 Therefore, it is suggested that Policy H2 includes the wording “at least” before the quantum of development for any strategic location or allocation. For example, Policy A13 would instead state “at least”.
Policy H8 Specialist accommodation for older people and those with specialised needs
3.29 National Planning Practice Guidance for Housing for Older and Disabled People states how plan- making authorities should set clear policies to address the housing needs for groups with particular needs such as older and disabled people.

3.30 The Housing and Economic Development Needs Assessment (HEDNA) (April 2022) assesses the period between 2021-2039 for older people and those with a disability.

3.31 This concludes that there will be a 42% increase in the population above 65 years old, amounting to 67% of the total population growth.

3.32 The HEDNA sets out how the East-West Corridor has a higher percentage of over 65 year olds (24.7%) compared to both Chichester City (24.2%) and the Plan Area North area (23.4%).

3.33 The needs arising from this, amounts to between 2,131 and 2,872 additional dwellings with support or care, and a need for 429-800 additional nursing and residential care bedspaces. This equates to approximately 17-24% of all homes needing to be some form of specialist accommodation for older people.

3.34 In this context, the HEDNA makes an important recommendation that the Council allocate specific sites for housing with care to ensure the identified needs are met. In contrast Policy H8 is a criteria based policy that seeks specialist accommodation for older people on housing sites over 200 units based on evidence of local need.

3.35 As written, there is no confirmation on the quantum of specialist accommodation that this policy or other site allocations will secure and how the specific need for each application is calculated. Policy H8 fails to address the identified overall need clearly, as required by National guidance. Therefore, it is recommended the Local Plan allocates sites to deliver this type of accommodation as intended by the HEDNA.

3.36 This approach risks the land on these sites being unable to deliver both the expected market/affordable housing and the specialist accommodation on site.

3.37 The land under Hallam’s control would be a suitable site for this type of accommodation, which is situated along the east-west corridor in a sustainable location on the edge of Southbourne.

4 Southbourne

4.1 Southbourne is a key area in the District, in terms of existing development, its status as a Settlement Hub and its potential to accommodate future development.
Role of Southbourne
4.2 Southbourne is identified as a Settlement Hub within Policy S2.

4.3 Southbourne is located within the east-west corridor with a range of existing facilities, good transport links, and employment opportunities both to the east and the west.

4.4 As set out in the Submission Plan, Southbourne has good access to educational facilities serving the residents, including primary schools, junior schools and secondary schools. There are a number of convenience stores and other community services and facilities such as a GP practice, pharmacy and places of worship.

4.5 The Bourne Community Leisure Centre provides local residents with access to community sports facilities. Access to public open space is also good through connections to Southbourne Recreation Ground. There is potential for more open space to be provided for local residents within the Local Plan Review and the strategic allocation proposed and this approach is embedded within our own Vision Document.

4.6 A key focus of the Sustainability Appraisal and the Submission Plan is for schemes to promote a modal shift in transportation. The strong public transport links within Southbourne to the wider surrounding area allows access to employment opportunities within the east-west corridor. Southbourne has strong public transport connections to the local and wider area, through bus and train services, to areas including: Chichester, Portsmouth, Havant, Littlehampton, Brighton, Southampton and London.

4.7 For these reasons, Southbourne is rightly designated as a Settlement Hub and is eminently suitable to serve as a BLD.

4.8 The Southbourne Level Crossing Report May 2021 analyses the options for delivering the railway crossing at Southbourne. It concludes that circa 750 dwellings can be delivered north of the railway line before triggering the requirement for a new crossing. The report highlights how sites south of the rail line are not likely to impact on the level crossing and can therefore be delivered earlier than await the railway line improvements.

4.9 Therefore, in this context it would be appropriate to allocate small and medium scale sites to the south of the railway, which is less constrained by the capacity restriction on the railway crossing.

4.10 The land under Hallam’s control is to the south of the railway line, would help facilitate a future new railway crossing to the north of the site, and would be of a medium scale to deliver housing early in the period plan.
Strategic Allocation A13
4.11 The Key Diagram appears to suggest that new development is to be located to the west and east of Southbourne, remedying the previously unsuccessful approach of focusing development only to the east. Similarly, the Key Diagram acknowledges the need for development to the south of the railway line, facilitating development north of the railway line. It is recommended the wording of the policy should be updated to reflect this diagram, as suggested below:

Provision will be made for a mixed use development within the broad location for development to the west and east of Southbourne, as shown on the Key Diagram.
4.12 Previously, the Preferred Approach consultation document set out at Policy AL13 a minimum of 1,250 dwellings at Southbourne and to be identified in the revised Southborne Neighbourhood Plan. (emphasis added)

4.13 The Submission Plan now allocates Policy A13 for 1,050 dwellings and will be established through the making of allocation(s) in the future Site Allocation DPD or the revised Southbourne NP. This strategic allocation is to act as a mixed use extension to the existing settlement.

4.14 It is acknowledged that the land north of Cooks Lane (Application number: 22/00157/REM) received Reserved Matters approval in August 2022 for 199 dwellings, with the reduction in quantum of development for the BLD reflecting this committed development. A practical effect of this is that this consent will not contribute to the wider infrastructure requirements associated with a larger scale of development.

4.15 It is disappointing to see the phrase “a minimum of” has been removed. This conflicts with the flexibility set out earlier in the consultation document, and also reduces the potential of making effective use of the land for housing that will assist in meeting the overall need of the District.

4.16 Policy A13 prescribes a number of requirements that must be met (criterion 1 – 16). These are considerations that reflect principles of place making and sustainable development and provide a sound framework for the preparation of the allocation through either mechanism.

4.17 One of these requirements states that future development “Provide[s] any required mitigation to ensure there is no adverse impact on the safety of existing or planned railway crossings.” The existing Southbourne Neighbourhood Plan, at Objective 9, outlines the issues relating to the railway crossing and the plans for addressing this challenge in the future.

4.18 Related to this is the need for the provision of “suitable means of access to the site(s), securing necessary off-site improvements (including highways) … to promote sustainable transport options.”

4.19 The combination of the requirements relating to the railway crossing and the provision of a suitable means of access show the importance of accessibility to the A27, A259 and the east-west railway line, which are the principal public transport corridors for Southbourne.

4.20 Development will be well connected to Southbourne via footway and cycle connections to the east and offers the opportunity to help realise the construction of a new strategic road and bridge link over the West Coastway Rail Line through provision of land and proportionate contributions to this scheme.

4.21 Criteria 13 ensures there will be sufficient capacity within the relevant wastewater infrastructure before the delivery of development, which addresses (for Southbourne) the identified constraints for the District in relation to housing delivery.

4.22 The remaining requirements of Policy A13 cover the quality and range of development, the provision of education, community and transport facilities, provision of public open space and green infrastructure, and the impact of development on the landscape. These are each appropriate considerations for the Site Allocations DPD.

4.23 Having regard to the above, the allocation of 1,050 dwellings for Southbourne is, in part, appropriate.

4.24 However, this policy should allow for the delivery of small or medium scale parcels of land, in accordance with the NPPF at an early stage of delivery of the wider allocation to enable prompt and timely housing at Southbourne whilst infrastructure upgrades are commenced. The Local Plan should identify and allocate these smaller scale sites to ensure these can come forward early in the plan period.

4.25 A new criteria is proposed to be included in the wording of Policy A13, stating:

(17) To identify land for early delivery on small to medium scale sites which are not constrained by the need for a new railway crossing.
4.26 Therefore, the principle of a strategic allocation for mixed use housing is considered appropriate but amendments should be made to the wording of the policy to reflect the approach to flexibility, the inclusion of small and medium scale sites, and the dispersion of development to both the west and east of Southbourne.
Southbourne Neighbourhood Plan
4.27 As set out in the paragraph 10.56 of the Submission Plan, development phasing is a key issue to address through the allocation of development sites for this BLD.

4.28 Paragraph 70 of the NPPF states that “Neighbourhood planning groups should also consider the opportunities for allocating small and medium-sized sites suitable for housing in their area.” Southbourne Parish Council should be aware of this when allocating the strategic sites, to ensure that there are a mix of housing sites, that could come forward sooner than the principal element of the larger strategic site.

4.29 Through the preparation of the Neighbourhood Plan, the Parish Council should take into account the allocation of smaller sites, which could come forward as part of and alongside the larger strategic site. This will ensure that there is not a delay in the provision of housing within Southbourne and the plan area.

4.30 As set out previously, the most suitable mechanism for progressing the Southbourne BLD would be the Site Allocation DPD. Whether the sites are allocated through the Site Allocations DPD or the NP, there is a requirement to identify small and medium scale site.
Land to the north of Gosden Green
4.31 The land under Hallam’s control to the north of Gosden Green, should either be allocated in the Local Plan as a medium scale site or should be a key component of the BLD. The site can deliver both market/affordable residential units and specialist elderly accommodation. The site will create flexibility in achieving the housing requirement of the plan area early on in the plan period.

4.32 The accompanying Vision Document demonstrates how as an early development parcel for the wider BLD, a series of key benefits in accordance with the 13 criteria of Policy A13 will be achieved.

4.33 The Proposed Submission Plan at Policy H8 identifies the need for specialist accommodation for older people and those with specialist needs. Although not set out in the Vision Document, this site can deliver, early in the plan period, much needed specialist elderly accommodation.

4.34 Figure 3 of the Vision Document presents the scheme’s ability to connect into a wider masterplan for the strategic development, as it comes forward in the future. However, at the same time has the ability to come forward at an earlier rate being physically unconstrained and a well contained parcel of land.

4.35 Figure 9 provides context on connectivity, and the modal shift this scheme aims to achieve. The ability to walk to a range of services and facilities, including the train station further demonstrates the ability for the early delivery of this parcel of the BLD.

4.36 The impact of the highways network has been assessed for both a full residential scheme and specialist elderly housing, highlighting how the residential scheme will introduce approximately 55 new vehicles to the network at peak times, resulting in less than 1 car per minute in the peak hour. Either scheme will have a negligible impact on the highway network and would have a negligible impact on A27.

4.37 The site is to the south of the railway line, as previously mentioned, and would be unconstrained by the capacity constraint of the existing railway crossing.

4.38 For these reasons, the land under Hallam’s control should be allocated within the Local Plan.

5 Conclusion
5.1 These representations are submitted on behalf of Hallam Land Management Limited.

5.2 In the context of national, local and neighbourhood planning policies, the Local Plan has an important role in providing policies and proposals for residential development to meet future needs.

5.3 The proposed objectively assessed need for housing across the plan area is not agreed, and the Council should review the latest transport evidence which currently do not demonstrate how there are exception circumstances, in accordance with paragraph 62 of the NPPF. The Council should also extend the plan period to ensure it meets the requirements of a minimum of 15 years in the NPPF.

5.4 Consistent with the established strategy to focus development in the District’s east-west corridor, the Broad Location for Development to Southbourne as a Settlement Hub is, as a matter of principle, a sound proposition. Importantly the Key Diagram identifies the broad location for this development to the west and east of the settlement.

5.5 As discussed, there should be flexibility embedded into all strategic allocations, in particular those which are Broad Locations for Development through the use of the wording “at least”. This will ensure that the “at least” quantum of housing delivery is met and affords flexibility to all housing sites coming forward.

5.6 The responsibility for allocating additional development land to meet this requirement has been given to either the Parish Council through the preparation of a new Neighbourhood Plan or through the Council reviewing the Site Allocations DPD. It is recommended that for the larger strategic allocations and locations the Site Allocations DPD is the more suitable mechanism for identifying land given the need to ensure that proposals are sound.

5.7 Whilst the scale of development proposed is strategic in nature, it is entirely appropriate to consider how different development parcels might contribute towards that and in particular early opportunities that facilitate larger scale development later in the plan period.

5.8 To this end, land to the west of Southbourne and south of the railway line could be allocated as the first phase of the strategic site allocation, as a medium size site, so that this southern section of the new link road is built to enable access to land to the north. This will reduce the pressure placed on the centre of Southbourne, the highway capacity on the A27, and the existing railway crossing.

5.9 By allocating small to medium scale sites in the Local Plan, this will bring forward development at a quicker pace and ensure that the objectively assessed needs for housing across the plan area are met each year. These can be delivered without prejudice to the larger strategic allocations and locations.

5.10 Currently, the Submission Plan fails to address the increasing need for specialist accommodation, with Policy H8 failing to secure specific delivery of such housing, instead moving this matter into major development schemes with no mechanism for assessing need at that stage. It is recommended that the Local Plan allocates sites for specialist accommodation.

5.11 Hallam control land to the west of Southbourne, which adjoins the land at Gosden Green which has already been built. The land controlled by Hallam could be: allocated as a medium scale site within the Local Plan; included as part of the western strategic allocation of Broad Location for Development at Southbourne; or could be allocated for specialist elderly accommodation, ensuring land is readily available for development early in the plan period to address identified needs.

5.12 This would be consistent with the development strategy for the Plan and positively contribute towards meeting future development needs of the plan area.

5.13 These representations have demonstrated that in part the Submission Plan has been positively prepared and justified, however the key recommendations in these Representations should be followed to ensure the plan preparation accords with Paragraph 35 of the NPPF.

Thank you for consulting Horsham District Council on the Chichester Proposed Submission Local Plan 2021-2039. We are grateful for the opportunity to be able to comment on your emerging plan. Overall, we consider that the plan has positively sought to balance the provision of future needs with other wider objectives in a manner that contributes to achieving sustainable development. I would also take the opportunity to reaffirm Horsham District Council’s (HDC’s) commitment to continued dialogue under the Duty to Cooperate and joint working between our two councils. We have a number of comments on the Proposed Submission Chichester Local Plan 2021 to 2039 to make on individual policies which we have set out below:

Policy S1 Spatial Development Strategy

We support this policy in principle, but consider it is not justified as stands. We note the spatial distribution in the plan period is split into three areas: East – West Corridor, the Manhood Peninsula, and North Plan area (which is the only part of Chichester district which directly adjoins Horsham district). HDC acknowledges Chichester District Council’s position that it is not able to meet its entire identified local housing need of 638 dwellings per annum, given the constraints associated with the required upgrades to the strategic road network in order to facilitate growth, potential environmental constraints and wider infrastructure restrictions. It is understood that National Highways requires a cap on growth due to the limited capacity of the A27. The proposed housing supply target is therefore 575 dwellings per annum.

HDC acknowledges and welcomes that significant effort has been put into identifying development capacity in a way that reflects the principle of positive planning. Nevertheless, the NPPF and PPG set a high bar for ‘leaving no stone unturned’ in respect of meeting development needs. We support that planned growth is directed to sustainable locations where access to local services and access to transport links are easier to access than remote rural areas. It is acknowledged Chichester City is the most populous settlement in the district as well as being most sustainable. We support that growth and future development should be focussed in the East-West Corridor, and in particular in or close to the City, first and foremost. We also acknowledge wider infrastructure deficiencies will need to be addressed in strategic locations before they can accommodate more growth.

We support your continued dialogue with National Highways to support improvements to the strategic road network and note a Statement of Common Ground (SoCG) will be published and updated as part of a continuous dialogue with National Highways. The SoCG is important as part of the justification for a lower housing supply figure and should transparently demonstrate why the constraints on the A27 will not allow higher growth in the East West corridor, in order to evidence that maximum housing needs have been achieved in the City and East West Corridor. This evidence is needed for HDC to inform its own DtC position with Chichester District Council (CDC).

Chichester District is planning below the standard methodology housing target and has therefore asked HDC if it can accommodate some of Chichester’s unmet housing need. HDC has confirmed that we are not in a position to accommodate Chichester’s unmet development needs because of our own water neutrality constraint. Furthermore, the primary housing market for Horsham District is the Northern West Sussex HMA, whose development needs are substantially driven by the Gatwick sub-region, and it is this HMA that would be prioritised with respect to meeting unmet development needs.

As a partner in the Sussex North Water Neutrality grouping also impacted by this constraint, CDC jointly owns the relevant evidence, and our two authorities share an ongoing commitment to work on this as our Duty to Cooperate dialogue continues. As ever, the latest position with regards to Water Neutrality and the impact on the delivery of housing and other development needs can be set out in a Statement of Common Ground (SoCG) between our two Councils.




Policy NE16 Water Management and Water Quality

We support this policy which is clear in its encouragement of efficient use of water as part of good management framework.

Policy NE17 Water Neutrality

Water neutrality is a significant issue affecting both our districts. Horsham District Council supports this policy which is derived from the joint work undertaken by Chichester District Council, Horsham District Council and Crawley Borough Council. We look forward to continued working with CDC on the development of the implementation scheme, in order to deliver the JBA Water Neutrality Assessment study. This will ensure all new development is in conformity with the Habitat Regulations and can demonstrate water neutrality.

Policy H1 Meeting Housing Needs

As outlined earlier in this response, we acknowledge that land supply in Chichester is constrained, and that CDC meeting the full housing requirement within its administrative boundary during the plan period up to 2039 would be challenging. Horsham District is not however in a position to accommodate any of Chichester District’s unmet housing need because of water neutrality and, looking forward, the need to prioritise meeting unmet needs within our primary housing market: the Northern West Sussex HMA.

Policy H2 Strategic Locations/Allocations 2021 -2039

A significant proportion of CDC’s housing supply will be delivered through strategic allocations. Loxwood (220 dwellings) is identified as a strategic allocation and will come forward through the local plan process, with some allocations anticipated to be delivered through local neighbourhood plans. Given the challenges that face Neighbourhood Planning groups in the preparation and delivery of Neighbourhood Plans, (which can potentially delay the delivery of these allocations), we support the identification of strategic sites in the Local Plan, programmed for delivery earlier in the plan period.

As the delivery of strategic allocations requires significant infrastructure planning, including cross-boundary issues relating to the road network, education, healthcare and community facilities, Horsham District Council welcomes continued dialogue with the relevant stakeholders, to ensure development at strategic locations such as Loxwood are delivered in a timely manner and adhere to sustainable development principles. We have some specific concerns relating to strategic allocation policy A15: Loxwood which we have set out under that policy.

Policy H11 Meeting Gypsies, Travellers and Travelling Showpeople’s Need.

We note your position and your requirement to provide a number of pitches and plots for the travelling community during plan period. We support your policy position for intensification of existing pitches. Horsham District can’t at this point in time accommodate any of CDC’s unmet Gypsy, Traveller and Travelling Show people requirement as we are required to first address our own shortfall, and our evidence demonstrates that this alone will be challenging.

We have a body of evidence to support our position and we will continue to share our evidence with you as our Duty to Cooperate dialogue continues over the coming months. As ever, the latest position regarding Gypsy, Traveller and Travelling Showpeople will be set out in the Duty to Cooperate Statement of Common Ground between our two Councils.

Policy A15 Loxwood

We support this policy as it will contribute to meeting Chichester District’s unmet housing need, but consider it is not justified as stands and that its effectiveness could be improved. The five villages in the north of the Plan area (Kirdford, Wisborough Green, Loxwood, Ifold and Plaistow) are classified as Service Villages in the emerging Chichester Local Plan. They provide a reasonable range of basic facilities (e.g. primary school, convenience store and post office) to meet the everyday needs of local residents, or are villages that provide fewer of these facilities but that have reasonable access to them in nearby settlements. Loxwood is the strategic site identified to accommodate 220 dwellings over the plan period.

The nearby settlement of Billingshurst, in Horsham District, is considered to be the nearest main settlement to the villages identified above. Given the limited facilities available / or to be provided as part of the Loxwood allocation, it is considered that new residents are likely to be reliant at least some key facilities in Billingshurst, potentially including the GP surgery, the railway station (and rail user car park), The Weald secondary school and sixth form, the library and the retail and community facilities, including the leisure centre. Within Horsham District, there are potential proposals for strategic scale extensions to Billingshurst / new settlements relatively close to Billingshurst. Whilst no decisions have been made with respect to our local plan, housing growth delivered through our own local plan will create potential impacts on existing infrastructure which is already under significant pressure. We therefore require clear evidence that potential cumulative impacts on settlements in HDC have been considered as part of the proposed allocations. We would ask that CDC works collaboratively with HDC and other stakeholders to ensure future pressures on infrastructure in Horsham District is appropriately addressed. Consequently, we seek further clarification in Policy A15: Loxwood to emphasise the importance of collaborative working between stakeholders to mitigate against the potential cumulative impact of development.

I do hope these comments are helpful. I would like to emphasise that they are made in anticipation of further constructive dialogue between our authorities, and with an expectation that matters on which we have flagged concern can be readily addressed, and quite possibly eliminated through our Duty to Cooperate discussions. Should you require any further detail or information in regard to this response please don’t hesitate to contact a member of my Strategic Planning team.

We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.

Background

National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).

National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).

The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.

Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):

• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).

• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).

• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).

• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).

• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).

In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:

a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?

We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.

National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.

In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.

In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.

Further detail on the above can be provided by National Highways.

While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.

It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear 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 (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”

However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.

We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf

Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.

Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.

We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).

Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.

Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.

The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.

National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.

We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]

Summary

We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.

We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.

To make the plan sound the strategic site at Selsey needs to be reinstated in the plan with commensurate testing in the SA. The allocation would need to ensure that the development deals with flood resilience for access and egress to the B2145 in a proportionate way, working with the relevant agencies. The significant benefits of providing (partial) flood resilience to the wider community of Selsey needs to be recognised as part of the planning policy balance.

See attachments.

I am pleased to attach our representations in response to the Chichester Local Plan Regulation 19 consultation. These representations are submitted on behalf of our clients Deerhyde Ltd. owners of land in Selsey and located in the area for a significant number of years.
The submitted documents include the following:
• Representations statement
• Plans showing the potential road widening of Golf Links Lane and Paddock Lane, Selsey
• Development potential of sites for residential development at Golf Links Lane and Old Farm Road, Selsey taking account of flood zones 2 and 3 (2 plans 15-085 SK03 and SK04)
• Plans showing access options to Golf Links Lane site
• Plan showing tracking analysis for low-loaders
• Junction analysis
• Submission form
As detailed in the attached, after careful consideration we have concluded that the housing strategy for Chichester is flawed in principle as it fails to allocate sufficient sites in outside Chichester City (or adjacent to) to allow the remainder of the District to continue to provide houses for local people in areas where they are most needed.
In addition, our clients have put forward a suggestion for an infrastructure improvement to Selsey – namely the widening of Golf Links Lane and Paddocks Lane to accommodate delivery of caravans / other HGV / LGVs but also to provide a wider carriageway which could potentially incorporate a pavement / footpath cycleway to aid safer conveyance of pedestrians and vehicles in the area. Adding in a safer highway solution would also encourage car users to walk or cycle for local trips rather than risking congestion in the car. It would have the added benefit of diverting caravan park traffic travelling from the north into the caravan parks earlier and thus relieving congestion of Selsey High Street.
Introduction

1.1. Vail Williams LLP has been instructed by Deerhyde Ltd to submit representations to the Chichester Local Plan 2021-2039: Proposed Submission (Regulation 19) document.

1.2. As per the Website, these comments seek to address the three questions namely:
1. Is it legally compliant?
2. Is it sound?
3. Does it comply with the duty to cooperate?

1.3. These representations are largely focussed on the provision of housing and ensuring that a satisfactory access (both vehicular and pedestrian) can be maintained and enhanced, particularly in Selsey.

1.4. These representations reflect the fact that our client, Deerhyde Ltd, owns a significant amount of land in the Selsey area, an interest which was acquired in 1986 but with family ownership going back many years before then.

1.5. Our clients have identified a potential opportunity to facilitate highway improvements within Selsey which would be to the benefit of both residents and tourists using the holiday parks and other attractions alike. This would particularly be of benefit given the Council’s acknowledgement that the B2145 through Selsey is the busiest B road in the country These representations bring into question the ‘tests of soundness’. In particular regarding the questions as to whether it is ‘sound’ on the basis of whether it has been ‘positively prepared’, whether it is ‘justified’ and ‘effective’ in respect of the areas of concern raised with respect to employment land provisions.

1.6. As set out at Paragraph 35 of the NPPF local plans are required to be ‘sound’. Plans are considered sound when the following applies:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs1; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy2, taking into account the reasonable alternatives3, and based on proportionate evidence4;
c) Effective – deliverable over the plan period5, and based on effective joint working on crossboundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.6

1.7. These representations seek to highlight that Chapter 5 (Housing) has not been positively prepared, in so far as it does not provide [1.] “a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs”.
1.8. It is also considered that Chapter 5 is not justified as the housing strategy is [2.] is inappropriate as it relies on a number of large strategic sites, with multiple issues some of which are in conflict with other parts of the local plan.

1.9. Chapter 5 is also not justified with respect to its provisions do not [3.] take into account reasonable alternative sites.

1.10. It is considered on the basis of the other factors highlighted in these representations and the proposed housing land provision is not ‘consistent with national policy’ as the proposed provision does not enable the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. It is considered that the proposed plans are contrary to the NPPF paragraph 16a, 16b, 16c, 16d and paragraph 20a

2 Local Plan Representations

2.1. Having reviewed the draft Local Plan we would make the following comments:

2.2. Paragraph 3.1 asserts the Government’s encouragement for local planning authorities to ensure sustainable development is at the forefront when considering planning applications and that the National Planning Policy Framework (NPPF) defines sustainable development as “meeting the needs of the present without compromising the ability of future generations to meet their own needs”. Paragraph 3.5 goes on to advise the range of factors as are informed the spatial strategy which underpins the local plan which, inter alia, “the pattern of need and demand for housing and employment across the area”, “infrastructure capacity and constraints, in particular related to waste water treatment, roads and transport”, “the availability of potential housing types, their deliverability and phasing” and this needs to take place whilst being mindful of the environmental constraints taking a sequential approach to avoiding flood risk areas, protect the environmental designations, landscape quality, the historic environment and settlement character.

2.3. The principles outlined above are supported as these are the key facets of good planning and plan making. However it falls to local authorities to ensure that the sustainable approach includes providing a sufficient supply of homes and facilitating a variety of sites to come forward where needed, and that the needs of groups within specific housing requirements are addressed and that land with permission is developed without unnecessary delay. (Paragraph 65). Paragraph 66 states that within the overall requirement [for housing] strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations.

2.4. Paragraph 67 goes on, where it is not possible to provide a requirement figure for a neighbourhood area, the local planning authority should provide an indicative figure, if requested to do so by the neighbourhood planning body. This figure should take account of factors such as the latest evidence of local housing need, the population of the neighbourhood area and the most recently available planning strategy of the local planning authority.

2.5. Paragraph 68 asserts that strategic policy making authorities should have a clear understanding of the land available in their area through the preparation of a Strategic Housing Land Availability Assessment (SHLAA). From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and locally economic viability.

2.6. Further guidance states (Paragraph 69) that small and medium sized sites can make an important
[my emphasis] contribution to meeting the housing requirements of an area, and are often built-
out relatively quickly. To promote the development of a good mix of sites the local planning authority should identify sites of small and medium size and support the development of windfall sites through their promises and decisions giving great weight to the benefits of using suitable sites within existing settlements for homes.

2.7. Neighbourhood planning groups should also give particular consideration to the opportunities for allocating small and medium-sized sites suitable for housing in their area. Paragraph 71 goes on: where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply. Any allowance should be realistic having regard to the SHLAA, historic windfall delivery rate and expected future trends.

2.8. Whilst it is noted that the delivery of large scale sites can result in the delivery of large numbers of new homes, it is apparent that such developments take considerable time to work their way through the planning system to an approval and even then are only at outline stage. The delivery of new homes is therefore reliant on the Councils to efficiently determine reserved matters applications and, thereafter, discharge of conditions, to allow a swift implementation of planning applications and a timely start on site for the delivery of housing.

2.9. The inclusion of small and medium sites (ie. not reliant on strategic sites) within the housing mix
are invaluable in delivering housing quicker and potentially in places, perhaps outside the main settlements, which would allow new housing to be accessible to all which is one of the key facets of the NPPF.

2.10. This approach would assist with maintaining delivery of housing where existing allocations are either stalled or progressing slowly through the planning system or have simply been delayed in coming forward for perhaps other commercial reasons.

2.11. The plan is largely predicated on strategic sites, as detailed at Policy H2 which would provide 7,195 houses. This is a significant reliance on the strategic sites to deliver 75% of the overall housing target and much of them are predicated on the works to the A27 being completed in order to make them acceptable.

2.12. It should be noted that the above housing provision is predicated on the ability to identify mitigation for the impacts on the European environmental designations (including nutrient neutrality), addressing highway implications and negotiating the planning system.

The Manhood Peninsula

2.13. The preferred approached version of the Local Plan does include moderate growth for the settlement hubs of Selsey (250 dwellings) and East Wittering (350) and the service village of Hunston (200). However, since then several planning permissions have contributed to the moderate levels of growth on the Manhood Peninsula which the Council says has accounted for these housing numbers. The plan does not therefore include any strategic allocations on the Manhood Peninsula in recognition of this recently permitted growth and the ongoing constraints the area faces, save for 50 dwellings to come forward at North Mundham.

2.14. This approach is not considered sound as a reason to prevent development of any scale on the Manhood Peninsula (particularly Selsey) for the plan period. As detailed above, it is essential that the plan allocates land across its settlement hierarchy in order to maintain a sustainable and deliverable approach to development and to assist the continuing evolution and economic viability of settlements which rely heavily on tourism and also on new development to maintain
the supply of homes to provide options for all sectors of the local community to be able to live on the Peninsula should they so wish.

2.15. It is noted that at Policy S2 (settlement hierarchy), Selsey is listed as a “settlement hub” which is the second tier of settlement under Chichester city. Whilst this hierarchy, particularly in connection with Selsey is supported it is therefore surprising not to see more housing sites allocated within and around Selsey.

2.16. Given the potential number of environmental constraints on the Manhood Peninsula it is unlikely that sites of any excessive size would come forward and large numbers of dwellings would not necessarily result once the sites had taken account of their environmental constraints. That said, and as reflected above, sites of a size proportionate to their location but below “strategic” size can have an important part to play in the delivery of sufficient housing numbers in the right location at the
right time in accordance with the NPPF.

Housing

2.17. Policy H1 (meeting housing needs) sets out the housing requirement for the full plan period of 1 April 2021 to 31 March 2039 as 10,350 dwellings. This allocates 963 dwellings to the Manhood Peninsula and a windfall (small site allowance) allocation of 657 dwellings for the whole district. There are no strategic locations/allocations on the Manhood Peninsula under Policy H2 which is considered unsound, particularly given the position that Selsey holds in the settlement hierarchy. Furthermore, under Policy H3 (non-strategic parish housing requirements 2021-2039) Selsey has been allocated zero housing. Again, this is considered unsound as it prevents sustainable development and access to new houses for all settlements across the district.

2.18. An overreliance on consented sites coming forward to provide future housing is considered unsound as, in this case, it effectively prevents any further development on the Peninsula and in Selsey in particular.

Transport

2.19. Policy T1 (transport infrastructure) is specifically aimed at ensuring that integrated transport measures will be developed to mitigate the impact of planned development on the highway network, improve highway safety and air quality, promote more sustainable travel patterns and encourage increased use of sustainable motor travel, such as public transport, cycling and walking.

2.20. The council will work with National Highways, WSCC, other transport and service providers and developers to provide a better integrated transport network and improve accessibility to key services and facilities. The policy lists seven ways in which the key objectives of reducing the need to travel by car, enabling access to sustainable means of travel, including public transport, walking and cycling; managing travel demands; and mitigating the impacts of travelling by car can be achieved.

2.21. Whilst it is not intended to go through all of these in this document it is noted that all parties are expected to support the four objectives by working with relevant providers to improve accessibility to key services and facilities which would be relevant to Selsey (see below).

2.22. The policy is also aimed at planning to achieve a timely delivery of transport infrastructure on the A27 and elsewhere on the network which is needed to support new housing, employment and other development identified in this plan. The phasing of delivery of new development to align with provision of new transport infrastructure such as improvements to the A27 and elsewhere on the highway network, will be key to managing impacts on the highway. This is yet another impediment to the delivery of a strategic allocations and larger scale development which would, by their very nature, generate a higher highway impact on the transport network than carefully planned smaller developments which could satisfy a much more localised need and be cause less impact on the strategic road network. The tariff proposals outlined at paragraph 8.20 only covers part of West of Chichester and Tangmere SDLs and not the other strategic sites outlined at Policy H2.

2.23. Critically it is also understood that Highways England has pulled funding for the improvements to the Bognor Road roundabout as part of a package of A27 improvements. On this basis it is unclear how further funding would secured at this time.

2.24. The lack of soundness to the approach of significant reliance on strategic sites, due to the current lack of capacity of the A27, is evident in the text that accompanies the policy which states that opportunities to secure funding to implement this package of improvements will be maximised by working proactively with Government agencies, other public sector organisations and private investors. Developer contributions from new development will also be sought. It is clear that smaller scale developments which would have a significantly lesser impact on the highway network could deliver housing quicker and with fewer constraints to implementation. It is for these reasons that smaller sites should be allocated, particularly in the Manhood Peninsula, for development.

2.25. The content of Policy T2 (transport development) is largely supported and considered sound save for the fact that it does not seem to cover the improvement of local transport routes, particularly those that would assist in improving the circulation of traffic around smaller settlements. The policy should be amended to specifically relate to local transport improvements which are locally important to aid traffic circulation and reduce congestion.

Neighbourhood Plan

2.26. The Selsey Neighbourhood Plan does not seek to allocate any sites or residential development, instead relying on those which were allocated in the previous local plan and, in particular, developments at Park Farm/Middle Field and Drift Field totalling 249 houses. It is assumed that this existing commitment accommodates the neighbourhood plan of 150 houses which is the justification for not allocating of residential development in the neighbourhood plan. However, this is short sighted as the neighbourhood plan runs to 2029 and, although development sites are largely controversial within smaller communities there is a lack of recognition of the requirement to provide new houses for existing and future residents (including descendants of current residents) in order to maintain the vitality and viability of the settlement outside of the tourist season where it is recognised that the local population will swell.

2.27. These points add further weight to the considered lack of soundness to the housing policies in the local plan which fail to recognise the need for smaller allocations within the Manhood Peninsula, particularly Selsey.

3 Local Infrastructure Provision

Selsey Road Improvements

3.1. Our clients wish to put forward a potential highway improvement scheme for Selsey which has come about given their extensive historic knowledge of the town and experience of significant congestion along Selsey High Street as a result of an over-reliance of this route by traffic using the caravan parks. It would be a common sense alternative route (to using High Street) which will alleviate congestion along Selsey High Street/School Lane/Paddock Lane/Warners Lane, particularly during the summer months.

3.2. The local plan focusses its attention on the need to improve the strategic highway network but this proposal would provide a significant benefit at a local level in Selsey. As per the attached plan, our clients propose to widen Golf Links Lane from its junction with the B2145 Chichester Road to its junction with Paddock Lane, then widen Paddock Lane and make it up to adoptable standard to enable delivery of holiday traffic to the point where it meets the north eastern corner of White Horse Caravan Park, from which point the road has been made up to carry holiday traffic. At the moment, the northern section of Paddock Lane is just a rough track which is not suitable for ordinary road traffic. It is envisaged that, in conjunction with the owner of the largest caravan parks, Warner’s Lane will also be improved. It is currently a tarmac road in poor condition with no footways and one section is too narrow to allow two vehicles to pass each other. This is not satisfactory for the major access route to the largest caravan parks.

3.3. Golf Links Lane is currently a single track, tarmac road which is in poor condition. It is two-way but much of it is too narrow to allow two vehicles to pass each other. It serves Northcommon Farm, a small housing development on the northern side, Selsey Golf Club and Selsey Country Club (which comprises c.300 holiday chalets and an associated licensed club). It if were to be made up to adoptable standard to the point where it meets Paddock Lane, it would improve access for existing users but, importantly, it would also create a more direct access route (in conjunction with Paddock Lane) for traffic associated with thousands of holiday caravans as well as a touring caravan park.

3.4. Given that a large proportion of holiday traffic and other tourist industry-related traffic (HGVs carrying food and drink, caravan transporters, tractor/trailer transport and public transport) use the route along High Street/School Lane/Paddock Lane/Warners Lane it is considered that this could be diverted from the B2145 Chichester Road further north than Selsey High Street, thus taking traffic away from the congested High Street. An easier, more direct route to the major caravan parks would be an attractive alternative.

3.5. The mechanism to deliver such a proposal is not yet the subject of formal agreement. A large proportion of the land required to widen the roads is within the ownership of Deerhyde Limited (our clients) and the owner of the major caravan parks. The latter has been very supportive of the proposal verbally. A short section of land is not in any specific ownership but our clients have long-standing rights over its use, which can be traced back to 1830. Our clients are serious about facilitating these highway improvements, including the use of their land, which will inevitably have a significant financial impact upon them.

Potential Residential Development Sites

3.6. In order to mitigate the financial impact including both the loss of their land and the implementation of the proposed highway improvements our clients would like to promote two sites for residential development, namely land north of Golf Links Lane (13.5 acres/5.46 hectares) and land west of Old Farm Road for residential development. Whilst the north western corner of the site is located within Flood Zones 2 and 3 it is considered that the developable area of the site would be approximately 4 hectares and could therefore deliver approximately 120 to 140 dwellings. This includes retaining the existing boundary screening along the south eastern boundary and avoiding Flood Zones 2 and 3. An indicative plan is attached to this statement.

3.7. Thawscroft Ltd, an associated company, also owns land west of Old Farm Road, Selsey (2.8ha / 6.9 acres) which taking account of the flood risk constraints along its western boundary could accommodate approximately 50 dwellings. An indicative plan is attached to this statement.

3.8. Having reviewed the planning history of the site it is noted that a planning application (under the name of Thawscroft Limited) was made in December 2016, refused in June 2017 and the appeal was dismissed on 11 June 2018.

3.9. The reasons for refusal related to the following:

1. Site is located outside the defined settlement boundary for Selsey.

2. When the planning officer was giving evidence, he stated that he knew of an alternative site at lower risk of flooding but he would not identify it. After the appeal, an area of land north of Park Lane was identified for 250 houses. The land in question becomes waterlogged in the winter and is highly prone to surface water flooding. It is also only about 250m from Pagham Harbour, a site of major ecological importance with a significant level of protection afforded to it. The planning officer said the real issue with our appeal was one of numbers so it seemed curious to me that a site with a much larger number (250) was identified soon afterwards. Also, the land south of Park Lane (similarly prone to surface water flooding) was in the numbers for 2015/20 but in fact could not be started until 2021 so the planning inspector was misled. I believe that was crucial to the outcome. Landlink have proposed land west of the “Wave” roundabout (opposite Asda). This may be as an alternative for the land north of Park Lane. Neither parcel would be a good fit in the settlement policy area, whereas the land to the west of Old Farm Road would be, a fact acknowledged by planning officers in the past.

3. We did in fact offer to provide contributions towards improving the A27 so that reason for refusal was withdrawn prior to the appeal being heard.

4. As far as I can recall, the Council was content with our proposals in these matters at the time the appeal was heard. The criticism was that the need to avoid Flood Zones 2 and 3 created a narrow site which meant that the layout was said to be cramped. It could be that, with a smaller number of houses, MH Architects could provide an improved layout. Maybe this is reflected in the plan to which Vail Williams refer in paragraph 3.13.

3.10. It is considered that, as detailed above, given the Council’s approach to an over-reliance on large strategic sites to fulfil its housing need and the lack of sites identified for development on the Manhood Peninsula (and in Selsey in particular) during the plan period this site could be proven to be an appropriate location for development as a “windfall site” to help maintain housing supply whilst the strategic sites are in the planning system.

3.11. It is considered the dwellings on the site could be laid out to avoid the Flood Zones 2 and 3 and therefore be at considerably less flood risk than the proposal which was dismissed at appeal. This is set out in the enclosed plan. This would overcome reason for refusal 2.

3.12. Reasons for refusal 3 and 4 would be overcome through the agreement of under Section 106 of the Town & Country Planning Act to provide contributions towards the improvement to the A27 on a proportionate basis to the size of the site and the number of dwellings and also the relevant number of affordable housing units required by policy (or justified as part of a viability exercise). Other matters such as the management of the landscaping, open space, buffers and drainage infrastructure could also be secured by the Section 106 agreement.

3.13. We commend the above highways solution and subsequent development sites to officers in consideration of the draft Local Plan.

4 Conclusions

4.1. It is clear that whilst the overarching strategy of the location of the majority of development in the largest urban settlement of Chichester or adjacent to it is sound the lack of allocation of significant housing numbers to those areas outside Chichester is unsound. This would mean that the vast majority of the district would attract very little housing over the planning period to 2039 thus ensuring that existing settlements would not evolve and would potentially shrink as existing residents and descendants of residents migrate to the Chichester or its strategic urban extensions.

4.2. Outside Chichester, the strategic proposals for Southbourne and Tangmere are similarly isolated. The Manhood Peninsula is particularly lacking in the provision of additional housing sites during the plan period with the justification provided that, for Selsey in particular, recent planning permissions which are being built or have been completed would accommodate all of the housing need going forward for the plan period.

4.3. This approach is flawed for two main reasons (making the Local Plan unsound):

1. The over-reliance on strategic allocations which themselves are constrained by the capacity issues on the A27 and environmental issues such as nitrate neutrality (and any future water neutrality issues which migrate south from the north of Chichester) and the usual impacts on the European sites could mean that these sites are slower in being delivered with little in the way of alternatives allowed for in the local plan.

2. The failure to acknowledge any future development potential of note within the Manhood Peninsula and in particular Selsey will constrain the continued vitality and viability of the settlements within the Manhood Peninsula, particularly following the pandemic when the service sectors are struggling. Taking into account that Selsey in particular but other settlements along the coast within the Manhood Peninsula are reliant on seasonal tourist activity, additional residents are relied upon outside these times in order to provide income for those businesses which may struggle to survive outside the holiday seasons. An effective block on development would significantly reduce the potential future viability of these settlements outside the tourist season.

4.4. The emphasis on the stated urban-focussed housing strategy encourages neighbourhood planning groups/parish and town councils to maintain an opposition to the relevant rather than a proactive policy framework to direct appropriate development within their areas.

4.5. Our clients have detailed above one way which their land could be used in conjunction with others to facilitate a local infrastructure improvement to assist traffic circulation and access in and around Selsey itself which would need to be funded by future residential development and we commend this proposal to you for further consideration.

4.6. We trust that officers will take these representations into account and we look forward to receiving confirmation that the representations have been duly made.

See attachment.

1 Introduction

1.1 This representation provides a response to the Regulation 19: Local Plan Consultation on behalf of our client Reside Developments Ltd. The submission covers the general principles of the Local Plan, but has a focus on Land at Herons Farm, Kirdford, which is in our clients control. The land is shown on the attached location plan included at Appendix 1 and hereon referred to as the
site.

1.2 This representation will provide a written responses in relation to the Regulation 19 Local Plan Consultation which directly relate to the promotion of our client’s land for future development.

2 Comments on Specific Questions/Tests

2.1 In response to the national planning legislation, this Regulation 19 Local Plan Consultation invites comments on three specific questions, and is the final consultation phase, before the Regulation 19 version of the Local Plan is submitted for Examination.

2.2 This representation will respond on these specific questions, and then highlight how our client’s site could help fulfil the full housing requirement for the District. This could be through an allocation within the Council’s Local Plan, or as currently proposed, through a Neighbourhood Plan allocation.

Is the plan ‘sound’?

2.3 Paragraph 35 of the National Planning Policy Framework defines the tests for soundness which
requires the plan to be positively prepared, justified, effective and consistent with National Policy.
These matters will now be considered in further detail in relation to the current consultation on the Regulation 19 version of the Local Plan.

Is the plan positively prepared and justified?

2.4 Policy S1 of the Draft Local Plan sets out the spatial development strategy for the District and how the Council will achieve sustainable growth over the plan period and Policy H1 sets out the housing target in response to the strategy. Both policies have been informed by the Sustainability Appraisal (SA) dated January 2023 and the Plan objectives, which are set out at paragraph 2.5.2 of the SA and the Council’s HEDNA (April 2022).

2.5 The SA then goes on to discuss the potential growth scenarios and confirms two points:
i. Standard method housing figure for Chichester (excluding SDNP) is 638 dwellings per annum, or 11,484 in total over the Plan period
ii. The above figure is capped at 40% above the baseline need and that the uncapped figure is significantly higher than this at 884 dwellings per annum (dpa)

2.6 Of particular note is that point ii. above seeks to cap the overall housing increase by no more than 40% above the previously adopted LP housing figure of 435 dpa. The Local Plan then goes on to constrain housing numbers due to an alleged capacity concern along the A27 strategic road network. The Council therefore result in a constrained housing figure by virtue of the standard
method ‘steps’ and also due to infrastructure capacity. It should be noted that the 435 dpa figure within the 2015 Local Plan was similarly constrained and an early review was the only basis for accepting this reduced housing figure. This early review did not take place.

2.7 In terms of the influence of the A27, this is the key matter that constrains growth within the southern part of the District. This is based on the evidence base documents that state that the road network cannot accommodate an annual housing figure of more than 535 dpa. This is a fundamental point and one that is not agreeable as we believe there is capacity to accommodate at least the local housing need within the highway network, alongside potential improvements
identified for the following reason.

2.8 The Transport Study (January 2023) is the key document on which the Council rely upon to constrain their housing figure to 535 dpa. On review of this document, it is clear that the Council’s consultants undertook a sensitivity analysis as to whether the core scenario that supports the 535 dpa position in the local plan could accommodate a higher level of growth. The conclusion in paragraph 5.6.5 and 11.2.3 of the Transport Study appears to be that 700 dpa could be
accommodated (in the southern plan area) by the mitigation proposed for the 535 dpa core test, with some additional, and as yet undesigned and not costed, mitigation works beyond those highlighted for the Bognor and Fishbourne roundabouts.

2.9 Accordingly, the Council’s own evidence base has undertaken the assessment and concluded that a higher growth figure could be accommodated on the A27, subject to appropriate improvement works. Given the testing of the higher growth figure, which appears to accommodate the higher growth figure, the exceptional circumstances to constrain growth, as set out at paragraph 60 on the NPPF do not exist and the Plan could be considered unsound on this point alone.

2.10 As a result of the above, the SA does not consider a scenario where the Council would meet its local housing need, nor a scenario where it exceeds its local housing need, which is of relevance given the scale of development expected for adjoining authorities, including the highly constrained SDNP area.

2.11 It should also be noted that the draft Plan does not therefore address any need in relation to unmet need of neighbouring authorities and it does not contain evidence to suggest that these matters have been discussed with the adjoining Authorities. Notably, Arun District Council have confirmed that they will be objecting to the Plan and currently proposed on the basis that they have a significant housing need themselves. This is likely to be further influenced by unmet need from Chichester, who again are seeking to constrain housing requirements, which was the case
in 2015 and the subsequent knock on from that was for Arun to address some of that need in their 2018 Local Plan.

2.12 Given that we do not accept that the A27 capacity matters present a ceiling in terms of housing delivery (based on the Council’s Transport Study comments and that of its own consultants), it is not accepted that the Plan and associated SA demonstrates reasonable alternatives have been considered and it is not therefore positively prepared, nor is their approach to housing figures justified.

Effective?

2.13 On the basis of the 535 dpa figure, it is considered that the selected areas for growth and figures are deliverable over the Plan period, however, as set out above, the plan area could accommodate a greater level of growth.

2.14 It should also be noted that the Plan relies on the delivery of Neighbourhood Plan and / or small site allocations DPD. This is set out under Policy H3 in the draft document. This states the following in terms of delivery:
‘If draft neighbourhood plans making provision for at least the minimum housing numbers of the relevant area have not made demonstrable progress the council will allocate sites for development within a development plan document in order to meet the requirements of this
Local Plan.’

2.15 The above is not precise and does provide any clear timetable for delivery within the Plan period.
Whilst the strategy in the comments above could be effective, the Local Plan needs to give a clear timescale for completion of the supplementary Development Plan documents in order to give a clear timescale for this to be completed.

Is the plan consistent with National Policy?
2.16 On the basis of the comments above, the approach to selected sites for allocation based on the
535 dpa figure is considered to be consistent. However, due to the lack of evidence to demonstrate this, the 535 dpa figure should be capped. Given the A27 capacity points raised, the draft Plan does not appear to meet the exceptional circumstances allowed for at paragraph 61
of the NPPF to justify their alternative approach. The Plan as proposed is therefore inconsistent with NPPF when read as a whole.

3 Approach to development in Kirdford

Overview

3.1 The Draft Local Plan defined Kirdford as a service village, which benefits from some local facilities and services including a village hall, a local shop and two pubs. The village has been allocated 50 units within the draft local plan and is therefore suitable for a quantum of growth. The Sustainability Appraisal (SA) identifies Kirdford as a village with some facilities, albeit that due to the absence of a school, these are limited. The SA notes that the delivery of community infrastructure would be required to accommodate any quantum of housing, our client’s land provides ample opportunities to provide this infrastructure alongside housing. The HELAA
identifies a number of sites which could come forward through the Neighbourhood Plan process.

Sustainability Appraisal

3.2 Section 5.4 of the SA states that it is important to consider each of the settlements within the plan area, and explore reasonable growth scenarios. 5.4.2 continues this, stating that there is a clear need to explore a wide range of growth quantum scenarios in the northeast plan area.

3.3 The Sustainability Appraisal addresses the constraints of this area in terms of its rural locality,
unsustainable travel patterns and achieving water neutrality. 5.4.7 sets out that there are three reasonable growth scenarios for each of the four Parishes in the Northeast plan area, if the option of a new settlement at Crouchlands Farm is ruled out as unreasonable. 5.4.8 states there is a strong argument to suggest that this option is unreasonable, nevertheless, it has been
deemed appropriate to take the option forward to consideration. Within the SA, the Council justifies their approach which comprises a blend between Scenario 1 and Scenario 2 as described below:
 Scenario 1 – Lower growth scenario across all parishes – This would relate to an allocation of 50 units to Kirdford.
 Scenario 2 – Higher growth scenario across all parishes – This would relate to an allocation of 150 units to Kirdford.
3.4 The SA sets out that it is fair to rule-out the lowest growth scenario for Kirdford (growth at committed sites only). The SA also sets out there is an argument for ruling out the highest growth scenario (300 homes) as unreasonable, as Kirdford is poorly connected and does not benefit from a primary school. The SA sets out three growth scenarios following the above. These scenarios relate to 50 homes, 150 homes, and 300 homes.

3.5 A blended approach for Parishes within the Northeast plan area has been supported within the
SA, attributing the Scenario 1 model (lower growth) to Kirdford.

3.6 The reasoning given by the Council for attributing the lower growth figure to Kirdford relates to the unsuitability of the northeast plan area as a whole, including unsustainable travel patterns, risks to achieving water neutrality and settlement specific concerns relating to the potential impacts of growth of Kirdford.

3.7 Whilst these concerns raised within the SA and those regarding the existing infrastructure of the village are noted, we believe that the need to support the growth of existing villages, and the ability of development to create and enhance infrastructure should be afforded weight when considering the housing numbers attributed to the village.

3.8 The SA raises concerns surrounding the HELAA options towards the North of the village. This is mainly due to the connectivity to the village and road network, and environmental concerns.
These concerns will be addressed later in this representation.

3.9 It should be noted more broadly that higher growth scenarios can provide more significant community infrastructure enhancements to the area.

4 Suitability of Site

Site Description

4.1 Our client’s land is located to the North of the main settlement of Kirdford, which is situated in the northeast of the District. The plan submitted alongside this statement includes land edged in red, to be considered for housing/community uses, and land in blue for biodiversity enhancements. For ease of reference, the red area has been split into Area A, Area B and Area C,
which correspond to the split of the site in the HELAA. The site is connected to Kirdford by Footpath 610 and 606. As mentioned previously, the site was previously submitted to the Council’s call for sites and is included in the most recent HELAA.

4.2 The Southernmost part of our client’s land is annotated as Area A on the drawing included at
Appendix 1 (HELAA reference HKD0007). The site was considered to be potentially suitable, subject to detailed consideration of access, and heritage impact. We believe that through well considered design, there is clear potential for development on this parcel as the site is well connected to the P.R.O.W and local transport network. Footpath 606 runs along the Northern
boundary of the site, and Footpath 610 runs along the Western boundary of the site which provide access to the main settlement of the Kirdford. The access track to Heron’s Farm is adjacent to the Eastern boundary of the site. Whilst the concerns relating to connectivity are
noted, we believe there is strong evidence to suggest the site is well connected to the settlement, and there are achievable technical solutions to access.

4.3 The central parcel of our client’s ownership is annotated as Area B on the drawing included at
Appendix 1 (HELAA reference HKD0009). The site has been considered potentially suitable subject to consideration of access and landscape matters. The site is immediately adjacent to the to the established residential development at Bramley Close, and an allocated site with planning permission (HELAA reference HKD0002). We are of the view that there are technical solutions to access at the site, which can be explored as part of our ‘next steps’. Footpath 610 provides pedestrian links to the main settlement. Further to this, we are of the view that development of this site to the North of the settlement appears as a natural continuation of Kirdford. This is due to the presence of the adjacent site to the West, the sports pitches to the North, and the shaping of the existing woodland. Initial landscaping works have been completed, and it has been concluded that appropriate landscape-led masterplanning, and green infrastructure plans can
be provided as part of any prospective development, which would allow the landscape characteristics of the site and its locality to be retained and enhanced. The site provides an opportunity to introduce a new landscape framework within the parcels and enables any
proposed development to sit within a treed landscape. Further works for the site would look to come forward following liaison with the Parish Council, which could include further landscaping evidence.

4.4 The Northernmost parcel is annotated as Area C on the drawing included at Appendix 1 (HELAA
reference HKD0011). The site was deemed to be potentially suitable for residential development subject to considerations of access. As set out previously within this statement, the site has potential vehicular and pedestrian links to the settlement, and the wider transport network. We feel there are multiple technical solutions to achieving access to the site.

4.5 Whilst noted that in order to ease the consideration of the site, it is necessary to divide the site into sections, we are of the view that our clients land should be looked at more strategically. The SA sets out that the delivery of community infrastructure would be required to accommodate any quantum of housing and we would look to provide this within our clients ownership. The
provision of this infrastructure will be subject to consultation with the Parish Council and local
occupiers to understand what community infrastructure would be sought for the area. Further, the parcels provide an opportunity to introduce a new landscape framework and enables any development to sit within a treed landscape. The land within our client’s control is considered to have potential to accommodate a quantum of up to 200 dwellings, including provision for selfbuild units.

4.6 The area outlined in blue is put forward as land for biodiversity enhancement, which could be delivered as part of any application.

Sustainability

4.7 The site is suitably located to deliver a host of benefits to the local area and help achieve objectives of the northeast of the District, without harm to the key attractions for visitors, the setting of the National Park, or the rural character of the locality.

Water Neutrality

4.8 One of the constraints of the north-east of the District is the requirement is for all new development to meet water neutrality, to ensure that any new it does not impact further on the habitat site comprising the Arun Valley Special Area of Conservation (SAC) or the Arun Valley Special Protection Area (SPA) & Ramsar site, in terms of groundwater abstraction within the Sussex North Water Supply Zone. It is anticipated that further advice and a mitigation strategy will be created by the Council and its partners to demonstrate how developments can achieve water neutrality. However, at present applicants are required to provide a water neutrality strategy to demonstrate how the development can achieve water neutrality.

4.9 To provide the Council with reassurance that the site is deliverable despite this constraint, it should be noted that our client has worked on other sites with this constraint, and has developed approved strategies in this instance to mitigate development.

5 Conclusion

5.1 Whilst we understand the approach the Council has taken in terms of the selection of sites to meet the 535 dpa figures, we consider that the Plan area is capable of accommodating a greater housing quantum. This will facilitate development and help villages in particular to flourish and meet the objectives of the Local Plan. The Council have failed to provide sufficient justification
for not meeting its housing need in full and have not suitably considered unmet need from adjoining authorities. The latter is particularly relevant given constraints of the SDNP. The Council’s position of growth is predicated on the basis of the A27 not having sufficient capacity to accommodate a higher growth of 535 dpa. Its own evidence base (Transport Study 2023)
contradicts this position and therefore the Council should at least be meeting their local housing need and also considering what part it can play with meeting unmet needs for the adjoining authorities.

5.2 Our clients land is well placed to assist in the delivery of a sustainable expansion of Kirdford, and
deliver both much needed housing within the north-eastern plan area, but also provide highquality infrastructure within the area. The allocation of a greater quantum of housing to the village will support the vitality, and viability of services and facilities within the Northern villages.

5.3 At present, the Plan fails to be positively prepared and is inconsistent with the NPPF. On the basis
that the Council don’t reconsider their position, we wish to be present at the relevant Examination hearings to represent our clients’ interests and further discuss the views set out in this submission. Our next steps will include liaison with the Parish Council in order to best
understand what they would like to see from development proposals within the area.

When revised dwelling requirement is established for Policy H1, consideration will need to be given to either increasing amount of strategic allocations in Policy H2, and/or increasing housing figure in Policy H3. Settlement of Westbourne is a sustainable location for additional development, recognised by allocations in previous Local Plans and more recent housing allocations in ‘made’ Westbourne Neighbourhood Plan 2021, less likely to generate traffic movements on the A27 Chichester Bypass. Land at Monks Hill (HWE0014) would make ideal extension to the settlement. Has been assessed as potentially suitable/developable and capable of delivering about 125 dwellings by the Housing and Economic Land Availability Assessment 2021. [see plan within attachment]

See representations

Allocate submitted sites.

See attached.

Conclusion

In light of all the above we contend that Sites HOV0006 (Sherwood Nursery) and HOV0012 (Landsdowne Nursery) should be reconsidered for allocation for housing development in the Draft Plan. The Sites are positively assessed in the HELAA, and are situated adjacent to existing consented and planned allocated sites. This area is clearly suitable for new housing. The Sites are previously developed and provide an opportunity for new housing in a sustainable location, without encroaching onto greenfield land. In this context the natural next step would be to add the Sites to the draft Plan as additional site allocations for residential development.
We put these two sites forward with the intention to provide high quality housing in an area with an identified need. We have made it clear in the above representations that the Sites are eminently available, sustainably located and can provide much needed new residential units.
The District Council’s proposed housing figures for the Plan period are considered to be insufficient to meet the needs of the District when the significant unmet needs of adjacent and other nearby authorities are taken into account.
In this context, the broad location of Shopwhyke (east of Chichester) is acknowledged as being a sustainable location in the context of Chichester District, and we consider that it should be aiming to provide an increased housing figure during the Plan period.
The Sites are unconstrained by any landscape or other planning designations. The work that has been undertaken, and the conclusions of which clearly identify that the Sites are suitable for development.
We contend that Sherwood Nursery should be removed from the Strategic Wildlife Corridor designation for the reasons we have set out.
In its current form, we contend that the Draft Plan does not meet soundness tests insofar that it does not positively contribute to the achievement of sustainable development, and nor does it comply with the strategic policies of the area, by failing to provide a sufficient quantum of housing.

Re the strategic and Area based policies in connection with the above plan.

I have read the proposal from the CDC regarding the development in Loxwood, and I strongly object to it.
Over 200 new houses will not enhance our village. It is mentioned they want to create open spaces and trees, we have exactly that now. We have open spaces and beautiful trees, and views already,just leave nature as it is.
We have no bus service to speak about.
No spaces in the Primary School
The Medical Centre struggles to cope with the present residents.
The Post Office and General Store is closed.
It is hardly safe to walk through the village with no proper pavements, while the heavy traffic thunders through.
We have no industry or jobs for newcomers, so they will have to commute out of the village and create heavier traffic.
I cannot see any reason to build so many houses, so as I mentioned I object to this proposal.

Matter of water supply needs to be addressed, water neutrality does not appear to be working.
Increase in population requires a full bus service if traffic reduction is to be achieved in an effort to promote climate control.

I refer to the above Local plan as published 3rd February 2023 and in particular to the Strategic and Area Based Policies and sections of Policy A15.
I object to further development of Loxwood Village by the addition of a minimum of 220 houses as included in the above referred to plan.
I make the following comments and observations on which my objection is formed.
1. Water supply. The present water supply to Loxwood village is just about adequate. Whenever a new house is completed we suffer a notable and permanent drop in water pressure so much so that care has to be taken to ensure only one water outlet eg shower is in use at one time. Further water demand will cause further drop in pressure unless the matter of supply is addressed, water neutrality does not appear to be working.
2. Waste water and sewerage. Some is being removed by tankers from recent developments. As there appears to be no plan to upgrade the wastewater and sewage systems more tanker shipments can be anticipated along with increased traffic, danger of spillage and damage to the environment.
3. Public transport. At present we are served by one bus a day on four days a week. Inevitably with an increase in population a full service would be required if traffic reduction is to be achieved in an effort to promote climate control. I doubt if a reliable and viable adequate bus service could be provided. It appears rural bus services are diminishing not increasing.
4. Medical Centre. This appears to be at or beyond capacity given time required to obtain an appointment with a doctor. Doctors seem to change very frequently.
5. Open Views. I can't agree that more building will give greater views.
6. Employment. No manufacturing or service industry of any size in Loxwood or nearby. Any new population would have to travel for work, Similarly no shop means travel for shopping. Not good for Climate Control.

For the above reasons I am against any further housing development in Loxwood.

Executive Summary

The Local Plan as written lacks ambition and vision, and will be detrimental to the landscape within which the district lies. It is a plan borne out of a need to produce a legal document which will satisfy the regulatory authorities. In terms of Urban Planning it fails “To meet the needs of the present without compromising the ability of future generations to meet their own needs” (NPPF).

The development that will consequentially arise from the deployment of such a made Local Plan is not sustainable. It will adversely affect the Character, Amenity and Safety of the built environment, throughout our district.

In particular, the Local Plan is inadequate for the needs of the people in the district both at present and in the future because –

1. It has been written in advance of the District having a properly formed and agreed Climate Emergency Action Plan. It is inconceivable that such a key document will not shape our Local Plan. It is this Action Plan that is needed first in order to provide the long-term strategic view as to how and what the District will look like in the future; this, in turn, will help form and shape the policies outlined in any prospective, Local Plan. The Plan as proposed is moribund, as a result of “cart before the horse” thinking.

2. The Local Plan as written does not adequately address how infrastructure, transport and services are going to be materially and strategically improved to meet the predicted growth and shift to a significantly ageing population. There is presently insufficient capacity to supply services and to have adequate people and environmentally friendly connectivity, as a direct result of decades of neglect towards investing in infrastructure and services to meet the needs of the District’s population. We are led to believe that developers through increased levies in order to gain permission to build will fulfil this need, but all that this will result in is an uncoordinated, dysfunctional mess completely lacking in any future-proof master planning approach. We contend that this will do nothing for the quality of life of Chichester District residents and it will create a vacuum whereby few if indeed any can be held accountable or indeed found liable for shortcomings in the future.

3. The Local Plan as written does not state how it will go about addressing the need to create affordable homes. The District Council’s record on this matter since the last made plan has been inadequate and now the creation of affordable homes has become urgent as political/economic/social factors drive an ever increasing rate of change within the District.

4. Flood risks assessments used in forming the Plan are out of date (last completed in 2018) and any decision to allocate sites is contrary to Environment Agency policy. Additionally, since March 2021 Natural England established a position in relationship to ‘Hold the Line’ vs. ‘Managed Retreat’ in environmentally sensitive areas, of which the Chichester Harbour AONB is a significant example. CDC have failed to set out an appropriate policy within the proposed Local Plan that addresses this requirement.

5. The A27 needs significant investment in order to yield significant benefits for those travelling through the East-West corridor; this is unfunded. Essential improvements to the A27 are key to the success of any Local Plan particularly as the city’s ambitions are to expand significantly in the next two decades. But any ambitions will fall flat if the A27 is not improved before such plans are implemented.. The A259 is an increasingly dangerous so-called ‘resilient road’ with a significant increase in accidents and fatalities in recent years. In 2011, the BBC named the road as the “most crash prone A road” in the UK. There is nothing in the Local Plan that addresses this issue. There is no capacity within the strategic road network serving our district to accommodate the increase in housing planned, and the Local Plan does not guarantee it.

6. There is insufficient wastewater treatment capacity in the District to support the current houses let alone more. The tankering of wastewater from recent developments that Southern Water has not been able to connect to their network and in recent months the required emergency use of tankers to pump out overflowing sewers within our City/District reflects the gross weakness of short-termism dominated thinking at its worst and is an indictment of how broken our water system is. The provision of wastewater treatment is absolutely critical and essential to the well-being of all our residents and the long-term safety of our built environment. The abdication by those in authority, whether that be nationally, regionally or locally, is causing serious harm to the people to whom those in power owe a duty of care and their lack of urgency in dealing properly with this issue is seriously jeopardizing the environment in which we and all wildlife co-exist.

7. Settlement Boundaries should be left to the determination of Parish Councils to make and nobody else. The proposed policy outlined in the Local Plan to allow development on plots of land adjacent to existing settlement boundaries is ill-conceived and will lead to coalescence which is in contradiction of Policy NE3.

8. All the sites allocated in the Strategic Area Based Policies appear to be in the majority of cases Greenfield Sites. The plan makes little, if any reference to the development of Brownfield sites. In fact, there is not a Policy that relates to this source of land within the Local Plan as proposed. Whilst in the 2021 HELAA Report sites identified as being suitable for development in the District as being Brownfield sites were predicted to yield over 4000 new dwellings. Why would our Local Plan not seek to develop these sites ahead of Greenfield sites?

9. The Local Plan does not define the minimum size that a wildlife corridor should be in width. What does close proximity to a wildlife corridor mean? How can you have a policy (NE 4) that suggests you can have development within a wildlife corridor? These exceptions need to have clear measures and accountability for providing evidence of no adverse impact on the wildlife corridor where a development is proposed. Our view is quite clear. Wildlife and indeed nature in the UK is under serious and in the case of far too many species, potentially terminal threat. Natural England has suggested that a Wildlife Corridor should not be less than 100metres wide. The proposed Wildlife Corridors agreed to by CDC must be enlarged and fully protected from any development. This is essential and urgent for those Wildlife Corridors which allow wildlife to achieve essential connectivity between the Chichester Harbour AONB and the South Downs National Park.

10. Biodiversity Policy NE5 - This is an absolute nonsense. If biodiversity is going to be harmed there should be no ability to mitigate or for developers to be able to buy their way out of this situation. This mindset is exactly why we are seeing a significant decline in biodiversity in the District which should be a rich in biodiversity area and why the World Economic Forum Report (2023) cites the UK as one of the worst countries in the world for destroying its biodiversity.

11. In many cases as set out in the Policies the strategic requirements lack being SMART in nature – particularly the M Measurable. These need to be explicit and clear: “you get what you measure”.

12. 65% of the perimeter of the District of Chichester south of the SDNP is coastal in nature. The remainder being land-facing. Policy NE11 does not sufficiently address the impact of building property in close proximity to the area surrounding the harbour, something acknowledged by the Harbour Conservancy in a published report in 2018 reflecting upon how surrounding the harbour with housing was detrimental to it long-term health. And here we are 5 years on and all of the organizations that CDC are saying that they are working in collaboration with, to remedy the decline in the harbour’s condition, are failing to implement the actions necessary in a reasonable timescale. CDC are following when they should be actually taking the lead on the issue. Being followers rather than leaders makes it easy to abdicate responsibility. There must be full and transparent accountability.

13. The very significant space constraints for the plan area must be taken into account. The standard methodology need no longer apply where there are exceptional circumstances and we are certain that our District should be treated as a special case because of the developable land area is severely reduced by the South Downs National Park (SDNP) to the north and the unique marine AONB of Chichester Harbour to the south. A target of 535dpa is way too high. This number should be reduced to reflect the fact that only 30% of the area can be developed and much of that is rural/semi-rural land which provides essential connectivity for wildlife via a number of wildlife corridors running between the SDNP and the AONB. Excessive housebuilding will do irretrievable damage to the environment and lead to a significant deterioration in quality of life for all who reside within the East / West corridor.

14. Many of the sites identified in the Strategic & Area Based Policies could result in Grade 1 ^ 2 farmland being built upon. The UK is not self-sufficient in our food security. It is short-sighted to expect the world to return to what we have come to expect. Our good quality agricultural land should not all be covered with non-environmentally friendly designed homes.