Policy H3 Non-Strategic Parish Housing Requirements 2021 - 2039

There needs to be a mechanism in planning to only allow residential occupation by local residents.

I live in East Wittering and one of the things which has become very apparent over the last few years is the number of properties, including new builds on larger estates, which are being bought as investment properties and especially for holiday lets. This is pushing house prices higher and excluding local people and families from getting on the property ladder.
There needs to be a mechanism in planning to only allow residential occupation by local residents.

The allocation of houses to be fairly distributed.

We have lived in Wisborough Green for 23 years in this beautiful village. We strongly object to the additional 75 houses. Our village’s infrastructure cannot support further development due to the lack of public transport, sewage, roads, medical facilities, schools, water. We have 3 brownfield sites already allocated. Any further development would be on greenfield sites. CDC has been dithering and indecisive and want to overload the NE parishes. This is due to the debacle surrounding the upgrading of the A27 which is going to drag on for many years. Homes are needed in the southern area not the northern.

The Local Plan should allocate sites at a District Level, and not delegate to Neighbourhood Plans.

Please refer to attached supporting document. Policy H3 is discussed on page 13.

The local plan should both allocate non-strategic sites and define settlement boundaries around the District if it is to meet its role and purpose under the NPPF.

The settlement boundary fails to include the Land South West of Willetts Way which was found in the Housing Economic Land Availability Assessment (HELAA) to be suitable, available and achievable for up to 10 units (HLX0006).

As with Policy S1, we are in agreement with the Draft Local Plan defining Loxwood as a ‘Service Village’ in terms of settlement hierarchy with a need to direct growth to the most accessible and best-connected locations, including villages with good public transport options.
We seek to acknowledge the policy discussion on settlement boundaries, and support the presumption in favour of sustainable development within the settlement boundary of service villages.
However, we consider the Draft Local Plan to be ‘ineffective’ and ‘unjustified' in this respect by giving the power to define the Settlement Boundaries to Neighbourhood Plans. The Draft Local Plan cannot be ‘positively prepared’ when suitable, available and achievable sites are left fragmented and overlooked by Parish Councils creating piecemeal plots outside of the settlement boundary for often unjustified reasons, the Neighbourhood Plan process being subject to lesser scrutiny (having only to meet basic conditions) than local plans.
In line with our comments on Policy S1 – Spatial Development Strategy, the local plan should both allocate non-strategic sites and define settlement boundaries around the District if it is to meet its role and purpose under the NPPF.
In relation to Loxwood for example, the settlement boundary as defined by the Neighbourhood Plan is not representative of the current village and its settlement, or suitably reflective of the levels of housing growth and allocations required. The current settlement boundary is shown below in the Settlement Boundary (Loxwood Neighbourhood Plan Reg 15) (Figure 4). The settlement boundary fails to include the Land South West of Willetts Way which was found in the Housing Economic Land Availability Assessment (HELAA) to be suitable, available and achievable for up to 10 units (HLX0006). The site is clearly sustainable, being close to the village centre, and associated services but was excluded for unjustified reasons through the previous Neighbourhood Plan process.
Furthermore, the settlement boundary also excludes the High Street and associated residential properties to the south of the village centre which are historically and currently part of the village. The historic map shown below (Historical Ordnance survey map dated 1912) shows the small settlement of Loxwood at that time with the junction of Station Road and the High Street and only a small number of properties but the residential dwellings on the High Street were central to the evolution of the village and close to services, facilities, surgeries and the school which grew around them. To exclude the High Street and land to the rear including Land South West of Willetts Way is illogical and unjustified.
Figure 6 indicates where the logical and justified settlement boundary should be to the south of Loxwood (represented by the red line). The inclusion of this area is both a sustainable allocation of 10 new homes at Land South West of Willetts Way, but also a more accurate reflection of the actual settlement boundary of the village, through the inclusion of the historic ‘High Street’.
In order for the Draft Local Plan to be ‘justified’ and ‘effective’ in delivering housing through small scale sites, the Local Plan needs to specify the settlement boundaries and allocate sites, and not delegate to Neighbourhood Plans.

Whilst it is agreed that Loxwood should be subject to non-strategic housing allocations, we cannot support this Policy H3, based on its reliance on Policy H2 and neighbourhood plan allocations.
In order for the Draft Local Plan to be ‘justified’ and ‘effective’ in delivering housing through small scale sites, the Local Plan should allocate sites at a District Level, and not delegate to Neighbourhood Plans.

It is acknowledged that Loxwood is marked with an ‘*’ outlining that a strategic location has been identified via a neighbourhood plan within Policy H2.
This is discussed in greater detail under Policy H2 representations, however, we consider the approach of housing allocation and defining settlement boundaries via neighbourhood plans and parish allocations to be ‘ineffective’ and ‘unjustified’.
In relation to Loxwood for example, the settlement boundary as defined by the Neighbourhood Plan is not representative of the current village and its settlement, or suitably reflective of the levels of housing growth and allocations required. The current settlement boundary fails to include the Land South West of Willetts Way which was found in the Housing Economic Land Availability Assessment (HELAA) to be suitable, available and achievable for up to 10 units (HLX0006). The site is clearly sustainable, being close to the village centre, and associated services but was excluded for unjustified reasons through the previous Neighbourhood Plan process.
The Draft Local Plan cannot be ‘positively prepared’ when suitable, available and achievable sites are left fragmented and overlooked by Parish Councils creating piecemeal plots outside of the settlement boundary for unjustified reasons, while the Neighbourhood Plan process is subject to lesser scrutiny (having only to meet basic conditions) than local plans.
Whilst it is agreed that Loxwood should be subject to non-strategic housing allocations, we cannot support this Policy H3, based on its reliance on Policy H2 and neighbourhood plan allocations.
In order for the Draft Local Plan to be ‘justified’ and ‘effective’ in delivering housing through small scale sites, the Local Plan should allocate sites at a District Level, and not delegate to Neighbourhood Plans.

Allow the democratic process within the Neighbourhood Plan to decide what is best for small villages.

For our village, Wisborough Green, to allocate an extra 75-houses is not really small-scale.
The present infrastructure is inadequate and new residents will probably need a car to live here.
The danger here includes the spoiling of the character of the village.

After 'If draft neighbourhood plans making provision for at least the minimum housing numbers of the relevant area have not made demonstrable progress the Council' a line should be added to say 'after checking deliverability with the parish council concerned'.

After 'If draft neighbourhood plans making provision for at least the minimum housing numbers of the relevant area have not made demonstrable progress the Council' a line should be added to say 'after checking deliverability with the parish council concerned'.

With respect to Wisborough Green Water Quality and Waste Water...
a) There will be adverse impact from additional sewage spilling into adjacent water bodies and groundwater.
b) Additional sewage spilling will adversely affect surface and ground water quality.
d) Significant wastewater infrastructure improvement is required to properly cope with the current load. As per this Policy, additional housing development must align with the infrastructure development.

Hunston Parish Council is pleased to see the withdrawal of the strategic housing allocation for Hunston and the rest of the Manhood Peninsula.

For the period 2021-39 East Wittering will be allocated at least the estimated number of social and affordable housing which will appear on the Chichester Housing waiting list over this period.

East Wittering has been allocated zero for Non Strategic Parish Housing Requirements for 2021-39 but we do have a need, at least for affordable and social housing in this period. Witness the number of local people waiting on the Chichester Housing waiting list

I RELUCTANTLY support the allocation of 75 houses but WG has NO INFRASTRUCTURE to support ANY additional housing. We DO NOT have a doctors’ surgery, dentist, sports centre, supermarket, petrol station - to access any of the aforementioned requires the use of a car, contrary to LP policy. The village primary school is not only at capacity but in excess of 70% of pupils come in from surrounding villages by car, again, contrary to LP policy. We only have one small top-up shop. Sewage treatment and electricity supply are under pressure plus there is ABSOLUTELY no mobile signal.

The Local Plan needs to provide a greater level of housing to Fishbourne Parish, given its proximity to Chichester City and available capacity, in order to contribute to meeting the housing need of the District.

Fishbourne is an area that is well located to Chichester City and should therefore be prioritised as a location for development. The emerging Local Plan, at Policy H3, indicates a housing figure of 30 dwellings to be allocated through the Fishbourne Neighbourhood Plan. Five sites in the parish have been assessed in the HELAA and subsequently discounted, including Lawrence Farm. Given its proximity adjacent to the southern edge of Chichester City and its highly sustainable location, Berkeley believes the site should be allocated in the Local Plan or the Parish housing allocation be increased to enable a review of the Neighbourhood Plan to allocate sites to meet the local housing need more fully.

Put all the dwellings in cities, where they are needed; or, at the very least, within walking distance of a train station or an area served by a regular (i.e. every 30 minutes) bus service running throughout the day.

This would permit people to use public transport to commute, shop reach services such as schools, doctors, hospitals etc.

I object strongly to this approach of randomly distributing houses to villages. If we truly are to adopt a low-carbon lifestyle, dwellings need to be built near employment and public transport. Villages have neither.

A greater level of housing needs to be allocated towards Lavant parish, given the capacity of suitable sites.

Lavant is an area that is well located to Chichester City and should therefore be prioritised as a location for development. The emerging Local Plan, at Policy H3, indicates a housing figure of zero dwellings to be allocated through the Lavant Neighbourhood Plan. Three sites in the parish have been assessed in the HELAA and subsequently discounted, including Raughmere Farm. Given its proximity adjacent to the northern edge of Chichester City and its highly sustainable location, Berkeley believes the site should be allocated in the Local Plan or the Parish housing allocation be increased to enable a review of the Neighbourhood Plan to allocate sites to meet the local housing need more fully.

Reduction in the number of houses projected for Plaistow, Ifold and Kirdford.

I am gravely concerned that after so much prior development the projected number of houses for the village of Kirdford greatly exceeds what is reasonable in relation to its size and village status.
I do not believe this Plan properly reflects environmental constraints or the lack of appropriate infrastructure which is currently under grave strain.
The policy threatens the very identity of Kirdford as a village.

The plan should clarify that a zero figure in Policy H3 does not mean all development opportunities, including windfalls, must be resisted. The zero figure is offered as a strategic guide to housing locations but is not an indication that all forms of housing will be inappropriate.

It is inappropriate to require villages to provide a zero-housing figure. Villages may not be strategic locations for significant additional housing, but it is not unreasonable, through neighbouring planning or individual promotions to support some limited development subject to material considerations and individual merit.

At Lavant for example the Estate has land interests where a small contribution to housing supply could be made – not necessarily as open market housing, but specific quality housing to meet identified needs. In other villages in-fill development might be appropriate.

We support the allocation of 50 new homes in Kirdford. The Plan sets out that this new housing will be delivered through the Neighbourhood Plan process however at the current time there is uncertainty as to if or when the Kirdford Neighbourhood Plan will be formally reviewed. On this basis, we consider it important that a clear alternative delivery mechanism be set out within the Plan to ensure certainty to allow for the Plan to be considered effective.

Increase Fishbourne and Nutbourne to at least 100; Increase Birdham to 50; Change Selsey, East and West Wittering from 0 to 50 each

Increase provision in certain villages where the sensitivity assessment has shown the capability of accommodating growth and not set out figures based on political pressures from Parish Councils

We would want to see a reduction in the housing allocation to a number that we believe is achievable on what land is available.

The Neighbourhood Plan team of Boxgrove Parish Council wish to contest the allocation of 50 dwellings during the Local Plan duration.

The Local Plan consultation period has not allowed sufficient time for proper local consultation and includes proposals that have never previously been consulted upon.

We do not understand how so many of the sites, previously discounted in the 2018 HELAA, for various reasons, are now designated in the 2021 HELAA as having ‘no known constraints’ to development on the same sites.

Furthermore, out of 11 Service Village Parishes, found to have potential sites for dwellings in 2018, 7 of these now have a zero allocation in the Local Plan. Boxgrove has been allocated 50 dwellings, despite over 50% of Boxgrove’s land area lying within the boundary of the SDNP.

All of the sites identified are outside of the existing Settlement Boundary, and are therefore in ‘The Countryside’, in contravention of your Policy NE10.

The village school is at capacity and there are no known plans to expand it.

There are future capacity issues at the A27 Tangmere roundabout junction and concerns about future short cutting through Boxgrove and the already narrow and winding local roads to the north.

Boxgrove and the village of Halnaker both have Conservation Areas and there are a total of 51 listed buildings and two Scheduled Monuments in the Parish many of which would be affected by development on the sites identified.

The Conservation Area Character Appraisals identify many long views out of the CA’s, which would be compromised by development.

Development would be in contravention of your Policies P9, P10 and P11 of the Local Plan.

All the sites, identified as potentially developable, are on agricultural land. These are either currently farmed, are vineyards or are livery. This land is graded 2 or 3 in contravention of Policy NE2 Natural Landscape.

In conclusion, we believe that the HELAA and the allocation of 50 dwellings for Boxgrove in the Local Plan are unachievable on most of the sites identified. We are sure that a small number of sites for a lower number of dwellings maybe achievable, and intend to consider this as part of the revisions to our Neighbourhood Plan.

Please refer to the attached document for a detailed response. A sustainability-based approach does not support the proposed allocation and it should
revert to that proposed at Regulation 18 stage.

Please refer to the attached document for a detailed response.

Remove housing figure for Loxwood.

Policy A15 10.66-10.77 Object to 220 new dwellings in Loxwood :
Environmental depletion through loss of habitat for wildlife including Skylarks and other ground-nesting birds, Barn & Tawney Owls & bats that hunt over the fields, the area where a Cuckoo is active each year.
Very limited pubic transport.
Inadequate parking at nearest station : Billingshurst.
Inadequate roads from.
Increasing volume of traffic from any significant housing development.
Lack of fresh water capacity & ability of public sewer to cope with additional capacity.
Create suburban developement that would change th character of the village
Loss of footpaths/public rights of way

The allocation of housing to the north need to be reduced back to the levels allocated in 2020

I am concerned that the proposed housing quota for the villages to the North has been set because the Council have been unable to resolve its issues regarding the A27. Residential development of any scale is better suited to the large towns in the South and the Council need to commit to a solution to the A27 and then a housing policy around it. Allocating housing to the North as a short term fudge will only serve to create long term issues for future generations to struggle with.
Beyond the A27 there is no logic to the revised allocations for the villages to the North and that is unacceptable. Any allocation needs to be based on a sound evidence base and strategy and the Council have failed to evidence such a case.
I firmly agree that a local plan should be in place but it must be one that is sound and which has properly considered all of the factors such as infrastructure, ecology, utilities, public transport, car reliance, school places, medical facilities and sewage capacity. Any reasonable analysis of the villages in the North clearly shows that they are unsuitable for the extent of development now proposed. Any reasonable analysis would show that any number of towns to the south would be much better suited.
The proposed changes to the housing allocation for the villages to the North will cause irreversible harm to the local biodiversity and character of the area. The proposed number of additional houses is huge in proportion to the existing size of the villages. No consideration of scale in the current proposal.
Assumptions that have formed the basis of the allocations are flawed, there a simply no buses so which buses will the new residents be using? The local bus runs between 10am and 2pm 4 days a week. That is not sufficient to sustain a viable community with work and wellbeing commitments. There is no shop in Loxwood so how is it a service village?
All in all the revised allocations are based on ill conceived notions and poor judgement and should not be adopted. The allocations made in 2018 were sensible, the increase in 2020 were excessive and the proposed increase in 2023 is frankly wrong and needs to be withdrawn.

Development allocations for the NE plan area have been set a High level of growth, an increase over a lower level advised by CDC in 2018. Whether or not the new increases to the NE plan area are delivered - they are insignificant at the district and county level - however they are massive at village level. The accumulative impact will make village dwelling numbers increase 30% to 70% over a 10 year period (from when these villages started Neighbourhood Plans) which risk irreversible change to their character. The area includes quintessential examples of the Sussex village which risk being lost in a development sprawl all the way beyond Crawley with few and dwindling gaps.

The policy does expect village development sites to be allocated through Neighbourhood Plans (NP) process, however the targets have been set by unsound assumptions and limited analysis of the HEELA process.

Proposed change:
The H3 policy should allow the NE villages to set their own levels of development through the NP process, from a target range set from the Lower growth values and the value in the March 2023 proposal. For example, Wisborough Green would have range 40 - 75 allocation, not the fixed and arbitrary 75.

With this change, the NE villages can use the more rigorous NP process of site evaluation, and can use the better and more local knowledge of resources to 'fine tune' the practical growth that each NP area can plan for.

The increased allocations for NE area are a direct reaction to the infrastructure issues surrounding A27 in the south. CDC are obliged to look elsewhere with 'no stone unturned', yet there is no comparable evaluation of infrastructure resources in the NE. The presumption is simply 'they can cope with more'.

The targets have been set by unsound assumptions.

The duty of co-operation with neighbouring authorities is only at macro level, and does not consider the relatively large impact to the NE area of the massive Billingshurst and Dunsfold developments - all within 3 miles of the NE villages.

The land should be allocated for residential development as requested above. It is a highly sustainable location and can contribute to the Councils housing land supply and boost housing delivery. The land can come forward for development in 2024 and a Full planning application is currently being prepared for submission in Summer 2023. This site can provide housing early in the development plan period.

Land at Graylingwell Hospital (Graylingwell Park) Kingsmead Avenue, Chichester granted outline planning permission for a primary school as part of 14/01018/OUT should be allocated for residential development. West Sussex County Council have confirmed that the school is no longer required. The the land is ideally suited to provide additional housing as part of the Graylingwell Park development.The land can accommodate approximately 100 dwellings a split of of Market and Affordable Dwellings.Flooding and Drainage issues have been resolved and Flood Modelling has been completed. Only a thin margin of Phase 10 is in the Floodplain. as shown on the attached plan.

Most of the sites in the 2021 HELAA were previously considered by CDC to be not suitable for development yet they are now considered to be so. There is no rationale for this decision. The Boxgrove NP is undergoing review and should be allowed to determine what is deliverable in the Parish not given an arbitrary housing number with no evidence to support its delivery.

There has been no consultation with parishes over the revised Parish Housing Requirements. Whilst the situation on the Manhood Peninsula is accepted there are equal issues in Boxgrove with over capacity on the A27, flooding and drainage issues , capacity at the local school and general lack of facilities.

Reduce the number of additional houses in Plaistow and Ifold to 10.

25 additional homes for Plaistow and Ifold is excessive as I don't believe there is a local need for so much housing. The existing infrastructure cannot support that number of houses: the rural lanes and roads are already strained and not being maintained, the water supply cannot sustain that number of houses, this will be a threat to the quiet, rural nature of the villages, in particular Plaistow.

Land West of Church Road (Northern Parcel) should be allocated for strategic development. Accordingly, the West Wittering Parish should be noted with a ‘*’

It is considered that ‘small-scale’ should be defined within the Policy, noting that 6 dwellings is the minimum for allocation but no guidance is given about when a site stops being ‘small-scale’ and becomes ‘strategic’ and to be included under Policy H2.

It is noted that West Wittering Parish is not apportioned development. As set out under objections to Policy H2 it is considered that Land West of Church Road (Northern Parcel) should be allocated for strategic development. Accordingly, the West Wittering Parish should be noted with a ‘*’

This housing need shortfall is exacerbated by the fact that the Plan fails to take account of the full potential of all of the new strategic locations within the District, such as Boxgrove. Indeed, there is an evidence base that supports the case that Boxgrove has the potential to accommodate a strategic level of housing growth, rather than the conclusion that it has limited capacity due to constraints – or the 50 homes proposed by CDC in Plan Policy H3.

Our client has prepared a Vision Document as part of a strategic promotion of the Land on Durbans Road (located on a relatively unconstrained site on the northern edge of Wisborough Green), which is attached in support of this representation. The Vision Document demonstrates there is sufficient capacity to deliver c. 50 additional dwellings within comfortable walking distance, via safe and convenient walking routes, of a range of local amenities. The Council have not fully justified the disproportionate level of housing for Loxwood against that of Wisborough Green and on this basis the draft Plan is at greater risk of being found ‘unsound’.

Our client is fully in agreement with the Council’s Vision and Strategic Objectives, with regard to the dispersal of growth to the more sustainable rural villages. However, the limited housing provision for Wisborough Green of 75 dwellings, against the 220 dwellings proposed for Loxwood (draft Policy H2) is not considered to be reflective of the constraints and sustainability credentials of these settlements.

We would encourage the Local Plan to allocate small-scale housing sites and or reconsider the redrawing of development boundaries surrounding non-strategic settlements to provide greater opportunities for windfall development.

In particular we respectfully request that the settlement boundary of Ifold be extended to include land to the rear of Felside, Chalk Road, RH14 OUD and the site allocated. In doing so, this represents a logical extension to Ifold, taking the settlement boundary up to the extent of existing rear gardens, wholly consistent with the limits of the settlement boundary elsewhere.

Whilst we are wholly supportive of the policy’s ambition to deliver new homes through small-scale housing sites, we raise concern with the approach proposed and its over reliance on sites being identified through the neighbourhood/community planning process. We contend the housing needs will not be met in an appropriate timeframe given the extensive levels of inputs and resources required to adopt an NDP.
We maintain that opportunities should be made for development to come forward through small scale allocations and/or through an encouragement of windfall development following extensions to development boundaries. Please refer to our supporting representation cocument attached.