Policy H8 Specialist accommodation for older people and those with specialised needs

As a solution, and assuming such a policy is justified (on which no comment is made) it is recommended that the policy is reworded in a similar way to Policy H6 (subject to our comments on that policy) to make it clear that provision of specialist accommodation on SDLs will be only expected where allowed for in the relevant allocation policy having been discussed and agreed with the relevant developer or site promoter.

We object to this policy as currently worded. Whilst recognizing there may be a need for specialist housing for older persons, the policy as worded runs counter to the provisions of the A6 West of Chichester allocation policy and masterplan for the site, neither of which include for specialist accommodation for older persons referenced in the West of Chichester Allocation policy. Miller and Vistry made comments on the regulation 18 plan (DM2 as was) to the same affect but have had no subsequent discussions with CDC about such a requirement. T
Notwithstanding the above, in response to comments from the Housing Officer to the phase 2 application, the phase 2 proposals do include a proportion of bungalows to cater for down sizers and older persons.

Recommendation
In order for Policy H8 to be more positively prepared to assist in delivering the substantial need for specialist housing for older people, policy H8 should be amended so that it reads as follows:

Policy H8 Specialist accommodation for older people and those with specialised needs

Specialist housing for older people

All housing sites over 200 units, including those allocated in this plan, will be required to provide specialist accommodation housing for older people.

The Council will also support proposals delivering specialist housing for older people across all tenures in sustainable locations. Specialist housing for older people should be located in in close proximity to everyday services, be well connected by safe and suitable walking / cycling routes or public transport for the intended occupier.

Specialist housing
Proposals for specialist housing, such as homes for, students, HMOs or essential worker accommodation37, and other groups requiring specifically designed accommodation will be supported where the following criteria are met:
1. There is an identified need;
2. It will not lead to a concentration of similar uses in an area that would be detrimental to the character or function of an area and / or residential amenity;
3. It is in close proximity to everyday services, connecting by safe and suitable walking / cycling routes or public transport for the intended occupier;
4. It can be demonstrated that the development is designed to provide the most appropriate types of support for the target resident;
5. It can be demonstrated that revenue funding can be secured to maintain the long-term viability of the scheme (if relevant to the type of accommodation proposed); and
6. The scheme is supported by the relevant agencies (if relevant to the accommodation type to be provided).

Proposals which may result in the loss of specialist needs accommodation will not be permitted unless it can be demonstrated that there is no longer a need for such accommodation in the plan area, or alternative provision is being made available locally through replacement or new facilities.

Policy H8 Specialist accommodation for older people and those with specialised needs

Thank you for the opportunity to comment on the Chichester Local Plan 2021-2039 Proposed Submission Draft (Regulation 19) consultation. McCarthy Stone is the leading provider of specialist housing for older people.

Whilst we are encouraged by ‘Policy H8 Specialist accommodation for older people and those with specialised needs’ we feel that trying to combine a policy on encouraging specialist housing for older people and specialist accommodation has resulted in a confusing policy that is not positively prepared. Given the substantial need for specialist housing for older people identified within the Chichester Housing and Economic Development Needs Assessment, 2022, Iceni (HEDNA) we feel the policy should be redrafted to make it clearer and more consistent with national policy as detailed in our response to policy H5 Housing Mix and specifically paragraphs 001 Reference ID: 63-001-20190626, 003 Reference ID: 63-003-20190626 and 006 Reference ID: 63-006-20190626 of PPG Housing for Older and Disabled People. This should ensure that some of the substantial need for specialist housing for older people is delivered without applicants having to consider policy requirements that would not be relevant for such schemes.

In addition, developers of older people’s housing schemes should not be required to demonstrate need given the substantial need identified.

At present, we do not consider the existing reference to “opportunities should be taken….” to be sufficient to really drive delivery. However, any final policy should allow for flexibility in the provision of suitable housing relative to the site in question. We would also like to see a more universal policy, which takes into account disability and other need requirements.

We consider this needs to be better defined. Given the demographic changes and if the district wishes to see a greater proportion of specialist older people’s housing delivered at low cost, greater clarity is needed.

We propose an amendment to policy H8 to confirm that specialist accommodation for older persons can 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. 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 comments included below from WSCC are Holding Objections. We will continue to work with Chichester District Council and as further work is completed will consider if objections can be withdrawn.

Transport Overview
The County Council has worked with Chichester District Council to develop the Chichester Local Plan and its supporting evidence base and will continue to do so. Although the overall direction of the Local Plan is supported, from a highways and transport perspective, there are three key issues remaining that need to be addressed in order to demonstrate that the Plan is sound:

1. There is insufficient evidence to demonstrate that key infrastructure (i.e. Terminus Road Diversion) will be deliverable;
2. The package of sustainable transport infrastructure and measures is not yet sufficiently well-developed to demonstrate that it is deliverable as part of the monitor and manage process; and
3. There is insufficient evidence to demonstrate that the capacity of the transport network can accommodate the scale of development proposed as part of the Southbourne Broad Location for Development.
The following sections explain; a) the reasons for these issues; b) why they affect the soundness of the Local Plan; and, c) what changes should be made to the Local Plan to remedy the issues.

Deliverability of Key Infrastructure

The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model for 2039 has been demonstrated to be capable in-principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, there are significant risks to deliverability of junction mitigation measures, which have required further work to be undertaken on developing a short to medium term strategy based on phased prioritisation of infrastructure and sustainable transport improvements, to be governed under a monitor and manage approach.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds the likely value of developer contributions and additional funding has not yet been secured.

At the Regulation 18 consultation stage in December 2018 to January 2019 the County Council identified delivery risks with the Stockbridge Link Road and Terminus Road Diversion schemes due to the earthworks likely to be required and to confirm the extent of land take required for both schemes. The County Council stated that feasibility work would need to be undertaken for these improvements prior to Plan submission to confirm that the schemes are deliverable. A brief for such a feasibility study was agreed in 2019, but to date, this work has not been commissioned. It is the County Council’s view that Stockbridge Link Road (SLR) should be disregarded as a potential part of a long-term transport mitigation strategy for 2039 and beyond until such time as it can be demonstrated that the scheme is deliverable. Paragraph 8.14 of the Local Plan acknowledges that the SLR is not deliverable as part of the Local Plan mitigation package.

The Terminus Road Diversion is still identified as part of the highest priority in the Local Plan mitigation package (i.e. A27 Fishbourne Junction) which is expected to be delivered once sufficient funding is collected. The County Council considers that in the absence of this feasibility work, the deliverability of the Terminus Road Diversion cannot be confirmed. In particular, given the recent impacts of inflation in the construction industry, this work will need to robustly estimate the costs and confirm delivery arrangements. In the absence of this feasibility work, there is currently insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF as key infrastructure does not appear to be deliverable.

In order to remedy this issue regarding the Terminus Road Diversion, the County Council requests that feasibility work is undertaken prior to the examination to confirm deliverability of the proposed Terminus Road Diversion.

Sustainable Transport Infrastructure & Measures

The transport study modelling for end of Plan period also includes some proposed highways mitigation schemes within Chichester City. The County Council has previously requested that these be replaced by sustainable transport improvements to comply with the West Sussex Transport Plan 2022-2036. However, only limited modification has been made to these proposed schemes, with a suggestion in text at paragraph 7.3.2 of the main transport study that the costs for these schemes can be reallocated to sustainable transport improvements which are not specified. Although this does help to explain how sustainable transport infrastructure schemes and measures can be at least partially funded, it is rare that schemes will be fully funded using developer contributions. Furthermore, funding is not the only issue that needs to be overcome to secure delivery of these schemes and measures.

The Infrastructure Delivery Plan (IDP) lists the proposed mitigation measures and in some cases provides information on the rationale, phasing, cost, funding and delivery arrangements. However, there are still many gaps in the information, probably because schemes are currently at an early conceptual stage. The County Council’s experience is that it is unlikely that schemes will be fully funded using developer contributions (because doing so would not be compliant with the CIL regulations) so delivery of these schemes will be partially dependent on securing funding from central Government or other sources. The IDP currently fails to identify the scheme-specific requirements for additional funding and the overall scale of additional funding required.

The County Council considers the level of information currently available on the sustainable transport package to be insufficient to demonstrate deliverability of a credible and coordinated sustainable transport package of improved infrastructure and services. Therefore, there is insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF.

In order to remedy this issue, the County Council requests that further technical work is undertaken to develop the schemes and measures in the sustainable transport package prior to the examination. In particular, this should focus on the following schemes and measures and some cases, this will build on work that has already taken place:
1. St. Paul’s & Parklands cycle routes
2. Improving existing public transport services towards Madgwick Lane
3. Provision of improved bus services for the village serving the development areas of Southbourne Parish
4. Improving cycling connectivity to link the built-out areas of Shopwhyke Lakes with Tangmere and Oving etc

As not all the severely impacted A27 junctions have a reasonable prospect of being physically improved in the Plan period, more investigation into potential public transport enhancements is also required, particularly to strengthen routes that cross the bypass. This may require further amendments to the IDP.

This work should aim to identify options for sustainable transport schemes that can be a priority for investment, provide information to enable safeguarding of routes (e.g. cycle routes) from development and provide a basis for applications for third party funding to support their delivery. The relative priority of such measures would need to be considered under the monitor and manage approach by the proposed Traffic and Infrastructure Management Group for implementation in addition to the proposed improvement at the A27/A259 Fishbourne junction.

To address this issue and support delivery of the sustainable transport package, the County Council also recommends the following minor amendments to Policy T1: Transport Infrastructure:

At bullet point .7 change “other small-scale junction improvements” to read “other sustainable transport and safety focused improvements, including at junctions” and change “These will increase road capacity, reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas” to “These will increase road capacity on strategic roads, and on both strategic and local roads reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas notably by encouraging and prioritising sustainable modes.”

Southbourne Broad Location for Development

The scale of development that can be accommodated at the Southbourne Broad Location will be, at least partially, dependent on the capacity of the transport network to accommodate the associated traffic movements. As the Broad Location spans the railway line, many of these traffic movements would need to cross the railway line. The County Council is concerned that there is currently insufficient capacity of the existing level crossings, notably at Stein Road, to accommodate the additional traffic movements. This could mean that the cumulative impact of development on the traffic network is severe, which is not consistent with Paragraph 111 of the NPPF.

The transport evidence base does not yet provide sufficient assurance that the proposed scale of development can be accommodated. This is because the base level of traffic flow has not been compared to local traffic counts, either in the initial validation of the strategic model or through a new count which the County Council has previously requested, and the assumptions about level crossing downtimes have not been validated against observed data. The County Council is concerned that the assessment of capacity of the local road network to accommodate the quantum of dwellings proposed for the Broad Location may be overoptimistic by underestimating existing flow levels and the duration of level crossing downtime. As a consequence, the proposed quantum may not be deliverable without unacceptable impacts to the conditions on Stein Road and to the level of traffic seeking to use rural lanes to the north of the village to avoid the level crossing.

In order to remedy this issue, the County Council requests that either additional transport evidence is provided prior to the examination to demonstrate that the proposed scale of development is deliverable, or that Policy A13 is changed to remove the proposed scale of development until such evidence is provided.

The following comments from education, minerals and waste, Adults Services and Health, highways & transport and public rights of way, do not affect the soundness of the Plan. However, Chichester District Council should take these into account and, where possible, make minor amendments to the Local Plan and/or evidence base studies before submission of the Local Plan for examination. Officers are happy to meet and discuss any of these comments, and proposed minor amendments to address these comments, ahead of submission:

1) Education

Land West of Chichester

Previous comments have been made requesting that the policy refers to ‘Phase 2 should include expansion of the primary school for the further 1FE of teaching accommodation with nursery and SEND provision’. While it is recognised that reference is made to this in the IDP this is a supporting document to the Local Plan and should not be solely relied on. It is requested that paragraph 10.19 is amended to read: ‘a local centre with retail, community and employment uses (minimum of approximately 2500 sqm E(g)(i) Use Class), two form entry (2FE) primary school and one form entry (1FE) teaching accommodation with nursery and SEND, informal and formal open space (including a country park), allotments,…’

This should also be included in the 3rd bullet point of Policy A6 or the wording of the policy should be drafted to reflect more recent policy requirements i.e. Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.

There are some inconsistencies with the wording of the strategic policies, not every policy includes the criterion ‘Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.’ While this may be due to some policies being carried through from the adopted local plan it is inconsistent.

Policy A8 Land East of Chichester

As an education authority WSCC do not request 1FE schools in line with government guidance. As per our earlier comments and discussions we requested a 2 FE primary school for the site.

3rd bullet point of Policy A8 should be amended to read: ‘A neighbourhood centre incorporating local shops, a community centre, flexible space for employment/ small-scale leisure uses and a one-form (expandable to two-form) two form entry primary school with provision for early years/ childcare and special educational needs and disability…’

2) Minerals and Waste

The references to safeguarding minerals is inconsistent and it is suggested that the wording in the email sent to CDC (attached) in relation to Policy AL3 should be used in the policies for the other sites for consistency. Reference to safeguarding minerals and waste infrastructure should also be included in some other policies as previously indicated:

• Policy A2 – needs to include reference to safeguarding minerals and waste infrastructure.
• Policy A7 – needs to include reference to safeguarding waste infrastructure.
• Policy A15 (Loxwood) – needs to include reference to minerals safeguarding as within the clay MSA.
• Policy A21 – needs to include reference to minerals safeguarding.

Also, the reference to the safeguarding guidance needs to be checked to ensure that it is worded correctly as ‘Minerals and Waste Safeguarding Guidance’.

3) Older Person Housing

It is noted that the plan refers to older person housing as specialist housing. WSCC strategy supports the provision of ‘extra care housing’ while this might be similar development it enables younger people to access the accommodation for whatever medical reason i.e. MS, strokes rather than limiting it to a certain age group. Officers are happy to meet and discuss this further.

4) Highways and Transport

Public Transport Priority Infrastructure

The Public Transport section of the main transport study report starting at paragraph 6.2.7 requires revisiting. There is reference to “an expansion of the bus priority lane system within Chichester City Centre” which does not match the existing bus provision in the City which does not provide bus priority lanes on street. It does have restrictions on motor traffic in the adjoining parts of South Street and West Street which provide for bus and cycle only access in both directions of travel plus access for essential goods vehicle loading in the westbound direction only. In addition, the suggestion in the following paragraph for “a time-based system where certain routes are restricted to public transport only during specific times” is not evidenced or developed and as such considered unlikely to be practical and enforceable at most locations used by bus routes in the City. More developed proposals for additional bus priority, improvements to bus passenger facilities or testing of specific locations for bus-only access would be welcomed as part of developing a costed sustainable transport mitigation package.

Park and Ride

The discussion of possible park and ride facilities for the City at paragraphs 6.2.9 to 6.2.16 of the main transport study should also acknowledge. An important part of making park and ride well used by motorists is increasing the price of city centre parking to provide a financial incentive to take up significantly cheaper park and ride charges for parking and travel. However, if park and ride sites are not provided accessible to all major approach routes to the city, such a charging strategy would not be seen to be equitable, whereas only a single site is proposed in the District Council’s emerging parking strategy and the report acknowledges at 6.2.11 that “locations for potential park and ride sites are also deemed to be limited”. The bullet at 6.2.15 “Cost of schemes compared to benefit are likely to be initially lower than highway schemes” may have been incorrectly worded given that this is listed as an issue rather than a benefit. The text may have been intended to say that the ratio of benefit to cost for park and ride schemes may be lower than for conventional highway schemes?

A286 New Park Road / A286 St Pancras Road (Junction 7)
This junction scheme includes pedestrian crossing facilities which are welcomed and also includes a length of advisory cycle lane starting in the middle of the junction for cyclists remaining on St Pancras. However, the approach to the junction on St Pancras from Eastgate Square remains intimidating to cyclists, so further measures would need to be added to make the layout cycle-friendly or the cycle facility is likely to be of limited benefit. This could include decreasing traffic speeds. Until this is done the conclusion at 8.4.4 of the main transport study; “The mitigation scheme includes improvements for pedestrians and cyclists which will lead to increased use of active travel modes and reduce the need for physical mitigation here” is only supported for pedestrians, not for cyclists.

A259 Via Ravenna / A259 Cathedral Way Roundabout (Junction 8)
It is stated at 7.3.8 of the main transport study that “the mitigation may be required to avoid queuing back towards the A27, as well as for capacity issues”. In light of this potential safety issue for the previous junction on Cathedral Way and for the A27 Fishbourne junction, the proposal at 7.3.6 that the scheme delivery should be tied to the monitor and manage regime to see if and when it is required is accepted. This is different to the approach for other junctions in the City because of the potential safety issue. This monitoring approach would be likely to follow after the A259 Cathedral Way / Fishbourne Road East / Terminus Road (as diverted) (Junction 10) improvement, which is to be brought forward as an integral part of the A27 Fishbourne roundabout mitigation scheme, but may allow for increased eastbound flows on Cathedral Way.

A286 Northgate Gyratory
An additional mitigation scheme is proposed at paragraph 7.3.134 of the main transport study for the A286 Northgate Gyratory along its southern arm from Oaklands Way to Orchard Street. The proposal to add traffic signals is welcomed in concept as it can help to control traffic speeds making the junction more friendly for cyclists and pedestrians. However, the layout shown at figure 7-8 does not maximise the opportunity to improve convenience and safety for pedestrians by providing a priority link to reach the central island, which contains employment space and the fire station, nor to assist crossing the exit towards Orchard Street. The scheme would benefit from further development to prioritise active travel movements and should also be fitted with transponders for bus priority.

Fishbourne Road West / Appledram Lane South (Junction 11)
At paragraphs 7.4.1 to 7.4.2 of the main transport study, the junction of Fishbourne Road West / Appledram Lane South (Junction 11) is considered. The proposal to mitigate impacts at this junction through delivery of the Stockbridge Link Road scheme is not considered deliverable, so the approach at this location requires re-thinking. The County Council would not support measures to increase capacity for through traffic on Appledram Lane South, the approach should be to reduce severance and improve safety and comfort for active travel on Appledram Lane by reducing vehicle speeds and as far as possible volume. This should consider the needs of pedestrians and cyclists both for local access and for users of the Salterns Way leisure cycling route.

TEMPro Background Traffic Growth Comparisons
At section 10.2 of the main transport study a comparison is made of the TEMPro 7.2 growth rates used in the study for external traffic with new TEMPro 8.0 growth rates since released by the Department for Transport, which notes that the TEMPro 8.0 rates are significantly lower, if these rates were used then the level of transport impacts could be lower. Unfortunately, a number of highways authorities in the Transport for the South East (TfSE) area including the County Council and Hampshire County Council have concerns that the planning assumptions used in TEMPro v8 core growth scenario underestimate the numbers of additional households forecasted compared to targets in adopted Local Plans for delivering new dwellings. TfSE are currently raising these collective concerns with DfT with a view to obtaining an early update to TEMPro 8 planning assumptions. Although for the purposes of this study TEMPro is not applied to trips produced in Chichester District, from the County Council’s analysis TEMPRo v8 core underestimates the increase in households per year in Arun District by over 50% and in Horsham District by 30% when compared with adopted development plans. On this basis it may be useful to instead compare TEMPro 7.2 with TEMPro 8.0 high growth scenario.

North of District Spatial Scenarios Testing
For the Northern Spatial Scenarios Test provided as an appendix to the main transport study, this had not been updated for the final preferred spatial strategy or in light of the County Council’s previous comments on the March 2022 issue to the District Council. The spatial strategy now is similar but not identical to the Scenario 4: Significant Growth 1 option in the reported tests, totalling 370 dwellings across the four northern parishes, compared to 410 in the test. In both cases the largest allocation is at Loxwood; 220 dwellings were proposed in the Scenario 4 as compared to 200 in this test. Some other tests proposed higher numbers.
The testing in the northern part of the district had used the same trip generation rates per dwelling as in the South of the District, but the County Council considers that in practice private motor vehicle trip generation per dwelling is likely to be higher due to the rural nature of the area, including a lack of local facilities and shops within walking distance of development, a very low level of public transport services and lack of surfaced cycle routes.
The level of development proposed is not at the level capable of delivering transformative transport improvements to match the trip making patterns around Chichester and the A259 corridor to Bosham and Southbourne. This may be offset in part by the lower total amount of development compared to the tested scenario 4. Nonetheless, it would be helpful to adjust the scenario for the spatial strategy now proposed and to provide information on additional traffic movements per peak hour from these parishes using the A272 at junctions at Wisborough Green and reaching the A272/A29 junction at Billingshurst and the A272/A283 junction at the north of Petworth.

Neutral Month and Summer Month Comparison Technical Note
The Neutral Month and Summer Month Comparison Technical Note in the main transport study treats July as a neutral month rather than a summer month. Paragraph 1.3.1 states “The flows were analysed by looking at traffic data for August 2019 this being considered to represent summer traffic. This was compared against traffic data from the neutral months of June, July, September and October also from 2019.” The County Council does not accept this methodology as school summer holidays start part way through July and education traffic is also affected by the formal exam period, whilst there is typically a high level of seasonal leisure traffic including summer outdoor events in this month. It is acceptable to use August alone as the summer comparator month. However, July traffic should be removed from the neutral months analysis and should be substituted with May traffic data from the same year of 2019, provided that sufficient data is available from that month.

5) Public Rights of Way (PRoW)

It is a positive step to see PRoW acknowledged as valued by communities and as part of the area’s green infrastructure. Whilst Policy P14 (Green Infrastructure) states that development proposals should not be detrimental to the network of public rights of way and bridleways (please note bridleways are Public Rights of Way), a more proactively positive approach that seeks enhancements to the network as mitigation, would be welcomed. The improvement, upgrading of existing PRoW and creation of new PRoW where possible, to allow for a greater number of users to access the network would be beneficial. This is somewhat addressed in Policy T1 which refers only to routes identified in the Local Transport Plan, Local Cycling and Walking Infrastructure Plan (LCWIP) and the Infrastructure Delivery Plan. Opportunities to these, should not be limited if they arise elsewhere.
It is surprising to see there is no mention of PRoW within Chapter 8 under Active Travel – Walking and Cycling. The PRoW network provides extensive walking and cycling opportunities, often off-road, and important links between places and non-PRoW routes.

Set out the level of need to be clear what is required

See attachment.

See attachment.

It is recommended Local Plan allocates sites to deliver this type of accommodation as intended by the HEDNA. Site promoted at Land to North of Gosden Green is suitable.

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.

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.

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.

Suggest first paragraph be amended to:
‘All New housing sites over 200 units, which are allocated in the Local Plan, will provide specialist accommodation for older people as set out in the relevant site-specific allocation policies. The specific type and amount of accommodation required will depend on the size and location of the site.’

See attachment.

We request that this policy is amended to add ‘where appropriate and viable’, acknowledging that viability and site-specific factors need to be taken into consideration.

We write in response to the above consultation on behalf of our client, the Church Commissioners for England (CCE). CCE owns a large amount of land in the area largely to the south, west and east of Chichester.
We welcome the opportunity to further engage with the Local Plan process. Whilst we support some aspects of the Local Plan, we consider that some changes are likely to be necessary to ensure that the Plan can be found sound.

By way of background, CCE submitted several sites for consideration as part of the Housing Economic Land Availability Assessment (HELAA) in 2021. These sites were previously promoted as part of the Preferred Approach Local Plan Regulation 18 Consultation in 2019.
As part of these representations, we take the opportunity to re-promote a number of CCE’s sites, which could assist the Council in delivering much needed housing for the district. CCE has updated its technical work and provide Vision Documents in relation to its landholdings in Southbourne, Oving, and Hunston Parishes to demonstrate how additional housing can be delivered. These Vision Documents are enclosed.
We consider this and other aspects of the emerging Local Plan below.

Chapter 2: Vision & Strategic Objectives

The Local Plan Vision details a positive approach to supporting sustainable development in the context of the climate emergency. CCE welcomes the Vision for Chichester, particularly the importance placed on the delivery of new homes in ‘Objective 3’ and the delivery of new infrastructure to support the new development in ‘Objective 7’.

Chapter 3: Spatial Strategy and Settlement Hierarchy

The Spatial Strategy builds on the previous Local Plan by focussing growth on Chichester city as the main sub-regional centre. Outside Chichester city and its closest settlements, development will focus on the two settlement hubs within the east-west corridor at Tangmere and Southbourne. This approach is supported by CCE.

Policy S1 Spatial Development Strategy

Draft Policy S1 (Spatial Development Strategy) identifies the broad approach to providing sustainable development in the plan area, which includes ensuring that new residential development is distributed in line with the settlement hierarchy, with a greater proportion of development in the larger and more sustainable settlements. We support this strategy, with particular support for development at the settlement hubs of Southbourne (Policy A13) and Tangmere (Policy A14). We also support that provision is made for extant Site Allocations and the Tangmere strategic site remains allocated under draft Policy A14.

Policy A14 continues to allocate Land West of Tangmere for 1,300 dwellings. CCE questions the Council’s decision to not amend the existing settlement boundary of Tangmere to include the land subject to the allocation. Without amending the settlement boundary, the future growth of Tangmere may be hindered. As such, the settlement boundary of Tangmere should be amended to include the allocated site to ensure that the plan is justified.

Draft Policy S1 also refers to development in service villages such as Bosham, Hambrook and Loxwood.
Hunston is excluded from the Spatial Strategy but is identified as a Service Village within the Settlement Hierarchy in draft Policy SP2 (Settlement Hierarchy). The draft Local Plan suggests that the allocation of homes in Hunston has been removed as a result of growth in the Manhood Peninsula. CCE acknowledges that the overall housing numbers across the district have been reduced as a result of local constraints but reiterate that their landholding in Hunston remains a suitable site for housing should the Council need to identify more land for housing. This is discussed further below.

Policy S2 Settlement Hierarchy

As stated in paragraph 3.31 of the draft local plan, ‘The NPPF encourages housing delivery where it will enhance or maintain the vitality of rural communities’. Paragraph 79 of the NPPF (2021) states that ‘To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby’.

CCE owns substantial land holdings in South Mundham, which is in close proximity to North Mundham/Runcton which is defined as a Service Village. As such, whilst South Mundham does not contain any services, development in the hamlet would enable sustainable growth to support facilities in North Mundham and Runcton. To ensure that the draft plan is consistent with national policy, South Mundham should be considered as part of North Mundham as a Service Village when considering the future pairing/grouping of some settlements where the facilities and services could be shared to capitalise on the close connections some settlements have.
Development outside the settlements listed in the hierarchy in SP2 is restricted to proposals which require a countryside location or meet an essential local rural local need or supports rural diversification in accordance with Policy NE10. To this end, CCE has smaller land holdings in Tangmere, Oving, South Mundham, Birdham, Chidham and Sidlesham, which may be suitable for conversion for residential use or via windfall housing. Location plans for each of the sites can be found in Appendices 1-8.

Chapter 4: Climate Change and the Natural Environment

Policy NE4 Strategic Wildlife Corridors

The East of City strategic wildlife corridor has been relocated to the eastern side of proposed Site Allocation A8 (Land to the East of Chichester). The relocation of this wildlife corridor follows additional evidence that shows that the commuting route for Barbastelle Bats is along Drayton Lane.

CCE owns land to the east of Drayton Lane (immediately adjacent to the wildlife corridor and to the east of draft allocation A8) and surrounding the village of Oving. Its land has been identified in the HELAA (2021) as being developable, including site HOV0017 (Drayton Lane). The land east of Drayton Lane is sustainably located being close to Chichester and its amenities. The site provides an opportunity to sensitively and sustainably provide additional homes for the District. In accordance with Draft Policy NE4, the proposals for the Land East of Drayton Lane will not have an adverse impact on the integrity and function of the wildlife corridor and will not undermine the connectivity and ecological value of the corridor. This Vision Document will be shared under separate cover.

The eastern edge of the relocated wildlife corridor encroaches into CCE land. Any proposal on this land would be required to take the statutory protection for bats and other protected species into consideration and managed as part of a sensitive masterplan for development and on this basis, it is considered unnecessary to extend the wildlife corridor to encroach into the CCE site.

It is also considered that the detail of policy NE4 goes beyond the purpose of the policy, which should be to safeguard wildlife rich habitats and wider ecological networks. The policy is clear that development should only be permitted where it would not create an adverse effect upon the ecological value, function, integrity and connectivity of the corridors. It does not resist development in principle. This therefore makes redundant policy text 1, which seeks to introduce a sequential test for preferable sites outside of a wildlife corridor. It is considered that this test conflicts with the underlying purpose of the policy, which is to safeguard wildlife corridors from harmful impacts that cannot be mitigated, and should therefore be deleted.

Policy NE7 Development and Disturbance of Birds

CCE is broadly supportive of Policy NE7. However, they would like to note that the situation regarding the national guidance on nutrient neutrality is still evolving and therefore, this policy is only relevant to current legislation. Policy NE7 may therefore not be relevant throughout the entirety of the plan period. As such, CCE considers that it is necessary in this instance to ensure that an appropriate reference to changing legislation is included within the policy to prevent it from becoming out of date and would also ensure that the policy remains effective once adopted.

Policy NE10 The Countryside

CCE is supportive of the inclusion of a policy referencing the conversion of existing buildings in the countryside, however, we believe that Policy NE10 is not consistent with national policy. Policy NE10 criteria B states that proposals for the conversion of buildings in the countryside will be permitted where ‘it has been demonstrated that economic and community uses have been considered before residential, with residential uses only permitted if economic and community uses are shown to be inappropriate and unviable’. This policy is not in accordance with Paragraph 152 of the NPPF (2021) which states that the reuse of existing resources should be encouraged, including ‘the conversion of existing buildings’. Under paragraph 152, there is no prerequisite to adopt a sequential approach, or to give preference to other uses. As such, criteria B should be omitted from Policy NE10. Reference to criteria B should also be removed from criteria C.

Chapter 5: Housing

Policy H1 Meeting Housing Needs

The Preferred Approach Local Plan was based on meeting the identified objectively assessed housing needs of the plan area of 638 dwellings per annum. However, due to constraints, particularly the capacity of the A27, the Submission Version of the Local Plan has planned for a housing requirement below the need derived from the standard method. The Plan proposes to deliver 535 dpa in the southern plan area and a further 40 dpa in the northern plan area, a total supply of 10,350 dwellings over the plan period from 2021 – 2039 (575 dpa).

The Planning Inspectorate has previously asked the Council to determine what level of housing could be achieved based on deliverable improvements to the A27 and to consider whether the full housing needs could be met another way. It is acknowledged that the Council has carried out the additional work required and the local constraints have resulted in a proposed lower housing requirement.

The NPPF (2021) confirms 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 – unless exceptional circumstances justify an alternative approach (para. 61). CCE acknowledges that that housing numbers have been reduced as a result of local constraints and it will be down to the Inspector to determine whether the Council’s exceptional circumstances justify this. Should the Planning Inspector find that the Council requires additional land to meet the housing need using the standard method, CCE’s land at Southbourne, Oving, Drayton Land and Hunston are suitable, available and developable for housing. In addition, CCE’s rural development sites could also contribute to meeting the housing need.

Policy H2 Strategic Allocations

Draft Policy H2 confirms that the Tangmere Strategic Development Location is carried forward from the 2015 Local Plan and this is supported by CCE. Strong support is also given for the Broad Location of Development in Southbourne (Policy A13) for up to 1,050 dwellings.

Policy H5 Housing Mix

Draft Policy H5 confirms that the housing mix for a development will be based on the most up to date HEDNA to address identified local needs and market demands. We suggest that the Council considers a range of criteria, including site characteristics, when determining the housing mix for individual sites and this should be reflected in wording of Policy H5.

Policy H7 Rural and First Homes Exception Sites

Draft Policy H7 relates to rural and first homes exception sites. CCE is supportive of the principle of the inclusion of a rural exceptions policy. However, we have concerns over criteria contained within the policy which limits the amount of development that can be delivered under it.

The NPPF (2021) at paragraph 78 states that planning policies and decisions should be responsive to local circumstances and support housing development that reflect local needs. Furthermore it also states that ‘local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs’.

The key aspect of the policy is to enable the delivery of rural exception sites which would address an identified local need. Within the policy, there is no limit on the amount of development that can be delivered and therefore, it is considered that if Policy H7 is limited to a maximum of 30 dwellings it could serve to hinder development (especially on slightly larger sites), which would otherwise be sustainable. As such, we consider that the amount of development should not be limited and rather should be dictated on a site and need specific basis. CCE considers that for Policy H7 to be positively prepared and in accordance with National Policy, criteria 2 should be removed.

In addition, criteria 6 states that proposals for affordable housing on rural exception sites will only be supported where ‘the site is located adjacent or as close as possible to the existing settlement boundary and does not result in scattered or isolated development in rural areas’. The NPPF (2021) does not specify the location of rural exception sites. As such, to be consistent with national policy, criteria 6 should also be omitted.

Furthermore, Policy H7 states that ‘applications for first homes exception sites that propose the inclusion of a small proportion of market housing will be expected to provide robust evidence…’.
However, in the policy there is no allowance for the provision of market housing on rural exception sites in addition to first homes exception sites. As a result of this, the requirements of the policy are again not consistent with national policy. Paragraph 78 of the NPPF (2021) is supportive of ‘some market housing’ where it would facilitate the delivery of rural exception sites. As such, CCE considers that Policy H7 should be amended as follows:

‘Applications for rural and first homes exceptions sites that propose the inclusion of a small proportion of market housing will be expected to provide robust evidence that the site would be unviable without such housing being included’.

Policy H8 Specialist Accommodation

Draft Policy H8 confirms that all housing sites over 200 units, including those allocated in this plan, will be required to provide specialist accommodation for older people with a support or care component. We request that this policy is amended to add ‘where appropriate and viable’, acknowledging that viability and site-specific factors need to be taken into consideration.

Chapter 6: Place-making

Policy P3 Density

We support the objective of Draft Policy P3 (Density) to make the most efficient use of land and follow a design led approach to achieve the optimum density for a site. The Policy does not prescribe an appropriate density for the District and this is supported. However, we consider that reference should be made to the fact that density may vary depending upon site specific circumstances and could be higher where transport links and access to services is good.

Chapter 7: Employment and Economy

Policy E3 and E4 Horticultural Development

Chapter 7 of the draft Local Plan confirms that 67 hectares of land is identified to meet the future horticultural land need within four Horticultural Development Areas (HDAs) over the plan period. It is confirmed that an additional 137 hectares of horticultural land is also forecast to be required outside of HDAs to meet future need.

CCE has significant landholdings which could assist the Council in addressing the insufficient availability within the current HDAs. The CCE sites which are considered suitable for horticulture development are listed below and location plans for each of the sites can be found in Appendices 9-13.
• Somerley Farm, NE East Wittering, PO20 7JB
• Fisher Farm, South Mundham, PO20 1ND
• Church & Haise Farm, Sidlesham
• Cowdry Farm, Birdham
• Groves Farm, nr Merston, PO20 2DX / Colworth Manor Farm PO20 2DU.

CCE supports draft Policy E3 which confirms that “approximately 137 hectares of land is also needed outside of HDAs to meet anticipated horticultural and ancillary development land need for the plan period.” Support is also given for draft Policy E4 in relation to land outside HDAs. This Policy confirms that proposals for horticultural development can come forward outside the HDAs, subject to a set of criteria. We would welcome continued discussion with the Council on how these sites could help meet the districts horticultural needs in the future.

Chapter 10: Strategic and Area Based Policies

CCE supports Chichester District Council’s proposal to allocate additional land for housing at
Southbourne and to maintain the existing allocation at Tangmere. We also consider that CCE’s land at Hunston and Oving could assist the Council in meeting its housing needs, should additional housing be required. We consider these opportunities in turn below.

Policy A13 Southbourne Broad Location for Development

CCE supports draft Policy A13 and the allocation of a Broad Location for Development in Southbourne for a mixed-use form of development including 1,050 dwellings.

CCE has significant landholdings around Southbourne which is suitable, available and developable. The land to the north and west of Southbourne measures 70ha and is wholly within CCE’s control. The land adjoins the existing settlement and provides an opportunity for a sustainable extension to Southbourne with the potential to deliver c. 1,200 homes for the village, as well as employment, community uses and a significant amount of new public space and green open space. A new Vision Document is enclosed which explains one way in which this opportunity could be realised. Importantly, it is considered that there are no technical impediments that would prevent development from coming forward on this site.

This site has been promoted throughout the Southbourne Neighbourhood Plan process, most recently in the December 2022 consultation. The new Vision Document demonstrates that the CCE site presents the opportunity to provide a comprehensive development that would contain strategic housing growth, significant areas of green infrastructure and open space in a sustainable location. The key access strategy for the site is to provide two new access points from the south A259 Main Road and the east Stein Road. These access points would connect to a spine road which would form a continuous vehicle route around the north-western edge of Southbourne.

The site almost entirely comprises a Secondary Support Area under the Solent Waders and Brent Goose Strategy (SWBGS), which aims to protect the network of non-designated terrestrial wader and brent goose sites that support the Solent Special Protection Areas (SPA) from land take and recreational pressure associated with new development. Due to the designation of the site, discussion was undertaken with the Hampshire and Isle of Wight Wildlife Trust with a view to determine a suitable approach for the scheme and an appropriate survey effort to establish the use of the site by designated birds. As a result of these discussions, wintering bird surveys are taking place. The aim of these surveys is to explore opportunities for mitigation for this SWBGS support area such that development within the red line can proceed without adverse impacts to the bird populations noted within this strategy. Following the survey, the results and approach will be presented to Natural England for further discussion.

In relation to viability, we note that Policy A13 sets several policy objectives for development at Southbourne. The NPPF (2021) notes that where there are up-to-date policies which have set out the contributions expected from development, planning applications that comply with them should be assumed to be viable (para. 58). With this in mind the policy objectives outlined within Policy A13 will require viability testing to be undertaken to ensure a policy compliant scheme is both viable and deliverable. This is necessary to ensure that the policy is sound.

The Policy suggests that employment opportunities are required to be delivered as part of the allocation but there is no specific reference to the amount of use required. CCE supports this proposed approach as it is sufficiently flexible to enable an amount of employment land to be proposed in response to market conditions at the appropriate time and this will help to support delivery of the allocation.

The scale of development proposed has been reduced from 1,250 to 1,050 dwellings to reflect the proportionate reduction in housing numbers across the parishes in the east west corridor as a consequence of the limit on numbers in the southern plan area. If the Inspector finds that additional housing is required, the Vision Document submitted demonstrates that the CCE site in Southbourne could deliver c. 1,200 homes and so could increase housing without needing to identify additional land for development elsewhere.

To summarise, the site could accommodate approximately 1,200 homes which could be delivered on a phased basis early in the plan period. There are no overriding physical or technical constraints that would act as an impediment to development. There is also a clear access arrangement proposed.

Policy A14 Land West of Tangmere

CCE supports that Policy A14 is carried forward into this Local Plan to facilitate the delivery of a residential-led development of at least 1,300 dwellings.

Additional sites

Hunston

CCE further promotes land (15.31ha) located east of the B2145 Selsey Road in Hunston for 240 new homes. The land is deliverable and is fully within CCE’s control. The site is highly accessible, located within a maximum of 5-6 minutes walking distance to Selsey Road, where several bus routes connect the village to Chichester.

CCE notes that the Council assessed the HELAA site (ref. HHN0016) as ‘developable’. A Vision Document has previously been prepared and submitted to demonstrate the commitment to it being brought forward for residential development within the plan period. This document is enclosed.

To address the Council’s concerns in relation to flooding, following publication of the Chichester Strategic Flood Risk Assessment (SFRA), we have prepared an updated Flood Risk Scoping Study which provides an overview of flood risk constraints across the site from a range of sources. Various mitigation measures are recommended in line with recommendations of the Chichester SFRA and prevailing local and national guidance and best practice. With these measures in place, it is likely that the flood risk could be managed effectively in accordance with the requirements of the NPPF. Detailed data has also been requested from the Environment Agency, which will feed into further technical work that is being carried out.

Should the Inspector conclude that additional housing is required, CCE considers that their site is the most appropriate and sustainable location for development in Hunston. The site provides an opportunity to sensitively and sustainably extend the existing village boundary to provide additional homes to meet an identified housing need.

Land East of Drayton Lane

CCE owns land to the east of Drayton Lane which is bound by Tangmere Road to the north and crosses Oving Road and the railway line to the south. The site is c.1km from the centre of Chichester and comprises 49ha. The site was assessed in the HELAA 2021 as developable ‘HOV0017’. A Vision Document has been prepared and was presented to the Council in 2022. This includes a detailed analysis of the site and its surroundings and provided justification as to why the site is suitable for development. This technical review of the site concludes there are no technical impediments to development.

The Vision Document demonstrates how the proposals for the land east of Drayton Lane could be developed as an extension to the draft allocation A8 (Land to the east of Chichester) for up to 700 new homes. The land east of Drayton Lane is fully within the CCE’s control, is available for development now and is deliverable with some development achievable within the first five years of the plan period. It represents an opportunity to provide new homes, facilities and significant community benefits, through a sensitively designed development that integrates into the surrounding landscape.

The Vision for this site is a landscape and ecology led masterplan which would celebrate the rich wildlife characters of the different surrounding landscapes and uses the connection between countryside and community to generate its character and identity. The Vision Document demonstrates that this is a suitable location for development.

Should the Inspector conclude that additional housing is required, CCE considers that the land east of Drayton Lane would form a natural extension to allocation A8 and is an appropriate and sustainable location for new development.

Appendix C Additional Guidance
Appendix C provides additional guidance on evidence which needs to be submitted in support of certain planning applications related mainly to development in the countryside. As mentioned in the comments above provided in response to Policy NE10, there is no prerequisite contained within the NPPF (2021) that requires an applicant to demonstrate that previous uses were proven unviable prior to the conversion of a building in the countryside to residential use. As such, to be in accordance with national policy, reference to Policy NE10 should be omitted from Appendix C.

Conclusion

CCE welcomes the opportunity to comment on the Local Plan and is keen to continue to engage with the Council, especially in relation to the Broad Location for Development in Southbourne. CCE is supportive of the Council’s aspirations in the Local Plan. However, the changes set out above are considered likely to be necessary to ensure the plan is sound.

CCE is a considerable landowner in Chichester with land largely to the south, west and east of
Chichester which could assist the Council in meeting their housing and development needs throughout the plan period.

See attachments for site information.

It is considered that a residential care home (including housing for dementia needs) could be developed on the Land South of Main Road without causing harm to the AONB and this would provide for a clear need within the village whilst also providing employment to local workers.

I write in response to the regulation 19 consultation version of the Chichester Local Plan 20212039 on behalf of my client Obsidian Strategic.

Obsidian Strategic have an interest in a site to the South of Main Road, in Hermitage, within the Southbourne Neighbourhood Plan Area. Further details in relation to the site are set out within the appendices of these representations and referred to throughout.

Housing Requirement

The identified housing need for Chichester District Council (CDC) as calculated by the standard method is 638 dwellings per annum (dpa). However, the local plan only seeks to provide 575 dpa or a total supply of 10,350 over the plan period (2021-2039). As result the proposed strategy represents an under supply of 1,134 over the plan period. Furthermore, the undersupply means that CDC is unable to accommodate the unmet arising from the South Downs National Park.

In recent years CDC has not been able to demonstrate a five year housing land supply nor has it delivered housing against the requirements of the Housing Delivery Test. It is therefore important that the unmet need is made up within the early part of the plan period.

Paragraph 5.2 of the plan states that the under supply is due to constraints across the district particularly the capacity of the A27.

Policy H1 (Meeting Housing Needs) sets out the housing target of 10,350 dwellings to be delivered over the plan period 2021-2039. Considering the existing commitments, allocations and permissions this gives a remaining figure without planning permission of 3,056 homes for allocation in the Local Plan.
Strategic Allocations
Policy H2 of the reg 19 plan sets out the following strategic site allocations which are carried forward from the 2015 Local Plan:

**Table**

Table 11 of the latest Annual Monitoring Report (AMR) (produced in November 2022) show the progress of delivery from these allocations:

**Table**

Table 12 of the AMR sets out the progress of the large sites towards future delivery as follows:

**Table**

The Housing Trajectory as set out in Appendix E of the Local Plan shows delivery of the existing allocations as set out under policy H2. Given that the Land at Shopwyke (A7) and the Land at Westhampnett/North-East Chichester (A9) already have permission for the number of dwellings in the allocation and construction has already started, there is no objection to the predicted levels of delivery as set out in the trajectory.
However, the housing trajectory sets out delivery from the Land West of Chichester (Phase 2) (A6) and Tangmere SDL as follows:

**Table**

Given that neither of these sites have outline permission then the delivery of units from both sites in a little over 5 years from the adoption of the plan is considered wholly unachievable.

CDC has presented no evidence to justify how this timeframe would be achieved and it is considered that the trajectory is unreliable as a result.


The Local Plan sets out a Broad Location for Development at Southbourne which would be delivered through either the Neighbourhood Plan process or a Site Allocation DPD:

**Table**

The Housing Trajectory as set out in appendix E of the Local Plan sets out the following delivery from this site:

**Table**

Given that policy A13 remains as a ‘broad area for development’ it is not considered that there is adequate justification for the trajectory as set out. Notwithstanding the effectiveness of allocating a site in this way, an exact location for the housing is yet to be defined, nor is delivery through the neighbourhood plan/DPD confirmed (further details on this is set out within the reps). Until a more detailed site can be defined and delivery confirmed it is not considered that CDC is able to guarantee delivery of dwellings in the housing trajectory as it has done so within the plan.

Non-Strategic Parish Housing Requirements
Policy H3 sets out the following housing requirements from individual parishes.

**Table**

The supporting text of policy H3 sets out that 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.

Table 13 of AMR identifies that there has been historically poor delivery of net housing completions from parishes:

**Table**

The overall strategy as set out by CDC in the plan is highly dependent on the delivery of housing from Neighbourhood Plan areas. Whilst this approach is not un-sound in itself, it is considered that the plan in its current form allows for little mitigation or alternatives should delivery not come forward in the neighbourhood plan areas.

In order for the plan to be considered positively prepared and justified it is recommended that additional wording is added to policy H3 to state that individual applications can come forward on sustainable sites outside of existing settlement boundaries in parishes should delivery not come forward within the first five years of the plan period. Priority should be given to any sites already identified within draft versions of Neighbourhood Plans.

on sustainable sites outside of existing settlement boundaries in parishes should delivery not come forward within the first five years of the plan period. Priority should be given to any sites already identified within draft versions of Neighbourhood Plans.
Southbourne
As set out, the Local Plan proposes a ‘Broad Location for Development’ at Southbourne for the delivery of 1,050 dwellings. This approach follows the withdrawal of the previously draft version of Neighbourhood Plan after it was found not to comply with basis conditions following examination in early 2022. Southbourne Parish Council is now pursuing a revised Neighbourhood Plan which has been submitted to CDC for a regulation 16 consultation. Obsidian previously responded to the regulation 14 consultation in late 2022 and these are appended to these representations.
The revised Southbourne Neighbourhood Plan does not seek to allocate any new housing allocations and instead takes a protectionist stance against any new development as an interim position whilst the Local Plan is prepared. However, once the Neighbourhood Plan is made, it would form part of the development plan for CDC. It is highly likely that a made Neighbourhood Plan in the form currently proposed by Southbourne would make the allocation of additional housing in the parish less likely rather than more likely.
The Sustainability Appraisal (SA) as prepared for the regulation 19 of the Local Plan sets out the proposed approach to Southbourne as follows:
3.1. With the decision of Southbourne Parish Council to no longer proceed with the inclusion of a strategic allocation in their neighbourhood plan, the Council considered three options for taking forward development in Southbourne, namely:
• Option 1 - redistribute the housing number elsewhere
• Option 2 - allocate a strategic site
• Option 3 - identify a Broad Location for Development
The SA goes on to set out the reason for option 1, for redistributing the housing number elsewhere, being discounted as follows:
3.2. As set out in the Housing Background Paper, the preferred spatial strategy is to focus the majority of growth at Chichester and the east west corridor, with a focus on the Settlement Hubs within the corridor. To redistribute the housing number to other parts of the plan area would not be consistent with the preferred spatial strategy nor reflective of the role of Southbourne as one of the more sustainable locations in the plan area capable of delivering strategic scale development. The ability to redistribute the number to other locations within the east/west corridor is also severely limited due to infrastructure constraints (impact on A27 junctions) or environmental restrictions (wastewater treatment capacity). For these reasons, Option 1 was discounted.
Whilst it is accepted that the redistribution of the entire requirement of 1,050 homes would be problematic, it is considered that CDC should have tested the allocation of other alternative sites such as that at Main Road, Hermitage and other suitable alternative sites.
The SA goes on to set out consideration of option 2 as follows:
3.3. In order to allocate a site in a Local Plan, it needs to have gone through a rigorous process to ensure that the Council can demonstrate that the allocated site is suitable, given reasonable alternatives, and is based on proportionate evidence. Given there is more than one site or combination of sites that could come forward as an allocation in Southbourne, a clear process setting out for why one site was chosen over another would be needed, informed by site specific technical information.
This is correct and it is therefore not accepted that an approach to allocate a broad area for development would be robust, deliverable or effective. The SA goes on to state:
3.5. The allocation of a strategic site at Southbourne would also be a significant change in approach at a late stage of the Local Plan preparation process. The additional technical evidence that would need to be undertaken to justify a Local Plan allocation at this stage would impact significantly in terms of delay to the finalisation of the Regulation 19 Local Plan and its subsequent submission to the Secretary of State for examination. For these reasons Option 2 was discounted.
This provides further weight to the position set out within these representations that the expectation of delivery from the ‘broad area’ at Southbourne is overly ambitious and it is clear there is significant technical work to undertake on the delivery of homes from the allocation as part of the future plan making process.
The SA goes on to set out the justification of option 3 as follows:
3.6. The identification of a BLD is consistent with the National Planning Policy Framework (NPPF). Paragraph 68 states that for years 6 -10 of the plan, local authorities should through their planning policies identify a supply of ‘specific, developable sites or broad locations for growth’.
3.7. There is no definition of ‘broad locations’ in national policy. It is generally taken to be an area within which housebuilding could reasonably be expected to take place based on the availability of land having regard to the Housing and Economic Land Availability Assessment (HELAA). A BLD does not have a specific geographic location or physical boundary. Areas are identified as broad locations because at that stage it is not yet possible to identify the precise boundaries of a site until further detailed site work has been done. By identifying a broad location gives flexibility and may increase the prospect of appropriate and effective growth i.e. where there is some doubt as to the most effective site boundary could prevent growth coming forward or prevent the most sustainable solution. However, a broad location might be expected to accommodate a significant amount of development; in some cases a single site may be of a sufficient size to accommodate all of the potential development or a number of sites that abut other sites may be considered together.
This is not considered a rational approach to take. Whilst there is no definition of ‘broad location’ within national policy it is considered that the words ‘specific’ and ‘developable’ must be taken at their basic meaning and indeed as set out in the glossary of the framework. It is not considered that the allocation of such a large area for a ‘broad location’ would be specific, effective or justified against the tests of soundness in the NPPF.
The allocation of Southbourne under policy A13 would represent over 10% of the total housing delivery in the plan. This is considered too significant to leave to a broad location for development.
As set out, Southbourne Parish Council is already at advanced stages of a revised Neighbourhood Plan which does not include the allocation of any of the development parcel envisaged under policy A13. In terms of delivery through the Site Allocations DPD, the timetable for this is set out within the most recent Local Development Scheme (January 2023) which sets out the following:

**Table**

As set out, the housing trajectory assumes delivery of dwellings from the allocation at Southbourne in 2028/29. Given that the Site Allocation DPD would not be delivered until Winter 26/27 at the earliest, and the delivery through the Neighbourhood Plan has been discounted by the progression of a NP without the allocation, then the deliverability of any development at Southbourne remains wholly unjustified within the plan period.
The SA goes on to set out the approach to alternative sites in Southbourne Parish as follows:
4.3. The 2021 HELAA assessed 41 sites in Southbourne Parish (see Appendix 1). Of these, 18 sites were discounted because the site either had planning permission/were under construction (five sites); it was within the Chichester Harbour Area of Outstanding Natural Beauty (AONB) (eight sites); there was insurmountable access issues (two sites); it was in Flood Zone 3 (one site); or there was a legal restriction on the site use (in this case a Section 106 Agreement restricting use to open space) (two sites). These sites were not considered further for inclusion within the BLD.
The land at Main Road was one of the sites discounted due to being located in the AONB. For the reasons set out within subsequent sections of these representation, it is not considered that it was necessary to discount sites within the AONB as other councils have taken the decision to use such sites to meet housing need and not considered the AONB as an absolute constraint.
Specialist Accommodation for Older People
Para 5.41 of the regulation 19 of the Plan sets out the following:
The Housing and Economic Development Needs Assessment (HEDNA) 2022 estimates the greatest population increase in the district by 2039 to be those in age groups 75 and over. To support an ageing population there should be provision of suitable housing options for the differing needs of individuals, including:
• Sufficient adaptable and/or accessible market housing stock so that those wishing to remain in their own homes can do so as their needs change.
• Smaller homes, for those wishing to downsize, and bungalows.
• Extra care housing, for those able to live relatively independently but requiring on-site support.
• Care homes, for those needing additional support.
Table 8.1 of the HEDNA sets out the current population breakdown for separate groups over 65 and demonstrates that CDC has a significantly higher percentage in all age groups over 65 than the average in West Sussex, the South East or England:

**Table**

Policy 8.12 of the HEDNA goes on to set out the need for different groups as follows:

**Table**

The HEDNA sets out the following commentary in this regard:
8.41 It can be seen by 2039 there is an estimated need for between 2,131 and 2,872 additional dwellings with support or care across the whole study area. In addition, there is a need for 429-800 additional nursing and residential care bedspaces.
8.42 Typically for bedspaces it is conventional to convert to dwellings using a standard multiplier (1.80 bedspaces per dwelling for older persons accommodation) and this would therefore equate to around 238-445 dwellings.
8.43 In total, the older persons analysis points towards a need for around 2,369-3,317 units over the 2021-39 period (132-184 per annum) – the older person need equates to some 17-24% of all homes needing to be some form of specialist accommodation for older people.

Given the significant need for Specialist Housing Accommodation across the district it is vital that this is planned for adequately within the emerging Local Plan. The Planning Practice Guidance sets out why it is important to plan for housing needs of older people as follows:
The need to provide housing for older people is critical. People are living longer lives and the proportion of older people in the population is increasing. In mid-2016 there were 1.6 million people aged 85 and over; by mid-2041 this is projected to double to 3.2 million. Offering older people a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social care and health systems. Therefore, an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking.
Paragraph: 001 Reference ID: 63-001-20190626 Revision date: 26 June 2019
The PPG goes onto state how housing requirements of such groups should be addressed in plans:
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 planmaking authority will consider proposals for the different types of housing that these groups are likely to require. They could also 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.
Paragraph: 006 Reference ID: 63-006-20190626 Revision date: 26 June 2019
Policy H8 states:
All housing sites over 200 units, including those allocated in this plan, will be required to provide specialist accommodation for older people to include a support or care component. The specific type and amount of accommodation required will depend on the size and location of the site.

Proposals for specialist housing, such as homes for older people, student, HMOs or essential worker accommodation, and other groups requiring specifically designed accommodation will be supported where the following criteria are met:

1) There is an identified need;
2) It will not lead to a concentration of similar uses in an area that would be detrimental to the character or function of an area and / or residential amenity;

3) It is in close proximity to everyday services, connecting by safe and suitable walking / cycling routes or public transport for the intended occupier;
4) It can be demonstrated that the development is designed to provide the most appropriate types of support for the target resident;
5) It can be demonstrated that revenue funding can be secured to maintain the longterm viability of the scheme (if relevant to the type of accommodation proposed); and
6) The scheme is supported by the relevant agencies (if relevant to the accommodation type to be provided).

Proposals which may result in the loss of specialist needs accommodation will not be permitted unless it can be demonstrated that there is no longer a need for such accommodation in the plan area, or alternative provision is being made available locally through replacement or new facilities.

Whilst this approach goes some way to addressing the care needs it is felt that the policy lacks effectiveness and should take a far more constructive and positive approach to the provision of housing for older people.
The wide range of different housing typologies is set out within the Planning Practice Guidance as follows:
• Age-restricted general market housing: This type of housing is generally for people aged 55 and over and the active elderly. It may include some shared amenities such as communal gardens, but does not include support or care services.
• Retirement living or sheltered housing: This usually consists of purpose-built flats or bungalows with limited communal facilities such as a lounge, laundry room and guest room. It does not generally provide care services, but provides some support to enable residents to live independently. This can include 24 hour on-site assistance (alarm) and a warden or house manager.
• Extra care housing or housing-with-care: This usually consists of purpose-built or adapted flats or bungalows with a medium to high level of care available if required, through an onsite care agency registered through the Care Quality Commission (CQC). Residents are able to live independently with 24 hour access to support services and staff, and meals are also available. There are often extensive communal areas, such as space to socialise or a wellbeing centre. In some cases, these developments are known as retirement communities or villages - the intention is for residents to benefit from varying levels of care as time progresses.
• Residential care homes and nursing homes: These have individual rooms within a residential building and provide a high level of care meeting all activities of daily living. They do not usually include support services for independent living. This type of housing can also include dementia care homes.
[Paragraph: 010 Reference ID: 63-010-20190626].

It is considered that a residential care home (including housing for dementia needs) could be developed on the Land South of Main Road without causing harm to the AONB and this would provide for a clear need within the village whilst also providing employment to local workers.
Development in AONB
The NPPF sets out the following in relation to development in the AONB at paragraph 172 as follows:
Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development55 other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:
a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated
Footnote 55 of paragraph 172 is relevant for the consideration of what is considered as major development and states:
For the purposes of paragraphs 172 and 173, whether a proposal is ‘major development’ is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the purposes for which the area has been designated or defined.
No evidence is set out within the Local Plan or supporting evidence base to state what is considered to be a major development site in the district. Neither the Chichester Harbour AONB: State of the AONB Report (May 2018) or the Chichester Harbour AONB Landscape Character Assessment (April 2019) contain any references to what is considered to constitute a major development.
This is a matter which has been considered at length within other Local Plan examinations. As part of the evidence for its Local Plan, the South Downs National Park sought successive legal opinions from James Maurici QC on what should be considered as ‘Major Development’ in the AONB and have subsequently become widely known as the ‘Maurici Opinions’ in other Local Plan examinations. The opinions set out the following conclusions:
• It is a matter of planning judgement to be decided by the decision maker.
• Major development is to be given its ordinary meaning, and it would be wrong to apply the definition of major development contained within the Town and Country Planning (Development Management Procedure) (England) Order 2015. It would also be wrong to apply any set or rigid criteria for defining major development, and the definition should not be restricted to development proposals that raise issues of national significance.
• The decision maker may consider whether the proposed development has the potential to cause a significant adverse impact on the purposes for which the area has been designated or defined, rather than whether there will indeed be a significant adverse impact from the proposed development.
• The decision maker may consider the proposed development in its local context as a matter of planning judgement.
• There may be other considerations but which may not determine whether a proposed development is major development. For example, if the proposed development is Environmental Impact Assessment (EIA) development.
• The ordinary sense of the word ‘major’ is important and the decision maker should take a common sense view as to whether the proposed development could be considered major development.

In the Mid Sussex District Council Site Allocations DPD Evidence Base there is a topic paper setting out consideration of Major Development in the AONB and concludes that several of the allocations, in some cases up to 70 dwellings, would not be classed as major development in the AONB following a detailed review of each of the factors as set out in footnote 55 of the NPPF against each proposed allocation.
It is considered that this approach should have been undertaken for each of the individual sites discounted in the Local Plan (including Main Road, Hermitage), rather than simply discounting on the sole fact that they were in the AONB.
Sustainability Appraisal
The legal frameworks for SAs are set out within section 19 of the Planning and Compulsory Purchase Act 2004 which states that the authority must prepare a plan with the objective of contributing to the achievement of sustainable development. Moreover, the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 states that SAs must ensure that the potential environmental effects are given full consideration alongside social and economic issues.

It is not considered that the council has given full consideration to all effects nor are the conclusions of the SA in respect of those impacts robust and logical.
Paragraph 32 of the framework goes on to state that the SA should demonstrate how the plan has addressed relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).
The SA sets out whether it was reasonable to explore higher growth scenarios as follows:
5.2.12 As discussed above, the PPG on Housing and Economic Needs Assessment sets out reasons for providing for ‘above LHN’ through local plans, referring to situations where there are “growth strategies for the area... (e.g. Housing Deals); strategic infrastructure improvements that are likely to drive an increase in [need]; or an authority agreeing to take on unmet need from neighbouring authorities...” Also, affordable housing needs can serve as a reason for considering setting the housing requirement at a figure above LHN, with the PPG stating: “An increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes.”
5.2.13 However, in the Chichester context there is little or no argument for exploring scenarios whereby the housing requirement is set at a figure above LHN, given the issues discussed above at paragraph 5.2.11. Unmet housing needs are a widespread issue across the sub-region, but there is no realistic potential to provide for unmet housing needs within Chichester. At the time of the Preferred Approach consultation (2018/19), the proposal was to provide for both locally arising housing needs in full and a proportion of the unmet needs arising from the SDNP (41 dpa). Also, it is noted that the SA report published as part of the consultation considered scenarios – considered to be ‘reasonable’ at that point in time – that would see the housing requirement set at figures significantly above LHN (800 dpa and 1,000 dpa were tested). However, at the current time, in light of the latest available evidence, scenarios involving setting the housing requirement at a figure above LHN can be safely ruled out as unreasonable.
It is not considered that a figure at or above the LHN would be considered unreasonable and that this matter has not been given full consideration (as per the requirements of the SA regulations), particularly in regard to the social impacts of not meeting housing need in full.
Appendix V of the SA sets out commentary in regard to Parish Scenarios. This sets out the following in relation to Southbourne (with emphasis added):

With regards to the extent of the broad location, this matter is considered fairly uncontentious (for the current purposes of arriving at reasonable growth scenarios). Specifically, the proposal is to identify an area of search that includes developable HELAA sites that relate relatively well to the Southbourne settlement edge and avoid the Strategic Wildlife Corridor associated with the Ham Brook, also naturally mindful of the need to maintain a landscape gap to settlements within Chidham and Hambrook Parish, to the east. It is important to note that the total theoretical capacity of developable HELAA sites within this broad area is far in excess of the number of homes that would need delivered under any reasonably foreseeable scenario.
The broad location provides flexibility to identify a detailed allocation either through a Site Allocations Plan or, should the Parish Council wish to do so, a revised Southbourne Parish Neighbourhood Plan. Site selection considerations will likely include: transport and access (including mindful of links to the train station and by car to Portsmouth); accessibility and community infrastructure (mindful of the secondary school, recreation ground and employment area at the western edge of the village); heritage (e.g. there is a historic rural lane to the east, associated with two listed buildings), topography and landscape (including any visual links to the SDNP and/or the AONB) and the potential to secure a strategic scheme that delivers more than just new market homes, and potentially significant ‘planning gain’ for the local community.
With regards to the number of homes that should be supported, there is logic to further exploring the scale of growth that was previously considered through the now withdrawn Southbourne NP, and it is not clear that there is an argument for considering lower growth. Additionally, there is a clear argument for exploring the possibility of higher growth, to ensure a suitably comprehensive scheme, with a high level of ‘planning gain’.
In conclusion, there are two scenarios for Southbourne Parish, namely completions, commitments and windfall plus either: 1) a broad location for 1,050 homes; or
2) a broad location for ~1,500 homes.
As set out, it is not considered that the SA has considered adequate reasonable alternatives to growth at Southbourne which would include allocation of sites elsewhere in the village including within the AONB that can deliver in the early part of the plan period.

Conclusions
There are significant 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.
The Council has not adequately considered reasonable alternatives through the Sustainability Appraisal as published alongside the plan which should have included consideration to the allocation of the site in order to deliver housing in the early part of the plan period.
The plan fails to adequately consider the need for housing for older people, given that the population over 65 across CDC is significantly in excess of the average in the county, south east and county as a whole.
CDC discounted all sites within the AONB, including the site at Main Road, Hermitage, at an early stage of the plan making process. This is not considered effective or consistent with national policy which does not class such sites as an absolute constraint. Other local authorities have allocated such sites in order to deliver the full objectively assessed needs.
ABC will continue to make further representations on the deliverability of the site as part of the plan making progress.

Chichester Local Plan – Proposed Submission
Duty to Co-operate
The Statutory Housing Authority welcomes the opportunity to comment on the Chichester Local Plan 2021 – 2039 and strongly commends the Local Planning Authority on progressing with its plan-making activities at a time when a number of Local Planning Authorities across the country have stalled owing to a state of flux in the national policy picture.
Chichester District Council Housing Authority considers that the Chichester Planning Policy Team have engaged in a pro-active manner in an ongoing basis to meet the needs of our communities. Furthermore, the authority has been consulted throughout in the crafting of the proposed housing policies H1 – H10 and confirm that the Duty to Co-operate has been met in this regard.

Is it legally compliant?
The Housing Authority consider the plan as presented, to be legally compliant and have no specific comments in relation to the Sustainability Appraisal, Habitats Regulations Assessment or the Statement of Community Involvement.

Soundness
The Housing Authority is satisfied that the plan is positively prepared and seeks to meet the housing need for both market and affordable housing, so far as is practicable, whilst having consideration for the various constraints of the plan area including AONB designation, heritage matters, flooding matters and infrastructure capacity issues. The Housing Authority believe the plan seeks to balance between these competing demands in a sustainable and realistic manner for the plan period 2021 -2039.
The Housing Authority consider the plan provides for a reasonable evidence based strategy which is consistent with national planning policy and guidance and contributes to the delivery of sustainable development, having regard to the reasonable alternatives available.
Meeting housing need
The Housing Authority considers the plan meets housing need so far as is realistically possible considering the constraints of the plan area.
Policy H1, including the Broad Spatial Distribution - is noted.
Policy H2, the strategic locations are broadly located in areas where the Council held Housing Register indicates the highest level of housing need.
Policy H3 - is noted.
Policy H4 – The Housing Authority fully endorse and support the provisions contained in Policy H4.
Policy H5 - The Housing Authority is supportive of the housing mix outlined in policy H5 and the ability to reflect local need where it is appropriate to do so. Furthermore it is right to provide this level of certainty, whilst allowing for some degree of flexibility.
Policy H6 - The Housing Authority are in full support of this policy and fully endorse the opportunity for Neighbourhood Planning groups to bring forward Self and Custom Build serviced plots. The Housing Authority are encouraged by the potential that may arise with the call for sites for such plots. We look forward to working with our colleagues and communities to bring forward Self and Custom Build opportunities within the plan area.
Policy H7 - The Housing Authority recognise the difficulties in bringing forward exception sites for affordable housing and welcome this policy which seeks to enable the needs of our rural communities to be met.
Policy H8 - The Housing Authority strongly advocate for the inclusion of specialist accommodation for older people, and the intention is to secure affordable housing across all specialist accommodation for older people, including Extra Care to meet the needs of those unable to secure such accommodation in the open market.
H9 – The Housing Authority support the policy to retain accommodation for rural workers.

H10-H14 – The Housing Authority has no observations to make in relation to these polices.