Policy P3 Density

It should be specifically stated that wildlife and biodiversity needs to be taken into account.
The optimum density of development should take account of areas. For example rural areas should not be suitable for developments with a density of 35 houses per hectare.

It should be specifically stated that wildlife and biodiversity needs to be taken into account.
The optimum density of development should take account of areas. For example rural areas should not be suitable for developments with a density of 35 houses per hectare.

WGPC supports this policy intent.

This policy is generally supported, particularly in relation to encouraging higher densities in the most accessible locations.

The policy needs to recognise that the density of development will need to increase within the Runcton HDA during the plan period and the Council should proactively plan for this in order to maintain the economic momentum of the Chichester food cluster.

The reference to making the most efficient use of land is recognised. The policy does however need to recognise that the density of development will need to increase within the Runcton HDA during the plan period and the Council should proactively plan for this in order to maintain the economic momentum of the Chichester food cluster. The need to increase density will assist in addressing the conclusions within the Council’s evidence base that substantial land will be required outside current HDA’s to meet the industry’s needs. Increased densities will reduce the industry’s land requirements, whilst also maintaining the countryside and ensuring economic growth.

See attachment.

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.

Pertinent parts of draft policy P3 could well be integrated with draft Policy P2, thereby helping to rationalise the number of policies.

See attachment.

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.

See attached representation.

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 should be specifically stated that wildlife and biodiversity needs to be taken into account.
The optimum density of development should take account of areas. For example rural areas should not be suitable for developments with a density of 35 houses per hectare.